Yolo-Solano Air Quality Management District

1947 Galileo Court, Suite 103

Davis, CA 95618

(530)757-3650

www.ysaqmd.org

PROPOSED AMENDMENTS TO

ORGANIC SOLVENT RULES

RULE 1.1, GENERAL PROVISIONS AND DEFINITIONS

RULE 2.25, METAL PARTS AND PRODUCTS COATING OPERATIONS

RULE 2.26, MOTOR VEHICLE AND MOBILE EQUIPMENT COATING

OPERATIONS

RULE 2.29, GRAPHIC ARTS PRINTING OPERATIONS

RULE 2.30, POLYESTER RESIN OPERATIONS

RULE 2.31, SURFACE PREPARATION AND CLEANUP

RULE 2.33, ADHESIVE OPERATIONS

RULE 2.35, PHARMACEUTICAL MANUFACTURING OPERATIONS

RULE 2.39, WOOD PRODUCTS COATING OPERATIONS

PROPOSED REPEAL OF

RULE 2.24, SOLVENT CLEANING OPERATIONS (DEGREASING)

FINAL STAFF REPORT

May 5, 2008

Prepared by: Nancy Fletcher

nfletcher@ysaqmd.org

Reviewed by: Susan McLaughlin

smclaughlin@ysaqmd.org
Table of Contents Page

I. EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 03

A. BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 04

II. DISCUSSION OF PROPOSED RULE REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . 10

III. COMPARISON TO OTHER APPLICABLE REGULATIONS AND REQUIREMENTS . 31

IV. IMPACTS OF THE PROPOSED RULE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

V. ENVIRONMENTAL IMPACTS OF METHODS OF COMPLIANCE . . . . . . . . . . . . . . . 42

VI. REGULATORY FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

VII. PUBLIC COMMENTS AND STAFF RESPONSES . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

VIII. REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

ATTACHMENT A PROPOSED AMENDMENTS TO:

RULE 1.1, GENERAL PROVISIONS AND DEFINITIONS

RULE 2.25, METAL PARTS AND PRODUCTS COATING

OPERATIONS

RULE 2.26, MOTOR VEHICLE AND MOBILE EQUIPMENT COATING

OPERATIONS

RULE 2.29, GRAPHIC ARTS PRINTING OPERATIONS

RULE 2.30, POLYESTER RESIN OPERATIONS

RULE 2.31, SURFACE PREPARATION AND CLEANUP

RULE 2.33, ADHESIVE OPERATIONS

RULE 2.35, PHARMACEUTICAL MANUFACTURING OPERATIONS

RULE 2.39, WOOD PRODUCTS COATING OPERATIONS

STRIKE-OUT UNDERLINE VERSIONS

ATTACHMENT B EMISSION CALCULATIONS

ATTACHMENT C NOTICE OF EXEMPTION FROM CEQA GUIDELINES 

ATTACHMENT D RESOLUTION NO. 08-05

ATTACHMENT E WRITTEN COMMENTS RECEIVED
Staff Report - Organic Solvent Rules May 5, 2008

Page 3

I. EXECUTIVE SUMMARY

On May 14, 2008, the Yolo-Solano Air Quality Management District (District) Board of

Director’s will consider the proposed amendments to Rule 1.1 General Provisions and

Definitions, Rule 2.25 Metal Parts and Products Coating Operations, Rule 2.26 Motor

Vehicle and Mobile Equipment Coating Operations, Rule 2.29 Graphic Arts Printing

Operations, Rule 2.30 Polyester Resin Operations, Rule 2.31 Surface Preparation and

Cleanup, Rule 2.33 Adhesive Operations, Rule 2.35 Pharmaceutical Manufacturing

Operations, and Rule 2.39 Wood Products Coating Operations. In addition the Board will

consider the recision of Rule 2.24 Solvent Cleaning Operations (Degreasing) . 

