# Control Techniques Guidelines: Industrial Cleaning Solvents Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg1 of 290

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### i EPA 453/R-06-001 September 2006



# Control Techniques Guidelines: Industrial Cleaning Solvents

Sector Policies and Programs Division Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency RTP, NC Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg3 of 290

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### iii TABLE OF CONTENTS

Section Title Page No.

I. Introduction................................................................................................................ ..........1
II. Background and Overview ..................................................................................................2

III. Applicability ............................................................................................................. ...........5
IV. State and Local Regulatory Approaches..............................................................................6

V. Recommended Control Options...........................................................................................7

A. Recommended Control Measures............................................................................7 1 Work Practices.............................................................................................7 2 VOC Content Limit......................................................................................8 3 Alternative Composite Vapor Pressure Limit..............................................8

B. Suggested Exclusions...............................................................................................8 1 Categories Listed for Regulation under CAA Section 183(e) .....................8 2 Categories with Specific Exemptions under Bay Area 8-4-116 ..................9 3 Categories with Specific Exemptions under Bay Area 8-4-117 ..................9 4 Categories with Special Limits in South Coast AQMD Rule 1171(c) and exemptions in 1171(h) .............................................................9

VI. Impacts of Recommended Controls...................................................................................10

VII. References................................................................................................................ ..........12
Appendix A. 1994 Control Techniques Guidelines: Industrial Cleaning Solvents ................. A-1

Appendix B. Summary of Regulations in California Reviewed for Industrial Solvent Cleaning CTG ..................................................................................................................B -1
Appendix C. Summary of NAICS Codes for nonattainment facilities estimated to meet the applicability criteria recommended in the CTG.....................................................C-1

Appendix D. Number of nonattainment facilities organized by State that are estimated to meet the applicability criteria recommended in the CTG........................................... D-1

Appendix E. Costs and Emission Reductions for the Recommendation Concerning Solvent Substitution ....................................................................................................E-1 Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg5 of 290

### iv 

## NOTICE

This report is issued by the Sector Policies and Programs Division of the Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency to provide information to State and local air pollution control agencies. Mention of trade names and commercial products is not intended to constitute endorsement or recommendation for use. Copies of this report are available as supplies permit-from the Library Services Office (at 541-2777 or library.rtp@epa.gov) of the U S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711 They can also be downloaded from the FDMS e-docket websited ( www.fdms.gov ) by searching under Docket No. EPA-HQ-OAR-0535 or, for a nominal fee, from the National Technical Information Service, 5285 Port Royal Road, springfield VA 22161 (800) 553-NTIS)

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### 1 I. Introduction
Clean Air Act (CAA) section 172(c)(1) provides that state implementation plans (SIPs) for nonattainment areas must include “reasonably available control measures” (RACM), including “reasonably available control techniques” (RACT), for sources of emissions. Section 182(b)(2) provides that for certain nonattainment areas, States must revise their SIPs to include RACT for sources of VOC emissions covered by a control techniques guidelines document (CTG) issued after November 15, 1990 and prior to the area’s date of attainment.

The United States Environmental Protection Agency (EPA) defines RACT as “the lowest emission limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility.” 44 FR 53761 (Sept. 17, 1979). In subsequent Federal Register notices, EPA has addressed how states can meet the RACT requirements of the Act. Significantly, RACT for a particular industry is determined on a case-by-case basis, considering issues of technological and economic feasibility.

CAA section 183(e) directs EPA to list for regulation those categories of products that account for at least 80 percent of the VOC emissions, on a reactivity-adjusted basis, from consumer and commercial products in areas that violate the NAAQS for ozone (i.e., ozone nonattainment areas). EPA issued such a list on March 23, 1995, and has revised the list periodically. SeeMarch 23, 1995 (60 FR 15264); see also 71 FR 28320 (May 16, 2006), 70 FR 69759 (Nov. 17, 2005); 64 FR 13422 (Mar. 18, 1999). Industrial cleaning solvents are included on the current section 183(e) list.

This CTG is intended to provide state and local air pollution control authorities information that should assist them in determining RACT for industrial cleaning solvents. In developing this CTG, EPA, among other things, evaluated the sources of VOC emissions from the use of industrial cleaning solvents and the available control approaches for addressing these emissions, including the costs of such approaches. Based on available information and data, EPA provides recommendations for determining RACT for the categories at issue in this document.

States can use the recommendations in this CTG to inform their own determination as to what constitutes RACT in their particular areas. The information contained in this document is provided only as guidance. This guidance does not change, or substitute for, applicable sections of the CAA or EPA’s regulations; nor is it a regulation itself. This document does not impose any legally binding requirements on any entity. It provides only recommendations for state and local air pollution control agencies to consider in determining RACT. State and local pollution control agencies are free to implement other technically-sound approaches that are consistent with the CAA and EPA’s implementing regulations Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg7 of 290

### 2 The recommendations contained in this CTG are based on data and information currently available to EPA. These general recommendations may not apply to a particular situation based upon the circumstances of a specific source. Regardless of whether a State chooses to implement the recommendations contained herein through State rules, or to issue State rules that adopt different approaches for RACT for VOCs for offset lithographic printing and letterpress printing, States must submit their RACT rules to EPA for review and approval as part of the SIP process. EPA will evaluate the rules and determine, through notice and comment rulemaking in the SIP process, whether they meet the RACT requirements of the Act and EPA’s regulations. To the extent a State adopts any of the recommendations in this guidance into its State RACT rules, interested parties can raise questions and objections about the substance of this guidance and the appropriateness of the application of this guidance to a particular situation during the development of the State rules and EPA’s SIP approval process.

CAA section 182(b)(2) provides that a CTG issued after November 15, 1990 and before the date of attainment must include the date by which States must submit SIP revisions in response to the CTG. States subject to section 182(b) should submit their SIP revisions within one year of the date of issuance of this final CTG. States subject to CAA section 172(c)(1) may take action in response to this guidance, as necessary to attain.

The remainder of this document is divided into five (5) sections. Section II Provides Background and Overview, which lists the cleaning (unit) operations associated with industrial cleaning solvents and identifies the sources of VOC emissions from those cleaning operations. Section III describes the emissions threshold that applies to this CTG. Section IV summarizes state and local regulatory approaches for addressing such emissions. Section V describes the available control options for addressing VOC emissions and. lists categories of industries we are recommending for exclusion from this CTG. This information supplements the survey of state CTG summarized in Appendix B of the 1994 ACT. Section VI provides our proposed recommendations for RACT for industrial cleaning solvents.), and discusses the cost-effectiveness of the recommended controls. Section VII provides references.

II. Background and Overview
This category of consumer and commercial products includes the industrial cleaning solvents used by many industries. It includes a variety of products that are used to remove contaminants such as adhesives, inks, paint, dirt, soil, oil, and grease. Contaminants are removed from parts, products, tools, machinery, equipment, vessels, floors, walls, and other work production related work areas for a variety of reasons including safety, operability, and to avoid product contamination. The cleaning solvents used in these (unit) operations are, in many cases, generally available bulk solvents that are used for a multitude of applications not limited to cleaning. For example, petroleum distillates may be used as a cleaning solvent, as a paint thinner, or as an ingredient used in the manufacture of a coating, such as paint. Because a portion of all solvents Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg8 of 290

### 3 evaporate during use, such solvent-based cleaning materials result in large amounts of emissions of VOC.

In 1994, EPA completed a study of industrial cleaning solvents that characterized cleaning operations carried out within six focus industries (automotive, electrical equipment, magnetic tape, furniture, packaging, and photographic supplies) to evaluate sources of evaporative emissions from VOC solvents used as cleaning materials. (See Reference 1 in the reference section for the full citation to these documents.)

We believe that the range of cleaning activities performed in these focus industries provided a good variety of cleaning operations for the study, and that the information obtained relevant to VOC emission sources and possible control techniques can be applied to virtually any industry.

Data collected by EPA during the development of the 1994 Alternative Control Techniques (ACT) (to be referred to as 1994 ACT or ACT) document for industrial cleaning solvents show nationwide usage of VOC solvent from six industries studied is more than 360,000 Mg/yr (400,000 tpy). 1 

### We also reported in the ACT document that the estimated total VOC solvent usage for cleaning by all U.S. industry was more than 910,000 Mg/yr (1 million tpy). This number was estimated using multiple sources, and not based on data from the facilities we surveyed. In general, VOC emissions occur from industrial cleaning solvents through evaporation during cleaning activities such as wiping, flushing, and brushing, as well as from storage and disposal of used shop towels and solvent.

The 1994 ACT included as Appendix A to this CTG. The document provides a thorough discussion of cleaning activities and types of cleaning operations in a wide and diverse assortment of industrial facilities, frequently used cleaning solvents, and the practices (or lack of) for managing solvents. It, also, identifies a methodology for estimating VOC emissions by cleaning operation, discusses control techniques for addressing such emissions, the costs-benefit of setting up a solvent accounting and management system, and other items.

EPA surveyed 34 facilities in the six focus industries and collected approximately 300 individual cleaning data sets or unit operation systems (UOS) representing emissions from the nine types of cleaning unit operations (UO) in the focus industries for the ACT document. These nine UO are identified below together with the VOC emission distribution based on the UOS material balance data:

1 Spray Gun Cleaning (50 percent); 2 Spray Booth Cleaning (14 percent); 3 Large Manufactured Components Cleaning (14 percent); 4 Parts Cleaning (7.0 percent); 5 Equipment Cleaning (6.9 percent); 6 Line Cleaning (3.6 percent); 7 Floor Cleaning (2.9 percent); Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg9 of 290

### 4 8 Tank Cleaning (0.82 percent); and 9 Small Manufactured Components Cleaning (0.44 percent).

Because spray gun cleaning (one of the UO) accounted for 50 percent of the emissions from cleaning operations, the ACT dedicated appendix G of the document to describe procedures for determining, in a consistent way, VOC emissions from a number of subcategories of spray gun cleaning. The subcategories represented the range of gun cleaning practices in the focus industries in 1994. However, due to the availability of enclosed gun cleaners today, states have disallowed gun cleaning methods that result in high solvent emissions.

