CALIFORNIA AIR RESOURCES BOARD



### APCD/AQMD RULE EVALUATION FORM -- Page 1 (Electronic Format)

Submitted by Santa Barbara County APCD July 11, 2012 I. GENERAL INFORMATION

District: Santa Barbara County APCD

Rule No(s): 102, 202, 321, 330, 337, 349, and 353 Date amended: June 21, 2012

Rule Title(s): Definitions, Exemptions to Rule 201, Solvent Cleaning Machines and Solvent Cleaning, Surface Coating of Metal Parts and Products, Surface Coat ing of Aerospace Vehicles and Components, Polyester Resin Operations,
Adhesives and Sealants

Date Submitted to ARB: Circa July 11, 2012

If an Amended Rule, Date Last Amended (or Adopted): Rule 102: March 17, 20 11; Rule 202: March 17, 2011; Rule 321: September 20, 2010; Rule 330: January 20, 2000; Rule 337: October 20, 1994; Rule 349: April 27, 1993; and Rule 353: August 19, 1999.

Is the Rule Intended to be Sent to the U.S. EPA as a SIP Revision? Yes No (If No, do not complete remainder of form)

District Contact: Doug Grapple Phone Number: 805. 961.8883 E-mail Address: grappled@sbcapcd.org.

Narrative Summary of New Rule or Rule Changes: New Rule Amended Rules

RULE 102, DEFINITIONS : The District added and modified several solv ent-related and surface-coating definitions that are used in various parts of the rulebook. The definition of reactive organic compound was updated to include most of the exempt compounds listed in 40 CFR 50.100(s) and an exempt compound definition was added. RULE 202,
EXEMPTIONS TO RULE 201 : The main change updated the test method for low ROC-content solvents to refer to the
SCAQMD Method 313-91. RULE 321, SOLVENT CLEANING MACHINES AND SOLVENT CLEANING : A slight amendment to exemption B.6 was made to clarify that the so lvent cleaning machine requirements of Rule 321 apply when facilities subject to an operation-specific rule are using a degreaser. 1 RULE 330, SURFACE COATING OF METAL
PARTS AND PRODUCTS : Added Rule 321-type exemptions, definitions, and general solvent cleaning, recordkeeping, reporting, source testing, and compliance provisions. RULE 337, SURFACE COATING OF AEROSPACE VEHICLES
AND COMPONENTS : In addition to the changes outlined for Rule 330, we added: 1) adhesive and sealant provisions; and 2) coating categories and limits from a USEPA Control Techniques Guideline document and a federal regulation for the source category. The District also lowered the stripper ROC limit from 400 to 300 grams per liter in response to suggestions by the ARB and the USEPA. RULE 349, POLYESTER RESIN OPERATIONS : The changes outlined for Rule 330 were included in PAR 349. Lower polyester resin ma terial monomer contents limits and a higher add-on control equipment overall efficiency limit were also added. These ne w provisions have a 24-month phase-in period to allow for product sale- through and available stock depletion. Lastly, staff ma de minor changes to the rule ’s Attachment A, “Static Method for Determination of Volatile Emissions from Polyester and Vinyl Ester Resins.” RULE 353, ADHESIVES AND
SEALANTS : The District amended the rule to include Rule 321-ty pe provisions like in the other rules. We added application equipment requirements and stripper use provisions . The ROC-content limits on several products were also

reduced.

Pollutant(s) Regulated by the Rule (Check): ROG (NOx) SO2 (CO) PM TAC (name):

1 On Sept. 29, 2011, EPA approved the vers ion of Rule 321 adopted on Sept. 20, 2010 (76 FR 60376). Due to the minor nature of t he Rule 321 revisions on June 21, 2012, the responses shown in Sections II - VI apply only to the recently amended Rules 330, 337, 349,

and 353. The District will address the EPA concerns with Ru le 321, as outlined in the July 2011 Technical Support Document, th e next time Rule 321 is amended. This amendment is slated for the 2013 - 2015 timeframe.CALIFORNIA AIR RESOURCES BOARD



### APCD/AQMD RULE EVALUATION FORM -- Page 2 (Electronic Format)

Submitted by Santa Barbara County APCD July 11, 2012 II. EFFECT ON EMISSIONS

Complete this section ONLY for rules that, when implemented, will result in quantifiable changes in emissions. Attach reference(s) for emission factor(s) and other information. A ttach calculation sheet showing how the emission information provided below was determined.

