Final Staff Report with Appendices for Amendments

to Rule 4603 and Rule 4684 SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

FINAL STAFF REPORT

Amendments to: Rule 4603 (Surface Coating of Metal Parts and Pr oducts)

Rule 4684 (Polyester Resin Operations)

September 17, 2009

Prepared by: Joven R. Nazareno, Senior Air Quality Engineer

Reviewed by: George Heinen, Rule Development Superv isor

Errol Villegas, Planning Manager

I. SUMMARY

A. Reasons for Rule Development and Implementation

The United States Environmental Protection Agency ( EPA) and the California Air Resources Board (ARB) classified the San Joaquin Valley Air B asin (SJVAB) as a serious and severe

non-attainment area for the federal and state ozone standards, respectively. Clean Air Act (CAA) section 172 (2)(1) provides that state implem entation plans (SIPs) for nonattainment areas must include reasonably available control tec hnology (RACT), for sources of emissions. Section 182 (b)(2) provides for certain nonattainment areas, States must revise

their SIPs to include RACT for sources of VOC emiss ions covered by all Control Techniques Guidelines (CTG) documents issued after November 15 , 1990 and prior to the area’s date of

attainment.

CAA section 183(e) directs EPA to list for regulati on those categories of products that account for at least 80 percent of the VOC emission s, on a reactivity-adjusted basis, from consumer and commercial products in areas that viol ate the national ambient air quality standards (NAAQS) for ozone (i.e., ozone nonattainm ent areas). EPA issued the list on March 23, 1995, and continues to revise the list pe riodically. In September 2008, EPA promulgated a new CTG for Miscellaneous Metal and P lastic Parts Coatings (EPA453/R08/003) and a new CTG for Fiberglass Boat Manu facturing Materials (EPA-453/R08-004). CAA section 182(b)(2) requires that a CTG issued between November 15, 1990, and the date of attainment include the date by whic h States subject to section 182(b) must submit SIP revisions in response to the CTG. EPA i s providing, in said CTGs, a one-year period for the required submittal.

B. Description of the Rule Development Project

The sole purpose of this rule development project i s to amend Rule 4603 (Surface Coating of Metal Parts and Products) and Rule 4684 (Polyest er Resin Operations) to implement RACT requirements as recommended in the CTG for Mis cellaneous Metal and Plastic Parts Coatings (EPA-453/R08/003) and the CTG for Fi berglass Boat ManufacturingSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 Materials (EPA-453/R-08-004) promulgated by EPA in September 2008, as required by

the CAA. The CTG for Miscellaneous Metal and Plas tic Products would be incorporated into Rule 4603 and the CTG for Fiberglass Boat Manu facturing will be incorporated into Rule 4684. The CTGs contains VOC content limits, V OC control device efficiency, and work practice standards tor educe VOC emissions fro m these source categories. The

CTG standards are discussed in Section III of this Final Draft Staff Report.

In developing a CTG, EPA, among other things, evalu ates the sources of VOC emissions from application processes and the available contro l approaches for addressing these emissions, including the costs of such approaches. Based on available information and data, EPA provides recommendations for RACT for mis cellaneous metal and plastic products and for fiberglass boat manufacturing mate rials. EPA considers the CTGs to be presumptive RACT standards (63 FR 15015, 3/27/98); therefore, the rules will be

considered RACT after amendments to include the lat est CTG requirements.

II. BACKGROUND

A. Existing Rule 4603 (Surface Coating of Metal Par ts and Products)

Rule 4603 was last amended in October 2008, which i ncorporated the 2007 CTG for large appliances coatings and 2007 CTG for metal furnitur e coatings. The rule applies to the surface coating of metal parts and products, large appliances parts and products, and metal furniture, as well as the solvent cleaning ac tivities associated with coating operations. The purpose of the rule is to limit VO C emissions from coating of metal parts and products, large appliances parts and products, and metal furniture, and from organic cleaning, storage and disposal of solvents and wast e solvent materials associated with such coating application and solvent cleaning opera tions.

The rule specifies separate VOC limits for each cat egory of coatings depending on the type of product being coated. The existing rule does no t include surface coating of plastic parts and products, and pleasure crafts. The 2008 CTG f or miscellaneous metal products included surface coating of plastic products and pl easure crafts. Rather than developing a separate rule, the surface coating of plastic produ cts and pleasure crafts would be incorporated into Rule 4603 consistent with the app licability intent of the CTG.

Rule 4603 allows certain exemptions from the rule o r from the coating VOC content limits. For example, a facility is exempt from the VOC cont ent limits of the rule if the amount of coatings used does not exceed a total of 55 gallons of non-compliant coatings per rolling consecutive 365-day period, provided the operator c omplies with the coating application methods and administrative requirements such as rec ordkeeping. Also coating operations that are subject to other District coating rules su ch as Rule 4661 (Organic Solvents), Rule 4602 (Motor vehicle and Mobile Equipment Coating Op erations), Rule 4612 (Motor Vehicle and Mobile Equipment Operations Phase II), and Rule 4605 (Aerospace Assembly andSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 Component Manufacturing Operations) Rule 4604 (Can and Coil Coating Operations). Additional exemptions from the rule includes coatin g operation involving touch-up and repair, polyester resin operations and the applicat ion of polyester resin to metal parts and products. The rule also contains certain exemption s for solvent cleaning operations.

Rule 4603 establishes VOC content limits for coatin gs used in the manufacture and fabrication of metal parts and products. Except fo r coatings used on large appliances parts and products, and metal furniture coating ope rations , the general VOC limits for baked coating and for air-dried coating is 275 gram s per liter (2.3 pounds/gallon) and 340 grams/liter (2.8 pounds/gallon), respectively. Bot h limits are expressed weight of VOC/volume of coating, less water and less exempt c ompounds, as applied. The VOC limits for specialty coatings ranging from 360 gram s/liter (3.0 pounds/gallon) to 880 grams/liter (7.3 pounds/gallon) depending on the ca tegory of coating. Specialty coating category includes camouflage, extreme performance, heat resistant, high gloss, high performance architectural, high temperature, metall ic topcoat, pretreatment primer, silicone release, solar absorbent, and solid film l ubricant. It is important to mention that if a certain coating type is not included under any of the listed specialty coating category, then the VOC limit for such coating is defaulted to the general coatings’ VOC limit (i.e., the general VOC limits for baked coating and for air-dr ied coating is 275 grams per liter (2.3 pounds/gallon) and 340 grams/liter (2.8 pounds/gall on), respectively.

The VOC limits for coatings used on large appliance s parts and products, and metal furniture coating operations range from 275 grams/l iter (2.3 lb/gal) to 420 grams/liter (3.5 lb/gallon) depending on the type of coating applied and whether it is air-dried or baked. The coating types for large appliances parts and pr oducts, and metal furniture coating specified in the rule includes general one componen t, general, multi-component, extreme performance, heat resistant, metallic, pretreatment coating, and solar absorbent. As mentioned above, if a certain coating type is not i ncluded under any of the listed coating category for large appliances and metal furniture c oating category, then the VOC limit for such coating is defaulted to the general coatings’ VOC limit (i.e., the general VOC limits for baked coating and for air-dried coating is 275 grams per liter (2.3 pounds/gallon) and 340 grams/liter (2.8 pounds/gallon), respectively.

In lieu of complying with the applicable coating VO C limits, an operator may use an APCO-approved VOC emission control system provided it is under District permit, has an overall capture and control efficiency of at least 90 percent by weight, and the emissions resulting from the use of the control system would not result in emissions in excess of those that would have been achieved had the operato r complied with the VOC content limits of the coating or solvents. In addition to the coatings VOC limits, the rule also include provisions for coating application methods, which include electrostatic application, electrodeposition, high-volume, low-pressure (HVLP) spray equipment, flow coating, roll coating dip coating, brush coating or other applica tion method demonstrated to the District as capable of achieving at least 65 percent transfe r efficiency.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 Rule 4603 establishes work practice standards only for large appliances parts and products, and metal furniture coating operations pu rsuant to EPA CTGs for such source categories. The current rule’s work practice stand ards for coating operations only apply to large appliances and metal furniture coating operat ions but not to other metal parts and products coating operations. The rule also include s organic solvent cleaning requirements. The current VOC content limits for o rganic solvent cleaning materials is 25 grams/liter (0.21 pound/gallon) for all types of cl eaning operations. Also, the rule includes administrative requirements such as coating product labeling, recordkeeping, and test methods to demonstrate compliance with the emission standards of the rule.

