South Coast Air Quality Management District
South Coast Air Quality Management District
BOARD MEETING DATE: November 9, 2001 AGENDA NO. 32
Amend Rule 1162 - Polyester Resin Operations
SYNOPSIS:
The proposed Amendments will further reduce emissions of VOC and hazardous air pollutant compounds from composite manufacturing operations by employing Pollution Prevention (P2) technologies. The amendments will require the use of less polluting nonatomizing application technologies, lower monomer content of resin and gel coat materials, and inert fillers and vapor suppressants. PAR 1162 will implement portions of control measures CTS-08 and CTS-09.
COMMITTEE:
Stationary Source, September 28, 2001, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
- Certifying the CEQA Final Environmental Assessment (EA) for Proposed Amended
Rule 1162-Polyester Resin Operations;
- Amending Rule 1162 - Polyester Resin Operations.
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Rule 1162 applies to all polyester resin (composite) operations in the AQMD, which include but are not limited to, the manufacturers of the bathware products, vanity installations, hulls for recreational and commercial watercraft, bodies for recreational vehicles, building panels and appliances, automotive, aerospace and aircraft components, and structural components for chemical process equipment and storage tanks.
In January 2001, the AQMD adopted Rule 1132-Further Control of VOC Emissions from High-Emitting Spray Booth Facilities. Rule 1132 implemented the first phase and a portion of the second phase of Control Measure CTS-09. Rule 1132 applies to high-emitting operations of several industries including the composite industry and identifies a series of pollution prevention (P2) technologies as a compliance option for the composite facilities subject to this rule. The adopting resolution of Rule 1132 also directed staff to work with the composite industry to develop an amendment to Rule 1162 that incorporates and implements the P2 strategies included in Rule 1132 across the entire composite industry.
The objective of PAR 1162 is to implement the Board’s direction and further reduce volatile organic compound (VOC) and hazardous air pollutant (HAP) emissions utilizing and expanding the P2 technologies incorporated in Rule 1132. P2 technologies involve the use of nonatomizing application technologies and modifying the chemistry of the materials to minimize the release of VOC and HAP emissions at the source.
Based on the1998-99 Emissions Inventory Report, staff has identified 81 composite facilities in the AQMD subject to PAR 1162. The annual emissions inventory of these facilities is estimated at 7.98 tons per day of VOCs and HAPs.
Proposal
PAR 1162 will further reduce VOC and HAP emissions from composite operations by applying P2 technologies and implement portions of Control Measure CTS-08 and Control Measure CTS-09 of the 1999 AQMP Amendments to the 1997 Ozone State Implementation Plan of the South Coast Air Basin.
The proposed rule would reduce approximately 5.40 tons per day, which represents approximately 68 % of the VOC and HAP emissions of all composite facilities in the AQMD. These emission reductions will fully meet the reduction commitments of CTS-08 and CTS-09.
The use of nonatomizing application technologies, low monomer resin material, fillers and vapor suppressants will reduce waste and emissions. Resin material savings from waste and emission reductions are expected to offset most of the cost impacts associated with this amendment, and may potentially lead to a total net cost savings.
Policy Issues
Composite fabricators have expressed concerns regarding the requirement to use nonatomizing application techniques to spray gel coats.
Staff is cognizant of the difficulties and learning curve associated with the use of nonatomizing application technologies to spray gel coats. While progress made so far is encouraging, staff recognizes additional time may be needed to complete the fine-tuning of the nonatomizing application of gel coats and also allow for a smooth transition for the entire industry to the new technology. As a result, staff has modified the proposal and extended the effective date for the use of nonatomizing gel coat applications to July 1, 2003, and is committing to conduct a technology assessment to confirm the feasibility of the technology six months prior to the effective date.
AQMP and Legal Mandates
The California Health and Safety Code requires the AQMD to adopt an Air Quality Management Plan (AQMP) to meet state and federal ambient air standards in the Basin. In addition, the California Health and Safety Code requires that the AQMD adopt rules and regulations that carry out the objectives of the AQMP. The proposed rule amendment implements the control measures CTS-08 and CTS-09 of the 1999 Amendment to the 1997 AQMP.
CEQA & Socioeconomic Analysis
Pursuant to the California Environmental Quality Act (CEQA) and the AQMD’s Certified Regulatory Program (Rule 110), staff has prepared an Environmental Assessment (EA) for PAR 1162. The Draft EA, which was made available for a 30-day review period, concluded that PAR 1162 would not have any significant adverse affect on the environment. No comments were received on the Draft EA. The Final EA is included as part of the attached package for the public hearing on the proposed amendments. There are no significant socioeconomic impacts anticipated from the proposed amendments. The cost-effectiveness of the proposed amendments ranges from a cost saving to a cost of up to $719 per ton of VOC reduced.
Implementation Plan
The proposed rule will affect all composite facilities in the District. Staff will continue to work with the affected facilities and its trade association and be available should a need arise for assistance during implementation.
Resource Impacts
When fully implemented, PAR 1162 is not expected to significantly increase the workload for compliance staff.
/ / /