BOARD MEETING DATE: March 12, 1999 AGENDA NO. 5
PROPOSAL:
Set Public Hearing May 14, 1999 to Amend Rule 1113 - Architectural Coatings
SYNOPSIS:
The proposed amendments will implement the AQMP Control Measure for architectural coatings through decreasing VOC limits for industrial maintenance coatings; nonflat coatings; primers, sealers, and undercoaters (PSU); quick-dry enamels; quick-dry PSU; stains; roof coatings; and waterproofing wood sealers. The proposed amendments will also establish new coating categories and VOC limits for rust-preventative coatings; floor coatings; and waterproofing concrete/masonry sealers, as well as provide needed clarifications. Lastly, the proposed amendments will expand the averaging provision to provide additional flexibility to manufacturers.
COMMITTEE:
Stationary Source, February 19, 1999, Recommended for Approval
RECOMMENDED ACTION:
Set Public Hearing May 14, 1999 to Amend Rule 1113 - Architectural Coatings.
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Rule 1113 is applicable to manufacturers, distributors, and end-users of architectural and industrial maintenance (AIM) coatings. It was first adopted in 1977, and has undergone numerous amendments. The purpose of the rule is to reduce VOC emissions from the use of AIM coatings, primarily by placing VOC limits on various coating categories.
On August 21, 1990, the Superior Court of Los Angeles County entered a judgment against AQMD in the case Dunn-Edwards Corporation, et al. vs. SCAQMD, et al. The judgment denied in part, and granted in part, the petition for writ of mandate seeking to overturn certain amendments made in February 1990. As a result, the AQMD was prevented from enforcing the lower VOC limits for aerosol coatings, industrial maintenance coatings, lacquers, quick-dry enamels, and quick-dry primers, sealers and undercoaters. This judgment impacted approximately 4.5 tons per day (tpd) of VOC emissions. Other amendments adopted in February 1990 and prior rule provisions remained in effect.
Rule 1113 - Architectural Coatings was last amended on November 8, 1996, resulting in approximately 10.3 tpd of VOC emission reductions. Subsequently, three separate lawsuits were filed by industry challenging the lower limits for flats and lacquers on both state and federal grounds. The AQMD has prevailed in all three lawsuits on all state grounds, and has succeeded in obtaining dismissal of most of the federal grounds.
The current proposed amendments will lower the VOC limits for all coating categories impacted by the 1990 court judgment, except lacquers, which was addressed in the last rulemaking. The proposed amendments also include lower limits for additional categories. The proposed lower VOC limits are all based on the concept of reformulation of existing coatings, either with water, exempt solvents, and/or currently available, innovative resin technology. The proposed amendments will also add a few additional specialty coating categories, establish current and future effective limits for the new categories, and expand the averaging provision.
In response to industry concerns, the AQMD contracted Eastern Michigan University (EMU), Coatings Research Institute, to further evaluate six of the seven issues previously raised by EL RAP pertaining to coating categories in the current proposal, and to provide recommendations for future compliance limits for the different coating categories. This study concluded that low- and zero-VOC coatings are currently available for the proposed coating categories, but could not reach conclusions regarding the overall performance of these coatings, as compared to current, compliant solvent-based coating formulations, since performance data was not provided to the researcher.
In order to obtain such performance data regarding application and durability characteristics of the low- and zero-VOC coatings currently available, the AQMD contracted National Technical Systems (NTS) to do a side-by-side comparison of zero-, low-, and high-VOC coatings. Since this study was initiated, staff has performed its own technology assessment of these low- and zero-VOC coatings and has gained even more information pertaining to their performance characteristics. Based on its own assessment, staff is confident that both the proposed compliance limits and deadlines are achievable. Staff will nevertheless reassess the deadlines based upon the laboratory results of the NTS study and propose any necessary adjustments prior to the Board hearing. These results are expected to be completed within the next few weeks.
Proposal
The following VOC limits are proposed to be lowered, which will result in an emission reduction of about 21 tons per day of VOCs:
Floor Coatings
Establish the VOC limit for floor coatings of 420 g/l, effective date upon adoption, and lower the VOC limit from 420 g/l to 100 g/l effective January 1, 2002, and further reduce from 100 g/l to 50 g/l effective January 1, 2005. The proposed floor coating category is a subset of the industrial maintenance coating category, which has a VOC limit of 420 g/l. Conduct a product availability assessment by January 1, 2001 for the 100 g/l limit and January 1, 2004 for the 50 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of their floor coatings, on a sales-weighted basis.
