California’s South Coast Air Quality Management District (SCAQMD) has removed two marine coatings categories from its proposed 2012 Air Quality Management Plan (AQMP). The AQMP originally proposed further reductions in volatile organic compounds (VOC) content for for Marine Coatings Operations (rules 1106 () and Pleasure Craft Coatings Operations (1106.1).
But following ACA comments stating that further VOC reductions are not technologically feasible, SCAQMD excluded the coating categories from further regulation for the next year.
The California Health and Safety Code Section 40471(b) requires that SCAQMD prepare a report on the health impacts of air pollution in the South Coast Air Basin in conjunction with the preparation of the Air Quality Management Plan revisions.
ACA on Aug. 31 submitted detailed comments to SCAQMD on its proposed 2012 Air Quality Management Plan AQMP, which also includes potential future measures for VOC emission limits from Architectural and Industrial Maintenance (AIM) coatings. SCAQMD 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). The district is also considering amending or eliminating the small container exemption for architectural coatings. The district will be presenting its plan to its Board on Nov. 2, 2012, but will not be amending the actual regulations for a few years.
ACA has submitted several rounds of comments on the draft plan and has also met with district staff to discuss further reductions from architectural coatings (Rule 1113). In its latest comments, ACA asked SCAQMD to remove several proposed VOC reduction control measures for coatings and solvents. Of note, general emissions from AIM coatings have leveled off at around 12 tons per day, even though volumes are starting to increase.
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. ACA is encouraged that the district has at least included some language that allows for flexibility in the future, stating that any specific numeric goals or targets may be adjusted during the course of future rulemakings based on technical and economic concerns.
Specifically, ACA commented that SCAQMD should remove the proposed VOC reduction control measures – CTS-01, CTS-02, CTS-03, and CTS-04 – from the draft plan in consideration of the indisputably significant strides the paint and coatings industry has made in reducing its products’ VOC emissions in the past, noting that the district should focus on other sources for further emissions reductions instead of unfairly targeting the coatings industry. In doing so, ACA urged the district to take credit for the emissions reductions outlined in the 2007 AQMP CTS-02 “Clean Coating Certification Program” – emission credits resulting from the Rule 314 AIM fee rule, which amount to more than double the emission estimates from the current draft CTS-01. Given these credits, ACA argued that the 2012 AQMP CTS-01 is not necessary. ACA comments noted that just since the 2007 AQMP, the district has obtained nearly 26 tons per day (tpd) of VOC emission reductions at a cost of $73.8 million; the district estimates that this level will be further reduced to just 15 tpd by 2014, including colorants, reflecting a drop of approximately 37 to 40 tpd from architectural coatings alone in the past 12 years. This drop represents over 70 percent of the VOC emissions inventory from this source category – a severe cut by any standards. ACA believes that imposing even further VOC reductions on the industry is untenable.
Moreover, ACA underscored that reducing VOC emission will have no appreciable impact on ozone formation since the SCAQMD region is nitrogen oxide (NOx) limited. ACA urges the district to continue to focus on NOx reductions and remove the proposed VOC measures from the AQMP, especially since VOC measures are not cost effective for reducing ozone compared to NOx reductions.
The district’s next AQMP Advisory Group meeting is scheduled for Sept. 20, 2012.
SCAQMD is also considering possibly removing the Low Vapor Pressure (LVP) exemption via the CTS-04 control measure for Further Reductions from Consumer Products.