South Coast Air Quality Management District
South Coast Air Quality Management District
BOARD MEETING DATE: November 9, 2001 AGENDA NO. 33
Amend Rule 1107 - Coating of Metal Parts and Products
SYNOPSIS:
The proposed amendments will add laboratory methods to determine the acid content and elemental metal content of certain metal coatings, the efficiency of a control device abating low VOC concentrations, as well as include a limited exemption for electrocoatings and other clarifications.
COMMITTEE:
Stationary Source, August 24, 2001, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
- Certifying the CEQA Notice of Exemption Proposed Amended Rule 1107 - Coating of Metal Parts and Products; and
- Amending Rule 1107 - Coating of Metal Parts and Products
Barry R. Wallerstein, D.Env.
Executive Officer
On February 5, 2001, CARB requested the AQMD to include in this rule test methods for determining the acid content of coatings containing acid, as well as test methods for determining the metal content of metallic coatings.
In addition to CARB's concerns over test methodology inclusion, coatings manufacturers made two additional requests. First, representatives of precatalyzed electric insulating varnish (EIV) manufacturers expressed concern over the applicability of EPA Method 24 in determining the VOC content of these materials. The coatings are designed to cure at 150°C, rather than the 110°C required in EPA Method 24. At the lower temperature, the monomers do not cross-link and lead to volatilization rather than polymerization. The AQMD laboratory has run extensive tests to determine the VOC content of these materials at the higher cure temperature and at various sample weights. The AQMD laboratory needs the latitude to use modified methods of Method 24, where applicable and approved by EPA and CARB, to improve the accuracy of the analysis of VOC content of precatalyzed electric insulating varnishes.
Second, one electrocoating manufacturer has submitted a separate request to exempt "E-coatings" from VOC content restrictions due to the higher VOC content of the coating than what is currently allowed under Rule 1107 VOC content in the coating concentrate. The concentrate is added to high volumes of water to affect the process of electrophoresis. Not all E-coating concentrates are high in VOC. In this case, it is a recently developed polyurethane electrocoating concentrate for use on plumbing fixtures, and lock and latch sets, under American National Standard Institute specifications, and under equivalence with current VOC limitations that brings this issue to the proposed amendments.
On September 12, 2001, additional comments from CARB were received on the proposed amendments to Rule 1107. Some of these comments relating to definitional additions and modifications have been incorporated into the rule.
Other rule improvements, resulting from correspondence with AQMD Engineering and Compliance personnel and rule development staff brought about an applicability clarification. Distinctions between Rule 1107 and Rule 1113 - Architectural Coatings are now identified in rule applicability language.
The purpose of this proposed rule amendment is to: (1) Add appropriate test methods for determining the acid content of etching fillers and pretreatment coatings, and the metal particle content of metallic coatings, and efficiency of an emission control system venting low VOC concentrations; and (2) Address proper VOC content analysis of precatalyzed electric insulating varnishes as approved by the USEPA, the California Air Resources Board, and the AQMD; and (3) Allow the limited use of electrocoatings with coating concentrates higher in VOC content than what is currently allowed based on equivalent emission reductions; and (4) add definitions and clarify other language as necessary.
There are no adverse environmental or socioeconomic impacts that result from these proposed amendments to Rule 1107.
Proposal
Staff proposes to revise Rule 1107 as follows:
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ASTM Method D 1613 to determine the acid content of pretreatment primers and etching fillers to enhance rule clarity.
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AQMD Method 318 to quantify the weight percent of elemental aluminum metal in coatings by x-ray defraction to enhance rule clarity.
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AQMD Method 311 to quantify the metal content for other metals than aluminum contained in coatings to enhance rule clarity.
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Method 25.3 for the determination of low concentration non-methane non-ethane organic compound emissions. The method was EPA approved in March 2000.
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Add a definition for electrocoating process, electrostatic attraction, flow coat, dip coat, roll coater, alternative emission control plan, catalyst as clarifications to the rule.
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Allow the use of any other applicable method approved by the USEPA, CARB, and the AQMD not currently listed in the rule.
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Modify the definition of electric insulating varnish to include the application of these materials to power transformers and further clarify use of these materials.
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Modify the definition for textured finish to include that the coatings used to form the appearance of a textured finish are the textured coatings.
This proposal will not result in any adverse environmental or socioeconomic impacts.
Policy Issues
There are no remaining unresolved policy issues.
AQMP and Legal Mandates
The California Health and Safety Code requires the AQMD to adopt an 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. The proposed amendments to Rule 1107 are not required by a control measure of the 1997 AQMP, as amended in 1999. In addition, the proposed changes to Rule 1107 are not a result of any legal mandates.
CEQA and Socioeconomic Analysis
Pursuant to State CEQA Guidelines §15002 (k)(1), staff has reviewed the proposed amendments to Rule 1107 and has determined with certainty that the proposed project does not have the potential to adversely impact air quality or any other environmental area. Staff has concluded that the proposed project is exempt from CEQA pursuant to State CEQA Guidelines §15061 (b)(3) - Review for Exemption. A Notice of Exemption has been prepared pursuant to State CEQA Guidelines §15062 - Notice of Exemption and will be filed with the county clerks of Los Angeles, Orange, Riverside and San Bernardino counties immediately following the adoption of the proposed amended rule. There are no additional costs associated with the proposed amendments. Therefore, no significant socioeconomic impacts have been identified as a result of the proposed amendments.
Health and Safety Code Section 40920.6 requires an incremental cost effectiveness analysis when there is more than one control option to achieve the emission reduction objective of the proposed amendments, relative to ozone, CO, SOx, NOx, and their precursors. Since the proposal provides clarification to test methods and additional relief to affected facilities, no additional control is required. Therefore, the incremental cost effectiveness analysis requirement does not apply.
Implementation Plan
Current implementation and outreach programs are adequate to implement the proposed amendments.
Resource Impacts
Implementation of the proposed amendments is not expected to have any impacts on staff or fiscal resources.
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