The purpose of identifying these UO is to assist State and local agencies in identifying the sources of VOC emissions from cleaning activities and to provide a structure for developing and applying control techniques to mitigate VOC emissions from industrial cleaning solvents used in these UO. This CTG is intended to cover all industrial cleaning operations. EPA believes that all categories of industrial cleaning operations are represented or can be classified under one of the nine cleaning categories listed in this CTG. See also ACT (describing nine UO in further detail). EPA has not, to date, identified any industrial cleaning activity that would not fall within one of the nine UO, but even if such a situation occurred, this CTG is intended to cover all industrial cleaning operations irrespective of whether they can be properly categorized as one of the nine UO. That said, we recognize that there are several cleaning operations that may already be the subject of regulatory requirements, and we urge States to consider the specific industries and operations in their jurisdictions and any existing regulatory requirements applicable to those operations and tailor their RACT rules in response to this CTG accordingly. Finally, janitorial supplies used for cleaning offices, bathrooms or other similar areas are not covered by this CTG.

The ACT document provided a quantitative overview of cleaning solvents used and a model for accounting and tracking solvent usage--a solvent management system. It also provided a methodology for calculating emissions in a consistent way. A brief outline on how to manage emissions from cleaning operations is presented in Fig 4-1 of the ACT (see Appendix A).

Although the industrial cleaning solvent product category includes a variety of different products with differing VOC contents, and although these products are used in different ways by a wide range of industries, we believe that there are several basic approaches to achieve VOC emission reductions. First, the users of the products can control emissions through work practices targeted at the activities and sources of emissions specific to the user’s industry (e.g., keeping solvent containers covered, properly storing and disposing of used shop towels and solvent, etc.). Second, users can also reduce overall VOC emissions through solvent substitution (e.g., use of low - VOC, no -VOC, or low -vapor pressure solvents). They can also reduce VOC emissions by using add-on controls, modifying equipment, or upgrading to using a lower emitting cleaning technology. Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg10 of 290

### 5 Theoretically, solvent substitution could be achieved at the point of manufacture or at the point of use, but in practice it is usually the user who selects the solvent or mixture of solvents to use in the various industrial cleaning operations throughout a facility. These general approaches are effective strategies to achieve significant emission reductions from this product category, notwithstanding the variation in the products, their users, and their specific uses.

III. Applicability (Scope of Sources)
This CTG applies to industries that have to use organic solvent for cleaning unit operations such as mixing vessels (tanks), spray booths, and parts cleaners, where a facility emits at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls in an ozone nonattainment area. The cleaning activities for removal of foreign material from substrate being cleaned include actions (activities) such as wiping, flushing, or spraying.

The applicability threshold of 6.8 kg/day (15 lb/day) of VOC is consistent with the threshold level contained in many previous final CTGs. It is also consistent with the purpose of the section 183(e) program. In section 183(e), Congress directed EPA to assist States in achieving VOC emission reductions from consumer and commercial products. These products individually may result in relatively small amounts of VOC emissions, but, in the aggregate, they contribute significantly to ozone formation in nonattainment areas. Given the nature of the products and sources at issue here, we believe that the 6.8 kg/day (15 lb/day) of VOC per day applicability threshold is appropriate. For purposes of determining whether this threshold is met at a given facility performing industrial cleaning operations, the facility should consider the VOC emissions from the use of organic solvent cleaning prior to controls.

Some industries with solvent cleaning operations are presently covered by an existing CTG (e.g., aerospace). Other industries with solvent cleaning operations may be the subject of a CTG that is presently being developed (e.g., printing) or may be the subject of a future CTG (e.g., automobiles and light trucks coatings). CTGs often recommend control approaches for a particular industry, like printing, and those approaches achieve important VOC emission reductions. We recommend that States consider excluding from the applicability of their State rules promulgated in response to this CTG, those industries relevant to the product categories listed for regulation under CAA section 183(e). See 71 FR 44540. We list below the section 183(e) industries that the States may wish to consider excluding from the applicability of their State rules. States should also consider the structure of the Bay Area cleaning solvent rule, which ensures that particular cleaning activities are only subject to one set of requirements, as opposed to duplicative requirements. For example, under the Bay area structure, there is a cleaning exemption that is common to all Bay Area AQMD rules. There are cleaning standards found in each individual rule, such as metal parts and products, plastic parts, etc. The exemption exempts cleaning that is subject to Regulation 8, Rule 16, which governs cleaning in vats, containers, cold cleaners, vapor degreasers, etc, in which there is some standing liquid, either in the cleaning area or a remote reservoir. “The only intent Docket No. EPA-HQ-OAR-2006-0535

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### 6 here is to make it clear that only one rule applies to a type of cleaning operation.” For example, cleaning a metal part by dipping in liquid solvent is subject to a 50 g/l standard in Reg. 8, Rule 16. Wipe cleaning that same part is subject to a 50 g/l standard in Reg. 8, Rule 19. Cleaning of spray booths by solvent wiping, a stationary structure would be subject to the architectural coating rule, Regulation 8, Rule 3. Consequently, a State may wish to exclude industrial categories to parallel the Bay Area rule overall structure or may wish to follow a structure where all the wipe cleaning and cleaning in a container are kept together and then address the specific needs of various types of substrates all within the wipe cleaning standards. The South Coast AQMD is one example of a California district that uses this format (e.g., AQMD Rule 1171(c)).

We estimate that there are approximately 7360 facilities in nonattainment areas for 8-hour ozone standards of which 2520 would be potentially affected because they meet the 6.8 kg/day (15 lb/day) of VOC applicability threshold for this CTG. Of these facilities, we estimate that approximately 1290 are located in areas for which RACT is required under section 182(b) of the CAA. We derived these number based on available information concerning the use of industrial cleaning solvents from the 2002 EPA National Emissions Inventory. The cost aspects are presented in greater detail in Appendix E.

IV. State and Local Regulatory Approaches
We reviewed regulations issued by three different local air pollution control authorities in California. These regulations are aimed at reducing VOC emissions from industrial cleaning solvents by combining work practice standards and placing limits on the VOC content of the solvent used. They also provided as an additional option the use of add-on controls. The work practice standards are similar for the air pollution control authorities. However, the VOC content limits required for certain applications and the add-on control overall efficiency level that would need to be met, vary by district. Appendix B presents a summary of the industrial solvent cleaning regulations in the three California air pollution control districts.

EPA also reviewed various State rules including:

1 Michigan; 2 Florida; 3 New Jersey; and 4 Indiana.

The above State rules do not require VOC content limits. Instead, equipment standards, work practices, and recordkeeping are required by sources. Regulations in these States on parts cleaners have an overall similar structure. However, there are specific differences. For example, the New Jersey rule applies to cold cleaning machines that use 2 gallons or more of solvents with greater than 5 percent (by mass) VOC. This is similar to a VOC limit of approximately 50 g VOC/liter. Both New Jersey and Illinois do not allow the use of solvents with a vapor pressure greater than 1 mm Hg (at 68 degrees Docket No. EPA-HQ-OAR-2006-0535

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### 7 F) in parts cleaners --“cold cleaning machines.” The other States listed do not have similar provisions.

V. Recommended Control Options
The recommended measures for controlling emissions of VOC from the use, storage, and disposal of industrial cleaning solvents includes work practice standards, limitations on VOC content of the cleaning materials, and an optional alternative limit on composite vapor pressure of the cleaning materials. They also include the use of add-on controls with an overall emission reduction of at least 85 percent by mass. The first two recommendations and the last one are based on the Bay Area AQMD rule. Following the section discussing recommended control measures is a discussion of the industrial categories that we are recommending that States and local agencies consider excluding from applicability of these recommended control measure.

States can adopt these recommendations and include them in their SIP revisions or adopt RACT rules that provide for different approaches. For example, for a given industrial sector or cleaning operation, where appropriate, a State may offer the flexibility of requiring only work practices. Regardless of the approach a State pursues in its RACT rule, EPA will review the State RACT rule as part of the SIP approval process and will make the final determination as to whether the State rule comports with the RACT requirements of the Act.

When developing RACT measures for industrial cleaning operations, we suggest specific category exclusions, similar to the ones provided for the Bay Area and South Coast rules and that State and local agencies consider the specific industries and operations in their jurisdictions and the individual requirements of those operations and tailor their rules to those specific scenarios accordingly.

Furthermore, in considering existing cleaning requirements as bases for specific exemptions from their general industrial cleaning solvents rules, State and local agencies should take into account how current those measures are. EPA believes that more recent rules are likely to be more effective than older, possibly outdated, rules. We remind the States that the ultimate determination of whether any specific State or local measures meet any applicable RACT requirement will occur during the notice and comment rulemaking process associated with EPA action on SIP submissions. For ease of reference, in discussing the control recommendations below, we refer to the nine unit operations that we believe are representative of all industrial cleaning operations.

A. Recommended Control Measures

1. Work Practices

Recommended work practices that will help reduce VOC emissions from the use, handling, storage, and disposal of cleaning solvents and shop towels include: Docket No. EPA-HQ-OAR-2006-0535

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### 8 1 Covering open containers and used applicators; 2 Minimizing air circulation around cleaning operations; 3 Properly disposing of used solvent and shop towels; and 4. Implementing equipment practices that minimize emissions (e.g., keeping arts cleaners covered, maintaining cleaning equipment to repair solvent leaks, etc.).

