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September 5, 2006

Environmental Protection Agency (EPA) Docket Center

Public Reading Room (B102), EPA West

1301 Constitution avenue, NW

Washington, DC 20460

> Re: Consumer and Commercial Products-Industrial Cleaning Solvents;
> Docket No. EPA-HQ-OAR-2006-0535

Ladies and Gentlemen:

The National Automobile Dealers Association (NADA) represents 20,000
franchised automobile and truck dealers who sell new and used motor
vehicles and engage in service, repair and parts sales. Together they
employ in excess of 1,300,000 people nationwide yet a significant number
are small businesses as defined by the Small Business Administration

Last month, EPA asked for comment on a proposed Control Techniques
Guideline (CTG) for volatile organic compounds (VOCs) from industrial
cleaning solvents. 71 Fed. Reg. 44522, *et seq.* (August 4, 2006). In
response, NADA offers the following comments and suggestions.

**I. GENERAL COMMENTS**

Wherever possible, a national rule designed to limit potential VOC
emissions from industrial solvents is preferred, given that such a rule
would not impose direct regulatory burdens on end users such as
dealerships. Dealerships use solvents for:

> 1\. Parts cleaners, in conjunction with mechanical service and repair;
>
> 2\. Surface preparation, in conjunction with autobody repair;
>
> 3\. Spray gun cleaning, in conjunction with autobody refinishing; and
>
> 4\. Various spray applications using refillable or non-refillable
> containers, in conjunction with mechanical service and repair and
> autobody operations.

**II. MECHANICAL SERVICE AND REPAIR**

As mentioned above, dealerships and other vehicle service and repair
facilities clean parts in machines typically equipped with
petroleum-based solvents. In its 1994 comments on a proposed EPA cold
cleaning machine new source performance standard, NADA indicated that
these small parts cleaners typically have solvent air surfaces of less
than 1.8m^2^. 59 Fed. Reg. 46602, *et seq.* (September 9, 1994). NADA
also noted that parts cleaner manufacturers

voluntarily incorporate emissions-reducing features into their machines,
including minimum

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September 5, 2006

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freeboard, drain racks and covers. NADA also indicated that dealerships
were experimenting with alternative parts cleaners using aqueous
materials and bio-remediation.

In its 1994 comments addressing a proposed national emission standard
for hazardous air pollutants applicable to halogenated solvent cleaning,
NADA noted that halogenated solvents in regulated units rarely existed
in dealership service and repair shops, and typically only in enclosed
units with water barriers. 40 CFR §63.460. Dealerships today only, if at
all, use relatively minor amounts of halogenated solvents in refillable
and non-refillable cans.

Vehicle maintenance petroleum-based parts cleaners, both remote
reservoir (sink-on-drum) and immersion, are described in a report
entitled *Parts Cleaning in Auto Repair Facilities; The Conversion to
Water*; I.d. No. PJ-9993444-01-0 (April, 1997). That report also
suggested that aqueous based units may serve as appropriate alternatives
to petroleum-based solvent cleaners. As a practical matter, the utility
of aqueous based units depends on their specific application, and they
raise potential waste water concerns. While aqueous-based remote
reservoir and immersion cleaners cost roughly the same or a little more
to operate than solvent cleaners, aqueous cabinet units have the
advantage of significantly increasing technician labor efficiency.
Importantly, modern mineral spirit, petroleum naphtha and Stoddard
solvent formulations have very low reactivity and, in conjunction with
the design features of automotive parts cleaners, are *de minimis*
sources of VOCs.

**III. AUTOMOTIVE REFINISHING**

Automobile and truck dealerships manage around 8,000 autobody shops
nationwide. These shops often use cleaning solvents to prepare surfaces
and clean spray guns. Notably, EPA's national rule governing VOCs from
Automobile Refinish Coatings applies to paint system components and not
to cleaning solvents used in autobody shops. 40 CFR Part 59, Subpart B.
On the other hand, EPA presently is considering automobile refinish air
toxics controls that may impact the use of surface preparation and gun
cleaning solvents. Before moving forward with controls aimed at autobody
cleaning solvents VOC emissions, EPA should review potential controls
under consideration in the air toxics proceeding.

Assuming EPA decides to move forward with regulating automobile refinish
cleaning solvents, a national rule should be used to regulate the VOC
content of the cleaning solvents themselves, thereby avoiding any
unnecessary and burdensome regulation of end users. In the alternative,
a CTG applicable to automobile refinish operations should be no more
stringent than

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September 5, 2006

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the Bay Area Air Quality Management District Rule 45 provision governing
Surface Preparation and Solvent Loss Minimization (8-45-308), should
require all automobile refinish operations to use enclosed spray gun
washers, and should avoid any recordkeeping or reporting mandates.

**IV. CONCLUSION**

Consistent with the above, NADA urges EPA to issue a national rule that:

1\. Only regulates parts cleaner solvent formulations with greater than
5% VOC, by weight, and

2\. Sets a composite vapor pressure limit of 8 millimeters of mercury
(mmHg) for such solvent formulations.

Alternatively, if EPA moves forward with a CTG, it should:

1\. Provide clear-cut compliance guidance regarding how small
facilities, such as dealerships, calculate their cleaning solvent VOC
emissions, and

2\. Not impose any recordkeeping or reporting mandates.

On behalf of NADA, I thank EPA for the opportunity to comment on this
matter.

Respectfully submitted,

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Douglas I. Greenhaus

Director, Environment Health and Safety