CALIFORNIA AIR RESOURCES BOARD



### AP CD/ A QMD RULE EVALUATION FORM - Page 1

I. GENERAL INFORMATION

District: South Coast Air Quality Management District Rule No: 1162

Date Adopted/Amended/Rescinded: Amended 07/08/05

Rule Title: Polyester Resin Operations

Date Submitted to ARB: March 6, 200 9

If an Amended Rule, Date Last Amended (or Adopted): July 9, 2004

Is the rule intended to be sent to the U.S. EPA as a SIP Revision? ( x ) Yes ( ) No. If NO, do not complete remainder of form.

District Contact: Helmy Sultan Phone Number: (909) 396-2362

Narrative Summary of New Rule or Rule Changes: ( ) New Rule ( x ) Amended Rule

Summary of Rule 1162 Amendments

(I) November 9, 2001 Amendment

Rule 1162 – Polyester Resin Operations was amended to further reduce VOC and hazardous air pollutant (HAP) emissions from compos ite manufacturing operations by implementing Pollution Prevention (P2) technologies. The am endments required the use of lower monomer content of gel coat and resin materials, inert fillers and vapor suppressants, and less polluting nonatomizing application technologies.

((II) July 11, 2003 Amendment

Rule 1162 was amended to postpone the effective date for the nonatomizing spray application technique of gel coats requirement from Ju ly 1, 2003 to July 1, 2004. The amendment was necessary to allow for completion of testing to establish a more appropriate definition of the nonatomizing spray application techniques of gel coats.

(III) July 9, 2004 Amendment

Rule 1162 was amended to further postpone the effective date for the nonatomizing spray application of gel coats from July 1, 2004 to July 1, 2005 to allow for the completion of the AQMD Gel Coat Testing Program. In addition, the amendments added a modified U.S.EPA definition of nonatomizing application technique of gel coats as found In the National Emissions Standards of Hazardous Air Pollutants (NESHAP) for Reinforced Plastic Composite Production (40 CFR, Part 63, Subpart WWWW).

(IV) July 8, 2005 Amendment

The recent amendment of Rule 1162 removed the requirement of applying gel coat solely with the nonatomizing spray application techniques, established a list of acceptable low emitting application techniques for gel coat, and clarified the use of hand-held atomized spay application equipment for gel coat touch-up and repair. In addition, the proposed amendments added a transfer efficiency exemption for limited usage of pin striping gel coat applications.CALIFORNIA AIR RESOURCES BOARD



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Pollutant(s) Regulated by the Rule (Circle): ROG NOx SO2 CO TAC (name): ROG (Such as Styrene and Methylmethacrylate)

II. EFFECT ON EMISSIONS

Complete this section ONLY for rules that, when im plemented, will result in quantifiable changes in

emissions. Attach reference(s) for emission factor(s ) and other information. Attach calculation sheet showing how the emission informati on provided below was determined.

Net Effect on Emissions: ( ) Increase ( x) Decrease ( ) N/A

The emission reduction commitment for this Source Category is 1.6 tons/day (2010 Summer

Planning Inventory. The remaining emission reduction commitment is for Phase II of Control Measure CTS-09).

SCC/CES Code Affected: If a SCC Code is Assigned, SIC Code Affected: 3731-32 & 3081-89

(NOTE: If more than one SCC or CES code or mo re than one combination of SCC and SIC codes are needed, fill out the following information on a separate form for each combination of codes.)

Inventory Year Used to Calculate Changes in Emissions: 1998-99

Area Affected: South Coast Air Quality Management District

Future Year Control Profile Estimate (Provide information on as many years as possible): N/A

Emissions Inventories and Reductions



### The emissions inventory and reductions of Rule 1162 amendments can be calculated

as follows:

Reported 1

Emissions Adjusted 2

Emissions Emissions of Gel Coats and Resins

Tpy tpd Tpy tpd

1998-99 Emissions Inventory 1942 5.32 3290 9.01

1998-99 Emissions Reduction 3 1351 3.70 2288 6.27

2010 Annual Average Emissions Inventory 2460 6.74 4168 11.42

2010 Annual Average Emissions Reduction 4 1711 4.69 2898 7.94

2010 Planning Emissions Inventory 3275 8.97 5548 15.20

2010 Planning Emissions Reduction 4 2277 6.24 3858 10.57

2010 Planning Emissions Reduction from Large Composite Facility 5 2004 5.49 3395 9.30

2010 Planning Rule 1132 SIP Reductions (already claimed) 6 978 2.68 1657 4.54

2010 Planning Emissions Creditable to CTS-09 7 1026 2.81 1738 4.76

2010 Planning Emissions Creditable to CTS-08 8 273 0.75 463 1.27

(1): The reported emissions inventory of the composite facilities in the District is based on 1998-

