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Coating Makers Work to Blunt New Rules

Friday, July 13, 2012

More items for Coating Materials

Coating manufacturers are making inroads against California’s plan to further tighten emission rules on metal coating operations, the American Coatings Association reports.

Coating makers are working to modify the rules, which apply to most metal coating operations.

The South Coast Air Quality Management District (SCAQMD) has proposed new amendments to California’s Rule 1107-Coating of Metal Parts and Products, which was last revised in January 2006.

South Coast is the Los Angeles-area air-quality agency that frequently sets the course for national pollution rules. ACA represents coating manufacturers.

The manufacturers’ group has been deeply involved in developing the latest amendments to the metal coating rule and says it is having an impact, including negotiating a one-year delay in the implementation date.

Who is Affected

South Coast says the changes are needed to help the region meet federal and state air quality mandates. Coatings are the single largest source of VOCs that the district can regulate.
 
Originally adopted in 1979 and amended seven times since then, the Metal Coating rule applies to all metal coatings operations, except those performed on aerospace assembly, magnet wire, marine craft, motor vehicle, metal container, and coil coatings.

U.S. EPA

Architectural, traffic and industrial maintenance coatings emitted about 58 tons of ozone—the equivalent of emissions from 1.7 million motor vehicles—per day in the South Coast air basin in 2002.

Typically, the rule would affect fabricators and manufacturers of steel products, shipping containers, structural metals, machinery, transportation equipment, shelving and lockers, and paints and coatings.

Amendment Highlights

The proposed amendments would, among other things:

• Amend VOC limits for certain metal coating categories;

• Establish new coating categories and VOC content limits;

• Include a 12-month sell-through and use-through provision;

• Expand the applicability of the rule to include some metal stripping operations;

• Expand and clarify the definition and requirements for Extreme Performance coatings;

• Establish new reporting and record-keeping provisions for operations that use coatings containing dimethyl carbonate (DMC) and tertiary-butyl acetate (t-BAC);

• Consider limited exemptions for DMC and t-BAC coatings; and

• Prohibit the use of Group II Exempt Solvents in metal coatings or strippers.

The amendment process has been underway for almost a year. Among the changes ACA has shaped:

• Doubling the sell-through and use-through provision, which had been six months;

• Increasing the allowable t-BAC and DMC thresholds;

• Making the viscosity exemption “more reasonable”; and

• Modifying some of the rule language.

Remaining Concerns

ACA still wants other changes before the amendments become final. The group’s most recent round of comments noted several concerns.

Chief among them is what ACA believes are problematic interim limits. The district contends that interim limits are needed to encourage waterborne coatings. ACA argues, however, that the interim limits will eliminate many high-solids coatings.

ACA also maintains that waterborne coatings will need to be reformulated to meet the 150 g/l General and 275 g/l (150 g/l material VOC) General Waterborne interim limits, especially given the new lacquer definition, stringent General Waterborne material VOC limits, and stringent Waterborne Coating definition.

The district says that many waterborne coatings already meet the General and General Waterborne coatings limits; coating makers disagree.

ACA is again urging the district to drop the proposed Jan. 1, 2015, interim limits to give manufacturers more time to develop coatings and to work with application facilities to install and become comfortable with the new coatings and equipment.

ACA also contends that the proposed definition for waterborne coatings at 5 percent of the volatile fraction is too stringent and would eliminate many of these coatings. ACA wants to modify the definition as “any coating which contains more than 20 percent by weight in its volatile fraction, as applied.”

Finally, ACA is also urging the district to keep the tentative Jan. 1, 2018, effective date for the amendments, saying that less time will force certain coating operations to leave the district.

Meeting, Vote Scheduled

The district has set a public meeting on the amendments for Wednesday (July 18) at its headquarters in Los Angeles County. The AQMD Governing Board is scheduled to vote on the amendments Nov. 2 at a public hearing.

For more information, contact David Darling, ACA’s senior director of environmental affairs.