High Temperature - Industrial Maintenance Coatings
Establish the VOC limit for high temperature - industrial maintenance coatings of 550 g/l, effective January 1, 2002, and lower to 420 g/l effective January 1, 2005.
Industrial Maintenance Coatings
Lower the VOC limit for industrial maintenance coatings from 420 g/l to 250 g/l effective January 1, 2002. Then reduce the VOC limit from 250 g/l to 100 g/l effective January 1, 2005. Conduct a product availability assessment by January 1, 2001 for the 250 g/l and by January 1, 2004 for the 100 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of their industrial maintenance coatings, on a sales-weighted basis.
Nonflats
Lower the VOC limit for nonflats from 250 g/l to 150 g/l, effective January 1, 2002 and further reduce from 150 g/l to 50 g/l, effective January 1, 2005. Conduct a product availability assessment by January 1, 2001 for the 100 g/l limit and January 1, 2004 for the 50 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of their nonflats, on a sales-weighted basis.
Primers, Sealers, and Undercoaters
Lower the VOC limit for primers, sealers, and undercoaters from 350 g/l to 100 g/l, effective January 1, 2002, and further reduce from 100 g/l to 50 g/l, effective January 1, 2005. Conduct a product availability assessment by January 1, 2001 for the 100 g/l limit and January 1, 2004 for the 50 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of their primers, sealers, and undercoaters, on a sales-weighted basis.
Quick-Dry Enamels
Lower the VOC limit for quick-dry enamels from 400 g/l to 150 g/l, effective January 1, 2002, and further reduce the VOC limit from 150 g/l to 50 g/l effective January 1, 2005. Conduct a product availability assessment by January 1, 2001 for the 150 g/l limit and January 1, 2004 for the 50 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of nonflats, on a sales-weighted basis.
Quick-Dry Primers, Sealers, and Undercoaters
Establish the VOC limit for quick-dry primers, sealers, and undercoaters at 350 g/l, effective date of adoption, unless the manufacturer submits an exemption report pursuant to Rule 1113(g)(3). Lower the quick-dry primers, sealers, and undercoaters to 100 g/l, effective January 1, 2002, and further reduce from 100 g/l to 50 g/l effective January 1, 2005. Conduct a product availability assessment by January 1, 2001 for the 100 g/l and January 1, 2004 for the 50 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of their primers, sealers, and undercoaters, on a sales-weighted basis.
Roof Coatings
Lower the VOC limits for roof coatings from 300 g/l to 250 g/l, effective date upon adoption.
Rust Preventative Coatings
Establish the VOC limit for rust preventative coatings at 420 g/l, effective date upon adoption, and then lower from 420 g/l to 250 g/l effective January 1, 2002, and then further lower to 100 g/l, effective January 1, 2005. The proposed rust preventative coating category is currently a subset of the industrial maintenance coating category, which has a VOC limit of 420 g/l, and primers, sealers, and undercoaters, which has a VOC limit of 350 g/l. Conduct a product availability assessment by January 1, 2001 for the 250 g/l and January 1, 2004 for the 100 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of their rust preventative coatings, on a sales-weighted basis.
Stains
Lower the VOC limits for stains from 350 g/l to 250 g/l, effective January 1, 2002.
Waterproofing Wood Sealers
Lower the VOC limit for waterproofing wood sealers from 400 g/l to 250 g/l, effective January 1, 2002.
Policy Issues
Industry members, mainly manufacturers and contractors, provided several suggestions and introduced issues that they believe need additional research. The Environmental Legislative & Regulatory Advocacy Program (EL RAP) and other manufacturers have eight main issues: that low-VOC coatings are thicker, and thus require more thinning, more priming, more topcoats, more touch-ups and repair work, more frequent recoating, substitution, and more reactivity. Due to these eight issues, some manufacturers believe that coatings with higher VOC content will be substituted for the proposed lower VOC content coatings resulting in an increase in VOC emissions. They also believe a larger amount of low-VOC coatings will be used, resulting in an actual increase in VOC emissions. Lastly, manufacturers expressed concern regarding the lack of sufficient time necessary for research and development of the reformulated coatings.