B. Existing Rule 4684 (Polyester Resin Operations)

Rule 4684 was adopted on May 19, 1994. The rule ha s undergone two amendments with the last occurring on September 20, 2007. The Sept ember 2007 rule amendments implemented the Best Available Retrofit Control Tec hnology (BARCT) standards for organic solvent cleaning operations, pursuant to th e California Health and Safety Code. The purpose of the rule is to limit VOC emissions f rom polyester resin operations and from organic solvent cleaning, storage and disposal of s olvents and waste solvent materials associated with such operations. The rule applies to commercial and industrial polyester resin operations. Polyester resin operations is de fined in the rule as methods used for the production or rework of products by mixing, pouring , hand layup, impregnating, injecting, forming, winding, spraying, and/or curing with fibe rglass, filers, or other reinforcement materials and associated cleanup.

Rule 4684 exempts facilities that use less than 20 gallons per month of polyester resin, provided the operator keeps the records required by the rule to demonstrate exemption status. Also exempt from the organic cleaning requ irements of the rule are cleaning of solar cells, laser hardware, scientific instruments , or high precision optics. Cleaning in laboratory tests and analyses, or bench scale or re search and development projects is also exempt from the organic cleaning requirements of the rule.

Rule 4684 allows an operator to choose one of three compliance methods. One option is to use low-VOC polyester resins ranging from 35% to 50% by weight monomer content depending on the type of resin or gel coat. The se cond option is to use resins containing vapor suppressant wherein the weight loss from VOC emissions does not exceed 60 grams per square meter of exposed surface during re sin polymerization. The third option is to operate an APCO-approved VOC emission control system that achieves an overall capture and control efficiency of at least 85 perce nt by weight.

Rule 4684 requires that spray application of resins be performed using airless, airassisted airless, high-volume low-pressure spray eq uipment, or electrostatic spray equipment. In lieu of using the specified spray eq uipment, the operator may comply by operating an APCO-approved VOC emission control sys tem around the applicationSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 operation, provided the control system achieves an overall capture and control efficiency of at least 85 percent by weight. Rule 4684 requires operators to use organic solvent cleaning materials that contain no more than 25 grams/liter (0.21 pound/gallon) for al l types of cleaning operations. Also, the rule includes administrative requirements such as r ecordkeeping and test methods to demonstrate compliance with the emission standards of the rule.

For detailed requirements, please refer to the curr ent Rules 4603 and 4684, which are available on the District’s website at www.valleyai r.org.

III. EPA CTG for Miscellaneous Metal and Plastic Pa rts (EPA-453/R-08-003, September 2008)

In September 2008, EPA issued the CTG for miscellan eous metal and plastic parts coatings. The CTG applies to facilities where the total actual VOC emissions, including related cleaning activities, from all miscellaneous metal parts and products, miscellaneous plastic parts and products, and pleasure crafts at the facility are equal to or exceed 6.8 kilograms per day (15 pounds per day), or an equiva lent level of 2.7 tons per 12-month rolling period, before consideration of controls. The recommended threshold level is equivalent to the evaporation of approximately two gallons of solvent per day. EPA does not recommend the CTG standards apply to facilities that emit less than this level because of the very small reductions that can be achieved.

CTG considers miscellaneous metal products and plas tic products to include, but are not limited to, metal and plastic components of the fol lowing types of products as well as the products themselves: fabricated metal products, mo lded plastic parts, small and large farm machinery, commercial and industrial machinery and equipment, automotive and transportation equipment, interior or exterior auto motive parts, construction equipment, motor vehicles, pleasure crafts (recreational boats ), extruded aluminum structural components, railroad cars, heavier vehicles, lawn a nd garden equipment, business machines, laboratory and medical equipment, electro nic equipment, steel drums, metal pipes, and numerous other industrial and household products. This CTG does not apply to other types of coating operations that are subje ct to other CTGs, such as fiberglass boat glass manufacturing for which a separate CTG w as published by EPA in September

2008.

The CTG for miscellaneous metal and plastic parts a nd products includes VOC coating limits for miscellaneous metal parts and products, plastic parts and products, automotive/transportation and business machine plas tic parts, pleasure crafts, and motor

vehicles.

The following discussions are excerpts from the pro visions of the CTG: Process Description and Sources of VOC EmissionsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 Application of coatings on metal or plastic parts a nd products serve decorative, protective, and functional purposes. The coatings on the subst rates of metal parts and products protect them from corrosion by providing resistance to moisture, heat, and outdoor elements. Coating plastic parts and products provi des color, texture, or protection which improves appearance and durability, and can also fu nction to attenuate electromagnetic interference/radio interference (EMI/RFI) signals, and to hide mold lines and flaws in the

substrate surface.

The three main process operations in the metal and plastic parts and products coating application process are surface preparation, coatin g application, and cleaning activities. All three operations use VOC-containing materials ( coatings, thinners, and cleaning materials). Surface preparation is performed to co rrect any flaws in the part prior to coating, and to prepare the part to receive the coa ting. There are several different steps involve in the cleaning process of metal parts such as acid or alkaline cleaning, water rinse, phosphate treatment, water rinse, and pretre atment and/or water rinse, and finally drying the parts in an oven. For plastic parts or products, some sanding may be done to remove burrs or other inconsistencies besides putty ing to fill any gaps or small cracks in the plastic part. For pre-primed plastic parts, sp ot primer may be applied to any areas missing primer or with an inconsistent primer appli cation. After pretreatment, any remaining residue must be removed, typically, by wi ping of the dust with water or alcohol soaked rugs.

Coatings are applied using different methods such a s conventional air spray, airless spray, air-assisted airless spray, electrostatic spray, hi gh volume low pressure (HVLP), dip coating, flow coating, roll coating, electrocoating , autophoric coating, and zinc-arc spray. The CTG describes these different coating applicati on methods. In a typical liquid spray and dip coating operations, the coated parts/produc ts move from the coating application area through a flash-of area where solvents in the coating begin to evaporate slowly, thus avoiding bubbling of the coating while it is curing in the oven. After the typical coating operation, large appliance products are dried and c ured using heated dryers or by air drying. Touch-up operations are performed using ma nual air spray guns and a lacquer base coating, which has good drying characteristics that allow for shorter drying times.

VOC emissions from the coating processes occur from the evaporation of solvents in the coatings during coating application/flash-off and d rying/curing of the coatings. About 65 to 80 percent of the VOC from spraying liquid coatings are emitted during the application and flash-off operations, and 20 to 35 percent are emit ted from the crying/curing operation. The remaining portion of the emissions is primarily from mixing or thinning operations.

Available Controls for VOC Emissions from Coatings

Two general types of emission control techniques fo r reducing VOC emissions from large appliance coatings are pollution prevention measure s and emission capture and add-on control systems. Pollution prevention measures inc lude coating productSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 substitution/reformulation, work practices, and equ ipment substitution. Low VOC content coatings (alternative coating formulations) include powder coatings, waterborne coatings, higher solids coatings, and ultraviolet (UV) curabl e liquid coatings and UV curable powder coatings. Work practice standards include storing VOC-containing materials and coatingrelated waste materials in closed containers, makin g sure that mixing and storage containers are kept close at all times as much as p ossible, minimizing spills, and conveying materials in closed containers or pipes. In addition to pollution prevention measures, emissions can be reduced by the use of ca pture system in conjunction with add-on control systems (e.g., thermal or catalytic oxidizer, adsorption, or absorption) that either destroy or recover VOCs in the exhaust strea ms.

