SACRAMENTO METROPOLITAN 

AIR QUALITY MANAGEMENT DISTRICT

STAFF REPORT 

RULE 450 – GRAPHIC ARTS OPERATIONS 

RULE 451 – SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS 

RULE 452 – CAN COATING 

RULE 454 – DEGREASING OPERATIONS 

RULE 456 – AEROSPACE ASSEMBLY AND COMPONENT COATING OPERATIONS 

RULE 463 – WOOD PRODUCTS COATINGS 

RULE 464 – ORGANIC CHEMICAL MANUFACTURING OPERATIONS 

RULE 465 – POLYESTER RESIN OPERATIONS 

 RULE 466 – SOLVENT CLEANING 

August 25, 2008 

Prepared by: Jimmy Cheng 

Assistant Air Quality Engineer 

Reviewed by: Kevin J. Williams, Ph.D. 

 Program Coordinator 

Aleta Kennard 

Program Supervisor 

Approved by: Brigette Tollstrup 

 Division Manager 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 2 

BACKGROUND

Ground level ozone is a secondary pollutant formed from photochemical reactions of 

nitrogen oxides (NOx) and volatile organic compounds (VOCs) in the presence of 

sunlight. Ozone is a strong irritant that adversely affects human health and damages 

crops and other environmental resources. As documented by the U.S. Environmental 

Protection Agency (EPA) in the most recent Criteria Document for ozone (U.S. EPA 

2006), both short-term and long-term exposure to ozone can irritate and damage the 

human respiratory system, resulting in: 

• decreased lung function; 

• development and aggravation of asthma; 

• increased risk of cardiovascular problems such as heart attacks and strokes; 

• increased hospitalizations and emergency room visits; and 

• premature deaths. 

The District is currently designated as a nonattainment area for both the state and 

federal ozone standards. Since VOCs are a precursor to ozone, one of the strategies to 

control ozone pollution is to reduce VOC emissions from existing stationary sources. 

The primary purpose of this rule project is to amend the solvent cleaning limits and 

requirements specified in Rule 450, Graphic Arts Operations; Rule 451, Surface Coating 

of Miscellaneous Metal Parts and Products; Rule 452, Can Coating; Rule 454, 

Degreasing Operations; Rule 456, Aerospace Assembly and Component Coating 

Operations; Rule 463, Wood Products Coatings; Rule 464, Organic Chemical 

Manufacturing Operations; Rule 465, Polyester Resin Operations; and Rule 466, Solvent 

Cleaning. In the 2003 Triennial Report, the District committed to adopt more stringent 

solvent cleaning standards to satisfy state plan requirements for “all feasible measures.” 

These amendments will fulfill that state plan commitment, and will also achieve emission 

reductions that will help the District attain the federal 8-hour ozone standard. These 

rules were originally adopted to meet federal Reasonably Available Control Technology 

(RACT) requirements, state Best Available Retrofit Control Technology (BARCT) 

requirements, and to meet 1994 State Implementation Plan requirements. 

Solvent cleaning is an essential part of any manufacturing operation or service operation 

(e.g., automotive repair, graphic arts printing) and is not limited just to application 

equipment, but also includes manufactured or serviced parts or equipment. The 

cleaning process generally involves surface preparation such as wipe cleaning or 

degreasing to remove grease and other contaminants prior to assembling. Currently, 

most of the cleaning is done using cleanup materials containing VOCs or materials 

containing inorganic or exempt compounds (e.g., halogenated solvents, and nonhalogenated solvents.) Some of the halogenated solvents have been regulated by EPA 

under 40 CFR Part 463, Subpart T – National Emission Standards for Halogenated 

Solvent Cleaning. 

Staff is also proposing to amend Rules 450 and 451 to conform to recent Control 

Technique Guideline documents (CTGs) promulgated by EPA. The two graphic artsrelated CTGs, dated September 2006, address emissions from offset lithographic and 

letterpress printing and flexible package printing. The September 2007 CTG for metal 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 3 

furniture coatings address emissions from such coating operations. 

BACKGROUND FOR EACH RULE

The proposed changes will lower the VOC content limits for cleaning solvents to feasible 

limits that have been implemented in the South Coast Air Quality Management District 

(SCAQMD). Additionally, the proposed changes will lower the VOC limits for fountain 

solutions and include control device requirements specified in the 2006 CTGs for graphic 

arts operations, and lower the VOC limits and increase the emissions control equipment 

efficiency requirement for metal furniture coatings to be consistent with the 2007 CTG for 

metal furniture coatings. 

Rule 450- Graphic Arts Operations

Adopted on July 23, 1981 and last amended on March 23, 2000, Rule 450 regulates 

VOC emissions from graphic arts operations, which include cleaning activities for 

gravure, screen printing, flexographic, lithographic, and various other coating and 

laminating operations. This rule is being proposed for amendment in order to require 

that general cleaning and application equipment cleaning operations use cleanup 

materials with lower VOC content than previously allowed. The proposed amendments 

will: 

• Lower the solvent VOC limits for several cleaning categories to as low as 25 

grams per liter (g/l); and 

• Eliminate the current VOC composite vapor pressure limits and all references to 

vapor pressure limits. 

• For sources that emit more than 450 pounds of VOC per month, lower the VOC 

limits for fountain solutions. 

• For sources that emit 25 tons of VOC or more per year, require control 

equipment for lithographic, letterpress, and flexible package printing operations, 

in conformance with the 2006 CTGs. 

Rule 451- Surface Coating of Miscellaneous Metal Parts and Products

Rule 451 was adopted on June 19, 1979 and was last amended on October 2, 1997. 

This rule applies to coating, coating removal (stripping), surface preparation, and 

cleanup operations for miscellaneous metal parts and products. The proposed 

amendment will lower the VOC limit for surface preparation and cleanup materials to 25 

g/l, lower the VOC limits for metal furniture coatings to as low as 275 g/l, and increase 

the emissions control equipment efficiency requirement to 90%. 

Rule 452- Can Coating

Rule 452 was adopted on June 19, 1979 and last amended on September 5, 1996. Can 

coating operations include surface preparation and cleanup. The proposed 

amendments will: 

• Lower the VOC limit for cleaning to 25 g/l. 
Staff Report 

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August 25, 2008, Page 4 

• Reduce the VOC content limits for two piece and three piece interior body sprays 

and end sealing compounds. 

• Specify acceptable application methods. 

• Increase emissions control equipment efficiency requirement to 90%. 

Rule 454- Degreasing Operations

Adopted on June 5, 1979 and last amended on May 23, 2002, Rule 454 regulates VOC 

emissions from solvent degreasing operations. As defined in this rule, degreasing 

operations include vapor and non-vapor (cold) degreasing. This rule is being proposed 

for amendment in order to require that all degreasing operations use solvents that 

contain no more than 25 g/l of VOCs. This rule currently allows the use of airtight/airless 

cleaning system or emissions control equipment as alternatives to complying with the 

VOC limit. Staff proposes to retain the option to use an airtight/airless cleaning system. 

Staff also proposes to add an exemption for the degreasing of high-voltage microwave 

vacuum tubes. 

Rule 456- Aerospace Assembly and Component Coating Operations

Rule 456 was adopted on February 23, 1993 and was last amended on July 23, 1998. 

This rule limits VOC emissions from aerospace assembly and coating operations, which 

include coating removal (stripping), surface preparation and cleaning, and application 

equipment cleanup material. The proposed amendments to this rule will lower the 

solvent VOC limit for cleaning application equipment to 25 g/l. 

Rule 463- Wood Products Coatings

Rule 463 was adopted on September 5, 1996 and was last amended on July 23, 1998. 

This rule regulates VOC emissions from wood coating operations, including strippers 

used on wood products and surface preparation and cleanup materials. The proposed 

amendments will reduce the VOC limit for surface preparation and cleanup materials to 

25 g/l and will lower the low usage exemption to 55 gallons per year. Additionally, Staff 

proposes to restrict the use of the emissions averaging provisions to a maximum of 20 

gallons per year of historical reproduction coatings. 

Rule 464- Organic Chemical Manufacturing Operations

Rule 464 was adopted on July 23, 1998 and has never been amended. This rule limits 

VOC emissions from organic chemical plants. Cleanup activities, which include 

maintenance solvent cleaning and in-line solvent cleaning of process units and piping, 

are regulated under this rule. 

The solvent cleaning requirements for Rule 464 are found under the cleanup and 

storage requirements section. The proposed amendments will reduce the VOC limit for 

maintenance cleaning solvent to 25 g/l. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 5 

Rule 465- Polyester Resin Operations

Rule 465 was adopted on February 6, 1997 and was last amended on June 4, 1998. 

The rule regulates emissions from polyester resin operations. Polyester resin operations 

include but are not limited to bathtub, shower, and sink manufacturers, spa and boat 

manufacturers, and tomato bin manufacturers, and include cleaning materials. The 

proposed amendments will reduce the VOC limit for cleaning materials to 25 g/l. 

Additionally, Staff proposes to increase the emissions control equipment efficiency 

requirement to 90%. 

Rule 466- Solvent Cleaning 

Prior to the adoption of Rule 466 on May 23, 2002, there were still cleaning activities 

such as the cleaning of electrical and electronic components, medical devices and 

pharmaceuticals, and architectural coating application equipment, that were not 

regulated by the industry-specific solvent cleaning rules (Rules 450, 451, etc.). Rule 466 

was implemented to capture these solvent cleaning activities. This rule has not been 

amended since adoption. The proposed amendments will: 

• Lower the solvent VOC limits for several cleaning categories to as low as 25 g/l, 

and 

• Add a new VOC standard of 200 grams per liter for the sterilization of food 

product manufacturing and processing equipment. 

• Add an exemption for the cleaning of high-voltage microwave vacuum tubes. 

LEGAL MANDATES 

Attainment Demonstration Plan: The District is designated as a nonattainment area 

for the federal 8-hour ozone standard (69 FR 23858, April 30, 2004). U.S. EPA’s Phase 

2 Rule (70 FR 71611, Nov. 29, 2005) to implement the 8-hour ozone standard requires 

the District to submit an attainment demonstration plan into the state implementation 

plan. 

The proposed amendments will achieve reductions in VOC emissions that will be 

necessary to help the Sacramento area attain the federal 8-hour ozone standard. These 

rules will be included in the attainment demonstration plan. 

 

Reasonably Available Control Technology (RACT); Clean Air Act (CAA) section 172 

(c)(1) specifies that state implementation plans (SIPs) for nonattainment areas must 

include “reasonably available control measures” (RACM), including “reasonably 

available control technology” (RACT), for sources of emissions. Section 182 (b)(2) 

specifically provides that for nonattainment areas classified as “moderate” or worse, 

states must revise their SIPs to include RACT for sources of VOC emissions covered by 

a CTG document issued after November 15, 1990 and prior to the area’s date of 

attainment. 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, 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 6 

1979). In developing CTGs, EPA evaluates, among other things, the sources of VOC 

emissions and the available control approaches for addressing these emissions, 

including the costs of such approaches. Based on available information and data, EPA 

provides the recommendations for RACT.

The details of the 2006 CTGs pertaining to graphic arts operations and the 2007 CTG for 

metal furniture coatings are summarized below. 

CTG for Offset Lithographic Printing and Letterpress Printing (EPA-453/R-06-002)

Applicability

This CTG, promulgated by EPA in September 2006, provides control recommendations 

for reducing VOC emissions stemming from the use of fountain solutions, cleaning 

materials, and inks in offset lithographic printing and cleaning materials and inks in 

letterpress printing. The requirements for fountain solutions do not apply to offset 

lithographic printing operations with less than or equal to 15 pounds per day of actual 

VOC emissions. The requirements for control equipment do not apply to presses with 

potential to emit less than 25 tons of VOC per year, prior to controls. 

Recommended Control Options

The CTG specifies three methods to reduce VOC emissions from offset lithographic 

printing and letterpress printing. These options are add-on controls; process 

modifications or work practices; and material reformulation or substitution. Specific CTG 

requirements are detailed below. 

A. Heatset web offset lithographic and heatset letterpress inks and dryers add-on control 

requirements: 

• The recommended level of control for VOC emissions from heatset dryers is 90 percent 

control efficiency for a control device whose first installation date was prior to the 

effective date of a State RACT rule, which was issued after the date of this CTG. 

• The recommended level of control for VOC emissions from heatset dryers is 95 percent 

control efficiency for a control device whose first installation date was on or after the 

effective date of the State RACT rule, which was issued after the date of this CTG. 

• To accommodate situations where the inlet VOC concentration is so low that a 90 or 95 

percent efficiency may not be achievable, it is recommended that an alternative 

requirement be specified for the control device outlet concentration to be no more than 

20 ppmv as hexane on a dry basis. 

B. Fountain Solution VOC content limits: 

• Heatset Web Offset Lithographic Printing: 1.6% alcohol by weight (or 3% if chilled) 

• Sheet-fed Offset Lithographic Printing: 5% alcohol by weight (or 8.5% if chilled) 

• Coldset Web Offset Lithographic Printing: 5% percent alcohol substitute by weight and 

no alcohol in the fountain solution 

C. Cleaning materials VOC limits: 

The following recommendations apply to blanket washing, roller washing, plate cleaners, 

metering roller cleaners, impression cylinder cleaners, rubber rejuvenators, and other 

cleaners used for cleaning a press, press parts, or to remove dried ink from areas 
Staff Report 

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August 25, 2008, Page 7 

around a press. 

• Use cleaning materials with a VOC composite vapor pressure less than 10mm Hg at 20 

degrees C or cleaning materials containing less than 70 weight % VOC. 

D. Work Practices 

• Keep cleaning materials and used shop towels in closed containers. 

CTG for Offset Flexible Package Printing (EPA-453/R-06-003)

Applicability

This CTG, promulgated by EPA in September 2006, provides control recommendations 

for reducing VOC emissions from inks, coatings, adhesives and cleaning materials used 

in flexible package printing. The requirements for control equipment do not apply to 

presses with potential to emit less than 25 tons of VOC per year, prior to controls. 

Recommended Control Options

The two options for reducing VOC emissions from inks, coatings, and adhesives used in 

the flexible package printing industry are adding/improving add-on controls, and material 

reformulation or substitution. 

Recommendations for controlling VOC emissions from inks, coatings, adhesives and 

cleaning materials used in flexible package printing operations are as follows: 

A. Coatings, inks and adhesives used on flexible packaging printing presses 

The recommended control levels in the final CTG include the following: 

• 65% overall control for a press that was first installed prior to March 14, 1995 and that 

is controlled by an add-on air pollution control device whose first installation date was 

prior to the effective date of the State RACT rule. 

• 70% overall control for a press that was first installed prior to March 14, 1995 and that 

is controlled by an add-on air pollution control device whose first installation date was on 

or after the effective date of the State RACT rule. 

• 75% overall control for a press that was first installed on or after March 14, 1995 and 

that is controlled by an add-on air pollution control device whose first installation date 

was prior to the effective date of the State RACT rule. 

• 80% overall control for a press that was first installed on or after March 14, 1995 and 

that is controlled by an add-on air pollution control device whose first installation date 

was on or after the effective date of the State RACT rule. 

B. Cleaning Materials Work Practices at Flexible Package Printing Presses 

Keep cleaning materials and used shop towels in closed containers, and conveying 

cleaning materials from one location to another in closed containers or pipes. 

The proposed amendments will meet RACT requirements and achieve reductions in 

VOC emissions that will be necessary to help the Sacramento area attain the federal 8-

hour ozone standard. These rules will be included in the attainment demonstration plan. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 8 

CTG for Metal Furniture Coatings (EPA-453/R-07-005)

Applicability

This CTG, promulgated by EPA in September 2007, provides control recommendations 

for reducing VOC emissions stemming from the use of surface coatings on metal 

furniture. The requirements for metal furniture do not apply to each metal furniture 

surface coating unit at a facility where the total actual VOC emissions from all such 

operations, including related cleaning activities, are less than 15 pounds per day 

(equivalent to 3 tons per 12-month rolling period) before consideration of controls. 

Recommended Control Options

The CTG specifies three methods to reduce VOC emissions from metal furniture 

coatings. These options are lower VOC limits, add-on controls, work practices, or 

application methods. Various exemptions are also recommended. Specific CTG 

requirements are detailed below. 

 

A. Metal furniture coatings VOC content limits: 

VOC CONTENT: Grams/Liter 

(Lbs/Gal) 

excluding water and exempt 

compounds 

COATING TYPE AIR DRIED BAKED 

General, One-Component 275 (2.3) 275 (2.3) 

General, Multi-Component 340 (2.8) 275 (2.3) 

Extreme High Gloss 340 (2.8) 360 (3.0) 

Extreme Performance 420 (3.5) 360 (3.0) 

Heat Resistant 420 (3.5) 360 (3.0) 

Metallic 420 (3.5) 420 (3.5) 

Pretreatment Coatings 420 (3.5) 420 (3.5) 

Solar Absorbent 420 (3.5) 360 (3.0) 

B. Add-on control requirements: 

The CTG recommends an overall control efficiency of 90% for metal furniture coating 

operations. 

C. Work Practices 

• store all VOC-containing materials and used shop towels in closed containers 

• ensure that mixing and storage containers used for VOC-containing materials are kept 

closed at all times except when depositing or removing these materials 

• minimize spills of VOC-containing materials 

• convey VOC-containing materials from one location to another in closed containers or 

pipes 

• minimize VOC emission from cleaning of storage, mixing, and conveying equipment 

D. Application Methods 

The following application methods are recommended: 

• Electrostatic application 
Staff Report 

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August 25, 2008, Page 9 

• HVLP spray 

• Flow coat 

• Roller coat 

• Dip coat, including electrodeposition 

• Other coating application methods capable of achieving a transfer efficiency 

equivalent or better than that achieved by HVLP spraying 

Recommended exemptions

The CTG recommends the following types of coatings and coating operations be exempt 

from our recommended VOC content limits: 

• Stencil coatings 

• Safety-indicating coatings 

• Solid-film lubricants 

• Electric-insulating and thermal-conducting coatings 

• Touch-up and repair coatings 

• Coating application utilizing hand-held aerosol cans 

State Mandates: 

Serious Nonattainment Plan Requirements: The District is designated as a serious 

nonattainment area for the state ozone standard. The California Clean Air Act requires 

areas with this designation to adopt control measures required in sections 40913, 40914, 

and 40919 of the California HSC: 

• HSC Section 40913 requires districts to develop a plan to achieve California’s 

ambient air quality standards by the earliest practicable date. 

• HSC Section 40914(b)(2) requires every nonattainment district which cannot 

achieve a reduction of 5% or more per year in district wide emissions to include 

in their state attainment plans “every feasible measure” to reduce the emissions 

of nonattainment pollutants and their precursors. SCAQMD Rule 1171, which 

regulates emissions from solvent cleaning, qualifies as a “feasible measure.” 

The District’s 2003 Triennial Plan update included a commitment to achieve VOC 

emission reductions of 0.37 tons per day by implementing more stringent, 

feasible controls on solvent cleaning. The proposed amendments will achieve 

VOC emission reductions of 0.54 tons per day and will satisfy the state plan 

commitment. 

• HSC Section 40919(a)(3) requires districts with serious nonattainment for ozone 

to adopt BARCT for all existing permitted sources. Staff has found that the 

proposed amendments will meet the BARCT requirement. 

Transport Mitigation Emission Control Requirements: Title 17, Section 70600 of the 

California Code of Regulations requires that districts within the areas of origin of 

transported air pollutants, as identified in section 70500(c), include sufficient emission 

control measures (including “all feasible measures” and BARCT) in their attainment 

plans for ozone to mitigate the impact of pollution sources within their jurisdictions on 

ozone concentrations in downwind areas commensurate with the level of contribution. 

An upwind district shall comply with the transport mitigation planning and implementation 

requirements set forth in this section regardless of its attainment status, unless the 
Staff Report 

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August 25, 2008, Page 10 

upwind district complies with the requirements of section 70601. 

The proposed amendments are based on all feasible control measures and BARCT 

requirements, and therefore comply with the state mandates. 

SUMMARY OF REQUIREMENTS

The proposed rules will set more stringent VOC content limits, and in some cases 

eliminate vapor pressure limits. Several VOC limits in SCAQMD Rule 1171 for graphic 

arts-related cleaning categories have not yet been implemented. Staff considered these 

VOC limits with future effective dates in the proposed rules, as discussed below in the 

summary for Rule 450. 

The requirements for each proposed rule are as follows. 

Rule 450

Rule 450 includes cleaning and storage requirements for graphic arts operations. 

Solvent cleaning in a graphic arts operation falls under two categories: general cleaning 

(which includes maintenance, repair, and wipe cleaning) and application equipment 

cleaning (which includes such activities as cleaning for lithographic and letter press 

printing and screen printing). The rule currently allows compliance by meeting a VOC 

composite vapor pressure limit in lieu of achieving the VOC content limit. Alternatively, 

air pollution control equipment may be used if neither limit can be attained. 

The VOC limits for lithographic printing (other than newsprint substrates), screen 

printing, and UV/electron beam ink equipment cleaning in SCAQMD Rule 1171 recently 

became effective, on January 1, 2008. SCAQMD technology assessments completed in 

August 2006 provide evidence to support the implementation of these VOC limits. The 

San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) also used these 

limits, effective January 1, 2010, when they amended their graphic arts rule (Rule 4607) 

on September 20, 2007. Therefore, Staff proposes to lower the VOC limits in Rule 450 

for the above cleaning categories to the January 1, 2008 limits in SCAQMD Rule 1171, 

but with a future effective date of January 1, 2011. 

Staff proposes to add exemptions for two cleaning categories: cleaning of metering 

rollers and printing plates (for newsprint as well as other substrates) and stripping of 

cured inks, cured coatings, and cured adhesives. In the proposed exemption for 

metering rollers and printing plates, specific presses are not subject to the monthly 

usage limit for materials used to clean metering rollers and printing plates specified in 

Section 302.2, provided that they comply with the eventual VOC limit of 100 g/l (effective 

1/1/2011) for these components. The proposed exemption for the stripping of cured 

materials is for clarification purposes only, since the current definition of solvent cleaning 

already implies that stripping of such cured materials is exempt. 

Currently, Rule 450 allows cleaning solvents to comply with vapor pressure limits instead 

of VOC content limits. Staff is proposing to remove the solvent vapor pressure limits 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 11 

from Rule 450. This change is consistent with SCAQMD Rule 1171, which contains 

solvent VOC limits that are less than or equal to the current Rule 450 VOC limits and 

does not allow the use of low vapor pressure solvents in lieu of meeting the VOC content 

limits. Staff considers the SCAQMD VOC content limits to constitute a more stringent 

feasible measure than the current Rule 450 VOC content/vapor pressure limits. 

Adoption of the SCAQMD limits will result in greater and more quantifiable reductions 

from solvent cleaning in graphic arts operations. While low vapor pressure solvents may 

evaporate at a slower rate, all of the solvent eventually evaporates. Setting a lower VOC 

limit will reduce further what is eventually emitted to the air than setting a low vapor 

pressure limit. EPA’s CTG for Offset Lithographic Printing and Letterpress Printing 

(2006) states that the use of low vapor pressure cleaning materials (vapor pressure less 

than 10 mm Hg at 20 °C) results in an emission reduction comparable to using materials 

with 30% VOC by weight (approximately 240 g/l of VOC), considerably higher than the 

proposed VOC limits in Rule 450. 

Staff proposes to reduce the allowable VOC content of fountain solutions to those 

specified in the 2006 CTG for Offset Lithographic Printing and Letterpress Printing (see 

table following #8). In order to incorporate the CTG requirements, it is necessary to 

establish separate categories for heatset web, coldset web, sheet fed, and all other 

lithographic presses. 

The new requirements for emissions control equipment also address the 2006 CTG 

recommendations. Effective one year after the date of adoption, the minimum overall 

control system efficiency of 67% will be increased to various levels, depending upon the 

specific process involved and the date on which the press and emissions control 

equipment were first installed. Unless exempted in Section 110 as described below, 

sources must use emissions control equipment, and the equipment must achieve at 

least an overall efficiency of one of the following, whichever is applicable: 

Heatset Web Offset Lithographic Printing and Heatset Web Letterpress Printing: 

• 90% overall efficiency if permit application is deemed complete prior to (date of 

adoption) 

• 95% overall efficiency if permit application is deemed complete after (date of 

adoption). 

Flexible Package Printing Inks, Coatings, and Adhesives: 

• 70% overall efficiency for a press that was first installed prior to March 14, 1995. 

• 80% overall efficiency for a press that was first installed on or after March 14, 1995. 

To be consistent with the 2006 CTG recommendations, a new section was also added to 

provide an alternative to compliance with the overall system efficiency requirements for 

heatset web offset lithographic and heatset web letterpress printing. In lieu of complying 

with those overall efficiency requirements, sources are required to use emissions control 

equipment with mass outlet concentration no greater than 20 ppmv as hexane on a dry 

basis. For all other printing operations including exempted operations, the emissions 

control equipment (with a required 67% efficiency, consistent with the current 

requirement) is optional if the associated VOC limits are achieved. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 12 

The new exemptions in Section 110 of the proposed rule are also based on the 2006 

CTG recommendations. Fountain solutions are exempt from the revised VOC limits if 

the offset lithographic operations do not exceed 15 pounds of VOC per day (in which 

case the current VOC limits for fountain solutions will remain in effect). A heatset web 

offset lithographic press is exempt from the control equipment requirements if 1) the 

potential to emit from the dryer is less than 25 tons of VOC per year, or 2) the press is 

used for book printing, or 3) if the press has a maximum web width of 22 inches or less. 

Inks, coatings, and adhesives used for flexible package printing are exempt from the 

control equipment requirements if the potential to emit from the dryer is less than 25 tons 

of VOC per year. Section 110 also clarifies that if actual emissions from control 

equipment are at least 25 tons per year of VOC per rolling 12-month period, then that 

unit must comply with Section 303.1 and cannot use the exemptions in this section. This 

is a “once in, always in” requirement. 

The proposed amendments for this rule are listed below. For a detailed list of all 

changes to Rule 450, please refer to Appendix B. 

1. Lower the solvent VOC limits for several cleaning categories (see below). 

Current Limits Proposed Limits 

(The specified limits remain in effect 

until limits are replaced by limits listed 

in subsequent columns.)

Effective 

(one year 

after date of 

adoption) 

Effective 

Material Type 1/1/2011 

VOC Content 

g/l (lb/gal) 

Including Water 

and Exempt 

Compounds 

 VOC 

Composite 

Partial 

Pressure 

Millimeters of 

Mercury at 20 o

C (68 oF) 

VOC 

Content 

g/l (lb/gal) 

Including 

Water and 

Exempt 

Compounds 

VOC 

Content 

g/l (lb/gal) 

Including 

Water and 

Exempt 

Compounds 

General (e.g., maintenance, repair, 

solvent, wipe) Cleaning 

72 (0.60) 25 (0.21) 

Application Equipment Cleaning 

General (not specifically listed below) 

Lithographic and Letter Press Printing 

Newsprint substrates 

Blanket and Roller Washes 

Metering Rollers/Printing Plates 

Other On-Press Components 

Removable Press Components 

Substrates other than newsprint 

Blanket and Roller Washes 

Metering Rollers/Printing Plates 

Other On-Press Components 

Removable Press Components 

Screen Printing 

100 (0.83) 

300 (2.5) 

300 (2.5) 

100 (0.83) 

100 (0.83) 

300 (2.5) 

300 (2.5) 

100 (0.83) 

100 (0.83) 

300 (2.5) 

AND 

OR 

OR 

AND 

AND 

OR 

OR 

AND 

AND 

OR 

3 

10 

25 

3 

3 

10 

25 

3 

3 

10 

25 (0.21) 

100 (0.83) 

100 (0.83) 

100 (0.83) 

25 (0.21) 

25 (0.21) 

100 (0.83) 

100 (0.83) 

100 (0.83) 

100 (0.83) 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 13 

Current Limits Proposed Limits 

(The specified limits remain in effect 

until limits are replaced by limits listed 

in subsequent columns.)

Effective 

(one year 

after date of 

adoption) 

Effective 

Material Type 1/1/2011 

VOC Content 

g/l (lb/gal) 

Including Water 

and Exempt 

Compounds 

 VOC 

Composite 

Partial 

Pressure 

Millimeters of 

Mercury at 20 o

C (68 oF) 

VOC 

Content 

g/l (lb/gal) 

Including 

Water and 

Exempt 

Compounds 

VOC 

Content 

g/l (lb/gal) 

Including 

Water and 

Exempt 

Compounds 

Flexographic Printing 

Specialty Flexographic Printing 

Ultraviolet/Electron Beam Inks (Except 

Screen Printing) 

100 (0.83) 

810 (6.8) 

800 (6.7) 

AND 

AND 

AND

3 

21 

33 

25 (0.21) 

100 (0.83) 

650 (5.4) 100 (0.83) 

2. Add a new VOC limit of 100 g/l specifically for blanket and roller washes used on 

newsprint equipment (shown in the table above). 

3. Add a new VOC limit of 25 g/l specifically for removable press components (shown in 

the table above). 

4. Add definitions of “potential to emit,” “electron beam ink,” “newsprint,” “other on-press 

component”, “removable press component,” “stripping,” and “cured coating, cured 

ink, or cured adhesive,” using the same definitions as the ones in the SCAQMD 

rules. 

5. Replace the term “other cleaning” with “metering rollers/printing plates,” consistent 

with previous definition. 

6. Add a new VOC limit of 100 g/l specifically for metering rollers and printing plates 

used in newsprint operations (shown in the table above). 

7. Eliminate the current VOC composite vapor pressure limits. 

8. Add new categories for fountain solutions and lower the VOC limits, as shown in the 

following table. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 14 

VOC Content Limits 

Including water and exempt 

compounds 

MATERIAL TYPE 

Current Limits 

(g/l) 

(The specified 

limits remain in 

effect until limits 

are replaced by 

limits listed in 

the subsequent 

column.) 

Effective 

(One Year 

After Date 

Of 

Adoption) 

(% by 

weight) 

Heatset Web Offset Lithography 

Fountain Solutions Containing Alcohol 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

Fountain Solutions Containing No Alcohol 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

Coldset Web Offset Lithography 

Fountain Solutions Containing Alcohol 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

Fountain Solutions Containing No Alcohol 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

Sheet-fed Offset Lithography with maximum sheet size 

greater than 11 X 17 inches or total solution reservoir greater 

than 1 gallon 

Fountain Solutions Containing Alcohol 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

Fountain Solutions Containing No Alcohol 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

All Other Presses (includes offset lithographic presses 

exempt pursuant to Section 110.9) 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

100 

80 

100 

80 

100 

80 

100 

80 

100 

80 

100 

80 

100 

80 

3 

1.6 

5 

5 

(*See below) 

(*See below) 

5 

5 

8.5 

5 

5 

5 

10 

8 

* Effective one year after date of adoption, fountain solutions containing alcohol shall not be used in 

coldset web offset lithography printing operations.

9. Add a requirement for mandatory emissions control equipment for heatset web offset 

lithographic printing, heatset web letterpress printing, and flexible package printing 

inks, coatings, and adhesives. Increase the required overall control efficiency to the 

following levels: 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 15 

Process Description Overall Control Efficiency 

Current Proposed 

Heatset Web Offset Lithographic Printing 

and Heatset Web Letterpress Printing

 

Permit application complete prior to date of 

adoption 

67% 90% 

Permit application complete after date of 

adoption 

67% 95% 

Flexible Package Printing Inks, Coatings, 

and Adhesives

 

Press was first installed prior to 3/14/95 67% 70% 

Press was first installed on or after 3/14/95 67% 80% 

10. Add exemptions (as described above) for VOC content of fountain solutions and for 

control equipment for heatset web offset lithographic printing, heatset web letterpress 

printing, and flexible package printing inks, coatings, and adhesives. 

11. Update the recordkeeping section to include new usage record requirements for 

materials used for printing on newsprint. 

12. Add calculation method for determining overall emissions control equipment system 

efficiency. 

13. Update the test methods to specify the most current test methods. 

Rule 451

Rule 451 limits VOC emissions from the application of coating, coating removers 

(strippers), surface preparation material, and cleanup material to miscellaneous metal 

parts and products in a shop environment. Similar to Rule 450, Rule 451 also provides 

the option of using an emission control system in lieu of complying with the specified 

VOC emissions limits. 

Currently, Sections 110.2 and 110.3 of Rule 451 provide low-usage exemptions for 

aluminum coatings applied to window frames and door frames, as well as for 

pretreatment wash primers, that exceed the VOC limits in the rule, provided that the 

usage of such materials is less than 200 gallons per calendar year. Section 401 

requires facilities utilizing the low-usage exemptions to submit annual reports showing 

the usage of these materials. Staff reviewed the recent annual reports and found that no 

facility used such materials in an amount greater than 55 gallons per calendar year. 

Therefore, Staff is proposing to eliminate the low-usage exemptions in Sections 110.2 

and 110.3. The usage of these materials will be subject to the general low-usage 

exemption of 55 gallons per calendar year as specified in Section 110.1. The 55 

gallon/year exemption level is consistent with the EPA Region IX “Little Bluebook” 

(Guidance Document for Correcting Common VOC & Other Rule Deficiencies, April 1, 

1991, revised August 21, 2001). 

Staff also proposes to revise the current rule language such that electrostatic spray guns 

are subject to the proposed VOC requirement for cleanup of metal parts/products 

coating application equipment. This proposal is consistent with the June 30, 2005 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 16 

sunset of an exemption for electrostatic coating application equipment cleaning in 

SCAQMD Rule 1171. Also, the use of enclosed gun cleaners will no longer remain as a 

compliance option for the application equipment cleanup requirements under the 

proposed rule, consistent with SCAQMD Rule 1171. 

