11464 B Avenue, Auburn, CA 95603 • (530) 889-7130 • Fax (530) 889-7107
Thomas J. Christofk, Air Pollution Control Officer



### MEMORANDUM

TO: Board of Directors, Placer C ounty Air Pollution Control District

FROM: Todd K. Nishikawa, Principal Air Pollution Control Engineer

AGENDA DATE: December 11, 2003

SUBJECT: Approve Resolution #03-20, thereby adopting Amended Rule 240, Surface Preparation and Cleanup (Action/Public Hearing)

Action Requested :

Approve Resolution #03-20, in a Public Hear ing, thereby adopting Amended Rule 240, Surface Preparation and Cleanup

.

Background:

The proposed rule is included as a Volati le Organic Compound (VOC) control measure in the Sacramento Area Regional Ozone Atta inment Plan, which was adopted by the Board on December 20, 1994. VOC emissions a nd Oxides of Nitrogen (NOx) emissions are precursors to the photochemical formation of Ozone. The Attainment Plan was adopted in response to the 1990 Amendments to the Federal Clean Air Act (CAA) which required areas, designated “serious” for Ozone by the United States Environmental Protection Agency (USEPA), to submit a State Implementation Plan (SIP) revision. The

District met the 1994 Plan’s SIP commitment for the adoption of a surface preparation and cleanup solvent rule when Rule 240 was adopted on October 9, 1997.

Discussion:

The main purpose of the proposed amendment to Rule 240 is to add control measures and standards now in effect in equivalent rules in other districts, such as Sacramento, San Joaquin and South Coast. The present Rule 240 was adopted initially on October 9, 1997, and does not contain these newer prove n control measures and standards. Adoption of this amendment will establish grea ter uniformity in the Region in the control of Volatile Organic Compound (VOC) emissions from this stationary source category.

It is estimated that an addition reduction of 0.14 tons VOC per day can be achieved from the adoption and implementation of the proposed amendments to Rule 240.Rule 240, Surface Preparation and Cleanup

PCAPCD Board of Directors Agenda Date: December 11, 2003 Page 2



### The proposed rule amendment applies to all pe rsons in Placer County who engage in the production, repair, maintenance or servicing of parts, products, tools, machinery or equipment, and storage and disposal of VO C-containing materials used in solvent cleaning operations. Partial or complete ex emptions are allowed in numerous cases as listed in Section 104 of the rule.

The major affect of the proposed amendments is to set new and lower VOC limits for solvent cleaning activities. These lower limits are consistent with the limits currently in place in Sacramento and other jurisdictions and are proven to be feasible. The lower VOC limits and other new requirements do not become effective for 12 months. Other

amendments are:

Section 200, Definitions:

 Numerous new control devi ces and operations were added and language was revised for consistency.

Section 300, Standards:

 The rule allows for a twelve-month time pe riod after adoption to provide sources the time to implement methods and equipment to meet the more stringent and complete requirements contained in Section 301.2.

 Standards effective after the twelve-m onth period require lower VOC content in solvents and are more specific in describi ng various categories of equipment to be cleaned with varying VOC contents as appr opriate. (Other Districts have found that the lower VOC-content materials are readily available.)

 Allowable cleaning materials, methods and equipment are included in the Standards

Section.

Section 400, Administrative:

 All calculation formulas have been reloca ted from Section 200 to this Section. An additional formula to determine partial VOC Composite Partial Pressure was added,

since the Standards now include this type of measurement of solvent volatility. Also, Seller product liability requirements have been added.

Section 500, Monitoring and Records:

 Recordkeeping requirements were rearrang ed and expanded as necessary, due to the increased number and type of materials discussed in the ru le. Additional test methods and protocol items were added to this Section.

Fiscal Impacts:

As discussed in more detail in the Staff Report, Attachment 1, the cost of allowable solvents used for cleaning electronic and electrical equipment may increase about 15%, or $0.40 per pound. Other cleaning ope rations are expected to incu r little or no increases, since many available solvents now contain Acet one (not a VOC), and/or are water-based. These are in general, equal to or less costly than traditional VOC solvent based cleaners.Rule 240, Surface Preparation and Cleanup

PCAPCD Board of Directors Agenda Date: December 11, 2003 Page 3



### California Environmental Quality Act:

The District staff has determined that the ad option of this rule is categorically exempt from the California Environmental Quality Act (CEQA) requirements per the CEQA Guidelines, Section 15307, Actions by Regulat ory Agencies for Protection of Natural

Resources.

Public Outreach:

A public workshop was held on November 19, 2003 at the Placer County Planning

Commission Chambers in Auburn. Notifica tion for this workshop was done through direct mailing to those possibly affected by this rule and also through public notices printed in the Auburn Journal on Novemb er 3, 2003 and the Roseville Tribune on November 5, 2003. As of December 1, 2003, no oral or written comments have been

received.

Because the requirements of Rule 240 apply to many uses that are not permitted by the District, as well as requiring some additiona l businesses to be permitted, a major public outreach effort will be required to advise auto repair facilities and others of the requirements of the amended rule. The e ffective date of December 11, 2004, following adoption is an unusually long period to provi de for this outreach and any operations changes necessary for compliance.

Recommendation:

District staff recommend approval of Resolu tion #03-20, thereby adopting amended Rule 240, Surface and Preparation and Cleanup

.

