BOARD MEETING DATE: August 1, 2003
AGENDA NO. 27

Report on Emission Limits for Rule 1136 – Wood Products Coatings

SYNOPSIS:

Rule 1136 requires operators to submit progress reports and staff to evaluate the state of current technology toward meeting the future effective VOC limits of July 1, 2005. Based on the reports submitted and staff’s evaluation, technology exists to support the future limits for all coating categories.

COMMITTEE:

Stationary Source, June 27, 2003, Reviewed

RECOMMENDED ACTION:

Receive and file report.

Barry R. Wallerstein, D.Env.
Executive Officer

The 1996 version of Rule 1136 delayed implementation of more stringent VOC limitations and established a new, flexible scheme for compliance. The rule contained a provision that required wood finishers to submit progress reports by January 1, 2003. Staff was to evaluate the state of the technology and the progress made by industry. With the final compliance date still two years off, 15.6% of wood coaters are already fully in compliance and 32.0% are partially in compliance. This leads staff to believe that the limits are achievable and will be met by most users by the final compliance date. Furthermore, there are many available products that meet or exceed the allowable rule limits.

Background

On June 14, 1996, the Governing Board of the South Coast Air Quality Management District (AQMD) adopted flexible volatile organic compound (VOC) limits for coatings used on wood products. The Board also delayed the implementation dates for the final limits. This action resulted in postponing approximately 9 tons of VOC emission reductions per day, through July 1, 2005. Today, wood finishers have options within the most widely used coating categories of sealers, primers, undercoats, and topcoats. They may either comply with a straight VOC limit of 550 grams of VOC per liter of coating across the board, or, alternatively use a "hybrid" approach that combines the application of still higher VOC sealers, primers, and undercoats with low-VOC clear and pigmented topcoats. In the case of coatings for use on shutters, the reverse hybrid approach is true (low-VOC sealers, primers and undercoats combined with high-VOC topcoats). In either case, the emissions resulting from the use of hybrid coating systems compared to the straight 550 grams VOC per liter approach are equivalent on a solids basis. The rule also affords coating manufacturers flexibility by regulating VOC content on either a per volume basis (grams per liter or pounds per gallon), or on a per weight solids basis (lb VOC per pound of solids).

According to Rule 1136 subdivision (j), all wood finishers were required to submit progress reports to AQMD by January 1, 2003, that details the extent of compliance with future low-VOC limits scheduled to occur on July 1, 2005. The report may either state that compliance with the 2005 limits is already achieved, or it must list the current process, wood species, and the types of coatings used to date, as well as include any test results of low-VOC products tried and further outline the plan by which future compliance will take place. As a reminder, staff notified all the wood finishers of progress report submittal requirements, and included a form for easy reference and fill-in. Staff conducted two such mail outs, one on November 22, 2002, and a second notification on March 20, 2003. In addition a public consultation meeting was held on June 10, 2003, to afford industry an opportunity to comment on the contents of the Technology Assessment for Rule 1136 – Wood Products Coatings, which is attached to this letter.

The attached Technology Assessment reflects the state of wood coatings technology based on information derived from progress reports submitted by industry, staff’s independent research on products, and technology available, including field observations. Staff has researched and witnessed the application of existing low-VOC wood coatings technologies in an effort to determine their applicability and feasibility of use across the spectrum of wood products coating operations. Although there are coatings that could provide additional VOC reductions, further limitations on VOC content would reduce the number of compliant technologies available and in use for many applications. The expressed future VOC limits provided by Rule 1136 provide for a broad range of resin systems and cure types that will afford the industry sufficient choice in waterborne, exempt solvent borne, and high-solids coatings while dramatically reducing smog forming compounds.