In the current rule, Section 304.4 allows spray gun nozzles to be soaked in solventbased materials in a tightly covered container not exceeding 5 gallons in size. Staff 

proposes to eliminate this section to be consistent with SCAQMD Rule 1171, which 

currently does not contain such a provision. 

Staff proposes to reduce the allowable VOC content of metal furniture coatings (which is 

defined in the proposed rule) to those specified in the 2007 CTG for Metal Furniture 

Coatings (see table following #2). Under the current rule, metal furniture coating 

operations are subject to the coating VOC limits specified in Section 301. The proposed 

rule establishes separate VOC limits for metal furniture coating operations at sources 

emitting at least 3 tons of VOC emissions per 12-month rolling period prior to controls. 

As stated in the new exemption for metal furniture coatings, sources that emit less than 

3 tons per 12-month rolling period prior to controls are not subject to the metal furniture 

coatings requirements, but are subject to the requirements for miscellaneous metal parts 

and products coatings in Section 301 In order to incorporate the CTG requirements, it is 

necessary to establish two new coating categories (which are subject to the “all other 

coatings” category under the current rule), for general multi-component coatings and all 

other coatings. 

The new requirement for emissions control equipment also addresses the 2007 CTG 

recommendations. Effective on the rule adoption date, the minimum overall control 

system efficiency of 85% will be increased to 90%. 

The proposed rule also includes the following amendments: 

1. Lower both of the solvent VOC limits in the surface preparation/cleanup/storage 

requirements from 72 g/l to 25 g/l. 

2. Lower the VOC limits for metal furniture coatings at large sources (3 tons of VOC or 

more per 12-month rolling period) as shown in the following table, and add an 

exemption from this section for sources with emissions of less than 3 tons per 12-

month rolling period. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 17 

VOC CONTENT: Grams/Liter (Lbs/Gal) 

less water and exempt compounds 

CURRENT LIMITS EFFECTIVE (ONE YEAR 

AFTER DATE OF ADOPTION) 

COATING 

CATEGORY 

AIR DRIED BAKED AIR DRIED BAKED

General, MultiComponent 340 (2.8) 275 (2.3) 340 (2.8) 275 (2.3) 

Extreme High 

Gloss 

420 (3.5) 360 (3.0) 340 (2.8) 360 (3.0) 

Extreme 

Performance 

420 (3.5) 420 (3.5) 420 (3.5) 360 (3.0) 

Heat Resistant 420 (3.5) 360 (3.0) 420 (3.5) 360 (3.0) 

Metallic/Iridescent 420 (3.5) 420 (3.5) 420 (3.5) 420 (3.5) 

Pretreatment 

Wash Primer 

420 (3.5) 420 (3.5) 420 (3.5) 420 (3.5) 

Solar Absorbent 420 (3.5) 360 (3.0) 420 (3.5) 360 (3.0) 

All Other 

Coatings 

340 (2.8) 275 (2.3) 275 (2.3) 275 (2.3) 

3. Add definitions for “electrostatic spray,” “metal furniture,” and “multi-component 

coating.” 

4. Increase the overall emissions control equipment efficiency from 85% to 90%. 

5. Add an exemption for metal furniture coatings. 

6. Add additional work practice requirements for disposal of cloth, paper, or sponges 

used for coating application; minimizing spillage of VOC-containing materials; and 

conveyance of VOC-containing materials using closed containers or pipes, to be 

consistent with the 2007 CTG for Metal Furniture Coatings and the 2008 Draft CTG 

for Miscellaneous Metal and Plastic Parts Coatings (dated July 3, 2008). 

7. Revise the duration of records requirement from three to five years to be consistent 

with other District rules, and 

8. Update the test methods to specify the most current test methods. 

Rule 452

Rule 452 limits VOC emissions from can coating operations, which include coatings 

applied or intended for application onto the surfaces of metal cans or metal sheets, 

strips, rolls, and coils intended for can construction. The option of using of an emission 

control system instead of meeting the specified VOC emissions limits is available in this 

rule. The following amendments are proposed: 

1. Add applicability and severability sections to the rule. 

2. Lower the solvent VOC limits for cleanup of container assembly equipment from 200 

g/l to 25 g/l. 

3. Lower the VOC limits for three piece can interior body spray and two piece can 

interior body spray to be consistent with the more stringent, feasible limits in 

BAAQMD Rule 8-11, SJVAPCD Rule 4604. 

4. Separate the end sealing compound category into “end sealing compound for 

food/beverage cans” and “end sealing compound for non-food containers,” and 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 18 

establish VOC limits that are lower than the current VOC limit for end sealing 

compound. The proposed VOC limits for the two subcategories are consistent with 

the more stringent, feasible limits in SCAQMD Rule 1125. 

5. Add a definition of “dip coat,” “electrostatic spray,” “flow coat,” “food/beverage can,” 

”“hand application equipment,” “high-volume low-pressure application equipment,” 

“low-volume low-pressure application equipment,” and “roll coater.” 

6. Add section for application equipment requirements, consistent with the 

requirements in the other current District coating rules, with an additional option to 

use emissions control equipment that achieves an overall system efficiency of at 

least 85.5%. This requirement is consistent with current permit conditions and 

ensures that the emissions control equipment achieves an emission reduction 

equivalent to the use of HVLP. 

7. Add equations for calculation of overall system efficiency, of VOC content of cleanup 

material, and of percent control efficiency and VOC mass emission rate. 

8. Increase the required emissions control equipment efficiency from 85.5% to 90%, 

except when emissions control equipment is used as an application method as given 

under the application equipment requirements in new Section 304. 

9. Revise the duration of records requirement from two to five years to be consistent 

with other District rules, and 

10. Update the test methods to specify the most current test methods. 

Rule 454

Vapor and non-vapor degreasing operations are regulated under Rule 454. The 

proposed rule implements more stringent VOC limits for both types of degreasers. 

However, sources are still allowed to use an airtight/airless cleaning system in lieu of 

complying with the limits on VOC content. 

Section 110.5 in the current rule exempts solvent degreasing operations using exempt 

compounds mixed with VOCs not exceeding 5% in weight. Staff proposes to eliminate 

this exemption because it duplicates the exemption in Section 110.3, which is being 

proposed to sunset one year after the adoption date of these amendments. Under the 

proposed amendments, all degreasers using solvents containing 25 g/l or less of VOCs 

will be exempt from the rule. 

Staff is proposing to add an exemption for degreasing high-voltage microwave vacuum 

tubes, at the request of a facility within the District that manufactures these devices. 

Staff has reviewed detailed technical information submitted by this facility and concurs 

that the use of low-VOC solvents is technically infeasible for this application. The facility 

conducted testing of various low-VOC solvents and blends over the past three years and 

has been unable to find a suitable alternative to using 100% isopropyl alcohol for the 

cleaning of components during the manufacture and repair of high-voltage microwave 

vacuum tubes. The high-vacuum, high-voltage operation of the devices requires an 

ultra-low level of contamination by organic residues and moisture. Alternative low-VOC 

solvents were demonstrated to result in unacceptably high failure rates of these devices, 

which are the principal components of electronic radar-jamming devices. Some of these 

devices are used in aerospace applications, which are exempt under Rule 456. Staff 

researched the location of competitors for this source and identified SCAQMD and 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 19 

BAAQMD. Staff reviewed the rules for these districts and contacted SCAQMD staff to 

discuss the compliance status of these facilities. It was determined that the cleaning of 

these devices with high VOC solvents is allowed under the existing rules for aerospace 

assembly operations. 

The additional proposed changes to Rule 454 are presented below. 

1. Lower the solvent VOC limits for non-vapor degreasing operations from 50 g/l to 25 

g/l. 

2. Add a new VOC limit of 25 g/l for vapor degreasing operations. 

3. Add a definition of “water separator.” 

4. Add an exemption for degreasing of high-voltage microwave vacuum tubes. 

5. Revise the duration of records requirement from three to five years to be consistent 

with other District rules, and 

6. Update the test methods to specify the most current test methods. 

Rule 456

The proposed changes to this rule, which limits solvent VOC emissions from aerospace 

assembly and coating operations, primarily involve the implementation of more stringent 

VOC limits. The use of an emission control system will remain as an alternative to 

compliance with the specified VOC standards. However, the proposed rule will remove 

the option of using an enclosed gun cleaner in lieu of complying with the specified VOC 

limit for the cleaning of spray guns. This proposed change is consistent with the 

SCAQMD solvent cleaning rules, which currently do not allow the use of enclosed gun 

cleaners as a compliance method. 

Currently, Section 110 of Rule 456 provides a low-usage exemption for materials such 

as coatings, adhesives, maskants, and strippers that exceed the VOC limits in the rule, 

provided that the usage of such materials is less than 200 gallons per calendar year. 

Staff is proposing to lower the exemption level to 55 gallons per calendar year. The 55 

gallon/year exemption level is consistent with the EPA Region IX “Little Bluebook” 

(Guidance Document for Correcting Common VOC & Other Rule Deficiencies, April 1, 

1991, revised August 21, 2001). Section 401 requires facilities utilizing the low-usage 

exemption to submit annual reports showing the usage of these materials. Staff 

reviewed the recent annual reports and found that no facility used such materials in an 

amount greater than 55 gallons per calendar year. 

Staff also proposes to revise the current rule language such that electrostatic spray guns 

are subject to the proposed VOC requirement for the cleaning of spray guns. This 

inclusion of electrostatic spray guns follows from the June 30, 2005 sunset of an 

exemption for electrostatic coating application equipment cleaning in SCAQMD Rule 

1171. 

In the current rule, Section 304.4 allows spray gun nozzles to be soaked in solventbased materials in a tightly covered container not exceeding 5 gallons in size. Staff 

proposes to eliminate this section to be consistent with SCAQMD Rule 1171, which 

currently does not contain such a provision. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 20 

The following changes are also proposed: 

1. Lower the solvent VOC limits for the cleaning of spray guns used in coating 

operations from 200 g/l to 25 g/l. 

2. Add a sunset date for the option of using an enclosed gun cleaner in lieu of 

complying with the 25 g/l VOC limit for the cleaning of spray guns used in coating 

operations. 

3. Revise the low usage exemption to lower usage limit from 200 gallons to 55 gallons 

to be consistent with other District rules and with EPA Region IX “Little Bluebook.” 

4. Add a definition of “electrostatic spray.” 

5. Revise the duration of records requirement from three to five years to be consistent 

with other District rules, and 

6. Update the test methods to specify the most current test methods. 

Rule 463

Rule 463 regulates VOC emissions from coatings, strippers, and surface preparation 

and cleanup materials used in wood products coating operations. The proposed rule 

lowers the VOC limit for surface preparation and cleanup. The current VOC limit for 

strippers is equivalent to the limit specified by SCAQMD, and therefore remains the 

same. 

In the current rule, Section 308.1 allows spray gun nozzles to be soaked in solventbased materials in a tightly covered container not exceeding 5 gallons in size. Staff 

proposes to eliminate this section to be consistent with SCAQMD Rule 1171, which 

currently does not contain such a provision. 

Staff is proposing to limit the applicability of the emissions averaging provisions in 

Section 306 to a maximum of 20 gallons per year of noncompliant, refinishing coatings 

applied to historical reproductions of antique wood products. Only one facility in the 

District currently uses Section 306, Emissions Averaging Provisions, to comply with Rule 

463. This change is being proposed to address requirements in the EPA Region IX 

“Little Bluebook” (Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, April 1, 1991, revised August 21, 2001) and RACT requirements for major 

sources. 

The proposed changes to this rule are indicated below. 

1. Add a severability section to this rule. 

2. Remove the exemption pertaining to stencil coatings used in compliance with U.S. 

Military Specifications. (Staff determined that the facility that used this exemption is 

no longer in operation.) 

3. Lower the solvent VOC limit for surface preparation or cleanup from 200 g/l to 25 g/l. 

4. Revise the equation for determining compliance with emissions limits for coatings. 

5. Limit the applicability of Section 306, as described previously. 

6. Add definition of “historical reproduction coating.” 

7. Revise the duration of records requirement from three to five years to be consistent 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 21 

with other District rules, and 

8. Update the test methods to specify the most current test methods. 

Rule 464

Rule 464 limits VOC emissions from organic chemical plants. These are the proposed 

changes to Rule 464: 

1. Lower the solvent VOC limit for maintenance solvent cleaning from 50 g/l to 25 g/l, 

and 

2. Update the test methods to specify the most current test methods. 

Rule 465

Rule 465 regulates emissions of VOCs from polyester resin operations, which include 

bathtub, shower, and sink manufacturers and spa and boat manufacturers. The 

proposed changes to Rule 465 are listed below. 

1. Lower the solvent VOC limit for cleaning materials from 204 g/l to 25 g/l, 

2. Increase the overall emissions control efficiency requirements from 85% to 90% to 

be consistent with the more stringent, feasible requirements in SCAQMD Rule 1162. 

3. Revise the duration of records requirement from three to five years to be consistent 

with other District rules, and 

4. Update the test methods to specify the most current test methods. 

Rule 466

Rule 466 regulates emissions from solvent cleaning activities, which include repair and 

maintenance cleaning, architectural coating application equipment cleaning, cleaning 

during manufacturing, and surface preparation. The proposed amendments require 

general cleaning to be performed with materials that contain less than 25 grams per liter 

VOCs as applied. The proposed changes also involve lowering other VOC content 

limits, with various limits specified for each type of cleaning activity. For some cleaning 

activities, such as medical devices/pharmaceuticals and platelets, the VOC limits will 

remain unchanged. The proposed rule still allows the use of air pollution control 

equipment as an alternative to complying with the VOC limits proposed by the rule, 

although emission control systems must ensure that emissions are no greater than 

would have resulted from compliance with the applicable VOC limits. The rule also 

specifies cleaning method requirements, general equipment requirements, operating 

requirements, storage and disposal requirements, and recordkeeping requirements. 

Staff is proposing to add an exemption for the cleaning of high-voltage microwave 

vacuum tubes, at the request of a facility within the District that manufactures these 

devices. Staff has reviewed detailed technical information submitted by this facility and 

concurs that the use of low-VOC solvents is technically infeasible for this application. 

The facility conducted testing of various low-VOC solvents and blends over the past 

three years and has been unable to find a suitable alternative to using 100% isopropyl 

alcohol for the cleaning of components during the manufacture and repair of high-
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 22 

voltage microwave vacuum tubes. The high-vacuum, high-voltage operation of the 

devices requires an ultra-low level of contamination by organic residues and moisture. 

Alternative low-VOC solvents were demonstrated to result in unacceptably high failure 

rates of these devices, which are the principal components of electronic radar-jamming 

devices. Some of these devices are used in aerospace applications, which are exempt 

under Rule 456. Staff researched the location of competitors for this source and 

identified SCAQMD and BAAQMD. Staff reviewed the rules for these districts and 

contacted SCAQMD staff to discuss the compliance status of these facilities. It was 

determined that the cleaning of these devices with high VOC solvents is allowed under 

the existing rules for aerospace assembly operations. 

The current exemption in Section 110.2(g) for electrostatic coating application equipment 

cleaning is being proposed for removal, consistent with the June 30, 2005 sunset of an 

exemption for this cleaning category in SCAQMD Rule 1171. 

Staff also proposes to add a specific exemption from the solvent cleaning requirements 

for the stripping of cured inks, cured coatings, and cured adhesives. Since the current 

definition of solvent cleaning already implies that the stripping of such cured materials is 

exempt, this new exemption is for clarification purposes only. 

In the current rule, Section 302.8 allows spray gun nozzles to be soaked in solventbased materials in a tightly covered container not exceeding 5 gallons in size. Staff 

proposes to eliminate this section to be consistent with SCAQMD Rule 1171, which 

currently does not contain such a provision. 

The additional proposed changes are specified below. 

1. Lower the solvent VOC limits for several cleaning categories, as shown in the 

following table. 

VOC Content 

g/l (lb/gal) 

Solvent Cleaning Activity 

Prior to (one 

year after 

date of 

adoption) 

Effective (one 

year after 

date of 

adoption) 

General (wipe cleaning, maintenance cleaning) 50 (0.42) 25 (0.21) 

Product Cleaning During Manufacturing Process or Surface Preparation for 

Coating, Adhesive, Sealants, or Ink Application 

 General 

 Electrical Apparatus Components and Electronic Components 

 Medical Devices and Pharmaceuticals 

 Platelets 

50 (0.42) 

500 (4.2) 

800 (6.7) 

800 (6.7) 

25 (0.21) 

100 (0.83) 

800 (6.7) 

800 (6.7) 

Repair and Maintenance Cleaning 

 General 

 Electrical Apparatus Components and Electronic Components 

 Medical Devices and Pharmaceuticals 

 General Work Surfaces 

 Tools, Equipment, and Machinery 

 Platelets 

50 (0.42) 

900 (7.5) 

600 (5.0) 

800 (6.7) 

800 (6.7) 

25 (0.21) 

100 (0.83) 

600 (5.0) 

800 (6.7) 

800 (6.7) 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 23 

VOC Content 

g/l (lb/gal) 

Solvent Cleaning Activity 

Prior to (one 

year after 

date of 

adoption) 

Effective (one 

year after 

date of 

adoption) 

Architectural Coating Application Equipment 

Water based Coatings 

Enclosed Gun Cleaner 

No Enclosed Gun Cleaner 

Solvent based Coatings 

Enclosed Gun Cleaner 

No Enclosed Gun Cleaner, cleaning at jobsite 

No Enclosed Gun Cleaner, cleaning not at jobsite 

No limit 

50 (0.42) 

No limit 

300 (2.5) 

50 (0.42) 

25 (0.21) 

25 (0.21) 

25 (0.21) 

25 (0.21) 

25 (0.21) 

Sterilization of food manufacturing and processing equipment No limit 200 (1.68) 

2. Revise the duration of records requirement from three to five years to be consistent 

with other District rules, 

3. Add a new VOC limit of 200 g/l for the sterilization of food product manufacturing and 

processing equipment (shown in the table above). 

4. Add definitions of “general work surface,” “jobsite,” “pharmaceutical product,” 

“solvent based coating,” “water based coating,” “sterilization,” “food manufacturing 

and processing operation,” “stripping,” and “cured coating, cured ink, or cured 

adhesive,” using the same definitions as those in the SCAQMD rules, and 

5. Update the test methods to specify the most current test methods. 

6. Remove the exemption for the cleaning of electrostatic application equipment. 

7. Add an exemption for the cleaning of high-voltage microwave vacuum tubes. 

EMISSIONS IMPACT 

In most cases, emissions reductions for individual cleaning categories were calculated 

by multiplying the percentage reduction for that category by its corresponding emissions 

inventory. Percentage reductions were computed by comparing the current VOC limit to 

the proposed limit. (For example, the lowering of a VOC limit from 100 g/l to 25 g/l 

represents a 75% reduction.) Because more specific information is not available, these 

emissions calculations assume that all sources performing the specific cleaning activity 

use products matching the current VOC limit, and will replace them with products 

matching the proposed VOC limit. 

A different approach was used to calculate emission reductions for categories for which 

all affected sources could be identified. In these cases, more precise emissions 

reductions were computed by comparing the actual VOC content of the current products 

to the proposed VOC limits. The amounts of solvent products currently used by affected 

facilities were obtained though telephone inquiries and annual emission inventory 

surveys of these facilities. Usage amounts are not expected to change when switching 

from the current product to a compliant, low VOC product. Staff also assumed that 

current annual solvent usage amounts are representative of usage levels in 2010 (the 

year for which the emission reductions were estimated). 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 24 

Staff expects that compliance with the lower VOC limits will be achieved, in many cases, 

by using acetone (an exempt compound), or by using mixtures of acetone and other 

exempt compounds. The assumption that the VOC content of replacement materials will 

match the VOC limits leads to conservative estimates of the emission reductions. 

The total emission of VOC from all solvent cleaning operations, in the absence of the 

proposed amendments, is projected to be 498 tons per year in 2010. The allocation of 

this inventory to specific activities covered by individual rules in presented in Appendix 

C. 

 

Rule 450

As shown in Appendix C, the estimated 2010 emissions inventory for solvent cleaning 

activities associated with Rule 450 is 80.82 tons per year of VOC. The proposed 

amendments to the rule are expected to result in an overall VOC emission reduction of 

55.16 tons per year. The VOC emission reductions were estimated based on the 

following information: 

1. Estimated 2010 emissions inventory for Rule 450 in Appendix C, and 

2. The 2004 SCAQMD emissions inventory (from the 4/19/05 staff report for SCAQMD 

Rule 1171) to estimate the % of each graphic arts related cleaning activity, as shown 

in the following table. (The 2004 SCAQMD emissions inventory represents the last 

inventory prior to implementation of reduced VOC limits in 2005 and 2006 for Rule 

1171.) Graphic arts-related cleaning processes within Sacramento County are 

expected to be similar to the SCAQMD. These percentages were applied to the 

2010 emissions inventory to approximate the annual emissions for each cleaning 

activity. Except for newsprint and UV/electron beam inks, emissions reductions 

were calculated by using the current-to-proposed VOC limit comparison described in 

the beginning of the Emissions Impact section. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 25 

Cleaning Activity 

% of Rule 

450 

inventory 

2010 

Emissions 

Inventory 

(Tons/year)

Current 

VOC 

limit (g/l)

Proposed 

VOC limit 

(g/l) 

% VOC 

Emissions 

Reduction 

2010 VOC 

Emissions 

Reduction 

(Tons/year)

Repair & 

Maintenance 

Cleaning 

 

 (i) General* 0.00% 0.00 72 25 65.28% 0

Ink Application 

Equipment Cleaning 

 

 (i) General 0.96% 0.78 100 25 75.00% 0.58

 (ii) 

Flexographic or 

Gravure 5.02% 4.05 100 25 75.00% 3.04

 (iii) 

Litho/Letterpress 

 

 (1) Roller 

Wash-Blanket Wash 

& Metering Rollers & 

Printing Plates 

 

 (a) 

Newsprint 2.70%** 2.18** 300 100 83.49%** 1.82**

 (b) Other 

Substrates 67.33% 54.41 300 100 66.67% 36.28

 (2) Removable 

Press Components 0.58% 0.47 100 25 75.00% 0.35

 (iv) Screen 

Printing 20.45% 16.53 300 100 66.67% 11.02

 (vi) UV/Electron 

Beam Ink 0.85%** 0.69** 800 100 82.60%** 0.57**

 (vii) Specialty 

Flexographic 2.12% 1.72 810 100 87.65% 1.50

TOTAL 100.00% 80.82 68.25% 55.16

* Based on annual District survey data of permitted sources, general repair and maintenance 

cleaning solvent emissions are minimal. 

** For these categories, all sources were readily identified using the District permit database and 

other permit records. Annual emission inventory surveys, telephone surveys, and annual permit 

inspection reports provided the annual solvent usage amounts and VOC contents of current 

products necessary to compute more precise VOC emission inventories and reductions for each 

facility identified. Note that the VOC content of current products may exceed current limits if 

products comply with the low vapor pressure option. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 26 

No emissions reductions will result from the amendments proposed to address the 2006 

CTGs for graphic arts. According to District permitting records, all sources are already in 

compliance with the proposed VOC limits for fountain solutions. Of the 22 sources that 

conduct sheet-fed offset lithographic printing operations, six will be exempt (their 

emissions are below 15 lbs/day) and the rest currently use fountain solutions achieving 

the proposed VOC limits. Of the six sources that conduct coldset web offset lithographic 

printing operations, three will be exempt (their emissions are below 15 lbs/day) and the 

other three currently use fountain solutions containing less than 5% alcohol substitute. 

All four facilities conducting heatset web offset lithographic printing operations are using 

fountain solutions compliant with the proposed VOC limits. The graphic arts facilities 

that use presses exceeding the 25 tons/year potential to emit level already use 

emissions control equipment that achieve the proposed overall system efficiency levels. 

Each amendment will result in the following VOC emission reductions, calculated for 

2010: 

Requirement VOCs Reduced 

Tons/year 

General Repair and Maintenance 

Cleaning 

0 

Application Equipment Cleaning 

1. General (not specifically listed) 0.58 

2. Lithographic & Letter Press 

Printing, Blanket & Roller Washes 

Metering Rollers and Printing Plates, 

Newsprint 

1.82 

3. Lithographic & Letter Press 

Printing, Blanket & Roller Washes 

Metering Rollers and Printing Plates 

(Except Newsprint) 

36.28 

4. Lithographic & Letter Press 

Printing, Removable Press 

Components 

0.35 

5. Screen Printing 11.02 

6. Flexographic Printing 3.04 

7. Specialty Flexographic Printing 1.50 

8. Ultraviolet Inks (Except Screen 

Printing) 

0.57 

2006 CTG requirements for fountain 

solutions and control equipment 

0 

Total 55.16 

Rule 451

Staff identified 61 permitted metal parts/products coating operations in the District permit 

database. The estimated VOC emissions inventory for solvent cleaning activities 

associated with Rule 451 in 2010 is 11.09 tons per year, 7.15 tons per year of which are 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 27 

attributed to application equipment cleaning and 3.94 tons per year to surface 

preparation/cleanup (see Appendix C). The anticipated emission reduction for 2010 for 

surface preparation, product cleaning, and application equipment cleanup is a combined 

163 pounds per year. This reduction is relatively small because only five facilities 

currently use noncompliant material, according to annual facility inspection reports. 

Annual emissions inventory survey data showed that four of these facilities have small 

annual usage totals for these products, while one facility reported high usage of a 

product only slightly exceeding 25 g/l. The other facilities already meet the proposed 

standards, either by using the low usage exemption, exempt compounds (such as 

acetone), or soap and water. 

No emissions reductions will result from the amendments proposed to address the 2007 

CTG for metal furniture coatings. According to District permitting records, only one 

source currently conducts metal furniture coating operations. However, this facility only 

conducts powder coating operations, and its total annual emissions from such coating 

operations fall well below the applicability threshold of 3 tons of VOC per 12-month 

rolling period. Based on permitting records, Staff also determined that none of the 

existing facilities subject to Rule 451 use emissions control equipment. 

Rule 452

The estimated 2010 VOC emissions inventory for solvent cleaning associated with Rule 

452 is 13.31 tons per year for application equipment cleaning, as shown in Appendix C. 

There is currently only one can coating operation, Silgan Can Company. No emissions 

reductions will result from the proposed rule because Silgan does not use VOC 

containing solvents for cleaning, already meets the proposed lower VOC limits for can 

coating, and uses emissions control equipment to comply with the application equipment 

requirements in Section 304, which specifies the same overall control efficiency (85.5%) 

required under the current rule. Information contained in the annual emission inventory 

survey indicates that only exempt compounds are used for cleaning. 

Rule 454

As shown in Appendix C, the estimated 2010 VOC emissions inventory for solvent 

cleaning associated with Rule 454 is 101.97 tons per year. The proposed amendments 

to the rule are expected to result in an overall VOC emission reduction of 50.99 tons per 

year, calculated for 2010. 

Each amendment will result in the following VOC emission reductions: 

Requirement VOCs Reduced 

Tons/year 

Non-vapor degreasing 50.29 

Vapor degreasing 0.7 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 28 

Rule 456

The estimated 2010 VOC emissions inventory for solvent cleaning activities associated 

with Rule 456 is 14.32 tons per year, 9.03 tons per year of which are attributed to 

application equipment cleaning and 5.29 tons per year to surface preparation/cleanup. 

There are currently two facilities that conduct aerospace application equipment cleanup 

using noncompliant material. These facilities use high VOC materials in enclosed gun 

cleaners, which can no longer be used for compliance with the proposed VOC limits. 

Assuming that enclosed gun cleaners result in VOC emissions equivalent to the current 

VOC limit (200 g/l) for application equipment cleanup, the proposed requirements are 

expected to result in an overall emission reduction of 17 pounds per year. This 

reduction is based on the usage rates for the only two facilities that use noncompliant 

material. 

Rule 463

Despite no current requirement to use low VOC products for surface 

preparation/cleanup, all permitted sources already voluntarily perform surface 

preparation or cleanup activities using acetone or water. Because of the widespread, 

voluntary use of acetone for this cleaning activity, Staff has no reason to expect that 

unpermitted sources use VOC containing solvents. However, the current inventory for 

this category still assumes that wood coating sources use VOC-containing solvents. As 

given in Appendix C, the estimated 2010 VOC emissions inventory for solvent cleaning 

associated with this rule is 24.75 tons per year, consisting of 22.33 tons per year from 

application equipment cleaning and 2.42 tons per year from surface preparation/cleanup. 

Emission reductions were estimated by applying an 87% reduction (the VOC limits are 

lowered from 200 g/l to 25 g/l) to both the surface preparation and cleanup inventories. 

The adoption of the new requirements will result in an inventory reduction of 21.4 tons 

per year of VOC for this rule. 

Rule 464

None of the three facilities currently regulated by Rule 464 currently use solvent-based 

materials for maintenance cleaning in organic chemical manufacturing operations. 

Water-based detergent solutions are used for this purpose. No emissions reductions will 

result from the proposed rule. 

Rule 465: 

The five permitted sources in Sacramento County that conduct polyester resin 

operations use acetone in their cleaning activities. However, the inventory for this 

category still assumes that polyester resin operations use VOC-containing solvents. As 

computed in Appendix C, the estimated 2010 VOC emissions inventory for solvent 

cleaning activities associated with this rule is 1.97 tons per year, consisting of 1.44 tons 

per year from application equipment cleaning and 0.52 tons per year from surface 

preparation/cleanup. Emission reductions were estimated by applying an 87% reduction 

(the VOC limits are lowered from 204 g/l to 25 g/l) to both the surface preparation and 

cleanup inventories. The adoption of the new requirements will result in an inventory 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 29 

reduction of 1.72 tons per year of VOC for this category. 

Rule 466

The estimated 2010 VOC emissions inventory for solvent cleaning activities associated 

with Rule 466 is 141.91 tons per year, as shown in Appendix C. The proposed 

amendments to the rule are expected to result in an overall VOC emission reduction of 

66.24 tons per year (see below). The VOC emissions inventory and reductions were 

estimated based on the following information: 

1. Architectural coating equipment cleaning category: The 2010 CARB Ozone SIP 

Planning Inventory, Version 1.06, Sacramento NAA (Rf#980), November 16, 2006, 

was used (www.arb.ca.gov/app/emsinv/o3sip/fcemssumcat_o3v106.php). The 

inventory for this category is 82.82 tons per year. This inventory consists of both 

cleaning for water-based coatings and cleaning for solvent-based coatings A 

composite emissions reduction percentage of 57.1% was calculated based upon the 

assumption that 83% of architectural solvent usage is attributed to the water-based 

coatings subcategory (refer to the CARB report entitled “New Method for Estimating 

Emissions from Thinning and Cleanup Solvents,” March 9, 2006), and the remaining 

17% of the usage is attributed to solvent-based coating cleaning. The emissions 

reduction is an estimated 47.34 tons per year. 

2. All other solvent cleaning categories in Rule 466: The 2004 SCAQMD emissions 

inventory (see previous discussion for Rule 450) was used to establish the 

percentage breakdown for each solvent cleaning activity related to Rule 466. These 

cleaning processes within Sacramento County are expected to be similar to the 

SCAQMD. The percentage breakdown is shown in the table below. These 

percentages were applied to the remaining 2010 emissions inventory (see Appendix 

C) of 141.91-82.82 = 59.09 tons per year to approximate the annual emissions for 

each cleaning category. The current-to-proposed VOC limit comparison was then 

used to estimate the emissions reductions shown in the following table. The total 

emissions reduction for these solvent cleaning categories is 17.16 tons per year. 

Cleaning Activity 

% of Rule 466 

inventory 

(excluding 

architectural 

coating 

equipment 

cleaning) 

2010 

Emissions 

Inventory 

(Tons/year)

Current 

VOC 

limit 

(g/l) 

Proposed 

VOC limit 

(g/l) 

% VOC 

Emissions 

Reduction 

2010 VOC 

Emissions 

Reduction 

(Tons/year) 

 (A) Product Cleaning & 

Surface Preparation 

 

 (i) General 10.77% 6.36 50 25 50.00% 3.18

 (ii) 

Electrical/Electronic 

Apparatus & Components 

20.05% 11.85 500 100 80.00% 9.48
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 30 

Cleaning Activity 

% of Rule 466 

inventory 

(excluding 

architectural 

coating 

equipment 

cleaning) 

2010 

Emissions 

Inventory 

(Tons/year)

Current 

VOC 

limit 

(g/l) 

Proposed 

VOC limit 

(g/l) 

% VOC 

Emissions 

Reduction 

2010 VOC 

Emissions 

Reduction 

(Tons/year) 

 (iii) Medical Devices 

&Pharmaceuticals 

29.09% 17.19 800 800 0.00% 0.00

 (B) Repair & 

Maintenance 

 

 (i) General 8.25% 4.88 50 25 50.00% 2.44

 (ii) 

Electrical/Electronic 

Apparatus & Components 

3.93% 2.32 900 100 88.89% 2.06

 (iii) Medical Devices & 

Pharmaceuticals 

 

 (A) Tools, 

Machinery & Equipment 15.72% 9.29 800 800 0.00% 0.00

 (B) General Work 

Surfaces 

12.19% 7.20 600 600 0.00% 0.00

TOTAL 100.00% 59.09 29.04% 17.16

3. Methods #1 and #2 above were not used to calculate the emission reductions for 

food equipment sterilization. These emission reductions are based on annual 

emission inventory surveys, telephone surveys, and permit records. These 

reductions were calculated using the same methods as described above for readily 

identifiable sources. The estimated emission reduction is 1.74 tons per year. 

