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ProposedProposed California Low Emissions California Low Emissions and Reactivity (CLEAR) and Reactivity (CLEAR) Regulation For Aerosol Regulation For Aerosol

Coating ProductsCoating ProductsMeeting of the Reactivity Scientific

Advisory CommitteeAugust 26, 1998Riverside, California

California Environmental Protection Agency

Air Resources Board

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AgendaAgenda

RSAC Meeting on February 24 Legal Requirements Proposed Regulatory Language Program Elements Updated Table of MIRs Schedule

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Legal RequirementsLegal Requirements

Statutory Requirement for review

Public Process for review

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Public Process to Public Process to Adopt RegulationsAdopt Regulations

Staff Report and proposed Regulation released 45 days prior to October Board Hearing

Public review during this time

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Proposed CLEAR Proposed CLEAR Regulation For Aerosol Regulation For Aerosol

Coating ProductsCoating ProductsSections 94530 - 94539Sections 94530 - 94539

Voluntary Alternative to the Existing Aerosol Coating Regulation

Reactivity Based VOC Limits Requirements Parallel Current

Regulation

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Section 94531 - Section 94531 - DefinitionsDefinitions

VOC definition in Aerosol Coating

Regulation does not apply

Proposing 15 New Additional Definitions

Reactivity Related Terms

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Section 94532 - Section 94532 - CLEAR LimitsCLEAR Limits

Table of Limits

Two Methods

Percent Reduction

Complying Products

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Proposed Percent Proposed Percent Reduction Method Reduction Method to Set Limitsto Set Limits

Equivalence to “Percent Reduction” Aerosol Coating Product

Current Sales-Weighted Average VOC content

is 60% by weight.

Proposed Limit is 45% by weight.

Thus, a 25% mass reduction in VOC content.

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Percent Reduction Percent Reduction MethodMethodSteps

(1)Determine % reduction to the proposed VOC limit

(2)Calculate SWA-MIR for an

Aerosol Coatings Category

(3)Apply % reduction to MIR

of category

(4)Result = wtd-MIR Limit for

category

ExampleReduce emissions by 25%

MIRcat = 1.86 (g O3/ g product)

Reduce MIR by 25%

= (1 - 0.25) x 1.86 = 1.40 (g O3/ g product)

Wtd-MIR Limit

= 1.40 ( g O3/ g product)

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Determine the sales-weighted MIR of the complying products for the category:

= (wtd-MIR for each complying product x sales)/ sales

= SWA-MIR of complying products

= CLEAR Limit

Complying Market Share Method

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Composite Paint Formula and Composite Paint Formula and Calculation of Weighted Calculation of Weighted ReactivityReactivity

Weight WeightedContents Percent MIR Reactivity

acetone 35% 0.48 0.17toluene13% 4.19 0.54

propane 12% 0.64 0.08

xylene 8% 7.77 0.62

isobutane 12% 1.56 0.19

solids 20% 0 0.00

Total 100% 1.60

Product MIRabs = 1.60 g O3/g product

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Section 94533 - Section 94533 - Assignment of Assignment of

Maximum Incremental Maximum Incremental Reactivity (MIR) ValuesReactivity (MIR) Values

MIR value of Zero is assigned to:

Non-Carbon Containing Ingredients

CO2, Carbonic Acid, Metallic Carbides or

Carbonates, Ammonium Carbonate

Coating Solids

All other VOCs assigned a MIR value

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Establishing Establishing Uncertainty Factors Uncertainty Factors for MIRsfor MIRs

Need factors reflecting uncertainty associated with MIRs of individual compounds

Dr. Carter’s uncertainty rankings as basis

Proposals Uncertainty Bins Use of Upper-Limit MIRs

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Uncertainty Factor Uncertainty Factor ApproachApproach

Carter Uncertainty Ranking Uncertainty Factor

1 - 5, 9* 1.06 - 8, 10, 11 2.0

* Ranking of “9” infers that the current mechanism is expected to (or has been found to) over-predict reactivity.

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Upper Limit Upper Limit MethodologyMethodology

Methodology developed by Dr. Carter of University of California at Riverside

Published methodology based on interpretations from practical, experimental evidence

Discussed at February meeting

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MethodologyMethodology

Upper-Limit MIR = Kinetic Reactivity x Mechanistic Reactivity,

where ULMIR is in units of g O3 formed / g VOC emitted,Kinetic Reactivity is fraction of VOC reacting (unitless), andMechanistic Reactivity is g O3 formed / g VOC reacting.

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Upper Limit MIR Upper Limit MIR ProposalProposal

Propose to use methodology if no MIR value on Dr. Carter’s list

Reflects new chemical mechanism Affects less than one percent-by-

weight of reported aerosol coating VOCs

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Assigning MIRs to Assigning MIRs to Hydrocarbon Hydrocarbon SolventsSolvents

Used in aerosol coatings Solvents with constituents of

normal, branched and cyclic alkanes, and aromatic compounds

Goal is to identify classes or ‘bins’ and assign MIR value to each bin

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Categorizing Categorizing Hydrocarbon SolventsHydrocarbon Solvents

Binning criteria: Boiling range Aromatic content Alkane content

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SummarySummary

Statutory Requirement Voluntary Alternative to mass-

based Regulation Equivalent O3 Reductions

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Proposed CLEAR Proposed CLEAR Regulation Uses the Regulation Uses the MIR ScaleMIR Scale

Proposed regulation based on Dr. Carter’s August 6, 1998, updated Table of MIRs

Industry comments on list Review process

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Aerosol Coatings Aerosol Coatings ScheduleSchedule

• September 4, 1998

• October 22, 1998

Release Staff Report for Proposed Regulation

Board Hearing