SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis September 1 7, 2009

B-1 Final Staff Report with Appendices For

Proposed Amendments to Rule 4602 

## APPENDIX B

Rule Consistency Analysis

For Proposed Amendments to

Rule 4602

September 17, 2009SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis September 1 7, 2009

B-2 Final Staff Report with Appendices For

Proposed Amendments to Rule 4602 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis September 1 7, 2009

B-3 Final Staff Report with Appendices For

Proposed Amendments to Rule 4602 

### APPENDIX B Rule Consistency Analysis

I. REQUIREMENTS OF ANALYSIS

Pursuant to Section 40727.2 of the California Healt h and Safety Code, prior to adopting, amending, or repealing a rule or regulation, the Di strict is required to perform a written analysis that identifies and compares the air pollu tion control elements of the rule or regulation with corresponding elements of existing or proposed District and United States Environmental Protection Agency (EPA) rules, regulations, and guidelines that apply to the same source category. The elements th at were analyzed are emission standards, monitoring and testing, and recordkeepin g and reporting requirements.

II. RULE CONSISTENCY ANALYSIS

A. District Rules

Facilities could be subject to other District rules including:

 Rule 2201 New and Modified Stationary Source Revie w Rule

 Rule 4001 New Source Performance Standards

 Rule 4002 National Emissions Standards for Hazardo us Air Pollutants

 Rule 4603 Surface Coating of Metal Parts and Produ cts

 Rule 4612 Motor Vehicle and Mobile Equipment Coati ng Operations

 Rule 4653 Adhesives

 Rule 4661 Organic Solvents

 Rule 4663 Organic Solvent Cleaning, Storage, and D isposal

The above-listed rules are not in conflict with, no r are they inconsistent with the requirements of Proposed Rule 4602.

B. Federal EPA Rules and Regulations

1. Federal Control Techniques Guideline (CTG)

1977 CTG for Control of Volatile Organic Emissions from Existing Stationary Sources Volume II: Surface Coating of Cans, Coils, Paper, F abrics, Automobiles, and Light-Duty Trucks (EPA-450/2-77-008). The 1977 CTG and subse quent implementation guidance provided RACT recommendations for controlling VOC e missions from automobile and light-duty truck assembly surface coating operation s. These recommendations are

summarized in Table 1.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis September 1 7, 2009

B-4 Final Staff Report with Appendices For

Proposed Amendments to Rule 4602 Table 1. 1977 CTG Recommended VOC Emission Limits of Automobile and Light- Duty Truck Surface Coatings.

Electrodeposition primer operation 0.14 kg VOC/liter (1.2 lb/gal) of coating, excluding water and exempt compounds, or 0.17 kg VOC/liter (1.4 lb VOC/gallon) of coating solids deposited

Primer-Surfacer (guidecoat) operation 1.8 kg VOC/liter (15.1 lb VOC/gallon) of coating solids deposited on a daily average basis as determined by following the procedures in the Automobile Topcoat

Protocol

Topcoat operation 1.8 kg VOC/liter (15.1 lb VOC/gallon) of coating solids deposited on a daily average basis as determined by following the procedures in the Automobile Topcoat

Protocol

Final repair operation 0.58 kg VOC/liter (4.8 lb/gal) of coating, excluding water and exempt compounsd

2. Alternative Control Technology (ACT)

There is no EPA ACT for automobile and light-duty t ruck assembly coatings.

3. Federal New Source Performance Standards (NSPS)

40 CFR part 60 subpart MM (1980) The NSPS establis hed the emission limits calculated on a monthly basis for each prime coat o peration, guide coat (primersurfacer) operation, and topcoat operation located in an automobile or light-duty truck assembly plant constructed, reconstructed, or modif ied after October 5, 1979. The NSPS does not apply to plastic body component coati ng operations or to all-plastic automobile or light-duty truck bodies coated on sep arate coating lines. The VOC emission limit for prime coat operations depends on the solids turnover ration (R T ). The

solids turnover ratio is the ratio of total volume of coating solids added to the EDP system in a calendar month to the total volumetric design capacity of the EDP system.

