SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

Final Staff Report for

PROPOSED RULE 1144 – VANISHING OILS AND RUST INHIBITORS

Dated: March 2009

Deputy Executive Officer Planning, Rule Development, and Area Sources Elaine Chang, Dr.PH

Assistant Deputy Executive Officer Planning, Rule Development, and Area Sources Laki Tisopulos, Ph.D., P.E.

Planning and Rules Manager VOC Rule Development Larry M. Bowen, P.E.

Author: Mike Morris AQ Specialist

Reviewed by: Naveen Berry Planning and Rules Manager

Linda Vogel Senior Deputy District Counsel

Contributors Heather Farr AQ Specialist John McLaughlin Senior AQ Chemist Joan Niertit Principal AQ ChemistSOUTH COAST AIR QUALIT Y MANAGEMENT DISTRICT

GOVERNING BOARD

Chairman: WILLIAM A. BURKE, Ed.D. Speaker of the Assembly Appointee

Vice Chairman: S. ROY WILSON, Ed.D. Supervisor, Fourth District Riverside County Representative

MEMBERS:

MICHAEL D. ANTONOVICH Supervisor, Fifth District Los Angeles County Representative

MICHAEL CACCIOTTI Councilmember, City of South Pasadena Cities Representative, Los Angeles County, Eastern Region

BILL CAMPBELL Supervisor, Third District Orange County Representative

JANE W. CARNEY Senate Rules Committee Appointee

RONALD O. LOVERIDGE Mayor, City of Riverside Cities Representative, Riverside County

JOSEPH LYOU, Ph.D. Governor’s Appointee

JOSIE GONZALES Supervisor, Fifth District San Bernardino County Representative

JAN PERRY Councilmember 

### , 9 th 

### District City of Los Angeles

MIGUEL PULIDO Mayor, City of Santa Ana Cities Representative, Orange County

TONIA REYES URANGA Councilmember, City of Long Beach Cities Representative, Los Angeles County, Eastern Region

DENNIS YATES Mayor, City of Chino Cities Representative, San Bernardino County

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env.

## TABLE OF CONTENTS

Section Page Executive Summary 1 Background 2 Proposed Rule 4 Emission Inventory 10
Emission Reductions 13
Cost and Cost-Effectiveness 15
Incremental Cost-Effectiveness 17 Comments and Responses 19 Comparative Analysis 37
Socioeconomic Assessment 37 California Environmental Quality Act (CEQA) 38 Draft Findings under the Californi a Health and Safety Code 38
References 38

APPENDIX A – Vanishing Oil and Rust In hibitor VOC Content Test ResultsFinal Staff Report ________________________________

Proposed Rule 1144 1 March 2009 EXECUTIVE SUMMARY

Proposed Rule 1144 is designed to reduce VOC emissi ons from the use of vanishing oils and rust
inhibitors used at industrial faci lities during the manufacturing a nd assembly process of parts and products.

Vanishing oils and rust inhibi tors are categorized under miscellaneous solvent operations. A vanishing oil is a direct-contact lubricant or meta l working fluid that comes into direct contact with the product or part during manufacturing or assembly to reduce heat and friction, prolong the life of tools and machinery, improve product qua lity or carry away debr is. A rust inhibitor prevents or protects metal surfaces from corrosion.

Most vanishing oils and rust inhibitors are cu rrently subject to Rule 442 - Usage of Solvents,
which addresses VOC emissions from VOC-containing materials that are not subject to VOC limits in any Regulation XI rule. A small subset of aerospace fastener lubricative coatings are subject to Rule 1124 – Aerospace Assembly and Component Manufact uring Operations. Although the California Air Resources Board (CARB) regulates consumer lubricants, currently, no other local, state or federal re gulations or emissions restricti ons specifically pertaining to industrial vanishing oils or rust inhibitors.

The proposed rule will apply to VOC emissions fr om steel tube and spri ng manufacturers, steel mills, aerospace manufacturers, automobile part manufacturers and rebuilders and machine shops including broaching, drilling, drawing, form ing, forging, grinding, heading, honing, milling, stamping, tapping, thread cutting and turning operations.

Staff proposes the following requirements for Proposed Rule 1144:

• Establish a VOC limit of 50 grams per liter (g/l) of material for vanishing oils and a VOC limit of 300 g/l of material for rust inhib itors effective January 1, 2010, with a further reduction to 50 g/l effective January 1, 2012.

• Prohibit the sale of non-compliant vanishing oils and rust inhibitors. Exceptions are made for fluids subject to CARB consumer products regulation found in Title 17 of the California Code of Regulations, beginning at Section 94507.

• Allow vanishing oils and rust inhibitors manufac tured prior to the appropriate effective date to be sold or applied for six months.

• Require containers for vanishing oils and rust inhibitors to di splay the date of manufacture.

• Exempt certain applications, including lapping, si nker electrical discha rge machining (EDM), high profile aircraft corrosion inhibitors and aerosol aeros pace rust inhibitors where
alternative low-VOC formulations are not availa ble. Exempt rust inhibitors subject to a military specification, military standard or Pr oduct Part Approval Process (PPAP) as well as consumer products from VOC limits until January 1, 2011.

If approved, the proposed rule amendments will partial ly fully implement s control measure CTS01 in the 2007 Air Quality Management Plan. The resolutions to the rule will include a technology review to be completed by July September 1 , 2009 to resolve technical issues with the VOC content test method, evaluate potential screen ing tools for high wate r content samples, and develop VOC limits for other direct-contact lubricants and metal working fluids besides vanishing oils.Final Staff Report ________________________________

Proposed Rule 1144 2 March 2009 As proposed, the rule will reduce emissions by 2.71 tons per day with an estimated annualized cost of $8.1 million dollars. The overall cost-effec tiveness of the proposed rule is conservatively estimated to be $8,189 per ton of VOC emissions reduced.

BACKGROUND

Nationally, some 1.2 million workers are employed in machine finishing, machine tooling, and other metalworking and metal-forming operations th at use lubricants, metal working fluids or
rust inhibitors. In its Fabricated Metal Sector Notebook (1995), EPA estimates 10.2 percent of the fabricated metal industry are located in Cali fornia. According to listings in the California Manufacturers Register, the South Coast Air Basin accounts for a pproximately 70 percent of the industry in California. In 2008, there are more than 12,000 machine shops in the 4 county area serviced by AQMD. Of these machine shops, th e U.S. Census (2002) estimates that 88 percent have fewer than twenty employees . Typical industries using lubricants, meta l working fluids and
rust inhibitors include:

• Aerospace

• Machine Shop (Job Shop)

• Steel Mills

• Auto Rebuild

• Screw Machine

• Steel Tubes (Pipes)

• Steel Springs

• Captive

Captive machine shops are machine shops located in side of another type of business (aerospace, automotive, etc.) that supports th e business but are not the primary aspect of that business.

Metal working shops tend to be small businesses that generally do not use paints, coating, inks or adhesives, routinely use very low VOC content cleaning solvents, and ha ve limited interaction with the AQMD. Rule 219 – Equipment Not Requiring a Written Permit Pursuant to Regulation II, exempts machining equipment that use lubrican ts, metal working fluids and rust inhibitors
with VOC contents less than 50 grams per liter (g/l) or a VOC composite partial pressure of 20 mm Hg. Nearly all lubricants, metal working flui ds and rust inhibitors, including those with a high-VOC content, have a VOC composite of 5 mm Hg or less. Thus metal working shops rarely have permits with the Distri ct. Typical operations include:

• Broaching – Gear manufacturing util izing keyway, slots or spline.

• Drilling – Producing cylindrical holes

• Drawing – Forming flat sheet metal into “cup- shaped” parts. If the depth of the formed cup is equal to or greater than the radius of the cup, the process is called deep drawing.

• Forming – Spinning metal until a de sired thickness is achieved.

• Forging – Shaping metal by using localized comp ressive forces. Cold forging is done at
room temperature or near room temperature. Hot forging is done at a high temperature, which makes metal easier to shape and less li kely to fracture. Co mmon forging processes include: roll forging, swaging, cogging, open-di e forging, impression-die forging, press forging, automatic hot forging and upsetting.

• Grinding – Producing a fine finish using an abra sive wheel or belt.Final Staff Report ________________________________

Proposed Rule 1144 3 March 2009 • Heading – A metal forging process that invo lves rapidly punching a blank into a die to form a desired shape without adding heat. Co ld heading is most frequently used to produce fasteners such as bolts and screws without adding heat.

• Honing – Manufacturing of precision bores to improve the geometry, surface finish and dimensional control of the finished part.

• Milling – Cutting using a precisely controlled rotating cutter whic h rotates about the spindle axis and a table to which the workpi ece is affixed. The cutter and workpiece move relative to each other, generating a toolpath along which ma terial is removed.

• Rust Preventative/Inhibitor – Preventing corrosion on ferrous materials and some
nonferrous materials

• Stamping – Punching sheet metal strips using a pre ss tool which is lo aded on a press to form the sheet into a desired shape.

• Tapping – Creating threaded holes in part s or boring into parts and pipelines

• Threading – Thread cutting and thread ro lling applications for pipes and bolts

• Turning – Producing cylindrical parts

• Wire drawing – Reducing or changing the diamet er of a wire or rod by pulling the wire or rod through a single or series of drawing die(s).

Lubricants, metal working fluids and rust inhibitors are complex mixtures of oils, emulsifiers, anti-weld agents, corrosion inhibitors, extreme pr essure additives, buffers (alkaline reserve), biocides, and other additives. Some products cont ain extreme pressure (EP) additives containing chlorinated, sulfurized, or phos phorus-type extreme pressure ingredients. There are numerous formulations, ranging from straight oils (such as petroleum oils) to water-based fluids, which include soluble oils and semi-synt hetic/synthetic fluids. In gene ral, higher oil content provides better lubricity while higher water content allows more rapid cooling.

• Straight oil (neat oil) fluids are refined petroleum or vegetabl e oils. Straight oils are not designed to be dilute d with water.

• Soluble oil (emulsifiable oil) fluids are combinations of 30 percent to 85 percent straight oils and emulsifiers that may include other performance additives. Soluble oils are diluted with 5 to 40 parts water.

• Semi-synthetic fluids contain a lower amount of straight oil in the concentrate (5 percent to 30 percent), more emulsifiers, and 30 per cent to 50 percent water. The concentrate is further diluted with 10 to 40 parts water.

• Synthetic fluids contain no petroleum oils and may be water soluble or wa ter dispersible. The synthetic concentrate is diluted with 10 to 40 parts water.

In preparation for potential rule making act ivity, the AQMD and U.S. EPA Region IX cosponsored a report by the Instit ute for Research and Technical Assistance to id entify, te st and
demonstrate alternative low-VOC materials for vani shing oils and rust inhi bitors. Completed in 2006, the report, Assessment, Development and De monstration of Alternatives to VOC-Emitting Lubricants, Vanishing Oil and Rust Inhibitors concludes that “alternative low-VOC materials for a variety of different types of metal working operations are available and cost effective.” Thirteen facilities par ticipated in the study that reviewed stamping, honing, cutting, forming and rust inhibitor applications. In each hi gh-VOC application, a low-VOC alternative was demonstrated to have equivalent performance. Some of the participants found that their cost increased with the alternatives, but th e majority realized a cost-savings.Final Staff Report ________________________________

Proposed Rule 1144 4 March 2009 PROPOSED RULE

Staff proposes the following requirements for PR 1144:

Purpose and Applicability The purpose of the proposed rule is to reduce VOC emissions from vanishing oils and rust
inhibitors used at industrial facilities during manufacturing operat ions where the fluids come in direct content with the parts and products. Such operations will include metal working or metal removal activities during the manufacturing and a ssembly of products and goods. Examples of these activities include, but are not limited to, broaching, drilling, draw ing, forging, grinding, heading, honing, milling, stamping, tapping, thread cu tting, turning and wire drawing. Fluids used for rust and corrosion prevention and inhi bition during manufacturing and assembly of products and goods are also included.

Initially, the focus will be to limit solvent emissi ons from vanishing oils and solvent-based rust inhibitors. Vanishing oils are de fined as lubricants or metal wo rking fluids with a flash point less than 200 °F (93°C). In the near future, VOC limits will be establis hed for direct-contact lubricants and metal working fluids. The proposed rule is not intended to regulate the use of vanishing oils or rust inhibito rs for commercial, institutional or household use. Repair and maintenance activities are also not subject to th e rule unless the parts on which the fluids are applied are resold. For example, parts taken from machinery or vehicles that are repaired using fluids and then placed back into the same mach inery or vehicles are no t covered by the rule. Likewise, general maintenance and rust inhibiti on of buildings, vehicles or equipment are not subject to the rule. Examples include motor oi l, elevator grease, and care and maintenance of door hinges. Finally, vanishing oils that do not dire ctly come into cont act with parts and products during manufacturing, such as turbine oil, enclosed spi ndle oil and hydraulic fluids are not subject to the rule.

