State of California
AIR RESOURCES BOARD

Staff Report for the Proposed 
Suggested Control Measure
for Architectural Coatings


Volume II:
Technical Support Document

VI.

DESCRIPTION AND TECHNICAL ASSESSMENT
OF THE COATING CATEGORIES

TABLE OF CONTENTS FOR CHAPTER VI - SECTION B and SECTION C

For SECTION A CLICK HERE

 B. COATING CATEGORIES FOR WHICH THE PROPOSED VOC LIMITS ARE GENERALLY CONSISTENT WITH DISTRICT RULES

 1.

Bond Breakers
   Table VI-44  Bond Breakers

 

 Table VI-45  Bond Breakers

 2.

Concrete Curing Compounds

 

 Table VI-46  Concrete Curing Compounds

 

 Table VI-47  Concrete Curing Compounds

 3.

 Dry Fog Coatings

 

 Table VI-48  Dry Fog Coatings

 

 Table VI-49  Dry Fog Coatings

 4.

 Fire-Retardant Coatings - Clear

 

 Flame Spreading Classification

 

 Table VI-50  Clear Fire-Retardant Coatings

 

 Table VI-51  Clear Fire-Retardant Coatings

 5.

 Fire-Retardant Coatings - Opaque

 

 Table VI-52  Opaque Fire-Retardant Coatings

 

 Table VI-53  Opaque Fire-Retardant Coatings

 6.

 Form Release Compounds

 

 Table VI-54  Form Release Compounds

 

 Table VI-55  Form Release Compounds

 7.

Graphic Arts Coatings
   Table VI-56  Graphic Arts Coatings
   Table VI-57  Graphic Arts Coatings

 8.

 Magnesite Cement Coatings

 

 Table VI-58  Magnesite Cement Coatings

 

 Table VI-59  Magnesite Cement Coatings

 9.

 Mastic Texture Coatings

 

 Table VI-60  Mastic Texture Coatings

 

 Table VI-61  Mastic Texture Coatings

 10.

Metallic Pigmented Coatings

 

 Table VI-62  Metallic Pigmented Coatings

 

 Table VI-63  Metallic Pigmented Coatings

 11.

 Pre-Treatment Wash Primers

 

 Table VI-64  Pre-Treatment Wash Primers

 

 Table VI-65  Pre-Treatment Wash Primers

 12.

 Sanding Sealers (Non-Lacquer)

 

 Table VI-66  Sanding Sealers (Non-Lacquer)

 

 Table VI-67  Sanding Sealers (Non-Lacquer)

 13.

 Shellac - Clear

 

 Table VI-68  Shellac - Clear

 

 Table VI-69  Shellac - Clear

 14.

 Shellac - Opaque

 

 Table VI-70  Shellac - Opaque

 

 Table VI-71  Shellac - Opaque

 15.

 Varnishes

 

 Table VI-72a  Clear Varnishes

 

 Table VI-72b  Semitransparent Varnishes

 

 Table VI-73a  Clear Varnishes

 

 Table VI-73b  Semitransparent Varnishes

 16.

 Wood Preservatives

 

 Table VI-74a  Below Ground Wood Preservatives

 

 Table VI-74b  Clear Wood Preservatives

 

 Table VI-74c  Semitransparent Wood Preservatives

 

 Table VI-74d  Opaque Wood Preservatives

 

 Table VI-75a  Below Ground Wood Preservatives

 

 Table VI-75b  Clear Wood Preservatives

 

 Table VI-75c  Semitransparent Wood Preservatives

 

 Table VI-75d  Opaque Wood Preservatives

 C. CATEGORIES NOT PROPOSED FOR INCLUSION IN THE SCM

 1.

 Anti-Graffiti Coatings

 

 Table VI-76  Anti-Graffiti Coatings

 2.

 Calcimine Recoater Coatings

3.

Chalkboard Resurfacer Coatings

 

 Table VI-77  Chalkboard Refinisher Coatings

 4.

 Concrete Curing and Sealing Compounds

 5.

 Concrete Protective Coatings

 6.

 Concrete Surface Retarder Coatings

 7.

 Conversion Varnish Coatings

 8.

 Extreme High Durability Coatings

 9.

 Heat Reactive Coatings

 

 Table VI-78  Heat Reactive Coatings

 10,

 Impacted Immersion Coatings

 11.

 Nonferrous Ornamental Lacquer Coatings

 12.

 Nuclear Coatings

 

 Table VI-79  Nuclear Coatings

 13.

 Repair and Maintenance Thermoplastic Coatings

 

 Table VI-80 Repair and Maintenance Thermoplastic Coatings 

 14.

 Stain Controller Coatings

 15

 Thermoplastic Rubber Coatings and Mastics

16. 

 Zone Marking Coatings

B. COATING CATEGORIES FOR WHICH THE PROPOSED VOC LIMITS ARE GENERALLY CONSISTENT WITH DISTRICT RULES

We are proposing VOC limits for the following 16 coating categories that are generally consistent with the VOC limits in California's district architectural coatings rules, including the South Coast AQMD's Rule 1113. The discussions for each of these coating categories includes:

  1. product category description;
  2. discussion of the proposed volatile organic compound (VOC) limit, and our rationale for the proposed limit; and
  3. if applicable, a discussion of the issues associated with the proposed VOC limit, as raised by industry. The product categories are listed in alphabetical order.

1. Bond Breakers

Product Category Description:

Bond breakers are coatings that are applied between layers of concrete to prevent bonding of the first layer to the second layer. Coatings in this category are similar to form release compounds, except that form release compounds prevent bonding of the concrete to a
non-concrete form (TRG/ARB, 1989). The first coat of a bond breaker also helps cure the concrete (U.S. EPA, 1998).

Table VI-44 below summarizes our estimate of the sales and VOC emissions from the bond breakers category.

Table VI-44 Bond Breakers*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

PD

PD

750

~0.00

Water-Based

PD

PD

345

0.02

Total

PD

PD

345

0.02

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected Data.


Proposed VOC Limit and Basis for Recommendation:

We are proposing a 350 g/l VOC limit for bond breakers effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the high complying marketshare; the limit in current district rules; and the fact that most district architectural coating rules have had the same limit for several years. We also note that no adverse comments were received about the proposed limit.

Districts that regulate bond breakers (all districts except the Bay Area, Butte, Colusa, Feather River, and Monterey districts where the category is exempt) have a VOC limit of 350 g/l. Based on the recommendation of the 1989 SCM, the VOC limit for bond breakers of 350 g/l went into effect in district rules in September 1990 (TRG/ARB, 1989).

The U.S. EPA's National Architectural Coatings Rule limit of 600 g/l. However, this limit is found in the upper range of VOC content limits in existing state rules (none of the rules has a limit higher than 600 g/l) (U.S. EPA, 1998). We recommend that the VOC limit for bond breakers remain at 350 g/l at this time, which is consistent with current district rules.

Table VI-45 Bond Breakers*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

350

PD

PD

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
PD =Protected Data.

    Issues:

    1. Issue: No comments were received on bond breakers, and we know of no unresolved issues with this category.


2. Concrete Curing Compounds

Product Category Description:

Concrete curing compounds are coatings that are applied to fresh concrete to retard moisture evaporation. These coatings are used in road construction to provide moisture retention during curing, to help with design strength and other properties. Concrete curing compounds are designed to meet a number of ASTM specifications, including ASTM C-309, Type 1, 1D, and 2; Class A (U.S. EPA, 1998).

The U.S. EPA determined that concrete curing compounds, as well as other concrete curing products, may be underrepresented in the national Architectural Coatings Survey. One commenter explained that this is because concrete curing products are made by the construction industry, not coating manufacturers (U.S. EPA, 1998). They may also be underrepresented in the ARB's 1998 Architectural Coatings Survey for the same reason.

Table VI-46 below summarizes our estimate of the sales and VOC emissions from the concrete curing compounds category.

Table VI-46 Concrete Curing Compounds*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

37

399,298

677

0.05

Water-Based

0

180

0.19

Total

47

411,118

195

0.24

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.

Proposed VOC Limit and Basis for Recommendation:

We are proposing a 350 g/l VOC limit for concrete curing compounds effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the high complying marketshare; the limit in current district rules and the National Rule; and the fact that most district architectural coating rules have had the same limit for several years. We also note that no adverse comments were received about the proposed limit.

All district rules except one have a VOC limit of 350 g/l for concrete curing compounds (Butte County has a VOC limit of 800 g/l). In addition to the California districts, Arizona, Massachusetts, New Jersey, and New York have a 350 g/l limit (U.S. EPA, 1998). The U.S. EPA's National Architectural Coatings Rule also has a VOC limit of 350 g/l. All but one commenter argued that the limit is achievable (U.S. EPA, 1998).

We recommend that the VOC limit remain at 350 g/l at this time, the same as in current district rules, state rules, and the National Rule. The survey shows that there is about 95 percent compliance at 350 g/l, and this category is already heavily dominated by water-based formulations.

Table VI-47 Concrete Curing Compounds*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

350

36

95.10

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).


Issues:

1. Issue: No comments were received on concrete curing compounds, and we are unaware of any unresolved issues.

3. Dry Fog Coatings

Product Category Description:

Dry fog coatings, also called dry fall coatings or mill white coatings, are formulated so that when sprayed onto a substrate, the overspray droplets dry before they contact the floor or other surfaces. The coatings are designed to dry after falling 8 to 10 feet, depending on the formulation and the weather conditions. The use of dry fog coatings minimizes the amount of masking and covering of surfaces that are not to be coated, and the dried coating can simply be swept up for easy cleanup. The definition clarifies that these coatings are to be applied by spraying, not by brush or roller, since the quick-drying characteristics of dry fog coatings would not be necessary with non-spray application techniques (TRG/ARB, 1989).

Table VI-48 below summarizes our estimate of the sales and VOC emissions from the dry fog coatings category. As shown, dry fog coatings are available as both water-based and solvent-based products, with the lower VOC water-based products accounting for the majority of sales.

Table VI-48 Dry Fog Coatings*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

24

76,661

367

0.17

Water-Based

27

126,241

182

0.09

Total

51

202,902

252

0.26

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).

** Grams VOC per liter of coating, less water and exempt compounds.

Proposed VOC Limit and Basis for Recommendation:

We are proposing a 400 g/l VOC limit for dry fog coatings effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the high complying marketshare; the limit in current district rules and the National Rule; the fact that most district architectural coating rules have had the same limit for several years; and a review of product literature on coatings included in this category. We also note that no adverse comments were received about the proposed limit.

The VOC limit of 400 g/l for dry fog coatings is found in the all district rules (except Bay Area, Butte, Colusa, Feather River, and Monterey, where the category is exempt). The U.S. EPA's National Architectural Coatings Rule also specifies a VOC limit of 400 g/l. National survey data showed that 84 percent of dry fog coatings sales were at or below 400 g/l. Arizona, Kentucky, New York, New Jersey, Massachusetts, Rhode Island, and the California districts have the same limit. The U.S. EPA concluded that the evidence shows that dry fog coatings at or below 400 g/l perform acceptably well (U.S. EPA, 1998).

We recommend that the VOC limit for dry fog coatings remain at 400 g/l at this time, the same as in current district rules, state rules, and the National Rule. There is almost 97 percent compliance at 400 g/l.

Table VI-49 Dry Fog Coatings*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

400

46

96.60

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).

Issues:

1. Issue: No comments were received on dry fog coatings and, to our knowledge, no unresolved issues remain.


4. Fire-Retardant Coatings - Clear

Product Category Description:

Fire-retardant coatings are used to bring building and construction materials into compliance with federal, State and local building code requirements. The coatings must be fire tested and rated for their ability to retard ignition and flame spread. Both the coatings and the testing agency must be approved by building code officials. Clear fire-retardant coatings include, but are not limited to, clear varnishes and sealers. Fire-retardant coatings used on wood shingles are pressure-applied into the wood in a factory (Ho, 1999), and therefore, are not subject to the architectural coating rule.

Most fire-retardant coatings work by suppressing flame through intumescence, which means they become plastic and puff up on exposure to flame or excessive heat, solidifying into a foam about fifty times as thick as the coating film. This foam insulates the substrate from the flame (LeSota, 1995).

Fire-retardant coatings reduce flame spread on the surface of a material. Fire-retardant coatings are tested in a fire test chamber using ASTM Method E 84, "Standard Test Method for Surface Burning Characteristics of Building Materials." ASTM Method E 84 is used for testing of interior building materials, not those used on the exterior of buildings (Ho, 1999). This method requires that a 25 foot panel of the substrate coated with the fire-retardant coating be exposed to flame for ten minutes. The retarding of flame spread and smoke development are measured, and the coating receives a flame spread rating equating to Class A, B, or C building materials (Bratcher and Alvarez, 1996).

California building codes specify three classes of building materials (which correspond to the Class A, B, and C materials mentioned above), each with a range of possible flame spread indices. The following table summarizes this information (California Building Code, 1998).

Flame-Spread Classification

Building Material Qualified by:

Class

Flame Spread Index

I

0-25

II

26-75

III

76-200

The California Building Code is based on the Uniform Building Code of the International Conference of Building Code Officials (ICBO), while building codes in the eastern half of the U.S. are usually based on the fire hazard classifications of the National Fire Protection Association (NFPA) (Woods, 1999).

