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

to the Solvent Cleaning Portion of Eleven D istrict Rules SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

FINAL STAFF REPORT

Amendments to the organic solvent cleaning sections of the following rules:

Proposed Rule 4603 (Surface Coating of Metal Parts and Products)

Proposed Rule 4604 (Can and Coil Co ating Operations)

Proposed Rule 4605 (Aerospace Assembly and Component Coating

Operations)

Proposed Rule 4606 (Wood Products Coating Operations)

Proposed Rule 4607 (Graphic Arts)

Revised Proposed Rule 4612 (Motor Vehicle and Mobile Equipment Coating

Operat ions

– Phase II)

Proposed Rule 4653 (Adhesives)

Proposed Rule 4661 (Organic Solvents)

Proposed Rule 4662 (Organic Solvent Degreasing Operations)

Proposed Rule 4663 (Organic Solvent Cleaning, Storage, and Disposal)

Proposed Rule 4684 (Polyester Resin Operat ions)

September 20, 2007

Prepared by: Sandra Lowe Leseth, Air Quality Engineer

Laura Weber, Air Quality Specialist

Reviewed by: George Heinen, Supervising Air Quality Engineer

Joven Nazareno, Senior Air Quality Engineer Juscelino Siongco, Air Quality En gineer, Permit Services Jeff Voorhees, Air Quality Specialist, Compliance

I. SUMMARY

A. Reasons for Rule Development and Implementation

In the San Joaquin Valley Air Basin (SJVAB), monitored levels of ozone exceed National Ambient Air Quality Standards (NAAQS), which are set at levels that protect public health and welfare. Consequently, the U.S. Environmental Protection Agency (EPA) has classified the SJVAB’s air quality as serious for its nonattainment designation for the federal eight

- hour ozone NAA QS. Under the now revoked federal

one

- hour ozone standard, the SJVAB was classified as extreme nonattainment.

The federal Clean Air Act (CAA) requires air districts in nonattainment areas to prepare plans that are designed to achieve and maintain the NAA QS by the earliest practicableSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Organic Solvent Cleaning September 20, 2007

2 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules date, and no later than attainment deadlines given in the CAA. The San Joaquin Valley Unified Air Pollution Control District (District) adopted the Extreme Ozone Attainment

Demonstration Plan ( EOADP ) on October 8, 2004. The EOADP calls for a reduction in volatile organic compound (VOC) emissions by 2010 by implementing the solvent cleaning control measure to further reduce VOC emissions by introducing more stringent limits.

Although EPA has revoked the federal one

- hour ozon e NAAQS, the VOC emission reduction commitment for the solvent cleaning control measure must still be met. EPA’s final Phase 1 rule implementing the eight

- hour ozone NAAQS (Federal Register Volume 69 page 23858 (69 FR 23858) and 70 FR 30592) identifies a number of federal CAA requirements that applied to an area by virtue of its one

- hour ozone nonattainment classification and that continue to apply after revocation of the one

- hour ozone NAAQS [Code of Federal Regulations Title 40 Section 51.900(f) (40 CFR 51.900(f))]. Because the SJVAB was classified as extreme nonattainment, and because an attainment demonstration (as defined by 40 CFR 51.905) is one of the requirements, the EOADP becomes one of the requirements that still apply to the SJVAB by virtue of its former

classification under the now

- revoked one

- hour ozone NAAQS. The EOADP uses the VOC emissions reductions from this solvent cleaning control measure to project attainment. Without the reductions from this control measure, the EOADP does not proje ct attainment and therefore does not meet the requirements of 40 CFR 51.905. Thus the District must proceed with this rule amendment project’s emission reductions even though the one

- hour ozone standard has been revoked.

B. Description of the Project

Th e purpose of this rule project is to revise the solvent

- cleaning requirements of the rules listed in Table 1 to obtain as much VOC emission reductions as is expeditiously practicable, technologically feasible, and economically reasonable, as determined by the District’s Governing Board.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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3 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules Table 1

– Rules Included in this Rulemaking Project

Rule # Rule Title

4603 Surface Coating of Metal Parts and Products

4604 Can and Coil Coating Operations

4605 Aerospace Assembly and Component Coating Operations

4606 Wood Products Coating Operations

4607 Graphic Arts

4612 Motor Vehicle and Mobile Equipment Coating Operations

– Phase II

4653 Adhesives

4661 Organic Solvents

4662 Organic Solvent Degreasing Operations

4663 Organic Solvent Cleaning, Storage, and Disp osal

4684 Polyester Resin Operations

II. BACKGROUND

The organic solvent cleaning portions of the rules incorporate three different types of emission control standards: performance standards, equipment standards, and work practice standards.

1. Perfo rmance Standards

The federal Clean Air Act’s definition of “performance standards” refers to an allowable emission limit, meaning a limit on quantity of pollutant emitted over a specified period of time or a percent reduction. In all of the rules listed in Table 1, the allowable VOC content of the solvent used for solvent cleaning is specified.

2. Equipment Standards

Equipment standards specify the design, use, and operation of a particular piece of equipment. This standard is used in several rules fo r detailing which types of coating application equipment are allowed.

3. Work Practice Standards

Work practices refer to the management plans and procedures that would be undertaken to reduce emissions. Requiring that containers be covered except when adding or removing material from the container is one example of a work practice standard. Each rule in this rule project identifies at least one work practice standard to

limit VOC emissions.

For detailed requirements, please refer to the current rules, which are available on the District’s website at www.valleyair.org.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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4 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules III. PROPOSED CHANGES TO RULES

The California Health and Safety Code (CH&SC) Section 40914(b)(2) states that ozone attainment plans should include All Feasible Control Measures (AFCMs) . The ARB interprets “every feasible control measure to mean that, at a minimum, air districts must consider regulations that have been successfully implemented elsewhere. They should also consider going beyond what has already been accomplished by evalu ation of new technologies and innovative approaches that may offer potential emission reductions. Further, districts should consider not only technological factors, but also social, environmental, economic (e.g., cost effectiveness), and energy factors wh ich prevail in a district, along with the resources realistically available to a district to adopt, implement, and enforce the measures.”

