South Coast Air Quality Management District
South Coast Air Quality Management District
BOARD MEETING DATE: July 20, 2001 AGENDA NO. 40
Amend Rule 1113 – Architectural Coatings
SYNOPSIS:
The proposed amendments would 1) create a new category for clear wood finish brushing lacquers with an allowable VOC content of 680 g/l effective upon date of adoption and reduced to 275 g/l effective January 1, 2005; and 2) establish labeling and reporting requirements for such brushing lacquers to ensure their proper use and thus minimize emissions.
COMMITTEE:
Stationary Source May 25, 2001, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
- Certifying the Final Environmental Assessment (EA) for Proposed Amended Rule 1113 – Architectural Coatings; and
- Amending Rule 1113 – Architectural Coatings.
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Emissions of volatile organic compounds (VOCs) from stationary and mobile sources are major contributors to the formation of ozone (a key ingredient of smog) in the South Coast Air Basin. The formation of ozone occurs as VOCs react with oxides of nitrogen in the atmosphere. Ozone, a criteria pollutant, has been shown to adversely affect human health and contributes to the formation of another criteria pollutant, PM10.
The use of architectural coatings (coatings applied to stationary structures and their appurtenances) in the AQMD is a major source of VOC emissions. In 1977, Rule 1113 – Architectural Coatings, was adopted to reduce VOC emissions from the use of architectural coatings. The rule prohibits the manufacture, sale, distribution, or application of architectural coatings within the AQMD unless a specific VOC content for the coating is met.
Rule 1113 has been amended on numerous occasions. In November 1996, the rule was amended and included a requirement for the VOC content of clear lacquers to be reduced from 680 grams per liter (g/l) to 550 g/l, effective January 1, 1998. Acceptable lacquers applied by spray application methods were successfully developed to meet the 550 g/l requirement. In 1999, a coating manufacturer approached the AQMD stating that a 550 g/l brushing lacquer could not be successfully developed. These brushing lacquers are exclusively formulated for the residential "do-it-yourself" market and are not sprayed, but applied by hand with a brush. The manufacturer was virtually the only company marketing brushing lacquer in the AQMD. The AQMD recommended that the company seek a variance.
In 1999, the company was granted a variance for one year from the 680 g/l requirement for lacquers. The variance was extended for an additional year in 2000. Since being granted the variance, the manufacturer of the clear brushing lacquer has conducted extensive research efforts in an attempt to formulate a compliant product (550 g/l). AQMD staff met with the manufacturer on several occasions to discuss and evaluate these efforts. The company also filed a comprehensive written report outlining and summarizing their research efforts.
AQMD staff also applied several of the low-VOC brushing lacquers (550g/l) developed by the company to wood panels. The solvent systems of some of the coatings evaporated too quickly causing "brush drag" and leaving an unacceptable finish. Other formulations did not spread smoothly or evenly resulting in equally poor aesthetics.
Staff concluded that an amendment to the rule is necessary since no available compliant products are feasible at this time.
The manufacturer’s representatives indicated that their future efforts in reformulating brushing lacquers would be aimed at achieving the existing future limit in Rule 1113 of 275 g/l for other clear wood finishing lacquers (effective January 1, 2005). Thus, the amendment will include a requirement to reach this future limit.
PAR 1113 has provisions for technology assessments to be conducted for lacquers by year 2004. Staff intends to include brushing lacquers in this technology assessment if necessary.
In this amendment, staff proposes to:
The annual average emissions from architectural and industrial maintenance (AIM) coatings for the year 2000 is estimated at 59.4 tons per day (1997 AQMP). The summer annual average emissions for AIM coatings for year 2000 is over 70 tons per day. The manufacturer of the brushing lacquer estimates annual sales in the AQMD at 20,000 gallons per year. The potential activity of other companies marketing brushing lacquers in the AQMD will not necessarily result in an increase in the total use of brushing lacquers. The participation of other companies with brushing lacquers will most likely alter the market share among competing products and the 20,000 gallon per year consumption of brushing lacquers within the AQMD is assumed to be fixed. The emissions (0.16 tons per day) from the use of 20,000 gallons per year represents less than 0.27% of the total annual average emissions from all AIM coatings in the year 2000.
The creation of a new brushing lacquer category with an allowable VOC content of 680 grams per liter will delay emission reductions in the amount of 0.08 tons per day until 2005. However, the 1999 amendment to the 1997 State Implementation Plan (SIP) for ozone allows substitution of emission reductions from another rule that achieved more emission reductions than planned. The AQMD is substituting emission reductions in excess of the SIP commitment from another control measure to offset the temporary delay in reductions caused by this amendment to Rule 1113.
California Environmental Quality Act (CEQA) Analysis
Pursuant to California Environmental Quality Act (CEQA) and the AQMD’s Certified Regulatory Program (Rule 110), staff has prepared an Environmental Assessment (EA) for Proposed Amended Rule 1113 – Architectural Coatings. The Draft EA was made available for a 45-day review period. The analysis in the draft EA concluded that, because of the volume of coatings affected by the proposed amendments, delaying the final VOC content requirement would result in emission reductions foregone that would exceed the AQMD’s VOC significance threshold of 55 pounds per day. No other environmental areas would be adversely affected by the proposed project. The Final EA, which includes responses to comments made on the draft document, is included as part of the attached package for the public hearing on the proposed rule.
Socioeconomic Analysis
Since the amendment merely delays implementation of existing limitations, no additional costs are expected to be incurred by parties affected by this amendment. As a result, there are no socioeconomic impacts.
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 quality standards in the South Coast Air Basin. In addition the California Health & Safety Code requires that the AQMD adopt rules and regulations that carry out objectives of the AQMP. Though the amendment results in a delay of emission reductions, surplus reductions from other control measures will offset the delay and Proposed Amended Rule 1113 remains consistent with the requirements set forth in the AQMP and does not hinder in any fashion the clean air goals of AQMD.
Implementation Plan
All potential sources have been noticed of the proposed requirements. Should Rule 1113 be adopted, all sources that must comply will be notified through the AQMD’s outreach effort. Therefore, no additional implementation actions are expected to be necessary.
Resource Impacts
Since there are no implementation issues, Proposed Amended Rule 1113 will have no adverse impact on AQMD resources or budgets.
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