The definition used in the SCM is essentially the National Rule definition, except that we have removed the language pertaining to fire-resistant. During our research on the fire-retardant category, we found that a separate category for fire-resistant coatings was needed because these two categories are quite different in the mode of action, the materials protected, and the test methods used.

The fire-retardant coatings definition in the SCM also differs significantly from the definition used in district rules and the 1989 SCM. These district definitions describe fire-retardant coatings as those that have a flame spread index of less than 25 when tested in accordance with ASTM Designation E 84-87, using Douglas fir as the substrate. This definition is limiting in several ways.

The definition used in district rules specifies a flame spread index of less than 25, but as seen in the table above, this limits the classification of the building materials to Class I (Class A in the NFPA classification). The California Building Code allows Class II and III materials (Class B and C in the NFPA classification) to be used in some applications, for example where the materials are protected on both sides by sprinkler systems (California Building Code, 1998).

The districts' rule definition restricts the flame spread testing to Douglas fir. This is limiting because it precludes testing and certification of fire-retardant coatings on other building materials such as acoustical tiles, drywall, plywood, etc. Manufacturers of fire-retardant coatings are required to test and register their products with the State Fire Marshal's Office, and testing must be on the variety of substrates that the manufacturer claims the coating can be used on, not just Douglas fir (Woods, 1999).

The coatings are tested by a variety of testing laboratories. Each building inspection agency has its own list of approved laboratories for each type of building material
(Woods, 1999). In California, most building code officials at the local level use the approved testing laboratories list of the State Fire Marshal (Ho, 1999). These laboratories are further subdivided into those who are qualified and equipped to conduct certain tests and examinations (State Fire Marshal, 1998). The proposed definition does not restrict the choice of testing agencies to a single laboratory such as Underwriters Laboratory. The term ?approved laboratory" is used in the industry to imply a lab acceptable to a code official (Hopper, 1999). The term "testing agency" was chosen for the proposed definition based on the terminology used in the California Building Code.

Manufacturers submit their coatings for testing on certain specified building materials to the testing laboratory. The laboratory determines the flame spread and smoke density ratings. The test results are then submitted to the State Fire Marshal for review. If approved, the State Fire Marshal lists the product in its listing service or registry. The manufacturer must pay a fee to register the product in the listing service, and the listing has an expiration date. Both the fire-retardant chemical and the fire-retardant coating must be registered by the State Fire Marshal (Ho, 1999). Architects, contractors, and others who use these coatings have access to the listing of approved coatings.

The reference to federal building codes in the proposed definition is included because federal facilities such as office buildings, courthouses, prisons, hospitals, and military bases are subject to the federal requirements in the NFPA codes, whereas the California requirements are based on the ICBO codes (Woods, 1999).

The test method is important in defining fire-retardant products. The test method for flame spread index is referenced in the Test Methods section of the rule for information purposes. ASTM Designation E-84 is referenced, but the California Building Code references UBC Standard 8-1, which is virtually identical to the ASTM method. Individual testing laboratories also have their own flame spread tests; for example, Underwriters Laboratories uses UL 723, which is virtually the same as ASTM Method E-84 (Hopper, 1999).

Table VI-50 below summarizes our estimate of sales and VOC emissions from the clear fire-retardant coatings category.

Table VI-50 Clear Fire-Retardant Coatings*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

0

0

N/A

N/A

Water-Based

PD

PD

22

~0.00

Total

PD

PD

22

~0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).

** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected data.


Proposed VOC Limit and Basis for Recommendation:

We are proposing a 650 g/l VOC limit for clear fire-retardant coatings effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the high complying marketshare; the limit in current district rules; the fact that most district architectural coating rules have had the same limit for several years; a review of product literature on coatings included in this category; and discussions with manufacturers. We also note that no adverse comments were received about the proposed limit.

The VOC limit of 650 g/l for clear fire-retardant coatings is found in all district rules (except Bay Area, Butte County, Colusa County, and Feather River, which exempt this category, and Monterey and Placer County, which do not have a category for fire-retardant coatings).

The National Rule VOC limit for clear fire-retardant/resistive coatings is 850 g/l. However, the U.S. EPA does not provide rationale for this VOC limit (U.S. EPA, 1998). We recommend that the VOC limit for clear fire-retardant coatings remain at 650 g/l at this time, the same as in the 1989 SCM and all current district rules. There is 100 percent compliance at this limit.

Table VI-51 Clear Fire-Retardant Coatings*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

650

PD

100

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
PD = Protected Data.

    Issues:

    1. Issue: No unresolved issues remain with this category.


5. Fire-Retardant Coatings - Opaque

Product Category Description:

Fire-retardant coatings are described in the previous section on clear fire-retardant coatings. Opaque fire-retardant materials include, but are not limited to, coatings with flat or non-flat finishes and primers.

Table VI-52 below summarizes our estimate of sales and VOC emissions from the opaque fire- retardant coatings category. As shown, both solvent-based and water-based products are available, with the lower VOC water-based products accounting for the majority of sales.

Table VI-52 Opaque Fire-Retardant Coatings*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

20

10,297

267

0.02

Water-Based

37

45,912

46

0.01

Total

57

56,209

86

0.03

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.


Proposed VOC Limit and Basis for Recommendation:

We are proposing a 350 g/l VOC limit for opaque fire-retardant coatings effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the high complying marketshare; the limit in current district rules; the fact that most district architectural coating rules have had the same limit for several years; a review of product literature on coatings included in this category; and discussions with manufacturers. We also note that no adverse comments were received about the proposed limit.

The VOC limit of 350 g/l for opaque fire-retardant coatings is found in all district rules (except Bay Area, Butte County, Colusa County, and Feather River, which exempt this category, and Monterey and Placer County, which do not have a category for fire-retardant coatings).

The National Rule VOC limit for opaque fire-retardant/resistive coatings is 450 g/l. However, the U.S. EPA does not provide a rationale for this VOC limit (U.S. EPA, 1998). We recommend that the VOC limit for opaque fire-retardant coatings remain at 350 g/l at this time, the same as in the 1989 SCM and all district rules. There is virtually 100 percent compliance at this limit.

Table VI-53 Opaque Fire-Retardant Coatings*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

350

53

99.80

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).


Issues:

1. Issue: No unresolved issues remain on this category.

6. Form Release Compounds

Product Category Description:

Form release compounds are products designed for use on concrete forms to prevent freshly poured concrete from sticking to the form. The forms may be wood, metal, or other material other than concrete. They are used extensively in the building industry in concrete pouring operations (TRG/ARB, 1989).

A commenter on the National Rule speculated that concrete form release compounds may be underrepresented in the national Architectural Coatings Survey because they are made by the construction industry, not coating manufacturers (U.S. EPA, 1998). They may also be underrepresented in the ARB's 1998 Architectural Coatings Survey for the same reason.

Table VI-54 below summarizes our estimate of sales and VOC emissions from the form release compounds category. Sales were only 10,000 gallons in the 1993 survey, compared to 80,000 gallons in the 1998 survey.

Table VI-54 Form Release Compounds*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

9

11,025

247

0.02

Water-Based

4

72,218

2

~0.00

Total

13

83,243

34

0.02

Table VI-

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.


Proposed VOC Limit and Basis for Recommendation:

We are proposing a 250 g/l VOC limit for form release compounds effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the high complying marketshare; the limit in current district rules; and the fact that most district architectural coating rules have had the same limit for several years. We also note that no adverse comments were received about the proposed limit.

The form release compounds category appears in a few district rules: El Dorado, Imperial, Kern, Placer, Sacramento, San Diego, San Joaquin, Santa Barbara, and Ventura, all with a 250 g/l VOC limit. The category falls under the default limit of 250 g/l in the remaining districts.

In the 1989 SCM, the form release compounds category was created to separate these coatings (at a VOC limit of 250 g/l) from bond breakers (at 750 g/l effective September 1989, lowering to 350 g/l in September 1990). At that time, it was estimated that form release compounds were used in larger quantities than bond breakers (TRG/ARB, 1989).

The VOC limit for form release compounds in the U.S. EPA's National Architectural Coatings Rule is 450 g/l. The National Rule limit is found in the upper range of VOC content limits in existing state rules (U.S. EPA, 1998).

We recommend that the VOC limit for form-release compounds remain at 250 g/l at this time, the same as in current district rules.

Table VI-55 Form Release Compounds*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

250

PD

PD

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
PD = Protected Data.

    Issues:

    1. Issue: No comments were received on form release compounds, and we are unaware of any remaining issues.


7. Graphic Arts Coatings

Product Category Description:

Graphic arts coatings or sign coatings are products designed for hand-application by artists using brushes or rollers. They are used on indoor or outdoor signs or murals and include lettering enamels, poster colors, copy blockers, and bulletin enamels. A coating used on the structural components of billboards is not included in the definition. Most billboard signs are now pre-printed and are pasted to the billboard on-site.

The 1989 SCM clarified which graphic arts coatings were subject to architectural coating rules. This was necessary because, depending on the district in which the coating is applied, what substrate is being used, and where they are applied, graphic arts coatings could be subject to metal parts and products, wood products, plastic parts and products, or architectural coatings rules. The definition was designed to address the needs of sign painters without allowing high VOC coatings to be used for jobs not legitimately requiring sign coatings. To be an architectural coating, the sign would have to be coated after installation (TRG/ARB, 1989). Similarly, U.S. EPA clarified that if the coating is applied to an erected billboard, the coating used on the sign portion of the billboard would be classified as graphic arts, while the coating used on the steel supporting beams of the billboard would be an industrial maintenance coating
(U.S. EPA, 1998).

Table VI-56 below summarizes our estimate of sales and VOC emissions from the graphic arts coating category.

Table VI-56 Graphic Arts Coatings*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based ***

PD

PD

628

0.03

Water-Based

PD

PD

10

~0.00

Total

108

40,366

122

 

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.
*** Includes 100 percent solid coatings.
PD = Protected Data.


Proposed VOC Limit and Basis for Recommendation:

We are proposing a 500 g/l VOC limit for graphic arts coatings effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the high complying marketshare; the limit in current district rules; and the fact that most district architectural coating rules have had the same limit for several years. We also note that no adverse comments were received about the proposed limit.

All districts that have a graphic arts category in their architectural coating rules have a 500 g/l VOC limit. This category is exempt in the Bay Area, Butte County, Colusa County, Feather River, and Monterey districts. The VOC limit in the U.S. EPA's National Architectural Coatings Rule is 500 g/l. National survey data showed that 96 percent of the coatings were
500 g/l or below. Massachusetts, New York, New Jersey, and Rhode Island are at 450 g/l, while Kentucky and the California districts are at 500 g/l (U.S. EPA, 1998)

In earlier versions of the SCM, we proposed lowering the VOC limit for graphic arts coatings to 150 g/l, based on survey data. There is a large waterborne or 100 percent solids component of the survey data that may be non-architectural or may represent sign coatings other than those included in the definition. Based on comments and minimal emission reductions, we changed the proposed VOC limit to match that of district rules and the National Rule.

We recommend that the VOC limit for graphic arts coatings remain at 500 g/l at this time, the same as in current district rules and the National Rule. There is 81 percent compliance at the proposed 500 g/l limit.

Table VI-57 Graphic Arts Coatings*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

500

18

81.20

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).

    Issues:

    1. Issue: There are no known unresolved issues with this category.


8. Magnesite Cement Coatings

Product Category Description:

Magnesite cement coatings are designed for use on magnesite cement decking to protect the magnesite cement substrate from erosion by water.

Magnesite is a naturally occurring mineral composed of magnesium carbonate. For decades, exterior and interior floors have been made from magnesite because it is lightweight, stronger than concrete, water-resistant, non-combustible, and long-lasting (Magnesite, undated). Since the 1970s, newer materials have replaced magnesite cement in new construction. However, there is still a demand for magnesite cement for repair and retrofit of old magnesite cement (Armstrong, 1999).

Magnesite floors are laid using a formulation containing magnesium oxychloride cement and inert fillers. Clear and pigmented sealers are used to protect these magnesite floors, decks, and stairs from the weather, and to cover older surfaces that are discolored, patched, or worn (Magnesite Flooring System, undated). Magnesium oxychloride is highly alkaline and prevents adhesion of most coatings applied to it. The only successful magnesite cement coatings are acrylic lacquers. Coatings other than acrylic lacquers have failed within a week due to delamination (TRG/ARB, 1989).

Table VI-58 below summarizes our estimate of sales and VOC emissions from the magnesite cement coatings category.

Table VI-58 Magnesite Cement Coatings*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

PD

PD

590

0.14

Water-Based

PD

PD

0

~0.00

Total

5

37,501

589

0.14

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected Data.


Proposed VOC Limit and Basis for Recommendation:

We are proposing a 450 g/l VOC limit for magnesite cement coatings effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the limit in current district rules; and the fact that most district architectural coating rules have had the same limit for several years: discussions with a major manufacturer who has recently developed a complying product; and a technology assessment performed by the South Coast AQMD in 1996. We also note that no adverse comments were received about the proposed limit.

The VOC limit for magnesite cement coatings in most district rules is 450 g/l. The Mojave Desert and San Diego districts have a VOC limit of 600 g/l, and several districts do not list this category in their table of standards. The VOC limit in the U.S. EPA's National Architectural Coatings Rule is 600 g/l.

