### ATTACHMENT **6** VENTURA COUNTY APCD
STAFF REPORT
REVISIONS TO SOLVENT CLEANING REQUIREMENTS : R ule 74.13, Aerospace Assembly and Component Manufacturing Operations Rule 74.20, Adhesives and Sealants Rule 74.24, Marine Coating Operations
J u ly 24, 20 1 2

EXECUTIVE SUMMARY

S taff is proposing to revise Rule 74.1 3

, Aerospace Assembly and Component Manufacturing Operations

, Rule 74.20, Adhesives and Sealants, and Rule 74.24, Marine Coating Operations

, to reduce the reactive organic compound (ROC) emissions from the use of

solven t clean ers , especially those solvents used to clean coating or adhesives spray equipment . This

r ule development will implement an All Feasible

Measure as required by the California Clean Air Act (HSC Section 40914)

. Ventura County APCD’s

20 07 Air Qualit y Management Plan relies on adopting All Feasible Measures as a strategy to attain the ozone ambient air quality standard.

Proposed solvent cleaning requirements are based on ROC content limits in existing Ventura County coating rules and South Coast AQM D Rule 1171, Solvent Cleaning Operations. Existing Ventura County coating rules that already contain the proposed requirements include:

• Rule 74.12, Surface Coating of Metal Parts

• Rule 74.14, Polyester Resin Material Operations

• Rule 74.18, Motor Vehicle E quipment & Mobile Equipment Coating Operations

• Rule 74.19, Graphic Arts

• Rule 74.30, Wood Product Coatings

S taff is proposing to reduce ROC emissions from solvent cleaning operations at aerospace facilities (Rule 74.13) in Ventura County by lowering the RO C vapor pressure limit of coating application equipment cleaners from 45 to 5 mm Hg at 20 o C. Staff initially proposed the ultra

- low ROC content limit of 25 g/l for aerospace applications, but field testing results from these cleaners was unsatisfactory.

New ROC cleaning requirements for f acilities subject

to Rule 74.2 0, Adhesives and Sealants, include a new solvent cleaning ROC content limit of 25 g/l, except for inkjet printer head assembly, which would

continue to have the existing ROC content limit o f

2 00 g/l. In addition, adhesive cleanup including spray equipment cleaning would be also be subject to the new 25 g/l ROC content limit.

Similarly, the proposed new ROC content limit of 25 g/l is proposed for substrate surface preparation, cleanup, an d spray gun cleaning at marine coating operations (Rule 74.24). The proposed revisions may affect approximately 17 coating and/or adhesive spray operations (see Table 1)

. The permitted or potential ROC emissions from

these operations are approximately 18 tons per year. The estimated control effectiveness of the proposed

revisions is about 50 percent or 9 tons of ROC per

year. Except for aerospace coating cleaning operations, a ll of the e mission reductions are based

on using low

- ROC cleaners

. Ultra

- l ow ROC cleaners

can contain either exempt organic compound or

water

- based cleaners. Example s of exempt organic compounds include acetone

, acetone/methyl acetate blends, propylene carbonate, PCBTF, and t

- butyl

acetate. The existing rule s allow the use of l ow vapor pressure cleaners with a limit of 45 mm Hg for spray equipment cleanup

. Switching to low

- ROC cleaners for this cleaning process will reduce over 90 percent of the emission s because the low

- ROC

cleaners are 0.2 pounds ROC per gallon versus 6.6

pou nds ROC per gallon for the low

- vapor pressure

c leaners

.

The proposed new solvent cleaning requirements for aerospace coating cleaning is the lowering of the vapor pressure limit from 45 to 5 mm Hg at 20 o C. Although this proposal is not as effective as th e lower

mass

- based limit, the lower vapor pressure requirement will result in lower ROC emissions.

The estimated cost analysis for replacing existing cleaning products with low

- ROC versions was based on the 2003 technology assessment performed by the

Inst itute for Research and Assistance ( IRTA ) for South Coast AQMD Rule 1171 and the 2008 Ventura County APCD Staff Report for revisions to Rule 74.12, Coating of Metal Parts and Products . The

cost

- effectiveness for these cleaner replacements ranged from a co st savings to $0.1 8 per pound of ROC reduced. This indicates that the proposal is
very cost

- effective especially relative to new sources, which may be required under New Source Review to spend $9 per pound of ROC reduced to install best

available control technologies (BACT).

This report contains five additional sections: (1) Background, (2) Proposed Rule Re visions , (3) Comparison of Proposed Rule Requirements with Other Air Pollution Control Requirements, (4) Impact of the Proposed Rule, and (5) Envir onmental Impacts

of Methods of Compliance. The first section

### S taff Report Page 2

provides background information including regulatory history, latest air pollution control technology and source description. The second section explains the key features of the proposed

revisi ons. The third section compares the proposed requirements with existing federal requirements and Best Available Control Technology (BACT). The fourth section is an analysis of the proposed

amendment's effect on ROC emissions , cost

effectiveness, and soci oeconomic impacts. The last section examines the environmental impacts of compliance methods and the mitigations of those impacts.

