SACRAMENTO METROPOLITAN 

AIR QUALITY MANAGEMENT DISTRICT

STAFF REPORT 

RULE 454 – DEGREASING OPERATIONS 

And 

RULE 466 – SOLVENT CLEANING 

Prepared by: Ali Mohamad 

Associate Air Quality Engineer 

Reviewed by: Aleta Kennard, Supervisor 

Technical Services Section 

Approved by: Brigette Tollstrup 

 Division Manager 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 2

BACKGROUND

The District is proposing to adopt Rule 466 – SOLVENT CLEANING and also amend Rule 

454 – DEGREASING OPERATIONS. The District is required to adopt regulations to reduce 

VOC emissions associated with solvent cleaning operations. The District has committed in 

the State Implementation Plan (SIP) to reduce volatile organic compound (VOC) emissions 

from solvent cleaning activities. 

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 non-VOCs or 

exempt compounds (e.g., halogenated solvents, and non-halogenated solvents.) Some of 

the halogenated solvents are regulated by EPA under 40 CFR Part 463, Subpart T – 

National Emission Standards for Halogenated Solvent Cleaning. Sources using these 

solvents are required to comply with EPA regulations. 

Rule 466

Staff had incorporated solvent cleaning requirements in specific regulatory rules (graphic 

arts operations, adhesive application), but there are still cleaning activities such as cleaning 

of electrical apparatus and electronic components, architectural coating application 

equipment, polyester resin application equipment, and automotive repair cleaning that have 

not been regulated. Rule 466 will capture these cleaning activities and other cleaning 

operations such as wipe cleaning, maintenance cleaning, and tool and application 

equipment cleaning. 

Rule 454

Rule 454 which regulates VOC emissions from solvent degreasing operations is being 

amended in order to require that non-vapor degreasing operations use cleanup material that 

contains no more than 50 grams per liter of VOCs. The proposed amendments also allow 

the use of airtight/airless cleaning system as an alternative to complying with the 50 grams 

per liter VOC limit. Other amendments to the rule are intended to clarify the rule 

requirements and to respond to ARB and public comments on the rule. A detailed list of the 

proposed changes to the rule is included as Attachment C to the staff report. 

There are two types of degreasing operations regulated under Rule 454; vapor and nonvapor degreasing. In vapor degreasing the solvent is heated to enhance the degreasing 

process. Different controls such as a refrigerated freeboard chiller and a carbon adsorption 

system are used to minimize the emissions of VOCs from vapor degreasers. Non-vapor 

degreasing uses solvents at room temperature. It is very common for automotive repair 

shops to use one or more degreasers. The degreaser and the solvent are usually provided 

through a service agreement. The spent solvent is also taken by the solvent supplier and 

usually are recycled for reuse. The solvent recycling process is usually performed outside 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 3

the District (Based on conversation with Safety Kleen.) Different methods of cleaning are 

discussed below. 

Maintenance and Repair Cleaning: This type of cleaning is performed to keep equipment, 

tools, machinery, and general work area in a good condition. Examples of such cleaning 

include cleaning of engines and other parts during maintenance and repair of buses, 

aircraft, and trucks; cleaning of tools, machinery, equipment, and general work areas in 

shops. 

Manufacturing Cleaning: Manufacturing cleaning includes cleaning of manufactured parts 

during various stages of production processing such as cutting, machining, molding, and 

fabricating, and assembling of manufactured parts. 

Application Equipment Cleaning: This type of cleaning includes the cleaning of ink, 

coating, and adhesive application equipment. Examples of such equipment are paint spray 

equipment such as spray guns, cups, dispensing hoses, pressure pots, and distribution 

pipelines; dip tanks and roller coaters; and hand application equipment such as brushes, 

rollers, and trowels. 

Wipe Cleaning: Wipe cleaning is used when the use of a cleaning device is not feasible. 

Wipe cleaning is the cleaning of the surface by physically rubbing it with a material such as 

rag, paper, or cotton swab. 

Solvent Flushing: Solvent flushing is generally used for cleaning of coating or adhesive 

application equipment. The discharged solvent is usually collected in containers. 

Remote Reservoir Cleaning: This method employs a sink-on-drum type cleaning device. 

The cleaning solvent is usually stored in a drum and is pumped to the sink where the parts 

are being cleaned. The unused solvent returns to the solvent container. 

Staff is proposing a 50 grams per liter VOC standard for general maintenance cleaning and 

for solvents used in non-vapor degreasers. The proposed VOC standard is consistent with 

the standard adopted by the following districts. The effective dates of the 50 grams per liter 

VOC limit are also listed in the table below: 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 4

District Rule Number/Name 

Effective 

Date for 

VOC 

Limits 

Bay Area Air Quality Management 

District (BAAQMD) 

Rule 16, Solvent Cleaning 

Operations 

9/1/1999 

Rule 4662, Organic Solvents 

Degreasing Operations 

San Joaquin Valley Unified Air 11/19/2002 

Pollution Control District 

(SJVUAPCD) Rule 4663, Organic Solvents, 

Cleaning, Storage, and Disposal 

11/15/2003 

South Coast Air Quality 

Management District 

Rule 1171, Solvent Cleaning 

Operations 

12/1/2001 

Staff is also proposing other VOC content limits for cleaning of electrical apparatus and 

electronic components, medical devices and pharmaceuticals, tools, equipment, and 

machinery, and architectural coating application equipment. Other districts such as the 

SCAQMD, BAAQMD, and SJVUAPCD have also adopted similar VOC standards for solvent 

cleaning operations. 

The proposed rules give stationary sources alternatives to complying with the VOC limits 

being proposed. Stationary sources can use an airtight airless cleaning system or install and 

operate air pollution control equipment. 

LEGAL MANDATES 

 

Federal Mandate: The District has been designated as a severe nonattainment area for the 

federal ozone standard by the EPA. There are legal mandates that directly resulted from 

this classification. Section 182 (c) of the federal Clean Air Act Amendments of 1990 (42 

U.S.C. 7511a (c)) required all ozone nonattainment areas classified as “serious” and above 

to submit a State Implementation Plan (SIP) revision by November 15, 1994 which 

described, in part, how the area will achieve: (i) the National Ambient Air Quality Standard 

for ozone, and (ii) actual VOC emission reductions of at least three percent per year 

(averaged over each consecutive 3-year period beginning November 1993). Section 182(d) 

(42 U.S.C. 7511a (d)) requires the District to adopt the control measures proposed in the 

SIP. In addition, Section 172 (c)(1) (42 U.S.C. 7502) requires the District to adopt 

Reasonable Available Control Technology for major stationary sources. 

The District has committed in the SIP to reduce VOC emissions from solvent used in 

surface preparation and cleanup operations. The SIP commitment is to reduce this category 

in the ozone nonattainment area by 3.9 tons per day by 2005. This category has been 

reduced by 2.33 tons per day . The District has reduced 1.19 tons per day from adoption of 

control measures in specific prohibitory rules for surface preparation and cleanup 

operations. Proposed Rule 466 and changes to Rule 454 are needed in order to achieve 

the additional reductions needed to meet the SIP commitment. 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 5

State Mandates: The District is designated serious nonattainment 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 Health and Safety 

Code (CHSC): 

Plan Requirements: Section 40913 requires districts to develop a plan to achieve 

California’s ambient air quality standard by the earliest practicable date. The 1994 

Sacramento Area Regional Ozone Attainment Plan lists surface preparation and cleanup as 

one of the stationary source control measures for reducing VOCs (1994 Attainment Plan, 

Appendix D-8). New Rule 466 and amendments to Rule 454 are being proposed to meet 

this requirement. 

All Feasible Measures Requirements: Section 40914 requires each district plan to 

demonstrate that the plan includes “every feasible measure.” Districts must adopt the most 

effective control measures to reduce VOC emissions from solvent cleaning operations. 

Many Districts such as SCAQMD, BAAQMD, and SJVUAPCD have adopted regulations 

that require the use of a 50 grams per liter VOC-containing solvent for general cleaning. 

Staff evaluated the standards in the proposed rules against similar applicable requirements 

adopted by these districts. The results are included as Attachment B to the Staff Report. 

Best Available Retrofit Requirements: Section 40919 requires districts with serious 

nonattainment for ozone to adopt Best Available Retrofit Control Technology (BARCT) for all 

existing sources. BARCT means an emission limitation that is based on the maximum 

degree of reduction achievable, taking into account environmental, energy, and economic 

impacts by each class or category of sources (CHSC Section 40406). Staff has found that 

the proposed VOC requirements meet the BARCT requirement and therefore the proposed 

rules meet the requirements of CHSC Section 40919. 

Transport Mitigation Requirements: Title 17, California Code of Regulations, Section 

70600 requires districts within the areas of origin of transported air pollutants, to include 

sufficient control measures in their attainment plans for ozone to mitigate the impact of 

pollution sources within their jurisdictions on ozone concentrations in downwind areas. The 

District is an identified transporter of air pollutants. The regulations require the District's 

plan must contain at minimum requirements for BARCT for source categories that 

collectively amount to 75% of the 1987 actual VOC and NOx emissions inventory. 

