SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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, 2009SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX B: Rule Consistency Analysis September 17 , 2009

B-2 Final Staff Report with Appendices for Proposed Amendments to Rule 4603 and Rule 4684 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 e lements of the proposed rule with the corresponding elements of existing or proposed Dist rict and United States Environmental Protection Agency (EPA) rules, regula tions, and guidelines that apply to the affected source category. The elements that we re analyzed are emission limits; work practices; monitoring and testing; and recordk eeping and reporting requirements. The analysis is detailed in Section II of this repo rt. 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/Tr ansportation Plastic Parts and Products, and Pleasure Crafts) and Rule 4684 (Polye ster Resin Operations). The analysis for Rule 4603 was confined to those provis ions that incorporate into Rule 4603 the standards established in EPA’s Control Techniqu es Guidelines (CTGs) for metal parts and products, plastic parts and products, aut omotive/transportation and business machine plastic parts and products, and pleasure cr afts coating operations appliance coating operations, metal furniture coating operati ons, and flat wood paneling products coating operations. The analysis for Rule 4684 was confined to those provisions that incorporate into Rule 4684 the standards establishe d in EPA’s CTG for fiberglass boat manufacturing. Existing VOC limits, operating para meters, monitoring, testing, records, and reporting requirements from coating operations other than those that affect the implementation of the CTG standards were not analyz ed for purposes of the rule consistency analysis.

A. Existing or Proposed District Rules

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

Rule 1020 (Definitions)

Rule 1020 applies to sources subject to Rule 4603 a nd Rule 4684 only because the

definition of VOC is referred to the definition tha t is indicated in Rule 1020. District staff is not proposing any change to the existing definit ion of VOC so there is no impact on the proposed amendments to the rules.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 exe mption 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 coati ng per day or less than eight gallons of coating per year. Powder coating operations tha t 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 sour ces of air pollution and establishes the mechanisms including emission trade-offs by whi ch 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 stationar y sources of all nonattainment pollutants and their precursors. In addition it es tablishes the requirements that trigger the need to install and operate Best Available Cont rol Technology (BACT) and emission offsets. The proposed changes to Rule 4603 and 468 4 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) requ ires that for nonattainment areas (such as the District ) a revision to the State Imp lementation Plan is required for each category of VOC sources covered by CTG documents be tween 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 C ontrol 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 Co atings (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 i ncorporate 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 emissi on control efficiency, and work practice standards, except those CTG coatings VOC l imits which are less stringent than the existing limits in the rule were not included b ecause they would be a relaxation of the SIP-approved version of the rule as discussed i n the Final Draft Staff Report.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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) Docum ent for Industrial Cleaning Solvents (EPA-453-94-015), February 1994

This ACT contained detailed discussion on solvent c leaning activities (i.e., dipping, flushing, purging, spraying, and wiping) and factor s that affect emissions. However, the ACT does not specify any solvent VOC limit or emiss ion standards. Therefore, it does not serve any meaningful purpose for RACT determina tion 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 alte rnative 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 w ipe cleaning, non-atomized solvent flow, and solvent flushing. The rule prohibits atom ization of solvent into open air unless it is vented to an APCO-approved VOC emission contr ol system, and also prohibits use of VOC containing materials to clean spray equipmen t 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/Trans portation 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 o f non-VOC coatings (zinc-arc, UV, powder, or vapor cure coatings), process modificati ons (improvement in coating application equipment), or add-on controls are all available alternative control options. The VOC coating limits recommended by the ACT range d 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 coatin gs, or type of automotive/transportation specialty coatings

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

a. 40 CFR 60 Subpart TTT (Surface Coating of Plasti c 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 modi fication after January 8, 1986. TheSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 typ ewriters, electronic computing devices, calculating and accounting machines, offic e machines, and photocopy machines. The VOC limits for prime coats (1.5 kg/l iter coating solids applied), color coats (1.5 kg/liter coating solids applied), textur e 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 o f business machines. While the NSPS defines affected facility as spray booths, all resulting VOC emissions from applied coating (i.e., including emissions during f lash off and curing) must also be included in calculating a facility’s compliance sta tus. The standards also account for the transfer efficiency of the coating application equi pment, 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 o f VOC emitted per volume of coating solids applied is within the applicable lim it. The NSPS did not address cleaning operations materials.