Attachment #1: Resolution #03-20, Thereby Adopting Amended Rule 240, Surface Preparation and Cleanup

Exhibit I: Proposed Amendment for Rule 240, Surface Preparation and Cleanup

Attachment #2: Staff Report: Rule 240, Surface and Preparation and Cleanup

### ATTACHMENT 1

### ATTACHMENT 2

### EXHIBIT I

## PLACER COUNTY
AIR POLLUTION CONTROL DISTRICT

STAFF REPORT

Rule 240, Surface Preparation and Cleanup

December 11, 2003BACKGROUND

The District is proposing to amend Rule 240, Su rface Preparation and Cleanup. The District is required to adopt regulations to reduce VOC emissions associated with solvent cleaning operations. The District has committed in the St ate Implementation Plan (SIP) to reduce volatile organic compound (VOC) emissions from solvent cleaning activities.

Solvent cleaning is an essential part of any ma nufacturing operation or service operation (e.g., automotive repair, graphic arts printing) and is not limited just to application equipment, but also includes manufactured or serviced parts or equipm ent. The cleaning process generally involves surface preparation such as wipe cleaning or degreasing to remove grease and other contaminants prior to assembling. Currently, most of the clean ing is done using clea nup materials containing VOCs or materials containing non-VOCs or exempt compounds (e.g., halogenated solvents, and non-halogenated solvents.) Some of the haloge nated solvents are regulated by United States Environmental Protection Agency (USEPA) unde r 40 CFR Part 463, Subpart T – National Emission Standards for Halogenated Solvent Clean ing. Sources using these solvents are required to comply with USEPA regulations.

Rule 240 currently regulates solvent cleaning activities from coating and manufacturing operations that are not specifically regulated by other District rules. The proposed amendments will expand the rule to include cleaning activiti es such as cleaning of electrical apparatus and electronic components, architectural coating application equipment, polyester resin application equipment, and automotive repair clea ning that have not been regulated.

Rule 240

Rule 240, which regulates VOC emissions from so lvent degreasing operations, is being amended in order to require non-vapor degreasing operations (also referred to as cold degreasing) to be preformed using cleanup material that contains no more than 50 grams per liter of VOCs. The proposed amendments also allow the use of ai r pollution control devi ces or airtight/airless cleaning system s as an alternative to complying with the 50 grams per liter VOC limit. Other amendments to the rule are intended to clarify the rule requirements and to respond to ARB and public comments on the rule. A detailed list of th e proposed changes to the rule is included as Attachment C to the staff report.

There are different methods of cleaning as discussed below.

Maintenance and Repair Cleaning: This type of cleaning is performed to keep equipment, tools, machinery, and general work area in a good condition. Examples of such cleaning include cleaning of engines and other parts during maintena nce and repair of buses, aircraft, and trucks; cleaning of tools, machinery, equipm ent, and general work areas in shops.

Manufacturing Cleaning: Manufacturing cleaning includes cleaning of manufactured parts during various stages of production processing such as cutting, machining, molding, and fabricating, and assembling of manufactured parts. The cleaning is performed to remove contaminants such as cutting oil and grease.

Application Equipment Cleaning: This type of cleaning includes the cleaning of ink, coating, and adhesive application equipment. Examples of such equipment are paint spray equipment such as spray guns, cups, dispensing hoses, pressure pots, and distribution pipelines; dip tanks and roller coaters; and hand application equipm ent such as brushes, rollers, and trowels.Wipe Cleaning: Wipe cleaning is used when the use of a cleaning device is not feasible or only spot cleaning to remove fingerprints, oil, and gr ease is required. Wipe cleaning is the cleaning of the surface by physically rubbing it with a ma terial such as rag, paper, or cotton swab.

Solvent Flushing: Solvent flushing is generally used for cleaning of ink, coating, and adhesive application equipment. The discharged solv ent is usually collected in containers.

Remote Reservoir Cleaning: This method employs a sink-on-drum type cleaning device. The cleaning solvent is usually stored in a drum and is pumped to the sink where the parts are being

cleaned. The unused solvent retu rns to the solvent container.



### LEGAL MANDATES

Federal Mandate: The Sacramento Region has been designated as a severe nonattainment area for the federal ozone standard by the EPA. There are legal mandates that directly resulted from this classification. Section 182 (c) of the fede ral Clean Air Act Amendments of 1990 (42 U.S.C. 7511a (c)) required all ozone nonattainment areas classified as “serious” and above to submit a State Implementation Plan (SIP) revision by No vember 15, 1994 which described, in part, how the area will achieve: (i) the National Ambient Air Quality Standard for ozone, and (ii) actual VOC emission reductions of at least three pe rcent per year (averaged over each consecutive 3- year period beginning November 1993). Sec tion 182(d) (42 U.S.C. 7511a (d)) requires the District to adopt the control measures proposed in the SIP. In addition, Section 172 (c)(1) (42 U.S.C. 7502) requires the District to adopt R easonable Available Control Technology for major stationary sources.

The District committed in the SIP to reduce VOC emissions from solvent used in surface preparation and cleanup operations. The SIP comm itment is to reduce this category in the Sacramento ozone nonattainment area by 3.9 tons per day by 2005. This category has been reduced by 2.33 tons per day. The District has reduced 0.60 tons per day from adoption of control measures in Rule 240 for surface prepar ation and cleanup operations. Proposed changes

to Rule 240 are needed in order to achieve the additional reductions needed to meet the SIP

commitment.

