UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

South Coast Air Quality Management District, Rule 1171, 

Solvent Cleaning Operations

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

June 2011
2

Agency: South Coast Air Quality Management District 

(SCAQMD)

SIP Approved Rule: Rule 1171 – Solvent Cleaning Operations

Adopted – August 2, 1991

Submitted – May 24, 2005

EPA Approved – July 1, 2005 (70 FR 38023)

Interim Versions of Rule 1171 – Solvent Cleaning

Rule that EPA has not Amended - May 6, 2005

acted on: Submitted – July 18, 2008

Amended – July 14, 2006

Submitted – May 17, 2010

Subject of this TSD: Rule 1171 – Solvent Cleaning Operations

Amended – February 1, 2008

Submitted – April 5, 2011

RULE SUMMARY -

Rule 1171 reduces emissions of Volatile Organic Compounds (VOCs), air toxic 

contaminants and stratospheric ozone-depleting or global-warming compounds 

from the use, storage and disposal of solvent cleaning materials in solvent 

cleaning operations and activities. The changes incorporated by the February 1,

2008 amendment include:

1. Expanded the rule’s applicability to include all solvent suppliers.

2. Clarified the following terms:

a. Full service solvent provider

b. Newsprint

c. On-press screen cleaning

d. Removable press component

e. Screen reclamation

f. Solvent supplier

3. Removed VOC Composite Partial Pressure from definitions.

4. Added VOC limits effective 1/1/2008 and 1/1/2009 and reduced current 

limits for the following categories:

a. (A) Product Cleaning During Manufacturing Process Or Surface 

Preparation for Coating, Adhesive or Ink Application (ii) Electrical 

Apparatus Components and Electronic Components changed from 

500 g/l and 100 g/l to 100 g/l.

b. (B) Repair and Maintenance (ii) Electrical Apparatus Components 

and Electronic Components changed from 900 g/l and 100g/l to 

100 g/l.

c. (C) Cleaning of Coatings or Adhesive Application Equipment 

changed from 500 g/l and 25 g/l to 25 g/l.

d. (D) Cleaning of Ink Application Equipment (iii) Gravure Printing (A)

Publication changed from 750 g/l and 100 g/l to 100 g/l.
3

e. (D) Cleaning of Ink Application Equipment (iv) Lithographic or 

Letterpress Printing (A) Roller Wash – Step 1 and (B) Roller Wash -

Step 2 changed from 600 g/l and 100 g/l and 800 g/l and 100 g/l to 

(A) Roller Wash, Blanket Wash & On-press Components at 100 g/l

for (I) Newsprint and 500 g/l for (II) Other Substrates.

f. (D) Cleaning of Ink Application Equipment (v) Screen Printing 

changed from 750 g/l and 100 g/l to 500 g/l.

g. (D) Cleaning of Ink Application Equipment (vi) Ultraviolet 

Ink/Electron Beam Ink application Equipment (except screen 

printing changed from 800 g/l and 100 g/l to 650 g/l.

h. (D) Cleaning of Ink Application Equipment (vii) Specialty 

Flexographic Printing changed from 600 g/l and 100 g/l to 100 g/l.

5. Required that solvent suppliers be subject to recordkeeping requirements.

6. Required that operators maintain written dilution instructions.

7. Added labelling requirements in accordance with Rule 443.1

8. Removed outdated rule requirements regarding a technology assessment 

report.

9. Prohibited full service solvent providers from assisting in non-compliant 

solvent cleaning usage.

10. Removed testing for the determination of VOC composite partial pressure.

11. Revised the determination of efficiency of the emission control system by 

replacing testing of the efficiency of the collection device with testing of the 

capture efficiency of the emission control system. Broadened testing to 

apply to the efficiency of control equipment instead of to the efficiency of 

the control device and replaced SCAQMD test method 25.1 with 25.3. 

12. Extended the date from June 30, 2005 to December 31, 2008 for 

terminating the exemption for cleaning of photocurable resins from 

stereolithography equipment and models. 

13. Extended the date from June 30, 2005 to January 1, 2009 for terminating 

the exemption for cleaning of ultraviolet or electron beam lamps and 

reflectors used to cure ultraviolet inks or coatings.

14. Exempted the cleaning of adhesive application equipment used for thin 

metal laminating operations from the VOC limits requirements provided 

the cleanup solvent contains no more than 950 g/l VOC.

15. Exempted the cleaning of electronic and electrical cables from the VOC 

limit requirements provided the cleanup solvent contains no more than 

400 g/l VOC.
4

16. Exempted the touch-up cleaning performed on printed circuit boards 

where surface mounted devices have already been attached from the 

VOC limits requirements provided the cleanup solvent contains no more 

than of 800 g/l VOC.

