SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT. Appendix A: Comments and Responses August 20, 2000 APPENDIX A

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1 APPENDIX A COMMENTS AND RESPONSES FOR PROPOSED AMENDMENTS TO RULE 4603 AND RULE 4684 August 20, 2009 A - 1 Final Draft Staff Report with Appendices for

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3 SUMMARY OF SIGNIFICANT COMMENTS AND DISTRICT STAFF S RESPONSES EPA Comments on Rule Comment: Consider the following revision to section 4.6: The provisions of this rule shall not apply to polyester resin operations and the application of polyester resin to metal parts and products. an operation subject to the requirements of Rule 4684 (Polyester Resin Operations). (EPA) Response: Please refer to the proposed rule for changes. 2. Comment: In Sections 5.5, 5.6 and 5.7, the rule exempts coating operations where the VOC emissions are less than 2.7 tons of VOC per 12-month rolling period for each coating category. To be consistent with EPA s 2008 CTG for Miscellaneous Metal and Plastic Products Coating, please revise this exemption so the VOC emissions are no greater than 2.7 tons of VOC per 12-month rolling period for all coating categories combined. (EPA) Response: The previously proposed language has been revised to make it consistent with the referenced CTG. Please refer to the proposed rule for changes. 3. Comment: Clarify Section 5.12 so that the application equipment requirements apply to plastic parts and pleasure craft coatings. (EPA) Response: The recommended change has been incorporated in the equipment application requirements of the rule. 4. Comment: Replace the VOC limits in Table 4 for clearcoat and for fog coat, and in Table 5 for finish primer/surfacer and high build primer/surfacer to match the CTG limits. (EPA) Response: The typographical errors in the previously proposed VOC limits for coatings mentioned by EPA have been corrected to match the CTG limits. 5. Comment: Consider removing existing Section pertaining to the VOC control system. (EPA) Response: Section has been deleted rule since it is duplicative of the same requirements that are already specified in Section A - 3 Final Draft Staff Report with Appendices for

4 EPA Comments on Rule Comment: As noted in the Technical Support Document (TSD) for EPA s proposed limited approval/disapproval of Rule 4684 (see FR 34704), the rule appears to apply to several major sources that are not boat manufacturing facilities, and are not covered by the 2008 CTG for Fiberglass Boat Manufacturing Materials. Rules in nonattainment areas must require RACT for major sources that are not covered by a CTG. Neither the District s April 2009 RACT SIP Demonstration nor the District s June 2009 staff report for the rule demonstrates that the requirements in the rule imposes RACT for major sources that are not fiberglass boat manufacturing. EPA identified the following two RACT deficiencies in their May 2008 TSD: SCAQMD Rule 1162, BAAQMD Rule 8-50, Ventura APCD Rule and Mojave Desert AQMD Rule 1162 contain more stringent monomer content than those in Rule SCAQMD Rule 1162, Ventura APCD Rule and Sacramento AQMD Rule 465 contain more stringent VOC capture and control system efficiency and is not limited to periods of continuous operation unlike Rule (EPA) Response: As stated by District staff in the Final Draft Staff Report, the sole purpose of this rulemaking project is to incorporate the 2008 CTG for Fiberglass Boat Manufacturing Materials into Rule This CTG does not address any emission standards for non-boat manufacturing materials. As stated in the District s RACT SIP Demonstration that was submitted to EPA in April 2009, although Rule 4684 limits are not identical to those contained within other districts rules, those are considered beyond RACT. The VOC limits and emission control requirements of Rule 4684 are consistent with the standards specified in ARB s Determination of Reasonably Available and Best Available Retrofit Control Technology for Polyester Resin Operations, which EPA should consider as the basis for RACT since there is no CTG for this source category. District staff researched ozone nonattainment areas in other states that are also required by CAA to have RACT rules, and found that they have no specific regulations on polyester resin operations even though they have sources in their jurisdictions. Staff believes that in the absence of a CTG for this source category, RACT is defined by the standards in ARB s RACT determination document, which was the basis of Rule District staff will review the benefits and costs of strengthening the rule beyond RACT in the context of an attainment plan control measure. 7. Comments: SCAQMD Rule 1162 and MDAQMD 1162 require non gel coats to be applied with atomizing application techniques and some additional requirements for closed mold systems and pultrusion operations. A - 4 Final Draft Staff Report with Appendices for