Emission Limits Based on Low-VOC Coatings

The CTG include suggested limits for a variety of c oatings. The following sections detail those limits for the four major categories:

1. Metal Parts and Products Coatings

The CTG recommends the VOC limits for metal parts a nd products coatings as shown in

Table 1. These limits would be added to Rule 4603 as appropriate.

Table 1 Metal Parts and Products VOC Content Limits

VOC Limit

Air-dried baked Coating Type

kg/l coating lb/gal coating kg/l coating lb/gal coating

General, one component 0.34 2.8 0.28 2.3 General, multi-component 0.34 2.8 0.28 2.3 Camouflage 0.42 3.5 0.42 3.5 Electric-insulating varnish 0.42 3.5 0.42 3.5 Etching filler 0.42 3.5 0.42 3.5 Extreme high Gloss 0.42 3.5 0.36 3.0 Extreme performance 0.42 3.5 0.36 3.0

Heat resistant 0.42 3.5 0.36 3.0 High performance

architectural 0.74 6.2 0.74 6.2

High temperature 0.42 3.5 0.42 3.5

Metallic 0.42 3.5 0.42 3.5 Military specification 0.34 2.8 0.28 2.3

Mold seal 0.42 3.5 0.42 3.5 Pan backing 0.42 3.5 0.42 3.5

Pre-fabricated architectural multi-component 0.42 3.5 0.28 2.3SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 Table 1 Metal Parts and Products VOC Content Limits (continued)

VOC Limit

Air-dried baked Coating Type

kg/l coating lb/gal coating kg/l coating lb/gal coating

Pre-fabricated architectural
one-component 0.42 3.5 0.28 2.3

Pretreatment coatings 0.42 3.5 0.42 3.5 Repair and touch up 0.42 3.5 0.36 3.0

Silicon release 0.42 3.5 0.42 3.5

Solar-absorbent 0.42 3.5 0.36 3.0 Vacuum-metalizing 0.42 3.5 0.42 3.5 Drum coating, new, exterior 0.34 2.8 0.34 2.8 Drum coating, new, interior 0.42 3.5 0.42 3.5 Drum coating, reconditioned, exterior 0.42 3.5 0.42 3.5

Drum coating, reconditioned, interior 0.50 4.2 0.50 4.2

2. Plastic Parts and Products Coatings

Current Rule 4603 only applies to metal parts and p roducts, large appliances parts and products, and metal furniture coating operations. Rather than developing a separate rule to implement the CTG for plastic parts and products coating operations and pleasure craft coating operations, District staff is proposing to revise the existing applicability of the rule so it would also apply to plastic parts and product s coating operations and pleasure craft coating operations. The CTG recommends the VOC lim its for plastic parts and products

shown in Table 2. These limits would be added to R ule 4603 as appropriate.

Table 2 Plastic Parts and Products VOC Content Limi ts Coating Type Kg VOC/liter coating Lb VOC/gal coatin g General one component 0.28 2.3 General multi-component 0.42 3.5 Electric dissipating coatings and shock-free coatings 0.80 6.7

Extreme performance 0.42 (2 pack coatings) 3.5 (2 p ack coatings)

Metallic 0.42 3.5 Military specification 0.34 (1 pack) 0.42 (2 pack) 2.8 (1 pack) 3.5 (2 pack)

Mod-seal 0.76 6.3 Multi-colored coatings 0.68 5.7 Optical coatings 0.80 6.7 Vacuum-metalizing 0.80 6.7SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 For plastic parts and products coating operations ( except for automotive/transportation and business machine plastic parts and products), t he CTG recommended that the coating operations listed below would not need to c omply with the applicable coating VOC limits for plastic parts and products coating opera tions, but they would be subject to the work practice standards.

• Touch up and repair.

• Stencil coatings applied on clear or transparent s ubstrate.

• Clear or translucent coatings.

• Coatings applied at a paint manufacturing facility while conducting performance tests on coatings.

• Any individual coating category used in volumes le ss than 50 gallons in any one calendar year, if substitute compliance coatings ar e not available, provided the total usage of all such coatings does not exceed 200 gall ons per calendar year, per stationary source.

• Reflective coatings used on highway cones.

• Mask coatings that are less than 0.5 millimeter th ick (dried) and area coated is less than 25 square inches.

• Electromagnetic interference/radio frequency inter ference shielding coatings

• Mask coatings that are less than 0.5 millimeter th ick (dried) and the area coated is less than 25 square inches.

• Heparin-bezalkonium chloride (HBAC)-containing coa tings applied to medical devices, provided the total usage of all such coati ngs does not exceed 100 gallons per year per facility.

Furthermore, for plastic parts and products coating operations (except for automotive/transportation and business machine plas tic parts and products, the coating application methods would not apply to airbrush coa ting application operation using 5 gallons or less of coating per calendar year, provi ded the operator keeps the records required by the rule to demonstrate that the coatin g usage is below the allowable exemption amount.

3. Automotive/Transportation and Business Machine P lastic Parts and Products Coating

The CTG recommended the VOC limits shown in Table 3 . These limits would be added to Rule 4603 as appropriate.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 Table 3 - VOC Content Limits for Automotive/Transpo rtation and Business Machine Plastic Parts and Products Coating Operations
Automotive/Transportation Plastic Parts and Product s Coatings
Coating Type VOC Limit in kg/liter (lb/gallon) I. High Baked Coatings – Interior and Exterior

Flexible Primer 0.54 (4.5)

Non-flexible Primer 0.42 (3.5)

Basecoat 0.52 (4.3)

Clearcoat 0.48 (4.0)

Non-basecoat/clearcoat 0.52 (4.3) II. Low Bake/Air-Dried Coatings – Exterior Parts

Primers 0.58 (4.8)

Basecoat 0.60 (5.0)

Clearcoat 0.54 (4.5)

Non-basecoat/clearcoat 0.60 (5.0) III. Low Bake/Air-Dried Coatings – Interior parts 0.60 (5.0) IV. Touch-up and Repair Coatings 0.62 (5.2)

Business Machine Plastic Parts and Products Coating s Coating Type VOC Limit in kg/liter (lb/gallon)

Primer 0.35 (2.9) Topcoat 0.35 (2.9)

Texture Coat 0.35 (2.9) Fog Coat 0.26 (2.2) Touch-up and Repair 0.35 (2.9)

4. Pleasure Craft Coating

The CTG recommends the VOC limits for pleasure craf t surface coating shown in Table 4. These limits would be added to Rule 4603 as appropr iate.

Table 4 Pleasure Craft Surface Coating VOC Content Limits Coating Type VOC limit in kg/liter coating VOC limi t in lb/gal coating
Extreme high gloss topcoat 0.49 4.1 High gloss topcoat 0.42 3.5 Pretreatment wash primers 0.78 6.5 Finish primer/surfacer 0.42 3.5 High build primer surface 0.34 2.8

Aluminum substrate antifoulant coating 0.56 4.7

Other substrate antifoulant coating 0.33 2.8

All other pleasure craft surface coating for metal or plastic 0.42 3.5SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 5. Motor Vehicle Materials

The CTG included VOC limits for motor vehicle mater ials as shown in Table 5. These limits will not be included in Rule 4603, but they will be included in proposed amendments to Rule 4602 (Motor Vehicle Assembly Coatings) curr ently underway in order to implement the CTG for Automobile and Light-Duty Truck Assembl y Coatings promulgated by EPA in September 2008.

Table 5 Motor Vehicle Materials VOC Content Limits Motor Vehicle Material VOC limit in kg/liter coatin g VOC limit in lb/gal coating

Cavite wax 0.65 5.4

Sealer 0.65 5.4

Deadener 0.65 5.4 Gasket/gasket sealing

material 0.20 1.7

Underbody coating 0.65 5.4 Trunk interior coating 0.65 5.4

Bedliner 0.20 1.7 Lubricating wax/compound 0.70 5.8

Add-on Control system

If product performance or other needs dictate the u se of higher VOC materials than those

that would meet the recommended VOC limits in Table s 1 through 4, a facility could choose to use add-on control equipment with an over all control efficiency of 90 percent in lieu of using low-VOC coatings and specified applic ation methods. This control option applies to all coatings and thinners applied to mis cellaneous metal and plastic components or products, except for motor vehicles. But as noted above, the VOC limits

for motor vehicles materials would not be included in Rule 4603, but they would be included in a separate rulemaking project to amend Rule 4602 (Motor Vehicle Assembly Coatings).