The table below summarizes the VOC emission reductions: 

 

Requirement VOCs Reduced 

Tons/year 

Product Cleaning During Manufacturing 

Process or Surface Preparation for Coating, 

Adhesive, Sealants, or Ink Application 

1. General 3.18 

2. Electrical Apparatus Components and 

Electronic Components 

9.48 

3. Medical Devices and Pharmaceuticals 0 (no change in VOC limit) 

4. Platelets 0 (no change in VOC limit) 

Repair and Maintenance Cleaning 

1. General 2.44 

2. Electrical Apparatus Components and 

Electronic Components 

2.06 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 31 

Requirement VOCs Reduced 

Tons/year 

3. Medical Devices and PharmaceuticalsGeneral Work Surfaces 0 (no change in VOC limit) 

4. Medical Devices and PharmaceuticalsTools, Equipment, and Machinery 0 (no change in VOC limit) 

5. Platelets 0 (no change in VOC limit) 

Architectural Coating Application Equipment 

1. Water-based Coatings 

2. Solvent-based Coatings 

47.34 

(combined) 

Sterilization of food product manufacturing 

and processing equipment 

1.74 

Total 66.24 

Total Emission Reduction for All Rules:

The total reduction in VOC emissions from the amendment of all nine rules is 195.64 

tons per year, calculated for 2010. The table below summarizes the emission reductions 

for each rule. 

Rule VOCs Reduced 

Tons/year 

450 55.16 

451 0.081 

452 0 

454 50.99 

456 0.008 

463 21.44 

464 0 

465 1.72 

466 66.24 

Total 195.64 

COST IMPACT

Section 40703 of the California Health and Safety Code requires that districts consider 

and make public findings relating to the cost effectiveness of implementing an emission 

control measure. 

Cost to Businesses:

The majority of the proposed solvent cleaning limits are not expected to result in 

additional costs to the industry because compliant products, which have been readily 

available for some time, do not cost more than the materials currently used, with 

exceptions noted in the following sections. SCAQMD has released several technology 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 32 

assessments in 2003 and 2006 demonstrating that, for many cleaning applications, 

current cleaning products can be diluted with water or blended with other compliant 

products to form a compliant cleaning material that is also equally effective. These 

technology assessments are available at http://www.aqmd.gov/rules/support.html#r1171. 

A technology assessment1

 performed by SCAQMD concluded that compliant products 

for the cleaning of application equipment are readily available in the market and do not 

result in additional costs to industry. SCAQMD has published a list of “Clean Air 

Solvents,” defined as solvents with VOC concentrations not greater than 25 g/l, that 

comply with both SCAQMD Rules 1122- Solvent Degreasers and 1171- Solvent 

Cleaning Operations. Businesses looking for information on compliant products will find 

further information at the SCAQMD Clean Air Solvent Certification Program at 

http://www.aqmd.gov/rules/cas/index.html. 

The cost information presented below is primarily based on SCAQMD cost estimates, 

which are applicable because industry processes in SCAQMD are similar to those in 

SMAQMD. Staff expects that sources in SMAQMD can readily replace their current 

products with the compliant products because they are currently available in SCAQMD. 

The following sections provide additional cost information for each proposed rule. 

Rule 450

General Wipe Cleaning: There will be no additional costs for this category. Low VOC 

cleaners are detergent-based and cost more per gallon than solvent-based cleaners, but 

can be diluted with water, resulting in a lower total cost. 

Application Equipment Cleaning - Roller and Blanket Washes, Metering Rollers and 

Printing Plates, and Other On-Press Components: Based on the March 2006 SCAQMD 

technology assessment for lithographic printing, the cost of compliant material is 

approximately $16 per gallon, while the approximate average cost of the current 

cleaning products is $6.60 per gallon. 

Application Equipment Cleaning – Removable Press Components: According to the 

9/27/99 staff report for SCAQMD Rule 1171, the proposed requirements will result in 

increased costs if handwiping is performed, but no additional costs if remote reservoir 

cleaners are used (see the 8/15/96 staff report for SCAQMD Rule 1171 for cost 

effectiveness analysis for remote reservoir cleaners). SCAQMD estimates that 75% of 

the emissions from this category are from handwipe operations and the remaining 25% 

are from using remote reservoir cleaners. SCAQMD states that current handwiping 

materials can be blended with acetone, a mixture of acetone, MeAc, and PCBTF, or a 

mixture of MeAc and PCBTF to achieve the proposed 25 g/l limit, for an average cost of 

$19 per gallon. The approximate average cost of the current cleaning products is $9 per 

gallon. 

 

 

1

 “Assessment, Development and Demonstration of Low-VOC Cleaning Systems for South Coast Air Quality 

Management District Rule 1171,” SCAQMD, August 2003. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 33 

Application Equipment Cleaning – Screen Printing: Based on the May 2006 SCAQMD 

technology assessment for screen printing, the cost of a typical compliant material is 

approximately $10.90 per gallon, while the typical cost of the current cleaning products is 

approximately $13 per gallon. Most screen printing operations are expected to reduce 

costs by switching to the lower VOC cleaning materials. 

Application Equipment Cleanup – Flexographic Printing: The proposed requirements 

applicable to flexographic printing are not expected to result in an increase in cost to 

affected businesses, according to SCAQMD’s industry sources (1999 staff report for 

SCAQMD Rule 1171). 

Application Equipment Cleanup – Specialty Flexographic Printing: The proposed 

requirements applicable to specialty flexographic printing are expected to result in cost 

savings for affected businesses, according to the 9/27/99 staff report for SCAQMD Rule 

1171. SCAQMD states that the 100 g/l limit can be met by blending VOC materials 

currently used (IPA) with water. The estimated cost of this mixture is $1 per gallon, 

whereas the cost of IPA is approximately $6 per gallon. 

Application Equipment Cleanup – Ultraviolet/Electron Beam Inks: The 650 g/l VOC limit 

was implemented by SCAQMD in July 2006. According to the June 2006 SCAQMD 

Rule 1171 staff report, SCAQMD expects no additional compliance costs associated 

with this new VOC limit. SCAQMD also states that compliant products are readily 

available and their costs are comparable to that of existing high-VOC solvents. 

The eventual VOC limit of 100 g/l (effective 1/1/2010) is expected to result in cost 

savings for the one permitted source that performs application equipment cleanup of 

UV/electron beam inks. This facility uses a UV wash costing $6 per gallon, according to 

a recent telephone survey. The 9/27/99 staff report for SCAQMD Rule 1171 estimates 

that a compliant product (a blend of IPA, the current VOC material, with water) costs $1 

per gallon. 

Fountain Solutions and Control Equipment: As described earlier, no graphic arts 

facilities will be affected by the proposed changes for fountain solutions and control 

equipment because they either will be exempt or already use solvents or control 

equipment achieving the proposed, CTG-recommended requirements. Therefore, no 

additional compliance costs will be incurred. 

Rule 451

Application Equipment Cleanup: The proposed requirements are expected to result in 

cost savings for affected businesses. According to the November 2003 staff report for 

SCAQMD Rule 1171, the average cost of compliant material (consisting of such 

products as acetone, a mixture of acetone and PCBTF, and a mixture of acetone and 

sulfonic acid) is $11 per gallon. The average cost of currently used material is $14.16 

per gallon. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 34 

Product Cleaning or Surface Preparation: SCAQMD stated in the 1999 staff report for 

Rule 1171 that reducing the VOC limit from 70 g/l to 25 g/l would not result in increased 

cost due to minimal material substitution necessary to lower the VOC content. For the 

same reason, Staff believes that lowering this VOC limit from 72 g/l to 25 g/l will not 

increase costs. 

SCAQMD has found that cleaning products meeting the 25 g/l VOC limit are comparable 

to those complying with the 50 g/l limit (as well as those complying with the previous limit 

of 70 g/l) in terms of average price. Staff therefore believes that lowering the limit from 

72 g/l will not lead to additional compliance costs. 

Metal Furniture Coatings and Control Equipment: District permitting records indicate 

that only one facility in Sacramento County conducts metal furniture coating operations. 

However, this facility only conducts powder coating operations, and its total annual 

emissions from such coating operations fall well below the applicability threshold of 3 

tons of VOC per 12-month rolling period. Based on permitting records, staff also 

determined that none of the existing facilities subject to Rule 451 use emissions control 

equipment. Therefore, the proposed CTG-recommended amendments will not lead to 

additional compliance costs. 

Rule 452

The only source affected by this proposed rule is already in compliance with the 

proposed rule. As a result, no additional compliance costs are incurred. 

Rule 454

In the previous amendment of Rule 454, Staff found that almost all of the regulated 

facilities were using solvent type parts cleaners, which are usually leased. With the 

eventual adoption of the amendment, the affected sources were essentially required to 

replace these degreasers with new units that are designed to be used with aqueous 

cleaners since almost all of the low VOC cleaners are aqueous. Those same sources, 

which have since installed aqueous cleaning equipment, do not need to replace their 

cleaning systems again because the new rule requires them only to switch to another 

aqueous material with lower VOC content. There will be no additional compliance costs 

associated with Rule 454 because no cleaning system replacement is necessary and the 

cost of compliant materials is comparable to the current aqueous products used. 

Rule 456

Compliance costs are expected to decrease for the two sources that currently perform 

spray gun cleaning using noncompliant materials. The average cost of the noncompliant 

material is $23.40 per gallon, while the average cost of compliant material, as given in 

the November 2003 staff report for SCAQMD Rule 1171, is $11 per gallon. Examples of 

compliant materials include acetone, an acetone/PCBTF blend, and an acetone/ sulfonic 

acid blend. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 35 

Rule 463

The proposed amendments are not expected to result in a change in cost for affected 

businesses because they are already using exempt compounds. Acetone, an exempt 

compound, is currently used in surface preparation operations. 

Rule 464

Facilities currently regulated by Rule 464 use water-based detergent solutions for 

maintenance cleaning in organic chemical manufacturing operations. Because these 

materials already comply with the proposed limits, there will be no additional costs.

Rule 465

There will be no additional compliance costs associated with the proposed amendments. 

Acetone is the cleaning product used in polyester resin operations. 

Rule 466

General Product Cleaning/ Surface Preparation, General Repair/Maintenance Cleaning, 

Cleaning of Architectural Coating Application for Solvent-based coatings (for cleaning 

not performed at jobsite) and Water-based coatings, and Spray gun cleaning: There is 

no expected cost increase for these categories because sources are already using 

aqueous cleaners or acetone to meet the current 50 g/l VOC limit. The proposed rule 

will require some sources to switch from one aqueous cleaning solvent to another 

comparably-priced material that meets the new VOC limit.

Product Cleaning/ Surface Preparation- Electrical Apparatus and Electronic 

Components: The proposed requirements applicable to cleaning of electrical 

components are expected to result in either cost savings or increases for affected 

businesses, depending on the compliant product a particular source chooses. The 

following table summarizes the approximate cost of current cleaning products and their 

potential replacements. The cost data is based on the 9/27/99 staff report for SCAQMD 

Rule 1171. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 36 

*Note: Exempt solvent blend is a mixture of acetone, methyl acetate, and 

parachlorobenzotrifluoride. Estimated cost of this mixture is $23 per gallon, according to 

the 9/27/99 staff report for SCAQMD Rule 1171. 

Repair/Maintenance Cleaning- Electrical Apparatus and Electronic Components: 

The proposed requirements applicable to repair/maintenance cleaning of electrical 

components are expected to result in either cost savings or increases for affected 

businesses, depending on the compliant product a particular source chooses. The table 

below summarizes the approximate cost of current cleaning products and their potential 

replacements. The cost data is based on the 9/27/99 staff report for SCAQMD Rule 

1171. 

Category Cost of Current Material 

(900 g/l) 

Cost of Compliant 

Material (100 g/l) 

Printed circuit boards $6 per gallon (IPA) $1 per gallon (mixture 

of deionized water and 

IPA) 

Other electrical and 

electronic components 

$6 per gallon (IPA) 

 

$3 per gallon (mixture 

of current material with 

acetone) 

Or 

$21 per gallon (mixture 

of current material with 

exempt solvent blend) 

*Exempt solvent blend is a mixture of acetone, methyl acetate, and 

parachlorobenzotrifluoride. Estimated cost of this mixture is $23 per gallon, according to 

the 9/27/99 staff report for SCAQMD Rule 1171. 

Category Cost of Current Material 

(500 g/l) 

Cost of Compliant 

Material (100 g/l) 

Printed circuit boards $3 per gallon (mixture of 

deionized water and IPA) 

$1 per gallon (mixture 

of deionized water and 

IPA) 

Other electrical and 

electronic components 

$5 per gallon (mixture of 

current material with 

acetone) 

Or 

$14 per gallon (mixture of 

current material with 

exempt solvent blend*) 

$3 per gallon (mixture 

of current material with 

acetone) 

Or 

$21 per gallon (mixture 

of current material with 

exempt solvent blend*) 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 37 

Architectural Coating Application Equipment- Solvent based Coatings (for cleaning 

performed at jobsite): 

 

Sources that perform this type of cleaning at the jobsite currently use a mixture of 

thinner, acetone and other exempt solvents to meet the 300 g/l limit. There will be an 

increase in compliance cost. The cost data shown in the table below was taken from the 

5/23/02 staff report for Rules 454 and 466 and the 9/27/99 staff report for SCAQMD Rule 

1171. 

 

Cost of Current Material (300 g/l) Cost of Compliant Material (25 g/l) 

$7 per gallon (mixture of thinner, 

acetone and other exempt solvents) 

$19 per gallon (mixture of current 

material with acetone and other 

exempt solvents) 

Sterilization of food product manufacturing and processing equipment: 

The proposed requirements applicable to food manufacturing/processing equipment 

sterilization are expected to result in cost savings for affected businesses. Staff 

identified one source that currently conducts this sterilization process. This facility will 

be able to meet the 200 g/l VOC limit by diluting their current VOC product (IPA) with 

water. This compliance method has been proven to be sufficient for accomplishing the 

FDA-required sterilization for sources subject to a similar VOC standard in SCAQMD. 

(Please refer to the 8/23/00 staff report for SCAQMD Rule 1131 for supporting 

documentation.) The cost data of the current non-compliant material is based on a price 

quote from an online vendor for a 500 gallon drum of sterilizing product. Diluting with 

water will lower the IPA usage at this facility to 35% of the current usage. 

Category Cost of Current Material 

(571 g/l) 

Cost of Compliant 

Material (200 g/l) 

Sterilization of food product 

manufacturing and 

processing equipment

$13.61 per gallon (IPA) $4.76 per gallon 

(mixture of water and 

IPA) 

Overall Rule Cost Effectiveness: 

The cost effectiveness estimates for the rule amendments are shown in the following 

table. The rule-by-rule cost data in the preceding “Cost Impact” section was used to 

calculate the overall compliance cost and the corresponding cost effectiveness for each 

rule. The sum of all compliance costs divided by the sum of all emission reductions 

(from the preceding “Emissions Impact” section) yields the overall cost effectiveness for 

the particular rule. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 38 

Rule Cost Effectiveness 

450 $3.70 per lb of VOC reduced 

451 Cost savings 

456 Cost savings 

466 $3.70 per lb of VOC reduced 

In year 2007 dollars, previously adopted District rules have cost effectiveness figures for 

VOC reductions ranging from $1.06 per pound of VOC reduced (for the 8/21/1990 

adoption of Rule 452) to as much as $18.05 per pound of VOC reduced (for the 

12/17/1991 adoption of Rule 449, Transfer of Gasoline into Vehicle Fuel Tanks). 

Cost to the District:

The proposed amendments are not expected to result in additional costs to the District. 

Sources affected by the rule amendments are already subject to requirements under the 

existing rules. 

SOCIOECONOMIC IMPACT 

CHSC Section 40728.5 requires a district to perform an assessment of the 

socioeconomic impacts before adopting, amending, or repealing a rule that will 

significantly affect air quality or emission limitations. The District Board is required to 

actively consider the socioeconomic impacts of the proposal and make a good faith 

effort to minimize adverse socioeconomic impacts. 

CHSC Section 40728.5 defines “socioeconomic impact” to mean the following: 

1. The type of industry or business, including small business, affected by the 

proposed rule or rule amendments. 

2. The impact of the proposed rule or rule amendments on employment and the 

economy of the region. 

3. The range of probable costs, including costs to industry or business, including 

small business. 

4. The availability and cost-effectiveness of alternatives to the proposed rule or rule 

amendments. 

5. The emission reduction potential of the rule or regulation. 

6. The necessity of adopting, amending, or repealing the rule or regulation to attain 

state and federal ambient air standards. 

Type of industry or business, including small business, affected by the rule 

amendments: 

Rule 450 applies to all graphic arts operations, including small businesses. According to 

the Sacramento County business directory, there are over 260 graphic arts operations in 

the District. All of these graphic arts operations are currently subject to the solvent 

cleaning limits in Rule 450 and will be affected by the proposed rule amendments. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 39 

There are 61 permitted metal parts and products coating operations that are currently 

subject to the requirements of Rule 451. Five of these operations will be affected by the 

new solvent cleaning limits in the proposed rule. All other operations already employ 

exempt compounds, water, or low-VOC material for surface preparation and/or 

equipment cleaning. As described earlier, none of the current sources subject to Rule 

451 will be affected by the proposed CTG-recommended changes. 

There is only one can coating process operating within the District. This source 

manufactures steel and aluminum containers used for food products like soup, meat, 

vegetables, and coffee. The proposed changes to Rule 452 will not affect this source 

because exempt compounds are already being used to clean container assembly 

equipment. 

Rule 454 will affect all degreasing operations. The majority of degreasers in the District 

are parts cleaners, but only two parts cleaners are required to obtain air district permits 

because most parts cleaners are smaller than our 100 gallon exemption. All parts 

cleaners, however, are subject to Rule 454. Parts cleaners are widely used by 

automotive repair shops. According to the Bureau of Automotive Repair, there are over 

1900 automotive repair operations in the county. In addition to the two permitted parts 

cleaners, there are three other permitted degreasing operations in the District. 

Rule 456 will affect two aerospace coating operations. All other facilities are in 

compliance with the proposed VOC limits for spray gun cleaning, the only cleaning 

activity with a reduced VOC limit. 

All wood products operations exceeding 55 gallons a year in coating and stripper usage 

are subject to the new requirements in Rule 463. Many of the wood products operations 

are conducted by small businesses that produce wood household furniture, kitchen 

cabinets, television cabinets, office furniture, and store fixtures. All permitted businesses 

are already in compliance with the proposed VOC content limits in this rule. Because of 

the widespread use of acetone, businesses that are exempt from permit requirements 

because of low usage are also expected to be in compliance with the proposed limits. 

Organic chemical manufacturing operations with uncontrolled VOC emissions exceeding 

15 pounds per day are required to comply with the requirements of the Rule 464. As 

mentioned earlier, none of the three facilities currently regulated by Rule 464 use 

solvent-based materials for maintenance cleaning, and are, therefore, already in 

compliance with the proposed rule. 

Rule 465 will affect businesses that use polyester resins in their manufacturing process, 

which include tub, shower, and sink manufacturers and tomato bin manufacturers. 

There are currently seven facilities regulated by the rule. These sources and others with 

resin usage exceeding 20 gallons per month are subject to the new requirements. As 

previously stated, products currently used by these sources comply with the proposed 

rule. 

Rule 466 was introduced in 2002 to address previously unregulated cleaning operations, 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 40 

such as wipe cleaning and cleaning of medical devices and pharmaceuticals, electrical 

apparatus components and electronic components, and architectural application 

equipment. The proposed rule will continue to regulate these operations and other 

solvent cleaning operations not already addressed by the industry specific solvent 

cleaning rules. 

Impact of rule amendments on employment and the economy in the District: 

Amendments for two of the rules – Rule 450 and Rule 466 – will result in additional costs 

to businesses to comply with the new requirements. The increase in annual costs for 

the entire graphic arts industry is estimated to be $408,000 per year, or about $1,550 per 

year for each graphic arts operation. A socioeconomic impact analysis was performed 

by SJVUAPCD when they adopted nearly identical solvent cleaning requirements for 

graphic arts operations on September 20, 2007, and they concluded that compliance 

costs for the printing industry, as a percentage of net profits, were well below the level at 

which significant economic or employment impacts would occur. Printing operations in 

Sacramento County are similar to those in SJVUAPCD, and Staff expects that the 

proposed amendments to Rule 450 will not significantly impact employment or the 

economy in the District. 

The amendments to Rule 466 are estimated to increase annual costs by a total of 

$489,000 per year, or about $130 per year for each affected business. These cost 

increases are relatively minor and are not expected to result in significant effects on 

employment or the economy in the District. 

Range of Probable Costs of Rule Amendments: This is discussed under the "COST 

IMPACT" section above. 

Availability and Cost-Effectiveness of Alternatives to Rules: 

The most fundamental alternative to the proposed rules is to not amend them. However, 

the District is required by Section 40914(b)(2) of the Health and Safety Code to include 

in its state attainment plan “all feasible measures” to reduce ozone precursors. The 

proposed standards have been demonstrated as feasible in the SCAQMD, and 

consequently, the District committed to them in the 2003 Triennial Report. This 

evaluation confirms that the proposed changes provide substantive, cost effective 

emission benefits. Many of them provide cost savings. If the proposed rules are not 

adopted, the District will not fulfill this state plan commitment. Furthermore, the VOC 

emissions reductions will not be achieved, which could require the District to implement 

less cost effective measures for other sources in order to attain the federal 8-hour ozone 

standard. 

Emission Reduction Potential: The proposed amendments to the rules will achieve an 

emission reduction of at least 195.64 tons per year of VOCs in 2010 (See discussion 

under Emissions Impact). 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 41 

Necessity of Adopting, Amending, or Repealing the Rules of Regulation to Attain 

State and Federal Ambient Air Standards: 

The proposed amendments to the solvent cleaning rules are necessary to comply with 

all feasible measures requirements and provide additional VOC emission reductions that 

contribute to the attainment of both the state and federal ozone standards, in 

Sacramento County and downwind areas. 

INCREMENTAL COST EFFECTIVENESS ANALYSIS 

Pursuant to Health and Safety Code Section 40920.6(a)(3), the District is required to 

perform incremental cost effectiveness analysis prior to adopting requirements for Best 

Available Retrofit Control Technology (BARCT) or a “feasible measure” requirement 

pursuant to HSC Section 40914. The District is required to identify one or more potential 

control options that achieve the emission reduction objective for the regulation. Staff 

evaluated the cost effectiveness of using alternative control options such as the use of 

air pollution control equipment, where feasible. Staff did not perform a cost 

effectiveness analysis where the use of air pollution control equipment is not feasible 

(e.g., wipe cleaning for equipment and machinery.) No other options could meet the 

emission reduction commitments for these rules. 

The incremental cost effectiveness analysis performed for this rule is based on the 

Discounted Cash Flow cost analysis method to compute the present value of the 

proposed rule’s costs over a 10-year period (the assumed equipment lifetime), using a 

7.0% interest rate (based on a U.S. Treasury Security maturing in 10 years plus two 

percent.) The incremental cost effectiveness analysis was performed for the following: 

1. Compliant materials (proposed control option); 

2. Air pollution control equipment; and 

3. Compliant materials and air pollution control equipment. 

The incremental cost effectiveness was performed for the following control options: 

1. Use of compliant materials vs. air pollution control equipment 

2. Use of control equipment vs. air pollution control equipment and compliant 

material. 

3. Use of compliant materials vs. air pollution control equipment and compliant 

material. 

The following equation was used to calculate the incremental cost: 

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

−

− =

2 1

2 1 / ($ / )

option option

option opetion

TER TER

PV PV

IC E ton

Where: IC = Incremental Cost ($) 

E = Emission reduction (tons) 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 42 

PVoption 2 = Present value of control costs for 

option 2 ($/yr) 

PVoption 1 = Present value of control costs for 

 option 1 ($/yr) 

TERoption2 = Total emission reduction for option 2 

over a 10-year period (tons) 

TERoption1 = Total emission reduction for option 1 

over a 10-year period (tons) 

 Rule 450

As discussed earlier, cost increases are expected for the cleaning of blanket and roller 

washes, metering rollers and printing plates, other on-press components, and removable 

press components. 

As stated earlier, incremental cost effectiveness analysis was performed for compliant 

materials only, air pollution control (APC) equipment only, and both compliant materials 

and APC equipment. This analysis assumes typical press room dimensions of 40’ W x 

60’ L x 20’ H and 6 air changes occur per hour, thus requiring a blower with a flow rate 

with an airflow capacity of least 5,000 cubic feet per minute (CFM) The cost of APC 

equipment is based on actual cost data taken from the EPA Air Pollution Control Cost 

Manual, Sixth Edition. The costs of using a Calgon Carbon Corporation’s High Flow 

Ventsorb System carbon adsorption system with a flow rate of 6,000 CFM— to 

accommodate the typical printing facility airflow rate of 5,000 CFM— was used for these 

calculations. The High Flow Ventsorb System represents the lowest priced carbon 

adsorption system (according to the EPA cost manual) with sufficient airflow capacity. 

This cost analysis also accounted for all capital costs and annual costs of using a carbon 

adsorption system. Capital costs include installation costs, equipment costs, and labor 

costs, and annual costs include carbon replacement costs, electricity costs, labor costs, 

property taxes, insurance, overhead, and administrative costs. The tables listing the 

cost effectiveness and incremental costs of these control options are shown below. 

 Present Value Annualized Total Emission Cost 

Control Option of Cost Cost Reduction Effectiveness 

 $ $/yr Tons/year $/ton $/lb 

Compliant Material $2,867,214 $408,226 55.16 $7,400 $3.70 

APC Equipment $39,068,293 $5,562,446 53.74 $103,502 $51.75

Compliant & APC $33,336,134 $4,746,315 72.22 $65,719 $32.86

 

 IC/E IC/E 

Incremental Comparisons 

 ($/ton) ($/lb) 

Compliant material vs. add on control 

equipment -$2,551,170 -$1,275

Compliant material vs. add on control equipment and 

compliant material $178,599 $89.30 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 43 

Based on the above analysis, it is not cost effective to require the use of APC equipment 

instead of compliant material because APC equipment costs more and reduces less 

VOCs. Also, the incremental cost effectiveness of using both compliant material and 

APC equipment vs. only compliant material also significantly exceeds $18.05/lb.

Rules 451, 452, 454, 456, 463, 464, and 465 

Compliance costs are expected to decrease for sources regulated by Rules 451 and 

456. Sources regulated by Rules 452, 463, 464, and 465 are already in compliance with 

the VOC limits proposed. No incremental cost effectiveness analysis is necessary for 

these rules. 

Emission reductions will result from the proposed changes to Rule 454. However, 

incremental cost effectiveness analysis is not needed for these rules because there are 

no added compliance costs for this rule. 

Rule 466

As stated earlier, incremental cost effectiveness analysis was performed for compliant 

materials only, air pollution control (APC) equipment only, and both compliant materials 

and APC equipment. Staff assumes the room dimensions and airflow requirements for a 

printing facility and a non-printing facility to be the same, since the 7/19/02 SCAQMD 

staff report for Rule 1171 states that the airflow requirement for a non-printing facility is 

approximately 5,000 CFM. Therefore, equipment, installation, and annual costs are 

assumed to be similar as well, and the costs computed for Rule 450 can be used here 

(only the annual emission reductions differ from that of Rule 450). The tables listing the 

cost effectiveness and incremental costs of these control options are shown below. 

 Present Value Annualized 

Total 

Emission Cost 

Control Option of Cost Cost Reduction Effectiveness 

 $ $/yr Tons/year $/ton $/lb 

Compliant 

Material $3,437,559 $489,431 66.23 $7,390 $3.70

APC Equipment $405,861,794 $57,785,588 121.33 $476,255 $238.13

Compliant & APC $396,024,905 $56,385,037 130.94 $430,630 $215.32

 

 IC/E IC/E 

Incremental Comparisons 

 ($/ton) ($/lb) 

Compliant material vs. add on control equipment $730,276 $365 

Compliant material vs. add on control 

equipment and compliant material $606,699 $303 

Based on the above analysis, the cost effectiveness of using APC equipment or using 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 44 

both APC equipment and compliant material significantly exceeds the most expensive 

control measure ever required by the District, $18.05 per pound. 

OTHER FACTORS: 

Technological Feasibility: The VOC limits proposed in the solvent cleaning rules are 

based on requirements adopted and implemented by SCAQMD. Therefore, the 

proposed VOC limits are technologically feasible. 

Enforceability: Reporting requirements and testing procedures have been included in 

the rules to increase enforceability, as required by EPA. 

Public Acceptability: Similar requirements are currently implemented in SCAQMD. 

The rules have a future compliance timeline to allow time for affected businesses to 

identify and purchase the appropriate complaint materials. Therefore, Staff expects 

these rules and other associated costs to be acceptable to the public. 

PUBLIC COMMENTS 

Staff held a public workshop to discuss the proposed amendments on April 28, 2008. A 

public notice was mailed to interested parties including all permitted stationary sources, 

printing and automotive repair shops identified through the yellow pages, and all persons 

who have requested to receive rulemaking notices. The notice was posted on the 

District website, and the draft rules and staff report were made available for public 

review at that time. 

Staff received several comments and questions at the workshop, as well as written 

comments from industry and CARB. All comments and responses are included in 

Appendix D. 

ENVIRONMENTAL REVIEW AND COMPLIANCE

Staff finds that the proposed rules are exempt from the California Environmental Quality 

Act as an action by a regulatory agency for protection of the environment (Class 8 

Categorical Exemption, Section 15308 State CEQA Guidelines) and because it can be 

seen with certainty that there is no possibility that the activity in question may have a 

significant adverse effect on the environment (Section 15061(b)(3), State CEQA 

Guidelines). 

California Public Resources Code (Section 21159) requires an environmental analysis of 

the reasonably foreseeable methods of compliance. Compliance is expected to be 

achieved by the replacement of current cleaning solvents with compliant products. 

Compliant products may contain higher levels of exempt compounds, but these exempt 

compounds are generally less toxic than the VOC solvents they replace. The proposed 

rules will not increase emissions and will not cause any other significant adverse effects 

on the environment; therefore Staff has concluded that no environmental impacts will be 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 45 

caused by compliance with the proposed rules. 

FINDINGS

The California Health and Safety Code, Division 26, Air Resources, require local Districts 

to comply with a rule adoption protocol as set forth in Section 40727 of the Code. This 

section has been revised through legislative mandate to contain six findings that the 

District must make when developing, amending, or repealing a rule. These findings, 

effective January 1, 1992, and their definitions are listed in the table below. 

Rule 450

FINDING FINDING DETERMINATION 

Authority: The District must find that a 

provision of law or of a state or federal 

regulation permits or requires the District to 

adopt, amend, or repeal the rule. 

The District is authorized to adopt rules and regulations by 

California Health and Safety Code, Sections 40001, 40702, 

40716, 41010 and 41013. (CHSC Section 40727(b)(2)) 

Necessity: The District must find that the 

rulemaking demonstrates that a need 

exists for the rule, or for its amendment or 

repeal. 

Proposed amendments to Rule 450 are necessary in order 

to meet the Federal Clean Air Act Reasonably Available 

Control Technology requirements (Sections 182(b)(2) and 

172(c)(1) (42 U.S.C. 7502 of the Federal Clean Air Act 

Amendments of 1990), 1994 Sacramento Area Regional 

Ozone Attainment Plan (CHSC Section 40913), the state’s 

Best Available Retrofit Control Technology requirements 

(CHSC Section 40919(a)(3)), and “all feasible measures” 

requirement (CHSC Section 40914) for reducing volatile 

organic compound emissions from graphic arts operations. 

(CHSC Section 40727(b)(1)) 

Clarity: The District must find that the rule 

is written or displayed so that its meaning 

can be easily understood by the persons 

directly affected by it. 

Staff has reviewed the proposed rule amendments and 

determined that they can be easily understood by the 

affected industry. In addition, the record contains no 

evidence that the persons directly affected by the rule can 

not understand it. (CHSC Section 40727(b)(3)) 

Consistency: The rule is in harmony with, 

and not in conflict with or contradictory to, 

existing statutes, court decisions, or state 

or federal regulations. 

The proposed rule amendments do not conflict with and are 

not contradictory to, existing statutes, court decisions, or 

state or federal regulations. (CHSC Section 40727(b)(4)) 

Non-Duplication: The District must find 

that either: 1) The rule does not impose the 

same requirements as an existing state or 

federal regulation; or 2) that the duplicative 

requirements are necessary or proper to 

execute the powers and duties granted to, 

and imposed upon the District. 

The proposed rule amendments do not duplicate any state 

laws or regulations, regarding the attainment and 

maintenance of state and federal air quality standards. 

(CHSC Section 40727(b)(5)) 

Reference: The District must refer to any 

statute, court decision, or other provision of 

law that the District implements, interprets, 

or makes specific by adopting, amending 

or repealing the rule. 

CHSC Sections 40913, 40914 and 40919(a)(3), 41010; 

Sections 182(b)(2) and 172(c)(1) of the Federal Clean Air 

Act Amendments of 1990. (CHSC Section 40727(b)(6)) 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 46 

FINDING FINDING DETERMINATION 

Additional Informational Requirements 

(CHSC Section 40727.2): In complying 

with CHSC Section 40727.2, the District 

must identify all federal requirements and 

District rules that apply to the same 

equipment or source type as the proposed 

rule or amendments. 