5 Response: Please refer to response to EPA comment #6 above. In addition, the 2008 CTG for fiberglass boat manufacturing does not require such standards. 8. Comments: SCAQMD Rule 1162 and BAAQMD Rule do not exempt facilities that use less than 20 gallons of polyester resin materials a month, though they have some exemptions that Rule 4684 does not have. (EPA) Response: Please refer to response to EPA comment #6 above. In addition, the 2008 CTG for fiberglass boat manufacturing recommends that the standards apply only to those facilities whose total emissions are 2.7 tons per 12-month rolling period. 9. Comments: Clarify that the VOC emission control system must satisfy all conditions in Sections through (EPA) Response: The requirements have been clarified and reformatted. Please see the proposed rule for changes 10. Comment: In Section , clarify how sources must demonstrate that the VOC emission control system is reducing emissions to a level that is not greater that would have been achieved through the use of compliant materials. (EPA) Response: Please refer to the proposed rule which included a provision for the required equivalency demonstration. 11. Comment: SCAQMD Rule 1162 requires vapor suppressed resin material to contain additives to reduce VOC evaporation loss to less than 50 grams/sq.meter of surface area and only allowed sources to comply by using vapor suppressed resin in lieu of meeting the monomer contents before July 1, Rule 4684 allows non-boat manufacturing facilities to comply vapor suppressed resin with the weight loss from VOC emissions does not exceed 60 grams/sq.meter instead of meeting the monomer content. Also, Rule 1162 requires tub/shower resins to meet both the monomer content and be vapor suppressed. Consider whether more stringent requirements are feasible for SJVAPCD sources. (EPA) Response: Please refer to response to EPA comment #6 above. In addition, the 2008 CTG for fiberglass boat manufacturing does not require such standards. 12. Comment: Please remove the phrase "excluding any materials that are exempt" from the definition of the terms in Equation 2 in Section That phrase is included in the definitions of these terms in the 2008 Fiberglass Boat Manufacturing Materials CTG. However, we believe the phrase refers to exemptions for certain types of materials that are described on pg. 25 of the CTG. In previous conversations, District Staff has noted that adding those exemptions A - 5 Final Draft Staff Report with Appendices for

6 could lead to potential SIP relaxation issues. EPA agrees, and supports not adding any unnecessary exemptions to the draft rule. (EPA) Response: District staff is proposing to include an exemption recommended in the CTG only for production resins (including skin coats) that must meet the specifications for use in military vessels or must be approved by the U.S. Coast Guard for use in construction of lifeboats, rescue boats, and other life-saving appliances. District staff believes that this provision does not constitute a relaxation of a SIP-approved version of rule 4684 because there are no fiberglass boat manufacturing facilities in the District that are currently manufacturing such types of vessels. Since such resin type for this specific use is considered an exempt material by the CTG, the calculation equation cited by EPA does not need to be changed. 13. Comment: Per the recommendations of the CTG, Section allows fiberglass boat manufacturing operations to comply by using add-on controls. The add-on control compliance option in the current SIP approved rule requires an 85% overall capture and control efficiency. Please ensure that the add-on control requirements for fiberglass boat manufacturing facilities do not relax requirements in the SIP approved version of the rule. (EPA) Response: Please see the proposed rule for changes. 14. Comment: EPA understands that the District plans to insert clarifying language in Section to indicate, per language on page 28 of the CTG, that for materials that are not included in the emissions average, the facilities will use the other compliance options in the draft rule. Also, the District plans to insert language in the draft rule from page 31 of the CTG to clarify the terms "plus vacuum bagging with roll-out" and "plus vacuum bagging without roll-out" in Table 2. Response: Please see the proposed rule for changes. ARB Comments on Rule 4684 ARB staff has reviewed the draft and has no comments on Rule 4684 at this time. ARB Comments on Rule Comment: ARB recommends adding in Section Table 3 a VOC limit of 340 grams of VOC per liter of coating for Military Specification 1-pack coatings, and revising the VOC limit for High-Baked Coatings Interior and Exterior Clear Coats to 480 g VOC per liter of coating and the VOC limit for Fog Coat to 260 g VOC per liter of coating as recommended in the September 2008 Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings. A - 6 Final Draft Staff Report with Appendices for

