SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis September 17, 2009 

B-1 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4684 

APPENDIX B 

RULE CONSISTENCY ANALYSIS 

FOR PROPOSED AMENDMENTS TO RULE 4603 AND RULE 4684 

September 17, 2009
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis September 17, 2009 

B-2 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4684 

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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis September 17, 2009 

B-3 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4684 

RULE CONSISTENCY ANALYSIS 

I. REQUIREMENTS FOR RULE CONSISTENCY ANALYSIS

Prior to adopting, amending, or repealing a rule or regulation, California Health and 

Safety Code Section 40727.2 requires that District staff perform a written analysis that 

identifies and compares the air pollution control elements of the proposed rule with the 

corresponding elements of existing or proposed District and United States 

Environmental Protection Agency (EPA) rules, regulations, and guidelines that apply to 

the affected source category. The elements that were analyzed are emission limits; 

work practices; monitoring and testing; and recordkeeping and reporting requirements. 

The analysis is detailed in Section II of this report. Conclusions based on the analysis 

are shown in Section III. 

II. RULE CONSISTENCY ANALYSIS 

District staff reviewed EPA rules, regulations, and guidelines, as well as District rules for 

the source categories covered by Rule 4603 (Surface Coating of Metal Parts and 

Products, Plastic Parts and Products, Automotive/Transportation Plastic Parts and 

Products, and Pleasure Crafts) and Rule 4684 (Polyester Resin Operations). The 

analysis for Rule 4603 was confined to those provisions that incorporate into Rule 4603 

the standards established in EPA’s Control Techniques Guidelines (CTGs) for metal 

parts and products, plastic parts and products, automotive/transportation and business 

machine plastic parts and products, and pleasure crafts coating operations appliance 

coating operations, metal furniture coating operations, and flat wood paneling products 

coating operations. The analysis for Rule 4684 was confined to those provisions that 

incorporate into Rule 4684 the standards established in EPA’s CTG for fiberglass boat 

manufacturing. Existing VOC limits, operating parameters, monitoring, testing, records, 

and reporting requirements from coating operations other than those that affect the 

implementation of the CTG standards were not analyzed for purposes of the rule 

consistency analysis. 

A. Existing or Proposed District Rules 

The following existing District prohibitory rules also apply to Rule 4603 and Rule 4684: 

Rule 1020 (Definitions) 

Rule 1020 applies to sources subject to Rule 4603 and Rule 4684 only because the 

definition of VOC is referred to the definition that is indicated in Rule 1020. District staff 

is not proposing any change to the existing definition of VOC so there is no impact on 

the proposed amendments to the rules. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis September 17, 2009 

B-4 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4684 

Rule 2020 (Exemptions) 

Rule 2020 Section 6.8.2 provides operators some exemption from obtaining a District 

Permit to Operate (PTO) for certain surface coating operations. Specifically, Section 

6.8.2 exempts from PTO surface coating operations, except powder coating 

operations), which use less than one quart of coating per day or less than eight gallons 

of coating per year. Powder coating operations that use less than five pounds of 

coating material per day or less than 50 pounds of material per year is exempt from 

PTO. 

Rule 2201 (New or Modified Stationary Source Review) 

Rule 2201 applies to permitting of new or modified stationary sources of air pollution. It 

provides the review new or modified stationary sources of air pollution and establishes 

the mechanisms including emission trade-offs by which Authorities to Construct such 

sources may be granted without interfering with the attainment or maintenance of 

Ambient Air Quality standards. It also requires no net increase in emissions above 

specified thresholds from new or modified stationary sources of all nonattainment 

pollutants and their precursors. In addition it establishes the requirements that trigger 

the need to install and operate Best Available Control Technology (BACT) and emission 

offsets. The proposed changes to Rule 4603 and 4684 do not change the existing 

requirements of Rule 2201. As discussed in Section I.A of the Final Draft Staff Report 

the federal Clean Air Act Section 182(b)(2)(a) requires that for nonattainment areas 

(such as the District ) a revision to the State Implementation Plan is required for each 

category of VOC sources covered by CTG documents between November 15, 1990 and 

the date of attainment. The emission standards of existing Rule 4603 and Rule 4684 

are less stringent than the CTG standards for these source categories, therefore in 

order to make the rules meet Reasonably Available Control Technology (RACT) 

standards, the proposed amendments to rules must be implemented within 12 months 

from the date the CTGs were published. 