State Mandates: The Sacramento Region is designated as a serious nonattainment for the state

ozone standard. The California Clean Air Act requires areas with this designation to adopt control measures required in Sections 40913, 40914, and 40919 of the California Health and Safety Code (CHSC):

Plan Requirements: Section 40913 requires districts to develop a plan to achieve California’s ambient air quality standard by the earliest practicable date. The 1994 Sacramento Area Regional Ozone Attainment Plan lists surface preparation and cleanup as one of the stationary source control measures for reducing VOCs (1994 Attainment Pl an, Appendix D-8). Amendments to Rule 240 are being proposed to meet this requirement.

All Feasible Measures Requirements: Section 40914 requires each district plan to demonstrate that the plan includes “every feasible measure.” Districts must adopt the most effective control measures to reduce VOC emissions from solvent cleaning operations. Other Districts such as SCAQMD, SMAQMD, BAAQMD, and SJVUAPCD have adopted regulations that require the use of a 50 grams per liter VOC-containing solvent for ge neral cleaning. The SCAQMD has also revised their rule to require the use of cleanup materials with VOC content of 25 grams per liter (Effective January 1, 2003.) Staff evaluated the standards in the proposed rule against similarapplicable requirements adopted by these district s. The results are included as Attachment B to the Staff Report.

Best Available Retrofit Requirements: Section 40919 requires districts with serious nonattainment for ozone to adopt Best Available Retrofit Control Technology (BARCT) for all existing sources. BARCT means an emission limita tion that is based on the maximum degree of reduction achievable, taking into account environmental, energy, and economic impacts by each class or category of sources (CHSC Section 40406). Staff has found that the proposed VOC requirements meet the BARCT requirement and therefore the proposed rule meets the requirements of CHSC Section 40919.

Transport Mitigation Requirements: Title 17, California Code of Regulations, Section 70600 requires districts within the areas of origin of transported air pollutants, to include sufficient control measures in their attainment plans for ozone to mitigate the impact of pollution sources within their jurisdictions on ozone concentra tions in downwind areas. The District is an identified transporter of air pollutants. The regula tions require the District's plan must contain at minimum requirements for BARCT for source categ ories that collectively amount to 75% of the 1987 actual VOC and NOx emissions inventory.

Section 39610 of the California Health and Safety Code requires the state board to identify air basins that transport air pollutants to other air basi ns or subregions that contribute to violation of the ambient air quality standard for ozone. Th e state board has identified the District as a transporter of air pollutants to the Upper S acramento Valley and Broader Sacramento Area.

Section 40910 of the California Health and Safe ty Code requires districts to consider full spectrum of emission sources and focus particular attention on reducing the emissions for transportation and areawide emission sources.

SUMMARY OF PROPOSED RULE REQUIREMENTS

Staff is proposing a 50 grams per liter VOC standa rd for general maintenance cleaning. The proposed VOC standard is consistent with the standa rd adopted by other districts. Those districts and the effective dates of the 50 grams per liter VOC limit are listed in the following table:

District 

### Rule Number/Name Effective

Date for

VOC

Limits Bay Area Air Quality Management District (BAAQMD) Rule 16, Solvent Cleaning Operations 9/1/1999

Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 454, Degreasing Operations and Rule 466, Solvent Cleaning 5/22/03

Rule 4662, Organic Solvents Degreasing Operations 11/19/2002 San Joaquin Valley Unified Air

Pollution Control District (SJVUAPCD) Rule 4663, Organic Solvents, Cleaning, Storage, and Disposal 11/15/2003

South Coast Air Quality Management

District Rule 1171, Solvent Cleaning Operations 12/1/2001

Staff is also proposing other VOC content lim its for cleaning of electrical apparatus and electronic components, medical devices and pharma ceuticals, tools, equipment, and machinery,and architectural coating application equipment. Other districts such as the SCAQMD, BAAQMD, and SJVUAPCD have also adopted similar VOC standards for solvent cleaning operations.

The proposed rule amendment gives stationary sources alternatives to complying with the VOC limits being proposed. Stationary sources can use an airtight airless cleaning system or install and operate air pollution control equipment. The pr oposed requirements for each rule are discussed

below:

Rule 240 requires general cleaning to be performed by materials that contain less than 50 grams per liter VOCs as applied. The rule also includ es other requirements for cleaning electrical and electronic apparatus components, architectural a pplication equipment, and adhesive application equipment. The VOC limit varies depending on the equipment being cleaned. The rule allows the use of air pollution control equipment or an air tight or airless cleaning system as alternatives to complying with the VOC limits proposed by the rule. The rule also specifies cleaning method requirements, general equipment requirements, operating requirements, storage and disposal requirements, and recordkeeping requirements.

A list of all of the proposed changes to Rule 240 is included as Attachment C to the staff report.

RULE IMPACT ANALYSIS

Type of Sources Affected: The amended rule 240 will affect cleani ng operations not currently regulated. Those operations include wipe cleaning and cl eaning of medical devices and pharmaceuticals, electrical apparatus components and electronic components, and architectural application equipment. Staff does not know the number of operations to which this rule will apply. However, many operations will be regulated only through the rule (i.e. no permits will be issued). As a result a significant public education and outreach e ffort to affected operators will be necessary, and this is one reason for the unusually long 12 months between rule adoption and the effective date of the new provisions.

Impact on Regional Economy: Staff analyzed the impact of the proposed requirements on

sources in the District. Products are available on the market that meet these limits and are not expected to adversely impact these sources. The table below summarizes the costs for different cleaners used by operations subject to this rule.

