SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis November 21, 2010

B-1 Final Staff Report with Appendice s For Proposed Amendments to Ru le 4612 

## APPENDIX B

Rule Consistency Analysis

November 21, 2010SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis November 21, 2010

B-2 Final Staff Report with Appendice s For Proposed Amendments to Ru le 4612 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis November 21, 2010

B-3 Final Staff Report with Appendice s For Proposed Amendments to Ru le 4612 I. REQUIREMENTS FOR RULE CONSISTENCY ANALYSIS

Pursuant to Section 40727.2 of the California Healt h and Safety Code, 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 elements an alyzed are emission standards, monitoring and testing, and recordkeeping and repor ting requirements.

II. RULE CONSISTENCY ANALYSIS

A. District Rules

Facilities subject to District Rule 4612 could be s ubject to other District rules including:

 Rule 2201 New and Modified Stationary Source Revie w  Rule 4001 New Source Performance Standards

 Rule 4002 National Emissions Standards for Hazardo us Air Pollutants

 Rule 4101 Visible Emissions

 Rule 4102 Nuisance

 Rule 4201 Particulate Matter Concentration

 Rule 4661 Organic Solvents

 Rule 4663 Organic Solvent Cleaning, Storage, and D isposal

The above-listed rules are not in conflict with, no r are they inconsistent with the requirements of Proposed Rule 4612.

B. Federal EPA Rules and Regulations

Federal Control Techniques Guideline (CTG)

1. EPA-450/2-76-028 1976/11 Control of Volatile Organic Emissions from Existing Stationary Sources - Volume I: Control Methods for Surface Coating Operations The CTG applies to surface coating operations locat ed in marginal, moderate, serious or severe ozone nonattainment areas that has the po tential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 1 0 tons/year of VOC for extreme

ozone nonattainment areas. This CTG will not be co mpared to District Rule 4612 since the source category (Motor Vehicle and Mobile Equip ment Coating) is addressed in

another CTG: EPA-450/2-77-008 1977/05 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume II: Surface Co ating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks (See di scussion below).SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis November 21, 2010

B-4 Final Staff Report with Appendice s For Proposed Amendments to Ru le 4612 2. EPA-450/2-77-008 1977/05 Control of Volatile Organic Emissions from Existing Stationary Sources - Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks The CTG applies to motor vehicle surface coating op erations located in marginal, moderate, serious or severe ozone nonattainment are as that has the potential to emit greater than or equal to 25 tons/year of VOC, and e qual to greater than 10 tons/year of

VOC for extreme ozone nonattainment areas. The tab le below identifies the CTG requirements and how Rule 4612 compares to the auto mobile and light-duty truck coating requirements.

Table B1 - Rule and CTG Comparison
Coating Type CTG (lb/gal) Rule 4612 (lb/gal)

Prime 2.8 2.1
Topcoat 4.2 2.1
Final Repair Topcoat 5.5 2.1

3. EPA-453/R-08-006 2008/09 Control Techniques Guidelines for Automobile and LightDuty Truck Assembly Coatings The CTG applies to vehicle assembly coating operati ons located in marginal, moderate,

serious or severe ozone nonattainment areas that ha s the potential to emit greater than or equal to 25 tons/year of VOC, and equal to great er than 10 tons/year of VOC for

extreme ozone nonattainment areas. There are no ve hicle assembly plants in the District; therefore, this CTG will not be examined.

Alternative Control Technology (ACT)

EPA-453/R-94-017 1994/02 Alternative Control Techniques Document - Surface Coating of Automotive/Transportation and Business M achine Plastic Parts The ACT applies to the coating of plastic parts for the automotive industry, business machines, and other miscellaneous plastic parts. T he ACT identifies an automotive coating work practice standards, VOC content limits , application methods, and add-on

control efficiencies based on California District r ules as of 1994. Since SJVAPCD Rule 4612 is at least as stringent overall compared to o ther Districts (see analysis below in Section III), a detailed evaluation of the ACT is n ot necessary.

Federal New Source Performance Standards (NSPS) 40 CFR 60 Subpart MM (Standards of Performance for Automobile and Light Duty Truck Surface Coating Operations) applies to assemb ly plant coatings. There are no vehicle assembly plants in the Distric t; therefore, this NSPS will not be

examined.

National Emission Standards for Hazardous Air Pollu tants (NESHAPs) and Maximum Achievable Performance Standards (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 promulgatedSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis November 21, 2010

B-5 Final Staff Report with Appendice s For Proposed Amendments to Ru le 4612 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 issued to affe cted sources.

40 CFR 63 Subpart IIII (National Emission Standards for HAPs: Surface Coating of Automobiles and Light-Duty Trucks) The requirements in this subpart are not directly c omparable to the District Rule 4612

limits. The NESHAP HAP emission limits which are e xpressed in terms of % HAP, HAP emission concentration, and mass (kg) of HAP per ma ss (kg) of solids are not directly comparable to the coatings VOC limit which is expre ssed 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 VO Cs may be HAPs; therefore,

there is no direct correlation between the NESHAP l imits versus District Rule 4612 VOC

limits.

EPA Policy on Recordkeeping The recordkeeping requirement in Rule 4612 is consi stent with EPA’s policy to keep and maintain records for at least five years.

III. CONCLUSION

Based on the above analysis, District staff found t hat the proposed amendments to Rule 4612 would not conflict with federal rules, regulat ions, or policies covering similar stationary sources.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis November 21, 2010

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