EL DORADO COUNTY AIR QUALITY MANAGEMENT DISTRICT

RULE 240 - POLYESTER RESIN OPERATIONS
(Adopted: February 15, 2000)

INDEX

240.1 GENERAL

  1. PURPOSE
  2. APPLICABILITY
  3. EXEMPTION—LOW USAGE
  4. SEVERABILITY

240.2 DEFINITIONS

  1. AIRLESS SPRAY EQUIPMENT
  2. AIR ASSISTED AIRLESS SPRAY EQUIPMENT
  3. CATALYST
  4. CLEANING MATERIAL
  5. CLOSED MOLD SYSTEM
  6. CONTROL SYSTEM
  7. CORROSION-RESISTANT MATERIALS
  8. CROSS-LINKING
  9. CURE
  10. ELECTROSTATIC AIR SPRAY EQUIPMENT
  11. ENCLOSED GUN CLEANER
  12. FIBERGLASS
  13. GEL COAT
  14. HIGH VOLUME LOW PRESSURE (HVLP) APPLICATION EQUIPMENT
  15. INHIBITOR
  16. LOW-VOLUME LOW-PRESSURE (LVLP) APPLICATION EQUIPMENT
  17. MONOMER
  18. POLYESTER
  19. POLYESTER RESIN MATERIALS
  20. POLYESTER RESIN OPERATIONS
  21. POLYMER
  22. POLYMERIZATION
  23. REPAIR
  24. RESIN
  25. SPECIALTY RESIN
  26. TOUCH-UP
  27. VAPOR SUPPRESSANT
  28. WASTE MATERIAL

240.3 STANDARDS

  1. PROCESS AND CONTROL REQUIREMENTS
  2. SPRAY APPLICATION REQUIREMENTS
  3. CLEANING MATERIAL REQUIREMENTS
  4. STORAGE AND DISPOSAL REQUIREMENTS

240.4 ADMINISTRATIVE REQUIREMENTS

  1. CALCULATION FOR DETERMINING VOC WEIGHT PER VOLUME OF MATERIAL
  2. CALCULATION FOR DETERMINING PERCENT MONOMER (STYRENE) CONTENT AS APPLIED
  3. CALCULATION FOR DETERMINATION PERCENT CONTROL EFFICIENCY & VOC MASS EMISSION RATE
  4. CALCULATION FOR DETERMINING OVERALL SYSTEM EFFICIENCY
  5. OPERATION AND MAINTENANCE PLAN
  6. PROCEDURE FOR PROCESSING OPERATION AND MAINTENANCE PLAN
  7. COMPLIANCE SCHEDULE

240.5 MONITORING AND RECORDKEEPING

  1. RECORD KEEPING
  2. FREQUENCY OF RECORD KEEPING
  3. DURATION OF RECORDS
  4. TESTING PROCEDURES

240.6 VIOLATIONS

RULE 240
POLYESTER RESIN OPERATIONS


240.1 GENERAL

  1. PURPOSE: The purpose of this rule is to reduce emissions of volatile organic compounds from polyester resin operations.

  2. APPLICABILITY: This rule applies to any person who supplies, sells, offers for sale, applies, or solicits the application of any gel coat or polyester resin material, or who manufacturers any gel coat or polyester resin in the District.

  3. EXEMPTION—LOW USAGE: The provisions of this rule, other than the record keeping requirements of Section 240.5 A., shall not apply to any person operating a polyester resin operation where the volume of polyester resin materials used is less than 20 gallons per month.

  4. SEVERABILITY: If any section, subsection, sentence, clause, phrase, or portion of this rule is, for any reason, held invalid, unconstitutional, or unenforceable by any court of competent jurisdiction, such portion shall be deemed as a separate, distinct, and independent provision, and such holding shall not affect the validity of the remaining portions thereof.


240.2 DEFINITIONS

  1. AIRLESS SPRAY EQUIPMENT: Equipment for applying materials by use of fluid pressure without atomizing air, including heated airless spray.

