# SanJoaquin

# Valley
AIR POLLUTIONCONTROL DISTRICT

GOVERNING BOARD

J. Steven Worthley, Chair Supervisor. Tulare County
Leroy Ornellas, ViceChair Superv~sor, San Joaquin County
Tony Barba Supervisor, Kings County
Raji Brar Councilmember, City of Arvin

JudithG. Case Supervisor, Fresno County

Ronn Dominici Supervisor, Madera County

Jon McQuiston Supervisor, Kern County

MichaelG. Nelson Supervisor, MercedCounty

WtlliarnO'Brien Supervisor. StanislausCounty

I-

. Perea Cb-..illi?Iembet. City of Fresno

Chris Vierra Councilmember. City 01 Ceres

Seyed Sadredin Executive Director1 Air Pollution Control OHicer

NorthernRegionOff~ce 4800 Enterprise Way Modesto. CA 95356-8718 (2091557-6400 FAX (209)557-6475

Central Region Office 1990 East GettysburgAvenue Fresno, CA 93726-0244 (559) 230-6000 FAX (5591230-6061

Southern Region Ollice 2700 M Street, Suite 275 Bakerslield, CA 93301 -2373 (661) 326-6900 FAX (661) 326-6985 DA-TE

### : September 20, 2007
TO: SJVUAPCD Governing Board
FROM: Seyed Sadredin, Executive Project Coordinator: Sandra Lowe-Leseth


### RE: ADOPT PROPOSED AMENDMENTS AND REVISED PROPOSEDAMENDMENTS 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. Inaccordance with federal Clean Air Act requirements for nonattainment areas, the San Joaquin Valley UnifiedAir Pollution Control District (District) adopted the 2004 Extreme Ozone Attainment Demonstration Planand the 2007 Ozone Planto 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 andvolatile organic compounds (VOC), the precursors to ground-level ozone.

The revised proposed rule amendments satisfy a control measure commitment included in boththe 2004 Ozone Plan and the 2007 Ozone Plan. The revised proposed amendments would establish more stringent VOC limitsfor 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 isto revise the solvent-cleaning requirements ofthe rules listed in

## able 1to 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 inthis 

### 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 expectedthat operatorswill comply with the proposed requirements by either switching to a non-VOC solvent or using detergent inwater. Operators would have 12 monthsto 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 4661 4662 4663 4684 Organic Solvents Organic Solvent Degreasing Operations Organic Solvent Cleaning, Storage, and Disposal Polvester Resin OuerationsSJVUAPCD Governing Board ADOPT PROPOSED AMENDMENTS AND REVISED PROPOSEDAMENDMENTS 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[ I

-~ 550 550 goingto 250 in 2010 

# 1
5. Flexographic Printing 50 25 6. Specialty Flexographic Printing 600 100 

# I I I on Nochange

7. Gravure Printing
8. Lithographicor Letterpress Printing
9. Screen Printing 10. Ultraviolet InWElectron Beam Ink Application Equipment (except



### There is a 

### 100-g/Llimit in the SCAQMD rule for cleaning of ink application equipment usedfor lithographylletterpress, screen-printing, and ultravioleVelectron beam inks (UVIEB). This limit has not been achieved in practice. The SCAQMD staff and printing industry representatives are inthe middle of a technology assessment to determine if the 100-glL limit istechnically feasible by2008. 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 limitswere determined to be infeasible, District staff would have sufficient time to re-openthe rule to include whatever VOC content limits were found to be appropriate forthese specific source categories. 50 

### -450 depending onspecifics
50 

### - 600 depending onspecifics
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 November2004, EPA removedTBAC 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 oneof the original proponents strongly advocating a TBAC exemption, but softened their stand later inthe 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 increasedchncer 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-VOConly for consumer products. The SCAQMD has exempted TBAC only in certain specific usage categories, but since productsthat are compliant with the low-VOC content limits for solvent cleaning exist 25 - 100 dependingon 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 NochangeSJVUAPCD Governing Board ADOPT PROPOSED AMENDMENTS AND REVISED PROPOSED AMENDMENTS TO THE SOL VENT CLEANING PORTION OFELEVEN DISTRICTRULES 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 inthe future, the District would consider makingTBAC an exempt compound. UntilARB 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. Rule4602 (Motor Vehicle and Mobile Equipment Coating Operations) isthe 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 2would limit operatorsto bug and tar remover subjectto the Consumer Products Regulation (California Code of Regulations Section 94570 et seq.). The change allows operators access to cleaning materialthat has limitedVOC 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 ImpactAnalysis



### As required by the California Environmental Quality Act (CEQA), District staff has investigated the likely environmental impacts of amendments to the solvent cleaning portionof 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 onthe environment. Staffwill recommend to the Governing Board that a Noticeof Exemption be filed under the provisions of Public Resource Code 15061 (b)(3). Rule ConsistencyAnalysis



### 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 iSJVUAPCD Governing Board ADOPT PROPOSED AMENDMENTS AND REVISED PROPOSED AMENDMENTS TO THE SOLVENT CLEANING PORTION OFELEVEN 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 inAugust 2006, and public workshops in November 2006, April 2007, and June 2007 inorder 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 ofthe public hearing for the proposed rule amendments has been published in a general circulation newspaper ineach of the eight San Joaquin Valley counties. The public notice has been mailedto affected sources and interested parties. The noticeof 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 inAppendix 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 (5pages) Proposed Amendments to Rule 4603 (24pages) ProposedAmendments to Rule 4604 (30pages) ProposedAmendments to Rule 4605 (20pages) Proposed Amendments to Rule 4606 (22pages) Proposed Amendments to Rule 4607 (28pages) Revised Proposed Amendments to Rule 4612 (16pages) Proposed.Amendments to Rule 4653 (24pages) ProposedAmendments to Rule 4661 (10pages) ProposedAmendments to Rule 4662 (20pages)

. ProposedAmendments to Rule 4663 (18 pages) Proposed Amendments to Rule 4684 (1 4pages) Final Draff Staff Report with Appendices For Proposed Amendments and Revised Proposed Amendments to the Solvent Cleaning Portion of Eleven District Rules (72 pages)