Section 39610 of the California Health and Safety Code requires the state board to identify 

air basins that transport air pollutants to other air basins or subregions that contribute to 

violation of the ambient air quality standard for ozone. The state board has identified the 

District as a transporter of air pollutants to the Upper Sacramento Valley and Broader 

Sacramento Area. 

Section 40910 of the California Health and Safety Code requires districts to consider full 

spectrum of emission sources and focus particular attention on reducing the emissions for 

transportation and areawide emission sources. 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 6

SUMMARY OF PROPOSED RULE REQUIREMENTS

Rule 466

Rule 466 requires general cleaning to be performed by materials that contain less than 50 

grams per liter VOCs as applied. The rule also includes other requirements for cleaning 

electrical and electronic apparatus components, architectural application equipment, and 

adhesive application equipment. The VOC limit varies depending on the equipment being 

cleaned. The rule allows the use of air pollution control equipment or an airtight or airless 

cleaning system as alternatives to complying with the VOC limits proposed by the rule. The 

rule also specifies cleaning method requirements, general equipment requirements, 

operating requirements, storage and disposal requirements, and recordkeeping 

requirements. 

Rule 454

Proposed amendments to Rule 454 require non-vapor degreasers to use solvents with a 

VOC content of 50 grams per liter or less. The rule allows the use of solvents with VOC 

content higher than 50 grams per liter for degreasing of electronic components and other 

components which require higher VOC solvents if the solvents comply with the VOC limits in 

Rule 466. The amendments also include increasing the freeboard ratio for vapor 

degreasers from 0.75 to 1.0, adding new control requirements for vapor degreasers, and 

operating requirements applicable to remote reservoir cleaners. A list of all of the proposed 

changes to Rule 454 is included as Attachment C to the staff report. 

SOCIOECONOMIC IMPACT ANALYSIS

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. 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 7

Type of Affected Business and Industry Including Small Business: Rule 466 will affect 

cleaning operations not currently regulated. Those operations include wipe cleaning and 

cleaning of medical devices and pharmaceuticals, electrical apparatus components and 

electronic components, and architectural application equipment. Rule 454 proposed 

amendments will affect stationary sources that use degreasers as part of their cleaning 

operations. Degreasers (also known as part cleaners) are widely used by automotive repair 

shops, manufacturing operations, small printing shops, electric and electronic components 

repair and manufacturing facilities, and miscellaneous repair and maintenance operations. 

Staff estimates that the proposed rules will impact the automotive service industry the most. 

Based on information supplied by the Department of Consumer Affairs, there are 

approximately 1700 automotive repair and paint operations, 50 graphic arts operations, and 

about 2000 architectural paint operations that would be affected by Rule 466. 

Impact on Regional Economy: Staff analyzed the impact of the proposed requirements on 

sources in the District. Almost all of the facilities are currently using solvent type parts 

cleaners. These cleaners are usually leased for a monthly fee. The leasing company 

usually supplies the solvent and also picks up the spent solvent for disposal. Affected 

sources will be 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. 

Aqueous cleaners are generally made of concentrated alkaline detergents. They require 

heat in order to effectively clean the parts. The spent solvent will also have to be disposed 

through a certified waste recycler. There are many suppliers available that supply aqueous 

parts cleaner as well as cleaning materials. The cost of a part cleaner varies depending on 

the manufacturer and the capacity of the cleaner. The disposal cost is about $275 to $350 

per drum of waste (Based on cost disposal information from Mr. Glen Brown, General 

Manager, River City Painting.) Cost effectiveness analysis comparing the cost of solvent 

part cleaners and aqueous part cleaners showed cost savings for affected business (See 

tables in Section Range of Probable Costs Due to Rule 466). Rule 466 specifies other VOC 

limits for other cleaning operations. Products are available on the market that meet these 

limits and are not expected to adversely impact these sources. The table below summarizes 

the costs for different cleaners used by operations subject to these rules. 

Type of Cleaning Operation Cost of High 

VOC Material 

$ 

Cost of Low VOC Material 

$ 

Architectural Coating 4-6 3-8 

Electrical & Electronic 

Equipment 

3-6 3-14 

Medical Devices and 

pharmaceuticals 

6-8 Same since no low VOC materials 

are required to be used. 

Repair and maintenance 

cleaning 

4 -6 3 - 6 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 8

Staff evaluated the impact on architectural coating operations and found that these 

operations use water based coatings for the majority of their painting operations (About 84% 

of the most commonly used architectural coatings sold for use in California are water based 

(ARB's 1998 Architectural Coatings Survey Results Final Report.) Staff confirmed this by 

contacting architectural paint contractors in the District. Staff also found that the paint 

application equipment are either cleaned at the site or brought back to the shop for 

cleaning. Application equipment using water based coatings are usually cleaned with water. 

 Application equipment using solvent based coatings are currently being cleaned with a 

thinner. Some paint contractors use a distiller to recycle waste solvents. Others contract 

with a waste recycler for their spent solvents. The cost of low VOC solvents generally 

ranges between $6 to $8 per gallon compared to paint thinner at $4 to $6 per gallon. 

Sources can also use a solvent blend of acetone and other exempt solvents at a cost of $3 

per gallon (see discussions under Range of Probable Costs Due to Rule 466). The impact 

from the lower VOC limit for cleanup solvents is expected to be minimal since only small 

percentage of the coatings used are solvent based coatings. The rule also requires that 

cleaning of spray guns to be done using an enclosed gun cleaner when the cleaning is done 

at the shop. There are many types of gun cleaners available for this purpose. The cost of 

gun cleaners ranges from $750 for a single-gun cleaner to $2300 for a four-gun cleaner. 

Socioeconomic Impact Analysis Performed by other Districts: The SCAQMD evaluated 

the economical impacts of their Rule 1171 using an economic policy model, the REMI 

(Regional Economic Modeling) model and concluded that their Rule 1171 would not have 

an adverse impact on the economy in the SCAQMD (Final Staff Report for Rule 1171, 

Solvent Cleaning Operations, July 1991.) The study concluded that approximately four jobs 

will be created annually in directly regulated sources. A more recent SJVUAPCD 

socioeconomic impact study prepared by Jack Faucett Associates for Rule 4663, Organic 

Solvent, Cleaning, Storage, and Disposal amendments also concluded a modest impact for 

regional economy of the San Joaquin Valley. The impact on the SJVUAPCD economy was 

an employment change of two jobs. Staff expects no impact from the new regulations on 

employment the District. 

Range of Probable Costs Due to Rules 454 and 466: The costs associated with 

complying with the requirements in Rules 466 and 454 are discussed below: 

Range of Probable Cost for Proposed 50 Grams per Liter VOC Limit: The cost for using 

solvents and aqueous cleaners are summarized in the table below. These costs are based 

on cost information contained in EPA Region IX pollution prevention program fact sheet 

titled "Aqueous Part Cleanings". This fact sheet is part of a package fact sheets entitled 

either "The Pollution Prevention Tool Kit, Best Environmental Practices for Auto Repair" 

(publication number EPA-909-E-99-001) or The Pollution Prevention Tool Kit, Best 

Environmental Practices for Fleet Maintenance" (publication number EPA-909-E-99-002). 

The costs comparison below is based on a case study on a full service automotive repair 

shop with six technicians and 14 bays. The shop purchased an aqueous spray cabinet and 

also an aqueous microbial sink-top unit. The spray cabinet solution and sludge were 

disposed of as separate waste streams every 6 months by a waste disposal company. The 

microbial unit did not require solution disposal in over 16 months of use. The majority of cost 

savings were in cleaning labor. 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 9

As seen the in the tables above, using aqueous cleaners resulted in cost savings for this 

shop. 

Range of Probable Cost for other Types of Cleaning: The cost impacts are summarized 

in the table below. The cost impacts for electrical, medical, pharmaceutical, and repair and 

maintenance cleaning are based on information contained in a recent report prepared for 

SJVUAPCD organic solvent cleaning rule by Jack Faucett and Associates, Socioeconomic 

Impact Analysis of Organic Solvent Cleaning, Storage, and Disposal Rule Project, 

November 2001, Appendix A. Staff believes that these costs are similar for Sacramento 

Parts Cleaning Costs Comparison 

Two Solvent Units 

Annual Costs 

$ 

Leasing, waste management 1260 

Electricity 1400 

Cleaning labor 31200 

Total Cost 33,860 

Aqueous Spray Cabinet Aqueous Microbial Sink-Top 

 Annual Costs 

$ 

 Annual Costs 

$ 

Purchase price (onetime) 1,600 Purchase price 

(one-time) 

1,300 

Chemicals 75 Chemicals 325 

Solution and sludge 

disposal 

425 Filters 60 

Electricity 3,100 Solution and 

sludge disposal 

289 

Cleaning labor 11,232 Electricity 360 

 Cleaning labor 3,120 

Total Cost 16,432 Total Cost 5,454 

Total Capital Cost: $2,900 Annual Savings: $14,874 Payback Period: 0.2 Year 

Note: The cost analysis above is based on replacing the two solvent units with two aqueous 

units (one of the aqueous units also uses microbes to aid in the cleaning Process.) The 

analyses show that adding microbes to the aqueous unit reduces the operating cost 

significantly since heating of the solution in the unit is not needed. 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 10

based on telephone conversations with solvent suppliers. The cost impacts for architectural 

application equipment cleaning are based on Staff analysis. 

