State of California
AIR RESOURCES BOARD

Santa Anita Room
Bonaventure Hotel
Fifth & Figueroa
Los Angeles, CA

June 29, 1978
10:00 a.m.
AGENDA
Page

78-12-1 Consideration of a Proposed Model Rule for the Control 1
of Volatile Organic Compounds from Marine Coating
Operations

78-12-2 Consideration of a Model Rule for the Control of 61
Volatile Organic Compounds from Metal Furniture Coating
Operations

78-12-3 Other Business -
a. Executive Session - Personnel & Litigation
b. Research Proposals

ITEM NO.: 78-12-1

Consideration of a Proposed Model Rule for the Control of
Volatile Organic Compounds from Marine Coating Operations.

RECOMMENDATION

Approve the model rule and direct the staff to transmit it to the
South Coast Air Quality Management District, the Bay Area Air
Pollution Control District, and the San Diego County Air
Pollution Control District for consideration as an amendment to
their rules and regulations.

SUMMARY

The staff of the Air Resources Board has identified the need to
reduce organic emissions from sources in a number of air basins,
where the ambient air quality standard for oxidant has been
exceeded on numerous occasions.

Marine coatings are those coatings applied to boats, ships, and
their appurtenances. A majority of the marine coatings are
applied in shipyards located along California's coast and, for
the most part, in the State's major urban areas (i.e., the South
Coast, San Diego, and the San Francisco Bay Area Air Basins).
The application of marine coatings and the associated use of
solvent for thinning and clean-up generate organic compound
emissions of over ten tons per day.

It has been determined that adequate substitutes for conventional
low-solids marine coatings exist and are commercially available.
High-performance coatings, many of which are higher in solids
content, and substantially more durable and longer lasting than
conventional coatings, are being used by the marine industry.

The high-solids content of high-performance coatings, combined
with an extended coating life results in lower overall emissions
of volatile organic compounds from marine coating operations.
For those coatings exhibiting superior performance properties and
not possessing the technology to attain high solids, a temporary
exemption was included in the proposed rule.

The proposed rule would apply to all marine coatings applied
after January 1, 1982. These coatings would be limited to 295
grams of volatile organic compound per liter of coating as
applied, excluding water. Antifouling coatings, primers
containing phosphoric acid, and those coatings sold in containers
of one gallon or less are exempt from all requirements of this
rule. High-performance coatings, whose levels are currently
lower than the recommended level are given temporary exemptions
until January 1, 1985.

An emission reduction of approximately 3.5 tons per day may be
achieved through compliance with the proposed model rule in 1982.
The cost-effectiveness of the emission control options ranges
from a credit of $1.56 to a cost of $0.93 per pound of emissions
reduced.

Table of Contents

Page

I. Introduction. . . . . . . . . . . . . . . . . . . . . . . .1

II. Conclusions and Recommendations . . . . . . . . . . . . . .3
A. Conclusions. . . . . . . . . . . . . . . . . . . . . .3
B. Recommendation . . . . . . . . . . . . . . . . . . . .5
Proposed Model Rule. . . . . . . . . . . . . . . . . .6

III. Discussion of Model Rule. . . . . . . . . . . . . . . . . .8

IV. Background. . . . . . . . . . . . . . . . . . . . . . . . 11
A. High Performance Coatings. . . . . . . . . . . . . . 11
B. Overview of Industry . . . . . . . . . . . . . . . . 13
1. General . . . . . . . . . . . . . . . . . . . . 13
2. California Shipyards. . . . . . . . . . . . . . 14
3. Port Activity . . . . . . . . . . . . . . . . . 16

V. Emissions . . . . . . . . . . . . . . . . . . . . . . . . 17
A. Industry Survey. . . . . . . . . . . . . . . . . . . 17
B. Emission Estimates . . . . . . . . . . . . . . . . . 19

VI. Existing Technology in the Marine Coatings Industry . . . 20
A. General Discussion . . . . . . . . . . . . . . . . . 20
B. Epoxy Coatings . . . . . . . . . . . . . . . . . . . 22
C. Chlorinated Rubber Coatings. . . . . . . . . . . . . 23
D. Polyurethane Coatings. . . . . . . . . . . . . . . . 24
E. Acrylic Coatings . . . . . . . . . . . . . . . . . . 26
F. Vinyl Coatings . . . . . . . . . . . . . . . . . . . 26
G. Inorganic Zinc Coatings. . . . . . . . . . . . . . . 27
H. Antifouling Coatings . . . . . . . . . . . . . . . . 28

