BOARD MEETING DATE: December 5, 2003
AGENDA NO. 28

Annual Status Report and Technology Assessments on Rule 1113 – Architectural Coatings

SYNOPSIS:

At the December 6, 2002 meeting, the Board approved a resolution directing staff to provide a progress report on achieving the 2006 compliance limits and the rule requirement for a technology assessment of lacquer coatings. This report fulfills that directive and provides staff’s recommendation on further addressing the following subjects: (1) meetings with committees; (2) compliance activities associated with implementation; (3) averaging compliance option programs received and reviewed; and (4) additional low- and zero-VOC architectural coating products available. Finally, staff has included a discussion of other technology assessments completed relative to available coatings technologies.

COMMITTEE:

Stationary Source, October 24, 2003, Reviewed

RECOMMENDED ACTION:

Receive and file this report.

Barry R. Wallerstein, D.Env.
Executive Officer

PURPOSE

This report serves three main purposes:

• Fourth annual progress report for implementation of Rule 1113–Architectural Coatings.
   
• Report on progress in producing compliant products with respect to the coating categories subject to the July 1, 2006 limits in the rule.
   
• Technology assessment report on lacquer coatings as required by Rule 1113.

BACKGROUND

The 2003 AQMP indicates that the contribution of VOC emissions from architectural coatings continues to be one of the most significant non-mobile sources attributable to ozone pollution within the District. Based on the report "1997 Annual Average Emissions by Source Category in the South Coast Air Basin," more than 50 tons per day of VOCs are from architectural coatings. The District considers VOC reductions from architectural coatings to be a critical component of its attainment plan.

This report is intended to give the Board an overall perspective as to the performance and acceptability of low- and zero- VOC coatings that are in use today across a wide spectrum of coating substrates and environmental conditions. The report also summarizes meetings with stakeholders and reports on progress in implementing a number of rule-related programs.

FIELD ACTIVITIES

This year’s technology assessment focused on visiting close to 40 locations where low- and zero-VOC products were being applied in manufacturing and insitu architectural settings. Staff asked applicators to comment on performance, ease of application, dry times, cost and appearance of the coatings. Detailed reports have been prepared and made available to the Rule 1113 advisory committee. They are summarized in the 2003 Annual Report. Staff also viewed many previous applications of the same low- and zero-VOC products from several years ago and heard testimony from individuals on how well the coatings are holding up to daily usage. The coatings observed by staff included applications to floors (both wood and concrete), concrete structures, stains on wood, coatings for use on metal, various architectural coatings for homes, parking structures, and many other substrates.

Rule 1136-Technical Assessment

The results of the technical assessment and the industrial progress reports required under Rule 1136 indicate that the technology exists and is in use today in the form of many resin and solvent systems that have less than 275 g/l of VOCs for application to wood substrates. Many of these coatings fall within the proposed clear wood finishes category under Rule 1113 and indicate the ongoing use and reliability of the lower VOC finishes. The complete technology assessment, issued in June 2003, is available for the Board’s review in Appendix D of the Annual Report attached to this letter.

Specific Coating Category Assessments by District Staff

District staff continually evaluates coating products that are commercially available and that meet current and future VOC limits as established in Rule 1113. An analysis of technical data sheets (TDS) and material safety data sheets (MSDS) published by coating manufacturers is one of many methodologies used to complete assessments of available coatings. This list is continually updated as staff reviews additional information on compliant and super compliant architectural coating products that are currently available for the various categories studied.

Lacquers

Contract work completed by AVES in May 1999 to develop and demonstrate super compliant coatings, substantiates staff contentions that replacements for high-VOC clear wood finishes are feasible. Commercially available coating systems (both lacquer and varnish) were tested side-by-side with no-VOC lacquer and varnish topcoat systems for repair and refinishing. This new no-VOC varnish system showed the best overall appearance after repair, but had the highest coating usage because the two-component coating resulted in a limited pot life (period of material-reacting time during which coating can be applied). The new no-VOC lacquer system was the easiest to repair and showed the best gloss after repair. In order to obtain the impartial opinion of experienced painters on the performance of the new coatings, the painters of Commercial Casework, Inc. in Fremont, California conducted a field demonstration of the new coating system as part of this study. The personnel from Commercial Casework were impressed with the new wood coatings due to fast dry time, ease of use, and the safer working environment resulting from the absence of solvents.

District staff’s opinion is that the coatings formulated for this study could readily be applied in typical architectural settings. The final report titled, "Development and Demonstration of Zero- and Low-VOC Resin Technology for Advanced Control Measure Development," issued on March 29, 2001, is included in Appendix C of the Annual Report, attached to this letter, for the Board’s review.