Type of Cleaning Operation 

### Cost of High

VOC Material
$ Cost of Low VOC Material $

Architectural Coating 4-6 3-8 Electrical & Electronic Equipment 3-6 3-14

Medical Devices and pharmaceuticals 6-8 Same since no low VOC materials are required to be used. Repair and maintenance cleaning 4 -6 3 - 6

Staff evaluated the impact on architectural coa ting operations in the Sacramento Region, and found that these operations use water based coatings for the majority of their painting operations (About 84% of the most commonly used architectur al coatings sold for use in California are water based (ARB's 1998 Architectural Coatings Su rvey Results Final Report.) Staff also found that the paint application equipment is either clean ed at the site or brought back to the shop for cleaning. Application equipment using water based coatings are usually cleaned with water.Application equipment using solvent based coati ngs are currently being cleaned with thinner. Some paint contractors use a distiller to recycle waste solvents. Others contract with a waste recycler for their spent solvents. The cost of low VOC solvents generally ranges between $6 to $8 per gallon compared to paint thinner at $4 to $6 per gallon. Sources can also use a solvent blend of acetone and other exempt solvents at a cost of $3 per gallon (see discussions under Range of Probable Costs Due to Rule 240). The impact fro m the lower VOC limit fo r cleanup solvents is expected to be minimal since only small percen tage of the coatings used are solvent based coatings. The rule also requires that cleaning of spray guns to be done using an enclosed gun cleaner when the cleaning is done at the shop. There are many types of gun cleaners available for this purpose. The cost of gun cleaners ranges from $750 for a single-gun cleaner to $2300 for a four-gun cleaner.

Socioeconomic Impact Analysis Performed by other Districts: The SCAQMD evaluated the economical impacts of their Rule 1171 using an economic policy model, the REMI (Regional Economic Modeling) model and c oncluded that their Rule 1171 would not have an adverse impact on the economy in the SCAQMD (Final Staff Report for Rule 1171, Solvent Cleaning Operations, July 1991.) The study concluded that approximately four jobs will be created annually in directly regulated sources. A more recent SJVUAPCD socioeconomic impact study prepared by Jack Faucett Associ ates for Rule 4663, Organic So lvent, Cleaning, Storage, and Disposal amendments also concluded a modest impact for regional economy of the San Joaquin Valley. The impact on the SJVUAPCD economy wa s an employment change of two jobs. Staff expects no impact from the new regulations on employment in the District.

Range of Probable Cost for Proposed 50 Gram s per Liter VOC Limit, Due to this Rule

Amendment: The costs for using solvents and aqueou s cleaners are summarized in the table

below. These costs are based on cost informa tion contained in an EPA Region IX pollution prevention program fact sheet titled "Aqueous Part Cleanings". This fact sheet is part of a package of fact sheets entitled either "The Po llution Prevention Tool Kit, Best Environmental Practices for Auto Repair" (publication number EPA-909-E-99-001) or The Pollution Prevention Tool Kit, Best Environmental Practices for Fleet Maintenance" (publication number EPA-909-E99-002). The costs comparison below is based on a case study for a typical full service automotive repair shop with six technicians a nd 14 bays. The shop purchased an aqueous spray cabinet and also an aqueous microbial sink-top uni t. The spray cabinet solution and sludge were disposed of as separate waste streams every 6 months by a waste disposal company. The microbial unit did not require solution disposal in over 16 months of use. The majority of cost savings were in cleaning labor.Parts Cleaning Costs Comparison



### Two Solvent Units

Annual Costs $ Leasing, waste management 1260 Electricity 1400 Cleaning labor 31200

Total Cost 33,860

Aqueous Spray Cabinet 

### Aqueous Microbial Sink-Top

Annual Costs $ Annual Costs $ Purchase price (one-time) 1,600 Purchase price (onetime) 1,300

Chemicals 75 Chemicals 325 Solution and sludge disposal 425 Filters 60

Electricity 3,100 Solution and sludge disposal 289

Cleaning labor 11,232 Electricity 360 Cleaning labor 3,120

Total Cost 16,432 Total Cost 5,240



### Total Capital Cost: $2,900 Annual Savings: $14,874 Payb ack Period: 0.2

Year

Note: The cost analysis above is based on replacing th e two solvent units with two aqueous units (one of the aqueous units also uses microbes to aid in the cleaning Process.) The analyses show that adding microbes to the aqueous unit reduces the operating cost significantly since heating of the solution in

h i i d d



### As seen the in the tables above, using aqueous cleaners resulted in cost savings for this shop.

Range of Probable Cost for other Types of Cleaning: The cost impacts are summarized in the table below. The cost impacts for electrical, me dical, pharmaceutical, and repair and maintenance cleaning are based on information contained in a recent report prepared for SJVUAPCD organic solvent cleaning rule by Jack Faucett and Associates, Socioeconomic Impact Analysis of Organic Solvent Cleaning, Storage, and Disposal Rule Project , November 2001, Appendix A. Staff

believes that these costs are similar for Placer based on telephone conversations with solvent suppliers. The cost impacts for architectural application equipment cleaning are based on Staff analysis.Type of Solvent Cleaning Cost Impact Electrical Apparatus and Electronic Equipment There will be a small overall increase in solvent cost (about 15% or $0.4/pound) based on the cost effectiveness analysis performed by Jack Faucett.

