Final Staff Report with Appendices

for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules

SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

FINAL STAFF REPORT

Amendments to the organic solvent cleaning sections of the following rules:

Proposed Rule 4603 (Surface Coating of Metal Parts and Products)

Proposed Rule 4604 (Can and Coil Coating Operations)

Proposed Rule 4605 (Aerospace Assembly and Component Coating 

Operations)

Proposed Rule 4606 (Wood Products Coating Operations)

Proposed Rule 4607 (Graphic Arts)

Revised Proposed Rule 4612 (Motor Vehicle and Mobile Equipment Coating 

Operations – Phase II)

Proposed Rule 4653 (Adhesives)

Proposed Rule 4661 (Organic Solvents)

Proposed Rule 4662 (Organic Solvent Degreasing Operations)

Proposed Rule 4663 (Organic Solvent Cleaning, Storage, and Disposal)

Proposed Rule 4684 (Polyester Resin Operations)

September 20, 2007

Prepared by: Sandra Lowe Leseth, Air Quality Engineer

Laura Weber, Air Quality Specialist

Reviewed by: George Heinen, Supervising Air Quality Engineer

Joven Nazareno, Senior Air Quality Engineer

Juscelino Siongco, Air Quality Engineer, Permit Services

Jeff Voorhees, Air Quality Specialist, Compliance

I. SUMMARY

A. Reasons for Rule Development and Implementation

In the San Joaquin Valley Air Basin (SJVAB), monitored levels of ozone exceed 

National Ambient Air Quality Standards (NAAQS), which are set at levels that protect 

public health and welfare. Consequently, the U.S. Environmental Protection Agency 

(EPA) has classified the SJVAB’s air quality as serious for its nonattainment 

designation for the federal eight-hour ozone NAAQS. Under the now revoked federal 

one-hour ozone standard, the SJVAB was classified as extreme nonattainment.

The federal Clean Air Act (CAA) requires air districts in nonattainment areas to prepare 

plans that are designed to achieve and maintain the NAAQS by the earliest practicable 
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date, and no later than attainment deadlines given in the CAA. The San Joaquin Valley 

Unified Air Pollution Control District (District) adopted the Extreme Ozone Attainment 

Demonstration Plan (EOADP) on October 8, 2004. The EOADP calls for a reduction in 

volatile organic compound (VOC) emissions by 2010 by implementing the solvent 

cleaning control measure to further reduce VOC emissions by introducing more 

stringent limits.

Although EPA has revoked the federal one-hour ozone NAAQS, the VOC emission 

reduction commitment for the solvent cleaning control measure must still be met. 

EPA’s final Phase 1 rule implementing the eight-hour ozone NAAQS (Federal Register 

Volume 69 page 23858 (69 FR 23858) and 70 FR 30592) identifies a number of federal 

CAA requirements that applied to an area by virtue of its one-hour ozone nonattainment 

classification and that continue to apply after revocation of the one-hour ozone NAAQS 

[Code of Federal Regulations Title 40 Section 51.900(f) (40 CFR 51.900(f))]. Because 

the SJVAB was classified as extreme nonattainment, and because an attainment 

demonstration (as defined by 40 CFR 51.905) is one of the requirements, the EOADP

becomes one of the requirements that still apply to the SJVAB by virtue of its former 

classification under the now-revoked one-hour ozone NAAQS. The EOADP uses the 

VOC emissions reductions from this solvent cleaning control measure to project 

attainment. Without the reductions from this control measure, the EOADP does not 

project attainment and therefore does not meet the requirements of 40 CFR 51.905. 

Thus the District must proceed with this rule amendment project’s emission reductions 

even though the one-hour ozone standard has been revoked.

B. Description of the Project

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

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

practicable, technologically feasible, and economically reasonable, as determined by 

the District’s Governing Board. 
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for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules

Table 1 – Rules Included in this Rulemaking Project

Rule # Rule Title

4603 Surface Coating of Metal Parts and Products

4604 Can and Coil Coating Operations

4605 Aerospace Assembly and Component Coating Operations

4606 Wood Products Coating Operations

4607 Graphic Arts

4612 Motor Vehicle and Mobile Equipment Coating Operations – Phase II

4653 Adhesives

4661 Organic Solvents

4662 Organic Solvent Degreasing Operations

4663 Organic Solvent Cleaning, Storage, and Disposal

4684 Polyester Resin Operations

II. BACKGROUND

The organic solvent cleaning portions of the rules incorporate three different types of 

emission control standards: performance standards, equipment standards, and work 

practice standards.

1. Performance Standards

The federal Clean Air Act’s definition of “performance standards” refers to an allowable 

emission limit, meaning a limit on quantity of pollutant emitted over a specified period of 

time or a percent reduction. In all of the rules listed in Table 1, the allowable VOC 

content of the solvent used for solvent cleaning is specified.

2. Equipment Standards

Equipment standards specify the design, use, and operation of a particular piece of 

equipment. This standard is used in several rules for detailing which types of coating 

application equipment are allowed.

3. Work Practice Standards

Work practices refer to the management plans and procedures that would be 

undertaken to reduce emissions. Requiring that containers be covered except when 

adding or removing material from the container is one example of a work practice 

standard. Each rule in this rule project identifies at least one work practice standard to 

limit VOC emissions.

For detailed requirements, please refer to the current rules, which are available on the 

District’s website at www.valleyair.org.
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III. PROPOSED CHANGES TO RULES

The California Health and Safety Code (CH&SC) Section 40914(b)(2) states that ozone 

attainment plans should include All Feasible Control Measures (AFCMs). The ARB 

interprets “every feasible control measure to mean that, at a minimum, air districts must 

consider regulations that have been successfully implemented elsewhere. They should 

also consider going beyond what has already been accomplished by evaluation of new 

technologies and innovative approaches that may offer potential emission reductions. 

Further, districts should consider not only technological factors, but also social, 

environmental, economic (e.g., cost effectiveness), and energy factors which prevail in 

a district, along with the resources realistically available to a district to adopt, 

implement, and enforce the measures.” 