2. VOC Content Limit

We recommend a generally applicable VOC content limit of 50 grams VOC per liter (0.42 1b/gal) of cleaning material for each of the nine cleaning UO identified in the Background and Overview section, unless emissions are controlled by an emission control system with an overall control efficiency of at least 85 percent. This limit is modeled on the “general use” category of the Bay Area AQMD solvent cleaning regulations, taking into account the specific exclusions provided for in the Bay Area AQMD rule and described below.

3. Alternative Composite Vapor Pressure Limit

In addition to the recommended VOC content limit, EPA is recommending inclusion of a composite vapor pressure limit of 8 millimeters of mercury (mmHg) at 20 degrees Celsius, as (1) a replacement for the 50 g/l VOC content limit entirely; or (2) an alternative limit that may be used in lieu of the 50 g/l VOC content limit for specific operations as determined by the State or local agency.

B. Suggested Exclusions

This section includes product categories that EPA has listed for regulation under section 183(e) as well as categories of cleaning operations that are specifically excluded from applicability in Bay Area Regulation 8 rule 4. The Bay Area exclusions are provided as examples for consideration by the State and local agencies.

1. Categories Listed for Regulation under CAA Section 183(e)

We recommend that the States exclude from applicability those cleaning operations in the following categories listed for regulation under CAA section 183(e):

1 Aerospace coatings; 2 Wood furniture coatings; 3 Shipbuilding and repair coatings; 4 Flexible packaging printing materials; 5 Lithographic printing materials; 6 Letterpress printing materials; 7 Flat wood paneling coatings; Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg14 of 290

### 9 8 Large appliance coatings; 9 Metal furniture coatings; 10 Paper film and foil coating; 11 Plastic parts coatings; 12 Miscellaneous metals parts coatings; 13 Fiberglass boat manufacturing materials; 14 Miscellaneous industrial adhesives; and 15 Auto and light-duty truck assembly coatings.

2. Categories with Specific Exemptions under Bay Area 8-4-116

1 Electrical and electronic components; 2 Precision optics; 3 Numismatic dies; 4 Stripping of cured inks, coatings, and adhesives; 5. Cleaning of resin, coating, ink, and adhesive mixing, molding, and application equipment; 5 Research and development laboratories; 6 Medical device or pharmaceutical manufacturing; and 7 Performance or quality assurance testing of coatings, inks, or adhesives.

3. Categories Subject to Specific Rules and Exemptions under Bay Area 8-4- 117
1 Architectural coating; 2 Metal container, closure, and coil coating; 3 Paper, fabric, and film coating; 4 Light and medium duty motor vehicle assembly plants; 5 Surface coating of metal furniture and large appliances; 6 Surface coating of miscellaneous metal parts and products; 7 Graphic arts printing and coating operations; 8 Coating of flat wood paneling and wood flat stock; 9 Magnet wire coating operations; 10 Aerospace assembly and component coating operations; 11 Semiconductor wafer fabrication operations; 12 Surface coating of plastic parts and products; 13 Wood products coating; 14 Coating, ink, and adhesive manufacturing; 15 Flexible and rigid disc manufacturing; 16 Marine vessel coating; 17 Motor vehicle and mobile equipment coating operations; and 18 Polyester resin operations.

Appendix C provides a summary of NAICS Codes for nonattainment facilities estimated to meet the applicability criteria recommended in this CTG. Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg15 of 290

### 10 4. Categories with special limits in South Coast AQMD Rule 1171(c)

In addition to the Bay Area exclusions, and as discussed earlier, the more stringent South Coast AQMD “general use” limit of 25 g/l (0.21 lb/gal) is accompanied by higher limits for several individual operations. Although we are not recommending higher limits for these categories beyond the 50 g/l limit in this CTG, State and local agencies should be aware of the individual performance requirements in these categories when developing individual State or local cleaning solvent rules based on the specific industries within their jurisdictions. We suggest that State and local agencies refer to the South Coast rule for more details on subcategories and specific limits. The broad categories are:

1. Product cleaning during manufacturing process or surface preparation for coating; 2. Repair and maintenance cleaning; 3. Cleaning of coatings or adhesives application equipment; 4. Cleaning of ink application equipment; and 5. Cleaning of polyester resin application equipment.

VI. Impacts of Recommended Controls
EPA estimates that there are approximately 2,524 facilities in ozone nonattainment areas that would be affected by this CTG. These facilities had emissions that exceed the emission threshold of 6.8 kg (15 lb) of VOC per day. Total aggregate VOC emissions from solvent cleaning operations from these nonattainment sources are approximately 64,000 Mg/yr (71,000 tpy). Appendix D summarizes the potential number of facilities and their emissions that may be subject to this CTG by State.

EPA used studies published by the Bay Area AQMD to estimate the cost of compliance for the measures recommended in this CTG. According to these estimates, EPA believes that affected sources may either incur minimal additional costs or realize a savings on a case - by - case basis, depending primarily on facts such as how much they currently spend to operate high-VOC content solvent - based parts cleaners, and the cost of organic solvent disposal. The Bay Area AQMD studies indicate that there is a cost savings associated with replacing high-VOC cleaning materials with low-VOC, waterbased cleaning materials.

The total VOC emissions from solvent cleaning operations (64,000 Mg/yr (71,000 tpy) were determined by first assigning the VOC emissions from solvent cleaning operations at each facility using the 2002 National Emissions Inventory (NEI) database to one of two general groups: parts cleaners, and other solvent cleaning operations. The parts cleaner subgroup included emissions from all SCC codes with a “degreasing” or cold solvent cleaning/stripping classification in SCC_L3. VOC emissions from this subcategory are approximately 4,000 Mg/yr (4,400 tpy). The other solvent cleaning operations included all other SCCs that were identified as solvent cleaning operations. The VOC emissions from the other subgroup are approximately 60,000 Mg/yr (66,000 Docket No. EPA-HQ-OAR-2006-0535

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### 11 tpy). These emissions do not include emissions from halogenated parts cleaners. Consistent with our recommendations to the States, we did not include in these emissions those from facilities represented by the 183(e) source categories listed in section V. They also do not include remissions from research and development facilities, or emissions from manufacturing and assembly of electrical and electronic components.

Costs associated with switchover to aqueous parts cleaners (cleaning systems or washers) include the initial cost of equipment, solvent costs, filters, electricity, and waste disposal costs. Many of these costs are also incurred when operating higher VOC solvent cleaners. A study on parts cleaners, for example, has shown typical annual costs for mineral spirits parts cleaners as $1,453. Estimates on annual costs for aqueous parts cleaners, in comparison, range from $1,171 to $1,480, thus showing that facilities could either face a slight increase in cleaning costs or realize a cost savings as a result of the switchover. 6



### Facilities may either incur minimal additional costs or realize a savings on a caseby-case basis, depending primarily on how much they currently spend to operate the high VOC content solvent-based parts cleaners, the cost of organic solvent disposal, and air emission fees levied for VOC emissions. A study provided by the California Bay Area AQMD shows that the cost-effectiveness for meeting the 50 grams of VOC per liter of cleaning material limit for a parts cleaner is estimated at $1,832/Mg (1,664/ton). 6,7 

### This represents the annual cost of compliance (industry wide) for parts cleaners (Table 4 of the Bay Area Regulation 8, Rule 16). We determined that replacing high VOC content cleaning materials with low VOC water-based cleaning materials for the other cleaning (unit) operations (e.g., cleaning of large manufactured surfaces, tank cleaning, and gun cleaning, etc.) would result in an estimated cost savings of $1,460/Mg. For this calculation we only considered the cost-difference in cleaning material cost and costdifference in waste disposal cost. The savings is a result of lower cost of aqueous cleaners which offset the increase in waste disposal cost for aqueous cleaners. Appendix E explains how we calculated the cost of applying the solvent substitution option for reducing VOC emissions from the use of organic cleaning solvents.

As explained above, this CTG is guidance for the States to use in determining RACT for VOC from industrial cleaning solvents. State and local pollution control agencies are free to implement other technically-sound approaches for RACT that are consistent with the CAA and EPA’s implementing regulations. Accordingly, there is necessarily some uncertainty in any prediction of costs and emission impacts associated with the recommendations in this document. Nevertheless, assuming that States adopt the recommendations in this CTG or comparable approaches, EPA anticipates a net cost savings. We based this prediction on an assumption that substitution of low-VOC materials for high-VOC materials is possible for all uses. Because this assumption is not true for some applications, this prediction may not be valid in all cases. Docket No. EPA-HQ-OAR-2006-0535

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### 12 VII. References
1. U.S. Environmental Protection Agency, Alternative Control Techniques Document—Industrial Cleaning Solvents , February 1994. EPA-453/R-94-015. (NTIS PB 94-181-694).

2. Bay Area Air Quality Management District, Regulation 8, Rule 16: Solvent Cleaning Operations . http:// www.arb.ca.gov/DRDB/BA/CURHTML/R8- 16.PDF, (Accessed June 27, 2006).

3. South Coast Air Quality Management District, Rule 1171: Solvent Cleaning Operations.
4. Sacramento Metropolitan Air Quality Management District, Rule 466: Solvent Cleaning.

5. U.S. Environmental Protection Agency, Control of Volatile Organic Emissions from Solvent Metal Cleaning , November 1977. EPA-450/2-77-022.

