COLUSA COUNTY AIR POLLUTION CONTROL DISTRICT

REGULATION II - PROHIBITIONS

RULE 2.37 - VOLATILE ORGANIC COMPOUND CONTROL MEASURE FOR POLYESTER RESIN OPERATIONS
(Adopted 1/23/96)

a. PURPOSE

To reduce Volatile Organic Compound emissions from polyester resin operations to levels consistent with reasonably available control technology (RACT).

b. APPLICABILITY

This rule is applicable to all commercial, military, and industrial stationary sources performing polyester resin operations.

c. EXEMPTIONS

The provisions of Section e. shall not apply to touch-up and repair.

d. DEFINITIONS

  1. AIRLESS SPRAY

    A coatings spray application system using high fluid pressure to atomize the coating without compressed air.

  2. AIR-ASSISTED AIRLESS SPRAY

    A coating application system in which the coating fluid is supplied to the gun under fluid pressure and air is combined at the spray cap.

  3. CATALYST

    A substance added to the resin to initiate polymerization.

  4. CLEANING MATERIAL

    Materials used for cleaning including but not limited to, hands, tools, molds, application equipment, and work areas.

  5. CLOSED MOLD SYSTEM

    A method of forming an object from polyester resins by placing the material in a confining mold cavity and applying pressure and/or heat.

  6. CONTROL SYSTEM

    An emission control device and its associated collection system.

  7. CORROSION-RESISTANT MATERIALS

    Polyester resin materials used to make products for corrosion resistant applications such as tooling, fuel, or chemical tanks, swimming pools, and boat hulls.

  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 SPRAY

    The spray application of coatings where an electrostatic potential is created between the part to be coated and the coating particles.

  11. FIBERGLASS

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

  12. FIRE RETARDANT MATERIAL

    Polyester resin materials used to make products that are resistant to flame or fire.

  13. GEL COAT

    A polyester resin surface coating, either pigmented or clear, that provides a cosmetic enhancement and improves resistance to degradation from exposure to the environment.

  14. GENERAL PURPOSE POLYESTER RESINS

    Materials that are not corrosion resistant, fire retardant, high strength, vapor suppressed, or gel coats.

  15. GRAMS OF VOC PER LITER OF MATERIAL

    The weight of VOC per volume of material is calculated by the following equation:

  16. HIGH-STRENGTH MATERIALS

    Polyester resins which have casting tensile strength of 10,000 psi or more and which are used primarily for manufacturing of high performance boats and skis.

  17. HIGH VOLUME-LOW PRESSURE

    Spray equipment used to apply coatings by means of a gun which operates between 0.1 and 10 psi air pressure at the air cap of the spray gun.

  18. INHIBITOR

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

  19. LOW-VOC EMISSIONS RESIN SYSTEMS

    Polyester resin materials which contain vapor suppressants to reduce monomer evaporation loss.

  20. MONOMER

    A relatively low-molecular-weight organic compound, such as styrene, that combines with itself, or other similar compounds by a cross-linking reaction to become a cured thermosetting resin.

  21. POLYESTER

    A polymer containing repeating ester groups and multiple sites of unsaturation and which is soluble in styrene.

  22. POLYESTER RESIN MATERIALS

    Materials including, but not limited to, unsaturated polyester resins 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 in polyester resin operations.

  23. POLYESTER RESIN OPERATIONS

    Methods used for the production, rework, repair or touch-up of products by mixing, pouring, hand lay-up, impregnating, injecting, forming, winding, spraying, and/or curing unsaturated polyester resin materials.

  24. POLYMER

    A chemical compound comprised of a large number of chemical units and which is formed by the chemical linking of monomers.

  25. PULTRUSION

    A process where continuous roving strands are moved through a strand-tensioning device into a resin bath for impregnation and then passed through a heated die for curing.

  26. REPAIR

    That 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.

  27. RESIN

    Any of a class of organic polymers of natural or synthetic origin used in reinforced products to surround and hold fibers, and is solid or semi-solid in the cured state.

  28. TOUCH-UP

    That portion of the fabrication process that is necessary to cover minor imperfections.

