# FINAL STAFF REPORT

Rule 3. 14 : Surface Preparation and Clean

- up 

## Rule 3.19 : Vehicle and Automotive Coating Operations


## Rule 3.2 0: Wood Product Coatings Operations



## Rule 1.1: Definitions



### Date of Release: June 6 , 2011

Schedule of Meetings

Rule Changes Workshop: April 21 , 20 11 Public Hearing: June 6, 2011

### STAFF REPORT

Dat e of Release: June 6 , 2011

Scheduled Date of FRAQMD Adoption: June 6, 2011 Feather River AQMD, 1007 Live Oak Blvd, Suite B

- 3,

Yuba City, California 95991

Contents Page

1. Executive Summary

................................ ................................ ........................... 1

2. Background

................................ ................................ ................................ ........ 2

3. Legal Mandate

................................ ................................ ................................ ... 2

4. Propo sed Rule Requirements

................................ ................................ ............. 4

5. Socioeconomic Impact

................................ ................................ ....................... 7

6. Impact s of the Pro posed Rule

................................ ................................ ............ 7

7. Estimated Cost Impact

................................ ................................ ....................... 8

8. Environmental Review and Compliance

................................ ......................... 10

9. Required Findings

................................ ................................ ............................ 10

10. References

................................ ................................ ................................ ........ 11

...........................................

Appendix A: Rule Analysis Appendix B: Public Notice Appendix C: Comments and ResponsesProposed Rule: 3.14 6/6/2011

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- 

### 1.0 Executive Summary:

Feather River Air Quality Management District (District) is a Bi

- County agency that administer s local,

state

, and federal air quality management program s for Yuba and Sutter Counties. Under the provisions of

the California Clean Air Act (CCAA) of 1988 , Yuba County and the northern portion of Sutter County

hav e been designated as “ nonattainment

- transitional” for failing to meet the state ozone standard. The southern portion of Sutter County is designated as “severe ” nonattainment for failing to meet the state

ozone standard.

Ozone is formed when volatile organic compounds (VOC s ) react with nitrogen oxides (NOx) in the presence of sun light, and is one compo nent of smog

. It is a strong irritant that attacks the respiratory system and leads to the damage of lung tissues. Exposure to ozone aggravates asthma, bronchitis and other respiratory diseases, as w ell as cardiovascular diseases. VOC r e ductions are necess ary to attain and maintain the state ambient air quality standard for ozone.

The 2009 Air Quality Attainment Plan requires the Northern Sacramento Valley Air Basin (NSVAB) to adopt rules and regulations deemed necessary to attain and maintain the state am bient air quality standard for criteria pollutants at the earliest practical date. District Staff is proposing to modify District Rule 3.14, Solvent Degreasing, to fulfill the commitment made by the District and to help attain the state ambient air qualit y standards for ozone.

Because portions of the District have been designated as nonattainment for failure to meet the federal 8

- hour ground

- level ozone standard, the United States Environ mental Protection Agency ( EPA) requires the District to implement measures to reduce ozon e precursors. The District has committed to implement

control measures and reduce pollution through the State Implementation Plan (SIP). The SIP is federally enforceable through the EPA and the F ederal Clean Air Act (CAA).

District Rule 3.14, Solvent Degreasing, was adopted in June of 1991. For the 2011 amendments, the District proposes to rename this rule “Surface Preparation and Clean

- up” to account for the various uses of solvent. The rule will effectively lower the VOC content li mit for the various uses of solvents and document procedures to reduce the evaporation of solvents in to the atmosphere . Lower VOC content

limits for these solvents have been achieved for most applications in other Air Districts through the use of

aqueous t e chnologies or by transitioning to exempt compounds

.

Solvent cleaning is performed by manufacturing and service operations for application equipment and manufactured or serviced parts. The proposed rule amendments will affect a wide variety of industries. Any source performing solvent cleaning will be affected, including sources not currently regulated by the District. Industries potentially affected include repair shops , automotive service stations , printing/graphic

arts operations

, and various other coat ing operations

.

To limit confusion with the overlap of multiple rules containing solvent requirements, the District is

propo sing to consolidate the surface preparation and clean

- up requirements into Ru le 3.14. The District

will remove the requirements for surface preparation and clean

- up from District Rule 3.19 and 3.20, including applicable VOC limits, equipment requirements, and wo rk practice requirements. The current requirements will be in effect in District Rule 3.14 until the more string ent requirements take effect in

December 2011

. Furthermore, the District is proposing to modify District Rule 1.1 to contain the definitions for VOC, ROG, and exempt compounds. This will negate the need to list the definitions in each prohibitory rule.