BACKGROUND

Introduction

Several of the coatings and adhesives regulations in Ventura County have not had significant am endments

in almost a decade. These include Rule 74.1 3

, Aerospace Assembly and Component Manufacturing Operations

, Rule 74.20, Adhesives and Sealants, and Rule 74.24, Marine Coating Operations

. In the meantime, recent developments in low

- ROC cleaning

solv ent technology and the availability of low

reactive newly exempted organic solvents such as t

butyl acetate and propylene carbonate has allowed the

formulation of ultra

- low (less than 25 grams per liter) cleaning solvents to replace high

- ROC cleaners in a wide range of cleaning applications. This has provided the opportunity to further reduce ROC emissions from both coating and adhesives sources, particularly in the area of spray equipment cleaning.

The technical justification for the more stringent

cle aning ROC limits in these rules is based on the following:

1. These new low

- ROC solvents have been used successfully at coating and adhesive operations in both Ventura County and the

South Coast for several years

.

2. These requirements have been in effect in a number of existing Ventura County APCD

rules and in South Coast AQMD Rule 1171 since July 2005.

3. The South Coast AQMD has published technology assessments on the new low

ROC solvent cleaners to determine both cost and applicability.

In 2003, IRTA prepar ed a report for the South Coast AQMD, entitled “Assessment, Development and

Demonstration of Low

- VOC Cleaning Systems for SCAQMD Rule 1171.” IRTA investigated and

tested low and Non

- VOC alternatives in a variety of cleaning processes. The aim was to ide ntify cleaning technologies that could be substituted for existing high VOC technologies. The target VOC content for the spray equipment application for this study was 25 grams per liter, which is the same as the new ROC content limit being proposed. The spray equipment cleaning operations at three aerospace companies (Hydro

- Aire, Gulfstream, and California Propeller) and two companies (Hickory Springs and VACCO) using adhesives were evaluated by IRTA.

Besides performing technology assessments on the

n ew low

- ROC cleaners, the South Coast AQMD

maintains a current list of Clean Air Solvents on their website. Clean Air Solvents have been certified by SCAQMD to be less than 25 grams of ROC per liter. The current list may be found in Appendix A of this

rep ort.

Although the coatings and adhesives rules subject to this proposed revision have not been amended in a long time, the proposal will only focus on the solvent cleaning requirements associated with those rules rather than those impacting individual coa tings or adhesives. Focusing on the solvent cleaning operations for these rules provides the most cost

effective way to achieve the most emission reductions. However, some minor changes to recordkeeping requirements, definitions

, or test methods may be proposed for clarification purposes or to achieve consistency with other district rules.

Aerospace Operations

– Case Studies

The 2003 IRTA report focused on reducing ROC

emissions from many different types of solvent cleaning operations at numerous in dustries. The aerospace industry was one of the main industries analyzed by their technology assessment. This study evaluated the effectiveness of replacing high

- ROC cleaning solvents with low

- ROC cleaning alternatives for cleaning aerospace coating sp ray equipment. On

site demonstrations were successful at three different aerospace facilities, including Californian Propeller, Gulfstream, and Hydro

- Aire.

California P ropeller, a small aerospace subcontractor located in Burbank, was able to successfull y switch to

the low

- ROC exempt solvent acetone instead of MEK solvent. Acetone is an exempt solvent because of it s low photochemical reactivity. The acetone at $3.32

### Staff Report Page 3

per gallon is thirty

- five percent less expensive than MEK, which is priced at $5.12 per gallon. The coatings used at this facility are typical aerospace coatings, including chromated epoxy primer and polyurethane topcoat.

Similarly, the aerospace coatings used at the Gulfstream aircraft manufacturing facility in Long Beach are easily clean ed using the exempt ROC solvent acetone. According to the 2003 Technology Assessment, when this facility switched from the existing lacquer thinner to acetone, it reduced overall cleaning costs by 75 percent.

Another aerospace company that switched f rom MEK to acetone to clean aerospace coating spray equipment is Hydro

- Aire, a Boeing subcontractor based in Burbank. Hydro

- Aire was able to continue using their existing spray gun washer and their cleaning costs were reduced by approximately 31
percent.

Adhesive Bonding Operations

– Case Studies

The 2003 IRTA report also focused on reducing ROC

emissions from solvent cleaning of adhesive spray equipment. This study evaluated the effectiveness of replacing high

- ROC cleaning solvents with low

- ROC

clean ing alternatives. On site demonstrations were

successful at t wo different facilities using adhesive spray equipment , including Hickory Springs and

Medtronics

.

Hickory Springs, a furniture manufacture located in Commerce, California, produces flexible sl abstock foam, and uses an acetone

- based adhesive to bond the foam pieces. Originally, this company was using lacquer thinner to clean the adhesive spray equipment. Two successful cleaning alternatives include acetone and a blend of Soy Gold 2000 (a soy

b ased cleaner) and water. The acetone alternative reduced cleaning costs by 12 percent while the soy

based cleaner was 85 percent less costly than using the lacquer thinner.

