1 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

FINAL STAFF REPORT

Rule 4653 (Adhesives and Sealants)

September 16, 2010

Prepared by: Anna Myers, Air Quality Specialist

Reviewed by: Colette Kincaid, Senior Air Quality Sp ecialist Joven R. Nazareno, Senior Air Quality Engineer George Heinen, Rule Development Supervisor Michael Carrera, Compliance Manager Errol Villegas, Strategies and Incentives Program Manager Samir Sheikh, Director of Strategies and Incentive s

I. SUMMARY

The purpose of Rule 4653 (Adhesives) is to reduce e missions of VOCs from the application of adhesive products and associated sol vent cleaning operations. This source category includes any person who supplies, s ells, offers for sale, or applies any adhesive product, or associated solvents, for use w ithin the San Joaquin Valley Air Basin (SJVAB).

The San Joaquin Valley Unified Air Pollution Contro l District (District) Governing Board adopted the Eight-Hour 2007 Ozone Plan (Ozone Plan) . One of the commitments

within the Ozone Plan is to amend Rule 4653 and tak e those amendments to the Governing Board for public hearing and adoption by the third quarter of 2010. However, the Environmental Protection Agency (EPA) promulgat ed a Control Techniques Guideline (CTG) for Miscellaneous Industrial Adhesi ves (EPA-453/R-08-005) in September of 2008. Therefore, as required by the F ederal Clean Air Act (CAA), the District amended Rule 4653 in September 2009 to inc orporate CTG requirements.

Amendments included VOC content limits for certain adhesives categories and new requirements for work practices. The effective dat e of the new VOC content limits adopted per the EPA CTG is January 1, 2011.

The purpose of this rule-amending project is to ame nd Rule 4653 (Adhesives) to fulfill commitments in the Ozone Plan. During this rule-am ending project, District staff considered the more stringent VOC limits for adhesi ves currently enforced in other air districts, and explored the possibility of the addi tion of sealant products, to ensure this rule is as stringent as other air districts in Cali fornia.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

2 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 A. Reasons for Rule Development and Implementation

The EPA and the California Air Resources Board (ARB ) classified the SJVAB as

extreme and severe non-attainment area for federal and state ozone standards, respectively. In accordance with CAA requirements for non-attainment areas, the District adopted the 2007 Ozone Plan to establish t he strategy for attaining the federal eight-hour ozone standard.

The District’s 2007 Ozone Plan includes control mea sure S-SOL-6 (Adhesives & Sealants) as part of the listed VOC control measure s. As such, this rule development project is subject to the CAA and the California He alth and Safety Code (CH&SC) requirements. This rule-amendment project will see k to obtain as much VOC emissions reduction from the source category as is expeditiou sly practicable, technologically feasible, and economically reasonable, as determine d by the District's Governing Board. Furthermore, the District intends to satisfy the re quirements identified in Table 1 below.

Table 1 Ozone Plan Commitments Subject Reference Requirement

BACM Federal Register

8/18/94 Provisions in attainment plans should include the application of best available control measures (BAC M) to existing major stationary sources.

BARCT CH&SC 40919(a)(3)

2007 Ozone Plan Ozone attainment plan should provide for best available retrofit technology (BARCT) for existing permitted sources. -

Deadlines Ozone Plan Adoption of rule amendments by the 3 rd quarter of

2010.

Feasible

Controls CH&SC 40914(a)(2) Ozone attainment plans should include "all feasible

control measures."

RACT CAA 182(b)(2) and

182(f) Ozone attainment plans shall assure that reasonably available control technology (RACT) for oxides of nitrogen (NOx) and volatile organic compounds (VOC) is in use at sources and on source categories at or

above the RACT threshold.

RACT

Threshold 70 Federal Register

30592-30596

5/26/05 The applicable RACT threshold for control measures shall be the threshold in effect on June 15, 2004. The Districts threshold on June 15, 2004 was 10 tons pe r year (tpy) for NOx or VOC.

Reductions Ozone Plan Emissions reduction will be calculated during the r ule development process.

Timeline CAA Section

172(c)(1) Ozone attainment plans shall implement control measures as expeditiously as practicable, and provi de

for attainment.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

3 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 B. Climate Change

The California Global Warming Solutions Act of 2006 (AB 32) created a comprehensive, multi-year program to reduce green house gas (GHG) emissions in California, with the goal of restoring emissions to 1990 levels by 2020. In the coming years, the ARB and the Legislature will be developing policies and pro grams to implement Assembly Bill 32 (AB 32). There are many win-win strategies that ca n reduce both GHG and criteria/toxic pollutant emissions. However, the D istrict’s primary mission remains to achieve attainment with air quality standards to pr otect public health. Therefore, when

situations that involve tradeoffs between GHG and c riteria or toxic pollutants arise, the District will give precedence to reducing criteria or toxic pollutant emissions due to the more immediate public health concerns associated wi th such pollutants.

C. Description of Project

The 2007 Ozone Plan commitment includes pursuing th e lowering of the VOC content

of adhesives to match limits in other air districts , with a 3% reduction of the baseline emissions. It is important to note that Rule 4653 was amended in September of 2007 to implement new solvent cleaning requirements effecti ve on and after September 2008. As such, current solvent cleaning requirements are the most stringent limits in California at this time. Therefore, emission reductions will come from more stringent VOC limits

for adhesives and the addition of sealants and seal ant primers to rule language.

D. Rule Development Process

As part of the rule development process, District s taff conducted two public workshops, one on February 11, 2010 and one on July 13, 2010, at which time a draft version of Rule 4653 and a draft staff report were available. District staff presented the objectives of the proposed rulemaking project, reviewed draft amendments, explained the District’s rule development process, solicit suggestions from affected stakeholders on how best to achieve the emission reductions, and informed all i nterested parties about comment periods, and the tentative date for the public hear ing for the adoption of the draft amendments. A two-week public comment period follo wed each workshop; comments received from the public, ARB, and EPA were incorpo rated into the draft rule and draft staff report as appropriate.

The proposed amendments to Rule 4653, the Final Dra ft Staff Report will be published and made available for review and comment prior to the public hearing to consider the adoption of the amendments by the District's Govern ing Board. Comments received were incorporated into the proposed rule amendments as appropriate District staff intends to submit the proposed rule amendments to t he District Governing Board for consideration of adoption during the third quarter of 2010.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

4 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 II. DISCUSSION

A. Sealants

Some air districts in California have prohibitory r equirements for sealants and sealant primers included within their adhesives rules. Bay Area Air Quality Management District (BAAQMD) Rule 8-51 defines sealant product as any m aterial with adhesive properties used primarily to fill, seal, waterproof, or weathe rproof gaps or joints between two surfaces. Sealant products include sealant primers and caulk. Ventura County APCD (VCAPCD) Rule 74.20 defines a sealant primer as any product intended by the manufacturer to be applied to a substrate, prior to the application of a sealant, to enhance the bonding surface. Further discussion re garding sealant products and VOC content limits for sealant products is provided in Section III (Current and Proposed Regulations) of this final draft staff report.

B. Adhesives

BAAQMD Rule 74.20 defines an adhesive product as an y material which is applied for the primary purpose of bonding two surfaces togethe r by surface attachment. Adhesives are usually used during assembly processe s to join surfaces. Adhesives allow for faster assembly speeds, less labor input, and more ability for joining dissimilar materials than other fastening methods. The classi fications of adhesives include solution/waterborne, solvent-borne, solid, pressure sensitive and reactive.