The District is revising the solvent-cleaning requirements for surface preparation and

cleanup of the aforementioned rules to lower emissions of volatile organic compounds

(VOCs). The District is proposing to lower the VOC content limit for solvents used for

surface preparation and cleanup. Lower VOC content limits for these solvents have been

achieved, for most applications in other Air Districts through the use of aqueous or semiaqueous technologies, exempt compounds, or the development of new cleaning

materials/technologies.

Staff is proposing a two tier approach for lowering the VOC content limit for solvents used

for surface preparation and cleanup. Staff is proposing to lower the limits for general

categories to 50 grams per liter by 2009, and 25 grams per liter by 2011. The District is

proposing higher VOC limits and exemptions for specific cleaning categories that are

unable to completely convert to aqueous solutions. The proposed limits are mainly based

on limits established by the South Coast Air Quality Management District (SCAQMD),

based on technology assessments they performed. Due to the difficulty the printing industry

has experienced with meeting the limits established by the SCAQMD, the SCAQMD has

postponed the implementation date for specific categories. Therefore the District has

worked with the United States Environmental Protection Agency (EPA) , California Air

Resources Board (ARB) and printing industry to establish an alternative limit for these

categories. The District is committed to revisiting these categories before the effective date

of 2011 to determine if the lower limits are achievable at that time. 

Standards for surface preparation and cleanup are currently in the individual prohibitory

rules, as well as in Rule 2.31 Surface Preparation and Cleanup. The District is proposing

to restructure the rules, by moving the requirements for surface preparation and cleanup

from the individual category rules to Rule 2.31. District Staff is also proposing to incorporate

other changes resulting in improvement to rule clarity, effectiveness, and consistency with

other agencies.

The main revisions to the surface preparation and cleanup requirements in the

aforementioned rules include the following:

1. Establish lower material VOC limits for most cleaning applications,

2. Create new subcategories for solvent cleaning activities and modify rule

exemptions,
Staff Report - Organic Solvent Rules May 5, 2008

Page 4

3. Remove vapor pressure requirements for surface preparation and cleanup from all

categories and replace with restrictions based on VOC content in grams per liter,

4. Create a standard format for consistency,

5. Standardize rule language where applicable,

6. Move all requirements for cleaning materials used for surface preparation and

cleanup to Rule 2.31,

7. Update the standards and requirements for surface preparation and cleanup,

8. Update test methods for control systems,

9. Rescind Rule 2.24, Solvent Cleaning Operations (Degreasing).

Amendments to the aforementioned rules are expected to lower VOC emissions from

solvent cleaning operations in the District by 278 tons per year.

Solvent cleaning is performed by manufacturing and service operations for application

equipment and manufactured or serviced parts. Solvent cleaning encompasses both

surface preparation and cleanup. The proposed rule amendments will affect a wide variety

of industries. Any source performing solvent cleaning will be affected, including sources

not currently regulated by the District. Industries potentially affected include repair shops,

automotive service stations, other vehicle repair shops including truck, bicycle, recreational

vehicle and fleet repair, agriculture, printing/graphic arts, coating operations including

architectural coatings, pharmaceuticals, and other manufacturing. 

The proposed amendments will neither have a significant nor detrimental effect on the

environment. Therefore, staff has prepared a Notice of Exemption to satisfy the

requirements of the California Environmental Quality Act (CEQA). The notice states that the

revisions to the Rules are exempt from the requirements of CEQA pursuant to Section

15308, Actions by Regulatory Agencies for Protection of the Environment.

A. BACKGROUND

Ozone

Reducing VOC emissions is part of the District’s strategies for reducing ozone formation.

Ozone is not directly emitted from polluting sources and is classified as a secondary

pollutant. Ozone forms in the atmosphere through complex chemical reactions between

VOCs and nitrogen oxides with the presence of a catalyst such as sunlight.