Type of Solvent 

Cleaning 

Cost Impact 

Electrical Apparatus and 

Electronic Equipment 

There will be a small overall increase in solvent cost (about 15% or 

$0.4/pound) based on the cost effectiveness analysis performed by 

Jack Faucett. 

Medical and 

Pharmaceutical 

There is no expected cost increase for this category of cleaning. This 

is based on the assumption that some of the cleaning will be done 

using acetone or a solvent blend. The overall compliance cost will be 

about the same compared with the current solvent usage. (Based on 

cost effectiveness analysis performed by Jack Faucett) 

Repair and Maintenance 

Cleaning 

There is no expected cost increase for this category of cleaning since 

the general cleaning will be replaced with aqueous cleaners and 

acetone which will not result in added costs compared with the current 

costs for the cleanup solvents (see cost comparison for solvent and 

aqueous part cleaners in the table on page 9). The cost of thinner is 

about $4 to $6 per gallon. The cost of replacement solvents ranges 

between $4 to $6 per gallons. Sources can also use acetone with 

other exempt solvents at a cost of $3 per gallon, which is cheaper than 

the cost of the thinner (Based on cost effectiveness analysis 

performed by Jack Faucett.) 

Architectural Coating 

Application Equipment 

Cleaning 

The rule requires the use of 50 grams per liter VOC content for 

cleaning after using water based coatings, 300 grams per liter VOC 

content when cleaning after using solvent based coatings on the 

jobsite, and an enclosed gun cleaner when cleaning at the shop. This 

includes paint guns, brushes and other application equipment. There 

is no cost increase for cleaning when cleaning after using water based 

paints since the application equipment is cleaned with water. 

Approximately 84% of the coatings used are water based. 

A thinner is currently used to clean application equipment when 

solvent based coatings are used. The thinner will be replaced by a 

blend of acetone and other exempt solvents. The cost of thinner is 

about $4 to $6 per gallon. The cost of replacement solvents ranges 

between $6 to $8 per gallons (a 25% increase in solvent cost.) 

Sources can also use acetone with other exempt solvents at a cost of 

$3 per gallon, which is cheaper than the cost of the thinner (Based on 

cost effectiveness analysis performed by Jack Faucett.) The cost of a 

gun cleaner ranges between $750 for a single gun cleaner to $2300 

for a four-gun cleaner (Based on cost information from vendors of gun 

cleaners). Some contractors clean their application equipment at the 

jobsite, others bring their equipment to the shop for cleaning. Some 

are currently using gun cleaners. 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 11

Staff also analyzed the cost impact from raising the freeboard ratio for vapor degreasers 

from 0.75 to one and the new additional equipment requirements. Only one facility is 

affected and uses only one vapor degreaser. The vapor degreaser complies with the 

proposed requirements. Additional costs to affected businesses may include the cost of 

complying with the new recordkeeping requirements for solvent usage since many 

businesses are not required to do so at this time. This cost will vary depending on the 

number of part cleaners at the facility. 

Availability/Cost Effectiveness of Alternatives to Rules 454 and 466: Staff evaluated all 

of the VOC limits adopted by other Districts and chose these limits since they have been 

demonstrated to be technologically feasible (see Attachment B.) The SCAQMD have more 

stringent VOC limits for cleaning with future effective date (July 1, 2005). Staff did not chose 

these limits since they have not been yet demonstrated to be technologically feasible. Staff 

also evaluated the cost effectiveness of the rules and compared them with similar rules 

adopted by other Districts (see Attachment B.) One alternative to the rules is to adopt the 

solvent cleaning regulations adopted by other districts. Staff did not select this alternative 

since there are some cleaning processes in our district which are different than those in 

other districts (e.g., cleaning of platelets, aerospace parts degreasing) and one of the other 

districts also provides exemption from the 50 grams per liter VOC limit for one degreaser 

per facility. The other alternative to these rules is not to adopt them. This would require 

replacement of lost emission reductions from other sources. However, the District is 

required by state law (see discussion under State Mandates) to adopt BARCT for source 

categories that collectively amount to 75 percent of the 1987 actual reactive hydrocarbon 

emissions inventory for permitted stationary sources. Because this is such a large emission 

source category, it would be difficult or impossible to meet this requirements without these 

rules. Additionally, the District is required by federal law to adopt RACT for major stationary 

sources. Several major sources (e.g., Aerojet, Procter and Gamble) have solvent cleaning 

operations that have not met a RACT requirement.

Emission Reduction Potential for Rules 454 and 466: The District estimates that 1.3 tons 

of VOC emission reductions will be achieved from the proposed regulations. The VOC 

emission reductions were estimated based on the following information: 

1. Emission inventory developed by the District based on statewide emissions data 

that was developed by the California Air Resources Board. 

2. Solvent usage data provided by Safety Kleen, which represents the majority of 

cleanup solvents used in the automotive repair industry in the District. 

Necessity of Amending Rule 454 and Adopting Rule 466: (See discussion under Legal 

Mandates Section) 

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 for Best Available Retrofit Control 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 12

Technology (BARCT). 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 it is 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 analyses are summarized in the table below. The cost 

of compliant materials and air pollution control equipment are based on actual cost data 

from solvent and air pollution control equipment suppliers (see cost data for part cleaners in 

Page 9). 

Cost Effectiveness 

Control Option 

Present Value of 

Control Cost 

($) ($/ton) ($/lb.) 

Compliant Materials Cost Saving of 

13,475.79 

Cost Saving of 

1.93 

Cost Saving of 

11.62 

APC Control Equipment 2,286.15 3,874.83 1.94 

Compliant Materials and 

Control Equipment 

15,761.94 25,919.29 12.90 

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. 

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 = Emissions reductions (tons) 

PVoption 2 = Present value of control costs for 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 13

option 2 ($/yr) 

PVoption 1 = Present value of control costs for 

 option 1 ($/yr) 

TERoption2 = Total emission reductions for option2 

over a 10-year period (tons) 

 TERoption1 = Total emissions reductions for option 

1 over a 10-year period (tons) 

The following table lists the incremental costs of these control options: 

Option IC/E 

($/ton) 

IC/E 

($/lb.) 

Compliant material vs. add on control equipment 1,576.19 788.10 

Add on control equipment vs. add on control equipment 

and compliant material 

974,591 487.30 

Based on the incremental cost effectiveness analysis, the most effective option is using 

compliant material. As shown above, requiring air pollution control equipment is not cost 

effective as a control option.

OTHER FACTORS: 

Technological Feasibility: The VOC limits proposed in Rules 466 and 454 for cleaning 

materials are based on requirements adopted and implemented by BAAQMD, SCAQMD, 

and SJVUAPCD. Therefore, the proposed VOC limits are technologically feasible. 

Enforceability: Reporting requirements and testing procedures have been included in the 

rules to increase enforceability. 

Public Acceptability: Staff made changes to these rules in response to public comments to 

address their concerns. Staff added exemptions for specific types of solvent cleaning 

and/or degreasing operations (e.g., aerospace components, and electronic components) 

which are not feasible using solvents with 50 grams per liter VOC limit. Similar requirements 

are currently implemented in BAAQMD, SCAQMD, and SJVUAPCD. The rules have a 

future compliance timeline to allow time for affected businesses to purchase new equipment 

or retrofit their existing equipment. Therefore, staff expects these rules and other 

associated costs to be acceptable to the public. 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 14

ENVIRONMENTAL REVIEW AND COMPLIANCE

The District's environmental coordinator has determined that the proposed amendments to 

Rule 454 and adoption of Rule 466 are subject to the provisions of the California 

Environmental Quality Act (CEQA). Pursuant to section 15063 of the state CEQA 

Guidelines the District conducted an initial study to determine if the project may have a 

significant adverse effect on the environment. Based on the findings of the initial study, the 

District's Environmental Coordinator has determined that the proposed rules will not have a 

significant effect on the environment. A Negative Declaration was prepared for these rules. 

PUBLIC COMMENTS 

Notice of the Public Hearing was published in the newspaper and also posted on the 

District's website. Copies of the rules were also posted on the District's website. 5000 

copies of the public notice were mailed to affected businesses and interested parties. The 

rules were also sent to ARB and EPA for review and comment. Staff held a public 

workshop on April 3, 2002. Staff received comments from ARB, EPA, and affected 

businesses. 

All comments and their responses are listed in Attachment D to the staff report. 

DISTRICT IMPACTS 

Staff estimated that Rule 466 and amendments to Rule 454 will require additional 0.71 

fulltime employee (FTE) the Field Operations Section and 0.01 FTE in the Permitting 

Section to implement the requirements of these rules. 