C. Application

The process of adhesive and sealant application occ urs by applying the product to a substrate, followed by curing or drying. The produ ct may be in an aerosol or a liquid, with application techniques including spraying, rol ling, or dipping. There are several different types of application technologies availab le for application and the selection of the application technology can significantly affect the amount of product used and the resulting VOC emissions from the application proces s.

The most common application methods include air ato mized spray, airless spray, electrostatic spray, high volume/low pressure (HVLP ) spray, dip coating, flow coating, brush or roll coating, electro-coating, and hand ap plication. Spray application operations generally occur in a spray booth by manu al or automated means. Spray booths capture overspray, keep solvent vapors away from employees, and keep external contaminants out of the application operat ion. Airflow in a booth equipped with a filter generally passes from the spray applicator , over the substrate, and through a

filter bank. A series of baffles located in front of the filters collects overspray, and in some cases, the collected overspray is recycled.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

5 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Conventional Air Spray Conventional air spray application uses compressed air at high pressure (30 to 90 psi) to pull the product from a reservoir and atomize it . The mixture of air and atomized product then deposits onto the substrate. Conventi onal air spray has a relatively low transfer efficiency compared to other application m ethods because the high pressure of air causes a majority of the product to not land on the substrate and become overspray

waste.

Airless Spray With airless spray, a pump forces the product throu gh an atomizing nozzle at high pressure (1,000 to 6,000 psi). Airless spray is id eal for rapid coverage of large areas when a heavy film build is required. The size of a irless spray droplets is larger making the spray cloud less turbulent. The transfer effic iency of airless spray is typically superior to conventional air spray.

Electrostatic Spray Reports indicate that electrostatic spray systems h ave the highest transfer efficiency of all the spray application techniques. In electrost atic spray application, the product and substrate are oppositely charged. The grounded sub strate attracts the negatively charged particles, resulting in minimal overspray, resulting in lower VOC emissions.

HVLP Systems HVLP systems use low air pressure (generally not mo re than 10 psi), and utilize specialized nozzles. The specialized nozzles provi de better air and fluid flow at the lower air pressure, shape the air/spray pattern, an d guide the atomized particles to the substrate. Lower air pressures result in greater t ransfer efficiency compared to conventional air atomized spray systems.

Dip Coating Typically used for large complicated parts where it would be difficult to use other methods, dip coating has high transfer efficiencies . Dip coating occurs by dipping the substrate into a tank containing the product, and t hen draining off the excess. Typically, systems have some means of recirculation of tank co ntents, filters to remove sediment and contaminants, and a means for controlling the v iscosity of the fluid. Solvent losses occur from the large surface area of the tank. Thi nner is added to the tank (water or solvent thinner, depending on the product used) to maintain the desired viscosity.

Flow Coating Flow coating is similar to dip coating but involves conveying the substrate over an enclosed sink. Low-pressure streams, or flows appl ying the product as the item passes under a series of nozzles. Excess product drains b ack into the sink, is filtered, and pumped back into a holding tank. A typical flow co ater tank is enclosed and is smaller than the equivalent dip coating tank. As a result, a smaller quantity of product is used and less solvent evaporates than would during dip t ank operations.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

6 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Other Methods High viscosity product applications include roll co ating, brush coating, electro-coating, and hand coating techniques. Electro-coating, also called electrodeposition is a specialized form of dip coating. The product and t he substrate have opposite electric charges. The product is adhered to the part by ele ctrical attraction, which produces a uniform application on the substrate.

D. Available Controls and Regulatory Approaches

The primary source of VOC emissions from adhesive a nd sealant product application is evaporation from the products during and after appl ication of adhesives, sealants, and associated cleaning products. Control techniques f or reducing VOC emissions from application processes include pollution prevention and emission capture and control systems. Pollution prevention is the most prevalen t control technique in use at facilities operating adhesive application processes. Add-on c apture and control systems are available to industry, but few facilities utilize t his control technique, as it can be very costly. The following is a summary of the availabl e control options for reducing these

VOC emissions.

1. Pollution Prevention Measures Pollution prevention measures include product subst itution/reformulation, work practice procedures, and equipment substitution.

a. Product Substitution/Reformulation An effective pollution prevention measure is to sub stitute higher-solvent products with waterborne products, higher solids products, and re active products as these products

contain little or no solvents. Manufacturers are c ontinuing to develop waterborne formulations that replace conventional organic solv ent-borne products. These products are generally available, and many application proce sses are capable of converting to these products.

b. Work Practices Work practice procedures are physical actions, spec ific to an industry, intended to affect emission reductions. Work practices can effectivel y reduce the waste generated during adhesive and sealant material preparation, applicat ion, and equipment cleaning. Waste may be reduced by effectively controlling material preparation, maximizing the amount of product transferred to the substrate via applica tion methods with higher transfer efficiencies, improved spray technique, and proper equipment maintenance. Requirements were added to rule language for work p ractice requirements during the previous rule-amending project to adopt EPA CTG req uirements.

c. Equipment Substitution Technologies such electrostatic and high volume low -pressure (HVLP) spray equipment achieves higher transfer efficiencies than many con ventional methods. Increased transfer efficiency translates to decreased usage o f VOC containing materials.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

7 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Electrostatic spraying may achieve transfer efficie ncies of up to 90 percent depending on the product shape, size, and substrate. HVLP sy stems use reduced air pressure and increases transfer efficiency. HVLP spray syst ems can achieve transfer efficiencies of up to 65 percent under optimal conditions and wi th good operator technique.

2. Emission Capture and Control Systems When combined with an add-on control system that de stroys or recovers VOC from exhaust streams, capture systems reduce VOC emissio ns from adhesive and sealant application processes. Although capture systems an d add-on control devices are available to facilities, they are generally not use d due to cost considerations. Operators will typically use lower VOC products and alternati ve application methods. Although add-on controls can control VOC emissions in spray booth exhaust, it is generally not cost effective to do so because of the large volume of air that needs to be treated compared to the low concentration of VOC.

a. Capture Systems Capture systems, such as hoods, floor air sweeps, a nd enclosures, collect solventladen air from process vents and/or fugitive emissi ons, and direct the captured air to a control device. The design of the capture system c ontributes to the overall VOC control efficiency. An efficient capture system maximizes the capture of emissions and minimizes the capture of dilution air. Spray booth design and air management can

reduce the volume of exhaust air and maximize the V OC concentration of the exhaust air, which can reduce the cost of control. Facilit ies may combine several captured VOC-laden streams and duct them to a single control device.

b. Add-on Control Systems Add-on Control Systems reduce the amount of VOC emi ssions by either destruction or recovery (with or without recycling) of VOC emissio n in the exhaust streams. The two categories of add-on control devices include combus tion (thermal or catalytic oxidation) and recovery (adsorption and absorption). The foll owing summary discusses those control devices in known use with adhesive applicat ion processes including oxidation, adsorption, and absorption.

