California’s South Coast Air Quality Management District, or SCAQMD, has proposed amendments to its Rule 1107-Coating of Metal Parts and Products. Already, the air district has incorporated some of the American Coating Association's suggested revisions to the rule, including the extension of compliance dates by one year, a 1-year sell through and use-through (previously 6 months), an increase in tertiary butyl acetate (TBAc) and dimethyl carbonate (DMC) permit modification thresholds, a more reasonable viscosity exemption, and additional rule language modifications.
Amendments to Rule 1107 will be considered for adoption by the AQMD Governing Board at a public hearing tentatively scheduled for Nov.2, 2012.
The air quality objective of Rule 1107 is to reduce volatile organic compound (VOC) emissions from the use of metal coatings. The rule applies to all metal coatings operations except those performed on aerospace assembly, magnet wire, marine craft, motor vehicle, metal container, and coil coating operations.
The amendment process has been ongoing for the better part of a year. ACA has been actively involved, submitting several rounds of comments.
In its most recent comments, ACA addressed a host of remaining concerns for the coatings industry. Chief among them is what ACA believes are problematic interim limits. As background, the district believes that it needs to include the interim limit to encourage waterborne coatings; however, ACA is concerned that many high solids coatings will be lost given the proposed interim limits. ACA 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 claims that many waterborne coatings in use today already meet the General and General Waterborne coatings limits; however, industry data suggests that this is not the case.
Given the major impacts that the proposed General 150 g/l limit, General Waterborne 150 g/l material VOC limit, and stringent Waterborne Coating definition will have on both coatings manufacturers and coatings application facilities, ACA once again suggested dropping the proposed Jan. 1, 2015 interim limits in order to give coatings manufacturers adequate time to develop coatings and reach out to customers as well as coatings application facilities to purchase, install, permit, and become comfortable with the new coatings and equipment.
ACA noted in its comments that the district has provided long implementation lead times in other rules, including Rule 1113 for Architectural and Industrial Maintenance (AIM) coatings. ACA hopes that the Jan. 1, 2018 effective date will provide the industry adequate time to comply, as compared to the current proposal that will likely force operations to leave the district. Since the district is not bound by specific State Implementation Plan (SIP) commitments for Rule 1107, ACA believes there should not be any SIP commitment obstacles to dropping the interim limits.
Moreover, ACA commented that the proposed definition for waterborne coatings at 5 percent of the volatile fraction is too stringent and would eliminate many waterborne coatings. Instead, ACA suggested the waterborne coating definition be modified as “any coating which contains more than 20 percent by weight in its volatile fraction, as applied.”
ACA staff will be participating in SCAQMD’s next public consultation meeting on the amendments to the rules on July 18.