Forefront of air pollution regulations nationwide Delegates responsibility of stationary sources to local air districts

Transcription

1 California Air Resource Board/ South Coast Air Quality Management District Background Lead air pollution regulatory agency in California Responsibilities include: Vehicle emissions Greenhouse gas emissions Consumer products Forefront of air pollution regulations nationwide Delegates responsibility of stationary sources to local air districts Evaporation Studies 1

2 CARB/SCAQMD Background (Cont.) SCAQMD local air pollution control district Jurisdiction limited to Los Angeles, Orange, Riverside and San Bernardino counties 16.5 million residents Largest manufacturing base in the U.S. Responsible for stationary sources Refineries Industrial manufacturing Gas stations Dry cleaners Evaporation Studies 2

3 May 2012 Industry s Response to a New Paint Thinner Regulation

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5 Background Paint Thinners and Multi-Purpose Solvents previously unregulated Original idea from IRTA efforts Immense source of VOC emissions Almost 10 tons per day in SCAQMD alone In 2009, SCAQMD adopted VOC limits CARB adopted similar limits shortly thereafter Critical difference in how agencies define VOC Evaporation Studies 5

6 Rule Requirements VOC content limited to 25 g/l or 3% Non-compliant products may not be sold in stores Preemption clause included to avoid regulatory overlap for other types of consumer products Evaporation Studies 6

7 Currently Available Products Thinners that Do Not Contain Acetone 25 g/l VOC or less MANUFACTURER PRODUCT DESCRIPTION PRODUCT CHEMISTRY VOC (g/l) THINNERS CONTAINING NO ACETONE: Carboline Company 236 E Thinner < 100% PCBTF 0 Deft Finishes VOC Exempt Reducer IS % PCBTF 0 Ellis Paint Company 78 Co-Solvent Low-VOC 2-Butoxyethanol, n-propyl Alcohol 25 Pacific Coast Lacquer 1720B Compliant Waterborne Cleaning Solution PropGlycolMonomethylEther, n-prop Alcohol 24 Sunnyside Corporation Green Envy Paint Thinner < 5% PCBTF/H2O 19 Note: All formulations using 50% PCBTF are in bold type 7

8 Currently Available Products Thinners That Contain Acetone 25 g/l VOC or less MANUFACTURER PRODUCT DESCRIPTION ACETONE CONTAINING THINNERS: PRODUCT CHEMISTRY Carboline Company 225 E Thinner < 100% Acetone 0 VOC (g/l) MANUFACTURER Pacific Coast Lacquer PRODUCT DESCRIPTION ACETONE CONTAINING THINNERS: 2040 NOVOC Compliant Universal Solvent PRODUCT CHEMISTRY VOC (g/l) 80% Acetone, 20% Methyl Acetate 0 Carboline Company 243 E Thinner 55% PCBTF, 55% Acetone 0 Pacific Coast Lacquer 8050 Medium Universal Solvent 50% PCBTF, 50% Acetone 0 Deft Finishes VOC Exempt Reducer IS % PCBTF, 10-30% Acetone 0 Pacific Coast Lacquer 8075 Slow Universal Exempt Reducer 75% PCBTF, 25% Acetone 0 Ellis Paint Company 2040 NOVOC Compliant Universal Solvent 80% Acetone, 20% Methyl Acetate 5 Pacific Coast Lacquer 2010 Acetone 100% Acetone 0 Ellis Paint Company 80/20 Zero VOC Exempt Solvent 80% Acetone, 20% Methyl Acetate 5 Packaging Service Co., Inc. Crown Acetone % Acetone 0 Ellis Paint Company 70 Acetone 100% Acetone 0 Packaging Service Co., Inc. LVLT01 Crown NEXT Lacquer Thinner 85-95% Acetone, 5% Soy 0 M.L. Campbell VC 1681 Medium Reducer, VOC Exempt 70% Acetone, 30% PCBTF 0 PPG Acetone CP Acetone 0 M.L. Campbell VC 1671 Slow Retarder, VOC Exempt 70% PCBTF, 30% Acetone 0 Rust-Oleum 2400 Thinner < 100% Acetone 0 M.L. Campbell VC16936 Fast Reducer, VOC Exempt 100% Acetone 0 Note: All formulations using 50% PCBTF are in bold type Rust-Oleum VOC Compliant Thinner < 100% Acetone 0 Note: All formulations using 50% PCBTF are in bold type 8