In the context of rule development, District staff construes AFCM to mean that each rulemaking project seeks to obt ain as much emission reduction from the rule’s source category as is expeditiously practicable, technologically feasible and economically reasonable, as determined by the District’s Governing Board. To this end, District staff compared the current emissio n limits or control technology against what limits or control technology has been promulgated in other districts, as well as reviewing the federal, state, and local Best Available Control Technology (BACT) clearinghouses for the most

recent control technol ogy available for the source category.

This section of the staff report has two parts. The first part will discuss the proposed amendments that would be incorporated into all of the rules. The second part of this section will detail the proposed amen dments that are unique to each rule.

A. Proposed Amendments that Affect All Rules

No changes are planned for either Section 1.0 (Purpose) or Section 2.0 (Applicability). This rule project would not affect which specific source categories are subject to the individual rules, therefore, no change is proposed for these two sections. In Section 3.0 (Definitions), seven definitions would be added for clarity. These definitions would be: APCO, ARB, ASTM, CFR, EPA, normal business hours, and SCAQMD. The ter m “composite vapor pressure” would be removed from all rules except Rule 4605 (Aerospace Assembly and Component Coating Operations). In all rules except Rule 4605, the composite vapor pressure has been removed as a condition of use. In

addition to the ne w definitions there have been two modifications to definitions. First, the definition of maintenance cleaning has been standardized to clarify that maintenance cleaning does not include the cleaning of application equipment. Second,

the definition of thi nner has been revised for clarity at the suggestion of ARB staff. Section 3.0 in each of the rules would be renumbered as needed. In Section 4.0, no change is the same for all rules. The proposed amendments for Section 4.0 are

discussed below under the individual rule review.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Organic Solvent Cleaning September 20, 2007

5 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules Section 5.0 (Requirements) outlines the provisions of the rule. For all rules, District staff is proposing to standardize certain terms. The terms “person,” “owner or operator,” and “operator” would be standardized throughout the rules to read “operator.” For emission control devices, “add

- on device,” “pollution control equipment,” and other similar terms would be standardized to “VOC emission control system.” For rules associated with coating or printing, t he coating/ink VOC co ntent limits would not be changed as part of this rule development project. However, the VOC content limits table would be simplified to include only those coatings/inks currently specified and the associated VOC content limits and remove any date associa ted with the tables, since the dates have already passed.

The VOC content limits for cleaning solvents proposed for this rule project are based on

South Coast Air Quality Management District (SCAQMD) Rule 1171 (Solvent Cleaning Operations), last amended i n July 2006. In October 1999, SCAQMD Rule 1171

established a two

- tier approach to lowering the VOC content limits for all solvent cleaning activities. Tier I was implemented in December 2001. The Tier II VOC limits had an original implementation date of July 1, 2005, but was subject to completion of technology assessments to determine feasibility of VOC content limits. For all categories except the cleaning of ink application equipment used for specific printing operations, the technology assessment was completed in August 2003. The technology assessment concluded that the Tier II VOC content limits were feasible for these source categories. For cleaning of ink application equipment used for lithography/letterpress, screen printing, and UV/EB inks, an interim VOC content limit of 500 grams per liter was established for the cleaning of lithography/letterpress and screen printing application equipment. A slightly higher interim limit was established for cleaning UV/EB ink application equipment

– 650 g/L. The technology assessment for the remaining source categories was completed in August 2006. SCAQMD staff recommended that the implementation date for the Tier II limits for the remaining source categories be extended by 18 months

– until January 1, 2008 . Based on SCAQMD’s technology assessment, District staff is proposing similar VOC content

limits for solvents used for solvent cleaning with a similar timeline.

The SCAQMD staff and printing industry representatives are in the middle of a technology a ssessment to determine if the 100

- g/L limits for cleaning of ink application equipment used for lithography/letterpress, screen printing, and ultraviolet/electron beam inks (UV/EB) is technically feasible by 2008. District staff is proposing that the

comp liance for these source categories be January 1, 2010, allowing the SCAQMD and printing industry to complete their assessment and determine the feasibility of a 100 g/L VOC content limit. If SCAQMD staff determines that the limit is not technologically

fe asible, District staff would have enough time to re

- open Rule 4607 (Graphic Arts) before the compliance deadline in order to include more appropriate VOC content limits for these specific source categories.

Although Table 2 shows many cleaning categories, each rule contains only the part of Table 2 that is most appropriate for the sources subject to the given rule. OperatorsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Organic Solvent Cleaning September 20, 2007

6 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules would have 12 months to come into compliance with the new VOC content limit. Based on the current rule project schedule, the compli ance date would be September 2008 for all of the rules except Rule 4612 (Motor Vehicle and Mobile Equipment Coating Operations

– Phase II). Since Rule 4612 does not become effective until January 1, 2009, District staff is proposing that the solvent clean ing VOC content limits become

effective on the same date. The solvent

- cleaning portions of Rule 4602, the Phase I version of Rule 4612, will remain in place until Rule 4612 becomes effective.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Organic Solvent Cleaning September 20, 2007

7 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules 

### Table 2

– VOC Content Limits for Solvents Used in Solvent Cleani ng
Solvent Category Effective through September 20, 2008 Effective on September 21, 2008

VOC Limit in g/L (lb/gal) Proposed VOC Limit in g/L (lb/gal)

A. Product Cleaning During Manufacturing Process or Surface Preparation for Coating, Adhesi ve, or Ink Application

1. General 50 (0.42) 25 (0.21)

2. Electrical Apparatus Components and Electronic Components 500 (4.2) 100 (0.83)

3. Medical Devices & Pharmaceuticals 800 (6.7) 800 (6.7)

B. Repair and Maintenance Cleaning

1. General 50 (0.42) 25 (0.21)

2 Electrical Apparatus Components and Electronic Components 900 (7.5) 100 (0.83)

3 Medical Devices & Pharmaceuticals

3.1 Tools, Equipment, & Machinery 800 (6.7) 800 (6.7)

3.2 General Work Surfaces 600 (5.0) 600 (5.0)

C. Cleaning of Coati ngs/Adhesives/Polyester Resin Application Equipment

1. Coatings or Adhesives 550 (4.6) 25 (0.21)

2. Polyester Resin 50 (0.42) 25 (0.21)

3. Sheet coater for three

- piece can 550 (4.6) Effective 9/21/2008

- 550 (4.6)