Medtronics Diabetes is a medical device manufacturer located in Northridge that u ses UV

radiation

- cured adhesives in its packaging and manufacturing operation. The Northridge facility produces both insulin pump therapy and continuous glucose monitoring systems. One of the operations used to bond polycarbonate sensor s to a medical

p atch was able to switch to a complying water

- based cleaner called Mirachem 500. Cleaning of other automated medical device assembly machines was accomplished using acetone in place of isopropyl alcohol, and there was no additional cost for this replaceme nt.

Marine Coating Operation

– Case Study

Metrex, a valve manufacturer from Glendora, rebuilds, refurbishes, and builds various valves designed to withstand the marine environment. They were using lacquer thinner to clean the spray equipment used to s pray solvent

- based coatings. They successfully switched to an acetone cleaner that reduced material costs by 18 percent.

Emission Source Inventory

The twenty operations currently permitted by the

District that are subject to the proposed rule revision s are shown in Table 1. This table provides the permitted or potential emissions from solvent cleaning operations located at each listed facility.

T he estimated total permitted emissions from this source category is approximately 18 tons of ROC per

year. The actual emissions depend on the production

level and the corresponding coating or adhesive usage at each of the affected facilities.

### Staff Report Page 4



### Table 1. Permitted O perations Subject to Proposed Rule Revisions

Facility Name Permitted ROC

Emissions (tons/year) Type of Operation SIC Code

Aquaria Inc. 0.42 Aquarium Products 3231
California Air National Guard 0.81 Military 9711 CP Aviation, Inc. 0.04 Aircraft Parts 3728 Custom Industrial Finishes, LLC 1.7 Coati ng Application 3479 Elite Metal Finishing 0.05 Electroplating 3471
ERG International 0.8 Furniture 2522 General MagnaPlate 0.73 Electroplating 3471

L

- 3 Communications Corp. 0.8 Radar/Sonar 3812 Meggitt Safety Systems Inc. 1.21 Aircraft Parts 3728
Metalcrafters 1.81 Coating Application 3499 Milgard Manufacturing 4.03 Window/Door Mfg. 3211 Naval Base Ventura County 3.31 Military 9711 Packaging Corp 0.28 Corrugated Box Mfg. 2653

Pentair Pool Products 0.13 Pool Products 3648 Ricoh Printing Systems 0.1 Inkjet Printer Mfg. 3955 Royal Coatings 1.21 Coating Application 3479 Talley Actuators 1.0 Aircraft Parts 3728

TOTAL PERMITTED EMISSIONS 18.43

PROPOSED RULE RE VISIONS

The proposed rule revisi ons will reduce ROC emissions from solvent cleaning processes at aerospace facilities (Rule 74.13), bonding operations (Rule 74.20), and marine coating operations (Rule 74.24). Even though there are many similarities in the cleaning processes from each of the source categories, it is necessary to review each rule separately to account for any significant differences in each of the operations.

Rule 74.13, Aerospace Assembly and Component Manufacturing Ope rations

Staff is proposing to reduce ROC emissions from cleaning coating application equipment by lowering the current vapor pressure limit of 45 mm Hg to 5 mm Hg (Subsection B.2.b)

. Field testing at the Navy’s aerospace coating operations at Point Mugu showed inadequate cleaning performance using the

ultra

- low ROC cleaners. Instead, staff is proposing to lower the existing vapor pressure limit to 5 mm Hg. The Navy has been using a cleaner manufactured by Inland Technologies (EP

- 921) successfully for ma ny years, and the vapor pressure of this product is less than 1 mm Hg.

The draft rule proposal also contains many changes designed to clarify existing requirements without changing the rule stringenc y. These proposed changes to Rule 74.13 are summarized in Table 2.

Rule 74.20, Adhesives and Sealants

The proposed change to the solvent cleaning requirements in Subsection B.4 impact the substrate surface preparation solvents used to clean surfaces prior to bonding. The new requirement for this operation i s an ROC content limit of 25 grams per liter in place of the 70 g/l limit in the existing rule. Staff is not proposing to change the special allowance for inkjet printer head cleaning, in which the ROC content limit remains at 200 grams per liter. This

e xception is based on current operations at the inkjet head manufacturer, Ricoh of Simi Valley. The other significant proposed change to this requirement is the replacement of the ROC vapor pressure limit of 45 mm Hg with the mass

- based ROC content limit o f 25 grams per liter for Single Ply Roof Membrane Installation. Prior to adopting this change, staff will contact the Singe Ply Roof Institute to obtain feedback on this proposal.

In Subsection B.5 and B.7, staff is proposing to replace the existing vapo r pressure limit of 45 mm Hg

for adhesiv e cleanup (Subsection B.5) and for cleaning adhesive spray equipment (Subsection B.7)

### Staff Report Page 5

with the mass

- based ROC content limit of 25 grams per liter. Adhesive cleanup is the removal of uncured adhesive from parts, tool s, or work areas. As discussed earlier, the proposed change from a vapor pressure limit to a low

- ROC content limit results in a

96 reduction in emissions. This draft rule proposal also contains many changes designed to clarify existing requirements wit hout changing the rule stringency. These proposed changes to Rule 74.20 are summarized in Table 3.



