UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA’s Direct F inal Rulemaking

for the

California State Implementation Plan

South Coast Air Quality Management District, Rule 1132, Further Control of VOC Emissions From High

Emitting Spray Booth Facilities

Prepared by: David Grounds

Reviewed by: Andrew Steckel

January 7 , 2011RULE IDENTIFICATION

Agency : South Coast Air Q uality 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, Fur ther Control Of VOC Emi ssions From High

- Emitting Spray Booth Facilities, i s a rule designed to further reduce volatile organi c compound (VOC)
emissions from large aerospace, metal, plastics, wood products coatings and open molding composite manufacturing operations.

T he 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 o f the sprayed materials to reduce the VOC emissions or a combination of control system and reformulation

. There are a pproximately 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) . Compo site 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 produ ce 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 S C AQMD designed Rule

11 3 2 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), c hanged the “Approved E mission Factors” definition to exclude the UEF emission rates for gel coat non

- atomizing application. In Section (b)(3), a dded a new definition for “C omposite M aterial ” 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), d eleted 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), d eleted 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 Synth etic 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 an d 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 co mply 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

re cordkeeping 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 i dentified 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 Ma y 5, 2006.

3. Rule 1132, “Further Control Of VOC Emissions From High

- Emitting Spray Booth Facilities,” Approved April 26, 2004.