  2. AIR-ASSISTED AIRLESS SPRAY EQUIPMENT: Equipment for applying materials by use of fluid pressure to atomize coating and air pressure between 0.1 and 10 pounds per square inch gauge (psig) to adjust spray pattern.

  3. CATALYST: A substance added to resin to initiate or promote polymerization.

  4. CLEANING MATERIAL: Any material containing a volatile organic compound (VOC) and used to clean hands, work areas, tools, molds, application equipment, and any other equipment related to a polyester resin operation.

  5. CLOSED MOLD SYSTEM: A method of forming objects from polyester resin material by placing the polyester resin material in a confining mold cavity and applying pressure and/or heat.

  6. CONTROL SYSTEM: A device used to reduce emissions of VOC and its associated collection system.

  7. CORROSION-RESISTANT MATERIALS: Materials that include halogenated, furan, bisphenol A, vinyl ester, or isophthalic resins and are used to make products for corrosive or fire retardant applications.

  8. CROSS-LINKING: The process of chemically bonding two or more polymer chains together.

  9. CURE: To polymerize, i.e. to transform from a liquid to a solid or semi-solid state to achieve desired product physical properties, including hardness.

  10. ELECTROSTATIC AIR SPRAY EQUIPMENT: Equipment used to apply materials by charging atomized particles that are deposited by electrostatic attraction.

  11. ENCLOSED GUN CLEANER:

    1. A device that is used for the cleaning of spray guns, pots and hoses, that has an enclosed solvent container, is not open to the ambient air when in use, and has a mechanism to force the cleanup material through the gun while the cleaner is in operation; or

    2. A device that is used for the cleaning of spray guns, pots and hoses, that has an enclosed solvent container, uses non-atomized solvent flow to flush the spray equipment and collects and returns the discharged solvent to the enclosed container.

  12. FIBERGLASS: A fiber similar in appearance to wool or cotton fiber but made from glass.

  13. GEL COAT: A polyester resin topcoat that enhances appearance and improves resistance to degradation from exposure to the environment. A gel coat may be pigmented or may be clear.

  14. HIGH-VOLUME LOW-PRESSURE (HVLP) APPLICATION EQUIPMENT: Equipment used to apply coatings by means of a gun which is designed to be and is operated between 0.1 and 10.0 pounds per square inch gauge (psig) air pressure measured dynamically at the center of the air cap and at the air horns.

  15. INHIBITOR: A substance used to slow down or prevent a chemical reaction.

  16. LOW-VOLUME LOW-PRESSURE (LVLP) APPLICATION EQUIPMENT: Spray coating application equipment with air pressure between 0.1 and 10.0 pounds per square inch gauge (psig) and air volume less than 15.5 cfm per spray gun and which operates at a maximum fluid delivery pressure of 50 psig.

  17. MONOMER: An organic compound that combines with itself, or other similar compounds, to become a cured thermosetting resin.

  18. POLYESTER: A complex polymeric ester containing difunctional acids and alcohols dissolved in a monomer.

  19. POLYESTER RESIN MATERIALS: Unsaturated polyester resin such as isophthalic, orthophthalic, halogenated, bisphenol-A, vinyl-ester, or furan resins; cross-linking agents; catalysts, gel coats, inhibitors, accelerators, promoters, and any other VOC-containing materials comprising a resin made from polyester. Inert filler and cleaning material are excluded from this definition.

  20. POLYESTER RESIN OPERATIONS: The production or rework of products by mixing, pouring, hand lay-up, impregnating, injecting, forming, winding, spraying, and/or curing unsaturated polyester resin materials with fiberglass, fillers, or any other reinforcement materials, and associated cleanup.

  21. POLYMER: A chemical compound comprised of a large number of chemical units, which is formed by the chemical linking of monomers.

  22. POLYMERIZATION: To transform from a liquid to a solid or semi-solid state to achieve desired product physical properties, including hardness.

