Emissions averaging added to Southern California's Rule 1136.

The Regulatory/Negotiations process which led to the development of the National Emissions Standard for Hazardous Air Pollutants has given wood finishers in the Los Angeles area a new tool for compliance with that regions air quality regulations.

During the Reg-Neg process, Control Technique Guidelines were developed. These guidelines were, in effect, suggestions to states and regions across the country with poor air quality on how to improve the air.

One of those suggestions was to allow wood finishers to average emissions from the various finishing steps. The goal of averaging is to help companies comply with regulations while reducing overall emissions. This suggestion was put to the Los Angeles' air quality governing board, the Southern California Air Quality Management District (SCAQMD), who, after consideration, agreed to add the averaging provision to its Rule 1136 - Wood Products Coating, which regulates VOC emissions by wood finishers.

The SCAQMD voted Sept. 8 to amend Rule 1136. In addition to adopting the averaging provision, Rule 1136 was amended to include EPA-mandated language corrections, the granting of a 10-month deadline extension for architectural wood finishers and additional testing methods. The EPA-mandated corrections had to be made so that Rule 1136 could be folded into California's State Implementation Plan or SIP. The SIP is used to help states reduce emissions of chemicals and improve overall air quality. Failure to make these corrections could have led to Federal EPA sanctions including the withholding of federal highway funds. This rule change was the 10th time the rule had been amended since its adoption in September 1983.

Under the averaging amendment, wood finishing facilities can average the amount of VOCs emitted from their stains, sealers, clear topcoats and pigmented coatings. Companies who average their VOC emissions in their reporting must be able to show that emissions are at least 10 percent below allowable emission levels. According to the SCAQMD, the averaging proposal provides companies "another tool" for compliance and produces a 10 percent reduction in emissions without any "socioeconomic impact." The VOC limits (in pounds per gallon) are: sealers 2.0; clear top coats 2.3; extreme performance coatings 3.5; fillers 4.2;. high-solid stains 5.8; pigmented coatings 2.3; fiberboard/particleboard coatings and multi-colored coatings 5.7; and, mold-seal coatings 6.3.

To be eligible to average, the company must submit a averaging plan to the SCAQMD and the US EPA and receive approval of the plan in writing from both agencies. The plan must include, at a minimum: a description of the wood products coatings to be included in the averaging program; and a description of the quantification and recordkeeping procedures for coating usage; coating VOC and solids content; VOC emissions; and calculations to show daily compliance.

A second amendment to the rule granted architectural woodworkers a deadline extension for compliance with the VOC emission. The door was also left open for future extensions. The compliance deadline was extended from Sept. 1, 1995, to July 1, 1996. The extension gives credence to industry contentions that with current finishing materials and technologies, architectural woodworkers could not meet the emission limits and achieve the same finishing quality on its high-end products.

This argument is based on quality standards developed by the Architectural Woodwork Institute. The AWI's National Architectural Woodwork Quality Standards establishes three levels of quality: premium, custom and economy. Under the Premium Quality standard, solventborne finishes are mandated; waterborne finishes are currently not permitted. However, under Rule 1136, architectural woodworkers would, for the most part, be mandated to use waterborne finishes, according to AWI.

Because of this, the SCAQMD has said it will work with the industry to attempt to develop a "viable compliance strategy."

The agency also left open the possibility of extending the deadline even further. In the Comment and Response section of SCAQMD's amendment draft proposal, the air quality agency said that its "Staff will reconsider the 7-1-96 (July 1, 1996) limits at a later date if the limits are found to be unachievable despite the best efforts of the industry."

Because of the deadline extension, the SCAQMD said that there may be some environmental impacts but they are considered to be within the scope of an previously-conducted environmental analysis.

In a letter from AWI 1994-95 president Yves Des Marais to SCAQMD, Des Marais said his members produce little in the way of annual emissions. According to an AWl survey, 74 percent of its members released under 5 tons of emissions of all types per year.

"The architectural woodwork industry is unique and, we believe, fundamentally different from other industries which would also be affected by the proposal," said Des Marais. "The total volume of work done by our industry is minuscule compared to wood furniture, but we are dealing with a huge variety of situations and different materials."

The other changes to the rule included adding test methods for capture efficiency of emission control systems and transfer efficiency of spray equipment, a method to calculate equivalent efficiencies of control systems, definitions and other language.