6. Bay Area Air Quality Management District, Staff Report: Proposed Amendments to BAAQMD Regulation 8, Rule 16: Solvent Cleaning Operations, September 2002.
7. South Coast Air Quality Management District, Staff Report for Proposed Amendment to Rule 1171 - Solvent Cleaning Operations , August 15, 1996. Docket No. EPA-HQ-OAR-2006-0535

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### A-1 

# Appendix A

1994 Control Techniques Guidelines: Industrial Cleaning Solvents

. Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg19 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg20 of 290 Docket No. EPA-HQ-OAR-2006-0535Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg21 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg22 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg23 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg24 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg25 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg26 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg27 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg28 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg29 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg30 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg31 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg32 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg33 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg34 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg35 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg36 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg37 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg38 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg39 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg40 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg41 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg42 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg43 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg44 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg45 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg46 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg47 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg48 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg49 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg50 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg51 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg52 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg53 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg54 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg55 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg56 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg57 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg58 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg59 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg60 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg61 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg62 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg63 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg64 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg65 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg66 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg67 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg68 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg69 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg70 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg71 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg72 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg73 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg74 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg75 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg76 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg77 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg78 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg79 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg80 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg81 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg82 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg83 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg84 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg85 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg86 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg87 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg88 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg89 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg90 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg91 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg92 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg93 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg94 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg95 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg96 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg97 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg98 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg99 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg100 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg101 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg102 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg103 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg104 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg105 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg106 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg107 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg108 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg109 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg110 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg111 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg112 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg113 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg114 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg115 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg116 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg117 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg118 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg119 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg120 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg121 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg122 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg123 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg124 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg125 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg126 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg127 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg128 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg129 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg130 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg131 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg132 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg133 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg134 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg135 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg136 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg137 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg138 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg139 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg140 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg141 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg142 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg143 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg144 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg145 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg146 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg147 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg148 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg149 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg150 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg151 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg152 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg153 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg154 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg155 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg156 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg157 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg158 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg159 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg160 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg161 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg162 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg163 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg164 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg165 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg166 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg167 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg168 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg169 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg170 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg171 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg172 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg173 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg174 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg175 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg176 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg177 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg178 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg179 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg180 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg181 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg182 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg183 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg184 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg185 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg186 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg187 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg188 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg189 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg190 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg191 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg192 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg193 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg194 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg195 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg196 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg197 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg198 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg199 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg200 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg201 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg202 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg203 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg204 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg205 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg206 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg207 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg208 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg209 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg210 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg211 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg212 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg213 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg214 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg215 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg216 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg217 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg218 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg219 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg220 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg221 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg222 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg223 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg224 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg225 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg226 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg227 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg228 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg229 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg230 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg231 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg232 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg233 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg234 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg235 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg236 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg237 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg238 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg239 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg240 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg241 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg242 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg243 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg244 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg245 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg246 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg247 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg248 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg249 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg250 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg251 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg252 of 290Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg253 of 290

### B-2 This page intentionally left blank. Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg254 of 290

### B-1 

# Appendix B

Summary of Regulations in California Reviewed for Industrial Cleaning Solvents CTG Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg255 of 290

### B-3 Appendix B. Summary of Regulations in California Reviewed for Industrial Solvent Cleaning CTG

Regulation Exemptions Standards BAAQMD Regulation 8, Rule 16 x Semiconductor Solvent Cleaners x Aerospace Stripping Operations x Vapor Phase Solder Reflow Operations x Dry Cleaning Operations x Stripping Operations x Aerospace components x Electrical and electronic components x Precision optics x Medical devices x Cleaning of resin, coating, ink, and adhesive mixing, molding and application equipment x Cleaning associated with research and development operations. x Performance testing to determine coating, adhesive or ink performance x Testing for QA/QC purposes x Work practices to minimize emissions, and x Use solvent with VOC content of 50 g/l or less, or x Vent emissions to an emission control device achieving 90% reduction

SMAQMD Rule 466 x Cleaning of solar cells, laser hardware, scientific instruments, and high precision optics, x Cleaning of cotton swabs to remove cottonseed oil before cleaning of high precision optics x Cleaning of paper-based gaskets and clutch assemblies where rubber is bonded to metal by means of an adhesive x Cleaning of application x Work practices to minimize emissions, and x Vent emissions to an emission control device achieving 95% reduction through a collection system with a collection efficiency of 90%, or x Use solvent with VOC content of 50 g/l or less, except for the following activities:

o 500 g/l for product cleaning during Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg256 of 290

### B-4 equipment used to apply coatings on satellites and radiation effect coatings, x Cleaning of electrostatic coating application equipment x Janitorial cleaning x Cleaning of sterilization ink indicating equipment if solvent usage is less than 1.5 gpd. x Cleaning with aerosol provided that 160 fluid oz or less of aerosol is used per day manufacture of electrical apparatus components and electronic components

o 800 g/l for product cleaning during manufacture of medical devices and pharmaceuticals, platelets,

o 900 g/l for repair and maintenance of electrical apparatus components and electrical components

o 800 g/l for repair and maintenance of medical devices and pharmaceuticals tools, equipment, and machinery, and platelets

o 600 g/l for repair and maintenance of medical devices and pharmaceuticals general work surfaces

o 300 g/l for solvent based architectural coating application equipment

SCAQMD Rule 1171 x Cleaning carried out in batch loaded cold cleaners, vapor degreasers, converyorized degreasers, x Motion picture film cleaning equipment x Dry cleaning subject to Rule 1102 or 1422 x Semiconductor manufacturing subject to Rule 1164 x Work practices to minimize emissions, and x Vent emissions to an emission control device achieving 95% reduction through a collection system with a collection efficiency of 90%, or x Use solvent with VOC content of 25 g/l or less, except for the following Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg257 of 290

### B-5 x Aerospace assembly and component manufacturing operations (except coating application equipment cleaning, and storage and disposal of VOC containing materials used in solvent cleaning operations) subject to Rule 1124 x Resin manufacturing subject to Rule 1141 x Coatings and ink manufacturing subject to Rule 1141.1 x Janitorial cleaning x Stripping of cured coatings, cured ink, or cured adhesives The following do not have to comply with VOC content limits in the rule: x Cleaning solar cells, laser hardware, scientific instruments, and high precision optics x Medical and pharmaceutical facilities using up to 1.5 gpd solvents x Cleaning motor vehicles on application lines subject to Rule 1115 x Cleaning of photocurable resins from stereolithography equipment and models x Cleaning of adhesive application equipment for thin metal laminating if VOC content is no more than 950 g/L x Cleaning of electronic cables if VOC content is no more than 400 g/l x Circuit board touch up if activities:

o 100 g/l for product cleaning during manufacture of electrical apparatus components and electronic components

o 800 g/l for product cleaning during manufacture of medical devices and pharmaceuticals,

o 100 g/l for repair and maintenance of electrical apparatus components and electrical components

o 800 g/l for repair and maintenance of medical devices and pharmaceuticals tools, equipment, and machinery,

o 600 g/l for repair and maintenance of medical devices and pharmaceuticals general work surfaces

o 100 g/l for gravure printing on publications

o 100 g/l for lithographic or letterpress printing (roller wash-step 1, and step 2)

o 100 g/l for screen printing

o 100 g/l for ultraviolet ink/electron beam ink application equipment Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg258 of 290

### B-6 VOC content is nor more than 800 g/l x Transdermal drug delivery product manufacturing using less than 3 gpd ethyl acetate x Cleaning of application equipment used for solvent-borne fluropolymer coatings if VOC content is no more than 900 g/l x Facilities cleaning sterilization indicating ink using less than 1.5 gpd solvent x Cleaning operations in printing pre-press or graphic arts pre-press areas, including the cleaning of film processors, color scanners, plate processors, film cleaning, and plate cleaning x Cleaning of cotton swabs to remove cottonseed oil before cleaning of high precision optics x Cleaning of paper-based gaskets and clutch assemblies where rubber is bonded to metal by means of an adhesive x Cleaning of application equipment used to apply coatings on satellites and radiation effect coatings, x Cleaning with aerosol provided that 160 fluid oz or less of aerosol is used per day x Cleaning associated with research and development operations. x Testing for QA/QC o 100 g/l specialty flexographic printing Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg259 of 290

### B-7 purposes Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg260 of 290

### C-1 

# Appendix C



# Summary of NAICS Codes for nonattainment facilities Estimated to meet the applicability criteria recommended in this CTG Docket No. EPA-HQ-OAR-2006-0535

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### This page intentionally left blank Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg263 of 290

### C-2 Appendix C : Summary of NAICS Codes for nonattainment estimated to meet the applicability criteria recommended in the CTG

NAICS NAICS DESCRIPTION 42 Wholesale Trade 321 Wood Product Manufacturing 325 Chemical Manufacturing 327 Nonmetallic Mineral Product Manufacturing 331 Primary Metal Manufacturing 332 Fabricated Metal Product Manufacturing 333 Machinery Manufacturing 334 Computer and Electroni c Product Manufacturing 337 Furniture and Relate d Product Manufacturing 339 Miscellaneous Manufacturing

3336 Engine, Turbine, and Powe r Transmission Equipment Manufacturing 3399 Other Miscellaneous Manufacturing 11112 Oilseed (except Soybean) Farming 23511 Plumbing, Heating, and Ai r-Conditioning Contractors 23521 Painting and Wall Covering Contractors 31212 Breweries 31321 Broadwo ven Fabric Mills 31323 Nonwoven Fabric Mills 31331 Textile and Fab ric Finishing Mills 31332 Fabric Coating Mills 31611 Leather and Hide Tanning and Finishing 32191 Millwork 32199 All Other Wood Product Manufacturing 32213 Paperboard Mills 32311 Printing 32551 Paint and Coating Manufacturing 32552 Adhesive Manufacturing 32591 Printing Ink Manufacturing

