BOARD MEETING DATE: January 6, 2006
AGENDA NO. 27

Amend Rule 1107 – Coating Of Metal Parts and Products

SYNPOSIS:

The proposed amendment will add an exemption for the use of up to ten gallons per year per facility of liquid photoresist applied to metal substrates with a thickness of not more than 0.060 inches.

COMMITTEE:

None

RECOMMENDED ACTIONS:

Adopt the attached resolution:

1. Certifying the CEQA Notice of Exemption (NOE) for the proposed amendments.
2. Amending Rule 1107 – Coating Of Metal Parts and Products.

Barry R. Wallerstein, D.Env.
Executive Officer

Background

On November 4, 2005, the Board amended Rule 1107 – Coating of Metal Parts and Products to reduce VOC emissions from the use of extreme high-gloss and prefabricated architectural coatings. Just prior to the public hearing, comment was received that the low-VOC technology required by Rule 1107 was not available for liquid photoresist coatings necessary for the manufacture of precision-etched parts from their metal substrates (1-60 mils in thickness) and an exemption was requested. The preliminary investigation by staff indicated low-VOC technology may not be available for this coating category. Very little of the material is used in the manufacturing process and only a few companies in the AQMD may be involved in this type of coating activity. Staff committed to expeditiously complete the investigation and return to the Board with the appropriate recommendation.

Analysis and Impacts

The photofabrication process begins as a computer drawing which is transferred to photographic film by laser imaging or by photographic means. Several images are transferred to film, and then transferred again to a photoresist coated thin sheet metal by ultra-violet light or electron beam to reverse polymerize areas that the light or beam sees. This creates softened places in the coating that are removed by a developing solution, exposing the metal underneath so that subsequent chemical etching of the exposed metal can take place. That part of the coating not exposed to light remains to protect it from etching or other chemical metal removal techniques, and is stripped away in the final step, revealing extremely small and intricate thin metal mechanisms for the medical device, antenna, and microwave industries.

The coatings necessary for this intricate activity are extremely low in solids content and therefore, very high in VOC (approximately 6.7 pounds per gallon). No low-VOC substitute has been identified. In addition, only a small amount of coating is applied during coating application. The annual usage at a facility is no more than ten gallons. There are currently six facilities in the AQMD performing photochemical machining of their metal substrates. Even if it is assumed that the number of facilities expands to ten and each uses a maximum of ten gallons per year, the average total daily VOC emission is less than 2.0 pounds per day. With such a low usage on the market, it is unlikely that low-VOC formulation will be developed and therefore, the current technology represents best available retrofit technology for this process.

Due to the unavailability of low-VOC technology and the minimal emissions from these operations, staff recommends an exemption for liquid photoresist coatings applied to thin metal substrates provided the annual usage of liquid photoresist coating is no more than ten gallons per facility. An exemption with such a low emission impact does not have a significant affect on air quality or emission limitations.

Legislative Authority

The California legislature created the AQMD in 1977 (Lewis-Presley Air Quality Management Act, Health and Safety Code Section 40400 et seq.) as the agency responsible for developing and enforcing air pollution control rules and regulations in the South Coast Basin (Basin). By statute, the AQMD is required to adopt an AQMP demonstrating compliance with all state and federal ambient air quality standards for the Basin [California Health and Safety Code Section 40460(a)]. Furthermore, the AQMD must adopt rules and regulations that carry out the AQMP [California Health and Safety Code Section 40440(a)].

Proposal

Staff is proposing to add exemption (f)(9) to allow the use of up to 10 gallons per year of liquid photoresist for photofabrication of metal substrates with a thickness not exceeding 0.060 inches. Definitions (b)(42) and (b)(43) have also been added to identify the meaning of a photoresist coating and photoresist operations.

California Environmental Quality Act (CEQA) Analysis

Pursuant to CEQA and the AQMD’s Certified Regulatory Program (Rule 110), staff has prepared a Notice of Exemption (NOE) for Proposed Amended Rule 1107 – Coating of Metal Parts and Products. The NOE will conclude that the proposed amendment will not have any significant adverse effect on the environment. The NOE is included as Attachment F.

Cost and Resource Impacts

The proposed amendment to Rule 1107 will not result in increased costs to the affected industries and there will be no additional impact on AQMD resources.

AQMP and Legal Mandates

The California Health and Safety Code requires the AQMD to adopt an AQMP to meet state and federal ambient air quality 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 amendment to Rule 1107 does not have a significant impact on air quality or emissions limitations and, therefore, will not affect the ozone attainment strategy outlined in the AQMP.

Comparative Analysis

Pursuant to California Health and Safety Code §40727.2(g), PAR 1107 complies with the requirements of California Health and Safety Code §40727.2 since it does not impose a new emission limit or standard, make an existing emission limit or standard more stringent, or impose new or more stringent monitoring, reporting or recordkeeping requirements.

Draft Findings

Necessity - The AQMD Governing Board has determined that a need exists to amend Rule 1107 – Coating off Metal Parts and Products, to exempt liquid photoresist coatings, used in small amounts for thin metal photofabrication, due to the unavailability of low-VOC coatings.

Authority -The AQMD Governing Board obtains its authority to adopt, amend, or repeal rules and regulations from Sections 39002, 39650 et seq., 40000, 40001, 40440, 40441, 40702, 41508, and 41700 of the California Health and Safety Code.

Clarity - The AQMD Governing Board has determined that Proposed Amended Rule 1107 – Coating of Metal Parts and Products as proposed to be amended is written or displayed so that its meaning can easily be understood by the persons directly affected by it.

Consistency - The AQMD Governing Board has determined that Proposed Amended Rule 1107 – Coating of Metal Parts and Products as proposed to be amended is in harmony with, and not in conflict with or contradictory to, existing statutes, court decisions, federal or state regulations.

Non-Duplication - The AQMD Governing Board has determined that Rule 1107 – Coating of Metal Parts and Products as proposed to be amended does not impose the same requirements as any existing federal regulations, and the proposed amended rule is necessary and proper to execute the powers and duties granted to, and imposed upon, the AQMD.

Reference - In amending this regulation, the AQMD Governing Board references the following statutes which the AQMD hereby implements, interprets or makes specific: California Health and Safety Code Section 40001 (rules to achieve ambient air quality standards), and Federal Clean Air Act Section 172(c)(1) (RACT).

Problem - The AQMD Governing Board finds and determines that there is a problem that Proposed Amended Rule 1107 will alleviate, the unavailability of low-VOC liquid photoresist coatings used for photofabrication of thin metal parts.

Attachments (EXE 121kb)

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