Oxidation destroys VOC emissions in an exhaust stream by expo sing the stream to an oxidizing atmosphere at high temperatures. Oxidize rs may be of thermal or catalytic design and combust VOC-containing exhaust streams. Catalytic oxidizers are similar to thermal oxidizers but employ a catalyst to aid in t he oxidation reaction. As a result, catalytic oxidizers operate at lower combustion tem peratures relative to that required in thermal oxidizers. Both types of oxidizers general ly utilize either regenerative or recuperative techniques to preheat inlet gas in ord er to decrease energy costs associated with high oxidation temperatures. They may also use primary or secondary heat recovery to reduce energy consumption. In gen eral, oxidizers can achieve destruction efficiencies of greater than 95 percent as applied to application operations with high and constant concentrations of VOC.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

8 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Adsorption occurs when the unbalanced molecular forces on the surface of solids (the adsorbant) attract and retain gases and particulate matter that meet the solid. Adhesive application operations most commonly utilize carbon adsorbers. In a typical carbon adsorber, VOC-laden air passes through a fixed bed of granular activated carbon. To avoid interruption of VOC control, adsorber beds ar e operated in parallel. In this arrangement, when the adsorption capacity of one be d is exhausted, the bed is removed from service, and a second adsorber bed is put into service, ensuring that a control device is operating at all times. The spen t carbon bed in the first adsorber bed is then regenerated in preparation to be put back i nto service. Carbon adsorption systems can achieve control device efficiencies equ al to or greater than 95 percent.

Carbon adsorption captures but does not destroy the VOC it removes from the air stream. Carbon adsorbers are thermally regenerated by passing steam through the carbon beds. The VOC is desorbed, removed from the carbon, and transferred to the exhaust or recovery steam. The VOC-containing stea m is then condensed, and the VOC solvent is separated from the water. If the op erator so chooses, the recovered solvent is then decanted for sale or reuse. Regene ration can also be performed via hot air. Hot-air regeneration can be quite attractive when dealing with water-soluble solvents. Carbon adsorption is most amenable to co atings that use a single solvent; if adsorbers collect solvent mixtures, the solvent cou ld be distilled for reuse.

Absorption is the process by which a gas stream is dissolved i n a liquid by adjoining the gas stream to a liquid. Water is the most common a bsorbent, but organic solvents may

also be used. The addition of reactive chemical ad ditives to the absorbent will increase solubility of the absorbed pollutant, thereby enhan cing removal efficiency.

3. Available Controls for VOC Emissions from Clean ing Materials Pollution prevention is the most common emission co ntrol technique for reducing VOC emissions from cleaning operations. The pollution prevention measures applicable to adhesive and sealant application processes include product substitution or reformulation, and work practice procedures. Clean ing materials with low or no VOC content may be used to reduce or eliminate VOC emis sions from using these materials. Work practice procedures may also reduce VOC emissi on during cleaning operations by reducing the amount of VOC that can evaporate du e to exposure to air.

Add-on control technologies are not in use specific ally to reduce VOC emissions from cleaning operations associated with miscellaneous a dhesive or sealant application processes. However, in some instances, cleaning op erations occur within a capture system that ducts to an add-on control system, such as a hood routed to a thermal oxidizer, where the VOC emissions from the cleaning operations are destroyed.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

9 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 III. CURRENT AND PROPOSED REGULATIONS

A. Current Regulations

District Rule 4653 (Adhesives) currently sets limit s for VOC emissions from the application of adhesive products and associated org anic solvent cleaning operations. Rule language also provides operators with an optio n to alternatively control VOC emissions from coating operations by using a VOC em ission control system in lieu of complying with the VOC content limits.

1. Existing State VOC Requirements In 1998, ARB issued a guidance document that includ ed ARB’s determination of reasonably available control technology (RACT) and best available retrofit control technology (BARCT) for Adhesives and Sealants. ARB based the majority of its RACT determination on limits already in effect in South Coast Air Quality Management District (SCAQMD), BAAQMD, and Ventura County APCD, and conc luded that the VOC limits for adhesives and sealants presented in its RACT de termination were achievable and cost-effective. Furthermore, ARB stated in its RAC T determination that most of the adhesive and sealant products sold in 1998 were alr eady compliant with the VOC limits

that were determined to be RACT.

2. Existing Local Adhesive and Sealant Requirement s Thirteen air districts in California have establish ed rules specifically for adhesives. The

various district adhesives rules do not all contain the same adhesive categories and limits as the ARB RACT guidance. Among these distr icts, the South Coast AQMD has generally adopted the most stringent VOC content li mits for adhesives. If add-on controls are used, South Coast Rule 1168 requires t hat the control system capture at least 80 percent of the VOC emissions. Several air districts require the use of specific types of high-efficiency adhesive application metho ds to reduce VOC emissions. At least seven other District’s rules that regulate em issions from adhesives are similar to South Coast Rule 1168 in that they also require tha t sources use methods that achieve high transfer efficiency.

Air districts in California that regulate the VOC e missions generated from cleaning materials used in adhesive application processes re quire a combination of work practice and equipment standards and limits on the VOC conte nt, boiling point, or composite vapor pressure of the solvent. Additionally, some District rules allow the use of add-on

controls as an alternative to the VOC content/boili ng point/vapor pressure limits for cleaning materials. The work practice and equipmen t standards that have been adopted by California Districts include, for exampl e, using closed containers for storing solvent and solvent containing wipes and rags, usin g enclosed and automated spray gun washing equipment, and prohibiting atomized spr aying of solvent during spray gun cleaning.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

10 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Of the air districts that include sealant product r equirements as a part of their adhesives rules, most share the same VOC content limits for s aid sealants and sealant primers categories, with the following few exceptions. Pla cer County Air Pollution Control District has a sealant limit for PVC welding sealan ts with a VOC content limit of 480 grams per liter, the other Districts do not. BAAQM D does not have a VOC content limit specific to marine deck sealant primers. SCAQMD ha s a VOC content limit of 500 grams per liter specified for modified bituminous s ealant primers, the other districts do not. The shared sealant and sealant primer categor ies and corresponding VOC content limits are displayed in Tables 2 and 3 below.

Table 2 Sealant Limits (Various Districts)
Category VOC content (grams/liter)

Architectural 250

Marine Deck 760

Nonmembrane Roof 300
Roadway 250
Single-Ply Roof Membrane 450

Other Sealants 420

Table 3 Sealant Primer Limits (Various District s)
Category VOC content (grams/liter)
Architectural Nonporous 250

Architectural Porous 775

Marine Deck 760

Other Sealant Primers 750

B. Proposed Amendments Proposed amendments would include the following cha nges.

Section 1.0 Purpose Section 1.0 would be amended to incorporate sealant s products.

Section 2.0 Applicability Section 2.0 would be amended to include sealant pro ducts to the applicability of this

rule.

Section 3.0 Definitions The “Definitions” section would be expanded from 97 definitions to 141definitions. Several definitions would be added to clarify curre nt rule requirements as well as provide for the addition of sealants, sealant prime rs, and new adhesives categories to rule language.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

11 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Section 4.0 Exemptions Section 4.0 would be amended for clarity and to inc lude sealant products.

Section 5.0 Requirements

Section 5.1.1 Adhesive VOC content limits would be amended to make the limits as stringent as adhesive VOC limits in other air distr icts, and to add several new adhesive categories that were not previously regulated or we re previously regulated under another adhesive category with a higher VOC content limit. The following is a discussion of the adhesive categories and proposed amendments and additions to the adhesive categories and limits.

