Overview of California s Aerosol Coatings Regulation

Transcription

1 Overview of California s Aerosol Coatings Regulation September 2005 California Environmental Protection Agency Air Resources Board 1

2 Status Limits in effect since mid-2002 for general coatings; since 2003 for specialty coatings U.S. EPA s final approval of the Aerosol Coatings Regulation was published in the September 13, 2005, Federal Register 2

3 Topics Background Why Reactivity? Aerosol Coatings Regulation Tools for a Reactivity Program Elements of the Regulation Future Activities Lessons Learned 3

4 New Regulatory Concept Limits based on reactivity Efficient ozone reductions Cost savings Compliance flexibility 4

5 What Is Photochemical Reactivity? VOCs react in atmosphere leading to the formation of varying amounts of ozone Reactivity: measure of a VOC s potential to react to form ozone VOC reactivity quantified and compared using a numerical scale 5

6 Why Investigate Reactivity- Based Control Program? Large VOC mass reductions achieved Further reductions needed Mass reductions where feasible Reducing reactivity warrants investigation Potential to provide needed ozone reductions while providing flexibility 6

7 Commitment to Consider Reactivity in Regulations Basis for RAFs in LEV/CF regulations (1990) Continual research funding to improve science State Implementation Plan commitment Reactivity Scientific Advisory Committee advises on use of science 7

8 California s Aerosol Coatings Regulation Mass-based limits adopted in 1996 Revised tier 2 limits November 1998 Board directive to investigate reactivity option 8

9 Why Propose Reactivity Regulation for Aerosol Coatings? Preservation of water-based aerosol coatings Well-defined consumer product category Speciated VOC data available VOC ingredients well-studied for reactivity Industry open to reactivity approach 9

10 Development Process Fifteen stakeholder workgroup meetings Eight Public Workshops Four Reactivity Scientific Advisory Committee meetings (RSAC) 10

11 Tools Necessary for Reactivity Program Scale for VOC reactivity comparison Detailed product VOC speciation Product sales information Reactivity of ingredients wellcharacterized 11

12 Scale: Maximum Incremental Reactivity (MIR) Developed by Dr. Bill Carter at University of California, Riverside Used to compare ozone formation potentials Derived from box modeling of 30+ airsheds Robustness generally confirmed with detailed 3-D modeling Basis for scale peer-reviewed and found to represent State-of-the-Art 12

13 13 Range of MIR Values (g O 3 / g VOC) Acetone 0.43 Propane 0.56 Butane/Isobutane 1.33/1.35 Mineral Spirit (bin 9) 1.62 ( ) MEK Butoxyethanol 2.90 IPA 0.71 ETOH 1.69 Toluene 3.97 Xylenes (bin 21) 7.37

14 Speciated Data: Calculating Product-Weighted MIR 7 Contents Weight Fraction MIR Weighted Reactivity acetone toluene propane xylene butane solids Total Product MIR = 1.47 g O 3 /g product 14

15 Other Elements of the Regulation 15

16 Using the MIR Scale Develop methods so all VOCs can be used Upper limit MIRs Hydrocarbon solvent bins MIR value uncertainty Include provision for updating the scale Over 80% of aerosol coating ingredients have low uncertainty 16

17 Hydrocarbon Solvent Bins Twenty bins for solvents predominately paraffinic, isoparaffinic, and cyclic alkanes mean boiling point aromatic content Four bins for solvents containing only aromatic hydrocarbons boiling range 17

18 No VOC Exemptions Mass-based regulation VOC definition exempts acetone and other low & negligibly reactive compounds Reactivity-based regulation Reactivity of low & negligibly reactive compounds accounted for No exemptions 18

19 Prohibition on Use of Toxic Air Contaminants Prohibit Use of: -- Trichloroethylene (TCE) -- Methylene Chloride (MeCl) -- Perchloroethylene (Perc) 19

20 Relating Ozone Reduction to VOC Reduction O 3 reduction (tons per day) SWA MIR of VOCs = VOC (tons per day) therefore, 10 tons per day Ozone reduction = 3 tons per day VOC reduction 20

21 Economic Impacts Reactivity-based limits -- average cost effectiveness of $0.74 per pound Mass-based limits -- average cost effectiveness of $1.57 per pound Lower cost reflects additional flexibility 21

22 Next Steps for California Continue to seek mass reductions when feasible Use reactivity to achieve further ozone reductions Investigate other consumer product categories Currently surveying 2003 calendar year sales Architectural coatings evaluation 22

23 Lessons Learned Efficient ozone reductions Reactivity approach may not be appropriate for all categories Review categories on a case-by-case basis Provides more flexibility Cost-effective 23