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Appendix B: Rule Consistency Analysis August 18, 2 011

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For Proposed Amendments to Ru le 4684 

## APPENDIX B

RULE CONSISTENCY ANALYSIS FOR PROPOSED AMENDMENTS T O

RULE 4684 (POLYESTER RESIN OPERATIONS)

August 18, 2011SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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For Proposed Amendments to Ru le 4684 

### Rule Consistency Analysis for Proposed Amendments t o Rule 4684

I. REQUIREMENTS OF ANALYSIS

Pursuant to the California Health and Safety Code § 40727.2, prior to adopting, amending, or repealing a rule or regulation, the Di strict is required to perform a written analysis that identifies and compares the air pollu tion control elements of the rule or regulation with corresponding elements of existing or proposed District and United States Environmental Protection Agency (EPA) rules, regulations, and guidelines that apply to the same source category. The rule elemen ts analyzed are emission limits or control efficiency, operating parameters and work p ractices, monitoring and testing, and recordkeeping and reporting requirements.

II. RULE CONSISTENCY ANALYSIS

A. District Rules

Polyester Resin Operations could be subject to othe r District rules including:

• Rule 2010 (Permits Required),

• Rule 2201 (New and Modified Stationary Source Revi ew Rule),

• Rule 4102 (Nuisance),

The above-listed rules are not in conflict nor are they inconsistent with the requirements of Proposed Rule 4684.

B. Federal EPA Rules and Regulations

1. EPA-453/R-08-004 Control Technique Guidelines (C TG) for Fiberglass Boat Manufacturing Materials

EPA finalized the above CTG in September 2008. The last rule amendments in September 2009 incorporated the standards of the CT G and therefore the Rule 4684 is consistent with the CTG’s applicability threshold, resin and gelcoat monomer content limits, add-on control equipment emission control e fficiency, and work practice

standards.

This CTG provides control recommendations for reduc ing VOC emissions from the use of gel coats, resins, and materials used to clean a pplication equipment in fiberglass boat manufacturing operations. The CTG lists the availa ble controls options for resin and gel

coal as follows:SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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For Proposed Amendments to Ru le 4684 • Low monomer VOC resins and gel coats.

• Vapor suppressed resins and gel coats.

• Non-atomizing resin applications.

• Closed Molding.

• Add on control systems.

The CTG requires the following in order to meet the recommended open molding resin and gel coat limits: (1) achieve the individual mon omer VOC content limit through the use of low-monomer VOC materials, either by using o nly low monomer VOC materials within a covered operation, or by averaging the mon omer VOC contents for all materials used within an operation on a weight-adjusted basis ; (2) meet the numerical monomer VOC emission rate limits, which would enable a faci lity to average emissions among different operations using equations to estimate mo nomer VOC emission rates from each operation based on the material and applicatio n method; or (3) use add-on

controls to achieve a numerical monomer VOC emissio n rate that is determined for each facility based on the mix of application metho ds and materials used at that facility.

Since previous amendments to Rule 4684 incorporated the CTG standards, the monomer contents of resins and gel coats being prop osed are consistent with the specified limits prescribed by the CTG.

2. EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.

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

There is no NSPS for this source category.

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

a. Subpart VVVV—National Emission Standards for Haz ardous Air Pollutants for Boat Manufacturing

This subpart establishes national emission standard s for hazardous air pollutants (HAP) for new and existing boat manufacturing facilities that performs resin and gel coat operations, carpet and fabric adhesive operations, or aluminum recreational boat surface coating operations. This subpart also estab lishes requirements to demonstrate initial and continuous compliance with the emission standards. The applicability of this subpart is equivalent to that of District Rule 4684

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For Proposed Amendments to Ru le 4684 Subpart VVVV states that compliance with the subpar t may be demonstrated by using one of the following options for the resins and gel coats used in open molding operations at your facility:

(a) Maximum achievable control technology (MACT) model point value averaging (emissions averaging) option:

(1) Demonstrate that emissions from the open moldi ng resin and gel coat operations that you average meet the emission limit in §63.5698 using the procedures described in §63.5710. Compliance with t his option is based on a 12- month rolling average.

(2) Those operations and materials not included in the emissions average must comply with either paragraph (b) or (c) of this sec tion.

(b) Compliant materials option: Demonstrate compliance by using resins and gel coats that meet the organic HAP content requirement s in Table 2 to this subpart. Compliance with this option is based on a 12-month rolling average.

(c) Add-on control option: Use an enclosure and add-on control device, and demonstrate that the resulting emissions meet the e mission limit in §63.5698. Compliance with this option is based on control dev ice performance testing and control device monitoring.

Subpart VVVV emission limits are similar to the CTG limits for fiberglass boat manufacturing materials. Since the previous amendm ents to Rule 4684 in September 2009 incorporated the CTG standards, the proposed a mendments to Rule 4684 are still consistent with the specified limits prescribed by the CTG and the NESHAP.

Subpart VVVV prescribes the use of EPA Method 18 to measure organic HAP emissions or EPA Method 25A to measure total gaseou s organic emissions as a surrogate for total organic HAP emissions. If EPA M ethod 25A is used, all gaseous organic emissions measured as carbon are assumed to be organic HAP emissions. If EPA Method 18 is used and the number of organic HAP in the exhaust stream exceeds five, the use of multiple chromatographic columns m ust be taken into account and analytical techniques should be considered to get a n accurate measure of at least 90 percent of the total organic HAP mass emissions. Me thod 18 should not be used to measure organic HAP emissions from a combustion dev ice; Method 25A should be used instead and assume that all gaseous organic ma ss emissions measured as carbon are organic HAP emissions. To measure gas v olumetric flow rate, EPA Method 2, 2A, 2C, 2D, 2F or 2G, should be used, as appropr iate.

In comparison with Subpart VVVV test methods, Rule 4684 prescribes the use of ASTM D2369-87 for determining the monomer content of unc atalyzed resin materials,SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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For Proposed Amendments to Ru le 4684 SCAQMD Method 309 for measuring the emission rate p er square meter of exposed surface during polymerization of resins, EPA Method 204-204F for determining the capture efficiency of a VOC emission control system , EPA Methods 2, 2A, or 2D for measuring flowrates and EPA Methods 25, 25A, or 25B for measuring total gaseous organic concentrations at the inlet and outlet of a VOC control device.

Subpart VVVV requires that monthly records of the r esin and gel coats used need to be maintained. District Rule 4684 requires that these records be maintained on a daily basis. District Rule 4684 has more stringent recor dkeeping requirements than Subpart

VVVV.

5. Federal Lowest Achievable Emission Rate (LAER) a nd Federal Best Available Control Technology (BACT)

EPA staff maintains a database of Reasonably Availa ble Control Technology (RACT), BACT, and LAER technologies that have been provided to EPA by state and local permitting agencies. A review of polyester resin o perations permits in the RACT/BACT/LAER Clearinghouse (RBLC) determined that the limits and technology that could be used to meet the proposed emission li mits is available and in use in other part of the United States.

6. EPA Policies and Guidelines

Maintenance of Records

Title V (federal) permits and MACT standards requir e five-year record maintenance. The proposed recordkeeping for District Rule 4684 r equires that operators maintain records for at least five years. Proposed Rule 468 4 therefore is consistent with EPA recordkeeping policy.

III. CONCLUSION

Based on the above discussion, District staff found that the proposed amendments to Rule 4684 would not conflict with federal rules, re gulations, or policies covering similar stationary sources.