Multipurpose Construction Adhesive Multipurpose Construction Adhesive is a current adh esive category for Rule 4653. The current VOC limit for this adhesive category is 200 g/l. Effective on and after January 1, 2012, the Multipurpose Construction Adhesive VOC co ntent limit would become 70 g/l.

The new VOC content limit will make this VOC limit as stringent as the VOC content limit for this adhesive category in the adhesives r ules in the SCAQMD, VCAPCD, and the San Diego Air Pollution Control District (SDAPC D).

Ceramic Tile Adhesive Ceramic Tile Adhesive is a current adhesive categor y for Rule 4653. The current VOC limit for this adhesive category is 130 g/l. Effec tive on and after January 1, 2012, the VOC content limit would become 65 g/l. The new VOC content limit will make this VOC limit as stringent as the VOC content limit for thi s adhesive category in the adhesives rules in SCAQMD, VCAPCD, and SDAPCD. This category would be presented twice in Table 2 of proposed rule language for organizationa l purposes.

Cove Base Installation Adhesive

Cove Base Installation Adhesive is a current adhesi ve category for Rule 4653. The current VOC limit for this adhesive category is 250 g/l, but will become 150 g/l effective on and after January 1, 2011 due to a previous rule -amending project to adopt EPA CTG standards. Effective on and after January 1, 2 012, the VOC content limit would become 50 g/l. The new VOC content limit of 50 g/l will make this VOC limit as stringent as the VOC content limit for this adhesiv e category in the adhesives rules in SCAQMD, VCAPCD, and SDAPCD.

Dry Wall Adhesive Dry Wall Adhesives are adhesives intended by the ma nufacturer to be used during the installation of gypsum dry wall to studs or solid s urfaces. Effective on and after January 1, 2012, the Dry Wall Adhesive category would be a new category to rule language. Adhesives in this category are currently regulated as Multipurpose Construction Adhesive with a VOC content limit of 200 g/l. Howe ver, this new adhesives category would have a VOC content limit of 50 g/l to make it as stringent as the VOC content limits for this category in the adhesives rules in SCAQMD and VCAPCD.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

12 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Panel Adhesive Panel Adhesive is an adhesive intended by the manuf acturer to be used for the installation of plywood, pre-decorated hardboard (o r tileboard), fiberglass, reinforced plastic, and similar pre-decorated hardboard or non -decorated panels to studs or solid surfaces using an adhesive formulated for that purp ose. The definition of Panel Installation Adhesive was added to rule language du ring the previous rule-amending project to add EPA CTG requirements to rule require ments. Effective on and after January 1, 2012, the Panel Adhesive category would be a new category to rule language. Adhesives in this category are currently regulated as Multipurpose

Construction Adhesive with a VOC content limit of 2 00 g/l. However, this new adhesives category would have a VOC content limit o f 50 g/l to make it as stringent as the VOC content limits for this category in the adh esives rules in SCAQMD and

VCAPCD.

Floor Covering Installation Adhesive Floor Covering Installation Adhesive is a current a dhesive category for Rule 4653, with a current VOC limit of 150 g/l. There are no propo sed amendments for this adhesive category at this time.

Ceramic Floor Tile Installation Adhesive Ceramic Tile Adhesive is a current adhesive categor y for Rule 4653. The current VOC limit for this adhesive category is 130 g/l. Effec tive on and after January 1, 2012, the VOC content limit would become 65 g/l. The new VOC content limit will make this VOC limit as stringent as the VOC content limit for thi s adhesive category in the adhesives rules in the SCAQMD, VCAPCD, and SDAPCD. This cate gory would be presented twice in Table 2 for organizational purposes.

Indoor Carpet Adhesive Indoor Carpet Adhesives are adhesives used during t he installation of a carpet that is in an enclosure and is not exposed to ambient weather conditions during normal use. Effective on and after January 1, 2012, the Indoor Carpet Adhesives category would be a new category to rule language. Adhesives in this category are currently regulated as Floor Covering Installation adhesives with a VOC co ntent limit of 150 g/l. However, this new adhesives category would have a VOC content lim it of 50 g/l to make it as stringent as the VOC content limits for this category in the adhesives rules in SCAQMD, VCAPCD, and SDAPCD.

Carpet Pad Adhesive Carpet Pad Adhesives are adhesives used for the ins tallation of a carpet pad (or cushion) beneath a carpet. Effective on and after January 1, 2012, the Indoor Carpet Pad Adhesive category would be a new category to ru le language. Adhesives in this category are currently regulated as Floor Covering Installation adhesives with a VOC content limit of 150 g/l. However, this new adhesi ves category would have a VOC content limit of 50 g/l to make it as stringent as the VOC content limits for this category in the adhesives rules in SCAQMD, VCAPCD, and SDAPC D.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

13 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Outdoor Carpet Adhesive Outdoor Carpet Adhesives are adhesives used during the installation of carpet that is not in an enclosure and is exposed to ambient weath er conditions during normal use. Effective on and after January 1, 2012, the Indoor Carpet Adhesive category would be a new category to rule language. Adhesives in this c ategory are currently regulated as Floor Covering Installation adhesives with a VOC co ntent limit of 150 g/l. This new adhesives category would be created to provide cons istency in coating categories, clarifying the difference between indoor and outdoo r carpet adhesives. This adhesive category would have a VOC content limit of 150 g/l which is consistent with its current VOC limit, as it is as stringent as the VOC content limits for this category in the adhesives rules in SCAQMD, VCAPCD, and SDAPCD.

Rubber Flooring Adhesive Rubber Flooring Adhesives are adhesives used for th e installation of flooring material in which both the back and the top surface are made of synthetic rubber, and which may

be in sheet or tile form. Effective on and after J anuary 1, 2012, the Rubber Flooring Adhesive category would be a new category to rule l anguage. Adhesives in this category are currently regulated as Floor Covering Installation Adhesives with a VOC content limit of 150 g/l. However, this new adhesi ve category would have a VOC content limit of 60 g/l to make it as stringent as the VOC content limits for this category in the adhesives rules in SCAQMD, VCAPCD, and SDAPC D.

Perimeter Bonded Sheet Flooring Installation Adhesi ve Perimeter Bonded Sheet Flooring Installation Adhesi ve is a current adhesive category for Rule 4653, with a current VOC limit of 660 g/l. There are no proposed amendments for this adhesive category at this time.

Subfloor Adhesive

Subfloor Adhesives are used for the installation of subflooring material over floor joists. Effective on and after January 1, 2012, the Subfloo r Adhesive category would be a new category to rule language. Adhesives in this categ ory are currently regulated as Multipurpose Construction Adhesive with a VOC conte nt limit of 200 g/l. However, this new adhesives category will have a VOC content limi t of 50 g/l to make it as stringent as the VOC content limits for this category in the adh esives rules in SCAQMD, VCAPCD,

and SDAPCD.

VCT and Asphalt Tile Adhesive VCT and Asphalt Tile Adhesives are any adhesives in tended by the manufacturer for the installation of vinyl composite tile or asphalt tile flooring. Effective on and after January 1, 2012, the VCT and Asphalt Tile Adhesive category would be a new category to rule language. Adhesives in this category are c urrently regulated as Floor Covering

Installation Adhesive with a VOC content limit of 1 50 g/l. However, this new adhesives category will have a VOC content limit of 50 g/l to make it as stringent as the VOC content limits for this category in the adhesives r ules in SCAQMD, VCAPCD, and

SDAPCD.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

14 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Wood Flooring Adhesive Wood Flooring Adhesives are adhesives intended by t he manufacturer to be used to install a wood floor surface, including but not lim ited to parquet tiles and wood planks. Effective on and after January 1, 2012, the Wood Fl ooring Adhesive category would be a new category to rule language. Adhesives in this category are currently regulated as Floor Covering Installation Adhesive with a VOC con tent limit of 150 g/l. However, this new adhesives category will have a VOC content limi t of 100 g/l to make it as stringent as the VOC content limits for this category in the adhesives rules in SCAQMD, VCAPCD, and SDAPCD.

