SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 16, 2010 

B-1 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

APPENDIX B 

Emission Reduction Analysis 

September 16, 2010 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 16, 2010 

B-2 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

This page intentionally blank. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 16, 2010 

B-3 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

This appendix identifies the estimated volatile organic compound (VOC) emission 

reductions for proposed amendments to Rule 4653. These estimates are based on the 

best available information at the time that this report was written. 

I. SUMMARY 

The District’s 2007 Eight-Hour Ozone Plan (Ozone Plan) indentifies the 2008 baseline 

inventory of VOC emissions for the Adhesives (S-Sol-06) control measure to be 3.3 tons 

per day (tpd). The Ozone Plan commits the District to achieving a reduction of 0.12 

tons (3%) of VOC per day from this source category. However, the 2008 baseline 

emission inventory includes not only the adhesives and sealants, but the emissions 

from associated solvent cleaning operations and other activities at these operations as 

well. According to the 2007 Ozone Plan, the affected EIC codes for this source 

category include 250-292-8200; 250-292-8202; 250-292-8250. 

Table B-1 2007 Ozone Plan Baseline Emission Inventory (tpd) 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 3.2 3.3 3.5 3.6 3.9 4.1 4.3 4.9 

The ARB Almanac Emission Database for the EIC’s previously mentioned for 2008 was 

0.64 tpd of VOC. A 3% reduction from the current ARB emission inventory would be 

0.02 tpd VOC. The 2007 challenge of this emission reduction analysis is that neither 

the Ozone Plan nor the ARB database indicates what percentage of the emissions 

database is attributed to each adhesive product as discussed further in Section III 

(Emission Reduction Analysis) of this Appendix. 

This emission reduction analysis, using a conservative approach, estimates the 

emission reductions to be 18% of the baseline. When applied to the ARB emission 

inventory of 0.64 tpd VOC, emission reductions are estimated at 0.12 tpd VOC. 

Therefore, this rule-amending project exceeds the Ozone Plan commitment. Table B-2 

below illustrates the future predicted emission reductions based on this rule-amending 

project. 

Table B-2 Future Emission Reductions (tpd) 

Pollutant 2012 2014 2017 2020 2023 

VOC 0.12 0.12 0.13 0.14 0.15 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 16, 2010 

B-4 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

II. BACKGROUND 

District Rule 4653 (Adhesives) was adopted on March 17, 1994 and has since been 

amended six times. The most recent amendments were adopted by the District’s 

Governing Board in September 2009. The purpose of the 2007 rule amendtments were 

to adopt standards from the Environmental Protection Agency (EPA) Control 

Techniques Guidelines (CTG) for Industrial Adhesives. The EPA CTG for Industrial 

Adhesives was promulgated in September of 2008. The adopted 2009 Final Draft Staff 

Report for the proposed amendments to Rule 4653 stated, “Staff believe that no VOC 

emissions reductions will result from this rule-amending project.” As such, for this ruleamending project, staff will assume the amendments made during the previous ruleamendment project have not affected the emission inventory in the Ozone Plan and will 

assume the current baseline emission inventory is still current and correct. 

With this rule-amending project staff is proposing to increase the stringency of current 

VOC requirements for certain adhesive product categories, add new adhesives to rule 

language, and add sealants and sealant primers to rule language to make this rule as 

stringent as other adhesive and sealant rules in other air districts in California. 

The proposed VOC limits have been in rule language of adhesives rules in other air 

districts in California dating to 2002 for adhesive products and dating to 1998 for sealant 

products. Staff assumes that because of the size and quantity of other air districts in 

California and the number of years that have passed since enforcement that 

manufacturers are already selling these compliant products into the San Joaquin Valley Air 

Basin (SJVAB). Staff researched adhesive and sealant products found that compliant 

products are readily available. Therefore, staff assumes this is what businesses and 

operators in the SJVAB have available to them. It is important to note that staff did find 

products with VOC contents higher than the proposed VOC limits; however, these 

products are, in large, exempt from rule language. These products are exempt because 

they are either sold and supplied in 8 oz or less non-reusable containers, or are 

considered as household adhesive products subject to Article 2, Consumer Products and 

are therefore regulated by the Air Resources Board (ARB). 

The emission reductions accounted for in this Appendix for this rule-amending project are 

for SIP purposes only. As such, these emission reductions have never been accounted 

for in previous rule-amending projects or SIP submittals. Staff believes that in reality these 

emission reductions have already occurred. Staff believe this because the proposed VOC 

content limits for this rule-amending project have been in affect for up to twelve years in 

other air districts in California, and compliant products are already being sold in the 

SJVAB. 