The South Coast AQMD examined magnesite coatings in its 1996 amendments to Rule 1113. At that time, an interim VOC limit of 600 g/l was established, and as of January 1, 1999, a VOC limit of 450 g/l is now in effect (South Coast AQMD, 1996). In November 1998, a major manufacturer indicated that after many years of reformulation, they could meet the 450 g/l limit. There are some limitations in using the coating in hot weather, however, which are handled by applying the coating at night (Armstrong, 1999).

We recommend that the VOC limit for magnesite cement coatings remain at 450 g/l at this time, the same as in current district rules.

Table VI-59 Magnesite Cement Coatings*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

450

PD

PD

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
PD = Protected Data.

    Issues:

    1. Issue: No comments were received regarding magnesite cement coatings, and to our knowledge there are no unresolved issues.


9. Mastic Texture Coatings

Product Category Description:

Mastic texture coatings are products used to cover and conceal holes, cracks, and surface irregularities. These coatings are applied in a single coat, with the dry film at least 10 mils thick.
These coatings are highly viscous water-based or solvent-borne coatings used by homeowners or contractors for interior and exterior masonry (U.S. EPA, 1998). The definition in the 1989 SCM includes a film thickness specification to identify that these coatings are high-build coatings (TRG/ARB, 1989).

Table VI-60 below summarizes our estimate of sales and VOC emissions from the mastic texture coatings category.

Table VI-60 Mastic Texture Coatings*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

PD

PD

223

0.08

Water-Based

PD

PD

79

0.07

Total

56

299,727

118

0.15

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected Data.


Proposed VOC Limit and Basis for Recommendation:

We are proposing a 300 g/l VOC limit for mastic texture coatings effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the high complying marketshare; the limit in current district rules; the fact that most district architectural coating rules have had the same limit for several years; a review of product literature on coatings included in this category; and comments justifying this limit based on performance requirements. We also note that no adverse comments were received about the proposed limit.

All district rules that include a category for mastic texture coatings have a VOC limit of 300 g/l. This category is exempt in the Bay Area, Butte County, Colusa County, Feather River, and Monterey districts. The VOC limit in the U.S. EPA's National Architectural Coatings Rule is also 300 g/l.

Table VI-61 Mastic Texture Coatings*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

300

56

100

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).

    Issues:

    1. Issue: There are no known unresolved issues with this category.


10. Metallic Pigmented Coatings

Product Category Description:

Metallic pigmented coatings are products that contain at least 48 grams of elemental metal pigment per liter of coating, as applied. This metal content is equivalent to 0.4 pounds of metal per gallon of coating. South Coast AQMD Method 318-95, "Determination of Weight Percent Elemental Metal in Coatings by X-Ray Diffraction," is used to determine the metallic content of the coating.

Metallic pigmented coatings produce a dry film that has a metallic appearance. This effect is produced by incorporating fine flakes of various metals (e.g., copper, bronze, aluminum) to the coating. The aluminum can be leafing or nonleafing. Leafing means that the metal is in the form of thin flat flakes that align themselves so that they appear to be floating on or near the surface of the coating (LeSota, 1995).

In the U.S. EPA rulemaking, issues were raised about the inclusion of zinc-rich coatings in the metallic pigmented coating category. Zinc-rich coatings are applied to structural steel beams to prevent corrosion during the construction of large buildings. Zinc-rich coatings are lower in VOC than metallic pigmented coatings because the zinc content of the dry film can be 50 percent or higher. U.S. EPA concluded that creating a separate category for zinc-rich coatings was not warranted, and these coatings fit under the metallic pigmented category (U.S. EPA, 1998).

Inorganic zinc-rich primers are considered metallic pigmented coatings because the elemental zinc particles in the film are held to the surface of the substrate through a non-organic silicate binder (LeSota, 1995). Organic zinc-rich primers are also considered metallic pigmented coatings because elemental zinc powder is used, along with an organic binder such as an epoxy or urethane that holds the pigment to the film (Sherwin-Williams, undated). The pigment zinc oxide (ZnO) does not contain elemental zinc (LeSota, 1995) and thus does not qualify as a source of zinc for metallic pigmented coatings. Aluminum roof coatings are considered metallic pigmented coatings, as are asphalt aluminum roof coatings as long as they have 48 grams of elemental metal pigment per liter of coating, as applied. Bituminous coatings are excluded from the metallic pigmented coating definition in the National Rule, but they have the same VOC limit of 500 g/l.

Table VI-62 below summarizes our estimate of sales and VOC emissions from the metallic pigmented coatings category.

Table VI-62 Metallic Pigmented Coatings*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

119

272,965

456

0.77

Water-Based

6

119,862

137

0.04

Total

125

392,827

358

0.81

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.


Proposed VOC Limit and Basis for Recommendation:

We are proposing a 500 g/l VOC limit for metallic pigmented coatings effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the high complying marketshare; the limit in current district rules and the National Rule; the fact that most district architectural coating rules have had the same limit for several years; and a review of product literature on coatings included in this category. We also note that no adverse comments were received about the proposed limit.

Every district rule with a metallic pigmented category has a VOC limit of 500 g/l. This category is exempt in the Bay Area, Butte County, Colusa County, Feather River, and Monterey districts. The National Rule VOC limit is also 500 g/l, and includes coatings formulated with zinc pigment. Kentucky, New York, New Jersey, Massachusetts, Rhode Island, and some of the California districts have 500 g/l limits. The national survey showed that 90 percent of these coatings had VOC contents from 300-500 g/l (U.S. EPA, 1998).

In earlier versions of the SCM, we had proposed excluding zinc from the definition of metallic pigmented coatings because zinc-rich primers, which would fall under this category, have a VOC content limit lower than 500 g/l. We are now proposing that the definition include coatings containing elemental zinc, which is consistent with the National Rule and South Coast AQMD Rule 1113. Further, we have proposed that the most restrictive VOC limit section of the SCM does not apply to metallic pigmented coatings, as has been the case for years in most district rules. Thus, a coating containing the metallic content required by the definition need meet only the 500 g/l VOC limit of metallic pigmented coatings, even though it overlaps with another category.

We recommend that the VOC limit for metallic pigmented coatings remain at 500 g/l at this time, the same as in current district rules and the National Rule. The survey shows 98 percent compliance at this limit, even with solvent-based coatings.

Table VI-63 Metallic Pigmented Coatings*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

500

98

98.30

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).

    Issues:

    1. Issue: The proposed definition restricts this category to metallic coatings not including zinc metallic coatings. With the introduction of the lower limits, this limitation is unreasonable, and the zinc exclusion should be removed.

      Response: We agree, and have removed the exclusion of zinc from the definition.


    2. Issue: We manufacture a zinc-rich coating containing zinc powder that contains 95 percent zinc in the dried film and is applied in the field. Zinc is the densest and most difficult metal to

    formulate into coatings. We urge you to change your definition to include zinc.

      Response: We agree with the change in the definition. The coating described would be considered a metallic pigmented coating.


    3. Issue: The higher limit for the asphaltic aluminum coating is appropriate because they are the best product for increasing reflectance on black asphaltic roofing surfaces.

      Response: The National Rule definition for metallic pigmented excludes bituminous coatings, but we have not proposed similar language, in keeping with the long-standing definition used in California. We agree that this asphaltic aluminum roof coating would be considered a metallic pigmented coating.


    4. Issue: The definition for metallic pigmented coatings exempts zinc as a metal, which would essentially eliminate organic and inorganic zinc-rich primers. We request that you change this definition to agree with South Coast AQMD Rule 1113 and the National AIM Rule definitions.

      Response: We agree with the change in the definition to include elemental zinc metal. We also agree that organic and inorganic zinc-rich primers are included in the definition of metallic pigmented coating.


    5. Issue: The proposed definition for metallic pigmented coatings excludes zinc. This is surprising since virtually all other regulatory bodies have included zinc. Zinc-rich coatings at 250 g/l have not been proven for field application. Water-based inorganic zinc (which has close to zero VOC) is considered by a majority of applicators and specifiers to be unsuited for field application.

      Response: We modified the definition to include zinc-rich coatings as suggested.


    6. Issue: High-temperature metallic coatings shouldn't be penalized because they can be used at high temperature. The use of metallic pigments requires a higher limit because of the metal. The metallic pigmented definition excludes zinc, while the South Coast AQMD and National Rule include zinc.

      Response: We have made the requested change to the definition of metallic pigmented coatings. The exception under the Most Restrictive VOC Limit section in the SCM specifies that high-temperature metallic pigmented coatings are subject to the VOC limit for metallic pigmented coatings at 500 g/l.


    7. Issue: There are a lot of metallic coatings that contain powdered zinc, copper, bronzes based on zinc, and combinations of copper/aluminum/zinc pigments. Pigment is defined in the National Rule to include corrosion inhibition, but pigment is not defined in the SCM. Zinc-rich primers have VOC contents of roughly 340-420 g/l. Zinc-rich primers should be in their own category or in the metallic pigmented category.

      Response: The definition of pigment in the National Rule refers to finely ground, insoluble powder that is used for color, corrosion inhibition, and other specific purposes. Thus, zinc in zinc-rich primers would fall under the definition of pigment because they are used for corrosion inhibition, and the coating would be considered a metallic pigmented coating. The decorative metals such as copper and bronze described by the commenter would also be pigments, thus including these coatings in the metallic pigmented coating category. Although some zinc-rich primers have a VOC content considerably less than the 500 g/l limit of metallic pigmented coatings, we are still including them in the metallic pigmented category.


    8. Issue: Inorganic zinc and zinc containing coatings have always been treated as industrial maintenance (IM) coatings in the South Coast AQMD, and that's the way they've been reported as well. Metallic coatings contained pure elemental metal, but zinc oxide was included in IM because they didn't qualify as pure metal. Metallic pigmented coatings were originally a decorative coating, so decorative may need to be in the definition.

      Response: The commenter is referring to an earlier version of the SCM where zinc coatings were excluded from the definition of metallic pigmented. We have modified the metallic pigmented coating definition to include zinc, consistent with district rules. In the exceptions to the most restrictive VOC limit of current district rules, where a metallic coating is used as primer/sealer/undercoater, roof, high-temperature, or industrial maintenance coatings, the higher limit (i.e., metallic pigmented) applies. We do not believe any clarification is required for zinc-rich coatings; the amount of elemental metal should be the deciding factor in determining whether a coating is a metallic pigmented coating, not the type of metal. Zinc oxide is not an elemental metal, and its presence does not make a coating a metallic pigmented coating. We disagree that metallic pigmented coatings are purely decorative. To comply with the definition of metallic pigmented coatings, the amount and the form of the metal are the determining factors, not the function of the metal in the coating.


11. Pre-Treatment Wash Primers

Product Category Description:

Pre-treatment wash primers are wash coats used prior to the application of primer or topcoat. They must contain at least 0.5 percent acid, by weight, and are applied to bare metal surfaces to provide corrosion resistance and to promote adhesion of subsequent topcoats. Pre-treatment wash primers are often used on aluminum and galvanized metal surfaces (TRG/ARB, 1989).

These coatings provide excellent adhesion when applied to clean alloys, ferrous, or nonferrous surfaces, partially due to a reaction with the substrate. They also impart a corrosion resistant film that is a good surface for the application of coatings. These primers form very thin films, and are similar to etching solutions. The etched surface may be primed for maximum protection (LeSota, 1995).

Table VI-64 below summarizes our estimate of sales and VOC emissions from the pre-treatment wash primers category.

Table VI-64 Pre-Treatment Wash Primers*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

PD

PD

716

0.00

Water-Based

PD

PD

248

0.04

Total

30

71,940

252

0.04

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected Data.


Proposed VOC Limit and Basis for Recommendation:

We are proposing a 420 g/l VOC limit for pre-treatment wash primers effective
January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the limit in current district rules; and the fact that most district architectural coating rules have had the same limit for several years. We also note that no adverse comments were received about the proposed limit.

The most common district VOC limit for pre-treatment wash primers is 420 g/l. This limit is in the following districts: Imperial, Kern, Sacramento, San Joaquin, Santa Barbara, and Ventura districts. El Dorado and Placer districts have a VOC limit of 675 g/l, while Antelope Valley, Mojave, San Diego, and South Coast have a limit of 780 g/l. The remaining districts do not include a category for pre-treatment wash primers.

The 1989 SCM set the VOC limit at 780 g/l, effective September 1989, and a future-effective limit of 420 g/l VOC limit in September 1994 (TRG/ARB, 1989).

A variety of district coating rules (e.g., Bay Area Rule 8-43, Surface Coating of Marine Vessels; Sacramento Rule 451, Surface Coatings of Miscellaneous Metal Parts and Products;
San Joaquin Rule 4603, Surface Coating of Metal Parts and Products; and Ventura Rule 74.12, Surface Coating of Metal Parts and Products) have categories for pre-treatment wash primers, with a VOC limit of 420 or less.

The VOC limit in the U.S. EPA's National Architectural Coatings Rule is 780 g/l. However, we recommend that the VOC limit for pre-treatment wash primers remain at 420 g/l at this time, the same as most district architectural coating rules and several other district metal coating rules. Although the South Coast AQMD has a higher limit than that proposed in the SCM, the statewide emission reductions are still virtually zero.

