SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

APPENDIX 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 assumptions 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 solvent 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 

Reduction (%)

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 operations. 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 degreasing 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 represent 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 represent 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 cleaning 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 emission 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, District 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 inventory 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 amendments 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 Coast 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 staff 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 the 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 particular 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, emission 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 

emission 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, nonarchitectural processes

EIC VOC?

2005 Emissions 

(tpd)

Cleaning-only 2005 

VOC Emissions (tpd)

Estimated VOC 

Emission 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 0.003

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

220-206-3300-0000 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 0.002

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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