Effective 10/1/2011

- 250 (2.3)

D. Cle aning of Ink Application Equipment

1. General 50 (0.42) 25 (0.21)

2. Flexographic Printing 50 (0.42) 25 (0.21)

3. Specialty Flexographic Printing 600 (5.0) 100 (0.83)

4. Gravure Printing

4.1 Publication 450 (3.8) 100 (0.83)

4.2 Packaging 50 (0.42) 25 (0.21)

5. Lithographic or Letterpress Printing

5.1 Roller Wash Step 1 600 (5.0) Effective 9/21/2008

– 500 (4.2)

Effective 1/1/2010

- 100 (0.83)

5.2 Roller Wash

– Step 2; Roller

Wash

– not specified, Blanket Wash, and On

- Press Components 800 (6.7) Effective 9/21/2008

– 500 (4.2)

Effective 1/1/2010

- 100 (0.83)

5.3 Removable Press Components 50 (0.42) 25 (0.21)

6. Screen Printing 750 (6.3) Effective 9/21/2008

– 500 (4.2)

Effective 1/1/2010

- 100 (0.83)

7. Ultraviolet Ink/Electron Beam Ink Applica tion Equipment (except screen printing) 800 (6.7) Effective 9/21/2008

- 650 (5.4)

Effective 1/1/2010

- 100 (0.83)

Continued on next pageSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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8 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules Solvent Category Effective through September 20, 2008 Effective on September 21, 2008

VOC Limit in g/L (lb/gal) Proposed VOC Limit in g/L (lb/gal)

E. Aerospace Assembly and Component Coating Operations

1. Surface Cleaning, Clean

- up, or Jet Engine or Rocket Engine Gas Path Cleaning or Flushing 200 g/L or < 45 mm Hg composite vapor pressure 200 g/L or < 45 mm Hg composite vapor pressure

2. Coating Strippers 300 g/L or < 9.5 mm Hg composite vapor pressure 300 g/L or < 9.5 mm Hg composite vapor pressure

Some cleaning operations allow the use of cleaning solvents with VOC content greater than 50 grams per liter (g/L) for certain cleaning operations. Operators with these cleaning operations have several work practice standards and equipment standards to

which they must adhere in addition to meeting the VOC content limits for the cleaning solvent. District staff is proposing that the VOC content limit for triggering the work practice/equipment standards be reduced to 25 g/L. Operators would have 12 months

to c ome into compliance with the work practice/equipment standards using new VOC content limit. In lieu of complying with the solvent cleaning VOC content limits or work practice/equipment standards, operators may use an APCO

- approved VOC emission control sys tem that meets the specified control efficiency, provided that the emissions do not exceed the level that would have resulted from complying with the solvent cleaning methods and VOC content limits. The work practices requirement has been

reworded to clar ify the intent that the operator must both meet the limits of the solvent cleaning content and use work practices if the cleaning operation has an allowable VOC content limit greater than the current 50 g/L or the proposed 25 g/L.

If there were any rule s ections that are no longer in effect, the sections would be removed. Sections outlining current requirements that contain dates in the past would have the dates removed to streamline the rule language.

In Section 6.0 (Recordkeeping), the records retentio n requirement would be clarified. It is proposed that records be retained on site for a period of five years, made available on site during normal business hours, and records submitted upon request. Although this was the intention of the provisions, it h ad not been stated as clearly in all of the rules. Test methods for determining composite partial pressure of solvents would be removed from all rules except Rule 4605 (Aerospace Assembly and Component Coating Operations) since any reference to composite vapor pressure for solvents has been superceded in all rules except Rule 4605.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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9 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules B. Proposed Amendments Unique to Individual Rules

This part of the final draft staff report highlights the proposed amendments unique to individual rules. The proposed change s mentioned in Section III.A of this final draft staff report would be incorporated in each rule listed in Table 1.

1. Rule 4603 (Surface Coating of Metal Parts and Products)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and S ection 3.0 (Definitions) would be revised as noted in Section III.A of this staff report. For this rule, the definitions of “bench scale” and “research and development” would be added for clarity. Several definitions have been modified for clarity at the suggestion of ARB staff. Section 4.0 (Exemptions) would have two exemptions removed. The first exemption removed has to do with low usage coatings. This exemption expired in 2002 and District staff recommends that the exemption language be taken out of the rule. The second exemption is one concerning BACT and offset requirements. Current Rule 4603 specifically exempts a certain type of equipment/process modification from both BACT and offset requirements. It is EPA policy that no rule except a Distri ct’s New Stationary Source Rule (NSR Rule) can exempt a source from BACT and offset requirements. Therefore, the automatic exemption from BACT and offset requirements would be removed from the rule. The net result of removing the exemption would be

that all equipment/process modifications would be required to meet any BACT or offset requirements specified in District Rule 2201 (New and Modified Source Review Rule) unless the modification meets the conditions for being exempt from BACT or offset requiremen ts. The situations where a modification would be exempt from BACT or offsets are spelled out in District Rule 2201.

The limited exemption for low

- use of non

- compliant coatings would be reworded for clarity to address an EPA concern. The revision repre sents a clarification of current requirements, not a change in the exemption. Three exemptions would be added to Section 4.0. Rule 4612 (Motor Vehicle and Mobile Equipment Coating Operations

– Phase II) will replace Rule 4602 (Motor Vehicle and Mobile Eq uipment Operations) on January 1, 2009. Rule 4603 cites Rule 4602 in the exemption section, so District staff is proposing that the exemption for Rule 4602 end on December 31, 2008 and that the exemption be added for Rule 4612, beginning January 1, 2009. The remaining proposed exemptions to be added to Section 4.0 are not new to the rule. These exemptions exist in the solvent cleaning portion of Section 5.0 (Requirements). They would be moved to Section 4.0 for clarity.