Proposed Amendments to Rule 4603

The District’s permit database indicates that there approximately 300 permitted sources that are subject to Rule 4603. Staff reviewed the reports of inspections conducted by the District’s Compliance Division and determined that operators are already using coatings that comply with the draft amendments to Rule 4603.

Comparison of Rule 4603 Coating VOC Limits with CTG Standards

Rule 4603 general coating limits are: Air-dried is 275 grams per liter (2.3 pounds per gallon) of coating, less water and exempt compounds , as applied. Baked is 340 gramsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 per liter (2.8 pounds per gallon) of coating, less water and exempt compounds, as applied. The specialty coating VOC limits for baked range fr om 880 grams per liter (7.3 pounds per gallon) to 360 grams per liter (3.0 pounds per gall on) of coating, less water and exempt compound, as applied, depending on the type of spec ialty coating; and for air-dried the limits range from 880 grams per liter (7.3 pounds p er gallon) to 420 grams per liter (3.5 pounds per gallon) of coating less water and exempt compound, as applied, depending on the type of specialty coating. Coatings that are n ot specified in the table of VOC limits for specialty coatings are defaulted to the general coa ting category as specified above.

Rule 4603 does not include all the metal parts and products coating categories listed in the CTG. Those coating categories included in the CTG are considered by District staff as being regulated under the general coating limits sp ecified in Rule 4603. Some of the CTG coating VOC limits for miscellaneous metal part s and products (except for coatings used for large appliances and metal furniture coati ng operations) are less stringent than Rule 4603 existing general coating limits (baked: 2 .8 pounds per gallon; air-dried: 2.3 pounds per gallon) for the following CTG coating ca tegories:

• Electric-insulating varnish: 3.5 pounds per gallon (baked or air dried)

• Etching filler: 3.5 pounds per gallon (baked and a ir dried)

• Mold seal: 3.5 pounds per gallon (baked or air dri ed)

• Pan backing: 3.5 pounds per gallon (baked or air d ried)

• Prefabricated architectural multi-component: 3.5 p ounds per gallon (air-dried)

• Prefabricated architectural one-component: 3.5 pou nds per gallon (air-dried)

• Pretreatment coating: 3.5 pounds per gallon (baked and air dried)

• Vacuum-metalizing: 3.5 pounds per gallon (baked or air-dried)

In addition, the CTG limits for baked camouflage co ating and for metallic coating of 3.5 pounds per gallon is less stringent than Rule 4603 limit of 3.0 pounds per gallon. The CTG limit for baked extreme performance coating of 3.0 pounds per gallon is slightly more stringent than Rule 4603 limit of 3.5 pounds per ga llon. Repair and touch-up coating is exempt in Rule 4603, but the CTG’s repair and touch repair coating VOC limit is 3.5 pounds per gallon (air-dried) and 3.0 pounds per ga llon (baked).

As discussed above, for metal parts and products CT G coating VOC limits, District staff is proposing only to incorporate the VOC limit for ext reme performance coating because it is more stringent than the existing rule 4603, remove the current rule’s exemption for touch and repair and also specify the CTG limit of 3.5 lb /gal for air dried and 3.0 lb/gal for baked. Other coating categories in the CTG which have less stringent VOC limits than Rule 4603 general coating limits, as discussed above, would n ot be incorporated because it would beSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 a relaxation of the current SIP-approved rule which EPA does allow. Likewise, the CTG recommends to not apply the VOC limits for the sten cil coatings; safety-indicating coatings; solid-film lubricants; electric-insulatin g and thermal-conducting coatings, magnetic data storage disk; and plastic extruded on to metal parts to form a coating. These exemptions would not be incorporated into the rule because it would constitute a relaxation of the SIP-approved version of the rule since Rule 4603 currently does not currently exempt such coating operations.

The CTG’s VOC limits for drum coating categories wo uld not be included in Rule 4603 since drum manufacturing is subject to Rule 4603 (C an and Coil Coating Operations).

The CTG limit for reconditioned drum interior coati ng of 4.2 lb/gal (504 grams/liter) is slightly more stringent that Rule 4604 limit of 510 grams/liter. However, since there is no reconditioned drum coating operation currently oper ating within the District, staff would not recommend amending Rule 4604. Any reconditioned dr um coating operation that may operate in the future within the District would be subject to Rule 2201 (New and Modified Stationary Source Rule) requirements for Best Avail able Control technology (BACT) and emission offset requirements. Therefore, it is not necessary to amend Rule 4604 at this

time.

The following are proposed amendments to Rule 4603 to implement the CTG for miscellaneous metal parts and products coatings. T he proposed amendments would be effective on and after January 1, 2011.

• The title of the rule would be changed to read: Su rface Coating of Miscellaneous Metal Parts and Products, Plastic Parts and Products, and Pleasure Crafts.

• Section 1.0 (Purpose) would be changed to include limiting the VOC emissions from plastic parts and products, automotive/transportati on and business machine plastic parts and products, and pleasure craft coating oper ations.

• Section 2.0 (Applicability) would be changed so th e rule also applies to plastic parts and products, automotive/transportation and busines s machine plastic parts and products, and pleasure craft coating operations.

• Section 3.0 (Definitions) would be include 25 new definitions and modify some existing definitions to enhance clarity and effectiveness of the rule.

• Section 4.0 (Exemption) would be modified so that the existing exemption for touch-up and repair would be removed effective on and after (one day before rule amendments adoption date) and a VOC content limit of 360 grams /liter (3.0 lb/gallons) for baked and 420 grams/liter (3.5 lb/gallon) for air-dried would be specified to make it consistent with

the CTG.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 • Section 5.0 (Requirements) would include changes t o the existing table of VOC limits for metal parts and products coating operations, ad d separate tables of VOC coating limits for plastic parts and products, for automoti ve/transportation and business machine plastic parts and products, and for pleasur e craft.

• The work practice standards recommended by the CTG would be incorporated into Rule 4603. The standards include: storing all VOC- containing coatings, thinners, and cleaning materials, and waste materials in closed n on-absorbent and non-leaking containers, and such containers should remain close d at all times, except when specifically in use; closing the mixing vessels tha t contain VOC coatings and other materials, except when specifically in use; minimiz ing spills of any VOC-containing materials and clean up spills immediately; and conv eying VOC-containing materials in closed containers or pipes. Although the CTG only recommends work practice standards, but no specific VOC limit for organic cl eaning solvents, the sources in the District covered by the CTG would still be required to comply with the existing cleaning solvent VOC limit of 25 grams/liter in order to pre vent relaxation of the SIP-approved

rule.

• Existing Section 6.5 would be deleted because it s erves no useful purpose since the year of revision of ASTM test method is already spe cified in the rule itself. EPA has historically wanted the District to specify the rev ision year of the ASTM test method instead of stating “the most recent version of such test method”.

For Miscellaneous Metal Parts and Products Coatings

• The existing VOC content limit for Extreme Perform ance Coating would be lowered from 420 grams/liter (3.5 lb/gallon) to 360 grams/l iter (3.0 lb/gallon) to make it

consistent with the CTG.

