UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA’s Direct Final Rulemaking

for the 

California State Implementation Plan

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

Operations

Prepared by: David Grounds

Reviewed by: Andrew Steckel

December 14, 2010
RULE 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 non-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. The 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-453/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 Manufacturing 

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 does 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. Please consider eliminating the low usage exemption in Section 103. See for example, 

Bay Area Air Quality Management District (BAAQMD) Rule 50, and South Coast Air 

Quality Management District Rule 1162 which have no such exemption. 

2. Sections 104, 303 and 501.4 contain old sunset date clauses that need not be repeated 

in future amendment.

3. In Section 301b, please consider lowering the VOC emission limit to 50 grams per square 

meter of exposed surface. See for example, BAAQMD, 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, BAAQMD 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, BAAQMD Regulation 8, Rule 50, Section 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 testing thereafter. Please 

add this testing frequency information to the next revision.
EPA ACTION – 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.

BAAQMD, 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.”