SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Comments and Responses October 16, 2008

A - 1 Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606 

# APPENDIX A

COMMENTS AND RESPONSES FOR RULES 4603 AND 4606

October 16, 2008SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Comments and Responses October 16, 2008

A - 2 Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606 SUMMARY OF SIGNIFICANT COMMENTS ON SEPTEMBER 18, 20 08 VERSION OF

PROPOSED AMENDMENTS TO RULE 4603 AND RULE 4606

AND DISTRICT STAFF’S RESPONSES

EPA Comments

EPA has reviewed proposed Rules 4603 and 4606 and h as no comments at this time.

ARB Comments on Rule 4603

1. Comment: From our discussion with District staff, we under stand that the purpose

of the current rule amendments is to make the rule consistent with the U.S. EPA requirements for RACT and RACM. Given the District ’s nonattainment of the State ozone and PM air quality standards, we recommend th at the District consider All

Feasible Measures that have been successfully implemented elsewhere.

Specifically, the district should lower the VOC lim it for general air-dried coatings from 340 grams per liter (g/L) specified in Section 5.1.2 to 275 g/L. The VOC limits in Table 1 for Extreme High Gloss (Air Dried) shoul d be changed from 420 g/L to 340 g/L and Extreme Performance (Baked) should be c hanged from 420 g/L to 360 g/L. (ARB)

Response: Although SCAQMD Rule 1107 has lower VOC limits on t he coating categories mentioned by ARB and EPA, it should be n oted that Rule 1107 has many exemptions than Rule 4603. Without a thorough analysis of the potential emissions generated by Rule 1107 exemptions, it is difficult to conclude that Rule 1107 is overall more stringent simply because three coating categories have slightly lower limits than Rule 4603. District sta ff will consider ARB’s comments when the rule is reopened in the future.

ARB Comment on Rule 4606

2. Comment: Section 5.0, Table 1, VOC Content Limits: The VOC limit for Sanding Sealer is 275 g/l. Ventura County Air Pollution Co ntrol District (VCAPCD) Rule 74- 30, Section (B)(1), has a limit of 240 g/l for this category. We recommend that the

District include this lower limit in the rule.

Response: Ventura’s Rule 74-30 has a limit of 240 grams/liter for new wood products and 680 grams/liter for refinishing operat ion. Although refinishing is exempt by Rule 4606, based on a review of the Distr ict’s Permit to Operate database, there are only two permitted wood coating facilities that perform wood coating refinishing operations that emit a total of one ton/year of VOC. The emissions generated by Ventura’s 680 grams/liter li mit for refinishing coatings may actually be higher (depending on the number of faci lities) than the emissions fromSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Comments and Responses October 16, 2008

A - 3 Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606 the 275 grams/liter limit in Rule 4606. Staff beli eves that overall Rule 4606 is as stringent as Rule 74-30.

3. Comment: The VOC limit for strippers is 350 g/l. San Dieg o County Air Pollution Control District Rule 67-11, Section (d)(5)(i), has a limit of 200 g/l for strippers. We

recommend that the District include this lower limi t in the rule.

Response: San Diego County Rule 67-11 allows the use of str ipper that has 200 grams/liter, or has an initial boiling point (IBP) of 190 o C (374 o F) or greater, or has a total vapor pressure (VP) of 20 mmHg or less at 68 o F. It is important to mention that even though a material has a low IBP or low VP such that it evaporates slowly, it may have a high VOC content that results to high er emissions after a period of time. For example, stoddard solvent (mineral spiri t) has a low VP (about 3.1 mm Hg) but it is 100% volatiles by volume, and therefo re the emissions would be greater than the emissions that would result from R ule 4606 stripper VOC limit of 350 grams/liter. Staff believes that overall the s tripper VOC limit of Rule 4606 is as stringent as Rule 67-11 that allows three complianc e options mentioned above.

4. Comment: Section 5.4.3 requires the overall capture and co ntrol efficiency to be at least 85% by weight. VCAPCD Rule 74-30 Section (B)(6)(a) has an overall capture and control efficiency of at least 90% by w eight. We recommend that the District include this higher efficiency in the rule

.

Response: Currently, there are no existing permitted wood coa ting operations in the District that operate a VOC emission control sy stem so changing the control efficiency at this time would not result in any emi ssions reduction. New or modified wood coating operations that elect to install and o perate a VOC emission control system would be subject to District rule 2201 (New and Modified Stationary Source Review Rule) and would be evaluated for Best Availa ble Control Technology (BACT) and Offset requirements. BACT type VOC emis sion control system would require at least 90% overall capture and control ef ficiency. Staff will consider increasing the control efficiency when the rule is reopened for future amendments.

5. Comment: Section 5.7.2 limits the VOC content of strippabl e booth coating to 450 g/l. This requirement would fit better in Section 5.1. We recommend moving this

limit to Section 5.1.

Response: District staff previously responded to similar AR B comment that the strippable booth coating is part of the solvent cle aning provisions of the rule to minimize VOC emissions. Such coating is applied on the surface of interior walls and floors of paint booth for protection from overs pray during products coating operations, which later on can be peeled off instea d of cleaning with organic solvents. Relocating the strippable booth coating limit in Section 5.1 that pertains to wood coatings VOC limits would imply that stripp able booth coating is used onSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Comments and Responses October 16, 2008

A - 4 Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606 wood products which is not the case. Therefore, th e existing provision will remain

in its current location in the rule.

Stakeholders’ Comments

No comments were received from stakeholders.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX B: Rule Consistency Analysis October 16, 2008

B-1 Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606 

# APPENDIX B

RULE CONSISTENCY ANALYSIS

FOR PROPOSED AMENDMENTS TO RULE 4603 AND RULE 4606

October 16, 2008SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX B: Rule Consistency Analysis October 16, 2008

B-2 Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606 RULE CONSISTENCY ANALYSIS

I. REQUIREMENTS FOR RULE CONSISTENCY ANALYSIS

Prior to adopting, amending, or repealing a rule or regulation, California Health and Safety Code Section 40727.2 requires that District staff perform a written analysis that identifies and compares the air pollution control e lements of the proposed rule with the corresponding elements of existing or proposed Dist rict and United States Environmental Protection Agency (EPA) rules, regula tions, and guidelines that apply to the affected source category. The elements that we re analyzed are emission limits; work practices; monitoring and testing; and recordk eeping and reporting requirements. The analysis is detailed in Section II of this repo rt. Conclusions based on the analysis

are shown in Section III.

II. RULE CONSISTENCY ANALYSIS

District staff reviewed EPA rules, regulations, and guidelines, as well as District rules for the source categories covered by Rule 4603 and Rule 4606. The analysis was confined to those provisions that incorporate the standards established in EPA’s CTGs for large appliance coating operations, metal furniture coati ng operations, and flat wood paneling products coating operations. Existing coatings VOC limits, operating parameters, monitoring, testing, records, and reporting require ments from coating operations other than those that affect the implementation of the CT G standards were not analyzed for purposes of the rule consistency analysis.

A. Existing or Proposed District Rules

The following existing District prohibitory rules a lso apply to Rule 4603 (Surface Coating of Metal Parts and Products) and Rule 4606 (Wood Co ating Operations):

Rule 1020 (Definitions)

Rule 1020 applies to sources subject to Rule 4603 a nd Rule 4606 only because the

definition of VOC is referred to the definition tha t is indicated in Rule 1020. District staff is not proposing any change to the existing definit ion of VOC so there is no impact on the proposed amendments to the rules.

Rule 2020 (Exemptions)

Rule 2020 Section 6.8.2 provides operators some exe mption from obtaining a District Permit to Operate (PTO) for certain surface coating operations. Specifically, Section 6.8.2 exempts from PTO surface coating operations, except powder coating operations), which use less than one quart of coati ng per day or less than eight gallons of coating per year. Powder coating operations tha t use less than five pounds ofSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX B: Rule Consistency Analysis October 16, 2008

B-3 Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606 coating material per day or less than 50 pounds of material per year is exempt from

PTO.

Rule 2201 (New or Modified Stationary Source Review )

Rule 2201 applies to permitting of new or modified stationary sources of air pollution. It provides the review new or modified stationary sour ces of air pollution and establishes the mechanisms including emission trade-offs by whi ch Authorities to Construct such sources may be granted without interfering with the attainment or maintenance of Ambient Air Quality standards. It also requires no net increase in emissions above specified thresholds from new or modified stationar y sources of all nonattainment pollutants and their precursors. In addition it es tablishes the requirements that trigger the need to install and operate Best Available Cont rol Technology (BACT) and emission offsets. The proposed changes to Rule 4603 and 460 6 do not change the existing requirements of Rule 2201. As discussed in Section IIIC of the Final Draft Staff Report metal furniture coating operation sources that are likely subject to the proposed changes to Rule 4603 are already using coatings tha t meet the proposed VOC limits. In addition, there is no flat wood product coating ope ration in the District, therefore the proposed changes to Rule 4606 does not affect the r equirements of Rule 2201.

B. Existing or Proposed Federal Rules, Regulations, and Guidelines

1. Control Techniques Guidelines (CTGs)

CTG for Large Appliance Coatings (EPA 453/R-07-004) and CTG for Metal Furniture Coatings (EPA 453/R-07-005)

EPA finalized the above CTGs in September 2007. Th e standards established by these

CTGs are summarized in Sections IIIA and IIIC of th e Final Draft Staff Report. Since the purpose of the rulemaking project is to incorpo rate the standards of the CTGs, the proposed changes to Rule 4603 are identical to the CTGs’ applicability threshold, coating VOC limits, add-on control equipment emissi on control efficiency, and work practice standards.