Amendm ents to the se rule s are expected to lower VOC emissions from solvent cleaning o perations in the District by 28 tons per year.Proposed Rule: 3.14 6/6/2011

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- 

### 2.0 Background :

Ozone Reducing VOC emissions is p art of the District’s strategy for reducing ozone formation. Ozone is not directly emitted from polluting sources and is classified as a secondary pollutant. It forms in the atmosphere through complex chemical reactions between VOCs and nitrogen oxides with the presence of a catalyst

, such as sunlight. Ozone is a highly reactive gas that can be harmful to public health when it is in high concentrations at ground level. High concentrations can irritate the nose and throat and can aggravate respiratory conditions such as asthma, bronchiti s, and emphysema.

Regulations

The EPA and the California Air Resources Board (ARB) have adopted ambient air quality standards to determine outdoor pollutant levels considered safe for the public. The standards are health

- based and designed to provide prot ection for the most sensitive groups.

The Federal Clean Air Act ( F CAA) requires air districts in nonattainment for the ozone standards to prepare a plan describing how the National Ambient Air Quality Standard will be met. The District

commit ted as part of the 8

- Hour Ozone Attainment Plan to reduce VOC from surface preparation and

clean

- up operations in order to assist in achieving attainment and to demonstrate actual VOC emission

reductions. On the state level, t he California Clean Air Act (CCAA) require s the District to develop a plan

to achieve attainment with the state ozone standard.

VOC Emission Reductions The District is propo sing to amend the existing rule by lowering the VOC limits for surface preparation

and clean

- up solvent s , which the Distric t expects to be met by increasing the use of aqueous cleaning technologies and exempt compounds. For most cleaning activities, low VOC and aqueous solvents have been successfully used as a substitute for organic based cleaners in many industrial and commer cial applications. There are numerous products readily avail able since other air Districts throughout the State have been requiring low VOC cleaners for several years.



### 3.0 Legal Mandate :

Federal Mandates In 2004, EPA designated the Sacramento region as one of the nation’s four worst 8

- hour ozone nonattainment areas. This region, called the Sacramento Federal Nonattainment Area (SFNA), includes all of Sacramento and Yolo counties and portions of Placer, El Dorado, Solano, and Sutter counties.

Federal law and regulations set specific planning requirements for adopting and implementing a plan to meet reasonable further progress goals and demonstrate attainment of the 1997 federal ozone standard as expeditiously as practicable, but no later than our attainme nt deadline. This State Implementation Plan (SIP) contains a list of control measures which will help the area meet FCAA planning requirements for

the 1997 health based standards for 8

- hour ozone. A modification to Rule 3.14 was included on the list as

a f easible control measure.

Furthermore, t he FCAA requires areas designated as non

- attainment and classified moderate and above to implement Reasonable Available Control Technology (RACT) for “major sources ” of VOCs and NOx subject to Control Techn ology Guidelines (CTG) issued by the EPA

. RACT is defined as “ the lowest emission limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility.” District Rule 3.14 is

based on EPA ’s CTG for Industrial Cleaning Solvents , which was issued in September 2006

. GrantedProposed Rule: 3.14 6/6/2011

- 3

- there are currently no “ major sources ” of VOCs or NOx within the SFNA portion of the District , adopting

the rule now will make it easier to enforce federal law if a new major source is constructed

.

State Mandates

The CCAA requires areas designated as nonattainment for ozone to develop a plan, in accordance with

s ection 40913 of Cal ifornia Health and Safety Code , to achieve California’s ambient air quality standard by the earliest practical date by adopting cost

- effective control measures.

The SFNA portion of Sutter County is designated as “severe” nonattainment for the st ate ozone standard. CH&S Code, s ection 40920 requires the District to adopt a control measure that will use Best Available Retrofit Control Technology (BARCT) for all exi sting stationary sources in this area. BARCT

, as defined

in the CH&S , is as “an emission limitation that is based on the maximum degree of reduction ach ievable, taking into account environmental, energy and economical impacts by ea ch class or category of source.

