San Joaquin Valley 

AIR POLLUTION CONTROL DISTRICT 

GOVERNING BOARD 

J. Steven Worthley, Chair 

Supervisor. Tulare County 

Leroy Ornellas, Vice Chair 

Superv~sor, San Joaquin County 

Tony Barba 

Supervisor, Kings County 

Raji Brar 

Councilmember, City of Arvin 

Judith G. Case 

Supervisor, Fresno County 

Ronn Dominici 

Supervisor, Madera County 

Jon McQuiston 

Supervisor, Kern County 

Michael G. Nelson 

Supervisor, Merced County 

Wtlliarn O'Brien 

Supervisor. Stanislaus County 

I- . Perea 

Cb-..illi?Iembet. City of Fresno 

Chris Vierra 

Councilmember. City 01 Ceres 

Seyed Sadredin 

Executive Director1 

Air Pollution Control OHicer 

Northern Region Off~ce 

4800 Enterprise Way 

Modesto. CA 95356-8718 

(2091 557-6400 

FAX (209) 557-6475 

Central Region Office 

1990 East Gettysburg Avenue 

Fresno, CA 93726-0244 

(559) 230-6000 

FAX (5591 230-6061 

Southern Region Ollice 

2700 M Street, Suite 275 

Bakerslield, CA 93301 -2373 

(661) 326-6900 

FAX (661) 326-6985 

DA-T E : September 20, 2007 

TO: SJVUAPCD Governing Board 

FROM: Seyed Sadredin, Executive 

Project Coordinator: Sandra Lowe-Leseth 

RE: ADOPT PROPOSED AMENDMENTS AND REVISED 

PROPOSED AMENDMENTS TO THE SOLVENT 

CLEANING PORTION OF ELEVEN DISTRICT RULES 

RECOMMENDATION: 

1. Adopt proposed amendments and revised proposed amendments 

to the solvent cleaning portion of eleven District rules, and 

2. Authorize Chair to sign the attached Resolution. 

BACKGROUND: 

The San Joaquin Valley Air Basin is classified as a nonattainment area 

for the state and federal ozone standards. In accordance with federal 

Clean Air Act requirements for nonattainment areas, the San Joaquin 

Valley Unified Air Pollution Control District (District) adopted the 2004 

Extreme Ozone Attainment Demonstration Plan and the 2007 Ozone 

Plan to establish the strategy for attaining the,one-hour and the eighthour ozone standards. The ozone attainment strategy is comprised of 

regulatory and incentive-based measures to reduce emissions of 

nitrogen oxides and volatile organic compounds (VOC), the precursors 

to ground-level ozone. 

The revised proposed rule amendments satisfy a control measure 

commitment included in both the 2004 Ozone Plan and the 2007 Ozone 

Plan. The revised proposed amendments would establish more 

stringent VOC limits for solvent cleaning equipment and activities. 

Overall, the revised proposed amendments are estimated to generate a 

total of about 3.3 tons per day of VOC reductions, which is a 60% 

reduction from the 2005 baseline emissions for this category. 
SJVUAPCD Governing Board 

ADOPT PROPOSED AMENDMENTS AND REVISED PROPOSED AMENDMENTS TO THE SOLVENT 

CLEANING PORTION OF ELEVEN DISTRICT RULES 

September 20, 2007 

DISCUSSION: 

The purpose of this rule project is to revise the solvent-cleaning requirements of the 

rules listed in able 1 to obtain as much VOC emission reductions as is expeditiously 

practicable and technologically feasible. Some examples of sources subject to these 

rules include body shops, printers, can manufacturers, and other coating facilities. This 

rule project also affects degreasers, which are also known as parts cleaners. Some 

typical industries that use parts cleaners are engine repair shops and maintenance 

areas of crude oil production facilities. 

Table 1 - Rules Included in this Rulemaking Project 

Rule # 

4603 

4604 

4605 

4606 

4607 

4612 

4653 

In establishing the VOC limits for this proposal, the VOC content limits for cleaning 

solvents in South Coast Air Quality Management District (SCAQMD) Rule 1171 (Solvent 

Cleaning Operations), last amended in July 2006, were considered. It is expected that 

operators will comply with the proposed requirements by either switching to a non-VOC 

solvent or using detergent in water. Operators would have 12 months to begin using the 

new cleaning material. 