In the context of rule development, District staff construes AFCM to mean that each 

rulemaking project seeks to obtain as much emission reduction from the rule’s source 

category as is expeditiously practicable, technologically feasible and economically 

reasonable, as determined by the District’s Governing Board. To this end, District staff 

compared the current emission limits or control technology against what limits or control 

technology has been promulgated in other districts, as well as reviewing the federal, 

state, and local Best Available Control Technology (BACT) clearinghouses for the most 

recent control technology available for the source category. 

This section of the staff report has two parts. The first part will discuss the proposed 

amendments that would be incorporated into all of the rules. The second part of this 

section will detail the proposed amendments that are unique to each rule.

A. Proposed Amendments that Affect All Rules

No changes are planned for either Section 1.0 (Purpose) or Section 2.0 (Applicability). 

This rule project would not affect which specific source categories are subject to the 

individual rules, therefore, no change is proposed for these two sections. In Section 3.0 

(Definitions), seven definitions would be added for clarity. These definitions would be: 

APCO, ARB, ASTM, CFR, EPA, normal business hours, and SCAQMD. The term 

“composite vapor pressure” would be removed from all rules except Rule 4605 

(Aerospace Assembly and Component Coating Operations). In all rules except Rule 

4605, the composite vapor pressure has been removed as a condition of use. In 

addition to the new definitions there have been two modifications to definitions. First, 

the definition of maintenance cleaning has been standardized to clarify that 

maintenance cleaning does not include the cleaning of application equipment. Second, 

the definition of thinner has been revised for clarity at the suggestion of ARB staff. 

Section 3.0 in each of the rules would be renumbered as needed. In Section 4.0, no 

change is the same for all rules. The proposed amendments for Section 4.0 are 

discussed below under the individual rule review.
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Section 5.0 (Requirements) outlines the provisions of the rule. For all rules, District 

staff is proposing to standardize certain terms. The terms “person,” “owner or 

operator,” and “operator” would be standardized throughout the rules to read “operator.” 

For emission control devices, “add-on device,” “pollution control equipment,” and other 

similar terms would be standardized to “VOC emission control system.” For rules 

associated with coating or printing, the coating/ink VOC content limits would not be 

changed as part of this rule development project. However, the VOC content limits 

table would be simplified to include only those coatings/inks currently specified and the 

associated VOC content limits and remove any date associated with the tables, since 

the dates have already passed.

The VOC content limits for cleaning solvents proposed for this rule project are based on 

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

Operations), last amended in July 2006. In October 1999, SCAQMD Rule 1171 

established a two-tier approach to lowering the VOC content limits for all solvent 

cleaning activities. Tier I was implemented in December 2001. The Tier II VOC limits 

had an original implementation date of July 1, 2005, but was subject to completion of 

technology assessments to determine feasibility of VOC content limits. For all 

categories except the cleaning of ink application equipment used for specific printing 

operations, the technology assessment was completed in August 2003. The 

technology assessment concluded that the Tier II VOC content limits were feasible for 

these source categories. For cleaning of ink application equipment used for 

lithography/letterpress, screen printing, and UV/EB inks, an interim VOC content limit of 

500 grams per liter was established for the cleaning of lithography/letterpress and 

screen printing application equipment. A slightly higher interim limit was established for 

cleaning UV/EB ink application equipment – 650 g/L. The technology assessment for 

the remaining source categories was completed in August 2006. SCAQMD staff 

recommended that the implementation date for the Tier II limits for the remaining 

source categories be extended by 18 months – until January 1, 2008. Based on 

SCAQMD’s technology assessment, District staff is proposing similar VOC content 

limits for solvents used for solvent cleaning with a similar timeline. 

The SCAQMD staff and printing industry representatives are in the middle of a 

technology assessment to determine if the 100-g/L limits for cleaning of ink application 

equipment used for lithography/letterpress, screen printing, and ultraviolet/electron 

beam inks (UV/EB) is technically feasible by 2008. District staff is proposing that the 

compliance for these source categories be January 1, 2010, allowing the SCAQMD and 

printing industry to complete their assessment and determine the feasibility of a 100 g/L 

VOC content limit. If SCAQMD staff determines that the limit is not technologically 

feasible, District staff would have enough time to re-open Rule 4607 (Graphic Arts) 

before the compliance deadline in order to include more appropriate VOC content limits 

for these specific source categories.

Although Table 2 shows many cleaning categories, each rule contains only the part of 

Table 2 that is most appropriate for the sources subject to the given rule. Operators 
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would have 12 months to come into compliance with the new VOC content limit. Based 

on the current rule project schedule, the compliance date would be September 2008 for 

all of the rules except Rule 4612 (Motor Vehicle and Mobile Equipment Coating 

Operations – Phase II). Since Rule 4612 does not become effective until January 1, 

2009, District staff is proposing that the solvent cleaning VOC content limits become 

effective on the same date. The solvent-cleaning portions of Rule 4602, the Phase I 

version of Rule 4612, will remain in place until Rule 4612 becomes effective.
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Table 2 –VOC Content Limits for Solvents Used in Solvent Cleaning

Solvent Category Effective through 

September 20, 2008

Effective on 

September 21, 2008

VOC Limit 

in g/L (lb/gal)

Proposed VOC Limit 

in g/L (lb/gal)

A. Product Cleaning During Manufacturing Process or Surface Preparation for 

Coating, Adhesive, or Ink Application

1. General 50 (0.42) 25 (0.21)

2. Electrical Apparatus Components 

and Electronic Components

500 (4.2) 100 (0.83)

3. Medical Devices & Pharmaceuticals 800 (6.7) 800 (6.7)

B. Repair and Maintenance Cleaning

1. General 50 (0.42) 25 (0.21)

2 Electrical Apparatus Components 

and Electronic Components

900 (7.5) 100 (0.83)

3 Medical Devices & Pharmaceuticals

3.1 Tools, Equipment, & Machinery 800 (6.7) 800 (6.7)

3.2 General Work Surfaces 600 (5.0) 600 (5.0)

C. Cleaning of Coatings/Adhesives/Polyester Resin Application Equipment

1. Coatings or Adhesives 550 (4.6) 25 (0.21)

2. Polyester Resin 50 (0.42) 25 (0.21)

3. Sheet coater for three-piece can 550 (4.6) Effective 9/21/2008 - 550 (4.6)

Effective 10/1/2011 - 250 (2.3)