CTG for Flat Wood Paneling Coatings (EPA 453/R-06-0 04)

EPA finalized the above CTG in September 2006. The standards established by this

CTG are summarized in Section IIID of the Final Dra ft Staff Report. Since the purpose of the rulemaking project is to incorporate the sta ndards of the CTG, the proposed changes to Rule 4603 are identical to the CTG’s app licability threshold, coating VOC limits, add-on control equipment emission control e fficiency, and work practice

standards.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX B: Rule Consistency Analysis October 16, 2008

B-4 Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606 2. New Source Performance Standards (NSPS)

NSPS requirements are organized by source category in 40 Code of Federal Regulation (CFR) Part 60. Since EPA has delegated the authori ty to implement NSPS requirements to the District, all NSPS promulgated by EPA have been incorporated by reference into District Rule 4001 (New Source Perfo rmance Standards). Rule 4001 lists 71 NSPS which apply to a variety of source categori es.

District staff analyzed two NSPSs that are relevant to the proposed amendments to Rule 4603 to incorporate the CTG standards for meta l furniture and large appliance parts and products coating operations into the rule . 40 CFR 60 Subpart EE establishes the NSPS for surface coating of metal furniture. 4 0 CFR 60 Subpart SS establishes the NSPS for industrial coating of large appliances. T he analysis of the major provisions of Rule 4603 in comparison with 40 CFR 60 Subpart EE a nd Subpart SS is presented in Table 1 of this report. District staff did not fin d any NSPS relevant to wood coating operations. Therefore, no rule consistency analysi s was done to compare Rule 4606

with NSPS.

3. National Emission Standards for Hazardous Air Po llutants (NESHAPs)

NESHAPs are requirements contained in 40 CFR 61 and 40 CFR 63. Since EPA has delegated the authority to implement NESHAP require ments to the District, all NESHAP promulgated by EPA have been incorporated by refere nce into District Rule 4002 (national Emission Standards for Hazardous Air Poll utants).

District staff analyzed two NESHAPs that are releva nt to the proposed amendments to Rule 4603 to incorporate the CTG standards for meta l furniture and large appliance parts and products coating operations. 40 CFR 63 S ubpart NNNN establishes the NESHAP standards for surface coating of large appli ances. 40 CFR 63 Subpart RRRR

establishes the NESHAP standards for surface coatin g of metal furniture. Although, 40 CFR 63 Subpart MMMM applies to surface coating of m iscellaneous metal parts and products, District staff did not analyze this NESHA P since there is no change to the existing Rule 4603 requirements for miscellaneous m etal parts and products other than to incorporate the CTG standards specifically for m etal furniture and large appliance parts and products coating operations. The analysi s of the major provisions of Rule 4603 in comparison with 40 CFR 63 Subpart NNNN and Subpart RRRR is presented in Table 2 of this report.

District staff analyzed one NESHAP that is relevant to the proposed amendments to Rule 4606 to incorporate the CTG standards for flat wood paneling products coating operations. 40 CFR 63 Subpart QQQQ establishes the NESHAP standards for surface coating of wood building products. According to EP A, the Wood Building Products source category was originally listed as the “flat wood peneling” source category, but he name was changed to wood building products to more accurately reflect the types of products and manufacturing sources in the source ca tegory. The wood buildingSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX B: Rule Consistency Analysis October 16, 2008

B-5 Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606 products covered by 40 CFR 63 Subpart QQQQ include interior wall paneling and tileboard, exterior siding and primed doorskins, ot her interior panels, flooring, doors, window, and miscellaneous. The analysis of the maj or provisions of Rule 4606 pertaining to flat wood paneling products coating o perations in comparison with 40 CFR 63 Subpart QQQQ is presented in Table 3 of this rep ort.

III. RESULTS OF RULE CONSISTENCY ANALYSIS

District staff found that facilities affected by th e proposed changes to Rule 4603 are already using coatings that comply with the propose d coating VOC limits. The proposed changes to Rule 4606 would not affect exis ting wood products coating operations because the changes only applies to flat wood paneling coating operations.