Table VI-65 Pre-Treatment Wash Primers*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

420

PD

PD

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
PD = Protected Data.

    Issues:

    1. Issue: Are there any pre-treatment wash primers at 420 g/l that work?.

      Response: A majority of the marketshare in this category is for complying products; since they are sold, we must assume they work. Sherwin-Williams makes two water-based wash primers with VOC contents less than 200 g/l. Cardinal Industrial Finishes has formulated a two-component wash primer specifically to meet the 420 g/l limits in California districts. The 420 g/l limit has been in effect in many district rules since 1994, and the same limit is in effect in a variety of district metal parts and marine vessel rules.


12. Sanding Sealers (Non-Lacquer)

Product Category Description:

Sanding sealers are clear coatings applied to bare wood to seal the wood and provide a coat that can be sanded smoothly. This category does not include lacquer-type sanding sealers. The application of a sanding sealer to wood provides a first coat that is quite hard, and seals or fills the wood, but it does not conceal the wood grain (LeSota, 1995). Lacquer sanding sealers are included in the lacquer category because they perform essentially like lacquers
(U.S. EPA, 1998).

The sanding sealer category was added to the 1989 SCM by the direction of our Board at its May 12, 1989 hearing. The definition specified that these coatings are to be used prior to the application of varnish, and that they must be labeled accordingly (ARB, 1989). We are proposing the use of the U.S. EPA's National Architectural Coatings Rule definition because it is more descriptive of the function of sanding sealers and does not direct which topcoat must be used. The definition does, however, clarify that lacquer sanding sealers are to be included in the lacquer category.

In general, non-lacquer sanding sealers are water-based acrylics or urethanes, and are recommended for use with water-based stains and polyurethane varnishes. In general, solvent-based lacquer sanding sealers are used in conjunction with solvent-based stains and clear lacquer or alkyd topcoats. There are exceptions to these statements, however.

Table VI-66 below summarizes our estimate of sales and VOC emissions from the non-lacquer sanding sealers category.

Table VI-66 Sanding Sealers (Non-Lacquer)*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

26

110,767

665

0.46

Water-Based

5

5,166

281

~0.00

Total

31

115,933

648

0.46

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.


Proposed VOC Limit and Basis for Recommendation:

We are proposing a 350 g/l VOC limit for non-lacquer sanding sealers effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the limit in current district rules; the fact that most district architectural coating rules have had the same limit for several years; and the fact that several complying water-based products were reported in the survey. We also note that no adverse comments were received about the proposed limit.

Several districts have a VOC limit for sanding sealers of 350 g/l (Antelope, Imperial, Kern, Sacramento, San Joaquin, Santa Barbara, and South Coast), while others have a 550 g/l limit (Mojave and San Diego). Three other districts (El Dorado, Placer, and Ventura) have a 350 g/l limit for non-lacquer sanding sealers. The VOC limit in the U.S. EPA's National Architectural Coatings Rule is 550 g/l.

We recommend that the VOC limit for non-lacquer sanding sealers remain at 350 g/l at this time, the same as in most of the district rules. In contrast to current district rules, we are recommending that the sanding sealers category represent only non-lacquer products because non-lacquer sanding sealers are usually recommended for use with varnishes, while lacquer sanding sealers are used with lacquer topcoats.

Table VI-67 Sanding Sealers (Non-Lacquer) *

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

350

5

4.50

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).

    Issues:

    1. Issue: We can not make sanding sealers and a number of other categories of the quality, application flexibility and chemical composition safety our customers expect at the very low limits currently proposed.

      Response: The 350 g/l VOC limit has been in effect in most of the district rules for many years, and the survey and our technical analysis shows that there are a number of complying products with acceptable performance characteristics.


    2. Issue: Since you have a limit for waterproofing sealers and for sanding sealers, what about waterproofing wood sanding sealers? It is a waterproofing sealer as well as a sanding sealer.

      Response: The SCM specifies where there are two or more uses for the product, the lowest VOC content limit applies, i.e., the 250 g/l waterproofing wood sealer limit.


13. Shellac - Clear

Product Category Description:

Shellacs can be clear or opaque and are formulated with the resinous secretions of the lac beetle, Laccifer lacca. Shellac coatings are designed to form a uniform coat regardless of how many layers are applied. Each layer of shellac that is applied partially dissolves the previous coat. Shellac Coatings are products, which contain alcohol and dry by evaporation without a chemical reaction. It is for this reason that shellacs are also easily removed. (Angelo Brothers, 1965; Martin, undated)

Clear shellac coatings are designed to protect the substrate with a durable, protective film that allows full and total transmission of light. Clear shellac coatings are typically sold as bleached or natural. Shellac coatings, in which pigment is artificially added, are considered opaque shellacs (See Shellac - Opaque). (Hoyas, 1999; Zinsser, 1996)

Clear shellacs were a regulated category in the 1989 SCM and the U.S. EPA regulates them in the National Rule. According to the U.S. EPA, the majority of state rules define shellac broadly as a coating formulated with natural resins with nitrocellulose resins excluded to avoid overlap with the lacquer category.(TRG/ARB, 1989; U.S. EPA, 1998) While we understand the U.S. EPA's rationale for their definition of shellac, we do not believe that this is an appropriate change for the SCM. District rules have defined shellac as proposed in the SCM for at least the past ten years. In addition to California, several other states use the proposed SCM definition as well. We believe that the U.S. EPA definition may increase emissions in this category, may cause confusion to the consumers, and will be difficult to enforce because of the inherent problems associated in defining "natural resin." Shellacs have always been specific to the lac beetle. Due to the limited availability of lac beetles, potential use of shellac as a quick-dry primer, general-purpose primer and clear wood finish is minimized.

Using the U.S. EPA definition would expand the availability of high VOC products, and may potentially reduce the emission reductions in two other categories:

  1. quick-dry primers, sealers, and undercoaters; and
  2. primers, sealers, and undercoaters. Outside of California, these alcohol-thinned, non-laccifer lacca, natural resin products are marketed as quick-dry primers, sealers, and undercoaters; or primers, sealers, and undercoaters. We believe that there are acceptable alternatives to these products in the quick-dry, specialty, or general primers, sealers, and undercoaters categories.


Table VI-68 below summarizes our estimate of sales and VOC emissions from the shellac-clear coatings category.

Table VI-68 Shellac - Clear*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

PD

PD

614

0.11

Water-Based

0

N/A

N/A

Total

PD

PD

614

0.11

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected Data.


Proposed VOC Limit and Basis for Recommendation:

We are proposing a VOC limit of 730 g/l for clear shellacs effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible by the effective date based on the complying marketshare, the limit in current district rules, and the length of time that these limits have been in effect. The proposed limit is consistent with the 1989 SCM, district rules, and the National Rule. The ARB survey data show 100 percent compliance with the proposed limit.

Table VI-69 Shellac - Clear*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

730

PD

100

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
PD = Protected Data.

    Issues:
    1. Issue: The commenters urge CARB not to modify the definition of shellac in the current or future versions of air control measures. The commenters state that the U.S. EPA has allowed the category of shellac to be reinterpreted, to become confused and to become a "loophole" for manufacturers wishing to violate the spirit of the original CARB regulations put forth many years ago.
      Response: We agree with the commenter and have, therefore, changed the shellac definition back to its previous wording. Shellacs shall include only those coatings that are solely formulated with the resinous secretions of the lac beetle (Laccifer lacca), which is how shellac has been defined for hundreds of years. The proposed definition is consistent with the 1989 SCM's shellac definition, and is the most common shellac definition found in the California districts' architectural coatings rules. Since the shellac category has been regulated for many years and the VOC limit is relatively high, it is important that we limit the definition so that our emission reductions are not compromised. Coatings containing other natural resins may continue to use the most applicable coating category, just as they have in the past. We believe that any substantial change to the definition will not only confuse consumers, but also may reduce our estimated emission reductions.
    2. Issue: The commenter urges the ARB to return to the original definition of shellac. If not, the commenter believes this change in the shellac definition will result in a number of unintended consequences, all of which will certainly increase the amount of VOC emissions, both near and long term.
      Response: We agree with the commenter and have changed the shellac definition back to its previous wording. See response to Issue 1.


    3. Issue: Both in person and in writing, we have requested language uniformity with the National AIM VOC Rule. By changing the definition for shellac we feel you have created a monopolistic situation for the users of paint in California. This does not lead to less air pollution; rather it leads to a more costly less available single product source for extreme stain blocking needs.

      Response: We disagree with the commenter. We do not believe that it is appropriate to change the definition to include all natural resins. Shellacs were broken out of the lacquer category many years ago to address the unique formulation. Outside of California, these other natural resin products are marketed as quick-dry primers, sealers, and undercoaters; or primers, sealers, and undercoaters. There are acceptable alternatives to these products in the quick-dry, specialty, or general primers, sealers, and undercoaters categories. Changing the shellac definition may reduce the emission reductions and sales in the quick-dry and general primers, sealers, and undercoaters categories and increase sales and emissions in the revised shellac category. Currently, cost and availability limit shellac coatings sales. The high cost of the coating makes it prohibitive for use as a general primer, sealer, and undercoater.


    4. Issue: For shellac, ARB reverted to the older definition in SCM and district rules, where shellac is limited to the secretions of the lac beetle. We spent a lot of time in the national negotiations making the federal folks aware that the one resin was not the only substance in the world that performed the function of sealing in alcohol. Functionality and product quality is not limited to lac beetle resin.

      Response: We disagree. Please see response to Issue 3.


14. Shellac - Opaque

Product Category Description:

Shellacs can be clear or opaque and are formulated with the resinous secretions of the lac beetle, Laccifer lacca. Shellac coatings are designed to form a uniform coat regardless of how many layers are administered. Each coating layer partially dissolves the previous coat and dries to form one thicker coat. Shellac coatings are products, which use ethyl alcohol as the primary solvent and dry by evaporation without a chemical reaction. It is for this reason that shellacs are also easily removed. (Angelo Brothers, 1965; Martin, undated)

Opaque shellac coatings are designed to protect the substrate with a durable, protective film. This film layer does not allow full and total transmission of light. Opaque shellac coatings are typically white and are rarely tinted. Shellac coatings in which any pigment is artificially added are considered opaque shellacs. (Hoyas, 1999; Zinsser, 1999; Zinsser,1995)

Opaque (pigmented) shellacs were a regulated category in the 1989 SCM and the U.S. EPA regulates them in the national rule. According to the U.S. EPA, the majority of state rules define shellac broadly as a coating formulated with natural resins, with nitrocellulose resins excluded to avoid overlap with the lacquer category. Although the definitions may change from state to state, all state rules reviewed have 550 g/l limit for opaque shellacs. For a more detailed discussion on the definition of shellac, please see the Clear Shellac discussion for additional information. (TRG/ARB, 1989; U.S. EPA, 1998)

Table VI-70 below summarizes our estimate of sales and VOC emissions from the shellac - opaque coatings category.

Table VI-70 Shellac - Opaque*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

PD

PD

534

0.41

Water-Based

0

N/A

N/A

Total

PD

PD

534

0.41

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected Data.


Proposed VOC Limit and Basis for Recommendation:

We are proposing a VOC limit of 550 g/l for opaque shellacs effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible by the effective date based on the following items: the complying marketshare; the limit in current district rules; and the length of time that these limits have been in effect.

This proposed limit is consistent with the 1989 SCM, district rules, and the National Rule. Certain applications of shellac require thinning to meet customer needs. Although the sales weighted average for opaque shellac is near the proposed limit of 550 g/l, 100 percent of the market complies with the proposed limit, even with recommended thinning.

Table VI-71 Shellac - Opaque*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

550

PD

100

0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
PD = Protected Data.

    Issues:

    1. Issue: Please see previous section on clear shellacs.

15. Varnishes

Product Category Description:

Varnishes are clear or semi-transparent coatings that may contain a small amount of pigment to color the surface, or to control the final sheen or gloss of the finish. The varnish category excludes lacquers and shellacs, which dry by evaporation. Varnishes used on floors are subject to the varnish VOC limit rather than the floor coating VOC limit.

The definition in the proposed SCM is essentially the same as that in the U.S. EPA's National Architectural Coatings Rule definition. The definition used in the 1989 SCM defines varnishes simply as clear wood finishes formulated with various resins to dry by chemical reaction on exposure to air. We believe that the National Rule definition is more descriptive of the characteristics of the finished film, which distinguishes varnishes from shellacs and lacquers. The distinguishing characteristics of shellacs and lacquers are their ingredients, lac beetle exudate and cellulosic or synthetic resins, respectively. Varnishes are commonly made with alkyds, urethanes, polyurethanes, phenols, and modified resin systems, and they are characterized by a hard film that can be formulated to resist abrasion, chemicals, acids, alkalis, alcohol, steam, hot grease, salt water, gasoline, or solvents.

The primary criticisms of varnishes are their tendency to dry slowly and to yellow (TRG/ARB, 1989). Varnishes yellow because they are made with oils that naturally yellow as they age, although some oils yellow less than others. In some woods, the yellowing can enhance the richness of the wood (Marino). In general, water-based polyurethanes yellow less than oil-based varnishes. The drying times vary greatly depending on the formulation, but in general it is true that varnishes dry-to-recoat more slowly than lacquers.