D. Cleaning of Ink Application Equipment

1. General 50 (0.42) 25 (0.21)

2. Flexographic Printing 50 (0.42) 25 (0.21)

3. Specialty Flexographic Printing 600 (5.0) 100 (0.83)

4. Gravure Printing

4.1 Publication 450 (3.8) 100 (0.83)

4.2 Packaging 50 (0.42) 25 (0.21) 

5. Lithographic or Letterpress Printing

5.1 Roller Wash Step 1 600 (5.0) Effective 9/21/2008 – 500 (4.2)

Effective 1/1/2010 - 100 (0.83)

5.2 Roller Wash – Step 2; Roller 

Wash – not specified, Blanket 

Wash, and On-Press 

Components

800 (6.7) Effective 9/21/2008 – 500 (4.2)

Effective 1/1/2010 - 100 (0.83)

5.3 Removable Press 

Components 50 (0.42) 25 (0.21)

6. Screen Printing 750 (6.3) Effective 9/21/2008 – 500 (4.2)

Effective 1/1/2010 - 100 (0.83)

7. Ultraviolet Ink/Electron Beam Ink 

Application Equipment (except 

screen printing)

800 (6.7) Effective 9/21/2008 - 650 (5.4)

Effective 1/1/2010 - 100 (0.83)

Continued on next page
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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Solvent Category Effective through 

September 20, 2008

Effective on 

September 21, 2008

VOC Limit 

in g/L (lb/gal)

Proposed VOC Limit 

in g/L (lb/gal)

E. Aerospace Assembly and Component Coating Operations

1. Surface Cleaning, Clean-up, or Jet 

Engine or Rocket Engine Gas Path 

Cleaning or Flushing

200 g/L or < 45 mm Hg 

composite vapor pressure

200 g/L or < 45 mm Hg 

composite vapor pressure

2. Coating Strippers 300 g/L or < 9.5 mm Hg 

composite vapor pressure

300 g/L or < 9.5 mm Hg 

composite vapor pressure

Some cleaning operations allow the use of cleaning solvents with VOC content greater 

than 50 grams per liter (g/L) for certain cleaning operations. Operators with these 

cleaning operations have several work practice standards and equipment standards to 

which they must adhere in addition to meeting the VOC content limits for the cleaning 

solvent. District staff is proposing that the VOC content limit for triggering the work 

practice/equipment standards be reduced to 25 g/L. Operators would have 12 months 

to come into compliance with the work practice/equipment standards using new VOC 

content limit. In lieu of complying with the solvent cleaning VOC content limits or work 

practice/equipment standards, operators may use an APCO-approved VOC emission 

control system that meets the specified control efficiency, provided that the emissions 

do not exceed the level that would have resulted from complying with the solvent 

cleaning methods and VOC content limits. The work practices requirement has been 

reworded to clarify the intent that the operator must both meet the limits of the solvent 

cleaning content and use work practices if the cleaning operation has an allowable VOC 

content limit greater than the current 50 g/L or the proposed 25 g/L.

If there were any rule sections that are no longer in effect, the sections would be 

removed. Sections outlining current requirements that contain dates in the past would 

have the dates removed to streamline the rule language.

In Section 6.0 (Recordkeeping), the records retention requirement would be clarified. It 

is proposed that records be retained on site for a period of five years, made available 

on site during normal business hours, and records submitted upon request. Although 

this was the intention of the provisions, it had not been stated as clearly in all of the 

rules. Test methods for determining composite partial pressure of solvents would be 

removed from all rules except Rule 4605 (Aerospace Assembly and Component 

Coating Operations) since any reference to composite vapor pressure for solvents has 

been superceded in all rules except Rule 4605.
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B. Proposed Amendments Unique to Individual Rules

This part of the final draft staff report highlights the proposed amendments unique to 

individual rules. The proposed changes mentioned in Section III.A of this final draft 

staff report would be incorporated in each rule listed in Table 1. 

1. Rule 4603 (Surface Coating of Metal Parts and Products)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 

(Definitions) would be revised as noted in Section III.A of this staff report. For this rule, 

the definitions of “bench scale” and “research and development” would be added for 

clarity. Several definitions have been modified for clarity at the suggestion of ARB staff. 

Section 4.0 (Exemptions) would have two exemptions removed. The first exemption 

removed has to do with low usage coatings. This exemption expired in 2002 and 

District staff recommends that the exemption language be taken out of the rule. The 

second exemption is one concerning BACT and offset requirements. Current Rule 

4603 specifically exempts a certain type of equipment/process modification from both 

BACT and offset requirements. It is EPA policy that no rule except a District’s New 

Stationary Source Rule (NSR Rule) can exempt a source from BACT and offset 

requirements. Therefore, the automatic exemption from BACT and offset requirements 

would be removed from the rule. The net result of removing the exemption would be 

that all equipment/process modifications would be required to meet any BACT or offset 

requirements specified in District Rule 2201 (New and Modified Source Review Rule) 

unless the modification meets the conditions for being exempt from BACT or offset 

requirements. The situations where a modification would be exempt from BACT or 

offsets are spelled out in District Rule 2201. 

The limited exemption for low-use of non-compliant coatings would be reworded for 

clarity to address an EPA concern. The revision represents a clarification of current 

requirements, not a change in the exemption. Three exemptions would be added to 

Section 4.0. Rule 4612 (Motor Vehicle and Mobile Equipment Coating Operations –

Phase II) will replace Rule 4602 (Motor Vehicle and Mobile Equipment Operations) on 

January 1, 2009. Rule 4603 cites Rule 4602 in the exemption section, so District staff 

is proposing that the exemption for Rule 4602 end on December 31, 2008 and that the 

exemption be added for Rule 4612, beginning January 1, 2009. The remaining 

proposed exemptions to be added to Section 4.0 are not new to the rule. These 

exemptions exist in the solvent cleaning portion of Section 5.0 (Requirements). They 

would be moved to Section 4.0 for clarity. 

The language in Section 5.0 for operator and VOC emission control system would be 

standardized, as noted in Section III.A of this staff report. In Section 5.3, the VOC 

emission control system requirements would be spelled out more clearly. There would 

be no added requirements and no requirements would be removed. Section 5.4 in the 

current rule no longer applies to operations subject to Rule 4603 as of November 14, 

2002 and, therefore, would be removed from the rule. The section titled “Organic 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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Solvent Cleaning, Storage and Disposal Requirements” would be revised to reflect the 

VOC content limits and effective dates proposed in Table 2 above. The solvent 

cleaning work practices requirement would be reworded to clarify that the operator must 

meet VOC content limits and utilize work practices for certain cleaning operations. The 

current exemptions from the solvent-cleaning solvent VOC content limits would be 

moved from this section to Section 4.0 (Exemptions).