Yuba County and the northern area of Sutter County are designated as “non attainment

- transitional” for

the state ozone standard. CH& S Code, section 40925.5 requires the District to adopt a control measure

that will use RACT for all ex isting stationary sources in these areas.

All Feasible Measures Requirements California Health and Safety Code

, s ection 40914 requires the District’s plan to demonstrate that the plan includes “every feasible measure" to co ntrol emissions. All feasible control measures are those which have the most effective regulatory emissions standards demonstrated in California’ s air districts.

Other districts have already implemented regulations limiting the VOC content in materials used for surface preparation and clean

- up . A VOC standard of 50 grams per liter for materials, used for general cleaning, has been in effect in th e S outh C oast A ir Q uality M anagement D istrict (SCAQMD) and the Bay Area AQMD (BAAQMD) since 1999. The San Joaquin Valley Air Pollution Control District (SJVAPCD) and Sacramento Metropolitan AQMD (SMAQMD) have also adopted the 50 gram per liter

standard. Th e ARB has noted in their Identification of Performance Standards that this VOC limit represents the most effective strategy for reducing emissions for this source category.

In 2005, t he SCAQMD further reduced the VOC standard to 25 grams per liter for materials used for general cleaning and have adopted stringent limits for other categories. The SJVAPCD, SMAQMD, and

Yolo

- Solano AQMD (YSAQMD) followed shortly thereafter in 2007

- 2008.

The District has evaluated the standards in the rule against similar requirements recently adopted by other

districts. The District has determined that the standards a re feasible and have been achieved in practice.Proposed Rule: 3.14 6/6/2011

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- 

### 4 .0 Proposed Rule Requirements:

The District is proposing to lower the VOC limits for certain source categories and to establish VOC limits on source categories not previously limited . For most cleaning operations, the District will require

sources to use cleaning materials with a 5 0 gram per liter limit f or VOCs , effective 1 2 / 3 1/ 2011

. Compliance with the new requirements can be achieved through the use of aqueous technologies, exempt compounds, or other emission control technologies.

Operators using cleaning m aterials with a VOC content of 5 0 grams per liter or less will be exempt from the requirements of Rule 3.14 . Any source claiming this exemption is still subject to the requirements of

Section E.3 Burden of Proof , which can easily be satisfied by having a Material Data Safety Sheet for the cleaning material on hand

.

The following table summarizes the District’s approach for lowering VOC content limits. The table includes current VOC content limits for solvents used for surface preparation and clean

- up and cites the rules where the requirements are currently found. The table also includes the lower proposed limits and new categories.

Table 1: VOC Content Limits

Category VOC Content Limit (grams/Liter)

Prior to

1 2 / 3 1/2011 Effective

1 2 / 3 1 /201 1

Product Cleaning Coatings and Adhesives 50

Vehicles & Mobile Eqmt.
[Rule 3.19] Surface Prep 200 50
Handheld Spray 780 50

Wood Products [Rule 3.20] 200 50

Metal Parts and Products 50
Polyester Resins 50

Inks 50
Electrical Apparatus Components & Electronic Components 100

Aerospace Components 900
Medical Devices, Pharmaceuticals, and

Pharmaceutical Products 800

Cleaning of Application Equipment Coating s and Adhesives 50

Vehicles & Mobile Eqmt. [Rule 3.19] 50

Wood Products [Rule 3.20] 50

Metal Parts and Products 50
Polyester Resins 50
Printing Operations : Screen Printing

, Lithographic and Letterpress

, Ultraviolet

, Flexographic

, Gravure (Publication ) 100

Aerospace Components 50
Medical Devices, Pharmaceuticals, and

Pharmaceutical Products 80 0

Sterilization of food manufacturing and processing equipment 200

General: Industries Not Specified Above 50

Comparison of Similar Solvent Rules enacted in the State As stated earlier, numerous districts across California have already enacted similar solvent rules. Since there are a few variations in the requirements stated in these rules, a side

- by

- side comparison was performed. These comparisons can be seen below in Table 2.Proposed Rule: 3.14 6/6/2011

- 5

- Table 2 : Comparison of District Rules

FRAQMD Proposed Rule Other District Limits

South Coast

AQMD Sac Metro

AQMD Yolo

- Solano

AQMD San Joaquin

APCD

Applicability

Exemption Levels

Usage 20 gal/yr NA NA 10 gal/yr 55 gal/yr

VOC Content 50 g/L 25 g/L 25 g/L 25 g/L 25 g/L
Requirements Product Cleaning
Coatings, Wood Products,
Metal Parts, Resins, Inks 50 g/L 25 g/L 25 g/L 25 g/L 25 g/L

