BOARD MEETING DATE: November 4, 2005
AGENDA NO. 37

Amend Rule 1107 – Coating of Metal Parts and Products

SYNOPSIS:

The proposed amendments establish new, future effective, VOC limits for specific coating categories, and improve the clarity and enforceability of the rule.

COMMITTEE:

Stationary Source, September 23, 2005, Reviewed

1. Certifying the CEQA Environmental Assessment (EA) for
   Proposed Amended Rule 1107 – Coating of Metal Parts and Products; and
    
2. Amending Rule 1107 – Coating of Metal Parts and Products.

Barry R. Wallerstein, D.Env.
Executive Officer

Background

The objective of proposed amended Rule 1107 (PAR 1107) – Coating of Metal Parts and Products is to implement, in part, the 2003 Air Quality Management Plan (AQMP) control measure CTS-10 Miscellaneous Industrial Coatings and Solvent Operations (VOC). The total commitment of this control measure is a reduction of airborne volatile organic compounds (VOCs) of three tons per day by 2010.

Rule 1107 – Coating of Metal Parts and Products governs all original factory applied finishes to a wide variety of metals such as steel, aluminum, copper, brass, and special alloys, as fabricated into saleable parts and products. There are approximately 1,530 sources applying coatings to these products within the AQMD. Rule 1107 sets VOC limits for twenty-one categories of coatings for air-dried, as well as baked coating systems. Current VOC limits range from 275 grams of VOC per liter to 420 grams per liter. The largest emission sources are single and multi-component general use coatings, extreme high-gloss coatings, metallic coatings and prefabricated architectural component coatings. The remaining categories are specialty categories. After conducting a technology review, staff has focused its attention on two of the larger coating categories: prefabricated architectural component coatings and extreme high-gloss coatings. Sufficient coating technologies have been developed and are currently in use for a wide variety of applications that allows the AQMD to cost effectively obtain emissions reductions by lowering the VOC limits for these two coating categories. A reduction in VOC content for extreme high-gloss coatings is proposed from 420 grams per liter to 340 grams per liter and for prefabricated architectural component coatings from 420 grams per liter to 275 grams per liter for single-component coatings and to 340 grams per liter for multi-component coatings.

Several coating high transfer efficiency exemptions are being eliminated due to the development and availability of high-volume, low-pressure (HVLP) spray application technology. The rule still allows for the demonstration of alternate spray techniques that are equivalent to or better than HVLP spray technologies for transfer efficiency.

Based on the development of lower detection limits for EPA approved SCAQMD Method 25.3 (Determination of Low Concentration Non-Methane Organic Compound Emissions from Clean Fueled Combustion Sources), the alternative for demonstrating a 95% destruction efficiency across a control device is by measurement of 5 parts per million by volume (ppmv), or less at the outlet side of the control device. The alternative compliance limit in the rule is currently 50 ppmv.

Based on these proposed changes, staff is projecting an emission reduction of 0.8 tons per day of VOC at a cost-effectiveness of approximately $6,900 per ton of VOC reduced, which will partially fulfill the commitment for AQMP Control Measure CTS-10.

Proposal

The staff proposal is summarized as follows:

• Extreme High-Gloss Coatings
  Reduce the VOC limit from 420 grams per liter (g/l) to 340 g/l effective July 1, 2007
   
• Prefabricated Architectural Coatings
  Reduce the VOC limit for the prefabricated architectural coating category effective July 1, 2007 as follows:
  • Single component coatings from 420 g/l to 275 g/l
  • Multi-component coatings from 420 g/l to 340 g/l
     
• Modify the Alternative Requirement for 95 Percent Destruction Efficiency
  SCAQMD Method 25.3 (Determination of Low Concentration Non-Methane Organic Compound Emissions from Clean Fueled Combustion Sources) is approved by EPA to accommodate low inlet and concentrations down to 5 parts per million by volume (ppmv) instead of 50 ppmv.
   
• Modify/Delete Certain Transfer Efficiency Exemptions
  Certain exemptions are outdated and HVLP spray equipment are readily available.

The total amount of VOC emission reductions is 0.8 tons per day.

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 addition, the California Health and Safety Code requires that the AQMD adopt rules and regulations that carry out the objectives of the AQMP. Control Measure #CTS-10 in the 2003 AQMP commits to 3.0 tons of VOC per day of reductions of which this amendment to Rule 1107 partially fulfills.

CEQA and Socioeconomic Analysis

Pursuant to the California Environmental Quality Act (CEQA) and the AQMD’s Certified Regulatory Program (Rule 110), the AQMD prepared a Draft Environmental Assessment (EA) for Proposed Amended Rule 1107 – Coating of Metal Parts and Products, which was released for a 30-day public review period. One comment letter was received on the Draft EA, and has been incorporated as part of the Final EA which is included as part of this Adoption Hearing package.

A socioeconomic analysis has been conducted on the proposed amendments to Rule 1107. PAR 1107 will affect approximately 1530 metal coating sources in the district. They belong to a broad range of sectors in the economy. The annualized cost for all sources, including capital equipment and operating and maintenance costs, is projected to be $2.48 million. It is estimated that an average of 51 jobs would be foregone annually between 2007 and 2020 in the four-county region. This job estimate was within the noise of the model.

Implementation Plan

There will be no change from current Rule 1107 implementation procedures.

Resource Impacts

Implementation of the proposed amendments will have little or no impact on AQMD resources.

Attachments (EXE 724kb)

1. Summary of Proposed Amendments
2. Rule Development Process
3. Key Contacts List
4. Resolution
5. Rule Language
6. Final Staff Report
7. Final Environmental Assessment
8. Final Socioeconomic Assessment

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