The language in Section 5.0 fo r operator and VOC emission control system would be standardized, as noted in Section III.A of this staff report. In Section 5.3, the VOC emission control system requirements would be spelled out more clearly. There would be no added requirements and no requirements would be removed. Section 5.4 in the current rule no longer applies to operations subject to Rule 4603 as of November 14, 2002 and, therefore, would be removed from the rule. The section titled “OrganicSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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to the Solvent Cleaning Portion of Eleven District Rules Solvent Cleaning, Storage and Disposal Requirements” would be revised to reflect the VOC content limits and effective dates proposed in Table 2 above. The solvent cleaning work practices requirement would be reworded to clarify that the operator must meet VOC content limits and utilize work p ractices for certain cleaning operations. The current exemptions from the solvent

- cleaning solvent VOC content limits would be moved from this section to Section 4.0 (Exemptions).

In Section 6.0 (Administrative Requirements), provisions that were no long er in effect and dates on provisions that are already in effect would be taken out of the rule. Language would be standardized in this rule section and record retention provisions would be clarified, as noted in Section III.A of this staff report. Refere nces to composite partial vapor pressure would be removed throughout Section 6.0, since the standard is being deleted from the rule. The current rule does not specify how often coating s usage records to be kept. The proposed rule would specify daily rec ords are to be kept by the operator.

Several changes would be made to Section 6.3 (Test Methods). The two test methods used for the VOC emission control system would be moved to a new subsection that would outline the calculation of overall capture and c ontrol efficiency. The current rule is not clear on how to perform the calculation. Two current test methods would also be revised. The test method for metallic/iridescent topcoat is incorrect, as noted by EPA Region IX staff in their comments earlier i n the rule development process. SCAQMD Method 318 (Determination of Weight Percent of Elemental Metal in Coatings by X

- Ray Diffraction Method, July 1996) would be replacing the current test method. The test method for acid content of pre

- treatment wash p rimers would be updated to the latest

EPA

- approved version of ASTM D1613

- 96. Section 6.0 would be renumbered, as appropriate.

2. Rule 4604 (Can and Coil Coating Operations)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Sect ion 3.0 (Definitions) would be revised as noted in Section III.A of this staff report. For this rule, the definitions of “bench scale” and “research and development” would be added for clarity. Section 4.0 (Exemptions) would have an exemption removed tha t has to do with low usage coatings. This exemption expired in 2005. The exemption that replaced it would have the compliance date removed, since the date is in the past. The section would be renumbered as appropriate.

The language in Section 5.0 for o perator and VOC emission control system would be standardized, as noted in Section III.A of this staff report. In Section 5.3 (Prohibition of Specification and Sale), the subsections with compliance dates prior to January 2006

would be removed from the ru le. The section titled “Organic Solvent Cleaning, Storage and Disposal Requirements” would be revised to reflect the VOC content limits and effective dates proposed in Table 2 above, with the exception of sheet coating. Work practices would be triggered at 50 g/L until 12 months after rule adoption date, at whichSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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to the Solvent Cleaning Portion of Eleven District Rules time the trigger point of 25 g/L would begin. Facilities that utilize the work practices specified in the rule are currently allowed to use solvent cleaners with a VOC content limit of 550 g/L. For cleaning of coating application equipment that is not three

- piece sheet coaters, the maximum allowable VOC content for cleaning outside the control of a VOC emission control system would go to 25 g/L. For cleaning of three

- piece can sheet coating equ ipment outside a VOC emission control system, the maximum allowable VOC content would remain 550 g/L through September 30, 2011. As of October 1, 2011, the District would allow a maximum VOC content limit of 250 g/L to

clean sheet coaters for three

- piece cans. The SCAQMD in Rule 1177 does not allow for the use of solvent cleaners for the cleaning of sheet coaters for three piece cans if those cleaners have a VOC content of 25 g/L or greater. However, this limit is not achieved in practice since all facil ities within the South Coast basin that are required to comply with this limit utilize a VOC capture and control system. Currently, no effective solvent cleaners exist that will work for cleaning sheet coaters. However, the District is confident that by September 30, 2011 there will be solvent cleaner available for this purpose. In addition to the change in VOC content limit for coating application equipment, the solvent cleaning work practices requirement would be reworded to clarify that the operator m ust meet VOC content limits as well as utilize work practices for certain cleaning operations. Section 5.5 would have the compliance date removed, but no changes to the rule provisions themselves.

In Section 6.0 (Administrative Requirements), provisions that were no longer in effect and dates on provisions that are already in effect would be taken out of the rule. Language would be standardized in this rule section and record retention provisions clarified, as noted in Section III.A of this staff report. References to composite partial vapor pressure would be removed throughout Section 6.0, since the standard is being deleted from the rule. Within the solvent usage records, operators would be required to calculate the VOC content of a batch, if the oper ator mixes the ingredients. The

subsections of Section 6.0 would be renumbered as needed.

3. Rule 4605 (Aerospace Assembly and Component Coating Operations)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 (Definit ions) would be revised as noted in Section III.A of this staff report. Four definitions would be removed since some adhesive categories have been replaced. The removed definitions would be epoxy phenolic primer, m etal to metal/metal to honeycomb core bon ding primer, military primer, and nitrile phenolic primer. Unlike other rules in this rule project, the definition of composite partial vapor pressure, which is not in the current rule, would be added to Section 3.0. This is because the cleaning solvent provisions allow composite vapor pressure as a specification. Section 3.0 would be renumbered as appropriate.

In Section 4.0 (Exemptions), the exemption associated with jet engine or rocket engine gas path cleaning or flushing operations that use trichlo roethylene would be edited to remove an exemption that has expired. Jet engine or rocket engine flushing using anySAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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to the Solvent Cleaning Portion of Eleven District Rules solvent other than trichloroethylene would remain exempt. There is language in Section 4.3 calling for records to prove the exemption. Thi s language has been removed, since there are no usage limits for laboratories.

Current Rule 4605 specifically exempts a certain type of equipment/process modification from both BACT and offset requirements. The automatic exemption from

BACT and offset re quirements would be removed from the rule. The net result of removing the exemption would be that all equipment/process modifications would be required to meet any BACT or offset requirements specified in Rule 2201 (New and Modified Source Review Rule) un less the modification meets the conditions for being exempt from BACT or offset requirements. The situations where a modification would be exempt from BACT or offsets is spelled out in Rule 2201. It is EPA policy that no rule except a District’s New Stat ionary Source Rule (NSR Rule) can exempt a source from BACT and offset requirements.