Operations and substances already subject to VO C limits in Regulation XI will not be subject to the limits, labeling requirements an d prohibition of sales proposed in this rule. Such substances include solid film lubricants, dry lubricative mate rials and barrier coatings subject to Rule 1124. Paints and coatings intended to completely cure and leave a solid, permanen t film to beautify and protect metal surfaces are subject to other coating rule s in Regulation XI and are not subject to this rule. Examples include aerospace, architec tural, auto body, and metal paints and coatings where applicable VOC limits are in Rules 1113 – Architectural Coatings, Rule 1124, Rule 1151 – Motor Vehicle and Mobile Eq uipment Non-Assembly Line Co ating Operations and Rule 1107 – Coating of Metal Parts and Products, respectively.

A prohibition of sale is included in the rule. Thus, the propos ed rule also applies to anyone who manufactures for use, supplies, soli cits, sells or offers for sale va nishing oils and rust inhibitors subject to the rule. Consumer products subject to the CARB consumer products regulation found
in Title 17 of the California C ode of Regulations, be ginning at Section 94507, are also exempted from the prohibition of sale. As noted above, th e use of vanishing oils and rust inhibitors in households and general maintenance of buildings, vehicles or equi pment is also not subject to this rule. But, consumer produc t vanishing oils and rust inhib itors used during manufacture and assembly of products and goods are subject to this regulation, effe ctive January 1, 2011; facilities using such products must meet the applicable VOC content limits.Final Staff Report ________________________________

Proposed Rule 1144 5 March 2009 Requirements The proposed rule will establish a VOC limit of 50 g/l of material for vanishing oils and a VOC limit of 300 g/l of material for ru st inhibitors effec tive January 1, 2010, with a further reduction to 50 g/l effective January 1, 2012. The VOC content limits apply to the fluids as they are used, including dilution. Water or exempt solvents ar e included when calculating material volume. Thus, a rust inhibitor concentrate with a VOC cont ent of 75 g/l that is diluted with water at a ratio of two parts water to one part lubricant concentrate (2:1) would have a VOC content of 25 g/l. Many soluble, semi-synthetic and synthetic fl uids are heavily diluted with water when used. Typical dilution ratios range from five parts water to one part concentrate to 40 or more parts water to one part concentrate. Evaporation and contamination during use will cause the VOC content to fluctuate. Manufacturers and suppliers believe the fluctuation could be as high as 30 percent. This could cause fluids with 25 g/l VOC content to increase to nearly 35 g/l VOC content without regular monitoring. Monitoring th e fluid beyond what is n ecessary to facilitate proper operating parameters wi ll increase labor costs.

An estimated 89 percent of lubricants and metal working fluids have a VOC content of 200 g/l of material or less after dilution. The soluble, semi-synthetic and synthetic metal working fluids have low VOC because of the high water content of those fluids. However, many straight oils have low VOC because they are essentially non-volatile.

Low-VOC alternatives to vanishing oils are ava ilable, and in most cases exclusively used for broaching, drilling, drawing, forging, heading, honing, milling, tapping, threading, turning and wire drawing. Most cutting and grinding appli cations also use low-VOC products as well as nearly all coolants and lubricants.

Light Oils Light oils with viscosities lower than 20 centis tokes at 40°C, but flashpoints greater than 200°F

, are used as viscosity additives, lubricants for older high speed spindle machines and as metal working fluids for other applications. Newe r spindle machines use heavily water-diluted products and are designed to be resistant to water co rrosion while older machines are not. Based on discussions with industry, and recogniz ing the use of light, high flash point oils as metal working fluids, VOC limits will be established after technical issues regarding the test
method have been resolved.

Vanishing Oils Vanishing oils are designed to evaporate off qu ickly leaving no residue. They are typically comprised primarily of solvent such as kerosene or mineral spirits a nd commonly are just the
neat solvent themselves. Conventional vanishin g oils have VOC conten ts ranging from 600 g/l to 750 g/l with flash points below 200°F. Vanish ing oils leave a light co ating of lubricant on the part during processing and then evaporate shortly thereafter. They need to provide enough lubricity to prevent machinery and parts from se izing, but they provide ve ry little protection to tooling. They are used because they evaporat e and later cleaning operations are unnecessary. Vanishing oils should not leave behind tacky or gummy residues. Because parts on which vanishing oils are applied are not cleaned afte rwards, the vanishing oil must not encourage corrosion and may even provide some small amount of corrosion protection.

Alternatives to high solvent content vanishing oils include water-dilutable metal working fluids and straight oils. Water-dilutable metal working fl uids used in a vanishing oil applications have sufficient rust preventative com pounds to protect parts when the water evaporates. They provideFinal Staff Report ________________________________

Proposed Rule 1144 6 March 2009 sufficient lubricity but, like traditional vanishing oils, provide little tooling protection. Because they are so dilute, they evaporat e leaving a dry, light pr otective film that is not tacky or gummy.
Parts machined in this manner were found to ha ve similar or superior corrosion protection to parts machined with conventional solvent-based vanishing oil, and did not require subsequent cleaning according to an AQMD co-sponsored report, “Assessment, Development and
Demonstration of Alternatives to VOC-Em itting Lubricants, Vanishing Oils and Rust Inhibitors.” The high water content of the wate r-dilutable metal working fluids used in these applications makes them less e xpensive than vanishing oils.

Use of a high flash point oil as a vanishing oil al ternative could also provide acceptable results in certain situations. There would be little if any ev aporation, but the residue would not be tacky or gummy and corrosion protection would be excellent . Cleaning would be required, however, and would increase to some extent, f acility’s processing cost. Theref ore, with consideration for the numerous compliant alternatives available, the proposed limits for vanishing oils have an implementation date of January 1, 2010.

Rust Inhibitors
The rule will limit rust inhib itors, including rust preventatives and corrosion inhibitors, to a VOC content of 300 g/l or material by January 1, 2010, with further reductions to 50 g/l of material in
2012. Some facilities use rust inhibitors that are nearly identical in composition and VOC content to vanishing oils. Metal parts are coated , usually by dipping or application by rag, with a formulation of solvent such as mineral spirits or kerosene that may also contain small amounts of
heavier oils and/or wax. The solvent evaporates away, leaving behind a small amount of heavier oil, wax or trace amounts of the solvent that coats th e metal surface with a water repellent or protective layer. The heavier oils and wax provide much more protection than does the evaporated solvent.

Water-based rust inhibitors have very low VOC c ontent after dilution and are formulated to leave behind a nearly invisible protectiv e coating after the water evaporat es. The protective coating is soluble in water but still protects steel, cast iron, and other ferrous parts from in-plant corrosion and outdoor shipping environments. An added bene fit of the coating is that it can be easily removed using mild aqueous cleaners if required. Water-based rust inhibitors are comparable in price to the solvent-based rust inhibitors.

Alternative high flash point straight oil rust inhibitors coat a meta l surface with an oil that rejects water. Over a long time the oil may thicken into a nearly solid protective coating. These products provide excellent long-t erm protection and while they have a higher cost per gallon, they are superior in quality to most high VOC pr oducts. Straight oil rust inhibitors may contain small amounts of solvents, and the VOC content of such products tested ranges from less than 25 g/l to 253 g/l. Labora tory testing results of rust inhi bitors, using EPA Test Method 24, is
summarized in Table I.

Table I – VOC Content of Rust Inhibitors

Cleaner/Rust Inhibitor 121 – 765 g/l Consumer/General 530 g/l Rust Inhibitor 12 -420 g/l Rust Inhibitor/Stamping 295* - 380 g/l

*Before dilutionFinal Staff Report ________________________________

Proposed Rule 1144 7 March 2009 A use and sell-through provision has been included in this rule that will allow products
manufactured before the effective date of the rule to be sold and used for up to six months after
the effective date. This will allow manufacturer s, suppliers and users to deplete their existing
inventories. To facilitate this provision, manufacturers and supplie rs will be required to display
the date or a date code of manufacture on the container beginni ng January 2010.

Sale in the AQMD of vanishing oils and rust in hibitors, is prohibited unless they meet the VOC limits of this rule. The prohibition will not apply to products sold in this District for shipment outside of this District or for shipment to othe r manufacturers for repack aging. It will also not apply to fluids subject to CARB consumer produc ts regulation, as set fo rth in Title 17 of the California Code of Regulations , beginning at Section 94507. Th ese provisions will help to redirect some of the burden of determining the compliance status of products from the machine shops and other users to the manufacturers a nd suppliers who are more familiar with VOC
determination.

The prohibition of sale will apply to manufacturers and suppliers who manufacture for use, sell,
offer for sale or distribute di rectly. Manufacturers that se ll products through independent distributors may be able to discha rge liability unde r this provision, provided they forewarned the independent distributors in wr iting about the compliance status of the product. However, independent distributors will be subjec t to the prohibition of sale.

A provision has been included that allows a facili ty, if it so chooses, to use high-VOC vanishing
oils and rust inhibitors where the emissions ar e vented to a control de vice that has a capture efficiency of 90 percent or more on a mass basis and a control effi ciency of 95 percent or more on a mass basis, or to a maximum 5 ppm VOC by volume from the exhaust. While it is very unlikely that any facility will install a control devi ce just to meet th e proposed rule, some facilities already have control devices that control emissions from work areas that contain vanishing oils or rust inhibitors. In those in stances, the emissions are already being reduced and further restrictions are unnecessary.

Recordkeeping Requirements Many of the facilities subject to the provisions of this rule are small businesses with limited
interaction with the District. Those small fac ilities with operations and equipment that do not use paints, coatings, solvents or adhesives an d do not require permits with the District are unlikely to have had experience in keeping daily records. Rule 109 – Recordkeeping for Volatile Organic Compound Emissions requires stationary sources using VOC c ontaining materials to keep records to determine rule applicability an d rule compliance. Records are usually required on a daily basis, but for most of the product categories the materi al VOC content of products in use are below 50 g/l. Products w ith VOC contents, after applicable dilution, of less than 50 g/l are “Super Compliant Materials” and qualify for ex emption from recordkeep ing at facilities that
do not exceed four tons of VOC emissions in any calendar year, determined by annual recordkeeping. Facilities that emit more than f our tons of VOC annually may qualify for the monthly recordkeeping option.

Test Methods and Procedures While there is no formal regulatory requirement to use a particular test method for determining VOC content of lubricants, metal working fluids or rust inhibitors, the default method used is U.S. EPA Reference Method 24 (Method 24). Met hod 24 was originally de signed to determine the VOC content of coatings and inks only. Si nce there is no other U.S. EPA approved testFinal Staff Report ________________________________

Proposed Rule 1144 8 March 2009 method for determining VOC content of vanishing oils and rust inhibitors, Method 24 will be included as the approved test method. Method 24 determines the VOC content of a product by measuring the water and the non-volatile fracti on. The remainder is considered VOC (less exempt solvents). The non-volatile fraction is de termined by placing the sample in a forced air over at 110°C for sixty minutes. Duplicates samples are run to validate the results. However, Method 24 does provide accurate and repeatable re sults for relatively high VOC content solventbased materials. Until technical issues regardin g other test methods have been resolved, it will
be used to determine VOC content.

Future Alternative VOC Content Test Methods An alternative method is SCAQMD Method 313 – Determination of Volatile Organic Compounds (VOC) by Gas Chromatograph/Mass Sp ectrometry (GC/MS), originally approved for use in 1991. The principle of this U.S. EPA-a pproved method is to inject a liquid sample into
GC/MS and sum the concentrations of the indivi dual compounds. The oven is initially at 50°C and kept there for five minutes. It is ramped up 15°C per minute until th e sample reaches 200°C,
then held at 200°C for fifteen minutes. The to tal specified sampling period is 30 minutes, and previous testing has indicated that methyl palmitate elutes at the 30 minute mark. All compounds, besides water and exempt solvents, that elute prior to methyl palmitate are
considered to be VOC.

In November 2008, the District revised th e test method to SCAQMD Method 313L – Determination of VOC Hydrocarbon Compounds in Lubricants, primarily to accommodate equipment changes. The column type (DB624) a nd length of column (30 meters) have changed, thereby changing the times when various peaks app ear. However, the order of the peaks remains unchanged and methyl palmitate will continue to be used as the marker compound defining volatility. The temperature in the GC oven will con tinue to be raised after the methyl palmitate peak is reached until the entire sample elutes. Only peaks that occur at or before the methyl palmitate peak are considered when determining VOC content by quantifying the peaks using a Flame Ionization Detector (FID). By specify ing the column type and length, the flow and temperature may be varied without altering the VOC content results as long as the methyl palmitate marker compound is iden tified. This would be useful when trying to further resolve peaks especially when water or exempt compounds are present. The revised protocol is referred
to as a GC/FID method. Method 313L has been used extensively for low-VOC solvents and consumer products certified by the AQMD in its Clean Air Solvent and Clean Air Choices Cleaner certification programs. The results from the certification program have shown the method to be reliable and accurate for both high water content and heavy, high flash point oil products. However, independent and industry labor atories are not familiar with this method and have requested round-robin testing, particularly with re spect to high flash point heavy oils used
as direct-contact lubricants a nd metal working fluids. VOC limits for those categories will be
established after technical i ssues have been resolved.

