UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

South Coast Air Quality Management District, Rule 1162, Polyester Resin Operations

Prepared by: David Grounds Reviewed by: Andrew Steckel January 10, 2011RULE IDENTIFICATION

Agency : South Coast Air Quality Management District (SCAQMD)

SIP Approved Rule : Rule 1162

– Polyester Resin Operations Adopted

– November 17, 2000
Submitted

– March 14, 2001 EPA Approved

– February 12, 2002 (67 FR 6410)

Subject of this TSD : Rule 1162

– Polyester Resin Operations Adopted

– July 8, 2005
Submitted

– April 6, 2009

RULE SUMMARY

– SCAQMD Rule 1162, Poly ester Resin Operations, is a rule that limits volatile organic compound (VOC) emissions during the manufacturing, fabrication, rework, repair, and touch up of composite products made of polyester resin and gel coat. SCAQMD regulates an
extreme 8

- hour ozone non

- attainment area , and S C AQMD designed Rule 1162 partly to address the requirements for ozone non

- attainment areas as described in Clean Air Act (CAA) section 182( e ).

The significant changes in Rule 1162 relative to the SIP approved rule include:
1. Expanded applicability to include automotive, aircraft, and aerospace components.
2. Added several definitions to improve clarity.
3. Lowered monomer content in polyester resins.

4. Listed specific application techniques for resins and gel coats.
5. Lowered weight lo ss from VOC emissions for vapor suppressed resins.
6. Expanded test methods.

7. Added a small usage exemption for the application of pin striping gel coat.

EPA EVALUATION CRITERIA

- The following criteria were used to evaluate the submitted Rule
1162:

1. Enforceability

– Section 110(a)(2)(A) of the CAA requires that regulations submitted to EPA for incorporation into the SIP must be clear and legally enforceable.

2. Reasonably Available Control Technology ( RACT )

– “ Control Techniques Guidelines for Industrial Cleaning Solvents” (EPA

- 453/R

- 06

- 001 , 9/ 06), “ Control of VOC Emissions from Manufacture of High

- Density Polyethylene, Polypropylene, and Polystyrene Resins ”(EPA

- 450/3

- 83

- 008, 11/83 )

, “ Control of VOC Fugitive Emissions from Synthetic Organic

Ch emical Polymer and Resin Manufacturing Equipment ” (EPA

- 450/3

- 83

- 006, 3/84 ), “Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials” (EPA

453/R

- 08

- 004 , 9/08 ), CARB’s RACT/BARCT guidance titled, “Organic Solvent Cleaning and Degreasing Op erations” (July 18, 1991), and other state and local rules for this category were used to help evaluate the RACT requirements of CAA § 182( e ).

3. SIP Relaxation

– Where previous versions of rules have been SIP approved, new submittals must comply with CAA §110(l) and §193 regarding SIP relaxations.

EPA EVALUATION

– The submitted SCAQMD Rule 1162 is more stringent than the approved SIP, largely beca use of the lowered monomer content of resins and l owered weight loss from VOC emissions for vapor suppressed resins. The current SIP submittal generally contains sufficient testing and recordkeeping requirements to satisfy enforcement requirements. The str ingency of requirements in submitted Rule 1162 is also generally consistent with relevant national guidance and analogous rules in other areas that help define RACT

.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 1162 sufficient for EPA to propose less than full approval.

RECOMMENDATIONS

- The following revisions are not currently the basis for rule disapproval,
but are recommended for the next time the rule is amende d.

In Sections c(1)(A) and c(1)(B), we recommend removing the old effective dates. In Section e(1), we recommend requiring record retention on

- site for five years, consistent with Title V requirements and to improve compliance and enforceability. We

note that Bay Area Air Quality Management District (BAAQMD) Regulation 8, Rule 50, Section 502.3 requires record retention for three years. We recommend adding a new section for surface preparation and cleaning products. See for example, BAAQMD, Regulation 8, R ule 50, Section 305.

EPA ACTION

– Rule 1162 largely fulfills the relevant CAA §110 and part D requirements. EPA staff recommends full approval of Rule 1162 pursuant to CAA §110(k)(3) and §301(a).

REFERENCES

– SCAQMD Rule 1162, “Polyester Resin Operations,” Adopted July 8, 2005

. Rule 1162 Final Staff Report, July 8, 2005

. SCAQMD Rule 1162, “Polyester Resin Operations,” Adopted November 17, 2000

. BAAQMD
, Rule 50, “ Polyester Resin Operations .”