99 emissions inventory (1942 tpy). This emissions inventory incorporated the emissions inventory of composite facilities included in Rule 1162 Staff Report 2001 (1534 tpy), the emissions inventory of additional composite facilities not included in Rule 1162 Staff Report 2001 (175 tpy) and the emissions inventory of the area sources (233 tpy). [Reported Emissions Inventory = 1534 tpy + 175 tpy + 233 tpy = 1942 tpy].CALIFORNIA AIR RESOURCES BOARD



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(2): The adjusted emissions inventory of the composite facilities is calculated by multiplying the

reported emissions inventory (based on AP 42 emission factors) by the emissions inventory adjusting factor (1.6941). The emissions inventory adjusting factor represents the ratio between the emissions inventory of composite facilities in the South Coast A.Q.M.D, calculated using the UEF 2001Table (2599 tpy - see 2001 Rule 1162 Staff Report) and AP 42 emission factors (1534.18 tpy). [Emissions Inventory Adjusting Factor = 2,599 tpy/1534.18 tpy = 1.6491] [Adjusted emission inventory = 1942 tpy x 1.6941= 3290 tpy].

(3):The emissions reduction of the proposed amendments (1807 tpy) is equal to the emissions reduction calculated in 2001 Rule 1162 Staff Report(1971 tpy) minus the emissions reductions foregone due to the deletion of the requirement of the nonatomizing spray application technique of gel coat and the pin striping exemption (162 tpy). [Emissions Reduction = 1971 tpy – 162 tpy =1807 tpy] The emissions reduction percentage of the proposed amendments is equal to the emissions reduction of the proposed amendments (1807 tpy) divided by the emissions inventory of only resins and gel coats and excluding the emissions inventory of solvents, coatings and adhesives, as calculated in 2001 Rule 1162 Staff Report (2599 tpy) [Emissions Reduction Percentage = 1807 tpy/2599 tpy x 100 = 69.5267% ~ 69.53%]
Therefore, the 1998-99 Emissions Reduction can be calculated as follows: For Reported Emissions Inventory =1942 tpy x 69.53% = 1351 tpy For Adjusted Emissions Inventory =3290 tpy x 69.53% = 2288 tpy

(4): The emissions inventory of the 2010 Annual Average Emissions Reduction and the 2010 Planning Emissions Reduction are calculated by multiplying the 2010 Annual Average Emissions Inventory and the 2010 Planning Emissions Inventory by the emissions reduction percentage of the proposed amendments (69.53%). [2010 Adjusted Average Emissions Reduction = 4168 tpy x 69.53% = 2898 tpy . [2010 Adjusted Planning Emissions Reduction = 5548 tpy x 69.53% = 3858 tpy].

(5): The emissions inventory of the composite facilities emitting more than 20 tons per year to approximately 88 % of the total emissions inventory and reductions for the source category. [2010 Adjusted Planning Emissions Reduction for Large Facilities = 3858 tpy x 88% = 3395 tpy]

(6): Rule 1132 SIP commitment emissions reduction claimed for composite facilities that emit more the 20 tons per day and utilize spray booth(s) in their operations. The 2010 planning emissions reductions claimed for the Rule 1132 SIP was estimated as 2.68 tons per day (reported emissions) and 4.54 tons per day (adjusted emissions). [2010 Adjusted Planning Emissions Reduction Claimed for Rule 1132 = 4.54 tpd x 365 = 1657 tpy]

(7): The 2010 planning emissions reduction creditable to CTS-08 is equal to the difference between 2010 planning emissions reduction from large facilities and what has already been claimed in the SIP submittal package for Rule 1132 [2010 Adjusted Planning Emissions Reduction Creditable to CTS-09 = 3395 tpy – 1657 tpy =

1738 tpy].