Net Effect on Emissions: Increase Decrease N/A

Emission Reduction Commitment in SIP for this Source Category : 8.9838 tons per year of ROC, 0.0325 tons per day of
ROC

Inventory Year Used to Calculate Changes in Emissions: 2009 Area Affected: Santa Barbara County

Future Year Control Profile Estimate (Provide information on as many years as possible) : See the following table:

CONTROL
MEASURE RULE CES/SCC SIC/EIC Control
Profile

2020 Control
Profile

2030
R-SC-2 330/337 66662 23023090000000 0.3319 0.3319

R-SC-2 330/337 40200101 1629 0.0637 0.0637

R-SC-2 330/337 40200101 3471 0.3938 0.3938

R-SC-2 330/337 40200101 4953 0.0745 0.0745

R-SC-2 330/337 40200101 7532 0.6859 0.6859

R-SC-2 330/337 40200110 3674 0.0086 0.0086

R-SL-5 349 74674 41040350180000 0.2383 0.2383

R-SL-5 349 40200912 2599 0.6309 0.6309

R-SL-5 349 40200918 3721 0.7583 0.7583

R-SL-9 353 83030 25029282020000 0.0188 0.0188

Baseline Inventory in the SIP for the Control Measure: 110. 5235 tons per year of ROC, 0.3245 tons per day of ROC

Emissions Reduction Commitment in the SIP for the Control Measur e: 8.9838 tons per year of ROC, 0.0325 tons per day
of ROC

Revised Baseline Inventory (if any): 109.7864 tons per year of ROC, 0.3294 tons per day of ROC

Revised Emission Reduction Estimate (if developed): 8.32 17 tons per year of ROC, 0.0303 tons per day of ROC

Note that the district’s input to the Rule Evaluation Form will not be used as input to the ARB’s emission forecasting and planning.

III. SOURCES/ATTAINMENT STATUS

District is: Attainment Nonattainment Split

Approximate Total Number of Small (<100 TPY) Sources Affected by this Amendment: 74

Percent in Nonattainment Area: 0%

Number of Large (> 100 TPY) Sources Controlled: 11 Percent in Nonattainment Area: 0%CALIFORNIA AIR RESOURCES BOARD



### APCD/AQMD RULE EVALUATION FORM -- Page 3 (Electronic Format)

Submitted by Santa Barbara County APCD July 11, 2012 Name(s) and Location(s) (city and county) of Large (> 100 TPY) Sources Controlled by Rule (Attach additional sheets as necessary) : 1. DCOR, Dos Cuadras - South County, So uth County Offshore, Santa Barbara County. 1 2. E & B - South Cuyama, New Cuyama. 3. ERG Resources - Cat Canyon We st, Cat Canyon Oil Field. 4. Exxon - SYU Project, Las Flores Canyon. 5. Greka South Cat Canyon, Cat Canyon. 6. Pacific Coast Energy Company, Orcutt Hill Field. 7. Pacific Operators - Carpinteria, Carpinteria. 8. Pt. Pedernales/Lompoc Oil Fields, Offshore and Lompoc Oil Fields. 9. So Cal Gas - La Goleta, Goleta. 10. The Point Arguello Projec t, Offshore and Gaviota. 11. Venoco - Ellwood, Ellwood.

IV. EMISSION REDUCTION TECHNOLOGY

Does the Rule Include Emission Limits that are Continuous? Yes No

If Yes, Those Limits are in Section(s) 330.D.4.a, 337.D.3.a, 349.D.1.f.i, and 353.I.1.

Other Methods in the Rule for Achieving Emission Reductions are: Use of low-ROC solvents, enhanced requirements on work practices (keeping solvent containers closed, properly di sposing of spent solvents), and lower ROC-content limits on coatings, strippers, and polyester resin materials.