The NSPS limits and the 1977 CTG recommendations f or primer-surfacer and topcoat cannot be directly compared because of differences in the compliance period and how transfer efficiency is considered.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis September 1 7, 2009

B-5 Final Staff Report with Appendices For

Proposed Amendments to Rule 4602 Table 2. 1980 NSPS VOC Emission Limits for Automobi le and Light-duty Truck Surface Coatings

Prime coat Operations (Non-EDP) 0.17 kg VOC/liter (1.42 lb/gal) coating s olids applied

When solids

turnover ration (R T ) > 0.16: When 0.040< R T

< 0.160: When R T <0.040:

Prime coat Operations (EDP) 0.17 kg VOC/liter

(1.42 lb/gal) coating solids applied 0.17x350 0.160- RT

Kg VOC/liter (0.17x350 0.160- RT

x8.34 lb/gal) coating solids applied No VOC emission

limit

Guide coat Operations (including the guidecoat application, flashoff area, and oven) 1.40 kg VOC/liter (11.7 lb/gal) coating solids applied

Topcoat Operations (including topcoat application, flash-off area, and oven) 1.47 kg VOC/liter (12.3 lb/gal) coa ting solids applied

4. National Emission Standards for Hazardous Air Po llutants (NESHAPs) and Maximum Achievable Performance Standards (MACTs)

40 CFR part 63 Subpart IIII (2004), National Emissi on Standards for Hazardous Air Pollutants; Surface Coating of Automobile and Light -Duty Trucks. The NESHAP covers all equipment used to apply coating to new a utomobile or light-duty truck bodies or body parts and to dry or cure the coatings after application; all storage containers and mixing vessels in which vehicle body coatings, thin ners, and cleaning materials are stored and mixed; all manual and automated equipmen t and containers used for conveying vehicle body coatings, thinners, and clea ning materials; and all storage containers and all manual and automated equipment a nd containers used to convey waste materials generated by an automobile and ligh t-duty truck assembly coating operation.

The 2004 NESHAP for automobile and light-duty truck assembly coating imposed organic HAP emission limitations calculated on a mo nthly basis for existing sources. More stringent limits apply to new sources. The NE SHAP also sets emission limits for coatings not included in the CTG or NSPS, including glass bonding primer, glass bonding adhesive, and some coatings and thinners.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis September 1 7, 2009

B-6 Final Staff Report with Appendices For

Proposed Amendments to Rule 4602 Table 3. 2004 NESHAP HAP Emission Limits for Auto mobile and Light-Duty Truck Surface Coatings.

0.060 kg organic HAP/liter of coating solids deposited (0.50 lb/gal) for new or

reconstructed affected sources Combined primer-surfacer, topcoat, final repair, glass bonding primer, and glass bonding adhesive operation plus all coatings and thinners, except for deadener

materials and for adhesive and sealer materials that are not components of glass bonding systems, used in coating operations added to the affected source. 0.132 kg organic HAP/liter of coating solids deposited (1.10 lb/gal) for existing affected

sources

0.036 kg organic HAP/liter of coating solids deposited (0.30 lb/gal) for new or

reconstructed affected sourcesCombined electrodeposition primer, primersurfacer, topcoat, final repair, glass bonding primer, and glass bonding adhesive operation plus all coatings and thinners, except for deadener materials

and for adhesive and sealer materials that are not components of glass bonding systems, used in coating operations added

to the affected source 0.072 kg organic HAP/liter of coating solids deposited (0.60 lb/gal) for existing affected

sources

5. EPA Policy on Recordkeeping

The recordkeeping requirement in Rule 4602 is consi stent with EPA’s policy to keep and maintain records for at least five years.

III. CONCLUSION

Based on the above analysis, District staff found t hat the proposed amendments to Rule 4602 would not conflict with federal rules, regulat ions, or policies covering similar stationary sources.