In Section 6.0 (Administrative Requirements), provisions that were no longer in effect 

and dates on provisions that are already in effect would be taken out of the rule. 

Language would be standardized in this rule section and record retention provisions 

would be clarified, as noted in Section III.A of this staff report. References to composite 

partial vapor pressure would be removed throughout Section 6.0, since the standard is 

being deleted from the rule. The current rule does not specify how often coating s 

usage records to be kept. The proposed rule would specify daily records are to be kept 

by the operator.

Several changes would be made to Section 6.3 (Test Methods). The two test methods 

used for the VOC emission control system would be moved to a new subsection that 

would outline the calculation of overall capture and control efficiency. The current rule 

is not clear on how to perform the calculation. Two current test methods would also be 

revised. The test method for metallic/iridescent topcoat is incorrect, as noted by EPA 

Region IX staff in their comments earlier in the rule development process. SCAQMD 

Method 318 (Determination of Weight Percent of Elemental Metal in Coatings by X-Ray 

Diffraction Method, July 1996) would be replacing the current test method. The test 

method for acid content of pre-treatment wash primers would be updated to the latest 

EPA-approved version of ASTM D1613-96. Section 6.0 would be renumbered, as 

appropriate.

2. Rule 4604 (Can and Coil Coating Operations)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 

(Definitions) would be revised as noted in Section III.A of this staff report. For this rule, 

the definitions of “bench scale” and “research and development” would be added for 

clarity. Section 4.0 (Exemptions) would have an exemption removed that has to do with 

low usage coatings. This exemption expired in 2005. The exemption that replaced it 

would have the compliance date removed, since the date is in the past. The section 

would be renumbered as appropriate.

The language in Section 5.0 for operator and VOC emission control system would be 

standardized, as noted in Section III.A of this staff report. In Section 5.3 (Prohibition of 

Specification and Sale), the subsections with compliance dates prior to January 2006 

would be removed from the rule. The section titled “Organic Solvent Cleaning, Storage 

and Disposal Requirements” would be revised to reflect the VOC content limits and 

effective dates proposed in Table 2 above, with the exception of sheet coating. Work 

practices would be triggered at 50 g/L until 12 months after rule adoption date, at which 
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time the trigger point of 25 g/L would begin. Facilities that utilize the work practices 

specified in the rule are currently allowed to use solvent cleaners with a VOC content 

limit of 550 g/L. For cleaning of coating application equipment that is not three-piece 

sheet coaters, the maximum allowable VOC content for cleaning outside the control of 

a VOC emission control system would go to 25 g/L. For cleaning of three-piece can 

sheet coating equipment outside a VOC emission control system, the maximum 

allowable VOC content would remain 550 g/L through September 30, 2011. As of 

October 1, 2011, the District would allow a maximum VOC content limit of 250 g/L to 

clean sheet coaters for three-piece cans. The SCAQMD in Rule 1177 does not allow 

for the use of solvent cleaners for the cleaning of sheet coaters for three piece cans if 

those cleaners have a VOC content of 25 g/L or greater. However, this limit is not 

achieved in practice since all facilities within the South Coast basin that are required to 

comply with this limit utilize a VOC capture and control system. Currently, no effective 

solvent cleaners exist that will work for cleaning sheet coaters. However, the District is 

confident that by September 30, 2011 there will be solvent cleaner available for this 

purpose. In addition to the change in VOC content limit for coating application 

equipment, the solvent cleaning work practices requirement would be reworded to 

clarify that the operator must meet VOC content limits as well as utilize work practices 

for certain cleaning operations. Section 5.5 would have the compliance date removed, 

but no changes to the rule provisions themselves.

In Section 6.0 (Administrative Requirements), provisions that were no longer in effect 

and dates on provisions that are already in effect would be taken out of the rule. 

Language would be standardized in this rule section and record retention provisions 

clarified, as noted in Section III.A of this staff report. References to composite partial 

vapor pressure would be removed throughout Section 6.0, since the standard is being 

deleted from the rule. Within the solvent usage records, operators would be required to 

calculate the VOC content of a batch, if the operator mixes the ingredients. The 

subsections of Section 6.0 would be renumbered as needed.

3. Rule 4605 (Aerospace Assembly and Component Coating Operations)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 

(Definitions) would be revised as noted in Section III.A of this staff report. Four 

definitions would be removed since some adhesive categories have been replaced. 

The removed definitions would be epoxy phenolic primer, metal to metal/metal to 

honeycomb core bonding primer, military primer, and nitrile phenolic primer. Unlike other 

rules in this rule project, the definition of composite partial vapor pressure, which is not in 

the current rule, would be added to Section 3.0. This is because the cleaning solvent 

provisions allow composite vapor pressure as a specification. Section 3.0 would be 

renumbered as appropriate.

In Section 4.0 (Exemptions), the exemption associated with jet engine or rocket engine 

gas path cleaning or flushing operations that use trichloroethylene would be edited to 

remove an exemption that has expired. Jet engine or rocket engine flushing using any 
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solvent other than trichloroethylene would remain exempt. There is language in Section 

4.3 calling for records to prove the exemption. This language has been removed, since 

there are no usage limits for laboratories.

Current Rule 4605 specifically exempts a certain type of equipment/process 

modification from both BACT and offset requirements. The automatic exemption from 

BACT and offset requirements would be removed from the rule. The net result of 

removing the exemption would be that all equipment/process modifications would be 

required to meet any BACT or offset requirements specified in Rule 2201 (New and 

Modified Source Review Rule) unless the modification meets the conditions for being 

exempt from BACT or offset requirements. The situations where a modification would 

be exempt from BACT or offsets is spelled out in Rule 2201. It is EPA policy that no 

rule except a District’s New Stationary Source Rule (NSR Rule) can exempt a source 

from BACT and offset requirements.

