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 11 71

,

Solvent Cleaning Operation s

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

June 20112

Agency: South Coast Air Quality Management District (SCAQMD)

SIP Approved Rule: Rule 11 71

– Solvent Cleaning Operation s 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 no t A mend ed

- May 6 , 2005

acted on : Submitted

– July 18, 2008

A mend ed

– July 14, 2006

Submitted

– May 17, 2010

Subject of this TSD: Rule 11 71

– Solvent Cleaning Operations

Amended

– February 1, 2008

Submitted

– April 5

, 201 1

RULE SUMMARY

- Rule 11 71 reduces emissions of Volatile Organic Compounds (VOCs) , air toxic contaminants and stratospheric ozon e

- 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 defin itions.

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 Ap plication (ii) Electrical Apparatus Components and Electronic Components chang ed 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 (i v ) Lithographic or Letterpress Printing (A) Roller Wash

– Step 1 and (B) Roller Wash

- Step 2 changed from 60 0 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 a n d 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. R equired 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 emissi on control system by replacing testing of the efficiency of the collection de vice 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. Extend ed the date from June 30, 2005 to December 31, 2008 for terminating the exempti on for cleaning of phot o curable resins from

stere olithography equipment and models.

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

the exempti on for c leaning 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

40 0 g/l VOC

.4

16. Exempted the touch

- up cleaning performed on printed ci rcuit 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 limit s :

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 i n 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 S olvent 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 1 8, 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 nonattainme nt area, any SIP

approved 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.

Addin g the applicability and the recordkeeping requirements of this rule to solvent suppliers expands the scope of enforceability. The clarification of terms and5

specific labelling requirements further augment the enforceability of the rule as does p rohibiting 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 Technolog y (BARCT) Organic Solvent Cleaning and Degreasing Operations , and with analogous rules in other areas (e.g., Sacramento Metropolitan AQMD Rule 4 66 ) and we have no basis to require more stringent requirements at this time under EPA requirements for RACT (Cl ean 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 ha ve been added to the rule . These changes strengthen t he rule

.

There are two additional exemptions with deadlines and the extension of two existing exemption deadlines that represent rule relaxation s . However, all the dates for these exemptions have effectively expired and do not continue to
represent SIP relaxations

.

T hree permanent exemption categories were added , which do represent rule

relaxation s

, including: Cleaning of adhesive application equipment used for thin metal laminating operations provided the cleanup solvent contains no more than 950 g/l

VOC

. C leaning of electronic and electrical cables provided the cleanup solvent contains no more than 400 g/l VOC

. C leani ng 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, the se additional exemptions are offset by the overall emissions reductions , and the rule submittal as a whole would significantly strengthen the SIP

.

Therefore, w e propose to determine that our approval of the submittal would comply with CAA § 193 because the SIP , as revis ed 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 the6

on

- going process for ensuring the require ments 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 11 71 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 c larity, we recommend that the definition of the following terms be

revised:

a. Aerosol Pr oduct 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 Lithogra phic Printing in subsection (b) (28) to th e 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 Cleanin g: “...liquid solvent is pumped from a solvent container to a sink

- like work ar ea 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 Cleani ng definition in subsection (b) (46) to state : “is a solvent cleanin g 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 a dding recordkeeping of key operating pa rameters 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) t o SCAQMD Method 303

- 91, August 1996.7 b. Revise reference to SCAQMD Method 304 in subsection (e)(1) (B) to
SCAQMD Method 30 4

- 91, F ebruary 1996.

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

SCAQMD Method 313

- 91, June 1993.

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

SCAQMD Method 318

- 91, February 1993.

e. Revise reference to SCAQMD Metho d 25.1 in subsec tion (e)(3) (B) to SCAQMD Method 25.1, February 1997.

f. Revise reference to SCAQM D Method 25.3 in subsection (e)(3) ( B) to SCAQMD Method 25.3, March 2000.

g. Revise reference to A RB 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 110 2, referenc ed 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 114 3 pursuant to CAA §110(k ) ( 3) and §301(a).

REFERENCES

- 1. SCAQMD Rule 11 71

, Solvent Cleaning Operation s, as submitted on April

5 , 201 1

. 2. SCAQMD Rule 11 71

, Solvent Cleaning Operation s, as submitted on May

24 , 20 05

. 3. “Control of Volatile Organic Emissions from Solvent Metal Cleaning,” EPA

450/2

- 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,” EPA

453/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.pdf8

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.