ATTACHMENT 6

VENTURA COUNTY APCD

STAFF REPORT

REVISIONS TO SOLVENT CLEANING REQUIREMENTS:

Rule 74.13, Aerospace Assembly and Component Manufacturing Operations

Rule 74.20, Adhesives and Sealants

Rule 74.24, Marine Coating Operations

July 24, 2012

EXECUTIVE SUMMARY

Staff is proposing to revise Rule 74.13, 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 

solvent cleaners, especially those solvents used to 

clean coating or adhesives spray equipment. This 

rule development will implement an All Feasible 

Measure as required by the California Clean Air Act

(HSC Section 40914). Ventura County APCD’s 

2007 Air Quality 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 AQMD 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 Equipment & Mobile 

Equipment Coating Operations

• Rule 74.19, Graphic Arts

• Rule 74.30, Wood Product Coatings

Staff is proposing to reduce ROC emissions from 

solvent cleaning operations at aerospace facilities 

(Rule 74.13) in Ventura County by lowering the ROC 

vapor pressure limit of coating application equipment 

cleaners from 45 to 5 mm Hg at 20o

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 facilities subject 

to Rule 74.20, 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 of 

200 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, and 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, all of the emission reductions are based 

on using low-ROC cleaners. Ultra-low ROC cleaners 

can contain either exempt organic compound or 

water-based cleaners. Examples of exempt organic 

compounds include acetone, acetone/methyl acetate 

blends, propylene carbonate, PCBTF, and t-butyl 

acetate. The existing rules allow the use of low 

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 emissions because the low-ROC 

cleaners are 0.2 pounds ROC per gallon versus 6.6 

pounds ROC per gallon for the low-vapor pressure 

cleaners.

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 20o

C. 

Although this proposal is not as effective as the 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 

Institute 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 cost savings to $0.18 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 Revisions, (3) 

Comparison of Proposed Rule Requirements with 

Other Air Pollution Control Requirements, (4) Impact 

of the Proposed Rule, and (5) Environmental Impacts 

of Methods of Compliance. The first section 
Staff 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 

revisions. 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, costeffectiveness, and socioeconomic 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 amendments 

in almost a decade. These include Rule 74.13, 

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 

solvent technology and the availability of lowreactive newly exempted organic solvents such as tbutyl 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 

cleaning 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 lowROC solvent cleaners to determine both cost 

and applicability.

In 2003, IRTA prepared 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 identify 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 

new 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 

report.

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 coatings or 

adhesives. Focusing on the solvent cleaning 

operations for these rules provides the most costeffective 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 industries. 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 spray equipment. On 

site demonstrations were successful at three different 

aerospace facilities, including Californian Propeller, 

Gulfstream, and Hydro-Aire.

California Propeller, a small aerospace subcontractor 

located in Burbank, was able to successfully switch to 

the low-ROC exempt solvent acetone instead of MEK 

solvent. Acetone is an exempt solvent because of its

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 cleaned 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 from 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 

cleaning alternatives. On site demonstrations were 

successful at two different facilities using adhesive 

spray equipment, including Hickory Springs and 

Medtronics.

Hickory Springs, a furniture manufacture located in 

Commerce, California, produces flexible slabstock 

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 soybased cleaner) and water. The acetone alternative 

reduced cleaning costs by 12 percent while the soybased cleaner was 85 percent less costly than using 

the lacquer thinner.

Medtronics Diabetes is a medical device 

manufacturer located in Northridge that uses 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 sensors to a medical 

patch 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 

replacement. 

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 spray 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 revisions

are shown in Table 1. This table provides the 

permitted or potential emissions from solvent 

cleaning operations located at each listed facility. 

The 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 Operations 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 Coating 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 REVISIONS

The proposed rule revisions 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 Operations

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 many 

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 stringency. 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 is 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 

exception 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 of 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 vapor pressure limit of 45 mm Hg 

for adhesive 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, tools, 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 without 

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” Consistent with Rule 74.6

B.4 Storage of ROC Containing Materials Consistent 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 Coatings Allow use of complying low solid 

materials

C.2 Clarify Low Use Exemption for Coatings and 

Adhesives

Consistent with Rule 74.12

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

D Clarify Recordkeeping Requirements Consistent with Rule 74.12

E.6 and E.7 Clarify Test Methods Consistent 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 Materials Consistent 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 Consistent with Rule 74.12

E.4 Clarify Test Method Consistent 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 of 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, Summary 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 

parameters

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 REQUIREMENTS

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.

Comparison 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 1996 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 

Solvents 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 Rules 74.13, 74.20, 74.24, and 

74.24.1. None of the 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 are 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 Rules 74.13, 74.20, 

74.24, and 74.24.1 be compared with Best Available 

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 solvent 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 PROPOSED 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 cleaning will contribute to over 90 percent of the 

total reductions. 

The 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 availability, 

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 versions 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 

background 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

Adhesive 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 $0.18 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 one 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 regulations 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 control 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 

small 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 boatyards, 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, including 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 costeffectiveness of $0.18 per pound of ROC 

reduced 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 

to Chapter 10 (commencing with Section 

40910).

Ventura County is classified as a serious

nonattainment area for the federal Ambient Air 

Quality Standards for ozone. These proposed 

rule amendments will reduce ROC emissions 

that are precursors to the formation 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 ozone 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 following information on proposed 

revisions to Rules 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 environmental 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 

Mitigation 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 solvents may cause water 

impacts

Compliance with wastewater 

discharge standards and waste 

disposal requirements will 

mitigate these impacts.

Human Health and Safety Impacts: 

Cleaning solvents may be replaced 

with products containing more toxic

or more flammable 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 enclosures may be

constructed around the control 

equipment.

This analysis demonstrates that the 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. Dow Corning OS-2 Silicone Cleaner and Surface Prep Solvent, Midland, MI.

www.dowcorning.com/applications/search/default.aspx?R=1241EN

2. Environmental 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 Categories: 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 Adhesives 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 Assessment to Determine the Relationship of Solvent Vapor Pressure and 

VOC Mass Emissions, Diamond Bar, California, April 10, 2002.

9. SCAQMD Rule 1171, Solvent Cleaning Operations, last amended May 1, 2009.

10. SCAQMD Workshop, “Safer Alternatives to Toxic Cleanup Solvents,” Diamond Bar, California, March 7, 

2007.

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

Products, last revised April 8, 2008.

12. VCAPCD Staff Report, “Revisions to Rule 74.12, Surface Coating of Metal Parts and Products,” February 28, 

2008.

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

14 VCAPCD Rule 74.18, Motor Vehicle and Mobile Equipment Coating Operations, last revised November 11, 

2008.

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

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

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

DISCLAIMER

This 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 Solvent 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 ENGINEERED 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. LACQUER 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. PG-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-SprayHD, ARMAKLEEN 4 IN 1 CLEANER 

Ray Ashley (609) 497-7571

Clea Care Essentials CLEA DEGREASER CL46540, CLEA DEGREASER 

CL46650 

Randy Block (888) 323-2532

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) 886-8240

(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

Graymills 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 (760) 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 WashSteam 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 Louie (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) 662-0333

(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, HURRISAFE 

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 CarltonCarew(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, QSOL 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