BOARD MEETING DATE: July 11, 2003
AGENDA NO. 34

Amend Rule 1162 – Polyester Resin Operations

SYNOPSIS:

The proposed amendment will postpone the effective date for the non-atomized application of gel coats from July 1, 2003 to July 1, 2004. The amendment is necessary to allow for the completion of testing, evaluation by staff and purchase and installation of compliant equipment by industry.

COMMITTEE:

Stationary Source, June 27, 2003, Reviewed

RECOMMENDED ACTION:

Adopt the attached resolution:

1. Certifying the CEQA Final Environmental Assessment (EA) for Proposed Amended Rule 1162-Polyester Resin Operations;
    
2. 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.

The objective of PAR 1162 is to postpone only the effective date to require the nonatomizing application of gel coats, as required in Rule 1162, from July 1, 2003, to July 1, 2004, to establish the appropriate measurement parameters to be used in the definition of the nonatomizing spray application technique for gel coats. This additional time is required to identify appropriate parameters, complete a testing program in the selecting parameters, analyze the results, incorporate the parameters into the definition of nonatomizing spray application technique of gel coats and allow for the purchase and installation of the compliant equipment by industry.

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 volatile organic compounds (VOCs) and hazardous air pollutants (HAPs). The VOC emissions reduction of the November 2001 rule amendment was estimated to be 5.40 tons per day and the current proposed amendment will delay a VOC emission reduction of 0.43 tons per day for one year.

Proposal

PAR 1162 will postpone the effective date to require the nonatomizing application of gel coats, as required in Rule 1162, from July 1, 2003, to July 1, 2004, to establish the appropriate definition of the nonatomizing spray application technique of gel coats. The use of nonatomizing spray application technologies is estimated to reduce VOC emissions from the application phase by an average of 72%. The emissions from the spraying phase represent 55% of the total emissions profile of composite operations. Therefore, the use of nonatomizing spray application technology in gel coat operations is estimated to achieve an average VOC emissions reduction of about 40% by weight. (November 2001 Staff Report)

Policy Issues

The technique for nonatomizing spray application of gel coats has been demonstrated and is in use. There are however, a few operations, such as high production operations that are still perfecting this application technique to produce an acceptable product quality. Regardless of the gel coat application though, the minimum of three inches of coherent stream without droplets that defines nonatomizing spray application technique in the rule is not appropriate for gel coats. A different definition for gel coats based on pressure of application or other parameters will be necessary.

Once a new definition is established, staff is aware that purchase of equipment, and more impotantly, training the applicators will be required to implement the nonatomizing spray application techniques. Staff will contine to work with gel coat manufacturers, spray equipment suppliers and composite product fabricators to assist in the implentation of the techniques.

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.

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 45-day review period, concluded that PAR 1162 would have significant adverse air quality impacts, including toxic air contaminant impacts because the delay in anticipated daily VOC emissions reductions exceeds the AQMD’s VOC and hazard index thresholds. Therefore, a Statement of Findings and Overriding Considerations has been prepared. No other significant adverse impacts were identified as a result of implementing the proposed project. 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 amendment.

There will be no socioeconomic analysis associated with the amendment because there is no additional cost for the composite industry.

Implementation Plan

The proposed rule will affect all composite facilities in the AQMD. Staff will continue to work with the affected facilities and their trade association during implementation.

Resource Impacts

While no fiscal impacts are anticipated from the implementation of the proposed amendment, the development of a new definition for nonatomizing application of gel coats, including conducting some testing that may be necessary, may result in minor fiscal impacts.

Attachments

1. Summary of Proposed Rule
2. Rule Development Process
3. Key Contacts
4. Resolution
5. Rule Language
6. Staff Report
7. Environmental Assessment

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