32613 Laminated Plastics Plate, Sheet (ex cept Packaging), and Shape Manufacturing 32614 Polystyrene Foam Product Manufacturing

32615 Urethane and Other Foam Product (except Polystyrene) Manufacturing 32721 Glass and Glass Product Manufacturing 32739 Other Concrete Product Manufacturing 32791 Abrasive Product Manufacturing 33121 Iron and SteelPipe and Tube Manufacturing from Purchased Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg264 of 290

### C-3 Steel 33231 Plate Work and Fabricated Structural Product Manufacturing 33251 Hardware Manufacturing 33281 Coating, Engraving, Heat Treating, and Allied Activities 33291 Metal Valve Manufacturing 33299 All Other Fabricated Me tal Product Manufacturing 33312 Construction M achinery Manufacturing 33322 Plastics and Rubber Industry Machinery Manufacturing 33329 Other Industrial Machinery Manufacturing

33341 Ventilation, Heating, Air-Cond itioning, and Commercial Refrigeration Equipm ent Manufacturing 33392 Material Handling Equipment Manufacturing 33511 Electric Lamp Bulb and Part Manufacturing 33611 Automobile and Light Duty Motor Vehicle Manufacturing 33612 Heavy Duty Tru ck Manufacturing 33621 Motor Vehicle Body and Trailer Manufacturing

33632 Motor Vehicle Electrical and Electronic Equipment Manufacturing 33634 Motor Vehicle Brake System Manufacturing

33635 Motor Vehicle Transmission and Power Train Parts Manufacturing 33636 Motor Vehicle Seating an d Interior Trim Manufacturing 33651 Railroad Rollin g Stock Manufacturing 33699 Other Transportation Equipment Manufacturing 33711 Wood Kitchen Cabinet and Countertop Manufacturing 33712 Household and Institutional Furniture Manufacturing 33721 Office Furniture (including Fixtures) Manufacturing 33995 Sign Manufacturing 42131 Lumber, Plywood, Millwo rk, and Wood Panel Wholesalers 42183 Industrial Mach inery and Equipment Wholesalers 42213 Industrial and Pers onal Service Paper Wholesalers 44211 Furniture Stores 45431 Fuel Dealers 48821 Support Activities for Rail Transportation 49211 Couriers 51223 Music Publishers 53112 Lessors of Nonresidential Buildings (except Miniwarehouses) 54138 Testing Laboratories

54171 Research and Development in the Physical, Engineering, and Life Sciences 61131 Colleges, Universities, and Professional Schools 81121 Electronic and Precision Equipment Repair and Maintenance

81131 Commercial and Industrial Machi nery and Equipment (except Automotive and Electroni c) Repair and Maintenance

81149 Other Personal and Household Goods Repair and Maintenance 92214 Correctional Institutions 92612 Regulation and Administration of Transportation Programs 211111 Crude Petroleum and Natural Gas Extraction Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg265 of 290

### C-4 211112 Natural Gas Liquid Extraction 221111 Hydroelectric Power Generation 221112 Fossil Fu el Electric Power Generation 221113 Nuclear Electric Power Generation 221310 Water Supply an d Irrigation Systems 236118 Residential Remodelers 236220 Commercial and Institutional Building Construction 237120 Oil and Gas Pipeline and Related Structures Construction 237310 Highway, Street, and Bridge Construction 238170 Siding Contractors 238290 Other Building Equipment Contractors 38320 Painting and Wall Covering Contractors 238350 Finish Carp entry Contractors 238910 Site Preparation Contractors 311111 Dog and Cat Food Manufacturing

311320 Chocolate and Confectionery Manufacturing from Cacao Beans 311340 Nonchocolate Conf ectionery Manufacturing 311812 Commer cial Bakeries 311919 Other Snack Food Manufacturing 311942 Spice and Extract Manufacturing 311991 Perishable Prep ared Food Manufacturing 312111 Soft Dr ink Manufacturing 312112 BottledWater Manufacturing 312120 Breweries 312221 Cigare tte Manufacturing 313112 Yarn Texturizin g, Throwing, and Twisting Mills 313113 Thread Mills 313221 Narrow Fabric Mills 313230 Nonwoven Fabric Mills 313311 Broadwoven Fabric Finishing Mills

313312 Textile and Fabric Finishing(except Broadwoven Fabric) Mills 313320 Fabric Coating Mills 314110 Carpet and Rug Mills 314912 Canvas and Related Product Mills 314991 Rope, Cordag e, and Twine Mills 314992 Tire Cord and Tire Fabric Mills 314999 All Other Miscellaneous Tex tile Product Mills 315111 Sheer Hosiery Mills 315991 Hat, Cap, and Millinery Manufacturing 315999 Other Apparel Accessories and Other Apparel Manufacturing 316110 Leather and Hide Tanning and Finishing 316213 Men's Footwear (except Athletic) Manufacturing 316999 All Other Leather Good Manufacturing 321114 Wood Preservation 321219 Reconstituted Wood Product Manufacturing 321911 Wood Window and DoorManufacturing Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg266 of 290

### C-5 321918 Other Millwork (including Flooring) 321920 Wood Container and Pallet Manufacturing 321991 Manufactured Home (M obile Home) Manufacturing 321992 PrefabricatedWood Building Manufacturing 321999 All Other Miscellaneous Wood Pr oduct Manufacturing 322110 Pulp Mills 322121 Paper (except Newsprint) Mills 322122 Newsprint Mills 322130 Paperboard Mills 322211 Corrugated and Solid Fiber Box Manufacturing 322212 Foldin g Paperboard Box Manufacturing 322214 Fiber Can, Tube, Drum, and Similar Products Manufacturing

322221 Coated and Laminated Packaging Paper and Plastics Film Manufacturing 322222 Coated and Laminated Paper Manufacturing 322231 Die-Cut Paper and Paperboard Office Supplies Manufacturing 322232 Envelope Manufacturing 322299 All Other Converted Paper Product Manufacturing 323110 Commercial Lith ographic Printing 323111 Commercial Gravure Printing 323112 Commercial Flexographic Printing 323113 Commercial Screen Printing 323116 Manifold Business Forms Printing 323117 Book s Printing 323122 Prepress Services 324110 Petro leum Refineries 324122 Asphalt Shing le and Coating Materials Manufacturing 324191 Petroleum Lubricating Oil and Grease Manufacturing 324199 All Other Petroleum and Coal Products Manufacturing 325110 Petroche mical Manufacturing 325131 Inorganic Dye and Pigment Manufacturing 325132 Synthetic Organic Dy e and Pigment Manufacturing 325188 All Other Basic Ino rganic Chemical Manufacturing 325199 All Other Basic Orga nic Chemical Manufacturing 325211 Plastics Material and Resin Manufacturing 325212 Synthetic Rubber Manufacturing 325222 Noncellulosic Or ganic Fiber Manufacturing 325411 Medicinal and Botanical Manufacturing 325412 Pharmaceutical Preparation Manufacturing 325413 In-Vitro Diagnostic Substan ce Manufacturing 325510 Paint and Co ating Manufacturing 325520 Adhesive Manufacturing 325611 Soap and Other Detergent Manufacturing 325612 Polish and Other Sanitation Go od Manufacturing 325613 Surface Active Agent Manufacturing 325620 Toilet Preparation Manufacturing 325910 Printing Ink Manufacturing 325991 Custom Compounding of Purchased Resins Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg267 of 290

### C-6 325992 Photographic Film, Paper, Plate, and Chemical Manufacturing

325998 All Other Miscellaneous Chemical Product and Preparation Manufacturing

326112 Plastics Packaging Film and Sheet (including Laminated) Manufacturing

326113 Unlaminated Plastics Film and Sheet (except Packaging) Manufacturing 326121 Unlamin ated Plastics Profile Shap e Manufacturing

326130 Laminated Plastics Plate, Sheet (ex cept Packaging), and Shape Manufacturing 326140 Polystyr ene Foam Produ ct Manufacturing

326150 Urethane and Other Foam Product (except Polystyrene) Manufacturing 326160 Plastics Bottle Manufacturing 326191 Plastics Plumbi ng Fixture Manufacturing 326192 Resilient Floor Covering Manufacturing 326199 All Other Plastic s Product Manufacturing 326211 Tire Manufactur ing (except Retreading) 326212 Tir e Retreading 326220 Rubber and Plastics Hoses and Beltin g Manufacturing 326291 Rubber Pr oduct Manufacturing for Mechanical Use 326299 All Other Rubb er Product Manufacturing

327112 Vitreous China, Fine Earthenware, and Other Pottery Product Manufacturing 327121 Brick and Structural Clay Tile Manufacturing 327123 Other Structural Clay Product Manufacturing 327124 Clay Refracto ry Manufacturing 327125 Nonclay Refractory Manufacturing 327211 Flat Glass Manufacturing 327212 Other Pressed and Blow n Glass and Glassware Manufacturing 327213 Glass Container Manufacturing 327215 Glass Produ ct Manufacturing Made of Purchased Glass 327310 Cement Manufacturing 327331 Concrete Block and Brick Manufacturing 327332 Concre te Pipe Manufacturing 327390 Other Concret e Product Manufacturing 327910 Abrasive Pr oduct Manufacturing 327991 Cut Ston e and Stone Pr oduct Manufacturing 327993 Mineral Wool Manufacturing

327999 All Other Miscellaneous Nonm etallic MineralProduct Manufacturing 331111 Iro n and Steel Mills 331112 Electrometallurgical Ferroalloy Product Manufacturing

331210 Iron and Steel Pipe and TubeManufacturing from Purchased Steel 331221 Rolled Steel Shape Manufacturing 331222 Steel Wire Drawing 331312 Primary Aluminum Production 331314 Secondary Smelting and Alloying of Aluminum Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg268 of 290

