BOARD MEETING DATE: December 4, 2009
AGENDA NO. 38
PROPOSAL:
Amend Rule 1145 – Plastic, Rubber, Leather and Glass Coatings
SYNOPSIS:
The proposed amendment would, in part, implement control measure MCS-07 – Application of All Feasible Measures of the 2007 AQMP by aligning the current VOC limit for the multi-color category with the VOC limit recommended in U.S. EPA Control Techniques Guidelines. A new coating category is recommended for addition to the table of standards for coating glass panels used in refrigerated glass door assemblies. Other minor clarifications and corrections
(e.g. numbering) are also proposed.
COMMITTEE:
Stationary Source, July 24, 2009, and October 16, 2009, Reviewed
RECOMMENDED ACTIONS:
Adopt the resolution:
- Certifying the Final Environmental Assessment (EA) for Proposed Amended Rule 1145 – Plastic, Rubber, Leather and Glass Coatings; and
- Amending Rule 1145 - Plastic, Rubber, Leather and Glass Coatings.
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Rule 1145 was originally adopted by the Governing Board on July 8, 1983 and has undergone fifteen subsequent amendments. AQMD staff found that the September 2008 U.S. EPA Control Techniques Guidelines (“CTG”) recommended a maximum Volatile Organic Compound (“VOC”) limit of 680 grams per liter (“g/L”) for the multi-color coating category which is slightly lower than the current VOC limit of 685 grams per liter for the multi-color coating category in Rule 1145. This amendment proposes to bring the current rule VOC limit in line with the September 2008 CTG recommended VOC limit.
AQMD staff has been working with a refrigeration cabinet glass door manufacturer since February 2008 in search of an alternate low-VOC coating to replace the existing performance coating. The manufacturer (“facility”) has a niche coating operation that does not meet the current VOC limits in Rule 1145 for a two-component coating and consequently has been operating under a two-year variance that will expire on December 31, 2009. AQMD staff has found through research of SIC codes that the manufacturer is the only facility in the AQMD jurisdiction that manufactures refrigerated glass doors using this niche coating operation.
The facility currently hand roll-coats a one-inch wide border, measured from the edge and wrapping all the way around the perimeter of the glass panel during the manufacturing of their refrigerated glass doors. The coating must adhere to the glass substrate primarily because the coating will become the substrate for the spacer and the sealant that will seal the glass panels together. The glass doors are manufactured using three glass panels per door assembly and are assembled in a sandwich-like configuration. If the coating fails, the seal will fail and the refrigerated glass door assembly will be rejected by the customer and will have to be replaced under warranty. The manufacturer has not found a suitable low-VOC coating that could meet their performance requirements and be compliant with the two-component coating category currently limited at 120 g/L VOC in Rule 1145, despite having tried several coating technologies as required by the increments of progress contained in their variance. AQMD staff proposes a new coating category, Refrigerated Glass Door (“RGD”) coatings, which would allow the manufacturer to continue to operate their niche coating operations in compliance after their variance expires.
Prior to the roll-coating operation, the facility employed a silk-screening process which also required constant screen clean-up both during the screening operation and for the end-of-the-day screen clean-up. The manufacturer complied with the silk-screening operation under the requirements of Rule 1130.1 –Screen Printing Operations which currently allows for a 600 g/L maximum VOC limit for glass surface coatings. The facility realized that the silk-screening operation required an excess amount of coating as well as cleaning solvent required to clean the screens. The manufacturer applied for and obtained a variance to convert the coating operation over to a much simpler hand roll-coating operation which no longer required any further screen cleaning exercises. The hand roll-coating operation reduced the facility’s overall VOC emissions since the screen clean-up was no longer needed. The facility was required to obtain the variance because the hand roll-coating operation no longer fell under the purview of Rule 1130.1 but instead fell under the purview of Rule 1145 and into the general two-component coating category that currently has a maximum VOC limit of 120 g/L.