TABLE OF FINDINGS

Six Required Findings: According to Section 40727(a) of the California Health & Safety 

Code, prior to adopting or amending a rule or regulation, an air district’s board must 

make findings of necessity, authority, clarity, consistency, non-duplication, and 

reference. The findings must be based on the following: 

1. Information presented in the District’s written analysis (see Appendix A), 

prepared pursuant to Health and Safety Code Section 40727.2, 

2. Information contained in the rulemaking records pursuant to Section 40728 of the 

Health and Safety Code, and 

3. Relevant information presented at the Board’s hearing for the rule. 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 15

The table below sets the findings and the basis for making the finding. 

 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. 

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 (Attachment A-1) contains a 

comparison of other requirements that apply to solvent 

cleaning operations. 
Staff Report 

Rules 454 & 466 

May 23, 2002, Page 16

 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. 

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 (Attachment A-2) contains a 

comparison of other requirements that apply to solvent 

cleaning operations. 
Attachment A 

Rule Consistency Analysis 

Proposed Rule 466 and amendments to Rule 454 will limit the VOC emissions from solvent 

cleaning operations. There are EPA standards such as Best Available Control Technology (BACT) 

and Lowest Achievable Emission Rate (LEAR) that apply to solvent cleaning operations. 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. Rules 454 and 466 exempt solvent degreasing operations 

regulated under 40 CFR Part 63 Subpart T from their requirements. Therefore, Rules 466 and 454 

do not duplicate the NESHAP requirements. The rule consistency matrixes for Rules 454 and 466 

are listed below in Attachments A-1 and A-2. 
Attachment A 

Rules Consistency Matrixes 

Rules 454 & 466 

May 23, 2002, Page 2

Attachment A-1 

40727.2 Matrix for Proposed Amendments to Rule 454, Solvent Degreasing 

Elements of 

Comparison 

Specific 

Provisions 

Rule 454 BACT/LEAR 

Exemptions Cleaning operations using cleanup 

materials containing less than 50 

grams per liter VOCs; Cleanup 

operations specifically regulated under 

other prohibitory rules; Other 

exemptions 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 

use an airtight airless cleaning system 

or install air pollution control 

equipment 

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 

85% overall collection and control 

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 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. 

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. 
Attachment A 

Rules Consistency Matrixes 

Rules 454 & 466 

May 23, 2002, Page 3

Attachment A-2 

40727.2 Matrix for Proposed Amendments to Rule 466, Solvent Cleaning 

Elements of 

Comparison 

Specific 

Provisions 

Rule 466 BACT/LEAR 

Exemptions Cleaning operations using cleanup 

materials containing less than 50 

grams per liter VOCs; Cleanup 

operations specifically regulated 

under other prohibitory rules; Other 

exemptions 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 use an airtight airless cleaning 

system 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. 

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. 

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 466. 

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. 
Attachment B 

IDENTIFICATION OF ACHIEVABLE PERFORMANCE STANDARDS AND EMERGING 

TECHNOLOGIES FOR SOLVENT CLEANING 

The California Clean Air Act requires districts unable to achieve five percent annual 

emission reductions to demonstrate to the California Air Resources Board’s (CARB) 

satisfaction that it has included every feasible emission control measure in its plan and has 

an expeditious rule adoption schedule. According to CARB, no district has been able to 

demonstrate five percent (5%) annual reduction in ozone precursors. Therefore, every 

district’s plan is evaluated on the basis of demonstrating adoption of “Every Feasible 

Measure.” 

CARB has used the definition for “feasible” from the California Environmental Quality Act 

(CEQA) (14 California Code of Regulations, Section 15364). CEQA defines "feasible" as: 

“capable of being accomplished in a successful manner within a reasonable period of time, 

taking into account economic, environmental, legal, social, and technological factors.” 

According to CARB the adoption of every feasible measure involves the adoption of 

regulations that have been successfully implemented elsewhere. CARB’s interpretation is 

explained at length in Identification of Achievable Performance Standards and Emerging 

Technologies for Stationary Sources, March 1998.

The District compared the requirements in Rule 454 and 466 with other with similar rules 

adopted by the South Coast Air Quality Management District (SCAQMD), Bay Area Air 

Quality Management District (BAAQMD), and San Joaquin Unified Air Pollution Control 

District (SJUAPCD). 
Attachment B 

Identification of Achievable Performance Standards 

 and Emerging Technologies for Solvent Cleaning 

Rules 454 & 466 

May 23, 2002, Page 2

Rule 466 

Exemptions 

Rule 466 SCAQMD SJVUAPCD BAAQMD 

1. Cleaning with aerosol 

products if 160 fluid ounces 

or less per day are used. 

2. Cleaning of electrostatic 

coating application 

equipment. 

3. Cleaning of nozzle tips 

of automated spray 

equipment systems, except 

for robotic systems, and 

cleaning with spray bottles 

or containers if solvents 

used comply with the VOC 

limits in Section 301. 

4. Solvents with VOC 

content of 50 grams per liter 

or less. 

5. Cleaning of ink 

sterilization equipment with 

usage < 1.5 gallons per 

day. 

6. Cleaning of application 

equipment used to apply 

coatings on satellites and 

radiation effect coatings. 

7. Cleaning of electrostatic 

coating application 

equipment. 

1. Cleaning with aerosol 

products if 160 fluid 

ounces or less per day 

are used. 

2. Cleaning of 

electrostatic coating 

application equipment. 

3. Cleaning of 

architectural coating 

application equipment 

provided that the 

cleanup solvent used 

does not exceed 950 g/l 

VOCs (Expires June 30, 

2005). 

4. Medical devices and 

pharmaceutical facilities 

using up to 1.5 gallons 

per day of solvents. 

5. Cleaning of nozzle 

tips of automated spray 

equipment systems, 

except for robotic 

systems, and cleaning 

with spray bottles or 

containers if solvents 

used comply with the 

VOC limits in Section 

301. 

6. Cleaning operations 

using cleanup material 

with VOC content less 

than or equal to 50 

grams per liter are 

exempt from the rule 

requirements. 

1. Cleaning of 

architectural coating 

application equipment 

provided that the 

cleanup solvent used 

does not exceed 950 g/l 

VOCs. 

2. Cleaning method 

requirements do not 

apply if using 50 grams 

per liter VOC containing 

solvents. 

3. Cleaning in 

laboratory tests and 

analysis, or research 

scale or research and 

development projects. 

4. Stationary sources 

using 55 gallons or less 

of solvents per a rolling 

365 days. 

5. Storage and disposal 

if using solvents with 

less than 50 grams per 

liter VOC content. 

6. One degreaser per 

building, which uses 

unheated, nonhalogenated solvents 

with open top surface 

area of <1 m2 and a 

capacity of <2 gallons. 

7. Cleaning of flight 

electrical parts using 

unheated nonhalogenated solvents. 

1. Wipe Cleaning 

2. Aerospace stripping 

operations. 

Comments – Rule 466 

The Comments below discuss the basis for selecting the exemptions in this rule. 

Staff added requirements for cleaning of architectural coating application equipment at 50 grams per 

liter for water based paints and 300 grams per liter for solvent based paints which is more stringent 

than that of other districts. Staff believes that there is a big emission reductions potential from this 

category and that since most architectural painting is done using water based paint which can be 
Attachment B 

Identification of Achievable Performance Standards 

 and Emerging Technologies for Solvent Cleaning 

Rules 454 & 466 

May 23, 2002, Page 3

Comments – Rule 466 

cleaned with water. 

Staff did not adopt other exemptions for usage which are included in some other district rules since 

staff believes that compliant material is available for use with minimal cost impact to affected 

facilities. 

VOC Limits – Rule 466 

Cleanup Type Rule SJVUAPCD 

466 

SCAQMD 

11/15/2002 11/15/2003 

BAAQMD 

Product Cleaning During Manufacturing 

Process or Surface Preparation for 

Coating, Adhesive, or Ink Application 

General 

Electrical Apparatus and 

Electronic Components 

Medical Devices and Pharmaceuticals 

Platelets 

50 

500 

800 

800 

50 

500 

800 

No limit 

50 

900 (33 mmHg) 

900 (33 mmHg) 

No limit 

50 

500 

800 

No limit 

50 

No limit 

No limit 

No limit 

Repair and Maintenance Cleaning 

General 

Electrical Apparatus and 

Electronic Components 

Medical Devices and Pharmaceuticals 

 Tools Equipment and 

 Machinery 

 General Work Surfaces 

 Platelets 

50 

900 

800 

600 

800 

50 

900 

800 

600 

No limit 

50 

900 (20 mmHg) 

900 (33 mmHg) 

900 (33 mmHg) 

No limit 

50 

900 

800 

600 

No limit 

50 

No limit 

No limit 

No limit 

Architectural Coating Application 

Equipment 

 Water based coatings 

 Solvent based Coatings – 

 Jobsite and no Enclosed Gun 

 Cleaner 

50 

300 

950 

950 

950 

950 

950 

950 

No limit 

950 
Attachment B 

Identification of Achievable Performance Standards 

 and Emerging Technologies for Solvent Cleaning 

Rules 454 & 466 

May 23, 2002, Page 4

Comments – Rule 466 

Below is a discussion of the different VOC limits proposed in this rule that are different than those adopted by 

other districts and reasons for selecting these them. 

