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PROPOSAL:

Set Public Hearing August 14, 1998 to Amend Rule 1107 – Coating of Metal Parts and Products

SYNOPSIS:

This proposal will divide the general air-dried coating category into two parts: single-component and multi-component coatings, and reduce the VOC content of the single-component coating from 2.8 to 2.3 lb/gal. Small use exemptions for one gallon per day and 55 gallons per year of non-compliant coatings are also being deleted due to the availability of compliant coatings. This proposal will reduce 1.0 ton per day of VOC emissions by March 1999.

COMMITTEE:

Stationary Source, June 19, 1998, Reviewed

RECOMMENDED ACTION:

Set Public Hearing August 14, 1998 Board meeting to amend Rule 1107 – Coating of Metal Parts and Products.

Barry R. Wallerstein, D.Env.
Acting Executive Officer

Background

Rule 1107 – Coating of Metal Parts and Products, was first adopted in June 1979, to control Volatile Organic Compound (VOC) emissions from the use of coatings to metal substrates. Today, there are approximately 1,500 permitted facilities in the South Coast Air Basin (Basin) that perform coating operations on metal parts and products. An estimated additional 425 facilities perform metal coating operations, but are too small to require permits. About 300 of the permitted facilities will be affected by this rule amendment, and except for a few highly specialized coating operations all of the small sources will need to comply with the proposed rule requirements.

Control measure 97-CTS-O2H in the 1997 Air Quality Management Plan (AQMP) calls for reductions in VOC emissions that results from the use of metal parts and products coatings either by reducing the VOC content or by requiring add-on control equipment.

Rule 1107 - Coating of Metal Parts and Products, limits the VOC content of 20 different types of coatings, by category, cure temperature and application technique. In general, coatings are classified as either air-dried (cured below 194°F) or baked (cured above 194°F). Air-dried coatings account for approximately 87% of the VOC emissions from this source category, with baked coatings accountings for the remaining 13%. Staff has evaluated the state of current technology and focused its attention on reducing the VOC content of single component liquid air-dried coatings in the general category (decorative coatings with a gloss rating less than 75 on a 60° meter).

This proposal will achieve VOC emission reductions of 1.0 ton per day principally through the proposed VOC limitation for single-component air-dried coatings of 2.3 lb VOC/gal, less water and less exempt compounds coatings. The cost-effectiveness for the universe of existing metal coaters is $7,200 per ton of VOC reduced.

Summary of Proposed Amendments

Effective March 1, 1999, the staff proposal will:

• set a new VOC limit for single-component general category air-dried metal parts and products coatings at 2.3 lb VOC/gal, less water and less exempt compounds;

• delete small uses exemptions of non compliant coatings for

  • facilities using less than one gallon of coating per day; and

  • facilities using no more than 55 gallons of coatings per rolling 12-month period;

• allow use of electric-insulating and thermally-conductive coatings under exemption; and

• retain the 55-gallon per year exemption for essential public service coatings used in repair and maintenance procedures.

Policy Issues

There are no major unresolved policy issues.

AQMD 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 total amount of emission reductions obtained by implementation of this rule is approximately 1.0 ton of VOC per day. The cost effectiveness of these reductions is $7,200 per ton of VOC reduced.

CEQA and Socioeconomic Analysis

AQMD staff has reviewed the proposed Rule 1107 - Coating of Metal Parts and Products, pursuant to state CEQA Guidelines Section 15002 (k)(2) and the AQMD’s Certified Regulatory Program (Rule 110). A Draft Environmental Assessment (EA) with no significant adverse impacts has been prepared because, although the Draft EA concluded that the proposed rule has the potential to adversely affect air quality, water demand and water quality, the impacts will not be significant. The Draft EA was circulated for a 30-day public review and comment period which ended June 22, 1998. All comments received will be addressed and incorporated into the final EA for the proposed project.

A Socioeconomic Assessment is prepared for the proposed amendments to Rule 1107 and is included in this set hearing package.

Implementation Plan

Enforcement staff will continue current inspection practices for the 1,500 permitted facilities subject to Rule 1107 - Coating of Metal Parts and Products by permit. Permitted facilities will be kept informed of the amendments by mail, outreach, and internet posting on the AQMD Home Page. Suppliers of coatings will be identified and notified by mail of the proposed amendments to Rule 1107 - Coating of Metal Parts and Products, so that area sources may be better informed. Dialogue will continue with coating associations so that their membership will be notified of these rule amendments.

Resource Impacts

AQMD resources are sufficient to implement the proposed amendments and no additional impacts are expected on staff or fiscal resources.

Attachments

Summary of Proposed Amendments
Rule Development Process
Key Contacts List
Draft Rule Language
Draft Staff Report
CEQA Draft Environmental Assessment
Draft Socioeconomic Assessment

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