5. National Emission Standards for Hazardous Air Po llutants (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 de legated the authority to implement NESHAP requirements to the District, NESH APs and MACTs promulgated by EPA are usually incorporated by reference into D istrict Rule 4002 (National Emission Standards for Hazardous Air Pollutants). It is imp ortant to mention that the District implements NESHAPs and MACTs by incorporating the e mission standards as conditions of the Permits to Operate that are issue d to affected sources. The three NESHAPs that apply to miscellaneous metal parts and products, large appliances, and metal furniture coating operations are briefly disc ussed below.

a. 40 CFR Part 63 Subpart MMMM (NESHAP for Surface Coa ting of Miscellaneous Metal Parts and Products)

This NESHAP applies to new, reconstructed, or exist ing affected source that uses 946 liters (250 gallons) per year or more of coatings t hat contain hazardous air pollutants (HAPs) in surface coating of miscellaneous metal pa rts and products defined in the NESHAP, and that is a major source, located at a ma jor source, or a part of a major source. A major source of HAP emissions is a stati onary 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 reportin g requirements. The NESHAP also contains exemptions for certain types of surface co ating operations.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 fluoro polymer 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 mat erials, conveying HAP materials from one location to another in closed containers or pip es, closing mixing vessels except when adding, removing, or mixing the contents; and minimizing emissions during cleaning of storage, mixing, and conveying equipmen t. The proposed work practice

standards in Rule 4603 are consistent with the NESH AP requirements.

This NESHAP prescribed the use of EPA Method 311 fo r determining the mass of organic HAP, EPA Method 24 for determining mass fra ction of nonaquesous volatile matter, and EPA Method 204 for determining the capt ure efficiency of an emission capture system. Rule 4603 prescribes the use of EP A Method 24 for determining the VOC content of coatings and solvents, EPA Method 20 4-204 F for determining the capture efficiency of an emission control system, E PA Methods 2, 2A, or 2D for determining flowrates and EPA Methods 25, 25A, or 2 5B for measuring total organic gaseous concentrations at the inlet and outlet of t he emission control system.

It is important to mention, however, that the NESHA P 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 whic h 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 bet ween the NESHAP limit versus District

Rule 4603 VOC limits.

b. 40 CFR Part 63, Subpart PPPP (NESHAP for Surfac e Coating of Plastic Parts and Products)

This NESHAP applies to major sources of hazardous a ir pollutants that performs plastic parts and products surface coating operations, exce pt 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 cl eaning, and depainting at affected sources, but does not apply to sources that use les s than 100 gallons (378 liters) per year of HAP-containing coatings. The NESHAP coatin gs VOC limits range from 0.16 to 1.34 kg of HAP/kg coating solids depending on the t ype of coating (i.e., general use coatings, automotive lamp coatings, thermoplastic o lefin coatings, and assembled onroad vehicle coatings.)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 fo r determining the mass of organic HAP, EPA Method 24 for determining mass fra ction of nonaqeous volatile matter, and EPA Method 204 for determining the capt ure efficiency of an emission capture system. Rule 4603 prescribes the use of EP A Method 24 for determining the VOC content of coatings and solvents, EPA Method 20 4-204 F for determining the capture efficiency of an emission control system, E PA Methods 2, 2A, or 2D for determining flowrates and EPA Methods 25, 25A, or 2 5B for measuring total organic gaseous concentrations at the inlet and outlet of t he emission control system.

It is important to mention, however, that the NESHA P 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 whic h 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 bet ween 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 (C TG) 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 standa rds 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 equi pment emission control efficiency, 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 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 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 amongSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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

Since the proposed amendments to Rule 4684 is inten ded to incorporate the CTG standards, the monomer contents of resins and gel c oats 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 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

.

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 molding resin and gel coat operations that you aver age 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 sec tion.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 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 proposed amendm ents to Rule 4684 is intended to incorporate the CTG standards, the proposed amendme nts 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 gaseou s organic emissions as a surrogate for total organic HAP emissions. If EPA M ethod 25A, you must assume that all gaseous organic emissions measured as carbon ar e 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 chro matographic columns and analytical techniques to get an accurate measure of at least 9 0 percent of the total organic HAP mass emissions. Do not use Method 18 to measure org anic HAP emissions from a combustion device; use instead Method 25A and assum e that all gaseous organic mass emissions measured as carbon are organic HAP emissi ons. Use EPA Method 2, 2A, 2C, 2D, 2F or 2G, as appropriate, to measure gas vo lumetric flow rate.

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, 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.

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 fed eral rules, regulations, or policies covering similar stationary sources.