Staff Report

– Feather River AQMD

Rule 3.19

- Vehicle And Mobile Coating Operations

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- 19Rpt 6/1/98

Proposed Rule 3.19, Vehicle and Mobile Equipment Coating Operations

Date Of Release June 1, 1998

Date of Board Consideration: July 6, 1998

Executive Summary
The California Air resources Board and the Federal Environmental Protection Age ncy have promulgated health

- based Ambient Air Quality Standards for photochemical oxidants, commonly referred to as ozone or smog

. Volatile organic compounds are precursors to and react to form ozone in the atmosphere

. The Feather River Air Quality Manag ement District (FRAQMD) includes Y uba and Sutter Counties and is part of the Northern Sacramento Valley Air Basin (NSVAB) which has been designated moderate

non

- attainment for the health

- based California Ambient Air Quality Standard for ozone

. The Califo rnia Clean Air Act (CCAA) of 1988 mandates that non

- attainment area development a plan to achieve attainment of the CCAA standards "at the earliest practical date. ” The Northern Sacramento Valley Basin Coordinating Council, of which the FRAQMD is a membe r, developed an Air Quality Plan in response to this mandate in 1991 (subsequently updated in 1994 and 1997 )

. Potential emissions from automobile finish coatings were identified as a source of volatile organic compounds for which

reasonable emissions controls exist

. Rule 3.19, Vehicle And Mobile Coating Operations, is proposed to reduce the emissions of reactive organic compounds from vehicle and mobile coating operations.

1.0 PURPOSE The purpose of Proposed rule 3.19 is to reduce ambient ozone levels by contro lling volatile organic compound (VOC) emissions into the atmosphere from the coatings and solvents used in automotive and mobile equipment refinishing

. Ambient ozone is formed from the combination of reactive organic compounds (evaporative type emissions a ssociated with petroleum based compound products) with oxides of nitrogen (combustion related compounds) in the presence of sunlight

. The basic control strategy is to inventory the precursor compounds (i.e., reactive organic compounds, and oxides of nitrogen) and then seek cost

- effective emission reductions from sources of these emissions

. By reducing the precursors, the resultant ozone product is reduced, bringing the area into compliance with the health

- based State and Federal ambient air quality standar

ds.

2. BACKGROUND The California Clean Air Act (CCAA) of 1988 mandates that a non

- attainment areas development a plan to achieve attainment of the CCAA standards "at the earliest practical date."

The Valley Air Basin (NSVAB) is consider ed to be a moderate non

- attainment area for the California Ambient Air Quality Standard for ozone. The Northern Sacramento Valley developed an Air Quality Plan in response to this mandate in 1991 and updated this plan in 1994 and 1997.

.Staff Report

Rule 3.19

- Vehicle And Mobile Coating Operations

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- 19Rpt 6/1/98 2 Automobile finish coatings w as included in the 1991 attainment plant for the Northern Sacramento Valley Air Basin and again included in the revised 1994 and 1997 attainment plan s in Table VI

- 1, "List of Feasible Measures for Stationary Sources" as a reactive organic gas (ROG) control measure. This measure was to be proposed and implemented by applicable Districts no later than July 1, 1996.

This draft rule is based on the “California Clean Air Act Guidance, Determination of Reasonable Available Control Technology and Best Available Retrofit C ontrol Technology (RACT , BART)

For Automotive Refinishing Operations” guideline document (dated January 8, 1991), from the

Draft “National Volatile Organic Compound Emission Standards for Consumer and Commercial Products”; Subpart E

-- National Volatile O rganic Compound Emission Standards for Automobile Refinish Coatings, and from rules other Districts have adopted for this category.

3.0 APPLICABILITY This rule applies to any person who supplies, sells, offers for sale, applies, or specifies the use of

c oatings for vehicles, mobile equipment and their parts or components.

4.0 STANDARDS This rule does the following:

Contains a prohibition from manufacturing, soliciting, requiring for use, specifying, or selling, any coatings not meeting the limits of V OC content expressed in the rule.

Limits the VOC content of the coatings listed with respect to the type of coating and whether the application of the coating required a color match.