The language in Section 5.0 for operator and VOC emission control system would be 

standardized, as noted in Section III.A of this staff report. Section 5.2.2 (Coating 

Application Equipment Cleaning) would be removed since the provisions of Section 

5.2.3, also titled “Coating Application Equipment Cleaning,” replaced it. Section 5.0 

would be renumbered as appropriate.

In Section 6.0 (Administrative Requirements), language would be standardized and 

record retention provisions would be clarified, as noted in Section III.A of this staff 

report. The test method related to composite vapor pressure was updated to SCAQMD 

308 (Quantification of Compounds by Gas Chromatography). As of January 2006, 

ASTM had withdrawn the test method cited in the rule. The test method requirements 

for a VOC emission control system would be clarified. The subsections of Section 6.0 

would be renumbered as needed.

4. Rule 4606 (Wood Products Coating Operations)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 

(Definitions) would be revised as noted in Section III.A of this staff report. In Section 

4.0 (Exemptions), current Rule 4606 specifically exempts a certain type of 

equipment/process modification from both BACT and offset requirements. The 

automatic exemption from BACT and offset requirements would be removed from the 

rule. The net result of removing the exemption would be that all equipment/process 

modifications would be required to meet any BACT or offset requirements specified in 

Rule 2201 (New and Modified Source Review Rule) unless the modification meets the 

conditions for being exempt from BACT or offset requirements. The situations where a 

modification would be exempt from BACT or offsets is spelled out in Rule 2201. It is 

EPA policy that no rule except a District’s New Stationary Source Rule (NSR Rule) can 

exempt a source from BACT and offset requirements.
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The language in Section 5.0 (Requirements) for operator and VOC emission control 

system would be standardized, as noted in Section III.A of this staff report. In Section 

5.3, the VOC emission control system requirements would be spelled out more clearly. 

Section 5.5 in the current rule no longer applied to operations subject to Rule 4606 as 

of November 14, 2002 and, therefore, would be removed from the rule. The section 

titled “Organic Solvent Cleaning, Storage and Disposal Requirements” would be revised 

to reflect the VOC content limits and effective dates proposed in Table 2 of this staff 

report. Also, operators would have the option to use higher VOC content solvent for 

cleaning equipment if a VOC emission control system is used. The change would allow 

operators flexibility in solvent cleaning practices with no change in VOC emissions. 

Section 5.0 would be renumbered, as appropriate. The solvent cleaning work practices 

requirement would be reworded to clarify that the operator must meet VOC content 

limits and utilize work practices for certain cleaning operations.

In Section 6.0 (Administrative Requirements), provisions that were no longer in effect 

and dates on provisions that are already in effect would be taken out of the rule. 

Language would be standardized in this rule section and record retention provisions 

would be clarified, as noted in Section III.A of this staff report. References to composite 

partial vapor pressure would be removed throughout Section 6.0, since the standard is 

being deleted from the rule. The required records and specified test methods for VOC 

emission control systems would be added to clarify the intent. Within the solvent usage 

records, operators would be required to calculate the VOC content of a batch, if the 

operator mixes the ingredients. Section 6.0 would be renumbered as needed.

5. Rule 4607 (Graphic Arts)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 

(Definitions) would be revised as noted in Section III.A of this staff report. For this rule, 

the definitions of “bench scale” and “research and development” would be added for 

clarity. In Section 4.0 (Exemptions), one exemption would be added. The added 

exemption is not new to the rule. It exists in the solvent cleaning portion of Section 5.0 

(Requirements) and would be moved to Section 4.0 for clarity.

The language in Section 5.0 for operator and VOC emission control system would be 

standardized, as noted in Section III.A of this staff report. In Section 5.6, the types of 

coating application equipment would be listed for clarity. For this rule development 

project, District staff is not proposing any new or added coating application equipment 

types. However, if an operator would like to use coating application equipment not 

specifically listed in Section 5.6, the operator would have the option to use the 

equipment, if it met a minimum 65% transfer efficiency. The addition of this 

requirement would allow operators to take advantage of new technology, if the 

technology is shown to minimize VOC emissions. Section 5.7 (Evaporative Loss 

Minimization) would be removed because it is no longer in effect. 
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The cleaning solvent VOC content limits would be handled slightly differently than in 

other rules. Before the last SCAQMD Rule 1171 amendments, SCAQMD staff, in 

cooperation with printing industry representatives, performed a technical assessment 

for certain solvent cleaning operations. The assessment found that original SCAQMD 

limit of 100 g/L is not technologically feasible at this time for certain solvent cleaning 

operations at printing facilities. Therefore, the most recent amendments to SCAQMD 

Rule 1171 extend compliance with low VOC content limits until the year 2008 for offset 

lithograph printing and letter-press printing. In view of SCAQMD staff’s analysis, District 

staff recommends to delay compliance with the 100-g/L VOC content limit until 2010 for 

the cleaning operations identified by SCAQMD staff. In the interim, operators of offset 

lithographs and letter press printers would have a 500 g/L (4.2 lb/gal) VOC content limit 

on cleaning solvents used for cleaning on-press component, roller wash, and blanket 

wash. The interim VOC content limit would mirror SCAQMD’s VOC content limits for 

these specific solvent-cleaning categories. Cleaning of ultraviolet/electron beam ink 

application equipment would also have an interim VOC content limit – in this case 650 

g/L. 

The exemptions from the Table 5 VOC content limits would be moved to Section 4.0 

(Exemptions) for clarity. Also, operators would have the option to use higher VOC 

content solvent for cleaning if a VOC emission control system is used. The change 

would allow operators flexibility in solvent cleaning practices with no change in VOC 

emissions. The solvent cleaning work practices requirement would be reworded to 

clarify that the operator must meet VOC content limits and utilize work practices for 

certain cleaning operations.

In Section 6.0 (Administrative Requirements), provisions that are no longer in effect and 

dates on provisions that are already in effect would be taken out of the rule. Language 

would be standardized in this rule section and record retention provisions would be 

clarified, as noted in Section III.A of this staff report. References to composite partial 

vapor pressure would be removed throughout Section 6.0, since the standard is being 

deleted from the rule. The required records and specified test methods for VOC 

emission control systems would be added as a separate section to clarify the intent. 

