UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

f or

EPA’s Direct Final Rulemaking

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California State Implementation Plan

Sacramento Metropolitan Air Quality Management District, rule 465, Polyester Resin Operations

Prepared by: David Grounds Reviewed by: Andrew Steckel
December 1 4 , 2010RULE IDENTIFICATION

Agency: Sacramento Metropolitan Air Quality Management District (SMAQMD)

Previous Rule: Rule 465

– Polyester Resin Operations Adopted

– February 6, 1997
Amended

– June 4, 1998

Subject of this TSD: Rule 465

– Polyester Resin Operations Adopted

– September 25, 2008
Submitted

– September 15, 2009

RULE SUMMARY

– SMAQMD Rule 465, Polyester Resin Operations, is a rule designed to reduce emissions of volatile organic compounds (VOC) from polyester resin operations at each stage of the polyester resin operation. SMAQMD is designated as a severe n on

- attainment area for the
federal 8

- hour ozone standard (69 FR 23858, April 30, 2004) , and SMAQMD designed Rule 465 partly to address the requirements for ozone non

- attainment areas as described in Clean Air Act (CAA) section 182.

While Sacramento originally adopted Rule 465 in 1997, no version of this rule has been approved by EPA into the SIP. T he current SIP submittal limits solvent VOC materials to 25 g/l, establishes a 90% overall emission control efficiency, requires records to be maintained for 5 years, and specifies the most current test methods.

EPA EVALUATION CRITERIA

- The following criteria were used to evaluate the submitted Rule
465 :

1. Enforceability

– Section 110(a)(2)(A) of the CAA requires that regulations submitted to EPA for incorporation into the SIP must be clear and legally enforceable.

2. Reasonably Available Control Technology ( RACT ) (CAA § 182 )

– SMAQMD believes that there are currently no major sources ( at least 25 tpy VOC ) of polyester resin operations in SMAQMD that would require RACT implementation. Additionally, SMAQMD believes there is only one custom boat manufacturer with VOC emissions well below the limit of 2.7 tpy as stated in the 2008 CTG (EPA

- 453/R

- 08

- 004). SMAQMD plans to submit a negative declaration for this CTG category in 2011. While it appears RACT is not required, we have compared Rule 465 against analogous rules in other areas and relevant national guidance including EPA’s Control Technique Guidelines (CTG) titled,

“ Control Techniques Guidelines for Industrial Cleaning Solvents” (EPA

- 4 53/R

- 06

- 001
, 9/ 06), “Control of VOC Emissions from Manufacture of High

- Density Polyethylene,Polypropylene, and Polystyrene Resins” (EPA

- 450/3

- 83

- 008, 11/83), “Control of VOC

Fugitive Emissions from Synthetic Organic Chemical Polymer and Resin Manufacturi ng Equipment” (EPA

- 450/3

- 83

- 006, 3/84), “Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials” (EPA

- 453/R

- 08

- 004, 9/08), CARB’s RACT/BARCT guidance titled, “Organic Solvent Cleaning and Degreasing Operations” (July 18, 1991), and other state and local rules for this category

.

3. SIP Relaxation

– Where previous versions of rules have been SIP approved, new submittals must comply with CAA §110(l) and §193 regarding SIP relaxations.

EPA EVALUATION

– The current SIP submittal generally contains sufficient testing and recordkeeping requirements to satisfy enforcement requirements. The stringency of requirements in submitted Rule 465 is also generally consistent with relevant guidance and analogous rules in other areas

. Therefore, while RACT may not be required for this source category, we believe that Rule 465 would implement RACT. Since no previous version of these requirements is already in the SIP, approval of this version only improves the SIP and do es not relax the SIP in violation of CAA section 110(l) or 193.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 465 sufficient for EPA to propose less than full approval.

RECOMMENDATIONS

– The following revisions are not currently the basis for rule disapproval,
but are recommended for the next time the rule is amended.

1. P lease consider eliminating the low usage exemption in Section 103. See for example, Bay Area Air Quality Management D istrict (BAAQMD) Rule 50

, and South Coast Air Quality Management District Rule 1162 which have no such exemption.
2. Section s 104 , 303 and 501.4 contain old sunset date clause s that need not be repeated
in future amendment

. 3. In Section 301b, please consider l owering the VOC emission limit to 50 grams per square meter of exposed surface. See for example, B A AQMD, Regulation 8, Rule 50, Section
301.5.
4. In Section 301.1 (a)(2), please consider lowering the pigmented gel coat in the weight range to 28

- 37%. See for example, B A AQMD Regulation 8, Rule 50, Section 301.6.
5. In Section 301.1(a)(3), please consider lowering specialty resin and clear coat weight limits to below 50%. See for example, B A AQMD Regulation 8, Rule 50, Sectio n 301.6.
6. No testing frequency is specified in the rule. However, the Staff Report does indicate initial testing to verify system control efficiency with annual tes t ing thereafter. Please add this testing frequency information to the next revision.EPA AC TION

– The submitted Rule 465 largely fulfills the relevant CAA §110 and part D

requirements. EPA staff recommends approval of Rule 465 pursuant to CAA §110(k)(3) and §301(a).

REFERENCES

– SMAQMD Rule 465, “ Polyester Resin Operations

. ” Staff Report, August 25, 2008

. B A AQMD, Regulation 8, Rule 50, “ Polyester Resin Operations .” San Joaquin Valley APCD, Regulation IV, Rule 4684, “ Polyester Resin Operations .” South Coast AQMD, Regulation XI, Rule 1162, “ Polyester Resin Operations .”