The eight issues focus on two main points. The first seven issues all state that the new formulations, either solvent-based or waterborne, result in more coating use and an overall increase in VOC emissions over a period of time. The eighth issue involves the reactivity of solvents used in waterborne coatings. EL RAP contends that these result in more ozone formation as compared to solvents in solvent-based formulations.
In response to these concerns, the staff has again analyzed each of the specific issues raised by EL RAP. That analysis is included in the draft Subsequent Environmental Assessment (SEA).
In summary, with regards to additional thinning, the focus of the proposed amendments is limited to coatings that are mainly solventless formulations, waterborne formulations or based on using exempt solvents, thereby eliminating any concerns of thinning the coating, as supplied, with VOC.
To examine the issues of thickness, priming, topcoats, touch-up and repair, and frequent recoating, staff used coating coverage estimates, typical dry mil thickness, recommended priming, and estimated life of coating, listed on container labels and technical data sheets or provided by manufacturers during personal interviews and phone surveys. Staff’s preliminary analysis comparing emissions from the proposed lower-VOC content coatings with emissions from potential substitute coatings shows an overall VOC emission reduction as a result of the proposed amendments. An extensive discussion regarding the feasibility of reactivity-based ozone control policy development is included in the attached staff report to address the eighth issue.
To date, manufacturers have not provided data to support the claim that the lower VOC coatings could cause an increase in emissions. As a part of the current rulemaking efforts, staff has requested life-cycle studies that may have been conducted over the past seven years, but none were provided.
Staff has proposed several amendments to Rule 1113 to address concerns raised relative to sufficient time to research, develop, and market compliant coatings. The proposed amendments provide a two-and-one-half year and a six-year time period for future compliance limits, as well as an averaging provision for the affected categories that would allow manufacturers to offset non-compliant coatings with super-compliant coatings. The AQMD has also committed to a product availability assessment one year prior to the future rule limits for the affected categories. It should be noted, however, that the proposed limits are principally based on currently available and marketed coatings.
AQMP and Legal Mandates
The 1997 AQMP estimates increased AIM emissions for the Summer-day average (due to population growth) at 68.2 tpd in 1997, growing to 74.7 tpd by the year 2005 and 79.4 tpd by the year 2010 without additional AIM regulations. If left unchecked, AIM coating emissions alone would account for more than 26% of the allowed VOC emissions. Therefore, the 1997 AQMP has a specific control measure (CTS-07) to reduce AIM VOC emissions by 50% by the year 2010, as well as a long-term measure requiring an additional 25% reduction in VOCs. This cumulative 62 tpd emission reduction based on the Summer Planning Inventory is the largest of all short- and long-term control measures.
Installation of air pollution control equipment is not feasible for reducing AIM emissions, thereby leaving coating reformulation as the only practical means to achieve the required reductions. The current proposal emphasizes reformulation of existing coatings, primarily by using currently available, technologically innovative resins, as well as utilizing the growing list of exempt solvents.
These proposed Rule 1113 amendments will implement the 1994 and 1997 architectural coatings control measure, and will seek to reduce AIM emissions by approximately 36% or 21 tons per day.
CEQA
Pursuant to CEQA procedure and AQMD Rule 110 - Rule Adoption Procedures to Assure Protection and Enhancement of the Environment, AQMD is preparing a Draft SEA for the proposed amendments to Rule 1113. The Draft SEA will be circulated for a public review and comment period. All comments received on the Draft SEA will be incorporated into the Final SEA for the proposed project.
Socioeconomic Analysis
Staff is evaluating the cost of compliance with the proposed amendments, which will be included in the final staff report.
Implementation Plan
A notice will be sent to all AIM coating manufacturers.
Resource Impact
Existing AQMD resources will be sufficient to implement the proposed changes to this rule with minimal impact on the budget.