Platelets Cleaning: Staff added a cleanup requirement for platelets in response to public comments. This 

standard is not included in rules adopted by other districts since this cleaning process in unique to one facility 

in the District. Staff chose 800 grams per liter VOC limit based on information supplied by the facility. 

Architectural Coating Application Equipment Cleanup: Staff added a 300 grams per liter VOC limit for cleaning 

of application equipment when using solvent based paints and 50 gram per liter VOC limit when using water 

based paints and the use of enclosed gun cleaner when cleaning at the shop. These limits are more stringent 

than other districts. Staff chose these limits since most architectural paints are water based and can be 

cleaned with water. Staff also believes that there are solvents with 300 grams per liter VOC limit available for 

cleaning of these types of equipment. 

District Cost Effectiveness Comparison 

Overall Rule Cost Effectiveness $/lb SMAQMD SCAQMD SJVUAPCD 

-$0.42 -$0.1 -$0.5 
Attachment B 

Identification of Achievable Performance Standards 

 and Emerging Technologies for Solvent Cleaning 

Rules 454 & 466 

May 23, 2002, Page 5

Rule 454 

Exemptions – Rule 454 

Rule 454 SCAQMD SJVUAPCD BAAQMD 

1. Cleaning using 

solvents that comply 

with the VOC 

standards in Rule 

466. The VOC 

standards in Rule 

466 are higher than 

50 grams per liter 

VOC content. This 

exemption is limited 

to two years from 

adoption date. 

2. Degreasing of 

aerospace parts, 

tools, and machinery. 

3. Cleaning products 

subject to Consumer 

Products Regulation. 

1. Non-vapor degreaser with 

surface area <1 square foot, 

or <2 gallons capacity and 

<5 gallons monthly usage, 

and used to clean electrical, 

high precision optics, 

electronic application, or 

aerospace and military 

applications until January 1, 

2003. 

2. Motion picture cleaning 

equipment. 

3. Cleaning of medical 

devices. 

4. Vapor degreaser used to 

clean electronic equipment 

for use 100 miles above 

earth's surface and VOC 

emissions are <22 pounds 

per month. 

5. Until December 31, 2003, 

cleaning of photocurable 

resins from stereolithography 

equipment and models. 

1. Non-vapor degreaser 

with surface area <1 

square foot, or <2 

gallons capacity and <5 

gallons monthly usage, 

and used to clean 

electrical, high precision 

optics, electronic 

application, or 

aerospace and military 

applications. 

2. One non-vapor 

degreaser per building 

with <1 square foot and 

<2 gallons capacity. 

3. Non-vapor degreaser 

used to clean flight 

critical parts, until April 

19, 2006. 

1. Non-vapor 

degreaser with <1 

square foot area and 

< 1 gallon capacity. 

2. Semiconductor 

solvent cleaner with 

<10 gallons 

capacity. 

3. One single cold 

cleaner per facility 

with solvent loss 

<20 gallons per 

year. 

3. Permitted cold 

cleaner that has a 

valid Permit to 

Operate. 

Comments – Rule 454 

The Comments below discuss the basis for selecting the exemptions in this rule. 

Staff did not provide an exemption for one non-vapor degreaser for the 50 grams per liter VOC limit as in 

BAAQMD since most facilities have only one non-vapor degreaser and this would greatly impact the 

amount of emission reductions from this cleaning category. 

Staff added a 2-year limited exemption from the 50 grams per liter VOC limit for degreasing of electrical 

and electronic components and medical devices and pharmaceuticals which is consistent with other the 

SCAQMD district. Staff believes this exemption will allow affected sources additional time to find 

alternative cleaning methods and materials that comply with the rule. 

Staff added an exemption for degreasing associated with aerospace manufacturing since this type of 

cleaning is not addressed in Rule 456 which regulates aerospace manufacturing. Staff received 

comments requesting this exemption in the rule or the inclusion of this cleaning requirement in Rule 454. 
Attachment B 

Identification of Achievable Performance Standards 

 and Emerging Technologies for Solvent Cleaning 

Rules 454 & 466 

May 23, 2002, Page 6

Comments – Rule 454 

The facility stated that the solvents used have received prior approval for use in aerospace and military 

applications and it would be time consuming and very costly to switch to different solvents. 

Staff did not adopt other exemptions for usage which are included in some other district rules since staff 

believes that compliant material is available for use with minimal cost impact to affected facilities. 

VOC Limits 

Cleanup Type Rule 454 SCAQMD SJVUAPCD 

10/19/2002 

BAAQMD 

Non-vapor (Cold Degreasing) 50 50 50 50 

District Cost Effectiveness Comparison 

Overall Rule Cost Effectiveness $/lb SMAQMD SCAQMD SJVUAPCD 

-$0.42 -$0.1 -$0.5 
Attachment C 

Summary of Changes 

Rule 454, Degreasing Operations 

Existing 

Section 

Number 

New 

Section 

Number 

Proposed Change 

NA 102 Added a new section for Applicability to clarify what source and/or operations 

the rule applies to. 

NA 103 Added a new section for Severability to clarify that if any provision of the rule 

is deemed invalid by court order, the rest of rule provisions remain in full force.

110.2 Same Removed the exemption for non-vapor degreasers with area less than one 

square meters. 

NA 110.3 Added an exemption from the rule if a cleanup solvent is used in a non-vapor 

degreaser and the cleanup solvent contains 50 grams per liter VOCs or less.

110.5 110.6 Revised this section to clarify it in response to ARB comments. (see 

Attachment D) 

NA 110.7 Added an exemption in response to public comments from the 50 grams per 

liter VOC limit in Section 303 for degreasing of specific components and 

products (e.g., electrical and electronic components, medical devices) and to 

require that the solvent used comply with the applicable VOC limit in Rule 

466, Solvent Cleaning. Also limited this exemption to two years from the last 

rule adoption date (see Attachment D). 

NA 110.8 Add an exemption for consumer products that are regulated by ARB under 

their Consumer Products Regulations in response to public comments (see 

Attachment D). 

NA 110.9 Added and exemption from the 50 grams per liter VOC limit requirement for 

non-vapor degreasers for degreasing of aerospace components in response 

to Aerojet comments (see Attachment D). 

NA 201 Added a definition for "Airtight/Airless Cleaning System". This definition is 

same as the definition used in the SCAQMD Rule 1122, Solvent Degreasing.

NA 202 Added a definition for "Circumferential Trough". This definition is the same 

definition as that used in SCAQMD Rule 1122, Solvent Degreasers. 

NA 203 Added a definition for "Closed Container". This definition is similar to the 

definition used in District Rule 459. 

NA 209 Added a definition for "Key System Operating Parameters" since it is used in 

Section 403. 

206 210 Revised the definition of "Leak" to expand it to include visible mist. 

207 211 Revised the definition of "Lip Exhaust" by adding "System" to clarify it. 

216 220 Added "volatile" to the definition of "Solvent" to clarify it. 

NA 221 Added a definition for "Solvent Degreasing" since it is used in the rule. This 

definition is same as the definition used in the SCAQMD Rule 1122, Solvent 

Degreasing. 
Attachment C 

Summary of Changes 

Rule 454 

May 23, 2002, Page 2

NA 224 Added a definition for "Superheated Vapor Zone". This definition is the same 

definition as that used in SCAQMD Rule 1122, Solvent Degreasers. 

219 226 Revised the definition of "Volatile Solvent" to reflect the correct section 

number. 

220 227 Revised the definition of "Wipe Cleaning" to clarify it. 

301 NA Add requirement for solvent containers in response to ARB Comment. (see 

Attachment D) 

302 NA Revised this section to require the use of solvents that contain 50 grams per 

liter of VOCs or use an airtight/airless cleaning system. 

NA 303 Added a new requirement for airtight/airless cleaning system to provide 

sources with an option to low VOC solvents. 

303 304 Revised this section to require a freeboard ratio of 1.0 instead of 0.75 and to 

add other control requirements for the vapor degreaser. New Section 304.1 

combines previous requirements in Sections 303.1 through 303.3. Section 

304.2 includes new requirements for vapor degreasers added to the rule in 

response to ARB comments to make the requirements consistent with other 

Districts. 

NA 305 Added new requirements applicable to a remote reservoir cleaner since the 

rule regulates this equipment. 

306 308 Revised this section to add storage and transfer requirements in response to 

ARB comments. (see Attachment D) 

307 309 Revised this section to clarify it and to remove the reference to the timeline 

that have already passed. Also added requirements applicable to 

airtight/airless cleaning system to this section in response to ARB comments. 

(see Attachment D) 

308 310 Revised this section to make it consistent with other prohibitory rules. 

401 Same Removed this section since the compliance dates are addressed in other 

specific sections of the rule. 

401 402 Revised this section to clarify that this section is intended to calculate VOC 

content of solvents including water and exempt compounds. 

NA 402 Added a new section for determining percent control efficiency and VOC mass 

emission rate. 

403 Same Removed the compliance date that has passed and revised to make 

consistent with other prohibitory rules. 