Single-Ply Roof Material Installation Adhesive Single-Ply Roof Material Installation Adhesive is a current adhesive category for Rule 4653, with a current VOC limit of 250 g/l. There a re no proposed amendments for this adhesive category at this time.

Non-Membrane Roof Adhesive

Non-Membrane Roof Adhesives are adhesives intended by the manufacturer to be used for the installation or repair of non-membrane roof s. This category includes plastic or asphalt roof cement, asphalt roof coatings and cold application cement. Effective on and after January 1, 2012, the Non-Membrane Roof Ad hesive category would be a new category to rule language. It is important to note that this adhesive category is new to regulation. This product is currently being sold i n the SJVAB as either a consumer product, an unregulated product, or in small contai ners. Effective on and after January 1, 2012, the VOC content limit for Non-Membrane Roo f Adhesives would be 300 g/l. This VOC content limit will be as stringent as the VOC content limits for this category in the adhesives rules in SCAQMD, VCAPCD, and SDAPCD.

Structural Glazing Structural Glazing is a current adhesive category f or Rule 4653, with a current VOC limit of 100 g/l. There are no proposed amendments for t his adhesive category at this time.

Structural Wood Member Adhesive

Structural Wood Member Adhesives are used for the c onstruction of any load bearing joints in wooden joists, trusses, or beams. Effect ive on and after January 1, 2012, the Structural Wood Member Adhesives category would be a new category to rule language. Adhesives in this category are currently regulated as Multipurpose

Construction Adhesive with a VOC content limit of 2 00 g/l. However, this new adhesives category would have a VOC content limit o f 140 g/l to make it as stringent as the VOC content limits for this category in the adh esives rules in SCAQMD, VCAPCD,

and SDAPCD.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

15 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Contact Adhesive Contact Adhesive is a current adhesive category for Rule 4653. The current VOC limit for this adhesive category is 250 g/l. Effective o n and after January 1, 2012, the VOC content limit would be 80 g/l. The new VOC content limit will make this VOC limit as stringent as the VOC content limit for this adhesiv e category in the adhesives rules in the SCAQMD, VCAPCD, and SDAPCD.

Contact Adhesive – Specialty Contact Adhesive – Specialty is a current adhesive category for Rule 4653, with a current VOC limit of 250 g/l. There are no propose d amendments for this adhesive category at this time.

Rubber Vulcanization Adhesive/Primer

Rubber Vulcanization Adhesive/Primer is a current a dhesive category for Rule 4653, with a current VOC limit of 850 g/l. There are no proposed amendments for this adhesive category at this time.

Tire Retread Tire Retread is a current adhesive category for Rul e 4653, with a current VOC limit of 100 g/l. This category was originally added to rul e language as tire repair, but comments from EPA clarified that the category shoul d be Tire Retread, therefore the proposed amendment to this category is to correct t he name of the adhesive category There are no proposed amendments for the VOC conten t of this adhesive category at

this time.

Motor Vehicle Adhesive Motor Vehicle Adhesive is a current adhesive catego ry for Rule 4653. It was added to rule language during the previous rule-amending pro ject to adopt EPA CTG requirements. The VOC content limit for Motor Vehi cle Adhesives is 250 g/l. There are no proposed amendments for this adhesive category a t this time.

Motor Vehicle Weatherstrip Adhesive Motor Vehicle Weatherstrip Adhesive is a new adhesi ve category for Rule 4653. The definition was added to rule language during the pr evious rule amending project to adopt EPA CTG requirements. However, a VOC content limit was not assigned to this adhesive at the time of adoption. Effective on and after January 1, 2012, the VOC content limit would be 750 g/l to make it as string ent as the EPA CTG. Staff had originally left this category with an unassigned VO C content limit so it would be subject to the default limit of 250 g/l, however, staff hav e been unsuccessful in finding an existing product with a VOC content limit that coul d meet the 250 g/l VOC content limit. In an effort to avoid imposing a potentially techno logically infeasible VOC content limit for this adhesive category, staff recommends adopti ng a VOC content limit consistent

with the EPA CTG standards.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

16 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Traffic Marking Tape Adhesive/Primer Traffic Marking Tape Adhesive Primer is an adhesive primer intended by the manufacturer to be applied to the substrate prior t o the installation of traffic marking tape. Effective on and after January 1, 2012, the Traffic Marking Tape Adhesive Primer category would be a new category to rule language. Adhesives in this category are currently regulated as Adhesive Primers with a VOC content limit of 250 g/l. However, this new adhesives category will have a VOC content limit of 150 g/l to make it as stringent as the VOC content limits for this catego ry in the adhesives rules in SCAQMD, VCAPCD, and SDAPCD and the BAAQMD.

Top and Trim Adhesive Top and Trim Adhesive intended by the manufacture t o be used to install automotive and marine trim, including, but not limited to head liners, vinyl tops, vinyl trim, sunroofs, dash covering, door covering, floor covering, panel covering, and upholstery. Effective on and after January 1, 2012, the Top and Trim Adhe sive category would be a new category to rule language. It is important to note that this adhesive category is new to regulation. This product is currently being sold i n the SJVAB as either a consumer product, an unregulated product, or in small contai ners. Effective on and after January 1, 2012, the VOC content limit for Top and Trim Adh esives would be 540 g/l. This VOC content limit will be as stringent as the VOC conte nt limits for this category in the adhesives rules in BAAQMD, VCAPCD, and SDAPCD.

Waterproof Resorcinol Glue Waterproof Resorcinol Glue is a current adhesive ca tegory for Rule 4653, with a current VOC limit of 170 g/l. There are no proposed amendm ents for this adhesive category at

this time.

Staple and Nail Manufacturing Adhesive Staple and Nail Manufacturing Adhesive is a current adhesive category for Rule 4653, with a current VOC limit of 100 g/l. There are no proposed amendments for this adhesive category at this time.

Thin Metal Laminating Adhesive Thin Metal Laminating Adhesive is any adhesive inte nded by the manufacturer for use in bonding multiple layers of metal to metal or met al to plastic on the production of electronic or magnetic components in which the thic kness of the bonded line(s) is less than 0.25 millimeters. Thin Metal Laminating Adhes ive is a new adhesive category for Rule 4653. The definition was added to rule langua ge during the previous ruleamending project to adopt EPA CTG requirements. Ho wever, a VOC content limit was not assigned to this adhesive at the time of adopti on. Effective on and after January 1, 2012, the VOC content limit would be 780 g/l to mak e it as stringent as the EPA CTG, BAAQMD, and SDAPCD. Staff had originally left this category with an unassigned VOC content limit so it would be subject to the default limit of 250 g/l, however, staff have been unsuccessful in finding an existing product wi th a VOC content limit that could meet the 250 g/l VOC content limit. In an effort t o avoid imposing a potentiallySAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

17 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 technologically infeasible VOC content limit for th is adhesive category, staff recommends adopting a VOC content limit consistent with the EPA CTG, BAAQMD,

and SDAPCD standards.