Industry has suggested thermogravimetric analysis (TGA) testing as an alternative method to determine VOC content. TGA determines changes in weight relative to time and temperature. It has been suggested that it would provide more repeatable results for heavy, high flash point oils. However, issues such as determining the paramete rs of the test (time and temperature) and high water content samples have not been resolved. Th e District will continue to review TGA testing as a possible alternative test method to Method 24.Final Staff Report ________________________________

Proposed Rule 1144 9 March 2009 The District has committed to conduct round robi n testing of Method 313L and TGA. This will provide sufficient time to establis h the validity of an alternativ e test method to Method 24. It will also determine the parameters to be used for TGA testing. During the round robin testing, if appropriate, a screening tool will be developed to minimize testing cost s for high water content samples that would have negligible VOC. Many of the high water content samples are emulsions of high flash point oils and surfactants . As noted above, the VOC content of the high flash point oils are unresolved and, once resolve d, will have an impact on what screening value to designate. It is also possible that Me thod 313L will be validated for high water content samples making a screening tool unnecessary. Th is commitment has been included in the Resolutions to be adopted with the proposed rule.

Test methods to determine flash point and the capt ure and control efficiency of a control device
are also included.

Exemptions Some highly specialized applications have be en exempted from the proposed regulation. Lapping and sinker EDM are small usage applica tions (less than 0.01 and 0.03 tons per day of VOC emissions, respectively) where alternative low- VOC formulations have not been identified. Rust inhibitors and vanishing oils used on assemble d aircraft and avionics will also be exempted. These fluids provide protection fo r flight instruments and major aircraft structures including upper edge floor beams, wheel wells, pressure decks and center wing sect ions. VOC emissions from these specifically exempted aerospace opera tions are less than 0.002 ton per day. Finally, small very specialized operations conducted on space vehicles components, where fluids may adsorb into coatings and adhesives and then o ff-gas when the spacecraft reaches outer space, will also be exempted.

An exemption that expires January 1, 2011 has b een included for rust inhibitors used in association with military specifications, military standards, Department of Defense documents or Production Part Approval Processes. Based on feedback from industry, especially end-users, additional time is necessary to conduct replacemen t trials, determine cust omer acceptability and to make changes to military specific ations and/or PPAP specifications.

Exemptions for consumer products to the rule’s labeling requirements and sales prohibition are included in the proposed rule. These products are already subjec t to Title 17 of the California Code of Regulations, beginning at Section 94 507, also known as the California Consumer Product Regulation. The California Consumer Product Regulation includes statewide labeling requirements and a sales prohibiti on for consumer products, and th e proposed rule will not add further requirements. The use of these prod ucts during the manufacture and assembly of products and parts, will also be exempted until January 1, 2011. Afterwards, consumer products used during manufacturing and a ssembly must meet the same VO C limits as industrial products. Regulation of VOC content at st ationary sources falls squarely within the long-established authority of air districts. There is no reason to encourage their use, with corresponding higher VOC content, by providing a blanket exempt status. From a survey done of local machine shops, there will be a one year delay in approxi mately 0.007 tons per day of VOC emissions.

Vanishing oils and rust inhibi tors used in a controlled envi ronment, where emissions are captured by a control device, are not subject to the VOC limits nor are they subject to the rule’s prohibition of sales provision. Pursuant to subparagraph (i)(5 )(E), manufacturers and suppliers of high-VOC vanishing oils and rust inhibitors should positively identify facilities that will beFinal Staff Report ________________________________

Proposed Rule 1144 10 March 2009 using their products in a controlled environm ent before selling otherwise non-compliant products. Likewise, vanishing oils and rust inhibitors manufactured or sold for use outside the District will not be subject to the labeling require ments of the proposed rule. The intent of the proposed rule is to regulate onl y the products being manufactured or sold for use inside the
District.

Finally, vanishing oils and rust inhibitors alrea dy subject to VOC limits in Regulation XI will not be subject to the limits, labeling requirements a nd prohibition of sales proposed in this rule. These will include solid film lubricants, dry lubricative materials and barrier coatings subject to Rule 1124. Paints and coatings intended to comple tely cure and leave a so lid, permanent film to beautify and protect metal surfaces are also exempt . Paints and coatings are subject to other coating rules in Regulation XI.

EMISSION INVENTORY

The overall national inventory of metal worki ng fluids was taken from the International
Lubricant Manufacturers Associati on (2003). It indicates that 117 million gallons were sold nationwide (see Table II).

Table II – National Sales

Lubricant and Metalworking

Fluid Type Amount Sold (millions of gallons/year) Straight 27.3

Soluble 49.3 Semi-Synthetic 21.7 Synthetic 18.9

Total 117.2

EPA, in its Fabricated Metal Sector Notebook (1995), estimates 10.2 percen t of the fabricated metal industry is located in California. Acco rding to listings in th e California Manufacturers Register, the Basin accounts for approximately 70 pe rcent of the industry in California. This would indicate that 8.3 million gallons of industri al lubricants and metal working fluids were sold in the Basin in 2006 (see Table III).

Table III – Ratio of National Sale s to South Coast Air Basin Sales

Lubricants and Metal Working
Fluid Amount Sold
Nationwide (millions of gallons/year) Amount Sold
in California

(millions of gallons/year) Amount Sold in
South Coast (thousands of gallons/year) Straight 27.3 2.8 2,000 Soluble 49.3 5.0 3,500 Semi-Synthetic 21.7 2.2 1,500 Synthetic 18.9 1.9 1,300

Total 117.2 11.9 8,300Final Staff Report ________________________________

Proposed Rule 1144 11 March 2009 To supplement these estimates, in 2006, the AQM D conducted a survey of local metal working fluid manufacturers, suppliers and users. The survey data indicated that those local manufacturers and suppliers annually sold 4.2 m illion gallons of industrial lubricants, metal working fluids, rust inhibitors, vanishing oils and solvent in the Basin (see Table IV). Presumably, the solvents are used as vanishing oils, rust preven tatives, for thinning other metal working fluids or cleaning.

Table IV – Volume Surveyed

Fluid Type Volume Surveyed (thousand gallons)

Lubricants and Metal Working Fluids 2,564.6 Light Oil 48.9 100 SUS Naphthenic Oil 1,119.2 Vanishing Oil 64.1

Rust Inhibitors 155.7

Solvent 238.0 Total 4,190.5

Approximately 30 percent or 71,000 gallons of th e 238,000 gallons of solvents reported in the survey are used for cleaning applications subj ect to Rule 1124 and ca nnot be included in the VOC emission inventory for this rule making activity.

Table V – Applicable Volume

Fluid Type Applicable Volume Surveyed (thousand gallons) General MWF and Lubricants 2,564.6 Light Oil 48.9 100 SUS Naphthenic Oil 1,119.2 Vanishing Oil 64.1

Rust Inhibitors 155.7

Solvent 167.0 Total 4,119.5

Of the 4.2 million gallons, only 11 percent of the sales were high-VOC light oils, vanishing oils, rust preventatives and solvents. However, an additional 27 percent are petroleum-based metal working fluids with relatively low VOC conten ts but in significant enough volumes to warrant
future consideration.

A serious drawback from the survey and national sales data was the lack of VOC information on the lubricants and metal working fluids. More than eighty percent of the volume surveyed listed
the VOC content as “None” or not determined. Therefore, the AQMD sampled a broad range of products from local manufacturers and suppliers a nd performed VOC testing to establish a more accurate emissions inventory. The sample results for vanishing oils and rust inhibitors, using Method 24, are presented below in Table VI.

Table VI – Test Results Using EPA Method 24

Type VOC Content # of Samples

Rust PreventativesFinal Staff Report ________________________________

Proposed Rule 1144 12 March 2009 Cleaner/Rust Preventative <25 – 760 g/l 2 Consumer/General 514 g/l 1 Rust Preventative <10 – 560 g/l 4 Rust Preventative/Stamping 51* - 125 g/l 2 Vanishing 650 - 750 g/l 3

*Before dilution
Using the sales weighted average from the su rvey information and the EPA Test Method 24 sample test results, the emission inventory for vanishing oils, rust inhibitors and solvent was determined. Vanishing oils reported in the surv ey had a sales weighted average VOC content of 710 g/l. Solvent-based rust inhibitors had sa les weighted average VOC content of 660 g/l. Using this methodology, the VOC emission inventor y of vanishing oils, rust inhibitors and solvent is estimated to be 6.81 tons per day and is summarized in Table X.

Table VII – Surveyed Emission Inventory

MWF Type Volume Surveyed (thousand gallons) Sales Weighted Average VOC

Content (g/l) Total VOC Emission (tons per day) General MWF and Lubes 2,564.6 TBD TBD Light Oil 48.9 TBD TBD 100 SUS Naphthenic Oil 1,119.2 TBD TBD Vanishing Oil 64.1 710 0.52

Rust Inhibitors 155.7 660 1.17

Solvent 167.0 790 1.50

Total 4,119.5 N/A 3.19

TBD = data not available at this time

The AQMD survey correlated well w ith the ratio of lubricants to metal working fluids compared
to national sales data. National sales data indicates 67 percent of applicable sales are industrial lubricant and 33 percent are metal working fluids. The survey data shows 63 percent of applicable fluids are industrial lubricants and 37 percent are metal working fluids. It appears that the survey of local manufactur ers and suppliers conducted by th e AQMD captured just over half of the metal working fluid sales predicted by the na tional sales figures. The survey data could be extended to regional and national manufacturers and suppliers if n ecessary. Extrapolating from national sales figures, the overall VOC emission inventory can be as high as 13 6 .3 tons per day
as seen in Table VIII.

Table VIII – Emission Invent ory from National Sales

MWF Type Volume Projected (thousand gallons) Sales Weighted Average VOC

Content (g/l) Total VOC Emission (tons per day)

General MWF and Lubricants 5,081.1 TBD TBD Light Oil 96.8 TBD TBD

100 SUS Naphthenic Oil 2,217.4 TBD TBD Vanishing Oil 127 710 1.03Final Staff Report ________________________________

Proposed Rule 1144 13 March 2009 Rust Inhibitors 308.4 660 2.32

Solvent 330.8 790 2.98

Total 8,161.8 N/A 6.33

TBD = data not available at this time

EMISSION REDUCTIONS

The proposed rule will establish a VOC content limit of 50 g/l for vanishing oils effective January 1, 2010. Rust inhibito rs will initially be limited to 300 g/l effective January 1, 2010, with further reductions to 50 g/l will be require d in 2012. Exemptions are included for aerospace
avionic and assembled aircraft rust inhibitors, military specificati on or PPAP rust inhibitors, and
other small volume uses.

For the majority of the total volume of direct-c ontact lubricants, metal working fluids and rust inhibitors, the proposed limits will have no impact . However, the rule will produce substantial VOC emission reductions from vanishing oils, rust inhibitors, and solvents used to dilute lubricants or metal working fluids or used dir ectly as vanishing oils or rust inhibitors. The solvent usage is distributed over high flash point li ght oils, vanishing oils and rust inhibitors in the same ratio as the sales volume (20 percen t, 23 percent and 57 pe rcent respectively). Implementation dates, based on extensive disc ussions and feedback from end-users and suppliers, have been adjusted to focus on reductions in VOCs from solvents over the first few years. Future amendments to the rule, adopt ed after the VOC content test method technical issues for high flash point oils have been reso lved, will address emissions from direct-contact lubricants and metal working fluids. This approach addresses many technical concerns expressed by industry and provide s additional time for further an alysis of the VOC test method
results.

Approximately ten percent of the volume (15,600 ga llons) of rust inhibito rs sold is used for specified operations such as military specifica tion, military standards or PPAP according to the Independent Lubricant Manufacturers Association (ILMA). Those uses will be exempt until 2011 and emission reductions (0.06 tons per day) from those uses will be realized in 2011. Limiting the VOC content of rust inhibitors, ex cluding specified rust inhibitors, and solvents used in rust inhibitors to 300 g/l will redu ce VOC emissions by 1.93 tons per day by 2010 (2.00 tons per day by 2011). Table IX, below, summarizes the emission reductions

Table IX – Emission Reductions Realized in 2010 (Vanishing Oils and Rust Inhibitors)

Fluid Type Volume Surveyed (thousand

gallons) Sales Weighted
Ave
VOC
Content

(g/l)** Proposed
VOC
Content (g/l) Percent
Reduction Total VOC
Emission Inventory (tons per day) Total
VOC
Emission
Reduction (tons per day)

Rust Inhibitors 140.1 660 300 55% 1.06 0.58Final Staff Report ________________________________

Proposed Rule 1144 14 March 2009

Solvent (Rust Inhibitors) 95.2 790 300 62% 0.86 0.53

S pecified Rust
Inhibitors 15.6 660 300 55% 0.12 0.06*
Vanishing Oil 64.1 710 50 93% 0.52 0.50

Solvent (Vanishing Oil) 38.4 790 50 94% 0.35 0.33

Total 386.8 3.21 2.00

* Realized January 1, 2011
** Based on EPA Method 24

Finally, in 2012, the limits for rust inhibitors will be lowe red to 50 g/l. This will further reduce VOC emission from rust inhibitor operations by another 0.71 ton per day (see Table X).