501 Same Removed the past compliance date for recordkeeping requirements. Also 

revised this section to make it consistent with other prohibitory rules and to 

respond to ARB comment. Changed the duration for keeping records on-site 

from two years to three years to make it consistent with other rules. 

502.1 Same Revised the reference to ASTM test method to reflect the latest version of the 

test method. 

502.2 Same Revised this section to make it consistent with other prohibitory rules. 

502.3 Same Revised this section to make it consistent with other prohibitory rules. 
Attachment C 

Summary of Changes 

Rule 454 

May 23, 2002, Page 3

502.5 Same Revised this section to make it consistent with other prohibitory rules. 

NA 502.7 Added a new section for determining VOC leaks in response to ARB 

comments. (see Attachment D) 
Attachment D 

Comments and Response 

Rules 454 & 466 

1. Screenprinting and Graphic Imaging Association International (SGIA) 

(Comment received via e-mail) 

Comment You may remember me as we worked together on the development of Rule 

450, Graphic Arts, as it pertains to screen printing operations. Regarding 

the application of Rule 466, I would like to discuss with you the solvent 

cleaning products that are used by digital printing operations. These facilities 

primarily use ink jet or electrostatic technologies to produce advertising 

displays, billboards, etc. First, I may be under the wrong assumption -- but 

would this rule impact these facilities? I am assuming yes, since there is a 

definition of ink application equipment in the proposal. The digital printing 

industry is not able, due to technical reasons, to use solvents with a VOC 

content of 50 grams per liter. I would like to discuss with you the possibility 

of exempting these applications until we have had the opportunity to 

research and discuss this issue. Digital printing applications is the growing 

segment of the printing industry and we need to carefully craft regulatory 

requirements that allow both industrial growth as well as use of technologies 

that are more beneficial to the environment. 

Response Rule 466 does not apply to cleaning associated with digital printing 

operations. Cleaning associated with digital printing is subject to Rule 450 

cleaning requirements. 

2. California Air Resources Board (ARB) Comments 

(Comments received via e-mail) 

Rule 454

Comment #1 Section 110.4 Exemptions: This section states that Section 308.7 does not 

apply to operations conducted pursuant to Section 308.10.b. It appears that 

this reference should be changed from “308.10.b.” to “308.9.b.” 

Response #1 Staff made the correction as requested. 

Comment #2 Section 110.6 Exemptions: This section states that the rule does not apply to 

“...solvent degreasing operations using volatile organic compounds 

complying with the NESHAP requirements of 40 CFR Part 63 Subpart T – 

Halogenated Solvents Emissions from Solvent Cleaning.” It is 

recommended that this section be clarified by saying: “...solvent degreasing 
Attachment D 

Comments and Responses 

Rules 454 & 466 

May 23, 2002, Page 2

operations that are subject to the NESHAP...” 

Response #2 Staff removed this section from the rule since it applies to degreasing 

operations that are regulated under Rule 454. 

Comment #3 Section 202 Definitions – Closed Container: This definition does not include 

any requirements for the type of cover that is used (e.g., “impermeable 

cover”.) With the current language, a piece of cardboard could conceivably 

meet this definition. It is recommended that this definition be modified to 

require that the cover be impermeable or non-absorbent. 

Response #3 Staff made the change as recommended. 

Comment #4 Section 303.2 Airtight/Airless Clean System Requirements: This section 

contains a requirement that units shall not have vapor leaks greater than 50 

ppm, as measured by a portable analyzer. However, the rule does not 

contain a test method, monitoring requirements, or recordkeeping 

requirements for determining the vapor concentration. To improve rule 

enforceability, it is recommended that a test method (e.g., EPA Method 21), 

monitoring requirements, and recordkeeping requirements be added. 

Response #4 Staff revised Section 303.2 and added new Section 502.7 for determining 

VOC leak. 

Comment #5 Sections 303.3, 303.4, and 303.5 Airtight/Airless Clean System 

Requirements: These sections contain operating requirements that seem to 

be applicable to all degreasers. It is recommended that these requirements 

be moved to Section 308, “General Operating Requirements”. 

Response #5 Staff added operating requirements to Section 308. Staff also kept these 

requirements in Section 303 to alert the operator of these requirements. 

Comment #6 Section 304.1 Vapor Degreasers; Equipment Requirements: The freeboard 

ratio is required to be at least 0.75. It is recommended that this ratio be 

increased to 1.0, as is the case for similar solvent rules in other Districts 

(e.g., SCAQMD Rule 1122 Section (e) and SJVUAPCD Rule 4662 Section 

5.1.2.1.1). 

Response #6 Staff revised this rule as recommended. 
Attachment D 

Comments and Responses 

Rules 454 & 466 

May 23, 2002, Page 3

Comment #7 Section 304 Vapor Degreasers; Equipment Requirements: It is 

recommended that additional equipment requirements be added to be 

consistent with similar solvent rules in other Districts (e.g., SCAQMD Rule 

1122 Section (e)(1)(B) and SJVUAPCD Rule 4662 Section 5.3.2.1): 

- Automated parts handling system 

- Primary condensing coils 

- Perimeter trough 

- Water separator 

- Superheater vapor zone 

Response #7 Staff revised Section 304 to make the equipment requirements for vapor 

degreasers consistent with other districts. 

Comment #8 Section 305.3, Remote Reservoir Degreaser: The requirement for a leakfree solvent container seems to be applicable to all degreasers. It is 

recommended that this requirement be moved to Section 301, “General 

Equipment Requirements”. 

Response #8 Staff added these requirements to Section 301. Staff also kept these 

requirements in Section 305 to ensure that the operator is kept aware of 

these requirements. 

Comment #9 Section 308.2, General Operating Requirements: This section prohibits 

leaks, but it doesn’t include a requirement for repairing leaks. To improve 

enforceability, it is recommended that the rule include a time frame for 

repairing leaks (e.g., within 48 hours as in SCAQMD Rule 1122 (c)(1)(D).) 

Response #9 Staff did not add this requirement to this rule. The rule as written is more 

stringent since it does not allow any leak. Equipment that has a leak has to 

be taken out of service and repaired before returning to operation. 

Comment #10Former Section 306.9, General Operating Requirements: The proposed 

changes include deleting the statement: “Do not degrease porous or 

absorbent materials such as cloth, leather, wood, or rope.” It is 

recommended that this requirement be retained. 

Response #10 Staff retained this requirement in the rule as recommended. 
Attachment D 

Comments and Responses 

Rules 454 & 466 

May 23, 2002, Page 4

Rule 466

Comment #1 Section 110.5 Exemptions: This section states that the rule does not apply to 

“...solvent degreasing operations using volatile organic compounds 

complying with the NESHAP requirements of 40 CFR Part 63 Subpart T – 

Halogenated Solvents Emissions from Solvent Cleaning.” It is 

recommended that this section be clarified by saying: “...solvent degreasing 

operations that are subject to the NESHAP...” 

Response #1 Staff revised this section as recommended. 

Comment #2 Section 110.1 Exemptions: This section provides exemptions for cleaning 

operations that are covered by other rules. It is recommended that 

SMAQMD Rule 465 (Polyester Resin Operations) be added to this list, to 

prevent potential inconsistencies in VOC limits. 

Response #2 Staff added Rule 465 to the list of exemptions. 

Comment #3 Section 207 Definitions – Closed Container: This definition does not include 

any requirements for the type of cover that is used (e.g., “impermeable 

cover”.) With the current language, a piece of cardboard could conceivably 

meet this definition. It is recommended that this definition be modified to 

require that the cover be impermeable or non-absorbent. 

Response #3 Staff revised the definition as recommended. 

Comment #4 Section 208 Definitions – Coating: This definition is limited to materials that 

form a film, but some coatings actually impregnate surfaces. It is 

recommended that this definition be replaced with the “Coating” definition 

from SMAQMD Rule 442: “A material applied onto or impregnated into a 

substrate for protective, decorative, or functional purposes. Such materials 

include, but are not limited to, paints, varnishes, sealers, and stains.” 

Response #4 Staff revised this definition as recommended. 

Comment #5 Sections 238, 403, 502.5 and 502.6 Composite Partial Pressure: Rule 466 

does not appear to contain any requirements that pertain to VOC composite 

partial pressure. Therefore, it seems that these sections could be deleted 

from the rule. 

Response #5 Staff removed these sections from the rule. 
Attachment D 

Comments and Responses 

Rules 454 & 466 

May 23, 2002, Page 5

Comment #6 Section 303.1 Storage and Disposal Requirements: This section requires 

that “All solvents be stored in closed containers...” It is recommended that 

this be revised to say “All solvents be stored in non-absorbent, non-leaking 

closed containers...” 

Response #6 Staff revised this section as recommended. 

Comment #7 Section 305.1 General Prohibitions: This section would prohibit the sale or 

supply of any “noncompliant solvent” that would be applied “at any physical 

location within the District”. It is not clear how this prohibition of sale would 

be enforced. Since a given solvent could potentially be used for multiple 

applications, the supplier of the solvent would not necessarily know whether 

the solvent would be used in a non-compliant manner. 