Includes an add on control equipment provision in the rule allows for t he use of coatings that do not meet the requirements of the rule, provided that the overall control system efficiency is not less than 85 percent.

Inc ludes housekeeping procedures and limits for the VOC content of surface preparation and cleanup materials

.

Specifies the use of spray application equipment with a transfer efficiency of at least 65

percent.

Specifies the use of an enclosed gun cleaner or a low emissions spray gun cleaner for spray equipment cleaning.

Requires that coating of an entire ve hicle be performed in a spray booth.Staff Report

Rule 3.19

- Vehicle And Mobile Coating Operations

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- 19Rpt 6/1/98 3 5.0 EXEMPTIONS Coatings in hand

- held non

- refillable aerosol containers and non

- aerosol containers with a capacity of 16 fluid ounces or less are exempt from the rule.

The application of logos, letters, numbers, and graphics to a painted surface is exempt from the

rule.

Any coating operation of a vehicle or mobile equipment by a resident of a one or two family dwelling is exempt provided the resident is the registered owner, is not being conducted as a business, limi ted to two vehicles per year, and does not cause a public nuisance.

Exemption from the spray booth and prep station requirement is allowed with prior approval from the APCO for vehicles which, due to the shape or size, cannot reasonably be contained in

a ny available substitute spray booth.

Exemption from the spray booth and prep station requirement is allowed for touch

- up and repair, or spot priming operations which do not exceed nine (9) square feet per vehicle.

Exemption from the spray booth and prep station requirement is allowed for any weld

- thru primer.

Also proposed is a limited exemption for non

- commercial operations, including agricultural operations and construction vehicles.

6.0 RECORDS AND TEST METHODS The rule requires that a list of current ly used coatings and surface preparation and cleanup materials (e.g., solvents) be maintained along with Material Safety Data Sheets (MSDS).

The rule requires that daily records be maintained with the coating identification, mix ratios, quantity of each c oating applied and whether a color match was required.

The rule requires that manufacturers specification sheets for solvent used for substrate surface cleaning and application equipment cleanup be available for review as well as daily records kept

which identify each solvent and its use, the VOC content of the solvent, and the volume used.

This rule requires that records be maintained for a minimum of two years from the date of each entry and be available to District personnel upon request.

The rule con tains appropriate test methods to determine compliance with the rule requirements for VOC limits and emission control equipment.Staff Report

Rule 3.19

- Vehicle And Mobile Coating Operations

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- 19Rpt 6/1/98 4 7. 0 AVAILABILITY OF C OATINGS AND SOLVENTS Manufacturers have already reformulated and field

- tested surface coatings meeting the requirements of this proposed rule. These coatings are currently available on the market and have been in use in many counties in California for several years. In addition, the limits proposed are those that have been identified in the draft “Nationa l Volatile Organic Compound

Emission Standards for Consumer and Co mmercial Products”; Subpart E

-- National Volatile Organic Compound Emission Standards for Automobile Refinish Coatings. These limits are proposed as national limits and have been researched , and workshopped with paint manufacture r s throughout the United States. The VOC limit for solvents in this proposed rule will not adversely limit the types of solvents currently utilized.

8.0 CONTROL EFFICIENCY

Table VI

- 1, "List of Feasible Measures for Stationary Sources" in the 1994 attainment plan update estimates that an automobile finish coatings measure would provide a 25 percent control efficiency.

9.0 COST IMPACTS The implementation of the rule will require some auto body shop businesses to pu rchase new equipment to stay competitive. Most of these purchases are a one

- time purchase and therefore

should be amortized over a ten

- year lifetime. This equipment may include, but is not limited to, paint booths, heat lamps, fans or room heaters, addit ional booth insulation, HVLP spray guns and tips, and/or enclosed gun cleaners.

The rule may necessitate operators to install heat lamps, fans or room heaters to meet the compliance deadline for the primers/surfacers.

The necessity of a booth is requir ed for all paint application facilities that coat surfaces greater than 9 square feet. This requirement for a booth is also currently mandated by the Uniform Fire Code. Therefore this expense is not expected to be a new cost.

The implementation of this rule will require some shops to purchase HVLP Spray guns. Currently the industry standard has been to use these types of guns because of the savings in paint costs due to the higher transfer efficiencies. However, some shops have not converted all

guns to HVLP's.

