01/14 Rule 74.31: 1

VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT

RULE 74.31 – METALWORKING FLUIDS AND DIRECT-CONTACT LUBRICANTS (Adopted 11/12/2013)

A. Applicability and Purpose

The provisions of this rule apply to any person wh o uses metalworking fluids or directcontact lubricants on products or parts; and to any manufacturer or supplier who supplies, sells, or offers for sale either metalworking fluid s or direct-contact lubricants for use at

industrial or commercial facilities.

This rule shall apply to all Reactive Organic Comp ound (ROC) containing fluids used for metalworking including, but not limited to, metal r emoval, metal forming, metal treating, or lubricating operations where the metalworking fl uid or direct-contact lubricant come into contact with products or parts including, but not limited to, blanking, broaching, coining, cutting, drilling, drawing, forming, forgi ng, grinding, heading, honing, lapping, marquenching, milling, piercing, quenching, roll fo rming, rolling, stamping, tapping, threading, turning, and wire drawing.

This rule also applies to ROC containing fluids us ed for metal protection, including rust and corrosion prevention and inhibition, but shall not apply to coatings, sealants, adhesives, or lubricants regulated by other Distric t rules including, but not limited to, Rule 74.12, Surface Coating of Metal Parts and Prod ucts, or 74.13, Aerospace Assembly and Component Manufacturing Operations.

B. Requirements

1. ROC Content. No person shall use or solicit the use of any met alworking fluid,

vanishing oil, or direct-contact lubricant with a R eactive Organic Compound (ROC) content in excess of the following limits, as applied:

Grams of ROC per Liter of Material (pounds per gall on) Fluid Category Effective January 1, 2014 Vanishing Oil 50 (0.42) Metalworking Fluid: Metal Forming 75 (0.63) Metal Removal – General 75 (0.63) Metal Removal – Precision Metal 130 (1.08) Metal Treating 75 (0.63) Metal Protecting – General 50 (0.42)

Metal Protecting – Military Specified

Preservative 340 (2.83)

Direct-Contact Lubricant 50 (0.42)01/14 Rule 74.31: 2

2. Depletion of Metalworking Fluid User Inventory : Until January 1, 2015, a

person may use a metalworking fluid or direct-conta ct lubricant in excess of the applicable ROC content limit if the product was pur chased prior to January 1, 2014. Purchase records, sales invoices, or bill of sales may be used to verify eligibility for this provision.

3. Prohibition of Sale . No person shall manufacture, supply, offer for s ale, sell or

distribute to any person a metalworking fluid or di rect-contact lubricant for use in the District which, at the time of sale, contains m ore ROC per liter of material than the corresponding limit in effect in Subsectio n B.1. The ROC content of metalworking fluids or direct contact lubricants th at are normally diluted prior to use shall be calculated using the minimum recommend ed dilution ratio per product label or product data sheet.

This prohibition of sale shall not apply to a man ufacturer or supplier of a noncomplying metalworking fluid or direct-contact lubr icant provided this fluid or lubricant was sold to an independent distributor th at was informed in writing by the manufacturer or supplier that this fluid or lub ricant does not comply with District regulations.

This prohibition of sale shall not apply to any m etalworking fluid or direct-contact

lubricant that is collected and directed to an emis sion control system that complies with the provision of Subsection B.4.

4. Control Equipment

A person may comply with the provisions of Subse ction B.1 by using an emission

control system provided that:

a. The control device shall reduce reactive organ ic compound (ROC)

emissions from an emission collection system by at least 95 percent, by weight, or the output of the air pollution control device is no more than 5 ppm ROC by volume calculated as carbon with no dilu tion, and

b. The emission collection system has been demons trated to collect at least

90 percent by weight of the ROC emissions generated by the sources of

ROC emissions.

c. Written approval in the form of an Authority t o Construct and a Permit to

Operate for such equipment is received from the Air Pollution Control Officer (APCO).

d. Any approved emission control system shall be ma intained and used at all times in proper working condition.01/14 Rule 74.31: 3

5. Administrative Requirements

a. Inventory Compliance List: Any owner or operator subject to this rule

shall develop and maintain a VOC or ROC listing of metalworking fluids and direct-contact lubricants purchased for use at the facility. This list shall contain at least the following information an d shall be updated within seven (7) calendar days from the date of receipt of a new metalworking fluid or direct contact lubricant at the facility:

1) Name of Company, Facility Address, and APCD Permit Number, if applicable. 2) For each metalworking fluid and direct-contac t lubricant: the manufacturer name, product name, product number or ID code, fluid category according to this rule, VOC or ROC c ontent in grams per liter of material, and corresponding ROC limit, if applicable.

b. Monthly Purchase Records : Monthly purchase records shall be kept of

all ROC-containing metalworking fluids and direct-c ontact lubricants and shall include product supplier, manufacturer name, product name, product number or ID code, and quantities purchased. Month ly purchase records may be used to verify the validity of the inventory compliance list.

c. All records shall be retained for a minimum of two years from the date of each entry, and shall be made available to District personnel upon request.

