SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX B: Rule Consistency Analysis June 16, 201 1

Final Draft Staff Report with Ap pendices For Proposed Amendments to Ru le 4605 B - 1 

## APPENDIX B

Rule Consistency Analysis

June 16, 2011SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX B: Rule Consistency Analysis June 16, 201 1

Final Draft Staff Report with Appendices For Proposed Amendments to Ru le 4605 B - 2 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX B: Rule Consistency Analysis June 16, 201 1

Final Draft Staff Report with Appendices For Proposed Amendments to Ru le 4605 B - 3 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 Draft Rule 4605 with the corresponding elements of existing or proposed District and United States Environmental Protection Agency (EPA) rules, regula tions, and guidelines that apply to the same source category. The rule elements that w ere analyzed are emission limits or control efficiency, operating parameters and work p ractices, monitoring and testing, and recordkeeping and reporting requirements.

II. RESULTS OF ANALYSIS

A. District Rules

Facilities could be subject to other District rules including:

 Rule 2201 New and Modified Stationary Source Revie w Rule

 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 4605.

There is only one District rule that has solvent cl eaning requirements that are not part of this rule project – Rule 4612 (Motor Vehicle and Mo bile Equipment Coating OperationsPhase II). It should be noted that Rule 4612 super seded the requirements in Rule 4602 (Motor Vehicle and Mobile Equipment Coating Operati ons) on and after January 1, 2009. Rule 4612 was amended October 21, 2010 and incorpor ated the provisions of solvent cleaning operations. The proposed amendments to Rul e 4605 are consistent with the requirements in Rule 4612.

B. United States Environmental Protection Agency Ru les and Regulations

1. EPA-Control Technique Guidelines (CTG)

1. The CTG EPA-453/R-97-004 1997/12 applies to Surface Coating Operations at Aerospace Manufacturing and Rework Operations located in marginal, moderate,

serious or severe ozone nonattainment areas that ha s the potential to emit greater than or equal to 25 tons/year of VOC, and equal to great er than 10 tons/year of VOC forSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX B: Rule Consistency Analysis June 16, 201 1

Final Draft Staff Report with Appendices For Proposed Amendments to Ru le 4605 B - 4 extreme ozone nonattainment areas. District Rule 46 05 is more stringent than the CTG limits for 34 categories. The proposed amendments to Rule 4605 will make it as stringent as the CTG in the 19 remaining categories . As such, District staff concludes that District Rule 4605 is more stringent than the CTG.

2. The CTG EPA-450/2-77-034 1977/12 applies to Surface Coating of Large Appliances operations located in marginal, moderate, serious o r severe ozone nonattainment areas that have the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of V OC for extreme ozone

nonattainment areas.

Since this CTG applies to large appliance coating; therefore, it will not be compared to SJVAPCD Rule 4605 which covers aerospace coating.

3. The CTG EPA-450/2-77-022 1977/11 applies to VOC Emissions from Solvent Metal Cleaning operations located in marginal, moderate, serious o r severe ozone nonattainment areas that have the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of V OC for extreme ozone

nonattainment areas.

This CTG applies to the use of the following degrea sing equipment: cold cleaners, open top vapor degreasers, and conveyorized degreasers. Identified in the CTG are design and work practice standards for cold cleaners, open top vapor degreasers, and conveyorized degreasers, for example: cover the sol vent tank, have a facility for waste solvent and draining cleaned parts, permanent label s on operating parts, close degreaser when not in use, drain parts until drippi ng ceases, no excessive splashing if solvent is sprayed. The CTG also identifies add-on controls such as refrigeration

chillers and carbon control.

SJVACPD Rule 4605 identifies solvent VOC content li mits or a control system with efficiencies of at least 90% capture and 95% contro l, and that would not allow more emissions than if compliant materials were utilized . The general solvent limit is 200 g/L; the coating stripper solvent limit is currently 300 g/L.

Since the CTG does not identify control requirement s any more stringent than SJVACPD Rule 4605, District staff considers Rule 46 05 at least as stringent as the

CTG.

2. EPA - Alternative Control Technology (ACT)

There is no EPA ACT guidance document for aerospace coating operations.

3. Standards of Performance for New Stationary Sou rces (NSPS)

There is no NSPS guidance document for aerospace co ating operations.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX B: Rule Consistency Analysis June 16, 201 1

Final Draft Staff Report with Appendices For Proposed Amendments to Ru le 4605 B - 5 4. National Emission Standards for Hazardous Air P ollutants (NESHAPs) and Maximum Achievable Control Technologi es (MACTs)

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations (CFR) Part 61 and 40 CFR Part 63. Since EPA has del egated the authority to implement NESHAP requirements to the District, NESH APs and MACTs promulgated by EPA are usually incorporated by reference into D istrict Rule 4002 (National Emission Standards for Hazardous Air Pollutants). It is imp ortant to mention that the District implements NESHAPs and MACTs by incorporating the e mission standards as conditions of the Permits to Operate issued to affe cted sources.

1. 40 CFR 63 Subpart GG (National Emission Standard s for HAPs: Aerospace Manufacturing and Rework Facilities) The requirements in this subpart are not directly c omparable to the District Rule 4605

VOC limits. The NESHAP HAP emission limits which ar e expressed in terms of percent HAP, HAP emission concentration, and mass (kg) of H AP per mass (kg) of solids are not directly comparable to the coatings VOC limit w hich is expressed in terms of grams (or lb) of VOC per liter (or gallons) of coatings, less water and exempt compounds, as applied. In addition, some HAPs may be exempt VOCs , and some VOCs may be

HAPs; therefore, there is no direct correlation bet ween the NESHAP limit versus District

Rule 4605

VOC limits.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX B: Rule Consistency Analysis June 16, 201 1

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