### Table 2. Summary of Clarifications to Rule 74.13, Aerospace Assembly and Component Manufacturing

RULE SUBSECTION(S) CLARIFICATION OBJECTIVE /EXPLANATION

B.2 and G. 48 Define “Solvent Cleaning” Consisten t with Rule 74.6

B.4 Storage of ROC Containing Materials Consisten t with Rule 74.12

B.5e and B.5.f Clarify HVLP Spray Equipment Requirements Allow alternative test methods

B.10 Low

- Solid Adhesives and Co atings Allow use of complying low solid

materials

C.2 Clarify Low Use Exemption for Coatings and

Adhesives Consisten t with Rule 74.12

C.6 Clarify existing exemption for vapor degreasers. Consisten t with current practice

D Clarify Recordkeeping Requireme nts Consisten t with Rule 74.12

E.6 and E.7 Clarify Test Methods Consisten t with Rule 74.12



### Table 3

. Summary of Clarifications to Rule 74. 20

, Adhesives and Sealants

RULE SUBSECTION(S) CLARIFICATION OBJECTIVE /EXPLANATION

B. 6 Storage of ROC Containing Ma terials Consisten t with Rule 74.12

B.8.b

– B.8.d No longer specifies control equipment parameters Duplicates APCD permit conditions

C.6 Deletes Provision Allowing Sell Through of

Adhesives No longer needed because the deadline for this allowance is past.

D Clarify Recordkeeping Requirements Consisten t with Rule 74.12

E. 4 Clarify Test Method Consisten t with Rule 74.12

Rule 74.24, Marine Coating Operations

Staff is proposed to replace the vapor pressure limit of 45 mm Hg for general coating cleanup and coating spray equipment cleaning with the mass

- based ROC content limit of 25 grams per liter (Subsection B.4.a). In Subsection B.4.b, staff is proposed to lower the ROC content limit for substrate surface cleaning from 200 to 25 grams ROC per liter o f material. The only other proposed change to the solvent cleaning requirements is the proposed deletion of the exemption in Subsection C.5, which allows the use of up to 5 gallons per year of noncomplying solvents. Since acetone is an exempt ROC solvent , this exemption is no longer needed.

This draft rule proposal also contains many changes designed to clarify existing requirements without changing the rule stringency. These proposed changes to Rule 74.24 are summarized in Table 4.

### Staff Report Page 6



### Table 4, Su mmary of Clarifications to Rule 74.24, Marine Coatings

RULE
SUBSECTIONS CLARIFICATION OBJECTIVE/EXPLANATION

B.1 and B.2 Allow the Use of Complying Low

- Solid Coatings Consistent with other coating rules

B.3 No longer specifies control equipment
paramete rs Duplicates APCD permit conditions

B. 5 Storage of ROC Containing Materials Consistent with Rule 74.12

D Clarify Recordkeeping Requirements Consistent with Rule 74.12

E. 3 Clarify Test Method Consistent with Rule 74.12

COMPARISON OF PROPOSED RULE R EQUIREMENTS
WITH OTHER AIR POLLUTION CONTROL REQUIREMENTS

Health and Safety Code Section 40727.2 requires Districts to compare the requirements of a proposed revised rule with other air pollution control requirements. These other air pollution control requirements include federal New Source Performance Standards (NSPS), federal National

Emissions Standards for Hazardous Air Pollutants (NESHAPS), Best Available Control Technology (BACT) and any other District rule that applies to the same equipment.

Com parison with Federal NSPS and NESHAPS

The federal NESHAPS that may impact aerospace operations is the 1998 Maximum Achievable Control Technology (MACT) for Aerospace. The federal NESHAPS that will impact the shipbuilding and ship repair industry is the 1 996 Control Techniques Guidelines for Shipbuilding and Ship Repair Operations. The federal Control Techniques Guidelines (CTG) for adhesive operations is the 2008

CTG for Miscellaneous Industrial Adhesives. Finally, the 2006 CTG for Industrial Cleaning

S olvents is the most applicable federal guidance on the proposed solvent cleaning requirements for this rule development. The elements of the NSPS

, NESHAPS , and CTGs were compared to proposed

amendments to Rule s 74.1 3, 74.20, 74.24, and

74.24.1 . None of t he proposed amendments to these

rules affect the: • Units used for emission standards

• Monitoring Frequency

• Test Methods

• Recordkeeping Requirements No emission averaging provisions or reporting requirements are contained in these rules . In summary, there a re no conflicting requirements with

the federal NSPS

, NESHAPS , or CTGs

.

Comparison with BACT Requirements

Health and Safety Code Section 40727.2 (a) requires that the proposed amendments to Rule s 74.13, 74.20, 74.24, and 74.24.1 be compared with Best A vailable Control Technology. The CAPCOA Engineering Manager Rule Development Subcommittee developed guidance on this matter. Under this guidance, it was recommended that BACT be interpreted as a District’s BACT determination.

BACT for the industrial solv ent cleaning was determined by comparing the proposal to South Coast AQMD Rule 1171, Solvent Cleaning Operations, the most stringent rule of this type in California. Besides using the South Coast rule as BACT, existing VCAPCD Rules 74.12, 74.14, 74.18, 74 .19, and

74.30 also have the BACT ROC content limit for cleaning solvents at 25 grams per liter.

