VOC emission enforcement: the search for non-compliance.

VOC EMISSION ENFORCEMENT: THE SEARCH FOR NON-COMPLIANCE

Editor's note: Although vehicles account for roughly 30 percent of the nation's volatile organic compound (VOC) emissions, surface coatings rank fourth, contributing 13 percent of the problem, according to the Draft Document of Control Techniques for VOC Emissions.

Included in surface coatings, at 1 percent, wood finishing is estimated to account for 220,000 tons of VOC emissions per year. And while wood finishing may be considered a small source problem by some, it has come under strict regulation in non-attainment areas of the country by government agencies involved in the battle to clean the air.

At 0.33 parts per million of VOCs, Southern California has the dubious distinction of being ranked the nation's top non-attainment zone as determined by the U.S. Environmental Protection Agency. It also has the strictest finishing regulations on the books, South Coast Air Quality Management District Rule 1136. (See chart on page 120.)

There are some firms, such as Eric Morgan and Cardinal of California, which have chosen to move their manufacturing/finishing facilities to Mexico to beat the regulations. However, others visited by WOOD & WOOD PRODUCTS, GuildCraft and Terra Furniture, have made the difficult decision to stay. There are among the 20,000 to 30,000 finishing sources in the Southern California basin area which walk the tight line between achieving quality finishes and compliance with the nation's strict rule.

Rule 1136 compliance falls under the jurisdiction of the South Coast Air Quality Management District, a four-county (Pasadena, Colton, Long Beach and Anaheim) regulatory body which conducts annual plant inspections for equipment permits, finishing and other VOC-causing material usage and disposal, plus recordkeeping adherence.

After a few hours, the morning haze burned off from the Southern California skyline. But the brown-tinged smog remained.

All in all, it was a typical day for a VOC inspection tour.

From this outsider's point of view, it appeared a relatively painless procedure. For although companies are not forewarned of impending inspections, they are usually prepared, said Armando Villena, an inspector with the Pasadena Enforcement Division of the SCAQMD.

Commerce, Calif.-based GuildCraft certainly was. A semi-custom manufacturer of doors/panels, subcomponents, furniture and cabinetry, GuildCraft employs between 35 to 40 employees, working one eight-hour shift per day.

It was a few hours into the workday, June 19, when Villena and I arrived. He was armed with basic company information including emission permits and a list of the finishing materials used. In the presence of John Sachs, general manager, and Brad Muncy, production manager, the 1 1/2-hour inspection began.

"We're basically looking for compliance with the operating permits and if the materials used are in compliance. We're also looking at records from the past year," Villena said.

Recordkeeping is 40 percent of the SCAQMD's VOC-emission regulations. Similarly, the first 30 to 40 minutes of the inspection included a review of the company's daily finishing materials usage record as required under Rule 1136.

To comply with Rule 1136, GuildCraft switched from nitrocellulose/traditional type finishes to high solids and water-based materials, including a water-reducible stain. Muncy discussed some of the more common detriments in switching from nitrocellulose products. "Lots of times we'll use a two-coat sealer over a one-coat top-coat. The problem is that lots of times the sealer is a high solid. So you can do a light coat for an open coat look or use two coats for a more filled coat. We end up using the sealer in a light coat over the water-based to alleviate grain raising."

"In the interest of trying to be compliant," Sachs added, "we are putting our necks out in the field. There's only so much testing you can do. Water-based finishes are twice as expensive. And nitrocellulose is often a better quality finish, with no grain raising like with water based."

GuildCraft, which uses solvents for clean-up only, was warned of the impending passage of proposed Rule 1171, scheduled to go into effect later this year. As stated in Rule 1171, daily records must be maintained even if the solvent is for clean-up usage only.

Next step - the walk through

While most of the attention is often centered on VOC compliance of finishing emissions, VOCs are also discharged by adhesives, the regulation of which falls under SCAQMD Rule 1168. And although the agency does not have jurisdiction over wood dust regulation compliance, Villena said the SCAQMD will notify the Occupational Safety and Health Administration if flagrant violations are present.