Past and On-going Coating Studies

In this Annual Report, staff has summarized other studies regarding architectural coatings indicating the availability of compliant coatings in the specific categories studied. These categories included wood coating products, industrial maintenance coatings and other general categories such as nonflats, primers, sealers, undercoaters, floor, rust and waterproofing products. The studies demonstrate that low-and-zero VOC coatings are as good, if not better, than the higher VOC counterparts and meet or exceed expected performance coating characteristics. The data was generated from the following studies: USEPA and Midwest Research Institute Case Studies, National Technical Systems, KTA-Tator, Southern California Alliance of Publicly-Owned Treatment Works (SCAP) and Essential Public Service Agencies.

The Essential Public Service Agencies study is scheduled to be completed in 2005. Results of the completed study will be presented to the industry and the Board upon completion.

ROUTINE ACTIVITIES

Averaging Compliance Option (ACO) Plans

The AQMD, working extensively with members of the architectural coatings industry and other stakeholders developed and incorporated an alternative compliance option into Rule 1113, the Averaging Compliance Option (ACO). The purpose of the ACO is to promote compliance flexibility and allow manufacturers additional time to reformulate certain compliant products of their choice. In the November 8, 1996 amendments to Rule 1113, an ACO was included for the Flats category with subsequent amendments on May 14, 1999 designed to streamline its implementation and add categories to provide additional compliance flexibility with the future limits. Initially, the first year that the ACO was made available, there were three manufacturers that submitted plans for the period of June 30, 2001 to July 01, 2002, all of which elected to average flat coatings. Today, there are eight manufacturers that are utilizing the ACO for averaging a variety of coating categories including flats, nonflats, floor, industrial maintenance, primers, sealers, undercoaters, quick-dry primers, quick-dry sealers, quick-dry undercoaters, quick-dry enamels and rust preventative.

Averaging Compliance Option (ACO) Audits

ACO audits for two of the three manufacturers that originally filed plans were conducted and completed by the District for the period of June 30, 2001 to July 01, 2002. District staff is currently in the process of auditing the final manufacturer that had a plan in place during the original time period. The results of the completed audits indicate that the facilities were able to comply with the averaging compliance option in the rule. District staff is committed to initiating audits for the eight manufacturers utilizing the ACO for the most recent period, beginning January 1, 2003, and ending December 31, 2003 during the first quarter of next year.

Meetings

Since last year’s annual report to the Board, the District has continued to have meetings with the Rule 1113 Working Group and Technical Advisory Committee. The following meetings took place during this reporting period:
 

SUMMARY

• Surveys and studies have substantiated that the list of viable compliant and super-compliant coatings continues to grow and share a significantly increasing portion of the architectural coatings market.
   
• The District’s research of technical information (i.e. MSDS, sales data, marketing brochures, etc.) and other sources continues to support staff’s position that there are a substantial number of ultra-low VOC products available that meet future proposed limits.
   
• The compliant coatings are being used and meet or exceed expected performance characteristics for many different substrates in various environmental conditions.

Future Program Activities and Studies

Over the next year, staff will study all coating categories whose limits will have changed with the anticipated December, 2003 amendments to Rule 1113. In addition, the Technical Advisory Committee has asked staff to study several coating categories in more detail to confirm some of the performance conclusions derived from the technology assessments. Working with this committee and other manufacturers, staff has agreed that high-gloss non-flats, clear wood finishes including varnishes and exterior stains applied to horizontal surfaces are good candidates for further study in 2004 and 2005.

In addition to these technology assessments, staff will continue to research the feasibility of further reductions in the VOC content of all architectural coating categories by and through the use of all available resources. Those resources include but are not limited to holding meetings with the Technical Advisory Committee and Working Group members, further evaluation of the 2001 CARB Architectural Coatings Survey, review of results of studies underway by Essential Public Service Agencies on performance of industrial maintenance coatings and continuing field audits and contractor surveys of in-use applications of compliant and super compliant coatings. Additionally, staff will continue to review sources of information on the availability of zero- and low-VOC products as well as working with wood product coating manufacturers to test a variety of coatings for field applications. Staff will also continue to evaluate sales records and field compliance audits of those manufacturers utilizing the averaging compliance option available under the rule.

The next Annual Report will be presented to the Governing Board in December of 2004.

Attachment (10, 828 KB)

1. Annual Status Report and Technology Assessments on Rule 1113-
   Architectural Coatings, December 2003

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