IMPACT OF THE PROPOS ED RULE

ROC Emissions Impacts

As shown earlier in Table 1, the permitted emissions (ROC) from solvent cleaning operations subject to proposed rule revisions are about 18 tons per year. The derivation of the projected ROC emission

reductions of 9 tons per year from the proposed

amendments are shown in Table 6 . The more wide

### Staff Report Page 7

spread use of low ROC cleaning solvents for spray gun clea ning will contribute to over 9 0 percent of the

total reductions.

T he ROC emission reductions from this source
category are significant , and all emission reductions

are needed to reach the federal and state ambient ozone air quality standards. The avail ability, feasibility, and cost

- effectiveness of the proposed cleaning solvents make this proposal worthwhile.



### Table 6

. Projected ROC Emission Reductions

Source Category Baseline

ROC

Emissions (tons/yr) Estimated

Control Efficiency ROC

Emission

Reductions (tons/yr) Spray Gun Cleaning 10.5 80 % 8.40

Surface Prep 0.4 88% 0.35

Cleanup 0.26 97 % 0.25

TOTAL 9. 0

Cost

- Effectiveness

According to the IRTA technology assessment, the costs were reduced when replacing spray gun cleaning solvent with low

- ROC ve rsions for many different source categories. The cost

reductions are summarized in Table 7 from the case studies of aerospace, adhesive, and marine coating operations described earlier in the

b ackground section of this report. The range of

cost reduction varied from 85 percent reduction to no change in costs.

Table 7

. Cost Reductions from Solvent Replacement Company Type of Operation % Cost

Reduction Calif Propeller Aerospace 35

Gulfstream Aerospace 75 Hydro

- Aire Aerospace 31 Hickory Springs Adhesiv e 85

Medtronics

Diabetes Adhesive No change

Metrex Marine 18

Another source of cost information was the 2008 Ventura County APCD Staff Report for revisions to Rule 74.12, Coating of Metal Parts and Products

, which involved similar requirements for the replacement of spray gun cleaning solvents . The cost

- effectiveness for these cleaner replacements ranged from a cost savings to $0.1 8 per pound of ROC reduced. This indicates that the proposal is
very cost

- effective especially relative to new sources, which may be required under New Source Review to spend $9 per pound of ROC reduced to install best available control technologies (BACT).



### Incremental Cost

- Effectiveness Analysis

Health and Safety Code Section 40920.6(a) requires districts to identify o ne or more potential control options, assess the cost

- effectiveness of those options,

and calculate the incremental cost

- effectiveness. Health and Safety Code Section 40920.6 also requires

an assessment of the incremental cost

- effectiveness for proposed r egulations relative to ozone, carbon

monoxide (CO), sulfur oxides (SOx), nitrogen oxides (NOx), and their precursors.

Incremental cost

- effectiveness is defined as the difference in control costs divided by the difference

in emission reductions between two potential control options achieving the same emission reduction goal of a regulation. The proposed amendments to the solvent cleaning requirements of Rule 74. 13, 74.20,

and 74.24 will require the most stringent viable ROC

limits and no other viable contr ol option can achieve the same amount of emission reductions. Therefore,

the incremental cost

- effectiveness analysis does not apply to this rulemaking.



### Socioeconomic Analysis

Assembly Bill 2061 (Polanco), which became effective January 1, 1992, requires that the District Board consider the socioeconomic impacts of any new rule. The Board must evaluate the following

socioeconomic information on proposed amendments to Rules 74.13, 74.20, and 74.24

.

(1) The type of industries or businesses, including

sm all business, affected by the rule or regulation.

The adoption of amendments to these rules may directly affect the twenty permitted operations in the county (see Table 1). These include aerospace, marine coating, pleasure craft coating, commercial boat yards, and other operations that involve the use of commercial

adhesives.

(2) The impact of the rule amendments on employment and the economy of the region.

### Staff Report Page 8

Revisions to these rules are not expected to have a negative impact on either employment or the economy of Ventura County. According to the cost analysis of the proposed revisions, some companies may benefit from reduced material costs, which should help economic growth.

(3) The range of probable costs, including costs to industry or business, incl uding small business, of the rule or regulation.

Cost reductions were noted for several industries including aerospace, marine, and adhesive bonding operations. Based on an earlier staff report, a maximum cost

effectiveness of $0.18 per pound of ROC

red uced may be expected for replacement of cleaning solvents used for spray gun cleaning.

(4) The availability and cost

- effectiveness of alternatives to the rule or regulation being proposed or amended.

Since the proposed rule amendments are the

most cost

- effective control option, no other alternatives were analyzed. (5) The emission reduction potential of the rule or regulation.

The anticipated emission reduction potential of the proposed rule is about 9 tons per year of

ROC emissions. These emission reductions

result from the use of low

- ROC cleanup solvents and solvents used to clean application equipment.

(6) The necessity of adopting, amending, or repealing the rule or regulation in order to attain state and federal ambient air standards pursuant

t o Chapter 10 (commencing with Section 40910).

Ventura County is classified as a se rious

nonattainment area for the federal Ambient Air Quality Standards for ozone. These proposed

rule amendments will reduce ROC emissions that are precursors to the forma tion of ozone. According to the 2007 AQMP, these emission reductions will help the District in its effort to

attain the standards. California Health and Safety Code Section 40914(b)(2) requires that the District adopt every feasible measure to

reduce ozo ne precursors.