• The current exemption for touchup and repair coati ng would be remove and new VOC limits would be 360 grams/liter (3.0 lb/gallon) for baked and 420 grams/liter (3.5 lb/gallon) for air-dried

Plastic Parts and Products Coating Operations (Exce pt for Automotive/Transportation and Business Machine Plastic Parts and Products)

District staff reviewed the District Permit databas e and determined that there are only two permitted facilities that perform surface coating o f plastic parts and products 1 , but each facility’s total VOC emissions from coating and cle aning operations, before consideration of controls, are below the CTG applicability thresh old of 15 lb VOC/day or 2.7 tons VOC

1 Fairmont Sign Company (PTO: N-4223-1): Permit VOC limit for plastic coating operation is 2 lb/day. Premier Coatings-DBA Premier Finishing (PTO: N-4338 -12-1): Permit VOC limit for plastic coating operation is 3,195 lb/year (1.59 tons/year).SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 per 12-month rolling period from all metal parts an d products, automotive/transportation and business machine plastic parts and products, an d pleasure craft coating operations, including related cleaning operations, before consi deration of controls, at a stationary source. Although no existing sources would be sub ject to the draft coating VOC limits,

District staff would include the CTG limits into th e rule as a “back-stop” in the event new or modified sources become subject to the coating limi ts in the future.

The following are proposed amendments to Rule 4603 to implement the CTG for plastic parts and products coatings:

• The rule would include the CTG VOC content limits ranging from 275 grams/liter (2.3 lb/gallon) to 804 grams/liter (6.7 lb/gallon), depe nding on the type of coating (i.e., general one component coating, general multi-compon ent coating, extreme performance coating, metallic coating, multi-colore d coating, etc.). The VOC limits would only apply to operators whose total VOC emiss ions from all metal parts and products, automotive/transportation and business ma chine plastic parts and products, and pleasure craft coating operations, including re lated cleaning operations, before consideration of controls, at a stationary source a re equal to or greater than 2.7 tons of VOC per 12-month rolling period. Operators of plas tic parts and products coating operations whose total VOC emissions at a stationar y source are below the 2.7 tons of VOC per 12-month rolling period threshold are not r equired to comply with the applicable coatings VOC limits. However, the opera tor would need to comply with the applicable recordkeeping requirements of the rule a nd also calculate the VOC emission

to demonstrate if the VOC emissions are below the s pecified threshold.

• As recommended by the CTG, the exemption in Sectio n 4.0 would include a provision that the coatings VOC limits in Table 3 and the sol vent cleaning requirements would not apply to the coatings and coating operations li sted below provided the operator complies with the work practice standards and coati ng application methods specified in

the rule.

• Touch-up and repair coatings;

• Stencil coatings applied on clear or transparent s ubstrate;

• Clear or translucent coatings;

• Coatings applied at a paint manufacturing facility while conducting performance tests on coatings;

• Individual coating category used in volumes less t han 50 gallons in any one calendar year, if substitute compliance coatings ar e not available, provided the total usage of all such coatings does not exceed 20 0 gallons per calendar year, per stationary source;

• Reflective coatings used on highways;

• Mask coatings that are less than 0.5 mm thick (dri ed) and the area coated is less than 25 square inches;SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 • Electro-magnetic interference (EMI) and radio freq uency interference (RFI) shielding coatings;

• Heparin-bezalkonium chloride (HBAC)- containing co atings applied on medical devices, provided the total usage of all such coati ngs does not exceed 100 gallons per calendar year, per stationary source; and

• The coating application methods would not apply to airbrush operations using five (5) gallons or less of coating per calendar year pr ovided the operator complies with the applicable VOC limits, work practice stand ards, and recordkeeping requirement in the rule.

• As recommended by EPA, Section 4.7 would be clarif ied that the exemption for polyester resin operations and the application of p olyester resin materials on metal parts and products would be clarified by specifying that such operations are subject to Rule 4684 (Polyester Resin Operations).

• As discussed above, the work practice standards re commended by the CTG would be included in the rule and would apply to plastic par ts and products coating operations.

Automotive/Transportation and Business Machine Plas tic Parts and Products Coating Operations

District staff reviewed the District Permit databas e and determined that there are no facilities that perform automotive/transportation a nd business machine plastic parts and products coating operations. Although no sources w ould be subject to the new coating VOC limits, District staff would include the CTG li mits into the rule as a “back-stop” in the event new or modified sources become subject to the coating limits in the future.

The following are proposed amendments to Rule 4603 to implement the CTG for automotive/transportation and business machine plas tic parts and products coatings:

• The rule would include coating VOC content limits ranging from 348 grams/liter (2.9 lb/gallon) to 600 grams/liter (5.0 lb/gallon), depe nding on the type of coating (e.g., general one component coating, general multi-compon ent coating, extreme performance coating, metallic coating, multi-colore d coating, etc.).

• As recommended by the CTG, the coating VOC limits would only apply to operators whose total VOC emissions from all metal parts and products, automotive/transportation and business machine plas tic parts and products, and pleasure craft coating operations, including relate d cleaning activities, before consideration of controls, at a stationary source a re equal to or greater than 2.7 tons of VOC per 12-month rolling period. Operators of auto motive/transportation and business machine plastic parts and products coating operatio ns whose total VOC emissions at a stationary source are below the 2.7 tons of VOC per 12-month rolling period threshold are not required to comply with the applicable coat ings VOC limits. However, theSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 operator shall comply with the applicable recordkee ping requirements of the rule and

calculate the VOC emission to demonstrate if the VO C emissions are below the specified

threshold.

• As recommended by the CTG, the exemption in Sectio n 4.0 would include a provision that the coatings VOC limits and the solvent cleani ng requirements would not apply to the coatings and coating operations listed below pr ovided the operator complies with the work practice standards and coating application methods specified in the rule.

• Texture coatings;

• Vacuum metalizing coatings;

• Gloss reducers;

• Texture topcoats;

• Adhesion primers;

• Resist coatings; and

• Stencil coatings.

• As discussed above, the work practice standards re commended by the CTG would be included in the rule and would also apply to automo tive/transportation and business machine plastic parts and products coating operatio ns.

Pleasure Craft Coating Operations

District staff reviewed the District Permit databas e and determined that there are seven permitted facilities that maybe performing surface coating of pleasure crafts 2 and could be subject to the new coating VOC limits being include d into the rule.

The following are proposed amendments to Rule 4603 to implement the CTG for pleasure craft coatings:

• The rule would include coatings VOC content limits ranging from 336 grams/liter (2.8 lb/gallon) to 780 grams/liter (6.5 lb/gallon), depe nding on the type of coating (e.g., extreme high gloss, high gloss, pretreatment wash p rimer, high build primer surfacer, aluminum substrate antifoulant coating, etc.).

• As recommended by the CTG, the coatings VOC conten t limits would only apply to pleasure craft coating operations whose total actua l VOC emissions from all metal parts and products, automotive/transportation and b usiness machine plastic parts and products, and pleasure craft coating operations, in cluding related cleaning activities, before consideration of controls, at a stationary s ource are equal to or greater than 2.7

2 International Inboard Marine (PTO: N-3296); Marine Services (PTO: N-3905); Malibu Boats LLC (PTO: N3941); Fineline Industries, Inc. (PTO: N-1246-1-1); Wakecraft Boats Inc. (PTO: N-7450-1-0); Belmont Bo ats (PTO: C-110-1-0); Sanger Boats, Inc. (C-1074-1-4);SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 tons of VOC per 12-month rolling period. Operator s of pleasure craft coating operations whose total VOC emissions at a stationar y source below the 2.7 tons of VOC per 12-month rolling period threshold are not r equired to comply with the applicable coatings VOC limits. However, the opera tor shall comply with the applicable recordkeeping requirements of the rule and calculat e the VOC emission to demonstrate if the VOC emissions are below the specified thresh old.

• As recommended by the CTG, the coating application methods would not apply to extreme gloss coatings and the solvent cleaning req uirements provided the operator complies with the VOC limit for such coating catego ry and the work practice standards

of this rule.

• As recommended by EPA, existing Section 5.7.6 pert aining to alternative compliance option which allows an operator to operate an APCO approved VOC emission control system in lieu of complying with the specified clea ning solvent VOC limit would be deleted because this section is duplicative of the identical provision in existing Section 5.10.2 that allows an alternative compliance option

.

• The application equipment requirements in Section 5.12 would be modified to specify that the required coating application methods apply to metal parts and products, large appliances parts and products, metal furniture, pla stic parts and products, automotive/transportation and business machine part s and products, and pleasure

crafts.

