California’s South Coast Air Quality Management District (SCAQMD) is developing its 2012 Air Quality Management Plan (AQMP), which will include potential future measures for volatile organic compound (VOC) emission limits from Architectural and Industrial Maintentance (AIM) coatings.
ACA submitted comments on the draft plan on June 13 and has also met with district staff to discuss further reductions from architectural coatings (Rule 1113). Of note, general emissions from AIM coatings have leveled off at around 12 tons per day, even though volumes are starting to increase.
The district is looking at a 25 g/l regulatory VOC content limit for flats/nonflats and primer, sealer, undercoaters, or an equivalent material VOC content (approximately 12 g/l material VOC limit)
ACA wants to assure that appropriate inventory credit is given for the significant reductions already achieved in mass and reactivity of VOC emissions from architectural coatings, and additional reductions to come from requirements for colorants, VOC limit reductions, and thinning/cleaning solvents.
ACA is concerned that if extreme and unproven reductions are approved, the industry will be forced to achieve the VOC targets regardless of whether the set control measures are technologically feasible. ACA fears that once these reduction estimates are approved in the AQMP and the State Implementation Plan (SIP), the District may sidestep the technical concerns claiming that it has no choice since the reductions are “locked” into the Plan/SIP. Given this significant concern, ACA urged the district to amend the Plan to clearly state that any specific numeric goals or targets are subject to the district’s statutory authority to regulate non-mobile sources and may be adjusted in the future based on technological feasibility analyses.
SCAQMD held its tenth meeting on the plan development on June 14.
ACA raised its general concern with the absence of the following in the Air Quality Management Plan:
(1) assessment of technological or economic feasibility of the proposals, which may amount to pointless bans on useful products;
(2) assessment of potentially significant unintended adverse environmental impacts from either (a) substitution of inadequate alternatives, or (b) lack of adequate protective maintenance painting; and
(3) demonstration that further reductions in VOC emissions from architectural coatings would be necessary or helpful in achieving ozone attainment under the increasingly NOx-limited conditions of the South Coast Air Basin.
In its comments ACA specifically expressed concern that limits lower than 50 g/l (flat and nonflat) and 100 g/l for primers, sealers, and undercoaters may be difficult given the current problems associated with VOC test methods. ACA suggested SCAQMD complete a technology assessment to be sure that it is technologically feasible to lower the VOC limits, especially since certain products need to be kept at the current limits.
ACA also maintains that eliminating the small container exemption, or eliminating the exemption for certain categories is problematic since the small container exemption is critical given the fact that the SCAQMD Rule 1113 limits are the most stringent in the United States. This exemption provides a “safety valve” or a last resort option that allows for traditional products in problem situations when the limits in categories become more stringent or a category is eliminated. There are also a host of niche coatings that manufacturers can now sell in small containers that would need to be categorized if the small container exemption is modified or removed.
Finally, ACA voiced concern that the district is imposing transfer efficiency requirements on equipment used to apply AIM coatings. With regards to the laser paint targeting system, ACA is concerned that the system is sold exclusively by Iowa University and has not been widely distributed throughout the United States. While this technology may be useful for training contractors to properly apply coatings in an automotive refinish shop under controlled conditions, this technology may not be applicable to field applied coatings. As such, ACA is concerned that it may be difficult for the District to document and receive SIP credit for increased efficiency from the use of this technology. Further, this equipment is expensive – approximately $100 per unit (not including replacement of the lithium battery that has a tested average life of only 20 hours). ACA is also concerned that this technology was designed for auto refinish coatings shops, and it may not work on AIM spray equipment that is used in the field (large areas, use of wands, rough texture substrates, sunny locations).
SCAQMD is also considering possibly removing the Low Vapor Pressure (LVP) exemption via CTS-04 Further Reductions from Consumer Products