1 Proposed California Low Emissions and Reactivity (CLEAR) Regulation For Aerosol Coating Products Meeting of the Reactivity Scientific Advisory Committee August 26, 1998 Riverside, California California Environmental Protection Agency Air Resources Board

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

3 Legal Requirements v Statutory Requirement for review v Public Process for review

4 Public Process to Adopt Regulations v Staff Report and proposed Regulation released 45 days prior to October Board Hearing v Public review during this time

5 Proposed CLEAR Regulation For Aerosol Coating Products Sections v Voluntary Alternative to the Existing Aerosol Coating Regulation v Reactivity Based VOC Limits v Requirements Parallel Current Regulation

6 Section Definitions v VOC definition in Aerosol Coating Regulation does not apply v Proposing 15 New Additional Definitions u Reactivity Related Terms

7 Section CLEAR Limits v Table of Limits v Two Methods u Percent Reduction u Complying Products

8 Proposed Percent Reduction Method to Set Limits v Equivalence to “Percent Reduction” u Aerosol Coating Product u Current Sales-Weighted Average VOC content is 60% by weight. u Proposed Limit is 45% by weight. u Thus, a 25% mass reduction in VOC content.

9 Percent Reduction Method Steps (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 Example Reduce emissions by 25% MIR cat = 1.86 (g O 3 / g product) Reduce MIR by 25% = ( ) x 1.86 = 1.40 (g O 3 / g product) Wtd-MIR Limit = 1.40 ( g O 3 / g product)

10 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

11 Composite Paint Formula and Calculation of Weighted Reactivity Weight Weighted ContentsPercentMIR Reactivity acetone35% toluene13% propane12% xylene 8% isobutane12% solids20% Total 100% 1.60 Product MIR abs = 1.60 g O 3 /g product

12 Section Assignment of Maximum Incremental Reactivity (MIR) Values v MIR value of Zero is assigned to: u Non-Carbon Containing Ingredients u CO 2, Carbonic Acid, Metallic Carbides or Carbonates, Ammonium Carbonate u Coating Solids v All other VOCs assigned a MIR value

13 Establishing Uncertainty Factors for MIRs v Need factors reflecting uncertainty associated with MIRs of individual compounds v Dr. Carter’s uncertainty rankings as basis v Proposals v Uncertainty Bins v Use of Upper-Limit MIRs

14 Uncertainty Factor Approach Carter Uncertainty RankingUncertainty Factor 1 - 5, 9* , 10, *Ranking of “9” infers that the current mechanism is expected to (or has been found to) over-predict reactivity.

15 Upper Limit Methodology v Methodology developed by Dr. Carter of University of California at Riverside v Published methodology based on interpretations from practical, experimental evidence v Discussed at February meeting

16 Methodology Upper-Limit MIR = Kinetic Reactivity x Mechanistic Reactivity, where ULMIR is in units of g O 3 formed / g VOC emitted, Kinetic Reactivity is fraction of VOC reacting (unitless), and Mechanistic Reactivity is g O 3 formed / g VOC reacting.

17 Upper Limit MIR Proposal v Propose to use methodology if no MIR value on Dr. Carter’s list v Reflects new chemical mechanism v Affects less than one percent-by-weight of reported aerosol coating VOCs

18 Assigning MIRs to Hydrocarbon Solvents v Used in aerosol coatings v Solvents with constituents of normal, branched and cyclic alkanes, and aromatic compounds v Goal is to identify classes or ‘bins’ and assign MIR value to each bin

19 Categorizing Hydrocarbon Solvents v Binning criteria: v Boiling range v Aromatic content v Alkane content

20 Summary v Statutory Requirement v Voluntary Alternative to mass-based Regulation v Equivalent O 3 Reductions

21 Proposed CLEAR Regulation Uses the MIR Scale v Proposed regulation based on Dr. Carter’s August 6, 1998, updated Table of MIRs v Industry comments on list v Review process

22 Aerosol Coatings Schedule September 4, 1998 October 22, 1998 Release Staff Report for Proposed Regulation Board Hearing