State of California
AIR RESOURCES BOARD
Pacific Ballroom
Holiday Inn - Embarcadero
1355 No. Harbor Drive
San Diego, CA
July 26, 1978
10:00 a.m.
AGENDA
Page
78-13-1 Approval of Minutes of June 28, 1978 Board Meeting I
78-13-2 Public Hearing to Consider the Adoption of a Schedule 001
of Fees for Source Testing and Other Special Testing
78-13-3 Consideration of Model Rule for the Control of Volatile 055
Organic Emissions from Can and Coil Coating Operations
78-13-4 Status Report on Memorandum of Understanding Between 152
the Department of Transportation and the Air Resources
Board Regarding Air Quality Planning and Transportation
Planning
78-13-5 Other Business -
a. Executive Session - Personnel and Litigation
b. Research Proposals
ITEM NO.: 78-13-2
Public Hearing to Consider Adoption of a Schedule of Fees for
Source Testing and Other Special Testing
RECOMMENDATION
Adopt Resolution 78-42 thereby adding a schedule of fees for
source testing and other special testing by the Board staff,
together with procedures applying thereto, into Title 17,
California Administrative Code and directing the Executive
Officer to recommend that local districts with source testing and
other special testing capabilities also adopt a schedule of fees
for such testing.
SUMMARY
Source testing and other special tests are necessary techniques
for determining whether emission sources are operating in
compliance with applicable emission and other limitations,
especially those governing non-visible emissions, and for
verifying the accuracy of in-stack monitors operated by emission
sources. Source testing is also valuable as a means of
evaluating the performance of emission control equipment and
techniques. Section 41510 of the Health and Safety Code
authorizes the Executive Officer of the Board to secure samples
of emissions from air pollution emission sources. Section 41512
of the Health and Safety Code gives the Board the discretion to
establish a schedule of fees not exceeding its costs associated
with securing such samples. To date, the staff has been funding
its source testing and other special testing operations from
monies included in the annual budget allotments to the Board.
The costs of these operations have included a basic source test
cost of 1,270 dollars per test, plus additional, pollutant-
specific test costs ranging from 25 dollars per sample to 335
dollars per sample, and approximately 1,220 dollars for each day
of continuous source testing. In addition, costs for special
testing such as Reid vapor pressure testing of petroleum
distillates, ambient air monitoring for vinyl chloride, visible
emission evaluations, etc., range from one dollar and 25 cents to
1,935 dollars. The adoption of a schedule of fees for source
testing and other special testing by the Board would shift the
costs of its source testing and other special testing from
general tax revenues to the air pollution emission source.
APPENDICES: Appendix A - Health and Safety Code Sections
Appendix B - Air Resources Board Calculation of
Recoverable Costs for Source
Testing Services and Other Special
Testing
Appendix C - Proposed Amendments to Title 17
ITEM NO.: 78-13-3
Consideration of a Proposed Model Rule for the Control of
Volatile Organic Compounds from Can and Coil Coating Operations.
RECOMMENDATION
Approve the model rule and direct the staff to transmit it to the
South Coast Air Quality Management District, the Bay Area Air
Pollution Control District, the San Diego County Air Pollution
Control District, and air pollution control districts in the
Sacramento and San Joaquin Valley Air Basins.
SUMMARY
The staff of the Air Resources Board has identified the need to
reduce organic emissions from sources in a number of air basins,
where the ambient air quality standard for oxidant has been
exceeded on numerous occasions.
Can and coil coatings are those coatings applied to the internal
and external surfaces of containers, pails, drums, collapsible
tubes, and other containers; and to flat stock and coiled metal
for metal protection and to enhance the esthetics. The major
portion of can and coil coating facilities are located in the
State's urban areas, in particular in the five air pollution
control districts mentioned. The application of can and coil
coatings generates organic compounc emissions of 34.2 tons per
day.
The proposed model rule would control emissions largely through
the use of waterborne coatings. At least one can coating
facility in California is using waterborne coatings exclusively,
and a substantial portion of others have either committed a
production line or are experimenting with the commercial
application of waterborne systems. Waterborne coatings replacing
the solvent-borne coatings in the can coating categories
responsible for the major portion of the emissions are either
commercially availabe or are in the final stages laboratory
evaluation.
Not only do waterborne coatings reduce emissions, but in
complying with the proposed model rule permit the shutdown of
afterburners resulting in a considerable savings in natural gas.
The staff estimates overall energy savings from the application
of the proposed model rule to be equivalent to 500,000 barrels of
fuel oil per year.
Other methods for emission control are the use of high-solids
coatings and/or incinerators. Incinerators operating with an
efficient volatile emissions capture system can reduce intake
emissions by approximately 90 percent.
The use of incinerators to control emissions from coil coating
lines is substantially more efficient than for can coating lines.