17. Removed the expired exemption for cleaning of architectural coating 

application equipment.

18. Added the following exemptions from the category “Cleaning of Ink 

Application Equipment” VOC limits:

a. The cleaning of metering rollers, dampening rollers and printing 

plates provided the solvent contains no more than 800 g/l VOC, 

until December 31, 2007.

b. On-press cleaning of screens and automatic cleaning equipment 

used in screen reclamation provided the solvent contains no more 

than 500 g/l VOC, until January 1, 2009.

c. On-press cleaning of metering rollers, dampening rollers and 

printing plates in UV/EB ink application equipment provided the 

solvent contains no more than 800 g/l VOC, until January 1, 2009.

EPA EVALUATION - The following criteria were used to evaluate the submitted 

rule. 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation 

Cutpoints, Deficiencies, and Deviations, EPA, May 25, 1988) and the Little 

Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 

2. Stringency – EPA’s Control Technique Guidelines (CTGs) titled, “Control of 

Volatile Organic Emissions from Solvent Metal Cleaning” (EPA-450/2-77-

022, November 1977) and “Control Techniques Guidelines for Industrial 

Cleaning Solvents” (EPA-453/R-06-001 September 2006), CARB’s 

RACT/BARCT guidance titled, “Organic Solvent Cleaning and Degreasing 

Operations” (July 18, 1991), and other state and local rules for this 

category were used to help evaluate the RACT requirements of CAA 

§182(b)(2). 

3. SIP Relaxation - We have evaluated this SIP revision to determine whether 

it would interfere with any applicable requirement concerning attainment 

and reasonable further progress (RFP) or any other applicable requirement 

of the Act (CAA §110(l)) or modify, in a nonattainment area, any SIPapproved control requirement in effect before November 15, 1990 (CAA 

§193).

Enforceability – Rule 1171 specifies clear, unambiguous and measurable testing 

and recordkeeping requirements such that the rule is enforceable in practice.

Adding the applicability and the recordkeeping requirements of this rule to solvent 

suppliers expands the scope of enforceability. The clarification of terms and 
5

specific labelling requirements further augment the enforceability of the rule as 

does prohibiting the full service solvent suppliers from aiding in the non-compliant 

usage of solvents.

Stringency – SCAQMD’s Rule 1171 is consistent with CARB’s Determination of 

Reasonably Available Control Technology (RACT) and Best Available Retrofit 

Control Technology (BARCT) Organic Solvent Cleaning and Degreasing 

Operations, and with analogous rules in other areas (e.g., Sacramento 

Metropolitan AQMD Rule 466) and we have no basis to require more stringent 

requirements at this time under EPA requirements for RACT (Clean Air Act 

Section 182(b) (2)) or RACM (Clean Air Act Section 172(c)(1)). 

SIP Relaxation – Rule 1171, Solvent Cleaning Operations, now requires that 

solvent suppliers comply with the rule’s requirements and prohibits full service 

providers from participating in non-compliant usage. Furthermore, specific 

recordkeeping for the supplier and operator and labeling requirements for anyone 

selling solvent cleaning materials have been added to the rule. These changes 

strengthen the rule. 

There are two additional exemptions with deadlines and the extension of two 

existing exemption deadlines that represent rule relaxations. However, all the 

dates for these exemptions have effectively expired and do not continue to 

represent SIP relaxations. 

Three permanent exemption categories were added, which do represent rule 

relaxations, including:

Cleaning of adhesive application equipment used for thin metal laminating 

operations provided the cleanup solvent contains no more than 950 g/l 

VOC.

Cleaning of electronic and electrical cables provided the cleanup solvent 

contains no more than 400 g/l VOC.

Cleaning performed on printed circuit boards where surface mounted 

devices have already been attached provided the cleanup solvent contains 

no more than of 800 g/l VOC.

SCAQMD estimates that these additional exemptions represent a total additional 

emission of 0.02 tons/day, while the total VOC reductions since January 1, 2008 

are 2.51 tons/day (insert citation for this). Consequently, these additional 

exemptions are offset by the overall emissions reductions, and the rule submittal 

as a whole would significantly strengthen the SIP. 

Therefore, we propose to determine that our approval of the submittal would 

comply with CAA § 193 because the SIP, as revised to reflect the submitted 

revision, is more stringent than the rule previously approved into SIP and would 

insure equivalent or great emission reductions of VOCs.

We also propose to determine that the approval of the submitted would comply 

with CAA § 110(l) because the proposed SIP revision would not interfere with the 
6

on-going process for ensuring the requirements for RFP and attainment of the 

NAAQS are met, and the submitted SIP revision is more stringent than the rule 

previously approved into the SIP.