Ozone is a highly reactive gas that can be harmful to public health when it is in high

concentrations at ground level. Ozone is a strong irritant that attacks the respiratory system

and can damage lung tissue. High concentrations can irritate the nose and throat and can

aggravate respiratory conditions such as asthma, bronchitis, and emphysema. 
Staff Report - Organic Solvent Rules May 5, 2008

Page 5

Regulations

The EPA and ARB have adopted ambient air quality standards to determine outdoor

pollutant levels considered safe for the public. The standards are health-based and

designed to provide protection for the most sensitive groups. Monitored levels of ozone in

the District exceeds both the State and Federal Ambient Air Quality Standard, designating

the District as non-attainment for both standards.

The Federal Clean Air Act (CAA) requires air districts in non-attainment for the ozone

standards to prepare a plan describing how the National Ambient Air Quality Standard will

be met. The District expects to commit as part of the 8-Hour Ozone Attainment Plan to VOC

reductions from surface preparation and cleanup operations in order to assist in achieving

attainment and demonstrate actual VOC emission reductions.

The California Clean Air Act requires the District to develop a plan to achieve attainment

with the state ozone standard. The plan requires the District to implement Best Available

Retrofit Control Technology (BARCT), defined in the California Health and Safety Code

(CH&SC) as “an emission limitation that is based on the maximum degree of reduction

achievable, taking into account environmental, energy and economical impacts by each

class or category of source.” Additionally, the District’s strategy for attainment must

achieve a 5% ozone precursor emission reduction or adopt all feasible control measures.

The District identified lowering VOC content limits for surface preparation and cleanup

operations as part of the plan to satisfy these requirements. 

All feasible control measures are those which have the most effective regulatory emissions

standards demonstrated in California’s air districts. Other districts have already

implemented regulations limiting the VOC content in materials used for surface preparation

and cleanup. A VOC standard of 50 grams per liter for materials, used for general cleaning

in some categories, has been in effect in the SCAQMD and Bay Area Air Quality

Management District (BAAQMD) since 1999. The San Joaquin Valley Air Pollution Control

District (SJVAPCD) and Sacramento Metropolitan Air Quality Management District

(SMAQMD) have also adopted the 50 gram per liter standard. The SCAQMD and

SJVAPCD have subsequently lowered the VOC standard to 25 grams per liter for materials

used for general cleaning and have adopted stringent limits for other categories. The tighter

standards have been in effect at the SCAQMD since 2005. In addition, SMAQMD is

currently proposing to lower VOC content limits for cleaning materials used for surface

preparation and cleanup based on these standards.

VOC Emission Reductions

Reducing VOCs from solvent usage has been a fundamental component of the District’s

historic ozone reduction strategy. The District has developed a series of rules designed to

regulate emissions of VOCs from sources using solvents, and from solvent waste

generated during production, repair, maintenance, and general work areas. The rules

require control of emissions from the entire process, including standards for the allowable

VOC content for the solvent used, standards for equipment, and standards for work
Staff Report - Organic Solvent Rules May 5, 2008

Page 6

practices.

The District is proposing to amend the existing rules by lowering the VOC limits for surface

preparation and cleanup solvent, which the District expects to be met by increasing the use

of aqueous cleaning technologies and exempt compounds. For most cleaning activities, low

VOC and aqueous solvents have been successfully used as a substitute for solvent based

cleaners in many industrial and commercial applications. There are numerous products

readily available as other air Districts throughout the State have been requiring low VOC

cleaners for several years. 

