State of California
AIR RESOURCES BOARD
Pacific Ballroom
Holiday Inn - Embarcadero
1355 No. Harbor Drive
San Diego, CA
July 27, 1978
10:00 a.m.
AGENDA
Page
78-14-1 Approval of Minutes of June 29, 1978 Board Meeting I
78-14-2 Continuation of Public Hearing to Consider Petitions 001
Submitted by the Southern California Edison Company and the
Los Angeles Department of Water and Power for Review of
Rule 475.1 of the South Coast Air Quality Management District
(SCAQMD), NOx and other Authorized Actions Relating to the
Subject Matter of Rule 475.1 (and Related Rule 475),
and to Consider the Need for a Model Rule for NOx
Control from Power Plants in Ventura County
78-14-3 Proposed Designation and Redesignation of Air Quality 317
Control Regions (AQCR)
78-14-4 Continuation of Hearing To Consider a Model Rule for 346
the Control of Volatile Organic Compound Emissions from
Metal Furniture and Fixture Coating Operations
78-14-5 Other Business -
a. Executive Session - Personnel and Litigation
b. Research Proposals
ITEM NO S.: 78-10-1, 78-11-1, AND 78-14-2
Continuation of Public Hearing to Consider Petitions Submitted by
the Southern California Edison Company and the Los Angeles
Department of Water and Power for Review of Rule 475.1 of the
South Coast Air Quality Management District (SCAQMD), NOx and
other Authorized Actions Relating to the Subject Matter of Rule
475.1 (and Related Rule 475), and to Consider the Need for a
Model Rule for NOx Control from Power Plants in Ventura County.
RECOMMENDATION
The Board should accept jurisdiction of the petitions filed by
the Southern California Edison Company and the Los Angeles
Department of Water and Power. After this public hearing, the
Board should determine whether the South Coast Air Quality
Management District's action in adopting Rule 475.1 (and related
Rule 475) was consistent with the purposes of Division 26 of the
Health and Safety Code. In making this determination, the Board
should include all relevant evidence, including the staff's
analysis of an alternative "system-wide" approach to controlling
NOx emissions from electric power generation. In connection with
this staff proposal, the Board should also consider taking action
under Health and Safety Code Section 41504 with respect to Rule
475.1 (and related Rule 475). Finally, the Board should consider
the need for a model rule for controlling NOx emissions from
electric power generating facilities in Ventura County.
SUMMARY
Two petitions have been filed by the Southern California Edison
Company and the Los Angeles Department of Water and Power seeking
review under Health and Safety Code Section 40451 of the South
Coast Air Quality Management District's adoption of Rule 475.1,
which requires electric power generating facilities to achieve a
90 percent reduction of NOx emissions by 1987. Three other
petitions were filed late by utilities operated by the cities of
Glendale, Burbank, and Pasadena. These petitions cannot be
accepted for formal review, but the utilities should be allowed
to present evidence as interested persons.
Under Section 40451, the Board has discretion to accept or deny
jurisdiciton, and to determine what evidence should be received
in addition to the record before a district. Since the issues
relate to a rule-making matter affecting the conduct of any
utility, rather than individual rights, strict trial-like rules
of evidence, including cross examination, need not (though they
may) be controlling.
Section 40451 provides that, after a public hearing on a
petition, the Board may find that the South Coast Air Quality
Management District's action was consistent or inconsistent with
the purposes of division 26 of the Health and Safety Code. Upon
finding that the action was inconsistent with these purposes, the
Board may take one or more of a number of remedial actions.
The petitions allege that Rule 475.1 will not promote attainment
of the ambient air quality standards, is not technologically
feasible, and is unreasonably expensive. Based on these
allegations, the petitions conclude that Rule 475.1 is
inconsistent with the purposes of Division 26, since in adopting a
"technology-forcing" rule the SCAQMD exceeded its statutory
authority to adopt rules reflecting the "best available
technological and administrative practices" (BATAP). The staff
believes that the rule is feasible and necessary and that BATAP
does require technology-forcing rules. The staff therefore
believes that Rule 475.1 is not inconsistent with the purposes of
Division 26 for the reasons set forth in the petitions.
In considering the petitions, the Board should also consider
evidence presented by the staff of an alternative approach to
controlling NOx emissions from power plants. This alternative
approach would achieve greater NOx reductions, at less cost, and
at earlier dates than would Rule 475.1. If the Board determines
that there is a substantial and significant difference between
the two rules with respect to the basic BATAP requirement, it
could conclude that the SCAQMD's action was inconsistent with the
purposes of Division 26, in that such action fails to use all
reasonable and available methods to achieve the ambient air
quality standards as expeditiously as practicable. Since part of
Southern California Edison's system is located in Ventura County,
the Board should also consider a complementary model rule for
Ventura County.