ENVIRONMENTAL IMPACTS OF METHODS OF COMPLIANCE California Public Resources Code Section 21159 requires the District to perform an environmental analysis of the reasonably foreseeable methods of compliance. The analysis must include the fo llowing information on proposed

revisions to Rule s 74.13, 74.20 and 74.24 :

(1) An analysis of the reasonably foreseeable environmental impacts of the methods of compliance. (2) An analysis of the reasonably foreseeable mitigation measures. (3) An analysis of the reasonably foreseeable alternative means of compliance with the rule or regulation.

Table 8 lists all reasonably foreseeable compliance methods, the environmental impacts of those methods, and measures that could be used to mitigate the environmen tal impacts.

### Staff Report Page 9

Table 8 Environmental Impacts and Mitigations of Methods of Compliance

Compliance Methods (including all reasonably foreseeable alternative means of compliance) Reasonably Foreseeable Environmental Impacts Reasonably Foreseeable Mitigatio n Measures

Reformulation of cleaning solvents Air Quality Impacts: Reformulation may result in the use of toxic

materials. Operators may use reformulated products with less or no toxic

materials.

Water Impacts: Improper disposal of cleaning sol vents may cause water impacts Compliance with wastewater discharge standards and waste disposal requirements will mitigate these impacts.

Human Health and Safety Impacts:

C leaning solvents may be replaced with products containing more toxic

or more flam mable compounds. Compliance with OSHA safety guidelines (e.g., personal protective equipment, prevention and response, emergency first aid procedures) reduces these impacts. Installation of Catalytic Oxidation

Add

- On Controls Solid Waste Disposal Impacts : May cause increase quantities of solid waste (catalyst material). Catalyst materials are valuable and are typically reclaimed and recycled. Noise Impacts: Fans and associated equipment with add

- on controls may

increase noise levels. Sound wall or e nclosures may be

constructed around the control equipment.

This analysis demonstrates that th e adoption of revisions to Rules 74.13, 74.20, and 74.24

, will not have a significant

effect on the environment due to unusual circumstances.

REFERENCES

1. D ow Corning OS

- 2 Silicone Cleaner and Surface Prep Solvent, Midland, MI. www.dowcorning.com/applications/search/default.aspx?R=1241EN

2

. Envi ronmental Protection Agency (EPA): Control Techniques Guideline for Industrial Cleaning Solvents, Sept

2006. EPA

- 453/R

- 06

- 001.

3

. EPA: “National Emission Standards for Hazardous Air Pollutants (NESHAP) and Control Techniques Guideline (CTG) for Source C ategories: Aerospace Manufacturing and Rework Facilities.” March 27, 1998. Federal Register Vol 63, No.59.

4

. Institute for Research and Technical Assistance (IRTA) , “ Assessment, Development, and Demonstration of

Low

- VOC Cleaning Systems for South Coast Air Quality Management District (SCAQMD) Rule 1171 ,” August 2003

5

. Institute for Research and Technical Assistance (IRTA) , “ Assessment, Development, and Demonstration of

Low

- VOC Materials for Cleaning Ultraviolet and Electron Beam Curable Coatings and Ad hesives for South Coast Air Quality Management District Rule 1171 ,” May 2006.

6

. PCL Data Sheet for PCL 2040 NOVOC Compliant Universal Solvent, Los Angeles, California, March 2009. www.pclautomotive.com/cleanAir.pdf

### Staff Report Page 10

7

. South Coast AQMD, Clean Air Certification Program, updated November 2009. http://aqmd.gov/rules/cas/index.html

8

. SCAQMD staff report, “Technology A ssessment to Determine the Relationship of Solvent Vapor Pressure and VOC Mass Emissions, Diamond Bar, California, April 10, 2002.

9

. S C AQMD Rule 1171, Solvent Cleaning Operations, last amended May 1, 2009.

1 0

. S C AQMD Workshop, “Safer Alternatives to Tox ic Cleanup Solvents,” Diamond Bar, California, March 7,

2007.

1 1

. Ventu ra County Air Pollution Control District (VCAPCD) Rule 74.12, Surface Coating of Metal Parts and

Products , last revised April 8, 2008.

1 2

. VCAPCD Staff Report, “Revisions to Rule 74.1 2, Surface Coating of Metal Parts and Products,” February 28,

2008.

1 3

. VCAPCD Rule 74.14, Polyester Resin Material Operations, last revised April 12, 2005.

1 4 VCAPCD Rule 74.18, Motor Vehicle and Mobile Equipment Coating Operations, last revised Novemb er 11,

2008.

1 5

. VCAPCD Rule 74.19, Graphic Arts, last revised June 14, 2011.

1 6

. VCAPCD Rule 74.30, Wood Product Coatings, last revised June 27, 2006.

1 7

. Ventura County Air Quality Management Plan, 2007 AQMP, adopted May 13, 2008.

DISCLAIMER

Thi s report contains references to company and product names to illustrate product availability. Mention of these names is not to be considered an endorsement by the Ventura County Air Pollution Control District.

