UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Placer County Air Pollution Control District, Rule 243, Polyester Resin Operations

Prepared by: David Grounds

Reviewed by: Andrew Steckel

January 1 4 , 2011RULE IDENTIFICATION

Agency: Placer County Air Pollution Control District (PCAPCD)

SIP Approved Rule : N/A

Subject of this TSD: Rule 243

– Polyester Resin Operations

Adopted

– April 10, 2003
Submitted

– December 7, 2010

RULE SUMMARY

– PCAPCD Rule 243, Polyester Resin Operations, is a rule designed to reduce the emissions of volatile organic compounds (VOCs) from polyester resin operations at each stage of the polye ster resin process. While Placer County originally adopted Rule 243 in 2003,
no version of this rule has been approved by EPA into the SIP. PCAPCD is designated as a severe

non

- attainment area for the federal 8

- hour ozone standard (69 FR 23858, April 30, 2004), and PCAPCD designed Rule 243 partly to address the requirements for ozone non

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

R ule 243 applies to any person who manufactures, sells, offers for sale or supplies polyester
resin for use in PCAPCD. The rule also applies to any person who uses polyester resins or uses a surface preparation solvent, cleanup solvent, or str ipper. The proposed rule is included as a VOC control measure in the Sacramento Area Regional Ozone Attainment Plan, which was adopted by the Board on December 20, 1994. Although the requirement for this rule is based on the Sacramento Area Regional Ozone Attainment Plan, PCAPCD applies the rule in all of Placer County. This maintains uniformity within the PCAPCD and avoids the need for multiple rules in the County.

There is only one permitted facility in Placer County affected by Rule 243. There are a num ber of small facilities, which are not currently required to obtain a permit but may be affected by the rule. Compliance is expected to be achieved by switching to a lower VOC resin. Emi ssions from fiberglass composite manufacturing were estimated to be 66 tons per year (tpy) in Placer County. This is equivalent to approximately 0.28 tons per day (tpd). This figure was reduced to 0.1 tpd after implementation of controls in the proposed rule.

Rule 243 generally includes:

S ections of A pplicability, D efinitions, S tandards, A dministrative R equirements,
M onitoring , Testing and R ecordkeeping.

C alculation formulas for Capture Efficiency, Control Device Efficiency, Emission Control System Efficiency, Grams of VOC per Liter of Material and Monomer Content.EPA EVALUATION CRITERIA

-

1. Enforceability

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

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

– PC A PCD believes that there are currently no major sources ( at least 25 tpy VOC ) of polyester resin operations
in PCAPCD that would require RACT implementation. While it appears RACT is not required, we have compared Rule 243 against analogous rules in other areas and relevant national guidance including : “ Control Techniques Guidelines for Industrial Cleaning Solvents” (EPA

- 453/R

- 06

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

- Density Polyethylene, Polypropy lene, and Polystyrene Resins” (EPA

- 450/3

- 83

- 008, 11/83), “Control of VOC Fugitive Emissions from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment” (EPA

- 450/3

- 83

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

453/R

- 08

- 004, 9/08), CARB’s RACT/BARCT guidance titled, “Organic Solvent Cleaning and Degreasing Operations” (July 18, 1991) . In addition, other state and local rules for this category were used to help evaluate the RACT requirements of C AA § 182(e).

3. SIP Relaxation

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

EPA EVALUATION

- The SIP submittal generally contains sufficient testing and recordkeeping requirements to satisfy enforcement requirements. The stringency of requirements in
submitted Rule 243 is also generally consistent with relevant guidance and analogous rules in
othe r areas that help define RACT. Therefore, while RACT may not be required for this source category, we believe that Rule 243 would implement RACT. Since no previous version of these requirements is already in the SIP, approval of this version only improves the SIP and does not relax the SIP in violation of CAA section 110(l) or 193.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 243 sufficient for EPA to propose less than full approval.

RECOMMENDATIONS

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

In Section 103.2, we recommend removing the partial exemption of 20 gallons per month for low usage of resin materials. Bay Area Air Quality Management Distr ict (BAAQMD) Regulation 8, Rule 50 does not have such an exemption.In Section 103.3, we recommend removing the partial exemption of 16 gallons per

month for low usage of cleaning materials. BAAQMD Regulation 8, Rule 50 does not have such an exemption, an d Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 465, Section 104 no longer has this exemption.

In Section 302, we recommend reducing resin and gel coat monomer content. See for example, BAAQMD Regulation 8, Rule 50, Section 301.6.

In Section 303.2, we recommend increas ing emission control system efficiency from a
minimum of 85% to at least 90%. See for example, SMAQMD Rule 465, Section 301.2.

In Section 304, we recommend lower ing cleaning materials from 1.7 to 0.21 pounds VOC per gallon. See for example SMAQMD Rule 465, Section 303.2.

In Section 502, we recommend retain ing all records on

- site for at least 5 years

, consistent with Title V requirements and to improve compliance and enforceability. See for example, SMAQMD Rule 465, Section 501.4.

EPA ACTION

- The submitted Rule 243 largely fulfills the relevant CAA §110 and part D requirements. EPA staff recommends approval of Rule 243 pursuant to CAA §110(k)(3) and §301(a).

REFERENCES

– PCAPCD Rule 243, “Polyester Resin Operations,” Adopted April 10, 2003

. PCAPCD Rule 243, Staff Report, March 27, 2003

. BAAQMD Regulation 8, Rule 50, “Polyester Resin Operations.” SMAQMD Rule 465, “Polyester Resin Operations.”