Medical and Pharmaceutical There is no expected cost increase for this category of cleaning. This is based on the assumption that some of the cleaning will be done using acetone or a solvent blend. The overall compliance cost will be about the same compared with the current solvent usage. (Based on cost effectiveness analysis performed by Jack Faucett) Repair and Maintenance Cleaning There is no expected cost increase for this category of cleaning since the general cleaning will be replaced with aqueous

cleaners and acetone which will not result in added costs compared with the current cost s for the cleanup solvents (see cost comparison for solvent and aqueous part cleaners in the table on page 9). The cost of thinner is about $4 to $6 per gallon. The cost of replacement solvents ranges between $4 to $6 per gallons. Sources can also use acetone with other exempt solvents at a cost of $3 per ga llon, which is cheaper than the cost of the thinner (Based on cost effectiveness analysis performed by Jack Faucett.) Architectural Coating Application Equipment Cleaning The rule requires the use of 50 grams per liter VOC content for cleaning after using water based coatings, 300 grams per liter VOC content when cleaning after using solvent based coatings on the jobsite, and an enclosed gun cleaner when cleaning at the shop. This includes paint guns, brushes and other application equipment. There is no cost increase for cleaning when cleaning after using water based paints since the application equipment is cleaned with water. Approximately 84% of the coatings used are water based.

A thinner is currently used to clean application equipment when solvent based coatings are used. The thinner will be replaced by a blend of acetone and other exempt solvents. The cost of thinner is about $4 to $6 per gallon. The cost of replacement solvents ranges be tween $6 to $8 per gallons (a 25% increase in solvent cost.) Sources can also use acetone with other exempt solvents at a cost of $3 per gallon, which is cheaper than the cost of the thinner (Based on cost effectiveness analysis performed by Jack Faucett.) The cost of a gun cleaner ranges between $750 for a single gun cleaner to $2300 for a four-gun cleaner (B ased on cost information from vendors of gun cleaners). Some contractors clean their application equipment at the jobsite, others bring their equipment to the shop for cleaning. Some are currently using gun cleaners.

Availability/Cost Effectiveness of Alternatives to Amending Rule 240: Staff evaluated all of the VOC limits adopted by other districts and chose these lim its since they have been demonstrated to be technologically feasible (see Attachment B.) Staff al so evaluated the cost effectiveness of the rule and compared it with similar rules adopted by other Districts (see Attachment B.) The only

alternative to this rule amendment is to not adopt it and to find additional emission reductionsfrom other sources. However, the District is required by state law (see discussion under State Mandates) to adopt BARCT for source categories that collectively amount to 75 percent of the 1987 actual reactive hydrocarbon emissions invent ory for permitted stationary sources. Because this is such a large emission source category, it would be difficult or impossible to meet this requirements without this rule. Additionally, the District is required by federal law to adopt RACT for major stationary sources.

Emission Reduction Potential for Rule 240: The District estimates that this rule amendment will result in a 78% overall reductions in VOC emissions from solvent usage. The amendments will reduce VOC emissions by 0.14 tons per day (49.68 tons per year.) The VOC emission reductions were estimated based on the year 2005 planning inventory (forecasted from Central California Ozone Study (CCOS) Inventory) (See Attachment D).



### Necessity of Amending Rule 240: (See discussion under Legal Mandates Section)

OTHER FACTORS:

Technological Feasibility: The VOC limits proposed for Rule 240 for cleaning materials are based on requirements adopted and implemented by BAAQMD, SCAQMD, SMAQMD, and SJVUAPCD. Therefore, the proposed VOC limits are technologically feasible.

Enforceability: Reporting requirements and testing procedures have been included in the rule to increase enforceability.

Public Acceptability: The requirements outlined in this amended rule are already in affect in many areas in California. The proposed lower VOC solvents limits effective on December 11, 2004, are proven control measures that set feasi ble VOC standards for surface preparation and cleanup. The adoption of limits equal to Sacram ento and other areas also levels the business “playing field” within the region.

ENVIRONMENTAL REVIEW AND COMPLIANCE

The proposed amendments to Rule 240 are subject to the provisions of the California Environmental Quality Act (CEQA). Staff evalua ted the proposed requireme nts to see if there are any significant adverse effects on the environm ent. Staff has concluded that based on the findings of air quality impact analysis performed by the staff of Sacramento Metropolitan Air Quality Management District (Initial Study, Amendmen ts to Rule 454, and Adoption of Rule 466, Sacramento Metropolitan Air Quality Management District ; April 2002) that there will be no significant impact on the environment from the amendments to this rule.



### DISTRICT IMPACTS

Additional permitting and compliance (e.g. inspectio ns) work associated with these revisions will be met with existing resources a nd planned for staff increases.TABLE OF FINDINGS

Six Required Findings: According to Section 40727(a) of the California Health & Safety Code, prior to adopting or amending a rule or regulation, an air district’s board must make findings of necessity, authority, clarity, consistency, non-duplication, and re ference. The findings must be based on the following:

1. Information presented in the District’s written analysis (see Appendix A), prepared pursuant to Health and Safety Code Section 40727.2,

2. Information contained in the rulemaking reco rds pursuant to Section 40728 of the Health and Safety Code, and

3. Relevant information presented at the Board’s hearing for the rule.

(Continued next page)The table below sets the findings and the basis for making the finding.