The discussion attached (Appendix A) contains a 

comparison of other requirements that apply to graphic arts 

operations. (CHSC Section 40727.2) 

Rule 451

FINDING FINDING DETERMINATION 

Authority: The District must find that a 

provision of law or of a state or federal 

regulation permits or requires the District to 

adopt, amend, or repeal the rule. 

The District is authorized to adopt rules and regulations by 

California Health and Safety Code, Sections 40001, 40702, 

40716, 41010 and 41013. (CHSC Section 40727(b)(2)) 

Necessity: The District must find that the 

rulemaking demonstrates that a need 

exists for the rule, or for its amendment or 

repeal. 

Proposed amendments to Rule 451 are necessary in order 

to meet the Federal Clean Air Act Reasonably Available 

Control Technology requirements (Sections 182(b)(2) and 

172(c)(1) (42 U.S.C. 7502 of the Federal Clean Air Act 

Amendments of 1990), 1994 Sacramento Area Regional 

Ozone Attainment Plan (CHSC Section 40913), the state’s 

Best Available Retrofit Control Technology requirements 

(CHSC Section 40919(a)(3)), and “all feasible measures” 

requirement (CHSC Section 40914) for reducing volatile 

organic compound emissions from surface coating of 

miscellaneous metal parts and products. (CHSC Section 

40727(b)(1)) 

Clarity: The District must find that the rule 

is written or displayed so that its meaning 

can be easily understood by the persons 

directly affected by it. 

Staff has reviewed the proposed rule amendments and 

determined that they can be easily understood by the 

affected industry. In addition, the record contains no 

evidence that the persons directly affected by the rule can 

not understand it. (CHSC Section 40727(b)(3)) 

Consistency: The rule is in harmony with, 

and not in conflict with or contradictory to, 

existing statutes, court decisions, or state 

or federal regulations. 

The proposed rule amendments do not conflict with and are 

not contradictory to, existing statutes, court decisions, or 

state or federal regulations. (CHSC Section 40727(b)(4)) 

Non-Duplication: The District must find 

that either: 1) The rule does not impose the 

same requirements as an existing state or 

federal regulation; or 2) that the duplicative 

requirements are necessary or proper to 

execute the powers and duties granted to, 

and imposed upon the District. 

The proposed rule amendments do not duplicate any state 

laws or regulations, regarding the attainment and 

maintenance of state and federal air quality standards. 

(CHSC Section 40727(b)(5)) 

Reference: The District must refer to any 

statute, court decision, or other provision of 

law that the District implements, interprets, 

or makes specific by adopting, amending 

or repealing the rule. 

CHSC Sections 40913, 40914 and 40919(a)(3), 41010; 

Sections 182(b)(2) and 172(c)(1) of the Federal Clean Air 

Act Amendments of 1990. (CHSC Section 40727(b)(6)) 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 47 

FINDING FINDING DETERMINATION 

Additional Informational Requirements 

(CHSC Section 40727.2): In complying 

with CHSC Section 40727.2, the District 

must identify all federal requirements and 

District rules that apply to the same 

equipment or source type as the proposed 

rule or amendments. 

The discussion attached (Appendix A) contains a 

comparison of other requirements that apply to surface 

coating of miscellaneous metal parts and products. (CHSC 

Section 40727.2) 

Rule 452

FINDING FINDING DETERMINATION 

Authority: The District must find that a 

provision of law or of a state or federal 

regulation permits or requires the District to 

adopt, amend, or repeal the rule. 

The District is authorized to adopt rules and regulations by 

California Health and Safety Code, Sections 40001, 40702, 

40716, 41010 and 41013. (CHSC Section 40727(b)(2)) 

Necessity: The District must find that the 

rulemaking demonstrates that a need 

exists for the rule, or for its amendment or 

repeal. 

Proposed amendments to Rule 452 are necessary in order 

to meet the Federal Clean Air Act Reasonably Available 

Control Technology requirements (Sections 182(b)(2) and 

172(c)(1) (42 U.S.C. 7502 of the Federal Clean Air Act 

Amendments of 1990), 1994 Sacramento Area Regional 

Ozone Attainment Plan (CHSC Section 40913), the state’s 

Best Available Retrofit Control Technology requirements 

(CHSC Section 40919(a)(3)), and “all feasible measures” 

requirement (CHSC Section 40914) for reducing volatile 

organic compound emissions from can coating operations. 

(CHSC Section 40727(b)(1)) 

Clarity: The District must find that the rule 

is written or displayed so that its meaning 

can be easily understood by the persons 

directly affected by it. 

Staff has reviewed the proposed rule amendments and 

determined that they can be easily understood by the 

affected industry. In addition, the record contains no 

evidence that the persons directly affected by the rule can 

not understand it. (CHSC Section 40727(b)(3)) 

Consistency: The rule is in harmony with, 

and not in conflict with or contradictory to, 

existing statutes, court decisions, or state 

or federal regulations. 

The proposed rule amendments do not conflict with and are 

not contradictory to, existing statutes, court decisions, or 

state or federal regulations. (CHSC Section 40727(b)(4)) 

Non-Duplication: The District must find 

that either: 1) The rule does not impose the 

same requirements as an existing state or 

federal regulation; or 2) that the duplicative 

requirements are necessary or proper to 

execute the powers and duties granted to, 

and imposed upon the District. 

The proposed rule amendments do not duplicate any state 

laws or regulations, regarding the attainment and 

maintenance of state and federal air quality standards. 

(CHSC Section 40727(b)(5)) 

Reference: The District must refer to any 

statute, court decision, or other provision of 

law that the District implements, interprets, 

or makes specific by adopting, amending 

or repealing the rule. 

CHSC Sections 40913, 40914 and 40919(a)(3), 41010; 

Sections 182(b)(2) and 172(c)(1) of the Federal Clean Air 

Act Amendments of 1990. (CHSC Section 40727(b)(6)) 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 48 

FINDING FINDING DETERMINATION 

Additional Informational Requirements 

(CHSC Section 40727.2): In complying 

with CHSC Section 40727.2, the District 

must identify all federal requirements and 

District rules that apply to the same 

equipment or source type as the proposed 

rule or amendments. 

The discussion attached (Appendix A) contains a 

comparison of other requirements that apply to can coating 

operations. (CHSC Section 40727.2) 

Rule 454

FINDING FINDING DETERMINATION 

Authority: The District must find that a 

provision of law or of a state or federal 

regulation permits or requires the District to 

adopt, amend, or repeal the rule. 

The District is authorized to adopt rules and regulations by 

California Health and Safety Code, Sections 40001, 40702, 

40716, 41010 and 41013. (CHSC Section 40727(b)(2)) 

Necessity: The District must find that the 

rulemaking demonstrates that a need 

exists for the rule, or for its amendment or 

repeal. 

Proposed amendments to Rule 454 are necessary in order 

to meet the Federal Clean Air Act Reasonably Available 

Control Technology requirements (Sections 182(b)(2) and 

172(c)(1) (42 U.S.C. 7502 of the Federal Clean Air Act 

Amendments of 1990), 1994 Sacramento Area Regional 

Ozone Attainment Plan (CHSC Section 40913), the state’s 

Best Available Retrofit Control Technology requirements 

(CHSC Section 40919(a)(3)), and “all feasible measures” 

requirement (CHSC Section 40914) for reducing volatile 

organic compound emissions from solvent cleaning 

operations. (CHSC Section 40727(b)(1)) 

Clarity: The District must find that the rule 

is written or displayed so that its meaning 

can be easily understood by the persons 

directly affected by it. 

Staff has reviewed the proposed rule amendments and 

determined that they can be easily understood by the 

affected industry. In addition, the record contains no 

evidence that the persons directly affected by the rule can 

not understand it. (CHSC Section 40727(b)(3)) 

Consistency: The rule is in harmony with, 

and not in conflict with or contradictory to, 

existing statutes, court decisions, or state 

or federal regulations. 

The proposed rule amendments do not conflict with and are 

not contradictory to, existing statutes, court decisions, or 

state or federal regulations. (CHSC Section 40727(b)(4)) 

Non-Duplication: The District must find 

that either: 1) The rule does not impose the 

same requirements as an existing state or 

federal regulation; or 2) that the duplicative 

requirements are necessary or proper to 

execute the powers and duties granted to, 

and imposed upon the District. 

The proposed rule amendments do not duplicate any state 

laws or regulations, regarding the attainment and 

maintenance of state and federal air quality standards. 

(CHSC Section 40727(b)(5)) 

Reference: The District must refer to any 

statute, court decision, or other provision of 

law that the District implements, interprets, 

or makes specific by adopting, amending 

or repealing the rule. 

CHSC Sections 40913, 40914 and 40919(a)(3), 41010; 

Sections 182(b)(2) and 172(c)(1) of the Federal Clean Air 

Act Amendments of 1990. (CHSC Section 40727(b)(6))
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 49 

FINDING FINDING DETERMINATION 

Additional Informational Requirements 

(CHSC Section 40727.2): In complying 

with CHSC Section 40727.2, the District 

must identify all federal requirements and 

District rules that apply to the same 

equipment or source type as the proposed 

rule or amendments. 

The discussion attached (Appendix A) contains a 

comparison of other requirements that apply to degreasing 

operations. (CHSC Section 40727.2) 

Rule 456

FINDING FINDING DETERMINATION 

Authority: The District must find that a 

provision of law or of a state or federal 

regulation permits or requires the District to 

adopt, amend, or repeal the rule. 

The District is authorized to adopt rules and regulations by 

California Health and Safety Code, Sections 40001, 40702, 

40716, 41010 and 41013. (CHSC Section 40727(b)(2)) 

Necessity: The District must find that the 

rulemaking demonstrates that a need 

exists for the rule, or for its amendment or 

repeal. 

Proposed amendments to Rule 456 are necessary in order 

to meet the Federal Clean Air Act Reasonably Available 

Control Technology requirements (Sections 182(b)(2) and 

172(c)(1) (42 U.S.C. 7502 of the Federal Clean Air Act 

Amendments of 1990), 1994 Sacramento Area Regional 

Ozone Attainment Plan (CHSC Section 40913), the state’s 

Best Available Retrofit Control Technology requirements 

(CHSC Section 40919(a)(3)), and “all feasible measures” 

requirement (CHSC Section 40914) for reducing volatile 

organic compound emissions from aerospace assembly 

and component coating operations. (CHSC Section 

40727(b)(1)) 

Clarity: The District must find that the rule 

is written or displayed so that its meaning 

can be easily understood by the persons 

directly affected by it. 

Staff has reviewed the proposed rule amendments and 

determined that they can be easily understood by the 

affected industry. In addition, the record contains no 

evidence that the persons directly affected by the rule can 

not understand it. (CHSC Section 40727(b)(3)) 

Consistency: The rule is in harmony with, 

and not in conflict with or contradictory to, 

existing statutes, court decisions, or state 

or federal regulations. 

The proposed rule amendments do not conflict with and are 

not contradictory to, existing statutes, court decisions, or 

state or federal regulations. (CHSC Section 40727(b)(4)) 

Non-Duplication: The District must find 

that either: 1) The rule does not impose the 

same requirements as an existing state or 

federal regulation; or 2) that the duplicative 

requirements are necessary or proper to 

execute the powers and duties granted to, 

and imposed upon the District. 

The proposed rule amendments do not duplicate any state 

laws or regulations, regarding the attainment and 

maintenance of state and federal air quality standards. 

(CHSC Section 40727(b)(5)) 

Reference: The District must refer to any 

statute, court decision, or other provision of 

law that the District implements, interprets, 

or makes specific by adopting, amending 

or repealing the rule. 

CHSC Sections 40913, 40914 and 40919(a)(3), 41010; 

Sections 182(b)(2) and 172(c)(1) of the Federal Clean Air 

Act Amendments of 1990. (CHSC Section 40727(b)(6)) 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 50 

FINDING FINDING DETERMINATION 

Additional Informational Requirements 

(CHSC Section 40727.2): In complying 

with CHSC Section 40727.2, the District 

must identify all federal requirements and 

District rules that apply to the same 

equipment or source type as the proposed 

rule or amendments. 

The discussion attached (Appendix A) contains a 

comparison of other requirements that apply to aerospace 

assembly and component coating operations. (CHSC 

Section 40727.2) 

Rule 463

FINDING FINDING DETERMINATION 

Authority: The District must find that a 

provision of law or of a state or federal 

regulation permits or requires the District to 

adopt, amend, or repeal the rule. 

The District is authorized to adopt rules and regulations by 

California Health and Safety Code, Sections 40001, 40702, 

40716, 41010 and 41013. (CHSC Section 40727(b)(2)) 

Necessity: The District must find that the 

rulemaking demonstrates that a need 

exists for the rule, or for its amendment or 

repeal. 

Proposed amendments to Rule 463 are necessary in order 

to meet the Federal Clean Air Act Reasonably Available 

Control Technology requirements (Sections 182(b)(2) and 

172(c)(1) (42 U.S.C. 7502 of the Federal Clean Air Act 

Amendments of 1990), 1994 Sacramento Area Regional 

Ozone Attainment Plan (CHSC Section 40913), the state’s 

Best Available Retrofit Control Technology requirements 

(CHSC Section 40919(a)(3)), and “all feasible measures” 

requirement (CHSC Section 40914) for reducing volatile 

organic compound emissions from wood products coating 

operations. (CHSC Section 40727(b)(1)) 

Clarity: The District must find that the rule 

is written or displayed so that its meaning 

can be easily understood by the persons 

directly affected by it. 

Staff has reviewed the proposed rule amendments and 

determined that they can be easily understood by the 

affected industry. In addition, the record contains no 

evidence that the persons directly affected by the rule can 

not understand it. (CHSC Section 40727(b)(3)) 

Consistency: The rule is in harmony with, 

and not in conflict with or contradictory to, 

existing statutes, court decisions, or state 

or federal regulations. 

The proposed rule amendments do not conflict with and are 

not contradictory to, existing statutes, court decisions, or 

state or federal regulations. (CHSC Section 40727(b)(4)) 

Non-Duplication: The District must find 

that either: 1) The rule does not impose the 

same requirements as an existing state or 

federal regulation; or 2) that the duplicative 

requirements are necessary or proper to 

execute the powers and duties granted to, 

and imposed upon the District. 

The proposed rule amendments do not duplicate any state 

laws or regulations, regarding the attainment and 

maintenance of state and federal air quality standards. 

(CHSC Section 40727(b)(5)) 

Reference: The District must refer to any 

statute, court decision, or other provision of 

law that the District implements, interprets, 

or makes specific by adopting, amending 

or repealing the rule. 

CHSC Sections 40913, 40914 and 40919(a)(3), 41010; 

Sections 182(b)(2) and 172(c)(1) of the Federal Clean Air 

Act Amendments of 1990. (CHSC Section 40727(b)(6)) 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 51 

FINDING FINDING DETERMINATION 

Additional Informational Requirements 

(CHSC Section 40727.2): In complying 

with CHSC Section 40727.2, the District 

must identify all federal requirements and 

District rules that apply to the same 

equipment or source type as the proposed 

rule or amendments. 

The discussion attached (Appendix A) contains a 

comparison of other requirements that apply to wood 

products coating operations. (CHSC Section 40727.2) 

Rule 464

FINDING FINDING DETERMINATION 

Authority: The District must find that a 

provision of law or of a state or federal 

regulation permits or requires the District to 

adopt, amend, or repeal the rule. 

The District is authorized to adopt rules and regulations by 

California Health and Safety Code, Sections 40001, 40702, 

40716, 41010 and 41013. (CHSC Section 40727(b)(2)) 

Necessity: The District must find that the 

rulemaking demonstrates that a need 

exists for the rule, or for its amendment or 

repeal. 

Proposed amendments to Rule 464 are necessary in order 

to meet the Federal Clean Air Act Reasonably Available 

Control Technology requirements (Sections 182(b)(2) and 

172(c)(1) (42 U.S.C. 7502 of the Federal Clean Air Act 

Amendments of 1990), 1994 Sacramento Area Regional 

Ozone Attainment Plan (CHSC Section 40913), the state’s 

Best Available Retrofit Control Technology requirements 

(CHSC Section 40919(a)(3)), and “all feasible measures” 

requirement (CHSC Section 40914) for reducing volatile 

organic compound emissions from organic chemical 

manufacturing operations. (CHSC Section 40727(b)(1)) 

Clarity: The District must find that the rule 

is written or displayed so that its meaning 

can be easily understood by the persons 

directly affected by it. 

Staff has reviewed the proposed rule amendments and 

determined that they can be easily understood by the 

affected industry. In addition, the record contains no 

evidence that the persons directly affected by the rule can 

not understand it. (CHSC Section 40727(b)(3)) 

Consistency: The rule is in harmony with, 

and not in conflict with or contradictory to, 

existing statutes, court decisions, or state 

or federal regulations. 

The proposed rule amendments do not conflict with and are 

not contradictory to, existing statutes, court decisions, or 

state or federal regulations. (CHSC Section 40727(b)(4)) 

Non-Duplication: The District must find 

that either: 1) The rule does not impose the 

same requirements as an existing state or 

federal regulation; or 2) that the duplicative 

requirements are necessary or proper to 

execute the powers and duties granted to, 

and imposed upon the District. 

The proposed rule amendments do not duplicate any state 

laws or regulations, regarding the attainment and 

maintenance of state and federal air quality standards. 

(CHSC Section 40727(b)(5)) 

Reference: The District must refer to any 

statute, court decision, or other provision of 

law that the District implements, interprets, 

or makes specific by adopting, amending 

or repealing the rule. 

CHSC Sections 40913, 40914 and 40919(a)(3), 41010; 

Sections 182(b)(2) and 172(c)(1) of the Federal Clean Air 

Act Amendments of 1990. (CHSC Section 40727(b)(6)) 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 52 

FINDING FINDING DETERMINATION 

Additional Informational Requirements 

(CHSC Section 40727.2): In complying 

with CHSC Section 40727.2, the District 

must identify all federal requirements and 

District rules that apply to the same 

equipment or source type as the proposed 

rule or amendments. 

The discussion attached (Appendix A) contains a 

comparison of other requirements that apply to organic 

chemical manufacturing operations. (CHSC Section 

40727.2) 

Rule 465

FINDING FINDING DETERMINATION 

Authority: The District must find that a 

provision of law or of a state or federal 

regulation permits or requires the District to 

adopt, amend, or repeal the rule. 

The District is authorized to adopt rules and regulations by 

California Health and Safety Code, Sections 40001, 40702, 

40716, 41010 and 41013. (CHSC Section 40727(b)(2)) 

Necessity: The District must find that the 

rulemaking demonstrates that a need 

exists for the rule, or for its amendment or 

repeal. 

Proposed amendments to Rule 465 are necessary in order 

to meet the Federal Clean Air Act Reasonably Available 

Control Technology requirements (Sections 182(b)(2) and 

172(c)(1) (42 U.S.C. 7502 of the Federal Clean Air Act 

Amendments of 1990), 1994 Sacramento Area Regional 

Ozone Attainment Plan (CHSC Section 40913), the state’s 

Best Available Retrofit Control Technology requirements 

(CHSC Section 40919(a)(3)), and “all feasible measures” 

requirement (CHSC Section 40914) for reducing volatile 

organic compound emissions from polyester resin 

operations. (CHSC Section 40727(b)(1)) 

Clarity: The District must find that the rule 

is written or displayed so that its meaning 

can be easily understood by the persons 

directly affected by it. 

Staff has reviewed the proposed rule amendments and 

determined that they can be easily understood by the 

affected industry. In addition, the record contains no 

evidence that the persons directly affected by the rule can 

not understand it. (CHSC Section 40727(b)(3)) 

Consistency: The rule is in harmony with, 

and not in conflict with or contradictory to, 

existing statutes, court decisions, or state 

or federal regulations. 

The proposed rule amendments do not conflict with and are 

not contradictory to, existing statutes, court decisions, or 

state or federal regulations. (CHSC Section 40727(b)(4)) 

Non-Duplication: The District must find 

that either: 1) The rule does not impose the 

same requirements as an existing state or 

federal regulation; or 2) that the duplicative 

requirements are necessary or proper to 

execute the powers and duties granted to, 

and imposed upon the District. 

The proposed rule amendments do not duplicate any state 

laws or regulations, regarding the attainment and 

maintenance of state and federal air quality standards. 

(CHSC Section 40727(b)(5)) 

Reference: The District must refer to any 

statute, court decision, or other provision of 

law that the District implements, interprets, 

or makes specific by adopting, amending 

or repealing the rule. 

CHSC Sections 40913, 40914 and 40919(a)(3), 41010; 

Sections 182(b)(2) and 172(c)(1) of the Federal Clean Air 

Act Amendments of 1990. (CHSC Section 40727(b)(6)) 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 53 

FINDING FINDING DETERMINATION 

Additional Informational Requirements 

(CHSC Section 40727.2): In complying 

with CHSC Section 40727.2, the District 

must identify all federal requirements and 

District rules that apply to the same 

equipment or source type as the proposed 

rule or amendments. 

The discussion attached (Appendix A) contains a 

comparison of other requirements that apply to polyester 

resin operations. (CHSC Section 40727.2) 

Rule 466

FINDING FINDING DETERMINATION 

Authority: The District must find that a 

provision of law or of a state or federal 

regulation permits or requires the District 

to adopt, amend, or repeal the rule. 

The District is authorized to adopt rules and regulations by 

California Health and Safety Code, Sections 40001, 40702, 

40716, 41010, and 41013. (CHSC Section 40727(b)(2)) 

Necessity: The District must find that the 

rulemaking demonstrates that a need 

exists for the rule, or for its amendment or 

repeal. 

It is necessary to adopt proposed Rule 466 in order to meet 

the Federal Clean Air Act Reasonably Available Control 

Technology requirements (Sections 182(b)(2) and 172(c)(1) 

(42 U.S.C. 7502 of the Federal Clean Air Act Amendments 

of 1990), 1994 Sacramento Area Regional Ozone 

Attainment Plan (CHSC Section 40913), the state’s Best 

Available Retrofit Control Technology requirements (CHSC 

Section 40919(a)(3)), and “all feasible measures” 

requirement (CHSC Section 40914) for reducing volatile 

organic compound emissions from solvent cleaning 

operations. (CHSC Section 40727(b)(1)) 

Clarity: The District must find that the 

rule is written or displayed so that its 

meaning can be easily understood by the 

persons directly affected by it. 

Staff has reviewed the rule and determined that it can be 

easily understood by the affected industry. In addition, the 

record contains no evidence that the persons directly 

affected by the rule can not understand it. (CHSC Section 

40727(b)(3)) 

Consistency: The rule is in harmony 

with, and not in conflict with or 

contradictory to, existing statutes, court 

decisions, or state or federal regulations. 

The proposed rule does not conflict with and are not 

contradictory to, existing statutes, court decisions, or state 

or federal regulations. (CHSC Section 40727(b)(4)) 

Non-Duplication: The District must find 

that either: 1) The rule does not impose 

the same requirements as an existing 

state or federal regulation; or 2) that the 

duplicative requirements are necessary or 

proper to execute the powers and duties 

granted to, and imposed upon the District. 

The proposed rule does not duplicate any state laws or 

regulations, regarding the attainment and maintenance of 

state and federal air quality standards. (CHSC Section 

40727(b)(5)) 

Reference: The District must refer to any 

statute, court decision, or other provision 

of law that the District implements, 

interprets, or makes specific by adopting, 

amending or repealing the rule. 

CHSC Sections 40913, 40914 and 40919(a)(3), 41010; 

Sections 182(b)(2) and 172(c)(1) of the Federal Clean Air 

Act Amendments of 1990. (CHSC Section 40727(b)(6)) 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 54 

FINDING FINDING DETERMINATION 

Additional Informational Requirements 

(CHSC Section 40727.2): In complying 

with CHSC Section 40727.2, the District 

must identify all federal requirements and 

District rules that apply to the same 

equipment or source type as the 

proposed rule or amendments. 

The discussion attached (Appendix A) contains a 

comparison of other requirements that apply to solvent 

cleaning operations. (CHSC Section 40727.2) 

REFERENCES

1. South Coast Air Quality Management District, “Clean Air Solvent (CAS) Certification 

Program.” http://www.aqmd.gov/rules/cas/index.html. 

2. Institute for Research and Technical Assistance, “Assessment, Development, and 

Demonstration of Low-VOC Cleaning Systems for South Coast Air Quality Management 

District Rule 1171.” August 2003. 

3. South Coast Air Quality Management District, “Technology Assessment to Determine 

the Relationship of Solvent Vapor Pressure and VOC Mass Emissions.” April 10, 2002. 

4. Air Resources Board, “New Method for Estimating Emissions from Thinning and 

Cleanup Solvents.” March 9, 2006. 

5. Bay Area Air Quality Management District, “BACT/TBACT Workbook – Guidelines for 

Best Available Control Technology.” http://www.baaqmd.gov/pmt/bactworkbook/

6. South Coast Air Quality Management District, “Rule 1130, Graphic Arts Operations,” 

October 8, 1999. 

7. South Coast Air Quality Management District, “Rule 1107, Coating of Metal Parts and 

Products,” January 6, 2006. 

8. South Coast Air Quality Management District, “Rule 1125, Metal Container, Closure and 

Coil Coating Operations,” January 13, 1995. 

9. South Coast Air Quality Management District, “Rule 1122, Solvent Degreasers,” October 

1, 2004. 

10. South Coast Air Quality Management District, “Rule 1124, Aerospace Assembly and 

Component Manufacturing Operations,” September 21, 2001. 

11. South Coast Air Quality Management District, “Rule 1136, Wood Products Coatings,” 

June 14, 1996. 

12. South Coast Air Quality Management District, “Rule 1162, Polyester Resin Operations,” 

July 8, 2005 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 55 

13. South Coast Air Quality Management District, “Rule 1171, Solvent Cleaning Operations,” 

May 6, 2005. 

14. South Coast Air Quality Management District, “Rule 1171, Solvent Cleaning Operations,” 

July 7, 2006. 

15. South Coast Air Quality Management District, “Staff Report for Proposed Amended Rule 

1122- Solvent Degreasers,” September 21, 2004. 

16. South Coast Air Quality Management District, “Final Report for Technology Assessment 

for 2006 VOC Limit for Vapor Degreasers Under Rule 1122- Solvent Degreasers,” 

October 12, 2005. 

17. South Coast Air Quality Management District, “Staff Report for Proposed Rule 1131- 

Food Product Manufacturing and Processing Operations,” August 23, 2000. 

18. South Coast Air Quality Management District, “Rule 1131- Food Product Manufacturing 

and Processing Operations,” June 6, 2003. 

19. South Coast Air Quality Management District, “Staff Report for Proposed Amended Rule 

1171- Solvent Cleaning Operations,” September 27, 1999. 

20. South Coast Air Quality Management District, “Staff Report for Proposed Amended Rule 

1171- Solvent Cleaning Operations,” July 19, 2002. 

21. South Coast Air Quality Management District, “Staff Report for Proposed Amended Rule 

1171- Solvent Cleaning Operations,” November 2003. 

22. South Coast Air Quality Management District, “Staff Report for Proposed Amended Rule 

1171- Solvent Cleaning Operations,” April 19, 2005. 

23. South Coast Air Quality Management District, “Staff Report for Proposed Amended Rule 

1171- Solvent Cleaning Operations,” June 2006. 

24. CARB Ozone SIP Planning Inventory, Version 1.06, Sacramento NAA (Rf#980), 

November 16, 2006. 

25. EPA Air Pollution Control Cost Manual, Sixth Edition, January 2002. 

26. Printing Industries Association/Graphic Arts Technical Foundation, “Assessment, 

Development, and Demonstration of Low-VOC Solvents for Cleaning of Lithographic 

Printing Ink Application Equipment,” March 2006. 

27. University of Tennessee Center for Clean Products and Clean Technologies, 

“Compatibility Testing of Low-VOC Alternative Cleaning Solvents for Lithographic 

Printing Application,” April 2006. 
Staff Report 

Rules 450, 451, 452, 454, 456, 463, 464, 465, 466 

August 25, 2008, Page 56 

28. Institute for Research and Technical Assistance, “Assessment, Development, and 

Demonstration of Low-VOC Materials for Cleaning Ultraviolet and Electron Beam 

Curable Coatings and Adhesives,” May 2006. 

29. Institute for Research and Technical Assistance, “Low-VOC, Low-Toxicity Clean up 

Solvents for Screen Printing: Safer Alternatives,” May 2006. 

30. Institute for Research and Technical Assistance, “Assessment, Development, and 

Demonstration of Low-VOC Materials for Cleaning of Lithographic Printing Ink 

Application Equipment,” May 2006. 

31. San Joaquin Valley Unified Air Pollution Control District, “Final Draft Staff Report for 

Rules 4603, 4604, 4605, 4606, 4607, 4612, 4653, 4661, 4662, 4663, and 4684,” August 

2007. 

32. United States Environmental Protection Agency, “Control Techniques Guidelines for 

Flexible Package Printing,” September 2006. 

33. United States Environmental Protection Agency, “Control Techniques Guidelines for 

Offset Lithographic Printing and Letterpress Printing,” September 2006. 

34. United States Environmental Protection Agency, “Control Techniques Guidelines for 

Metal Furniture Coatings,” September 2007. 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 57

Appendix A 

Rule Consistency Analysis 

Proposed Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 will limit the VOC emissions 

from solvent cleaning activities. There are EPA standards such as Best Available Control 

Technology (BACT) and Lowest Achievable Emission Rate (LAER) that apply to solvent 

cleaning. There are also National Emission Standards for regulating the emissions of 

Hazardous air pollutants from solvent cleaning operations. This regulation is 40 CFR Part 63 

Subpart T – Halogenated Solvent Emissions from Solvent Cleaning. Proposed Rule 454 now 

prohibits the use of solvents regulated under 40 CFR Part 63 Subpart T in degreasing 

operations unless an airless/airtight cleaning system is used. The rule consistency matrices for 

the proposed rules are listed in the following tables A-1 through A-9. 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 58

Appendix A-1 

40727.2 Matrix for Proposed Amendments to Rule 450, Graphic Arts Operations

Elements of 

Comparison 

Specific 

Provisions 

Proposed Rule 450 BACT/LAER (*) 

Exemptions Sixty pounds per month for actual 

VOC emissions or 175 pounds per 

month for potential emissions. 

Gravure printing; business and 

personal printers; prepress 

operations; aerosol adhesives for 

screen printing; aerosol adhesives 

other than screen printing; stripping 

of cured inks, coatings, and 

adhesives; lithographic and letter 

press printing- metering rollers and 

printing plates 

Fountain solutions for lower VOC if 

total offset lithographic printing 

operations emit less than or equal to 

450 pounds per month of VOC 

Heatset web offset lithographic 

printing presses or heatset web 

letterpress printing presses with 

potential to emit less than 25 tons 

per year of VOC prior to controls 

Heatset web offset lithographic 

printing presses used for book 

printing or presses with maximum 

web width of 22 inches or less 

Flexible package printing presses 

with potential to emit less than 25 

tons per year of VOC prior to 

controls 

10 pounds of VOCs per day. 

(Rule 202, NEW SOURCE 

REVIEW) 

Averaging 

Provisions 

For air pollution control equipment, 

meet the control and collection 

efficiency specified in the rule or lbsVOC/gal or grams of VOC/liter as 

applied. 

Compliance with 

control/collection is done 

using source test methods 

specified below and the 

corresponding averaging 

period (typically average of 

three 40-minute runs.) 

Units % Control or lbs-VOC/gal or grams 

of VOC/liter as applied. 

% Control or lbs-VOC/gal or 

grams of VOC/liter as 

applied. 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 59

Elements of 

Comparison 

Specific 

Provisions 

Proposed Rule 450 BACT/LAER (*) 

Emission 

Reductions 

Meet the VOC limits specified in 

Section 300 or install air pollution 

control equipment with overall 

control efficiency of 67% 

Mandatory control equipment for 

heatset web offset lithographic 

printing, heatset web letterpress 

printing, and flexible package 

printing with overall control 

efficiencies ranging from 67% to 

95%, depending on specific process 

and date of control equipment 

installation (see Sections 303 and 

304 of the rule)` 

If cost effective, capture and 

vent VOC to afterburner or 

carbon adsorption system 

with ≥98.5% 

destruction/recovery device 

efficiency; or VOC outlet ≤10 

ppmv. (*) 

Emission Limits 

Compliance 

alternatives 

Air Pollution Control Equipment Air Pollution Control 

Equipment 

Operating 

Parameters 

 

Work Practice 

Requirements 

Closed Containers; Proper disposal 

of spent solvents. 

Closed containers, proper 

disposal of spent solvents. 

Recordkeeping Records of VOC emissions and 

usage 

Records of emissions and 

operating parameters. 

Records vary depending on 

the control technology. 

Monitoring/ 

Records 

Frequency Daily and/or monthly. Records are 

to be kept for five years. 

Daily, monthly, and/or 

quarterly. 

Test Methods Applicable test methods are 

specified under Section 502 of the 

rule. 

Applicable EPA Methods 2, 

2C, 18, 25, 25A, 204, 204A, 

204B, 204C, 204D, 204E, 

204F or ARB Method 432. 

Monitoring/ 

Testing 

Frequency No testing frequency specified in the 

rule. 

Frequency can be annual if 

air pollution control 

equipment is selected. 

(*) BACT trigger level is based on District's Rule 202 – NEW SOURCE REVIEW. BACT limits are based on similar 

requirements adopted by other districts as BACT that are determined to be cost effective and technologically feasible. 