District staff has determined that there is no flat wood paneling products manufacturing company currently operating within the San Joaquin Valley. Furthermore, District staff found that none of the proposed requirements of thi s rulemaking project would conflict with federal rules, regulations, or policies coveri ng similar stationary sources.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAPPENDIX B: Rule Consistency Analysis October 16,2008B-6Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606Table 1 - Comparative Analysis of Rule 4603 and Applicable New Source Performance Standards (NSPS)Rule 460340 CFR 60 Subpart EE (Surface Coating of Metal Furniture) 40 CFR Subpart SS(Industrial Surface Coatingof Large Appliances)Applicability Metal parts and products, large appliances parts or products, andmetal furniture.Large appliances parts or products coating operations, and metalfurniture coating operations at a stationary sourcewhere theemissions are equal to or greater than 3 tons of VOC per 12-monthrolling period are subject to the new VOC content limits of theproposed Rule 4603.Metal furniture coating operation facility that commencesconstruction, modification, or reconstruction after11/28/80.Large appliance surfacecoating facility thatcommences construction,modification, orreconstruction after 12/24/80.Exemption Except for large appliance parts and products, and metal furniturethe rule exempts stationary source that uses 55 gallons or less ofnon compliant coatings per rolling 365-day periodFacilities using less than 3,842 liters of coating(as applied) peryear.None.Standards•General Coatings Limits (except for large appliance parts andproducts, and metal furniture):Baked: 275 grams/liter; Air-dried: 40 grams/literAir-dried Dip coating of steel joists: 340 grams/liter to 400grams/liter depending on viscosity of coatings.•Specialty Coating Limits (except for large appliance parts andproducts, and metal furniture):Baked: 360 to 880 grams/liter; Air-dried: 420 to 880 grams/liter.•Coatings Limits for Large Appliance Parts and Products, andMetal FurnitureBaked: 275 to 420 grams/liter; Air-dried: 275 to 420 grams/liter.•Install and operate a VOC emission control systeminstead ofcomplying with coating VOC limits.•Prohibits discharge into the atmosphere of VOC emissions frommetal furniture surface coating operation in excessof 0.90kg/liter (900 grams/liter) of coating solids applied.•Establishes specific performance tests and complianceprovisions.•Specifies coating application methods and correspondingtransfer efficiencies (air atomized - 25%; airlessspray - 25%;manual electrostatic spray - 60%; nonrotational automaticelectrostatic spray - 70; rotating head electrostatic spraymanual and automatic - 80%; dip and flow coating -90%;electrodeposition - 95%)•Allows use of VOC capture and control system to comply withthe required VOC emission limit. Requires testing andmonitoring of the VOC emission control system.Same as indicated for 40CFR 60 Subpart EE.Work Practice•Store all VOC-containing materials in closed containers.Containers must be closed at all times except whenspecificallyin use.•Close mixing vessels that contain VOC-containing coatings andmaterials, except when specifically in use.•Minimize spills and convey VOC-containing materials in closedcontainers or pipes.•Specifies coating application equipment (electrodeposition,electrostatic application, HVLP guns, flow coating,roll coating,dip coating, brush coating, continuous coating, orother typethat meets at least 65% transfer efficiency.None specified.None specified.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAPPENDIX B: Rule Consistency Analysis October 16,2008B-7Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606Continuation of Table 1 – Comparison of Rule 4603 and Applicable New Source Performance Standards (NSPS)Rule 460340 CFR 60 Subpart EE (Surface Coating of Metal Furniture) 40 CFR Subpart SS(Industrial Surface Coatingof Large Appliances)Recordkeeping andReportingMaintain records of MSDS for each coating used, VOCcontent ofcoating, and amount used. Keep records for at least five years andmake such records available to the APCO upon request.•Requires initial performance test and then monthlythereafter:Volume-weighted average mass of VOC emitted to theatmosphere per volume of applied coating solids fora period ofone calendar month.•List of coatings used during a period of one calendar month,VOC content of each coating and the minimum transferefficiency of coating application equipment used during themonth.•For VOC control system: total VOC emitted that enters thecontrol device, VOC reduction efficiency of the control device,average combustion temperature, description of method usedto establish the amount of VOC captured and sent totheincinerator.•For thermal and catalytic incinerators, each 3-hrperiod ofcoating operation during which the average temperaturerecorded immediately before the catalyst bed is more than 28oC(50oF) below the average temperature at the same locationduring the most recent performance test at which thedestruction efficiency was determined as specifiedin Section60.313.•For facilities where compliance is achieved through the use ofsolvent recovery system: volume of VOC-solvent recovered;overall VOC emission reduction achieved.•Submit a written report every calendar quarter ofeach instancewhere the volume-weighted average of the total massof VOCemitted into the atmosphere per volume of applied coatingsolids is greater than the specified limit. If noinstances haveoccurred during a particular quarter, a report stating this shallbe submitted semiannually.Same as indicated for 40CFR Subpart EE.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAPPENDIX B: Rule Consistency Analysis October 16,2008B-8Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606Table 2- Comparison of Rule 4603 and National Emission Standards for Hazardous Pollutants (NESHAP)Rule 4603 40 CFR 63 Subpart NNNN (Surface Coating of Large Appliances) 40 CFR 63 Subpart RRRR (SurfaceCoating of MetalFurniture)Applicability Refer to discussionindicated in Table 1•Large appliance parts and products coating facility that is a major source ofHAP that emits or has the potential to emit a single HAP of 9.07 megagrams(10 tons) per year or more or any combination of HAP of 22.68 megagrams (25tons) per year.•Applies to each new, reconstructed, and existing affected source.•A new affected source that commences constructionafter 7/23/02 and theconstruction is of a completely new large appliancesurface coating facilitywhere previously no large appliance surface coatingfacility had existed.•Major source of HAP that emits or has the potential toemit a single HAP of 9.07 megagrams (10 tons) per yearor more or any combination of HAP of 22.68 megagrams(25 tons) per year.•Applies to each new, reconstructed, and existing affectedsource.•A new affected source that commences constructionafter7/23/02 and the construction is of a completely newlargeappliance surface coating facility where previouslynolarge appliance surface coating facility had existed.Exemption Refer to discussionindicated in Table 1•Non-major sources of HAP.•Large appliance parts such as metal or plastic handles, hinges, or fastenersthat have a wider use beyond large appliances.•Surface coating conducted for the purpose of repairing or maintaining largeappliances used by a facility and not for commerce.•Surface coating of heat transfer coils or large commercial and industrial chillers.•Affected source that uses only coatings, and thinners thatcontain no organic HAP.•Surface coating of metal components of wood furnituresubject to wood furniture manufacturing NESHAP.•Surface coating conducted at research or laboratoryfacilities or that is part of janitorial, building,and facilitymaintenance operations.•Surface coating of only small items such as knobs,hinges, or screws that have a wider use beyond metalfurniture unless the surface coating occurs at an affectedmetal furniture source.•Surface coating of metal furniture conducted for thepurpose of repairing or maintaining metal furnitureusedby a major source and not for commerce, unless HAPemissions itself is as high as the rates specifiedabove.•Surface coating of metal furniture performed on-site atinstallations owned and operated by the Armed Forces ofthe U.S. (including coast Guard and National Guardof anyState).Standards Refer to discussionindicated in Table 1•Existing source: limits organic HAP emissions tothe atmosphere to no morethan 0.13 kg/liter (1.1 lb/gal) of coating solids used during each complianceperiod. The emission limit includes all coatings, thinners, and cleaning materialsused.•Includes three compliance options (use of compliant materials, emission ratewithout use of add-on controls, or emission rate with add-on controls).•For New or reconstructed source: emit no organicHAPduring each compliance period. May request alternativeemission limit provided the conditions of Section63.4890(b)(1) are met. If approved, the source must meetan alternative emission limit of 0.094 kg organic HAP perliter (0.78 lb/gallon) coating solids used for onlythosecomponents subject to the approval.•For existing affected source: no more than 0.10 kgorganicHAP per liter (0.83 lb/gallon) of coating solids during eachcompliance period.•Operators that use compliant material option are notrequired to meet any operating limits.•Operators that use the emission rate with add-on controlsoption are required to meet the operating limits specifiedin Table 1 of this subpart.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAPPENDIX B: Rule Consistency Analysis October 16,2008B-9Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606Continuation of Table 2- Comparison of Rule 4603 and National Emission Standards for Hazardous Pollutants (NESHAP)Rule 4603 40 CFR 63 Subpart NNNN (Surface Coating of Large Appliances) 40 CFR 63 Subpart RRRR (SurfaceCoating of MetalFurniture)Work Practice Refer to discussionindicated in Table 1•For operation that uses compliant material optionor emission rate without addon controls option, compliance with any work practice standards are notrequired.•For operation that use emission rate with add-on controls option, implement awork practice plan to minimize organic HAP emissions from storage, mixing,and conveying coatings, thinners, and cleaning materials used in, and wastematerials generated by, the coating operations. Store all HAP-containingmaterials in closed containers. Minimize spills ofHAP-containing materials.Convey HAP-containing materials from one location to another in closedcontainers or pipes. Mixing vessels must be closedexcept when removing, ormixing contents. Minimize HAP emissions during cleaning of storage, mixing,and conveying equipment.Same as discussed for 40 CFR 63 Subpart NNNN.Recordkeeping andReportingRefer to discussionindicated in Table 1•Submit Initial Notification no later than 6/23/03.For new or reconstructedsource, submit Initial Notification no later than 120 days after initial start-up or11/2002 whichever is later.•Submit semiannual compliance reports (period fromJanuary 1 through June 30or from July 1 through December 31).•Demonstration of compliance with the emission limit requires submission ofdetailed data which include mass fraction of HAP for one coating, one thinner,and for one cleaning material; volume fraction coating; density of coating;amount of waste materials and mass of HAP containedin waste material,determination of kg or HAP emitted per liter of coating solids.•For emission rate without add-on controls option:provide calculation of thetotal mass of HAP emissions; calculation of the total volume of coating solidsused; and calculation or HAP emission rates as specified in the applicableprovisions.•For emission rate with add-on controls option, provide the calculation of thetotal mass of HAP emissions for the coatings, thinners, and cleaning materialsused; calculation of the total volume of coating solids used; calculation of themass HAP emission reduction by emission capture systems and add-on controldevices; and calculation of HAP emission rate; a summary of the results ofeach add-on control device performance tests; a list of each emission capturesystem’s and add-on control device’s operating limits and a summary of thedata used to calculate those limits.•Keep records of the data and information specifiedin Section 63.4130.Same as discussed for 40 CFR 63 Subpart NNNN.ComplianceDeadlinesSix months after ruleamendments adoptiondate.•Comply by 7/23/02 if the initial start-up of new or reconstructed affected sourceis before 7/23/02.•Comply by the initial start-up date if the new orreconstructed source occursafter 7/23/02.•For existing source comply by 7/25/2005.•Comply by 5/23/03 if the initial start-up of new orreconstructed affected source is before 5/23/03•Comply by the initial start-up date if the initialstat-up dateis after 5/23/03.•Comply by 7/25/2005 for existing source.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAPPENDIX B: Rule Consistency Analysis October 16,2008B-10Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606Table 3 – Comparison of Rule 4606 with National Emission Standards for Hazardous Air Pollutants (NESHAP)Rule 460640 CFR 63 Subpart QQQQ (Surface Coating of Wood Building Products)Applicability Application of coatings to wood products, including furniture, cabinets, flatwood paneling, and custom replica furniture.Flat wood Paneling products coating operation thatemits 15 lb/day of VOCbefore consideration of controls.•Any affected source that performs surface coatingoperations involving wood buildingproducts that use at least 4,170 liters (1,100 gallons) of coating per year, and is a majorsource, is located at a major source, or is a partof a major source of HAP emissions.•A major source is a source that has the potentialto emit 9.0 megagrams/yr (10 tons/yr) of anysingle HAP or 22.68 megagrams/yr (25 tons/yr) of any combination of HAP.•Applies to new, reconstructed, and existing source( a new affected source is one on whichconstruction commenced after 6/21/02).Exemptions•Coating operations that use a total of less than 20 gallons of coating peryear.•Aerosol spray coatings for touch and repair.•Application of coatings by templates to add designs, letters, or numbers towood products.•Application of coatings to wooden instruments.•Residential noncommercial operations.•Architectural coatings subject to District Rule 4601.•Refinishing, replacement, and custom replica furniture coating operation.•Specific finishes, except for flat wood paneling products, (crackle lacquers,faux finishes, imitation wood grain, leaf finishes)•Surface coating operations covered by 40 CFR 63 Subpart DDDD (Plywood and CompositeWood Products).•Surface coating operations covered by 40 CFR 63 Subpart JJ (Wood FurnitureManufacturing).•Surface coating operations occurring during manufacture of prefabricated homes andmobile/modular homes.•Surface coating occurring at research and laboratory facilities, janitorial, building, and facilityconstruction or maintenance operations, hobby shopsfor personal rather than commercialpurposes, non commercial coating operations, or coating applications using hand-held nonrefillable aerosol containers.•Surface coating involving wood treatment or fire retardant operations located at wood buildingproducts sources that involve impregnating the woodproduct with the wood treatmentchemicals or fire retardant by using retort or other pressure vessel.Standards•For wood products except flat wood paneling: 275 to 750 grams/literdepending on type of coating. Low solid stain: 120grams/liter; Stripper:350 grams/liter.•For flat wood paneling products: 250 grams/liter of coating, less water andexempt compound, as applied, or 350 grams/liter ofmaterial as applied.•In lieu of complying with coating VOC limits, install and operate a VOCemission control system (overall capture and control efficiency of at least85% for wood products and at least 90% for flat wood paneling productscoating operation.•Cleaning solvent VOC limits:Until 9/20/08, 50 to 550 grams/liter dependingon type of cleaning operation. On and after 9/21/08, organic solvent limitis 25 grams/liter for any type of cleaning operation.•Emission Limits:•Doors, windows, and miscellaneous: 231 grams HAP/liter solids for existing sources; 57grams HAP/liter solids for new or reconstructed source.•Flooring: 83 grams HAP/liter solids for existing sources; 0 grams HAP/liter solids for new orreconstructed source.•Interior wall paneling or tileboard: 183 grams HAP/liter solids for existing sources; 5 gramsHAP/liter solids for new or reconstructed source.•Other interior panels: 20 grams HAP/liter solids for existing sources; 0 grams HAP/liter solidsfor new or reconstructed source.•Exterior siding and primed doorskins: 7 grams HAP/liter solids for existing sources; 0 gramsHAP/liter solids for new or reconstructed source.•Compliance Options: use compliant materials; HAPemission rate without add-on controls(12-month average emission) is less than or equal to the applicable emission limits; oremission rate with add-on controls (HAP emission rate is less or equal to the applicableemission limit with the use of add-on controls).Work Practice•Store all VOC-containing materials in closed containers which must remainclose at all times except when specifically in use.•Close mixing vessels containing VOC coatings and other materials, exceptwhen specifically in use.•Minimize spills of VOC-containing materials and clean spills immediately.Convey any VOC-containing materials in closed containers or pipes.•Store all organic-HAP coatings, thinners, cleaningmaterials, and waste materials in closedcontainers.•Cover mixing vessels containing organic-HAP exceptwhen adding, mixing or removingcontents.•Minimize emissions during cleaning of storage, mixing and conveying equipment.•Minimize spills of organic-HAP coatings, thinners,cleaning materials and waste materials.•Minimize emissions through careful handling and transfer (convey organic-HAP materialsfrom one location to another in closed containers or pipes)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAPPENDIX B: Rule Consistency Analysis October 16,2008B-11Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606Continuation of Table 3 – Comparison of Rule 4606 with National Emission Standards for Hazardous Air Pollutants (NESHAP)Rule 460640 CFR 63 Subpart QQQQ (Surface Coating of Wood Building Products)Recordkeeping andReporting•Maintain current list of coatings, inks, adhesives, and solvents in use,including manufacturers recommended mix ratio of components, VOCcontent and amount of each coatings, solvents, andadhesives used.•Records of key operating parameters of VOC emission control system.•Keep records for five years and make them available to the APCO uponrequest.•Requires continuous parameter monitoring for all capture.•Specifies the provisions for demonstrating compliance (based on rolling 12-month averageHAP emission rate) with the applicable HAP emissionlimit.•Submit Initial Notification within 120 days of start-up or 5/28/2003, whichever is later.•Submit Notification of Intent to conduct Performance Test at least 60 days prior to the test.•Submit performance test report within 60 days after completing the test.•Submit Notification of Compliance Status within 30days after the initial compliance period(the first 12 months after compliance date).•Submit semiannual compliance reports due on July 31 and January 31.•Keep records of reported information and all otherinformation necessary to documentcompliance for five years.ComplianceDeadlinesSix months after rule amendments adoption date.•Compliance date is 5/28/2006 for existing sources.•Compliance date is the initial start-up or 5/28/2003, whichever is later, for new orreconstructed sources.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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B-12 Final Staff Report with Appendices for Proposed