Summary of Proposed Amendment
Rule Development Flow Chart
Key Contacts
Key Issues and Responses
Staff Report
Rule Language
Emission Reduction Calculations
Statewide Comparison of Current Architectural Coatings Rules
ATTACHMENT A
SUMMARY OF PROPOSED AMENDMENTS
Rule 1113 |
| The following VOC limits are proposed to be lowered: Floor Coatings Establish the VOC limit for floor coatings of 420 g/l, effective date upon adoption, and lower the VOC limit from 420 g/l to 100 g/l effective January 1, 2002, and further reduce from 100 g/l to 50 g/l effective January 1, 2005. The proposed floor coating category is a subset of the industrial maintenance coating category, which has a VOC limit of 420 g/l. Conduct a product availability assessment by January 1, 2001 for the 100 g/l limit and January 1, 2004 for the 50 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of their floor coatings, on a sales-weighted basis. High Temperature - Industrial Maintenance Coatings Establish the VOC limit for high temperature - industrial maintenance coatings of 550 g/l, effective January 1, 2002, and lower to 420 g/l effective January 1, 2005. Industrial Maintenance Coatings Lower the VOC limit for industrial maintenance coatings from 420 g/l to 340 g/l effective January 1, 2001, and further reduce from 340 g/l to 250 g/l effective January 1, 2002. Then reduce the VOC limit from 250 g/l to 100 g/l effective January 1, 2005. Conduct a product availability assessment by January 1, 2001 for the 250 g/l and by January 1, 2004 for the 100 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of their industrial maintenance coatings, on a sales-weighted basis. Nonflats Lower the VOC limit for nonflats from 250 g/l to 150 g/l, effective January 1, 2002 and further reduce from 150 g/l to 50 g/l, effective January 1, 2005. Conduct a product availability assessment by January 1, 2001 for the 100 g/l limit and January 1, 2004 for the 50 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of their nonflats, on a sales-weighted basis. |
ATTACHMENT A
SUMMARY OF PROPOSED AMENDMENTS
CONTINUED
Rule 1113 |
| Primers, Sealers, and Undercoaters Lower the VOC limit for primers, sealers, and undercoaters from 350 g/l to 100 g/l, effective January 1, 2002, and further reduce from 100 g/l to 50 g/l, effective January 1, 2005. Conduct a product availability assessment by January 1, 2001 for the 100 g/l limit and January 1, 2004 for the 50 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of their primers, sealers, and undercoaters, on a sales-weighted basis. Quick-Dry Enamels Lower the VOC limit for quick-dry enamels from 400 g/l to 150 g/l, effective January 1, 2002, and further reduce the VOC limit from 150 g/l to 50 g/l effective January 1, 2005. Conduct a product availability assessment by January 1, 2001 for the 150 g/l limit and January 1, 2004 for the 50 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of nonflats, on a sales-weighted basis. Quick-Dry Primers, Sealers, and Undercoaters Establish the limit for quick-dry primers, sealers, and undercoaters at 350 g/l, effective date upon adoption, unless the manufacturer submits an exemption report pursuant to Rule 1113(g)(3). Lower the quick-dry primers, sealers, and undercoaters to 100 g/l, effective January 1, 2002, and further reduce from 100 g/l to 50 g/l effective January 1, 2005. Conduct a product availability assessment by January 1, 2001 for the 100 g/l and January 1, 2004 for the 50 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of their primers, sealers, and undercoaters, on a sales-weighted basis. Roof Coatings Lower the VOC limits for roof coatings from 300 g/l to 250 g/l, effective date upon adoption. |
ATTACHMENT A
SUMMARY OF PROPOSED AMENDMENTS
CONTINUED
Rule 1113 |
