BOARD MEETING DATE: August 13, 1999 AGENDA NO. 30
PROPOSAL:
Amend Rule 1104 - Wood Flat Stock Coating Operations
SYNOPSIS:
In response to CARB comments to incorporate all feasible control technologies, the proposed amendment reduces the allowable VOC content for inks and exterior siding coatings to 250 grams per liter.
COMMITTEE:
Stationary Source, June 18, 1999, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Rule 1104 – Wood Flat Stock Coating Operations controls VOC emissions from flat stock wood coating operations by (1) limiting the VOC content of coatings, inks and adhesives used in the manufacturing process; (2) specifying their application methods; and (3) requiring that solvent cleaning operations comply with Rule 1171 – Solvent Cleaning Operations. Wood flat stock includes flat boards that are used as decorative wood paneling intended for attachment to interior walls of buildings and structures, including, but not limited to homes, office buildings, mobile homes, trailers, prefabricated buildings, boats, and ships. Wood flat stock also includes exterior wood siding intended for use in commercial or residential construction. Specifically exempted from this rule are laminations of fiberglass, metal, or plastic sheets to wood panels, coating of wood panels for furniture end use, and coating of wood panels for use in aircraft. These laminating and coating operations are subject to Rules 1168, 1136 and 1124, respectively.
California Air Resources Board (CARB) has identified Rule 1104 as an existing South Coast Air Quality Management District (AQMD) rule that does not include all feasible control technologies for wood flat stock coating operations. CARB indicated that the Bay Area AQMD Rule 8-23 and Placer County APCD Rule 238 contain emission limits which are more effective than analogous emission limits for exterior siding coatings and adhesives contained in Rule 1104. CARB has recommended that the AQMD evaluate their concerns and if warranted, revise the VOC limits for inks and exterior siding coatings of Rule 1104 to reflect the more stringent requirements of the Bay Area AQMD and Placer County APCD. AQMD Staff have evaluated the state of current technology and agrees that the VOC limits for inks and exterior siding coatings should be reduced to 250 grams per liter. The basis for this determination is that there are a multitude of both ink and exterior siding coatings at or below 250 grams of VOC per liter that perform satisfactorily. There are currently two facilities subject to Rule 1104 of which one is already in compliance with the proposed amendments. Staff is currently assisting the other facility to facilitate its compliance with the proposed limits and has already provided the facility with a list of compliant coatings.
Summary of Proposed Amendments
Effective October 1, 1999, the staff proposal will:
Policy Issues
There are no major unresolved policy issues.
AQMP 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. There are currently two facilities subject to Rule 1104 of which one is already in compliance with the proposed amendments. The total amount of emission reductions obtained by implementation of this rule is approximately 2,900 pounds of VOC per year. The cost effectiveness of these reductions is $1,800 per ton of VOC reduced.
CEQA and Socioeconomic Analysis
Pursuant to the California Environmental Quality Act (CEQA), the AQMD has reviewed the proposed project and has prepared a Final Environmental Assessment (EA) identifying no significant impacts as a result of the proposed amendments. The EA has been circulated for a 30-day public review and comment period. No comments were received on the Draft EA. Therefore, no comments are included in the Final EA.
A Socioeconomic Assessment has been prepared for the proposed amendments to Rule 1104 and is included in the staff report. No significant socioeconomic impacts have been identified as a result of the proposed amendments.
Implementation Plan
Staff will continue current inspection practices for the two facilities subject to Rule 1104. Both facilities are permitted and will continue to be kept informed of the amendments by mail, outreach, and internet posting on the AQMD website.
Resource Impacts
Implementation of the proposed amendments is not expected to have impacts on staff or fiscal resources.
A. Summary of Proposed Amendments
B. Rule Development Process
C. Key Contacts List
D. Resolution
E. Rule Language
F. Staff Report
G. Final Environmental Assessment
/ / /