B. Rule Consistency Analysis for Rule 4603 

1. CTG for Miscellaneous Metal and Plastic Parts Coatings (EPA-453/R-08-003) 

EPA finalized the above-mentioned CTG in September 2008. The standards 

established by this CTG are summarized in Sections III of the Final Draft Staff Report. 

Since the purpose of the rulemaking project is to incorporate the standards of the CTG, 

the proposed changes to Rule 4603 are identical to the CTG’s applicability threshold, 

coating VOC limits, add-on control equipment emission control efficiency, and work 

practice standards, except those CTG coatings VOC limits which are less stringent than 

the existing limits in the rule were not included because they would be a relaxation of 

the SIP-approved version of the rule as discussed in the Final Draft Staff Report. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis September 17, 2009 

B-5 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4684 

2. EPA – Alternative Control Techniques (ACT) Document for Industrial Cleaning 

Solvents (EPA-453-94-015), February 1994 

This ACT contained detailed discussion on solvent cleaning activities (i.e., dipping, 

flushing, purging, spraying, and wiping) and factors that affect emissions. However, the 

ACT does not specify any solvent VOC limit or emission standards. Therefore, it does 

not serve any meaningful purpose for RACT determination of organic solvent cleaning 

activities. 

In comparison, District Rule 4603 requires the use of cleaning solvents with a VOC 

content of no more than 25 grams/liter. As an alternative to using compliant cleaning 

solvents, an operator may operate an APCO-approved VOC emission control system 

that has an overall capture and control efficiency of 90%. In addition, District Rule 4603 

also specifies allowable cleaning methods such as wipe cleaning, non-atomized solvent 

flow, and solvent flushing. The rule prohibits atomization of solvent into open air unless 

it is vented to an APCO-approved VOC emission control system, and also prohibits use 

of VOC containing materials to clean spray equipment unless an enclosed system is 

used. A spray equipment cleaning method other than an enclosed system may be used 

provided it is proven to be equally as an enclosed effective in controlling emissions. 

Based on the discussion above, District staff deems District Rule 4603 satisfies RACT. 

3. 1994 ACT for Surface Coating of Automotive/Transportation and Business 

Machine Plastic Parts 

This ACT provided alternative control technologies available for VOC emissions from 

surface coating of plastic parts in automotive and other transportation equipment and 

business machines. The ACT only presented options for alternative control and did not 

establish any RACT recommendation. The ACT stated the use of lower Voc content 

coatings (waterborne or high solids coatings) use of non-VOC coatings (zinc-arc, UV, 

powder, or vapor cure coatings), process modifications (improvement in coating 

application equipment), or add-on controls are all available alternative control options. 

The VOC coating limits recommended by the ACT ranged from 6.4 to 3.8 lb/gal coating 

less water and exempt compounds for Control Level 1, and from 6.4 to 3.2 lb/gal 

coating less water and exempt compounds for Control Level 2, depending on the 

specific type auto interior or exterior auto coatings, or type of automotive/transportation 

specialty coatings 

4. Standards of Performance for New Stationary Sources (NSPS) 

a. 40 CFR 60 Subpart TTT (Surface Coating of Plastic Parts for Business 

Machines) 

This 1988 NSPS limits the amount of VOC in coatings that are applied to office 

equipment, laboratory machines, and computers. The NSPS applies to coating booths 

that commence construction, reconstruction, or modification after January 8, 1986. The 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis September 17, 2009 