Two test methods would be added for determining the transfer efficiency of coatings 

application equipment. Section 6.0 would be renumbered as needed. In Section 7.0 

(Compliance Schedule), the compliance schedule with a date in the past would be 

removed. The schedule for operators losing an exemption would remain the same.
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6. Rule 4612 (Motor Vehicle and Mobile Equipment Coating Operations –

Phase II)

Since this rule was recently adopted, no changes would be made to Section 1.0 

(Purpose). Changes would be made throughout the rule to accommodate the addition 

of solvent cleaning provisions. In Section 3.0 (Definitions), the definition of stripping, 

solvent, and VOC content for solvents would be added. An exemption would be added 

to Section 4.0 (Exemptions) for stripping of dried or cured coatings. This exemption is 

similar to the one in Rule 4602 (Motor Vehicle and Mobile Equipment Coating 

Operations), which is the predecessor to Rule 4612. 

Although no changes to the VOC content for coatings would be proposed, an 

explanatory note at the end of Table 1 would be added for clarity. Also, the section 

currently titled “Alternate Compliance” would be changed to “VOC Emission Control 

Systems” to more clearly reflect the rule provisions in this section as well as outlining 

the requirements for a VOC emission control system. Solvent cleaning provisions 

would be added as Section 5.9 (Organic Solvent Cleaning, Storage, and Disposal 

Requirements). The solvent cleaning VOC content limit would be 25 g/L (0.21 lb/gal) 

for all types of cleaning operations except bug and tar removal. For bug and tar 

removal, operators would be allowed to use remover that is regulated under the 

California Code of Regulations Section 94507 et seq. which spells out the requirements 

for consumer products sold in California. In place of meeting the VOC content limits, 

the use of higher VOC content solvent would be allowed for all solvent-cleaning 

operations, provided the operator using the high-VOC solvent would install and operate 

a VOC emission control system that meets the requirements in Section 5.4 (VOC 

Emission Control Systems). Section 5.10 would outline the solvent storage and 

disposal requirement. The provision mirrors current Rule 4602 requirements for this 

same function.

In Section 6.0 (Administrative Requirement), record retention provisions would be 

clarified, as noted in Section III.A of this staff report. The records necessary to show 

compliance for solvents used in solvent cleaning operations would be added. For VOC 

emission control systems, language would be revised to clarify the current 

requirements. Within the solvent usage records, operators would be required to 

calculate the VOC content of a batch, if the operator mixes the ingredients. The 

requirements in Section 6.0 would be renumbered as needed.
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7. Rule 4653 (Adhesives)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 

(Definitions) would be revised as noted in Section III.A of this staff report. For this rule, 

the definitions of “bench scale,” “liquid leak,” “repair process,” and “research and 

development” would be added for clarity. The definition of solvent would be changed to 

point the operator to Rule 4663 (Organic Solvent Cleaning, Storage, and Disposal). 

One exemption would be added to Section 4.0 (Exemptions). The added exemption is 

not new to the rule. It exists in the solvent cleaning portion of Section 5.0 

(Requirements) and would be moved to Section 4.0 for clarity.

The language in Section 5.0 for operator and VOC emission control system would be 

standardized, as noted in Section III.A of this staff report. The adhesive VOC content 

limits would not be changed as part of this rule development project. However, the 

VOC content limits table would be simplified to include only those VOC content limits 

currently in force and remove any date associated with the table, since the dates have 

already passed. The provisions about adhesive application equipment have been 

moved to its own subsection for clarity. 

Section 5.2 in the current rule no longer applies to operations subject to Rule 4653 as 

of November 14, 2002 and, therefore, would be removed from the rule. The section 

titled “Organic Solvent Cleaning, Storage and Disposal Requirements” would be revised 

to reflect the VOC content limits and effective dates proposed in Table 2 of this staff 

report. The exemptions to the cleaning solvent VOC content limits would be moved 

from Section 5.3 to Section 4.0 (Exemptions) for clarity. In new Section 5.2, adhesive 

application equipment other than spray application would be allowed. Section 5.0 

would be renumbered, as appropriate. In Section 5.4, the VOC emission control 

system requirements would be spelled out more clearly. There would be no added 

requirements and no requirements would be removed. 

In Section 6.0 (Administrative Requirements), record retention provisions would be 

clarified, as noted in Section III.A of this staff report. The required records and 

specified test methods for VOC emission control systems would be added to clarify the 

intent. Within the solvent usage records, operators would be required to calculate the 

VOC content of a batch, if the operator mixes the ingredients. Section 6.0 would be 

renumbered as needed.
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8. Rule 4661 (Organic Solvents)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 

(Definitions) would be revised as noted in Section III.A of this staff report. Rule 4612 

(Motor Vehicle and Mobile Equipment Coating Operations – Phase II) will replace Rule 

4602 (Motor Vehicle and Mobile Equipment Operations) on January 1, 2009. Rule 

4661 cites Rule 4602 in the exemption section, so District staff is proposing that the 

exemption for Rule 4602 end on December 31, 2008 and that the exemption be added 

for Rule 4612, beginning January 1, 2009. 

Section 5.0 (Requirements) would be revised to include lower threshold for when a 

VOC emission control system would be required. There are currently three different 

thresholds: one for heated solvents, one for photochemically reactive solvents, and 

one for non-photochemically reactive solvents. All three of these would be phased out 

within six months of rule adoption to a single threshold of 833 pounds of VOC per 

calendar month. This threshold mirrors SCAQMD’s rule for similar sources. There are 

about 12 facilities with permits that cite Rule 4661 as a permit condition. These 

facilities would not need to change their operations since they are smaller operations 

that operate five days per week (about 20 days per month). The proposed requirement 

would set a minimum standard for any new sources that would be subject to this rule.

In Section 6.0 (Administrative Requirement), language would be standardized and 

record retention provisions would be clarified, as noted in Section III.A of this staff 

report. For VOC emission control systems, language would be revised to clarify the 

current requirements. The test method for determining the amount of daily VOC 

emissions would be moved to this section for clarity.

9. Rule 4662 (Organic Solvent Degreasing Operations)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 

(Definitions) would be revised as noted in Section III.A of this staff report. In Section 4.0 

(Exemptions), one exemption associated with degreasers used exclusively for cleaning 

flight critical parts using unheated non-halogenated solvents would be removed. This 

exemption is no longer in effect. 