6. Storage and Disposal of ROC-Containing Materials : All ROC-containing

materials shall be stored in closed vapor-tight, no n-leaking, nonabsorbent containers, except while adding or removing them fr om containers.

7. Container VOC Labeling Requirement. No person shall sell or distribute any

container whose contents include any metalworking f luid or direct-contact lubricant subject to this rule without displaying t he VOC content on the container.

C. Exemptions

1. The Sales Prohibition in Subsection B.3 and the Administrative Requirements in

Subsection B.5 shall not apply to metalworking flui ds and direct-contact lubricants subject to the consumer products regulat ions of the Air Resources Board (ARB) pursuant to Title 17. California Code o f Regulations, beginning at

Section 94507.

2. The ROC content limits of Subsection B.1 shall not apply to:01/14 Rule 74.31: 4 a. The use of any metalworking fluid or direct-cont act lubricant subject to ARB Consumer Product Regulations and applied via a hand-held prepressurized non-refillable aerosol product, provide d 100 cans or less per calendar year are used based on purchase and/or usa ge records.

b. The use of any metalworking fluid or direct co ntact lubricant for the

purpose of maintaining or repairing operator-owned machine tools.

c. Research Operations.

3. The Sales Prohibition in Subsection B.2 shall n ot apply to metalworking fluids

and direct-contact lubricants sold in this District for shipment and use outside of this district or for shipment to other manufacturer s for repackaging.

4. The ROC content limits of Subsection B.1 and th e Sales Prohibition in Subsection

B.2 shall not apply to metalworking fluids or direc t-contact lubricants designed by the manufacturer to be used solely for the followin g operations: a. Lapping;

b. Sinker EDM c. Avionics, assembled aircraft or any assembled aircraft component d. Space vehicle components e. Fluids utilizing the control equipment option in Subsection B.4

5. The Administrative Requirements in Subsection B. 5 shall not apply to metalworking fluids that are “Super Compliant,” (RO C content is 50 grams per liter of material or less). If a shop uses both su per compliant and non-super compliant materials, the administrative requirement s in Subsection B.5 still apply to the non-super compliant materials. Any person c laiming this exemption shall provide documentation or other evidence to substant iate this claim, upon request of APCD personnel. This exemption does not apply t o metalworking fluids used at metal forging operations.

D. Test Methods and Procedures

The following test methods and procedures shall be used to determine compliance.

1. Determination of ROC Content: ASTM E 1868-10, Standard Test Method for

Loss-On-Drying by Thermogravimetry. Quality assura nce and quality control procedures shall be conducted using SCAQMD Addition al Requirements to ASTM Standard Test Method E 1868-10 Loss on Drying by Thermogravimetry for Rule 1144 Metalworking Fluids and Direct-Contac t Lubricants, December 2010. Water content shall be determined by ASTM D 4017-02(2008)e1 (Standard

Test Method for Water in Paints and Paint Materials by Karl Fischer Method) if applicable to the specific sample. The exempt solv ent content shall be determined01/14 Rule 74.31: 5 by SCAQMD Method 303-91, Revised August 1996 (Deter mination of Exempt Compounds). Exempt Perfluorocarbon Compounds The following classes of compounds: cyclic, branche d, or linear, completely fluorinated alkanes; cyclic, branched, or linear, c ompletely fluorinated ethers with no unsaturations; cyclic, branched, or linear, comp letely fluorinated tertiary amines with no unsaturations; and sulfur-containing perfluorocarbons with no unsaturations and with sulfur bonds only to carbon and fluorine, will be analyzed as exempt compounds for compliance, only when manuf acturers specify which individual compounds are used in the coating formul ation. In addition, the manufacturers must identify the USEPA, CARB, or the SCAQMD approved test methods used to quantify the amount of each of thes e exempt compounds.

2. Determination of Flash Point: ASTM D93-07, Sta ndard Test Methods for Flash

Point by Pensky-Martens Closed Cup Tester.

3. The capture efficiency shall be determined ac cording to EPA's technical document, "Guidelines for Determining Capture Effic iency," January 9, 1995, and Methods in 40 CFR 51 Appendix M, Methods 204-204F, as applicable: Methods 204, Criteria for and Verification of a Per manent or Temporary Total Enclosure Method 204A, VOC Content in Liquid Input Stream Method 204B, VOC Emissions in Captured Stream Method 204C, VOC Emissions in Captured Stream (Dil ution Technique) Method 204D, VOC Emissions in Un-captured Stream f rom Temporary Total Enclosure Method 204E, VOC Emissions in Un-captured Stream f rom Building Enclosure, and Method 204F, VOC Content in Liquid Input Streams ( Distillation Approach)

Control system efficiency shall be determined by 40 CFR 60, Appendix A, Method 18, “Measurement of Gaseous Organic Compound Emissions by Gas Chromatography,” Method 25, “Determination of Total Gaseous Non-methane Organic Emissions as Carbon” or Method 25A, “Determ ination of Total Gaseous Organic Concentration Using a Flame Ionization Anal yzer.” Alternatively, South Coast AQMD Method 25.1, “Determination of Total Gas eous Non-methane Organic Emissions as Carbon,” or SCAQMD Method 25.3 (March 2000),

“Determination of Low Concentration Non-methane Non -ethane Organic Compound Emissions from Clean Fueled Combustion Sou rces,” may be substituted as applicable.