B-6 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4684 

standard defines the business machine sector as typewriters, electronic computing 

devices, calculating and accounting machines, office machines, and photocopy 

machines. The VOC limits for prime coats (1.5 kg/liter coating solids applied), color 

coats (1.5 kg/liter coating solids applied), texture coats (2.3 kg/liter coating solids 

applied), and touch-up coats (2.3 kg/liter coating solids applied) in any facility in which 

plastic parts are coated for use in manufacturing of business machines. While the 

NSPS defines affected facility as spray booths, all resulting VOC emissions from 

applied coating (i.e., including emissions during flash off and curing) must also be 

included in calculating a facility’s compliance status. The standards also account for the 

transfer efficiency of the coating application equipment, since they are in units of mass 

of VOC per volume of coating solids applied to the actual part. As an alternative 

compliance option, an add-on control device may be used, but the operator must 

demonstrate that the volume-weighted average mass of VOC emitted per volume of 

coating solids applied is within the applicable limit. The NSPS did not address cleaning 

operations materials. 

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

Maximum Achievable Control Technologies (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations 

(CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to 

implement NESHAP requirements to the District, NESHAPs and MACTs promulgated 

by EPA are usually incorporated by reference into District Rule 4002 (National Emission 

Standards for Hazardous Air Pollutants). It is important to mention that the District 

implements NESHAPs and MACTs by incorporating the emission standards as 

conditions of the Permits to Operate that are issued to affected sources. The three 

NESHAPs that apply to miscellaneous metal parts and products, large appliances, and 

metal furniture coating operations are briefly discussed below. 

a. 40 CFR Part 63 Subpart MMMM (NESHAP for Surface Coating of Miscellaneous 

Metal Parts and Products) 

This NESHAP applies to new, reconstructed, or existing affected source that uses 946 

liters (250 gallons) per year or more of coatings that contain hazardous air pollutants 

(HAPs) in surface coating of miscellaneous metal parts and products defined in the 

NESHAP, and that is a major source, located at a major source, or a part of a major 

source. A major source of HAP emissions is a stationary source that emits or has the 

potential to emit any single HAP at a rate of 9.07 megagrams (10 tons) or more per 

year, or any combination of HAP at a rate of 22.68 megagrams (25 tons) or more per 

year. The NESHAP include provisions for complying with the applicable emission limits, 

work practice standards, recordkeeping and reporting requirements. The NESHAP also 

contains exemptions for certain types of surface coating operations. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis September 17, 2009 

B-7 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4684 

The organic HAP emission limits range from 0.23 to 4.5 kg /liter coating solids 

depending on the type of coating (e.g., general use coating, high performance coating, 

rubber-to-metal coating, extreme performance fluoropolymer coating) and whether the 

coatings are used in existing facilities or new and reconstructed facilities. 

NESHAP work practice standards include storing all organic containing materials in 

closed containers, minimizing spills of all HAP materials, conveying HAP materials from 

one location to another in closed containers or pipes, closing mixing vessels except 

when adding, removing, or mixing the contents; and minimizing emissions during 

cleaning of storage, mixing, and conveying equipment. The proposed work practice 

standards in Rule 4603 are consistent with the NESHAP requirements. 

This NESHAP prescribed the use of EPA Method 311 for determining the mass of 

organic HAP, EPA Method 24 for determining mass fraction of nonaquesous volatile 

matter, and EPA Method 204 for determining the capture efficiency of an emission 

capture system. Rule 4603 prescribes the use of EPA Method 24 for determining the 

VOC content of coatings and solvents, EPA Method 204-204 F for determining the 

capture efficiency of an emission control system, EPA Methods 2, 2A, or 2D for 

determining flowrates and EPA Methods 25, 25A, or 25B for measuring total organic 

gaseous concentrations at the inlet and outlet of the emission control system. 