Amendments to Rule 4603 and Rule 4606 This page intentionally blank.Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4606 SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

FINAL STAFF REPORT

Proposed Amendments to: Rule 4603 (Surface Coating of Metal Parts and Produ cts)

Rule 4606 (Wood Products Coating Operations)

October 16, 2008

Prepared by: Joven R. Nazareno, Senior Air Quality Engineer

Reviewed by: George Heinen, Supervising Air Quality Engineer

Errol Villegas, Planning Manager

I. SUMMARY

A. Reasons for Rule Development and Implementation

The San Joaquin Valley Air Basin (SJVAB) is a conti nuous inter-mountain valley comprised of eight counties in the southern portion of the San Joaquin Valley of California: Fresno, Kings, Madera, Merced, San Joaq uin, Stanislaus, Tulare, and the Valley portion of Kern. The SJVAB is approximately 250 miles long, averages 80 miles wide, and is partially enclosed by the Coast Mounta in range on the west, the Tehachapi Mountains on the south, and the Sierra Nevada range on the east. These surrounding mountains trap pollution. Low wind speeds combined with low-lying inversion layers in

the winter create a climate conducive to the format ion of high particulate matter (PM) concentrations. The region’s hot, dry summers are conducive to ozone formation.

The SJVAB is currently designated as nonattainment for the national ambient air quality standard (NAAQS) for particulate matter 2.5 microns in diameter or less (PM2.5) and serious nonattainment for the eight-hour ozone NAAQ S. Prior to the United States Environmental Protection Agency’s (EPA’s) implement ation of the eight-hour ozone standard, the SJVAB was also classified as an extre me nonattainment area for the onehour ozone NAAQS. Although EPA revoked the one-hou r ozone NAAQS, the San Joaquin Valley Air Pollution Control District (Dist rict) is still required to meet certain requirements mandated by the federal Clean Air Act related to the extreme designation. In addition to being classified as nonattainment of federal air standards, SJVAB is

classified as severe nonattainment for the Californ ia ozone air quality standard and nonattainment for the California air quality standa rd for particulate matter ten microns in diameter or smaller (PM10).

The federal Clean Air Act (CAA) Section 172(c) prov ides that state implementation plans (SIPs) for nonattainment areas must include R easonably Available Control Technology (RACT) and Reasonably Available Control Measures (RACM), for sourcesSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4603 and Rule 4606 of emissions. Section 182(b)(2)(A) provides that f or certain nonattainment areas, states

must revise their SIPs to include RACT for each cat egory of volatile organic compounds (VOC) sources covered by Control Techniques Guideli nes (CTG) documents between November 15, 1990 and the date of attainment.

The United States Environmental Protection Agency ( EPA) defines RACT as “the lowest emission limitation that a particular source is capable of meeting by the application of control technology that is reasonabl y available considering technological and economic feasibility. 44 FR 53761 (September 17 , 1979). In subsequent Federal Register notices, EPA has addressed how states can meet the RACT requirements of the CAA. The CTG is intended to provide State and local air pollution control authorities such as San Joaquin Valley Unified Air Pollution Control District (District) information that should assist in determining RACT standards.

In September 2006, EPA issued a CTG for Flat Wood P aneling Coatings. In October 2007, EPA issued a CTG for Large Appliance Coatings , and a CTG for Metal Furniture Coatings. District staff considers the recommended controls in the CTGs constitute RACT as well as RACM for these source categories. The CTGs contains VOC content limits for coatings, VOC control device efficiency, and work practice standards to reduce VOC emissions from such coating operations. The CT G standards are discussed in Section III of this Draft Staff Report.

B. Description of the Rule Development Project

The purpose of this rule development project is to implement RACT and RACM by amending Rule 4603 (Surface Coating of Metal Parts and Products) and Rule 4606 (Wood Products Coating Operations). To accomplish this, the emission control standards recommended in the CTG for Large Applianc es Coatings, and the CTG for Metal Furniture Coatings would be included in Rule 4603. The emission control standards in the CTG for Flat Wood Paneling Coating s would be included in Rule 4606.

II. BACKGROUND

A. Existing Rule 4603 (Surface Coating of Metal Par ts and Products)

Rule 4603 was adopted in April 11, 1991. The rule has been amended several times, most recently on September 20, 2007. The rule appl ies to coating of metal parts and products and to the solvent cleaning process associ ated with coating operations. The purpose of the rule is to limit VOC emissions f rom coating of metal parts and products, and from organic cleaning, storage and di sposal of solvents and waste solvent materials associated with such coating.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4603 and Rule 4606 Rule 4603 allows certain exemptions from the rule o r from the coating VOC content limits. For example, a facility is exempt from the VOC content limits of the rule if the amount of coatings used does not exceed a total of 55 gallons of non-compliant coatings per rolling consecutive 365-day period, pr ovided the operator complies with the coating application methods and administrative requirements such as recordkeeping. Also coating operations that are su bject to other District coating rules such as Rule 4661 (Organic Solvents), Rule 4602 (Mo tor vehicle and Mobile Equipment Coating Operations), Rule 4612 (Motor Vehicle and M obile Equipment Operations Phase II), and Rule 4605 (Aerospace Assembly and Co mponent Manufacturing Operations) Rule 4604 (Can and Coil Coating Operati ons). Additional exemptions from the rule includes coating operation involving touch -up and repair, polyester resin operations and the application of polyester resin t o metal parts and products. The rule also contains certain exemptions for solvent cleani ng operations.

Rule 4603 establishes VOC content limits for coatin gs used in the manufacture and fabrication of metal parts and products. The gener al VOC limits for baked coating and for air-dried coating is 275 grams per liter (2.3 p ounds/gallon) and 340 grams/liter (2.8 pounds/gallon, respectively. Both limits are expre ssed weight of VOC/volume of coating, less water and less exempt compounds, as a pplied. The rule also establishes VOC limits for specialty coatings ranging from 360 grams/liter (3.0 pounds/gallon) to 880 grams/liter (7.3 pounds/gallon) depending on th e category of coating. Specialty coating category includes camouflage, extreme perfo rmance, heat resistant, high gloss, high performance architectural, high temperature, m etallic topcoat, pretreatment primer, silicone release, solar absorbent, and solid film l ubricant.

In lieu of complying with the coating VOC limits, a n operator may use an APCOapproved VOC emission control system provided it is under District permit, has an overall capture and control efficiency of at least 90 percent by weight, and the emissions resulting from the use of the control sys tem would not result in emissions in

excess of those that would have been achieved had t he operator complied with the VOC content limits of the coating or solvents. In addition to the coatings VOC limits, the rule also include provisions for coating applic ation methods, which include electrostatic application, electrodeposition, high- volume, low-pressure (HVLP) spray equipment, flow coating, roll coating dip coating, brush coating or other application method demonstrated to the District as capable of a chieving at least 65 percent transfer efficiency.

Rule 4603 establishes the VOC content limits for or ganic solvent cleaning materials. Until September 20, 2008, the VOC content limit of organic cleaning solvents range from 50 grams/liter (0.42 pound/gallon) to 550 gram s/liter (4.6 pounds/gallon) depending on the type of cleaning operation. These limits would drop to 25 grams/liter (0.21 pound/gallon) for all cleaning categories eff ective on and after September 21,

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Proposed Amendments to Rule 4603 and Rule 4606 B. Existing Rule 4606 (Wood Products Coating Operat ions)

Rule 4606 was adopted on December 19, 1991. The ru le has undergone several amendments with the last occurring on September 20, 2007. The purpose of the rule is to limit the emissions of VOC from wood products co ating operations, and from organic solvent cleaning, storage and disposal of solvents and waste solvent materials associated with such coating operations. The rule applies to coating of wood products, including furniture, cabinets, and custom replica. The rule define wood products as “objects such as cabinets (kitchen, bath, and vanit y), tables, chairs, beds, sofas, doors, trims, containers, tools, ladders, art objects, and any other objects made of solid wood and/or wood composition and/or of simulated wood ma terial used in combination with solid wood or wood composition.”

Rule 4606 allows certain exemptions from the rule o r from the coating VOC content limits. For example, the rule exempts aerosol-spra y coatings for touch and repair, stationary source that use a total of less than 20 gallons of coating per year in all wood products coating operations, application of coating s by template in order to add designs, letters, or numbers to wood products, coat ings to wooden musical instruments, and residential noncommercial operation. Also, the rule also exempts specific finishes such as crackle lacquers, faux finishes, imitation wood grain, and leaf finishes, refinishing, replacement, and custom replica furnit ure coating operation is also exempt

from the rule.

