South Coast Air Quality Management District

BOARD MEETING DATE: September 21, 2001 AGENDA NO. 31

PROPOSAL:

Amend Rule 1124 – Aerospace Assembly and Component Manufacturing Operations

SYNOPSIS:

The proposed amendments to Rule 1124 will adjust the VOC limits and compliance dates for several aerospace coating, sealant and adhesive categories to reflect the state of the technology; establish an industry-specific alternative compliance option to the risk reduction plan requirements of Rule 1402; and incorporate other minor improvements and clarifications.

COMMITTEE:

Stationary Source, July 27, 2001, Reviewed

RECOMMENDED ACTION:

Adopt the attached resolution:

Certifying the CEQA Final Environmental Assessment (EA) for Proposed Amended Rule 1124 – Aerospace Assembly and Component Manufacturing Operations; and

Amending Rule 1124 – Aerospace Assembly and Component Manufacturing Operations

Barry R. Wallerstein, D.Env.
Executive Officer

Background

The AQMD adopted Rule 1124 in July of 1979 to set baseline VOC concentrations for various VOC containing materials used during the manufacturing and assembly of aerospace components, and set future implementation dates. Today, the rule encompasses all assembly, component manufacturing, refinishing, repair, maintenance, and service operations of commercial and military airplanes, satellites, space shuttles, rockets, balloons, dirigibles, helicopters and missiles.

Among the materials used in the aerospace market are coatings, adhesives, sealants, lubricants, strippers, cleaning solvents, maskants and associated primers. Over the years, the AQMD has lowered VOC concentrations in a number of areas. As a result, Rule 1124 requires the aerospace industry to inform the AQMD, through periodic progress reports, the status of new lower VOC products relative to performance standards and qualification procedures. Staff's latest assessment of the state of the technology revealed that while progress has been made with respect to several aerospace material categories that will allow further lowering of the VOC limits, there are a few categories with technology forcing limits where compliant products are not available, and, therefore, achieving these limits is not technologically feasible. Amendments to Rule 1124 are proposed to revise the VOC limits for several aerospace materials to reflect the state of current technology.

Staff has also developed a compliance option to the risk reduction plan of Rule 1402 - Control of Toxic Air Contaminants from Existing Sources, in response to the Governing Board direction to develop an industry specific, technology based alternative compliance option.

Proposal

Staff proposes to revise the VOC content limits for certain categories and create or reinstate categories for adhesive bonding primers and adhesion promoters, as follows:

Reinstate the category for adhesion promoters with a VOC limit of 850 grams per liter and reduce the limit to 250 grams VOC per liter beginning January 1, 2005.
Create four subcategories for adhesive bonding primers in place of one general category:

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New Commercial Aircraft adhesive bonding primer is created as a subcategory and its VOC limit retained at 250 grams VOC per liter limit.

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All Military Aircraft adhesive bonding primer, Remanufactured Commercial Aircraft Parts adhesive bonding primer, and Sonic and Acoustic Applications for adhesive bonding primers are created as a subcategories and revised from 250 grams VOC per liter to 805 grams VOC per liter, since compliant materials with adequate performance characteristics for each application are not available at this time.

Staff also proposes to reduce VOC content, reinstate or create new categories for the following materials:

Create a new category for Mold Release Coatings and set the limit at 780 grams VOC per liter.
Create a category for Extrudable, Rollable, or Brushable Sealants and reduce the VOC limit from 675 grams per liter to 280 grams per liter on March 1, 2002.
Reduce the VOC limit for Military Fire Resistant Coatings from 980 grams per liter to 800 grams per liter.
Reinstate the category of Fastener Sealant and retain a VOC limit of 675 grams per liter.
Create a subcategory for Type I Chemical Milling Maskant and retain a 250 grams VOC per liter limit.
Create a subcategory for Type II Chemical Milling Maskant and reduce the VOC limit from 250 grams VOC to 160 grams VOC per liter.
Staff is also recommending an alternative to the risk-reduction plan requirements of Rule 1402 – Control of Toxic Air Contaminants from Existing Sources. The proposal is based on the application of existing control technologies and efficiencies achieved-in-practice that reduce toxicity-weighted emissions of carcinogenic components of aerospace materials. When the facility exceeds the risk action levels established by Rule 1402, the proposed compliance option calls for the reduction of a facility's toxicity-weighted organic solvent and particulate emissions by 90.0 and 99.0 percent, respectively. The proposed compliance option is not designed to replace or restrict a facility's ability to comply with the procedures established under Rule 1402, but rather, to provide an additional alternative to complying with Rule 1402.
Extend the limited exemption for fuel tank coatings from January 1, 2002 to January 1, 2005.
Clarify rule language and add definitions as appropriate.