Rule 240

FINDING FINDING DETERMINATION
Authority: The District must find that a provision of law or of a state or federal regulation permits or requires the District to adopt, amend, or repeal the rule. The District is authorized to adopt rules and regulations by California Health and Safety Code, Sections 40001, 40702, 40716, 41010 and 41013. (CHSC Section 40727(b)(2)) Necessity: The District must find that the rulemaking demonstrates that a need exists for the rule, or for its amendment or repeal. Proposed amendments to Rule 240 are necessary

in order to meet the Federal Clean Air Act Reasonably Available Control Technology requirements (Sections 182(b)(2) and 172(c)(1) (42 U.S.C. 7502

of the Federal Clean Air Act Amendments of 1990), 1994 Sacramento Area Regional Ozone Attainment Plan (CHSC Section 40913), the state’s Best Available Retrofit Control Technology requirements (CHSC Section 40919(a)(3)), and “all feasible measures” requirement (CHSC Section 40914) for reducing volatile organic compound emissions from solvent cleaning operations. (CHSC Section 40727(b)(1)) Clarity: The District must find that the rule is written or displayed so that its meaning can be easily understood by the persons directly affected by it. Staff has reviewed the proposed rule amendments and determined that they can be easily understood by the affected industry. In addition, the record contains no evidence that the persons directly affected by the rule can not understand it. (CHSC Section 40727(b)(3)) Consistency: The rule is in harmony with,

and not in conflict with or contradictory to, existing statutes, court decisions, or state or federal regulations. The proposed rule amendments do not conflict with and are not contradictory to, existing statutes, court decisions, or state or federal regulations. (CHSC Section 40727(b)(4)) Non-Duplication: The District must find that either: 1) The rule does not impose the same requirements as an existing state or federal regulation; or 2) that the duplicative requirements are necessary or proper to execute the powers and duties granted to, and imposed upon the District. The proposed rule amendments do not duplicate any state laws or regulations, regarding

the attainment and maintenance of state and federal air quality standards. (CHSC Section 40727(b)(5))FINDING FINDING DETERMINATION
Reference: The District must refer to any statute, court decision, or other provision of law that the District implements, interprets, or makes specific by adopting, amending or repealing the rule. CHSC Sections 40913, 40914 and 40919(a)(3),

41010.

Additional Informational Requirements (CHSC Section 40727.2): In complying with CHSC Section 40727.2, the District must identify all federal requirements and District rules that apply to the same equipment or source type as the proposed rule or amendments. The discussion attached (Attachment A-1) contains a comparison of other requirements that apply to solvent cleaning operations.Attachment A Rule Consistency Analysis

Proposed amendments to Rule 240 will limit the VOC emissions from solvent cleaning operations. There

are EPA standards such as Best Av ailable Control Technology (BACT) and Lowest Achievable Emission Rate (LEAR) that apply to solvent cleaning operatio ns. There are also National Emission Standards for regulating the emissions of Hazardous Air Pollutants from solvent cleaning operations. This regulation is 40 CFR Part 63 Subpart T – Halogenated Solvent Emissions from Solvent Cleaning. Rule 240 exempts solvent degreasing operations regulated under 40 CFR Part 63 Subpart T from their requirements. Therefore, Rule 240 does not duplicate the NESHAP re quirements. The rule consistency matrixes for

Rule 240 is listed below in Attachments A-1.Page 2 Rule 240 – Surface Preparation and Cleanup Attachment A - Rules Consistency Matrixes



### Attachment A-1 40727.2 Matrix for Proposed Amendments to Rule 240

Elements of Comparison Specific

Provisions Rule 240 BACT/LEAR

Exemptions Cleaning operations using cleanup materials containing less than 50 grams per liter VOCs; Cleanup operations specifically regulated under other prohibitory rules; Other exemptions are specified in Section 104 of the rule. 10 lbs-VOC/day

Averaging

Provisions None None

Units Lbs-VOC/gal or grams of VOC/liter Lbs-VOC/gal or grams of VOC/liter

Emissions

Reduction Meet the VOC limits in Section 300 or use an airtight airless cleaning system or install air pollution control equipment Use of solvents for general cleanup with VOC limit less than 50 grams per liter; Use of air pollution control device such as after burner, carbon adsorption system; use of exempt solvent such as

acetone. Emissions Limits

Compliance

Alternatives 95% control efficiency and 90% collection efficiency. Reduce VOC emissions by add on air pollution control equipment and meet certain control and collection efficiency (generally >95%).

Operating

Parameters Operating parameters for air pollution control equipment are specified in

Section 404 of the rule. Store solvents in closed containers; Use of rags to clean parts and use of a rag washing machine with solvent reclamation system; Use of enclosed cleaning system.

Work Practice Requirements Application equipm ent requirements; Storage and disposal requirements; surface preparation and cleanup requirements. Application equipm ent requirements; Storage and disposal requirements; surface preparation and cleanup requirements.

Recordkeeping Recordkeeping of usage; recordkeeping for air pollution control equipment if

installed. Recordkeeping of usage and recordkeeping for air pollution control equipment. Monitoring

& Records

Frequency Daily for exemptions and monthly for sources subject to the rule. Daily records for air pollution control equipment; Monthly records for solvent

usage.

Test Methods Applicable test methods are specified

under Section 502 of the rule. Applicable test methods are the same as

those listed in Rule 240. Monitoring

& Testing Frequency No testing frequency is specified in the rule. However, source testing Will be required for initial compliance verification if air pollution control equipment is installed Testing frequency thereafter will be specified based on

need. Initial testing to verify system control efficiency; Annual testing thereafter.Attachment B

IDENTIFICATION OF ACHIEVABLE PERFORMANCE STANDARDS AND EMERGING

TECHNOLOGIES FOR SOLVENT CLEANING



### The California Clean Air Act requires districts unable to achieve five percent annual emission

reductions to demonstrate to the California Air Resources Board’s (CARB) satisfaction that it has included every feasible emission control meas ure in its plan and has an expeditious rule adoption schedule. According to CARB, no district has been able to de monstrate five percent (5%) annual reduction in ozone precursors. Therefore, every distri ct’s plan is evaluated on the basis of demonstrating adoption of “Every Feasible Measure.”