Rule Title 

Surface Coating of Metal Parts and Products 

Can and Coil Coating Operations 

Aerospace Assembly and Component Coating Operations 

Wood Products Coating Operations 

Graphic Arts 

Motor Vehicle and Mobile Equipment Coating Operations - Phase I1 

Adhesives 

466 1 

4662 

4663 

4684 

Organic Solvents 

Organic Solvent Degreasing Operations 

Organic Solvent Cleaning, Storage, and Disposal 

Polvester Resin Ouerations 
SJVUAPCD Governing Board 

ADOPT PROPOSED AMENDMENTS AND REVISED PROPOSED AMENDMENTS TO THE SOLVENT 

CLEANING PORTION OF ELEVEN DISTRICT RULES 

September 20, 2007 

Table 2 -VOC Content Limits for Solvents Used in Solvent Cleaning 

Solvent Cleaning Category Current Rule I ~ffective on September 27a 

1. General Cleaning (I--- 50 25 

VOC Limit in glL 

2. Electrical Apparatus Components 

and Electronic Components 500 I 100 

Proposed VOC Limit 

in glL 

)

, -. I 

5. Flexographic Printing 

-~ 550 

50 

550 going to 250 

25 

in 2010 1 

6. Specialty Flexographic Printing 600 100 

I I I 

on No change 

7. Gravure Printing 

8. Lithographic or Letterpress Printing 

9. Screen Printing 

10. Ultraviolet InWElectron Beam Ink 

Application Equipment (except 

There is a 100-g/L limit in the SCAQMD rule for cleaning of ink application equipment 

used for lithographylletterpress, screen-printing, and ultravioleVelectron beam inks 

(UVIEB). This limit has not been achieved in practice. The SCAQMD staff and printing 

industry representatives are in the middle of a technology assessment to determine if 

the 100-glL limit is technically feasible by 2008. District staff is proposing that the 

compliance for these source categories in District Rule 4607 be January 1, 2010, 

allowing the SCAQMD and printing industry to complete their assessment and 

determine feasibility of the 100-g/L VOC content limits. If the limits were determined to 

be infeasible, District staff would have sufficient time to re-open the rule to include 

whatever VOC content limits were found to be appropriate for these specific source 

categories. 

50 - 450 depending on specifics 

50 - 600 depending on specifics 

750 

11. Aerospace Solvent Cleaning or 

Stripping 

During rule making, a request was made to exempt tertiary butyl acetate (TBAC) from 

the definition of VOC. In November 2004, EPA removed TBAC as a VOC due to its low 

photochemical reactivity and nearly all states, except California, have since made 

similar findings. The California Air Resources Board (ARB) was one of the original 

proponents strongly advocating a TBAC exemption, but softened their stand later in the 

process. The reason for ARB backing off on its support was a question of the overall 

health risk of TBAC. The Office of Environmental Health Hazard Assessment 

(OEHHA), in assessing TBAC, had some concerns about increased chncer risks 

associated with the use of this new chemical. ARB encouraged individual air districts to 

determine whether to exernpt TBAC rather than ARB exempting TBAC statewide. ARB 

has, however, allowed TBAC as a non-VOC only for consumer products. The 

SCAQMD has exempted TBAC only in certain specific usage categories, but since 

products that are compliant with the low-VOC content limits for solvent cleaning exist 

25 - 100 depending on specifics 

25-500 depending on specifics 

going to 25 - 100 in 2010 

500 going to 100 in 201 0 

800 650 going to 100 in 2010 

200-300 g/L or < 9.5 - 45 rnrn Hg 

composite vapor pressure 

depending on specifics 

No change 
SJVUAPCD Governing Board 

ADOPT PROPOSED AMENDMENTS AND REVISED PROPOSED AMENDMENTS TO THE SOL VENT 

CLEANING PORTION OF ELEVEN DISTRICT RULES 

September 20, 2007 -. 

that do not contain TBAC, SCAQNID did not exempt TBAC for solvent cleaning. District 

staff, therefore, recommends that if ARB exempts TBAC more generally in the future, 

the District would consider making TBAC an exempt compound. Until ARB generally 

exempts TBAC, it is recommended that TBAC remain a VOC for solvent cleaning. 