In fact, staff estimates that the capture system for coil coating
operations is about 85 percent efficient and currently reduces
emissions to below the limits established by the proposed model
rule.
The staff estimates that the can and coil coating industries
could reduce emissions by 22 tons per day if the proposed model
rule is adopted.
The cost-effectiveness of the emission control options ranges
from no change in cost to a savings of $0.18 per pound of reduced
emissions.
Table of Contents
Page
I. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
II. Conclusions and Recommendations . . . . . . . . . . . . . . . . . . .5
A. Conclusions. . . . . . . . . . . . . . . . . . . . . . . . . . .5
B. Recommendations. . . . . . . . . . . . . . . . . . . . . . . . .8
III. Discussion of Model Rule. . . . . . . . . . . . . . . . . . . . . . 14
IV. Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
A. Description of the Can and Coil Regulation Program . . . . . . 15
B. Overview of the Industries . . . . . . . . . . . . . . . . . . 17
1. Can Coaters . . . . . . . . . . . . . . . . . . . . . . . 17
2. Coil Coaters. . . . . . . . . . . . . . . . . . . . . . . 18
3. Processes . . . . . . . . . . . . . . . . . . . . . . . . 19
V. Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
A. Industry Survey. . . . . . . . . . . . . . . . . . . . . . . . 20
1. ARB Survey. . . . . . . . . . . . . . . . . . . . . . . . 20
2. Can Manufacturers Institute Survey. . . . . . . . . . . . 21
3. National Coil Coaters Association Survey. . . . . . . . . 21
B. Emission Estimate. . . . . . . . . . . . . . . . . . . . . . . 22
1. Air Resources Board . . . . . . . . . . . . . . . . . . . 22
2. CMI . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
3. Potential Emission Reductions . . . . . . . . . . . . . . 28
VI. Existing Technology in the Coating Industry . . . . . . . . . . . . 31
A. Cans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
B. Coils. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
VII. Emission Reduction Technology . . . . . . . . . . . . . . . . . . . 35
A. Waterborne Coatings. . . . . . . . . . . . . . . . . . . . . . 36
B. High-Solids coatings . . . . . . . . . . . . . . . . . . . . . 38
C. Powder Coatings. . . . . . . . . . . . . . . . . . . . . . . . 39
D. Afterburners . . . . . . . . . . . . . . . . . . . . . . . . . 40
E. Other Methods. . . . . . . . . . . . . . . . . . . . . . . . . 45
VIII. Impacts. . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
A. Economic Impacts . . . . . . . . . . . . . . . . . . . . . . . 46
1. Available Controls and Cost-effectiveness . . . . . . . . 46
a. Waterborne Coatings. . . . . . . . . . . . . . . . . 46
b. High-Solids Coatings . . . . . . . . . . . . . . . . 48
c. Powder Coatings. . . . . . . . . . . . . . . . . . . 49
d. Afterburners . . . . . . . . . . . . . . . . . . . . 50
B. Environmental Impacts. . . . . . . . . . . . . . . . . . . . . 55
1. Energy. . . . . . . . . . . . . . . . . . . . . . . . . . 55
2. Other . . . . . . . . . . . . . . . . . . . . . . . . . . 56
Appendix A - Surveys of Coating Manufacturers and Can and Coil
Coaters.
Appendix B - Notice of Public Consultation Meeting.
Appendix C - General Discussion of Can and Coil Coating
Processes.
Appendix D - Lists of Can and Coil Manufacturers in California.
ITEM NO.: 78-13-4
ARB/Caltrans Memorandum of Understanding Status Report
RECOMMENDATIONS
None.
SUMMARY
In May 1978, ARB and Caltrans completed a Memorandum of
Understanding (MOU) which defines the means for determining the
consistency of transportation plans and projects with air quality
plans which is required by federal regulations. The MOU was
brought to the attention of the Legislature which asked the
agencies to appear before a joint Senate/Assembly Transportation
Committee on June 13, 1978, to explain the MOU and some aspects
of the Clean Air Act as amended in 1977. The committee requested
that the ARB and Caltrans hold public meetings regarding the
respective roles of all levels of government and the private
sector in implementing the Clean Air Act and specifically keying
on the MOU.
The requested public meetings were held in Los Angeles on July
10, 1978 and in Oakland on July 11, 1978. In general, concerns
were raised about (1) recognizing local and regional roles in
developing plans and determining reasonably available
transportation control measures, (2) involving local and regional
agencies in a consultation process to resolve differences, (3)
clarifying project consistency with the State Implementation
Plan, and (4) a lack of local and regional involvement in
developing the MOU.
On August 8, 1978, ARB and Caltrans are to appear again before
the joint Senate/Assembly Transportation Committee to report the
results of the public meetings. It is proposed to revise the MOU
to address the above concerns.
This staff report is to inform the Board of the activities
concerning the MOU.