SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Rule Consistency Analysis August 18, 2011 

 B-1 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4684 

APPENDIX B 

RULE CONSISTENCY ANALYSIS FOR PROPOSED AMENDMENTS TO 

RULE 4684 (POLYESTER RESIN OPERATIONS) 

August 18, 2011 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Rule Consistency Analysis August 18, 2011 

 B-2 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4684 

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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Rule Consistency Analysis August 18, 2011 

 B-3 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4684 

Rule Consistency Analysis for Proposed Amendments to 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 District is required to perform a written 

analysis that identifies and compares the air pollution 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 elements analyzed are emission limits or 

control efficiency, operating parameters and work practices, monitoring and testing, and 

recordkeeping and reporting requirements. 

II. RULE CONSISTENCY ANALYSIS 

A. District Rules 

Polyester Resin Operations could be subject to other District rules including: 

• Rule 2010 (Permits Required), 

• Rule 2201 (New and Modified Stationary Source Review 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 (CTG) 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 CTG 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 efficiency, and work practice 

standards. 

This CTG provides control recommendations for reducing VOC emissions from the use 

of gel coats, resins, and materials used to clean application equipment in fiberglass boat 

manufacturing operations. The CTG lists the available controls options for resin and gel 

coal as follows: 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Rule Consistency Analysis August 18, 2011 

 B-4 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 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 monomer VOC content limit through the 

use of low-monomer VOC materials, either by using only low monomer VOC materials 

within a covered operation, or by averaging the monomer 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 facility to average emissions among 

different operations using equations to estimate monomer VOC emission rates from 

each operation based on the material and application method; or (3) use add-on 

controls to achieve a numerical monomer VOC emission rate that is determined for 

each facility based on the mix of application methods 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 proposed 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 Sources (NSPS) 

There is no NSPS for this source category. 

4. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

a. Subpart VVVV—National Emission Standards for Hazardous Air 

Pollutants for Boat Manufacturing 

This subpart establishes national emission standards 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 establishes requirements to demonstrate 

initial and continuous compliance with the emission standards. The applicability of this 

subpart is equivalent to that of District Rule 4684. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Rule Consistency Analysis August 18, 2011 

 B-5 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4684 

Subpart VVVV states that compliance with the subpart 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 molding resin and gel coat 

operations that you average meet the emission limit in §63.5698 using the 

procedures described in §63.5710. Compliance with this 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 section. 

(b) Compliant materials option: Demonstrate compliance by using resins and gel 

coats that meet the organic HAP content requirements 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 emission limit in §63.5698. 

Compliance with this option is based on control device performance testing and 

control device monitoring. 

Subpart VVVV emission limits are similar to the CTG limits for fiberglass boat 

manufacturing materials. Since the previous amendments to Rule 4684 in September 

2009 incorporated the CTG standards, the proposed amendments 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 gaseous organic emissions as a 

surrogate for total organic HAP emissions. If EPA Method 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 must be taken into account and 

analytical techniques should be considered to get an accurate measure of at least 90 

percent of the total organic HAP mass emissions. Method 18 should not be used to 

measure organic HAP emissions from a combustion device; Method 25A should be 

used instead and assume that all gaseous organic mass emissions measured as 

carbon are organic HAP emissions. To measure gas volumetric flow rate, EPA Method 

2, 2A, 2C, 2D, 2F or 2G, should be used, as appropriate. 

In comparison with Subpart VVVV test methods, Rule 4684 prescribes the use of ASTM 

D2369-87 for determining the monomer content of uncatalyzed resin materials, 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Rule Consistency Analysis August 18, 2011 

 B-6 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4684 

SCAQMD Method 309 for measuring the emission rate per 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 resin 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 recordkeeping requirements than Subpart 

VVVV. 

5. Federal Lowest Achievable Emission Rate (LAER) and Federal Best Available 

Control Technology (BACT) 

EPA staff maintains a database of Reasonably Available Control Technology (RACT), 

BACT, and LAER technologies that have been provided to EPA by state and local 

permitting agencies. A review of polyester resin operations permits in the 

RACT/BACT/LAER Clearinghouse (RBLC) determined that the limits and technology 

that could be used to meet the proposed emission limits 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 require five-year record maintenance. 

The proposed recordkeeping for District Rule 4684 requires that operators maintain 

records for at least five years. Proposed Rule 4684 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, regulations, or policies covering similar 

stationary sources.