Table VI-72a below summarizes our estimate of sales and VOC emissions from the varnish coatings category.

Table VI-72a Clear Varnishes*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

257

445,397

463

1.29

Water-Based

84

172,031

260

0.11

Total

341

617,428

406

1.40

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.

Table VI-72b Semitransparent Varnishes*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

67

100,292

459

0.29

Water-Based

23

61,917

296

0.05

Total

90

162,209

396

0.34

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).


Proposed VOC Limit and Basis for Recommendation:

We are proposing a 350 g/l VOC limit for varnishes effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the complying marketshare; the limit in current district rules; the fact that most district architectural coating rules have had the same limit for several years; and the results of performance testing in the Harlan study. We also note that no adverse comments were received about the proposed limit.

All districts except one have a VOC limit for varnishes of 350 g/l (Butte County has a VOC limit of 650 g/l.).

The National Rule VOC limit is 450 g/l. Rules in Kentucky, Massachusetts, New Jersey, New York, and Rhode Island have a limit of 450 g/l, Arizona and California districts (except Butte County) have a limit of 350 g/l, and Texas has a limit of 540 g/l. The national survey showed that 30 percent of sales were below 450 g/l. Varnishes recommended for floor coatings are subject to the varnish VOC limit (U.S. EPA, 1998).

From the sales weighted average survey data in Tables VI-68a and VI-68b above, it appears that only the water-based varnishes comply with the 350 g/l VOC limit. However, in Tables VI-72a and VI-72b below, it can be seen that roughly 50 percent of the marketshare complies with the 350 g/l VOC limit. The complying products include both water-based and solvent-borne products.

The ARB survey data show that in varnishes overall (a composite of clear and semi-transparent), about 30 percent of the water-based products and 18 percent of the solvent-borne products comply with the 350 g/l VOC limit that has been in effect in district rules for many years. There are differences in compliance between clear and semi-transparent varnishes, however. In water-based coatings, 28 percent of the clear varnishes comply, while 38 percent of the semitransparent varnishes comply. In solvent-borne coatings, 13 percent of the semitransparent varnishes comply, compared to 20 percent of the clear varnishes.

The 1995 Harlan Associates study (Harlan, 1995; Cowan, 1998) provides some insights on the performance of two water-based and three solvent-borne varnishes. Varnishes have not yet replaced lacquers as the product of choice for professional painters. The main advantages claimed for the use of lacquers rather than varnishes in the past include clarity, non-yellowing, quick drying and ease of touch-up. Except for ease of touch-up, many of the differences between lacquers and varnishes have narrowed with newer products. Test data shows that, in general, dry times are longer for varnishes than lacquers, but the two complying water-based varnishes dried faster than the solvent-borne products. Similarly, the differences between the high-VOC varnish and the other low VOC varnishes are small. Equivalent characteristics include hardness, application, appearance, flexibility, and gloss. Overall, the abrasion resistance of the low-VOC varnishes was superior to the high-VOC varnish tested. Similarly, the adhesive properties and resistance to water stains of the low-VOC varnishes were superior to the high-VOC varnish. The dry time for two of the low-VOC varnishes was shorter than the high VOC varnish, while the other two low-VOC varnishes did not have any grain raising problems. Sometimes, these coatings are applied as a system, with the stain followed by a sanding sealer and varnish topcoat. Thus, grain raising would not be a concern for this type of coating operation. Long-term testing was not conducted in the Harlan study, so no conclusions can be drawn about the yellowing tendency of each product. However, overall the low VOC products tested were at least as good as the high VOC product.

We recommend that the VOC limit for clear and semitransparent varnishes remain at 350 g/l at this time, the same as in most district rules. There are an adequate number of complying products in water-based and solvent-borne, clear and semitransparent varnishes, to justify these limits. Also, this limit has been in effect in the three largest districts since September 1987 (TRG/ARB, 1989). We cannot justify recommending a relaxation of the rule for the 17 districts that have the 350 g/l VOC limit.

Table VI-73a Clear Varnishes*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

350

146

47.60

0.00

* Based on ARB's 1998 Architectural and Industrial Maintenance Coatings Survey (ARB, 1998).
** Grams VOC per liter of coating, less water and exempt compounds.

Table VI-73b Semitransparent Varnishes*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

350

28

51.50

0.00

* Based on ARB's 1998 Architectural and Industrial Maintenance Coatings Survey (ARB, 1998).
** Grams VOC per liter of coating, less water and exempt compounds.

Issues:

1. Issue: There are no known unresolved issues with this category.


16. Wood Preservatives

Product Category Description:

Wood preservatives are products designed to protect exposed wood from decay or insect attack. Wood preservatives do not form films, but rather penetrate the wood (U.S. EPA, 1998; LeSota, 1995). These coatings are registered with both the U.S. EPA under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the California Department of Pesticide Regulation (DPR). Because of the time required for product registration under FIFRA, the U.S. EPA provided an additional six months for compliance with the VOC limits (U.S. EPA, 1998).

Based on a workshop comment, we are changing the definition of wood preservatives to clarify that the coating, rather than just the preservative chemical, must be registered with the U.S. EPA and DPR. In fact, both the coating and the chemical must be registered (Saldana, 1999). This was the intent of the 1989 SCM (TRG/ARB, 1989), and does not represent a change in strategy or interpretation. Further, in the 1989 SCM and district rules, this category was subdivided into below ground wood preservatives, clear and semitransparent wood preservatives, and opaque wood preservatives. We are proposing to collapse all wood preservatives into a single category.

Table VI-74a-71d below summarizes our estimate of sales and VOC emissions from the wood preservatives categories.

Table VI-74a Below Ground Wood Preservatives*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

PD

PD

352

0.01

Water-Based

PD

PD

350

~0.00

Total

PD

3,549

350

0.01

* Based on ARB's 1998 Architectural and Industrial Maintenance Coatings Survey (ARB, 1998).
** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected Data.

Table VI-74b Clear Wood Preservatives*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

8

157,119

141

0.14

Water-Based

12

67,123

102

0.02

Total

20

224,242

129

0.16

* Based on ARB's 1998 Architectural and Industrial Maintenance Coatings Survey (ARB, 1998).
** Grams VOC per liter of coating, less water and exempt compounds.

Table VI-74c Semitransparent Wood Preservatives*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

12

138,757

390

0.34

Water-Based

13

7,163

218

~0.00

Total

25

145,920

382

0.34

* Based on ARB's 1998 Architectural and Industrial Maintenance Coatings Survey (ARB, 1998).
** Grams VOC per liter of coating, less water and exempt compounds.

Table VI-74d Opaque Wood Preservatives*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

PD

PD

658

~0.00

Water-Based

PD

PD

132

~0.00

Total

PD

PD

314050

~0.00

* Based on ARB's 1998 Architectural and Industrial Maintenance Coatings Survey (ARB, 1998).
** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected Data.Table VI-74

Proposed VOC Limit and Basis for Recommendation:

We are proposing a 350 g/l VOC limit for wood preservatives effective January 1, 2003. This proposed VOC limit is technologically and commercially feasible based on: the high complying marketshare; the limit in current district rules; and the fact that most district architectural coating rules have had the same limit for several years. We also note that no adverse comments were received about the proposed limit.

As mentioned above, there are three categories of wood preservatives currently in most district rules, all with the same VOC limit. Below ground wood preservatives have a 350 g/l VOC limit in all districts except Mojave and San Diego, where they have a 600 g/l limit. Below ground wood preservatives are exempt in the Bay Area, Butte County, Colusa County, Feather River, and Monterey districts. Clear and semitransparent wood preservatives have a 350g/l VOC limit in all districts except Butte County (700 g/l). Opaque wood preservatives have a 350 g/l limit in all districts except Butte (650 g/l).

In the 1989 SCM, the clear and semitransparent wood preservatives had a 350 g/l VOC limit. The category for below ground wood preservatives was established with a VOC limit of 600 g/l. Three years later, in 1992, the SCM consolidated below ground wood preservatives and opaque wood preservatives with a VOC limit of 350 g/l. The three years was provided to reformulate below ground wood preservatives and to allow registration of the products under FIFRA and the California Department of Food and Agriculture (now DPR). Commenters claimed that registration could take up to two years (TRG/ARB, 1989).

The National Rule VOC limit is 550 g/l for below ground wood preservatives, 550 g/l for clear and semitransparent wood preservatives, and 350 g/l for opaque wood preservatives. Several states (Kentucky, Massachusetts, New Jersey, New York, Rhode Island) have 550 g/l limit for clear and semitransparent wood preservatives, while California districts (except Butte County) and Arizona have a 350 g/l limit (U.S. EPA, 1998).

Because all wood preservatives categories have been at 350 g/l in most district rules since 1992, we recommend collapsing all wood preservatives categories (i.e., clear, semitransparent, opaque, and below ground) into one category known as wood preservatives, with a VOC limit of 350 g/l. The survey showed that there is high compliance in all types of wood preservatives, and the function and registration process is similar for each. Also, since this limit has been in effect in most districts, we do not believe additional time for registration is needed.

Table VI-75a Below Ground Wood Preservatives*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

350

PD

PD

0.00

* Based on ARB's 1998 Architectural and Industrial Maintenance Coatings Survey (ARB, 1998).
PD = Protected Data.

Table VI-75b Clear Wood Preservatives*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

350

16

94.70

0.00

* Based on ARB's 1998 Architectural and Industrial Maintenance Coatings Survey (ARB, 1998).
** Grams VOC per liter of coating, less water and exempt compounds.

Table VI-75c Semitransparent Wood Preservatives*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

350

20

74.10

0.00

* Based on ARB's 1998 Architectural and Industrial Maintenance Coatings Survey (ARB, 1998).

Table VI-75d Opaque Wood Preservatives*

Proposed VOC Limit (g/l)

Number of Complying Products

Complying Marketshare (%) by Volume

Emission Reductions (excluding South Coast AQMD) (tons/day)

350

PD

PD

0.00

* Based on ARB's 1998 Architectural and Industrial Maintenance Coatings Survey (ARB, 1998).
PD = Protected Data.

Issues:

1. Issue: No known unresolved issues remain with this category.


C. CATEGORIES NOT PROPOSED FOR INCLUSION IN THE SCM

The following 16 coating categories are not included in the proposed SCM, but are included in the U.S. EPA's national architectural coatings rule. The discussion of each of these coating categories includes:

  1. a product category description;
  2. a rational for not including the product category in the proposed SCM; and
  3. if applicable, a discussion of the issues associated with the category, as raised by industry. The product categories are listed in alphabetical order.

With the exception of anti-graffiti coatings, these categories are not generally included in any of California's district architectural coatings regulations. The products under these categories are currently either:

  1. subject to other coating categories in district regulations;
  2. sold only under the small container exemption; or
  3. not sold in California (at least in areas with architectural coatings rules).

Nevertheless, we researched each of these categories because they were included in the U.S. EPA's architectural coatings regulation, and because in many cases these products will be subject to lower VOC limits under the proposed SCM compared to current district regulations. In researching these categories we considered a variety of factors, including:

  1. the VOC limit they would be subject to under the proposed SCM;
  2. the potential for reformulation as demonstrated by similar products already complying with the VOC limits in the proposed SCM;
  3. the availability of products that do not fall under the category as defined in the national rule, but fulfill the same basic function at a lower VOC content; and
  4. the extent to which products under the category are used in California. As explained in the following sections, we do not believe it is necessary to incorporate a new category and VOC limit for any of these categories.


1. Anti-graffiti Coatings

Product Category Description:

Anti-graffiti coatings, as defined in the U.S. EPA's architectural coatings regulation, are clear or opaque high performance coatings formulated and recommended for application to interior and exterior architectural structures such as walls, doors, partitions, fences, signs, and murals to deter adhesion of graffiti and to resist repeated scrubbing and exposure to harsh solvents, cleansers, or scouring agents used to remove graffiti (U.S. EPA, 9/11/98). Notwithstanding this definition, anti-graffiti products are available as both permanent and sacrificial coatings. Permanent anti-graffiti products are generally two-part polyurethane coatings that resist repeated scrubbing and exposure to harsh solvents, cleansers, or scouring agents, as mentioned in the U.S. EPA's definition. Sacrificial products, on the other hand, provide a layer on top of the substrate that can be removed with hot water or other cleansers if graffiti is applied (Sinak, 12/15/99, telephone conversation; Genesis Coatings, 12/13/99; Spectratone, 12/15/99 ). The sacrificial products are then applied over the affected area to renew the coating.

As shown in the table below, the anti-graffiti coatings that reported in the ARB's Architectural Coatings Survey include both solvent-borne and water-borne coatings, with the solvent-borne coatings accounting for the majority of emissions. According to the ARB's Architectural Coatings Survey, about 2,573 gallons of anti-graffiti coatings were sold in 1996.

Table VI-76 Anti-Graffiti Coatings*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

PD

PD

605

~0.00

Water-Based

PD

PD

92

~0.00

Total

4

2,573

225

~0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected data.


Rationale for Not Including Product Category in the SCM:

In the U.S. Environmental Protection Agency's national Architectural and Industrial Maintenance Rule, the permanent (not sacrificial) anti-graffiti coatings are regulated as a separate category with a 600 g/l VOC limit. However, in the ARB's SCM, anti-graffiti coatings would be classified as either:

  1. industrial maintenance coatings with a 250 gram/liter VOC limit; or
  2. as general flat or non-flat coatings with a 100 or 150 gram/liter VOC limit, respectively.