Adhesives 50 g/L 25 g/L <70 g/L 25 g/L 25 g/L
Vehicles & Mobile Equipment 50 g/L 25 g/L 72 g/L 25 g/L 25 g/L
Electrical Apparatus Components & Electronic Components 100 g/L 100 g/L 100 g/L 100 g/L 100 g/L

Aerospace Components 900 g/L 200 g/L or VOC composite

vapor pressure

< 45 mm Hg 200 g/L or VOC

composite

vapor pressure

< 45 mm Hg NA 200 g/L or VOC composite

vapor pressure

< 45 mm Hg
Medical Devices, Pharmaceuticals, and

Pharmaceutical Products 800 g/L 800 g/L 800 g/L 800 g/L 800 g/L

Requirements Cleaning of Application Equipment
Coatings, Wood Products, Metal Parts, Resins 50 g/L 25 g/L 25 g/L 25 g/L 25 g/L

Adhesives 50 g/L 25 g/L <70 g/L or gun cleaner 25 g/L 25 g/L

Vehicles & Mobile Equipment 50 g/L 25 g/L 72 g/L 25 g/L 25 g/L
Flexographic Printing 100 g/L 25 g/L 25 g/L 100 g/L 100 g/L Screen Printing, Gravure (Publication) 100 g/L 100 g/L 100 g/L 100 g/L 100 g/L

Lithographic and Letterpress & Ultraviolet Printing 100 g/L 100 g/L 100 g/L 238 g/L 100 g/L

Aerospace Components 50 g/L 25 g/L 25 g/L 25 g/L 25 g/L
Medical Devices, Pharmaceuticals, and

Pharmaceutical Products 80 0 g/L NA NA 810 g/L NA

Requirements

Other

Sterilization of food manufacturing and processing

equipment 200 g/L 200 g/L 200 g/L NA NA

Monitoring and Records

Amount of time in which records are required to be kept 3 years 3 years 5 years 2 years 5 years

Cleaning Solutions Common solvents currently used for surface preparation and clean

- up include acetone, d

- limonene

, and paint thinner/mineral spirits. Ac etone and d

- limonene are compliant solvents which do not need a permit

, so many cleaning operations in the District already incorporate these materials

. Whereas p aintProposed Rule: 3.14 6/6/2011

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- thinner/mineral spirits are the organic based , high VOC solvents which are planned to be phased out for high usage facilities.

One alternative to using organic based solvents is to start using aqueous solutions. Aqueous solutions are available in a wide ph range from acidic to alkaline. Acidic solutions are typic ally used for scale or salts,

but are not as effective for greases and oils. Neutral and alkaline sol utions can contain surfactants and rust inhibitors to improve effectiveness and prevent rusting or corrosion. Mildly alkaline solutions are suitable for oil and greases. The SCAQMD has certified over a hundred cleaners as “Clean Air Solvents” meeting speci fic criteria including the 25 grams per liter VOC content. In addition, SCAQMD maintains a list of companies who supply aqueous cleaners systems.

Aqueous Degreasing Systems Aqueous degreasing systems are generally equipped with a heating element to increa se the effectiveness of the cleaner. There is more flexibility with cleaning options for aqueous systems because the solutions

used are not as flammable as traditional organic solvents.

The five common types of cleaning systems that can be used with aqueo us solution s are as follows :

1. Sink

- on

- a

- drum : The sink

- on

- a

- drum parts washer consists of a sink mounted on a drum/barrel. The unit is equipped with a hose, brush applicator and is a manually operated. They can contain

filters or skimmers which extend the life of the cleaner. This unit is the most co mmonly used and most comparable to the traditional remote reservoir cleaners.

2. Enzyme System: Enzyme systems are similar to sink

- on

- a

- drum units. They use specially formulated enzyme cleaners. Microbes are added to the system through an impregnated filter or are added directly to the cleaner. The cleaner emulsifies the grease and the microbes brea kdown and biodegrade the oils.

3. Immersion Parts Washer : The immersion unit is similar to the sink

- on

- a

- drum, unit except it has a false sink, allowing access to a reservoir for cleaning or soaking when removed.