  23. REPAIR: The part of the fabrication process that requires the addition of polyester resin material to portions of a previously fabricated product in order to mend structural damage.

  24. RESIN: Any of a class of organic polymers of natural or synthetic origin used in reinforced products to surround and hold fibers or filler particles, and is solid or semisolid in the cured state.

  25. SPECIALTY RESIN: Any halogenated, furan, bisphenol-A, vinyl-ester, or isophthalic resin used to make products for exposure to one or more of the following extreme environmental conditions: acute or chronic exposure to corrosive agents, caustic agents, acidic agents, or flame.

  26. TOUCH-UP: The portion of the fabrication process that is used to cover minor imperfections.

  27. VAPOR SUPPRESSANT: A substance added to resin to minimize the diffusion of monomer vapor into the atmosphere.

  28. WASTE MATERIAL: Includes, but is not limited to, scraps resulting from cutting and grinding operations, any paper or cloth used for cleaning operations, waste resins, or any spent cleaning materials.

240.3 STANDARDS

  1. PROCESS AND CONTROL REQUIREMENTS:

    1. Each polyester resin operation shall comply with one of the following process or control requirements:
      1. Use low-VOC polyester resins with the following monomer content:
        1. Resins, except for specialty resins and gel coats, which contain no more than 35% by weight as applied, as determined by Section 240.5 D.3.
        2. Pigmented gel coats which contain no more than 45% by weight as applied, as determined by Section 240.5 D.3.
        3. Specialty resins and clear gel coats which contain no more than 50% by weight as applied, as determined by Section 240.5 D.3.
      2. A polyester resin material containing a vapor suppressant, such that weight loss from VOC emissions does not exceed 60 grams per square meter of exposed surface area during resin polymerization, as determined by Section 240.5 D.1.
      3. Use of a closed-mold system.

    2. As an alternative to Section 240.3 A.1, a source may install and operate an emissions control system that:
      1. Has been permitted by the Air Pollution Control Officer, pursuant to Rule 501 General Permit Requirements.
      2. Has an overall capture and control efficiency of 85% or greater on a mass basis, as determined by Section 240.4 D.
      3. Complies with the requirements of Section 240.4 E.

  2. SPRAY APPLICATION REQUIREMENTS: Spray application of polyester resin materials shall only be performed using one or more of the following application methods:
    1. airless,
    2. air-assisted airless,
    3. high-volume low-pressure (HVLP),
    4. low-volume low-pressure (LVLP),
    5. electrostatic spray equipment or
    6. any other equivalent method which has been approved in writing by the Air Pollution Control Officer, the U.S. Environmental Protection Agency and the California Air Resources Board.

  3. CLEANING MATERIAL REQUIREMENTS: A person shall not use cleaning materials containing more than 1.7 pounds of VOC per gallon (204 gm/l) as applied and as determined by Section 240.5 D.2., unless the material is used in an enclosed gun cleaner.

  4. STORAGE AND DISPOSAL REQUIREMENTS:
    1. Each polyester resin operation shall use closed containers to store all polyester resin materials, cleaning materials, and any VOC-containing materials, except when accessed for use.
    2. Each polyester resin operation shall use closed containers for the disposal of all uncured polyester resin materials, cleaning materials, waste materials, and any VOC-containing materials.

240.4 ADMINISTRATIVE REQUIREMENTS

  1. CALCULATION FOR DETERMINING VOC WEIGHT PER VOLUME OF MATERIAL:
    The weight of VOC per volume of material shall be calculated by the following equation:

    Grams VOC per liter of material = (Ws - Ww - Wec) / Vm

    Where:
    Ws = weight of all volatile compounds in grams
    Ww = weight of water in grams
    Wec = weight of exempt compounds in grams
    Vm = volume of the material in liters

  2. CALCULATION FOR DETERMINING PERCENT MONOMER (STYRENE) CONTENT AS APPLIED:
    The percent monomer content of a resin as applied shall be calculated by the following equations. Batch weight and styrene weight calculations shall be completed to provide inputs into percent monomer equation.