Table X – Emission Reductions Realized in 2012 (Rust Inhibitors)

Fluid Type Volume Surveyed (thousand

gallons) Sales Weighted
Ave
VOC
Content (g/l) Proposed
VOC
Content (g/l) Percent
Reduction Total VOC
Emission Inventory (tons per day) Total
VOC
Emission
Reduction (tons per day)

Rust Inhibitors 155.7 300 50 83% 0.53 0.44 Solvent (Rust Inhibitors) 95.2 300 50 83% 0.33 0.27

Total 250.9 0.86 0.71

At full implementation, PR 1144 will achieve 2 .71 tons per day of VOC reductions based on survey results only. Projecting from the AQMD survey data to nati onal sales figures, the potential emission reductions w ould nearly double to 4.96 tons of VOC emissions reduced, as
summarized in Table XI below.

Table XI – Emission Reducti ons from National Sales

MWF Type Volume Projected (thousand

gallons) Sales Weighted
Ave
VOC
Content (g/l) Proposed
VOC
Content Percent
Reduction Total VOC
Emission Inventory (tons per day) Total VOC
Emission
Reduction (tons per day) Vanishing Oil 127 710 50 94% 1.03 0.97
Rust Inhibitors 308 660 50 93% 2.32 2.16
Solvent 331 790 50 90% 2.99 1.83

Total 8,166 14.00 4.96

Multiple low-VOC commercially available pr oducts have been identified in numerous applications. In many applications, the only pr oducts in use are low-VOC products already in compliance with the proposed limits. Cold heading, drawing, honing, forging, milling machining and metal removal fluids as well as coolants and industrial lu bricants were all foundFinal Staff Report ________________________________

Proposed Rule 1144 15 March 2009 to have low-VOC content produc ts in widespread use. Fo r applications where high VOC products were identified, aqueous -, bio- and petroleum-based t echnologies were identified and demonstrated in field testing. Those alternatives were analyzed and found to have VOC contents that would meet the proposed limits.

The transition to low-VOC content vanishing oil alternatives and rust inhibitors is not expected to increase criteria pollutants or global warming ga ses. The substitution of one type of fluid with another will not have an impact on criteria pollutants other th an VOC. The increased use of control equipment is considered very unlikely, and therefore not expected to be a source of increased pollutants. There may be some neg ligible decrease in global warming gases from shipping concentrates inst ead of ready-to-use products because concentrates weigh less, reducing fuel consumption during transit.

COST AND COST-EFFECTIVENESS

The use of low-VOC alternatives to vanishing oils and rust inhibitors is expected to increase costs for machinery, including skimmers, decante rs, mixers, sump cleaners and possibly cleaning equipment. In addition, there would be an overall in crease in the cost of fl uids. On an individual facility basis, the costs may be significant, insignificant or even a cost savings.

For alternatives to vanishing oils, companies w ould ideally use a water soluble fluid that would not require cleaning. The soluble lubricants are heavily diluted with wate r and would likely cost less than a vanishing oil potentially resulting in a cost savings. They would have rust preventative compounds to prevent corrosion and evaporate leaving behind a light, corrosion protective film.

However, the worst case scenario for shops using vanishing oils would be to use a product that would require subsequent cleani ng. The shops would need to purchase cleaning equipment, automated handling equipment, cleaning chem istry, and pay for added electricity.

For a typical shop using 240 gallons of vanishin g oil annually, the shop w ould face an estimated annualized capital cost of $11,000, $2,900 in cleani ng chemistry and disposal costs and $3,800 in

increased electrical costs. The lubricant co st would decrease by $1,300 annually. The total maximum annual cost per typical facility would be $ 15

, 100 16,400

.

Table XII – Maximum Increased Cost per Vanishing Oil Facility

Annual Cost Capital (annualized) Cleaning Equipment $6,100 Automated Handling $4,900 Cleaning Chemistry $1,900 Disposal $1,000 Electricity $3,800 Lubricant <$1,300>

Total $16,400

Using the most conservative assumption for all vanishing oil usage (64,100 gallons), the maximum overall annual cost would be $4.4 million.Final Staff Report ________________________________

Proposed Rule 1144 16 March 2009 Total Volume of Vanishing Oil Typical facility usage Numb er of Facilities 64,100 gallons 240 gallons 267

Number of Facilities Cost per facility Total Annual Cost 267 $16,400 $4.4 million

The conversion from high VOC rust inhibitors to low VOC rust inhibito rs would only involve changes in chemical formulae. The equipment (tanks) would remain the same and there would
be no added electrical costs. Alternative formul ae have a higher cost, but since many of the rust inhibitors are diluted with water, the cost would be much more co mparable to the high VOC rust
inhibitors.

Again, the worst case scenario is evaluated and it is assumed that non-diluta ble rust inhibitors are used. The cost of mineral spirits used as a ru st inhibitor is approxima tely $3.60 per gallon. The

alternative bio-based rust inhi bitor sells for $8.30 per gallon, a $4.70 increase per gallon. The

alternative rust inhibitor would be used in the same volume as the mineral spirits. The cost increase over 155,700 thousand gallons would be $0.7 million dollars annually.

Total Volume of Rust Inhibitor Increa sed cost per gallon Total Annual Cost 155,700 gallons $4.70 $0.7 million

Solvent can be used as a vanishing oil, rust inhi bitor or diluent for light oils. When determining costs, the solvent usage is distri buted over high flash point oils, vani shing oils and rust inhibitors in the same ratio as the sales volume (20 percen t, 23 percent and 57 percen t respectively). Thus 33,400 are attributed towards high flash point oils, 38,400 gallo ns are attributed towards vanishing oil, and 95,200 gallons of solvent are used as rust inhibitors. The same worst-case methodology is used for vanishing oil and rust inhi bitors to determine the cost of replacing the
solvent. The total cost for solv ent replacement would be $2.9 million.

Total Volume of Solvent

Used as Vanishing Oil Typical fac ility usage Number of Facilities 38,400 gallons 240 gallons 160

Number of Facilities Cost per facility Total Annual Cost 160 $15,100 $2.4 million

Likewise,

Total Volume of Solvent

Used as Rust Inhibitor Increased cost per gallon Total Annual Cost 95,200 gallons $4.70 $0.4 million

Some shops may be required to do additional r ecord keeping demonstrating that their annual
emissions remain below four tons. Four tons of emissions from vanishing oi ls and rust inhibitors at 50 g/l (0.4 pounds per gallon) would be equivalent to over 19,000 gallons used per year. Of 115 machine shops surveyed, fewer than eight percen t used vanishing oils an d rust inhibitors in sufficient quantities to remotely approach the four ton annual limit. Of the more than 12,000 affected facilities, an estima ted 2,000 would require a more thor ough review of annual records. From discussions and experience with facilities conducting record keeping, it is estimated thatFinal Staff Report ________________________________

Proposed Rule 1144 17 March 2009 the process of gathering the year’s purchase reco rds would require about eight hours of labor per facility. At $20 per hour, the a nnual increase in r ecord keeping costs w ould be $20/hour * 8 hours/facility * 2,000 facilities = $0.1 million. Shops that use rust inhibitors with higher than 50 g/l VOC content would be required to track add itions to their fluid systems. There are an
estimated 600 facilities that woul d need to track high VOC rust i nhibitor usage. These systems are usually changed monthly or le ss frequently. At $20 per hour, the annual increase in record keeping costs for those shops would be $20/ hour * 12 hours/facility * 600 facilities = $0.1 million. The remaining facilities would require a negligible effort to demonstrate that their annual usage was below the four ton annual limit. Th e total annual increase in cost due to record keeping would be $0.2 million.

Manufacturers and suppliers will al so be required to determine th e VOC content of their products
and to label containers with the date of manufacture or date c ode. Manufacturers and suppliers offer several dozen rust inhibitors each. Many of those are similar with slight variations on the additives incorporated in the product. Manufactur ers and suppliers may be able to test some subset of products and be able to calculate the VOC content of their remaining products. Others will insist on testing every product to insure rule compliance. Conservatively assuming that there are 500 applicable rust inhibitors and every product would be la boratory tested at $350, there would be a one time cost of $0.2 million. Annualized over ten years, the additional annual cost to manufacturers and supplie rs would be negligible. Most containers use computerized labels that can be altered by simple reprogrammi ng. The cost to alter those labels is also considered negligible.

As proposed, the rule will reduce emissions by 2.71 tons per day w ith an estimated cost of $8.1 million dollars. The maximum overall cost-effectiveness of the proposed amendment will be $8,189 per ton of VOC emissions reduced on a cons ervative basis. However, studies conducted on the use of compliant rust inhibitors and vanish ing oils actually showed an overall reduction in costs, yielding a cost savi ngs to the facility.

Table XIII – Maximum Cost-Effectiveness

MWF Type Volume Surveyed (thousand

gallons) Total VOC
Emission Inventory (tons per day) Total VOC
Emission
Reduction (tons per day) Maximum
Cost (millions)
General MWF 3,683.8 1.05 0 $0.0
Vanishing Oil 64.1 0.52 0.5 $4.4

Rust Inhibitors 155.7 1.17 1.08 $0.7

Solvent 167 1.50 1.41 $2.8
Record keeping N/A N/A N/A $0.2 Laboratory Testing N/A N/A N/A negligible

Total 4,119.50 4.73 3.44 $8.1

INCREMENTAL COST-EFFECTIVENESS

Health and Safety Code Section 40920.6 require s the AQMD to perform an incremental cost analysis when adopting a Best Available Retrof it Control Technology (BARCT) rule or feasibleFinal Staff Report ________________________________

Proposed Rule 1144 18 March 2009 measure required by the California Clean Air Act. To perform this analysis, the AQMD must (1) identify one or more control options achie ving the emission reduction objectives for the proposed rule, (2) de termine the cost effectiveness for each option, and (3) calculate the incremental cost effectiveness for each option. To determine incremental costs, the AQMD must “calculate the difference in the dollar costs divided by the difference in the emission reduction potentials between each progressively more stringen t potential control option as compared to the next less expensive control option.”

Proposed Rule 1144 implements Control Me asure CTS-01 from the 2007 Air Quality Management Plan. Because Control Measure CT S-01 is intended to meet feasible measure requirements under the California Clean Air Act, an incremental cost analysis is required and is presented in this section.

Several alternative options were evaluated includ ing three more stringent standards and one less stringent standard. The first alternative examined was to require all lubricants, metal working
fluids and rust inhibitors to m eet a VOC content limit of 25 g/l. Similar low-VOC formulations
would be utilized but machine operators would have to monitor the fluids to ensure that evaporation or contaminants did not make th e fluid non-compliant. The second alternative
established limits for all direct -contact lubricants, metal working fluids and rust inhibitors, and required testing and product labeling. This w ould add additional costs for recordkeeping and testing. Another alterna tive examined would have allowed vani shing oils and rust preventatives to meet a final VOC content limit of 200 g/l. Th is would have allowed some affected operations to dilute fluids with lower cost high flash point oils. However, they would have been required to maintain daily records, and vani shing oil operations would have continued to require a cleaning process. Finally, the installati on and use of control devices to limit VOC content in lieu of a VOC content limit was analyzed. While no proce ss changes would have been necessary, there
would have been considerable costs from the in stallation of the control devices. Because the control device option was unlike th e other alternatives, it was co mpared to the least stringent (200 g/l) option.

The incremental cost analysis shows that lowering the limit to 25 g/l would have increased costs by $4.3 million over the proposed limit and only net a nother 62 tons per year (0.78 tons per day)
of VOC emissions. The incremental cost would be rather high because of the additional labor. The analysis also shows that requiring control de vices in lieu of VOC limits would have been cost prohibitive (more than $255,000 per ton of VOC reduced). Fi nally, the analysis indicates
that it would be cost-effective to regulate direct-contact lubricants and general metal working fluids (see Table XIV below). Th e District intends to do so as soon as the VOC content test
method technical issues have been resolved.

Table XIV – Incremental Cost-Effectiveness

VOC Limit (g/l) Emission
Reductions (tons per year) Annual
Cost (million) Incremental Cost ($ per additional

ton reduction) Overall Cost
Effectiveness
25 1,273.9 $12.4 $54,795 $9,734 50 (all categories) 1,211.8 $9.0 $4,042 $7,427 50 (vanishing oil and

rust inhibitor only) 989.2 $8.1 $4,215 $8,189 200 (vanishing oil and 941.7 $7.9 $8,389 $8,389Final Staff Report ________________________________

Proposed Rule 1144 19 March 2009 rust inhibitor only)

No Control 0.0 $0.0 N/A N/A
Control Device 1,270.2 $324.0 $962,253 $255,078Final Staff Report ________________________________

Proposed Rule 1144 20 March 2009 COMMENTS AND RESPONSES

This section reflects the public comments recei ved during the public workshop held September 23, 2008, the public consultation meeting held Oct ober 29, 2008 and subsequent public comment periods and staff responses.

