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PROPOSAL:

Set Public Hearing December 11, 1998 to Amend Rule 311516 – Motor Vehicle and Mobile Equipment Non-Assembly Line Coating Operations Wood Products.

SYNOPSIS:

Proposed amendments will address industry/staff concerns by delaying the implementation of Group II multistage topcoat VOC limits, exempting from the VOC limits topcoats used on prototype motor vehicles, adding 10% usage limitation on monthly basis for specialty coatings, extending "prohibition of sale, offer for sale, and distribution" applicability to all parties involved, requiring coating manufacturers/jobbers to offer for sale clearcoats with 2.1 lbs/gal VOC or less by January 1, 1999, and clarifying the rule language. Proposed amendments will result in a delay of 1200 lb/day emission reduction for about three and a half months due to delaying implementation of the multistage topcoat limit, and permanent average emission reduction loss of 9 lbs/day due to prototype motor vehicle exemption.

COMMITTEE:

Stationary Source, September 18, 1998, Reviewed

RECOMMENDED ACTION:

Set Public Hearing December 11, 1998 to Amend Rule 1151–Motor Vehicle and Mobile Equipment Non-Assembly Line Coating Operations

Barry R Wallerstein, D. Env.
Acting Executive Officer

Rule 1151 – Motor Vehicle and Mobile Equipment Non-Assembly Line Coating Operations regulates emissions of volatile organic compounds (VOCs) from coatings applied on motor vehicles and mobile equipment in non-assembly line coating operations. The examples of the facilities regulated under this rule are: autobody shops, new car dealer paint shops, fleet operator paint shops, custom-made car fabrication/paint facility, truck body builders, and residences. There are approximately 4,000 facilities, excluding residences, regulated under this rule.

Rule 1151 was first adopted in July 1988. At that time, the VOC emissions from automotive refinishing coatings was estimated to be approximately 29.7 tons per day which has been reduced to approximately 9.2 tons per day in 1997. This emission reduction was achieved by requiring in Rule 1151 the use of low VOC coatings and more efficient spray equipment. The low VOC coatings were developed primarily because technology-forcing VOC limits were included in Rule 1151 from its first adoption. However, during this time frame of reducing emissions in the industry, some manufacturers were not able to meet the challenge of the technology-forcing limits. At such occasions, coating manufacturers requested more time to develop coatings and the rule was amended to accommodate such requests. The December 9, 1994 amendment is an example of such cooperation between the industry and the District. In this amendment, implementation of four VOC limits was delayed from January 1, 1995 to January 1, 1997.

In late 1996, coating manufacturers indicated that they had not been and were not expected to be successful in formulating coatings to meet the January 1, 1997 VOC limits for Group I single-stage metallic/iridescent topcoats, Group II single-stage metallic/iridescent topcoats, and Group II primer sealers. In addition, significant concerns were raised regarding productivity, application properties and finish quality of multistage topcoats meeting the 3.5 lb/gal Group II multistage topcoat VOC limit.

In response to these problems, the major coating manufacturers’ Automotive Refinish Coalition under the auspices of the National Paint and Coating Association petitioned and received on December 19, 1996 a group product variance for one year, until December 18, 1997. The group product variance allowed higher VOC content than required under the rule for the following product categories.

1. Group I single-stage metallic/iridescent topcoats were allowed a maximum VOC content of 3.5 lb/gal until December 18, 1997.
2. Group II primer sealers were allowed a maximum VOC content of 3.5 lb/gal until December 18, 1997.
3. Group II multistage topcoats were allowed a maximum 4.5 lb/gal composite VOC content until December 18, 1997 provided the clearcoats did not exceed a VOC content of 3.7 lb/gal.
4. Group II single-stage metallic/iridescent topcoats were allowed a maximum VOC content of 4.3 lb/gal until March 31, 1997.

During 1997, the concerns regarding the Group I and Group II single-stage metallic/iridescent topcoats were resolved. In October, 1997, the Automotive Refinish Coalition of major coating manufacturers formally requested the District to amend the rule and increase the VOC limits of the Group II multistage topcoats and primer-sealers to 4.5 lb/gal and 3.5 lb/gal respectively, the limits allowed under the variance. The rationale for the request was that compliant multistage topcoats and primer-sealers lowered the productivity of typical autobody shops and many shops experienced significant application and quality problems with the compliant multistage topcoats. The assertion about the negative impact on autobody shops’ productivity was based on the coatings’ formulation chemistries - waterborne for primer surfacers and high solid isocyanate for clearcoats. Based on these arguments, the Hearing Board, on January 7, 1998, extended the group product variance for one more year, until December 18, 1998 for Group II multistage topcoats and Group II primer sealers.

