PROPOSAL:
Amend Rule 1168 – Adhesive and Sealant Applications
SYNOPSIS:
In addition to changes for clarity and consistency, the proposed amendments
maintain the current VOC limits for PVC and CPVC welding, reduce the VOC limit
for primers used in conjunction with PVC and CPVC welding, reduce the VOC limit
for ABS cements, postpone the final limit for top and trim adhesives until
January 1, 2007, and allow limited use of methylene chloride in adhesive
formulations used in the solvent welding of hard acrylic, polycarbonate and
polyethylene terephalate glycol plastics.
COMMITTEE:
Stationary Source, October 22 and November 19, 2004, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
- Certifying the CEQA Subsequent Environmental Assessment (SEA) for
Proposed Amended Rule 1168 – Adhesive and Sealant Applications; and
- Amending Rule 1168 – Adhesive and Sealant Applications.
Barry R. Wallerstein, D.Env.
Executive Officer
Background In part, the September 15, 2000 amendments to Rule 1168
included the addition of sales and use prohibitions for non-compliant
adhesives and sealants, and the phase-out of small use exemptions beginning
September 15, 2001. These rule revisions affected several small businesses
that apply adhesives in low volumes. One such industry is automotive and
marine top and trim where typical activities include the recovering of door
panels, seats, dashboards, convertible tops, and floor covering, as well as
the installation of sunroofs and vinyl tops. The June 2002 amendments created
a special category for top and trim adhesives and set an interim volatile
organic compound (VOC) limit of 540 grams per liter until January 1, 2004, and
a final VOC limit of 250 grams per liter thereafter. Staff performed a
technology assessment in 2003 to determine the feasibility of the 250 grams of
VOC per liter limit for top and trim applications. Based on the findings of
this evaluation, implementation of the January 1, 2004 limits was delayed to
January 1, 2005. The primary arguments for supporting a delay of the lower VOC
limit were difficulties in application of waterborne top and trim adhesives
(precise tack time, low initial strength, and lesser heat resistance), coupled
with the market availability of acetone-containing adhesives meeting the 250
grams of VOC per liter limit. Both types of adhesives, as well as hot melt
glues, were being used at larger automotive conversion shops but there were
performance and application concerns with water and acetone-based adhesives.
Exempt compound based replacement adhesives are still in development and to
date have not shown the necessary high heat and stain resistant
characteristics that are needed for the performance demands of this industry.
Previous amendments to Rule 1168 in December 1992, April 1997, and October
2003 also postponed the technology forcing final VOC limits for adhesives and
primers used to weld plastic pipes and pipe-fittings together to allow more
time for development of low-VOC formulations. Efforts to develop lower-VOC
adhesive technology has had limited success due to difficulties in
substituting exempt compounds for VOC solvents in polyvinyl chloride (PVC) and
chlorinated polyvinyl chloride (CPVC) welding formulations, obtaining other
regulatory agency and product approval requirements, such as those of the
National Sanitation Foundation (NSF), as well as conformity with specified
strength requirements of applicable American Society of Testing and Materials
(ASTM) standards. Also, as part of the June 7, 2003 amendment, the Board
approved a ban on the sale of adhesives and sealants containing toxic
chemicals such as methylene chloride, perchloroethylene, ethylene dichloride,
chloroform and trichloroethylene; completely phasing-out the use of these
solvents by January 1, 2005. The ban was justified by the availability of
alternative compliant adhesives and sealants. One exception to the
availability of non-methylene chloride containing adhesives is solvent welding
of hard acrylic, polycarbonate and polyethylene terephalate glycol plastic
fabrications. As a result, an additional year (and subsequent one-year
sell-through provision) was provided to allow for the continued development of
acceptable replacements for methylene chloride formulations. This amendment
to Rule 1168 implements the findings of a technology assessment regarding the
feasibility of using low-VOC automotive and marine top and trim adhesives by
January 1, 2005. It also addresses the viability of using non-methylene
chloride-based solvent cements to weld certain hard plastic fabrications, and
the feasibility of the January 1, 2005 VOC limits for PVC welding, CPVC
welding, and their associated primer. Although initial results on the
availability and use of top and trim adhesives meeting 250 grams VOC per liter
by January 1, 2005 were promising, recent information revealed that additional
time is required to develop acceptable performing products meeting this limit,
and staff is recommending a two-year extension of the current VOC limit of 540
grams per liter limit until January 1, 2007. Sufficiently welding hard
plastics, such as acrylic, polycarbonate, and polyethylene terephalate glycol
(PETG), without chlorinated solvents is also not technically feasible at this
time. Staff is recommending a limited exemption from the prohibition of sales
of adhesives containing methylene chloride used for these purposes, at a level
that is health protective. In addition, staff believes it is not technically
feasible to reduce the VOC content for PVC and CPVC solvent cements used to
weld such plastic pipes and fittings together beyond the current rule limits
of 510 and 490 grams of VOC per liter, respectively. However, manufacturers
have made some headway in reducing the VOC content of PVC and CPVC primers, as
well as acrylonitrile butadiene styrene (ABS) welding products that will help
to partially offset the VOC emission reductions foregone with the retention of
current VOC limits for PVC and CPVC welding. Proposal The staff proposal is summarized as follows:
- Top and Trim Adhesives:
Extend the compliance date for the final VOC limit from January 1, 2005 to January 1, 2007 and maintain the current VOC limit of 540 grams per liter in the interim in accordance with the results of a technology assessment.