The language in Section 5.0 for operator and VOC emission control system would be standardized, as noted in Section III.A of this staff report. Section 5.2.2 (Coating Ap plication Equipment Cleaning) would be removed since the provisions of Section 5.2.3, also titled “Coating Application Equipment Cleaning,” replaced it. Section 5.0 would be renumbered as appropriate.

In Section 6.0 (Administrative Requirements), languag e would be standardized and record retention provisions would be clarified, as noted in Section III.A of this staff report. The test method related to composite vapor pressure was updated to SCAQMD 308 (Quantification of Compounds by Gas Chromatography). As of January 2006, ASTM had withdrawn the test method cited in the rule. The test method requirements for a VOC emission control system would be clarified. The subsections of Section 6.0

would be renumbered as needed.

4. Rule 4606 (Wood Products Coati ng Operations)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 (Definitions) would be revised as noted in Section III.A of this staff report. In Section 4.0 (Exemptions), current Rule 4606 specifically exempts a ce rtain type of equipment/process modification from both BACT and offset requirements. The automatic exemption from BACT and offset requirements would be removed from the rule. The net result of removing the exemption would be that all equipment/process

mo difications would be required to meet any BACT or offset requirements specified in Rule 2201 (New and Modified Source Review Rule) unless the modification meets the conditions for being exempt from BACT or offset requirements. The situations where a

modif ication would be exempt from BACT or offsets is spelled out in Rule 2201. It is EPA policy that no rule except a District’s New Stationary Source Rule (NSR Rule) can exempt a source from BACT and offset requirements.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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to the Solvent Cleaning Portion of Eleven District Rules The language in Section 5.0 (Requirem ents) for operator and VOC emission control system would be standardized, as noted in Section III.A of this staff report. In Section 5.3, the VOC emission control system requirements would be spelled out more clearly.

Section 5.5 in the current rule no l onger applied to operations subject to Rule 4606 as of November 14, 2002 and, therefore, would be removed from the rule. The section titled “Organic Solvent Cleaning, Storage and Disposal Requirements” would be revised

to reflect the VOC content limits an d effective dates proposed in Table 2 of this staff report. Also, operators would have the option to use higher VOC content solvent for cleaning equipment if a VOC emission control system is used. The change would allow operators flexibility in solvent c leaning practices with no change in VOC emissions. Section 5.0 would be renumbered, as appropriate. The solvent cleaning work practices requirement would be reworded to clarify that the operator must meet VOC content limits and utilize work practices for certain cleaning operations.

In Section 6.0 (Administrative Requirements), provisions that were no longer in effect and dates on provisions that are already in effect would be taken out of the rule. Language would be standardized in this rule section an d record retention provisions would be clarified, as noted in Section III.A of this staff report. References to composite partial vapor pressure would be removed throughout Section 6.0, since the standard is being deleted from the rule. The required reco rds and specified test methods for VOC emission control systems would be added to clarify the intent. Within the solvent usage records, operators would be required to calculate the VOC content of a batch, if the operator mixes the ingredients. Section 6. 0 would be renumbered as needed.

5. Rule 4607 (Graphic Arts)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 (Definitions) would be revised as noted in Section III.A of this staff report. For this rule,

the defini tions of “bench scale” and “research and development” would be added for clarity. In Section 4.0 (Exemptions), one exemption would be added. The added exemption is not new to the rule. It exists in the solvent cleaning portion of Section 5.0 (Requiremen ts) and would be moved to Section 4.0 for clarity.

The language in Section 5.0 for operator and VOC emission control system would be standardized, as noted in Section III.A of this staff report. In Section 5.6, the types of coating application equipment would be listed for clarity. For this rule development project, District staff is not proposing any new or added coating application equipment types. However, if an operator would like to use coating application equipment not specifically listed in Secti on 5.6, the operator would have the option to use the equipment, if it met a minimum 65% transfer efficiency. The addition of this requirement would allow operators to take advantage of new technology, if the technology is shown to minimize VOC emissions. Section 5.7 (Evaporative Loss Minimization) would be removed because it is no longer in effect.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Organic Solvent Cleaning September 20, 2007

14 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules The cleaning solvent VOC content limits would be handled slightly differently than in other rules. Before the last SCAQMD Rule 1171 amendments, SCAQMD sta ff, in cooperation with printing industry representatives, performed a technical assessment for certain solvent cleaning operations. The assessment found that original SCAQMD limit of 100 g/L is not technologically feasible at this time for certain solven t cleaning operations at printing facilities. Therefore, the most recent amendments to SCAQMD Rule 1171 extend compliance with low VOC content limits until the year 2008 for offset lithograph printing and letter

- press printing. In view of SCAQMD staff’s analysis, District staff recommends to delay compliance with the 100

- g/L VOC content limit until 2010 for the cleaning operations identified by SCAQMD staff. In the interim, operators of offset lithographs and letter press printers would have a 500 g/L (4 .2 lb/gal) VOC content limit on cleaning solvents used for cleaning on

- press component, roller wash, and blanket
wash. The interim VOC content limit would mirror SCAQMD’s VOC content limits for these specific solvent

- cleaning categories. Cleaning of ultr aviolet/electron beam ink application equipment would also have an interim VOC content limit

– in this case 650 g/L.

The exemptions from the Table 5 VOC content limits would be moved to Section 4.0 (Exemptions) for clarity. Also, operators would have t he option to use higher VOC content solvent for cleaning if a VOC emission control system is used. The change would allow operators flexibility in solvent cleaning practices with no change in VOC emissions. The solvent cleaning work practices requirement would be reworded to clarify that the operator must meet VOC content limits and utilize work practices for certain cleaning operations.

In Section 6.0 (Administrative Requirements), provisions that are no longer in effect and dates on provisions that are already in effect would be taken out of the rule. Language would be standardized in this rule section and record retention provisions would be clarified, as noted in Section III.A of this staff report. References to composite partial vapor pressure woul d be removed throughout Section 6.0, since the standard is being deleted from the rule. The required records and specified test methods for VOC emission control systems would be added as a separate section to clarify the intent.