CARB has used the definition for “feasible” from the California Environmental Quality Act (CEQA) (14 California Code of Regulations, Section 15364). CEQA defines "feasible" as: “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors.” According to CARB the adoption of every feasible measure involves the adoption of regulations that have been successfully implemented elsewhere. CARB’s interpretation is explained at length in Iden tification of Achievable Performance Standards and Emerging Technologies for Sta tionary Sources, March 1998.



### On the following two pages, the District compare the requirements in Rule 240 with other similar rules adopted by SCAQMD, SMAQMD, and SJVUAPCD.Page 2 Rule 240 Surface Preparation and Cleanup

Attachment B - Identification of Achievable Performance Standards and Emerging Technologies for Solvent Cleaning

Rule 240

Exemptions – Rule 240 Rule 240 (as revised) SCAQMD SJVUAPCD SMAQMD 1. Cleaning with aerosol products if 160 fluid ounces or less per day are used.

2. Cleaning of electrostatic coating application equipment.

3. Cleaning of nozzle tips of automated spray equipment systems, except for robotic systems, and cleaning with spray bottles or containers if solvents used comply with

the VOC limits in Section

301.

4. Solvents with VOC content of 50 grams per liter

or less.

5. Cleaning of ink sterilization equipment with usage < 1.5 gallons per day.

6. Cleaning of application equipment used to apply coatings on satellites and radiation effect coatings.

7. Cleaning of electrostatic coating application equipment. 1. Cleaning with aerosol products if 160 fluid ounces or less per day are

used.

2. Cleaning of electrostatic coating application equipment.

3. Cleaning of architectural coating application equipment provided that the cleanup

solvent used does not exceed 950 g/l VOCs (Expires June 30, 2005).


### 4. Medical devices and pharmaceutical facilities using up to 1.5 gallons per day of

solvents.

5. Cleaning of nozzle tips of automated spray equipment systems, except for robotic systems, and cleaning with spray bottles or

containers if solvents used comply with the VOC

limits in Section 301.

6. Cleaning operations using cleanup material

with VOC content less than or equal to 50 grams per liter are exempt from the rule requirements. 1. Cleaning of architectural coating application equipment provided that the cleanup

solvent used does not exceed 950 g/l VOCs.

2. Cleaning method requirements do not apply if using 50 grams per liter VOC containing

solvents.

3. Cleaning in laboratory tests and analysis, or

research scale or

research and development projects.

4. Stationary sources using 55 gallons or less of solvents per a rolling 365 days.

5. Storage and disposal if using solvents with less than 50 grams per liter

VOC content.

6. One degreaser per building, which usesunheated, nonhalogenated solvents with open top surface

area of <1 m 2 and a capacity of <2 gallons.

7. Cleaning of flight electrical parts using

unheated nonhalogenated solvents. 1. Cleaning with aerosol products if 160 fluid ounces or less per day are

used.

2. Cleaning of electrostatic coating application equipment.

3. Cleaning of nozzle tips of automated spray equipment systems, except for robotic systems, and cleaning with spray bottles or

containers if solvents used comply with the VOC

limits in Section 301.

4. Solvents with VOC content of 50 grams per

liter or less.

5. Cleaning of ink sterilization equipment with usage < 1.5 gallons per day.

6. Cleaning of application equipment used to apply coatings on satellites and radiation effect coatings.

7. Cleaning of electrostatic coating application equipment.Page 3 Rule 240 Surface Preparation and Cleanup

Attachment B - Identification of Achievable Performance Standards and Emerging Technologies for Solvent Cleaning

VOC Limits – Rule 240

SJVUAPCD Cleanup Type Rule

240 SCAQMD

11/15/2002 11/15/2003 SMAQMD

Product Cleaning During Manufacturing Process or Surface Preparation for Coating, Adhesive, or Ink Application

General Electrical Apparatus and Electronic Components

Medical Devices and Pharmaceuticals 50

500

800 50

500

800 50

900 (33 mmHg) 900 (33 mmHg) 50

500

800 50

500

800 Repair and Maintenance Cleaning

General Electrical Apparatus and Electronic Components

Medical Devices and Pharmaceuticals Tools Equipment and Machinery

General Work Surfaces 50

900

800

600 50

900

800

600 50

900 (20 mmHg)

900 (33 mmHg) 900 (33 mmHg) 50

900

800

600 50

900

800

600 Architectural Coating Application Equipment Water based coatings Solvent based Coatings –

Jobsite and no Enclosed Gun

Cleaner 50

300 950

950 950

950 950

950 50

300Attachment C

Summary of Changes



### Rule 240, Surface Preparation and Cleanup

Existing

Section

Number New

Section

Number 

### Proposed Change

103 Added a new section for Severability to clar ify that if any provision of the rule is deemed invalid by court order, the rest of rule provisions remain in full force.

103 104 Revised this section to clarify it and to add new exemptions for various cleaning operations and process.

201

- Removed the definition of “Aerosol Pr oduct” and replaced it with new definition

for “Aerosol Cleaner” to be consistent with the rule.

201 Added a definition for "Adhesive”. This definition is same as the definition used in SMAQMD Rule 466, Solvent Cleaning.

202 Added a definition for "Aerosol Cleaner". This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

203 Added a definition for "Application Equipment". This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

202-203 204-205 Section renumbering

206 Added a definition for "Architectural Coatings Application Equipment Cleaning".

This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

204 Removed the definition of "Capture Efficiency".

205 Removed the definition of "Closed" since a new definition for closed container has

been added to the rule.