| Rust Preventative Coatings Establish the limit for rust preventative coatings at 420 g/l, effective date upon adoption, and then lower from 420 g/l to 250 g/l effective January 1, 2002, and then further lower to 100 g/l, effective January 1, 2005. The proposed rust preventative coating category is a subset of the industrial maintenance coating category, which has a VOC limit of 420 g/l, and primers, sealers, and undercoaters, which has a VOC limit of 350 g/l. Conduct a product availability assessment by January 1, 2001 for the 250 g/l and January 1, 2004 for the 100 g/l limit. Include an averaging provision to allow manufacturers to average the VOC content of their rust preventative coatings, on a sales-weighted basis. Stains Lower the VOC limits for stains from 350 g/l to 250 g/l, effective January 1, 2002. Waterproofing Wood Sealers Lower the VOC limit for waterproofing wood sealers from 400 g/l to 250 g/l, effective January 1, 2002. The container label requirements will be revised and require the special labeling for industrial maintenance coatings and rust preventative coatings. The exemption for Quick-Dry Primers, Sealers and Undercoaters will be deleted, effective January 1, 2002. |
ATTACHMENT B
RULE DEVELOPMENT PROCESS
RULE 1113 - Architectural Coatings
Formation of Current September 1998 |
ò
Six Working Group Meetings |
ò
Public Workshop: December 9, 1998 (2,600 notices mailed for workshop) |
ò
Set Public Hearing: March 12, 1999 |
ATTACHMENT C
KEY CONTACTS
Sal |
Fname |
Lname |
Coname |
| Mr. | Bert | Adams | Glaze N Seal |
| Ms. | Heidi | Alderman | Air Products & Chemicals |
| Ms. | Jodi | Allen | Union Carbide |
| Mr. | Don | Ames | State of CA Air Resources Board |
| Mr. | Bernie | Appleman | SSPC |
| Mr. | Allen | Armstrong | Hill Brothers Chemical Co. |
| Mr. | Yin | Aye | Smiland Paint Co. |
| Mr. | Marty | Balow | Frazee Paint Co. |
| Mr. | Jasen | Banta | Matt Construction |
| Mr. | Barry | Barman | KTA-TATOR, Inc. |
| Mr. | Paul | Beemer | Henry Co |
| Mr. | Chuck | Benesch | D’Angelos |
| Mr. | Howard | Berman | Kessler & Associates, Inc. |
| Mr. | Jim | Bossardt | Blast/Coat Systems, Inc. |
| Mr. | Tim | Bosveld | Dunn Edwards |
| Mr. | Larry | Breeding | Walt Disney Company |
| Mr. | Mike | Butler | Behr Process Corporation |
| Mr. | Mike | Callahan | Jacobs |
| Mr. | David | Clifford | AKZO NOBEL |
| Mr. | Curtis | Coleman | Law Offices of Curtis L. Coleman |
| Mr. | Gerrold | Coleman | Paramount Pictures |
| Mr. | Tim | Conhin | LADWP |
| Ms. | Margaret | Coon | Ameron Protective Coatings |
| Mr. | Stan | Cowen | Ventura County APCD |
| Mr. | Pete | Cutrona | Ellis Paint Co. |
| Mr. | James | Dabbs | Spectra-Tone Paint Corp. |
| Mr. | Geoffrey | Dearth | Air Products & Chem. Inc. |
| Mr. | Mike | De La Vega | Life Paint Company |
| Ms. | Stacey | Dobrosky | Union Carbide |
| Mr. | Lee | Doyle | S.G. Pinney & Associates Inc. |
| Mr. | Richard | Drisko | SSPC |
| Mr. | Phil | Drooks | Metropolitan Water District of So. California |
| Mr. | M. | Dyer | Devoe Castings |
| Mr. | Mehrdad | Emami | McWhorter Tech. |
| Mr. | Wes | Emerson | Rust-Oleum |
| Ms. | Daniela | Fernandez | County Government Center |
| Mr. | Bob | Floriani | ICI-Dulux |
| Ms. | Yvonne | Fong | U.S. EPA |
| Mr. | Chris | Foster | Smiland & Khachigian |
| Mr. | Randy | Francisco | McWhorter Technologies, Inc. |
| Mr. | David | Fredianc | CSDLAC |
| Mr. | Harley | Fung | Benjamin Moore & Co. |
| Ms. | P | Ghuman | LACSD |
| Mr. | John | Gordon | Pacific Tech. Consultants, Eastern Michigan Univ. |
| Mr. | Robert | Gross | PPG Industries, Inc. |
| Mr. | Lloyd | Haanstra | DEFT |
| Mr. | Jay | Haines | Texture Coatings of America, Inc. |
| Ms. | Madelyn | Harding | The Sherwin-Williams Co. |
| Mr. | Hal | Hargrave | Tri-County PDCA |
| Mr. | Richard | Hart | Hart Polymers |
| Mr. | Brian | Heath | The Valspar Corp. |
| Mr. | Robert | Henderson | Coatings Resource Corp. |
| Mr. | Tony | Hobbs | Tnemec Corporation |
