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 ManagerStaff 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 reduc e 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 applicati on), 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 degr easing 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 outsideStaff 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. Exam ples 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 11/19/2002 San Joaquin Valley Unified Air

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 airt ight airless cleaning sy stem 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 peri od 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 SI P 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 pr eparation 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 feasib le measure.” Districts must adopt the most

effective control measures to reduce VOC emissions from solvent cleaning operations. Many Districts such as SCAQMD, BAAQ MD, 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 BA RCT 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 t he 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 rese rvoir 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 bu siness, 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 printi ng shops, electric and electronic components repair and manufacturing facilities, and miscellaneous repair and maintenance operations. Staff estimates that the proposed rules will im pact the automotive service industry the most. Based on information supplied by the Depar tment 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 - 6Staff 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 majo rity 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 Resu lts 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 acet one 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 st udy 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 am endments 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 ex pects 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

si g nificantl y since heatin g 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 re sult 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 r equirements 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 District s 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 wi th future effective date (July 1, 2005). Staff did not chose these limits since they have not been yet demonstr ated 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 t he 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 sour ces. 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 achiev ed from the proposed regulations. The VOC emission reductions were estimated based on the following information:

1. Emission inventory developed by the Di strict 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 ControlStaff 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 objec tive 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 assum ed 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 polluti on control equipment and compliant material.

The following equation was used to calculate the incremental cost:



### ⎟ ⎟ ⎠ ⎞ ⎜ ⎜ ⎝ ⎛

− −

=

1 2 1 2 

### ) / ($ /

option option opetion option



### TER TER PV

PV

ton E IC

Where: IC = Incremental Cost ($) E = Emissions reductions (tons)

PV option 2 = Present value of control costs forStaff Report

Rules 454 & 466 May 23, 2002, Page 13

option 2 ($/yr)

PV option 1 = Present value of control costs for option 1 ($/yr)

TER option2 = Total emission reductions for option2 over a 10-year period (tons)

TER option1 = 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 adopt ed 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 det ermined that the proposed rules will not have a significant effect on the environment. A Negat ive 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 Ac t 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 m easures” 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 eas ily 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 Ru le 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 requirement s (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 specific ally 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 requirem ents 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 cl osed 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; su rface 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 implement ed 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 usesunheated, nonhalogenated solvents with open top surface

area of <1 m 2 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 t here is a big emission reductions potential from this category and that since most architectural paint ing is done using water based paint which can beAttachment 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

SJVUAPCD Cleanup Type Rule

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

950Attachment 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 district s 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 paint s and 50 gram per liter VOC limit when using water based paints and the use of enclosed gun cleaner when cleani ng 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

SMAQMD SCAQMD SJVUAPCD Overall Rule Cost Effectiveness $/lb
-$0.42 -$0.1 -$0.5Attachment 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 degr easer 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 pharmac euticals which is cons istent 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 wit h 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 ar e 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

SJVUAPCD Cleanup Type Rule 454 SCAQMD

10/19/2002 BAAQMD

Non-vapor (Cold Degreasing) 50 50 50 50

District Cost Effectiveness Comparison

SMAQMD SCAQMD SJVUAPCD Overall Rule Cost Effectiveness $/lb
-$0.42 -$0.1 -$0.5Attachment 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 gram s 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 airti ght/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 gr owth 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 clarif ied by saying: “...solvent degreasingAttachment 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 #10 Former 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 clarif ied 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 secti on 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 recordk eeping 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 addi tion 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 complyAttachment 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 t he 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 t hen proposed bans on the use of petroleum solvent in the cleaning of parts resulting from automotive and industrial maintenance and repair activity. These comments dem onstrated 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 veryAttachment 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’sAttachment 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 Ca rter 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 SafetyAttachment 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 feasibilit y 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, event ually 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 hav e 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 beAttachment 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 extensivel y 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 degreasingAttachment D Comments and Responses

Rules 454 & 466 May 23, 2002, Page 13

operations for aerospace components.

Response Staff added an exemption for degreasi ng 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 wor kshop. The public wor kshop 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