Elastomeric Adhesive Elastomeric Adhesive is a rubber or thermoplastic b ased adhesive intended by the

manufacturer to be used in the manufacture of life preserving equipment including, but not limited to, aircraft float systems, life rafts, and life jackets; or other personal or equipment protection products. Effective on and af ter January 1, 2012, the Elastomeric Adhesive category would be a new category to rule l anguage. It is important to note that this adhesive category is new to regulation. If this product is currently being sold in the SJVAB it is as either a consumer product, an un regulated product, or in small containers. Effective on and after January 1, 2012 , the VOC content limit for Elastomeric Adhesives would be 750 g/l. This VOC c ontent limit will be as stringent as the VOC content limits for this category in the adh esives rule in SDAPCD.

Flexible Vinyl Adhesive Flexible Vinyl Adhesive is a new adhesive category for Rule 4653, with a current VOC limit of 250 g/l. Flexible Vinyl Adhesive was adde d to rule language during the previous rule-amending project to adopt EPA CTG requirements . However, because the VOC content limit is equal to the default limit, the ca tegory was not added to the Table 1 with the other adhesive categories. However, for the sa ke of clarity of rule requirements, Flexible Vinyl Adhesives will be added to Table 2, maintaining the VOC content limit of 250 g/l.

ABS Welding Adhesive ABS Welding Adhesive is a current adhesive category for Rule 4653. The current VOC limit for this adhesive category is 400 g/l. Effec tive on and after January 1, 2012, the VOC content limit would become 325 g/l. The new VO C content limit will make this VOC limit as stringent as the VOC content limit for this adhesive category in the
adhesives rules in the SCAQMD.

Cellulosic Plastic Welding Adhesive Cellulosic Plastic Welding Adhesives are adhesives intended for use with cellulosic plastics which are any plastic containing the natur ally occurring polymer or polysaccharide, cellulose. Effective on and after January 1, 2012, the Cellulosic Plastic Welding Adhesive category would be a new category t o rule language. It is important to note that this adhesive category is new to regulati on. If this product is currently being sold in the SJVAB, it is as either a consumer produ ct, an unregulated product, or in small containers. Effective on and after January 1 , 2012, the VOC content limit for Cellulosic Plastic Welding Adhesives would be 100 g /l. This VOC content limit will be as stringent as the VOC content limits for this cat egory in the adhesives rule in

VCAPCD.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

18 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 CPVC Welding Adhesive CPVC Welding Adhesive is a current adhesive categor y for Rule 4653, with a current VOC limit of 490 g/l. There are no proposed amendm ents for this adhesive category at

this time.

PVC Welding Adhesive PVC Welding Adhesive is a current adhesive category for Rule 4653, with a current VOC limit of 510 g/l. Effective January 1, 2011 th e VOC content limit will change to 500 g/l per the previous rule-amending project to adopt EPA CTG requirements.

During the rule-amending process, staff received on e stakeholder comment. The commenter expressed concern regarding the feasibili ty of PVC welding adhesives with the 500 g/l VOC content limit. In response to the comment, staff further researched the availability of PVC welding adhesives at 500 g/l VO C content and the feasibility of manufacturing it. During the research process, sta ff had conversations with representatives from EPA Region IX office, the SCAQ MD, and the Antelope Valley AQMD. Conversations with staff from EPA Region IX i ndicated that the 500 g/l VOC content limit in the CTG for PVC welding adhesives may have been an oversight and is not technologically feasible at this time. EPA now concurs with the CARB RACT/BARCT analysis for PVC welding adhesives with a VOC content limit of 510 g/l and recommends the District adopt this limit.

Antelope Valley AQMD had amended their Rule 168 fro m 285g/l to 510 g/l while adopting CTG limits and to mirror SCAQMD in January 2010. El Dorado APCD Rule 236 Adhesives has not updated VOC content limit, wh ich was based on an earlier SCAQMD limit. SCAQMD now has a limit of 510 g/l in their rule for this category. Changing the VOC content limit for PVC welding adhe sives will make this limit as stringent as other air districts in California with the exception of El Dorado APCD who currently have the old SCAQMD limit in their rule.

No emission reductions were claimed from this adhes ive category during the 2009 ruleamending project. Because the VOC content limit ha s yet to take effect and no emissions reductions were claimed, there will be no increase in emissions from this rule-amending project. The 500 g/l VOC limit has n ot been approved into the District’s SIP by EPA, and this proposed action would thus not constitute a SIP relaxation.

Styrene-Acrylonitrile Welding Adhesive Styrene-Acrylonitrile Welding Adhesive is an adhesi ve intended by the manufacturer to weld styrene-acrylonitrile co-polymer plastics. Ef fective on and after January 1, 2012, the Styrene-Acrylonitrile Welding Adhesive category would be a new category to rule language. It is important to note that this adhesi ve category is new to regulation. If this product is currently being sold in the SJVAB it is as either a consumer product, an unregulated product, or in small containers. Effec tive on and after January 1, 2012, the VOC content limit for Styrene-Acrylonitrile Welding Adhesive would be 100 g/l. ThisSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

19 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 VOC content limit will be as stringent as the VOC c ontent limits for this category in the

adhesives rules in VCAPCD.

Plastic Cement Welding Adhesive Primer Plastic Cement Welding Adhesive Primer is a current adhesive category for Rule 4653. The current VOC limit for this adhesive category is 650 g/l. Effective on and after January 1, 2012, the VOC content limit would become 400 g/l. The new VOC content limit will make this VOC limit as stringent as the VOC content limit for this adhesive category in the adhesives rules in the Sacramento M etro Air Quality Managemetn District (SCAQMD).

Other Plastic Cement Welding Adhesive Other Plastic Cement Welding Adhesive is a current adhesive category for Rule 4653. The current VOC limit for this adhesive category is 450 g/l. Effective on and after January 1, 2012, the VOC content limit would become 250 g/l. The new VOC content limit will make this VOC limit as stringent as the VOC content limit for this adhesive category in the adhesives rules in the SCAQMD.

Automotive Glass Primer Automotive Glass Primer is a new adhesive category for Rule 4653. The definition was added to rule language during the previous rule ame nding project to adopt EPA CTG requirements. However, a VOC content limit was not assigned to this adhesive at the time of adoption. The CTG recommended a VOC conten t limit of 900 g/l, however, effective on and after January 1, 2012, the VOC con tent limit would be 700 g/l to make it as stringent as adhesives of the same category in t he BAAQMD, VCAPCD, and SDAPCD. Staff had originally left this category wi th an unassigned VOC content limit so it would be subject to the default limit of 250 g/l, however, staff have been unsuccessful in finding an existing product with a VOC content limit that could meet the 250 g/l VOC content limit. In an effort to avoid i mposing a potentially technologically

infeasible VOC content limit for this adhesive cate gory, staff recommends adopting a

VOC content limit consistent with the EPA CTG stand ards.