Comment 1 We request that SCAQMD delay the rulemaking process. The test me thod was only recently
released and there is insufficient time to dete rmine applications that may be affected. The current effective date, coupled with the aggre ssive rule making schedule, is infeasible. Thousands of companies may need to implemen t alternatives. Manufact urers and suppliers do not have sufficient support staff to test and impl ement alternatives. In addition to delaying the rule, we recommend delaying the effective date s for the proposed rule. We suggest an exemption for high flash point oils or to delay th e effective date for metal working fluids, except vanishing oils, until 2012. The AQMD should also consider phased-in or staged limits.

Response While not every potential product has had the VOC content definitively determined, it is clear that high-solvent content metal wo rking fluids and rust inhibitors and straight solvents are within the purview of the rule. As part of the rule de velopment process, staff has identified numerous commercially available products al ready complying with the proposed limits. Also, the Public Hearing has been moved from December 2008 to March 2009 to provide more time for public review and input. Nevertheless, to provide more time to resolve technical issues regarding the VOC content test method, the proposed rule has b een modified to establish limits for vanishing oil and rust preventatives only. Direct-contact lubricants and ge neral metal working fluids will be regulated after the test method technical i ssues have been resolved. Furthermore, an exemption has been added to delay the 300 g/l VOC limit applicable to rust inhibitors for products used under PPAP and military specificati ons by one year, providing a two year window requested by industry to revise th e applicable spec ifications. Lastly, exem ptions for certain lowvolume categories have been added to the proposed rule to alleviate reformulation efforts for those categories.

Comment 2 Special consideration shoul d be given for applications specifi ed for operations where fluid usage is dictated by military specification, PPAP or cu stomer specifications. We believe a one year delay should be allowed to determine which fluids are affected, contact customers to advise them of the rule making and initiate replacement trials. We also as k for an additional year beyond the delay to determine customer acceptability.

Response High-solvent content metal working fluids and ru st inhibitors, light, hi gh flash point oils and straight solvents will be the affected formula tions and while manufactur ers have a large number of products, only a small subset will require furthe r testing to determine compliance. However, until the technical issues regardi ng the test method have been resolved, only vanishing oils and rust inhibitors will be regulat ed. We agree that replacement trials to determine customer acceptability and changes to military specifica tions and/or PPAP specifications will take additional time. Therefore, as noted above, the proposed rule has been modified to delay the effective date to provide more transition time for manufacturers to reformulate and test their products, as well as amending specif ications. An exemption has be en added to delay the 300 g/lFinal Staff Report ________________________________

Proposed Rule 1144 21 March 2009 VOC limit applicable to rust inhibitors for pr oducts used under PPAP and military specifications by an additional year.

Comment 3 There was insufficient notice for the public workshop. Many shops had not received notice of the meeting until the weekend before the workshop.

Response
All stakeholders in staff’s distri bution list that had expressed an interest in participating in the public workshop and rule development process we re notified by e-mail ten days in advance of the September 23, 2008 meeting. Staff also asked th e stakeholders to forw ard the meeting notice to others who may be interested. Notices we re mailed to over 7,000 pot entially interested
entities that were not included in staff’s distribution list. News paper notice in all four counties was also provided. Sufficient notice was provide d to meet statutory requirements for notice of the Board hearing. However, an additional meeting, a Public Consultation Meeting, was held in
late October with sufficient not ice provided by mail for potentia lly impacted facilities. This provided another opportunity for the regulated community to pr ovide comments regarding the proposed rule. Further, in addi tion to the public workshop and c onsultation meetings, staff will continue meeting with representatives of th e impacted industry through its ongoing working group meetings to continue a ddressing any pending issues.

Comment 4
The referenced test method remains a draft and has not been validated, peer reviewed and/or accepted by testing organizations such as Ameri can Society for Testing and Materials (ASTM), American Oil Chemists Society (AOCS), Ameri can Chemical Society (ACS) for metal working fluids. A poor test method is the worst thi ng that could happen in this regulation. Has SCAQMD Test Method 313L been validated for VOC testing of neat oil or emulsion samples?
Labs that can conduct this method have not been identified and their ex perience with the method
has not been evaluated.

Response Method 313L was developed to accurately test hi gh-VOC solvent-based as well as higher water content low-VOC products. Howeve r, based on comments presented by industry, es pecially lack of repeatability in non-AQMD laboratories, it has been replaced with EPA Test Method 24.
EPA Test Method 24 has been shown to be acceptable for relatively high solvent products including vanishing oils and solvent-based rust preventatives and will be used for those categories. However, it does not produce repeatable results for high water content or heavy (high flash point) oils. The AQM D has committed, in the Resolutions to be adopted along with the proposed rule, to conduct round robin testing on Method 313L and TGA. Once Method 313L, TGA or another method has been shown to be adequate, limits will be established for high water content fluids and high flash point oils used as direct-contact lubricants and general metal working fluids.

Comment 5 A possible alternative to GC/FID analysis is the use of TGA to determine VOC levels. This analysis methodology can accurately and efficiently determine the volatility characteristics of a sample, both neat oil samples and emulsi on samples at any desired temperature.Final Staff Report ________________________________

Proposed Rule 1144 22 March 2009 Response The TGA test method is very similar to EPA Method 24 with respect to its strengths and weaknesses. It would provide ac curate and repeatable results for high-solvent or petroleumbased oil products, but will not provide acceptabl e results for low-VOC products that contain high water content. To utilize TGA testing, time and temperature parameters must be determined and an enforceable way to handle high water content must be established. The District agrees to continue reviewing the merits of TGA testing with inte rested stakeholders and considering it as an approved test method if further data provides sufficient evidence.

Comment 6 It may be possible to mimic the test results of the SCAQMD GC/MS procedure using a capillary GC unit equipped with FID a nd could produce a comparable chromatograph to the GC/MS results. This form of VOC testing was documente d by California Polytechnic State University in a progress report from 2006, under sponsorship of CARB and Cal EPA, in the development of a new VOC analysis method for architectural coatings. Results from the new headspace method were compared using the standard direct sample injection method (ASTM method 6886). Results reported seem to indicate the static headspace analysis method to provide results comparable to direct injecti on analysis method for compounds showing GC column elution times prior to an industry recogni zed reference standard.

Response Test Method 313L utilizes a capillary GC unit e quipped with FID as described in the comment. We agree that the results are comparable to other methods using methyl palmitate as the reference standard. Head space analysis would requi re very high temperatures to ensure that the sample would completely volatilize for the compete chromatograph to be analyzed. Lower temperatures would provide an incomplete chromat ograph and potentially give an artificially low VOC result. In addition, numer ous other factors in headspace an alysis, such as liquid to vapor ratios and sample transfer, suggest that headsp ace analysis would be less reliable than direct injection. However, based on comments receive d, Method 313L has been replaced with EPA Test Method 24, as suggested by several members of industry.

Comment 7 Methyl palmitate is not normally classified as a volatile compound, but SCAQMD uses it to
define what constitutes a VOC. What is the basis for this d ecision, and are any other regulatory agencies in agreement with the decision?

Response
Test Method 313L is a modified version of SCAQMD Method 313 – Determination of Volatile Organic Compounds (VOC) by Gas Chromatogra ph/Mass Spectrometry (GC/MS) which has been accepted by CARB and U.S. EPA for AQMD ru le implementation and in air districts in California and Arizona since 1991. In this method, the total specified sampling period is 30 minutes. Previous testing has sh own that methyl palmitate elutes at the 30 minute mark. The AQMD includes all compounds, besides water and exem pt solvents, that elute prior to methyl palmitate, to be VOC. The modifications stream line the test significan tly, reducing cost and labor as well as allowing the use of commercially available GC columns. In modifying the test, the compounds elute out in the same order and methyl palmitate remains the endpoint determining volatility. However, based on co mments received, Method 313L has been replaced with EPA Test Method 24, as suggested by several members of industry.Final Staff Report ________________________________

Proposed Rule 1144 23 March 2009 Comment 8 The data reported by AQMD was calculated ba sed on the manufacturer’s recommended dilution of the product after testing of the neat product. Since in-use samples will be used to determine customer compliance, the results should correlate to actual dilu tions and real world conditions
versus calculated dilutions. The results varied by 100 percent for one sample and 33 percent for
another. A validated test does not have such variability, especially when critical to both compliance and enforcement.

Response Testing to verify that results from dilute samp les correlate to earlier results from neat samples
calculated based on the manufacturer’s recomme nded dilution has been completed and shows that Method 313L results correlate very well wh en testing neat and diluted samples. These
results have been shared with the public and included as Tabl e XV – Dilute Sample Results
below. While the commentor criticizes the resu lts as having large percentile differences, these differences equate to less than 20 g/l. These are very small values and all samples tested would fall well within the VOC limits proposed. Additionally, it is routine enforcement policy to recognize a margin of error for samp le results equal to +/- 20 per cent for VOC limits of 50 g/l or
less.

Table XV – Dilute Sample Results

Sample ID (Dilution ratio) Neat Predicted Tested

Sample 001 (8%) 20 g/l 2 g/l 2 g/l

Sample 002 (10%) 140 g/l 14 g/l 10 g/l
Sample 003 (20%) 140 g/l 28 g/l 8 g/l

However, based on comments received, Method 313L has been replaced with EPA Test Method 24, as suggested by several members of industr y. Industry’s proposal TGA method also has similar limitations for testing dilute samples with high water content.

Comment 9 The high temperature (200°C) at the injection port for the FID is not reflective of real world conditions. Glycerin may break down at such a high temperature giving false results. A lower temperature, such as 40°C would be better.

Response The temperature at the injection port is not intended to reflect real world conditions but to provide a complete chromatograph of the fluid for further analysis. While much of the fluid will elute at that high temperature, only the portion occurring before methyl palmitate is considered when determining VOC content. There has been no indication that glycerin or any other chemical compound breaks down giving false results . A lower injection port temperature could potentially leave some volatiles in the injection po rt giving an artificially low result. However, based on comments received, Me thod 313L has been replaced w ith EPA Test Method 24, as suggested by several members of industry.Final Staff Report ________________________________

Proposed Rule 1144 24 March 2009 Comment 10 The proposed test method utilizes direct injec tion. We believe head space analysis is more accurate than direct injection.

Response Head space analysis would requ ire very high temperatures to ensure that the sample would completely volatilize for the compete chromatogra ph to be analyzed. Lower temperatures will provide an incomplete chromatograph and potentially give an artificially low VOC result. In addition, numerous other factors in headspace analys is, such as liquid to vapor ratios and sample transfer, suggest that head space analysis would be less reliable than direct injection. However, based on comments received, Me thod 313L has been replaced w ith EPA Test Method 24, as suggested by several members of industry.

Comment 11 The inventory figures, particularly from vanishi ng oil applications, are inaccurate and outdated. Many assumptions are based on census data from 1995 and 2002. Sales are down and there are fewer companies using these fluids when they we re reported in 2006. The survey captured 95 percent of the sales at that time and the national sales estimates are far too high. A new inventory survey should be conducte d before the rule is heard.

Response The inventory figures were pr ovided by surveying local manuf acturers and suppliers. Those figures were for annual sales in the District for 2004, 2005 and part of 2006. The results are relatively consistent over the survey period, and national sale s confirm relatively stable sales. In response to the comment, earlier survey respondents were contacted and invited to revise earlier annual sales or provide new sales da ta if they wished. None have provided any additional data. Census assumptions regarding national sales data confirm survey sales data, but only the 2006 survey sales data collected for the South Coast have been used for making emission estimates. Based on discussions with industry pertaining to solvents used as lubricants, metal working fluids, vanishing oils and rust inhibitors, th e local survey may underestimate the volume and associated emissions. While the local survey and the national sales figures were used as reference points to establish the baseline i nventory for rulemaking, staff is cognizant of the limitations of initial surveys and intends to refine them by periodically conducting future

surveys.

Comment 12
There is known interfer ence in the proposed test method (Met hod 313L) from surfactants used in the suggested alternative metal working fluids . Will the proposed test method give accurate
results?

Response The proposed test method has been shown to give accurate, repeatable results for a wide range of products, including those that cont ain surfactants. Surfactants ar e commonly found in cleaning products. Cleaning products submitted for Clean Air Solvent and Clean Air Choices Cleaner certification are reliably tested using the proposed test met hod. However, independent and industry laboratories are not familiar with this method and have requested round-robin testing, particularly with respect to direct-contact lubr icants and metal working fluids. Therefore, VOC limits for those categories will be established afte r the technical issues have been resolved.Final Staff Report ________________________________

Proposed Rule 1144 25 March 2009 Comment 13 The costs for manufacturers and suppliers will have to test each and every product costing $60,000 to $150,000. They will also have costs for research and development and technical support staff. The projected emission reduc tions only represent 0.5 percent of the VOC
emissions in the basin. Additional strain will be placed on small businesses hard pressed by severe economic conditions. Companies cannot a fford to modify processes. Many companies are leaving the basin and additiona l costs will accelerate their depa rture. The proposed rule will have huge costs for little gain.