9 A Success Story Right? Industry provides costeffective alternatives Relatively low in toxicity Significant emission reductions: 9.75 tpd in AQMD More than 20 tpd statewide 9

10 Preemption Preemption clause Multi-Purpose Solvents Does not include any products making any representation that the product may be used as, or is suitable for use as a consumer product which qualifies under another definition in California Code of Regulations Paint Thinners No Preemption clause included Commercialized products use Preemption as loophole LVP Study 10

11 LVP Solvent Exemption Low Vapor Pressure (LVP) Solvents defined as: Vapor pressure less than 0.1 mmhg Boiling point greater than 216 C 12 carbon atoms or more LVP only exempted by ARB in consumer products Not exempt in AQMD even for consumer products Manufacturers using preemption to gain access to LVP solvent exemption LVP Study 11

12 Physical Properties of Chemicals Not an LVP Chemical *CARB Bin 11-G CAS Carbon Atoms Boiling Point ( C) Vapor Pressure (mm 25C) Isopropyl alcohol Propylene glycol Ethylene glycol Dodecane (C12) Texanol Pentadecance (C15) Conosol to to 278 <0.01 to * TXIB Hexadecane (C16) Glycerol < Methyl hexadecane N/A Heptadecane (C17) < Eicosane (C20) MIR Difficult to Correlate Physical Properties with Overall Volatility LVP Study 12

13 Evaporative Studies Project Goal Evaluate Relative Ozone Generation Potential Between Acetone and Various LVP Solvents in Real World Applications Model Paint Brush Cleaning and Panel (Wipe) Cleaning Conduct Measured Solvent Loss Experiments Based on Model Test Protocols Calculate Relative Ozone Generation Potential Based on Maximum Incremental Reactivity (MIR) and Measured Solvent Loss LVP Study 13

14 Process Characterization Brush Cleaning Emissions from Solvent Batch Cleaning Result from: 1. Evaporation During Cleaning 2. Carry-Out of Solvent on Parts (Brushes) Cleaned 3. Disposal of Spent Solvent Evaporation Carry-Out Spent Solvent Disposal EPA, AP-42 Compilation of Air Pollutant Emission Factors, Chapter 4, Section 6 Evaporation Studies 14

15 Process Characterization Panel Cleaning Emissions from Wipe (Panel) Cleaning Result from: 1. Evaporation During Cleaning 2. Spent Solvent (Carry-Out) on Cleaning Rag Evaporation Spent Solvent on Rag ( Carry-Out ) Evaporation Studies 15

16 Modeled Test Results Summary [(Emissions, Grams) x MIR] * Compliant with SCAQMD Rule 1143 Final Rule Limit Brush Panel Acetone * Conosol Benzyl Alcohol Methyl Soyate * Aromatic DnPB Lacquer Thinner * District-Wide Contribution from Brush and Panel Cleaning Evaluated based on Presumed Sales Distributions, Normalized to Modeled Use Rate Evaporation Studies 16

17 Relative* Ozone Formation from Acetone, LVP Solvent 1, Incremental Ozone Index (Acetone = 100) Acetone Conosol 200 Benzyl Alcohol Methyl Soyate Aromatic 200 DnPB Lacquer Thinner 80:20, Panel:Brush , , :5, Panel:Brush , , * Based on solvent loss to air, by weight, multiplied by M.I.R., indexed to acetone (acetone = 100). 80:20 and 95:5 ratios refer to the estimated distribution of solvent use for panel and brush cleaning. LVP Study 17