The printing industry has experienced difficulty with converting to products that meet the

lower limits established by the SCAQMD for lithographic/letterpress printing, screen printing

and ultraviolet ink. The limits adopted by the SCAQMD have not yet been successfully

implemented for all printing categories. During the past years ,the SCAQMD has postponed

the implementation date for specific categories due to the inability of industry to meet the

limits. The SCAQMD limit for letterpress and lithographic of 100 grams per year just

recently went into effect. Previous attempts to meet this limit have been unsuccessful. The

SCAQMD also postponed the implementation of 100 grams per liter in the for the ultraviolet

category until 2009. In response, the District worked with the EPA and printing industry to

establish alternative composite vapor pressure requirements for these limited printing

categories. However, the ARB strongly urged the District to reconsider the use of vapor

pressure requirements. In response, the District worked with both the EPA and ARB to

establish slightly higher limits based on a representative VOC content for solvents meeting

a composite vapor pressure of 10 mm Hg for these categories. The VOC content limits

were calculated based on the assumption referenced on page 17 in the EPA’s Control

Technique Guidelines for Offset Lithographic Printing and Letterpress Printing (September

2006), using cleaning materials from a solvent with a VOC composite partial vapor pressure

less than 10 mm Hg at 20EC with good work practices results in an emission reduction

comparable to using cleaning materials containing less than 30 weight percent VOC. The

District is committed to revisiting these categories before the effective date of 2011 to

determine if the lower limits are achievable at that time. 

The District is proposing a two tier approach for lowering the VOC limits for cleaning. For

most cleaning operations, the District will first require sources to use cleaning materials with

a 50 grams per liter limit for VOCs, effective 2009. By 2011, most cleaning operations will

be required to use a cleaning material with a VOC content of 25 grams per liter or less.

Compliance with the new requirements can be achieved through the use of aqueous

technologies, exempt compounds, or other emission control technologies. Operators using

cleaning materials with a VOC content of 25 grams per liter or less will be exempt from the

requirements of Rule 2.31. Any source claiming an exemption is still subject to the

requirements of Section 503 Burden of Proof. 

The following table summarizes the District’s approach for lowering VOC content limits. The

table includes current VOC content limits for solvents used for surface preparation and

cleanup and cites the rules where the requirements are currently found. The table also

includes the lower proposed limits and new categories.
Staff Report - Organic Solvent Rules May 5, 2008

Page 7

VOC content limit

grams/liter

Currently in Effect Effective

7/1/2009

Effective

1/1/2011

Product

Cleaning

General Coating, Adhesive, or Ink

Application

200

(Rule 2.31, 301.1)

50 25

Metal Parts and Products 200 or boiling point > 190E C

(Rule 2.25, 304.1)

Motor Vehicle 72

(Rule 2.26, 303.1)

Motor Vehicle (plastic

parts)

780

(Rule 2.26, 303.1)

Cleanup Materials -

Polyester Resin

Solvent reclamation if VOC>

200 g/l and usage > 4

gal/day

(Rule 2.30, 302)

Surface Prep & Cleanup -

W ood Products

200

(Rule 2.39, 306.5)

Electrical Apparatus Components &

Electronic Components

900

(Rule 2.31, 301.6)

500 100

Medical Devices & Pharmaceuticals 800 800

Repair Cleaning

& Maintenance

Cleaning

General 900

(Rule 2.31, 201.2)

50 25

Electrical Apparatus Components &

Electronic Components

900 100

Medical Devices & Pharmaceuticals

-Tools, Equipment, Machinery

800 800

Medical Devices & Pharmaceuticals 

-General W ork Surfaces

600 600
Staff Report - Organic Solvent Rules May 5, 2008

VOC content limit

grams/liter

Currently in Effect Effective

7/1/2009

Effective

1/1/2011

Page 8

Cleaning of

Application

Equipment

Coatings and Adhesives 950

(Rule 2.31, 301.2)

50 25

Polyester Resin 200 g/l - or 

1100 & < 1.0 mm Hg - or

solvent reclamation system

(Rule 2.31, 301.4)

Inks - Screen Printing 1070 and 5 mm Hg

(Rule 2.31, 301.5a)

500 100

Inks - Lithographic and Letterpress 900 and 25 mm Hg

(Rule 2.31, 301.5b)