Response The sixteen million Southern Californians residing in the South Coast Air Basin experience the nation’s worst air quality. Proposed Rule 1144 partially fully implements control measure CTS01 of the 2007 AQMP, which reflects the South Coast Air Basin’s comprehensive strategy to improve air quality and meet the state and federal air quality st andards. CTS-01 is a vital component of the stationary source VOC control strategy. Wh en implemented, Rule 1144 will reduce approximately 2.7 tons of VOC per day, a significant level of emission reductions. While staff acknowledges that there are costs associat ed with the implementation of Rule 1144, staff has attempted to craft a rule that minimizes such costs, while maximizing emission reduction benefits. The analysis included in this staff report shows that the revised staff proposal is technologically feasible and very cost-effective. The proposed rule does not require that each and every product be tested. Calc ulations of VOC content for fo rmulations with compounds of known VOC contents are acceptable. The cost-effec tiveness analysis conservatively includes the cost to test 500 rust inhibitor samples. Cost s for research and development and technical support staff are considered in the higher cost of lo w-VOC alternatives and included in the costeffectiveness calculations in the Staff Report. Companies have the option to use alternative products that may not require process modificati on. However, the Staff Report includes a costeffectiveness analysis using the most conser vative assumptions. Th e analysis shows the proposed rule is cost-effective. Case studies of facilities that have used these alternative products and modified processes may even realize a cost savings. A SocioEconomic assessment
of PR 1144 has been conducted to evaluate employment impacts.

Comment 14
Cost effectiveness and incremental cost effectiv eness calculations have not been provided. The District is specifically required by statute to consider, and make available to the public, its findings related to the co st-effectiveness of a cont rol measure it proposes to adopt. The District is also required to assess the availability and cost-e ffectiveness of alternatives to the proposed rule. Moreover, the District is also required to calculate the incremental cost-effectiveness of potential control options that achieve the emi ssion reduction objectives of the proposed rule.

Response
Cost effectiveness calculations were provided in the Preliminary Draft Staff Report as well as the Draft Staff Report. Incremental cost-effectiveness of potential c ontrol options are included in the Draft Staff Report, and were di scussed at working group meetings and presented at the Public Consultation Meeting.

Comment 15
VOC standards and test methods should be consistent statew ide and nationwide.Final Staff Report ________________________________

Proposed Rule 1144 26 March 2009 Response Nationally, EPA Method 24 is the default method to determine VOC content of fluids subject to regulation under the rule. Stat ewide, the only applicable sta ndard is for consumer product lubricants, CARB Method 310 – Determination of Volatile Organic Compounds (VOC) in Consumer Products and Reactive Organic Compounds in Aerosol Coating Products. CARB Method 310 is a GC/MS method that exempts solv ents with a vapor pressure less than 0.1 mm Hg. While this may be a satisfactory sta ndard for consumer products, the AQMD does not exempt low vapor pressure solvents, since VOCs are released over time and interact to form ozone and secondary organic aerosols.

Comment 16 The proposed limits are unachievable and there is no documentation supporting the conclusion
that alternatives are available. The Instit ute for Research and Technical Assistance (IRTA) report referenced in not available to the public and neither is the survey data collected by the AQMD.

Response Staff estimates, according to information provide d by manufacturers and s uppliers, that over 89 percent of the 4.2 million gallons of lubricants, meta l working fluids and rust inhibitors sold in the AQMD already meet the proposed limits. The specific sales volume information is
considered confidential and will not be provided to the public , but, the consolidated information is included in the Staff Report. Manufacturers and suppliers have provi ded hundreds of material safety data sheets for products that are used in nearly all machini ng applications. In the limited instances where high-VOC solvents uses we re indentified, IRTA conducted a technical
assessment of available alternatives that in cluded case studies where alternatives were demonstrated to be successful in production settings . The IRTA report is referenced in this
document and is available online at www.irta.us . Applications where high flash point light oils are used may require further time to implement alternatives and the effective date for those applications have been extended based on the reque sted time frame. Some exemptions have also been included where deemed appropriate.

Comment 17 A limit of 50 g/l should be considered in lieu of the 25 g/l proposed. Many tested products may meet the proposed limit in labo ratory settings but routine ev aporation and contamination may make the products non-compliant. Considerable la bor would be necessary to constantly verify that the product remained below 25 g/l at all times.

Response The revised staff proposal sets the VOC limits at 50 g/l to address commentor’s concerns. While many of the products tested would meet the or iginally proposed 25 g /l limit, the added labor involved to monitor products in us e to ensure that applicable fl uids remain compliant would add
considerable cost with mi nimal emission reductions.

Comment 18 High flash point light oil use with high VOC cont ent should be exempt for aluminum, stainless steel, copper, brass, and titanium cutting an d high speed grinding, coolants, EDM, fast quenching, honing, lapping, milling, and rolling oils. Special consideration should be given to lubricants specified by machine manufacturer s where deviation may cause the warranty and
service contract to be voided.Final Staff Report ________________________________

Proposed Rule 1144 27 March 2009 Response Light oils with viscosities less than 20 cSt (100 SUS) and flash points greater than 200°F that have a VOC content greater than 50 g/l include l ubricants for spindle machine oil, cutting fluids for aluminum, stainless steel, copper, brass, a nd titanium, lapping and sinker EDM applications. The other applications us e heavier oils or aqueous-based me tal working fluids that have VOC contents below the proposed limit. Due to their very low usage a nd lack of available alternatives, sinker EDM and la pping operations have been exem pted. The high speed spindle oils specified by machine manufact urers do not come into direct contact with parts or products being manufactured or assembled, and therefore ar e not subject to the proposed rule. High speed spindle oils account for approximately 5,000 gallons used per year. Slightly heavier, but lowVOC oils, are a viable alternative for cutting fluids. Testing and po ssibly some equipment changes are necessary to use these products. However, VOC limits will be established after technical issues regarding the VOC content test method have been resolved, and are not covered by the revised proposed rule language.

Comment 19 Assembled aircraft require sp ecialized corrosion inhibitors and lubricants and should be exempted from the proposed rule.

Response PR 1144 has been revised to exempt the specia lized lubricants and co rrosion inhibitors for assembled aircraft which represent less th an 0.002 ton per day of VOC emissions.

Comment 20 Lubricants and metal working fluids used durin g the manufacture and use of aircraft fasteners should be exempted from the proposed rule.

Response Limits for lubricants and metal working fluids will not be established until technical issues regarding the VOC conten t test method have been resolved. Regardless, lubricants and metal working fluids subject to Rule 1124, including barrier co atings, dry lubricativ e coatings and solid film lubricants are exempt from the provisions of this rule. Vanishing oils and rust preventative applications not subject to Rule 1124 will be subject to the proposed rule.

Comment 21 Straight oils are often used a nd provide valuable lubricating functions. Water-based fluids involve more maintenance, down time and tooli ng will wear out faster. They also cannot be skimmed from aqueous cleaning baths meaning additional waste generation and costs. Are there petroleum-based rust inhibitors th at comply with the regulation?

Response The proposed rule does not require the use of water- based alternatives. The majority of straight oils will comply with the proposed limits. Fac ilities where high-VOC solvents are utilized will generally have the option to choose between heav ier straight oils or aqueous-based, soluble, semi-synthetic or synthetic metal working flui ds. The AQMD has tested several petroleumbased rust inhibitors that comply with the propose d limits. Review of material safety data sheets provided by suppliers and manuf acturers indicated that most ca rry a compliant petroleum-based rust inhibitor. The AQMD cannot recommend specific suppliers but can provide a list of suppliers.Final Staff Report ________________________________

Proposed Rule 1144 28 March 2009 Comment 22 A more precise applicability statement and definition of terms is necessary. It is not clear which, if any, maintenance and repair act ivities are exempt from the ru le. Proposed Rule 1144 should
be clarified to also exclude re search and development.

Response The applicability statement has been modified to further improve clarity. Additional definitions have been included to clarify the scope and intent of the proposed rule. The rule applies only to the manufacture and assembly of products and part s. Repair and mainte nance activities are not applicable to the proposed rule. Neither are rese arch and development activ ities that do not meet
the definition of “manufactur e” in the proposed rule.

Comment 23 We strongly believe that there is no “necess ity” for the AQMD to regulate consumer and commercial products since CARB exercises c ontinuous regulatory jurisdiction over these products. Dual regulation by CA RB and AQMD is contrary to st ate Legislature’ s intent to establish a uniform set of regulations for consum er products. Additionally, it is not clear which provisions of the rule apply to consumer products.

Response Consumer products are exempt from the prohibiti on of sale provision of the proposed rule. Use of consumer products by households, instituti ons and commercial operations, and consumer products used for maintenance and repair activiti es are also exempt. However, the use of consumer products during the manufacture and asse mbly of parts and products must meet the same limit as industrial products specifically form ulated for those operations. Regulation of VOC content at stationary sources falls squarely within the long-estab lished authority of air districts. According to CARB, “[I]t was certainly not the pur pose of the ARB regulations to deprive districts of their long-standing author ity to regulate pollutio n-generating activities occurring at stationary sources, just because these ac tivities may involve the use of consumer products.” Walsh, Kathleen. CARB Genera l Counsel. "Interpretati on of Health and Safety Code Section 41712 (f)." Letter to William Wong, Se nior Deputy District Counsel. February 20,

2001.

Comment 24 All aerosol product uses should be exempt from the proposed rule.

Response Aerosol products are not normally used for most manufacture and assembly operations. There is no reason to encourage their use, with co rresponding higher VOC content, by providing a blanket exempt status.

Comment 25 The AQMD should consider a small containe r (one quart or less) exemption.

Response Small containers are not normally used for most manufacture and assembly operations. Providing an exemption would encourage wast eful packaging and provide a loophole for noncompliant products.Final Staff Report ________________________________

Proposed Rule 1144 29 March 2009 Comment 26 The AQMD should consider a small use exemption (i .e. 55 gallons per faci lity annually). Some parts require thread locking compounds, sealants , mask, hardeners, layout fluid, hand applied tapping compounds and other essential fluids that may contain VOC but should not be included in the proposed rule because of their small usage.

Response Applications such as sinker EDM, lapping, rust inhibition for avionics and assembled aircraft, where there is low usage and alternatives are unavailable have been included exempted in the rule. Thread locking compounds, sealants, masks, hardeners, and layout fluids do not meet the definitions for vanishing oil or rust inhibitor and the rule will not be applicable to those uses. Tapping fluids, applied by hand and by machine ar e metal working fluids and subject to the VOC limits in the rule, if th ey have a flash point less th an 200°F. Low-VOC products are available for tapping applications and there are liquid, paste and aerosol versions of the lowVOC hand tapping fluids. A general small use exemption would require shops to maintain extensive records to verify if the small us e exemption applied and is unnecessary when compliant alternatives are readily available.

Comment 27 A longer sell-through period is nece ssary to ensure that products in the supply chain at the effective date are able to be used in a timely manner.

Response While consumer products may remain on the shelf for an extended period of time, most fluids used for industrial applications are consumed within six months after purchase. Extending the sell-through period would allow high-VOC products to be stockpiled for a longer than normal period.

Comment 28 Local labeling is a challenge for consumer pr oducts that are sold locally, nationally and internationally.

Response The labeling provision of the rule has been re moved until technical issues regarding the VOC
content test method have been resolved. Even so, the District intends to exempt consumer products from any future labeling requirement.

Comment 29 Language should be included in the rule desc ribing the enforcement protocol for sampling products in use and directly from shipping containers.

Response Enforcement procedures are normally not included in rules. Sampling of products in use is typically done at the applicati on source. Verification of VOC c ontent of fluids in shipping containers is normally done by test ing the product from a sealed container. However, because of variations in circumstances the proc edures may be altered as necessary.Final Staff Report ________________________________

Proposed Rule 1144 30 March 2009 Comment 30 The District has routinely regula ted the aerospace industry separate ly due to its uni que status and
it should continue to do so. Rule 1124 is specifically designed to reduce VOC emissions from all aerospace manufacturing a nd assembly operations and other ap plications have been routinely been exempted from multiple other District rules.

Response Aerospace machining operations that have applicab le limits in Rule 1124 have been specifically exempted in the proposed rule. Metal working operations at aerosp ace facilities that have no specific limits in Rule 1124 are subject to Rule 442 as an unregulated source of VOC emissions. It is possible that at some future date Rule 1124 will be amended to include general machining operations that would immediately ex clude them from the provisions of this rule as provided by paragraph (h)(3) of the proposed rule. However, many operations at aerospace facilities, including solvent degreasing and plating, are subj ect to Reg. XI rules in addition to Rule 1124. Until Rule 1124 has specific limits for vanishing o il and rust inhibitors applications, proposed Rule 1144 will apply.

Comment 31 Isopropyl alcohol is necessary for cutting appl ications on critical sp ace vehicle components where the cutting fluid may penetr ate coatings, adhesives and subs trates and be off-gassed when exposed to the vacuum of space.

Response An exemption for space vehicle components is included in the revi sed staff proposal.

