VOCTASK FORCE UPDATE. Greg Johnson, Sherwin-Williams Kelly Franklin, RCMA Industry Affairs Coordinator John Ferraro, RCMA Executive Director

Transcription

1 VOCTASK FORCE UPDATE Greg Johnson, Sherwin-Williams Kelly Franklin, RCMA Industry Affairs Coordinator John Ferraro, RCMA Executive Director

2 RCMA VOC Task Force RCMA has a dedicated VOC Task Force for handling VOC-related issues. Key activities include: Monitoring rule developments Making recommendations to RCMA Board of Directors Drafting stakeholder comments during rule developments Identifying opportunities for new RCMA initiatives in VOC arena

3 NATIONAL OZONE STANDARD

4 National Ambient Air Quality Standard (NAAQS) EPA sets National Ambient Air Quality Standards for six criteria pollutants, per the 1970 Clean Air Act: Carbon Monoxide Lead Nitrogen Dioxide Ozone Particulate Pollution PM 2.5 PM 10 Sulfur Dioxide

5 National Ozone Standard Date Ozone (averaging time) Effect Pre ppm (1 hour) ppm (8 hour) National Ozone one-hour standard was 0.12 parts per million (ppm) Cities and regions fall out of compliance, including Houston, Dallas, most of California, parts of I-95 Corridor Mar ppm (8 hour) Additional areas in the country become non-compliant, including Great Lakes region.

6 CARB Current National Ozone Nonattainment Areas Based on 2008 Standard LADCO OTC Source: EPA

7 Source: EPA South Coast Nonattainment

8 State Implementation Plan (SIP) Requirements with Lowered NAAQS If a new Ozone Standard were to be announced January 1, Timeframe Requirement < 2016 EPAdesignates areas as meeting ( attainment areas ) or not meeting ( nonattainment areas ) the standards < 2017 All states must submit state implementationplans (SIPs) to show they can meet NAAQS < ~ Each nonattainment area SIP must outline the strategies and emissions control measures that show how the area will meet the NAAQS

9 National Ozone Standard - Revisions to the National Ozone Standard could increase pressure for further VOC reductions by states. - January 7th, 2010 EPA proposed to lower the ozone standard, currently.075 ppm, down to ppm ppm. - On September 2, 2011, the Obama administration sent out a press release withdrawing the draft NAAQS for Ozone. - EPA released the proposed rule that was not approved, which had set ppm. - EPA will once again revisit the standard in 2013.

10 National Ozone Standard Date Ozone (averaging time) Effect Pre ppm (1 hour) ppm (8 hour) National Ozone one-hour standard was 0.12 parts per million (ppm) Cities and regions fall out of compliance, including Houston, Dallas, most of California, parts of I-95 Corridor Mar ppm (8 hour) Additional areas in the country become non-compliant, including Great Lakes region. Jan Proposed ppm (8 hour) Could result in new non-compliant regions across the entire country, inclusive of Great Smoky Mountains National Park and other non-industrialized areas, as well as.

11 2010 Ozone Concentrations Source: EPA, Our Nation's Air - Status and Trends through 2010, February 2012

12 Ozone Concentrations Proposed Rule Comparison National Ozone Nonattainment Areas 2008 Standard National Ozone Nonattainment Areas Proposed.06ppm (all sites but dark blue) Source: EPA, Our Nation's Air - Status and Trends through 2010, February 2012

13 Actual Historical Ozone Reductions National National 8-hour Ozone Air Quality Trends % decrease nationally in Ozone Source: EPA, Our Nation's Air - Status and Trends through 2010, February 2012

14 REGULATORY BODIES REVIEW - EPA - CARB - SCAQMD - OTC - LADCO

15 United States Environmental Protection Founded in 1970 Agency (EPA) Revises National Ambient Air Quality Standard (NAAQS) Including National Ozone Standard Requires that nonattainment areas submit State Implementation Plans (SIPs) for reaching current NAAQS Can set National Rules for products, including Architectural & Industrial Maintenance Coatings

16 California Air Resources Board (CARB) Founded in 1968 California Air Resources Board (CARB) sets ambient air standards for the state and designs Suggested Control Measures (SCMs) for compliance. Oversees 35 local and regional California air districts who may implement rules to meet air quality requirements.

17 CARB Districts CARB has 35 Air Districts, each of which has the authority to create and implement air regulations. Photo credit: California Air Resources Board

18 Ozone Transport Commission (OTC) Comprised of Northeast states: Maine Vermont New Hampshire Massachusetts Rhode Island Connecticut New York New Jersey Pennsylvania Delaware Maryland Washington, DC Northern Virginia

19 Lake Michigan Air Directors Consortium Comprised of Great Lakes states: Wisconsin Illinois Indiana Michigan Ohio Minnesota Non-profit organization, funded by EPA and member states. 1989: Founded by IL, IN, MI, WI 2004: OH joins 2012: MN joins (LADCO)

20 AIM COATINGS RULES REVIEW - Typical Rule Evolution - EPA National AIM Coatings Rule - CARB 2000 SCM - OTC Phase I - CARB 2007 SCM - OTC Phase II - SCAQMD Rule 1113