District staff has revised Rule 4612 (Motor Vehicle and Mobile Equipment Coating 

Operations - Phase II) in response to stakeholders' comment. Rule 4602 (Motor 

Vehicle and Mobile Equipment Coating Operations) is the rule that is currently being 

enforced for this source category. Rule 4602 currently allows operators to use solvent 

of any VOC content to remove road tar from surfaces as long as the material is applied 

using hand-held spray bottles. Revised Proposed Rule 461 2 would limit operators to 

bug and tar remover subject to the Consumer Products Regulation (California Code of 

Regulations Section 94570 et seq.). The change allows operators access to cleaning 

material that has limited VOC content. 

Cost Effectiveness Analysis 

Pursuant to CH&SC 40920.6(a) a cost effectiveness analysis is required to be 

performed for rules that implement Best Available Retrofit Technology (BARCT) or all 

feasible control measures (AFCM). The cost effectiveness analysis for this rule project 

is attached as Appendix C of the Final Draft Staff Report. 

Socioeconomic Analysis 

Pursuant to CH&SC Section 40728.5, District staff is required to analyze the 

socioeconomic impacts of any proposed rule or rule amendment that significantly 

affects air quality or strengthens an emission limitation. The socioeconomic impact 

analysis report for this rule project is attached as Appendix D of the Final Draft Staff 

Report. 

Environmental Impact Analysis 

As required by the California Environmental Quality Act (CEQA), District staff has 

investigated the likely environmental impacts of amendments to the solvent cleaning 

portion of eleven District rules. Based on the lack of evidence to the contrary, District 

staff has concluded that the proposed amendments and the revised proposed 

amendments will not have any significant adverse effects on the environment. Staff will 

recommend to the Governing Board that a Notice of Exemption be filed under the 

provisions of Public Resource Code 15061 (b)(3). 

Rule Consistency Analysis 

Pursuant to CH&SC Section 40727.2, District staff prepared a rule consistency analysis 

that compares the elements of the solvent cleaning portion of eleven District rules with 

the corresponding elements of other District rules, federal regulations and guidelines i 
SJVUAPCD Governing Board 

ADOPT PROPOSED AMENDMENTS AND REVISED PROPOSED AMENDMENTS TO THE SOLVENT 

CL EANING PORTION OF ELEVEN DISTRICT RULES 

September 20, 2007 

that apply to the same source category or type of equipment. The analysis is attached 

as Appendix E of the Final Draft Staff Report. 

Rule Development Process 

As part of the rule development process, District staff conducted a public scoping 

meeting in August 2006, and public workshops in November 2006, April 2007, and June 

2007 in order to present, discuss, and solicit comments from the public, affected 

sources, EPA, and ARB on amendments to the solvent cleaning portion of eleven 

District rules. Comments received during the workshop process were incorporated into 

the proposed rule amendments as appropriate. 

The proposed amendments have been made available and the notice of the public 

hearing for the proposed rule amendments has been published in a general circulation 

newspaper in each of the eight San Joaquin Valley counties. The public notice has 

been mailed to affected sources and interested parties. The notice of public hearing 

solicits written comments, and identifies the name and telephone number of District staff 

who can answer questions and respond to comments. Comments received and District 

responses to the August 16,2007 proposed amendments are discussed in Appendix A 

of the Final Draft Staff Report. 

FISCAL IMPACT: 

District staff expects no fiscal impact to the District to result from this action. 

Attachments: 

Resolution for Proposed Amendments and Revised Proposed Amendments to the Solvent 

Cleaning Portion of Eleven District Rules (5 pages) 

Proposed Amendments to Rule 4603 (24 pages) 

Proposed Amendments to Rule 4604 (30 pages) 

Proposed Amendments to Rule 4605 (20 pages) 

Proposed Amendments to Rule 4606 (22 pages) 

Proposed Amendments to Rule 4607 (28 pages) 

Revised Proposed Amendments to Rule 461 2 (1 6 pages) 

Proposed.Amendments to Rule 4653 (24 pages) 

Proposed Amendments to Rule 4661 (10 pages) 

Proposed Amendments to Rule 4662 (20 pages) . 

Proposed Amendments to Rule 4663 (18 pages) 

Proposed Amendments to Rule 4684 (1 4 pages) 

Final Draff Staff Report with Appendices For Proposed Amendments and Revised Proposed 

Amendments to the Solvent Cleaning Portion of Eleven District Rules (72 pages)