4. Spray Cabinet: The spray unit operates by spraying or flushing high pressure cleaners in an

enclosed unit. These units are automated.

5. Ultrasonic Cleaner: The ultrasonic units use cavitation energy from soni c waves to clean parts. These units are effective for cleaning equipment or parts with small crevices or complex geometries, such as transmissions and carburetors. These units are automated.

Additional Rule Amendments To limit confusion with the overlap o f multiple rules containing solvent requirements, the District is proposing to consolidate the solvent surface preparation and clean

- up requirements into Rule 3.14 Surface Preparation and Clean

- up. The District will remove the requirements for surface prep aration and clean

- up from District Rule 3.19 and 3.20, including applicable VOC limits, equipment requirements, and work practice requirements. The current requirements will be in effect in District Rule 3.14 until the more stringent requirements take effe ct in December 2011. Furthermore, the District is proposing to modify District Rule 1.1 to contain the definitions for VOC, ROG, and exempt compounds. This will negate the need to list the definitions in each prohibitory rule.

District Rule 3.20 will also be cleaned up to remove deadlines and various other time

- related requirements that have passed. These changes will make the rule more clear and concise. The District believes that no further changes need to be made to the rule at this time.

The District is aware of the Suggested Control Measure (SCM) proposed by CARB for Automotive Coatings. This SCM proposes to reduce the VOC limits of various automotive coatings listed in DistrictProposed Rule: 3.14 6/6/2011

- 7

- Rule 3.19. However, the District will not implement the SCM at this time . The District is planning to review the SCM requirements within the next few years and determine if it will be a cost

- effective

measure for Yuba and Sutter Counties. However, District Ru le 3.19 will be cleaned up to remove

deadlines and various other time

- related requirements that have passed. These changes will make the rule

more clear and concise.



### 5.0 Socioeconomic Impact :

Yuba and Sutter C ounties have a combined population of less than 500,000 persons. The Required Assessment in subsection (d) of the Ca lifornia Health and Safety Code (Section 40728.5) states

, “T his section does not apply to any district with a population of less than 500,000 persons .” A s ocioeconomic impact an alysis is not required.



### 6.0 Emission Impacts of the Pro posed Rule :

The ARB maintains an emission inventory of pollutants emitted from different source categories. The source categories are assigned Emission Inventory C odes (EIC) describing the general emission group, the specific operation, and material. The District reviewed the categories applying to solvent cleaning and solvent degreasing. According to the 2005 emissions inventory for the SFNA portion of FRAQMD

, solvent cleaning and degreasing for al l categories account for approximately 3 tons of VOC per year. District staff estimates proposed rule amendments will result in a reduction of 1 .5 tons of VOC per year,

or 0.004 tons/day. FRAQMD has made a SIP commitment of reducing VOC emissions by 0.0006 tons/day in the SFNA. It is expected that FRAQMD will exceed its commitment through the implementation of this rule.

The rule will have a larger effect on the remaining northern portion of FRAQMD where the majority of the stationary sources are located. Staff es timates that there may be over 4 00 solvent cleaning machines in use at repair shops and manufacturing facilities in FRAQMD. Further more , the number of sources performing solvent cleaning that will be subject to Rule 3.14 is estimated to be in the r an ge of 75 to 15 0. After comparing the current VOC limits with the propos ed VOC limits for each category , the District

determined that there will be approximately a 28 ton per year VOC reduction.Proposed Rule: 3.14 6/6/2011

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- 

### 7.0 Estimated Cost Impact:

CH& SC Section 40703 requires the District, in the process of the adoption of any rule or regulation, to consider and make public its findings related to the cost effectiveness of the rule. Cost effectiveness for rulemaking purposes is calculated by dividing t he cost of air pollution controls required by the rule by the amount of air pollution reduced.

Aqueous Cleaning Systems The conversion from solvent cleaning degreasers to aqueous cleaning systems has been completed in the BAAQMD, SJVAPCD, SCAQMD, SMAQMD

, and YSAQMD . Costs for the conversion to aqueous systems are based on the staff reports for these rule efforts, a study completed by the Institute for Research and Technical Assistance’s Pollution Prevention Center (IRTA) for the EPA and Santa Barbara

Coun ty Air Pollution Control District, and cost information provided by equipment suppliers.