7 Response: The typographical errors in the table of limits have been corrected. Please refer to the rule for changes. 15. Comment: ARB suggested lowering the following coatings limits to meet the same limits as the South Coast AQMD: Coating Type VOC Limit (g VOC/liter) General One-Component 120 General Multi-Component 120 Electric Dissipating Coatings and Shock-Free Coatings 360 Response: As stated by District staff in the Final Draft Staff Report, the sole purpose of these proposed Rule 4603 amendments is to incorporate the RACT requirements established by EPA in the 2008 CTG. The South Coast limits are beyond RACT and are not prescribed in the CTG. District staff will review the SCAQM rule provisions for potential emissions reductions, in the context of future attainment plan control measure. 16. Comment: ARB recommended that Section 5.11 be modified so as to require that the storage containers be airtight. Response: District staff incorporated the work practices standards recommended in the CTG. The CTG requires the storage containers used for VOC-containing materials to be kept closed at all times except when depositing or removing these materials. The CTG does not require airtight containers. Stakeholders Comments National Paint Coatings Association (NPCA) RadTech International North America (RT) 17. Comment: Rule 4603: The proposed VOC limits for pleasure craft coatings, especially in the cases of high gloss, extreme gloss, and antifouling coatings are too low. NPCA member companies have made and will continue to make efforts to develop effective lower VOC pleasure craft coatings, but so far have not been able to do so at the proposed VOC limits. EPA is conducting a comprehensive technology review of pleasure craft coatings for purposes of setting NESHAP emissions limits. This data will provide a much more current and thorough understanding of what constitute RACT for these coatings. (NPCA) A - 7 Final Draft Staff Report with Appendices for

8 Response: The proposed amendments to Rule 4603 would include the 2008 CTG limits for pleasure craft coatings requirements. According to page 30 of the CTG, the pleasure craft coatings include the VOC content limits in the South Coast AQMD Rule (Pleasure Craft Coating Operations). It is important to mention that the SCAQMD Rule limits have been in place since January 1, In a telephone conversation, SCAQMD staff indicated their sources are able to comply with Rule limits, and that compliant coatings are commercially available. With regards to any future EPA NESHAP for this source category, the District will address the requirements in a separate rulemaking project when EPA promulgates the standards. 13. Comment: The staff report for Rule 4684 should reflect the findings of SCAQMD board which included Ultraviolet (UV)/Electron Beam (EB) technology as a compliant option in SCAQMD Rule 1162 (Polyester Resin Operations) as compliant option. The SCAQMD staff report (page 13) adopted on November 9, 2001 states: UV curing and electron beam (EB) are considered near zero or zero emissions resins because of their instantaneous polymerization. (RT) Response: Please refer to page 20 of the Final Draft Staff Report which cited SCAQMD s November 2001 Final Staff Report for Rule 1162 pertaining to UV/EB resins. However, District staff will not include UV/EB coatings as a compliance option in Rule 4684 since the CTG has not specifically included such coatings as a compliance option in the resin and gel coat monomer content limits. A - 8 Final Draft Staff Report with Appendices for