V. OTHER REQUIREMENTS

The Rules Contain:

Emission Limits in Sections: 330.D.4.a, 337.D.3.a, 349.D.1.f.i, and 353.I.1.

Work Practice Standards in Sections: 330.F, 337.F, 337.J.2, 349.D.3, 353.J.

Recordkeeping Requirements in Sections: 330.B.1, 330.B.2, 330.B.8.c, 330.H, 337.B.1, 337.B.2, 337.B.5.c, 337.H, 349.B.1, 349.B.2.c, 349.B.6, 349.F, 353.B.3, 353.B.9, 353.B.11, and 353.O.

Reporting Requirements in Sections: 330.L, 337.L, 349.I, and 353.S.

VI. IMPACT ON AIR QUALITY PLAN

No Impact Impacts RFP Impacts attainment

Discussion: The difference between the ROC emission reductio n in the 2010 plan and the rulemaking estimate is less than five pounds per day. With the 192 tons per year of ROC emission reduction anticipated from the Rule 321 amendments adopted in Sept. 2010, the five pounds per day shortage is insignificant.

FORM28.DOC

1 All of these sources are in Santa Barbara County. For the sake of brevity, the su bsequent data does not repeat the “county” name.Santa Barbara County APCD Page 1 July 11, 2012 

### ASSESSMENT OF SANTA BARBARA COUNTY ROC EMISSIONS REDUCTIONS FROM MODIFIED RULES 330, 349, AND 353 1



### EMISSION INVENTORY SOURCE CATEGORY Cleaning and Surface Coatings - Degreasing

EMISSION INVENTORY CODES (EICs) AND DESCRIPTIONS

x 23023090000000, Cleaning and Surface Coatings, Coatings and Related Process Solvents, Metal Parts and Products Coatings

x 23024032020000, Cleaning and Surface Coatings, Coatings and Related Process Solvents, Thinning And Cleanup Solvent Uses

x 23099591000000, Cleaning and Surface Coatings, Coatings and Related Process Solvents, Other

x 25029282020000, Cleaning and Surface Coatings, Adhesives and Sealants

x 41040350180000, Industrial Processes, Chemical, Fiberglass and Fiberglass Products Manufacturing

SOURCE CHARACTERISTICS

This assessment is for reactive organic compound (ROC) emission reductions due to the new and modified solvent cleaning requirements that were added to the following rules on June 21, 2012:

Rule 330, Surface Coating of Metal Parts and Products, Rule 337, Surface Coating of Aerospace Vehicles and Components Rule 349, Polyester Resin Operations, and Rule 353, Adhesives and Sealants

Solvent cleaning includes wipe cleaning (handwiping), solvent flushing operations, and coating application equipment cleaning. Generally, before applying a coating, an operator will wipe clean the surfaces using a solvent-laden rag. During the subsequent cleanup activities, overspray is removed by wipe cleaning and the spray application equipment is cleaned using a solvent.

METHODS

The primary way ROC emissions are reduced from solvent cleaning is by the use of low-ROC content solvents (typically 25 grams per liter or less).

Emission reductions are assessed using 2009 base year data with the application of controlrelated factors (e.g., percent exempt, compliance efficiency, and the maximum density of complying solvents).

1 Although Rule 337, Surface Coating of Aerospace Vehicles and Components, was part of the rulemaking project, no emission reductions were assessed from these operations . Staff was unable to assess emission reductions from such operations due to the lack of baseline data and there being no significant decrease in the ROC-content for

solvents used in cleaning activities.Santa Barbara County APCD Page 2 July 11, 2012 

### Base year 2009 data is comprised of data from two groups: “point source” and “area source.” Point sources using solvents subject to a Santa Barbara County Air Pollution Control District (District) Permit to Operate report their solvent us e to the District. Thus, the District’s point source data is based on recordkeeping and reporting performed by the sources to comply with their permit conditions. Area sources are generally non-permitted sources of emissions.