Rule 4606 establishes the coating VOC limits for wo od products that are not exempt from the rule. The VOC limits range from 275 grams /liter (3.3 pounds/gallon) to 750 grams/liter (6.3 pounds/gallon) depending on the co ating category. The VOC limit is expressed in weight of VOC per volume of coating, l ess water and less exempt compounds, as applied. The VOC limits for low-soli ds stain and for stripper is 120 grams/liter (1.0 pound/gallon) and 350 grams/liter (2.9 pounds/gallon), respectively. These limits are expressed in weight of VOC per vol ume of material. In lieu of complying with the coating VOC limits, an operator may use an APCO-approved VOC emission control system provided it is under Distri ct permit, has an overall capture and control efficiency of at least 85 percent by weight , and the emissions resulting from the use of the control system would not result in emiss ions in excess of those that would have been achieved had the operator complied with t he VOC content limits of the coating or solvents.

Rule 4606 establishes the VOC content limits for or ganic solvent cleaning materials. Until September 20, 2008, the VOC content limit of organic cleaning solvents range from 50 grams/liter (0.42 pound/gallon) to 550 gram s/liter (4.6 pounds/gallon) depending on the type of cleaning operation. These limits would drop to 25 grams/liter (0.21 pound/gallon) for all cleaning categories eff ective on and after September 21,

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5 Final Staff Report with Appendices for
Proposed Amendments to Rule 4603 and Rule 4606 For detailed requirements, please refer to the curr ent Rules 4603 and 4606, which are available on the District’s website at www.valleyai r.org.

III. PROPOSED CHANGES TO RULE 4603 AND RULE 4606

A. CTG for Large Appliance Coatings

In September 2007, EPA issued the CTG for large app liance coatings. The CTG applies to each large appliance coating operations, including related cleaning activities, at the facility that are equal to or exceed 15 poun ds per day, or an equivalent level such as 3 tons per 12-month rolling period, before consi deration of controls. Large appliance part is defined as any organic surface-coated metal , lid, door, casing, panel, or other interior or exterior metal part or accessory that i s assembled to form a large appliance product. Large appliance product is defined as any organic-surface coated metal range, oven, microwave, refrigerator, freezer, wash er, dryer, dishwasher, water heater, or trash compactor manufactured for household, comm ercial or recreational use. The following discussions are excerpts from the provisi ons of the CTG:

Process Description and Sources of VOC Emissions

Large appliance coatings include, but are not limit ed to materials referred to as paint, topcoats, basecoats, primers, enamels, and adhesive s used in the manufacture of large appliance parts or products. Coatings are applied using different methods such as air atomized spraying and airless spraying, dip coating , electrodeposition, and flow coating. In a typical liquid spray and dip coating operation s, the coated parts/products move from the coating application area through a flash-o f area where solvents in the coating begin to evaporate slowly, thus avoiding bubbling o f the coating while it is curing in the oven. After the typical coating operation, large ap pliance products are dried and cured using heated dryers or by air drying. Touch-up ope rations are performed using manual air spray guns and a lacquer base coating, which ha s good drying characteristics that allow for shorter drying times.

VOC emissions from large appliance coating processe s result from the evaporation of the coating components and cleaning materials. Dif ferent types of low-VOC coatings are available for large appliance parts and product s. These coatings include: powder coatings, waterborne coatings, higher solids coatin gs, and ultraviolet coatings.

Available Controls for VOC Emissions from Coatings

Two general types of emission control techniques fo r reducing VOC emissions from large appliance coatings are pollution prevention m easures and emission capture and add-on control systems. Pollution prevention measu res include coating product substitution/reformulation and work practices to re duce emissions. In addition toSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4603 and Rule 4606 pollution prevention measures, emissions can be red uced by the use of capture system in conjunction with add-on control systems (e.g., t hermal oxidizer or carbon adsorption) that destroy or recover VOC in the exhaust streams.

Emission Limits Based on Low-VOC Coatings

The CTG recommends the VOC limits for coatings as s hown in Table 1.

Table 1 – VOC Limit, mass of VOC/volume of coating, as applied

excluding water and exempt compounds

VOC Limit

Baked Air-dried Coating Type

kg/l lb/gal kg/l lb/gal General, one component 0.275 2.3 0.275 2.3 General, multi-component 0.275 2.3 0.340 2.8 Extreme High Gloss 0.360 3.0 0.340 2.8 Extreme high performance 0.360 3.0 0.420 3.5

Heat resistant 0.360 3.0 0.420 3.5

Metallic 0.420 3.5 0.420 3.5 Pretreatment coating 0.420 3.5 0.420 3.5

Solar absorbent 0.360 3.0 0.420 3.5

The CTG recommends exempting stencil coatings, safe ty-indicating coatings, solid-film lubricants, electric-insulating and thermal-conduct ing coatings, touch-up and repair coatings, and coating application utilizing hand-he ld aerosols

If product performance or other needs require the u se of high-VOC materials than those that would meet the recommended VOC limits, a facil ity could choose to use add-on control equipment to meet an overall control effici ency of 90 percent.

The CTG establishes work practice standards to redu ce VOC emissions. The standards include: storing all VOC coatings, thinne rs, and cleaning materials in closed containers, minimizing spills of VOC-containing coa tings, thinners, cleaning spills immediately, conveying VOC-containing materials in closed containers or pipes, closing mixing vessels which contain VOC coatings and other materials except when specifically in use, and minimizing emissions of VO C during cleaning of storage, mixing, and conveying equipment.

B. CTG for Metal Furniture Coatings

In September 2007, EPA issued the CTG for metal fur niture coatings. The CTG applies to each metal furniture coating operations at a facility where the total actual VOC emissions are equal to or exceed 15 pounds per day, or an equivalent level suchSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4603 and Rule 4606 as 3 tons per 12-month rolling period, before consi deration of controls. The CTG does not recommend control approaches for facilities tha t emit below this level because of the very small VOC emissions reductions that could be achieved. The following discussions are excerpts from the provisions contai ned in the CTG:

Process Description and Sources of VOC Emissions

A metal furniture is the furniture or components of furniture constructed either entirely or partially from metal. These include, but are not l imited to, the following products: household, office, institutional, laboratory, hospi tal, public building, restaurant, barber and beauty shop, dental furniture, as well as compo nents of these products. Metal Furniture also includes office and store fixtures, partitions, shelving, lockers, lamps and lighting fixtures, and wastebaskets. Metal furnitu re coatings include paints and adhesives and typically applied without a primer.

Metal furniture manufacturing process involves the following operations: (a) raw material preparation; (b) surface preparation; (c) coating and adhesive application; and (d) assembly. Raw material preparation and assembl y operations do not involve any VOC emissions. Primarily, the VOC emissions are ge nerated from process operations involving surface preparation, coating application, and cleaning activities that use VOCcontaining materials (e.g., coatings, thinners, and solvent-containing cleaning materials). The primary source of VOC emissions fr om metal furniture coating operation occur during the coating application proc ess, flash-off, and drying/curing of the coatings. The remainder of the emissions comes from mixing and thinning of the coatings as well as during cleaning operations.

Available Controls for VOC Emissions from Coatings

The two general emission control techniques for red ucing VOC emissions from metal furniture coating operations are: (1) pollution pr evention measures; (2) emission capture and add-on control systems. Pollution control measures include product substitu tion and reformulation, work practice procedures, and equipment substitution. VOC emissi ons can be reduced by using low VOC coatings such as powder coatings, higher solids coatings, waterborne coatings, and ultraviolet coatings. Using low-VOC cleaning m aterials also reduce VOC emissions during cleaning activities. Additionally, emission s can be minimized by using work practice procedures such as reducing coating wastes and using efficient coating application equipment that increases the coating tr ansfer efficiency

VOC emissions from coating operations can also be r educed by the use of capture systems in conjunction with add-on control device t hat either destroy or recover the VOC in the exhaust streams. Capture systems includ e hoods and enclosures to collect the solvent-laden air from the process vents or fug itive emissions from flash-off areas and then directing the captured air to a control de vice for destruction or recovery.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4603 and Rule 4606 Spray booths and ovens are the primary components o f the capture system. Add-on control systems include such devices as thermal oxi dizers, catalytic oxidizers, and

carbon adsorbers.

Emission Limits Based on Low-VOC Coatings

The CTG recommends the VOC limits for coatings as s hown in Tables 2.

Table 2 – VOC Limit, mass of VOC/volume of coating, as applied

excluding water and exempt compounds

Baked Air-Dried Coating Type kg/l lb/gal kg/l lb/gal General, One Component kg/l lb/gal 0.275 2.3 General, Multi-Component 0.275 2.3 0.340 2.8 Extreme High Gloss 0.275 2.3 0.340 2.8

Extreme Performance 0.360 3.0 0.420 3.5

Heat Resistant 0.360 3.0 0.420 3.5

Metallic 0.360 3.0 0.420 3.5 Pretreatment Coatings 0.420 3.5 0.420 3.5

Solar Absorbent 0.420 3.5 0.420 3.5

The CTG recommends exempting stencil coatings, safe ty-indicating coatings, solid-film lubricants, electric-insulating and thermal-conduct ing coatings, touch-up and repair coatings, and coating application utilizing hand-he ld aerosols

If product performance or other needs require the u se of high-VOC materials than those that would meet the recommended VOC limits, a facil ity could choose to use add-on control equipment to meet an overall control effici ency of 90 percent.

The CTG establishes work practice standards to redu ce VOC emissions. The standards include: storing all VOC coatings, thinne rs, and cleaning materials in closed containers, minimizing spills of VOC-containing coa tings, thinners, cleaning spills immediately, conveying VOC-containing materials in closed containers or pipes, closing mixing vessels which contain VOC coatings and other materials except when specifically in use, and minimizing emissions of VO C during cleaning of storage, mixing, and conveying equipment.

