SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX C: Cost Effectiveness Analysis for Solvent Cleaning September 20, 2007

C-1 Final Staff Report with Appendices

for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules

APPENDIX C

COSTS AND COST EFFECTIVENESS ANALYSIS FOR

THE SOLVENT CLEANING PORTION OF ELEVEN DISTRICT RULES

SEPTEMBER 20, 2007
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX C: Cost Effectiveness Analysis for Solvent Cleaning September 20, 2007

C-2 Final Staff Report with Appendices

for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules

I. SUMMARY

The proposed changes for solvent cleaning fall into three categories. These categories 

are:

Removing exemption for cleaning architectural coating application equipment,

Lower VOC content limits for solvents used to clean printing presses, and

Lower VOC content limit for solvents used in general cleaning operations.

Table 1 shows the total estimated costs and cost effectiveness for the proposed 

changes to the solvent cleaning portions of the District’s rules.

Table 1 – Summary of Costs and Cost Effectiveness

Net Annual Cost ($/yr)

Cost Effectiveness 

($/ton VOC reduced)

Low End High End Low-End High-End

Remove exemption for 

architectural solvent cleaning $307,165 $3,474,807 $536 $6,059

Printing industry changes $115,325 $115,325 $3,052 $3,052

Other solvent cleaning changes $0 $0 $0 $0

Totals $422,490 $3,590,132 $347 $2,948

II. REASON FOR ANALYSIS

The California Health and Safety Code 40920.6(a) requires the San Joaquin Valley 

Unified Air Pollution Control District to conduct both an "absolute" cost effectiveness 

analysis and an “incremental” cost effectiveness analysis of available emission control 

options prior to adopting each Best Available Retrofit Control Technology (BARCT) rule. 

The purpose of conducting a cost effectiveness analysis is to evaluate the economic 

reasonableness of the pollution control measure or rule. The analysis also serves as a 

guideline in developing the control requirements of a rule. 

Absolute cost effectiveness of a control option is the added annual cost, in dollars per 

year ($/yr), of a control technology or technique, divided by the emission reduction 

achieved, in tons reduced per year. The costs include capital equipment costs, 

engineering design costs, labor and maintenance costs. Incremental cost effectiveness 

is intended to measure the change in costs, in $/yr, and change in emissions reductions 

in tons reduced/year between two progressively more effective control options or 

technologies. The incremental cost effectiveness compares the differences in costs and 

the differences in emissions reductions of candidate control options. Incremental cost 

effectiveness does not reveal the emission reduction potential of the control options. 

Unlike the absolute cost effectiveness analysis that identifies the control option with the 

greatest emission reduction, incremental cost effectiveness does not present any 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX C: Cost Effectiveness Analysis for Solvent Cleaning September 20, 2007

C-3 Final Staff Report with Appendices

for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules

correlation between emissions reductions and cost effectiveness. Therefore, the 

relative values produced in the incremental cost effectiveness analysis and the absolute 

cost effectiveness values are not comparable and cannot be evaluated similarly. 

III. COSTS AND COST EFFECTIVENESS

A. Source of Cost Data

Typically, VOC emission control systems utilize a regenerative thermal oxidizer (RTO) 

as the VOC destruction device. A single RTO costs hundreds of thousands of dollars to 

buy and install and tens of thousands of dollars to operate each year. It is believed that 

operators will comply with the VOC content limits proposed by this rule project by 

reformulating or diluting the current cleaning solvent, since it would be more economical 

to change solvents rather than install capital equipment like a RTO to meet rule 

requirements.

The proposed amendments for this rule project can be divided into three categories. 

The first category is the changes to the various cleaning operations associated with 

printing/graphic arts. Based on District staff’s research, the cost of cleaning solvent in 

55 gallon quantities is $7 per gallon and $10 per gallon of current and proposed VOC 

content, respectively.

The second category is the removal of the exemption for the cleaning of architectural 

coating equipment. In November 2003, SCAQMD staff revised SCAQMD Rule 1171 

(Solvent Cleaning Operations) to remove an exemption for the cleaning of architectural 

coating application equipment. This report also cited a California Air Resources Board 

(ARB) survey done in 2000 related to coatings usage in the state. District staff used 

similar assumptions as those used in the SCAQMD report to determine the gallons of 

cleaning solvent used annually and the cost of replacing high-VOC cleaning solvent with 

low-VOC cleaning material. 

The final category is the VOC content change from 50 g/L to 25 g/L for general cleaning 

and certain other cleaning operations. Based on an informal survey of cleaning solvent 

vendors, there would be no additional material cost for the change. Operators would 

reduce the VOC content of the currently used material by thinning it with additional 

water or other exempt solvent (e.g., acetone or methyl acetate). 

B. Cost Calculations

1. Remove exemption for cleaning of architectural coating equipment

Based on the SCAQMD staff report, high-VOC solvent cleaner averaged $5 per gallon. 