Adhesive Primer Adhesive Primer is a current adhesive category for Rule 4653, with a current VOC limit of 250 g/l. There are no proposed amendments for t his adhesive category at this time. Section 5.1.2 would be amended to add fiberglass as a category for Adhesive Products with a VOC content of 80 grams per liter (g/l). Th e VOC content limit for Porous

Materials and Plastic Foam would both become more s tringent, they would each be changed from 120 g/l VOC to 50 g/l VOC effective on and after January 1, 2012.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

20 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Section 5.1.4 would be added to rule language to pr ovide VOC content limits for sealant products. Below, in table 4, is a summary of the p roposed sealant categories and VOC

content limits that would be effective on and after January 1, 2012.

Table 4 Sealant Product Categories

VOC Limit Sealant Product (g/l)

Architectural Sealant 250

Architectural Non Porous Sealant Primer 250

Architectural Porous Sealant Primer 775

Marine Deck Sealant and Sealant Primer 760

Modified Bituminous Sealant Primer 500

Non-Membrane Roof Sealant 300
Single-Ply Roof Sealant 450
Roadway Sealant 250

Other Sealants 420

Other Sealant Primers 750

Section 5.1.5 would be amended to include sealant p roducts.

Section 5.2 Application Equipment Section 5.2 would be amended to include sealant pro ducts.

Section 5.2.8 would be amended for clarity.

Section 5.3 Work Practices Section 5.3 would be amended to include sealant pro ducts and for clarity of rule requirements by consolidating the work practices fo r adhesives and sealants into one location in rule requirements.

Section 5.4 VOC Emission Control System Requirement s There are no proposed amendments recommended for Se ction 5.4 at this time.

Section 5.5 Organic Solvent Cleaning Requirements Section 5.5 would be amended to include sealant pro ducts.

Section 5.6 Solvent Storage and Disposal Requiremen ts (Previous) The language in Section 5.6 would be relocated from this section to Sections 5.3 and the new Section 5.6, in order to clarify rule requi rements.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

21 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Section 5.6 Work Practices for Solvent Cleaning Section 5.6 would be amended for clarity by consoli dating work practices for solvent cleaning into one location.

Section 5.7 Prohibition of Sale Section 5.7 would be amended to include sealant pro ducts.

Section 5.8 Sell Through This section would be added to rule language to pro vide a sell through period of 12

months after the effective date of new VOC content limits to provide an opportunity for manufacturers and retailers to sell through stock o n hand. This section would also allow the application of adhesive products and sealant pr oducts for up to 24 months after the specified effective date of new VOC content limits. In order to an operator to participate in the sell through provision the product must be l abeled to display the date or date code indicating when the product was manufactured a nd that product must comply with the standards in effect at the time the product was manufactured.

Other air districts in California do not generally have a labeling requirement in adhesive and sealant rules, therefore the labeling requireme nt mentioned above is not mandatory for all products, only for products that the manufa cturer wishes to participate in the new sell through provision of this rule.

Section 5.9 Prohibition of Specification Section 5.9 would be added to rule language to prov ide a requirement that no person shall solicit, require for use, or specify the appl ication of any adhesive products or sealant products, if such use of application result s in a violation of the provisions of the

rule.

Section 6.0 Administrative Requirements Section 6.0 would be amended to incorporate recordk eeping requirements. Labeling requirements, and test methods for sealant products

.

Section 6.1 would be amended to remove the requirem ent to maintain daily records of adhesives used at the facility. This requirement w ould be removed in order to streamline recordkeeping requirements, as there are no prohibitions in rule language to justify this recordkeeping requirement.

Section 6.5 Version of Test Methods Section 6.5 would be removed from rule language to reduce redundant language.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

22 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 IV. EMISSION REDUCTION ANALYSIS

The Ozone Plan identifies the annual emissions from the Rule 4653 source category

with current controls have a 2008 baseline emission inventory of 3.3 tons of VOC per day. The Ozone Plan commits the District to reduce VOC emissions from this source category by 3% by 2012. The VOC emission reduction is from this rule-amending project is 18% of the ARB emission inventory for th is source category, which is 0.12 tons per day. The estimated emission reductions fr om this rule-amending project

exceed Ozone Plan commitments. The emission reduct ion analysis is in Appendix B of this final draft staff report.

V. COST EFFECTIVENESS ANALYSIS

Pursuant to CH&SC section 40920.6(a), a cost effect iveness analysis is required for rules that implement BARCT. The purpose of the cost effe ctiveness analysis is to evaluate the

economic reasonableness of a new rule or rule amend ments. The analysis also serves as a guideline for developing the control requirements of the rule. The cost effectiveness analysis is in Appendix C of this final draft staff report.

VI. SOCIOECONOMIC ANALYSIS

Pursuant to CH&SC 40728.5, “whenever a district int ends to propose the adoption, amendment, or repeal of a rule or regulation that w ill significantly affect air quality or emissions limitations, that agency shall, to the ex tent data is available, perform an assessment of the socioeconomic impacts of the adop tion, amendment, or repeal of the rule or regulation.”

The adhesives and sealants source category is appli cable to any person who supplies, sells, offers for sale, or applies any adhesive pro duct or sealant product, or associated solvents, for use within the SJVAB. As such, the r equirements of Rule 4653 can apply to a wide variety of sources ranging from an indivi dual to a large company. This ruleamending project, if adopted, would make the VOC co ntent limits more stringent for certain types of adhesives, as well as add sealant products to rule language.

Affected sources could be impacted by the more stri ngent VOC content limits for adhesives as well as by the addition of sealants to rule language making it a newly regulated category. Additionally, sources could be impacted by the new work practice requirements that would be imposed on the newly reg ulated sealant products. Proposed VOC content limits for adhesive products a nd sealant products are currently enforced in other air districts, and have been in r ule language of adhesives rules in other air districts for the past five to ten years. As such, staff believes compliant adhesives and sealants are readily available and ar e currently being sold in the SJVAB. Work practice requirements include keeping containe rs closed at all times, except whenSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

23 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 depositing or removing the contents of the containe rs or when the container is empty, minimizing spills, and conveying products and waste in closed containers. Compliance with new work practice requirements for sealants wo uld not require the operator to purchase new materials, because operators are alrea dy complying with these standards as it would reduce waste and prevent accidental spi llage of product, which would waste the product, thus costing the operator more money t o replace lost product.

This rule-amending project is not expected to have significant, if any, costs associated

with it. Further discussion of the cost effectiven ess analysis is presented in Appendix C of this final draft staff report. As there would b e no costs associated with this ruleamending project, therefore no additional socio-eco nomic impacts.

VII. RULE CONSISTENCY ANALYSIS

Pursuant to CH&SC 40727.2, District staff has prepa red a rule consistency analysis that compares the elements of amendments with the corres ponding elements of other District rules, federal regulations and guidelines that apply to the same source category or type of equipment. District staff found that th e proposed amendments and requirements of this rule would not conflict with f ederal rules, regulations, or policies covering similar stationary sources. The rule cons istency analysis is presented in Appendix D of the Final Draft Staff Report.

VIII. ENVIRONMENTAL IMPACT ANALYSIS

Pursuant to the California Environmental Quality Ac t (CEQA), staff investigated the possible environmental impacts of the proposed amen dments to Rule 4653. Based on the lack of evidence to the contrary, District staf f has concluded that the proposed amendments to the rule will not have any significan t adverse effects on the environment. As such, staff recommends filing a No tice of Exemption under the provisions of Public Resource Code 15061(b)(3).