### C-7 331315 Aluminum Sheet, Plate, and Foil Manufacturing 331316 Aluminum Extruded Product Manufacturing 331319 Other Aluminum Rolling and Drawing 331421 Copper Rolling, Drawing, and Extruding 331422 Copper Wire (except Mechanical) Drawing 331423 Secondary Smelting, Refining, and Alloying of Copper

331491 Nonferrous Metal (except Copp er and Aluminum) Rolling, Drawing, and Extruding 331511 Iron Foundries 331512 Steel Investment Foundries 331513 Steel Foundries (e xcept Investment) 331524 Aluminum Found ries (except Die-Casting) 331525 Copper Foundries (except Die-Casting) 331528 Other Nonferrous Fo undries (except Die-Casting) 332112 Nonferrous Forging 332114 Custom Roll Forming 332115 Crown and Closure Manufacturing 332116 Metal Stamping 332117 Powder Metallurg y Part Manufacturing 332211 Cutlery and Flatware (except Precious) Manufacturing 332212 Hand and Edge Tool Manufacturing 332213 Saw Blade and Handsaw Manufacturing 332214 Kitchen Utensi l, Pot, and Pan Manufacturing 332311 Prefabricated Metal Building and Component Manufacturing 332312 Fabricated Stru ctural Metal Manufacturing 332313 Plate Work Manufacturing 332321 Metal Window and Door Manufacturing 332322 Sheet Metal Wo rk Manufacturing 332323 Ornamental and Architect ural Metal Work Manufacturing 332410 Power Boiler and Heat Exchanger Manufacturing 332420 Metal Tank (Heavy Gauge) Manufacturing 332431 Metal CanManufacturing 332439 Other Metal Container Manufacturing 332510 Hardwar e Manufacturing 332611 Spring (Heavy Gauge) Manufacturing 332612 Spring (Light Gauge) Manufacturing 332618 Other Fabricated Wire Product Manufacturing 332721 Precision Turned Product Manufacturing 332722 Bolt, Nut, Scr ew, Rivet, and Wa sher Manufacturing 332811 Metal Heat Treating

332812 Metal Coating, Engraving (except Jewelry and Silverware), and Allied Services to Manufacturers 332813 Electroplating, Plating, Polishing, Anodizing, and Coloring 332911 Industrial Valve Manufacturing 332919 Other Metal Valve and Pipe Fitting Manufacturing 332991 Ball and Roller Bearing Manufacturing 332993 Ammunition (except Small Arms) Manufacturing 332994 Small Arms Manufacturing Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg269 of 290

### C-8 332996 Fabricated Pipe and Pipe Fitting Manufacturing 332998 Enameled Iron and Metal Sanitary Ware Manufacturing

332999 All Other Miscellaneous Fabricated Metal Product Manufacturing 333111 Farm Machin ery and Equipment Manufacturing 333120 Construction M achinery Manufacturing 333131 Mining Machinery and Equipment Manufacturing 333132 Oil and Gas Field Machinery and Equipment Manufacturing 333210 Sawmill and Woodwo rking Machinery Manufacturing 333291 Paper Industry Machinery Manufacturing 333292 Textile Machinery Manufacturing 333293 Printing Machinery and Equipment Manufacturing 333295 Semiconductor M achinery Manufacturing 333298 All Other I ndustrial Machinery Manufacturing 333314 Optical Instrument and Len s Manufacturing 333315 Photographic and Photocopying Equipment Manufacturing

333319 Other Commercial and Service Industry Machinery Manufacturing 333412 Industr ial and Commercial Fan and Blower Manufacturing

333414 Heating Equipment (except Warm Air Furnaces) Manufacturing

333415 Air-Conditioning and Warm Air Heating Equipment and Commercial and Industrial Refrigeration Equipment Manufacturing 333512 Machine Tool (Metal Cutting Typ es) Manufacturing 333515 Cutting Tool and Mach ine Tool Accessory Manufacturing 333516 Rolling Mill Machinery and Equipment Manufacturing 333611 Turbine andTurbine Generator Set Units Manufacturing

333612 Speed Changer, Industrial H igh-Speed Drive, and Gear Manufacturing 333613 Mechanical Power Transmission Equipment Manufacturing 333618 Other Engine Eq uipment Manufacturing 333911 Pump and Pumping Equipment Manufacturing 333912 Air and Gas Compressor Manufacturing 333921 Elevator and MovingStairway Manufacturing 333922 Conveyor and Conveying Equipment Manufacturing

333923 Overhead Traveling Crane, Ho ist, and Monorail System Manufacturing

333924 Industrial Truck, Tractor, Trailer, and Stacker Machinery Manufacturing 333991 Power-Driven Handtool Manufacturing 333994 Industrial Process Furnace and Oven Manufacturing

333999 All Other Miscellaneous Gen eral Purpose Machinery Manufacturing 334111 Electronic Computer Manufacturing 334112 Computer Storage Device Manufacturing 334113 Computer Term inal Manufacturing 334119 Other Computer Peripheral Equipment Manufacturing

334220 Radio and Television Broadcasting and Wireless Communications Equipment Manufacturing Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg270 of 290

### C-9 334290 Other Communications Equipment Manufacturing 334310 Audio and Video Equip ment Manufacturing 334411 Electron Tube Manufacturing 334412 Bare Printed Cir cuit Board Manufacturing 334413 Semiconductor and Related Device Manufacturing 334414 Electronic Capacitor Manufacturing 334415 Electronic Resistor Manufacturing

334416 Electronic Coil, Transformer, and Other Inductor Manufacturing 334417 Electronic Connector Manufacturing

334418 Printed Circuit Assembly (Electronic Assembly) Manufacturing 334419 Other Electronic Component Manufacturing

334510 Electromedical and Electrotherapeutic Apparatus Manufacturing

334511 Search, Detection, Navigation, Guidance, Aeronautical, and Nautical System and Inst rument Manufacturing

334512 Automatic Environmental Control Manufacturing for Residential, Commercial, and Appliance Use

334513 Instruments and Related Products Manufacturing for Measuring, Displaying, and C ontrolling Industrial Process Variables 334516 Analytical Laboratory Instrument Manufacturing 334517 Irradiation Apparatus Manufacturing 334518 Watch, Clock, and Part Manufacturing 334519 Other Measuring and Controlling Device Manufacturing 334613 Magnetic and Optical Recording Media Manufacturing 335110 Electric Lamp Bulb and Part Manufacturing 335121 Residential Electric Lighting Fix ture Manufacturing

335122 Commercial, Industrial, and In stitutional Electric Lighting Fixture Manufacturing
335129 Other Lighting Equ ipment Manufacturing 335211 Electric Housewares and Household Fan Manufacturing 335221 Household Cooking Appliance Manufacturing 335222 Household Refrigerator and Home Freezer Manufacturing 335228 Other Major Household Appliance Manufacturing

335311 Power, Distribution, and Specialty Transformer Manufacturing 335312 Motor and Generator Manufacturing 335313 Switchgear and Switch board Apparatus Manufacturing 335314 Relay and Industr ial Control Manufacturing 335911 Storage Battery Manufacturing 335921 Fiber Optic Cable Manufacturing 335929 Other Communication an d Energy Wire Manufacturing 335932 Noncurrent-Carrying Wiring Device Manufacturing

335999 All Other Miscellaneous Electrical Equipment and Component Manufacturing 336111 Autom obile Manufacturing 336112 Light Truck and Utility Vehicle Manufacturing Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg271 of 290

### C-10 336211 Motor Vehicle Body Manufacturing 336212 Truck Trailer Manufacturing 336213 Motor Home Manufacturing 336214 Travel Trailer and Camper Manufacturing 336311 Carburetor, Piston, Piston Ring, and Va lve Manufacturing 336312 Gasoline Engine and Engine Parts Manufacturing 336321 Vehicular Lighting Equipment Manufacturing

336322 Other Motor Vehicle Electrical and Electronic Equipment Manufacturing 336340 Motor Vehicle Brake System Manufacturing

336350 Motor Vehicle Transmission and Power Train Parts Manufacturing 336360 Motor Vehicle Seating and Interior Trim Manufacturing 336370 Motor Vehicle Metal Stamping 336399 All Other Motor Vehicle Parts Manufacturing 336412 Aircraft Engine and Engine Parts Manufacturing 336413 Other Aircraft Parts and Auxiliary Equipment Manufacturing 336414 Guided Missile and Space Vehicle Manufacturing 336510 Railroad Ro lling Stock Manufacturing 336611 Ship Buildin g and Repairing 336612 Boat Building 336999 All Other Transportation Equipment Manufacturing 337110 Wood Kitchen Cabinet and Countertop Manufacturing 337121 Upholstered Household Furniture Manufacturing 337122 Nonupholstered Wood Household Furniture Manufacturing 337124 Metal Household Furniture Manufacturing 337125 Household Furniture (except Wood and Metal) Manufacturing 337127 Institutional Furniture Manufacturing

337129 Wood Television, Radio, and Sewing Machine Cabinet Manufacturing 337211 Wood Office Furniture Manufacturing

337212 Custom Architectural Woodwork and Millwork Manufacturing 337214 Office Furniture (except W ood) Manufacturing 337215 Showcase, Partition, Shelving, and Locker Manufacturing 337920 Blind and Shade Manufacturing 339111 Laboratory Apparatus and Furniture Manufacturing 339112 Surgical and MedicalInstrument Manufacturing 339113 Surgical Appliance and Supplies Manufacturing 339115 Ophthalmic Goods Manufacturing 339911 Jewelry (exc ept Costume) Manufacturing 339912 Silverware and Hollowware Manufacturing 339914 Costume Jewelryand Novelty Manufacturing 339920 Sporting and Athletic Goods Manufacturing 339932 Game, Toy, and Children's Vehicle Manufacturing 339941 Pen and Mechanical Pencil Manufacturing 339942 Lead Pen cil and Art G ood Manufacturing 339950 Sign Manufacturing Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg272 of 290