The area source inventory data is from the California Air Resources Board (ARB) California Emissions Inventory Development and Reporting System (CEIDARS). 1 

### The District provides ARB with its point source inventory. The ARB subtracts the District’s point source data from the area source emission inventory to avoid any double-counting of emissions.

The 2009 base year emission and reduction estimates were projected (grown) to 2020 and 2030 using activity factors (also known as activity indicators ) for each SCC-Standard Industrial Code (SIC) combination and for each area source (EIC number) category. 2 

### The annual activity is uniform throughout the year.

The following provides details on the different equations used to calculate emission reductions and projected (grown) figures.

Equation [1]

The general equation for calculating emission reductions is:

ER = (Current Emissions – Emissions After Control) * Compliance Factor [1]

Where:

ER = Emission Reduction Current Emissions = The ROC emissions from the 2009 inventory Emissions After Control = The ROC emissions with compliance with the revised rule requirements Compliance Factor = 80 percent (EPA/ARB default value)

Equation [2]

The equation for calculating the Emissions After Control for the solvent replacement control technique for a point source is:

1 Additional details on how the ARB develops CEIDARS data for the handwiping category may be obtained from the following web pages: www.arb.ca.gov/ei/areasrc/onehtm/one3-2.htm and www.arb.ca.gov/ei/areasrc/fullpdf/full3-2.pdf . The general public does not have access to CEIDARS reports. However, District staff may be requested to assist in generating such a report.

2 The District used data from the 2 010 Clean Air Plan, Table 6-7, coup led with mathematical interpolation techniques to derive the activity indicators for growing da ta from 2009, to 2020 and 2030. An Excel worksheet documenting these calculations is available from the District upon request.Santa Barbara County APCD Page 3 July 11, 2012 

### Emissions After Control (lbs/yr) = Current Thruput (gals/yr) * 1.5 Vol. Ratio * Density (lbs/gal) [2]



### Where:

Emissions After Control = The ROC emissions with compliance with the revised rule requirements (lbs/yr) Current Thruput = The 2009 inventory ROC-solvent net usage rate (gals/yr) 1


### 1.5 Vol. Ratio = The ratio of the volume of replacement material to ROC

solvent 2


### Density = The maximum allowable ROC density per the rule (lbs/gal)

Equation [3]

The equation for calculating the Emissions After Control for the solvent replacement control technique for area sources in the EICs 23023090000000, 25029282020000, and 41040350180000 categories is:

Emissions After Control (TPD) = [Current Emissions (TPD) * Exempt Eq (%)/100] + {[Current Thruput (gals/day) * 1.5 Vol. Ratio * Density (lbs/gal) * 1 ton/2000 lbs]*[1 – Exempt Eq (%)/100]} [3]



### Where:

Emissions After Control = The ROC emissions with compliance with the revised rule requirements (TPD) 3


### Current Emissions = The ROC emissions from the 2009 inventory (TPD) Current Thruput = The 2009 inventory ROC-solvent net usage rate (gals/yr) 4


### 1.5 Vol. Ratio = The ratio of the volume of replacement aqueous material to

ROC solvent Density = The maximum allowable ROC density per the rule (lbs/gal) Exempt Eq = Percent of equipment that is exempt from the requirements (%)

1 When throughput data was unavailable , staff calculated the figure using RO C emission and solvent ROC density data. For example: (X tons/day) * (260 day/year) * (2000 lbs/ton) * (1/density lbs/gal) = Y gals/year.

2 Per the South Coast AQMD Staff Report for Proposed Amended Rule 1122 – Solvent Degreasers, August 8, 2001, pages 14, 15, and 23.

3 The conversion from tons per day (TPD) to tons per year (TPY) is achieved by multiplying the TPD figure by 260 days per year for Rules 330 and 349, and 365 days per year for Rule 353.