Comment 32 Denatured alcohol is used for a high speed pr ecision CNC milling machine used for aluminum nameplates with graphics already printed upon th em. Using an exempt solvent would be costprohibitive and using a heavier metal working fl uid would require the parts to be cleaned afterwards. The manufacturer of the equipmen t has said that a reci rculating flood coolant process cannot be used or retr ofitted. An exemption is re quested for this application.

Response Staff does not believe that an exemption is warr anted for this vanishing oil operation. A higher flash point fluid is available as a low-VOC alternative. We acknowledge that using a low-VOC alternative metal working fluid would require additional cleaning and have included such costs in calculating the cost-effectiveness of the propos ed rule. The alternative would not necessarily need to be a flooding system and can be applied in the same manner as the alcohol is applied.

Comment 33 Users of consumer products should not be required to keep records. CARB already gets sales data of consumer products direc tly from manufacturers and supplie rs and this puts an additional and unnecessary burden on users of these products.

Response While CARB has consumer products sales records for emission purposes, records of consumer products used at an individual facility is necessary to de termine compliance with permit conditions, rule requirements and possible exemption status. A lternative record keeping is available for consumer products with a VOC content below 50 g/l pursuant to Rule 109.Final Staff Report ________________________________

Proposed Rule 1144 31 March 2009 Comment 34 CARB currently has a rule that regulates lu bricants used by household, institutional and
commercial establishments that do not manufactur e products. The proposed rule has wording in the applicability statement which conflicts with the CARB rule. The wording “commercial” and
“institutional” should be removed. The section should be reworded to accurately describe the intended target audience of this regulation

Response Agreed. “Institutional” and “commercial” have been removed and the applicability section has
been clarified.

Comment 35 The AQMD relied on one study that is limited to 13 specialized shops. More in depth work should be done before one limit is proposed for all lubricant and rust inhibitor uses.

Response While the AQMD used the IRTA study for some as pects of the cost-effectiveness calculations, the rule’s limits are based primarily on testing that has been conducted on the range of fluids
addressed in the rule. The results indicate th at 89 percent of the flui ds have a VOC content below the proposed limits. For the 11 percent of the fluids with higher VOC content, the AQMD has reviewed applicable operati ons to determine appropriate VOC content limits and effective dates, and has incorporated those changes into the proposed rule.

Comment 36
None of the tested alternative low-VOC rust inhib itors or lubricants discussed in the staff report are feasible for use in aerospace manufacturing and assembly. Even if replacement fluids were available, which is not likely, the process fo r identifying, qualifying an d obtaining approvals is difficult and time consuming and could not occu r within the Rule’s compliance deadline.

Response The aerospace industry has been using low-VOC lubricants, meta l working fluids and rust inhibitors on the vast majority of their metal working applications. Va nishing oils are highly uncommon in aerospace applicatio ns. Many tens or even hundreds of thousands of gallons of metal working fluids used on aerospace products ar e the aqueous-based or high flash point oils that the staff report identifies as low-VOC alte rnatives to high-VOC products. Many compliant products are specially desi gnated to have aerospace approvals. In three site vi sits and several conversations with aerospace facili ty industry representatives, onl y minor uses of moderate to high-VOC fluids were identified. These minor us es have been provided extended rule effective dates or exemptions as appropria te to compensate for the difficu lt and time consuming process to obtain approvals.

Comment 37 Proposed Rule 1144 should include a vapor pre ssure limit as an a lternative to a VOC concentration limit. Rule 219 exempts equipment from requiring a permit if the VOC content is below 50 g/l or the vapor pressure is less than 20 mm Hg at 20 °C.

Response Nearly all vanishing oils and rust inhibitors , including those with high VOC content, have a VOC composite of 5 mm Hg or less. Measurem ent of vapor pressure for complex chemicalFinal Staff Report ________________________________

Proposed Rule 1144 32 March 2009 blends is very difficult for lo w vapor pressure materials. A dditionally, the vapor pressure of fluids does not directly correlate with VOC content.

Comment 38 Small quantities of mineral spirits should be a llowed for the sole and express purpose of quality
control of machined parts. Metal working fluids need to be removed to precisely measure parts.

Response Proposed Rule 1144 does not apply to cleaning applic ations. Those activities are subject to Rule 1171 – Solvent Cleaning Operations.

Comment 39 The proposed rule allows vanishin g oils and rust inhibitors to be used in conjunction with a control device but prohibition of sales provision does not allow th eir sale. The prohibition of sale should include an exemption for products to be used in conjunction with a control device.

Response The revised proposed rule exempts products to be used in conjunction with a control device, in terms of VOC content, as we ll as the sales prohibition.

Comment 40 A mechanism should be provided in the rule for va riances or waivers for products and uses when substantial justification exists.

Response Regulation V provides a procedur e whereby a company can apply for a variance to allow it to continue temporarily operating wi thout penalty while in violation of AQMD rules, while it takes appropriate steps to meet air pollution control requirements. Variances can only be granted by the AQMD Hearing Board.

Comment 41 Manufacturers of certain machine tooling require th e use of specific brands of oil otherwise the warranty and service cont ract may be voided.

Response The limits for general metal working fluids and direct-contact lubricants have been removed
from the rule while test method issues are bein g resolved. VOC limits will apply to vanishing oils and high VOC rust inhibitors only.

Comment 42 CARB’s regulations are predicated on an emission inventory of all consumer products sold in the state. If a CARB-regulated product (e.g., multi -purpose lubricant) is used in a permitted stationary source (e.g., automobile repair facility), the emission reduction from that particular product has already been included in CARB’s cal culation of necessary state-wide reductions required to attain state and federal ambient air quality standard. To impose additional restrictions on a CARB-regulated product would result further re gulation of a product that has already been subject to a standard deemed to achieve maximum feasible reductions in VOCs. Moreover, any attempt to impose additional Distri ct regulation on such pr oducts would result in a double-counting of the emission reductions achieved by the stat ewide regulation.Final Staff Report ________________________________

Proposed Rule 1144 33 March 2009 Response Emissions from consumer products were not in cluded in the inventor y or emission reduction analysis for PR 1144, so there is no double-c ounting. The purpose of including consumer products was to limit and restrict the use of cons umer products at stationary sources. However, based on discussions with industry, these products are exempted until Ja nuary 1, 2011 from the
VOC limits.

Comment 43 Please accept a request that the time period for written comments be extended until March 1,
2009.

Response Extending the comment period from two weeks to five months would unnecessary delay the rule making activity. Nevertheless, sta ff will continue accep ting feedback from all stakeholders up until the Public Hearing that will be held by the AQMD Governing Board.

Comment 44 The machining industry has been actively involved in an effort to recycle oils in the Southern California basin for the past 12 years. They some times require a solvent additive to reduce the viscosity of the cutting oil so that it can continue to be used in the application. Leakage in the
machines results in ever increasi ng volumes of oil in the sump a nd ever increasing viscosity. If left unchecked, the oil will become unusable for th e application and will have to be disposed. We can use a higher viscosity additive but this would compound the increasing volume problem and significantly contribut e to oil disposal. Even though the elimination of th is solvent based
additive would contribute to th e reduction of VOCs, it would be minimal in comparison to the increased waste generation over th e next 12 years. Please consid er the allowance of high VOC solvent additives used to recycle oil.

Response Staff agrees that recycling of oil should continue. As long as the viscosity additive does not cause the flash point of the recycled oil to drop below 200°F, it can continue to be used. Once technical issues regarding the VOC content test method have been resolved, further limits will be
established for direct-contact l ubricants and general metal work ing fluids. Those limits will
reflect the District’s desire for oil recycling to continue.

Comment 45
The District should consider not re gulating lubricants or only regulat ing lubricants th at come into direct contact with parts or pr oducts during manufacturing or assemb ly. Lubricants have little VOC content and have widespread use in ma ny applications not under consideration by the
District.

Response The intent of the rule was to regulate fluids that come into direct contact with parts or products during manufacture or assembly. In accordance with the recommendation, the proposed rule has been revised to only fluids that come into di rect contact during manu facturing. This would initially apply only to vanishing oils and limits fo r direct-contact lubricants will be established after issues regarding the VOC content test method have been resolved.Final Staff Report ________________________________

Proposed Rule 1144 34 March 2009 Comment 46 The lighter, volatile chain lubricants, for which the VOC limit would preclude, provide a number of great benefits to the end users. They are de signed to penetrate to the inner parts of the chain links in small volumes and provide a film of so lid lubrication to all moving surfaces. The only
alternative fluids which woul d meet the proposed VOC limits would be higher viscosity
lubricants. These fluids would have less penetration of the chain leading to overall poorer lubrication of the internal parts of the chain and ultimately a much shortened chain life. These are typically large conveyor chains (hundreds, if not thousands of f eet long) which are critical to the manufacturing process for moving parts throughout a facility. The cost to replace a chain is typically 6 figures and this would not include any related downtime.

Response The intent of the rule was to regulate fluids that come into direct contact with parts or products during manufacture or assembly. As the commen tor points out, chain lubricants are used for conveyors that move the parts al ong during manufacturing but norma lly do not come into direct contact except for an incidental drip or splash that may occur. An incidental drip or splash
would not be considered direct contact and chain lubricants woul d not be subject to the rule unless they came into direct contact with the part or product during manufacturing.

Comment 47
Some definitions could be clarified to eliminate confusi on. “Lubricants” should apply to “machine tools” instead of just “tools”. “Met al Working Fluids” could be clarified by stating that metal working fluids functio n in the “tool and wo rkpiece interface.” Finally, the types of metal working fluids; straight oi l, semi-synthetic, synthe tic and soluble; shoul d be defined in the
rule.

Response Staff agrees with the recommendation for “Lub ricants” and “Metal Working Fluids” and has revised the definitions accordingly. The types of metal working fluids are used in the staff report but not in the rule language. Those terms are de fined in the staff report but are not necessary in the rule because they are not used there.

Comment 48 A higher VOC limit is necessary for water displ acing/fingerprint suppre ssing and “Domestic and
International” formulations. These cannot be re formulated at present, even using the best currently available technology and represen t a small fraction of total RP usage.

Response Low-VOC water-based and vegeta ble oil based alternatives have been identified for these applications. These alternatives have been av ailable for several years and, in some cases, for
several decades.

Comment 49 We suggest an annual technology review, includ ing a joint ILMA/San Joaquin Refining/AQMD study of Test Method 313L, to determine technologica l feasibility of future rule limits and test
methods.Final Staff Report ________________________________

Proposed Rule 1144 35 March 2009 Response We recommend a regular meeting schedule of the working group to continue discussions regarding issues that arise during the implementation of th e rule and the revision of specifications. The working group will be able to make recommendations for rule limits, test methods, definition clarifications, inventory review and other aspect s of the rule as issues might arise. This recommendation will be included as a resolution in the rule package.

Comment 50 Blending is necessary for viscosity ratings a nd new oil purchased could exceed VOC content
limits.

Response VOC limits for high flash point light oils used as direct-contact lubricants and general metal working fluids will be established after the technical issues regarding the VOC content test
method have been resolved.

Comment 51
Members in attendance of the Pub lic Consultation meeting requested a definition for light oils. The AQMD did little research on this evidently feeli ng replacement fluids were readily available.
Further consideration of this could satisfy both sides.

Response The AQMD’s interest in fluids used as lubricants, metal working fluids or rust inhibitors is their VOC contribution. The AQMD is very much aware of the concerns regard ing the use of high flash point light oils and has re quested details regarding potentially impacted applications.
While staff does conclude that alternative low-VOC products are available, staff has agreed that additional time may help industry to identify, test and implement th e alternatives. Light oils are defined by their viscosity which does not always tr anslate directly to VOC content and thus the AQMD has not tried to define “light oil” in a regulatory sense.

Comment 52 The latest draft of the rule exempts special in terests such as aerospace, small canisters using propellants and consumers. We are requestin g the same exemptions due to the negative economic consequences the proposed ru le will have on the area economies.

Response The proposed rule does include exemptions for some small applicati ons where alternative products have not been identified. These uses in clude rust inhibitors for assembled aircraft and space vehicles, sinker EDM and lapping applications, and fluids used in conjunction with control devices. Consumer products are exempt from the prohibition of sales provisions, but the VOC limits still apply if used in a manufacturing application. Consumer uses are already subject to CARB consumer product regulations. While sta ff acknowledges that there are costs associated with the implementation of Rule 1144, staff has a ttempted to craft a rule that minimizes such costs, while maximizing emission reduction benefits. The analysis included in this staff report shows that the revised staff proposal is technol ogically feasible and very cost-effective.

Comment 53 San Joaquin Refining uses GC/FID routinely to monitor our refining process and consider GC/FID analysis to be an acceptable means to characterize petroleum hydrocarbons by carbonFinal Staff Report ________________________________

Proposed Rule 1144 36 March 2009 distribution and type. We agree with othe rs the need for refinement of Method 313L, particularly the necessity of determining repeatab ility and reproducibility. It appears that methyl palmitate was selected as the marker from earlier re search work to character ize a series of methyl esters as biofuels that are subject to much higher temperatures than metal working fluids.
Consideration should be made for n-tetradecane (C14H30) as a marker for determining the volatility endpoint.