(**) Based on BACT adopted by the Bay Area Air Quality Management District, BACT/TBACT Workbook – Guidelines for Best 

Available Control Technology. 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 60

Appendix A-2 

40727.2 Matrix for Proposed Amendments to Rule 451, Surface Coating of Miscellaneous 

Metal Parts and Products

Elements of 

Comparison

Specific 

Provisions

Proposed Rule 451 BACT/LAER

Exemptions Usage less than 55 gal/yr 

Coating of prefabricated architectural 

components or structures not coated 

in a shop environment; motor 

vehicles; aircraft or aerospace 

vehicles, components, and tooling; 

cans, coils, or magnetic wire; 

adhesives; magnetic data storage 

discs; safety-indicating coatings; 

stencil coatings; conformal coatings; 

hand lettering 

Aerosol containers less than or equal 

to 1 liter 

Touch-up coating and repair coating 

operations; application of coatings 

producing a textured finish 

Metal furniture for lower VOC if less 

than 3 tons per year from such 

operations 

a) touch-up coatings 

b) stencil coatings 

c) aerosol coating products 

d) emission limits not applicable if 

using approved emissions 

control system, operating 

under an alternative emission 

control plan, or using less than 

twelve pounds per day for 

educational purposes at a 

training center. 

Averaging 

Provisions 

For air pollution control equipment, 

meet the control and collection 

efficiency specified in the rule or lbsVOC/gal or grams of VOC/liter as 

applied. 

For emission control equipment, 

must reduce emissions to level that 

is equivalent or lower than limit 

specified in rule. 

Units % Control or lbs-VOC/gal or grams of 

VOC/liter as applied. 

1. Grams per liter less water and 

exempt compounds, or; 

2. Pounds per gallon less water 

and exempt compounds. 

Emission 

Reductions 

Meet the emission limits specified in 

Section 300, or install emissions 

control equipment specified in 

Section 305 with overall system 

efficiency of ≥ 90%. 

Lower solvent content, higher 

transfer efficiency than required by 

applicable rules, and control 

equipment with overall 

capture/destruction efficiency of ≥

90% 

Emission Limits 

Compliance 

alternatives 

Air Pollution Control Equipment Air Pollution Control Equipment 

Operating 

Parameters 

 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 61

Elements of 

Comparison

Specific 

Provisions

Proposed Rule 451 BACT/LAER

Work Practice 

Requirements 

Closed containers for disposal of 

materials used for surface 

preparation, cleanup and coating 

removal; closed containers; cleanup 

to take place in an enclosed system; 

minimizing spills, conveyance of VOC 

materials using closed containers or 

pipes. 

Closed containers for disposal of 

materials used for surface 

preparation, cleanup and coating 

removal; closed containers; 

cleanup to take place in an 

enclosed system. 

Recordkeeping Recordkeeping of usage; 

recordkeeping for air pollution control 

equipment if used. 

Daily records of operations for most 

recent two years; method 

application and substrate type; 

amount of coating used including 

exempt amounts; VOC content of 

each coating; amount of surface 

prep and cleanup material used; 

vapor pressure of solvents, where 

applicable. 

Monitoring/ 

Records 

Frequency Daily and/or monthly for coating 

usages. Records kept for a 

continuous five-year period. 

Daily records of coating usages 

Test Methods Applicable test methods are specified 

under Section 502 of the rule. 

Applicable EPA Methods 2 or 2C, 

18, 24, 25, 25A, 204, 204A, 204B, 

204C, 024D, 204E, 204F, ASTM D 

4457-85 or ARB method 432, 

ASTM Standard D2832, ASTM D 

4457-85, SCAQMD 318, and 

Sections 221, and 404 of the Rule. 

Monitoring/ 

Testing 

Frequency No frequency specified in the rule 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 62

Appendix A-3 

40727.2 Matrix for Proposed Amendments to Rule 452, Can Coating

Elements of 

Comparison

Specific 

Provisions

Proposed Rule 452 BACT/LAER

Exemptions None a) touch-up coatings 

b) stencil coatings 

c) aerosol coating products 

d) emission limits not 

applicable if using 

approved emissions 

control system, operating 

under an alternative 

emission control plan, or 

using less than twelve 

pounds per day for 

educational purposes at a 

training center. 

Averaging 

Provisions 

For air pollution control equipment, 

meet the control and collection 

efficiency specified in the rule or lbsVOC/gal or grams of VOC/liter as 

applied. 

For emission control equipment, 

must reduce emissions to level that 

is equivalent or lower than limit 

specified in rule. 

Units % Control or lbs-VOC/gal or grams of 

VOC/liter as applied. 

1. Grams per liter less water and 

exempt compounds, or; 

2. Pounds per gallon less water 

and exempt compounds. 

Emission 

Reductions 

Meet the emission limits specified in 

Section 300, or install emissions 

control equipment specified in 

Section 302 with overall system 

efficiency of ≥ 90%. 

Lower solvent content, higher 

transfer efficiency than required by 

applicable rules, and control 

equipment with overall 

capture/destruction efficiency of ≥

90% 

Emission Limits 

Compliance 

alternatives 

Air Pollution Control Equipment Air Pollution Control Equipment 

Operating 

Parameters 

 

Work Practice 

Requirements 

Closed containers for disposal of 

materials used for cleanup; closed 

containers; cleanup to take place in 

an enclosed system. 

Closed containers for disposal of 

materials used for surface 

preparation, cleanup and coating 

removal; closed containers; 

cleanup to take place in an 

enclosed system. 

Recordkeeping Recordkeeping of usage; 

recordkeeping for air pollution control 

equipment if used. 

Daily records of operations for most 

recent two years; method 

application and substrate type; 

amount of coating used including 

exempt amounts; VOC content of 

each coating; amount of surface 

prep and cleanup material used; 

vapor pressure of solvents, where 

applicable. 

Monitoring/ 

Records 

Frequency Daily and/or monthly for coating 

usages. Records kept for a 

continuous five-year period. 

Daily records of coating usages 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 63

Elements of 

Comparison

Specific 

Provisions

Proposed Rule 452 BACT/LAER

Test Methods Applicable test methods are specified 

under Section 501 of the rule. 

Applicable EPA Methods 2 or 2C, 

18, 24, 25, 25A, 204, 204A, 204B, 

204C, 024D, 204E, 204F, ASTM D 

4457-85 or ARB method 432, 

ASTM Standard D2832, ASTM D 

4457-85, SCAQMD 318, and 

Sections 221, and 404 of the Rule. 

Monitoring/ 

Testing 

Frequency No frequency specified in the rule 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 64

Appendix A-4 

40727.2 Matrix for Proposed Amendments to Rule 454, Solvent Degreasing 

Elements of 

Comparison 

Specific 

Provisions 

Proposed Rule 454 BACT/LAER 

Exemptions Cleaning operations using cleanup 

materials containing less than 25 

grams per liter VOCs; Cleanup 

operations specifically regulated under 

other prohibitory rules; open-top vapor 

degreasers; degreasing of highvoltage microwave vacuum tubes 

10 lbs-VOC/day 

Averaging 

Provisions 

None None 

Units Lbs-VOC/gal or grams of VOC/liter Lbs-VOC/gal or grams of VOC/liter 

Emissions 

Reduction 

Meet the VOC limits in Section 300 or 

use an airtight airless cleaning system 

Typical BACT for cold solvent cleaning 

tanks is using low volatility solvents, 

drain cover, and a freeboard height at 

least 6 inches. Other BACT used by 

SJVUAPCD is the use of Safety Kleen 

Premium Solvent – California and a 

degreaser cover. 

Use of air pollution control equipment 

such as an afterburner with 99% 

destruction efficiency. 

Emissions 

Limits 

Compliance 

Alternatives 

Use an airtight airless cleaning system Reduce VOC emissions by add on air 

pollution control equipment and meet 

certain control and collection efficiency 

(generally >95%). 

Operating 

Parameters 

Operating parameters for air pollution 

control equipment are specified in 

Section 404 of the rule. 

Specific operating parameters will be 

specified in the permit to operate and 

will vary depending on the control 

technology selected. 

Work Practice 

Requirements 

Operating requirements for 

degreasers; Storage and disposal 

requirements for solvents. 

Operating requirements for degreasers; 

Storage and disposal requirements for 

solvents. 

Recordkeeping Recordkeeping of usage; 

recordkeeping for air pollution control 

equipment if used. 

Recordkeeping of usage and 

recordkeeping for air pollution control 

equipment. 

Monitoring/ 

Records 

Frequency Daily for exemptions and monthly for 

sources subject to the rule. Records 

are to be kept for five years. 

Daily records for air pollution control 

equipment; Monthly records for solvent 

usage. 

Test Methods Applicable test methods are specified 

under Section 502 of the rule. 

Applicable test methods are the same 

as those listed in Rule 454. 

Monitoring/ 

Testing 

Frequency No testing frequency is specified in the 

rule. 

Initial testing to verify system control 

efficiency; Annual testing thereafter. 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 65

Appendix A-5 

40727.2 Matrix for Proposed Amendments to Rule 456, Aerospace Assembly and 

Component Coating Operations 

Elements of 

Comparison 

Specific 

Provisions 

Proposed Rule 

456 

Aerospace 

Control 

Technology 

Guideline 

BACT/LAER Aerospace 

NESHAP 

Exemptions Less than 55 

gal/yr, aerosol 

containers <1 

liter, surface 

prep/clean for 

space vehicles 

and adhesive 

bonding; 

coatings applied 

via templates, 

stencil, stamp, or 

hand lettering; 

touch-up and 

repair coating 

operations and 

use of detail 

guns; application 

of coatings 

containing fillers 

adversely 

affecting 

atomization with 

HVLP spray 

guns; hand held 

spray containers 

less than or 

equal to 8 

ounces and total 

facility usage 

less than or 

equal to 10 

gal/yr 

Less than 200 

gal/yr, aerosol 

containers, 

space vehicles, 

cleanup of R & 

D, lab testing, 

rework 

operations 

 Certain waterreducible 

coatings, handheld spray 

application, 

essential use 

cleaning 

solvents 

Averaging 

Provisions 

 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 66

Elements of 

Comparison 

Specific 

Provisions 

Proposed Rule 

456 

Aerospace 

Control 

Technology 

Guideline 

BACT/LAER Aerospace 

NESHAP 

Units grams of 

VOC/liter (g/l) 

grams of 

VOC/liter (g/l) 

 

Surface prep 

and cleanup 

Cleaning/surface 

prep: VOC 

content limit of 

200 g/l; spray 

gun cleaning: 

VOC content 

limit of 25 g/l 

80% aqueous 

solvent or VOC 

with vapor 

pressure less 

than or equal to 

45 millimeters of 

mercury (mm 

Hg) at 20° C, or 

enclosed gun 

cleaner 

 Use of solvents 

less than 45 mm 

Hg at 20° C, or 

enclosed gun 

cleaner 

Stripping VOC content 

limit of 300 g/l 

 HAP strippers 

limited to 26 gal 

commercial, 50 

gal military per 

year 

Emissions 

Limits 

Compliance 

Alternatives 

85% overall 

system 

efficiency. 

VOC emissions 

capture and 

control 

equipment 

efficiency of at 

least 81% by 

weight 

 Carbon 

absorber, 

incineration, Hitransfer 

efficiency 

equipment to 

HVLP or 

electrostatic, 

spray booth 

vented to dry 

particle filter, 

waterwash hiefficiency 

particulate filter, 

stage II or III, 

particulate filter, 

capture and 

control of 81% 

Operating 

Parameters 

 

Work Practice 

Requirements 

All containers 

closed when not 

in use. VOC 

content available 

for all materials. 

All containers 

closed when not 

in use. Label all 

materials for 

VOC content. 

 Use of closed 

containers, other 

housekeeping 

measures 

Monitoring/ 

Records 

Recordkeeping List of materials 

with VOC 

contents, as 

applied, method 

of application, 

usage amounts, 

monitoring 

VOC content as 

applied, coating 

usage, aqueous 

and semiaqueous handwipe cleaning 

solvents- list 

 Continuous 

monitoring for 

pressure drop at 

filter unit. Name, 

vapor pressure, 

and 

documentation 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 67

Elements of 

Comparison 

Specific 

Provisions 

Proposed Rule 

456 

Aerospace 

Control 

Technology 

Guideline 

BACT/LAER Aerospace 

NESHAP 

parameters for 

control 

equipment 

materials with 

water contents, 

vapor pressure 

compliant handwipe cleaning 

solvents- list 

cleaning 

solvents and 

vapor pressures 

or, for blended 

solvents, VOC 

composite vapor 

pressures, 

exempt handwipe cleaning 

processes, 

monitoring 

parameters for 

control 

equipment 

for all HAP, 

solvents. 

Records of leaks 

from gun 

cleaners. VOC 

content of each 

VOC coating. 

Name, volume, 

and HAP content 

of all chemical 

strippers. Name, 

type of nonchemical 

equipment. 

Frequency Monthly for all; 

daily for noncompliant; 

records are to be 

kept for five 

years 

On annual basis Monthly for 

noncompliant, 

semi-annual for 

compliant 

coatings. 

Test Methods Applicable test 

methods are 

specified under 

Section 502 of 

the rule. 

VOC content: 

EPA Method 24 

Control 

Equipment: EPA 

method 18, 25, 

and/or 25A 

 Filtration 

Efficiency; 

Method 139, 

HAP and VOC 

content: Method 

24 

Carbon 

Absorption: 

Method 18 

Gas Analysis: 

Method 3 

Monitoring/ 

Testing 

Frequency As needed As needed As needed 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 68

Appendix A-6 

40727.2 Matrix for Proposed Amendments to Rule 463, Wood Products Coatings 

Elements of 

Comparison

Specific 

Provisions

Proposed Rule 463 BACT/LAER

Exemptions Usage less than 55 gal/yr; wood 

products coatings sold in nonrefillable aerosol containers; coating 

operations for the purpose of 

manufacturing a finished wood panel 

for attachment to inside walls of 

buildings; coating of architectural 

components or structures not coated 

in a shop environment 

a) touch-up coatings 

b) stencil coatings 

c) aerosol coating products 

d) emission limits not applicable if 

using approved emissions 

control system, operating 

under an alternative emission 

control plan, or using less than 

twelve pounds per day for 

educational purposes at a 

training center. 

Averaging 

Provisions 

Rolling 30-day averaging for a 

maximum of 20 gallons per year of 

historical reproduction coatings 

For emission control equipment, 

must reduce emissions to level that 

is equivalent or lower than limit 

specified in rule. 

Units % Control or lbs-VOC/gal or grams of 

VOC/liter as applied. 

3. Grams per liter less water and 

exempt compounds, or; 

4. Pounds per gallon less water 

and exempt compounds. 

Emission 

Reductions 

Meet the emission limits specified in 

Sections 300, or install emissions 

control equipment specified in 

Section 305 

Lower solvent content, higher 

transfer efficiency than required by 

applicable rules, and control 

equipment with overall 

capture/destruction efficiency of ≥

90% 

Emission Limits 

Compliance 

alternatives 

Air Pollution Control Equipment with 

equivalent or greater emission 

reduction than would result from 

compliance with VOC limits 

Air Pollution Control Equipment 

Operating 

Parameters 

 

Work Practice 

Requirements 

Closed containers for disposal of 

materials used for surface 

preparation, cleanup and coating 

removal; closed containers; cleanup 

to take place in an enclosed system. 

Closed containers for disposal of 

materials used for surface 

preparation, cleanup and coating 

removal; closed containers; 

cleanup to take place in an 

enclosed system. 

Recordkeeping Recordkeeping of usage; 

recordkeeping for air pollution control 

equipment if used. 

Daily records of operations for most 

recent two years; method 

application and substrate type; 

amount of coating used including 

exempt amounts; VOC content of 

each coating; amount of surface 

prep and cleanup material used; 

vapor pressure of solvents, where 

applicable. 

Monitoring/ 

Records 

Frequency Daily and/or monthly for coating 

usages. Records kept for a 

continuous five-year period. 

Daily records of coating usages 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 69

Elements of 

Comparison

Specific 

Provisions

Proposed Rule 463 BACT/LAER

Test Methods Applicable test methods are specified 

under Section 503 of the rule. 

Applicable EPA Methods 2 or 2C, 

18, 24, 25, 25A, 204, 204A, 204B, 

204C, 024D, 204E, 204F, ASTM D 

4457-85 or ARB method 432, 

ASTM Standard D2832, ASTM D 

4457-85, SCAQMD 318, and 

Sections 221, and 404 of the Rule. 

Monitoring/ 

Testing 

Frequency No frequency specified in the rule 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 70

Appendix A-7 

40727.2 Matrix for Proposed Amendments to Rule 464, Organic Chemical Manufacturing 

Operations 

Elements of 

Comparison 

Specific 

Provisions 

Proposed Rule 464 BACT/LAER 

Exemptions Equipment or operations with VOC 

emissions less than or equal to 15 

pounds per day; laboratory 

equipment solvent cleaning; solvent 

cleaning regulated by FDA with less 

than or equal to 15 pounds per day 

of VOC emissions 

Averaging 

Provisions 

 

Units 

Emissions 

Reduction 

90% control efficiency for VOC 

emissions exceeding 15 pounds per 

day 

Double bed type carbon adsorber 

(estimated control efficiency of 97%) 

Emissions Limits 

Compliance 

Alternatives 

90% overall control efficiency. 

Operating 

Parameters 

 

Work Practice 

Requirements 

 

Recordkeeping Daily recordkeeping is required for 

exempt equipment or operations 

emitting 15 pounds or less of VOCs 

per day. Daily recordkeeping is also 

required for cleanup solvent usage. 

Records are also required for 

source test results. 

Monitoring/Records 

Frequency Daily or annual (see above); records 

are to be kept for five years 

Test Methods Applicable test methods are 

specified under Section 502 of the 

rule. 

Monitoring/Testing 

Frequency Initial/annual as required by the 

APCO 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 71

Appendix A-8 

40727.2 Matrix for Proposed Amendments to Rule 465, Polyester Resin Operations 

Elements of 

Comparison 

Specific 

Provisions 

Proposed Rule 465 BACT/LAER 

Exemptions Polyester resin material usage less 

than 20 gallons per month 

10 lbs-VOC/day 

Averaging 

Provisions 

 None 

Units Lbs-VOC/gal or grams of VOC/liter Lbs-VOC/gal or grams of VOC/liter 

Emissions 

Reduction 

Meet the VOC limits in Sections 301 

and 303 or install air pollution 

control equipment 

If cost effective, vent to an afterburner 

(≥0.3 sec. retention time at ≥1400o

F) or 

an activated carbon adsorption system 

(≥6 ppm at outlet) (*)

Emissions Limits 

Compliance 

Alternatives 

90% overall efficiency Reduce VOC emissions by add on air 

pollution control equipment and meet 

certain control and collection efficiency 

(generally >95%). 

Operating 

Parameters 

Operating parameters for air 

pollution control equipment are 

specified in Section 405 of the rule. 

Store solvents in closed containers; Use 

of rags to clean parts and use of a rag 

washing machine with solvent 

reclamation system; Use of enclosed 

cleaning system. 

Work Practice 

Requirements 

Application equipment 

requirements; Storage and disposal 

requirements; surface preparation 

and cleanup requirements. 

Application equipment requirements; 

Storage and disposal requirements; 

surface preparation and cleanup 

requirements. 

Recordkeeping Recordkeeping of usage; 

recordkeeping for air pollution 

control equipment if installed. 

Recordkeeping of usage and 

recordkeeping for air pollution control 

equipment. 

Monitoring/Records 

Frequency Daily for exemptions and monthly 

for sources subject to the rule. 

Records are to be kept for five 

years. 

Daily records for air pollution control 

equipment; Monthly records for solvent 

usage. 

Test Methods Applicable test methods are 

specified under Section 502 of the 

rule. 

Applicable test methods are the same as 

those listed in Rule 465. 

Monitoring/Testing 

Frequency No testing frequency is specified in 

the rule. However, source testing 

Will be required for initial 

compliance verification if air 

pollution control equipment is 

installed Testing frequency 

thereafter will be specified based on 

need. 

Initial testing to verify system control 

efficiency; Annual testing thereafter. 

(*) Based on BACT adopted by the Bay Area Air Quality Management District, BACT/TBACT Workbook – Guidelines for Best 

Available Control Technology. 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 72

Appendix A-9 

40727.2 Matrix for Proposed Amendments to Rule 466, Solvent Cleaning 

Elements of 

Comparison 

Specific 

Provisions 

Proposed Rule 466 BACT/LAER 

Exemptions Cleaning operations using cleanup 

materials containing less than 25 

grams per liter VOCs; Cleanup 

operations specifically regulated 

under other prohibitory rules; Other 

exemptions specific to District are 

specified in Section 110 of the rule. 

10 lbs-VOC/day 

Averaging 

Provisions 

None None 

Units Lbs-VOC/gal or grams of VOC/liter Lbs-VOC/gal or grams of VOC/liter 

Emissions 

Reduction 

Meet the VOC limits in Section 300 

or install air pollution control 

equipment 

Use of solvents for general cleanup with 

VOC limit less than 50 grams per liter; 

Use of air pollution control device such as 

after burner, carbon adsorption system; 

use of exempt solvent such as acetone. 

Emissions Limits 

Compliance 

Alternatives 

95% control efficiency and 90% 

collection efficiency, and emissions 

must not be greater than would 

have resulted from compliance with 

applicable VOC limits 

Reduce VOC emissions by add on air 

pollution control equipment and meet 

certain control and collection efficiency 

(generally >95%). 

Operating 

Parameters 

Operating parameters for air 

pollution control equipment are 

specified in Section 405 of the rule. 

Store solvents in closed containers; Use 

of rags to clean parts and use of a rag 

washing machine with solvent 

reclamation system; Use of enclosed 

cleaning system. 

Work Practice 

Requirements 

Application equipment 

requirements; Storage and disposal 

requirements; surface preparation 

and cleanup requirements. 

Application equipment requirements; 

Storage and disposal requirements; 

surface preparation and cleanup 

requirements. 

Recordkeeping Recordkeeping of usage; 

recordkeeping for air pollution 

control equipment if installed. 

Recordkeeping of usage and 

recordkeeping for air pollution control 

equipment. 

Monitoring/Records 

Frequency Daily for exemptions and monthly 

for sources subject to the rule. 

Records are to be kept for five 

years. 

Daily records for air pollution control 

equipment; Monthly records for solvent 

usage. 

Monitoring/Testing Test Methods Applicable test methods are 

specified under Section 502 of the 

rule. 

Applicable test methods are the same as 

those listed in Rule 466. 
Appendix A 

Rule Consistency Matrices 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 73

Elements of 

Comparison 

Specific 

Provisions 

Proposed Rule 466 BACT/LAER 

Frequency No testing frequency is specified in 

the rule. However, source testing 

Will be required for initial 

compliance verification if air 

pollution control equipment is 

installed Testing frequency 

thereafter will be specified based on 

need. 

Initial testing to verify system control 

efficiency; Annual testing thereafter. 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 74

Appendix B 

Summary of Changes 

Rule 450, Graphic Arts Operations 

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

101-102 Same Updated references to renumbered sections. 

110.1 Same Removed paragraph (a) that is no longer applicable because it has expired.

110.2 NA Removed this section because it has expired. 

110.3-

110.6 

110.2-

110.5 

Sections renumbered. 

110.7 110.6 For clarification, revised the language to specify that this exemption is 

applicable to aerosol adhesives used by graphic arts operations “other than 

screen printing.” Consistent with original intent of this section as 

documented in the staff report for the 3/23/00 amendment of Rule 450. 

Added requirement that aerosol adhesives that are exempt from Rule 450 

under this section shall comply with the limits of Rule 460, Adhesives and 

Sealants (consistent with new section number 110.5). 

NA 110.7 Added an exemption for materials used to strip cured inks, cured coatings, 

or cured adhesives, consistent with SCAQMD Rule 1171. This exemption 

was already implied in the definition of Solvent Cleaning, but this new 

section has been added for clarification. 

NA 110.8 Added an exemption from the requirements of Sections 302.2, 501.3(b)(2), 

and 501.3(b)(5) for presses that use solvents containing 100 g/l VOC or 

less to clean metering rollers and printing plates. The reason for this 

exemption is that it is not necessary to restrict the usage of such solvents 

to 15% of the usage of blanket and roller washes if such solvents meet 

VOC limits as stringent as those for blanket and roller washes. 

NA 110.9 Added an exemption from the future requirements of Section 301.2 for 

fountain solutions used in an offset lithographic printing operation with 

actual emissions less than or equal to 450 pounds of VOC per month. This 

exemption fulfills the recommendations specified in the 2006 EPA Control 

Techniques Guidelines for Lithographic and Letterpress Printing. 

NA 110.10 Added an exemption from the requirements of Section 303.1 for heatset 

web offset lithographic presses and heatset web letterpress presses with 

potential to emit from the dryer less than 25 tons of VOC per year, prior to 

controls. This exemption fulfills the recommendations specified in the 2006 

EPA Control Techniques Guidelines for Lithographic and Letterpress 

Printing. 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 75

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

Added an exemption from the requirements of Section 303.1 for heatset 

web offset lithographic presses and heatset web letterpress presses used 

for book printing and for presses with maximum web width of 22 inches or 

less. This exemption fulfills the recommendations specified in the 2006 

EPA Control Techniques Guidelines for Lithographic and Letterpress 

Printing. 

Added rule language clarifying that if actual emissions prior to control 

equipment are at least 25 tons per year of VOC per rolling 12-month 

period, then that unit must comply with Section 303.1 and cannot use the 

exemptions in this section. This is a “once in, always in” requirement. 

NA 110.11 Added an exemption from the requirements of Section 303.2 for inks, 

coatings, and adhesives used in a flexible package printing press with 

potential to emit from the dryer less than 25 tons of VOC per year, prior to 

controls. This exemption fulfills the recommendations specified in the 2006 

EPA Control Techniques Guidelines for Lithographic and Letterpress 

Printing. 

Added rule language clarifying that if actual emissions prior to control 

equipment are at least 25 tons per year of VOC per rolling 12-month 

period, then that unit must comply with Section 303.1 and cannot use the 

exemption in this section. This is a “once in, always in” requirement. 

NA 210 For clarification, added a definition for cured ink, cured coating, or cured 

adhesive. This definition is consistent with SCAQMD Rule 1171. 

210 211 Section renumbered. 

NA 212 Added a definition for “electron beam ink.” This definition is the same as 

the definition used in SCAQMD Rule 1171. 

211-217 213-219 Sections renumbered. 

218 220 Corrected grammatical error. 

219-226 221-228 Sections renumbered. 

227 NA Removed the definition for “Lithographic and Letter Press Printing, Other 

Cleaning.” For clarification, references in the rule to “Other Cleaning” have 

been replaced with “cleaning of metering rollers and printing plates,” 

consistent with this former definition. 

228-231 229-232 Sections renumbered. 

232 233 Clarified that metering rollers transfer and meter fountain solution, not just 

water. 

NA 234 Added a definition for “Newsprint.” This definition is the same as the 

definition used in SCAQMD Rule 1171. 

233-236 235-238 Sections renumbered. 

NA 239 Added a definition for “Other On-Press Component.” This definition is the 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 76

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

same as the definition of “On-Press Component” used in SCAQMD Rule 

1171, but excludes blankets, rollers, metering rollers, and printing plates, 

which have different current limits. 

237 240 Sections renumbered. 

NA 241 Added a definition for “Potential to Emit.” This definition is the same as the 

definition used in Rule 202 – NEW SOURCE REVIEW. 

238-242 242-246 Sections renumbered. 

NA 247 Added a definition for “Removable Press Component.” This definition is 

the same as the definition used in SCAQMD Rule 1171. 

243-248 248-253 Sections renumbered. 

NA 254 For clarification, defined “Stripping” as the removal of cured inks, cured 

coatings, or cured adhesives, consistent with SCAQMD Rule 1171. 

249-259 255-265 Sections renumbered. 

301 Same Removed from the tables the limits that have expired. 

301.2 Same Revised the table to include more subcategories for chilled and non-chilled 

fountain solutions, and include more stringent VOC limits. The future limits 

fulfill the recommendations specified in the 2006 EPA Control Techniques 

Guidelines for Lithographic and Letterpress Printing. 

NA 301.4 Added a section prohibiting the use of fountain solutions containing alcohol 

on coldest web offset lithographic presses, consistent with the 

recommendations specified in the 2006 EPA Control Techniques 

Guidelines for Lithographic and Letterpress Printing. 

302.1 Same Revised the text to clarify that composite partial vapor pressure standards 

will no longer be in effect after new, more stringent VOC content limits take 

effect. 

Revised the table to include more stringent VOC limits for cleaning 

materials. The future limits are consistent with SCAQMD Rule 1171. 

Most new limits will take effect one year after the date of adoption; 

however, the new limits for the following categories have been delayed 

until 1/1/2011 to allow sufficient time for successful implementation in 

SCAQMD first: 

• Blanket and roller washes, cleaning of metering rollers and printing 

plates, and cleaning of other on-press components used in 

lithographic and letter press printing on substrates other than 

newsprint; 

• Screen printing; and 

• Ultraviolet/electron beam inks (interim limit to take effect one year 

after date of adoption; final limit to take effect 1/1/2011). 

Divided Lithographic and Letter Press Printing into two substrate groups 

(Newsprint, and Substrates other than Newsprint) to allow for different 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 77

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

effective dates, consistent with SCAQMD Rule 1171. 

Eliminated Lithographic and Letter Press Printing, Other Cleaning, and 

replaced with Metering Rollers and Printing Plates, consistent with former 

definition. 

Added new categories for Other On-Press Components and Removable 

Press Components, previously included under General cleaning, for 

clarification. These categories will ultimately be subject to different limits. 

302.2 Same Updated text to reflect the elimination of the definition of “Other Cleaning”, 

and replaced with “Cleaning of Metering Rollers and Printing Plates,” 

consistent with previous definition. Added a sunset date for this section so 

that it expires on 1/1/2011. After that date, the limits for cleaning metering 

rollers and printing plates will be at least as stringent as the limits for 

Blanket and Roller Washes; therefore, restricting the monthly usage of 

these cleaning materials to 15% will no longer be necessary. Added 

reference to exemption of Section 110.8. 

NA 303 Added requirements for mandatory control equipment for heatset web 

offset lithographic printing, heatset web letterpress printing, and flexible 

package printing. The revised emissions control equipment requirements 

are specified in new Sections 303.1—303.3 and are effective on the date of 

adoption. 

Added a section providing an alternative to compliance with the overall 

system efficiency requirements specified in Section 303.1. In lieu of 

complying with the overall efficiency requirements, sources are required to 

use emissions control equipment with mass outlet concentration no greater 

than 20 ppmv as hexane on a dry basis. 

The above requirements fulfill the recommendations specified in the 2006 

EPA Control Techniques Guidelines. 

303 304 Updated to reflect renumbered section, and clarified that this section 

applies to alternative control equipment. The current rule specifies 

separate efficiency level requirements for the control device and emission 

collection. The proposed rule specifies a combined overall system 

efficiency requirement rather than separate capture and control efficiency 

requirements. 

402.4 Same Revised so that sellers will not be required to display composite partial 

pressure after 1/1/2011, because after this date, there will no longer be any 

standards for composite partial pressure in effect. 

403 Same Updated ASTM method numbers to the most current versions. 

407 406 Removed the reference to deleted section 110.2. 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 78

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

NA 408 Added section specifying calculation method for determining overall system 

efficiency of emissions control equipment, consistent with the method 

stated in other District rules. 

501.1 Same Removed the reference to deleted section 110.2. Updated references to 

renumbered sections. 

501.3 Same Updated references to renumbered sections. Added a requirement to 

paragraph (b)(1) to differentiate between materials used for printing on 

newsprint and materials used for printing on other substrates until 1/1/2011 

(when the standards will be the same for all substrates). Clarified that 

presses exempt pursuant to Section 110.8 will not be required to maintain 

separate usage records for materials used for printing on newsprint and 

non-newsprint substrates. 

Updated text in paragraph (b)(4) to replace “Lithographic and Letter Press 

Printing, Other Cleaning” with “metering rollers and printing plates,” 

consistent with former definition. Added a sunset date for this paragraph 

so that it expires on 1/1/2011. Added reference to exemption of Section 

110.8. 

502 Same Updated ASTM method numbers to the most current, EPA-approved 

versions. Updated references to renumbered sections. Corrected 

typographical errors. 

NA 502.9 To clarify enforceability, added paragraph stating that where multiple test 

methods are specified, a violation established by any one of the test 

methods constitutes a violation of the rule. 

Rule 451, Surface Coating of Miscellaneous Metal Parts and Products 

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

110.1 110 Section renumbered, and updated to reflect new paragraphs added to 

section 305. 

110.2 NA Section deleted. The 200 gallon/year exemption for aluminum coatings on 

window and door frames is no longer necessary. Records indicate that the 

general 55 gallon/year exemption is sufficient for applicable District 

sources, and is consistent with the EPA Region IX “Little Bluebook.” 

110.3 NA Section deleted. The 200 gallon/year exemption for pretreatment wash 

primer is no longer necessary. Records indicate that the general 55 

gallon/year exemption is sufficient for applicable District sources, and is 

consistent with the EPA Region IX “Little Bluebook.” 

111 Same Moved the exemptions in Sections 111.6, 111.7, 111.8, and 111.10 into the 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 79

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

new Section 112. Clarified that the conformal coatings are regulated under 

Rule 456- Aerospace Assembly and Component Coating Operations. 