4 When throughput data was unavailable , staff calculated the figure using RO C emission and solvent ROC density data. For example: (X tons/day) * (260 day/year) * (2000 lbs/ton) * (1/density lbs/gal) = Y gals/year.Santa Barbara County APCD Page 4 July 11, 2012 

### Equation [4]

The equation for projecting future emissions data is:

Future Data = Emission Info * Activity Factor [4]

Where:

Future Data = Emissions (TPD or TPY) or emission reductions (TPD or TPY)

for CY 2020 or 2030 1


### Emissions Info = 2009 base year emissions (TPD or TPY) or emission reductions (TPD or TPY) with compliance with the rule requirements Activity Factor = The ratio of future year activity to base year activity; used to grow (increase or decrease) the 2009 base year data to CY

2020 or 2030

ASSUMPTIONS

1. The point source and area source inventory data shown in Attachments A and B are

correct. 2. The point and area sources identified in Attachments A and B will be subject to Rules 330, 337, 349, and 353. 3. That sources subject to the rules will use solvents having the maximum ROC content allowed by the rule. 4. The activity indicators shown in Attachments A and B are correct.

6. Solvent densities shown Attachments A and B are correct. 7. It is reasonable to convert from tons per year (TPY) to tons per day (TPD) and from tons per day to tons per year by using a 260 days per year operating schedule for Rules 330, and 349 and a 365 days per year operating schedule for Rule 353.

SAMPLE CALCULATIONS

1. Below is an example calculation of the ROC emission reductions from a point source solvent cleaning operation subject to the solvent replacement technique where the new maximum solvent ROC limit is 25 grams per liter (0.2086 lbs/gal): 2



### Using equation [2] and knowing the current throughput is 36.64 gallons per year:

Emissions After Control (lbs/yr) = 75 gals/yr * 1.5 Vol. Ratio * 0.2086 lbs/gal

Emissions After Control (lbs/yr) = 23.468 lbs/yr

1 The units depend on the units used for the “Emissions Info” figure: TPD or TPY.

2 This example uses the FI D 02031, DID 108710, data.Santa Barbara County APCD Page 5 July 11, 2012 

### Using equation [1] and knowing the current emission rate is 535.35 lbs/yr:

ER = (535.35 lbs/yr – 23.468 lbs/yr) * 0.8

ER = 409.51 lbs/yr or 0.2048 TPY

Using equation [4] to grow the 2009 base year emission reductions to 2020:

Future Data = 0.2048 TPY * 0.9999

CY 2020 ER = 0.2047 TPY or 0.0008 TPD

2. Below is an example calculation of the ROC emission reductions from an area source in due to solvent replacement where the new maximum allowable solvent ROC limit will be 25 grams per liter (0.2086 lbs/gal): 1



### Using equation [3] and knowing the current solvent cleaning emission rate is 0.0293 TPD , the throughput is 10.809 gallons per day, and 10 percent of the solvent cleaning is exempt:

Emissions After Control (TPD) = [0.0293 (TPD) * 10/100] + {[10.809 (gals/day) * 1.5 Vol. Ratio * 0.2086 (lbs/gal) * 1 ton/2000 lbs]*[1 - 10/100]}

Emissions After Control (TPD) = 0.0045 TPD

Using equation [1]:

ER = (0.0293 TPD - 0.0045 TPD) * 0.8

ER = 0.0199 TPD or 5.18 TPY

Using equation [4] to grow the 2009 base year emission reductions to 2020:

Future Data = 0.0199 TPD * 0.9999

CY 2020 ER = 0.0199 TPD or 5.18 TPY

1 This example uses data from EIC 23023090000000 (CES 66662).2009 POINT SOURCE EMISSIONS INVENTORY DATA AND ESTIMATED EMISSIONS REDUCTIONS FORSOLVENT CLEANING OPERATIONS SUBJECT TO AMENDED RULES 330 AND 349aAttachment ARule Facility FacilityNumberDeviceNumberCurrentSolv. ClngROCEmissions(lbs/yr)Proj'd Solv.Clng.Emissionwith 25 g/lLimitb(lbs/yr)ERsb(lbs/yr)ERs With an80% Comp.Eff. Factor(lbs/yr)Temp.Data(days/year)ReferenceEquationscActivityIndicatorActivityIndicatorUnits2020GrowthFactor2030GrowthFactor2020ERs inTPD2030ERs inTPD330 Atlas Copco Mafi-TrenchCompany LLC01717 103823 394.974 17.732 377.242 301.794 260 [1], [2], &[4]EmploymentIndustrialEmployee0.9999 0.9999 0.0006 0.0006330 Santa Barbara IndustrialFinishing02031 108710 535.350 23.468 511.883 409.506 260 [1], [2], &[4]EmploymentIndustrialEmployee0.9999 0.9999 0.0008 0.0008330 MarBorg Industries -Quarantina04576 108832 272.671 19.409 253.262 202.609 260 [1], [2], &[4]EmploymentIndustrialEmployee0.9999 0.9999 0.0004 0.0004330 Lompoc Unified SchoolDistrict04406 108830 360.160 17.210 342.951 274.360 260 [1], [2], &[4]EmploymentIndustrialEmployee0.9999 0.9999 0.0005 0.0005330 Raytheon-Hollister(Electronic Warfare)01971 001307 60.619 4.272 56.347 45.078 260 [1], [2], &[4]EmploymentIndustrialEmployee0.9999 0.9999 0.0001 0.0001Rule 330 point source totals (TPD) 0.0024 0.0024Rule 330 point source totals (TPY) 0.6166 0.6166349 Forms and Surfaces 06436 107594 165.633 7.912 157.721 126.177 260 [1], [2], &[4]EmploymentIndustrialEmployee0.9999 0.9999 0.0002 0.0002349 C&D Zodiac 03867 105586 616.242 28.524 587.718 470.174 260 [1], [2], &[4]EmploymentIndustrialEmployee0.9999 0.9999 0.0009 0.0009Rule 349 point source totals (TPD) 0.0011 0.0011Rule 349 point source totals (TPY) 0.2981 0.2981aThe District found that the point source emission reductions from Rules 337 and 353 were too speculative. Hence, no point emission reductionswere assessed for sources subject to Rules 337 and 353.bDoes not include the application of the 80% Compliance Efficiency Factor.cThereference equationsare identified in the document that accompanies this attachment and are the equations that were used to derive the figures.Page 1, July 11, 20122009 AREA SOURCE EMISSIONS INVENTORY DATA AND ESTIMATED EMISSION REDUCTIONS FORSOLVENT CLEANING OPERATIONS SUBJECT TO RULES 330, 349, AND 353aAttachment BRule Area Source CategEIC CES Current Solv. Clng. ROC Emissions (TPD) Exempt Equip't (%) Density (lbs/gal) Current Solvent Thruput (gals/day) Clng. Solv. Emissions After Control (TPD)
b ERs With 80% Comp. Eff. Factor (TPD) Ref. Equa-tions

c Activity Indicator Activity Indicator Units 2020 Growth Factor 2030 Growth Factor 2020 ERs (TPD) 2030 ERs (TPD)330 Cleaning andSurface Coatings,Coatings andRelated ProcessSolvents, MetalParts andProductsCoatings23023090000000 66662 0.0293 10 5.43 10.809 0.0045 0.01991 [3] and[4]EmploymEmploye0.9999 0.9999 0.0199 0.0199349 IndustrialProcesses,Chemical,Fiberglass andFiberglassProductsManufacturing41040350180000 74674 0.0033 0 6.76 0.98 0.0002 0.0025 [3] and[4]EmploymEmploye0.9999 0.9999 0.0025 0.0025353 Cleaning andSurface Coatings,Adhesives andSealants25029282020000 83030 0.007159 20 5.43 2.637 0.0018 0.0043 [3] and[4]EmploymEmploye0.9999 0.9999 0.0043 0.0043TOTALS0.0267 0.0267 0.0267aThere is no area source emission data for aerospace vehicle and component painting. Hence there are no area source emission reductions for Rule 337.bDoes not include the application of the 80% Compliance Efficiency Factor.c"Ref. Equations" stands forreference equations,which are identified in the document that accompanies this attachment andare the equations that were used to derive the figures.Page 1, July 11, 2012