Permanent anti-graffiti coatings would generally be classified as industrial maintenance coatings (unless they are designed for residential use) because they are designed to resist repeated scrubbing and exposure to harsh solvents, cleansers, or scouring agents. Sacrificial anti-graffiti coatings (or permanent anti-graffiti coatings for residential use) would generally be classified under the flat or non-flat coatings categories because they do not meet the criteria of an industrial maintenance coating.

We do not believe it is necessary to create a separate category with a higher VOC limit for anti-graffiti coatings because there are numerous manufacturers that currently produce products that comply with the proposed limits in the SCM (Sinak, 12/15/99, telephone conversation; Textured Coatings of America, 12/13/99; Aquarius Coatings, 9/98; Genesis Coatings, 12/13/99; Spectratone, 12/15/99). In addition, the sales-weighted average VOC content of the anti-graffiti products reported in the ARB's survey is 225 g/l (ARB, 9/99). The complying products include both permanent and sacrificial products, and many of these products have a VOC content at or near zero. We also note that some of the complying products are approved for use by the California Department of Transportation (CalTrans, 12/21/99; Sinak, 12/15/99, product literature).

    Issues:

    1. Issue: Anti-graffiti coatings go on apartment buildings, but if they are classified as industrial maintenance coatings, they would be prohibited under industrial maintenance restrictions in residential areas. With small volumes for these coatings, it will not be economically feasible for manufacturers to reformulate, and it will not produce significant emission reductions.

      Response: The prohibition on the use of industrial maintenance products in residential applications (in Section 3.6 of the proposed SCM) has been removed. Therefore, permanent antigraffiti products for use in residential applications, such as apartment buildings, will generally be subject to the 250 g/l VOC limit for industrial maintenance coatings. There are numerous anti-graffiti products, both permanent and sacrificial, that currently meet the 100 and 150 g/l VOC limits proposed for flat and nonflat coatings. Many of these products are zero, or near-zero VOC water-based products. These products could be used on apartment buildings and other residential areas. While each manufacturer will need to evaluate whether it is economically justified to reformulate higher VOC products to the proposed levels, many have already found it feasible to formulate low-VOC products, as demonstrated by the numerous complying formulations offered on the market.

    2. Issue: Anti-graffiti coatings should be included in the SCM at VOC limit of 600 g/l. This limit is needed for permanent anti-graffiti coatings based on solvent-borne polyurethane chemistry. Permanent coatings allow cleaning of subsequently applied graffiti for surfaces that cannot be repainted, such as murals. After cleaning, the anti-graffiti system does not need to be reapplied, and also reduces the repainting, and thereby reduces VOC emissions over time. The volumes sold are very small, and averaging is not possible with our product line.

      Response: As mentioned above, there are numerous permanent anti-graffiti coatings. These products are generally water-based two-part polyurethane coatings. There are numerous permanent anti-graffiti products on the market that meet the applicable 250 g/l VOC limit proposed in the SCM, and offer the benefits mentioned by the commenter. Many of these products are zero VOC, or near-zero VOC, water-based two-part polyurethane coatings.


    3. Issue: Anti-graffiti should be a separate category. There are sacrificial coatings, but the high performance ones are made with highly reactive urethane to get the cross-linking and reduce porosity and need 600 g/l. The true way to measure an anti-graffiti coating is to let graffiti cook in the sun for 7-10 days and try to clean without residue. Anti-graffiti systems are also available as a primer, clear coat, and colored coat, but not a clear coat-could this definition be worded to include an anti-graffiti system for water tanks with 340 g/l limit for each individual product

      Response: As mentioned above, there are numerous permanent anti-graffiti coatings on the market that comply with the applicable proposed 250 g/l VOC limit limits for flat and nonflat coatings. These coatings are generally two-part urethane systems, except that they are water-based instead of solvent-based. We do not have any specific information on the ease of removal of baked-on graffiti as mentioned by the commenter. We also do not have any information to justify changing the anti-graffiti definition or limit as proposed by the commenter.


2. Calcimine Recoater Coatings

Product Category Description:

Calcimine recoaters, as defined in the U.S. EPA's architectural coatings regulation, are flat solvent-borne coatings formulated and recommended specifically for recoating calcimine coated ceilings and other calcimine coated substrates (U.S. EPA, 9/11/98). Calcimine (or "powdered distemper" in Britain) is a water-thinned coating composed primarily of calcium carbonate and glue. Calcimine coatings are found in Victorian and Early American homes, especially on ceilings. Calcimine recoaters are light, puffy, gel-like coatings made of limed vegetable oils. They prevent peeling of old calcimine ceilings because they are solvent-based (calcimine is water soluble) and light (heavier coatings may cause calcimine to disbond). These coatings prevent the need to scrape off all the old calcimine coating prior to recoating.

We are not aware of any sales of calcimine recoaters in California. We are only aware of one manufacturer of these coatings. This manufacturer stated that these products are unique to the New England area (California Products Corporation, 12/10/99).

Rationale for Not Including Product Category in the SCM:

A category for calcimine recoaters was added to the U.S. EPA's national architectural coatings rule, with a VOC limit for 475 g/l. However, we do not believe it is necessary to include this category in the proposed SCM. As mentioned above, these coatings are not generally used in California. Also, no district rules include a category with a higher VOC limit for calcimine recoaters. This indicates that these coatings are not used in California because they generally contain a VOC content of 450 to 465 g/l (USEPA, 8/98), and the VOC limit for flat coatings is 250 g/l or lower in California's district rules.

3. Chalkboard Resurfacer Coatings

Product Category Description:

Chalkboard resurfacer coatings, as defined in the U.S. EPA's architectural coatings regulation, are products formulated and recommended for application to chalkboards to restore a suitable surface for writing with chalk (U.S. EPA, 9/11/98). Chalkboard resurfacers represent very low sales in California according to our Architectural Coatings Survey. The products reported in the survey are waterborne, with a sales-weighted average VOC content of 220 g/l.

Table VI-77 Chalkboard Refinisher Coatings*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

0

0

N/A

0

Water-Based

PD

PD

220

~0.00

Total

PD

PD

220

~0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected data.


Rationale for Not Including Product Category in the SCM:

Chalkboard resurfacers were provided with a separate category in the U.S. EPA's national architectural coatings regulation, with a 450 g/l VOC limit. However, in the ARB's SCM, we believe these coatings would generally be classified as industrial maintenance coatings with a 250 g/l VOC limit. This is because these products are generally for nonresidential use and are subjected to frequent heavy abrasion from writing with chalk and subsequent erasing. We believe the 250 g/l limit is appropriate because the sales-weighted average VOC content for these products as reported in the ARB's Architectural Coatings Survey is 220 g/l. There are no air pollution control agencies in California that provide a separate category with a higher VOC limit for these products in their rules.

4. Concrete Curing and Sealing Compounds

Product Category Description:

Concrete curing and sealing compounds form a membrane, or a thin pliable layer of tissue, that covers the concrete surface to reduce the loss of water during the hardening process. They also seal old and new concrete to provide resistance against dirt, liquid, alkalis, acids, and ultraviolet light, while providing adhesion promotion qualities (U.S. SECG). This category includes three types of coatings: concrete curing, concrete sealing, and concrete curing and sealing compounds, which can provide both proper curing and long term protection.

Membrane curing compounds are the most common type of concrete curing compounds used for keeping moisture in the concrete to maintain satisfactory moisture content and temperature during curing, so that the concrete may develop the desired strength and hardness. These compounds are low in cost and can easily be brushed or sprayed on immediately after the concrete is laid without worrying about marring the surface (U.S. EPA BID).

Concrete sealing compounds provide a glossy film on concrete slabs to make them resistant to liquid and dirt impregnation. Sealing compounds are designed to keep moisture out of the concrete, especially in the first year when the concrete is curing and gaining strength. They also seal concrete against alkali, acid, ultraviolet light, and promote adhesion. Concrete curing and sealing compounds are used on buildings for long-term protection, aesthetics, and durability in addition to curing (U.S. EPA BID).

One coating company's product literature states that their acrylic copolymer emulsion blend cures concrete and provides a protective coating for interior and exterior concrete including terrazzo surfaces (marble or stone chips set in mortar), and has a VOC content of 325 g/l. The product also claims to provide a clear membrane for new or existing concrete, hardens new concrete by promoting a proper cure for increased abrasion resistance, and can be used on industrial floor slabs, parking garages, warehouses, walls and columns, interior and exterior concrete surfaces, passenger and freight terminals. The literature also states that the drying time of the product is less than one hour under laboratory conditions, 4-6 hours for foot traffic, and 6-10 hours for wheel traffic. (Euclid Chemical)

Rationale for Not Including Product Category in the SCM:

For almost 10 years, most of California's district rules have had a VOC limit of 350 g/l for the concrete curing compounds. Concrete curing and sealing compounds were included as a separate category in the U.S. EPA's national architectural coatings regulation, but it is not found in any state rules as a separate category. It was given a 700 g/l VOC limit in the national regulation. However, in the ARB's SCM, we believe these coatings are already covered under two architectural coating categories as: (1) concrete curing compounds with a 350 g/l VOC limit, or (2) waterproofing concrete/masonry sealers with a 250 400 g/l VOC limit.

We believe these limits are appropriate as explained in the sections on concrete curing compounds (see section B, #2 Concrete Curing Compounds) and waterproofing sealers (see section A, #28 31 Waterproofing Concrete/Masonry Sealers). For example, the ARB's 1998 Architectural and Industrial Maintenance Coatings Survey, shows that the concrete curing compound category has a 95 percent compliance at the proposed 350 g/l level, and that this category is heavily dominated by water-based formulations. We also note that there are a number of water-based products on the market that advertise optimum protection for the curing and sealing of concrete (SealTight). Additionally, the waterproofing sealer coatings category shows numerous complying products currently on the market at the proposed 250 g/l VOC limit.

Issues:

1. Issue: One company requested the National Rule limit of 700 g/l, because in warm, dry weather, compressive strength of concrete is considerably lower when a concrete curing compound (350 g/l VOC) is used, as compared to concrete prepared with a curing and sealing compounds (700 g/l VOC).

Response: Concrete curing compounds have had a VOC limit of 350 g/l in most district rules for almost 10 years. As explained in this section, there are a number of formulation technologies available that can meet the 350 g/l concrete curing compound limit while providing the needed curing and sealing of the concrete. Thus, staff does not think this category with a 700 g/l is warranted.


5. Concrete Protective Coatings

Product Category Description:

Concrete protective coatings are products designed to protect concrete from spalling (fragment, flaking, or chipping) in freezing temperatures by protecting against water and chloride ion intrusion. Exposed concrete structures require protection from extreme weather conditions and salt spray that can break down concrete and deteriorate the structure. Water itself causes freeze/thaw damage and can be a dirt carrier, which can require expensive cleaning. In addition to water, substances dissolved in water, especially chloride compounds (from road salt) are more harmful than the freeze/thaw effects. Both chloride and sulfate ions carried by water chemically cause expansive forces that degrade rebar- and lime-containing construction materials. For example, the high alkalinity of new concrete protects steel rebars against corrosion, but as concrete ages, carbonation occurs, and the alkalinity of the concrete is lowered. Alkaline protection is lost and water-carrying chloride ions penetrate, causing steel to corrode. Coatings and sealers play an important role in extending the useful life of many structures by protection from these elements (PCI, 9/96).

These coatings are applied in a single coat, but produce a high-build layer over concrete, plaster, or other cement-like surfaces. They can be applied without a primer over form oils or uncured concrete. This category was included in the national survey under "high performance coatings." However, these coatings meet the definition of the waterproofing concrete/masonry sealers category in the SCM, which states, "a clear or pigmented film-forming coating that is labeled and formulated for sealing concrete and masonry to provide resistance against water, alkalis, acids, ultraviolet light, and staining." "a coating labeled as and formulated for application to a porous substrate for the primary purpose of preventing the penetration of water."

Rationale for Not Including Product Category in the SCM:

Concrete protective coatings were provided with a separate category in the U.S. EPA's national architectural coatings regulation, with an 350a 400 g/l VOC limit. However, in the ARB's SCM, we believe these coatings are basically covered under the waterproofing concrete/masonry sealer coating category with a 250 400 g/l proposed VOC limit.

As a regulated category, only Oregon and Kentucky have this category with a VOC limit of 400 g/l in both states. Since this category was added to the final National Rule after the ARB 1998 Architectural and Industrial Maintenance Coatings Survey was completed, no data was collected on this specific category. However as discussed previously our survey did include the waterproofing sealers category, and based on this survey data, literature searches, and testing results, ARB does not believe it is necessary to have a separate category for the concrete protective coatings because the waterproofing sealers coatings' formulations can provide the protection needed.

Issues:

1. Issue: One company requested a category for concrete protective coatings at 400 g/l, because the lower VOC products cannot penetrate form oil and release agent materials, provide the required adhesion, and provide long-term protection without requiring recoating.