The proposed VOC limits for specific adhesive categories affected by this rule-amending 

project are presented in Table B-3. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 16, 2010 

B-5 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Table B-3 Proposed Adhesive Product VOC Content Limits 

VOC Limit Effective on 

and after January 1, 2011 

VOC Limit Effective on 

Adhesive Category and after January 1, 2012 

(Grams per Liter) (Grams per Liter) 

Multipurpose Construction 200 70 

Ceramic Tile Adhesive 130 65 

Cove Base Installation 150 50 

Dry Wall and/or Panel Adhesive 200 50 

Ceramic Floor Tile Installation 130 65 

Indoor Carpet Adhesive 150 50 

Carpet Pad Adhesive 150 50 

Rubber Flooring Adhesive 150 60 

Subfloor Adhesive 150 50 

VCT and Asphalt Tile Adhesive 150 50 

Wood Flooring Adhesive 150 100 

Structural Wood Member Adhesive 200 140 

Contact Adhesive 250 80 

Traffic Marking Tape Adhesive/ Primer 250 150 

ABS Welding Adhesive 400 325 

Plastic Cement Welding Adhesive 

Primer 650 400 

Other Plastic Cement Welding Adhesive 450 250 

Table B-4 lists the proposed new adhesives categories. These adhesive products were 

not previously regulated by District Rule 4653 and are therefore new to regulation. 

These adhesive categories would be added to Table 2 of the proposed rule language. 

Table B-4 New Adhesive Categories to Rule Language 

VOC Limit Effective on 

and after January 1, 2011 

VOC Limit Effective on 

Adhesive Category and after January 1, 2012 

(Grams per Liter) (Grams per Liter) 

Non-Membrane Roof Adhesive n/a 300 

Motor Vehicle Weatherstrip Adhesive n/a 750 

Top and Trim Adhesive n/a 540 

Thin Metal Laminating Adhesive n/a 780 

Elastomeric Adhesive n/a 750 

Cellulosic Plastic Welding Adhesive n/a 100 

Styrene-Acrylonitrile Welding Adhesive n/a 100 

Automotive Glass Primer n/a 700 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 16, 2010 

B-6 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Table B-5 lists the proposed VOC content limits and the percent of VOC content limit 

reduction for adhesive products, from Table 3 of the proposed rule language that would 

be affected by this rule-amending project. 

Table B-5 Proposed VOC Content Limits and or Adhesive Products 

VOC Limit Effective on and 

after January 1, 2011 

VOC Limit Effective on and 

Material Bonded after January 1, 2012 

(Grams per Liter) (Grams per Liter) 

Porous Materials 120 50 

Plastic Foam 120 50 

Fiberglass 250 80 

Staff will not claim emission reductions from this source category at this time. The VOC 

content of sealants and sealant primers has been established and enforced in other air 

districts in California for up to twelve years. Therefore, staff assumes the currently sold 

sealants in the SJVAB have compliant VOC content limits. 

Table B-6 VOC Content Limits for Sealants and Sealant Primers 

VOC Limit Sealant Product (g/l) 

Architectural Sealant 250 

Architectural Non Porous Sealant Primer 250 

Architectural Porous Sealant Primer 775 

Marine Deck Sealant and Sealant Primer 760 

Modified Bituminous Sealant Primer 500 

Non-Membrane Roof Sealant 300 

Single-Ply Roof Sealant 450 

Roadway Sealant 250 

Other Sealants 420 

Other Sealant Primers 750 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 16, 2010 

B-7 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

III. EMISSION REDUCTION ANALYSIS 

A. ARB Emissions Inventory 

According to the ARB Cleaning and Surface Coating Methodologies Section 3.7 – 

Adhesives and Sealants document, the ARB determines the emissions from this source 

category by first determining the nationwide emissions from this source category, and 

then apportioned the appropriate percentage of those emissions to California. Finally, 

ARB distributed the emissions inventory to each county within California. Also, the ARB 

emissions inventory database states that the 2008 annual average baseline emissions 

from adhesives includes sealants, as confirmed by the ARB Cleaning and Surface 

Coating Methodologies Section 3.7 – Adhesives and Sealants. 

The ARB’s methodology is as follows: The emissions from sealants and adhesives are 

broken into two subcategories; solvent-based products and water-based products. Data 

for the emission estimates were taken from the Decision Resources article titled 

“Outlook for the U.S. Adhesives and Sealants Industry” and from the SAIC report titled 

“Development and Improvement of Organic Compound Emissions Inventory for 

California”. ARB uses the assumption that production equals usage. Based on the 

SAIC report, California’s use of national production of adhesives and sealants was 12.3 

percent of the national total. For information regarding how ARB determined the 

emission factors please refer to the ARB Cleaning and Surface Coating Methodologies 

Section 3.7 – Adhesives and Sealants document. ARB distributed statewide emission 

estimates to the counties based on construction trends of new non-residential and 

residential buildings in California. 