The implementation of this rule will require some shops to purchase an enclosed gun cleaner. Currently most shops are equipped with these gun cleaners to ease in gun cleanup.Staff Report

Rule 3.19

- Vehicle And Mobile Coating Operations

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- 19Rpt 6/1/98 5 Additionally, extra costs may be incurred while users of the new co atings become familiar with their application. More care may be required for training on how to mix, apply, and cure the newer coating systems. However, these costs are expected to be minimal and would have occurred anyway with the adoption of the nationa l standards.

Some facilities may not be affected by this rule. For example, some facilities are currently using

low

- VOC coatings and applying those coatings using HVLP guns in heated booths and clean their guns with enclosed gun cleaners.

Acti vity Capital Costs

Spray Booths: $60,000

- $100,000 Spray Guns (HVLP): Typical cost $450

- $500 but can go as high as $1,200 Spray Gun Tips: $200 per tip

Enclosed Gun Cleaner: $1000

- $2000 Portable Heat Lamp: $1500 per infrared lamp

Low VOC Coat ings: The cost differential between these and conventional coatings may be recuperated from material savings due to HVLP guns

10. COST EFFECTIVEN ESS

Table VI

- 2 in the 1994 attainment plan lists the automobile finishes coatings control measure at $2,000 per ton as being cost effective. The ARB RACT/BARCT guideline document states that the cost effectiveness for implementing RACT/BARCT is $2

- $2.25 per pound of VOC reduced ($4,000

- $4,500 per ton). However, this rule does not implement all BARCT implemen tation

measures and VOC limits

. It is expected that the actual cost effectiveness will vary since many facilities currently have the equipment on hand or will only need to purchase a portable heat lamp.

For example, if a facility purchases two heat lamps, an enclosed gun cleaner, three HVLP Spray guns and tips, then costs are:

(2) Heat Lamps: $3,000 (1) Enclosed Gun Cleaner: $1,500 (3) HVLP Spray Guns & Tips: $2,100

---------------------------------------------------- Total: $6,600

Assuming a 25 % emissions decrease from the implementation of the rule then: 72.5 Tons/year x .25 reduction = 18.125 tons/year of VOC emission decrease that could be expected in the NSVAB (see table below).Staff Report

Rule 3.19

- Vehicle And Mobile Coating Operations

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- 19Rpt 6/1/98 6 If 1/4 of the sources are required to purchase all of the ab ove equipment , then the cost per ton

of VOC reduced is 115 sources/ 4 = 29 sources

. 29 sources x $6,600 = $ 191,400 if 18.125 tons

of VOC reduced

, then = $10,560/ton reduced

.

If 1/4 of the sources are required to purchase only the heat lamps
, then t he cost per ton of VOC

reduced is: 29 sour ces x $3,000 = $87,000 if 18.125 tons of VOC reduced , then = $4,800/ton

reduced

.

Please note, these estimates are not amortized and therefore are over

- estimates when compared to a 10 year operation lifetime of the equipme nt.

It is not expected that any facility will choose to use add

- on control equipment in order to utilize coatings not meeting the VOC limits of the rule.

11.0 EMISSIONS INVENTORY A survey of the number of auto body refinish shops and other companies that refinish mobile equipment is included below by District. The actual number of facilities and emissions are expected to be greater due to the lack of facilities currently in the permit system and the unknown number sources that refinish mobile equipm ent:

County: No of Permitted

Facilities Total VOC Emissions (Tons)

Butte County AQMD 35 35.00 (1)

Colusa County APCD 8 4.11 (2)

Feather River AQMD 2 3.00 (3)

Glenn County APCD 0 unknown (4)

Shasta County AQMD 61 17.46 (5)

Tehama County APCD 9 12.93 (1)

Total: 115 72.5

(1) From auto body facilities only (2) All known sources (3) Emissions based on two permitted sources expect 16 more will obtain a permit (4) No sources permitted, no emissions data available (5) 199 4 emissions inventory. Emissions from insignificant sources (sources less than 0.5 tons) are not included. Emission total is from 29 of the 61 known sources.