The costs associated with converting equipment include the equipment costs, costs of products used, and operating costs. Traditional solvent units are generally lease d from waste management companies who service the equipment. Equipment, chemicals, and disposal costs are all included in the service charge. Costs for aqueous cleaning include specifically, the cost of the aqueous system, solution costs, disposal

costs fo r spent solutions and/or filters, filter costs, electricity costs and labor costs. Initial equipment costs for aqueous units vary depending on the type of machine, size of the unit, and features. The following table demonstrates the range for the different aqueous systems.

Table 2: Average Cost of Equipment

Aqueous Equipment System Cost of Equipment

Sink

- on

- a

- drum $328

- $3,000

Immersion unit $800

- $4,200
Enzyme system $1,000

- $2,400
Spray cabinet $1,600

- $6,400

Ultrasonic unit $2,700

- $12,000

The study performed by IRTA included a cost comparison for different case studies related to converting to aqueous cleaning systems. The report concluded a cost savings for facilities operating aqueous cleaning systems. The lower costs were attributed to t he longer life of the aqueous solutions and to the labor savings . The longer life of aqueous solutions meant both the amount of cleaning solution used decreased and there was less spent solution to dispose of. Labor savings were reported from the conversio ns to enzyme systems and automated units. Similarly, the SCAQMD reported an overall cost savings for the conversion to aqueous systems based on materia l savings and disposal savings.

The SJVAPCD analyzed the conversion to aqueous systems evaluatin g differ ent scenarios including:

F acilities with a single solvent degreaser switching to a single aqueous sink on a drum,

F acilities with a single degreaser switching to an enzyme

- cleaning unit,

F acilities with a single degreaser switching to a batch loaded aque ous unit larger in size, and

F acilities with two solvent degreasers switching to one batch loaded aqueous cleaning unit.

The SJVAPCD further broke down each scenario taking into account the usage of the unit. The analysis was made based on the following assumptions:

T he annual compliance cost includes annual operation and maintenance costs as well as annualized capit a l costs,

C oncentrated aqueous solutions are diluted with water and the cost of water is insignificant,

H andling of aqueous baths is inclu ded in the calculations,Proposed Rule: 3.14 6/6/2011

- 9

- A queous solutions are more effective when heated and any costs are included in the annual compliance cost,

L abor costs vary by equipment,

A queous baths last longer and require less change out than traditional solvents, and

S eventy percent of solvent is recycled and the remaining thirty percent are emissions.

The costs and cost effectiveness are reported as follows :

Table 3: Cost and Cost Effectiveness

Usage Annual Cost Cost

- Effectiveness ($/ton of VOC reduced)

Converting one solvent degreaser to an aqueous unit: Low usage $546 $12,937
Average Usage $903 $8,560 High Usage $1393 $6,603

Converting one solvent degreaser to an enzyme unit: Low usage $368 $8,132 Average Usage $430 $3,805 High Usage $468 $2,068

Converting one solvent degreaser to an automated aqueous unit: Low usage $128 $9,436 Average Usage $238 $2,316 High Usage $788 $3,832

Converting two solvent degreasers to automated aqueous units: Low usage

- $112

- $2,557 Average Usage

- $362

- $3,308 High Usage

- $412

- $1,883

The cost effectiveness analysis performed by the SJVAPCD is based on requiring cleaning solutions to comply with a VOC content limit of 50 grams per liter.

General Cleaning / Other Cleaning Operations The costs associated with lowering the VOC content of cleaning solutions varies depending on the category and specific cleaning process. Most cleaning operations use some type of wipe cleaning for surface preparation and clean

- up . The re are no equipment co sts for switching to aqueous cleaners for this category. Costs accrued are based on the cost of the replacement cleaners. Replacement cleaners include aqueous solutions, exempt compounds, or blends. The costs of aqueous solutions are generally higher

than traditional solvents. H owever
, they are sold in concentrated form and when diluted, the cost of the aqueous solution can be less than the cost for traditional solvents . Dilution ratios vary depending on the product, and typically range from 1

- 40% solution in water.

