### ATTACHMENT C

COUNTY OF SAN DIEGO AIR POLLUTION CONTROL DISTRICT

COMPARATIVE ANALYSIS OF

PROPOSED AMENDMENTS TO RULE 67.11

– WOOD PRODUCTS COATING OPERATIONS

STATUTORY REQUIREMENTS Prior to adopting, amending, or repealing a rule or regulation, California Health and Safety Code Section 40727 requires findings of necessity, authority, clarity, consistency, non

duplication, and reference. As part of the consistency finding to ensure proposed r ule requirements do not conflict with or contradict other Air Pollution Control District (District) or federal regulations, Health and Safety Code Section 40727.2(a) requires the District to perform a written analysis identifying and comparing the air poll ution control standards and other provisions of proposed amended Rule 67.11 with existing or proposed District rules and guidelines and existing federal rules, requirements, and guidelines applying to the same source category.

ANALYSIS Proposed amended R ule 67.11 applies to all wood products coating operations and associated cleaning operations emitting volatile organic compound s (VOC s )

. The U.S. Environmental Protection Agency (EPA) has published a Control Techniques Guidelines (CTG) for Wood Furniture M anufacturing Operations applicable to wood coating operations emitting 25 tons per year or more of VOC.

In addition, District New Source Review (NSR) Rule 20.2

- Non

- Major Stationary Sources, also applies to any new or modified wood products coating ope ration that would be subject to amend ed Rule 67.11. Rule 20.2 requires that any non

- major new or modified emission unit that has a post

- project potential to emit of 10 pounds/day or more of VOC be equipped with Best Available Control Technology (BACT). F or wood product coating operations, BACT is identified as either use of an add

- on emission control system, or if such system is demonstrated to be not cost

- effective, compliance with the requirements of Rule 67.1 1

. Proposed amended Rule 67.1 1 will take effect one year after the date of rule adoption. Since amended Rule 67.1 1 contains VOC content limits for various wood coatings and cleaning and stripping materials that are more stringent than the existing rule, these limits will become the

ne w BACT requirements.

CONCLUSION As shown in Table 1, there are no conflicts or contradictions between proposed amended Rule 67.11 and EPA's Control Technique Guidelines. Furthermore, there are no contradictions between the proposed amended rule and the D istrict’s NSR Rule 20.2 BACT requirements.

### Comparative Analysis

– Rule 67.11 C

- 2 TABLE 1

– COMPARATIVE ANALYSIS

Items for Comparison Proposed Amended Rule 67.11 SD APCD Best Available

Control Technology (BACT) CTG for Wood Furniture Manufacturing Operations Applicability All wood product coating

operations and associated stripping, surface preparation and coating application equipment cleaning

. Sources that emit > 10 lb/day of VOC. Wood product coating operations emitting 25 tons per year or more of VOC.

Exemptions Exempt from rul e:

1. Wood coating operations using 20 gallons or less of coatings per consecutive 12 months

. 2. Wood coating operations with VOC emissions of 150 lbs or less per consecutive 12 months

.

3. Use of non

- refillable handheld aerosol spray containers.

Exempt from equipment application standard: air brushing and touch

- up operations.

Exempt from emission standards: coatings applied to wooden musical instruments. N o exemptions N o exemptions

VOC Content Standards VOC content limits for

various categorie s of wood coatings and solvents. For operations using < 10 gal/day

– use of water

- based coatings when compatible with the operation and compliance with all other provisions of Rule 67.11, for the rest of the operation.

For operations using 10 gal/day or more

– a case

- by

case determination of applicable add

- on control requirements based on the District’s cost

- effectiveness guidance is required. VOC content limits for various categories of wood coatings and solvents.

Add

- On Emission Control Requirements Capture and control

efficiency >85 % by weight, as an alternative to complying with VOC content limits. Same as in Rule 67.11

– a

case

- by

- case determination of applicable add

- on control requirements based on the District’s cost

- effectiveness Control system that will achieve an equivalent reduction in emissions as achieved by complying with the applicable VOC limits.

### Comparative Analysis

– Rule 67.11 C

- 3 guidance is re quired.
Recordkeeping 1) Records to be kept for

three years.

2) Maintain current list of coating and solvent materials used.

3) Monthly records for coating materials and solvent use records. Same as in Rule 67.11. 1) Records to be kept for five
years.

2) Maintain current list of coating and solvent materials used.

3) Maintain records for the use of coating materials and solvents.

Test Methods Various methods approved

by EPA or ARB, including VOC conten t, vapor pressure , and capture efficiency. Same as in Rule 67.11. Various methods including VOC content, solids content, and capture efficiency.

* There are currently no applicable federal New Source Performance Standards (NSPS) to this source category. National Emission Standards for Hazardous Air Pollutants ( NES HAP)

– Wood Furniture Manufacturing Operations (NESHAP Subpart JJ)

– applies to facilities that emit more than 10 tons/year of any one hazardous air pollutant ( HAP ) or 25 tons/year of a combination of HAPs. There are currently no sources in San Diego County that are subject to this NESHAP.