• As discussed above, the work practice standards re commended by the CTG would be included in the rule and would also apply to pleasu re craft coating operations.

IV. CTG for Fiberglass Boat Manufacturing Materials (EPA-453/R-08-004, September 2008)

In September 2008, EPA issued a CTG for fiberglass boat manufacturing which provides recommendations for controlling VOC emissions from the use of gel coats, resins, and materials used to clean application equipment. Th e CTG applies to facilities that manufactures hulls or decks of boats from fiberglas s, or build molds to make fiberglass hulls or decks. The CTG does not apply to faciliti es that manufacture solely parts of boats (such as hatches, seats, or lockers) or boat traile rs, but do not manufacture decks or hulls of boats from fiberglass, or build molds to make hu lls or decks. However, if a facility

manufactures hulls or decks and also manufactures a ll other fiberglass boat parts (such as hatches, seats, lockers) then the facility is su bject to the CTG standards.

The CTG apply to fiberglass boat manufacturing faci lities where the total actual VOC emissions from all fiberglass boat manufacturing op erations including cleaning operations, before consideration of controls, are equal to or e xceed 15 lb/day or an equivalent threshold of 2.7 tons per 12-month rolling period. The CTG does not recommend theSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 control requirements apply to facilities below the stated threshold because of very small

VOC emission reductions that could be achieved sinc e such a level is considered to be very low within the fiberglass boat manufacturing i ndustry and is expected only from facilities producing only small number of small boa ts. The CTG does not extend to surface coatings applied to fiberglass boats and do es not apply to industrial adhesives used in the assembly of fiberglass boats. Surface coating of fiberglass and metal recreational boats (pleasure craft) and covered by the CTG for miscellaneous metal and plastic parts and products which is being incorpora ted into the draft amendments to Rule 4603 as discussed above. Polyester resin putties t hat are used in assembling fiberglass parts are not considered adhesives so they are subj ect to the fiberglass boat manufacturing CTG standards.

A. Process Description and Sources of VOC Emissions

The CTG includes a detailed discussion of the proce sses involve in manufacturing fiberglass boat hulls or decks and miscellaneous sm all fiberglass parts such as tanks, seats, lockers, and hatches. Fiberglass boats are typically manufactured in a process called open molding. Separate molds are used for b oat hull, deck, and miscellaneous small parts. Resins and gel coats are used to manu facture fiberglass boat hulls or decks and miscellaneous small parts.

The primary VOC emitted from fiberglass boat manufa cturing materials are styrene and methacrylate. The resin contains styrene and the g el coat contains both compounds. Styrene and methacrylate are both monomers. A frac tion of the monomer evaporates during resin and gel coat application and curing. The majority of the monomer is bound in the cross-linking reaction between the polymer mole cules in the hardened resin or gel coat which become part of the finished product, so not a ll of the styrene or methacrylate evaporate during the boat manufacturing process. T he amount of monomer VOC emitted is dependent on several factors, including initial monomer content, application method, and thickness of the part or the layer that is curi ng. The VOC emission is usually expressed in terms of lb monomer per ton of materia l applied, or kg per megagram.

B. Available Control Options for Resins and Gel Coa t

1. Low Monomer Resins and Gel Coats

Reducing the monomer content of the resin or gel co at and using non-atomized application method reduces the monomer VOC emission s from resins and gel coats used in open molding at fiberglass boat manufacturing pr ocess. The CTG discussed how different resins and gel coats can be reformulated to achieve varying levels of lowered monomer VOC contents depending on their use in the manufacturing process. From a regulatory standpoint, low-monomer VOC content requ irement is easier to monitor and enforce and also easier for facility operators to d emonstrate compliance on a continuousSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 basis compared to other control options such as ins talling and operating a VOC control
system.

As discussed in South Coast Air Quality Management District‘s Final Staff Report for Rule 1162 dated November 2001, Ultra Violet (UV) curing and Electron Beam (EB) resins are

considered near zero or zero emission resins becaus e of their instantaneous polymerization. SCAQMD staff’s research in 2001 in dicates that EB and UV curing technology for composite industry is a promising te chnology for certain applications.

2. Vapor Suppressed Resin and Gel Coats

Vapor suppressed resins and gel coats may be used t o achieve emissions reductions without changes in equipment. Vapor suppressed res in or gel coat have an additive, typically a wax, to reduce evaporation of monomer V OC by forming a film on the resin or gel coat surface as it cures. But the vapor suppre ssing wax presents significant technical problems in boat manufacturing. Boats are relative ly large and complex so they are usually built and assembled from subassemblies that eventually must be bonded together. To achieve a good secondary bond between two parts made of vapor suppressed resins, the wax film on the bonding surfaces must be remove d by grinding or sanding before the pars can be bonded. This additional surface prepar ation can be labor intensive such that one boat manufacturer estimated that switching to v apor suppressed resins caused about a 25% labor increase in building parts. Also, the ultimate strength of the bonded parts may also be reduced such that the possibility of st ructural failure may also increase.

3. Non-atomizing Resin Application

The CTG indicated that switching from atomizing to non-atomizing application of resin with a 35% styrene achieves a 41% emissions reduction. If both styrene content and application method are changed, the emission reduct ion can be greater that changing the percent styrene content alone or the application me thod only. The CTG stated that changing from an atomized application method with a resin of 40% styrene content to 35% styrene content that is applied with non-atomizing technology can achieve a 58% emission

reduction.

The CTG includes a detailed discussion on non-atomi zing resin application techniques, which include bucket and brush application by hand, resin rollers, resin impregnators, and fluid impingement technology. All these methods reduce emissions by eliminating the

atomization of resins. Non-atomizing technology is feasible for applying p roduction and tooling resins only. Gel coats must still be appli ed with atomizing spray guns, so reduction from gel coats can only be achieved by using low mo nomer VOC gel coats. An exception is gel coat that can be applied with a brush or rol ler to the interior areas of finished boats where cosmetic appearance is not as critical as the exterior.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 4. Closed Molding

Closed molding is a fabrication technique in which reinforced plastic parts are produced between the halves of a two-part mold, or between a mold and a flexible membrane, such as a bag. The four types of closed molding methods used in fiberglass boat manufacturing, as described in detail by the CTG, i nclude vacuum bagging, vacuumassisted resin transfer molding, resin transfer mol ding, and compression molding with sheet molding compound. Closed molding processes a s currently practiced cannot be used to reduce emissions during gel coat or skin co at application because these applications must still use conventional open moldi ng techniques reduce. But closed molding can still be used to reduce monomer VOC emi ssions from subsequent laminating steps after the gel coat and skin coat layers have been applied.

The CTG has indicated that one fiberglass boat manu facturer in the nation has developed a patented closed molding process that has replaced open molding for hulls of many of its smaller (17 to 22 feet long) power boats. However, closed molding is generally applicable to making large number of small parts, such as hatc hes, doors, or small number of high performance boat hulls and decks, but it is not fea sible to replace open molding with closed molding at all types of boat manufacturing f acilities

C. Proposed Amendments to Rule 4684 (Polyester Resi n Operations)

District staff reviewed the District Permit databas e and determined that there are seven fiberglass boat manufacturing facilities 3 that are currently subject to Rule 4684 and may be be affected by the VOC limits being proposed for re sins and gel coats. It is important to mention that some of the permitted boat manufacturi ng facilities in the District are major sources (sources that emit at least 10 tons per yea r of VOC or nitrogen oxides) so they will be issued federally-mandated Title V operating perm its. Other boat manufacturing facilities in the District permitted VOC emissions are less than the CTG applicability threshold of 2.7 tons per 12-month rolling period s o they will not be subject to the proposed amendments. In addition, those boat manuf acturers in the District that are major sources of hazardous air pollutant (sources t hat emit at least 10 tons per year of a single of HAP or at least 25 tons per year of a com bination of HAP) are already subject to the control requirements pursuant to 40 CFR Part 63 Subpart VVVV (National emission Standards for Hazardous Air Pollutants), which EPA promulgated in August 2001. The CTG control requirements for fiberglass boat manufa cturing materials are consistent with 40 CFR Part 63 Subpart VVVV.