| Mr. | Scott | Holland | Cal Western Paints |
| Mr. | Eddy | Huang | AVES |
| Mr. | Alex | Iaroli | E. P. S. |
| Mr. | George | Illes | LFR, Levine Fricke |
| Ms. | Gail | Ito | Chevron |
| Mr. | Mike | Jacola | Califronia Air Resources Board |
| Mr. | Barry | Jenkin | Benjamin Moore |
| Ms. | LaShawn | Johnson | Carboline Coatings |
| Ms. | Carol Yip | Kaufman | Metropolitan Water District of Southern California |
| Mr. | Ned | Kisner | Triangle Coatings |
| Ms. | Terri | Lasso | Sherwin-Williams |
| Mr. | Jay | Leause | PROCOS |
| Mr. | Martin | Ledwitz | SCE |
| Mr. | Gene | Lee | Rohm and Haas Company |
| Mr. | David | Leehy | Vista Paints |
| Mr. | Stanton | Lewis | City of Los Angeles |
| Mr. | Pat | Lofgren | ICI Paints |
| Mr. | John | Long | Smiland Paint Co. |
| Ms. | Geraldine | Lucas | Disneyland Resort |
| Mr. | Dave | Lunzer | Union Carbide |
| Mr. | Pat | Lutz | Dunn Edwards |
| Mr. | Todd | Maiden | Seyfarth, Shaw |
| Mr. | Tom | Marsden | Disneyland Resort |
| Mr. | Mike | Mason | Southern California Edison |
| Mr. | John L. | Massingill, Jr. | Eastern Michigan University |
| Ms. | Judith | McCourt | Union Carbide |
| Mr. | John | Means | Universal Studios |
| Mr. | Clayton | Miller | CIAQC |
| Mr. | Gil | Mislang | Dunn Edwards |
| Mr. | Norm | Mowrer | Ameron |
| Mr. | Jerry | Mulnix | Cal-Western Paints, Inc. |
| Mr. | Stephen | Murphy | Murphy Industrial Coatings |
| Mr. | Dinkar | Naik | Pacific Polymers |
| Mr. | Bob | Nelson | National Paint & Coating Association |
| Mr. | Wayne | Nelson | Spectra-Tone Paint |
| Mr. | Bob | Newton | NSTS |
| Mr. | Marcy | Nichol | TruServ Mfg |
| Mr. | R. | Novielli | Rohm & Haas |
| Mr. | Jim | Nyarady | CARB |
| Mr. | Bert | Osen | U.S. Celluluse |
| Mr. | Parker | Pace | BEHR Process |
| Mr. | Ijay | Palansky | Dunn Edwards |
| Mr. | Randy | Pasek | California Air Resources Board |
| Mr. | Fenando | Pedroza | Frazee Paint |
| Mr. | Herb | Pigram | Rohm & Haas Co. |
| Mr. | Hamid | Pourshirazi | Vista Paint |
| Mr. | Greg | Quinn | Los Angeles PDCA |
| Mr. | Joe | Ramirez | Ever Guard Coatings |
| Mr. | Bob | Reeves | Benjamin Moore Paints |
| Mr. | Benjamin | Remley | DuPont Engineered Services |
| Ms. | Ellen | Reinhardt | The Better Paint Tray LLC |
| Mr. | William | Riechers | Genesis Coatings, Inc. |
| Mr. | Ray | Robinson | ELRAP |
| Mr. | Mark | Robson | Golden State PDCA |
| Mr. | Andy | Rogerson | Caltrans |
| Mr. | Steve | Sanchez | US Can Company |
| Mr. | Oscar | Sandoval | Frazee Paint |
| Mr. | Anil | Sayta | Zynolyte/I.C.I Paints |
| Mr. | Jim | Sell | NPCA |
| Mr. | Rodney | Sells | Resin Technology Co. |
| Mr. | Patrick | Shannon | Sierra Performance Coatings |
| Ms. | Erin | Sheehy | Environmental Compliance Solutions |
| Mr. | Dean | Simeroth | Air Resources Board |
| Mr. | Mark | Simon | MWD |
| Mr. | Al | Singh | Surface Protection Inc. |
| Mr. | Jim | Sliff | Rust-Oleum |
| Mr. | Craig | Smith | C-F |
| Mr. | Harry | Sporidis | Kessler & Associates/Dunn-Edwards |
| Ms. | Christine | Stanley | Ameron Protective Coatings Systems |
| Mr. | Bob | Steel | Park Water District / SICC |
| Mr. | Joe | Stoddard | Mobile Pipe Wrappers & Coaters Inc. |
| Mr. | Gene | Suconey | Disneyland Resort |
| Ms. | Sharilen | Talati | |
| Ms. | Sheri | Thompson | Sherwin Williams |
| Mr. | Rob | Truitt | Dayton Superior Corp |
| Mr. | Jay | Umphrey | EPS Inc. |
| Ms. | Barbara | VanCina | Carboline |
| Mr. | John | Wallace | MWD |
| Mr. | John | Waltman | Cal Western Paints |
| Mr. | Robert | Wendoll | Dunn-Edwards Paints |
| Mr. | Peter | Whittingham | County of Los Angeles |
| Mr. | Max | Wills | Cal Poly State University |
| Mr. | Tek | Woo | Union Carbide |
| Mr. | Kevin | Worrall | TeraCota |
| Mr. | Steven | Yagade | Walt Disney Imagineering |
| Ms. | Carol | Yip Kaufman | MWD |
| Mr. | Mark | Zielinski | ICI |
ATTACHMENT D
KEY ISSUES AND RESPONSES
Rule 1113 |