650 238

Inks - Ultraviolet (except screen printing) 800 and 33 mm Hg

(Rule 2.31, 301.5d)

650 238

Inks - Specialty Flexographic 100 and 3 mm Hg

(Rule 2.31, 301.5c)

100 100

Inks - Gravure (Publication) 100 and 3 mm Hg

(Rule 2.31, 301.5c)

100 100

Inks - Other 100 and 3 mm Hg

(Rule 2.31, 301.5c)

50 25

Medical Devices & Pharmaceuticals 810 810

General Industry 50 25

Aqueous Degreasing Systems

Aqueous degreasing systems differ from solvent based systems. Traditional solvent parts

cleaners are constructed of steel or stainless steel, whereas aqueous systems are made

from steel, stainless steel or plastic. Aqueous units are generally equipped with a heating

element to increase the effectiveness of the cleaner. There is more flexibility with cleaning

options for aqueous systems because the solutions used are not as flammable as traditional

solvents. 

There are five common types of cleaning systems that can be used with aqueous solution:

1. Sink-on-a-drum. The sink-on-a-drum parts washer consists of a sink mounted on

a drum/barrel. The unit is equipped with a hose, brush applicator and is a manually

operated. They can contain filters or skimmers which extend the life of the cleaner.

This unit is the most commonly used and most comparable to the traditional remote
Staff Report - Organic Solvent Rules May 5, 2008

Page 9

reservoir cleaners.

2. Enzyme System. Enzyme systems are similar to sink-on-a-drum units. They use

specially formulated enzyme cleaners. Microbes are added to the system through an

impregnated filter or are added directly to the cleaner. The cleaner emulsifies the

grease and the microbes breakdown and biodegrade the oils. These units are

commonly made of plastic and have a long bath life.

3. Immersion Parts Washer. The immersion unit is similar to the sink-on-a-drum, unit

except it has a false sink, allowing access to a reservoir for cleaning or soaking when

removed. 

4. Spray Cabinet. The spray unit operates by spraying or flushing high pressure

cleaners in an enclosed unit. These units are automated.

5. Ultrasonic Cleaner. The ultrasonic units use cavitation energy from sonic waves to

clean parts. These units are effective for cleaning equipment or parts with small

crevices or complex geometries, such as transmissions and carburetors. These units

are automated. 

Cleaning Solutions

Compliance with the lower VOC content limits can be achieved through the use of aqueous

solutions, low VOC organic solvents, and exempt compounds. Many cleaning operations in

the District already incorporate compliant cleaning materials. Common solvents currently

used for surface preparation and cleanup include acetone, isopropyl alcohol, d-limonene and

paint thinner/mineral spirits. Acetone and d-limonene are already considered compliant

materials. Isopropyl alcohol is commonly used in many applications including pharmaceutical

operations regulated by the FDA.

There are many aqueous cleaners available meeting the requirements of the rule revisions.

Aqueous solutions are available in a wide ph range from acidic to alkaline. Acidic solutions

are typically used for scale or salts and are not as effective for greases and oils. Neutral and

alkaline solutions can contain surfactants and rust inhibitors to improve effectiveness and

prevent rusting or corrosion. Mildly alkaline solutions are suitable for oil and greases. The

SCAQMD has certified over a hundred cleaners as ‘Clean Air Solvents’, meeting specific

criteria including a VOC content limit of 25 grams per liter. In addition, SCAQMD maintains

a list of companies who supply aqueous cleaners and aqueous cleaning systems. 

Additional Rule Amendments

Due to past confusion with the overlap of multiple rules containing solvent requirements, the

District is proposing to consolidate the solvent surface preparation and cleanup requirements

into Rule 2.31 Surface Preparation and Cleanup. The District will remove requirements for

all aspects of surface preparation and cleanup from the individual rules, including applicable

VOC limits, equipment requirements and work practice requirements.
Staff Report - Organic Solvent Rules May 5, 2008

Page 10

The District is proposing to delete Rule 2.24 from the District Rules and Regulations.

