BOARD MEETING DATE: September 11, 1998 AGENDA NO. 26
PROPOSAL:
Status Report on Follow Up to Testimony Received at August 14, 1998 Public Hearing to Amend Rule 1107 – Coating of Metal Parts and Products
SYNOPSIS:
At the August 14, 1998 Board Meeting, Rule 1107 – Coating of Metal Parts and Products was amended to further reduce VOC emissions. At that meeting, a representative of Ingersoll-Dresser Pump Company presented testimony regarding the potential unavailability of compliant coatings, which may negatively impact their operations. The Board directed staff to meet with the company and report back at the September Board meeting. Staff has visited this company and worked with them to find several compliance options that will allow for normal business activities, as documented in this status report.
COMMITTEE:
Not Applicable.
RECOMMENDED ACTION:
Receive and File.
Barry R. Wallerstein, D.Env.
Acting Executive Officer
Background
Rule 1107 - Coating of Metal Parts and Products, was amended on August 14, 1998, to:
At the Board meeting, comments were received from a representative of Ingersoll-Dresser Pump Company regarding the potential unavailability of compliant products which may negatively affect their operations. The Board directed staff to work with this company to resolve their compliance issues and report back at the September Board meeting.
Findings
On August 20, 1998 staff visited Ingersoll-Dresser at 5715 Bickett Street, Huntington Park, CA 90025, to assess their operating needs. Ingersoll-Dresser manufactures single-and multi-stage pumps used in a variety of industries, including power companies and oil production facilities. The pumps range in power up to 20,000 horsepower. All parts are engineered and computer machined from raw metal stock, assembled, performance tested, mounted on stands and coated to meet customer satisfaction and specifications. Many of the pumps are subject to high temperatures, offshore conditions, chemical exposure, and other extreme conditions.
Ingersoll-Dresser uses a variety of two-component epoxies, high-temperature coatings, and single-component coatings. Some of the coatings used at this facility meet the Rule 1107 multi-component VOC limit of 2.8 lb/gal, which was not changed as a result of the latest rule amendment.
However, one multi-component epoxy finish used at this facility exceeds the current rule limit due to its VOC content of 4.5 lb/gal, but is used in small quantities of less than 55 gallons per year. Such small usage of high-VOC products is covered under exemption (g)(12) of Rule 1107, which is scheduled to sunset in March 1999 in the amended rule. This is the first issue addressed by staff. The second issue relates to a single-component coating with a VOC content of 2.8 lb/gal, which will be subject to a lower VOC limit of 2.3 lb/gal, effective March 1999. Staff recommendations on both issues are provided below.
Recommendations
The compliance options listed below were suggested to Ingersoll-Dresser representatives on August 20 during the site visit by staff. Company representatives responded positively to these recommendations and are actively investigating these options.
Issue 1: Small usage of multi-component epoxy coating containing 4.5 lb VOC per gallon
Staff recommends that the user should investigate the possibility of using a compliant high-temperature coating which is guaranteed to withstand 1000° F temperature. At least one coating is available and will comply with either the high-temperature coating VOC limit of 3.5 lb/gal or the general multicoating VOC limit of 2.8 lb/gal.
Alternatively, the company may elect to use a two-component polyurethane or epoxy coating with a VOC content of 2.8 lb/gal, which complies with the general multi-component coating VOC limit of Rule 1107. Such products are available from coating suppliers.
Issue 2: Usage of single-component coating containing 2.8 lb VOC per gallon
Depending on the specific use of the equipment being painted, some of this company’s coating applications may qualify for the higher VOC content limit of 3.5 lb/gal as an extreme-performance coating, pursuant to the provisions of Rule 1107(j). Extreme performance coatings are defined in Rule 1107(b)(14), and the company needs to apply for written approval from the District as specified in paragraph (j) of the rule. Staff recommends this avenue as a possible compliance option for qualifying applications.
Staff also suggests that Ingersoll-Dresser investigate the feasibility of applying a pretreatment primer under exemption (g)(6), and then applying an acrylic waterborne coating containing no more than 2.3 lb VOC/gal, which complies with Rule 1107 provisions. Staff’s preliminary calculations indicate that the potential facility VOC emissions are well below 10 tons/year, as required to qualify for exemption (g)(6) of Rule 1107.
In addition, staff provided Ingersoll-Dresser representatives with information on four coating manufacturers that reportedly supply compliant products.
Conclusions
Staff has found that a number of compliant coatings appear to be available for use in pump applications subject to high temperatures offshore conditions, chemical exposure, and other extreme conditions. However, the user will need additional time to investigate the cost and performance characteristics of available products to make an informed decision. Staff will monitor this issue and continue to assist the company. If additional rule changes are required, staff will apprise the Board of such facts and initiate appropriate action in a timely manner. It is believed that Ingersoll-Dresser can utilize one or more of the options outlined above to meet present and future Rule 1107 requirements effectively.
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