    Batch Weight = R + F + P + O

    Where:
    R = Resin Weight
    F = Filler Weight
    P = Pigment Weight
    O = Other Additives Weight

    Styrene Weight = R x SP
        100

    Where:
    R = Resin Weight
    SP = % Styrene in Resin(from Manufacturer)


    Percent Monomer =

    Styrene Weight

    		X 100
     

    Batch Weight

    		 
  3. CALCULATION FOR DETERMINING PERCENT CONTROL EFFICIENCY AND VOC MASS EMISSION RATE:
    The VOC mass emission rate shall be calculated both upstream and downstream of the emissions control device based on the respective VOC mass concentration and volumetric flow rate, pursuant to Section 240.5 D.6., and the following equation:

    M = (Q)(C)(60 min/hr) [Calculated upstream and downstream]

    Where:
    M = VOC mass emission rate (upstream/downstream), in lb/hr.
    Q = the volumetric flowrate at the inlet (upstream) or exhaust stack outlet (downstream), in scfm.
    C = the VOC mass concentration at the inlet (upstream) or outlet (downstream), in lb/scf, as measured pursuant to Section 240.5 D.6.

    The percent control efficiency is calculated as follows:

    % CE = [(MU - MD)/MU] x 100

    Where:
    CE = control efficiency.
    MU = the upstream VOC mass emission rate, in lb/hr.
    MD = the downstream VOC mass emission rate, in lb/hr.
  4. CALCULATION FOR DETERMINING OVERALL SYSTEM EFFICIENCY:
    To verify compliance with Section 240.3 A.2., the overall system efficiency is calculated as follows:

    % SE = [% CLE x % CE] x 100

    Where:
    SE = system efficiency.
    CLE = collection efficiency, as determined by Section 240.5 D.5.
    CE = control efficiency, as determined by Sections 240.4 C., and 240.5 D.6    .

  5. OPERATION AND MAINTENANCE PLAN: Any person using emission control equipment pursuant to Section 240.3 A.2., shall submit an Operation and Maintenance Plan for the emission control equipment to the Air Pollution Control Officer for approval. The Plan shall specify operation and maintenance procedures which will demonstrate continuous operation and compliance of the emission control equipment during periods of emission-producing operations. The Plan shall also specify which daily records must be kept to document the operation and maintenance procedures. These records shall comply with the requirements of Section 240.5. The Plan shall be implemented upon approval by the Air Pollution Control Officer.

  6. PROCEDURE FOR PROCESSING OPERATION AND MAINTENANCE PLAN:

    1. APPROVAL OF PLAN: The Air Pollution Control Officer shall determine whether the Operation and Maintenance Plan meets the requirements of Section 240.4 E., not later than 30 days after receipt of the Plan, or within a longer period of time agreed upon by the parties. The Air Pollution Control Officer shall approve an Operation and Maintenance Plan unless it fails to demonstrate continuous operation of the emission control equipment during periods of emission producing operations, according to the standards set forth in Section 240.3 A.2., or it fails to specify which daily records, in accordance with the requirements of Section 240.5, are to be kept to document the operation and maintenance procedures set forth in the Plan.

    2. REVISION OF PLAN: If the Air Pollution Control Officer does not approve an Operation and Maintenance Plan, the source shall receive written notice of the deficiency, and shall have an additional 30 days from the date of the notification of the deficiency to correct and resubmit the Operation and Maintenance Plan. The decision of the Air Pollution Control Officer regarding the resubmitted Operation and Maintenance Plan shall be final. Failure to correct the deficiency in an Operation and Maintenance Plan upon resubmittal shall constitute a violation of this rule that is subject to the penalties set forth in Health and Safety Code section 42400 et seq.

  7. COMPLIANCE SCHEDULE:

    1. A polyester resin operation which is subject to the requirements of this rule shall be in compliance no later than six (6) months from the date of adoption of this rule, except for facilities electing to comply with Section 240.3 A.2.