  29. VAPOR SUPPRESSANT

    A substance added to a resin to minimize the outward diffusion of monomer vapor into the atmosphere.

  30. VOLATILE ORGANIC COMPOUND (VOC)

    Any compound as defined in District Rule 1.2 - Definitions

  31. WASTE MATERIALS

    Those materials that include, but are not limited to, scraps resulting from cutting and grinding operations, any paper or cloth used for cleaning operations, waste resins, and any spent cleaning materials.

e. STANDARDS

  1. For each process, a person operating a polyester resin operation shall comply with either the material requirements or one of the applicable process requirements set forth below:

    A. MATERIAL REQUIREMENTS:

    1. The use of polyester resin material with a monomer content of no more than the following limits:

    Polyester Resin Materials Monomer Content in Uncatalyzed Polyester Resin Materials as Applied (Weight Percent as Determined by South Coast AQMD Method 312)
    General Purpose Polyester Resin 35
    Corrosion-Resistant 50
    Fire Retardant 42
    High Strength 48
    Clear Gel Coat 50
    Pigmented Gel Coat 45

    B. PROCESS REQUIREMENTS

    1. The use of a resin containing a vapor suppressant, so 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 h.1.A. of this rule.
    2. The weight loss of polyester materials shall be less than four (4) percent when a closed-mold system is used.
    3. A pultrusion operation shall have covered wet-out baths. From exit of the bath to the die, all but 18 inches of the perform distance shall be enclosed to minimize air flow. The weight loss of polyester materials shall be less than three (3) percent in a pultrusion operation.
    4. Installation and operation of control equipment pursuant to Section f. of this rule.
  2. Only airless, air-assisted airless, high volume-low pressure, or electrostatic spray equipment shall be used for the application of polyester resin materials in spraying operations.

  3. CLEANING MATERIAL REQUIREMENTS

    A. Where the use of cleaning materials containing more than 1.7 pounds of VOC per gallon of material as applied and as determined by Section h.1.F. of this rule or having a initial boiling point less than 190oC, as determined by Section h.1.D. of this rule, exceeds four (4) gallons per day, a cleaning material reclamation system shall be used. Such a reclamation system shall operate with at least 80 percent efficiency. Solvent residues for on-site reclamation systems shall not contain more than 20 percent VOC by weight as determined by Section h.1.E. of this rule.
  4. STORAGE AND DISPOSAL REQUIREMENTS

    A. Closed containers shall be used for the storage of all uncured polyester resin materials, cleaning materials, and any unused VOC-containing materials except when being accessed for use.

    B. Self-closing containers shall be used in such a manner that effectively controls VOC emissions to the atmosphere for the disposal of all uncured polyester resin materials, cleaning materials, waste materials, and any unused VOC-containing materials.

f. CONTROL EQUIPMENT

In lieu of complying with the requirements of paragraph e.1, a person may install and operate an emission control system approved by the APCO which is designed and operated for the collection of fugitive emissions from polyester resin material, and which has a control device with an overall control and capture efficiency of 85 percent or more on a mass basis as determined by Sections h.1.B. and h.1.G. of this rule.

g. COMPLIANCE DATES

  1. Any person subject to the requirements of this Rule shall be in compliance with all provisions within twelve months from date of adoption.
  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 f. shall have the control system installed and operating within 18 months from date of adoption of this Rule.

h. MONITORING AND RECORDKEEPING

  1. TEST METHODS

    The analysis of cleaning materials, polyester resin materials, and control/collection efficiency shall be determined by the appropriate test methods as follows:

    A. South Coast AQMD Method 309, "Static Volatile Emissions" shall be used to determine weight loss of volatile organic compound from vapor suppressed resins.

    B. EPA Method 25A, "Determination of Total Gaseous Organic Concentration Using a Flame Ionization Analyzer".

    C. EPA Method 18, "Measurement of Gaseous Organic Compound Emissions by Gas Chromatography".

    D. ASTM D1078-86, "Distillation Range of Volatile Organic Liquids".

    E. Cali