While the petitions address Rule 475.1, they also relate
indirectly to Rule 475, which in relevant part establishes NOx
control requirements for new power plants. These requirements
are in the near-term less stringent than those applied to
existing facilities by Rule 475.1. Accordingly, this report also
addresses the consistency of Rule 475 with the purposes of
division 26 of the Health and Safety Code.
Finally, this matter has been scheduled concurrently as a review
of Rules 475.1 and 475 under the Board's general powers to review
the adequacy of district rules and regulations for achieving and
maintaining the state ambient air quality standards (Health and
Safety Code Section 41500). If these rules are found to be
inadequate in this regard, the Board may amend them as necessary
(Health and Safety Code Section 41504).
ITEM NO.: 78-14-3
Proposed Designation and Redesignation of Air Quality Control
Regions (AQCRs).
RECOMMENDATION
(a) Designate the Lake County and Mountain Counties Air Basins
as AQCRs with boundaries the same as the current respective
basin boundaries.
(b) Redesignate the following air basins as AQCRs so that their
boundaries will be the same as the current basin boundaries:
North Coast Sacramento Valley
San Francisco Bay Area San Joaquin Valley
San Diego Southeast Desert
Northeast Plateau
(c) No change is proposed for the North Central Coast and Great
Basin Valleys AQCRs as their boundaries are the same as the
respective air basin boundaries.
(d) The remaining designations needed so that all the California
air basins and respective AQCRs will have the same
boundaries should be considered at future hearings.
SUMMARY
Since 1968, when the ARB established 11 air basins in California,
the boundaries of all but two have been changed and three
additional air basins have been established. The ARB held public
hearings on each of the changes prior to approving them.
The federally designated AQCRs, however, have not been changed,
and their boundaries remain the same as the boundaries of the
regional 11 air basins. The division of the State in two
different ways for air quality control purposes is a cause of
some confusion.
With the passage of the Clean Air Act Amendments of 1977, AQCRs
can be redesignated by each state if it obtains the approval of
the Administrator of the EPA.
ITEM NO'S.: 78-12-2 AND 78-14-4
Consideration of Model Rules for the Control of Volatile Organic
Compound Emissions from Metal Furniture and Fixture Coating
Operations
RECOMMENDATION
Approve model rule and direct staff to transmit it to the air
pollution control districts in the South Coast, San Francisco Bay
Area, San Joaquin Valley, North Central Coast, South Central
Coast, Sacramento Valley and Southeast Desert Basins for
consideration as an amendment to their rules and regulations.
SUMMARY
The use of solvents for a variety of cleaning and surface coating
operations are the most significant source of organic gas
emissions (primarily hydrocarbons) from non-vehicular sources in
all of California's metropolitan areas. The emission of organic
compounds contributed to both oxidant and aerosol formation in
the ambient air. Approximately 2 percent of all solvent related
emissions in California's urban areas are associated with the
painting of metal furniture and fixtures.
The staff estimates that there are approximately 144 metal
furniture and fixture manufacturers in California who coat their
products. Some additional coating is performed at job shops for
those manufacturers who do not conduct their own coating
operations.
Metal furniture and fixtures include metal products intended for
both home and institutional use such as:
Household Furniture Drapery Hardware
Office Furniture File Cabinets
Partitions Lamps
Waste Baskets Shelving
Lockers Beds
These articles are coated to prevent corrosion and to enhance
appearance.
Total emissions from sources in this category amount to slightly
more than fourteen tons per day in the state.
Coatings used in this source category generally contain about 75%
organic solvent, almost all of which evaporates as the coating
dries.
The staff proposes that emissions from these coating operations
be reduced initially in two ways, both of which are commercially
available and are being used in some coating operations.
The first method is to require the use of Low-solvent coatings,
approximately 30% solvent. These are available as waterborne
coatings, high-solids coatings, and powder coatings. The staff
has observed successful production uses of both waterborne and
powder coatings. The staff has observed successful production
uses of both waterborne and powder coatings. These operations
are described later in this report. High-solids coatings are
reported to be used in production in other parts of the U.S., but
not in California.
The second method is to require the use of electrostatic
application equipment for spray painting operations. The
advantage of this equipment is that it has high transfer
efficiency; that is, most of the coating that is sprayed is
electrically attracted to the object being coated. As a result,
there is less overspray, less coating wasted, and less emissions.
