Proposal:
Set Public Hearing to Amend Rule 1124 - Aerospace Assembly and Component Manufacturing Operations
Synopsis:
Proposed amendments will extend the compliance dates for several types of adhesive bonding primers, fuel-tank coatings, solid-film lubricants and primer coatings from 1997 to either 1998, 2000 or 2002 because compliant coatings have not been qualified by all major aerospace companies. In addition, the VOC limits are proposed to be decreased for dry lubricative coatings.
Committee:
Stationary Source, November 22, 1996, Scheduled for Review
Recommended Action:
Set Public Hearing December 13, 1996, to amend Rule 1124 - Aerospace Assembly and Component Manufacturing Operations.
James M. Lents, Ph.D.
Executive Officer
Background
The purpose of Rule 1124 - Aerospace Assembly and Component Manufacturing Operations, is to reduce VOC emissions from aircraft and space craft coating, assembly and cleaning operations. Rule 1124 applies to any operation associated with manufacturing aircraft and space vehicles including spare parts, rework, and related maintenance of these vehicles. Rule 1124 was first adopted in 1979, and has undergone numerous amendments. In 1987, Rule 1124 was amended to require reductions of the VOC content in a number of coating categories including: adhesives, fuel-tank coating, and primers. In 1990, solid-film lubricant was added as a coating category.
In 1992, the Board extended the deadline to achieve the lower VOC grams per liter (g/l) standards to January 1, 1994. In December of 1993, the Board again extended the deadline for achieving the lower VOC content standards for three coatings (fuel-tank coatings, barrier coatings and wire coatings) to January 1, 1996 and for two additional coatings (adhesive bonding primers and solid-film lubricant) to January 1, 1997.
Several aerospace facilities have approached the AQMD requesting an extension of time to comply with the lower VOC content requirements that become effective January 1, 1997. The request is based on the fact that not all aerospace companies have qualified coatings that meet the lower VOC g/l requirements.
Proposal
The proposed amendments will expand the primer coating category into two sub-categories and postpone the VOC compliance date for the commercial exterior aerodynamic structure sub-category from January 1997 to January 2000. This rule amendment will divide the adhesive bonding categories into seven sub-categories and postpone the existing VOC compliance dates for five sub-categories from January 1997 to January 2000 and January 2002. The proposed amendments will divide the fuel-tank coating category into two sub-categories and postpone the VOC compliance date for the epoxy fuel-tank coating sub-category from January 1997 to January 1998.
An exemption from the current fuel-tank coating VOC content limit is proposed until January 2002 for non-spray applications of rubber solution fuel-tank coatings at facilities which use less than 150 gallons per year on fuel-tanks having a maximum capacity of 35 gallons. In addition, a minor reduction in the existing VOC limitation for dry lubricative material in the fastener coatings category is proposed and the compliance date for solid-film lubricant is proposed to be deferred from January 1997 to January 1998.
Acetone is now considered an exempt material pursuant to EPA’s requirements. This rule amendment now references Rule 102 - Definition of Terms for acetone and all other compounds considered exempt instead of maintaining a separate list in Rule 1124. This will prevent further modification to Rule 1124 in the event new future compounds are added to the VOC exempt list.
AQMP and Legal Mandates
The proposed amendments are estimated to result in excess emissions of 49 tons/year to 231 tons/year, or 0.13 tons/day to 0.63 tons/day. However, this delay in the final emission reductions anticipated to occur from Rule 1124 is not projected to negatively affect attainment of the ozone standard by 2010.
CEQA Findings/Socioeconomic Analysis
The proposed amendments are considered significant pursuant to CEQA. As such, staff prepared a Draft Supplemental Environmental Assessment (SEA) for the proposed amendments to Rule 1124. The Draft SEA was circulated for a 45-day public review and comment period. The proposed amendments to Rule 1124 are in response to issues raised by the aerospace industry and aerospace coating manufacturers and will delay emission reductions with no changes in the final VOC limits. Therefore, there is no additional cost impact resulting from this amendment.
Key Issues
There are several key issues involved in these proposed rule amendments. Following are the key issues:
The aerospace industry requested permanent higher VOC content limits to address a limited use specialized coating. This coating falls under the existing exemption for limited uses and, therefore, staff is not recommending changes to the rule since industry’s concern is addressed by the existing exemption provision.
Industry is recommending definitions that are non-specific and open-ended (i.e., "substrate neutral" and "wide curing temperature band"). Staff believes that for consistent field interpretation and enforcement the definitions need to be specific in order to prevent coatings from being classified in a number of sub-categories.
The aerospace industry is concerned about discrepancies between Rule 1124 and the CTG currently being drafted by the EPA. The revised CTG is not available at this time. Staff will consider changes at a later date after the revised CTG is issued.
Resource Impacts
Existing AQMD resources will be sufficient to implement all of the proposed changes to the rule with no impact on the budget.
Summary of Proposed Amendments
Rule Development Process
Key Contacts
Rule Language
Staff Report
CEQA Analysis