Removed rule language requiring operations and coatings exempted under 

the remaining exemptions in this section to comply with Section 501. The 

remaining exemptions pertain to operations and coatings subject to other 

District rules. Therefore, Section 501 in the other District rules should 

apply to such operations and coatings, rather than Section 501 under Rule 

451. 

NA 112 Moved the exemptions in Sections 111.6, 111.7, 111.8, and 111.10 into 

this new section in order to require these operations and coatings to 

comply with the storage, disposal, and recordkeeping requirements. 

Clarified that only coatings applied exclusively by hand lettering are 

exempt. 

112-113 113-114 Sections renumbered. 

NA 115 Added an exemption for coatings on metal furniture. Such coating 

operations emitting less than 3 tons of VOC per 12-month rolling period are 

subject to the requirements of Section 301 (pertaining to miscellaneous 

metal parts and products coatings) rather than Section 302 (pertaining to 

metal furniture coatings). This exemption is consistent with the 

recommendations in the 2007 EPA Control Techniques Guidelines. 

NA 216 Added a definition for “electrostatic spray.” This definition is the same as 

the definition used in Shasta County AQMD Rule 3:13- Polyester Resin 

Operations. 

216-227 217-228 Sections renumbered. 

NA 229 Added a definition for “metal furniture.” This definition is consistent with the 

definition specified in the 2007 CTG for Metal Furniture Coatings. 

228-229 230-231 Sections renumbered. 

NA 232 Added a definition for “multi-component coating.” This definition is 

consistent with the definition used in SCAQMD Rule 1107- Coating of 

Metal Parts and Products. 

230 233 Updated to reflect the new paragraphs added to section 305. 

231 234 Section renumbered. 

232-246 235-249 Sections renumbered. 

301 Same Removed the expired VOC limits from the table. Clarified that the VOC 

content limits apply to materials “as applied.” 

NA 302 Established separate VOC limits for metal furniture coating operations 

emitting greater than or equal to 3 tons of VOC per 12-month rolling period 

from such operations, to be consistent with the recommendations specified 

in the 2007 CTG for Metal Furniture Coatings. Metal furniture coating 

operations emitting less than 3 tons of VOC per 12-month rolling period 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 80

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

remain subject to Section 301. 

302 303 Removed the past effective date. 

303.9 304.8 Section renumbered to correct previous error in numbering. 

304 305 Added a sunset date for the current standard for solvents used in the 

cleanup of application equipment in miscellaneous metal parts and 

products coating operations, and lowered the VOC limit to 25 g/l. Added a 

sunset date for the provision that allows application equipment to be 

cleaned in an enclosed gun cleaner in lieu of complying with the VOC limit. 

Added a sunset date for the exception for electrostatic spray guns. 

Changes are consistent with SCAQMD Rule 1171- Solvent Cleaning 

Operations, in (c)(1)(B)(i). 

Added a sunset date for the provision that allows the soaking of spray gun 

nozzles in solvents without a limit on VOC content. After the sunset date, 

spray gun nozzles are subject to the same requirements as other 

application equipment, consistent with SCAQMD Rule 1171. 

Added a sunset date for the current standard for solvents used in product 

cleaning or surface preparation, and lowered the VOC limit to 25 g/l. This 

limit is consistent with SCAQMD Rule 1171- Solvent Cleaning Operations, 

in (c)(1)(A)(i). 

Added additional work practice requirements for use of closed containers 

for disposal of cloth, paper or sponges used for coating application; 

minimizing spillage of VOC-containing materials; and for conveyance of 

VOC-containing materials using closed containers or pipes. These 

requirements are be consistent with the 2007 CTG for Metal Furniture 

Coatings and the 2008 EPA Draft CTG for Miscellaneous Metal and Plastic 

Parts Coatings (dated July 3. 2008). 

305 306 Updated to reflect the new paragraphs added to section 305. Increased 

the required overall emissions control efficiency from 85% to 90%, 

consistent with the recommendations in the 2007 CTG for Metal Furniture 

Coatings 

401 Same Removed the past effective date and updated to reflect new paragraphs 

added to section 305. 

405 Same Corrected previous typographical error in equation for calculating control 

efficiency. 

406 Same Corrected previous typographical errors in text and in equation for 

calculating overall system efficiency. 

407 Same Updated to reflect the new paragraphs added to section 305. 

501 Same Updated to include the new exemption Section 112. As discussed earlier, 

several exemptions in Section 111 in the current rule have been moved 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 81

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

into new Section 112 in order to require such operations and coatings to 

comply with the rule requirements for storage, disposal, and recordkeeping 

(this section). 

501.1 Same Corrected typographical error and updated to reflect the new paragraphs 

added to section 305. 

501.3 Same Updated to reflect the new paragraphs added to section 305. 

501.5 Same Added a sunset date for the current requirement for duration of records. 

Revised the requirement for duration of records to five years. This is 

consistent with other District rules. 

502 Same Updated ASTM method numbers to the most current versions. 

502.3 Same Updated to incorporate most recent U.S. EPA guidelines on determining 

capture efficiency. 

NA 502.7 To clarify enforceability, added paragraph stating that where multiple test 

methods are specified, a violation established by any one of the test 

methods constitutes a violation of the rule. 

Rule 452, Can Coating 

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

NA 102 Added an applicability section to this rule, consistent with other District 

rules. 

NA 103 Added a severability section to this rule, consistent with other District rules. 

NA 203 Added a definition for “dip coat.” This definition is the same as the 

definition used in other District rules. 

NA 204 Added a definition for “electrostatic spray.” This definition is the same as 

the definition used in Shasta County AQMD Rule 3:13- Polyester Resin 

Operations. 

203-205 205-207 Sections renumbered. 

NA 208 Added a definition for “flow coat.” This definition is the same as the 

definition used in other District rules. 

NA 209 Added a definition for “food/beverage can.” This definition is the same as 

the definition used in SCAQMD Rule 1125- Metal Container, Closure, and 

Coil Coating Operations. 

NA 210 Added a definition for “hand application equipment.” This definition is the 

same as the definition used in other District rules. 

NA 211 Added a definition for “high-volume low-pressure application equipment.” 

This definition is the same as the definition used in other District rules. 

206-207 212-213 Sections renumbered. 

NA 214 Added a definition for “low-volume low-pressure application equipment.” 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 82

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

This definition is the same as the definition used in other District rules. 

208 215 Section renumbered. 

NA 216 Added a definition for “roll coater.” This definition is the same as the 

definition used in other District rules. 

209-211 217-219 Sections renumbered. 

301 Same Lowered VOC limits for three piece can interior body spray and two piece 

can interior body spray to be consistent with the limits in BAAQMD Rule 8-

11 and SJVAPCD Rule 4604. 

Separated the end sealing compound category into “end sealing compound 

for food/beverage cans” and “end sealing compound for non-food 

containers,” and established VOC limits that are lower than the current 

VOC limit for end sealing compound. The proposed VOC limits for the two 

subcategories are consistent with the more stringent, feasible limits in 

SCAQMD Rule 1125. 

302 Same Increased emissions control efficiency requirement to be consistent with 

the requirements in BAAQMD Rule 8-11 and SJVAPCD Rule 4604. Added 

an equation for the calculation of the allowable daily emissions from 

emissions control equipment and from compliance with the VOC limits. 

303 Same Added a sunset date to the current VOC limit for cleanup of container 

assembly equipment, and removed the expired effective date. Revised the 

VOC limit for the cleanup of container assembly equipment to 25 g/l. This 

is now consistent with SCAQMD Rule 1171- Solvent Cleaning Operations, 

in (c)(1)(B)(i). 

NA 304 Added a section for application equipment requirements. These 

requirements are the same as the requirements in other District coating 

rules, with an additional option to use an add-on control device with an 

overall system efficiency of 85.5% (equivalent to 90% capture efficiency 

and 95% control efficiency). 

NA 403 Added a section for the calculation of VOC content of cleanup material, 

consistent with other District rules. 

NA 404 Added a section for the calculation of percent control efficiency and VOC 

mass emission rate, consistent with other District rules. Specified EPA 

Method 25A as an allowed method of determining VOC mass 

concentration to be consistent with other District rules. 

NA 405 Added a section for calculation for determining overall system efficiency. 

This calculation is the same as the calculation in other District rules. 

501.1 Same Added a reference to new section 403, which specifies the procedure for 

calculating VOC content of cleanup material. 

501.2 Same Added a reference to new section 404, which specifies the procedure for 

calculating the percent control efficiency. 

501.3 Same Revised the test methods for determining capture efficiency to be 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 83

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

consistent with other District rules. Specified EPA Method 25A as an 

allowed method of determining control efficiency and emission rates from 

control devices to be consistent with other District rules. 

501.4 Same Updated ASTM method number to the most current version. 

NA 501.5 To clarify enforceability, added paragraph stating that where multiple test 

methods are specified, a violation established by any one of the test 

methods constitutes a violation of the rule. 

504 Same Added a sunset date for the current requirement for duration of records. 

Revised the requirement for duration of records to five years. This is 

consistent with other District rules. 

Rule 454, Degreasing Operations 

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

110.2 NA Removed this section because it has since expired. 

110.3 110.2 Added a sunset date for the current exemption. 

NA 110.3 Revised the exemption to 25 grams per liter or less VOCs for solvents used 

in degreasers. This is consistent with SCAQMD Rule 1122, Solvent 

Degreasers, in (d). 

110.5 NA Removed this section because it duplicated the exemption in previous 

section 110.3, which is being sunset. 

110.6 110.5 Added a sunset date for the current exemption, which will make degreasers 

that are subject to the NESHAP also subject to the requirements of this 

rule, including VOC content limits. The NESHAP does not regulate VOC 

content. 

110.7 NA Removed this section because it has since expired. 

110.8 110.6 Section renumbered. 

110.9 110.7 Updated to reflect the new paragraph added to section 302 and 

renumbering of Rule 456. 

NA 110.8 Added an exemption for the degreasing of high-voltage microwave vacuum 

tubes because compliance with the degreasing VOC limit is not 

technologically feasible. 

215 Same Clarified the definition of non-vapor degreaser to emphasize that the 

definition includes remote reservoir degreasers. 

NA 226 Added a definition for “water separator.” This definition is the same as the 

definition used in SCAQMD Rule 1122. 

226-227 227-228 Sections renumbered. 

301 Same Deleted text that was unnecessary because the term “degreaser” already 

includes “remote reservoir degreaser.” 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 84

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

302 Same Clarified to emphasize that non-vapor degreasers are also subject to the 

requirements of Section 301. 

302.1 Same Removed the reference to Section 110.2 because this section has since 

expired. Removed “including remote reservoir degreasers” because the 

definition of “non-vapor degreasers” already includes remote reservoir 

degreasers. 

Corrected the typographical error to now read “b” instead of “d.” 

302.2 Same Added a sunset date for the current VOC limit for solvents used in nonvapor degreasers. 

NA 302.3 Revised the VOC limit for solvents used in non-vapor degreasers. 

Solvents used in non-vapor degreasers must have a VOC content of 25 g/l 

or less. This is consistent with SCAQMD Rule 1122, Solvent Degreasers, 

in (d). 

303 Same Corrected typographical error. 

304 Same Corrected grammatical error. 

304.1 NA Removed this section because it has since expired. 

304.2 304.1 Removed the effective date, which has passed. Corrected grammatical 

error. 

304.3 304.2 Updated to reflect renumbered section. 

NA 304.3 Added a new VOC limit for vapor degreasing operations. Solvents used in 

vapor degreasers must have a VOC content of 25 g/l or less. This is 

consistent with SCAQMD Rule 1122, Solvent Degreasers, in (e)(3). 

305 Same Removed the effective date, which has passed. Clarified to emphasize that 

remote reservoir degreasers are also subject to the requirements of 

Sections 301 and 302. 

309 Same Added emissions control equipment requirements to the requirements for 

lip exhaust system. After the sunset date for Section 310, emissions 

control equipment will no longer be allowed as an alternative to Sections 

302, 304, and 307 (see discussion of Section 310 below), but will still be 

allowed for venting emissions from a lip exhaust system. 

310 Same Added a sunset date for the provision allowing the use of emissions control 

equipment in lieu of compliance with the equipment requirements for 

degreasing operations. After the sunset date, the use of an emission 

control device as specified in this section would no longer ensure emission 

reductions that are equivalent to compliance with the other sections of the 

rule, which will require the use of solvents containing no more than 25 g/l 

VOC or the use of an airtight/airless system. Change is consistent with 

SCAQMD Rule 1122, Solvent Degreasers. 

401 Same Corrected typographical error. 

501.5 501.4 Corrected the typographical error to now read 501.4 instead of 501.5. 

Added a sunset date for the current requirement for duration of records. 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 85

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

Revised the requirement for duration of records to five years. This is 

consistent with other District rules. 

502 Same Updated ASTM method numbers to the most current versions. 

502.3 Same Reworded to be consistent with other District rules. No change in meaning.

NA 502.8 To clarify enforceability, added paragraph stating that where multiple test 

methods are specified, a violation established by any one of the test 

methods constitutes a violation of the rule. 

Rule 456, Aerospace Assembly and Component Coating Operations 

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

110 Same Effective 1/1/09, the low usage exemption will be lowered from 200 gallons 

per year to 55 gallons per year. Records indicate that the 55 gallons per 

year exemption is sufficient for applicable District sources, and is 

consistent with the EPA Region IX “Little Bluebook.” 

113 Same Updated to reflect renumbering of Section 304.5 to 304.6. 

NA 219 Added a definition for “electrostatic spray.” This definition is the same as 

the definition used in Shasta County AQMD Rule 3:13- Polyester Resin 

Operations. 

219-232 220-233 Sections renumbered. 

NA 234 Defined Material as any coating, coating remover, or solvent. 

233-234 235-236 Sections renumbered. 

235 237 Revised to clarify that non-compliant materials include adhesives, 

maskants, and strippers as well as coatings. 

236-262 238-264 Sections renumbered. 

301 Same Removed the past effective date. Clarified that the VOC limits are as 

applied. 

302 Same Removed the past effective date. 

304 Same Added a sunset date for current standard for cleaning of spray guns used 

in coating operations. Added a VOC limit of 25 g/l for cleaning of 

application equipment, effective one year after adoption date. This 

proposed provision applies to all application equipment, not just spray 

guns. An enclosed gun cleaner may still be used in lieu of complying with 

the 25 g/l limit, until two years after adoption date, when the VOC limit is 

applicable regardless of whether an enclosed gun cleaner is used. (This 

extension was added in response to a comment from an aerospace coating 

source, to allow sufficient time to test and requalify substitute solvents.) 

Eventual requirements (VOC limit without enclosed gun cleaner option) are 

consistent with SCAQMD Rule 1171- Solvent Cleaning Operations, in 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 86

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

(c)(1)(C). 

Added a sunset date for the provision that allows the soaking of spray gun 

nozzles in solvents without a limit on VOC content. After the sunset date, 

spray gun nozzles are subject to the same requirements as other 

application equipment, consistent with SCAQMD Rule 1171. 

Removed the past effective date. 

401 Same Removed the past effective date and clarified that non-compliant materials 

include adhesives, maskants, and strippers as well as coatings. 

406 Same Updated ASTM test method numbers to the most current versions. 

407 Same Corrected the typographical error in the equation for percent control 

efficiency. 

408 Same Corrected the typographical error in the equation for overall system 

efficiency 

501.5 Same Added a sunset date for the current requirement for duration of records. 

Revised the requirement for duration of records to five years. This is 

consistent with other District rules. 

502 Same Updated ASTM method numbers to the most current versions. 

502.5 Same Updated to incorporate most recent U.S. EPA guidelines on determining 

capture efficiency. 

NA 502.8 To clarify enforceability, added paragraph stating that where multiple test 

methods are specified, a violation established by any one of the test 

methods constitutes a violation of the rule. 

Rule 463, Wood Products Coatings 

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

NA 103 Added a severability section to this rule, consistent with other District rules. 

110.4 Same Clarified that coating of architectural components or structures not coated 

in a shop environment is subject to Rule 442- Architectural Coatings. 

110.5 NA Removed exemption pertaining to stencil coatings used to comply with U.S. 

Military Specifications. The facility that used this exemption is no longer in 

operation. 

210 Same Replaced the term “self sealing” with “combined sealer/topcoat” to clarify 

that conversion varnish is not subject to the VOC limit for sealers when 

used as a combined sealer/topcoat system. Removed the past effective 

date. 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 87

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

NA 220 Added a definition for “historical reproduction coating.” This definition limits 

the applicability of the emissions averaging provision specified in Section 

306.1 to a wood coating facility in Sacramento County. This facility, the 

only source in Sacramento County currently using the emissions averaging 

provision in the current Rule 463, will be allowed to continue to use the 

provision for the restoration of antique wood products to a historically 

accurate finish. 

220-222 221-223 Sections renumbered. 

NA 224 Added a definition for “major stationary source of VOC.” This definition 

was extracted from Rule 207, TITLE V – FEDERAL OPERATING PERMIT 

PROGRAM. 

223-242 225-244 Sections renumbered. 

301 Same Removed the past effective date. 

302 Same Clarified that the VOC limits are as applied. 

302.2 Same Revised the language to clarify that “VOC limits expressed in grams per 

liter shall be used” if emissions averaging is used to achieve rule 

compliance for low-solids stains, toners, and washcoats. 

Clarified that the VOC limit for conversion varnish is applicable “when used 

as a combined sealer/topcoat system.” Previously, this information could 

be found only in Section 210. 

Removed the expired VOC limits and the past effective date for the current 

VOC limits. 

Corrected typographical error to include correct units for low-solid stains, 

toners, and washcoats. 

302.3 NA Removed this section because it shouldn’t have applied after 7/1/05, but 

was never sunset. 

303.2 Same Revised the rule language to clarify that “VOC limits expressed in grams 

per liter shall be used” if emissions averaging is used to achieve rule 

compliance for low-solids stains, toners, and washcoats. 

Removed the past effective date for the current VOC limits. 

Corrected typographical errors, including correct units for low-solid stains, 

toners, and washcoats. 

304 Same Removed the past effective date. 

306 Same Revised the emissions averaging provision to limit its applicability to 

historical reproduction coatings only and not for a major stationary source, 

and to limit the usage of these coatings to 20 gallons per year per facility. 

These changes are proposed to address EPA comments concerning the 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 88

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

approvability of the averaging provision. 

Removed the section that is no longer applicable because it has since 

expired. Revised the equation for determining compliance with emissions 

limits for coatings for consistency with the expiration of the 0.9 multiplier. 

Added paragraph 306.2 to specify that if a stationary source does not 

satisfy the requirement to demonstrate compliance with the averaging 

provision at any time during a rolling 30-day period, the stationary source 

has exceeded the allowable emissions on every day of the rolling 30-day 

period. 

308 Same Added a sunset date for the provision that allows the soaking of spray gun 

nozzles in solvents without a limit on VOC content. After the sunset date, 

spray gun nozzles are subject to the same requirements as other 

application equipment, consistent with SCAQMD Rule 1171. 

Removed the past effective dates. Added a sunset date for the surface 

preparation/cleanup requirement that spray equipment must be 

disassembled and cleaned in an enclosed gun cleaner. After the sunset 

date, the rule no longer requires spray equipment cleanup to be performed 

using an enclosed gun cleaner, but still requires compliance with the 

proposed VOC limit for surface preparation and cleanup, consistent with 

SCAQMD Rule 1171. 

Added a sunset date for current VOC limit for surface preparation and 

cleanup with a VOC material. Added a new VOC limit for surface 

preparation and cleanup with a VOC material. This new limit is consistent 

with SCAQMD Rule 1171- Solvent Cleaning Operations, in (c)(1)(A)(i). 

401 Same Removed the past effective date. 

407 NA Removed this section because it has since expired. 

501.1 Same Inserted missing label for paragraph c. 

502 Same Added a sunset date for the current requirement for duration of records. 

Revised the requirement for duration of records to five years. This is 

consistent with other District rules. 

503 Same Updated ASTM method numbers to the most current versions. 

503.4 Same Reworded to be consistent with other District rules. No change in meaning.

NA 503.8 To clarify enforceability, added paragraph stating that where multiple test 

methods are specified, a violation established by any one of the test 

methods constitutes a violation of the rule. 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 89

Rule 464, Organic Chemical Manufacturing Operations 

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

110-113 Same Updated to reflect section 400 renumbering. 

115 Same Updated to reflect new paragraph added to section 308. 

301-304 Same Updated to reflect section 400 renumbering. 

305 Same Updated to reflect section 400 renumbering, and removed past effective 

dates. 

306-307 Same Updated to reflect section 400 renumbering. 

308 Same Added sunset date for current VOC limit for maintenance solvent cleaning. 

Lowered the VOC limit for maintenance solvent cleaning to 25 g/l. This 

new limit is consistent with SCAQMD Rule 1171- Solvent Cleaning 

Operations, in (c)(1)(B)(i). 

401 NA Deleted section because the compliance date has passed. 

402-413 401-412 Sections renumbered, and text updated to reflect renumbered sections. 

407 406 Updated ASTM method numbers to the most current versions. 

501.1 Same Updated to reflect section 400 renumbering. 

501.3 Same Updated to reflect section 400 renumbering. 

501.4-

501.7 

Same Added rule language to require sources to keep records of the VOC 

content of materials used. Sources already keep these records, but the 

added rule language clarifies this requirement. 

502.2 Same Changed “capture efficiency” to “collection efficiency” to maintain 

consistency with other sections of this rule. Reworded to be consistent 

with other District rules. No change in meaning. 

502.4 Same Updated ASTM method number to the most current version. 

NA 502.6 To clarify enforceability, added paragraph stating that where multiple test 

methods are specified, a violation established by any one of the test 

methods constitutes a violation of the rule. 

Rule 465, Polyester Resin Operations 

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

104 Same Added a sunset date for the current exemption for cleaning materials. This 

is consistent with SCAQMD Rule 1171- Solvent Cleaning Operations, 

which does not contain such an exemption. 

301 Same Increased overall control efficiency requirements to 90%, consistent with 

the requirements in SCAQMD Rule 1162. 

303 Same Added a sunset date for the current VOC limit for cleaning materials. 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 90

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

Lowered the VOC limit for cleaning materials to 25 g/l. Eliminated the 

provision currently allowing the use of an enclosed gun cleaner In lieu of 

compliance with the VOC content limit for cleaning materials. This new 

limit is consistent with SCAQMD Rule 1171-Solvent Cleaning Operations, 

in (c)(1)(E). 

404 Same Corrected previous typographical error in equation for calculating overall 

system efficiency. 

501.2c Same Replaced “non-compliant coatings” with “non-compliant materials” for 

consistency with Section 215. 

501.4 Same Added a sunset date for the current requirement for duration of records. 

Revised the requirement for duration of records to five years. This is 

consistent with other District rules. 

502.4 Same Updated ASTM method number to the most current version. 

502.5 Same Updated to incorporate most recent U.S. EPA guidelines on determining 

capture efficiency. 

NA 502.7 To clarify enforceability, added paragraph stating that where multiple test 

methods are specified, a violation established by any one of the test 

methods constitutes a violation of the rule. 

Rule 466, Solvent Cleaning Operations 

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

102 Same Clarified that the requirements of proposed Rule 466 apply to sterilization 

of food manufacturing and processing equipment 

110.2 Same Added a sunset date for current exemption for solvent cleaning. Lowered 

the VOC limit in the exemption to 25 g/l. This new limit is consistent with 

SCAQMD Rule 1171- Solvent Cleaning Operations, in (h)(1). 

Added an exemption for the cleaning of high-voltage microwave vacuum 

tubes because, similar to other exempt applications, compliance with the 

solvent VOC limit is not technologically feasible. 

Added a sunset date for the exemption for electrostatic coating application 

equipment, consistent with SCAQMD Rule 1171. 

110.4 Same Corrected typographical error. Cleaning of nozzle tips of automated spray 

equipment systems is not subject to the entire Section 302, not only 302.2. 

NA 110.5 Added an exemption for materials used to strip cured inks, cured coatings, 

or cured adhesives, consistent with SCAQMD Rule 1171. This exemption 

was already implied in the definition of Solvent Cleaning, but this new 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 91

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

section has been added for clarification. 

NA 209 For clarification, added a definition for cured ink, cured coating, or cured 

adhesive. This definition is consistent with SCAQMD Rule 1171. 

209-213 210-214 Sections renumbered. 

NA 215 Added a definition for food product manufacturing and processing 

operation. This definition is the same as the definition in SCAQMD Rule 

1131- Food Product Manufacturing and Processing Operations. 

NA 216 Added a definition for general work surface. This definition is the same as 

the definition in SCAQMD Rule 1171- Solvent Cleaning Operations. 

214-216 217-219 Sections renumbered. 

217 220 Revised the definition of janitorial cleaning. This definition is the same as 

the definition in SCAQMD Rule 1171- Solvent Cleaning Operations. 

NA 221 Added a definition for jobsite to clarify the applicability of the VOC limits in 

the table in Section 301.1. 

218-219 222-223 Sections renumbered. 

220 224 Revised the definition of maintenance cleaning. This definition is the same 

as the definition in SCAQMD Rule 1171- Solvent Cleaning Operations. 

221-226 225-230 Sections renumbered. 

NA 231 Added a definition for pharmaceutical product. This definition is the same 

as the definition in SCAQMD Rule 1171- Solvent Cleaning Operations. 

227-235 232-240 Sections renumbered. 

NA 241 Added a definition for solvent based coating to clarify the applicability of the 

VOC limits in the table in Section 301.1. 

236 242 Added a provision that effective one year after date of adoption, solvent 

cleaning operations will include the sterilization of food manufacturing and 

processing equipment. 

237 243 Section renumbered. 

NA 244 Added a definition for sterilization. This definition is the same as the 

definition in SCAQMD Rule 1131- Food Product Manufacturing and 

Processing Operations. 

238-239 245-246 Sections renumbered. 

NA 247 For clarification, defined “stripping” as the removal of cured inks, cured 

coatings, or cured adhesives. 

240-241 248-249 Sections renumbered. 

NA 250 Added a definition for water based coating to clarify the applicability of the 

VOC limits in the table in Section 301.1. 

242 251 Section renumbered. 

301 Same Replaced “per Section 502.1” with “pursuant to Section 502.1” for 

consistency with other rule language. 

Added sunset dates for current VOC standards for solvent cleaning 

activities. Lowered the VOC limits for solvent cleaning activities. These 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 92

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

new limits are consistent with SCAQMD Rule 1171- Solvent Cleaning 

Operations, in (c)(1). 

Added a sunset date for the current standards for architectural coating 

application equipment cleaning using solvent based coatings without an 

enclosed gun cleaner. Lowered the VOC limit to 25 g/l for this category. 

This new VOC limit applies regardless of whether an enclosed gun cleaner 

is used, and is consistent with SCAQMD Rule 1171. 

Added a new VOC standard for sterilization of food product manufacturing 

and processing equipment. This new limit is consistent with SCAQMD 

Rule 1131- Food Product Manufacturing and Processing Operations. 

302 Same Deleted sections that specified devices and methods used to clean 

architectural coating application equipment. These requirements have 

been added to the table in Section 301.1. 

Added a sunset date for the provision that allows the soaking of spray gun 

nozzles in solvents without a limit on VOC content. After the sunset date, 

spray gun nozzles are subject to the same requirements as other 

application equipment, consistent with SCAQMD Rule 1171. 

304 Same Deleted reference to Section 302, from which the architectural application 

equipment cleaning requirements have been moved to Section 301. 

Clarified that all of the following paragraphs apply. 

304.2 Same Updated to reflect section renumbering. 

NA 304.3 Added a provision requiring emissions from use of an emissions control 

equipment to be less than or equal to the emissions resulting from 

compliance with all applicable VOC limits. This is more stringent than 

SCAQMD Rule 1171, which does not contain such a provision. Added an 

equation for the calculation of the allowable quarterly emissions from 

emissions control equipment and from compliance with the VOC limits. 

401 NA Deleted section because the compliance date has passed. 

402-405 401-404 Sections renumbered. 

501.2 Same Updated to reflect section renumbering. 

501.4 Same Updated to reflect section renumbering. 

501.5 Same Added a sunset date for the current requirement for duration of records. 

Revised the requirement for duration of records to five years. This is 

consistent with other District rules. 

502.1 Same Updated to reflect section renumbering. 

502.2 Same Updated ASTM method number to the most current version. Updated to 

reflect section renumbering. 

502.4 Same Updated to incorporate most recent U.S. EPA guidelines on determining 

capture efficiency. 
Appendix B 

Summary of Changes 

Rules 450, 451, 452, 454, 456, 463, 464, 465, and 466 

August 25, 2008, Page 93

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

NA 502.6 To clarify enforceability, added paragraph stating that where multiple test 

methods are specified, a violation established by any one of the test 

methods constitutes a violation of the rule. 
Appendix C 

Allocation of the 2010 District Solvent Cleaning Emissions Inventory to Specific District Rules August 25, 2008, Page 94

Appendix C- Allocation of the 2010 District Solvent Cleaning Emissions Inventory to Specific D

VOC Emissions by EIC code 2010 Non-Coating, VOC TPY 2010 Coating - Application Equipment Cleaning - VOC TPY 2010 Coating EIC

2010 

Ozone 

SIP 

(v1.06 

RF980, 

11/16/06)) 

TPY 

Printing (Rule 450) 

Degreasing 

(Rule 

454) 

Other 

(Rule 

466) 

Misc. 

Metal 

Parts 

(Rule 

451) 

Can 

Coating 

(Rule 

452) 

AeroSpac

e 

(Rule 456) 

Auto 

Refinishin

g 

(Rule 459) 

Adhesives 

& 

Sealants 

(Rule 460) 

Wood 

Products 

(Rule 

463) 

Polyester 

Resin 

(Rule 

465) 

Misc. 

Metal 

Parts 

(Rule 

451) 

Can 

Coating 

(Rule 

452) 

AeroSpac

e 

(Rule 456) 

COLD CLEANING230-240-8300-0000 Coatings – Thinning and Cleanup Solvents (Unspecified) 116.10 92.2 22.3 1.4  220-204-0500-0000 Cold Cleaning – Petroleum Naphtha 190.46 64.94 69.91 7.15 13.31 9.03 8.71 3.63 0.00 4.88  220-204-3022-0000 Cold Cleaning – Alcohols (Unspecified) 4.67 4.67 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-204-3083-0000 Cold Cleaning – Chlorofluorocarbons (Unspecified) 1.06 1.06 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-204-3162-0000 Cold Cleaning – Fluorocarbons (Unspecified) 0.00  220-204-3176-0000 Cold Cleaning – Glycol Ethers (Unspecified) 0.29 0.29 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-204-3202-0000 Cold Cleaning – Isopropanol 0.37 0.37 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-204-3204-0000 Cold Cleaning – Ketones (Unspecified) 0.18 0.18 0.00 0.00 0.00 0.00 0.00 0.00 0.00 
Appendix C 

Allocation of the 2010 District Solvent Cleaning Emissions Inventory to Specific District Rules August 25, 2008, Page 95

VOC Emissions by EIC code 2010 Non-Coating, VOC TPY 2010 Coating - Application Equipment Cleaning - VOC TPY 2010 Coating EIC

2010 

Ozone 

SIP 

(v1.06 

RF980, 

11/16/06)) 

TPY 

Printing (Rule 450) 

Degreasing 

(Rule 

454) 

Other 

(Rule 

466) 

Misc. 

Metal 

Parts 

(Rule 

451) 

Can 

Coating 

(Rule 

452) 

AeroSpac

e 

(Rule 456) 

Auto 

Refinishin

g 

(Rule 459) 

Adhesives 

& 

Sealants 

(Rule 460) 

Wood 

Products 

(Rule 

463) 

Polyester 

Resin 

(Rule 

465) 

Misc. 

Metal 

Parts 

(Rule 

451) 

Can 

Coating 

(Rule 

452) 

AeroSpac

e 

(Rule 456) 

 220-204-3246-0000 Cold Cleaning – Methylene Chloride (Dichloromethane) 0.00  220-204-3333-0000 Cold Cleaning – Terpenes (Unspecified) 2.41 2.41 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-204-3339-0000 Cold Cleaning – Toluene/Xylene 0.15 0.15 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-204-3344-0000 Cold Cleaning – 1,1,1,-Trichloroethane (TCA) 0.00  220-204-8104-0000 Cold Cleaning – Degreasing Solvents – Pure (Unspecified) 0.07 0.07 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-204-8106-0000 Cold Cleaning – Degreasing Solvents – Blends (Unspecified) 21.46 21.46 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-206-3083-0000** Vapor DegreasingChlorofluorocarbons (Unspecified) 0.55 0.55  220-206-3107-0000** Vapor DegreasingDichlorofluoroethane (HCFC-141B) 0.04 0.04 
Appendix C 

Allocation of the 2010 District Solvent Cleaning Emissions Inventory to Specific District Rules August 25, 2008, Page 96

VOC Emissions by EIC code 2010 Non-Coating, VOC TPY 2010 Coating - Application Equipment Cleaning - VOC TPY 2010 Coating EIC

2010 

Ozone 

SIP 

(v1.06 

RF980, 

11/16/06)) 

TPY 

Printing (Rule 450) 

Degreasing 

(Rule 

454) 

Other 

(Rule 

466) 

Misc. 

Metal 

Parts 

(Rule 

451) 

Can 

Coating 

(Rule 

452) 

AeroSpac

e 

(Rule 456) 

Auto 

Refinishin

g 

(Rule 459) 

Adhesives 

& 

Sealants 

(Rule 460) 

Wood 

Products 

(Rule 

463) 

Polyester 

Resin 

(Rule 

465) 

Misc. 