VII. Impacts . . . . . . . . . . . . . . . . . . . . . . . . . 29
A. Emission Reductions. . . . . . . . . . . . . . . . . 29
B. Economic Impact. . . . . . . . . . . . . . . . . . . 31
1. Introduction. . . . . . . . . . . . . . . . . . 31
2. Costs Comparisons . . . . . . . . . . . . . . . 31
3. Cost-Effectiveness Estimates. . . . . . . . . . 35
4. Industry Effects. . . . . . . . . . . . . . . . 39
C. Environmental Impacts. . . . . . . . . . . . . . . . 43
1. Industrial Hygiene. . . . . . . . . . . . . . . 43
2. Energy Impacts. . . . . . . . . . . . . . . . . 44
3. Other Impacts . . . . . . . . . . . . . . . . . 45

ITEM NO.: 78-12-2

RECOMMENDATION

Approve model rule and direct staff to transmit it to the air
pollution control districts in the South Coast, San Francisco Bay
Area, San Joaquin Valley, North Central Coast, South Central
Coast, Sacramento Valley and Southeast Desert Basins for
consideration as an amendment to their rules and regulations.

SUMMARY

The use of solvents for a variety of cleaning and surface coating
operations are the most significant source of organic gas
emissions (primarily hydrocarbons) from non-vehicular sources in
all of California's metropolitan areas. The emission of organic
compounds contributed to both oxidant and aerosol formation in
the ambient air. Approximately 2 percent of all solvent related
emissions in California's urban areas are associated with the
painting of metal furniture and fixtures.

The staff estimates that there are approximately 144 metal
furniture and fixture manufacturers in California who coat their
products. Some additional coating is performed at job shops for
those manufacturers who do not conduct their own coating
operations.

Metal furniture and fixtures include metal products intended for
both home and institutional use such as:

Household Furniture Drapery Hardware
Office Furniture File Cabinets
Partitions Lamps
Waste Baskets Shelving
Lockers Beds

These articles are coated to prevent corrosion and to enhance
appearance.

Total emissions from sources in this category amount to slightly
more than fourteen tons per day in the state.

Coatings used in this source category generally contain about 75%
organic solvent, almost all of which evaporates as the coating
dries.

The staff proposes that emissions from these coating operations
be reduced initially in two ways, both of which are commercially
available and are being used in some coating operations.

The first method is to require the use of Low-solvent coatings,
approximately 30% solvent. These are available as waterborne
coatings, high-solids coatings, and powder coatings. The staff
has observed successful production uses of both waterborne and
powder coatings. The staff has observed successful production
uses of both waterborne and powder coatings. These operations
are described later in this report. High-solids coatings are
reported to be used in production in other parts of the U.S., but
not in California.

The second method is to require the use of electrostatic
application equipment for spray painting operations. The
advantage of this equipment is that it has high transfer
efficiency; that is, most of the coating that is sprayed is
electrically attracted to the object being coated. As a result,
there is less overspray, less coating wasted, and less emissions.
Electrostatic spray equipment can be used with all types of low
solvent coatings.

An additional step to reduce emissions even further is also
proposed. This second step would require the use of extremely
low-solvent type coatings, that is powder coatings or equivalent
low emission coatings. Although these coatings are available,
the costs associated with their use may be higher than for
waterborne or higher-solids coatings. To alleviate any potential
adverse impacts, a long lead-time is proposed prior to
implementation of this step.

Staff investigation has revealed that there are several reasons
to regulate metal furniture and fixture emissions. First,
technology is available which can result in a substantial
emission reduction, exceeding 80% of the twelve tons per day of
organic emissions from the furniture and fixture coating
category. Second, 75 percent of these emissions are in the South
Coast Air Basin, the area which has the state's most serious air
quality problem. Third, the cost of achieving the emission
reduction may be very low, and in some cases will be less than
maintaining present coating operations. For waterborne and high-solids
coatings, the cost of emissions reduced ranges from a
credit of $.64 per pound to a cost of $.31 per pound. Fourth, a
substantial savings in energy consumption can be realized,
equivalent to approximately 50,000 barrels of fuel oil per year.

Table of Contents

Page

I. Introduction. . . . . . . . . . . . . . . . . . . . . . . .1

II. Conclusions and Recommendations . . . . . . . . . . . . . .2
A. Conclusions. . . . . . . . . . . . . . . . . . . . . .2
B. Recommendations. . . . . . . . . . . . . . . . . . . .6

III. Background. . . . . . . . . . . . . . . . . . . . . . . . 10

IV. Emission Estimates. . . . . . . . . . . . . . . . . . . . 12
A. Total Emissions. . . . . . . . . . . . . . . . . . . 12
B. Potential Emission Reduction . . . . . . . . . . . . 13

V. Applicable Systems of Emission Reduction. . . . . . . . . 16
A. Low-Solvent Coatings
1. Powder. . . . . . . . . . . . . . . . . . . . . 18
2. Waterborne Coatings (Spray, Dip and Flow. . . . 21
3. Waterborne (Electrod