### Staff Report Page 11

APPENDIX A. List of Certified Clean Air Sol vent Products & Companies

Company Products Contact Name Telephone

1st

- Enviro Safety, INC. ORGANIC CLEANER/DEGREASER MILITARY

STRENGTH Ted Tidwell (239) 283

- 2511 (239) 283

- 1222

3M Chemicals 3M NOVEC ENGI NEERED FLUID HFE

- 7200

3M NOVEC ENGINEERED FLUID 8200 Kurt Werner (651) 733

- 8494

Ace Coating Co. ENVIRO

- POWER GREASE & TAR REMOVER

ENVIRO

- POWER INDUSTRIAL CLEANER Benjamin

Heilbrunn (800) 672

- 7100 (619) 697

- 3300

AG Environmental SOYGOLD 1000, SOYCLEAR 1500 Kathy Radachi Steve Nogel (402) 492

- 3316 (402) 492

- 3353

American Bio

- Clean Corp ABC Weapons Cleaner (WC), ABC Parts Cleaner (PC), Nature's Way HS Tammy Dunn

John Finn (714) 758

- 1402

Armick Chemicals NAVSOLVE Blair Heethuis (616) 656

- 1819

Ashland Inc. Presstige FB 8535, Presstige FB 8536 James Woodward (302) 594

- 5667

Baker Petrolite CLO 3074, CLW 3075 Rebecca Goff (281) 276

- 5444

Bortz Distributing Co. LACQUE R THINNER LVLTO 1 Steve Bortz (818) 342

- 8922

Brulin & Co FORMULA 515 DD, FORMULA 815 GD

FORMULA 815 GD

- NF, FORMULA 815 MX

BRULIN 1696B, BRULIN 1990 GD

TERRA GREEN DEGREASER

, AQUAVANTAGE
3800B, AQUAVANTAGE 3800GD,

AQUAVANTAGE 3887GD David Keller (317) 923

- 3211

Buckeye International,

Inc. SHOP MASTER RTU Tim Patridge (314) 291

- 1900

Castrol Industrial Inc. COME

- CLEAN 900, TECHNICLEAN 2000

, CASTROL KLEEN 3602 Greg Golminas (630) 961

- 6683

Chemex Industries, Inc. P G

- 5000 Barry Greenberg (714) 832

- 8441

Chem Free Corp SW

- 1

, SW

- 3 , SW

- 4, SW

- 6/8, SW

- 6LF, SW

- 7

, SW

- LF Onofre Ortiz (770) 564

- 5593

ChemSolv Consultants ChemSolv 8002 Robert Gaeta (714) 340

- 8134

### Staff Report Page 12

Church & Dwight Co Inc ARMAKLEEN MM

- Recycle, ARMAKLEEN M HP

- 2

, ARMAKLEEN M

- GP, ARMAKLEEN MPC

ARMAKLEEN MM

- DIP , ARMAKLEEN MM

- Spray

HD, ARMAKLEEN 4 IN 1 CLEANER Ray Ashley (609) 497

- 7571

Clea Care Essentials CLEA DEGREASER CL46540

, CLEA DEGREASER

CL46650 Randy Block (888) 3 23

- 2532

DeltaGreen, LLC Delta Green Concentrate Julie Gayevska

Alex Sklar Anthony Miremadi (310) 329

- 1883

Diana Industries
International, Inc. HS

- 1000 ENGINE AND PARTS CLEANER Jason Medina (800) 275

- 3951 (714) 964

- 1480
Domino Amjet, Inc. WL

- 880 WASH

, WL

- 890 WASH

, MC

- 890 MAKE

UP

, W

- 0029 WASH Karen Farrell (847) 244

- 2501

Ecolink ECOLINK 250 SS, NAVSOLVE Donald Beck (800) 8 86

- 8240 (770) 621

- 8240

Ellis Paint Co. PCL 1720B

, PCL 2040

, PCL 2071B

, PCL 4040

, Ellis Paint 80/20 Ruben Laguna

Karen Hollinhurst (323) 261

- 8114 (800) 752

- 1566

Force Dry Cleaning COLD PLUS CLEANER John Kelleher (562) 422

- 1257

Gemtek Products SAFECARE AIRCRAFT(SC

- AIRCRAFT)