### C-11 339991 Gasket, Packing, and Sealing Device Manufacturing 339992 Musical Instrument Manufacturing 339993 Fastener, Button, Need le, and Pin Manufacturing 339995 Burial Casket Manufacturing 339999 All Other Miscellaneous Manufacturing 423110 Automobile and Other Mo tor Vehicle Merchant Wholesalers

423310 Lumber, Plywood, Millwork, and Wood Panel Merchant Wholesalers 423510 Metal Service Centers and Other Metal Merchant Wholesalers

423810 Construction and Mining (except Oil Well) Machinery and Equipment Mercha nt Wholesalers 423990 Other Miscellaneous Dura ble Goods Merchant Wholesalers 424690 Other Chemical and Allied Products Merchant Wholesalers 424950 Paint, Varnish, and Supplies Merchant Wholesalers 425110 Busine ss to Business Electronic Markets 425120 Wholesale Trade Agents and Brokers 441110 New Car Dealers 441120 Used Car Dealers 442110 Furn iture Stores 442210 Floor Covering Stores 443111 Household Appliance Stores 444120 Paint and Wallpaper Stores 444190 Other Build ing Material Dealers 446199 All Other Healthand Personal Care Stores 451110 Sporting Goods Stores

453998 All Other Miscellaneous Store Retailers (except Tobacco Stores) 454312 Liquefied Petroleum Gas (Bottled Gas) Dealers 481219 Other Nonschedul ed Air Transportation 482111 Line-Haul Railroads 485111 Mixed Mode Transit Systems 485113 Bus and Other Motor Vehicle Transit Systems 485410 School and Employee Bus Transportation 485999 All Other Transit and Ground Passenger Transportation 488190 Other Support Activities for Air Transportation 488210 Support Activ ities for Rail Transportation 488490 Other Support Activities fo r Road Transportation 488999 All Other Suppo rt Activities for Transportation 491110 Po stal Service 493110 General Warehousing and Storage 511110 Newspaper Publishers 511120 Periodical Publishers 512110 Motion Picture and Video Production 512220 Integrated RecordProduction/Distribution 515120 Television Broadcasting 523930 Investment Advice 531120 Lessors of Nonresid ential Buildings (exce pt Miniwarehouses) 532299 All Other Co nsumer Goods Rental Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg273 of 290

### C-12 532411 Commercial Air, Rail, and Water Transportation Equipment Rental and Leasing 541330 Engin eering Services 541360 Geophysical Surveying and Mapping Services 541380 Testing Laboratories

541710 Research and Development in the Physical, Engineering, and Life Sciences

541720 Research and Development in the Social Sciences and Humanities 541850 Display Advertising 541940 Veter inary Services 561499 All Other Bu siness Support Services 562212 SolidWaste Landfill 562910 Remediation Services 562998 All Other Miscellaneous Waste Management Services 611110 Elementary an d Secondary Schools 611210 Junior Colleges 611310 Colleges, Universities, and Professional Schools 611513 Apprenticeship Training 621511 Medi cal Laboratories 621512 Diagnostic Imaging Centers 622110 Gene ral Medical and Surgical Hospitals 622210 Psychiatr ic and Substance Abuse Hospitals 622310 Specialty (exc ept Psychiatric and Substance Abuse) Hospitals

711310 Promoters of Performing Arts, Sports, and Similar Events with Facilities 711510 Independent Artists, Writers, and Performers 713110 Amusement and Theme Parks 722310 Food Service Contractors 811111 General Automotive Repair

811118 Other Automotive Mechanical and Electrical Repair and Maintenance 811121 Automotive Body, Pain t, and Interior Repair and Maintenance 811122 Automotive Glass Replacement Shops 811211 Consumer Electroni cs Repair and Maintenance

811310 Commercial and Industrial Machi nery and Equipment (except Automotive and Electroni c) Repair and Maintenance 811412 Appliance Repair and Maintenance 811420 Reupholstery and Furniture Repair

811490 Other Personal and Household Goods Repair and Maintenance 812320 Drycleaning and Laundry Services (except Coin-Operated) 812921 Photofinish ing Laboratories (except One-Hour) 812922 One-Hour Photofinishing 812990 All Other Personal Services 921190 Other General Government Support 922140 Correctional Institutions

923130 Administration of Human Resource Programs (except Education, Public Health, and Veterans' Affairs Programs) Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg274 of 290

### C-13 923140 Administration of Veterans' Affairs 926120 Regulation and Administra tion of Transportation Programs 927110 Space Research and Technology Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg275 of 290

### C-1 This page intentionally left blank. Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg276 of 290

### D-1 

# Appendix D

Number of Nonattainment Facilities organized by State that are Estimated to Meet the Applicability Criteria Recommended in the CTG, Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg277 of 290

### This page intentionally left blank. Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg278 of 290

### D-2 Appendix D. Number of nonattainment facilities organized by State that are estimated to meet the applicability criteria recommended in the CTG

State Number of Facilities Baseline VOC Emissions from Solvent

Utilization

(Mg/yr) Alabama 17 665 Arkansas 1 23 Arizona 51 1,567 California 619 5,730 Colorado 203 2,191 Connecticut 21 349 Delaware 3 18 Georgia 9 639 Illinois 130 2,293 Indiana 162 5,825 Kentucky 23 1,329 Louisiana 5 111 Massachusetts 268 2,960 Maryland 19 442 Maine 4 24 Michigan 157 3,469 Missouri 60 1,583 North Carolina 154 12,013 New Hampshire 11 447 New Jersey 32 657 New York 11 381 Ohio 17 1,823 Pennsylvania 166 3,660 Rhode Island 27 465 South Carolina 36 2,538 Tennessee 82 4,307 Texas 92 2,558 Virginia 36 2,762 Wisconsin 97 1,625 West Virginia 11 807 Totals: 2,524 63,261 Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg279 of 290This page intentionally left blank Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg280 of 290

### 1 

# Appendix E

Costs and Emission Reductions for the Recommendations Concerning Solvent Substitution Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg281 of 290

### E-1 Appendix E


## Costs and Emission Reductions for the Recommendation Concerning Solvent Substitution

I. Introduction

This memorandum addresses how we calculated the costs and VOC emission reductions for the recommended option involving substituting a high VOC solvent with a cleaning solution with 50gram per liter VOC.

According to the 2002 National Emissions Inventory (NEI), there are 2,524 facilities conducting solvent cleaning operations in the United States that are located in ozone nonattainment areas (based on April 2004 designations). These facilities had emissions that exceed the emission threshold of 6.8 kg (15 lb) of VOC per day before control. Total aggregate VOC emissions from solvent cleaning operations from these nonattainment sources are approximately 64,000 Mg/yr (71,000 tpy). We identified the facilities above the recommended daily VOC emission limit threshold from all SCC codes at the facility with source category classifications of interest.

The total VOC emissions from solvent cleaning operations were first determined by identifying SCCs that corresponded to solvent evaporation or solvent utilization at a facility. In this analysis, the SCCs that fit this category included SCC codes with an SCC level 1 description of “Petroleum and Solvent Evaporation” or “Solvent Utilization.” Next, this list of applicable SCC codes was narrowed to codes where the SCC level 2 code included "surface coating", "degreasing","dry cleaning”,” graphic arts", "rubber/plastics”, “All Solvent User Categories", or "organic solvent evaporation" it was included in the population of total VOC emissions from solvent cleaning operations.

This list of applicable SCC codes was further divided into one of three general groups: halogenated solvents, parts cleaners, and other solvent cleaning operations. Halogenated solvents were identified by reviewing the name of the solvent listed in the SCC level 4 description for halogenated compounds. As a result, all SCC codes representing halogenated solvents were removed from our estimate of total VOC emissions from solvent cleaning operations. SCC codes with “degreasing” or “cold solvent cleaning/stripping” in the SCC level 3 description were identified as parts cleaners

. The final subgroup covers “other solvent cleaning operations,” and this group includes all of the applicable SCC codes that were not classified as halogenated solvents or parts cleaners.

Several industries with solvent cleaning operations are covered under either section 183(e) of the Clean Air Act or are part of a category with a specific exemption to Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg282 of 290

### E-2 a Bay Area Rule. These are listed in the CTG, and were removed from the total VOC calculation.

This list of applicable SCC codes was further divided into one of three general groups: halogenated solvents, parts cleaners, and other solvent cleaning operations. Halogenated solvents were identified by reviewing the name of the solvent listed in the SCC level 4 description for halogenated compounds. As a result, all SCC codes representing halogenated solvents were removed from our estimate of total VOC emissions from solvent cleaning operations. SCC codes with “degreasing” or “cold solvent cleaning/stripping” in the SCC level 3 description were classified as part cleaners. The final subgroup covers “other solvent cleaning operations,” and this group includes all of the applicable SCC codes that were not classified as halogenated solvents or parts cleaners.

As a result of this analysis, we determined that there were approximately 64,000 Mg/yr (71,000) tpy) VOC from solvent cleaning operations. Of this total, 4,000 Mg/yr (4,400 tpy) were identified as parts cleaners and the remaining 60,000 Mg/yr (66,000 tpy) were classified as other solvent cleaning operations. We did not include in this analysis cleaning solvent emissions from 183(e) category of sources. Nor did we include emissions from research and development facilities, or emissions from manufacturing and assembly of electrical and electronic components.