Section 5.0 (Requirements) would be rearranged to emphasize the solvent’s VOC 

content requirements and the alternative to use VOC emission control systems. Also, 

those parts of the general degreaser requirements associated with specific types of 

degreasers would be moved to the section under the specific degreaser type. A new 

set of requirement would be added for cold cleaners that are under a VOC emission 

control system. These cleaners would be required to operate and maintain their system 

to minimize VOC emissions.

In Section 6.0 (Administrative Requirement), language was standardized in this rule 

section and record retention provisions clarified, as noted in Section III.A of this staff 
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report. For VOC emission control systems, language would be revised to clarify the 

current requirements. 

10. Rule 4663 (Organic Solvent Cleaning, Storage, and Disposal)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 

(Definitions) would be revised as noted in Section III.A of this staff report. For this rule, 

the definitions of “bench scale” and “research and development” would be added for 

clarity. The definitions in Section 3.0 would be renumbered as needed. Four 

exemptions would be added to Section 4.0. Rule 4612 (Motor Vehicle and Mobile 

Equipment Coating Operations – Phase II) will replace Rule 4602 (Motor Vehicle and 

Mobile Equipment Operations) as of January 1, 2009. Rule 4663 cites Rule 4602 in the 

exemption section, so District staff is proposing that the exemption for Rule 4602 end 

on December 31, 2008 and that an exemption begin for Rule 4612 on that date. The 

remaining added exemptions are not new to the rule, they were previously located in 

Section 5.0. Section 4.7 has been reworded to clarify that the cleaning of architectural 

coating application equipment would be subject to the 55 gallons per year limit in order 

to remain exempt. To add operations flexibility, an exemption was added for the use of 

aerosol cleaning products that are ARB-compliant.

The language in Section 5.0 (Requirements) for operator and VOC emission control 

system would be standardized, as noted in Section III.A of this staff report. The table 

containing the VOC content limits for solvents used for solvent cleaning would be 

amended to match the appropriate category limits in Table 2 of this staff report. The 

exemptions from the VOC content limits would be moved from Section 5.0 to Section 

4.0 (Exemptions) for clarity. Additionally, District staff is proposing that the exemption 

for cleaning of architectural coating application equipment be eliminated 12 months 

after rule adoption. SCAQMD removed a similar exemption from Rule 1171 (Solvent 

Cleaning Operations), ending the exemption in July 2005. In Section 5.2 (Cleaning 

Methods), wording would be changed to reflect a lower VOC content limit. Operators 

would have 12 months to come into compliance with the proposed limit. Section 5.3 

(VOC Emission Control System) would have phrasing added to clarify the current 

requirements. Added provisions include approval of the VOC emission control system 

by the APCO and limiting the emissions from a VOC emission control system to the 

amount of VOC emissions that would have been emitted if the operator had used 

compliant solvents and work practices. 

In Section 6.0 (Administrative Requirement), language would be standardized and 

record retention provisions would be clarified, as noted in Section III.A of this staff 

report. References to composite partial vapor pressure would be removed throughout 

Section 6.0, since the standard is being deleted from the rule. Within the solvent usage 

records, operators would be required to calculate the VOC content of a batch, if the 

operator mixes the ingredients. For VOC emission control systems, language would be 

revised to clarify the current requirements. 
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11. Rule 4684 (Polyester Resin Operations)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 

(Definitions) would be revised as noted in Section III.A of this staff report. For this rule, 

the definitions of “bench scale” and “research and development” would be added for 

clarity. One exemption would be added to Section 4.0 (Exemptions). The added 

exemption is not new to the rule. It exists in the solvent cleaning portion of Section 5.0 

(Requirements) and would be moved to Section 4.0 for clarity.

The language in Section 5.0 for VOC emission control system would be standardized, 

as noted in Section III.A of this staff report. Section 5.2. (Cleaning Materials 

Requirement) and Section 5.3 (Storage and Disposal Requirements) would be removed 

since the provisions of Section 5.4, titled “Organic Solvent Cleaning, Storage, and 

Disposal,” replaced these two sections. Also, the exemptions from the VOC content 

limits for solvent cleaning would be moved to Section 4.0 as a single exemption. The 

remaining exemption is no longer in force and would be taken out of the rule. Added to 

this section, operators would have the option to use higher VOC content solvent for 

solvent cleaning operations if a VOC emission control system is used. The change 

would allow operators flexibility in cleaning equipment with no change in VOC 

emissions. Section 5.0 would be renumbered as appropriate.

In Section 6.0 (Administrative Requirement), language would be standardized in this 

rule section and record retention provisions would be clarified, as noted in Section III.A 

of this staff report. For VOC emission control systems, language would be revised to 

clarify the current requirements. Two test methods would be added for determining 

whether the enclosed cleaning system for spray coating application equipment is 

equivalent to using low VOC coatings application equipment. 

C. Tertiary Butyl Acetate (TBAC)

During the rule making, it was requested that the District delist TBAC as a VOC so that 

it would be considered an exempt solvent in cleaning solution formulations. 

In November 2004, EPA announced that it had removed TBAC as a VOC due to its low 

photochemical reactivity. All states except California and New Jersey have exempted 

TBAC with New Jersey beginning the process to exempt TBAC just this year. At the 

state level, the California Air Resources Board (ARB) has exempted TBAC for 

consumer products. ARB encourages individual air districts to determine whether to 

exempt TBAC for stationary sources on a case-by-case basis rather than exempt TBAC 

on a statewide basis. ARB was one of the original proponents strongly advocating a 

TBAC exemption, but softened their stand later in the process. The reason for ARB 

backing off on its support was a question of the overall health risk of TBAC. The Office 

of Environmental Health Hazard Assessment (OEHHA), in assessing TBAC, had some 

concerns about the health risks associated with the increased use of this new chemical. 
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District staff contacted the staff of OEHHA to get more details on their concerns. The 

following bullets summarize OEHHA staff’s issues with TBAC.

Since TBAC is not in widespread use, there are no available human studies 

comparing those who use TBAC versus those who don’t. This lack is usually not 

a make-or-break issue for new chemicals.

OEHHA staff feels that there is not enough supporting information about TBAC, 

particularly the chronic exposure component, to adequately assess TBAC’s 

health risk. Chronic exposure is exposure over a long period of time to small or 

moderate amounts of a chemical.