- PVC and CPVC Welding
Retain the current VOC limits due to technical infeasibility to reduce the VOC limits further.
- Associated Adhesive Primer for PVC and CPVC Welding
Reduce the VOC limit from 650 grams per liter to 550 grams per liter on July 1, 2005 since compliant products are available and either currently have or will have prior to that date the required approvals from the other regulatory agencies.
- ABS Welding
Reduce the VOC limit from 400 grams per liter to 325 grams per liter on July 1, 2005 since compliant products are, or will be available prior to that date.
- Solvent Welding of Polycarbonate, Acrylic and Polyethylene Terephalate Glycol Sheet Plastics
Provide exemption from the prohibition of sales and use provision to limit solvent welding formulations to a maximum of 60 percent by weight of methylene chloride and limit on a health protective basis facility-wide use of these materials to 20 gallons annually.
The total amount of VOC emission reduction foregone resulting from plastic pipe and pipefitting welding cements and associated primers is 0.6 tons per day. A postponement of 0.2 tons of VOC emissions per day will be recaptured by January 1, 2007 from the use of lower-VOC automotive and marine top and trim adhesives. AQMP and Legal Mandates
The California Health and Safety Code require the AQMD to adopt an AQMP to
meet state and federal ambient air standards in the Basin. In addition, the
California Health and Safety Code require that the AQMD adopt rules and
regulations that carry out the objectives of the AQMP. Control Measure
#CTS-02E in the 1997 AQMP, as amended in 1999, calls for greater use of
low-VOC, high-solids, or multi-component adhesives to achieve further
reductions in daily VOC emissions. The VOC emissions reduction target for
CTS-02E was 1.3 tons per day for the 2010 planning inventory. The September
15, 2000 amendment of Rule 1168 achieved reductions of 8.0 tons per day for
2010 based on the planning inventory. When the limits under Rule 1168 cannot
be achieved, the Board must find that it is infeasible to implement the
measure by 2003. On June 7, 2002, the Board authorized a delay of the
implementation of technology forcing limits for PVC welding, CPVC welding,
associated primers and for other plastic cement welding to January 1, 2005.
The emission reductions delayed for these products was 0.85 tons per day of
VOC. The emission reductions delayed for top and trim adhesives as part of
the October 3, 2003 amendment to Rule 1168 were calculated to be 0.2 tons
per day of VOC, which is the same quantity of this proposal. Furthermore, if
a limit is found to be technologically infeasible, the AQMD may make up the
shortfall through alternative measures within two years after implementation
of Rule 1168 as it was amended in 1998. In this case, that shortfall has
been more than compensated by the September 15, 2000 amendments to Rule
1168, which achieved year 2010 reductions of 8.0 tons per day of VOC. These
reductions are well in excess of the required 1.3 tons of VOC reductions
required from Control Measure CTS-02E in the 1997 AQMP, as amended in 1999.
Therefore, the emissions forgone by this amendment to Rule 1168 of 0.60 tons
per day from plastic cement welding and associated primers, and an
additional 0.2 tons of VOC per day reductions that will be delayed until
January 1, 2007 for the automotive and marine top and trim industry, do not
negatively affect our original commitment of the State Implementation Plan
as amended in 1999. Furthermore, the 2003 AQMP accounted for a total of 3
tons per day of emissions to reflect potential reductions foregone due to an
infeasibility finding. Therefore, the proposed action would not interfere
with the attainment demonstration by 2010. CEQA and Socioeconomic Analysis
Pursuant to the California Environmental Quality Act (CEQA) and the AQMD’s
Certified Regulatory Program (Rule 110), the AQMD prepared a Subsequent
Draft Environmental Assessment (SEA) for Proposed Amended Rule 1168 –
Adhesive and Sealant Applications, which was released for a 45-day public
review period. A Revised Draft SEA was also later recirculated for a 45-day
public review period. One comment letter was received on the Draft SEA and
no comments were received on the Revised Draft SEA. A Final SEA has been
prepared and is included as part of this Adoption Hearing package. No significant socioeconomic impacts have been identified as a result of the proposed amendments. Implementation Plan Staff will continue to inspect facilities subject to Rule 1168. Resource Impacts Implementation of the proposed amendments will have limited impacts on staff and fiscal resources. Attachments
- Summary of Proposed Amendments
- Rule Development Process
- Key Contacts List
- Resolution
- Rule Language
- Final Staff Report
- Final Subsequent Environmental Assessment
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