This proposal will result in approximately 50 pounds per day of VOC emission reductions foregone in 2003. However, reductions in the allowable VOC content for several coating, primer, and sealant categories will reduce the emission reductions forgone to less than 12 pounds of VOC in 2005. This is less than the VOC significance threshold of 55 lbs/day used to determine if a project causes a significant impact on the environment. Therefore, there are no significant adverse environmental or socioeconomic impacts anticipated.

Policy Issues

During the rule amendment development process the aerospace industry commented that the lower future limit for adhesion promoters to be unwarranted since the emissions from these materials are small. However, the lower limits are necessary, since AQMD is obligated to implement all feasible measures to ensure expeditious progress towards attainment. Also, industry commented that the control efficiencies under the alternative toxics compliance option considered are too restrictive when the capture and control of toxic species is difficult such as in open-spray touch-up applications. Staff has revised the reduction efficiency for toxic particulate from 99.9 percent to 99.0 percent to account for such difficulties and retained the 90.0 percent reduction efficiency requirement for toxic organic solvent emissions, since this is an efficiency already achieved in practice.

AQMP and Legal Mandates

The proposed amendments to Rule 1124 are not required by a control measure of the 1997 Air Quality Management Plan (AQMP), as amended in 1999. However, the State Implementation Plan (SIP) Settlement Agreement requires the Board, in the event there is a relaxation or delay of technology forcing limits, to make a finding that it is infeasible to implement the measure provided that the limit is not delayed by more than two years. Alternatively, other measures can be adopted and implemented to eliminate the shortfall in reductions within two years after the implementation of the rule. Staff is recommending the use of emission reductions from other measures (i.e., Rule 461 – Gasoline Transfer and Dispensing, as amended in April 2000) to offset any emission reductions foregone as a result of the amendment.

CEQA and Socioeconomic Analysis

Pursuant to the California Environmental Quality Act (CEQA) and the AQMD’s Certified Regulatory Program (Rule 110), the AQMD has prepared a Draft Environmental Assessment (EA) for Proposed Amendments to Rule 1124 – Aerospace Assembly and Component Manufacturing Operations. The Draft EA concludes that implementation of the proposed project would not result in significant adverse environmental impacts. The Draft EA was released for a 30-day public review period. No comments were received on the Draft EA. The Final EA has been prepared and is included as part of this Adopt Hearing package.

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.

Implementation Plan

The aerospace industry is a well-informed group, typically employing environmental personnel. Staff will continue its outreach efforts to ensure the successful implementation of the amendments.

Resource Impacts

Air toxics plans are expected to be filed with the District for review and approval. Current processing staff is sufficient to assess the viability and compliance status of such submitted plans. Implementation of the proposed amendments is not expected to have significant impacts on staff or fiscal resources.

Attachments

Summary of Proposed Amendments
Rule Development Process
Key Contacts List
Resolution
Rule Language
Staff Report
Environmental Assessment

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This page updated: July 09, 2010
URL: http://www.aqmd.gov/hb/2001/010931a.html

–	New Commercial Aircraft adhesive bonding primer is created as a subcategory and its VOC limit retained at 250 grams VOC per liter limit.
–	All Military Aircraft adhesive bonding primer, Remanufactured Commercial Aircraft Parts adhesive bonding primer, and Sonic and Acoustic Applications for adhesive bonding primers are created as a subcategories and revised from 250 grams VOC per liter to 805 grams VOC per liter, since compliant materials with adequate performance characteristics for each application are not available at this time.