Requirements for batch cold cleaners, remote reservoir cleaners and gun washers will be

addressed in Rule 2.31. The District currently does not have any other degreaser permitted

or operating in the District. Any source proposing to operate a degreaser would require a

Permit to Operate and would be subject to Rule 3.4 -New Source Review. 

II. DISCUSSION OF PROPOSED RULE REQUIREMENTS

Listed below are descriptions of the proposed revisions and the intended purposes of the

revisions.

Rule 2.31 Surface Preparation and Cleanup

Sections 101 and 102

The term solvent cleaning operation was replaced with surface preparation and cleanup in

these sections. Staff is also revising the applicability to simplify the section. Staff added a

definition for surface preparation and cleanup so the parts of the definition will be replaced

by the defined term. In addition staff is adding the inclusion of any person selling or

distributing solvents subject to the provisions of the rule for clarity. Rule 2.31 includes

provisions in Section 402 Compliance Statement directed at persons selling or distributing

solvents subject to the rule. 

Sections 110- 113 (formerly 110-118) Exemptions

Staff is proposing to regroup the exemptions in this section into different categories for

clarity. Many of the exemptions listed are for portions of the rule not the entire rule. Staff

clustered the exemptions from different sections of the rule together. This allows quick

identification of what requirements of the rule the exemption is for.

Section 110 Exemptions - General

Staff is proposing to change the exemption for dry cleaning operations subject to Rule 9.7

to clarify the exemption covers all dry cleaning operations from the entire rule instead of

exempting the operations from only the rule standards. Dry cleaning operations are not

subject to Rule 2.31, they do not meet the applicability criteria. Rule 9.7 Perchloroethylene

Dry Cleaning Operations has source specific record keeping and testing requirements for

operations using perchloroethylene. 

Staff is proposing to remove former Section 110 Exemption - Small User. Staff is proposing

to add specific exemption categories, therefore the general exemption is no longer needed.

Staff is proposing to exempt cleaning operations using a solvent containing no more than

25 grams of VOC per liter of material. This exemption provides incentive for operators to use

alternative products. Compliant products do not require the controls of traditional high VOC

solvents. 

Staff is proposing to exempt janitorial cleaning and stripping of cured coatings, cured
Staff Report - Organic Solvent Rules May 5, 2008

Page 11

adhesives, and cured inks from the rule requirements. Previously these categories were

exempted from the rule standards, but were subject to record keeping conditions.

Staff is proposing to add an exemption for small degreasers. Rule 2.24 Solvent Cleaning

Operations, previously had an exemption for small degreasers with reservoir capacities of

five gallons or less or an evaporative area less than 1.0 square foot. The revised exemption

is more restrictive exempting degreasers with a capacity of 2.0 gallons or less or an

evaporative area of 1.0 square foot or less. 

Staff is proposing to add an exemption for operations subject to the NESHAP requirements

of 40 CFR Part 63 Subpart T. 

Staff is proposing to add an exemption for cleaning operations in printing pre-press or

graphic arts pre-press areas. This category has been exempted in SCAQMD Rule 1171. 

Section 111 Exemptions - Solvent Requirements

Staff is proposing to add an exemption for paper-based gaskets and clutch assemblies

where rubber is bonded to metal by means of an adhesive. These categories have been

identified by the SCAQMD and the California Trucking Association in a joint study as

categories that could not be properly cleaned with aqueous solvents. 

Staff is also proposing to add an exemption for solvents used to clean sterilization indicating

inks consistent with other agencies.

These categories have exemptions in SCAQMD Rule 1171, as well as, in other districts.

