APPENDIX B Rule Consistency Analysis For Proposed Amendments to Rule 4602 August 20, 2009 B-1 Final Draft Staff Report with Appendices
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I. REQUIREMENTS OF ANALYSIS APPENDIX B Rule Consistency Analysis Pursuant to Section 40727.2 of the California Health and Safety Code, prior to adopting, amending, or repealing a rule or regulation, the District is required to perform a written analysis that identifies and compares the air pollution control elements of the rule or regulation with corresponding elements of existing or proposed District and United States Environmental Protection Agency (EPA) rules, regulations, and guidelines that apply to the same source category. The elements that were analyzed are emission standards, monitoring and testing, and recordkeeping and reporting requirements. II. RULE CONSISTENCY ANALYSIS A. District Rules Facilities could be subject to other District rules including: Rule 2201 New and Modified Stationary Source Review Rule Rule 4001 New Source Performance Standards Rule 4002 National Emissions Standards for Hazardous Air Pollutants Rule 4603 Surface Coating of Metal Parts and Products Rule 4612 Motor Vehicle and Mobile Equipment Coating Operations Rule 4653 Adhesives Rule 4661 Organic Solvents Rule 4663 Organic Solvent Cleaning, Storage, and Disposal The above-listed rules are not in conflict with, nor are they inconsistent with the requirements of Proposed Rule 4602. B. Federal EPA Rules and Regulations 1. Federal Control Techniques Guideline (CTG) 1977 CTG for Control of Volatile Organic Emissions from Existing Stationary Sources Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks (EPA-450/2-77-008). The 1977 CTG and subsequent implementation guidance provided RACT recommendations for controlling VOC emissions from automobile and light-duty truck assembly surface coating operations. These recommendations are summarized in Table 1. B-3 Final Draft Staff Report with Appendices
Table 1. 1977 CTG Recommended VOC Emission Limits of Automobile and Light- Duty Truck Surface Coatings. Electrodeposition primer operation Primer-Surfacer (guidecoat) operation Topcoat operation Final repair operation 0.14 kg VOC/liter (1.2 lb/gal) of coating, excluding water and exempt compounds, or 0.17 kg VOC/liter (1.4 lb VOC/gallon) of coating solids deposited 1.8 kg VOC/liter (15.1 lb VOC/gallon) of coating solids deposited on a daily average basis as determined by following the procedures in the Automobile Topcoat Protocol 1.8 kg VOC/liter (15.1 lb VOC/gallon) of coating solids deposited on a daily average basis as determined by following the procedures in the Automobile Topcoat Protocol 0.58 kg VOC/liter (4.8 lb/gal) of coating, excluding water and exempt compounsd 2. Alternative Control Technology (ACT) There is no EPA ACT for automobile and light-duty truck assembly coatings. 3. Federal New Source Performance Standards (NSPS) 40 CFR part 60 subpart MM (1980) The NSPS established the emission limits calculated on a monthly basis for each prime coat operation, guide coat (primersurfacer) operation, and topcoat operation located in an automobile or light-duty truck assembly plant constructed, reconstructed, or modified after October 5, 1979. The NSPS does not apply to plastic body component coating operations or to all-plastic automobile or light-duty truck bodies coated on separate coating lines. The VOC emission limit for prime coat operations depends on the solids turnover ration (R T ). The solids turnover ratio is the ratio of total volume of coating solids added to the EDP system in a calendar month to the total volumetric design capacity of the EDP system. The NSPS limits and the 1977 CTG recommendations for primer-surfacer and topcoat cannot be directly compared because of differences in the compliance period and how transfer efficiency is considered. B-4 Final Draft Staff Report with Appendices
Table 2. 1980 NSPS VOC Emission Limits for Automobile and Light-duty Truck Surface Coatings Prime coat Operations (Non-EDP) 0.17 kg VOC/liter (1.42 lb/gal) coating solids applied Prime coat Operations (EDP) Guide coat Operations (including the guide coat application, flashoff area, and oven) Topcoat Operations (including topcoat application, flash-off area, and oven) When solids turnover ration (R T ) > 0.16: 0.17 kg VOC/liter (1.42 lb/gal) coating solids applied When 0.040< R T <0.160: When R T <0.040: 0.160- RT 0.17x350 Kg VOC/liter (0.17x350 x8.34 lb/gal) coating solids applied 0.160- RT No VOC emission limit 1.40 kg VOC/liter (11.7 lb/gal) coating solids applied 1.47 kg VOC/liter (12.3 lb/gal) coating solids applied 4. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and Maximum Achievable Performance Standards (MACTs) 40 CFR part 63 Subpart IIII (2004), National Emission Standards for Hazardous Air Pollutants; Surface Coating of Automobile and Light-Duty Trucks. The NESHAP covers all equipment used to apply coating to new automobile or light-duty truck bodies or body parts and to dry or cure the coatings after application; all storage containers and mixing vessels in which vehicle body coatings, thinners, and cleaning materials are stored and mixed; all manual and automated equipment and containers used for conveying vehicle body coatings, thinners, and cleaning materials; and all storage containers and all manual and automated equipment and containers used to convey waste materials generated by an automobile and light-duty truck assembly coating operation. The 2004 NESHAP for automobile and light-duty truck assembly coating imposed organic HAP emission limitations calculated on a monthly basis for existing sources. More stringent limits apply to new sources. The NESHAP also sets emission limits for coatings not included in the CTG or NSPS, including glass bonding primer, glass bonding adhesive, and some coatings and thinners. B-5 Final Draft Staff Report with Appendices
Table 3. 2004 NESHAP HAP Emission Limits for Automobile and Light-Duty Truck Surface Coatings. Combined primer-surfacer, topcoat, final repair, glass bonding primer, and glass bonding adhesive operation plus all coatings and thinners, except for deadener materials and for adhesive and sealer materials that are not components of glass bonding systems, used in coating operations added to the affected source. Combined electrodeposition primer, primersurfacer, topcoat, final repair, glass bonding primer, and glass bonding adhesive operation plus all coatings and thinners, except for deadener materials and for adhesive and sealer materials that are not components of glass bonding systems, used in coating operations added to the affected source 5. EPA Policy on Recordkeeping 0.060 kg organic HAP/liter of coating solids deposited (0.50 lb/gal) for new or reconstructed affected sources 0.132 kg organic HAP/liter of coating solids deposited (1.10 lb/gal) for existing affected sources 0.036 kg organic HAP/liter of coating solids deposited (0.30 lb/gal) for new or reconstructed affected sources 0.072 kg organic HAP/liter of coating solids deposited (0.60 lb/gal) for existing affected sources The recordkeeping requirement in Rule 4602 is consistent with EPA s policy to keep and maintain records for at least five years. III. CONCLUSION Based on the above analysis, District staff concludes that Proposed Rule 4602 satisfies RACT for automobile and light-duty truck coating operations in terms of emission limits and equipment standards. B-6 Final Draft Staff Report with Appendices