Two test methods would be added for determining the transfer efficiency of coatings application equipment. Section 6.0 would be renumbered as needed. In Section 7.0 (Compliance Schedule), the compliance schedule with a date in the past would be removed. The schedule for operato rs losing an exemption would remain the same.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Organic Solvent Cleaning September 20, 2007

15 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules 6. Rule 4612 (Motor Vehicle and Mobile Equipment Coating Operations

– Phase II)

Since this rule was recently adopted, no changes would be made to Section 1.0 (Purpose). Changes would be made throughout the r ule to accommodate the addition of solvent cleaning provisions. In Section 3.0 (Definitions), the definition of stripping, solvent, and VOC content for solvents would be added. An exemption would be added to Section 4.0 (Exemptions) for stripping of drie d or cured coatings. This exemption is similar to the one in Rule 4602 (Motor Vehicle and Mobile Equipment Coating Operations), which is the predecessor to Rule 4612.

Although no changes to the VOC content for coatings would be proposed, an explanatory note at the end of Table 1 would be added for clarity. Also, the section currently titled “Alternate Compliance” would be changed to “VOC Emission Control Systems” to more clearly reflect the rule provisions in this section as well as outlining the requi rements for a VOC emission control system. Solvent cleaning provisions would be added as Section 5.9 (Organic Solvent Cleaning, Storage, and Disposal Requirements). The solvent cleaning VOC content limit would be 25 g/L (0.21 lb/gal) for all types of cle aning operations except bug and tar removal. For bug and tar removal, operators would be allowed to use remover that is regulated under the California Code of Regulations Section 94507 et seq. which spells out the requirements for consumer products sold i n California. In place of meeting the VOC content limits, the use of higher VOC content solvent would be allowed for all solvent

- cleaning operations, provided the operator using the high

- VOC solvent would install and operate a VOC emission control system that meets the requirements in Section 5.4 (VOC Emission Control Systems). Section 5.10 would outline the solvent storage and disposal requirement. The provision mirrors current Rule 4602 requirements for this

same function.

In Section 6.0 (Administrati ve Requirement), record retention provisions would be clarified, as noted in Section III.A of this staff report. The records necessary to show compliance for solvents used in solvent cleaning operations would be added. For VOC emission control systems, l anguage would be revised to clarify the current requirements. Within the solvent usage records, operators would be required to calculate the VOC content of a batch, if the operator mixes the ingredients. The requirements in Section 6.0 would be renumbere d as needed.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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16 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules 7. Rule 4653 (Adhesives)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 (Definitions) would be revised as noted in Section III.A of this staff report. For this rule, the definitions of “bench scale,” “liquid leak,” “repair process,” and “research and development” would be added for clarity. The definition of solvent would be changed to point the operator to Rule 4663 (Organic Solvent Cleaning, Storage, and Disposal). One exemption would be added to Section 4.0 (Exemptions). The added exemption is not new to the rule. It exists in the solvent cleaning portion of Section 5.0 (Requirements) and would be moved to Section 4.0 for clarity.

The language in Section 5.0 for operator and VOC emission contro l system would be standardized, as noted in Section III.A of this staff report. The adhesive VOC content limits would not be changed as part of this rule development project. However, the VOC content limits table would be simplified to include only those VOC content limits currently in force and remove any date associated with the table, since the dates have already passed. The provisions about adhesive application equipment have been moved to its own subsection for clarity.

Section 5.2 in the current rule no longer applies to operations subject to Rule 4653 as of November 14, 2002 and, therefore, would be removed from the rule. The section titled “Organic Solvent Cleaning, Storage and Disposal Requirements” would be revised

to reflect the VOC content limits and effective dates proposed in Table 2 of this staff report. The exemptions to the cleaning solvent VOC content limits would be moved from Section 5.3 to Section 4.0 (Exemptions) for clarity. In new Section 5.2, adhesive application equipment ot her than spray application would be allowed. Section 5.0 would be renumbered, as appropriate. In Section 5.4, the VOC emission control system requirements would be spelled out more clearly. There would be no added requirements and no requirements would be removed.

In Section 6.0 (Administrative Requirements), record retention provisions would be clarified, as noted in Section III.A of this staff report. The required records and specified test methods for VOC emission control systems would be added to clarify the intent. Within the solvent usage records, operators would be required to calculate the VOC content of a batch, if the operator mixes the ingredients. Section 6.0 would be

renumbered as needed.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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17 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules 8. Rule 4661 (Organic Solvents)

Section 1.0 (P urpose), Section 2.0 (Applicability) would not be changed and Section 3.0 (Definitions) would be revised as noted in Section III.A of this staff report. Rule 4612 (Motor Vehicle and Mobile Equipment Coating Operations

– Phase II) will replace Rule 4602 (M otor Vehicle and Mobile Equipment Operations) on January 1, 2009. Rule 4661 cites Rule 4602 in the exemption section, so District staff is proposing that the exemption for Rule 4602 end on December 31, 2008 and that the exemption be added for Rule 4612, b eginning January 1, 2009.

Section 5.0 (Requirements) would be revised to include lower threshold for when a VOC emission control system would be required. There are currently three different thresholds: one for heated solvents, one for photochemically reactive solvents, and

one for non

- photochemically reactive solvents. All three of these would be phased out within six months of rule adoption to a single threshold of 833 pounds of VOC per
calendar month. This threshold mirrors SCAQMD’s rule for simila r sources. 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). The proposed requirement would set a minimum standard for any new sources that would be subject to this rule.

In Section 6.0 (Administrative Requirement), language would be standardized and record retention provisions would be clarified, as noted in Section I II.A of this staff report. For VOC emission control systems, language would be revised to clarify the current requirements. The test method for determining the amount of daily VOC emissions would be moved to this section for clarity.

9. Rule 4662 (Organ ic Solvent Degreasing Operations)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 (Definitions) would be revised as noted in Section III.A of this staff report. In Section 4.0 (Exemptions), one exemption associated with degreasers used exclusively for cleaning flight critical parts using unheated non

- halogenated solvents would be removed. This exemption is no longer in effect.