RULE DEFICIENCIES - We have identified no deficiencies with Rule 1171

sufficient for EPA to propose less than full approval. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION - The 

following revisions are not currently the basis for rule disapproval, but are 

recommended for the next time the rule is amended. 

1. For clarity, we recommend that the definition of the following terms be 

revised:

a. Aerosol Product defined in subsection (b)(1) should be revised to 

state that “it is a hand-held, non-refillable container which expels 

pressurized product by means of a manual propellant-induced 

force.”

b. Graphic Arts defined in subsection (b)(19) should include screen 

printing similar to the definition in SMAQMD Rule 450, Graphic Arts 

Operations.

c. Consider changing the definition for Lithographic Printing in 

subsection (b)(28) to the definition used in SMAQMD Rule 450, 

Graphic Arts Operations: “A printing operation in which the image 

and non-image areas exist in the same plane. The non-image area 

is treated chemically so that only the image area will be printed onto 

the substrate.”

d. Please revise the definition for Remote Reservoir Cleaner in 

subsection (b)(44), to correspond to that in the OAQPS Guideline for 

the Control of VOC from Solvent Metal Cleaning: “...liquid solvent is 

pumped from a solvent container to a sink-like work area and the 

solvent from the sink-like area drains into and enclosed solvent 

container, allowing no solvent to pool in the work area, while parts 

are being cleaned.

e. Clarify the Repair Cleaning definition in subsection (b)(46) to state: 

“is a solvent cleaning operation or activity carried out during a repair 

process, during which parts are not removed from equipment.”

f. The definition of Stereolithography should be revised to indicate that 

the process uses a “UV beam of light to solidify photocurable 

resins...”

2. Consider adding recordkeeping of key operating parameters for the control 

system in subsection (c) (6), to further strengthen this rule. See, for 

example, SMAQMD Rule 466, section 501.4.

3. The following revisions, which add the EPA approved version dates, should 

be incorporated to support the enforceability of this rule:

a. Revise reference to SCAQMD Method 303 in subsection (e)(1)(A) to 

SCAQMD Method 303-91, August 1996.
7

b. Revise reference to SCAQMD Method 304 in subsection (e)(1)(B) to 

SCAQMD Method 304-91, February 1996.

c. Revise reference to SCAQMD Method 313 in subsection (e)(2) to 

SCAQMD Method 313-91, June 1993.

d. Revise reference to SCAQMD Method 308 in subsection (e)(2) to

SCAQMD Method 318-91, February 1993.

e. Revise reference to SCAQMD Method 25.1 in subsection (e)(3)(B) 

to SCAQMD Method 25.1, February 1997.

f. Revise reference to SCAQMD Method 25.3 in subsection (e)(3)(B) 

to SCAQMD Method 25.3, March 2000.

g. Revise reference to ARB Method 422 in subsection (e)(3)(B) to ARB 

Method 422, Sept. 12, 1990.

4. Please clarify that the document listed in subsection (e)(3)(A) is a guidance

document, entitled GD-35.

5. In subsection (e)(3)(A)(i) please use the date for the most current version

of EPA methods 204 through 204F. 

6. The correct title of Rule 1102, referenced in subsection (g)(2)(B) is “Dry 

Cleaners Using Other Than Perchloroethylene” and the correct title of Rule 

1421 is “Control of Perchloroethylene Emissions from Dry Cleaning 

Systems

EPA ACTION - The rule fulfils the relevant CAA §110 part D requirements. EPA 

staff recommends a full approval of Rule 1143 pursuant to CAA §110(k)(3) and 

§301(a). 

REFERENCES -

1. SCAQMD Rule 1171, Solvent Cleaning Operations, as submitted on April 

5, 2011.

2. SCAQMD Rule 1171, Solvent Cleaning Operations, as submitted on May 

24, 2005.

3. “Control of Volatile Organic Emissions from Solvent Metal Cleaning,” EPA450/2-77-022, November 1977. 

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/197711_voc_epa450_2-77-

022_solvent_metal_cleaning.pdf

4. “Control Techniques Guidelines for Industrial Cleaning Solvents,” EPA453/R-06-001, September 2006.

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r-06-

001_ind_cleaning_solvents.pdf

5. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.

http://www.epa.gov/Region09/air/sips/littlebluebook2001.pdf
8

6. California Air Resources Board (CARB) Determination of Reasonable 

Available Control Technology (RACT) and Best Available Retrofit Control 

Technology (BARCT) for Organic Solvent Cleaning and Degreasing 

Operations July 18, 1991.