Electrostatic spray equipment can be used with all types of low
solvent coatings.
An additional step to reduce emissions even further is also
proposed. This second step would require the use of extremely
low-solvent type coatings, that is powder coatings or equivalent
low emission coatings. Although these coatings are available,
the costs associated with their use may be higher than for
waterborne or higher-solids coatings. To alleviate any potential
adverse impacts, a long lead-time is proposed prior to
implementation of this step.
Staff investigation has revealed that there are several reasons
to regulate metal furniture and fixture emissions. First,
technology is available which can result in a substantial
emission reduction, exceeding 80% of the twelve tons per day of
organic emissions from the furniture and fixture coating
category. Second, 75 percent of these emissions are in the South
Coast Air Basin, the area which has the state's most serious air
quality problem. Third, the cost of achieving the emission
reduction may be very low, and in some cases will be less than
maintaining present coating operations. For waterborne and high-
solids coatings, the cost of emissions reduced ranges from a
credit of $.64 per pound to a cost of $.31 per pound. Fourth, a
substantial savings in energy consumption can be realized,
equivalent to approximately 50,000 barrels of fuel oil per year.
Table of Contents
Page
I. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
II. Conclusions and Recommendations . . . . . . . . . . . . . . . . . . .2
A. Conclusions. . . . . . . . . . . . . . . . . . . . . . . . . . .2
B. Recommendations. . . . . . . . . . . . . . . . . . . . . . . . .6
III. Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
IV. Emission Estimates. . . . . . . . . . . . . . . . . . . . . . . . . 12
A. Total Emissions. . . . . . . . . . . . . . . . . . . . . . . . 12
B. Potential Emission Reduction . . . . . . . . . . . . . . . . . 13
V. Applicable Systems of Emission Reduction. . . . . . . . . . . . . . 16
A. Low-Solvent Coatings
1. Powder. . . . . . . . . . . . . . . . . . . . . . . . . . 18
2. Waterborne Coatings (Spray, Dip and Flow) . . . . . . . . 21
3. Waterborne (Electrodeposition). . . . . . . . . . . . . . 26
4. Higher Solids . . . . . . . . . . . . . . . . . . . . . . 29
B. Increased Application Efficiency . . . . . . . . . . . . . . . 30
C. Incineration . . . . . . . . . . . . . . . . . . . . . . . . . 31
VI. Survey of Metal Furniture and Fixture Coating Operations. . . . . . 32
VII. Imapcts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
A. Energy Impacts . . . . . . . . . . . . . . . . . . . . . . . . 34
B. Economic Impact. . . . . . . . . . . . . . . . . . . . . . . . 38
1. Available Options . . . . . . . . . . . . . . . . . . . . 38
a. Powder Coatings. . . . . . . . . . . . . . . . . . . 38
b. Waterborne Coatings (Spray, Dip, and Flow) . . . . . 39
c. Waterborne (Electrodeposition) . . . . . . . . . . . 41
d. High-Solids. . . . . . . . . . . . . . . . . . . . . 41
e. Application Efficiency . . . . . . . . . . . . . . . 42
f. Incineration . . . . . . . . . . . . . . . . . . . . 43
2. Economic Effects. . . . . . . . . . . . . . . . . . . . . 44
a. Industry Background. . . . . . . . . . . . . . . . . 44
b. Industry Impacts . . . . . . . . . . . . . . . . . . 45
c. Consumer Impacts . . . . . . . . . . . . . . . . . . 46
d. Industry Impacts - Phase Two . . . . . . . . . . . . 51
C. Environmental Impacts. . . . . . . . . . . . . . . . . . . . . 55
1. Isocyanates . . . . . . . . . . . . . . . . . . . . . . . 55
2. Volatile Amines . . . . . . . . . . . . . . . . . . . . . 56
VIII. References . . . . . . . . . . . . . . . . . . . . . . . . . . 59
Appendix A - Processes and Emission Points. . . . . . . . . . . .A-1
Appendix B - Letter Concerning the Consultation meeting
for Metal Furniture. . . . . . . . . . . . . . . . .B-1
South Coast Air Quality Management District
Proposed Model Rule for Metal Furniture Coatings and
Metal Furniture Coating Survey . . . . . . . . . . . . . . .
ARB Surveys of Coatings Applied to Metal . . . . . . . . . .
Appendix C - Assumptions used in Cost Estimates . . . . . . . . .C-1
Appendix D - Case Studies of Low-Solvent Coating Users. . . . . .D-1