(8): The 2010 planning emissions reduction creditable to CTS-08 is equal to the emissions inventory of the composite facilities emitting equal to or less than 20 tons per year which contributed approximately 12 % of the emissions inventory and reductions [2010 Adjusted Planning Emissions Reduction Creditable to CTS-08 = 3858 tpy x 12% = 463

tpy]CALIFORNIA AIR RESOURCES BOARD



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Rule 1162 emissions reductions can be calculated as follows:

Rule 1162 Reported Emission Reductions ( 2010 Planning) = 2.81 + 0.75 = 3.56 tpd

Rule 1162 Adjusted Emission Reductions (2010 Planning) = 4.76 + 1.27 = 6.03 tpd

Year Tons/Year Baseline Control Percent Control Control

Reductions Tons/Year Level Cont rol Level Factor
Subject to Rule

2010 Annual Average Adjusted Emissions Inventory

2898 / 4168 = 0.6953 x 100 = 69.53 % 1.00 - 0.6953 = 0.3047

2010 Summer Planning Adjusted Emissions Inventory

3858 / 5548 = 0.6953 x 100 = 69.53 % 1.00 - 0.6953 = 0.3047

Accordingly, the impact of the Rule 1162 amendment s on the emissions reduction of the composite facilities in the SCAQMD can be summarized as follows:

(I) November 9, 2001 Amendment

The 2010 Adjusted Planning Emissions creditable to CTS-08 and CTS-09 were 1.38 tpd and 5.60 tpd, respectively.

(II) July 11, 2003 Amendment

No impact of Rule 1162 amendments on composite facilities emissions

(III) July 9, 2004 Amendment

No impact of Rule 1162 amendments on composite facilities emissions

(IV) July 8, 2005 Amendment

The rule amendments included emissions reduction foregone due to the deletion of the gel coat nonatomizing spray application technique requirement and the addition of a transfer efficiency exemption of limited usage of pin striping gel coat application. As a result, the 2010 Adjusted Planning Emissions creditable to CTS-08 and CTS-09 were 1.27 tpd and 4.76 tpd, respectively.

III. SOURCES/ATTAINMENT STATUS

District is: ( ) Attainment ( x ) Nonattainment ( ) Split

Approximate Total Number of Small (<100 TPY) Sources Controlled by Rule: 78

Percent in Nonattainment Area: 100 %

Number of Large (> 100 TPY) Sources Controlled : 3 Percent in Nonattainment Area: 100%CALIFORNIA AIR RESOURCES BOARD



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Name(s) and Location(s) (city and county) of Large (> 100 TPY) Sources Controlled by Rule (Attach additional sheets as necessary):

Facility Name Facility ID Location City County Name

(1) Lasco Bathware, Inc. 24060 Anaheim Orange (2) Xerxes Corporation 70021 Anaheim Orange (3) Resinart Corporation 20302 Costa Mesa Orange

IV. EMISSION REDUCTION TECHNOLOGY



### Does the Rule Include Emission Limits that are Continuous? (x) Yes ( ) No If Yes, Those Limits are in Section(s) (c)(2)(A), (c)(3)(A )& (c) (3)(C) of the Rule (Section (c)(3)(B) of the rule was an emission limit until July 1, 2002).

Other Methods in the Rule for Achieving Emission Reductions are the following:

9 Require nonatomizing spray application technologies for spraying resins.

9 November 9, 2001amendment, requires the nonatomizing spray application technique of gel coat. This requirement was postponed in July 11, 2003 and July 9, 2004 amendments. It was deleted in July 8, 2005 amendment based on the results of the AQMD Gel Coat Testing Program where the nonatomizing spray application technique of gel coat showed no significant emissions reduction as compared to the conventional air-assisted airless spray application.

9 Require acceptable low emitting spray app lication equipment for spraying gel coats.

9 Use add-on control with 90% overall control efficiency.

9 Use fillers (inert, non-VOC material s) in composite fabrications.

9 Use vapor suppressants to reduce VOC and HAP emissions.

9 Allow alternative application processes and materials that result in equivalent emissions reductions and are approved by SCAQMD, CARB and EPA [see subsection (g)].

V. OTHER REQUIREMENTS

The Rule Contains:

Emission Limits in Section(s): (c)(2)(A), (c)(3)(A) & (c)(3)(C).

Work Practice Standards in Section(s): (c)(1)(A), (c)(1)(B), (c)(2)(C), (c)(3)(B), (c)(4), (c)(5) & (c)(6)

. Recordkeeping Requirements in Section(s): (e)

Attach a Completed EPA SIP Approvability Checklist - Enforceability or Provide an Equivalent Compliance/Enforcement Strategy Statement.

VI. IMPACT ON AIR QUALITY PLAN

( ) No Impact ( ) Impacts RFP (x) Impacts attainment

Discussion: Amended Rule 1162 fully implements remaining portions of control measures CTS08 and CTS-09 of the 1999 AQMP Amendment to the 1997 Ozone SIP Revision.

District: 

### South Coast Air Quality Management District