Response #7 Staff removed this section from the rule. 

Comment #8 Section 501.3, Usage Records: To enforce this rule, it will be necessary to 

know the type of solvent cleaning activity that is associated with a given 

solvent. Therefore, it is recommended that the recordkeeping requirements 

include identification of the cleaning activity, similar to SJVUAPCD Rule 

4663, Section 6.2.3.5. 

Response #8 Staff revised this section as recommended. 

3. Additional ARB Comments on Rules 454 and 466 

Rule 454

Comment Section 502.2 – Section 502.2 specifies control efficiency determination by 

EPA Methods 18, 25, or 25A or EPA Methods 2 or 2C. EPA Methods 2 and 

2C are for velocity and flow rate determination while EPA Methods 18, 25, 

and 25A are for determination of VOC concentrations. EPA Methods 2 or 

2C should be identified for use in addition to EPA Method 18, 25, or 25A, not 

as an alternative to them. The purpose of each group of methods should be 

identified. Since flow rate is addressed in Section 502.2 it might be most 

appropriate to delete reference to EPA Methods 2 and 2C from Section 

502.2. 

Response Staff made changes to the rule to address these comments. 

Comment Section 502.4 specifies "EPA Methods 2, 2A, 2c, and 2D" for flow rate 

measurements. These methods are alternatives and the wording "EPA 

Methods 2, 2A, 2C, or 2D" would be more appropriate. 
Attachment D 

Comments and Responses 

Rules 454 & 466 

May 23, 2002, Page 6

Response Staff made changes to the rule to address these comments. 
Attachment D 

Comments and Responses 

Rules 454 & 466 

May 23, 2002, Page 7

Rule 466

Comment Section 502.3 – Section 502.3 specifies efficiency determination by EPA 

Methods 18, 25, or 25 A or EPA Methods 2 or 2C. EPA Method 2 or 2C are 

for velocity and flow rate determination while EPA Methods 18, 25, and 25A 

are for determination of VOC concentrations. EPA Methods 2 or 2C should 

be identified for use in addition to EPA Method 18, 25, or 25A, not as 

alternative to them. The purpose of each group of methods should be 

identified. 

Response Staff revised the rule as recommended. 

4. Consumer Specialty Products Association (CSPA) Comment 

Comment CSPA requested that the District amend Rule 454 to include language 

clearly stating that Rule 454 requirements do not apply to products used by 

household and institutional consumers that are subject to regulations issued 

by the California Air Resources Board 

Response Staff added this exemption to Rule 454 as requested. 

5. Safety-Kleen Corporation Comments 

Comment Safety-Kleen's primary issue is the definition of solvent degreasing in Rule 

454. Our suggestion is that something is needed to state that solvent 

degreasing does not include cleaning activities that are exempt under Rule 

466. Both the definition of solvent degreasing in Rule 454 and the definition 

of solvent cleaning in Rule 466 include the removal of "contaminants". 

The appropriate place to make the distinction is probably in Section 102 of 

Rule 454. Addition of the following sentence to that section would clarify that 

the 50 g/l VOC requirements in Rule 454 are not intended to apply to the 

cleaning operations in Rule 454. 

"The provisions of this rule shall not apply to solvent cleaning operations in a 

remote reservoir solvent degreaser which are subject to the Standards in 

Section 300 of Rule 466." 

 Adding the preceding sentence to Section 102 of Rule 454 merely clarifies 

the intent, but it could avoid a lot of arguments with inspectors over what is 

solvent cleaning and what is solvent degreasing. 

Response Staff revised Section 102 of Rule 454 to clarify that the requirement to use 

50 grams per liter VOC limit does not apply to solvents used in a non-vapor 

degreaser or a remote reservoir degreaser providing these solvents comply 
Attachment D 

Comments and Responses 

Rules 454 & 466 

May 23, 2002, Page 8

with the applicable VOC limit in Section 300 of Rule 466. Staff also limited 

the exemption to two years from the date of adoption of rule amendments. 

6. NORA, An Association of Responsible Recyclers (NORA) Comments 

(Comments received via e-mail) 

NORA indicated that their comments are restricted to those provisions that apply to the cold 

cleaning of parts in Remote Reservoir (sink on a drum) parts cleaners during automotive 

and industrial repairs. NORA submitted technical comments in opposition to the proposed 

ban on parts cleaners with low volatility, low reactivity mineral spirits. These comments are 

listed below: 

Comment On October 12, 2001, The Parts Cleaning Council of NORA, An Association 

of Responsible Recyclers, a trade association of 200 small businesses, 

submitted technical comments to the San Francisco Bay Area Air Quality 

Management District and to other California Area Air Quality Management 

Districts addressing the then proposed bans on the use of petroleum solvent 

in the cleaning of parts resulting from automotive and industrial maintenance 

and repair activity. These comments demonstrated that the employment of 

best management practices in solvent parts cleaning using currently 

available low volatility, low reactivity mineral spirits reduces ozone formation 

potential to minimal levels and thus, parts cleaning with mineral spirits would 

have a positive impact on ozone concentrations in the Sacramento area. 

NORA offers five technical arguments to challenge the conventional wisdom 

that the use of mineral spirits in cleaning parts during maintenance and 

repair of automobiles and manufacturing machinery releases sufficient 

volumes of solvent vapor to adversely affect air quality in the Sacramento 

Area. To the best of our knowledge, the data on which the proposed rule 

changes are based is decades old. Most important, there is adequate time 

in the proposed twelve-month transition period to test the actual emissions 

from remote reservoir parts cleaners running on the modern low volatility, 

low reactivity mineral spirits now in common use in automobile repair parts 

cleaning. NORA members are eager to participate in a well-designed test to 

measure the volume and reactivity of emissions from sink on drum parts 

cleaners. The five technical comments are: 

1. The members of the American Chemistry Council supply NORA 

Parts Cleaning Council members with aromatic free mineral spirits 

with very little ozone reactivity. Dr. William Carter has tested this 

solvent in research sponsored by the California Air Resources 

Board. This research clearly demonstrates that aromatics-free 

mineral spirits has very low ozone formation potential. 

2. The mineral spirits referred to above also has very low volatility, less 

than mm vapor pressure at ambient temperature. The use of very 
Attachment D 

Comments and Responses 

Rules 454 & 466 

May 23, 2002, Page 9

low volatility solvent significantly reduces the evaporation rate from 

parts cleaning activities. NORA members' data on parts cleaning 

with low volatility mineral spirits indicate that the emission rate of 

petroleum vapor from sink on a drum parts cleaners is approximately 

one half of the amount assumed in calculating the reduction of 

emissions from banning the use of mineral spirits parts cleaning. 

3. NORA has offered to provide California Area Air Quality 

Management Districts with a list of Best Management Practices for 

the operation of “sink on drum” parts cleaners. However, most of 

these practices are incorporated in the Sacramento Metropolitan Air 

Quality Management District rules. These practices include technical 

changes in the operation of “sink on drum” parts cleaners that can 

further reduce the emission of vapors of a minimally reactive 

hydrocarbon by another order of magnitude and should be 

incorporated in the test suggested herein. 

4. As expected, the exaggerated estimate of emissions from cleaning 

repair parts with solvent in “sink on a drum” parts cleaners is based 

on excessive estimates of not only the evaporation rate of the low 

volatility mineral spirits, but the hours of operation of these units in 

typical automotive repair or, less often, in machinery repair. Because 

mineral spirits is such an efficient cleaner, only a few minutes are 

needed to actually wash the dirty part. With best management 

practices in force, the solvent stream is normally off and the sink acts 

as a cover over the quiescent solvent in the drum. 

5. NORA believes that observation and measurement of actual 

operation of a number of “sink on a drum” part cleaners in typical 

automotive and industrial service under best management practices 

will offer a sound technical basis for regulation of solvent based parts 

cleaning in the Sacramento Metropolitan Area. NORA would 

cooperate in such a study with Sacramento Metropolitan Air Quality 

Management District and/ or CARB. NORA would accept and 

support the regulations the resulted from such a study. 

Knowing that these proposed regulations on parts cleaning to be adopted by 

Sacramento Metropolitan Air Quality management District have already 

been adopted by the South Coast Air Quality Management District, the San 

Joaquin Valley Air Quality District, and the San Francisco Bay Area Air 

Quality Management District, (but not San Diego); NORA is well aware that 

the proposed ban on cleaning parts with solvent in Sacramento Area was 

likely to find support from the Sacramento Metropolitan Air Quality 

Management District and CARB in spite of the sound technical arguments 

against this approach. Nevertheless, NORA believes that our members and 

our small business customers are entitled to a response including our 

technical comments in spite of our members also servicing aqueous based 

parts cleaners. The purpose of this letter is to request the Agency’s 
Attachment D 

Comments and Responses 

Rules 454 & 466 

May 23, 2002, Page 10

consideration of and response to the technical comments on the use of very 

low reactivity, low volatility mineral spirits in repair parts cleaning. When the 

minimum impact on air quality from cleaning repair parts with low reactivity, 

low volatility mineral spirits under best management practices is compared 

to the negative impacts on water pollution and electrical consumption, 

neither trivial issues in California, from aqueous parts cleaning, the case for 

these regulations is extremely weak. 