The following are proposed amendments to Rule 4684. The proposed amendments would be effective on and after January 1, 2011.

3 International Inboard Marine (PTO: N-3296); Marine Services (PTO: N-3905); Malibu Boats LLC (PTO: N3941); Fineline Industries, Inc. (PTO: N-1246-1-1); Wakecraft Boats Inc. (PTO: N-7450-1-0); Belmont Bo ats (PTO: C-110-1-0); Sanger Boats, Inc. (C-1074-1-4);SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 • Section 2.0 (Applicability) would be expanded to c larify that the rule also applies to fiberglass boat manufacturing operations.

• Section 3.0 (Definitions) would include 17 new def initions of terms associated with fiberglass boat manufacturing in order to enhance t he clarity and effectiveness of the

rule.

• Section 4.1 (Exemption) would be modified to state that the existing 20 gallon or less per month of polyester resin materials usage exempt ion does not apply to fiberglass boat manufacturing. The reason for excluding fiber glass boat manufacturing from this low-usage exemption is due to the CTG not having a similar exemption for fiberglass boat manufacturing.

• As recommended by the CTG standards, a new Section 4.2 would be added to exempt production resins (including skin coats) that must meet the specifications for use in military vessels or must be approved by the U.S. Co ast Guard for use in construction of lifeboats, rescue boats, and other life-saving a ppliances approved under 40 CFR subchapter Q, or to the construction of small passe nger vessels regulated by 46 CFR subchapter T are exempt from the requirements of Se ction 5.2.2. This exemption does not constitute relaxation of the SIP-approved versi on of the rule because there are no boat manufacturing sources within the District is c urrently manufacturing vessels or pleasure crafts that meet the criteria stated above . The CTG recommended that the open molding and non-monomer VOC limits do not appl y to production and tooling resins, and pigmented, clear and tooling gel coat u sed for part or mold repair and touch-up, as well as 100% vinylester resin, Distric t staff is not incorporating the CTG’s recommendation to exempt such resins and gel coats because it would constitute relaxation of a SIP-approved version of Rule 4684 s ince existing permitted boat manufacturing facilities are able to comply with th e monomer content limits of the existing rule.

• Section 5.0 (Requirements). Section 5.1 would be modified to specify that the requirements apply to polyester resin operations, e xcept for fiberglass boat manufacturing which would subject to new Section 5. 2. New Section 5.2 would include three compliance options for controlling VO C emissions from fiberglass boat manufacturing. The new monomer VOC limits would app ly only to fiberglass boat manufacturing facilities whose total VOC emissions from open molding fiberglass boat manufacturing operations, including related solvent cleaning activities, before consideration of controls, at a stationary source a re equal to or greater than 2.7 tons of VOC per 12-month rolling period. The operator wou ld need to comply with the applicable recordkeeping requirements of the rule a nd would have to calculate the

VOC emissions to demonstrate that the VOC emissions are at least 2.7 tons per 12- month rolling period. Operators of fiberglass boat manufacturing operations whose VOC emissions are less than specified VOC applicabi lity threshold of 2.7 tons of VOCSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 per 12-month rolling period would be still be subje ct to the current resin and gel coat monomer content limit specified by the existing rul e (please see discussion on page 24 of this staff report). Please refer to the draft r ule for details of the emission control requirements of the compliance options listed below

.

o Compliant Material Option: Achieve the specified individual monomer content limits. The weighted average monomer VOC content l imits for fiberglass boat manufacturing open molding process ranging from 28% to 40% by weight depending on the type of resin (i.e., production re sin and tooling resin), type of gel coat (pigmented gel coat, clear gel coat, and tooli ng gel coat), and also depending on the application method. The proposed monomer VO C content limits are shown in Table 6. In addition to complying with the mono mer VOC content limit, each resin and each gel coat must not contain more than 5% by weight non-monomer

VOC content. The rule would include the calculation equations to determine the weighted average monomer VOC content.

Table 6 Compliant Materials Monomer VOC Content fo r Open Molding Resin and Gel

Coat
Material Application Method Weighted Average Monom er VOC content (weight percent)

limit
Production Resin Atomized (spray) 28%

Production Resin Nonatomized 35% Pigmented Gel Coat Any method 33% Clear Gel Coat Any method 48% Tooling Resin Atomized 30% Tooling Resin Nonatomized 39%

o Emissions Averaging Option: Meet the numerical monomer VOC emission rate limits as shown in Table 7, which would enable an o perator to average emissions among different operations using the equations in t he draft rule to estimate the monomer VOC emissions rates from each operation bas ed on material and application method. In addition to complying with a facility-specific monomer VOC mass emission rate (12-month rolling average), each resin and gel coat must not contain more than 5% by weight non-monomer VOC cont ent. A table of the Monomer VOC Emission Rate Formulas for Open Molding Operations would be

included in Rule 4684.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 Table 7 Monomer VOC Emission Rate Formulas for Open Molding

Material Application Method Formula to calculate

monomer VOC emission rate*

Atomized 0.014 x (Resin VOC%) 2.425

Atomized, plus vacuum bagging with roll-out 0.01185 x (Resin VOC%) 2.425

Atomized, plus vacuum bagging without rollout 0.009454 x (Resin VOC%) 2.425

Nonatomized 0.014 x (Resin VOC%) 2.275

Nonatomized, plus vacuum bagging with rollout 0.0110 x (Resin VOC%) 2.275 Production resin, Tooling

resin

Nonatomized, plus vacuum bagging without

roll-out 0.0076 x (Resin VOC%) 2.275

Pigmented gel coat, clear gel coat, tooling gel

coat All methods 0.0045 x (Gel coat VOC%) 1.675

 The formulas in Table 7 calculate monomer VOC emiss ions in kilograms of monomer per megagram of resin or gel coat applied. The formula s for vacuum bagging with roll-out are applicable when a facility rolls out the applied re sin and fabric prior to applying the vacuum bagging materials. The formulas for vacuum bagging without roll-out are applicable when a facility applies the vacuum bagging materials immediately af ter resin application without rolling the resin and fabric. VOC% = monomer VOC content as supplied , expressed as a weight-percent value

between 0 and 100%.

o Add-on Control Option: Install and operate an APCO-approved VOC control system to achieve a numerical monomer VOC emission limit that is determined for each facility based on the mix of application metho ds and materials used at that facility. Additionally the VOC control system must also meet the existing 85% capture and control efficiency specified in the cur rent rule.

Requirements for Fiberglass Boat Manufacturing Oper ations with VOC Emissions Less than 2.7 tons per 12-month Rolling Period

Operators of fiberglass boat manufacturing operatio ns whose VOC emissions are less than 2.7 tons of VOC per 12-month rolling period or fiberglass boat manufacturing operations using a closed molding process would be still be subject to the current resin and gel coat monomer content limit specified by the existing rule. The existing rule VOC limits are: 35% monomer by weight for low VOC resi ns, except for specialty resins and gel coats; 45% monomer by weight for low VOC pigmented gel coats; and 50% monomer by weight for low VOC specialty resins and clear gel c oats. In lieu of using materials thatSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 meet the monomer content limits, the existing rule allows the operator to (1) use of closed mold system; (2) use resin containing a vapor suppr essant, such that the weight loss from the VOC emissions does not exceed 60 grams per squa re meter of exposed surface during resin polymerization  3) install and operate an APCO-approved VOC control system that meets a specified capture and control e fficiency. In addition to complying with the existing rule’s VOC requirements, the operator would need to comply with the applicable recordkeeping requirements of the rule a nd calculate the VOC emissions from fiberglass boat manufacturing to demonstrate if the VOC emissions from all fiberglass boat manufacturing open molding operations, including re lated cleaning activities, are less than 2.7 tons of VOC per 12-month rolling period.