IX. RACT ANALYSIS

The Clean Air Act (CAA) Section 182(b)(2) states th at ozone attainment plans shall assure that RACT for volatile organic compounds (VO C) is applied at certain sources. A RACT analysis requires an examination of a rule a gainst Federal rules, regulations, and technology guidelines as well as comparing it a gainst rules from other Districts in California. District Rule 4653 was compared to fed eral and state regulations and guidance. The following is a discussion of that an alysis.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

24 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 A. EPA – Control Technique Guidelines (CTG) Since 1975, EPA staff has issued more than 35 CTGs covering a variety of VOC emission sources. One CTG promulgated by EPA has a n impact on Rule 4653. CTG for Miscellaneous Industrial Adhesives (EPA 453 /R-08-005)

This CTG applies to industrial adhesives applicatio ns 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 for

extreme ozone nonattainment areas. The emission st andards recommended by EPA in the CTG has been previously included in Rule 4653, therefore the proposed

amendments are not in conflict or inconsistent with the CTG.

B. EPA - Alternative Control Technology (ACT) There is no EPA ACT guidance document for adhesives

.

C. Standards of Performance for New Stationary Sour ces (NSPS)

There is no NSPS document for adhesives.

D. National Emission Standards for Hazardous Air Po llutants (NESHAPs) and Maximum Achievable Control Technologies (MACTs)

There is no NESHAPs/MACT document for adhesives.

District staff compared District Rule 4653 with the rules of other California Ozone nonattainment air districts’ rules (listed below) for adhesives operations. The results of the analysis are discussed below.

A. South Coast Air Quality Management District (SCA QMD) Rule 1168 – Adhesive and Sealant Applications (Amended January 7, 2005) B. Bay Area Air Quality Management District (BAAQMD ) Regulation 8 Rule 51 - Adhesive and Sealant Products (Amended July 17, 200 2) C. Sacramento Metropolitan Air Quality Management D istrict (SMAQMD) Rule 460 - Adhesives and Sealants (Amended November 30, 2000) D. Ventura County Air Pollution Control District (V CPCD) Rule 74.20 – Adhesives and Sealants (Amended January 1, 2005)

The following tables identify the adhesive and seal ant product comparisons for SJVAPCD current or proposed VOC content limits with those in other Districts in

California.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

25 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Table 5 General Adhesive Products

Material Bonded SJVAPCD SCAQMD BAAQMD SMAQMD VCAPCD

Metal to Metal 30 30 30 30 30

Porous Materials 50 50 120 120 50

Plastic Foam 50 50 120 50

Wood 30 30 30

Pre-formed Rubber Products 250 250 250
Reinforced Plastic Composite 200
Fiberglass 80 80 200 80

All Other Substrates 250 250 250

Table 6 Specialty Adhesive Products

Adhesive Product SJVAPCD SCAQMD BAAQMD SMAQMD VCAPCD Multipurpose Construction 70 70 200 200 70

Ceramic Tile Installation 65 65 130 130 65

Cove Base Installation 50 50 150 150 50 Dry Wall and Panel 50 50 50 Floor Covering Installation 150 150 150 150

Ceramic Floor Tile Installation 65 65 130 130 65 Indoor Carpet Adhesive 50 50 150 150 50 Carpet Pad Adhesive 50 50 Outdoor Carpet Adhesive 150 150 250 150 150 Rubber Flooring 60 60 60

Permiter Bonded Sheet Flooring Installation 660

660 660

Subfloor Adhesive 50 50 50 VCT and Asphalt Tile 50 50 50 Wood Flooring 100 100 100 Single-Ply Roof material

Installation 250

250 250 250 250

Non-Membrane Roof 300 300 300 300 Structural Glazing 100 100 100 100 100

Structural Wood Member

Adhesive 140

140 140SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

26 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Table 6 Specialty Adhesive Products (continued)

Adhesive Product SJVAPCD SCAQMD BAAQMD SMAQMD VCAPCD

Contact Adhesive 80 80 250 250 80 Contact Adhesive - Specialty 250 250 400 250 250

Rubber Vulcanization

Adhesive/Primer 850 850 850 850

Tire Retread 100 100 100 100 100

Motor Vehicle Adhesive 250

Motor Vehicle Weatherstrip

Adhesive 750

Traffic Marking Tape

Adhesive/Primer 150 150 150 150 150
Top and Trim Adhesive 540 540 540 540
Waterproof Resorcinol Glue 170 170 170
Staple and Nail Manufacturing 640
Thin Metal Laminating 780 780 780

Elastomeric 750
Flexible Vinyl 250 250 250
ABS Welding 325 325 400 400 400
Cellulosic Plastic Welding 100 100
CPVC Welding 490 490 490 490 490
PVC Welding 510 510 510 510 510
Styrene-Acrylonitrile Welding 100 100

Plastic Cement Welding

Adhesive Primer 400 550 650 400 650
Other Plastic Cement Welding 250 250 500 450 500

Automotive Glass Primer 700 700 700 700

Adhesive Primer 250 250 250SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

27 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 Table 7 Sealant Products

Sealant Product SJVAPCD SCAQMD BAAQMD SMAQMD VCAPCD

Architectural 250 250 250 250 250

Marine Deck 760 760 760 760 760

Nonmembrane Roof 300 300 300 300 300
Roadway 250 250 250 250 250 Single-Ply Roof

Membrane 450 450 450 450 450

Other 420 420 420 420 420

Sealant Primer
Architectural nonporous 250 250 250 250 250
Architectural porous 775 775 775 775 775

Modified Bituminous 500 500 not listed not listed

Marine Deck 760 760 not listed 760 760

Other 750 750 750 750 750SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4653 (Adhesives and Sealan ts) September 16, 2010

28 Final Staff Report with Appendices For Proposed Amendments to Rule 4653 IX. REFERENCES

1. Antelope Valley AQMD. Rule 1168 Adhesive Applic ations. April 11, 1997. 2. ARB. Almanac Emission Projection Data, and Clea ning and Surface Coating Methodologies Section 3.7 – Adhesives and Sealants. 2009. 3. Bay Area AQMD. Regulation 8 Organic Compounds R ule 51 Adhesive and Sealant Products. July 17, 2002. 4. El Dorado County AQMD. Rule 236 Adhesives. Jul y 25, 1995.

5. EPA. “EPA-453/R-08-005. CTG for Miscellaneous Industrial Adhesives”. September 2008. http://www.epa.gov/ttn/naaqs/ozone /ctg_act/index.htm

6. EPA. The Little Bluebook. 7. Placer County APCD. Rule 235 Adhesives. April 10, 1997. 8. Sacramento Metropolitan AQMD. Rule 460 Adhesive s and Sealants. November 30,

2000. 9. San Diego County APCD. Rule 67.21 Adhesive Mate rial Application Operations. November 14, 2008. 10. Santa Barbara County APCD. Rule 353 Adhesives and Sealants. August 19, 1999. 11. Shasta County AQMD. Rule 3:32 Adhesives and Se alants. July 26, 2005.
12. South Coast AQMD. Rule 1168 Adhesive and Seala nt Applications. January 7,

2005. 13. Tehama County APCD. Rule 4:40 Adhesives and Se alants. April 1, 2003. 14. Ventura County APCD. Rule 74.20 Adhesives and Sealants. January 11, 2005. 15. Yolo-Solano AQMD. Rule 2.33 Adhesive Operation s. May 14, 2008.