### SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

APPEN DIX B: VOC Emission Reductions September 20, 2007

B

- 1 Final Staff Report for with Appendices For Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules 

# APPENDIX B

EMISSION REDUCTION ANALYSIS FOR THE

SOLVENT CLEANING PORTION OF ELEVEN DISTRICT RULES

SEPTEMBER 20, 2007

### SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

APPENDIX B: VOC Emission Reductions September 20, 2007

B

- 2 Final Staff Report with Appendices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules 

### EMISSION REDUCTION ANALYSIS FOR THE

SOLVENT CLEANING PORTION OF ELEVEN DISTRICT RULES

I. SUMMARY

The purpose of this analysis is to estimate the VOC emissions reduction for the proposed amendments to the solvent cleaning portions of eleven District rules and to outline the methodologies used to calculate the VOC emissions reduction. This analysis also includes the assum ptions made for calculation of the VOC emission

reductions.

Total emission reductions include emissions reductions from four types of proposed amendments to the rules. As outlined in Section II of this appendix, the four changes

are: Lower VOC content limit for solvents used in general cleaning operations, Lower VOC content limits for solvents used to clean printing presses, and Removing the exemption for cleaning architectural coating application equipment Changing the VOC emission limit for general so lvent usage (Rule 4661)

Table 1 summarizes the estimated emission reductions from each of these changes. The calculation methodology is outlined in Section II of this appendix. Overall, the proposed amendments are estimated to have a total of about 3.3 tons per day of VOC emission reductions, which is about a 60% reduction to the adjusted 2005 baseline

VOC emissions.

Table 1

– Estimated Emission Reductions

Category 2005 Baseline

VOC Emissions (tpd) Adjusted Baseline

VOC Emissions (tpd) Estimated

Reducti on (%) Estimated VOC

Emission Reductions (tpd)

General Cleaning

- other than printing 6.12 3.32 50% 1.66
Printing Cleaning 1.28 0.52 20% 0.10 Architectural Coating Exemption Change 1.62 1.62 96.5% 1.57

Rule 4661 VOC

Emission Maximum 0.0 0.0 0.0% 0.00

Totals 9.03 5.47 3.34



### II. EMISSIONS AND EMISSION REDUCTION ANALYSIS

Operators in many different types of industries perform solvent cleaning and solvent degreasing. Under current rule provisions, the VOC content of the cleaning materials is

limited and the allowable content limit depends on the particular cleaning operation. Additionally, if the allowable VOC content is greater than 50 grams VOC per liter of

### SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

APPENDIX B: VOC Emission Reductions September 20, 2007

B

- 3 Final Staff Report with Appendices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules 

### material, there are required work practices to minimize VOC emissions from the cleaning oper ations. The allowable VOC content for nearly all of the cleaning materials would be reduced as part of this rule development project. The following sections outline the process used to determine the current VOC emissions from solvent cleaning/solvent deg reasing and the anticipated VOC emission reductions from proposed rule amendments.

A. VOC Emission Inventory for 2005

Emission inventory codes (EIC) describe the source category and consist of a 14

- digit code. The first three digits generally represen t a general emission group; the second three digits are representing a specific operation, followed by four digits for listing the material. The final four digits are used only for certain categories, are specific to the individual air district, and repre sent even more refined information about the emission source. For this rule project, District staff reviewed all of the EICs assigned to the District to determine which apply to solvent cleaning or solvent degreasing. District staff

tracks certain cleani ng categories using organic compounds that are exempt from being counted as VOCs. One example of this is EIC 230

- 240

- 3800

- 0000, which is for the use of acetone during cleaning and thinning in the industry “coatings and other related processes.” The emiss ion inventory for exempt compound EICs was set to zero.

Within the inventory, there are some EICs that apply to both thinning and cleaning or to both thinning and coatings. To estimate the emissions from solvent cleaning

- only in these categories, Distr ict staff assumed that 40% of the emissions apply to cleaning and the remaining 60% to thinning or coatings, as appropriate. Additionally, it is proposed to remove the exemption for architectural coatings cleaning from Proposed Rule 4663, so

the EIC that fits this description is included in the rule project’s emission inventory. Initial VOC emission inventory for solvent cleaning is estimated to be 9.0 tons VOC per day, using 2005 emissions data from the District’s 8

- hour Ozone Plan. Adjusting

emission i nventory categories to exclude thinning of coatings and other miscellaneous operations, the total emission inventory for this rule project estimated to be about 5.5 tons VOC per day.

B. VOC Emission Reductions

1. General Cleaning

– Other Than Printing

This rule project would change the allowable VOC content limit for general cleaning and surface preparation from 50 grams per liter (50 g/L) to 25 g/L. This represents a 50% reduction in VOC content. It is assumed that the 50% reduction applies to all emission inventory categories except the inventory for the solvent cleaning portions of printing and architectural coatings. For all emission inventory categories associated with solvent cleaning except printing and architectural coating, a factor of 50% was applied to the current emission inventory to get the estimated emission reductions. The rule amendments will reduce most solvent cleaning categories by a total of about 1.7 tons VOC per day, as shown in Table 2.

### SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

APPENDIX B: VOC Emission Reductions September 20, 2007

B

- 4 Final Staff Report with Appendices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules 

### 2. Printing Cleaning

In proposed a mendments to District Rule 4607 (Graphic Arts), the change in VOC content for solvent utilized in the cleaning of printing equipment would reduce the allowable VOC content in two steps. A technology assessment of the printing industry completed by South C oast Air Quality Management District (SCAQMD) staff in 2006 concluded that a 100 g/L limit for specific cleaning operations could be implemented by January 2008 for those that are not already at this limit. Industry sources dispute this finding. SCAQMD s taff have committed to another technology assessment for these groups. Additional emission reductions would occur if the proposed 100 g/L VOC content limit were found to be technologically feasible by SCAQMD staff. In Proposed Rule 4607, operators would have to be in compliance with a 100 g/L limit beginning in 2010. The difference in compliance date between the SCAQMD rule and Proposed Rule 4607 would allow additional time for SCAQMD staff to complete their assessment as well as potentially increasing t he availability of low

- VOC products for this application. The amendments to Rule 4607 propose the lowest possible level that has been achieved in practice for the specific cleaning operations. This interim limit is between

17% and 37% lower than current rule requirements. District staff has used 20% as an average reduction for the printing industry. Emission reductions are estimated at 0.1 tons VOC per day. Actual emission reductions could be higher than 20% for this source category, depending on the p articular cleaning operation and the VOC content of the cleaning solvent currently used by the operator.

3. Architectural Coating

– Exemption Change

Rule 4663 currently has an exemption for the cleaning of architectural coating application equipment. District staff proposes removing this exemption and subjecting the operators to a 25 g/L VOC content limit for cleaning solvents. Assuming that the average cleaning solvent currently used in this operation contains 770 g VOC per liter of material, emissi on reductions would be 100%

- (25/770) x 100 or 96.5% of baseline emissions. With 2000 baseline emissions of 1.62 tons per day, emission reductions are estimated at 1.57 tons per day for removing the exemption.

4. Rule 4661

– Maximum VOC Emission

There are about 12 facilities with permits that cite Rule 4661 as a permit condition. These facilities would not need to change their operations since they are smaller operations that operate five days per week (about 20 days per month). Therefore, no

emissio n reductions are expected as part of this rule change.

### SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

APPENDIX B: VOC Emission Reductions September 20, 2007

B

- 5 Final Staff Report with Appendices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules 

### Table 2

– EICs and VOC Emission Calculations for General Cleaning, non

- printing, non

architectural processes

EIC VOC? 2005 Emissions (tpd) Cleaning

- only 2005

VOC Emissions (tpd) Estimated VOC

Emissio n Reductions (tpd)

220

- 204

- 0500

- 0000 Y 1.023 1.023 0.511

220

- 204

- 3022

- 0000 Y 0.014 0.014 0.007

220

- 204

- 3083

- 0000 N 0.001 0.000 0.000

220

- 204

- 3176

- 0000 Y 0.001 0.001 0.000

220

- 204

- 3204

- 0000 Y 0.000 0.000 0.000

220

- 204

- 3333

- 0000 Y 0.006 0.006 0.0 03

220

- 204

- 3339

- 0000 Y 0.000 0.000 0.000

220

- 204

- 3344

- 0000 N 0.000 0.000 0.000

220

- 204

- 8106

- 0000 Y 0.039 0.039 0.020

220

- 206

- 3083

- 0000 N 0.004 0.000 0.000

220

- 206

- 3107

- 0000 N 0.000 0.000 0.000

220

- 206

- 3246

- 0000 N 0.000 0.000 0.000

220

- 206

- 330 0

- 0000 N 0.000 0.000 0.000

220

- 206

- 3301

- 0000 N 0.001 0.000 0.000

220

- 206

- 3344

- 0000 N 0.000 0.000 0.000

220

- 206

- 3346

- 0000 Y 0.002 0.002 0.001

220

- 206

- 8106

- 0000 Y 0.000 0.000 0.000

220

- 208

- 0500

- 0000 Y 0.148 0.148 0.074

220

- 208

- 3022

- 0000 Y 0.084 0 .084 0.042

220

- 208

- 3083

- 0000 N 0.000 0.000 0.000

220

- 208

- 3176

- 0000 Y 0.018 0.018 0.009

220

- 208

- 3204

- 0000 Y 0.063 0.063 0.032

220

- 208

- 3246

- 0000 N 0.000 0.000 0.000

220

- 208

- 3339

- 0000 Y 0.016 0.016 0.008

220

- 208

- 3344

- 0000 N 0.000 0.000 0.000

220

- 208

- 3346

- 0000 Y 0.001 0.001 0.000

220

- 208

- 8104

- 0000 Y 0.012 0.012 0.006

220

- 208

- 8106

- 0000 Y 0.038 0.038 0.019

230

- 216

- 8350

- 0000 Y 0.008 0.008 0.004

230

- 240

- 0500

- 0000 Y 0.000 0.000 0.000

230

- 240

- 3008

- 0000 N 0.015 0.000 0.000

230

- 240

- 3060

- 0000 Y 0.056 0.022 0.011

230

- 240

- 3202

- 0000 Y 0.004 0.002 0.001

230

- 240

- 3232

- 0000 Y 0.003 0.001 0.001

230

- 240

- 3372

- 0000 Y 0.000 0.000 0.000

230

- 240

- 8300

- 0000 Y 1.156 0.463 0.231

230

- 240

- 8350

- 0000 Y 0.011 0.004 0.002

299

- 995

- 0000

- 0000 Y 0.012 0.005 0.0 02

299

- 995

- 3158

- 0000 Y 0.002 0.002 0.001

299

- 995

- 8000

- 0000 Y 3.385 1.354 0.677

TOTAL EMISSIONS 6.121 3.324 1.662

### SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

APPENDIX B: VOC Emission Reductions September 20, 2007

B

- 6 Final Staff Report with Appendices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules 

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