C. Proposed Amendments to Rule 4603

Affected Sources

Based on research of the District’s permit database and observations of District Compliance Division inspectors, staff found that th ere are only two permitted facilitiesSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4603 and Rule 4606 which perform coating operations during manufacturi ng or fabricating cooling towers and cooling units, and one company that performs co ating on beverage vending machines (similar to refrigerators) that are consid ered as large appliance parts or products coating operations. The three affected fa cilities shown in Table 3 are already in compliance with the proposed coating VOC limits as shown in Table 1.

There are eight permitted metal furniture coating f acilities in the District as shown in Table 4. Four of these facilities are subject to t he CTG because their coating operation emissions exceed the 3 tons of VOC per 12-month rol ling period applicability threshold. The four facilities subject to the CTG emissions ap plicability threshold are already using coatings that comply with the proposed VOC content limits. The other four facilities emit less than the CTG emission applicability threshold so they are not subject to the proposed new limits even though they are already us ing compliant coatings. One of the total eight metal furniture coating facilities is e xempt from the CTG or Rule 4603 requirements because it is performing only touch an d repair coating operation of metal

furniture.

Table 3 – Permitted Large Appliances Coating Facili ties in the District

Facility Name CTG VOC

Limit airdried (lb/gal) Rule 4603

limit air-dried (lb/gal) VOC of

coating in use

air-dried (lb/gal) Compliance

with CTG

Limits Coating

Operation

VOC Emission (lb/day)

Baltimore

Aircoil of

California 2.3 2.8 <1% by weight powder coating N/A 3 lb/day (not subject to CTG)

2.3 2.8 1 yes

Evapco West 2.3 2.8 1.5 yes 49 lb/day (subject CTG) Pepsi Cola Bottling Company 2.3 (onecomponent coating)2.8 (multicomponent coating) 2.8 2.8 (multicomponent coating) yes 54.7 lb/day (subject to CTG)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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Proposed Amendments to Rule 4603 and Rule 4606 Table 4 – Permitted Metal Furniture Coating Facilit ies in the District

Facility Name CTG VOC

Limit airdried (lb/gal) Rule 4603

limit air-dried (lb/gal) VOC of

coating in use

air-dried (lb/gal) Compliance

with CTG

Limits Coating

Operation

VOC Emission (lb/day)

California State Prison 2.3 2.8 1.03 yes >15 lb/day (subject to CTG)

Sturdy Safe 2.3 2.8 2.6 N/A 5 lb/day (not subject to CTG)

Edsal Sandersky Corp. 2.3 2.8 <1% by weight powder coating yes 42 lb/day (subject to CTG)

Elements by Grapevine 2.3 2.8 2.1 yes 40 lb/day (subject to CTG)

Lodi Metal
Tech, Inc. 2.3 2.8 <1% by weight powder coating yes 49.3 (subject to CTG)

Ward

Brothers

Office

Furniture 2.3 2.8 2.25 N/A 11 lb/day (not subject to

CTG

2.3 2.8 2.57 N/A Levitt Weaver

Inc.

2.3 2.8 2.3 4.9 lb/day (not subject to CTG)

Frederick Antique

Restoration 2.3 2.8 2.1 exempt touch-up and repair exempt from

CTG and Rule

4603

The following are proposed amendments to Rule 4603:

• Section 1.0 (Purpose) and Section 2.0 (Applicabili ty)

These sections would be modified to clarify that la rge appliances parts or products, and metal furniture coating operations are subject to t he rule.

• Section 3.0 (Definitions)

The definitions of extreme high gloss, large applia nce part, large appliance product, metal furniture, multi-component coating, and one-c omponent coating would be added into the rule. The existing definition of extreme performance coating would be modified for clarity. As recommended by EPA, the existing n ames “metallic topcoat”, “high gloss”SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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11 Final Staff Report with Appendices for
Proposed Amendments to Rule 4603 and Rule 4606 and “pretreatment wash primer” in Table 1 would be changes to “metallic coating” and “extreme high gloss” and “pretreatment coating”, re spectively, for consistency with names of the coatings used in Table 2. The new or modified definitions would improve the clarity, effectiveness, and enforceability of t he rule.

• Section 5.2 (Specialty Coating Limits)

This section would be modified to clarify that the current specialty coating VOC limits in Table 1 apply to all metal parts and products, exce pt for coating operations on large appliance parts or products, and metal furniture th at are subject to new Section 5.4 as

discussed below.

• New Section 5.4 and New Table 2 (Coating Limits fo r Large Appliance Parts or Products, and Metal Furniture)

New Section 5.4.1 and new Table 2 would specify the coating limits for large appliance parts or products coating operations, or metal furn iture coating operations whose VOC emissions, including related cleaning activities, a t a stationary source are equal to or greater than 3.0 tons of VOC per 12-month rolling p eriod, before consideration of

controls. The VOC content limits in Table 2 of the rule range from 275 grams/liter (2.3 pounds/gallon) to 420 grams/liter (3.5 pounds/gallo n) of coating, less water and exempt compounds, as applied, depending on the type of coa ting. The coatings VOC content

limits in Table 2 of the rule are consistent with t he CTG limits discussed in Sections IIIA and IIIB of this staff report. In lieu of complyin g with Table 2 VOC limits, an operator use an APCO-approved VOC emission control system th at meets the requirements specified in the rule.

The new Table 2 coating VOC content limits are effe ctive on and after April 16, 2009. Since operators of existing large appliance parts a nd products coating operations and metal furniture coating operations are already usin g coatings that meet the proposed VOC content limits a longer compliance deadline is not needed.

Operators of large appliance parts or products coat ing operations, or metal furniture coating operations would need to keep the applicabl e records required by Section 6.2

of the rule to demonstrate if the VOC emissions fro m all large appliance parts or products coating operations, or metal furniture coa ting operations, including related cleaning activities, are equal to or greater than 3 tons of VOC per 12-month rolling period, thereby making the source operation subject to Table 2 limits.

In the June 24, 2008 version of Draft rule 4603, Di strict staff previously proposed that large appliance parts and products coating operatio ns and metal furniture coating operations at a stationary sources where the total actual VOC emissions are equal to or greater than 15 pounds of VOC per day or 3 tons of VOC per 12-month rolling period would be subject to the proposed new VOC content li mits in Table 2 of the draft rule. InSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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12 Final Staff Report with Appendices for
Proposed Amendments to Rule 4603 and Rule 4606 order to eliminate ambiguity in enforcing the rule because of previously proposed dual threshold, District staff would propose to use the 3 tons of VOC per 12-month rolling period threshold and delete the 15 pound of VOC per day threshold.

In the June 24, 2008 version of Draft Rule 4603, Di strict staff previously proposed a new Section 5.3.3 which stated that Table 2 coating VOC content limits in the rule would not apply to stencil coatings, safety-indicat ing coatings, solid-film lubricants, electric-insulating and thermal coatings, and coati ng application using hand-held aerosol cans performed at a stationary source whose VOC emissions from all large appliance parts or products coating operations or m etal furniture coating operations, including related cleaning activities, are equal to or greater than 3 tons of VOC per 12- month rolling period. But stationary sources whose emissions are less than this threshold would have been required to comply with t he existing limits in Section 5.1 and Section 5.2 Table 1 for stencil coatings, safety-in dicating coatings, solid-film lubricants, electric-insulating and thermal coatings, and coati ng application using hand-held aerosol cans. EPA commented that the previously pr oposed provision seems counterintuitive that larger facilities would need exemptions from the requirements that apply to smaller facilities. District staff reeval uated the previously proposed Section 5.3.3 and determined that EPA raised legitimate con cern. Therefore, in response to EPA’s concern, previously proposed Section 5.3.3 wo uld be deleted because the proposed provision would essentially relax the curr ent SIP-approved Rule 4603 since the existing rule does not exempt stencil coatings, safety-indicating coatings, solid-film lubricants, electric-insulating and thermal coating s, and coating application using handheld aerosol cans.

New Section 5.4.2 would specify that large applianc e parts or products coating operations, or metal furniture coating operations w hose VOC emissions, including related cleaning activities, at a stationary source are less than 3.0 tons per 12-month rolling period, before consideration of controls, a t a stationary source would need to comply with the existing VOC content limits of coat ings specified in Sections 5.1 and 5.2. This new provision is necessary to prevent re laxation of an existing SIP-approved

rule since sources whose emissions are less than 3. 0 tons per 12-month rolling period are currently subject to the existing VOC limits.

• Section 5.5.4 (VOC Emission Control System Require ment)

To enhance the effectiveness and enforceability of the rule, a calculation equation would be included to determine if the minimum required ov erall capture and control efficiency of an emission control system is at equivalent or grea ter level of VOC reduction as would be achieved using compliant materials, or work practic es.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4603 and Rule 4606 Octobe r 16, 2008

13 Final Staff Report with Appendices for
Proposed Amendments to Rule 4603 and Rule 4606 • New Section 5.6 (Work Practice Standards)

New Section 5.6 would include provisions for work p ractice standards that apply to large appliance parts and products, and metal furniture c oating operations, including cleaning activities, where the total VOC emissions are equal to or greater than 3.0 tons per 12- month rolling period. The work practice standards are consistent with the CTG as discussed in Section IIIA of the staff report.

• Section 6.3 (Test Methods)

Section 6.3 specifies the allowable test methods th at must be used to demonstrate compliance with the rule requirements. Section 6.3 would be revised to allow operators to use alternate test methods other than specified in the rule provided the test methods have been approved by the APCO, ARB, and EPA. This chan ge would provide operators flexibility to use other test methods that are equa lly efficient and accurate, but less expensive than the methods prescribed by the rule.