ARB’s methodology included the following assumptions: 

1. Production of adhesives and sealants equals usage. 

2. Data from Decision Resources and the SAIC report are reasonable bases for 

estimating usage of adhesives and sealants. 

3. Two categories are accounted for in the point source inventory: packaging and 

wood converting (forest products). 

4. Statewide emission estimates can be distributed to counties based on new nonresidential and residential construction trend data for each county in California. 

5. Emission factors derived from the SAIC report, the EPA report, the Decision 

Resources article, and a conversation with Henry J. Buccigross of Decision 

Resources are the most accurate and reliable data available at this time. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 16, 2010 

B-8 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

B. SJVAPCD Emission Reduction Analysis 

The ARB methodology for determining and distributing emissions from this source 

category, as explained above, does not specify the emissions from each individual type 

of adhesive product and sealant product. As such, District staff are unable to determine 

what percentage of emissions are generated from each adhesive and sealant product 

category. 

Staff began the emission reduction analysis by determining the percent of VOC 

reduction from each category of adhesive with a proposed VOC content limit that is 

more stringent than limits effective on and after January 1, 2011. As such, as 

previously mentioned, staff assumes that sealants and sealant primers sold in the 

SVJAB are compliant with proposed VOC content limit standards. Supporting this 

assumption is the fact that these products have been regulated and sold in other air 

districts in California at the proposed VOC limits for up to twelve years. As such, staff 

will assume no emission reductions from the addition of each sealant and sealant 

primer category to rule language. For purposes of performing a conservative estimate 

for this analysis, staff will not account for emission reductions from the addition of new 

adhesive categories. 

Table B-7 lists each adhesive product and sealant product category from tables two and 

three from the proposed rule language and the percent of VOC content reduction from 

each category. For purposes of this emission reduction analysis staff assume that the 

percentage of VOC content reductions are equivalent to the percentage of VOC 

emission reductions. 

The percentage of reduction of VOC content was calculated using the following 

equation: 

% Reduction = 















Current VOC limit

Current VOC limit - Proposed VOC limit

For example, the current VOC content limit for Multipurpose Construction Adhesive is 

200 g/l with a proposed limit of 70 g/l. 

% Reduction = 















200 g/l

200 g/l - 70 g/l

 = 65% 

Assuming the % reduction in VOC content is equivalent to the % reduction of VOC 

emissions. The Multipurpose Construction Adhesive source category will see a 65% 

reduction in VOC emissions. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 16, 2010 

B-9 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Adhesive and Sealant Products with Proposed VOC Content 

 Table B-7 Limits and Percentages of VOC Content Reductions 

VOC Limit Effective 

on and after January 

1, 2011 

VOC Limit Effective 

on and after 

January 1, 2012 

Adhesive Product - New 

Proposed VOC Content Limits 

(Grams per Liter) (Grams per Liter) 

Percent 

VOC 

Content 

Reduction 

Multipurpose Construction 200 70 65% 

Ceramic Tile Adhesive 130 65 50% 

Cove Base Installation 150 50 67% 

Dry Wall and/or Panel Adhesive 200 50 75% 

Ceramic Floor Tile Installation 130 65 50% 

Indoor Carpet Adhesive 150 50 67% 

Carpet Pad Adhesive 150 50 67% 

Rubber Flooring Adhesive 150 60 60% 

Subfloor Adhesive 150 50 67% 

VCT and Asphalt Tile Adhesive 150 50 67% 

Wood Flooring Adhesive 150 100 33% 

Structural Wood Member Adhesive 200 140 30% 

Contact Adhesive 250 80 68% 

Traffic Marking Tape Adhesive/ 

Primer 250 150 40% 

ABS Welding Adhesive 400 325 19% 

Plastic Cement Welding Adhesive 

Primer 650 400 38% 

Other Plastic Cement Welding 

Adhesive 450 250 44% 

Porous Materials 120 50 58% 

Plastic Foam 120 50 58% 

Fiberglass 250 80 68% 

Adhesive Product - New to Rule Language 

Motor Vehicle Weatherstrip 

Adhesive n/a 750 0% 

Non-Membrane Roof Adhesive n/a 300 0% 

Top and Trim Adhesive n/a 540 0% 

Thin Metal Laminating Adhesive n/a 780 0% 

Elastomeric Adhesive n/a 750 0% 

Cellulosic Plastic Welding Adhesive n/a 100 0% 

Styrene-Acrylonitrile Welding 

Adhesive n/a 100 0% 

Automotive Glass Primer n/a 700 0% 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 16, 2010 

B-10 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Adhesive and Sealant Products with Proposed VOC Content 

Table B-7 Limits and Percentages of VOC Content Reductions (continued)