Response: Staff is aware of numerous waterproofing sealer products that meet the proposed VOC limit of 250 g/l (see A, #28 Waterproofing Sealers). In addition, we believe the lower VOC products will adhere well with proper surface preparation. As with all coatings, the surface needs to be properly prepared prior to application of a coating for optimal performance. Thus, ARB does not believe it is necessary to have a separate category for these coatings. Since the release of the Draft Program EIR, the proposed VOC limit for the waterproofing concrete/masonry sealer category has been reestablished at 400 g/l (see A, #28 Waterproofing Concrete/Masonry Sealers). As stated above, we believe these coatings are basically covered under this category, and that it is not necessary to have a separate category for these coatings.


6. Concrete Surface Retarder Coatings

Product Category Description:

Concrete surface retarders are products designed to alter concrete hydration of freshly poured concrete. They are used to prolong the set time of the concrete, which allows for easy removal of the retarded mortar with a stiff brush and flushing with water to expose the aggregate. This produces an attractive exposed finish. At the job site, concrete surface retarders are used in the production of exposed aggregate finishes, to prevent hardening at a desired surface depth by altering the cement's hydration (U.S. EPA BID).

The liquid retarding ingredients include extender pigments, resin, and solvent that chemically interact with the concrete to prevent hardening where the retarder is applied on the surface (U.S. EPA SECG). Typically, concrete surface retarders are given 14-72 hours to affect the concrete system, after which time the non-hardened cement surface and the retarding liquid is either sacrificially brushed, blown, or washed away to give an architecturally pleasing surface of expose aggregate.

In addition to the liquid concrete surface retarders, some products consist of non-toxic, coated paper. The retarder paper produces the same altering affect for the concrete system as the liquid products. The paper requires no disposal problem or formwork clean-up, and is heat and abrasion resistant. Retarder paper can be used for patio slabs or architectural panels. The use of these paper products can be one-quarter of the cost of liquid retarders, and are available in varying strengths for a variety of aggregate sizes (Benton-Chemie).

Rationale for Not Including Product Category in the SCM:

This category is included in the U.S. EPA's architectural coatings national rule, with a VOC limit of 780 g/l. New Jersey and Texas do not regulate surface retarders because they do not believe they meet the definition of a coating. After investigating these products, ARB also concluded that they do not meet the definition of a coating. As noted above, these products are sacrificed by brushing or washing away, after they have affected the concrete system and do not create a hardened film. They are used only in the process of creating an exposed aggregate finish and are not part of the finished product.

Issues:

1. Issue: ARB received no comments on this category.

7. Conversion Varnish Coatings

Product Category Description:

Conversion varnish, as defined in the U.S. EPA's architectural coatings regulation, is a clear, acid curing coating with an alkyd or other resin blended with amino resins and supplied as a single component or two-component product. The film formation is the result of an acid-catalyzed condensation reaction, affecting a transetherification at the reactive ethers of the amino resins (U.S. EPA, 9/11/98). These coatings are often referred to as "swedish finishes" and reportedly range in VOC content from 535 to 725 g/l (EPA, 8/98). These coatings are typically used for professional application to wood flooring.

Sales and emissions information for conversion varnishes is not available since the ARB's Architectural Coatings Survey did not include a separate category for these products.

Rationale for Not Including Product Category in the SCM:

Conversion varnishes were provided with a separate category in the U.S. EPA's national architectural coatings regulation, with a 725 g/l VOC limit. However, in the ARB's SCM, these coatings would be classified as varnishes with a 350 g/l VOC limit. We believe the 350 g/l VOC limit is appropriate because durable clear varnishes suitable for wood flooring are available at or below 350 grams VOC per liter. According to the ARB's Architectural Coatings Survey, nearly half of the clear varnish category is currently at or below the 350 g/l VOC level. Many of these products are suitable for wood flooring applications (Benjamin Moore, 1/6/00; Kelly-Moore, 12/97; Valspar, 1/6/00). There are no air pollution control agencies in California that provide a separate category with a higher VOC limit for conversion varnishes in their architectural coatings rules.

8. Extreme High Durability Coatings

Product Category Description:

Extreme high durability coatings, as defined in the U.S. EPA's national architectural coatings regulation, are air-dried coatings, including fluoropolymer-based coatings, that are formulated and recommended for touch-up of precoated architectural aluminum extrusions and panels (U.S. EPA, 9/11/98). These coatings must meet the weathering requirements of the American Architectural Manufacturer's Association (AAMA) specification 605-98, Voluntary Specification, Performance Requirements and Test Procedures for High Performance Organic Coatings on Aluminum Extrusions and Panels, Section 7.9. Section 7.9 establishes performance standards for color retention, chalk resistance, gloss retention, and resistance to erosion, for test panels subjected to Florida exposure for five years. Factory applied finishes to architectural aluminum extrusions and panels are often designed to meet all the performance standards of AAMA specification 605-98 (which has now been superceded by more stringent performance standards in AAMA 2605-98).

Follow up conversations with the manufacturers that reported extreme high durability coatings in the ARB's Architectural Coatings Survey revealed that all the products reported in the category were miscategorized (Spraylat, 12/9/99; Conco Paint, 12/9/99; Futura, 1/6/00), and would generally fall under the industrial maintenance category. In addition, the only known manufacturer of these products did not report any sales in California.

Rationale for Not Including Product Category in the SCM:

Extreme high durability coatings were provided with a separate category in the U.S. EPA's national architectural coatings regulation, with an 800 g/l VOC limit. Under the proposed SCM, these products would generally be classified as industrial maintenance coatings with a 250 gram/liter VOC limit. We believe this is appropriate because extreme high durability coatings are designed for "exterior exposure of metal structures and structural components," one of the criteria that qualify a coating as an industrial maintenance coating. We believe high performance industrial maintenance coatings meeting the proposed 250 g/l VOC limit can be used for architectural aluminum applications. If extreme high durability coatings were to be sold for residential uses, they would generally be subject to the nonflat coatings limit with a 150 gram/liter VOC limit. However, we believe the high cost of these products (approximately $280/gallon - K&L, 12/9/99) makes them unlikely for residential uses. As mentioned above, we do not believe these products are currently sold in California. We also note that since these products are designed for touch-up, the exempt one liter or smaller containers would probably be used. There are no air pollution control agencies in California that provide a separate category with a higher VOC limit for these products in their architectural coatings rules.

9. Heat Reactive Coatings

Product Category Description:

As defined in the U.S. EPA's architectural coatings regulation, heat reactive coatings are high performance phenolic-based coatings requiring a minimum temperature of 191oC (375oF) to 204oC (400oF) to obtain complete polymerization or cure (U.S. EPA, 9/11/98). These coatings are formulated and recommended for commercial and industrial use to protect substrates from degradation and maintain product purity in which one or more of the following extreme conditions exist:

  1. continuous or repeated immersion exposure of 90 to 98 percent sulfuric acid, or oleum;
  2. continuous or repeated immersion exposure to strong organic solvents;
  3. continuous or repeated immersion exposure to petroleum processing at high temperatures and pressures; and
  4. continuous or repeated immersion exposure to food or pharmaceutical products which may or may not require high temperature sterilization.


As shown in Table VI-78, the heat reactive coatings reported in the ARB's Architectural Coatings Survey are solvent-based products with a sales weighted average VOC content of
378 grams VOC per liter of coating.

Table VI-78 Heat Reactive Coatings*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

PD

PD

378

~0.00

Water-Based

0

N/A

N/A

Total

PD

PD

378

~0.00

* Based on ARB's 1998 Architectural and Industrial Maintenance Coatings Survey (ARB, 9/99).
** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected data.


Rationale for Not Including Product Category in the SCM:

In the U.S. Environmental Protection Agency's national Architectural and Industrial Maintenance Rule, heat reactive coatings are regulated as a separate category with a 420 g/l VOC limit. However, we do not believe it is necessary to include a separate category for these products in the ARB's SCM. These products are not generally applied in the field to stationary structures (Heresite). These products are designed to be cured at 375 to 400oF as stated in the definition. This generally means that metal products are coated and baked in an oven in original equipment manufacturing applications. As such, these coatings would generally be subject to district miscellaneous metal parts rules rather than architectural coatings rules. We also note that industrial maintenance coatings meeting the 250 g/l VOC limit are available for chemical storage tanks and other applications where chemical resistance is needed. No district architectural coatings rules include a separate category with a higher limit for these coatings.

10. Impacted Immersion Coatings

Product Category Description:

Impacted immersion coatings are high-performance industrial maintenance products designed to be applied to steel structures subject to immersion in turbulent, debris-laden water. The impacted immersion coatings are specifically resistant to high-energy impact damage caused by floating ice or debris (U.S. EPA SECG). They are typically used in industrial, commercial, or institutional settings for use on immersed parts of bridges, dams, locks, oil rig stations, and power plants.

Rationale for Not Including Product Category in the SCM:

This category was included in the U.S. EPA's National Architectural and Industrial Maintenance Rule with a VOC limit of 450 g/l. Impacted immersion coatings are regulated under the ARB's SCM as industrial maintenance coatings because they are immersed in water, wastewater, or chemical solutions. Impacted immersion coatings were not included as a separate category in the ARB 1998 Architectural and Industrial Maintenance Coatings Survey; therefore, no data was collected on this category.

We do not believe a separate category is necessary because they can be reformulated to the 250 g/l limit using the technology for other industrial maintenance coatings. Our research has shown that some current solvent-free epoxies offer excellent surface wetting and penetration, characteristics that make them ideal for maintenance of pitted steel and eroded concrete
(JPLC, 11/99).

Issues:

1. Issue: ARB did not receive any comments on the impacted immersion coatings. There are no known unresolved issues with this category


11. Nonferrous Ornamental Lacquer Coatings

Product Category Description:

Nonferrous ornamental metal lacquers and surface protectant (or "nonferrous ornamental lacquers"), as defined in the U.S. EPA's architectural coatings regulation, are clear coatings formulated and recommended for application to ornamental architectural metal substrates (bronze, stainless steel, copper, brass, and anodized aluminum) to prevent oxidation, corrosion, and surface degradation. (U.S. EPA, 9/11/98)

Sales and emissions information for nonferrous ornamental lacquers is not available since the ARB's Architectural Coatings Survey did not include a separate category for these products.

Rationale for Not Including Product Category in the SCM:

Nonferrous ornamental lacquers were provided with a separate category in the U.S. EPA's national architectural coatings regulation, with an 870 g/l VOC limit. However, in the ARB's SCM, we believe these coatings would generally be classified as either: (1) rust preventive coatings with a 400 g/l VOC limit, if they are for residential use; or (2) industrial maintenance coatings with a 250 g/l VOC limit, if they are for nonresidential use. Due to the extremely high VOC limit established for these products, it is unlikely that they are used in areas of California subject to architectural coatings rules (except under the small size container exemption). There are no air pollution control agencies in California that provide a separate category with a higher VOC limit for these products in their architectural coatings rules.

12. Nuclear Coatings

Product Category Description:

Nuclear coatings, as defined in the U.S. EPA's architectural coatings regulation, are protective coatings formulated and recommended to seal porous surfaces such as steel (or concrete) that otherwise would be subject to intrusion by radioactive materials (U.S. EPA, 9/11/98). These coatings must be resistant to long-term (service life) cumulative radiation (per ASTM Method D 4082-89), relatively easy to decontaminate, and resistant to various chemicals to which the coatings are likely to be exposed (per ASTM Method D 3912-80). Nuclear coatings as defined can be used in both Level I (containment) and Level II (noncontainment) areas.

ASTM Method D 4082-89, Standard Test Method for Effects of Gamma Radiation on Coatings for Use in Light-Water Nuclear Power Plants, is designed to provide a uniform test to assess the suitability of coatings, used in nuclear power facilities, under continuous readiation exposure for the projected 40-year lifetime of the facilities, including radiation during a DBA (design basis accident). The test method specifies procedures for exposing sample coatings applied to steel panels and concrete blocks to gamma radiation under specified conditions, and then checking for various coating defects.

ASTM Method D 3912-80 (Reapproved 1989), Standard Test Method for Chemical Resistance of Coatings Used in Light-Water Nuclear Power Plants, is designed to measure the chemical resistance of coatings used in light-water nuclear power plants. The test method specifies procedures for immersing sample coatings applied to steel panels and concrete blocks in various test solutions commonly used in nuclear power facilities.

There are two nuclear power facilities operating in California that utilize nuclear coatings in maintenance and repair operations: (1) the Diablo Canyon site near Avila Beach (San Luis Obispo County), and (2) the San Onofre site near San Clemente (San Diego County). The Diablo Canyon site is operated by the Pacific Gas and Electric Company, and the San Onofre site is operated by the Southern California Edison Company and San Diego Gas and Electric Company.

As shown in the table below, the nuclear coatings that reported in the ARB's Architectural Coatings Survey include both solvent-borne and water-borne coatings. According to the ARB's Architectural Coatings Survey, about 700 gallons of nuclear coatings were sold in 1996, resulting in VOC emissions of less than one ton per year.

Table VI-79 Nuclear Coatings*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

PD

PD

248

~0.00

Water-Based

PD

PD

46

~0.00

Total

 4

697

50

~0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected data.


Rationale for Not Including Product Category in the SCM:

In the U.S. Environmental Protection Agency's national Architectural and Industrial Maintenance Rule, nuclear coatings are regulated as a separate category with a 450 g/l VOC limit. U.S. EPA based this limit on the 400 g/l limit for nuclear coatings in the shipbuilding and ship repair national emission standards for hazardous air pollutants (which includes a thinning exemption for coatings applied in cold weather). However, in the ARB's SCM, nuclear coatings would generally be classified as industrial maintenance coatings with a 250 g/l VOC limit.