Section 5.0 (Requirements) would be rearranged to emphasize the solvent’s VOC

content requirements and the alternative to use VOC emission control systems. Also, those parts of the general degreaser requirements associated with specific types of degreasers would be moved to the section under the specific degreaser type. A new set of requi rement would be added for cold cleaners that are under a VOC emission control system. These cleaners would be required to operate and maintain their system

to minimize VOC emissions.

In Section 6.0 (Administrative Requirement), language was standardized in this rule section and record retention provisions clarified, as noted in Section III.A of this staffSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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18 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules report. For VOC emission control systems, language would be revised to clarify the current requirements.

10. Rule 4663 (Organic Solvent Cleaning, Sto rage, and Disposal)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 (Definitions) would be revised as noted in Section III.A of this staff report. For this rule,

the definitions of “bench scale” and “research and d evelopment” would be added for clarity. The definitions in Section 3.0 would be renumbered as needed. Four exemptions would be added to Section 4.0. Rule 4612 (Motor Vehicle and Mobile Equipment Coating Operations

– Phase II) will replace Rule 4602 (Mot or Vehicle and Mobile Equipment Operations) as of January 1, 2009. Rule 4663 cites Rule 4602 in the exemption section, so District staff is proposing that the exemption for Rule 4602 end on December 31, 2008 and that an exemption begin for Rule 4612 on th at date. The remaining added exemptions are not new to the rule, they were previously located in Section 5.0. Section 4.7 has been reworded to clarify that the cleaning of architectural coating application equipment would be subject to the 55 gallons per year limit in order to remain exempt. To add operations flexibility, an exemption was added for the use of aerosol cleaning products that are ARB

- compliant.

The language in Section 5.0 (Requirements) for operator and VOC emission control system would be standardized, as noted in Section III.A of this staff report. The table containing the VOC content limits for solvents used for solvent cleaning would be amended to match the appropriate category limits in Table 2 of this staff report. The exemptions fr om the VOC content limits would be moved from Section 5.0 to Section 4.0 (Exemptions) for clarity. Additionally, District staff is proposing that the exemption

for cleaning of architectural coating application equipment be eliminated 12 months

after rule adoption. SCAQMD removed a similar exemption from Rule 1171 (Solvent Cleaning Operations), ending the exemption in July 2005. In Section 5.2 (Cleaning Methods), wording would be changed to reflect a lower VOC content limit. Operators

would have 12 month s to come into compliance with the proposed limit. Section 5.3 (VOC Emission Control System) would have phrasing added to clarify the current requirements. Added provisions include approval of the VOC emission control system by the APCO and limiting the emissions from a VOC emission control system to the amount of VOC emissions that would have been emitted if the operator had used compliant solvents and work practices.

In Section 6.0 (Administrative Requirement), language would be standardized and

reco rd retention provisions would be clarified, as noted in Section III.A of this staff report. References to composite partial vapor pressure would be removed throughout Section 6.0, since the standard is being deleted from the rule. Within the solvent usag e records, operators would be required to calculate the VOC content of a batch, if the operator mixes the ingredients. For VOC emission control systems, language would be revised to clarify the current requirements.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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19 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules 11. Rule 4684 (Polyester Resin Oper ations)

Section 1.0 (Purpose), Section 2.0 (Applicability) would not be changed and Section 3.0 (Definitions) would be revised as noted in Section III.A of this staff report. For this rule, the definitions of “bench scale” and “research and development” would be added for clarity. One exemption would be added to Section 4.0 (Exemptions). The added exemption is not new to the rule. It exists in the solvent cleaning portion of Section 5.0 (Requirements) and would be moved to Section 4.0 for clarity.

The language in Section 5.0 for VOC emission control system would be standardized, as noted in Section III.A of this staff report. Section 5.2. (Cleaning Materials Requirement) and Section 5.3 (Storage and Disposal Requirements) would be removed since the pr ovisions of Section 5.4, titled “Organic Solvent Cleaning, Storage, and Disposal,” replaced these two sections. Also, the exemptions from the VOC content limits for solvent cleaning would be moved to Section 4.0 as a single exemption. The remaining exemp tion is no longer in force and would be taken out of the rule. Added to this section, operators would have the option to use higher VOC content solvent for solvent cleaning operations if a VOC emission control system is used. The change would allow opera tors flexibility in cleaning equipment with no change in VOC emissions. Section 5.0 would be renumbered as appropriate.

In Section 6.0 (Administrative Requirement), language would be standardized in this rule section and record retention provisions would be clarified, as noted in Section III.A of this staff report. For VOC emission control systems, language would be revised to clarify the current requirements. Two test methods would be added for determining whether the enclosed cleaning system for spray coating application equipment is equivalent to using low VOC coatings application equipment.

C. Tertiary Butyl Acetate (TBAC)

During the rule making, it was requested that the District delist TBAC as a VOC so that it would be considered an exempt solv ent in cleaning solution formulations.

In November 2004, EPA announced that it had removed TBAC as a VOC due to its low photochemical reactivity. All states except California and New Jersey have exempted TBAC with New Jersey beginning the process to ex empt TBAC just this year. At the state level, the California Air Resources Board (ARB) has exempted TBAC for consumer products. ARB encourages individual air districts to determine whether to exempt TBAC for stationary sources on a case

- by

- case basis rat her than exempt TBAC on a statewide basis. ARB was one of the original proponents strongly advocating a TBAC exemption, but softened their stand later in the process. The reason for ARB backing off on its support was a question of the overall health risk of TBAC. The Office of Environmental Health Hazard Assessment (OEHHA), in assessing TBAC, had some

concerns about the health risks associated with the increased use of this new chemical.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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20 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules District staff contacted the staff of OEHHA to get more details on their concerns. The following bullets summarize OEHHA staff’s issues with TBAC.

Since TBAC is not in widespread use, there are no available human studies comparing those who use TBAC versus those who don’t. This lack is usually not

a make

- or

- break issu e for new chemicals.