21 Typical Model Rule Evolution SCAQMD Rule Developed & Adopted CARB Suggested Control Measure (SCM) CARB SCM Adoptions in CA Air Districts OTC Model Rule OTC State Adoptions LADCO State Adoptions EPA National Rule

22 EPA National AIM Coatings Rule 40 CFR Part 59 Last revised September 11, 1998 Product Category VOC Limit (g/l) Bituminous Coatings and Mastics 500 Industrial Maintenance Coatings 450 Metallic Pigmented Coatings 500 Roof Coatings 250

23 CARB 2000 Suggested Control Measure Approved by CARB June 20, 2000 Product Category National Rule CARB 2000 SCM Bituminous Roof Coatings Industrial Maintenance Coatings Metallic Pigmented Coatings Roof Coatings

24 OTC 2002 Model Rule Phase I Approved by OTC in 2002 Product Category National Rule CARB 2000 SCM OTCPhase I Bituminous Roof Coatings Industrial Maintenance Coating Metallic Pigmented Coatings Roof Coatings

25 CARB 2007 Suggested Control Measure Approved by CARB in October 2007 Product Category National Rule CARB 2000 SCM OTCPhase I CARB2007 SCM Aluminum Roof Coatings n/a n/a n/a 400 Bituminous Roof Coatings Industrial Maintenance Coating MetallicPigmented Coatings Roof Coatings

26 OTC 2010 Model Rule Phase II Approved by OTC June 2011 Product Category National Rule CARB 2000 SCM OTCPhase I CARB2007 SCM OTC Phase II Aluminum Roof Coatings Bituminous Roof Coatings Industrial Maintenance Coating MetallicPigmented Coatings n/a n/a n/a Roof Coatings

27 South Coast Rule 1113 Adopted by South Coast June 2011 Product Category National Rule CARB 2000 SCM OTC Phase I CARB 2007 SCM OTC Phase II SCAQMD Rule 1113 Aluminum Roof Coatings Bituminous Roof Coatings Industrial Maintenance Coatings MetallicPigmented Coatings n/a n/a n/a n/a * Roof Coatings * Definition revised to exclude roof coatings; limit 150 applicable 1/1/2014

28 AIM COATINGS RULE ADOPTIONS - National Rule Adoptions Overview - State Adoption Updates - California 2000 CARB SCM - California 2007 CARB SCM - California Air District Adoption Updates - South Coast Updates - National AIM Rule

29 National AIM Coatings Rule Adoptions

30 New York OTC Phase II Model Rule Adoption - Likely will be first OTC state to adopt updated AIM Coatings Rule based on the OTC 2010 Model Rule, Phase II - RCMA received draft of updated 6 NYCRR Part 205 ahead of stakeholder comment period - The draft rule calls for a January 1, 2014 effective date; RCMA submitted comments requesting this effective date be pushed back. - Rule still not finalized

31 OTC Phase II Model Rule Adoption New Hampshire - Current rule Env-A 4200 is set to expire in 2014 and they will consider whether to update to Phase II at that time. New Jersey - Looking to adopt Phase II but not currently pursuing due to conflicting priorities. Full process would take 2 or more years adoption not likely sooner than Connecticut - Adoption of OTC Phase II is currently in internal review. - Their office expects it will be 12 to 18 months until it is promulgated. Delaware - Had tentatively planned to start rule making procedure before year-end Plan to mirror OTC Phase II rule closely.

32 CARB Overview California Air Resources Board (CARB) sets ambient air standards for the state and designs Suggested Control Measures (SCMs) for compliance. 35 California districts who may implement rules to meet air quality requirements.

33 Following CARB 2000 SCM Butte Colusa Feather River Northern Sonoma Sacramento San Diego San Luis Obispo Santa Barbara Shasta Tehema Yolo-Solano

34 Following CARB 2007 SCM Antelope Valley Bay Area Ventura San Joaquin Imperial Kern Placer Mojave Desert Monterey Bay

35 Adopting CARB 2007 SCM Rule El Dorado Santa Barbara San Diego

36 CARB 2007 SCM Adoption Progress - Antelope Valley adopted revisions to their Rule 1113 to update to CARB 2007 SCM in June Lower VOC limits take effect June 18, San Diego put out a notice on September 24 that they will be holding a public workshop on proposed Rule on October 29. Proposed effective date is one year following adoption. - El Dorado updating AIM rule 215 to CARB 2007 SCM per their SIP. Hoping for rule out by year-end Would replace current rule which does not follow a CARB SCM or other well-known model. - San Diego s updated draft AIM rule is expected in the next two months for public comment.

37 South Coast Rule 1113 Reminder: Upcoming Compliance Deadline January 1, 2014 New Labeling Requirements: Noticeable and in clear and legible English; Separated from other text; and Conspicuous, as compared with other words, statements, designs, or devices in the label as to render it likely to be read and understood by an ordinary individual under customary conditions of purchase or use.