It is important to mention, however, that the NESHAP HAP emission limits which are 

expressed in terms of mass (kg) of HAP per volume (liter) of coating solids are not 

directly comparable to the coatings VOC limits which are expressed in terms of grams 

(or lb) of VOC per liter (or gallons) of coatings, less water and exempt compounds, as 

applied. In addition, some HAPs may be exempt VOCs, and some VOCs may be 

HAPs; therefore, there is no direct correlation between the NESHAP limit versus District 

Rule 4603 VOC limits. 

b. 40 CFR Part 63, Subpart PPPP (NESHAP for Surface Coating of Plastic Parts 

and Products) 

This NESHAP applies to major sources of hazardous air pollutants that performs plastic 

parts and products surface coating operations, except those covered by other major 

source surface coating NESHAP (e.g., plastic parts of wood furniture, large appliances, 

plastic parts of metal furniture, plastic parts of wood building products, aerospace 

vehicles and components, web coating, coil coating, ships and boats, auto and light 

duty truck plants. The NESHAP regulates coating cleaning, and depainting at affected 

sources, but does not apply to sources that use less than 100 gallons (378 liters) per 

year of HAP-containing coatings. The NESHAP coatings VOC limits range from 0.16 to 

1.34 kg of HAP/kg coating solids depending on the type of coating (i.e., general use 

coatings, automotive lamp coatings, thermoplastic olefin coatings, and assembled onroad vehicle coatings.) 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis September 17, 2009 

B-8 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4684 

This NESHAP prescribed the use of EPA Method 311 for determining the mass of 

organic HAP, EPA Method 24 for determining mass fraction of nonaqeous volatile 

matter, and EPA Method 204 for determining the capture efficiency of an emission 

capture system. Rule 4603 prescribes the use of EPA Method 24 for determining the 

VOC content of coatings and solvents, EPA Method 204-204 F for determining the 

capture efficiency of an emission control system, EPA Methods 2, 2A, or 2D for 

determining flowrates and EPA Methods 25, 25A, or 25B for measuring total organic 

gaseous concentrations at the inlet and outlet of the emission control system. 

It is important to mention, however, that the NESHAP HAP emission limits which are 

expressed in terms of mass (kg) of HAP per volume (liter) of coating solids are not 

directly comparable to the coatings VOC limits which are expressed in terms of grams 

(or lb) of VOC per liter (or gallons) of coatings, less water and exempt compounds, as 

applied. In addition, some HAPs may be exempt VOCs, and some VOCs may be 

HAPs; therefore, there is no direct correlation between the NESHAP limit versus District 

Rule 4603 VOC limits. 

B. Rule Consistency Analysis for Rule 4684 

1. EPA-453/R-08-004 Control Technique Guidelines (CTG) for Fiberglass Boat 

Manufacturing Materials 

EPA finalized the above CTG in September 2008. The standards established by this 

CTG are summarized in Section IV of the Final Draft Staff Report. Since the purpose of 

the rulemaking project is to incorporate the standards of the CTG, the proposed 

changes to Rule 4684 are 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: 

• 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 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis September 17, 2009 

B-9 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4684 

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. 

Please refer to the Final Draft Staff Report for detailed discussion of the CTG standards. 

Since the proposed amendments to Rule 4684 is intended to incorporate 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. 

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. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis September 17, 2009 

B-10 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4684 

(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 proposed amendments to Rule 4684 is intended to 

incorporate the CTG standards, the proposed amendments to Rule 4684 are 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, you must assume that 

all gaseous organic emissions measured as carbon are organic HAP emissions. If EPA 

Method 18 is used and the number of organic HAP in the exhaust stream exceeds five, 

you must take into account the use of multiple chromatographic columns and analytical 

techniques to get an accurate measure of at least 90 percent of the total organic HAP 

mass emissions. Do not use Method 18 to measure organic HAP emissions from a 

combustion device; use instead Method 25A and assume that all gaseous organic mass 

emissions measured as carbon are organic HAP emissions. Use EPA Method 2, 2A, 

2C, 2D, 2F or 2G, as appropriate, to measure gas volumetric flow rate. 

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, 

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. 

III. RESULT OF RULE CONSISTENCY ANALYSIS 

Based on the above discussion, District staff found that the proposed amendments to 

Rule 4603 and Rule 4684 would not conflict with federal rules, regulations, or policies 

covering similar stationary sources.