Public Process
A public workshop was held on June 25, 2009 to discuss the proposed amendments to Rule 1145. One comment was made during the public workshop and four additional comment letters were submitted after the public workshop but before the comment period deadline ending on July 8, 2009. There were two more e-mail comment communications submitted after the close of the comment period. The comments from the public workshop, the four comment letters and the e-mailed comment communications are presented in the staff report under the comments and responses section.
A Stationary Source Committee meeting was held on July 24, 2009 where AQMD staff presented the proposed amendments for Rule 1145. There were three members of the UV coating industry that commented that a UV coating could meet the facility’s performance requirements for their refrigerated glass door coatings despite the recent unacceptable adhesion results. A representative of the facility commented that UV coatings were tested in the past but did not meet their performance requirements for refrigerated glass door coatings. The Stationary Source Committee recommended one last final test using the UV coatings to determine a final disposition for UV technology for this niche operation.
AQMD contracted with an independent third-party tester who performed the adhesion by tape test for all of the glass sample panels (see Technical Assessment section of this Board Letter for further details). The end result of the final testing revealed that while the adhesion characteristics exhibited by the UV coatings would be acceptable in most other applications for this niche coating process, 86% of the UV coated substrates tested did not meet the facility’s performance specification of 100% adhesion, as compared to the epoxy coatings that met the 100% adhesion.
A second Stationary Source Committee meeting was held on October 16, 2009 where AQMD staff presented the results of the third-party tester and responded to further complaints from the UV coating industry that it had not been aware of the refrigerated glass door manufacturer’s coating performance specifications until a few days prior to the October 16 meeting. However, the refrigerated glass door manufacturer had e-mailed its performance specifications to the UV coating facility on August 5, over two months before the SSC meeting. On August 19, the UV coating facility acknowledged receipt of these performance specifications and approved them, sending a copy of its approval to the UV industry. As a result, AQMD staff recommends moving forward with the original proposal.
Technical Assessment
Following the Stationary Source Committee recommendation in July, AQMD staff contracted a third-party tester to conduct adhesion by tape pull-off tests in accordance with ASTM D 3359-97, the test method used to measure adhesion by tape, for all the coated glass sample panels. This is the same test method that the manufacturer has been using for several years to determine the degree of adhesion of their epoxy ink coatings as well as the alternate low-VOC coatings they tested. The facility considers any detachment; including flaking on the cuts, or ragged cut edges, as unacceptable adhesion quality. The UV and epoxy ink coated glass sample panels were divided into quadrants so four separate adhesion by tape pull-off tests could be performed on each glass sample panel. The third-party tester ran three series of adhesion by tape pull-off tests and these are discussed as follows.
Series 1 was for one sample glass panel coated with a UV coating. The facility shipped the UV coater six glass sample panels to be UV coated with only one UV coated panel sent to AQMD. AQMD staff provided this sample glass panel to the third-party tester in the unopened shipping cardboard container it came in. The results for all four adhesion by tape pull-off tests showed a 5B rating for each quadrant tested. The 5B rating means that no material was pulled up by the tape, the grade lines were sharp and crisp and the test met the performance requirement set by the facility’s adhesion performance needs.
Series 2 was for six sample glass panels coated with a UV coating and was essentially part of the first series of testing after the facility expressed concerns that only one UV coated glass sample panel was returned out of the six that were submitted. For the Series 2 testing, the UV coater requested that the facility ship them another twelve sample glass panels and the facility shipped the UV coater twelve glass sample panels to be UV coated however, six UV coated panels were sent to AQMD. AQMD staff provided these sample glass panels to the third-party tester in the unopened wooden shipping crate they came in. The results for all twenty-four adhesion by tape pull-off tests showed a 3B rating for each quadrant tested. Based on the facility’s performance specifications of 100% adhesion, 3B rating is unacceptable.