One animal study found a relationship between tertiary butanol and tumors in 

mice. Mammals (including humans) can metabolize TBAC to tertiary butanol. 

To OEHHA staff, this study raises concerns, meaning more studies would be 

needed to determine the exact relationship between tertiary butanol and TBAC, 

as well as the impact of that relationship on health risks.

Other tertiary butyl chemical exhibit cancer-causing potential, thus making the 

OEHHA staff wary of any chemical with a tertiary butyl structure, not just TBAC.

The gaps in information outlined above prevent OEHHA staff from issuing a health risk 

assessment. Without the support of an OEHHA assessment, it would be difficult for 

District staff to determine whether to exempt TBAC. Looking to other air districts for 

their assessment of TBAC, the SCAQMD Governing Board has decided to exempt 

TBAC only in certain specific usage categories. Products that are compliant with the 

low-VOC content limits for solvent cleaning exist that do not contain TBAC, so the 

SCAQMD Governing Board decided not to exempt TBAC for solvent cleaning. District 

staff, therefore, recommends that if ARB would exempt TBAC more generally 

throughout the state, District management would consider making TBAC an exempt 

compound. Until ARB generally exempts TBAC, it is recommended that TBAC remain 

a VOC for purposes of solvent cleaning.

IV. VOC EMISSIONS AND VOC EMISSION REDUCTIONS

Total emission reductions include emissions reductions from three categories of 

amendments to the rules. The three changes are:

Lower VOC content limit for solvents used in general cleaning operations,

Lower VOC content limits for solvents used to clean printing presses, and

Removing exemption for cleaning architectural coating application equipment

Overall, the proposed amendments are estimated to have a total of about 3.3 tons per 

day of VOC emission reductions, which is about a 60% reduction to the adjusted 2005 
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baseline VOC emissions of 5.5 tons per day. Details of the analysis are in Appendix B 

of this report.

V. COSTS AND COST EFFECTIVENESS ANALYSIS

The California Health and Safety Code 40920.6(a) requires the San Joaquin Valley 

Unified Air Pollution Control District to conduct a cost effectiveness analysis of available 

emission control options before adopting each BARCT rule. The purpose of conducting 

a cost effectiveness analysis is to evaluate the economic reasonableness of the 

pollution control measure or rule. The analysis also serves as a guideline in developing 

the control requirements listed in a rule. Details of the cost and cost effectiveness 

analysis are in Appendix C of this report.

VI. SOCIOECONOMIC IMPACT ANALYSIS

Under California state law, District staff is required to perform a socioeconomic impact 

analysis prior to adoption, amendment, or repeal of a rule that has significant air quality 

benefits or that will strengthen emission limitations. District staff held a meeting with 

members of the Socioeconomic Focus Group in April 2007. District staff analyzed the 

cost data and business feedback in order to ascertain the cost impacts of the draft rule. 

The socioeconomic impact analysis, which was prepared for the District by Applied 

Development Economics, determined that the proposed regulation would not have a 

significant impact on the affected industries. The results of the socioeconomic analysis 

are included as Appendix D to this staff report. 

VII. ENVIRONMENTAL IMPACTS

As part of the California Environmental Quality Act (CEQA), District staff is required to 

investigate the likely environmental impacts of the rule amendments from this rule 

project. Based on the lack of evidence to the contrary, District staff has concluded that 

the amendments, as proposed, will not have any significant adverse effects on the 

environment. Staff recommends filing a Notice of Exemption under the provisions of 

Public Resource Code 15061(b)(3).

VIII. RULE CONSISTENCY ANALYSIS

As required by California Health & Safety Code Section 40727.2, District staff has 

prepared a rule consistency analysis that compares the elements of amendments with 

the corresponding elements of other District rules, federal regulations and guidelines 

that apply to the same source category or type of equipment. District staff found that 
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facilities could comply with the proposed amendments to the solvent cleaning portions 

of the eleven District rules as well as all other existing or proposed District rules. 

Furthermore, District staff found that none of the proposed requirements of for this rule 

project would conflict with federal rules, regulations, or policies covering similar 

stationary sources. The analysis is contained in Appendix E of this staff report.

IX. RULE DEVELOPMENT PROCESS

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

meeting in August 2006. Public workshops were held in October 2006, April 2007, and 

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

sources, EPA, and ARB on the proposed amendments. Comments received during the 

workshop process were incorporated into the rule amendments as appropriate.

Proposed amendments to the solvent cleaning portions of eleven District rules and the 

Final Draft Staff Report have been published and made available to affected sources 

and interested parties prior to a public hearing by the Governing Board. District staff 

intends to submit the proposed rules to the District Governing Board for adoption on 

September 20, 2007. The notice of the public hearing for the proposed rules has been 

published in a general circulation newspaper in each of the eight San Joaquin Valley 

counties and has been mailed to affected sources and interested parties. The public 

notice solicited written comments by mail, and it also identified the name and telephone 

number of the District staff who can answer questions and respond to comments. 

Comments received and District responses for the August 18, 2007 version of the rule 

are discussed in Appendix A of the Final Draft Staff Report.

X. REFERENCES

1. South Coast Air Quality Management District – Rule 1122 “Solvent Degreasers” 

adopted March 2, 1979, last amended October 1, 2004.

2. South Coast Air Quality Management District – Rule 1171 “Solvent Cleaning 

Operations” adopted August 2, 1991, last amended July 14, 2006.

3. South Coast Air Quality Management District – Final Staff Report of Proposed 

Amended Rule 1171 – Solvent Cleaning Operations. June 2006.

4. South Coast Air Quality Management District – Staff Report for Proposed 

Amended Rule 1171 – Solvent Cleaning Operations. November 2003.

5. Bay Area Air Quality Management District – Regulation 8 Rule 4 “General 

Solvent and Surface Coating Operation” adopted March 17, 1982, last amended 

October 16, 2002.
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6. Bay Area Air Quality Management District – Regulation 8 Rule 16 “Solvent 

Cleaning Operations” adopted March 7, 1979, last amended October 16, 2002.

7. Code of Federal Regulations – Title 40 Parts 60, 61, and 63.

8. California Air Resources Board – Environmental Impact Assessment of tert-butyl 

acetate. January 2006
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