• Section 6.3.7 (Determination of Overall Capture an d Control Efficiency)

As recommended by EPA, two equations would be added in Section 6.3.7 for calculating the capture efficiency and the control efficiency o f a VOC emission control system. District staff included the same calculation equati ons from SCAQMD Rule 1136 (Wood Products Coatings) as recommended by EPA.

D. CTG for Flat Wood Paneling Coatings

In September 2006, EPA issued the CTG for flat wood paneling coatings. The CTG applies to facilities that apply flat wood paneling coatings that emit at least 15 pounds of VOC per day before consideration of controls. Flat wood paneling coatings means wood paneling products that are interior, exterior or tileboard (class I hardboard) panel to which protective, decorative, functional materia l or layer has been applied. EPA has determined that the 15 pounds of VOC per day applic ability threshold is appropriate and is consistent with Section 183(e) of the CAA. The following discussions are excerpts from the provisions contained in the CTG:

Process Description and Sources of VOC Emissions

Types of Flat Wood Paneling

The following discussions are selected excerpts fro m the CTG:

Flat wood paneling products are used in constructio n and can be classified into three product types: decorative interior panels, exterior siding, and tileboard.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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14 Final Staff Report with Appendices for
Proposed Amendments to Rule 4603 and Rule 4606 Decorative interior panels are hardboard, plywood, medium density fiberboard (MDF), or particleboard, that is usually grooved, embossed , and/or sometimes grain printed to resemble various wood species. Coated board used fo r interior panels are subject to industry performance specifications (consensus stan dards). These standards require multiple coating layers and coating steps. In order to maintain production speeds the use of solvents that evaporate without leaving cure blisters or residual solvent in the coating film or substrate are necessary. Interior p anels are typically manufactured at the same facilities as tileboard, but in much smaller q uantities.

Exterior siding may be made of solid wood, hardboar d, or waferboard. Siding made of solid wood and hardboard is typically primed at the manufacturing facility and finished in the field. Field applied coatings are not subject t o this CTG. Finishing of solid wood and hardboard may be performed during manufacturing; ho wever, this occurs on a limited basis. This industry segment involves exterior prod ucts that must have coatings able to withstand extreme and long-term weather conditions. These requirements impact the amount of VOC emitted from the coating of exterior siding.

Tileboard is a premium interior wall paneling produ ct made of hardboard that is used in high moisture areas such as kitchens and bathrooms. Tileboard must meet the specifications for Class I hardboard as approved by the American National Standards Institute (ANSI). The ANSI standard specifies requi rements and test methods for water absorption, thickness swelling, edge straightness, and moisture content. Tileboard has more stringent product performance requirements com pared to standard interior wall paneling.

Sources of VOC Emissions

Coatings are applied to flat wood paneling for thre e principal purposes: protection from moisture, temperature extremes, climate related haz ards, and from insect infestation; to improve appearance; and for surface modification (i .e., to enhance surfaces to make other coatings more effective). Releases of VOC occ ur during the coating process as the coatings are mixed or thinned, as they are appl ied to the substrate, and as they dry and the VOC within the coating evaporate into the a ir.

Coatings applied to flat wood paneling include fill ers, sealers, “groove” coats, primers, stains, basecoats, inks and topcoats. Most coatings are applied by direct roll coating, with filler being applied by reverse roll coating. Other coating methods include offset rotogravure, spray techniques, brush coating and cu rtain coating. A typical flat wood paneling coating line includes a succession of coat ing operations, which begins with mechanical alterations of the substrate (filling of holes, cutting of grooves, sanding, etc.), followed by the coating operations, and pack aging or stacking for shipment.

VOC emissions from a flat wood coating facility occ ur primarily at the coating line, with some emissions also occurring at paint mixing and s torage areas. To assist facilitiesSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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15 Final Staff Report with Appendices for
Proposed Amendments to Rule 4603 and Rule 4606 and regulatory agencies in estimating emissions, VO C emissions factors for conventional solvent based applied to interior prin ted panels are as follows (expressed as kilograms of VOC per 100 square meters coated): 3.0 for filler, 0.5 for sealer, 2.4 for basecoat, 0.3 for inks, and 1.8 for topcoats.

Available Controls to Meet the CTG Standards

• Low-VOC, waterborne coatings are generally availab le and are not produced and marketed specifically for flat wood paneling indust ry. Conversion to waterborne coatings can lower the VOC emissions greatly. Most coating operations are capable of converting to waterborne coatings.

• Ultraviolet Cure and Electron Beam Cure coatings i nvolve change in process, which is an alternative to using waterborne coatings. A VOC reduction of near 100 percent is achievable through the use of such coatings.

• Add-on Controls such as thermal oxidizers or carbo n adsorption could be use to reduce emissions especially for applications where performance requirements or other needs dictate the use of high-VOC coatings th at do not meet the CTG coating

VOC content limits.

Recommended Control Options

EPA recommends emission limits for inks, coatings a nd adhesives used by the flat wood paneling coating facilities as well as work pr actices for cleaning materials used. The recommended emissions limits for inks, coatings , and adhesives can be achieved either by using materials with VOC contents low eno ugh to achieve the limits during application, or by reducing the amount of VOC emitt ed through the use of add-on controls. Table 5 summarizes the coating VOC conten t limits recommended in this

CTG.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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16 Final Staff Report with Appendices for
Proposed Amendments to Rule 4603 and Rule 4606 Table 5 – CTG VOC Limits for Flat Wood Paneling Coa ting Operations

Should Meet One of These Emission Limits: Surface Coatings, Inks, or Adhesives Applied to the Following Flat Wood Paneling Categories lb VOC per gallon material (grams VOC per liter material) [Excluding water and exempt compounds] lb VOC per

gallon solids (grams VOC per liter solids) Overall Control

Efficiency Using an

Add-On Control

Device:

Printed interior panels made of hardwood plywood, or thin particleboard 2.1 (250) 2.9 (350) 90%

Natural finish hardwood plywood panels 2.1 (250) 2.9 (350) 90%

Class II finishes on hardboard panels 2.1 (250) 2.9 (350) 90%
Tileboard 2.1 (250) 2.9 (350) 90% Exterior siding 2.1 (250) 2.9 (350) 90%

The CTG establishes work practice standards to redu ce VOC emissions from coating operations. The standards include the following re quirements:

• Storing all VOC-containing coatings, thinners, cle aning materials, and waste

materials in closed containers. The containers shal l remain closed at all times, except when specifically in use.

• Closing mixing vessels that contain VOC coatings a nd other materials, except when specifically in use.

• Minimizing spills of any VOC-containing materials and clean up spills immediately.

• Conveying VOC-containing materials in closed conta iners or pipes.

. There are 80 facilities in the United States that p roduce flat wood paneling products, per the 2002 National Emissions Inventory (NEI). Of the 80 facilities producing flat wood paneling products, 24 are located in ozone nonattai nment areas (based on the April 2006 designations) and meet the standards presented in this CTG. Of those 24 facilities one is in California, that one being in Placer Coun ty. Upon further research by the EPA two facilities were found in California that produc e flat wood paneling, both of them are

located in the South Coast District. Information on flat wood paneling coatings facilities

in the South Coast area of California was not conta ined in the 2002 NEI database, and was therefore left out of Table 7. However, no fla t wood paneling manufacturing company is located in the San Joaquin Valley Air Ba sin.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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17 Final Staff Report with Appendices for
Proposed Amendments to Rule 4603 and Rule 4606 EPA used the 2002 NEI as the source of emissions da ta and statistical information concerning the flat wood paneling industry as a who le. Plants are located throughout the United States, with the largest number of facil ities on the Pacific Coast and in the

Southern States. Table 6 summarizes where the flat wood paneling coating facilities are located, as well as the associated Local and State Requirements.

Table 6 - Flat Wood Paneling Coating Facilities in Current No nattainment Areas and

Associated State or Local Requirements (Based on 20 02 NEI)

Ozone

Nonattainment

Area Number

of

Facilities Product Applicability Applicable State

Emission Limit Alternative Control

Device Limits

Placer County (California) 1 1978 CTG Not applicable to exterior siding. <2.1 lb VOC per gallon of coating (excluding water) Overall control efficiency

of 90%

Michigan 1 Interior paneling. Not applicable to exterior siding, cabinetry, furniture or

tileboard. 1978 CTG Limits 1978 CTG Limits

North Carolina 1 1978 CTG Not applicable to exterior siding and

tileboard. 1978 CTG Limits 1978 CTG Limits

Ohio 1 No rule specific to flat wood, wood building products or tileboard. 1978 CTG Limits 1978 CTG Limits

South Carolina 1 Wood construction products for interior paneling. Not applicable to exterior siding and tileboard. 1978 CTG Limits 1978 CTG Limits

Texas 2 Interior paneling and tileboard. Not applicable to exterior siding. 1978 CTG Limits 1978 CTG Limits

Virginia 1 Interior panels Not applicable to exterior siding and

tileboard. 1978 CTG Limits 1978 CTG Limits

Indiana 3 Interior panels Not applicable to exterior siding and tileboard. 1978 CTG Limits 1978 CTG Limits

Tennessee 1 Interior paneling. Not applicable to exterior siding and tileboard. 1978 CTG Limits 1978 CTG Limits

Illinois 1 None None None

Pennsylvania 8 None None None

New Hampshire 2 None None None

Wisconsin 1 1978 CTG Limits Not applicable to exterior siding and

tileboard. 1978 CTG Limits 1978 CTG LimitsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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18 Final Staff Report with Appendices for
Proposed Amendments to Rule 4603 and Rule 4606 E. Proposed Amendments to Rule 4606

Affected Sources

Based on research of the District’s permit database and observations of District Compliance Division inspectors, staff concluded tha t there is no flat wood paneling manufacturing in the San Joaquin Valley at this tim e. This supports the information presented by EPA that there are no facilities withi n the boundaries of the District subject to this CTG. Although, there is no flat wood pane ling manufacturing and coating operation in the District, staff is proposing to am end Rule 4606 to regulate the emissions from this source category if such a facil ity starts operation in the future within

the District.