, SC

- 1000 Sarah Kristoff (602) 265

- 8586

Global RES, Inc. RENEWABLE PRODUCT 291 Heidi Gautschi (909) 627

- 1177

G raymills Corp GM 330

, GM 550

, GM 660 Robert E. Schmalz (773) 477

- 4100

Green Nest LLC Green Nest All Purpose Cleaner Lisa Beres (949) 387

- 3804

Hitachi America, Ltd. CL 1000 Low VOC Cleaning Solution Mike McKinney (704) 494

- 3008

Hondo, Inc. POWERHOUSE A Jess Karr (661) 589

- 1042

Imperial Western

Products SOY ME E

- 12

, ENFORCE MOLD RELEASE E

- 46

, ENFORCE CONCRETE RELEASE E

- 44 Jayson Cabanyog (7 60) 427

- 9377

Integra Environmental,

Ltd (formerly NW Technologies NATURE'S WAY HS HARD SURFACE CLEANER

, NATURE'S WAY PC PARTS CLEANER Cathy Kaiser

Dr. Jock R. Collins

D.E. Wantz

Irina Jackson (713) 680

- 1234 (626) 969

- 7531 (800) 883

- 1458

IPAX of California GREEN UNIKLEEN Alex Sklar Julie Gayevska (310) 532

- 0353

Jayne Products Power Wash

- Steam Wash 1

, Power Wash

Steam Wash 2 Melinda Lussier (310) 715

- 3070

JNJ Industries, Inc. GLOBAL TECH AQUA SONIC AQUEOUS

CLEANER FOR SOLDER PASTE AND FLUX

, Bob Enterkin (800) 554

- 9994

### Staff Report Page 13

GLOBALTECH HEAVY DUTY DEGREASER

Kafko International OIL EATER Rick Morgando (847) 763

- 0333 (800) 528

- 0334

Kelleher Equipment Supply, Inc. COLD PLUS CLEANER John Kelleher (562) 422

- 1257

Keteca USA, Inc. WATER WORKS Marilyn Romero (877) 418

- 1306 (602) 278

- 7789

Kyzen Corp. AQUANOX A4512P

, AQUANOX A4520

, METALNOX M6314

, METALNOX M6435 Joan Quitmeyer Carolyn Leary (615) 831

- 0888

Lubricating Specialties

Co. SUPER BLUE MEDIUM/ HEAVY DUTY

INDUSTRIAL CLEANER Antoria Loui e (562) 776

- 4000

Magnaflux DARACLEAN 200

, DARACLEAN 238

, DARACLEAN 257

, DARACLEAN 282 GF Kimberly Hayes

Tamie Simmons (847) 657

- 5300

Mamco International Corp BIO

- T MAX Michael McCauley (800) 442

- 4686 (925) 376

- 7921

Master Chemical TRIM TASK 2

, TRIM CLEAN 2020 Joe Snyder

Michael Pitman (419) 874

- 7902 (419) 450

- 1114 Metalube Corp. MC

- 509/4U CLEANER

, SC

- 510/4U CLEANER

, AMC

- 511/4U CLEANER Diana Willis (951) 279

- 9181

Mirachem MIRACHEM 250

, MIRACLEAN 250

, MIRACHEM

500

, MIRACLEAN 500

, MIRACHEM 750

, MIRACLEAN 750

, MIRACLEAN PRESSROOM

CLEANER

, MIRACHEM 500 COMMERCIAL PARTS

WASHER FLUID Pat Doughty Peter Davy (800) 847

- 3527 (800) 662

- 03 33 (602) 272

- 6066

NAVAIR NAVSOLVE EL SAYED ARAFAT (301) 342

- 8054

NCH Corp. MULTI

- MIST POW'R BLAST

, ANIMAL Carolyn Seroka (972) 438

- 0264

Orison Marketing, LLC VPW SC

- 1000

, EVAPO

- RUST M'Lissa Bergan (800) 460

- 2403 (325) 692

- 1135 Packaging Service Co.,

Inc. CROWN LOW

- VOC LACQUER THINNER

, CROWN

LACQUER THINNER NEXT Katia Baizan (281) 485

- 1458

PCI Of America HURRISAFE 9450 [PARTS WASHER DEGREASER]

, HURRISAFE 9100

, H URRISAFE

9065 CAST IRON DEGREASER WITH RUST

INHIBITOR Bobbie Pettit (301) 468

- 1700 (800) 222

- 1455

Petroferm, Inc. CLEAN SAFE 787C

, HYDREX LV Beth Bivins

Bill Breault (859) 312

- 4602

Service Line, Inc RENEGADE PARTS WASHER DETERGENT Tim Silvius (800) 774

- 7900

### Staff Report Page 14

Sierra Technologies & Industrial Specialties Ecomate

– FN

, Ecomate

– MPC

, Ecomate

- SDIP Olabisi Carlton

Carew (480) 966

- 2892

State Industrial Products NEW ERA Julie Kasprisin (800) 782

- 2436

Summit Industrial

Products SUR

- CLEAN Danna Hafner (903) 534

- 8021

Sunshine Makers SIMPLE GREEN CLEAN BUILDING ALL PURPOSE

CLEANER Theresa Provolt (800) 228

- 0709

System One Technologies, Inc. QSOL 200 Cleaner

, QS OL 220 Cleaner

, QSOL

300 Cleaner Paul Mansur (305) 593

- 8015

Walter Surface Technologies AF

- Weld

, Alustar 300

, Bio

- Rust

, E

- Weld 3

, Star 200

, UNO S

, UNO S F Nathalie Vezina (514) 630

- 2800

WaterWorks PREG MAGIC

, DEPARTURE

, PREFLIGHT Nancy Layman (706) 698

- 4405

(800) 858

- 4111

Zestron Corp ATRON AC

- 300

, ATRON SP

- 200 Sylvain

Chamousset (703) 589

- 1198 (888) 999

- 9116 Zymo International (formerly ABC, Inc.) SURFZYME HD Rob Whiteman (904) 213

- 7994