APPENDIX B 

Emission Reduction Analysis For 

Amendments to Rule 4601 

December 17, 2009 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis December 17, 2009 

B-2 Final Staff Report with Appendices For 

Amendments to Rule 4601

This page intentionally blank. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis December 17, 2009 

B-3 Final Staff Report with Appendices For 

Amendments to Rule 4601

I. SUMMARY 

This appendix identifies the volatile organic compound (VOC) emission reductions for 

revised proposed amendments to Rule 4601 (Architectural Coatings). These estimates 

are based on the best available information at the time that this report was written. 

Emission reduction data was taken from the ARB SCM Staff Report. That data is used for 

this emission reduction analysis. 

The 2012 VOC emission inventory baseline is 9.7 tons per day (tpd) for Architectural 

Coatings. The District has committed to achieve a reduction of 2.0 tpd (21%) of VOC 

emissions in 2012. The 2004 VOC emission inventory for the San Joaquin Valley Air 

Basin (SJVAB) was 9.31 tpd. 

VOC emission reductions due to the revised proposed amendments are estimated to be 

2.7 tpd, a 29% reduction from the 2004 emission inventory. When the 2004 emission 

inventory reductions (29%) are applied to the 2012 baseline emissions of 9.7 tpd, the 

equivalent reduction is 2.8 tpd. This rule-amending project exceeds the Plan 

commitment by 0.8 tpd VOC. Table 1 below illustrates the future predicted emission 

reductions based on this rule-amending project. 

Table 1 Future Emission Reductions (tons per day)

Pollutant 2012 2014 2017 2020 2023 

VOC 2.8 3.0 3.0 3.2 3.2 

 

II. BACKGROUND 

Total emissions from architectural coatings and associated materials represent almost ten 

percent of the total VOC emissions from stationary and area sources, and almost five 

percent of all VOC emissions statewide. District staff is proposing to increase the 

stringency of current VOC requirements to reduce VOC emissions for architectural 

coatings. The proposed VOC limits are illustrated in Table 2. The majority of the 

proposed VOC limits were taken directly from the Air Resources Board (ARB) suggested 

control measure (SCM). 

Manufacturers of architectural coatings would comply with the proposed VOC limits by 

reformulating their products to replace some of the VOCs with water or exempt 

compounds or increasing the amount of resin and pigmented solids contained in the 

coatings. However, many of the coating products already comply with the VOC limits 

and, therefore, no reformulation would be necessary. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis December 17, 2009 

B-4 Final Staff Report with Appendices For 

Amendments to Rule 4601

Table 2 Proposed VOC limits for Architectural Coatings 

Proposed VOC Limit (g/l) 

Coating Category Effective Date 1/1/2011 Effective Date 1/1/2012 

Aluminum Roof 400 

Basement Specialty Coatings 400 

Bituminous Roof Coatings 50 

Bituminous Roof Primers 350 

Bond Breakers 350 

Concrete Curing Compounds 350 

Concrete/Masonry Sealer 100 

Driveway Sealer 50 

Dry Fog Coatings 150 

Faux Finishing Coatings 350 

Fire Resistive Coatings 350 

Flat Coatings 50 

Floor Coatings 100 

Form-Release Compounds 250 

Graphic Arts Coatings (Sign Paints) 500 

High Temperature Coatings 420 

Industrial Maintenance Coatings 250 

Low Solids Coatings 120 

Magnesite Cement Coatings 450 

Mastic Texture Coatings 100 

Metallic Pigmented Coatings 500 

Multi-Color Coatings 250 

Nonflat Coatings 100 

Nonflat - High Gloss Coatings 150 

Pre-Treatment Wash Primer 420 

Primers, Sealers, and Undercoaters 100 

Reactive Penetrating Sealer 350 

Recycled 250 

Roof 50 

Rust Preventative 250 

Shellacs: 

• Clear 730 

• Opaque 550 

Specialty Primers, Sealers, and Undercoaters 100 

Stains 250 

Stone Consolidant 450 

Swimming Pool Coatings 340 

Traffic Marking 100 

Tub and Tile Refinish 420 

Waterproofing Membranes 250 

Wood Coatings 275 

Wood Preservatives 350 

Zinc-Rich Primer 340 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis December 17, 2009 

B-5 Final Staff Report with Appendices For 

Amendments to Rule 4601

III. EMISSION REDUCTION ANALYSIS 

Emission reductions are the difference between the current emissions claimed for this 

rule project minus the emissions after rule implementation. 

Emission Reduction = Current Emissions – Emissions after Implementation 

A. Suggested Control Measure VOC Limits 

ARB estimated emissions from architectural coatings for the SCM using data from the 

2004 surveys of architectural coating sales in California as the baseline. The baseline 

is 95 tons per day (tpd) VOC statewide. ARB apportioned the emission inventory to air 

districts based on population. This total does not include VOC emissions from cleanup 

solvents, thinners, or additives. 

The SCM is intended for districts outside of the SCAQMD. As such, ARB estimated 

emission reductions excluding data from SCAQMD. California air districts outside of 

SCAQMD represent 56% of the state’s population, which equates to 53 tpd of VOC 

emissions, including emissions from small containers. Expected VOC emission reductions 

are 15.2 tpd, this represents a 28% overall emission reduction. VOC emissions from 

cleanup solvents, thinners, or additives are not accounted for in this analysis. Table 3 lists 

coating categories and corresponding VOC limits and emission reductions for large 

containers. Rule language provides for an exemption for small containers, therefore 

emissions from small containers were not included in the table. Because of the small 

container emission omission, the table shows an emission inventory of 47 tpd instead of 

the 53 tpd. Although there are emission reductions from 19 categories, 95 percent of the 

emission reductions are from nine categories, which account for 80% of the VOC 

emissions. 