We do not believe it is necessary to create a separate category with a higher VOC limit for nuclear coatings because there are currently products available that comply with the proposed 250 g/l limit in the SCM. The complying products include primers and surfacers (Carboline 893; K&L Nos. 6129 and 6548-S) and topcoats (Carboline 890; K&L Nos. 4500, 5000, and 9600 N). The complying products include products for both concrete (Carboline 890 and 893; K&L 6548-S, 4500, 5000 - floors only, and 6129 - floors only) and steel (Carboline 890 and 893; and K&L 4500, 9600 N, and 5000 - floors only). Discussions with personnel at California's nuclear power facilities indicate that the nuclear coatings they use are below 250 g/l (Southern California Edison, 1/6/00), or that they primarily use low VOC products and can use exempt quart for the occasions when a product above 250 g/l may be needed (Pacific Gas and Electricity, 1/13/00). We also note that the sales-weighted average VOC content of these coatings, as reported in the ARB's Architectural Coatings Survey is 50 g/l. No districts currently include a separate category with a higher VOC limit for nuclear coatings in their architectural coatings rules.

Issues:

1. Issue: We believe there is a need for nuclear coatings as defined in the National Rule. Our research shows that an average nuclear power plant will use up to 500 gallons per year on maintenance of Level 1 and Level 2 areas. The worst case would be if a plant completely repainted all these areas, which would require approximately 4,000 gallons per unit. This is an unusual occurrence and not normally expected through the life of the plant.

Response: Although the nuclear coatings category is not large, we do not believe a separate category with a higher VOC limit is necessary. As discussed above, we have identified several complying products that meet the 250 g/l VOC limit for industrial maintenance coatings.

2. Issue: Although the survey reveals that there are low VOC nuclear coatings, you can't assume that they can be used in all areas. Nuclear coatings for steel are not low VOC. The cost for getting a coating certified is enormous, and at those small volumes, there is no point in reformulating.

Response: As discussed above, nuclear coatings that are below the 250 gram/liter level are available for both concrete and steel, and California's nuclear power facilities are primarily purchasing these low VOC products. We realize that the volumes of nuclear coatings sold are not large and that some manufacturers will need to evaluate whether it is cost-effective to reformulate their products that are currently above 250 g/l. However, at least one manufacturer reported developing a low VOC nuclear coating in 1983 specifically for California due to VOC regulations (K&L, 12/7/99), indicating that it is not necessarily economically infeasible to invest in lower VOC nuclear formulations. We also note that if a manufacturer chooses not to reformulate certain higher VOC products, it is expected that customers will purchase more of the manufacturer's existing complying products, or more of a competitor's complying products, resulting in economic benefits to manufacturers offering these lower VOC products. Manufacturers may also choose to offer the product in the exempt smaller containers, for the few occasions where a California customer specifies a product above 250 g/l VOC.


13. Repair and Maintenance Thermoplastic Coatings

Product Category Description:

Repair and maintenance thermoplastic coatings, as defined in the U.S. EPA's architectural coatings regulation, are industrial maintenance coatings that have vinyl or chlorinated rubber as the primary resin and are recommended solely for the repair of existing vinyl or chlorinated rubber coatings without the full removal of the existing coating system
(U.S. EPA, 9/11/98).

As shown in the table below, the repair and maintenance thermoplastic coatings reported in the ARB's Architectural Coatings Survey have a sales-weighted average VOC content of less than 1 gram VOC per liter. To protect the confidentiality of proprietary data, sales or other information cannot be provided for this category.

Table VI-80 Repair and Maintenance Thermoplastic Coatings*

 

Number of Products

Category Sales (gallons/year)

Sales-Weighted Average VOC (grams/liter)**

VOC Emissions (excluding South Coast AQMD) (tons/day)

Solvent-Based

PD

PD

<1

~0.00

Water-Based

PD

PD

159

~0.00

Total

PD

PD

<1

~0.00

* Based on ARB's 1998 Architectural Coatings Survey Results Final Report (ARB, 1999).
** Grams VOC per liter of coating, less water and exempt compounds.
PD = Protected data.


Rationale for Not Including Product Category in the SCM:

In the U.S. Environmental Protection Agency's national Architectural and Industrial Maintenance Rule, repair and maintenance thermoplastic coatings are regulated as a separate category with a 650 g/l VOC limit. However, in the ARB's SCM, these coatings would generally be classified as industrial maintenance coatings with a 250 gram/liter VOC limit. We do not believe it is necessary to create a separate category with a higher VOC limit for repair and maintenance thermoplastic coatings because the sales weighted average VOC content of the products reported in the ARB's survey indicate that current products are well below this VOC level. Only two manufacturers reported products in this category in the ARB's Architectural Coatings Survey. One manufacturer said that their products were actually for original equipment manufacturer (OEM) applications, not architectural coatings (Simpsons Coating Group). We also note that no district rules currently contain a separate category with a higher VOC limit for these products.

14. Stain Controller Coatings

Product Category Description:

Stain controller coatings, as defined in the U.S. EPA's architectural coatings regulation, are conditioners or pretreament coatings formulated and recommended for application to wood prior to the application of a stain in order to prevent uneven penetration of the stain (U.S. EPA, 9/11/98). These products may be called wood conditioners, prestains, or washcoats. They are often recommended for soft woods such as pine, which are more likely to absorb stains unevenly.

Sales and emissions information for stain controllers is not available since the ARB's Architectural Coatings Survey did not include a separate category for these products. According to the one manufacturer, over 97 percent of the total sales for these coatings are exempt under the small container exemption (USEPA, 8/98).

Rationale for Not Including Product Category in the SCM:

Stain controllers were provided with a separate category in the U.S. EPA's national architectural coatings regulation, with an 720 g/l VOC limit. However, in the ARB's SCM, these coatings would generally be classified as low solids coatings with a VOC content limit of 120 g/l, including water and exempt compounds. We believe that this is appropriate because lower VOC water-based technology is available for these products. Several district architectural coatings and wood products coating rules in California specify a 120 g/l VOC limit for these products or related low-solids coatings. In addition, as mentioned above, these products are primarily sold in smaller, exempt containers. Finally, no district architectural coatings rule in California contains a separate category with a higher VOC limit for these products.

Issues:

1. Issue: This category was included in an early draft rule submitted by NPCA for Reg-Neg. It is a low-volume, specialty niche coating that it is not cost-effective to reformulate. These coatings would have to be very low solids to accept stain, but the use of water as a solvent would raise the grain of wood. It was added to the final version of the National Rule. The National Rule limit is 720 g/l.

Response: We do not believe it is necessary to provide a separate category with a 720 g/l VOC limit for these products. These products are currently complying with the 120 g/l VOC limit for low solids coatings in many areas of California, or they are only sold in small containers. Water-based formulations may require some sanding after application in cases were grain raising occurs, or a solvent-based product sold in one liter or smaller container sizes may be used. However, we note that some solvent-based products also recommend sanding after application (Benjamin Moore).

15. Thermoplastic Rubber Coatings and Mastics

Product Category Description:

Thermoplastic rubber coatings and mastics ("thermoplastic rubber coatings"), as defined in the U.S. EPA's architectural coatings regulation, are products formulated and recommended for application to roofing or other structural surfaces and that incorporate no less than 40 percent by weight of thermoplastic rubbers in the total resin solids, and may also contain other ingredients including, but not limited to, fillers, pigments, and modifying resins
(U.S. EPA, 9/11/98).

Follow up conversations with the manufacturers that reported thermoplastic rubber coatings in the ARB's Architectural Coatings Survey revealed that all the products reported in the category were miscategorized (Fine Line Paint, 1/12/00). The only known manufacturers of these products do not currently sell them in California.

Rationale for Not Including Product Category in the SCM:

Thermoplastic rubber coatings were provided with a separate category in the U.S. EPA's national architectural coatings regulation, with a 550 g/l VOC limit. However, in the ARB's SCM, these coatings would generally be classified as roof coatings with 250 g/l VOC limit. We believe that this is appropriate because lower VOC elastomeric latex or bituminous roof coatings, described elsewhere in this Chapter, are available that provide the same basic function. We also note that these products are not currently being sold in California. Finally, no district architectural coatings rule in California contains a separate category with a higher VOC limit for these products.

Issues:

1. Issue: A category with a 550 g/l VOC content limit should be provided for thermoplastic rubber and mastic coatings, as recognized in the national AIM rule. Alternatively, we suggest the expansion of the metallic pigmented coating category to also include highly reflective coating.

Response: We do not believe it is necessary to create a separate category with a higher VOC limit for these products because currently used bituminous and latex roofing products are available at less than half the VOC content of a 550 g/l thermoplastic rubber material. We also do not believe it is appropriate to modify the metallic pigmented coating category to include products that contain no metal.


2. Issue: Our thermoplastic rubber products are more durable, and result in less emissions over time than comparable bituminous roof products.

Response: We have no data to substantiate that thermoplastic rubber roofing products outlast their bituminous counterparts. We also note that latex roofing products are available.

3. Issue: Our thermoplastic rubber products work in situations where water-based or bituminous products fail. For example, they adhere well to single-ply membranes and adhere well when exposed to ponding water.

Response: We have no data to substantiate these performance claims. Also, since thermoplastic rubber products are not used in California, we assume that other roofing products can be used to address these situations.


16. Zone Marking Coatings

Product Category Description:

Zone marking coatings are products designed for use for marking and stripping driveways, parking lots, sidewalks, curbs, airport runways, or other traffic surfaces. The U.S. EPA established the zone marking coatings as a separate category from the traffic marking coatings. Under the U.S. EPA definition, the zone marking products have a size restriction requiring the product category to be sold or distributed in five gallon containers or smaller. Since the zone marking coatings have a higher VOC limit that traffic marking coatings, the restriction in size was established to discourage the use of these coatings in large-scale applications, such as those for general traffic markings intended for public roads and highways. (U.S. EPA SECG)

Rationale for Not Including Product Category in the SCM:

Zone marking coatings are included in U.S. EPA's architectural coatings national rule, with a 450 g/l VOC limit. However, this category does not appear in any state rules. Zone marking coatings are regulated under the ARB's SCM as traffic marking coatings, which the SCM defines as, "a coating formulated and recommended for marking and striping street, highways, or other traffic surfaces including, but not limited to, curbs, berms, driveways, parking lots, sidewalks, and airport runways." We do not believe a separate category is necessary because these coatings can be reformulated to the 150 g/l limit using the technology for traffic marking coatings. Zone marking coatings were not included in the ARB 1998 Architectural and Industrial Maintenance Coatings Survey; therefore, no data was collected on this category. However, ARB did request data on the traffic marking coating category, which includes the zone marking coatings by definition.

The ARB 1998 survey data for traffic coatings was based on information submitted by 30 manufacturers covering 189 different products. These products included water-based, solventborne, and 100 percent solid formulations. The survey indicated that the 1990 sales for water-based formulations (for traffic coating products) to be over a million gallons, with an average VOC content of 121 g/l, well below the proposed limit. This indicates a 53 percent complying marketshare for traffic marking coatings at the proposed 150 g/l VOC level.

Although no single traffic marking material is the most desirable in all applications, a combination of low- and zero-VOC-emitting marking materials can provide the performance necessary for highway safety. Water-based zone marking paints are available and the durability is comparable with that of other solventborne marking paints. One traffic line and marking product's literature states that it has a 45 g/l VOC content (Kelly-Moore). It also describes the product as durable, abrasion resistant flat acrylic finish for marking lanes, parking lots, industrial road traffic lanes, curbs, or areas on concrete or asphalt surfaces. Other typical low-VOC traffic marking coatings that meet the 150 g/l limit include coatings formulated as acetone-based solventborne coatings, epoxies, thermoplastics, permanent markers, and polyester tapes (U.S. EPA BID). In addition, the overall annualized costs of using water-based and zero-VOC coatings are lower than their solventborne counterparts. Compliant traffic coatings are commercially available and are being used by local governments, and Cal Trans, as well as professional contractors at all levels (U.S. EPA BID). In addition, various tests by national government agencies have concluded that once dry, water-based coatings are at least equally durable as solventborne coatings (MPC, 1995).

Issues:

1. Issue: ARB did not receive any comments on this category. There are no known unresolved issues with this category.

REFERENCES

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Example Low-VOC Coatings for Aggressive Exterior Exposure: Sherwin-Williams Centurion (also known as Poly-Dura-Thane) (66 g/l), Dupont Imron 230ZV (0 g/l), Ameron PSX 700 (120-204 g/l), Ameron Dimetcote 21-5 (0 g/l), Ameron Amercoat 220 (180 g/l), MAB Paints & Coatings Ply-Mastic Epoxy Coating (90 g/l), Envirocoat AST D45+ (212-229 g/l).

Example Low-VOC Coatings for Tank Linings: Advanced Polymer Sciences Siloxirane 2031 (108 g/l), Advanced Polymer Sciences Siloxirane 2032 (108 g/l), Coatings Resource Corp. CR-26 (0 g/l), and Coatings Resource Corp. CR-27 (0 g/l).

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