II. Cost Analysis
For this analysis, it was assumed that the total VOC emitted is equal to the total VOC used for solvent cleaning. This value was converted to a volume by using an average specific gravity (900g/l) for a typical all VOC cleaning solvents found in the ACT.
The study provided by the California Bay Area AQMD shows that the costeffectiveness for meeting the 50 grams of VOC per liter of cleaning material limit for a parts cleaner is estimated at $1,832/Mg (1,664/ton). 1,2 

### This represents the annual cost of compliance (industry wide) for parts cleaners (Table 4 of the Bay Area Regulation 8, Rule 16). We determined that replacing high VOC content cleaning materials with low VOC water-based cleaning materials for the other cleaning (unit) operations (e.g., cleaning of large manufactured surfaces, tank cleaning, and gun cleaning, etc.) would result in an estimated cost savings of $1,460/Mg. For this calculation we only considered the cost-difference in cleaning material cost and cost-difference in waste disposal cost. The savings is a result of lower cost of aqueous cleaners which offset the increase in waste disposal cost for aqueous cleaners. . 1



### Therefore, the national annual costs for complying with the 50 grams of VOC per liter limit on a cleaning (unit) operation basis are a summation of the costs of operating parts cleaners, and the savings realized by the other solvent cleaning operations. The annual national cost and emission impacts are a cost savings of $76 million and 61,000 Mg/yr (67,000 tpy) reduction in VOC emissions. Table 2 summarizes the cost estimates Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg283 of 290

### E-3 by attainment classification. Attachment 1 presents a sample calculation of cost and emission reductions for an individual facility. Lastly, facilities may either incur minimal additional costs or realize a savings on a case-by-case basis, depending primarily on how much they currently spend to operate the high VOC content solvent-based parts cleaners, the cost of organic solvent disposal, and air emission fees levied for VOC emissions. Also, the costs and VOC reductions will differ with the option that a facility would be required to use by a State for a cleaning operation.

References

1. Bay Area Air Quality Management District, Staff Report: Proposed Amendments to BAAQMD Regulation 8, Rule 16: Solvent Cleaning Operations, September 2002.
2. South Coast Air Quality Management District, Staff Report for Proposed Amendment to Rule 1171 - Solvent Cleaning Operations , August 15, 1996. Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg284 of 290

### E-4 Table 2. Summary of Costs and Emission Reductions for Nonattainment Facilities for the Recommendation Concerning Solvent Substitution

Solvent Cleaning Operation Affected facilities with VOC emissions  6.8 kg per day 2002 NEI* Baseline VOC

emissions (Mg/yr) Controlled VOC for facilities in

NAICS (2002 Mg/yr) Emission Reduction for Facilities in

NAICS

(tpy) Cost Effectiveness (2002 $ per Mg) Nationwide Cost (2002 $)

Parts Cleaners 613 3,990 221 3,768 1,833 6,905,900 Other Solvent Cleaning Operations 2,408 59,271 3,286 55,986 -1,459 -81,697,307 Totals (100% of facilities)* 2,524 63,261 3,507 59,754 -74,791,407 Totals (75% of facilities)** 1893 47,446 2,630 44,816 -56,093,556 Totals (50% of facilities)** 1262 31,630 1,753 29,877 -37,395,704 Totals (25% of facilities)** 631 15,815 877 14,939 -18,697,852

* Some facilities have emissions from both parts cleaners an d other solvent cleaning operations. The total number of facilities represents the number of facilities considered in this analysis (see Appendix C). Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg285 of 290

### E-5 

## Attachment 1. Costs and Emission Reductions Example Calculation for the Recommendation Concerning Solvent Substitution

An example is presented to illustrate the procedure we used to calculate the cost and VOC emission reductions resulting when the recommended 50 g/l VOC limit option is applied. In this example, we show an overa ll negative cost, which is representative of most of the nonattainment facilities the 2002 NEI database which cleaning solvents above the threshold limit. However, the net cost for a facility, that will be using this option, will depend on the level of VOC solvent emissions from parts cleaning relative to that for the other cleaning operations.

Procedure:

1 Estimated baseline VOC emissions from solvent cleaning operations for the facilities in the EPA 2002 NEI database. Only emissions identified as originating from “VOC” were included, due time constraints. Individually listed compounds were not screened for VOC status. Therefore, total VOC from cleaning solvents are somewhat underestimated. 2 Identified the facilities in nonattainment areas that emitted VOC from the use of organic solvents above a 6.8 kg/day (15 lb/day) threshold level. 3 Calculate separately, as identified in the NEI database, the cost of parts cleaners and other cleaning operations. 4 Used an average VOC concentration of 900 g/l, which we determined from the 1994 ACT, to convert VOC emissions to volume of solvent used. For this analysis we are assuming that the VOC emissions from solvent cleaning determined from the NEI database are equal to the volume of solvent used. 5 Multiplied by the VOC limit (50 g/l) by solvent usage to determine the VOC emissions after compliance with the limit. 6 Subtracted the value determined under 5 above from the NEI baseline emissions to estimate emission reductions 7 Used cost-effectiveness information from the Bay Area AQMD to calculate costs of reducing VOC. Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg286 of 290

### E-6 Table 1A. Emissions from Solvent Cleaning Operations (8-hour Ozone Non-Attainment Area based on 2002 NEI) *

NEI Unique Facility ID County FIPS SCC VOC emissions (tpy) Category Pollution Category NAICS Code SIC Code NEI22046 06059 40100308 0 NHPC VOC 713110 7996 NEI22046 06059 40100398 2.17 NHPC VOC 713110 7996 NEI22046 06059 40200210 0.08 otherNH VOC 713110 7996 NEI22046 06059 40200310 0.04 otherNH VOC 713110 7996 NEI22046 06059 40200410 0 otherNH VOC 713110 7996 NEI22046 06059 40200510 0.01 otherNH VOC 713110 7996 NEI22046 06059 40200610 0.19 otherNH VOC 713110 7996 NEI22046 06059 40200710 0.01 otherNH VOC 713110 7996 NEI22046 06059 40200901 0.01 otherNH VOC 713110 7996 NEI22046 06059 40200926 0 otherNH VOC 713110 7996 NEI22046 06059 40200998 2.02 otherNH VOC 713110 7996 NEI22046 06059 40201901 0.01 otherNH VOC 713110 7996 NEI22046 06059 40299995 0.64 otherNH VOC 713110 7996 NEI22046 06059 49000601 0.47 otherNH VOC 713110 7996


### Step 1: Calculate total facility emissions of VOC from solvent cleaning operations and determine if they are above threshold level of 6.8 kg/day (15 lb/day).

Total Facility Emissions = 0 + 2.17 + 0.08 + 0.04 + 0 + 0.01 + 0.19 + 0.01 + 0.01 + 0 + 2.02 + 0.01 + 0.64 + 0.47 = 5.64 tpy VOC Threshold = 15 lb/day * 1 ton/2000 lb * 365 days/yr = 2.74 tpy

or 2.17 ton/yr * 907,185 g/ton = 2,485 kg/yr (2.48 Megagrams/yr)

Since the facility emissions are above the VOC threshold limit of 6.8 kg/yr, go to step 2.

Step 2: Estimate baseline emissions and emission reductions from (1) parts cleaners and (2) other solvent cleaning operations.

2a. Parts Cleaners

The total VOC Emissions from Parts Cleaners used by this Facility = 2.17 ton/yr * 907.2kg/ton = 1,967 Kg/yr

We will assume that the average VOC concentrat ion (density) of the solvents used by this facility was 900 g/liter. If we replace the organic solvent with a cleaning solution with a VOC content (concentration) of 50 g/liter, the controlled emissions would be as follows:

= 1,967 kg/yr * (50 g/liter/900 g.liter) = 109.2 kg/yr (0.12 ton/yr) Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg287 of 290

### E-7 2a. Other Cleaning Operations

The total VOC Emissions from the Other Cleaners Operations in this Facility = 3.48 ton/yr * 907.2 kg/ton =3,154 kg/yr
Therefore, the controlled VOC emissions after solvent substitution are = 3,154 kg/yr * (50 g/liter/900 g.liter) = 175.2 kg/yr (0.19 ton/yr)

Step 3: Estimate the costs of switching to aqueous solvent.

3a. Parts Cleaners
Assumption $1,664 per ton of VOC emissions reduced

Tons VOC reduced due to solvent substitution = 2.17 ton/yr – 0.12 ton/yr = 2.05 ton/yr Cost to Facility = $1,664/ton reduced * 2.05 ton/yr = $3,408

3b. Other Solvent Cleaning Operations
Assumption -$1,325 (net savings) per ton of VOC reduced.

Tons VOC reduced to solvent substitution = 3.48 ton/yr – 0.19 ton/yr = 3.29 ton/yr Cost to Facility = -$1,325/ton reduced * 3.29 ton/yr = -$4,351 (savings)

3c. Calculate Total Facility Cost:

Cost from VOC reduced from Parts Cleaners + Cost from VOC reduced from Other Cleaning Operations = $3,408 + -$4,351 = - $943(net savings) Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg288 of 290This page intentionally left blank Docket No. EPA-HQ-OAR-2006-0535 CTG: Ind. Clng. Solv. pg289 of 290United StatesEnvironmental ProtectionAgencyOffice of Air Quality Planning and StandardsAir Quality Strategies and Standards DivisionResearch Triangle Park, NCPublication No. EPA 453/R-06-001September, 2006Postal information in this section where appropriate.Docket No. EPA-HQ-OAR-2006-0535CTG: Ind. Clng. Solv. pg290 of 290