18 Evaporation Studies Results Panel Cleaning Acetone has less ozone generating potential than all LVP solvents evaluated when modeled for evaporative and carryout losses Brush Cleaning Acetone has less ozone forming potential than most LVP solvents evaluated when modeled for evaporation and carryout losses Sensitivity analyses show that spent solvent may contribute up to 95% of ozone generating potential, while evaporative and carryout losses contribute only 5% When spent solvent impacts are considered, acetone has significantly less ozone forming potential than all LVP solvents evaluated Fate of spent solvent requires additional study LVP Study 18

19 Ambient Evaporation Study Parameters Sample Size: Approx 1 g Pan Configuration: Petri Dish Temperature: High - 30 C Low 20 C Ave. 24 C Humidity: High 52% Low 16% Ave 42% Air Flow: Negligible LVP Study 19

20 Overall Summary Ambient Evaporation Study % Non-Volatile Time (Days) LVP Study 20

21 Non-Volatiles - Isolated Ambient Evaporation Study (On-going) Room Temperature Evaporation Study Overall Summary (Non-Volatiles) % Non-Volatile Time (Days) Methyl Palmitate Soy Oil Glycerol LVP Study 21

22 Semi-Volatiles Isolated Ambient Evaporation Study (On-going) Room Temperature Evaporation Study Overall Summary (Semi-Volatiles) % Non-Volatile Time (Days) Pentadecance Dipropylene Glycol 2-Methyl Hexadecane Hexadecane Hynap N60HT Heptadecane LVP Study 22

23 Volatiles - Isolated Ambient Evaporation Study % Non-Volatile Time (Days) IPA Ethyl Lactate Consol 200 NMP Benzyl Alcohol Dodecane Propylene Glycol Ethylene Glycol Texanol TXIB LVP Study 23

24 Comparison Between Known VOC and Conosol 200 Ambient Evaporation Study % Non-Volatile Time (Days) Conosol 200 A IPA A Conosol 200 is compliant LVP replacement for paint thinners and multipurpose solvents like IPA Consumer Product regulation claims more than 12 tons per day emission reduction from this control measure LVP Study 24

25 LVP Contribution to VOC Content Product Category VOC (undiluted) g/l LVP (undiluted) g/l % VOC Attributable to LVP Household Dishwashing Soap % Household General Purpose Cleaner % Household Laundry Detergent % I&I Bathroom Cleaner % I&I Bathroom Cleaner % I&I Bathroom Cleaner % I&I Carpet Cleaner % I&I General Purpose Cleaner % I&I General Purpose Cleaner % I&I General Purpose Cleaner % I&I General Purpose Cleaner % I&I General Purpose Cleaner % I&I Glass and General Purpose Cleaner % I&I Glass and General Purpose Cleaner % I&I Glass and General Purpose Cleaner % I&I Glass Cleaner % I&I Glass Cleaner % Total VOC Attributable to LVP 51.8% Source: SCAQMD test results from selected I&I products LVP Study 25

26 Major Source Contribution To VOC (2020) Consumer Products 25% Trucks and Buses 3% Passenger Vehicles 18% Off-Road Lawn & Garden 6% Coatings (non-architectural) 8% Architectural Coatings 6% Other 22% Petroleum Marketing 5% 2020 VOC = 492 tons/day Source: ARB 2006 Almanac

27 Conclusions Reassessment important part of regulatory process Extended low temperature testing indicates some common LVP solvents readily volatilize When MIR is considered, LVP solvents do not produce the environmental benefits anticipated Many manufacturers utilize LVP exemption in product formulations LVP exemption parameters currently used to exclude volatile solvents should be reconsidered Pursue further testing to establish appropriate exemption parameters Low-temp/ambient evaporative studies LVP Study 27

28 Questions or Comments? Mike Morris - Air Quality Specialist (909) mmorris@aqmd.gov South Coast Air Quality Management District 28