The low-VOC cleaner ranged in price from $6 to $21 per gallon. Operators would 

already be using the high-VOC material, so the difference between the low-VOC and 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX C: Cost Effectiveness Analysis for Solvent Cleaning September 20, 2007

C-4 Final Staff Report with Appendices

for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules

the high-VOC cleaners multiplied by the estimated annual cleaning material solvent 

would be the cost to operations from the proposed rule amendments. This means that 

the cost of compliance for removing the exemption for cleaning architectural coating 

application equipment is estimated between $1 and $16 per gallon. Current estimated 

usage of high-VOC solvent is about 190,000 gallons per year. Acetone is an exempt 

compound that has some solvent properties, but also is more volatile than many of the 

solvents it would replace. District staff assumed that 10% more acetone/methyl acetate 

would be used compared to current solvent usage or about 211,000 gallons per year of 

low-VOC material. By subtracting the current annual cost of high-VOC solvent cleaning 

material from the projected low-VOC cleaning material cost, estimated annual 

compliance cost would range from $310,000 and $3.4 million.

Table 2 – Annual Costs for Removal of Architectural Cleaning Exemption

Annual usage 

(gallons/yr)

Cost per 

gallon

Annual Cost 

($/yr)

Net cost 

increase 

($/yr)

Current high-VOC solvent 191,978 $5 $959,892 ---

low-cost option 211,176 $6 $1,267,057 $307,165

high-cost option 211,176 $21 $4,434,699 $3,474,807

2. Change in VOC content limits for printing/graphic arts cleaning operations

Current solvent usage was taken from emission inventory statements that certain 

facilities are required to file with the District. It was assumed that annual solvent usage 

would not change with the change in VOC content limit. The annual solvent usage was 

multiplied by the difference in cost between the current solvent and solvent with the 

interim VOC content limit as proposed in Proposed Rule 4607. As shown in Table 4, 

the annual cost for the proposed change totals about $115,000.

Table 3 – Annual Costs for Graphic Arts Applications

Print Process

Current Usage 

(gal/yr)

Solvent Cost ($/gal)

Total Annual Compliance 

Cost ($/yr)

Current 

solvent

After rule 

adoption

Flexography 1,078 $7 $10 $3,235

Lithography 36,750 $7 $10 $110,249

Gravure 614 $7 $10 $1,841

Total $115,325

3. Change general cleaning VOC content limit from 50 g/L to 25 g/L

District staff conducted research to find compliant cleaning solvent with 25 g/L VOC. It 

was found that the difference between 50 g/L solvent and 25 g/L solvent is the amount 

of dilution. Therefore, the difference in cost between the current compliant cleaning 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX C: Cost Effectiveness Analysis for Solvent Cleaning September 20, 2007

C-5 Final Staff Report with Appendices

for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules

solvent and the proposed cleaning solvent is zero, since the operator could use water to 

dilute the current cleaning solvent to meet the lower VOC content limit.

C. Absolute Cost Effectiveness Analysis

The absolute cost effectiveness is the added cost of implementing the proposed 

amendments divided by the estimated emission reductions. As outlined above, there 

are three different areas where VOC emission reductions are expected: the removal of 

the exemption for cleaning of architectural application equipment, changes in the VOC 

content limit for cleaning printing/graphic arts application equipment, and changes in all 

other solvent cleaning VOC content limits. Table 4 below summarizes the costs and 

cost effectiveness for each of these changes. For architectural coatings, the range in 

cost effectiveness is about $540 to $6,000 per ton VOC removed. Cost effectiveness 

for changes to printing cleaning is estimated at $3,100 per ton. All other solvent 

cleaning changes have no net annual cost; therefore the cost effectiveness is $0 per ton 

VOC removed.

Table 4 –Costs and Cost Effectiveness Analysis

Net Annual Cost ($/yr)

Estimated VOC 

Emission 

Reductions (tpy)

Cost Effectiveness 

($/ton VOC reduced)

Low End High End Low-End High-End

Remove exemption for 

architectural solvent cleaning $307,165 $3,474,807 573.5 $536 $6,059

Printing industry changes $115,325 $115,325 37.8 $3,052 $3,052

Other solvent cleaning changes $0 $0 606.7 $0 $0

Totals $422,490 $3,590,132 1,218.0 $347 $2,948

D. Incremental Cost Effectiveness Analysis

Incremental cost effectiveness is intended to measure the change in costs, in $/yr, and 

change in emissions reductions in tons reduced/year between two progressively more 

effective control options or technologies. For this rule project, the limits are considered 

the lowest achieved in practice. Installing VOC control equipment would not reduce 

emissions beyond that mandated by the low VOC content limits. This means that there 

are no additional VOC emission reductions to be realized by installing a VOC emission 

control device. Therefore, no incremental cost effectiveness analysis was conducted.
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX C: Cost Effectiveness Analysis for Solvent Cleaning September 20, 2007

C-6 Final Staff Report with Appendices

for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules

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