1. September 2012

2. California Air Resource Board 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 2

3. The South Coast Air Quality Management District includes all of Orange County and portions of Los Angeles, San Bernardino and Riverside Counties, an area of 10,743 square miles with 16.5 million people and 10 million vehicles. South Coast Air Quality Management District South Coast Air Quality Management District

5. SCAQMD Background  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 5

6.  Population -  4.8 Million 16.5 Million  Vehicles -  2.3 Million 10.5 Million  Manufacturing -  $10.5 Billion$203.8 Billion  Peak Ozone Levels -  0.68 ppm 0.18 ppm Since 1950s

7. Major Source Contribution To VOC (2023) 2023 VOC = 530 tons/day Source: 2012 AQMP

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9. Background  Paint Thinners and Multi-Purpose Solvents previously unregulated  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 9

10. 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 consumer products categories already regulated by CARB 10

11. Examples of Currently Available Products Thinners that Do Not Contain Acetone 25 g/L VOC or less 11

12. Examples of Currently Available Products Thinners That Contain Acetone 25 g/L VOC or less 12

13.  Industry provides cost- effective alternatives  Relatively low in toxicity  Significant emission reductions:  9.75 tpd in AQMD  More than 20 tpd statewide 13 A Success Story…Right?

14. Preemption 14  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

15. LVP Solvent Exemption 15  Low Vapor Pressure (LVP) Solvents defined as:  Vapor pressure less than 0.1 mmHg  Boiling point greater than 216°C  More than 12 carbon atoms  LVP exempted by ARB in consumer products; but not elsewhere  Not exempt in AQMD; even for consumer products  Manufacturers using preemption to gain access to LVP solvent exemption

16. Physical Properties of Chemicals 1 MIR of Ethane = 0.27 2 CARB Bin 11-G ChemicalCAS Carbon Atoms Boiling Point (°C) Vapor Pressure (mm Hg @ 25C) MIR 1 Isopropyl alcohol67-63-0383440.61 Propylene glycol57-55-631880.132.58 Ethylene glycol107-21-121980.093.13 Texanol25265-77-4122440.010.76 Pentadecance (C15)629-62-9152700.010.50 Conosol 200 (Light Distillate)64742-47-89 to 16216 to 278<0.01 to 0.30.65 2 TXIB6846-50-0162800.0040.38 Hexadecane (C16)544-76-3162870.0050.45 Glycerol56-81-53290<0.0013.15 2 Methyl hexadecane1560-92-517291<0.01N/A Heptadecane (C17)629-78-717302<0.0010.42 Eicosane (C20)112-95-8203430.00010.36 16 Difficult to Correlate Physical Properties with Overall Volatility Not an LVP

17. 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 Evaporative Studies Project Goal 17

18. Process Characterization Brush Cleaning Emissions result from: 1. Evaporation During Cleaning 2. Carry-Out of Solvent on Parts (Brushes) Cleaned 3. Disposal of Spent Solvent Spent Solvent Disposal Evaporation EPA, AP-42 “Compilation of Air Pollutant Emission Factors”, Chapter 4, Section 6 Carry-Out 18

19. 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”) 19

20. Modeled Test Results Relative Ozone Formation 20 * Compliant with SCAQMD Rule 1143 – Final Rule Limit BrushPanelTotal Acetone/Soy blend * 11.427.0318.45 Lacquer Thinner * 19.562.9822.54 Acetone * 21.302.9224.22 Conosol 200 20.0711.4631.53 DnPB 58.0615.6873.74 Aromatic 200 143.5038.22181.72 Benzyl Alcohol 179.6952.77232.46 District-Wide Contribution from Brush and Panel Cleaning Evaluated based on Presumed Sales Distributions, Normalized to Modeled Use Rate

21. Ambient Evaporation Study Parameters 21 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

22. Overall Summary Ambient Evaporation Study 22

23. Non-Volatiles - Isolated Ambient Evaporation Study 23

24. Semi-Volatiles – Isolated Ambient Evaporation Study 24

25. Volatiles - Isolated Ambient Evaporation Study 25

26. Comparison Between Known VOC and Light Distillate Ambient Evaporation Study 26 Light Distillate is a “compliant” LVP replacement for paint thinners and multipurpose solvents like IPA Consumer Product regulation claims more than 20 tons per day emission reduction from this control measure statewide

27. LVP Contribution to VOC Content 27 Source: SCAQMD test results from selected I&I products  Most paint thinners and multi-purpose solvents are now 100% LVP  More than 51% of VOC content in janitorial cleaning products  Some as high as 99% LVP  Over time, more and more consumer products are using LVP solvents

28. Major Source Contribution To VOC (2023) 2023 VOC = 530 tons/day Source: 2012 AQMP

29. Conclusions 29  Reassessment important part of regulatory process  Extended ambient temperature testing indicates some common LVP solvents readily volatilize  http://www.aqmd.gov/prdas/Coatings/VOCs/RedefiningVOCs.pdf http://www.aqmd.gov/prdas/Coatings/VOCs/RedefiningVOCs.pdf  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

30. 30 Mike Morris - Air Quality Specialist (909) 396-3282 mmorris@aqmd.gov South Coast Air Quality Management District