SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis September 16, 2010

B-1 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 

## APPENDIX B

Emission Reduction Analysis

September 16, 2010SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis September 16, 2010

B-2 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis September 16, 2010

B-3 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 This appendix identifies the estimated volatile org anic compound (VOC) emission reductions for proposed amendments to Rule 4653. T hese estimates are based on the best available information at the time that this re port was written.

I. SUMMARY

The District’s 2007 Eight-Hour Ozone Plan (Ozone Pl an) 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 oth er activities at these operations as well. According to the 2007 Ozone Plan, the affect ed EIC codes for this source category include 250-292-8200; 250-292-8202; 250-29 2-8250.

Table B-1 2007 Ozone Plan Baseline Emission Invent ory (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 pre viously mentioned for 2008 was 0.64 tpd of VOC. A 3% reduction from the current A RB 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 conservat ive approach, estimates the emission reductions to be 18% of the baseline. Whe n 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 O zone Plan commitment. Table B-2 below illustrates the future predicted emission red uctions 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 0.15SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis September 16, 2010

B-4 Final Staff Report with Appendices For Proposed Amendments to Ru le 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 Protectio n Agency (EPA) Control Techniques Guidelines (CTG) for Industrial Adhesive s. The EPA CTG for Industrial Adhesives was promulgated in September of 2008. Th e adopted 2009 Final Draft Staff Report for the proposed amendments to Rule 4653 sta ted, “Staff believe that no VOC emissions reductions will result from this rule-ame nding project.” As such, for this ruleamending project, staff will assume the amendments made during the previous ruleamendment project have not affected the emission in ventory in the Ozone Plan and will assume the current baseline emission inventory is s till current and correct.

With this rule-amending project staff is proposing to increase the stringency of current VOC requirements for certain adhesive product categ ories, add new adhesives to rule language, and add sealants and sealant primers to r ule language to make this rule as stringent as other adhesive and sealant rules in ot her 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 a nd quantity of other air districts in California and the number of years that have passed since enforcement that manufacturers are already selling these compliant p roducts into the San Joaquin Valley Air Basin (SJVAB). Staff researched adhesive and seala nt products found that compliant products are readily available. Therefore, staff a ssumes 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 n on-reusable containers, or are considered as household adhesive products subject t o Article 2, Consumer Products and are therefore regulated by the Air Resources Board (ARB).

The emission reductions accounted for in this Appen dix for this rule-amending project are for SIP purposes only. As such, these emission red uctions have never been accounted for in previous rule-amending projects or SIP submi ttals. Staff believes that in reality these emission reductions have already occurred. Staff b elieve 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 pr oducts are already being sold in the SJVAB.

The proposed VOC limits for specific adhesive categ ories affected by this rule-amending project are presented in Table B-3.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis September 16, 2010

B-5 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 Table B-3 Proposed Adhesive Product VOC Content Li mits

VOC Limit Effective on and after January 1, 2011 VOC Limit Effective on and after January 1, 2012 Adhesive Category (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 categori es. 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 and after January 1, 2012 Adhesive Category (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 700SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis September 16, 2010

B-6 Final Staff Report with Appendices For Proposed Amendments to Ru le 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 th e proposed rule language that would be affected by this rule-amending project.

Table B-5 Proposed VOC Content Limits and or Adhes ive Products VOC Limit Effective on and after January 1, 2011 VOC Limit Effective on and after January 1, 2012 Material Bonded (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 es tablished and enforced in other air districts in California for up to twelve years. Th erefore, staff assumes the currently sold sealants in the SJVAB have compliant VOC content li mits.