The information presented in Table 3 is a summary of the emission reduction calculations 

performed by ARB. In performing the calculations ARB assumed there would be no 

difference in the amount of coatings used or purchased as a result of reformulation. 

Conservative estimates based on the VOC limits and sales data were made. Also, ARB’s 

calculations did not reflect the coatings used in the averaging program with higher VOC 

content limits, nor the coatings with lower VOC content limits, than the 2000 ARB SCM for 

architectural coatings. For further detail or explanation of the calculations used to create 

Table 3, please refer to Appendix E of the technical support document for the proposed 

amendments to the suggested control measure for architectural coatings. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis December 17, 2009 

B-6 Final Staff Report with Appendices For 

Amendments to Rule 4601

Table 3 Statewide (excluding SCAQMD) SCM VOC Emission Reductions 

by Product Category (Large containers only.) 

 

Existing 

VOC Limit 

(g/l) 

Proposed 

VOC Limit 

(g/l) 

Emissions 

in 2004 

(tpd) 

Emission 

Reductions 

(tpd) 

Aluminum Roof 500 400 1.1 0.19 

Basement Specialty Coatings 400 400 0.1 0 

Bituminous Roof Coatings 300 50 0.23 0.17 

Bituminous Roof Primers 350 350 0.13 0 

Bond Breakers 350 350 0.09 0 

Concrete Curing Compounds 350 350 0.25 0 

Concrete/Masonry Sealer 250-400 100 1.12 0.54 

Driveway Sealer 100 50 0.02 0 

Dry Fog Coatings 400 150 0.46 0.31 

Faux Finishing Coatings 350 350 0.11 0 

Fire Resistive Coatings 350 350 0.01 0 

Flat Coatings 100 50 7.59 3.12 

Floor Coatings 250 100 0.39 0.07 

Form-Release Compounds 250 250 0.45 0 

Graphic Arts Coatings (Sign Paints) 500 500 0 0 

High Temperature Coatings 420 420 0.02 0 

Industrial Maintenance Coatings 250 250 2.34 0 

Low Solids Coatings 120 120 0.02 0 

Magnesite Cement Coatings 450 450 0.05 0 

Mastic Texture Coatings 300 100 0.29 0.1 

Metallic Pigmented Coatings 500 500 0.05 0 

Multi-Color Coatings 250 250 0 0 

Nonflat Coatings 150 100 10.42 2.77 

Nonflat - High Gloss Coatings 250 150 3 0.91 

Pre-Treatment Wash Primer 420 420 0 0 

Primers, Sealers, and Undercoaters 200 100 3.98 1.12 

Reactive Penetrating Sealer 250-400 350 0.01 0 

Recycled 250 250 0 0 

Roof 250 50 0.22 0.07 

Rust Preventative 400 250 3.44 1.57 

Shellacs - Clear 730 730 0.14 0 

Shellacs - Opaque 550 550 0.44 0 

Specialty Primers, Sealers, and Undercoaters 350 100 3.4 2.62 

Stains 250 250 2.14 0 

Stone Consolidant 100-400 450 0 0 

Swimming Pool Coatings 340 340 0.03 0 

Traffic Marking 150 100 0.93 0.09 

Tub and Tile Refinish 100-250 420 0 0 

Waterproofing Membranes 250-400 250 0.65 0.09 

Wood Coatings 250-680 275 3.52 1.41 

Wood Preservatives 350 350 0.32 0 

Zinc-Rich Primer 500 340 0.04 0.01 

 Total: 47.4 15.2 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis December 17, 2009 

B-7 Final Staff Report with Appendices For 

Amendments to Rule 4601

ARB estimated reductions for individual districts by using district population 

percentages. The SJVAB accounts for 9.8% of California’s population. 

ARB calculated the tons per day of VOC emission reductions using the following 

methodology: 

1. Determine the baseline emission inventory for the SJVAB 

Multiply the percentage of California population in the SJVAB with the tpd of 

statewide VOC emissions from architectural coatings. The SJVAB accounts for 

9.8% of California’s population. VOC emissions in California from architectural 

coatings are 95 tpd. 

9.8% x 95 tpd = 9.31 tpd 

2. Determine SIP commitment for VOC emission reductions in tons per day 

Multiply the emission inventory from step 1 with the SIP commitment percentage 

(21%) 

9.31tpd x 21% = 1.96 tpd 

3. Calculate the percent of total SCM VOC emission reductions in the SJVAB 

Divide the percent of California’s population in the SJVAB, from step 1, by the 

non-SCAQMD portion of the state population (56%). 

9.8% ÷ 56% = 17.5% 

4. Calculate the reductions of VOC emissions from SCM limits 

Multiply the percentage of total SCM VOC emission reductions in the SJVAB, 

from step 3, with the reductions apportioned to the non-SCAQMD districts (15.2 

tpd, from Table 3). 

17.50 % x 15.2 tpd = 2.66 tpd 

5. Calculate the percent reduction of VOC emission using the SCM limits 

 Divide the VOC reductions, from step 4, by the baseline emission inventory, from 

 step 1. 

2.66 tpd / 9.31 tpd = 29% 

6. To evaluate consistency with the District’s SIP commitment the 29% is 

applied to the architectural coating SIP inventory 

29% x 9.7 tpd = 2.8 tpd
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis December 17, 2009 

B-8 Final Staff Report with Appendices For 

Amendments to Rule 4601

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