• As recommended by EPA, the current requirements fo r VOC control system in Section

5.1.1.4 would be modified to include a calculation equation that needs to be used by the operator in order to demonstrate that the control s ystem should reduce the VOC emissions at all times to a level that is not great er than the emissions which would have been achieved through the use of compliant material s, compliant equipment, or compliant work practices.

• As recommended by the CTG, work practice standards would be included requiring an operator to ensure that all containers with a capac ity equal to or greater than 208 liters (55 gallons), including those used for on-site mixi ng of putties and polyputties have a cover with no visible gaps in place at all times, e xcept when material is being placed or removed from a container, or when mixing or pumping equipment is being placed in or

removed from a container.

• Existing Section 6.4 would be deleted because it s erves no useful purpose since the year of revision of ASTM test method is already spe cified in the rule itself. EPA has historically wanted the District to specify the rev ision year of the ASTM test method instead of stating the term “most recent version of such test method”.

IV. VOC EMISSION AND REDUCTIONS

1. Rule 4603 VOC Emissions Reduction

a. Proposed Amendments to Miscellaneous Metal Parts and Products Coating Operations

The ARB emissions inventory database shows that the 2008 annual average baseline emission from metal parts and products coating oper ations is about 0.65 tons of VOC per day. The District’s permit database indicates that there approximately 300 permitted sources that are subject to Rule 4603. Staff revie wed the reports of inspections conducted by the District’s Compliance Division but unable to determine how many sources are using extreme performance coating, and how many sources are performingSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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26 Final Staff Report with Appendices for Amendments

to Rule 4603 and Rule 4684 touch-up and repair coating operation. However, si nce the federal Clean Air Act requires ozone nonattainment areas to implement RACT and tha t the CTGs promulgated by EPA constitute RACT requirements, at a minimum, Distric t staff is compelled to incorporate the CTG standards into Rule 4603. Any potential VOC em issions reduction resulting from the proposed amendments to the miscellaneous metal part s and products portion of the rule

would be estimated if new information is received b y District staff from affected sources during the rule development process.

b. Proposed Amendments for Plastic Parts and Produc ts, and automotive/Transportation and Business Machine Plas tic Parts and Products Coating Operations

The ARB emissions inventory database shows that the 2008 annual average baseline emission from plastic parts and products coating op erations is about 0.04 tons of VOC per day. The District’s permit database indicates that there are two permitted plastic parts and products coating facilities, but they are not subje ct to the draft amendments to incorporate the CTG’s plastic parts and products coating VOC li mits because the permitted VOC emissions of each facility are less than rule appli cability threshold of 2.7 tons per 12-month rolling average. There are no automotive/transport ation and business machine plastic parts and products coating operations currently ope rating within the District. Therefore, no VOC emissions reduction would result from the propo sed changes to the rule to include the coating VOC limits for plastic parts and produc ts coating operations and coating VOC limits for automotive/transportation and business m achine parts and products coating operations.

c. Proposed Amendments for Pleasure Craft Coating O perations

The ARB emissions inventory database shows that the 2008 annual average baseline emission from marine coatings (pleasure craft) is a bout 0.08 tons of VOC per day. A review of the seven permitted boat manufacturing an d boat repair facilities operating within the District showed only one facility with a permit condition on the use of antifoulant coating which allows a VOC content limit of 400 gra ms/liter (3.3 lb/gallon) and a daily VOC emission limit of 40 lb/day. The proposed VOC limi t is 336 grams/liter (2.8 lb/gallon). Assuming the facility uses 10 gallons per day of su ch coating, the VOC reduction is estimated at 5 lb/day (0.0025 ton/day) or 3,175 lb/ year (1.6 tons/year). Data on the quantity and type of coatings that are being used f or pleasure craft coating operations

within the District is not available at this time. Any potential VOC emissions reduction resulting from the proposed amendments would be upd ated if new information is received by District staff from affected sources.

2. Rule 4684 VOC Emissions Reduction

The proposed amendments to Rule 4684 incorporates t he CTG standards for fiberglass boat manufacturing materials which are essentially the same as the emission standardsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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27 Final Staff Report with Appendices for Amendments

to Rule 4603 and Rule 4684 specified in 40 CFR Part 63 Subpart VVVVV. As disc ussed above, some of the permitted fiberglass boat manufacturing facilities are major sources of hazardous air pollutants so they are already required to comply with 40 CFR Par t 63 Subpart VVVV (National

Emission Standards for Hazardous Air Pollutants for Boat Manufacturing). Other boat manufacturers are neither major sources of either V OC or HAPs, and are below the CTG applicability threshold. Therefore, no VOC emissio ns reduction is anticipated from the

draft amendments to Rule 4684.

V. COST EFFECTIVENESS AND SOCIOECONOMIC ANALYSES

Pursuant to California Health & Safety Code Section 40920.6(a), the District is required to analyze the cost effectiveness of new rules or rule amendments that implement Best Available Retrofit Control Technology (BARCT) or pl anning requirements to incorporate all

feasible measures. The draft amendments to Rule 46 03 and Rule 4684 would only add federal RACT requirements but not BARCT or all feas ible measure, and are therefore not subject to the cost effectiveness analysis mandate.

Pursuant to California Health & Safety Code Section 40728.5 (a) an assessment of the socioeconomic impacts is not required for any rule or regulation that only adopts a requirement that is substantially similar to, or is required by state or federal statute, regulation, or applicable formal guidance, such as a federal CTG. Since the proposed amendments to Rule 4603 and Rule 4684 implement the CTG standards mandated by the federal Clean Air Act, a socioeconomic impact analy sis is not required.

VI. ENVIRONMENTAL IMPACTS

Pursuant to the California Environmental Quality Ac t (CEQA), staff investigated the possible environmental impacts of the proposed amendments to Rule 4603 and Rule 4684. Based on the lack of evidence to the contrary, District s taff has concluded that the proposed amendments to the rules will not have any significa nt adverse effects on the environment. Staff recommends filing a Notice of Exemption under the provisions of Public Resource Code 15061 (b)(3).

VII. RULE CONSISTENCY ANALYSIS

As required by California Health & Safety Code Sect ion 40727.2, District staff will prepare a rule consistency analysis later in the rule devel opment process that compares the elements of amendments with the corresponding eleme nts of other District rules, federal regulations and guidelines that apply to the same s ource category or type of equipment. The analysis has indicated that none of the propose d requirements of these rules would conflict with federal rules, regulations, or polici es covering similar stationary sources.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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to Rule 4603 and Rule 4684 VIII. RULE DEVELOPMENT PROCESS

In June 2009, as part of the rule development proce ss, in June 2009 District staff mailed copies of the proposed amendments to Rules 4603 and 4684 to affected sources, interested parties, the public, EPA and ARB to soli cit their comments. In addition, the notice of the proposed amendments to the rules was also published in a general circulation newspaper in each of the eight San Joaq uin Valley counties. The commenting deadline ended on July 20, 2009. Comments received during the rule development process were incorporated into the rule amendments as appropriate. Comments received and District responses are discussed in Appendix A of the Final Draft Staff Report.

The notice of the public hearing for the proposed r ules will be published in a general circulation newspaper in each of the eight San Joaq uin Valley counties and was mailed to affected sources, interested parties, the public, E PA and ARB. The public notice will solicit written comments to be submitted by mail, a nd it also identified the name and telephone number of the District staff who can answ er questions and respond to comments. The Receive and File for these proposed actions is scheduled for August 20, 2009. The public hearing to consider the proposed actions by the District Governing Board is scheduled for September 17, 2009.

IX. REFERENCES

1. EPA CTG for Miscellaneous Metal and Plastic Part s Coatings (EPA 453/R-08-003), September 2008.

2. EPA CTG for Fiberglass Boat Manufacturing Materi als (EPA 453/R-08-004), September 2008.

3. 40 CFT Part 63 Subpart VVVV (National Emission S tandards for Hazardous Air Pollutants for Boat Manufacturing), August 22, 2001

.

4. SCAQMD Rule 1162 (Polyester Resin Operations) Fi nal Staff Report, November

2001.