Response Staff agrees that a GC/FID method such as Me thod 313L is an appropriate test method. As discussed in Comment 7 above, methyl palmitate was the endpoint eluted during a related EPAapproved test method to determine VOC content us ing a GC/MS method. Staff is unaware of the association of the endpoint with biofuels. Cu rrently there is no evidence suggesting that ntetradecane would be a better e ndpoint for determining volatility, while SCAQMD Test Method
313-91 has been used for more than a decade to determine VOC content with methyl palmitate eluting at the endpoint of the test. However, based on co mments received, Method 313L has been replaced with EPA Test Method 24, as suggested by several members of industry.

Comment 54 Quantitative aspects of Method 313L should be revise d or made clearer, part icularly in defining a non-arbitrary method of peak group integration when dealing with broad mineral oil “peak humps” that may bisect the methyl palmitate marker for the terminus of the chromatogram.

Response The quantification method provided in the method summary sufficiently explains the technique to determine VOC content when “peak humps” bisect the relative response times of the marker compounds including methyl palmitate. Specificall y, the portion of the p eak hump eluting prior to methyl palmitate is calculated as VOC while the portion of the peak hump eluting after the methyl palmitate marker is not. However, based on comments received, Method 313L has been replaced with EPA Test Method 24, as s uggested by several me mbers of industry.

Comment 55 Coalition for Clean Air applauds AQMD’s effort s to reduce emissions of VOC in lubricants, metal working fluids and rust inhibitors. We enc ourage you to reject industry’s requests to halt and/or delay this important rule . In the process of developing this rule, AQMD has been very considerate of industry’s comments and concerns and we feel that the timeline established in this draft can be met by industry.

Response The AQMD has made every effort to balance achi eving needed emission reductions in a timely manner, while allowing sufficien t time for industry to identif y, test and implement low-VOC
alternatives. Staff is committed to consideri ng all interested stakeholders concerns when developing the provisions of this regulation.

Comment 56
The rule should be bifurcated into two parts. The first covering solvents and be effective January 1, 2010. The second, covering high flas h point light oils, should be ex empt or with an effective date of January 1, 2012 allowing further study and de velopment of alternative low viscosity oils. This would allow the AQMD to realize most of the emission reductions (2.67 tons per day) and delay the more problematic and complex affected applications.Final Staff Report ________________________________

Proposed Rule 1144 37 March 2009 Response Staff agrees and the proposed rule has been m odified to delay establishing limits for metal working fluids and direct-contact lubricants, ex cept vanishing oils. Vanishing oils will have a VOC limit of 50 g/l, effective January 1, 2010. Li mits for metal working fluids and directcontact lubricants will be established once the t echnical issues regarding the VOC content test
method have been resolved.

Comment 57 Several applications utilize lubricants, metal work ing fluids and/or rust inhibitors where there has been insufficient time to determine if they will meet the proposed rules. These operations include cupper lubricants, bodymaking fluids/c oolants, necker lubric ants and can and end making press lubricants used in can manufact uring. It also includes wire bunching and stranding, tool grinding, cubic boron nitride gr inding, aluminum fin st amping, wire drawing, screw and bar machines, magnesium machining, temp er rolling, cold rolling, hot thread rolling oil, penetrating oils, coating or slushing oils used for rust i nhibition, water displacing rust preventatives, salt spray rust inhi bitors, long term rust inhibito rs and marine shipment rust inhibitors. Given the uncertainty , we feel compelled to request exemptions for these operations before knowing if they are nece ssary to protect ourselves.

Response Limits for metal working fluids and direct-con tact lubricants will be established once the technical issues regarding the VOC content test method have been resolved. The AQMD will
continue discussions with interested stakeholde rs through working grou p meetings to receive
data and information. Further evaluations w ill be made with respect to VOC limits and exemptions when evidence has been pr esented demonstrating necessity.

Comment 58 We recommend extending the deadline to 2013 fo r consumer products in conjunction with CARB’s consumer product regulation. We have worked extensively a nd successfully with
CARB but the District’s current proposed regulation has provided no time for consumer products
to reformulate.

Response An exemption for consumer products has been adde d to the rule that will allow additional time, until 2011, for reformulation. The estimated annual usage is relatively minimal but the District does not want to encourage users to switch to higher VOC consumer products because they are exempt. Additionally, industrial facilities present an opportunity to develop market share and customer acceptance for low-VOC consumer products.

Comment 59 We recommend an exemption for aerosol food gr ade silicone lubricants. While the silicone lubricant itself does not contain any VOC, the solv ents used as diluent a nd/or propellants will makes these products non-compliant.

Response Limits for direct-contact lubricants and general metal working fluids will be established after
VOC content test method issues have been resolved.Final Staff Report ________________________________

Proposed Rule 1144 38 March 2009 Comment 60 It is recommended that heavily d iluted aqueous fluids with greater than 90 percent water content be exempted from the rule. It is difficult to measure the VOC content of such products and it is clear that they have very little VOC content. In addition to the high water content, these types of products contain surfactants, oils and synthe tic fluids limiting the potential amount of VOC contained in the product.

Response High water content fluids do present additiona l challenges to accurately measuring the VOC content. The AQMD laboratory, however, has ha d extensive experience testing such materials with accurate, repeatable results. Industry has the option to test the fluids before they are diluted avoiding the laboratory challenges . Additionally, industry may calcu late the VOC content rather than conduct the actual test procedure. As part of the adopting resolution, staff will be committing to work with industry in validatin g Method 313L and/or TGA through round-robin testing. During the round robin testing, if appr opriate, a screening tool will be developed to minimize testing costs for high water content sample s that would have negligible VOC. Many of the high water content samples are emulsions of hi gh flash point oils and surfactants. As earlier noted, determining the VOC content of the high flash point oils is still unresolved and, once resolved, will have an impact on what screening va lue to designate. It is also possible that Method 313L may provide an alternative tool for testing high water content samples.

COMPARATIVE ANALYSIS

Health and Safety Code Section 40727.2 requ ires a written analysis comparing the proposed rule with existing federal and AQMD regulations. Federal regulations do not regulate VOC emissions from vanishing oil and rust inhibitor operations. Most vanishing oils and rust inhibitors are categorized by the AQMD under miscellaneous solvent operations. They are currently subject to Rule 442 - Usage of Solvents, which addresses VOC emissions from VOC-containing materials th at are not subject to VOC limits in any Regulation XI rule. Material or equipment subject to Rule 442, such as vanishing oils and rust inhibitors, are allowed to emit up to 833 pounds per month (fiv e tons per year) of VOC emissions per facility wit hout restriction. Solid film lubricants, dry lubricative materials and barrier coatings are subjec t to Rule 1124 - Aerospace Assembly and Component Manufacturing Operat ions, and are not subject to this proposed rule. Similarly, paints and coatings intended to completely cure and leave a solid, permanent film to beautify and protect metal surfaces are subject to other coati ng rules in Regulation XI and are not subject to this rule. Exampl es include aerospace, architectural, auto body, and metal paints and coatings with applicab le VOC limits in Rules 1113 – Architectural Coatings, Rule 1124, Rule 1151 - Motor Vehicl e and Mobile Equipment Non-Assembly Line Coating Operations, and Rule 1107 – Coating of Metal Parts and Products respectively.

SOCIOECONOMIC ASSESSMENT

A socioeconomic analysis of Proposed Rule 1144 has been performed. A draft report will be released no later than 30 days prior to the AQMD Governing Board hearing.Final Staff Report ________________________________

Proposed Rule 1144 39 March 2009 CALIFORNIA ENVIRONMENTA L QUALITY ACT (CEQA)

Pursuant to the Californi a Environmental Quality Act (CEQA) and AQMD Rule 110, appropriate documentation will be prepared to analyze any potential adverse environmental impacts associated with the Proposed Rule 1144. Comments received at the public workshop and CEQA scoping meeting will be considered when preparing the CEQA document.

DRAFT FINDINGS UNDER THE CALIFO RNIA HEALTH AND SAFETY CODE

Health and Safety Code Section 40727 requires th at prior to adopting, amending or repealing a rule or regulation, the AQMD Governing Board shall make findings of necessity, authority, clarity, consistency, non-duplication, and reference based on relevant information presented at the hearing. The draft findings are as follows:

Necessity – State and federal health-based ambient ai r quality standards for ozone are regularly and significantly exceeded in the AQMD. Th e reduction of VOC from Proposed Rule 1144 is part of a comprehensive strategy to meet federal and State air quality standards.

Authority - The AQMD Governing Board obtains its authority to adopt, amend, or repeal rules and regulations from Health and Sa fety Code Secti ons 39002, 40000, 40001, 40440, 40441,
40702 and 41508.

Clarity - The AQMD Governing Board has determin ed that Proposed Rule 1144 – Vanishing
Oils and Rust Inhibitors

, is written and displayed so that the meaning can be easily understood by persons directly affected by them.

Consistency - The AQMD Governing Board has determined that Proposed Rule 1144 – Vanishing Oils and Rust Inhibitors

, is in harmony with, and not in conflict with or contradictory to, existing statutes, court decisions , federal or state regulations.

Non-Duplication - The AQMD Governing Board has de termined that Proposed Rule 1144 – Vanishing Oils and Rust Inhibitors

, does not impose the same requirement as any existing state or federal regulation, and the proposed amendments are necessary and proper to execute the powers and duties granted to, and imposed upon, the AQMD.

Reference - In adopting this regulation, the AQMD Governing Board references the following statutes which the AQMD hereby implements, inte rprets or makes specific: California Health and Safety Code sections 40001, 40440, and 40702.

REFERENCES

“Comments of the Independent Lubricant Manuf acturers Association (ILMA) on ‘Metalworking Fluids: Summary of Nomination for Review: NTP 12th Report on Carcinogens, September 2003 Submitted by Report on Carcinogens Group, NIEHS’”, [Online] Available at

www. ilma.org /about/ntp_comments.pdf (Accessed July 29, 2008).

U.S. Environmental Protection Agency, Office of Enforcement and Compliance Assurance, Office of Compliance (September 1995). Sector Notebook Project: Pr ofile of the Fabricated Metal Products Industry [Online] Available at http://www.epa.gov/compliance/re sources/publications/assistanc e/sectors/notebooks/fabmetsn.pd

f (Accessed July 29, 2008).Final Staff Report ________________________________

Proposed Rule 1144 40 March 2009 California Manufacturers Register . Twinsburg: Harris Infosource, 2006.

Method 24 – Determination of Vola tile Matter Content, Water Content, Density, Volume Solids, and Weight Solids of Surface Coatings. U.S. Environmental Protection Agency, February 2000.

SCAQMD Method 313-91 – Determ ination of Volatile Orga nic Compounds (VOC) by Gas Chromatography/Mass Spectrometry (G C/MS). SCAQMD, February 1997

“Assessment, Development and Demonstration of Alternatives to VOC-Emitting Lubricants, Vanishing Oils and Rust Inhibi tors”, August 2006. Prepared by the Institute for Research and Technical Assistance for South Coast Air Qualit y Management District Under Contract No. 05058 and the United States Environmental Protection Agency Region IX.

Popoli, William (2000). Spindle Bearing Basics . Manufacturing Engineering Vol.125 No. 5

Saalmuller, Mark (2001). Evolving From Cam Multi-Spindles to CNC. Production Machining.

Zelinski, Peter (2006). Seeing More for CNC Multi-Spindles. Production Machining.

Sedelmeier, Gregory (2008). Managing Water Cont amination to Maintain Effective Steel Mill Lubrication. Machinery L ubrication Issue Number: 200807

Federal Energy Management Program. “FEM P Designated Product: Gas Water Heaters”
available online at http://www1.eere.energy.gov/femp/pdfs/pseep_gaswtrheaters.pdf (Accessed August 27, 2008).

Walsh, Kathleen. CARB General Counsel. "Interpr etation of Health and Safety Code Section 41712 (f)." Letter to William Wong, Senior Deputy Distri ct Counsel. February 20, 2001.Preliminary Draft Staff Report - Appendix A ________________________________

Proposed Rule 1144 A - 1 March 2009 Appendix A – Lubricant, Metal Working Flui d and Rust Inhibito r VOC Content Test Results (EPA Test Method 24)

Type Application Results

Rust Inhibitors Water-based Rust Inhibitor/Stamping 295 g/l* Straight/Consumer Consumer/General 530 g/l Straight Rust Inhibitor/Stamping 380 g/l Synthetic Corrosion Preventive 471 g/l Mineral Anti-Rust 253 g/l Vegetable Cleaner/Rust Inhibitor 121 g/l Unknown Cleaner/Rust Inhibitor 765 g/l

Straight Rust Inhibitor 119 g/l Straight Rust Inhibitor 420 g/l Straight Rust Inhibitor 12 g/l Vanishing Oils Straight Stamping 597 g/l Straight Stamping 686 g/l Vanishing Vanishing/Stamping 729 g/l

* Before dilution