VOC Limit Effective 

on and after January 

1, 2011 

VOC Limit Effective 

on and after January 

1, 2012 

Adhesive Product - No Proposed 

Change to VOC Content Limits 

(Grams per Liter) (Grams per Liter) 

Percent 

VOC 

Content 

Reduction

Floor Covering Installation 150 150 0% 

Outdoor Carpet 150 150 0% 

Perimeter Bonded Sheet Flooring 660 660 0% 

Single-Ply Roof Material Installation 250 250 0% 

Structural Glazing 100 100 0% 

Contact Adhesive-Specialty 250 250 0% 

Rubber Vulcanization 

Adhesive/Primer 850 850 0% 

Tire Retread 100 100 0% 

Motor Vehicle Adhesive 250 250 0% 

Waterproof Resorcinol Glue 170 170 0% 

Staple and Nail Manufacturing 640 640 0% 

Flexible Vinyl 250 250 0% 

CPVC Welding 490 490 0% 

PVC 500 500 0% 

Adhesive Primer 250 250 0% 

Adhesive Product - No change to VOC Content Limit 

Metal to metal 30 30 0% 

Wood 30 30 0% 

Pre-formed Rubber 250 250 0% 

Reinforced Plastic Composite 200 200 0% 

All other substrates 250 250 0% 

Sealant Product - New to Rule Language 

Architectural Sealant n/a 250 0% 

Marine Deck Sealant n/a 760 0% 

Non-membrane Roof Sealant n/a 300 0% 

Roadway Sealant n/a 250 0% 

Single-Ply Roof Membrane Sealant n/a 450 0% 

Other Sealants n/a 420 0% 

Architectural Non Porous Sealant 

primer n/a 250 0% 

Architectural Porous Sealant Primer n/a 775 0% 

Modified Bituminous Sealant Primer n/a 500 0% 

Marine Deck Sealant Primer n/a 760 0% 

Other Sealant Primers n/a 750 0% 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 16, 2010 

B-11 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

For purposes of this emission reduction analysis staff assume the percentage of VOC 

content reduction is equivalent to the percentage of emission reductions from each 

adhesive product. Staff is using a conservative approach to emission reductions 

claimed. As such, staff assumes that all emissions from this source category are 

distributed evenly between each type of adhesive and sealant product category. Staff 

determined the emission reduction using the following methodology. 

Staff averaged the percentage of emission reductions from all 59 adhesive product and 

sealant product categories. 

1. Determine the total percentage of emission reductions. Add the 59 percentages 

from column three “Percent VOC Content Reduction” in Table B-7. 

1091% 

2. Average the total percentage of emission reductions by all 59 adhesive product 

and sealant product categories. 

1091% / 59 = 18% 

3. Apply the percent VOC content reductions to the adjusted future emission 

reductions, as explained in Section III.C (Future Emission Reductions) of this 

Appendix. 

It is important to note that this is a conservative emission reduction estimate. A less 

conservative approach would be to apply the percentage of emission reductions to the 

28 adhesive product categories with new VOC limits. Using the less conservative 

methodology, the emission reduction percentage would be a much higher 38%. Staff 

reiterate that the emission reductions accounted for in this Appendix for this ruleamending project are for SIP purposes.

C. Future Emission Reductions 

Future emission reductions were calculated using the following methodology: 

1. Using 2008 information, determine what the percentage of reported VOC emissions 

from this source category, as reported in the Ozone Plan, are attributed to the 

actual adhesives and sealants from the specified ARB emission data for the source 

category. This is accomplished by dividing the 2008 Ozone Plan emission 

inventory of 0.64 tpd by the 2008 ARB emission inventory for the specified EIC 

codes of 3.3 tpd 

0.64 tpd / 3.3 tpd = 19% 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 16, 2010 

B-12 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

2. Determine the amount of emissions from specified EIC codes. Apply the 

percentage of emissions from adhesives and sealants from the specified EIC code 

(19%) to future predicted emissions from the Ozone Plan. 

0.19 X 

= 

3. Determine future emission reductions. Multiply the emissions, as determined in 

step C.2 of this analysis by the 18% conservative reduction from step B.2 of this 

analysis. 

 0.18 X 

= 

Pollutant 2011 2012 2014 2017 2020 2023

VOC 3.5 3.6 3.9 4.1 4.3 4.9 

Pollutant 2011 2012 2014 2017 2020 2023

VOC 0.67 0.68 0.74 0.78 0.82 0.93 

Pollutant 2011 2012 2014 2017 2020 2023

VOC 0.67 0.68 0.74 0.78 0.82 0.93 

Pollutant 2011 2012 2014 2017 2020 2023

VOC 0.12 0.12 0.13 0.14 0.15 0.17