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 County 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 Hearing, thereby adopting Amended Rule 240, 

Surface Preparation and Cleanup. 

Background:

 The proposed rule is included as a Volatile Organic Compound (VOC) control measure 

in the Sacramento Area Regional Ozone Attainment Plan, which was adopted by the 

Board on December 20, 1994. VOC emissions and 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 proven control measures and standards. 

Adoption of this amendment will establish greater 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 persons in Placer County who engage in the 

production, repair, maintenance or servicing of parts, products, tools, machinery or 

equipment, and storage and disposal of VOC-containing materials used in solvent 

cleaning operations. Partial or complete exemptions 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 devices and operations were added and language was revised 

for consistency. 

 Section 300, Standards: 

 The rule allows for a twelve-month time period 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-month period require lower VOC content in 

solvents and are more specific in describing various categories of equipment to be 

cleaned with varying VOC contents as appropriate. (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 relocated 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 rearranged and expanded as necessary, due to the 

increased number and type of materials discussed in the rule. 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 operations are expected to incur little or no increases, 

since many available solvents now contain Acetone (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 adoption of this rule is categorically exempt 

from the California Environmental Quality Act (CEQA) requirements per the CEQA 

Guidelines, Section 15307, Actions by Regulatory 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. Notification 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 November 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 additional 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 effective date of December 11, 2004, following 

adoption is an unusually long period to provide for this outreach and any operations 

changes necessary for compliance. 

Recommendation:

District staff recommend approval of Resolution #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, 2003
BACKGROUND

The District is proposing to amend Rule 240, Surface 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 State Implementation Plan (SIP) to reduce volatile 

organic compound (VOC) emissions from solvent cleaning activities. 

Solvent cleaning is an essential part of any manufacturing 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 equipment. 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 cleaning is done using cleanup materials containing 

VOCs or materials containing non-VOCs or exempt compounds (e.g., halogenated solvents, and 

non-halogenated solvents.) Some of the halogenated solvents are regulated by United States 

Environmental Protection Agency (USEPA) under 40 CFR Part 463, Subpart T – National 

Emission Standards for Halogenated Solvent Cleaning. 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 activities such as cleaning of electrical apparatus and 

electronic components, architectural coating application equipment, polyester resin application 

equipment, and automotive repair cleaning that have not been regulated. 

Rule 240

Rule 240, which regulates VOC emissions from solvent 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 air pollution control devices or airtight/airless 

cleaning systems 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 the 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 maintenance and repair of buses, aircraft, and trucks; 

cleaning of tools, machinery, equipment, 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 equipment 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 grease is required. Wipe cleaning is the cleaning of 

the surface by physically rubbing it with a material 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 solvent 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 returns 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 federal 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 November 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 percent per year (averaged over each consecutive 3-

year period beginning November 1993). Section 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 Reasonable 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 commitment 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 preparation 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 Plan, 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 general 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 similar 
applicable requirements adopted by these districts. 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 limitation 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 concentrations in downwind areas. The District is an 

identified transporter of air pollutants. The regulations require the District's plan must contain at 

minimum requirements for BARCT for source categories 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 basins or subregions that contribute to violation of 

the ambient air quality standard for ozone. The state board has identified the District as a 

transporter of air pollutants to the Upper Sacramento Valley and Broader Sacramento Area. 

Section 40910 of the California Health and Safety 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 standard for general maintenance cleaning. The 

proposed VOC standard is consistent with the standard 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 

San Joaquin Valley Unified Air 11/19/2002 

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 limits for cleaning of electrical apparatus and 

electronic components, medical devices and pharmaceuticals, 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 proposed 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 includes other requirements for cleaning electrical and 

electronic apparatus components, architectural application 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 airtight 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 cleaning operations not currently regulated. 

Those operations include wipe cleaning and cleaning 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 effort 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 coating 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 architectural coatings sold for use in California are 

water based (ARB's 1998 Architectural Coatings Survey Results Final Report.) Staff also found 

that the paint application equipment is either cleaned 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 coatings 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 from the lower VOC limit for cleanup solvents is 

expected to be minimal since only small percentage 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 concluded 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 Associates for Rule 4663, Organic Solvent, Cleaning, Storage, and 

Disposal amendments also concluded a modest impact for regional economy of the San Joaquin 

Valley. The impact on the SJVUAPCD economy was 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 Grams per Liter VOC Limit, Due to this Rule 

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

below. These costs are based on cost information 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 Pollution 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 and 14 bays. The shop purchased an aqueous spray 

cabinet and also an aqueous microbial sink-top unit. 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 Payback Period: 0.2 

Year

Note: The cost analysis above is based on replacing the 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, medical, 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 costs 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 gallon, 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 between $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 (Based 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 limits since they have been demonstrated to be 

technologically feasible (see Attachment B.) Staff also 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 reductions 
from 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 inventory 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 feasible VOC standards for surface preparation and 

cleanup. The adoption of limits equal to Sacramento 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 evaluated the proposed requirements to see if there 

are any significant adverse effects on the environment. 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, Amendments 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. inspections) work associated with these revisions will 

be met with existing resources and 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 reference. 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 records 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 Available Control Technology (BACT) and Lowest Achievable Emission 

Rate (LEAR) that apply to solvent cleaning operations. 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 requirements. 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 equipment requirements; 

Storage and disposal requirements; 

surface preparation and cleanup 

requirements. 

Application equipment 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 measure in its plan and has an expeditious rule 

adoption schedule. According to CARB, no district has been able to demonstrate five percent 

(5%) annual reduction in ozone precursors. Therefore, every district’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 Identification of Achievable Performance Standards and 

Emerging Technologies for Stationary 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 uses 

unheated, nonhalogenated solvents 

with open top surface 

area of <1 m2 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 

Cleanup Type Rule SJVUAPCD 

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 

300 
Attachment 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 clarify 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 Product” 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 Container". This definition is similar to the 

definition used in SMAQMD Rule 454, Degreasing Operations. 

208 Added a definition for "Coating". This definition 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 Apparatus Components” since it is used in the 

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

Solvent Cleaning. 

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

rule. This definition is the same definition 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 Operating 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 Optics” 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” since 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 clarify 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 definition 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” since 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 Solvent” 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 Container” 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 Architectural Components” since it is used in 

the rule. This definition is the same definition 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 Coating” 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 Instrument” 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 Indicating Ink". This definition is the same 
Page 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 listed under Section 

400. 

233 Removed this section from the rule since the calculation procedures are addressed 

under Section 400 of the rule. 

248 Added a definition for "Volatile Organic 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 Organic 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 compliance 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 replaced 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 percent 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 recordkeeping 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 

EIC Code Description Reductions 

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 overall control efficiency of 78%.