Metal 

Parts 

(Rule 

451) 

Can 

Coating 

(Rule 

452) 

AeroSpac

e 

(Rule 456) 

 220-206-3300-0000** Vapor DegreasingPerchloroethylene 0.00  220-206-3301-0000** Vapor DegreasingPerfluorocarbons (Unspecified) 0.15 0.15  220-206-3344-0000** Vapor Degreasing1,1,1,- Trichloroethane (TCA) 0.00  220-206-3346-0000** Vapor DegreasingTrichloroethylene (TCE) 0.66 0.66 WIPE CLEANING 220-208-0500-0000 Handwiping – Petroleum Naphtha 24.71 24.71 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-208-3022-0000 Handwiping – Alcohols (Unspecified) 11.17 11.17 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-208-3083-0000 Handwiping – Chlorofluorocarbons (Unspecified) 0.15 0.15 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-208-3176-0000 Handwiping – Glycol Ethers (Unspecified) 2.34 2.34 0.00 0.00 0.00 0.00 0.00 0.00 0.00 
Appendix C 

Allocation of the 2010 District Solvent Cleaning Emissions Inventory to Specific District Rules August 25, 2008, Page 97

VOC Emissions by EIC code 2010 Non-Coating, VOC TPY 2010 Coating - Application Equipment Cleaning - VOC TPY 2010 Coating EIC

2010 

Ozone 

SIP 

(v1.06 

RF980, 

11/16/06)) 

TPY 

Printing (Rule 450) 

Degreasing 

(Rule 

454) 

Other 

(Rule 

466) 

Misc. 

Metal 

Parts 

(Rule 

451) 

Can 

Coating 

(Rule 

452) 

AeroSpac

e 

(Rule 456) 

Auto 

Refinishin

g 

(Rule 459) 

Adhesives 

& 

Sealants 

(Rule 460) 

Wood 

Products 

(Rule 

463) 

Polyester 

Resin 

(Rule 

465) 

Misc. 

Metal 

Parts 

(Rule 

451) 

Can 

Coating 

(Rule 

452) 

AeroSpac

e 

(Rule 456) 

 220-208-3204-0000 Handwiping – Ketones (Unspecified) 8.47 8.47 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-208-3246-0000 Handwiping – Methylene Chloride (Dichloromethane) 0.00  220-208-3333-0000 Handwiping – Terpenes (Unspecified) 0.07 0.07 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-208-3339-0000 Handwiping – Toluene/Xylene 2.19 2.19 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-208-3344-0000 Handwiping – 1,1,1,-Trichloroethane (TCA) 0.00  220-208-3346-0000 Handwiping – Trichloroethylene (TCE) 0.22 0.22 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-208-8104-0000 Handwiping – Degreasing SolventsPure (Unspecified) 1.61 1.61 0.00 0.00 0.00 0.00 0.00 0.00 0.00  220-208-8106-0000 Handwiping – Degreasing Solvents –Blends (Unspecified) 5.15 5.15 0.00 0.00 0.00 0.00 0.00 0.00 0.00  230-216-8350-0000 Coatings – Preparation Solvents (Unspecified) 1.10 1.10 
Appendix C 

Allocation of the 2010 District Solvent Cleaning Emissions Inventory to Specific District Rules August 25, 2008, Page 98

VOC Emissions by EIC code 2010 Non-Coating, VOC TPY 2010 Coating - Application Equipment Cleaning - VOC TPY 2010 Coating EIC

2010 

Ozone 

SIP 

(v1.06 

RF980, 

11/16/06)) 

TPY 

Printing (Rule 450) 

Degreasing 

(Rule 

454) 

Other 

(Rule 

466) 

Misc. 

Metal 

Parts 

(Rule 

451) 

Can 

Coating 

(Rule 

452) 

AeroSpac

e 

(Rule 456) 

Auto 

Refinishin

g 

(Rule 459) 

Adhesives 

& 

Sealants 

(Rule 460) 

Wood 

Products 

(Rule 

463) 

Polyester 

Resin 

(Rule 

465) 

Misc. 

Metal 

Parts 

(Rule 

451) 

Can 

Coating 

(Rule 

452) 

AeroSpac

e 

(Rule 456) 

 230-240-3008-0000 Coatings – Acetone 0.00  230-240-3128-0000 Coatings – Ethyl Alcohol 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  230-240-3232-0000 Coatings – Methyl Ethyl Ketone (MEK) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  230-240-8302-0000 Coatings – Thinning Solvents (Unspecified) 0.22 0.00 0.00 0.00 0.00 0.05 0.00 0.06  230-240-8350-0000 Coatings – Cleanup Solvents (Unspecified) 1.24 0.00 0.00 0.00 0.00 0.26 0.00 0.35  240-240-3202-0000 Printing – Thinning and Cleanup Solvents – Isopropanol 15.00 15.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  240-240-3314-0000 Printing – Thinning and Cleanup Solvents – NPropanol 1.10 1.10  240-240-8302-0000 Printing – Thinning Solvents (Unspecified) 0.88 0.88 0.00 0.00 0.00 0.00 0.00 0.00 0.00  299-995-8000-0000 Coatings – Other Solvents (Unspecified) 0.84 0.84 
Appendix C 

Allocation of the 2010 District Solvent Cleaning Emissions Inventory to Specific District Rules August 25, 2008, Page 99

VOC Emissions by EIC code 2010 Non-Coating, VOC TPY 2010 Coating - Application Equipment Cleaning - VOC TPY 2010 Coating EIC

2010 

Ozone 

SIP 

(v1.06 

RF980, 

11/16/06)) 

TPY 

Printing (Rule 450) 

Degreasing 

(Rule 

454) 

Other 

(Rule 

466) 

Misc. 

Metal 

Parts 

(Rule 

451) 

Can 

Coating 

(Rule 

452) 

AeroSpac

e 

(Rule 456) 

Auto 

Refinishin

g 

(Rule 459) 

Adhesives 

& 

Sealants 

(Rule 460) 

Wood 

Products 

(Rule 

463) 

Polyester 

Resin 

(Rule 

465) 

Misc. 

Metal 

Parts 

(Rule 

451) 

Can 

Coating 

(Rule 

452) 

AeroSpac

e 

(Rule 456) 

 520-522-8300-0000** Architectural CoatingsThinning and Cleanup SolventsCoatings (Unspecified) 82.82 82.82 

Total TPY 497.77 80.82 101.97 141.9 7.15 13.31 9.03 92.23 8.71 22.33 1.44 3.94 0.00 5.29 

Total 

TPD 1.36 0.22 0.28 0.38 0.02 0.04 0.02 0.25 0.02 0.06 0.00 0.01 0.00 0.01 

Total VOC Emissions by District Rule

Rule 450- Graphic Arts 

Rule 451- Misc. Metal Parts 

Rule 452- Can Coating 

Rule 454- Degreasing 

Rule 456- Aerospace 

Rule 459- Auto Refinishing 

Rule 460- Adhesives & Sealants 

Rule 463Wood Products 

Total TPY (Application Equipment Cleaning) 80.82 7.15 13.31 9.03 92.23 8.71 22.33 Total TPY (Surface Preparation/Cleanup) 3.94 5.29 4.74 1.96 2.42 Total TPY (Other) 101.97 TOTAL TPY 80.82 11.09 13.31 101.97 14.32 96.97 10.67 24.75 
Appendix D 

Public Comments 

August 25, 2008, Page 100

APPENDIX D 

PUBLIC COMMENTS 

Public Workshop Comments (April 28, 2008) 

Participants: Kathy Adams 

Al Batakji 

Larry Battenberg 

Frederick Carr 

 Steve Cerniglit 

 Bill Coleman 

 George Contos 

Richard Crowe 

 Bob Dipper 

 Don Eggleston 

 Nancy Fletcher 

 Randy Harvey 

 Beth Barker Hidalgo 

Vern Howlett 

Ted Huff 

James Iwamoto 

Rodger Mannka 

Kevin Peterson 

David Ratajczak 

Jill Reed 

Chelsea Sand 

Randy Thompson 

Raymond Vigil 

Jim Williams 

Kevin Willy 

 

 

Comment #1: Is the 15% monthly usage limit for metering roller/printing plate cleaning 

in Rule 450 (Section 302.2) going away? What is the purpose of this 15% 

usage limit? Acetone is hazardous and extremely flammable, so why is it 

an exempt solvent? Also, it is not feasible to use non-acetone solvents 

because they leave residue. 

Response: The 15% usage limit is proposed to sunset when the VOC content of 

blanket/roller washes and metering rollers/printing plates are all required 

to meet a limit of 100 g/l. This usage limit was originally designed to limit 

the usage of metering roller/printing plate cleaning because the rule 

allows for higher vapor pressure limits than for blanket and roller washes. 

Acetone is an exempt compound because the U.S. EPA determined that 

acetone has negligible reactivity for forming ground-level ozone. 

 Sources in the South Coast AQMD are currently using non-acetone 

cleaning products to comply with the 100 g/l limit. Staff is proposing to 

extend by one year the effective dates for all categories in Rule 450 that 

have 1/1/2010 effective dates in the version of proposed Rule 450 

presented at the 4/28/08 Public Workshop. The new effective date for 

these categories is 1/1/2011. Staff believes that extending the effective 

dates for these categories will allow sufficient time for industry to convert 

to the lower VOC cleaning products and find suitable replacement 

solvents. 

Comment #2: It is currently not feasible to require low VOC solvents to be used on 

automatic washing systems for ink rollers. Manufacturers of automatic 

washing systems are not recommending the use of low VOC solvents, 

because of potential problems with the seals. 

 

Response: Sources in the South Coast AQMD are currently using low-VOC solvents 

in automatic washing systems. Staff believes the delayed effective date 

of 1/1/2011 for non-newsprint cleaning provides enough time to find 
Appendix D 

Public Comments 

August 25, 2008, Page 101

suitable materials. 

Comment #3: We plan on requesting exemptions for the use of higher VOC cleaning 

materials for our products because we find that soaking and degreasing is 

more effective than wipe cleaning. We will submit written comments 

regarding this. 

Response: Staff will review the written comments once we receive them. (See 

response to Comment #1 from Teledyne MEC). 

Comment #4: Will the VOC limit for gun cleaning drop to 25 g/l? 

Response: Yes, Staff proposes to lower the VOC limit for application equipment 

cleaning, which includes gun cleaning, to 25 g/l in Rules 451, 456, 463 

and 466. The option of using enclosed gun cleaners with solvents 

containing greater than 25 g/l VOC will no longer be allowed in the 

proposed rules. Solvents used in enclosed gun cleaners must comply 

with the 25 g/l limit as well. 

Comment #5: Solvents containing 25 g/l or less VOCs are not capable of cleaning guns 

effectively. The use of polyurethane in particular destroys the guns, 

thereby requiring the guns to be replaced frequently. 

Response: Based on the successful implementation of the 25 g/l limit for application 

equipment cleaning in other air districts, Staff believes compliant, 

effective solvents for gun cleaning are readily available. Staff believes 

that spray guns do not require specialized cleaning processes or 

products. 

Comment #6: When will these rules be adopted? 

Response: These amendments are tentatively scheduled for consideration at the 

September 25, 2008 Board meeting. 

Comment #7: Regarding Rule 450, we use the same material to clean removable press 

components that we use to clean blankets and rollers. Why is a 25 g/l 

VOC limit proposed for removable press components? 

Response: The 25 g/l VOC limit for cleaning removable press components has been 

demonstrated to be feasible in the South Coast AQMD. 

Comment #8: We use the same presses and cleaning materials for printing on both 

newsprint and non-newsprint substrates. The separate recordkeeping 

requirements proposed in Rule 450, Section 501.3 are unnecessary. 

Response: See response to Comment #3 from the Office of State Publishing. 

Comment #9: Regarding Rule 451, Section 110, Staff is proposing to delete the 200 

gal/yr low usage exemptions for aluminum coatings and pretreatment 

wash primers. A 55 gal/yr exemption is not enough for my business. 
Appendix D 

Public Comments 

August 25, 2008, Page 102

Response: In follow-up discussions with the commenter, Staff learned that this 

business will use powder coatings and will be able to comply with the rule 

as proposed. 

Comment #10: Regarding Rule 466, cleaning of high voltage electrical equipment is also 

critical. Why isn’t this cleaning application exempt? 

Response: See response to Comment #1 from SMUD. 

Letter from Alex Krichevsky, California Air Resources Board (April 24, 2008) 

Comment #1: We recommend that the District lower the exemption level in Section 

110.1 of Rule 450, from 60 pounds of VOC per month to 200 pounds per 

rolling 12-month period, since Ventura County Air Pollution Control 

District (VCAPCD) Rule 74.19 currently contains the latter exemption 

level. 

Response: The VCAPCD Rule 74.19 exemption specifies 200 pounds per rolling 12-

month period, but the exemption does not include VOC emissions from 

aerosol products, cold cleaners, and vapor degreasers in this 

determination. Also the VCAPCD rule includes an exemption for circuit 

board printing and specifies VOC limits for cleaning materials and printing 

adhesives that are higher than those specified in proposed Rule 450. 

Collectively, the exemptions and proposed VOC limits in proposed Rule 

450 will deliver greater emission reductions than that achieved by 

implementing the recommended VCAPCD exemption level and limits. 

Therefore, this change to the exemption level is not recommended. 

Comment #2: We recommend that the District revise the VOC limits in Rule 450 for 

“Extreme Performance Ink/Coating” for screen printing from 800 g/l to 400 

g/l and the VOC limit for “Sign Ink/Coating” from 500 g/l to 400 g/l, 

because other air districts in California (Bay Area and San Joaquin 

Valley) have implemented the 400 g/l limit in their respective rules. 

Response: SJVUAPCD Rule 4607 includes an exemption for facilities that emit less 

than 400 pounds of VOC per calendar month, which is less stringent than 

the exemption level in proposed Rule 450. Also, proposed Rule 450 

includes several VOC limits for solvent cleaning that are lower than those 

in SJVUAPCD Rule 4607. The 2002 emissions inventory for screen 

printing inks and coatings is only 0.07 tons per day of VOC. The two 

categories mentioned above only affect a portion of the screen printing 

inventory, and, therefore, Staff is not proposing to lower these limits. 

Comment #3: We recommend that the District withhold the proposed amendment of the 

VOC limit for cleaning of ultraviolet/electron beam inks (from 800 g/l to 

100 g/l on 1/1/2010) until after the VOC limit for this category becomes 

effective in South Coast AQMD Rule 1171 on 1/1/2009. The proposed 

VOC limit for ultraviolet inks is a technology forcing limit. 

Response: Staff is proposing to extend by one year the effective dates for all 

categories in Rule 450 that have 1/1/2010 effective dates in the version of 
Appendix D 

Public Comments 

August 25, 2008, Page 103

proposed Rule 450 presented at the 4/28/08 Public Workshop. The new 

effective date for these categories is 1/1/2011. Staff believes that 

extending the effective dates for these categories will allow sufficient time 

for industry to convert to the lower VOC cleaning products. 

Comment #4: We recommend that the combined collection and control efficiency for an 

emission control system in Rule 450 (Section 303) be raised from 67% to 

85%, consistent with the current requirement in San Diego County APCD 

Rule 67-16. 

Response: Staff now proposes to increase the overall emissions control system 

efficiencies to at least 90% for several types of printing processes to 

conform to two recent Control Techniques Requirements (CTGs) 

promulgated by EPA in September 2006. 

Comment #5: We recommend that the District revise Section 502.3 in Rule 450 to 

specify the latest ASTM method, ASTM Test Method D 4457-02(2008). 

Response: Staff has revised the rule language to specify this updated ASTM method. 

Comment #6: We recommend that the District revise Section 502.7 in Rule 450 to 

specify the latest ASTM method, ASTM Test Method D 2879-97(2007). 

Response: Staff has revised the rule language to specify this updated ASTM method. 

Comment #7: We recommend that the District revise the rule language in Rule 454 

(Section 310) to reflect the sunset date of the emissions control 

equipment requirement. 

 

Response: To address this potential loophole, Staff has added the emissions control 

equipment requirements to the lip exhaust system requirements (Section 

309), which still provide the option of using emissions control equipment. 

Comment #8: We recommend that the low usage exemption in Section 110 of Rule 463 

be lowered from 55 gallons per year to 20 gallons per year, consistent 

with the exemption level adopted by other air districts in California (Bay 

Area, El Dorado County, San Joaquin Valley, and Santa Barbara County) 

in their respective rules. 

Response: Unlike Rule 463, the rules at other air districts that contain this 20 

gallon/year exemption do not establish VOC limits for refinishing of wood 

products. Staff is proposing to maintain the current exemption level with 

the existing and proposed VOC limits for refinishing and repairing, which 

will collectively deliver greater VOC reductions than the requirements in 

other districts. 

Comment #9: We recommend that VOC limit for “High-Solid Stain” in Rule 463 be 

lowered from 350 g/l to 240 g/l and the VOC limit for “Sealer” from 275 g/l 

to 240 g/l, consistent with the VOC limits adopted by other air districts in 

California (El Dorado County, San Joaquin Valley, Santa Barbara County, 

and Ventura County). 
Appendix D 

Public Comments 

August 25, 2008, Page 104

Response: Staff determined that, as potential all-feasible measures, lowering the 

VOC limits for high-solid stains and sealers to the most stringent limits in 

the San Joaquin and Ventura County rules would reduce VOC emissions 

by less than 0.02 tons per day. Therefore, Staff is not proposing to lower 

these limits. 

Comment #10: We recommend that VOC limit for strippers in Rule 463 be lowered from 

350 g/l to 200 g/l, consistent with the VOC limit in SDAPCD Rule 67-11. 

Response: SDAPCD Rule 67-11 includes an exemption for sources with coating 

usage levels below 500 gallons per year, while Rule 463 exempts 

sources with coating usage levels less than 55 gallons per year. The 

District exemption is more stringent than the SDAPCD exemption, and 

therefore Staff is not proposing to lower the VOC limit for strippers. 

Comment #11: We recommend that the District revise Section 503.3 in Rule 463 to 

specify the latest ASTM method, ASTM Test Method D 4457-02(2008). 

Response: Staff has revised the rule language to specify this updated ASTM method. 

Comment #12: We recommend that the District revise Section 503.7 in Rule 463 to 

specify the latest ASTM method, ASTM Test Method D 5403-93(2007). 

Response: Staff has revised the rule language to specify this updated ASTM method. 

Comment #13: We recommend that the District revise the combined collection and 

control efficiency for an emission control system in Rule 465 (Section 

301.2) from 85% to 90%, consistent with the current requirement in 

SCAQMD Rule 1162. 

Response: Staff now proposes to increase the control efficiency requirement for Rule 

465 from 85% to 90%. 

Comment #14: We recommend that the District revise Section 502.2 in Rule 466 to 

specify the latest ASTM method, ASTM Test Method D 4457-02(2008). 

Response: Staff has revised the rule language to specify this updated ASTM method. 

Letter from Don Eggleston, Office of State Publishing (April 25, 2008) 

Comment #1: Compliance dates by substrate in Rule 450 (Section 302.1) are not 

appropriate for printers who use both newsprint and non-newsprint in their 

products from the same presses. At OSP, the same cleanup solvents are 

used on these presses regardless of substrate. Printers who use the 

same materials regardless of substrate should be allowed the maximum 

compliance period which is until 1/1/2010. 

 

Response: South Coast AQMD successfully implemented a similar two-tier structure 

for establishing effective dates for newsprint and non-newsprint 

substrates. The VOC limit for newsprint substrates became effective on 
Appendix D 

Public Comments 

August 25, 2008, Page 105

7/1/2006, earlier than the effective date of 1/1/2008 for the VOC limit for 

non-newsprint substrates. Staff therefore believes compliance dates by 

substrates, as it relates to newsprint and non-newsprint, is reasonable. 

Comment #2: For Rule 450 (Section 302.1), the proposed 25 g/l VOC limit for the 

cleaning of “Removable Press Components” is unreasonable because in 

most cases, the contamination is the same material removed from ink 

rollers and blankets, and blanket and roller washes are often used to 

clean such components. VOC limits for “Removable Press Components” 

should match those of “Blanket and Roller Washes.” 

Response: The 25 g/l VOC limit for the cleaning of “Removable Press Components” 

has already been demonstrated to be feasible in SCAQMD. Sources 

must utilize cleaning products other than blanket and roller washes to 

clean removable press components. Components that can be readily 

detached from the printing press do not necessitate specialized cleaning 

processes and higher VOC limits. 

Comment #3: Printers such as OSP use the same fountain solutions, same solvents, 

same adhesives, and essentially the same inks on presses that run both 

newsprint and other substrates. Therefore, the list of materials used for 

newsprint would be identical to the list of materials for other substrates. 

The requirement in Rule 450 (Section 501.3) for separate usage records 

to be kept for newsprint and non-newsprint substrates serves no practical 

purpose in this case, and should be dropped. 

 

Response: Staff has revised the recordkeeping requirement in Rule 450 for newsprint 

and non-newsprint substrates. The revised rule language does not 

require a source to keep separate usage records for newsprint and nonnewsprint substrates provided that the source can already comply with 

the 1/1/2011 requirements for newsprint substrates. 

Letter from Ted Huff, SMUD (May 5, 2008) 

Comment #1: We request that an exemption be added to Section 110.2c in Rule 466 to 

include high voltage gloves, hot sticks, rubber blankets, line hoses, 

mechanical jumpers, insulator covers, and high-voltage test equipment 

leads. This equipment is used by personnel on energized circuits to 

perform testing, switching, equipment repairs, protection of personnel and 

other related functions to equipment and apparatus that cannot be 

practically de-energized. This high voltage equipment (hot sticks, gloves, 

rubber blankets, line hoses, mechanical jumpers, insulator covers and 

high voltage test equipment leads) represents in some cases, the 

individual's only protection from injury or death from electrocution while 

working on energized circuits or equipment. The products currently used 

for cleaning of this high voltage equipment provides the necessary level 

of cleaning to ensure that the equipment remains safe for use on live or 

energized circuits. The concern is that lower VOC-content products may 

not clean the surface as thoroughly and leave a residue allowing tracking 

and flashover of the device. 
Appendix D 

Public Comments 

August 25, 2008, Page 106

Response: Staff has determined that compliant products (aerosol products) are 

readily available and have been successfully used by electrical utilities in 

SCAQMD. These aerosol cleaners are exempt from Rule 450 when used 

in quantities of 160 fluid ounces or less per day. CARB’s Consumer 

Products Regulations allow up to 45% VOC by weight for these electrical 

cleaners, which is lower that the current Rule 450 limit of 900 g/l but 

higher than the proposed limit of 100 g/l that will take effect one year after 

the date of adoption. 

Letter from Daniel B. Pourreau, Lyondell Chemical Company (May 5, 2008) 

Comment #1: We request that an exemption for tertiary-butyl acetate (TBAC) be added 

to all nine of the solvent cleaning rules. TBAC is a much better degreaser 

than acetone, produces less ozone than acetone, is safer to use than 

acetone, and was exempted from the federal VOC definition in November 

2004 because of its negligible photochemical reactivity. 

Response: Compliant products that do not contain TBAC are readily available. In 

order to exempt TBAC, Rule 101—General Provisions and Definitions, 

which lists all exempt compounds, would need to be revised to include 

TBAC. However, Rule 101 is not being proposed for amendment at this 

time. Staff will consider the request for the exemption of TBAC when 

Rule 101 is proposed for amendment. 

Letter from G.M. Bonetto, Ph.D., Printing Industries of California (PIC) (May 7, 2008) 

Comment #1: The District justifies its currently proposed VOC limits and corresponding 

implementation schedule by citing similar amendments already in effect in 

SCAQMD Rule 1171 and SCAQMD Technology Assessments that 

provide the supporting evidence. However, the results acquired in these 

technology assessments (specifically the report entitled “Assessment, 

Development, and Demonstration of Low-VOC Solvents for Cleaning of 

Lithographic Ink Application Equipment” by the Institute for Research and 

Technology Assistance”) are inconclusive and incomplete. Solvent 

formulations found to be successful during Institute for Research and 

Technology Assistance’s (IRTA) experiments do not work over the long 

term and cause a number of problems over time, including buildup and 

absorption of solvent residue on the rollers and reduction of the ink’s tack 

(which is detrimental because the level of ink tack governs the sharpness 

of the dot pattern). These problems have been substantiated in PIC’s 

independent studies, which were conducted by a well-known technical 

expert on lithographic printing. Additional problems and issues from the 

use of low-VOC solvents given in IRTA’s report include reduction of 

overall worker productivity and in extreme cases, fire hazards and 

destruction of the printing press. 

Response: These studies did not evaluate all of the materials currently available on 

the market. There are other products available on the market, and there 

is at least one source in Sacramento County already using cleaning 

materials that comply with these limits. 
Appendix D 

Public Comments 

August 25, 2008, Page 107

SCAQMD Rule 1171, adopted in 1999, set a date of July 1, 2005 for 

compliance with the 100 g/l limits. This date was extended twice, and the 

limits finally took effect on January 1, 2008. SCAQMD’s June 2006 staff 

report, which addressed the extension of the deadline for the final time, 

noted that field testing of compliant materials had been completed and 

that the additional 18 months (until 1/1/2008) would be necessary for 

additional testing and to give the industry time to transition to the new 

cleaning materials. Sources and their suppliers in SMAQMD are now 

working in earnest to make this transition. As was noted by Mr. Bonetto 

during discussions, there are other promising materials being developed, 

such as surfactant-based cleaners. 

Comment #2: PIC recommends that the District revise the definition of “Other On-Press 

Components” in Rule 450 to exclude dampening rollers, fountains, 

impression cylinders, and plates. The definition of “Removable Press 

Components” excludes these items. 

Response: Staff intended to exclude dampening rollers, fountains, impression 

cylinders, and plates from the definition of “Removable Press 

Components” in order for these items to be subject to the requirements 

for “Other On-Press Components.” Staff has revised the definition of 

“Other On-Press Components” to explicitly state that these items are 

included. 

Comment #3 PIC recommends that the District reduce the VOC limits for in Rule 450 

for the non-newsprint cleaning of blankets, rollers, metering 

rollers/printing plates, and other on-press components in two steps; first 

to less than 500 g/l one year after the effective date, and then to 100 g/l 

one year after the first date. This would give printers time to adjust to 

working with these low-VOC solvents. No other district attempted to 

move from the current limit to less than 100 g/l. It is hard to get these 

low-VOC solvents to work. The stepping down allows printers to become 

familiar with how lower solvent work and prepares them for less than 100 

g/l limit. In doing so, SMAQMD would have extended the Effective Date 

of the 100 g/l by only six months to around July 2010. Please seriously 

consider this request. 

Response: Staff has delayed the effective date for these categories to January 1, 

2011, giving sources additional time as requested to address issues that 

printers in SCAQMD currently encounter in their transition to the use of 

low-VOC solvents. 

Staff did not include an additional interim limit in the rule as requested. It 

has been determined that many sources (including the largest printing 

establishments) are already using solvents containing less than 500 g/l of 

VOC. Establishing an interim limit of 500 g/l without a vapor pressure 

option, thereby replacing the current limit 300 g/l with a vapor pressure 

option, for the above categories could constitute a relaxation of the 

current requirements. Since many sources are already phasing to lower 

VOC products with the current limits in place, staff did not include this PIC 

proposed limit. 
Appendix D 

Public Comments 

August 25, 2008, Page 108

Comment #4: PIC requests the removal of Section 302.2 in Rule 450, which specifies a 

15% usage limit for solvents used for cleaning metering rollers and 

printing plates. No other air district in the nation has this standard. It is 

also more difficult to find an effective low-VOC solvent for metering 

rollers/printing plates than for rollers/blankets, and because of this, 

printers will have no incentive to use lower VOC solvents because it will 

exceed the usage percentage for metering rollers/printing plates. PIC 

suggests establishing the same VOC limit for metering rollers/printing 

plates as for On-Press Components. It follows that Section 501.3(b)(4) 

(in which sources are required to keep monthly records showing the 

percentage of materials used for cleaning metering rollers/printing plates 

according to Section 302.2) should also be removed if the District grants 

PIC’s request for the removal of Section 302.2. 

 

Response: We agree with many of the issues raised and have made the following 

change. Section 302.2 now has a proposed sunset date of January 1, 

2011, when the non-newsprint VOC limits for blanket/roller washes, 

metering rollers/printing plates, and other on-press components become 

effective. The VOC limits for all three of these categories will be 100 g/l. 

To avoid relaxing the 15% usage limit, Section 302.2 will remain in effect 

until the 1/1/11 effective date for the three VOC limits mentioned above. 

 Under the proposed Rule 450, printers that use the same solvent for both 

metering rollers/printing plates and blankets/rollers and meet the 100 g/l 

limit for both materials are exempt from the 15% requirement. 

Comment #5: Sources should not be required to retain their records for more than 2 

years, as required in the proposed Rule 450 (Section 501.5). It is 

unreasonable for and especially burdensome on small businesses, which 

are now being asked to retain records for 5 years, equivalent to the EPA 

requirements for Title V sources. Ninety percent of all printing companies 

in SMAQMD have fewer than 15 employees. 

Response: The proposed requirement for sources to retain records for 5 years is 

intended to be a means of standardizing the record retention 

requirements for all of the solvent cleaning rules. Several rules, such as 

Rule 450, already currently require records to be kept for at least 5 years. 

The proposed rules are expected to be SIP-approved by EPA, rendering 

them federally enforceable rules. Requiring records to be kept for 5 years 

ensures consistency with federal statute of limitations of 5 years for acting 

upon a rule violation. 

Comment #6: Since the District is proposing to delete the vapor pressure requirement in 

Rule 450 on 1/1/2010, Section 502.7 should also be deleted. 

Response: Section 502.7 specifies the method of determining vapor pressure. 

Section 502.7 must remain in Rule 450 at least until 1/1/2011. The 

majority, but not all, of the vapor pressure requirements will be removed 

on 1/1/2010. Vapor pressure will remain a compliance option for nonnewsprint substrates and for screen printing until 1/1/2011. 
Appendix D 

Public Comments 

August 25, 2008, Page 109

Comment #7: The District should reconsider its decision to remove the vapor pressure 

compliance option. PIC and SCAQMD had agreed in discussions during 

the 10/8/1999 amendments to SCAQMD Rule 1171 that a study should 

be conducted to ascertain the relationship between vapor pressure and 

VOC mass emission rates. SCAQMD produced an inadequate study, 

however, since the study addressed how vapor pressure affects total 

mass emissions rather than emission rates as agreed upon during the 

discussions. SCAQMD based its decision to remove vapor pressure on 

its conclusion that lower vapor pressure do not lead to lower mass 

emissions, but acknowledges that lower vapor pressure does lead to 

lower mass emission rates. PIC agrees with the latter conclusion, and 

disagrees with SCAQMD’s decision to remove vapor pressure based on 

total mass emissions. 

It is also baffling that SCAQMD did not follow the solvent cleaning 

requirements set by EPA, which recognizes and supports the use of low 

vapor pressure cleaning solvents in several EPA documents. The EPA 

document entitled “Technical Support Document (TSD) for Title V 

Permitting of Printing Facilities (January 2005)” encourages the use of 

low vapor pressure products as a means of reducing emissions at a 

particular source. 

Response: South Coast’s studies focused on total mass emissions while PIC focuses 

on the mass emission rates. While low vapor pressure solvents may 

evaporate at a slower rate, the SCAQMD study showed that all of the 

solvent eventually evaporates. Since solvent eventually evaporates, 

setting a lower VOC limit will reduce further what is eventually emitted to 

the air than setting a low vapor pressure limit. 

In addition, even if we agreed with PIC’s focus on emission rates, low 

vapor pressure limits do not reduce emissions equivalent to the low-VOC 

limits being proposed. EPA’s document, Control Techniques Guidelines 

for Offset Lithographic Printing and Letterpress Printing (2006) 

recommends the use of low vapor pressure cleaning materials (specified 

in the CTG as having a vapor pressure of less than 10 mm Hg at 20 °C), 

and that the use of such materials results in an emission reduction 

comparable to using materials with 30% VOC by weight (or approximately 

240 g/l of VOC). However, the proposed limits in Rule 450 of 25 g/l VOC 

for general cleaning and 100 g/l for blanket and roller washes, metering 

rollers, printing plates, and other on-press components are lower than 

CTG limits and, therefore, will lead to greater emission reductions than 

low vapor pressure solvents. Furthermore, stand-alone VOC limits 

(without vapor pressure as a compliance option) have already been 

demonstrated to be feasible in SCAQMD, and some sources in 

Sacramento County are already using cleaning materials that comply with 

these limits. 

Comment #8: PIC believes that looking at just VOC content may likely result in higher 

consumption of materials and consequently, the creation of greater waste 

streams. 
Appendix D 

Public Comments 

August 25, 2008, Page 110

Response: Some of the compliant cleaning options, such as the impregnated cloth 

cleaning systems already in use at some Sacramento County sources, 

consume much less cleaning material than the previous cleaning 

techniques. Nevertheless, sources subject to Rule 450 are also required 

to comply with applicable state and federal regulations concerning the 

proper handling and disposal of hazardous waste. 

Letter from Al Batakji, Teledyne MEC (January 31, 2007) 

Comment #1: Teledyne MEC requests an exemption in Rules 454 and 466 for high 

voltage microwave tubes or rule language stating that alternative 

compliance in Rule 107 may be applied to high voltage microwave tubes. 