38 South Coast Rule 1113 Reminder: Upcoming Compliance Deadline January 1, 2014 Reduced VOC limits for: Concrete Surface Retarder (50) Dry-Fog Coatings (50) Faux Finish Coatings Decorative Coatings (100) Faux Finish Coatings Trowel Applied Coatings (50) Fire-Proofing Coatings (150) Form Release Compounds (100) Graphic Art (Sign) Coatings (150) Mastic Coatings (100) Metallic Pigmented Coatings (150)

39 South Coast Rule 1113 Reminder: Upcoming Compliance Deadline January 1, 2014 Reduced Default VOC Limit The VOC limit for the default category (e.g., any architectural coating that does not fall into one of the categories listed in the Rule 1113 table) will be reduced from 250 g/l to 50 g/l. VOC limits on colorants added at the point of sale: 50 g/l for architectural coatings 600 g/l for solvent-based industrial maintenance coatings 50 g/l for waterborne industrial maintenance coatings

40 South Coast 2012 Air Quality Management Plan (AQMP) - SCAQMD approved their 2012 Air Quality Management Plan (AQMP) on December 7, The AQMP calls for further reduction of VOC emissions from AIM Coatings, specifically by: - Small container exemption -eliminate certain categories, set limits, increase fees - Spray equipment requirements to increase transfer efficiency and reduce paint usage - Rule changes to be adopted , effective

41 National AIM Rule - Once several court-ordered deadline projects are completed later, EPA will possibly start working on the AIM rule. - RCMA has been working with OTC and American Coatings Association (ACA) on drafting a letter to EPA to adopt an updated National AIM Rule. - Beginning of rulemaking process had been suggested for Does not seem to be high priority at EPA.

42 ADHESIVES & SEALANTS RULE ADOPTIONS - Rule Overview - National Overview - State Adoption Updates - California Overview - South Coast Rule 1168

43 Rules Overview EPA Control Technique Guideline (CTG) for Industrial Adhesives Optional suggested regulation for nonattainment areas Only specific roofing category is for Single-Ply adhesives / sealants Adopted in NH and regions in IL, IN OTC 2005 Model Rule Adopted in all OTC states but VT, MA, NH Not adopted in any LADCO States Adopted in Utah nonattainment area SCAQMD Rule 1168 Last updated January 2005 Currently undergoing revisions

44 National Adhesive & Sealants Rule Adoptions

45 OTC Adhesive & Sealant Model Rule Adoption Utah New Rule Adoption: R OTC Model Rule adopted in Salt Lake City nonattainment area 1/1/2014 compliance date Massachusetts Draft rule 310 CMR 7.18 has been out since October 2011 but continues to be internally stalled. Vermont Had hoped to adopt OTC Model Rule for both AIM and Adhesives & Sealants in 2013, as resources allow.

46 CA Districts with Adhesive & Sealants Rules Based on South Coast Rule 1168 Antelope Valley Bay Area Air El Dorado Placer Sacramento San Diego San Joaquin Valley Santa Barbara Shasta South Coast Tehama Ventura Yolo-Solano

47 South Coast Rule Background South Coast announced plans to reopen Rule 1168, Adhesives & Sealants, in early 2012 Current Rule 1168 last updated 2005 South Coast hosted first Working Group call June 25, 2013 RCMA VOC Task Force convening regularly, attending working group calls

48 South Coast Rule 1168 Key Issues Clearer lines drawn between Rule 1113, Rule 1168, and CARB Consumer Products Rule Category definition updates, deletions, additions Nonmembrane roof adhesives / sealants Other roofing niche categories Exempt solvents Dimethyl Carbonate (DMC) Tert-Butyl Acetate (TBAC) VOC Limit Reductions

49 VOC TASK FORCE ACTIVITIES - VOC Maps Subscriptions - VOC Regulations Webinar - Regulatory Monitoring - Key 2013 Activities

50 RCMA VOC Map Subscriptions RCMA started selling subscriptions to RCMA VOC Maps in 2013 for $750 per user per year. 2 subscriptions sold in 2013 Hope to convert those subscriptions into RCMA memberships in 2014 Publicizing for 2014?

51 RCMA VOC Regulations Webinar Introduction to VOC rules and regulations, to establish RCMA as resourceand to enhance value of membership 50 attendees registered, including 5 nonmembers: Insulating Coatings Corporation RCA Asphalt Malarkey Roofing Sika Sarnafil CoatingsPro Magazine Archived presentation available in Members Only section of RCMA website

52 Regulatory Monitoring VOC Task Force identified the following issues as areas to continue monitoring: LEED version 4 International Green Construction Code (IgCC) EPA / National AIM Rule update EPA / National Ozone Standard revision CARB updated SCM for AIM Coatings or SCM for Adhesives & Sealants SCAQMD reopening of Rule 1168 (Adhesives & Sealants) OTC AIM Phase III development OTC AIM Phase II state-level adoptions Local / county-wide AIM and Adhesive & Sealants regulations

53 Key 2013 Initiatives Working with American Coatings Association (ACA) and Ozone Transport Commission (OTC) to make recommendations on an updated National AIM Rule Attending OTC Annual Meeting in New Haven, CT Lobbying Congressional representatives not to allow EPA to lower the National Ozone Standard Upcoming article in CoatingsPro Magazine

54 QUESTIONS?