A few months after the extension of the variance, the District staff learned that Akzo-Nobel, a member of the Automotive Refinish Coalition, had developed compliant 3.5 lb/gal multistage topcoats by using parachlorobenzotrifluoride (PCBTF), a solvent which was declared an exempt compound by the USEPA and the District, to formulate a new 2.1 lb/gal clearcoat. District staff visited and interviewed the personnel of 23 autobody shops who have been using Akzo-Nobel’s compliant multistage topcoats and learned that all but one of the users, who were interviewed, were very satisfied with the performance of the new coating. In the meantime, another member of the Coalition, Valspar, also was successful in developing a compliant multistage topcoat system using the same exempt solvent, PCBTF, in their clearcoat.

During 1998, the Coalition changed its position relative to increasing the VOC limit for Group II primer-sealers. This change is based on the following reasons.

1. The majority of the collision repair shops do not require the use of primer sealers, and
2. For collision repair shops that use primer sealers and production autobody shops, compliant products are or soon will be available.

Akzo-Nobel and Valspar formally requested the District to not increase the multistage topcoat limit to 4.5 lb/gal. However, the majority of the Coalition members, who currently do not have compliant 2.1 lb/gal clearcoats in the market petitioned the District to extend the 4.5 lb/gal limit for multistage topcoats for three months after the variance expires on December 18, 1998. Their position is that they will now accelerate their development, marketing, and training efforts and need three more months to make a smooth transition from 4.5 lb/gal to 3.5 lb/gal multistage topcoats.

In response to the majority of the coating manufacturers and the autobody shop industry, District staff is proposing to provide three additional months. Additionally, the staff is using this opportunity to propose other measures that will enhance the effectiveness of the rule.

The following changes are proposed:

1. Increase the current Group II multistage topcoat composite VOC limit of 3.5 lb/gal to 4.5 lb/gal effective December 12, 1998 and lower it back to 3.5 lb/gal on April 1, 1999.
2. Add a 10% usage limitation on a monthly basis for specialty coatings effective December 12, 1998.
3. Expand the "prohibition of sale, offer for sale, and distribution" applicability to all parties involved effective December 12, 1998.
4. Require coating manufacturers and jobbers to offer for sale clearcoats with 2.1 lb/gal VOC or less by January 1, 1999.
5. Add an exemption for topcoats supplied by assembly-line motor vehicle manufacturers for use on prototype motor vehicles effective December 12, 1998.
6. General clean-up of rule language.

A temporary emission reduction loss of 0.6 tons per day will occur until April 1, 1999 due to increasing the Group II multistage topcoat limit to 4.5 lb/gal. Additionally, a permanent emission reduction loss of 0.004 tons per day will result from the exemption for prototype motor vehicle manufacturing facilities.

The 1994 AQMP contained control measure CM #94CTS-F for further emission reductions from motor vehicle and mobile equipment non-assembly line coating operations. During the development of the 1997 AQMP, it was determined that further emission reductions from this industry would not be cost-effective. For this reason, the control measure has been deleted in the 1997 AQMP.

In accordance with the California Environmental Quality Act (CEQA), the AQMD, as lead agency, has reviewed proposed amended Rule 1151 pursuant to state CEQA Guidelines Section 15002(k). The proposed amended rule has the potential to generate significant adverse air quality impacts. Therefore, a Draft Supplemental Environmental Assessment (SEA) was prepared pursuant to AQMD’s certified regulatory program (Rule 110) and released on September 29, 1998, for a 45-day public review and comment period. All comments received on the Draft SEA will be addressed and incorporated into the Final SEA for the proposed project.

The proposed amendments would provide minor economic benefits to affected facilities. The extension of the compliance date for clear topcoats would provide paint manufacturers with additional time for the testing of compliant topcoats. The exemption of manufacturers of prototype motor vehicles from the rule would provide an economic benefit to the one such facility in the district. The prohibition of sale of non-compliant coatings, and the restriction of specialty coatings to 10 percent of total coatings usage would facilitate enforcement and reduce AQMD enforcement costs.

Approximately 1,400 public workshop notices were mailed to the regulated industry. These notices provided brief descriptions of proposed amendments to the rule. However, after the adoption of the proposed amendments, staff is planning to send advisory notices to the industry outlining the adopted changes in order to help them comply with the future compliance dates.

Existing AQMD resources will be sufficient tofor implementation of the proposed changess to thisese rules with no no impact on the budget.

Attachments

Summary of Proposed AmendmentAmendments
Rule Development Flow Chart
Key Contacts
Key Issues and Responses
Rule Language
Key Contacts
Rule Language
Staff Report

RULE 1151 – Motor Vehicle and Mobile Equipment Non-Assembly Line
Coating Operations

Total time spent in rule development: 4 months.

Coating & Solvent Manufacturers/Distributors

California Air Resources Board
United States Environmental Protection Agency

Attachments

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