These were a few of the things Villena looked for on his inspection.

Throughout the millwork and gluing areas, Villena examined everything from the Black Bros. glue spreader to the Manea case clamp; even the assembly glue bottle, used with the case clamp, was perused. Under Rule 1168, VOC-emitting adhesives must also be recorded.

The primary VOC source, the finishing area, was next. The company has three Industrial Systems spray booths armed with Binks HVLP guns for spraying solvents and air-assisted airless guns for the water-based finishes. Villena observed a worker spraying a Paramount Paint water-base clear sealer with Graco air-assisted airless sprayers set at 30 to 35 psi. Per Rule 1136, the company can use air-assisted airless guns until 1994, provided it complies with 1996 finishing material limits. Subsequently, the only equipment allowable is that which achieves a 65 percent transfer efficiency, such as HVLP guns.

"We have HVLP hookup, but we can't use the guns with water-based products because we don't get a good spray pattern," said Muncy. "But we can switch the guns back to HVLP if needed."

GuildCraft had replaced the finishing lines at the water spray booth to eliminate any trace of solvents. Said Sachs, "Everytime we change the finishing material for a project, we have to change something, either the guns, or the tips, or something else."

In addition to usage, storage and disposal of finishing materials is also a concern of the SCAQMD. Villena examined GuildCraft's coating supply, checking for VOC emissions posted on the containers. The company uses Lilly, Surface Protection, Sinclair and Sherwin-Williams products. All drying is done by open air for three to five days.

Rags used in conjunction with finishing materials, even for hand wiping, fall under hazardous waste disposal regulations. GuildCraft contracts with hazardous waste disposal firms to pick up and dispose of the cloths as well as receptacles containing solvent used for spray gun cleaning (other than water-based finishes). With regards to the spray booths, the water is pumped out and replaced approximately every six months by a licensed disposal company.

Final notes

If the company had used any new material not previously listed on reports, and without posted emissions, a sample would have been taken for testing at SCAQMD headquarters in El Monte.

In this case, however, the company was in compliance. The only points Villena made concerned recordkeeping and posting location of permits. A suggestion was made to post copies of the permits on the spray booths themselves for easier viewing by inspectors and personnel alike, rather than in a nearby room. With regards to recordkeeping, Villena requested monthly estimates from the past 12 months be sent to the Pasadena SCAQMD office for final emission limits evaluation.

"If the company had been found in non-compliance," Villena explained, "we would go back within 14 days to recheck. A normal violation notice has a 24-hour period to comply. We'd then continue to do daily checks if it resulted in a public nuisance or hazard."

Fines for non-compliance depend on the violations and circumstances, he added. If it is a procedural/administrative citation, i.e., recordkeeping, missing permits, etc., a notice to comply is sent. But if it is an emissions violation, the company is immediately cited. Although rare, fines for non-compliance can reach a maximum of $25,000 per day.

No rule, however, is infallible. There are instances where a company can be found in non-compliance through a technicality. Case in point, Villena cited, was a manufacturer who used adhesives, not as a binder, but as a finishing material. Should the company be evaluated under finishing Rule 1136 or adhesives Rule 1168? In another instance, a facility used a spackling gun to produce a finish. Can the company continue to use the atomizing gun or must it switch to an HVLP sprayer since it is producing a finished look?

The cases are still under review by the SCAQMD board. [Tabular Data Omitted]

PHOTO : SCAQMD inspector Armando Villena cross checks for compliance as a worker sprays a water-based clear sealer using Graco air-assisted airless guns, set at 30 to 35 psi.

PHOTO : From left, Brad Muncy, John Sachs and Armando Villena review GuildCraft's emission records.

PHORO : SCAQMD enforcement officers must inspect all finishing materials for VOC compliance, even those kept in storage.