The loss of the Sacramento Metropolitan Area as a market for solvent-based 

parts cleaning is a significant financial burden for several NORA members. 

The loss of the entire state as a market will be an even greater hardship to 

NORA members. Furthermore, we believe that the citizens and small 

businesses of Sacramento will be hurt by this rulemaking. We feel that it is in 

the best interest of the community to formulate public policy based on the 

review and consideration of all reasonable viewpoints, and we encourage 

you to ensure that will be done in this case. We must learn the Sacramento 

Metropolitan Area Air Quality Management District position relative to each 

of NORA’s technical comments, especially our proposal that an actual 

emission test be conducted, not only to validate that each of these issues 

were considered in the final rulemaking, but also in order to discover any 

weakness in our own logic and thereby understand and accept the final rule. 

NORA looks forward to receiving a response to our comments, or better yet, 

engaging in a dialog with the Sacramento Metropolitan Air Quality 

Management District staff in response to NORA’s technical comments. 

If, as we suspect, the complete ban on cleaning of parts with mineral spirits 

will eventually require reconsideration by the State of California, perhaps the 

consideration of and response to NORA’s technical comments will also 

prove valuable to the District as well as the citizens and small businesses of 

California. Management Practice for the operation on "sink on drum" parts 

cleaner could significantly reduce the emissions of VOCs. NORA also 

indicated that estimates of emissions cleaning repair parts with solvents is 

exaggerated based on excessive estimated of not only the evaporation rate 

of the low volatility mineral spirits, but the hours of operation of these units. 

Response Low Reactivity Solvents: Low reactivity based standards for aerosol products 

were used by CARB in the their Consumer Product Regulations. Solvents 

with low levels of reactivity have lower potential to reacting in the 

atmosphere to form ozone. Staff assumes that NORA is referring to work 

that Dr. Carter conducted for Safety Kleen, which involved performing 

chamber experiments on four Safety Kleen samples. (ARB has a current 

research contract with Dr. William Carter to conduct environmental chamber 

tests on mineral spirits/distillates, but the testing has not yet begun.) Dr. 

Carter’s research for Safety Kleen indicated that Type II-C mineral spirits 

had a maximum incremental reactivity (MIR) of approximately 0.8 grams 

ozone/gram VOC. The research also indicated that the MIR for Safety 
Attachment D 

Comments and Responses 

Rules 454 & 466 

May 23, 2002, Page 11

Kleen’s Type I-B mineral spirits is approximately 1.3 grams ozone/gram 

VOC. (To provide some perspective, the MIR for acetone is 0.4, the MIR for 

isopropyl alcohol is 0.7, and the MIR for methyl ethyl ketone is 1.5.) 

However, it may be incorrect to state that the research clearly demonstrated 

low ozone formation potential for mineral spirits in general. In his project 

report, Dr. Carter stated that “...the representativeness of these four 

samples to the full range of mineral spirits or similar samples being subject 

to VOC regulations is highly uncertain...” ARB’s upcoming chamber 

experiments will further evaluate this issue. At this time, given the results 

from this study, mineral spirits do not appear to be less reactive. 

ARB has used a reactivity-based approach for their Low Emission Vehicle 

regulations and aerosol coatings regulations. In addition, ARB is evaluating 

the feasibility of using a reactivity-based approach for architectural coatings. 

ARB is planning to evaluate the feasibility of a reactivity-based regulation for 

the use of multi-purpose solvents for consumer applications. The results of 

these efforts are expected to provide information that Districts may be able 

to use when they consider the possibility of a reactivity-based regulation for 

solvent cleaning and degreasing. Staff will evaluate the feasibility of 

allowing use of low reactivity solvents after these studies are concluded and 

any recommendations from ARB and EPA. 

Low Volatility Solvents: Using low volatility solvents reduces the rate of 

evaporation (loss) of these solvents compared with higher volatility mineral 

spirits. These solvents, however, eventually evaporate into the atmosphere. 

It may take more time to clean with low VOC solvents, but not more low VOC 

solvents to clean the same part. Additionally, low volatility solvents which 

are typically alkaline type cleaners have longer bed life than mineral spirits 

which also results in lower VOC emissions. 

Emission Estimates: Staff estimated the overall VOC emission reductions 

from solvent usage in the District and not based on hours of operation. VOC 

emission estimates from part cleaners are based on annual solvent usage 

and solvent loss data provided to the District. Staff therefore, believes that 

VOC emission reduction estimates are not exaggerated. 

Best Management Practice: NORA claims that the use of Best Management 

Practice for the operation of "sink on drum" parts cleaner will result in 

reductions of VOC emissions. Rule 454 already include requirements for 

such practice. 

Cost Impacts on Local Businesses: Staff analyzed the impact on local 

businesses in the District and found that using aqueous type cleaners will 

result in a net cost savings for these businesses. Staff understands that the 

proposed regulations may impact waste recyclers, but does not expect the 

impact to be significant since spent aqueous cleaners usually have to be 
Attachment D 

Comments and Responses 

Rules 454 & 466 

May 23, 2002, Page 12

disposed of in the same manner as spent cleanup solvents. 

Study of Emissions from Part Cleaners: Staff does not believe that an actual 

test is needed to verify the emissions from the parts cleaner. 

7. Aerojet Comments 

Staff received comments from Aerojet requesting changes to Rule 456, Aerospace 

Assembly and Component Coating Operations to incorporate the solvent cleaning 

requirements that are listed in the Aerospace NESHAPS (40 CFR Part 63 Subpart GG). 

Staff initially received two comment letters via e-mail and later received a third comment 

letter (Attachment E) dated April 11, 2002 that list all Aerojet comments. Below is a 

discussion of these comments. 

Aerojet has several cleaning operations that use solvents that do not comply with the 

proposed VOC limits in Rules 454 and 466. These solvent cleaning activities vary from 

solvent flushing to degreasing. Aerojet also indicated that the current solvent cleaning 

methods have been researched extensively and have been approved by the defense and 

aerospace industries for use. 

Staff discussed the comments with Carolyn Craig, Aerojet. Based on the information 

Carolyn Craig provided about the various cleaning operations, Staff was able to determine 

that most of these cleaning operations are regulated under Rule 456 (Rule 466 exempts 

solvent cleaning operations that are subject to Rule 456.) Staff also found out that Aerojet 

has other cleaning operations that are not regulated under Rule 456. These operations are 

regulated under Rules 454 and 466. These operations include degreasing of cast tooling 

and cleaning of platelets. Below is a summary of these comments. More background 

details of the cleaning operations and comments are listed the comment letter dated April 

11, 2002. 

Comment Aerojet requests an exemption from the solvent cleaning requirements in 

Rules 454 and 466 for cleaning associated with aerospace related 

components. Aerojet also requested that Staff amend Rule 456, to 

incorporate the aerospace NESHAPS solvent cleaning requirements into 

Rule 456. Aerojet indicated that these aerospace components must meet 

certain cleaning requirements that are approved by and any new cleanup 

materials must also be approved before use. Aerojet also indicated that 

VOC emissions from these cleaning operations are insignificant and had 

listed some of them as insignificant in their Title V permit. 

Response Staff added an exemption to these rules. Staff does not see a need to open 

Rule 456 at this time just to add solvent cleaning requirements for aerospace 

components that were not addressed in Rule 456 since these requirements 

have been incorporated under Rules 454 and 466. NESHAPs regulations 

apply regardless of whether they are in Rule 456 or not. 

Comment Aerojet requested that Rule 454 include an exemption for degreasing 
Attachment D 

Comments and Responses 

Rules 454 & 466 

May 23, 2002, Page 13

operations for aerospace components. 

Response Staff added an exemption for degreasing of aerospace components provided 

that they comply with solvent limits in Rule 456. 

Comment Aerojet requested that Rule 466 include an exemption or a VOC standard for 

cleaning of platelets. 

Response Staff added a 800 grams per liter VOC standard for platelets cleaning. This 

limit is based on the VOC content of the solvent currently being used by 

Aerojet. Aerojet indicated to staff that the solvent used for this cleaning 

process has been tested and certified for use and meets aerospace and 

military specifications. Aerojet also indicated that it is very expensive and 

time consuming to get approval to use alternate solvent. Staff also chose 

this standard since there are no other district rules that regulate this type of 

cleaning. 

8. Public Workshop Comments 

 

No comment were received at the public workshop. The public workshop was also attended 

by staff from CARB and Sacramento County Industrial Waste Section. Below is a list of the 

business representatives that are affected by the rules. 

Name Company Comments 

Dan Cole Sacramento Bee Currently using aqueous cleaners 

Donald Rothenbaum NEC 

Joseph Taudberg Renegade West Supplier of aqueous part cleaners 

George Contos Blomberg Window Systems 

Gary Dodson Elk Grove Unified School 

District 

Tested aqueous cleaners 

Steve LuQuire Safety Kleen Has aqueous part cleaners