Table B-6 VOC Content Limits for Sealants and Seal ant 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 750SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis September 16, 2010

B-7 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 III. EMISSION REDUCTION ANALYSIS

A. ARB Emissions Inventory

According to the ARB Cleaning and Surface Coating Methodologies Sect ion 3.7 – Adhesives and Sealants document, the ARB determines the emissions from th is source category by first determining the nationwide emissi ons from this source category, and then apportioned the appropriate percentage of thos e emissions to California. Finally, ARB distributed the emissions inventory to each cou nty within California. Also, the ARB emissions inventory database states that the 2008 a nnual average baseline emissions from adhesives includes sealants, as confirmed by t he ARB Cleaning and Surface Coating Methodologies Section 3.7 – Adhesives and S ealants

.
The ARB’s methodology is as follows: The emissions from sealants and adhesives are broken into two subcategories; solvent-based produc ts and water-based products. Data for the emission estimates were taken from the Deci sion Resources article titled “Outlook for the U.S. Adhesives and Sealants Indust ry” and from the SAIC report titled “Development and Improvement of Organic Compound Em issions Inventory for California”. ARB uses the assumption that producti on equals usage. Based on the SAIC report, California’s use of national productio n of adhesives and sealants was 12.3 percent of the national total. For information reg arding 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 tre nds of new non-residential and residential buildings in California.

ARB’s methodology included the following assumption s:

1. Production of adhesives and sealants equals usag e. 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 so urce 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, t he EPA report, the Decision Resources article, and a conversation with Henry J. Buccigross of Decision Resources are the most accurate and reliable data a vailable at this time.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis September 16, 2010

B-8 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 B. SJVAPCD Emission Reduction Analysis

The ARB methodology for determining and distributin g 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 eac h adhesive and sealant product category.

Staff began the emission reduction analysis by dete rmining the percent of VOC reduction from each category of adhesive with a pro posed VOC content limit that is more stringent than limits effective on and after J anuary 1, 2011. As such, as previously mentioned, staff assumes that sealants a nd sealant primers sold in the SVJAB are compliant with proposed VOC content limit standards. Supporting this assumption is the fact that these products have bee n 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 additio n 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 emiss ion reductions from the addition of new adhesive categories.

Table B-7 lists each adhesive product and sealant p roduct category from tables two and three from the proposed rule language and the perce nt of VOC content reduction from each category. For purposes of this emission reduc tion 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 calc ulated using the following equation:

% Reduction =        

limit

VOC Current limit

VOC Proposed - limit VOC Current

For example, the current VOC content limit for Mult ipurpose Construction Adhesive is 200 g/l with a proposed limit of 70 g/l.

% Reduction =        
g/l 200 g/l 70 - g/l 200

= 65%

Assuming the % reduction in VOC content is equivale nt 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 DI STRICT

Appendix B: Emission Reduction Analysis September 16, 2010

B-9 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 Adhesive and Sealant Products with Proposed VOC Con tent 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 DI STRICT

Appendix B: Emission Reduction Analysis September 16, 2010

B-10 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 Adhesive and Sealant Products with Proposed VOC Con tent Table B-7 Limits and Percentages of VOC Content Red uctions (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 DI STRICT

Appendix B: Emission Reduction Analysis September 16, 2010

B-11 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 For purposes of this emission reduction analysis st aff assume the percentage of VOC content reduction is equivalent to the percentage o f emission reductions from each adhesive product. Staff is using a conservative ap proach to emission reductions claimed. As such, staff assumes that all emissions from this source category are distributed evenly between each type of adhesive an d sealant product category. Staff determined the emission reduction using the followi ng methodology.

Staff averaged the percentage of emission reduction s from all 59 adhesive product and sealant product categories.

1. Determine the total percentage of emission reduc tions. Add the 59 percentages from column three “Percent VOC Content Reduction” i n Table B-7.

1091%

2. Average the total percentage of emission reducti ons 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 E mission 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 percent age of emission reductions to the 28 adhesive product categories with new VOC limits. Using the less conservative methodology, the emission reduction percentage woul d be a much higher 38%. Staff reiterate that the emission reductions accounted fo r in this Appendix for this ruleamending project are for SIP purposes.

C. Future Emission Reductions

Future emission reductions were calculated using th e following methodology:

1. Using 2008 information, determine what the perce ntage 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 AR B emission data for the source category. This is accomplished by dividing the 200 8 Ozone Plan emission inventory of 0.64 tpd by the 2008 ARB emission inve ntory for the specified EIC codes of 3.3 tpd

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

Appendix B: Emission Reduction Analysis September 16, 2010

B-12 Final Staff Report with Appendices For Proposed Amendments to Ru le 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 r eduction 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