206 Removed the definition of "Control Device Efficiency".

NA 207 Added a definition for "Closed Containe r". This definition is similar to the definition used in SMAQMD Rule 454, Degreasing Operations.

208 Added a definition for "Coating". This defi nition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

209 Added a definition for "Degreaser". This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

210 Added a definition for “Electrical Appara tus Components” since it is used in the

rule. This definition is the same defin ition as that used in SMAQMD Rule 466, Solvent Cleaning.

211 Added a definition for “Electrical Appara tus Components” since it is used in the

rule. This definition is the same defin ition as that used in SMAQMD Rule 466, Solvent Cleaning.

207

- Removed the definition of “Electronic Assembly” since it is addressed under the definition of “Electronic Component”.

208

- Removed the definition of “Emission Control System” to clarify the rule.

209 212 Section renumbering.

NA 218 Added a definition for "Key System Op erating Parameters" since it is used in

Section 404.Page 2 Rule 240 – Surface Preparation and Cleanup Attachment C - Summary of Changes

- 214 Added a definition for “High Precision Opti cs” since it is used in the rule. This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

- 215 Added a definition for “Hot Line Tool” sin ce it is used in the rule. This definition

is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

- 216 Added a definition for “Ink” since it is used in the rule. This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

211

- Removed the definition of “Facility” to clar ify the rule since it is not used in the

rule.

212 217 Section renumbering.

- 218 Added a definition for “Key System Operating Parameter” since it is used in the

rule. This definition is the same defin ition as that used in SMAQMD Rule 466, Solvent Cleaning.

213 219 Revised the definition of "Liquid Leak" to clarify it.

214 220 Section renumbering.

215 221 Section renumbering.

222 Added a definition for “Medical Device” si nce it is used in the rule. This definition

is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

216 223 Section renumbering.

217 224 Section renumbering.

225 Added a definition for “Non-Compliant Solv ent” since it is used in the rule. This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

226 Added a definition for “Non-Leaking Contai ner” since it is used in the rule. This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

218 227 Section renumbering.

228 Added a definition for “Polyester Resin” since it is used in the rule. This definition

is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

229 Added a definition for “Prefabricated Ar chitectural Components” since it is used in

the rule. This definition is the same defi nition as that used in SMAQMD Rule 466, Solvent Cleaning.

219 230 Section renumbering

231 Added a definition for "Product Cleaning". This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

232 Added a definition for “Radiation-Effect Co ating” since it is used in the rule. This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

220-221 233-234 Section renumbering

235 Added a definition for “Scientific Instru ment” since it is used in the rule. This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

235 Added a definition for "Scientific Instrument". This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

222-226 236-240 Section renumbering.

241 Added a definition for "Sterilization Indi cating Ink". This definition is the samePage 3 Rule 240 – Surface Preparation and Cleanup Attachment C - Summary of Changes definition as that used in SMAQMD Rule 466, Solvent Cleaning.

227-230 242-245 Section renumbering.

231 246 Revised this section to clarify it.

232 247 Revised this section to clarify it and to remove the equation for calculation VOC composite vapor pressure. The calculation procedure is now lis ted under Section

400.

233 Removed this section from the rule sinc e the calculation procedures are addressed

under Section 400 of the rule.

248 Added a definition for "Volatile Orga nic Compounds (VOC) As Applied". This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

249 Added a definition for "Volatile Orga nic Compounds (VOC) As Supplied". This definition is the same definition as that used in SMAQMD Rule 466, Solvent Cleaning.

234 250 Section Renumbering

301

- Revised this section to include new VOC limits for various types of cleaning operations and to add the complianc e timelines for meeting these limits.

302

- Revised this section to clarify it and to include the different cleaning devices and methods permitted by the District.

303

- Revised this section to clarify it and to add the requirements for the emission control system.

304

- Revised this section to clarify it.

401 Removed this section and repl aced it with new Section 404.

401 Added a new section for determining VOC content of Cleaning Solvents including water and exempt compounds.

402 Added a new section for determining pe rcent control efficiency and VOC mass

emissions.

403 Added a new section for calculating VOC composite vapor pressure.

404 Added a new section for operation and maintenance plan which replaces Section

401.

405 Added a new section for requirements applicable to sellers of solvents.

402 406 Section renumbering.

501

- Revised this section to clarify the r ecordkeeping requirements and added a new section for retaining the records which replaces Section 502.

502

- Removed this section from this rule since it is now addressed under Section 501.

503 502 Revised this section reflect the most recent changes to the test methods required by

this rule. Added new section for determining volumetric flow rate.Page 4 Rule 240 – Surface Preparation and Cleanup Attachment C - Summary of Changes

Attachment D

VOC Emission Reductions for Placer County APCD Rule 240 Amendments

Current

Emissions Emission

Reductions EIC Code Description tpd tpd

23021683500000 Cleanup Solvents Coating Unspecified 0.00

23024032520000 Thinning and Cleanup Solvent – Mineral Spirits 0.04 0.03

23024083000000 Thinning and Cleanup Solvents - Coating 0.14 0.11

23024083020000 Thinning Solvents – Coating Unspecified 0.00

23024083500000 Cleanup Solvents Coating Unspecified 0.00

29999580000000 Other cleaning and surface Prep Solvents Unspecified 0.00

Total 0.17 0.14

Assumptions:

1. VOC reductions are based on an ov erall control efficiency of 78%.