    2. Facilities operating prior to the date of adoption of this rule which elect to install and operate an emission control system pursuant to the requirements of Section 240.3 A.2., shall have the control system installed and operating by no later than twelve (12) months from the date of adoption.


240.5 MONITORING AND RECORDKEEPING

  1. RECORD KEEPING: In addition to any applicable record keeping requirements of either Rule 523 NEW SOURCE REVIEW, Rule 522 Title V - FEDERAL OPERATING PERMIT PROGRAM, and Rule 521 LIMIT POTENTIAL TO EMIT, or any other District rule which may be applicable, any person subject to this rule shall maintain the following records in order to evaluate compliance:

    1. Records of the type and quantity of all resins, catalysts, and cleaning materials used.

    2. Records of the type and quantity of all filler material, pigment materials, and all additional additives used in resins as applied.

    3. Records of the monomer content, in weight percent, of all resin materials used or stored at the facility.

    4. Records of the VOC content of all VOC containing cleaning materials used and stored at the facility, calculated pursuant to Section 240.4 A.

    5. Records showing the weight loss per square meter during resin polymerization for each vapor-suppressed resin, and amount of such resin used.

    6. Records of hours of operation and key operating parameters, pursuant to Section 240.4 E, for any add-on control equipment used to comply with Section 240.3 A.2.

  2. FREQUENCY OF RECORD KEEPING

    1. For sources which have total facility VOC emissions greater than 5 tons per year, records shall be maintained on a monthly basis.

    2. For sources which have total facility VOC emissions less than or equal to 5 tons per year, records shall be maintained on a annual basis.

    3. If at any time during a reporting period under Sections 240.5 B.1. or 240.5 B.2., a source uses a coating which does not comply with the standards set forth in Section 240.3 A., the source shall keep daily records regarding the use, including the lack of use, of that non-compliant resin during the applicable reporting period.

  3. DURATION OF RECORDS: Records required by this section shall be maintained on-site for a continuous five year period and made available to the Air Pollution Control Officer upon request.

  4. TESTING METHODS: The analysis of polyester resin materials, cleaning materials, and collection/control efficiency shall be conducted using the following testing procedures:

    1. RESIN VOC WEIGHT LOSS: "Static Method for Determination of Volatile Emissions from Polyester and Vinyl Ester Resins" (RACT/BARCT Guidance, 1991) shall be used for determining VOC emissions from polyester and vinyl ester resins as received from the manufacturer.

    2. DETERMINATION OF VOC CONTENT: VOC content of coatings shall be determined in accordance with EPA Method 24 and Section 240.4 A., of this rule as applicable.

    3. DETERMINATION OF PERCENT MONOMER CONTENT OF RESINS AS APPLIED: Percent monomer content as applied shall be determined in accordance with Section 240.4 B.

    4. DETERMINATION OF COMPOUNDS EXEMPT FROM VOC DEFINITION: Compounds exempted from the VOC definition, as listed in Rule 102, shall be determined in accordance with ASTM D 4457-85 or ARB Method 432. If any of the perfluorocarbons or volatile cyclic and linear methyl siloxanes are being claimed as exempt compounds, the person making the claim must state in advance which compounds are present, and the EPA-approved test method to be used to make the determination of these compounds.

    5. DETERMINATION OF COLLECTION EFFICIENCY: Efficiency of the collection system shall be determined using:
      1. Applicable U.S. EPA Methods 204, 204A, 204B, 204C, 204D, 204E, and/or 204F; or
      2. Any other method approved by the U.S. EPA, the California Air Resources Board, and the Air Pollution Control Officer.

    6. DETERMINATION OF CONTROL EFFICIENCY: Efficiency of control equipment shall be determined in accordance with EPA Method 18, 25, 25A, EPA Method 2 or 2C (whichever is applicable), and Section 240.4 C.

240.6 VIOLATIONS:
Failure to comply with any provision of this rule shall constitute a violation of this rule.