The following are proposed amendments to Rule 4606:

• Section 1.0 (Purpose) and Section 2.0 (Applicabili ty)

These sections would be modified to clearly indicat e that the rule applies also to flat wood paneling coating operation instead of just woo d products coating operations. This clarification is necessary because the current defi nition in the rule for wood products does not specifically include flat wood paneling pr oducts.

• Section 3.0 (Definitions)

As recommended by EPA, the definitions of Class II hardboard panel finishes, exterior wood siding, flat wood paneling coating operations, flat wood paneling product, hardwood plywood, natural finish hardwood plywood p anel, panel, particleboard, printed interior panel, and tileboard would be included in Section 3.0. These definitions are

similar to the definitions indicated in EPA’s 1978 CTG for Factory Surface Coating of Flat Wood Paneling (EPA-450/2-78-032), Placer Count y APCD Rule 238 (Factory Coating of Flat Wood Paneling), and SCAQMD Rule 110 4 (Wood Flat Stock Coating Operations). These definitions would improve the c larity and effectiveness of the rule

since these terms are used in the rule.

• New Section 5.3 and New Table 3 (Flat Wood Coating Operation)

New Section 5.3 and new Table 3 would specify the c oating limits for flat wood paneling products coating whose VOC emissions, including rel ated cleaning activities, at a stationary source are at least 15 pounds per day be fore consideration of controls. Table 3 of the rule would specify that for all flat wood paneling product categories, the VOC content limit of the coating should not exceed 250 grams/liter (2.1 pounds/gallon) of coating, excluding water and exempt compounds, a s applied. Operators would need to keep applicable records required by Sections 6.2 , 6.4, and 6.5 to demonstrate if the VOC emissions from flat wood paneling products coat ing operation exceed 15 poundsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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19 Final Staff Report with Appendices for
Proposed Amendments to Rule 4603 and Rule 4606 per day of VOC emissions, thereby making the source operation subject to Table 3 limits. The new coating VOC content limit is effec tive on and after April 16, 2009.

New Section 5.3.2 would specify that flat wood pane ling products coating operations whose VOC emissions, including related cleaning act ivities, are less than 15 pounds per day, before consideration of controls at a stat ionary source would need to comply with the existing applicable coatings VOC content l imits specified in Sections 5.1 Tables 1 or 2 of the current rule. This new provision is necessary to prevent relaxation of an existing SIP-approved rule since such sources are c urrently subject to the existing rule

limits.

• New Section 5.4.4 (VOC Control System Efficiency f or Flat Wood Paneling Product Coating Operation):

Existing Section 5.3 (now renumbered Section 5.4), allows an operator to install and operate an APCO-approved VOC emission control syste m in lieu of complying with the coatings VOC content limits. Section 5.4 specifies the criteria for an APCO- approved control system. The current control efficiency for wood products coating operations is 85 percent. However, for flat wood paneling produc ts coating operations VOC control system, new Section 5.4.4 would specify an overall capture and control efficiency of at least 90 percent by weight.

• New Section 5.6 (Work Practice Standards for Flat Wood Paneling Product Coating Operation)

This new section would specify the work practice st andards for flat wood paneling product coating operations. The work practice stan dards are consistent with the CTG as discussed in Section IIIC of the staff report.

• Section 6.8.5 (Determination of Overall Capture an d Control Efficiency)

As recommended by EPA, two equations would be added for calculating the capture efficiency and the control efficiency of a VOC emis sion control system. These calculation equations are similar to the requirements of SCAQMD Rule 1136 (Wood Products Coatings).

• Compliance Schedule

The proposed amendments to Rule 4606 would become e ffective on and after April 16, 2009. Since there is no flat wood coating faciliti es currently operating in the San Joaquin Valley Air Basin, a longer compliance perio d is not needed.

Existing Section 7.1 allows an operator who becomes subject to the requirements of the rule through loss of exemption status allowed by Se ction 4.0 would need to be in fullSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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20 Final Staff Report with Appendices for
Proposed Amendments to Rule 4603 and Rule 4606 compliance with the rule with 12 months from the da te that an exemption status is lost. District staff is proposing to revise Section 7.1 t hat would require the operator to be in compliance with the rule requirements effective on and after the date that the exemption is lost.

IV. VOC EMISSION AND REDUCTIONS

The ARB emissions inventory database shows that the 2008 annual baseline emission (grown and controlled) from metal parts and product s coating operations is about 0.65 tons of VOC per day. As discussed in Section IIIB of the Final Draft Staff Report, there are three large appliance parts and products and ei ght metal furniture coating operations facilities currently operating in the Sa n Joaquin Valley that would be subject to the proposed amendments to Rule 4603. These faci lities are already using coatings that meet the proposed VOC content limits, therefor e no VOC emissions reduction would result from the proposed changes to Rule 4603

.

The ARB emissions inventory database shows that the 2008 annual baseline emission (grown and controlled) from wood products coating o perations is about 1.3 tons of VOC per day. As previously mentioned, there is no flat wood paneling product manufacturing facility currently operating in the San Joaquin Val ley Air Basin, therefore no VOC emissions reduction would result in the proposed am endments to Rule 4606.

V. COST EFFECTIVENESS AND SOCIOECONOMIC ANALYSES

Pursuant to California Health & Safety Code Section 40920.6(a), the District is required to analyze the cost effectiveness of new rules or rule amendments that implement Best Available Retrofit Control Technology (BARCT) or al l feasible measure. The proposed

amendments to Rule 4603 and Rule 4606 would add fed eral RACT requirements but not BARCT or all feasible measure, and are therefore no t subject to the cost effectiveness analysis mandate. It is important to mention that affected sources subject to the proposed changes to Rule 4603 are already using coa tings that comply with the proposed VOC limits, therefore there are no additional costs associated with the proposed
amendments. Furthermore, since there are no source s in the District that manufacture flat wood paneling products, the proposed amendment s to Rule 4606 would not impose additional compliance costs.

Pursuant to California Health & Safety Code Section 40728.5 (a) requires the District to perform an assessment of the socioeconomic impacts of the adoption, amendment, or repeal of a rule or regulation that significantly a ffect air quality or emission limitation. As discussed above, sources subject to the proposed ch anges to Rule 4603 are already using coatings that meet the proposed limits and th at there is no flat wood paneling products manufacturing facilities currently operati ng in the District, therefore the proposedSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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21 Final Staff Report with Appendices for
Proposed Amendments to Rule 4603 and Rule 4606 amendments are not expected to have any adverse imp act on the regional economy of the San Joaquin Valley.

VI. ENVIRONMENTAL IMPACTS

Pursuant to the California Environmental Quality Ac t (CEQA), staff investigated the possible environmental impacts of the proposed amen dments to Rule 4603 and Rule

4606. Based on the lack of evidence to the contrar y, District staff has concluded that the proposed amendments to the rules will not have any significant adverse effects on the environment. Staff recommends filing a Notice of E xemption under the provisions of Public Resource Code 15061 (b)(3).

VII. RULE CONSISTENCY ANALYSIS

As required by California Health & Safety Code Sect ion 40727.2, District staff prepared a rule consistency analysis that compares the eleme nts of amendments with the corresponding elements of other District rules, fed eral regulations and guidelines that apply to the same source category or type of equipm ent. District staff found that none of the proposed requirements of these rules would c onflict with federal rules, regulations, or policies covering similar stationar y sources. The rule consistency analysis is presented in Appendix B of the Final St aff Report.

VIII. RULE DEVELOPMENT PROCESS

As part of the rule development process, in June 20 08 District staff mailed copies of the proposed amendments to Rules 4603 and 4606 to affec ted sources, interested parties, the public, EPA and ARB to solicit their comments. In addition, the notice of the proposed amendments to the rules was also published in a general circulation newspaper in each of the eight San Joaquin Valley c ounties. The commenting deadline ended on July 24, 2008. Comments received during t he rule development process were incorporated into the rule amendments as appro priate. Comments received and District responses are discussed in Appendix A of t he Final Draft Staff Report dated September 18, 2008.

District staff submitted the proposed rules to the District Governing Board for adoption on October 16, 2008. The notice of the public hear ing for the proposed rules was published in a general circulation newspaper in eac h of the eight San Joaquin Valley counties and was mailed to affected source, interes ted parties, the public, EPA and ARB. The public notice solicited written comments to be submitted by mail, and it also identified the name and telephone number of the Dis trict staff who can answer questions and respond to comments. The commenting deadline ended on SeptemberSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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22 Final Staff Report with Appendices for
Proposed Amendments to Rule 4603 and Rule 4606 29, 2008. Comments received during the rule develo pment process were incorporated into the rule amendments as appropriate. Comments received and District responses are discussed in Appendix A of the Final Staff Repo rt dated October 16 16, 2008.

IX. REFERENCES

1. EPA CTG for Large Appliance Coatings (EPA 453/R- 07-004), September 2007.

2. EPA CTG for Metal Furniture Coatings (EPA 453/R- 07-005), September 2007.

3. EPA CTG for Flat Wood Paneling Coatings (EPA 453 /R-06-004), September

2006.

4. EPA 450/2-78-032 (Control of Volatile Organic E missions from Existing Stationary Sources, Volume VII: Factory Surface Coa ting of Flat Wood Paneling).

5. South Coast Air Quality Management District (SCA QMD) Rule 1104 (Wood Flat Stock Coating Operations).

6. SCAQMD Rule 1107 (Coating of Metal Parts and Pro ducts).

7. Placer County Air Pollution Control District Rul e 238 (Factory Coating of Flat Wood Paneling).