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 1132, Further Control of VOC Emissions From HighEmitting Spray Booth Facilities

Prepared by: David Grounds

Reviewed by: Andrew Steckel

January 7, 2011
RULE IDENTIFICATION

Agency: South Coast Air Quality Management District (SCAQMD)

SIP Approved Rule: Rule 1132 – Further Control Of VOC Emissions From High-Emitting 

Spray Booth Facilities

Adopted – March 5, 2004

Submitted – April 1, 2004

EPA Approved – April 26, 2004 (69 FR 22445)

Subject of this TSD: Rule 1132 – Further Control Of VOC Emissions From High-Emitting 

Spray Booth Facilities

Adopted – May 5, 2006

Submitted – January 10, 2010

RULE SUMMARY – SCAQMD Rule 1132, Further Control Of VOC Emissions From High-Emitting

Spray Booth Facilities, is a rule designed to further reduce volatile organic compound (VOC)

emissions from large aerospace, metal, plastics, wood products coatings and open molding

composite manufacturing operations. 

The rule applies to spray booth facilities that emit more than 20 tons per year (tpy) of VOC and 

requires 65% emission reductions through the use of an air pollution control system,

reformulation of the sprayed materials to reduce the VOC emissions or a combination of 

control system and reformulation. There are approximately seventy nine (79) spray booth 

facilities, including nineteen (19) composite manufacturing facilities, in the SCAQMD that are 

subject to Rule 1132. 

Rule 1132 allows a facility to demonstrate non-atomized gel coat compliance through the use of

an Alternative Compliance Plan (ACP). Composite manufacturing facilities can calculate

emissions reduction for an ACP by using the approved emission factors from the Unified

Emission Factor (UEF) table. In order to obtain the emission reductions anticipated by the UEF

table for non-atomized gel coat spray application the application equipment would have to be 

operated at pressures that produce an inferior product surface that is not marketable. When

gel coat non-atomized application equipment is operated at pressures that produce products

that meet composite industry specifications, the application equipment produced essentially

the same emissions as conventional application methodology. The UEF table significantly

underestimates emissions from non-atomized gel coat applications. The main purpose of this

amendment is to prevent the use of the UEF table for non-atomizing gel coat application in

alternative compliance plans.
SCAQMD regulates an extreme 8-hour ozone non-attainment area, and SCAQMD designed Rule 

1132 partly to address the requirements for ozone non-attainment areas as described in Clean 

Air Act (CAA) section 182(e).

Significant changes in submitted SIP compared to SIP-approved rule include:

In Section (b)(1), changed the “Approved Emission Factors” definition to exclude the 

UEF emission rates for gel coat non-atomizing application.

In Section (b)(3), added a new definition for “Composite Material” to include gel coat 

materials and clarify that the bonding between gel coat, resin and reinforcement 

elements can be of mechanical and/or chemical nature.

In Section (d)(1), deleted the allowable method of fiberglass application since the 

chopper gun is the sole fiberglass application for the open molding composite 

operation.

In Section (d)(1), deleted the degree of roll-out as it is practically infeasible to have 

different emission rates for different degrees of roll-out.

EPA EVALUATION CRITERIA –

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)(CAA §182) – “Control Techniques for 

Miscellaneous Metal and Plastic Parts Coatings” (EPA-453/R-08-003, 9/08), “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 Chemical 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 Operations” (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 1132 is as stringent as the SIP. The changes 

are largely for clarification purposes and do not relax the rule by removing a compliance option 

for gel coat application. The SIP submittal generally contains sufficient testing and 

recordkeeping requirements to satisfy enforcement requirements. The stringency of 

requirements in submitted Rule 1132 is also generally consistent with relevant guidance and 

analogous rules in other areas that help define RACT. 

RULE DEFICIENCIES – We have identified no deficiencies with Rule 1132 sufficient for EPA to 

propose less than full approval.

EPA ACTION – Rule 1132 largely fulfills the relevant CAA §110 and part D requirements. EPA 

staff recommends full approval of Rule 1132 pursuant to CAA §110(k)(3) and §301(a).

REFERENCES –

1. SCAQMD Final Staff Report, May 2006.

2. Rule 1132, “Further Control Of VOC Emissions From High-Emitting Spray Booth 

Facilities,” Adopted May 5, 2006.

3. Rule 1132, “Further Control Of VOC Emissions From High-Emitting Spray Booth 

Facilities,” Approved April 26, 2004.