Series 3 was for five sample glass panels coated with the facility’s current epoxy ink. This test was performed as a result of a meeting held between AQMD staff and the facility’s staff. Both parties agreed to test the adhesion on the existing epoxy ink coating that the facility is currently using. The facility provided five epoxy ink coated sample glass panels to AQMD. AQMD staff provided these sample glass panels to the third-party tester in the unopened wooden shipping crate they came in. This adhesion by tape pull-off test was conducted using the same ASTM D 3359-97 test method and third-party tester used for Series 1 and 2. The results for all twenty adhesion by tape pull-off tests showed a 5B rating for each quadrant tested. The 5B rating means that no material was pulled up by the tape and the grade lines were sharp and crisp deeming all the test results as acceptable.
AQMD staff concluded from this technical assessment that the facility’s existing epoxy ink coating showed better adhesion performance based on the number of the tested areas that showed acceptable adhesion results. The UV coating test results for this particular niche coating process revealed that 86% of the UV coated substrates tested did not have acceptable adhesion. While they would be acceptable in most other applications, it does not meet the facility’s performance specification of 100% adhesion, which is met by the epoxy coatings that it is now using.
Proposal
The proposed amendments to Rule 1145 are designed to: (1) revise the VOC limit for the multi-color coatings category and bring it in line with the September 2008 U.S. EPA Control Techniques Guidelines, (2) establish a new coating category for a niche manufacturing process related to the manufacture of refrigerated glass doors for refrigeration cabinets, for which a compliant product is currently not available, (3) update the rule with the deletion of paragraph (c)(3), that refers to automotive coatings use which is now covered under Rule 1151 and, therefore no longer necessary, and (4) make minor clarifications and editorial corrections to the rule.
Impact Assessment
The total emissions for this proposed rule amendment can be calculated by combining the emissions benefit from the multi-color coating category of 0.4 lbs/day and adding them to the forgone emissions of the new refrigerated glass door coatings of 2.1 lbs/day, resulting in a combined 1.7 lbs/day of emissions forgone. It should also be noted, however, that when the facility eliminated the silk-screening process they no longer operated under Rule 1130.1 which allowed for a much higher VOC coating limit (the current VOC limit for glass surfaces is 600 g/L). In addition, there was no longer a need to clean the screens with solvent thus providing an additional emission benefit (the facility used two 55 gallon drums of solvent per year for screen cleaning). There is no expected cost increase associated with the reduction of the VOC limit for the multi-color coating category or the addition of a new refrigerated glass door coatings category.
AQMP and Legal Matters
The proposed amendment would, in part, implement control measure MCS-07-Application of All Feasible Measures of the 2007 Air Quality Management Plan. As a result, a comparative analysis is required by the California Health and Safety Code Section 40727.2 and is discussed in the staff report.
California Environmental Quality Act (CEQA)
Pursuant to California Environmental Quality Act (CEQA) Guidelines section 15252 and AQMD Rule 110, the AQMD has prepared an Environmental Assessment (EA) for PAR 1145. The Draft EA was released for a 30-day public review and comment period beginning June 30 and ending July 29, 2009. Three comment letters were received during the public comment period. Comment letters and responses to comments have been prepared and incorporated into the EA, so it is now a final EA.
Socioeconomic Impact Assessment
PAR 1145 would align the VOC limit for the multi-color coatings category with the September 2008 U.S. EPA Control Techniques Guidelines (CTG). No additional costs from such alignment are expected. PAR 1145 would also create a new coating category for refrigerated glass door coatings. This change will provide additional flexibility for one facility with special manufacturing requirements, and has no cost implications. All other changes to the existing rule language are editorial and do not have any associated cost implications.
Because the proposed amendments are not expected to require any installation of emission control devices or coatings reformulations, the rule amendments are not expected to generate any additional expenditure.
Implementation and Resources
Existing AQMD resources will be used to implement Proposed Amended Rule 1145.
Attachments (EXE, 924k)
A. Summary of Proposal
B. Rule Development Process
C. Key Contacts List
D. Resolution
E. Proposed Amended Rule 1145 Language
F. Final Staff Report
G. Final Environmental Assessment