OEHHA staff feels that there is not enough supporting information about TBAC, particularly the chronic exposure component, to adequately assess TBAC’s health risk. Chronic exposure is exposure over a long period of time to small or

m oderate amounts of a chemical.

One animal study found a relationship between tertiary butanol and tumors in mice. Mammals (including humans) can metabolize TBAC to tertiary butanol. To OEHHA staff, this study raises concerns, meaning more studies would be needed to determine the exact relationship between tertiary butanol and TBAC, as well as the impact of that relationship on health risks.

Other tertiary butyl chemical exhibit cancer

- causing potential, thus making the OEHHA staff wary of any chemical w ith a tertiary butyl structure, not just TBAC.

The gaps in information outlined above prevent OEHHA staff from issuing a health risk assessment. Without the support of an OEHHA assessment, it would be difficult for

District staff to determine whether to exempt TBAC. Looking to other air districts for their assessment of TBAC, the SCAQMD Governing Board has decided to exempt TBAC only in certain specific usage categories. Products that are compliant with the

low

- VOC content limits for solvent cleaning ex ist that do not contain TBAC, so the SCAQMD Governing Board decided not to exempt TBAC for solvent cleaning. District staff, therefore, recommends that if ARB would exempt TBAC more generally throughout the state, District management would consider making TBAC an exempt compound. Until ARB generally exempts TBAC, it is recommended that TBAC remain a VOC for purposes of solvent cleaning.

IV. VOC EMISSIONS AND VOC EMISSION REDUCTIONS

Total emission reductions include emissions reductions from three categ ories of amendments to the rules. The three 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 exemption for cleaning architectural coat ing application equipment

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 2005SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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to the Solvent Cleaning Portion of Eleven District Rules baseline VOC emissions of 5.5 tons per day. Details of the analysis are in Appendix B of this report.

V. COSTS AND COST EFFECTIVENESS ANALYSIS

The California Health and Safety Code 40920.6(a) requires the San Joaquin Valley Unified Air Pollution Control District to conduct a cost effectiveness analysis of avail able emission control options before adopting each BARCT rule. The purpose of conducting a cost effectiveness analysis is to evaluate the economic reasonableness of the pollution control measure or rule. The analysis also serves as a guideline in developi ng the control requirements listed in a rule. Details of the cost and cost effectiveness analysis are in Appendix C of this report.

VI. SOCIOECONOMIC IMPACT ANALYSIS

Under California state law, District staff is required to perform a socioeconomic impa ct analysis prior to adoption, amendment, or repeal of a rule that has significant air quality benefits or that will strengthen emission limitations. District staff held a meeting with members of the Socioeconomic Focus Group in April 2007. District staf f analyzed the cost data and business feedback in order to ascertain the cost impacts of the draft rule. The socioeconomic impact analysis, which was prepared for the District by Applied Development Economics, determined that the proposed regulation would not have a significant impact on the affected industries. The results of the socioeconomic analysis are included as Appendix D to this staff report.

VII. ENVIRONMENTAL IMPACTS

As part of the California Environmental Quality Act (CEQA), District staf f is required to investigate the likely environmental impacts of the rule amendments from this rule project. Based on the lack of evidence to the contrary, District staff has concluded that the amendments, as proposed, will not have any significant advers e effects on the environment. Staff recommends filing a Notice of Exemption under the provisions of Public Resource Code 15061(b)(3).

VIII. RULE CONSISTENCY ANALYSIS

As required by California Health & Safety Code Section 40727.2, District staff has

pre pared a rule consistency analysis that compares the elements of amendments with the corresponding elements of other District rules, federal regulations and guidelines that apply to the same source category or type of equipment. District staff found thatSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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22 Final Staff Report with Appe ndices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules f acilities could comply with the proposed amendments to the solvent cleaning portions of the eleven District rules as well as all other existing or proposed District rules. Furthermore, District staff found that none of the proposed requirements of for thi s rule project would conflict with federal rules, regulations, or policies covering similar stationary sources. The analysis is contained in Appendix E of this staff report.

IX. RULE DEVELOPMENT PROCESS

As part of the rule development process, District staff conducted a public scoping meeting in August 2006. Public workshops were held in October 2006, April 2007, and June 2007 in order to present, discuss, and solicit comments from the public, affected sources, EPA, and ARB on the proposed amendments. Comments received during the workshop process were incorporated into the rule amendments as appropriate.

Proposed amendments to the solvent cleaning portions of eleven District rules and the Final Draft Staff Report have been published and made available to affected sources and interested parties prior to a public hearing by the Governing Board. District staff intends to submit the proposed rules to the District Governing Board for adoption on September 20, 2007. The notice of the public hearing for the proposed rules has been published in a general circulation newspaper in each of the eight San Joaquin Valley counties and has been mailed to affected sources and interested parties. The public notice solicited written comments by mail, and it also identi fied the name and telephone number of the District staff who can answer questions and respond to comments. Comments received and District responses for the August 18, 2007 version of the rule are discussed in Appendix A of the Final Draft Staff Report.

X. REFERENCES

1. South Coast Air Quality Management District

– Rule 1122 “Solvent Degreasers” adopted March 2, 1979, last amended October 1, 2004.

2. South Coast Air Quality Management District

– Rule 1171 “Solvent Cleaning Operations” adopted August 2, 1991, last amended July 14, 2006.

3. South Coast Air Quality Management District

– Final Staff Report of Proposed

Amended Rule 1171

– Solvent Cleaning Operations. June 2006.

4. South Coast Air Quality Management District

– Staff Report for Proposed

Amen ded Rule 1171

– Solvent Cleaning Operations. November 2003.

5. Bay Area Air Quality Management District

– Regulation 8 Rule 4 “General Solvent and Surface Coating Operation” adopted March 17, 1982, last amended October 16, 2002.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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to the Solvent Cleaning Portion of Eleven District Rules 6. Bay Area Air Quality Management District

– Regulation 8 Rule 16 “Solvent Cleaning Operations” adopted March 7, 1979, last amended October 16, 2002.

7. Code of Federal Regulations

– Title 40 Parts 60, 61, and 63.

8. California Air Resources Board

– Environmental Impact Assess ment of tert

- butyl

acetate . January 2006SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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