Results of Submitted Progress Reports

The AQMD sent out notification of progress reporting requirements with an accompanying fill-in-the-blank form to all Rule 1136 facilities on two separate dates: the first on November 22, 2002 and the second on March 20, 2003. Out of 780 known wood product coaters, 366 companies submitted meaningful data (46.9% of the universe of wood finishers). The results were grouped by industry type as those that conduct finishing operations of the following types:

• Household Furniture;
• Office and Contract Furniture;
• Kitchen and Bathroom Cabinets;
• Architectural Millwork and Store Fixtures;
• Shutters, Blinds, Doors, Windows and Moldings;
• Specialty Products (Musical Instruments, Toys, Speaker Cabinets, Picture Frames, Skateboards, etc.);
• Repair and Refinishing Operations;
• Job Shops (conduct a variety of wood coating operations)

There are a significant number of companies that have already transitioned fully or partially to low-VOC compliant products two years ahead of time. There are examples of companies using low-VOC technology at both large and small businesses for every category, with only a few exceptions such as high end stringed instrument manufacturing and possibly church pews finishing and re-finishing. The industry-wide results are as follows:

• 15.6% using fully compliant wood finishes at or below the July 1, 2005 VOC limits
• 32.0% using some wood finishes that comply with the July 1, 2005 VOC limits
• 52.5% not yet using any wood finishes that comply with the July 1, 2005 VOC limits

Results of Technology Assessment

Several fundamental low-VOC coatings formulations are available and in use today as wood finishes including waterborne, exempt solvent borne, high-solids, and 100% solids applications. Within these categories several resin systems are available including acrylic, polyurethane, polyester, alkyd, nitrocellulose, and various copolymers or modifiers including but not limited to latex, polycarbonate, polyethylene, and urea. Many cure types are also available as one-component air-dried, pre-catalyzed or self catalyzing, two-component post catalyzed, thermally cured powder coatings and light curable materials. Staff believes, and has verified by actual use in the field of wood finishing, that with the abundance of these various coating systems the future limits of Rule 1136 are feasible. Facilities with specific use problems may be addressed in the future on a case-by-case basis.

Review Process

Upon completion of the draft Technology Assessment for Rule 1136 – Wood Products Coatings, staff notified on May 20, 2003, wood coating users, manufacturers and other interested parties about its availability and solicited comments on staff’s analysis and conclusions. Copies of the draft technology assessment were made available on the AQMD web site, or mailed to those who requested a copy. Further, a Public Consultation Meeting was held on June 10, 2003 in the AQMD auditorium. Verbal comments were received and responses to those comments are attached as an appendix to the Technology Assessment for Rule 1136 – Wood Products Coatings June 2003). No written comments were submitted.

Conclusions

Rule 1136 is a significant component of AQMD’s stationary source control strategy. The July 1, 2005 limits will reduce VOC emissions from this source category by approximately 9 tons per day. Adequately performing wood finishes that meet the July 1, 2005 VOC limits are readily available and have been successfully used across the spectrum of wood finishing operations including, household, office and contract furniture, cabinets, millwork and store fixtures, shutters, doors and windows, specialty wood products as wells as repair and refinishing operations, as indicated in staff’s technology assessment.

Although coatings are currently available that fall well below the final limits and that could provide additional VOC reductions, further limitations on VOC content is not recommended at this time because it would reduce the number of compliant technologies available and in use for many applications. The expressed future VOC limits in Rule 1136 provide for a broad range of resin systems and cure types that will afford the industry sufficient choice in waterborne, exempt solvent borne, and high-solids coatings while dramatically reducing smog forming compounds. Staff expects these technologies to also address conversion problems expressed by operators of certain niche applications such as guitar manufacturing and church pew refinishing. Staff will continue its case-by-case evaluation of these niche applications.

There are a significant number of companies (large and small) engaged in a variety of different wood finishing operations that have already fully or partially converted to low-VOC compliant products two years ahead of schedule. This early conversion rate attests to the feasibility of these future VOC limits. The remaining two years provide adequate time for the rest of industry to follow suit.

Attachment

Technology Assessment for Rule 1136 – Wood Products Coatings

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