4. Alternative Test Methods: The use of other tes t methods may be used in place of

test methods specified in this rule if they are det ermined to be equivalent or better and approved, in writing, by the Air Pollution Cont rol Officer.01/14 Rule 74.31: 6

E. Violations

Failure to comply with any provision of this rule shall constitute a violation of this rule.

F. Definitions

1. “Direct-Contact Lubricant”: Any fluid that com es into direct contact with the

product or part during manufacturing or assembly an d is used to reduce friction and to prolong the life of machine tools or machine ry. Fluids defined as MetalForming Fluids (Subsection F.5) or Metal Removal fl uids (Subsection F.8) are not subject to the ROC content limit for direct contact lubricants.

2. “Exempt Organic Compounds”: As defined in Rule 2 of these Rules.

3. "Grams of ROC per Liter of Material"(VOC Actual ): The weight of ROC per

volume of material and calculated by the following equation:

Grams of ROC per Liter W s - W w - W es of Material =

_____________ V m

Where: W s = Weight of volatile compounds (grams)

W w = Weight of water (grams)

W es = Weight of exempt organic compounds (grams)

V m = Volume of material (liters)

4. “Lapping”: A manufacturing method that employs particles of an abrasive

material, suspended in a liquid carrier, between ro tating plates.

5. “Metal Forming Fluid”: Any fluid used at the t ool and workpiece interface to

facilitate the flow of metal over the tool and to e xtend the life of the tool. Common metal forming operations include, but are no t limited to, blanking, coining, drawing, forming, forging, heading, pierci ng, roll forming, stamping, and wire drawing.

6. “Metal Protecting Fluid”: Any fluid that inhib its or prevents the corrosion of

metal surfaces, and applied independently of any ot her metalworking, lubricating, or cleaning application.

7. “Metal Protecting – Military Specified Preserva tive: Any metal protecting

preservative that was formulated by the manufacture r to comply with Mil Spec MIL PRF 16173E Class II Corrosion Inhibitor, and is designed to protect ferrous and non-ferrous parts for indoor or covered storage and during shipping.01/14 Rule 74.31: 7

8. “Metal Removal Fluid”: Any fluid used at the w orkpiece interface to facilitate the

removal of metal from the part, cool the part and t ool, extend the life of the tool, and to flush away chips and debris. Common metal r emoval operations, include, but are not limited to, broaching, cutting, drillin g, grinding, honing, lapping, milling, tapping, threading, and turning.

9. “Metal Treating Fluid”: Any fluid used to remo ve heat from metal parts, affect

their hardness, and/or change the grain structure o f the metal. Common metal treating operations, include, but are not limited t o, marquenching and quenching.

10. “Metalworking Fluid”: Any fluid that facilita tes operations involving the

working, protecting, or modifying of metals, includ ing metal forming, treating and removal, and may consist of straight oils, emulsifi able oils, synthetic, or semisynthetic fluids.

11. “Precision Metal Removal Fluid”: Any fluid us ed for: a. Carbide grinding machine tools where the machi ne tool manufacturer

specifies the viscosity of the fluid, or b. Machining of aluminum or magnesium in single o r multiple spindle

automatic machines.

12. “Reactive Organic Compound (ROC)”: As defined in Rule 2 of these rules. The

term "volatile organic compound" (VOC) is equivalen t to ROC.

13. “Research Operation”: Any prototype operation whose product is not designed to

be sold and whose sole purpose is to develop someth ing new or test an update of an existing version.

14. “Sinker Electrical Discharge Machining (EDM)”: A method of removing material

by a series of rapid recurring electric arcing disc harges between an electrode and the workpiece, in the presence of an energetic elec tric field and in an insulating oil. EDM using a water-based dielectric fluid such as Wire EDM are not included

in this definition.

15. “Space Vehicle”: A vehicle designed to travel beyond the earth’s atmosphere.

16. “Solicit”: Solicit is to require for use or t o specify by written or oral contract.

17. “Vanishing Oil”: Any direct-contact lubricant or metalworking fluid containing

petroleum distillates having a flash point less tha n 200 o F (93 o C) and is designed to evaporate from the workpiece after first providing necessary lubrication.