The SCAQMD reported costs of traditional solvents to range from $4 to $20 per gallon and replacement solvents from $2 to $40 per gallon. The BAAQMD reported the average cost for conventional solvents to be $12.25 per gallon and $5.97 per gallon for replacement solutions with a median price between $2.31 and $2.40 per gallon after dilution.Proposed Rule: 3.14 6/6/2011

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- 

### 8 .0 Environmental Review and Compliance:

The amendments to rule 3.14 are categorically exempt from the California Environmental Quality Act (CEQA) under Sections 15307 and 15308 of the State CEQA Guidelines and no exceptions to these exemptions apply. This exemption is allowed when the rule will help improve air quality in Yub a and Sutter County . California Public Resources Code (Section 21159) requires an environmental analysis of the reasonably foreseeable methods of compliance. The District has concluded that no reasonably foreseeable adverse environmental impacts will be ca used by adoption of the proposed rule.



### 9 .0 Required Findings:

The California Health and Safety Code, Division 26, Air Resources, requires local Districts to comply with a rule adoption protocol as set forth in Section 40727 of the Code. This section h as been revised through legislative mandate to contain 6 findings that the District must make when developing, amending, or repealing a rule. These findings and their definitions are listed in the following table.

Table 4 : Required Findings

FINDING DEFINITION REFERENCE Authority A district shall adopt rules and regulations

and do such acts as may be necessary or proper to execute the powers and duties granted to, and imposed upon, the district by this division and other statutory provisions Californ ia Health and Safety Code, Sections 40000, 40001, and 40702 are provisions of law that provide air districts with the authority to adopt these proposed rules.

Necessity The District has demonstrated that a need

for the rule, or for rule amendment or repeal. It is necessary for districts to adopt these amendments to comply with state law and to ensure consistency with neighboring air

districts. Clarity The rule is written or displayed so that its

meaning can easily be understood by the

persons directly affected by it There is no indication, at this time, that the proposed rules are writt en in such a manner

that it can not be easily understood by persons affected by the rule. Consistency This rule is in harmony with, and not in

conflict with or c ontradictory to, existing statutes, court decisions, or State or federal regulations. These rules are consistent with applicable statutory requirements.

Non

Duplication The rule does not impose the same

requirements as an existing State or federal regulat ion, unless the District finds that the requirements are necessary and proper to execute the powers and duties granted to, and imposed upon, the district The proposed rule does not impose requirements that duplicate existing laws or regulations.

Reference Any statute, court decision, or other

provision of law that the district implements, interprets, or makes specific by adopting, amending, or repealing a regulation. The proposed rule has been developed to meet the requirements of the 2003 State Implementa tion Plan.Proposed Rule: 3.14 6/6/2011

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- 

### 10 .0 References:

1) EPA 453/R

- 06

- 001 “Control Techniques Guidelines: Industrial Cleaning Solvents,” September

2006 2) Sac

- Metro Air Quality Management District, “Final Draft Staff Report for Rule 466

– Solvent Cleaning,” August 19, 2010. 3) Sacramento Regional 8

- Hour Ozone Attainmen t and Reasonable Further Progress Plan (September 2008). 4) San Joaquin Valley Unified Air Pollution Control District, “Final Draft Staff Report for Rules
4603, 4604, 4605, 4606, 4607, 4612, 4653, 4661, 4662, 4663, and 4684,” August 2007. 5) Santa Barbara Air Pollution Control District, “Rule 321 , Solvent Cleaning Machines and Solvent Cleaning ,” September 20, 2010

. 6) South Coast Air Quality Management District, “Clean Air Solvent (CAS) Certification Program.” http://www.aqmd.gov/rules/cas/index.html

. 7) South Coast Air Quality Management District, “Rule 1122, Solvent Degreasers,” October 1, 2004. 8) South Coast Air Quality Management District, “Rule 1171, Solvent Cleaning Op erations,” July 7,

2006. 9) South Coast Air Quality Management District, “Staff Report for Proposed Amended Rule 1122

- Solvent Degreasers,” September 21, 2004. 10) South Coast Air Quality Management District, “Staff Report for Proposed Amended Rule 1171

- Solvent Cleaning Operations,” June 2006. 11) South Coast Air Quality Management District, “Rule 1131

- Food Product Manufacturing and Processing Operations,” June 6, 2003. 12) Yolo

- Solano Air Quality Management District, “Final D raft Staff Report for Rules 1.1, 2.25, 2.26, 2.29, 2.30, 2.31, 2.33, 2.35, 2.39, 2.24,” May 200 8

.

# A PPENDIX A

Rule Analysis

# A PPENDIX B

Public Notice

# A PPENDIX C

Comments and Responses