## APPENDIX B

Emission Reduction Analysis For Amendments to Rule 4601

December 17, 2009SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 DI STRICT

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 compo und (VOC) emission reductions for revised proposed amendments to Rule 4601 (Architect ural 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 ton s 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 inv entory. 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-amendin g project exceeds the Plan commitment by 0.8 tpd VOC. Table 1 below illustrat es 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 ass ociated 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 s taff is proposing to increase the stringency of current VOC requirements to reduce VO C 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 Ai r Resources Board (ARB) suggested control measure (SCM).

Manufacturers of architectural coatings would compl y 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 pig mented solids contained in the coatings. However, many of the coating products al ready comply with the VOC limits and, therefore, no reformulation would be necessary

.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 Coat ings 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 340SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 impleme ntation.

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 Cali fornia as the baseline. The baseline is 95 tons per day (tpd) VOC statewide. ARB apport ioned 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 SC AQMD. As such, ARB estimated emission reductions excluding data from SCAQMD. Ca lifornia air districts outside of SCAQMD represent 56% of the state’s population, whi ch equates to 53 tpd of VOC emissions, including emissions from small container s. Expected VOC emission reductions are 15.2 tpd, this represents a 28% overall emissio n reduction. VOC emissions from cleanup solvents, thinners, or additives are not ac counted for in this analysis. Table 3 lists coating categories and corresponding VOC limits and emission reductions for large containers. Rule language provides for an exemptio n for small containers, therefore emissions from small containers were not included i n the table. Because of the small container emission omission, the table shows an emi ssion 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 o f the emission reduction calculations performed by ARB. In performing the calculations A RB assumed there would be no difference in the amount of coatings used or purcha sed 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 t he averaging program with higher VOC content limits, nor the coatings with lower VOC con tent limits, than the 2000 ARB SCM for architectural coatings. For further detail or expl anation of the calculations used to create Table 3, please refer to Appendix E of the technica l support document for the proposed amendments to the suggested control measure for arc hitectural coatings.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 Emis sion 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 1.1 2 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 10 0 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 15.2SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 b y using district population percentages. The SJVAB accounts for 9.8% of Califo rnia’s population.

ARB calculated the tons per day of VOC emission red uctions using the following methodology:

1. Determine the baseline emission inventory for th e 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 reduct ions in tons per day Multiply the emission inventory from step 1 with th e 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 th e 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 S CM limits Multiply the percentage of total SCM VOC emission r eductions 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 bas eline 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 tpdSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis December 17, 2009

B-8 Final Staff Report with Appendices For
Amendments to Rule 4601 This page intentionally blank.