(Teledyne had previously been granted a variance to allow Alternative 

Compliance pursuant to Rule 107.) Our small scale operation 

manufactures high voltage microwave tubes, which are the principal 

components of electronic radar jamming devices that are used primarily in 

military aircraft and vessels to protectively disable incoming missile 

guidance systems. The use of 100% anhydrous isopropyl alcohol (IPA) 

has proven for decades to be the most effective cleaning and degreasing 

solvent for such complicated and expensive assemblies ($15,000 each) in 

that it produces the least number of rejected assemblies or those that fail 

during use. In contrast, the use of an IPA/acetone blend has 

demonstrated in testing to result in twice the number of device rejects, 

due to increased residue retention on critical surfaces of the assemblies. 

Teledyne MEC has undergone extensive efforts to identify comparable 

alternatives to IPA, but no such solvent or blend has been found that 

cleans as effectively. To support the fact that 100% anhydrous IPA 

removes residue and other potential contaminants more effectively than 

alternatives, we have included reports from our own investigations, from 

component vendors, and from our mass spectrometry study of vacuum 

tube surfaces when exposed to different solvents. The airtight/airless 

cleaning system allowed in Rule 454 is not an option either because it 

would be impractical and infeasible to employ such a system to capture 

emissions from such operations, which involve hand manipulation of very 

small parts during cleaning and assembly. We estimate that such an 

exemption would lead to an increase of only 25 pounds of VOC emissions 

per operating day. 

 

Response: Staff has reviewed the technical information submitted by Teledyne 

pertaining to the cleaning of high voltage microwave tubes. Staff also 

reviewed rules in other districts where such devices are produced, and 

determined that the cleaning of such devices with high VOC solvents is 

allowed under existing rules for aerospace assembly operations. Staff 

acknowledges that these types of assemblies require high VOC products 

to clean them effectively and has proposed exemptions in Rule 454 and 

456. 
Appendix D 

Public Comments 

August 25, 2008, Page 111

Letter from Chelsea Sand, Aerojet (May 19, 2008) 

Comment #1: Aerojet requests a minimum delay of 2 years from rule adoption in the 

proposed effective date for Section 304.4 of Rule 456, which will reduce 

the VOC limit for application equipment cleanup from 200 g/l to 25 g/l and 

eliminate the enclosed gun cleaner compliance option. Aerojet is also 

requesting the retention of the enclosed gun cleaner compliance option, 

which is a critical compliance tool currently for Aerojet and achieves the 

same reductions as the reduced VOC limit. Aerojet is concerned about 

the proposed requirement for a number of reasons. These changes will 

cause Aerojet to place a heavier reliance on exempt solvents, particularly 

acetone, or an acetone-based material, which will have negative health 

and safety impacts (such as fire hazards) and will be restricted based on 

Environmental Health and Safety risks. There are no known 

commercially available products that achieve 25 g/l and can effectively 

cleaning aerospace coatings. A very limited number of substitute, 

compliant solvents are available that thoroughly clean multi-part epoxies 

and polyurethane containing materials. There is not enough time given 

by SMAQMD to test and requalify substitute solvents by the proposed 

effective date of this rule change. (This research process can potentially 

last a minimum of 36 months without any guarantee of successfully 

finding an alternative product.) Based on preliminary discussions with our 

suppliers, suitable replacements may not even exist. Aerojet would incur 

additional costs associated with the work to requalify and incorporate the 

replacement solvents, costs related to reduced productivity and 

throughput from diverting resources to this research of solvents, as well 

as the high costs of the replacement solvents themselves. If acetone is 

used, additional costs would come from controlling hazards in both 

explosive and inert operating areas and replacing damaged equipment as 

the result of applying acetone. Aerojet’s strict standards on health and 

safety rule out the use of all other SMAQMD exempt compounds. The 

aerospace facilities in SCAQMD, which were used as the basis for the 

compliance costs associated with achieving the 25 g/l limit in SCAQMD 

Rule 1171, are much smaller than the Aerojet campus in Sacramento and 

have far fewer spray booths. Therefore, it is inappropriate to assume that 

the same compliance costs in SCAQMD (which were based on the cost of 

acetone) could be applied to our facility. A delay in the rule effective date 

will allow Aerojet adequate time to conduct the necessary research for 

alternative products. Retention of the enclosed gun cleaner option will 

allow Aerojet to use this option to effectively clean spray guns and long 

booms/wands (also currently a SMAQMD approved technique). 

 

Response: Staff now proposes to retain the enclosed gun cleaner option until the 

proposed sunset date of two years from rule adoption. Delaying the 

sunset date for the enclosed gun cleaner option will allow Aerojet and 

other affected sources to continue to use this option while giving sufficient 

time for a suitable, low-VOC alternative solvent to be found and 

successfully implemented. 
Appendix D 

Public Comments 

August 25, 2008, Page 112

Letter from Andrew Steckel, EPA Region 9 (August 18, 2008) 

Rule 450 

Comment #1: Potential Approvability Issue: The 2006 CTG for Offset Lithographic 

Printing and Letterpress Printing recommends a 1.6 percent alcohol by 

weight fountain solution for heatset web offset lithographic printing, a 5 

percent alcohol by weight for sheet-fed offset lithographic printing, and 5 

percent alcohol substitute or less and no alcohol in the fountain solution 

for coldset web offset lithographic printing. For heatset web and sheet-fed 

printing, the CTG provides different approaches for achieving the 

recommended level of control. The 100 g/L VOC limit for chilled fountain 

solutions and 80 g/L limit for non-chilled fountain solutions in Section 

301.2 are not as stringent as the CTG recommendations. Please include 

requirements that are as stringent as the CTG recommendations. 

Response: Staff has revised proposed Rule 450 to conform to all of the 

recommendations in the 2006 CTG for Offset Lithographic Printing and 

Letterpress Printing. Refer to the Summary of Requirements section of 

this staff report for further details. 

Comment #2: Potential Approvability Issue: The 2006 CTG for Offset Lithographic 

Printing and Letterpress Printing recommends a control device with an 

overall control efficiency of 90% or 95% for heatset web offset 

lithographic printing depending on the first installation date of the control 

device, and also recommends that the dryer be operated at negative 

pressure. While Section 303.2.a requires a control device efficiency of at 

least 95%, Section 303.2.b requires an emission collection efficiency of at 

least 70%. The 70% emission collection efficiency requirement is not as 

stringent as requiring the dryer to operate at negative pressure. Please 

include requirements that are as stringent as the CTG recommendations. 

Please note that the CTG does not recommend that heatset web sources 

be allowed to use graphic art printing materials (inks and varnishes) with 

a certain VOC content instead of using an add-on control device. Please 

change rule requirements to allow heatset web sources to comply only by 

using control technology that has an overall capture and control efficiency 

that's equivalent to CTG recommendations or demonstrate that 

compliance with the VOC content limits is equally as stringent. 

Response: See response to EPA comment #1. Staff has revised proposed Rule 450 

to conform to the recommendations in the 2006 CTG for Offset 

Lithographic Printing and Letterpress Printing, including requirements for 

overall system efficiency (which combines capture and control). The 

proposed rule is now as stringent as the CTG recommendations. Refer to 

the Summary of Requirements section of this staff report for further 

details. 

Comment #3: Potential Approvability Issue: The 2006 CTG for Flexible Package 

Printing, depending on first installation date of the press and add-on 

control device, recommends an overall capture and control efficiency of 

up to 80%. Section 303.2 requires an overall capture and control 
Appendix D 

Public Comments 

August 25, 2008, Page 113

efficiency of only 67%. As an alternative to meeting the applicable capture 

and control efficiency, the CTG recommends that materials be used that 

meet the following limits: .8 kg VOC/kg solids applied or .16 kg VOC/kg 

materials applied. Please include requirements that are as stringent as 

the CTG recommendations. 

Response: Staff has revised proposed Rule 450 to conform to the recommendations 

in the 2006 CTG for Flexible Package Printing. Staff is not proposing to 

include the following less stringent overall system efficiencies specified 

below because these requirements would not apply to any existing or 

future sources. 

• 65% overall control for a press that was first installed prior to March 14, 

1995 and that is controlled by an add-on air pollution control device 

whose first installation date was prior to the effective date of the State 

RACT rule. 

• 75% overall control for a press that was first installed on or after March 

14, 1995 and that is controlled by an add-on air pollution control device 

whose first installation date was prior to the effective date of the State 

RACT rule. 

The option to use the low VOC materials in lieu of emissions control 

equipment was not included in the proposed rule. Staff determined that 

this compliance option is not necessary for any existing District sources 

and that it is unlikely that any future sources would need this compliance 

option. Refer to the Summary of Requirements section of this staff report 

for further details. 

Comment #4: Recommendation: Section 110.1 exempts any graphic art operation that 

has actual emissions of less than or equal to 60 pounds per calendar 

month. As noted in CARB's April 24 comments, VCAPCD Rule 74.19 

contains a current exemption limit of 200 pounds per rolling 12-month 

period. The SJVUAPCD is currently workshopping their Rule 4607 and 

also intends to lower their exemption to graphic arts operations which 

emit less than 200 pounds per 12 rolling consecutive calendar months. 

Please consider making Rule 450 limits as stringent. 

Response: See response to CARB comment #1. The VCAPCD Rule 74.19 

exemption specifies 200 pounds per rolling 12-month period, but the 

exemption does not include VOC emissions from aerosol products, cold 

cleaners, and vapor degreasers in this determination. Also the VCAPCD 

rule includes an exemption for circuit board printing and specifies VOC 

limits for cleaning materials and printing adhesives that are higher than 

those specified in proposed Rule 450. Collectively, the exemptions and 

proposed VOC limits in proposed Rule 450 will deliver greater emission 

reductions than that achieved by implementing the recommended 

VCAPCD exemption level and limits. Therefore, this change to the 

exemption level is not recommended. 

Comment #5: Recommendation: The VOC limit for “Extreme Performance Ink/Coating” 

for screen printing is currently 800 g/L. SJVUAPCD Rule 4607 and 
Appendix D 

Public Comments 

August 25, 2008, Page 114

BAAQMD Rule 8-20 both limit the VOC content for this category to 400 

g/L. Please consider making Rule 450 limits as stringent. 

Response: See response to CARB comment #2. SJVUAPCD Rule 4607 includes an 

exemption for facilities that emit less than 400 pounds of VOC per 

calendar month, which is less stringent than the exemption level in 

proposed Rule 450. Also, proposed Rule 450 includes several VOC limits 

for solvent cleaning that are lower than those in SJVUAPCD Rule 4607. 

The 2002 emissions inventory for screen printing inks and coatings is only 

0.07 tons per day of VOC. Staff has determined that lowering the VOC 

limits for the above categories will have minimal impact on overall 

emissions, and is not proposing to lower these limits. 

Comment #6: Recommendation: The VOC limit for “Sign Ink/Coating” for screen printing 

is currently 500 g/L. Both SJVUAPCD Rule 4607 and BAAQMD Rule 8-

20 limit the VOC content for this category to 400 g/L. Please consider 

making Rule 450 limits as stringent. 

Response: See response to CARB comment #2. SJVUAPCD Rule 4607 includes an 

exemption for facilities that emit less than 400 pounds of VOC per 

calendar month, which is less stringent than the exemption level in 

proposed Rule 450. Also, proposed Rule 450 includes several VOC limits 

for solvent cleaning that are lower than those in SJVUAPCD Rule 4607. 

The 2002 emissions inventory for screen printing inks and coatings is only 

0.07 tons per day of VOC. Staff has determined that lowering the VOC 

limits for the above categories will have minimal impact on overall 

emissions, and is not proposing to lower these limits. 

Rule 451

Comment #7: Potential Approvability Issue: Section 111.9 exempts conformal coatings. 

This exemption is not recommended in applicable CTGs. Please 

demonstrate that Rule 451 meets RACT even though this exemption is 

not recommended in applicable CTGs. 

Response: The exemption for conformal coatings was adopted in the 2/23/93 

amendment of Rule 451, in response to comment letters from industry 

submitted in the previous year. A letter from a process engineer with a 

paints and depaints company requested this exemption in order to clarify 

that such coatings are not categorized under electrical insulating 

coatings, which are subject to rule requirements. In her letter, the 

engineer stated that conformal coatings are applied to circuit boards, 

which usually contain very closely spaced circuits, and that moisture, 

corrosion, or fungi/bacteria can cause a short circuit and eventually result 

in catastrophic failure of the associated equipment. The District staff 

report for the 2/23/93 amendments states that this exemption was added 

for clarity because coating of printed circuit boards is regulated under a 

separate rule (referring to Rule 456, which was amended on the same 

date and includes a VOC limit for aerospace conformal coatings). A 

10/7/93 District letter to EPA explains that, at the time, survey results 

indicated that no non-aerospace operations in Sacramento County 
Appendix D 

Public Comments 

August 25, 2008, Page 115

applied conformal coatings. That is still the case today. Therefore, in 

response to this comment, Staff is proposing to limit the conformal 

coating exemption to those coatings regulated by Rule 456. 

Comment #8: Potential Approvability Issue: We understand that Rule 451 includes 

coating emission limits for metal furniture operations. Please ensure that 

Rule 451 requirements are as stringent as the recommendations in the 

2007 Metal Furniture Coatings CTG. Certain limits in the VOC content 

table in Section 301 are less stringent than the recommend emission 

limits for various coating categories in the 2007 Metal Furniture Coatings 

CTG (e.g., the VOC table in the rule has a 3.5 lb/gal air dried limit for 

extreme high gloss coatings whereas the CTG recommends a 2.8 lb/gal 

air dried limit for the same category). Moreover, the CTG recommends an 

overall capture and control efficiency of 90% whereas Section 305 only 

requires an overall capture and control efficiency of 85%. The CTG also 

recommends work practice standards for both coating and cleaning 

activities, whereas the rule only contains work practice standards for 

surface preparation and clean-up in Section 304. 

Response: Staff has revised proposed Rule 451 to conform to all of the 

recommendations in the 2007 CTG for Metal Furniture Coatings. Refer to 

the Summary of Requirements section of this staff report for further 

details. 

Comment #9: Recommendation: SCAQMD Rule 1107 has lower limits for the extreme 

high gloss, extreme performance, pre-fabricated architectural component, 

and general one-component coating categories. Please consider making 

Rule 451 limits as stringent as Rule 1107 for these categories. 

Response: See response to EPA comment #8. Staff has revised proposed Rule 451 

to conform to the recommendations in the 2007 CTG for Metal Furniture 

Coatings, including lowering the VOC limits for high-gloss, extreme 

performance, and general one-component coatings applied to metal 

furniture. 

The projected 2018 inventory for other metal parts and products coatings 

is only 0.09 tons per day of VOC. Rule 451 contains two categories, 

camouflage coatings and electrical insulating coatings, with limits that are 

more stringent than SCAQMD Rule 1107. In addition, SCAQMD Rule 

1107 contains more specialty coating categories, with higher VOC limits 

than are allowed under the “All Other Coatings” category of Rule 451. 

For these reasons, Staff determined that, as potential all-feasible 

measures, lowering the VOC limits for the coatings applied to other 

miscellaneous metal parts and products will have an insignificant impact 

on overall emissions. Therefore, Staff is not proposing to lower these 

VOC limits at this time. 

Rule 452

Comment #10: Potential Approvability Issue: Unlike similar rules in other areas, Rule 452 
Appendix D 

Public Comments 

August 25, 2008, Page 116

does not require sources to use specific coating application methods 

(see, for example, Section (c)(4) of South Coast Air Quality Management 

District (SCAQMD) Rule 1125 and Section 5.6.2 of San Joaquin Valley 

Air Pollution Control District (SJVUAPCD) Rule 4604). Please add 

provisions to Rule 452 that specify appropriate coating application 

methods. 

Response: Staff has added a new section that provides a list of approved coating 

application methods. This added section is the same as Section 303 in 

Rules 451 and 456, and includes an additional option to an air pollution 

control device with an overall control efficiency of at least 85.5%. 

Definitions for each method (roll coater, dip coat, electrostatic spray, flow 

coat, HVLP and LVLP application equipment, and hand application 

equipment) have also been added. 

Comment #11: Potential Approvability Issue: We noticed that there were several other 

California rules that had more stringent requirements than Rule 452. 

Please explain why each of the following more stringent requirements are 

not feasible in Sacramento or change Rule 452 to be equally as stringent: 

• The VOC limit for end sealing compound is 440 g/L. BAAQMD 

Rule 8-11 and SJVUAPCD Rule 4604 have a 60 g/L limit for drum, 

pail and lid end sealing compounds, and a 20 g/L limit for end 

sealing compounds in all other categories. 

• SCAQMD Rule 1125 has a 20 g/L limit for end sealing compounds 

for food/beverage cans and a 0 limit for end sealing compounds 

for non-food containers. 

• The VOC limit for three piece can interior body spray is 510. 

BAAQMD Rule 8-11 and SJVUAPCD Rule 4604 both have a 360 

g/L limit for this category. 

• The VOC limit for two piece can interior body spray is 440. 

BAAQMD Rule 8-11 and SJVUAPCD Rule 4604 both have a 420 

g/L limit for this category. 

• Section 302.1 requires an overall 85% capture and control 

efficiency for add-on control devices. BAAQMD Rule 8-11 and 

SJVUAPCD Rule 4604 both require an overall 90% capture and 

control efficiency. 

 

Response: Staff has revised proposed Rule 452 to include all of the recommended 

changes. Refer to the Summary of Requirements section of this staff 

report for further details. 

Comment #12: Recommendation: Section 302 allows sources to comply with the use of 

an add-on control device only if emissions do not exceed the level which 

would be achieved from the equivalent use of compliant coatings. 

However, Rule 452 does specify how to calculate whether the control 

device is achieving emission reductions that would be equivalent to using 

compliant coatings. We recommend adding a section that's similar to 

SJVUAPCD Rule 4604 Section 5.2.9. 
Appendix D 

Public Comments 

August 25, 2008, Page 117

Response: Staff has added a new section that provides an equation for calculating 

emissions equivalency. This added section is the same as Section 304.3 

in the proposed Rule 466. 

Rule 454

Comment #13: Recommendation: Section 304.1 gives sources the option of complying 

with rule requirements by operating a vapor degreaser with a water 

separator. We recommend adding a definition for water separator. See 

SCAQMD Rule 1122 Section (b)(40) for potential draft rule language. 

Response: Staff has added a definition for “water separator,” consistent with the one 

in SCAQMD Rule 1122. 

Comment #14: Recommendation: Rule 454 requires that airtight/airless cleaning systems 

not have a vapor leak of more than 50 parts per million measured as 

methane at the outlet of the airtight/airless cleaning system. SCAQMD 

Rule 1122 section (f)(4) requires that airless/air-tight equipment be 

maintained in a vapor-tight, leak-free condition and states that any leak is 

a violation. Please consider whether a similar provision would strengthen 

Rule 454. 

Response: SCAQMD Rule 1122 does not define what constitutes a vapor-tight, leakfree condition. Staff therefore considers Rule 454 to be as stringent as 

SCAQMD Rule 1122 in regards to requiring leak-free airtight/airless 

cleaning systems. 

Rule 456

Comment #15: Recommendation: Section 302 limits the VOC content of strippers to 300 

g/L of VOC per liter of material. Section B.6 of Imperial Rule 425 limits the 

VOC content of strippers to 200 g/L. Please consider inserting this lower 

limit into Rule 456. 

Response: Imperial County APCD Rule 425 exempts stationary source using less 

than 3 gallons per day of aerospace coatings, which is equivalent to 

1,095 gallons per year. Proposed Rule 456 exempts sources using less 

than 55 gallons per year of aerospace materials, including coatings and 

strippers. Because District sources use less coating volume than Imperial 

County’s exemption level, the combination of the exemption level and 

VOC limits in proposed Rule 456 is more stringent and will lead to greater 

emission reductions. 

Comment #16: Recommendation: The current limit for adhesives is 600 g/L. SJVUAPCD 

Rule 4605 has three different categories for adhesives - non-structural 

adhesives with a 250 g/L limit, structural autoclavable adhesives with a 50 

g/L limit, and structural nonautoclavable adhesives with a 850 g/L limit. 

Please consider whether including a category for non-structural 

adhesives or structural autoclavable adhesives would allow the District to 

obtain additional emission reductions. 
Appendix D 

Public Comments 

August 25, 2008, Page 118

Response: SJVUAPCD Rule 4605 exempts aerospace coating operations using less 

than 4 gallons per day of aerospace materials, which is equivalent to 

1,460 gallons per year. Proposed Rule 456 exempts sources using less 

than 55 gallons per year of aerospace materials. Because District 

sources use less coating volume than San Joaquin’s exemption level, the 

combination of the exemption level and VOC limits in proposed Rule 456 

is more stringent and will lead to greater emission reductions. 

Comment #17: Recommendation: The current limit for adhesive bonding agents is 780 

g/L. SJVUAPCD Rule 4605 has six different categories for adhesive 

bonding primer, three with a 250 g/L limit, and three with a 805 g/L limit. 

Please consider if including additional categories that have a 250 g/L limit 

would allow the District to obtain additional emission reductions. 

Response: See response to EPA comment #16. SJVUAPCD Rule 4605 exempts 

aerospace coating operations using less than 4 gallons per day of 

aerospace materials, which is equivalent to 1,460 gallons per year. 

Proposed Rule 456 exempts sources using less than 55 gallons per year 

of aerospace materials. . Because District sources use less coating 

volume than San Joaquin’s exemption level, the combination of the 

exemption level and VOC limits in proposed Rule 456 is more stringent 

and will lead to greater emission reductions. 

Rule 463

Comment #18: Potential Approvability Issue: Section 306 provides for a rolling 30 day 

averaging period for compliance with the rule's emission limits. From 

conversations with the District, we understand that only one very small 

source that refinishes antiques is currently utilizing this averaging 

provision. We are aware of no other areas that have SIP approved rules 

with such an extensive compliance period for wood coatings. Though we 

recognize that rules in other areas that have daily or no averaging 

provisions might be less stringent than Rule 463 in some other respects, 

we recommend the District remove this provision. However, if the District 

significantly narrows the scope of the provision (e.g., to very small 

sources refinishing antiques), we believe that the District can utilize our 

1% Screening Analysis (see December 2002 Memo from Andrew 

Steckel) to demonstrate that the averaging provision does not cause the 

rule to deviate from RACT or affect attainment of the eight hour ozone 

standard. 

Response: The only wood coating facility that currently uses this emissions 

averaging provision performs restorations of historical antique wood 

products. Based on the EPA recommendations above, Staff proposes to 

limit the applicability of this emissions averaging provision to this wood 

facility, and limit the total annual usage of such coating products to 20 

gallons per year. Using the 1% screening analysis, Staff was able to 

show that the emissions benefits from removing the averaging provision 

(and thus having this facility subject to the VOC limits in this rule) 

represent only 0.04% of baseline emissions, which is much less than 1%. 

Refer to the Summary of Requirements section of this staff report for 
Appendix D 

Public Comments 

August 25, 2008, Page 119

further details. 

Comment #19: Potential Approvability Issue: Please demonstrate that Rule 463 meets 

RACT though the exemption for military stencil coatings in Section 110.5 

is not in the 1996 Wood Furniture Manufacturing CTG. 

Response: Staff proposes to remove Section 110.5 in proposed Rule 463. The 

military facility that used this exemption is no longer in operation. 

Comment #20: Recommendation: Section 110.4 exempts the coating of architectural 

components or structures, not coated in a shop environment. We 

recommend that the District add rule language to Section 110.4 to clarify 

that the exempted wood products are still subject to the requirements in 

the District's architectural coatings rule. 

Response: Staff has added rule language clarifying that such components and 

structures are subject to Rule 442. 

Comment #21: Recommendation: The VOC limit for strippers is 350 g/l. San Diego 

County Air Pollution Control District (SDAPCD) Rule 67-11 Section 

(d)(5)(i) has a limit of 200 g/l for strippers. We recommend that the district 

include this lower limit in the rule. 

Response: See response to CARB comment #10. SDAPCD Rule 67-11 includes an 

exemption for sources with coating usage levels below 500 gallons per 

year, while Rule 463 exempts sources with coating usage levels less than 

55 gallons per year. The District exemption is more stringent than the 

SDAPCD exemption, and therefore Staff is not proposing to lower the 

VOC limit for strippers. 

Comment #22: Recommendation: Section 306 provides for a rolling 30 day averaging 

period for compliance with the rule's emission limits. Please confirm that 

District policy interprets any violation of the averaging period as a 

violation of each day of the averaged period. EPA recommends inserting 

language similar to the following to clarify this in the rule: “Any rolling 30-

day averaged value which exceeds the applicable emission limit shall 

constitute a violation of the rule for each day of the averaged period.” 

Response: Staff now proposes to insert rule language in Rule 463 as requested. 

Comment #23: Sources using less than 55 gallons per year of wood product coatings 

and/or strippers are exempt from the requirements of this rule. BAAQMD 

Rule 8-32, SJVUAPCD Rule 4606, and Santa Barbara County Air 

Pollution Control District (SBAPCD) Rule 351 limit this exemption to 20 

gallons per year. Please consider making Rule 463 as stringent. 

Response: See response to CARB comment #8. Unlike Rule 463, the rules at other 

air districts that contain this 20 gallon/year exemption do not establish 

VOC limits for refinishing of wood products. Staff is proposing to maintain 

the current exemption level with the existing and proposed VOC limits for 

refinishing and repairing, which will collectively deliver greater VOC 
Appendix D 

Public Comments 

August 25, 2008, Page 120

reductions than the requirements in other districts. 

Comment #24: The VOC limit for “High-Solid Stain” in Section 302.2 is 350 g/l. 

SJVUAPCD Rule 4606, SBAPCD Rule 351, and VCAPCD Rule 74-30 all 

have a limit of 240 g/l for this category. Please consider making Rule 463 

as stringent. 

Response: See response to CARB comment #9. Staff determined that, as potential 

all-feasible measures, lowering the VOC limits for high-solid stains and 

sealers to the most stringent limits in the San Joaquin and Ventura 

County rules would reduce VOC emissions by less than 0.02 tons per 

day. Therefore, Staff is not proposing to lower these limits. 

Comment #25: Recommendation: The VOC limit for “Sealer” in Section 302.2 is 275 g/l. 

VCAPCD Rule 74-30 has a limit of 240 g/l for this category. Please 

consider making Rule 463 as stringent. 

Response: See response to CARB comment #9. Staff determined that, as potential 

all-feasible measures, lowering the VOC limits for high-solid stains and 

sealers to the most stringent limits in the San Joaquin and Ventura 

County rules would reduce VOC emissions by less than 0.02 tons per 

day. Therefore, Staff is not proposing to lower these limits. 

Rule 464

Comment #26: Recommendation: While the recordkeeping provisions in Section 501.4 

through Section 501.7 require sources to keep daily records on-site of the 

types and amounts of organic compounds used for continuous processes 

as well as information about each production batch for batch processes, 

they do not specifically require sources to record the VOC content of the 

materials used. We recommend adding a recordkeeping requirement 

specifically for the VOC content of materials used. 

Response: Staff has added recordkeeping requirements for the VOC content of 

materials used in the proposed Rule 464. 

Rule 465

Comment #27: Potential Approvability Issue: We noticed several other California rules 

have more stringent requirements than Rule 465. Please explain why 

having the following more stringent requirements is not feasible or change 

Rule 465 to be equally as stringent: 

• Section 301.1.a.1 requires that general resins have a monomer 

content of no more than 35%. Ventura County Air Pollution 

Control District (VCAPCD) Rule 74.14 and SCAQMD Rule 1162 

have replaced the general purpose resin category with four subcategories: marble resins (10% monomer content or 32% as 

supplied, no fillers), solid surface resins (17% monomer content), 

tub/shower resins (24% monomer content or 35% as supplied, no 
Appendix D 

Public Comments 

August 25, 2008, Page 121

fillers), and lamination resins (31% monomer content or 35% as 

supplied, no fillers). 

• Section 301.1.a.2 requires that pigmented gel coats have a 

monomer content of no more than 45%. VCAPCD Rule 74.14 and 

SCAQMD Rule 1162 have replaced the limit for pigmented gel 

coats with lower limits in three sub-categories: white and off white 

(30% monomer content), non-white (37% monomer content), and 

primer (28% monomer content). 

• Section 301.1.a.3 requires that specialty resins and clear gel coats 

have a monomer content of no more than 50%. Rule 74.14 and 

SCAQMD Rule 1162 have replaced the limit for clear gel coats 

with two sub-categories that have lower limits: marble resins (40% 

monomer content) and other resins (44% monomer content). Rule 

465 defines specialty resins as "any...resin used to make product 

for exposure to one or more of the following extreme 

environmental conditions: acute or chronic exposure to corrosive 

agents, caustic agents, acidic agents, or flame." Both Rule 74.14 

and SCAQMD Rule 1162 also have 38% monomer content limit 

for fire retardant resin, 48% monomer content limit for corrosion 

resistant resin, and 40% monomer content limit for high strength 

resin. 

• Section 301.2 requires that emission control systems have an 

overall 85% control efficiency. Rule 74.14 and SCAQMD Rule 

1162 both require an overall capture and control efficiency of 90%. 

Response: EPA identified this as a potential approvability issue based on the fact 

that there is a polyester resin operation within the District that will become 

a major source of VOC if the District “bumps up” to a classification of 

severe nonattainment, as expected. Section 182(b)(2) of the federal 

Clean Air Act requires RACT for all major sources of VOC and all source 

categories for which EPA has promulgated a CTG. In recent discussions 

with the source, however, Staff has learned that the source is in the 

process of submitting an application to modify the permit to limit the 

potential-to-emit to less than 25 tons per year. In light of this 

development and because polyester resin operations is not a CTG 

category, Staff believes that this should no longer be considered a 

RACT/approvability issue. As potential all-feasible measures, Staff 

determined that lowering the VOC limits to those contained in the South 

Coast and Ventura County rules will only reduce VOC emissions by 0.1 

tons per day. Therefore, Staff is not proposing to lower these limits. 

However, Staff is proposing to increase the required overall capture and 

control efficiency to 90%. 

Rule 466

Comment #28: Potential Approvability Issue: The VOC standards table in Section 301 

allows for different limits for the solvent cleaning of architectural coating 
Appendix D 

Public Comments 

August 25, 2008, Page 122

application equipment for water based coatings and solvent based 

coatings. Until one year after rule adoption, for water based coatings, 

cleaning without an enclosed gun cleaner has a 50 g/L limit, whereas for 

solvent based coatings, cleaning without an enclosed gun cleaner can 

have a limit up to 300 g/L. 

 In order to ensure that these limits are enforceable, please define water 

based coating and solvent based coating. Also, under solvent based 

coatings, cleaning architectural coating equipment without an enclosed 

gun cleaner at the jobsite has a 300 g/L limit whereas cleaning 

architectural coating equipment without an enclosed gun cleaner not at 

the jobsite has a 50 g/L limit. In order to ensure that these limits are 

enforceable, please define job-site in the rule. 

Response: Staff has added definitions for “water based coating,” “solvent based 

coating,” and “jobsite.” 

Comment #29: Recommendation: Section 110.4 exempts the cleaning of the nozzle tips 

of automated spray equipment from the requirements of Section 302.2. 

Section 302.2 is one of many options that sources can pick from in order 

to be in compliance with the rule's requirements for cleaning devices and 

methods. Please ensure that the reference in Section 110.4 to Section 

302.2 is correct. 

Response: The reference to Section 302.2 is incorrect. Section 110.4 was intended 

to exempt such cleaning from the requirements in Section 302 as a 

whole, not only the one option indicated in the current Rule 466. Staff 

has corrected this typographical error. 

Comment #30: Recommendation: The District is widening the applicability of the rule by 

including VOC content limits for the sterilization of food manufacturing 

and processing equipment. We recommend clarifying this in Section 102, 

Applicability. 

Response: Staff has added this clarification to the Applicability section of proposed 

Rule 466. 

Comment #31: Recommendation: To further clarify the applicability of the VOC limits in 

table 301.1, we recommend adding a definition for pharmaceutical 

product and general work surfaces. Potential draft language can be found 

in SCAQMD Rule 1171. 

Response: Staff has added definitions for these terms, consistent with those 

specified in SCAQMD Rule 1171. 

Letter from Don Eggleston, Office of State Publishing (August 20, 2008) 

Comment #1: OSP requests the removal of Section 302.2 in Rule 450, which specifies a 

15% usage limit for solvents used for cleaning metering rollers and 

printing plates. OSP has been using new lower-VOC blanket wash for 

the last two months and discovered that smaller quantities of this wash 
Appendix D 

Public Comments 

August 25, 2008, Page 123

are needed to do the job when compared to washes previously used. 

This transition has already made a substantial impact on reduction of 

VOC emissions and waste generation at OSP. Unfortunately, this 

situation creates solvent usage ratios that exceed the 15% limit because 

our plate cleaner and metering roller cleaner usage is relatively the same 

from month to month. 

Response: Section 302.2 now has a proposed sunset date of January 1, 2011, when 

the non-newsprint VOC limits for blanket/roller washes, metering 

rollers/printing plates, and other on-press components become effective. 

The VOC limits for all three of these categories will be 100 g/l. To ensure 

equivalency with the 15% usage limit, Section 302.2 must remain in effect 

until the 1/1/11 effective date for the three VOC limits mentioned above. 

 Section 110.8 of proposed Rule 450 provides an exemption from the 15% 

usage limit for presses that use materials for cleaning metering rollers 

and printing plates containing 100 g/l of VOC or less.