|
|
Response |
| High-solids coatings will require thinning in the field | Manufacturers can reformulate existing coatings using resins that require less coalescing solvents, without increasing the solids in the coating. However, high solids coatings, with numerous IM coatings available at 100% solids, have been in the market for more than twenty years. These coatings are supplied ‘ready to use’ without the need for additional thinning in the field, and can be readily applied using airless spray equipment and the appropriate spray tips. Furthermore, the future limits are based on waterborne technology and the use of exempt solvents; therefore, thinning with VOCs will not be an issue, as these coatings are thinned with water, if needed. |
| Industrial Maintenance Coatings should not be banned for residential and commercial uses, and labeling should not be required | Industrial Maintenance Coatings are to be used in areas where high heat, chemical resistance, impact resistance, and corrosion resistance are an issue. In response to comments regarding problematic metal substrates used in commercial and residential development, staff has created the new ‘rust preventative coating’s, specifically for metal substrates. This category’s proposed limits and compliance deadlines are the same as Industrial Maintenance Coatings. Staff believes that the labeling of industrial maintenance coatings will enhance the enforceability of the rule, and mitigate potential misuse of industrial maintenance coatings |
ATTACHMENT D
KEY ISSUES AND RESPONSES
CONTINUED
Rule 1113 |
|
|
Response |
| Although some nonflat coatings can meet the proposed 150 g/l limit, not all can be reformulated to meet the proposed limits, especially by January 1, 2002. The AQMD should establish higher limits for exterior non-flats. | AQMD staff found, as a part of their data collection and information gathering phase, that over 56% of the total volume of nonflat coatings sold in California in 1996, complied with the January 1, 2002 proposed limit. This is based on information submitted by manufacturers regarding sales of both their interior and exterior nonflat coatings. Staff has also created a new specialty coating category called rust preventative coatings, that will be limited to metal substrates and will have a higher VOC limit. Staff also found compliant interior and exterior nonflat coatings with equivalent performance characteristics found in some higher-solvent containing nonflat coatings. The 1998 CARB survey also shows that over 40% of all nonflat coatings are recommended for both interior and exterior uses, indicating that a majority of the products are formulated the same for interior and exterior uses. In addition, staff included a commitment for a detailed product availability assessment one year prior to the implementation of the 150 g/l and 50 g/l limits in order to reevaluate available coatings. Lastly, staff has included an averaging provision for manufacturers to enable them to average the emissions from the nonflat coatings. This provision would allow them to continue selling non-compliant coatings, as long as the average sales-weighted emissions are equivalent or lower than emissions based on the VOC limits. |
ATTACHMENT D
KEY ISSUES AND RESPONSES
CONTINUED
Rule 1113 |
|
|
Response |
| Labeling of "rust preventative" coatings will result in greater costs and not result in additional air quality benefit. | Staff believes that the labeling of rust preventative coatings will enhance the enforceability of the rule, and mitigate potential misuse of rust preventative coatings. |
| Averaging provision is a good compliance option for affected coatings, but industry has proposed an alternative method that they believe will not place a cap on their coating sales. | Staff is currently evaluating Industry’s alternative averaging proposal. |
/ / /