 

Staff is proposing to add an exemption for the cleaning of coating and adhesive application

processes utilized to manufacture a transdermal drug delivery product. A similar exemption

is in place in SCAQMD Rule 1171. The exemption allows for the use of ethyl acetate for this

very specific process. Currently, the FDA has not validated the use of any other product for

this process. Ethyl acetate has a VOC content limit of 900 g/l and therefore exceeds the

proposed 800 and 810 g/l limits. The referenced process potentially involves the use of ethyl

acetate for surface preparation and cleanup for more than one category listed in the table.

Therefore the exemption includes the use of ethyl acetate for cleanup from the entire

process. 

Section 112 General Prohibitions

Staff is proposing to add an exemption from Section 301 General Prohibitions. Staff is

proposing to exempt printing operations where the roller or blanket wash is applied

automatically, consistent with the exemption in SCAQMD solvent rules.

Section 200 Definitions

Staff is proposing to streamline definitions for exempt compounds, maintenance cleaning,

remote reservoir cold cleaner, solvent, surface preparation and cleanup, volatile organic

compound, and volatile organic compound composite partial pressure for clarity and to make
Staff Report - Organic Solvent Rules May 5, 2008

Page 12

the language consistent with District rules. The definition for maintenance cleaning was

expanded to include sterilization. The definition for remote reservoir cold cleaners now

includes parts washer which is a more common name for the cleaning devices. The District

is proposing to move the calculation for VOC composite vapor pressure from the definition

section into Section 605, Calculation of Composite Vapor Pressure. Staff is proposing to add

standard definitions for air solvent interface, application equipment, batch loaded cold

cleaner, control device, doctor blade, electrical apparatus component, electronic component,

emission control system, freeboard height, freeboard ratio, general work surface, high

precision optics, intaglio printing, medical device, pharmaceutical, pharmaceutical product,

product cleaning, and VOC content. Staff is proposing to delete the definition for application

line, electronic assembly and grams of VOC per liter of material. Application line and

electronic assembly are not used in the rule and grams of VOC per liter of material will be

replaced with Section 604 Calculation of VOC content. Staff is proposing to remove the

definition for solvent cleaning operation and replace with a definition for surface preparation

and cleanup, due to inconsistencies with the use of the definition of solvent cleaning

operation.

Section 300 Standards.

Staff is proposing to replace the standards previously outlined in Section 301 General

Prohibitions with a table, for rule clarity. In addition, staff is proposing to create new

subcategories for solvent cleaning activities, lower VOC limits for many solvent cleaning

activities, and remove the vapor pressure requirements.

Staff is proposing to create new subcategories in order to establish feasible limits for

solvents used for different cleaning activities. The categories have been established by other

Districts after examining performance evaluations for solvents used for different cleaning

activities.

Staff is adding subcategories for medical devices and pharmaceutical operations that are

now subject to Rule 2.31. Limits take into considerations requirements for the use of

solvents for disinfection/sterilization required by the Food and Drug Administration (FDA)

and/or the National Institute for Health. The District is also proposing a separate category

for medical and pharmaceuticals in the printing section of the table. The District has a

pharmaceutical facility with a printing process regulated by the FDA. The limits proposed will

accommodate operational requirements from the FDA for this process. The District is

proposing the limit of 800 g/l for Product Cleaning - Medical Devices and Pharmaceuticals,

Repair Cleaning and Maintenance Cleaning - Medical Devices and Pharmaceuticals - Tools,

Equipment, Machinery effective 2009.

Staff is proposing to lower VOC content limits based on limits established in other Districts.

Staff have reviewed SCAQMD’s technology assessments for solvent usage and is proposing

limits based on those that have been successfully implemented with the exception of

proposed limits for specific printing subcategories. The cleaning of ink application equipment

for lithography/letterpress, screen printing, and ultraviolet/electron beam inks solvent

cleaning VOC content limit of 100 grams per liter had an original implementation date of July

1, 2005 in the SCAQMD. An interim limit was established while a technology assessment
Staff Report - Organic Solvent Rules May 5, 2008

Page 13

was performed for these categories. The technology assessment completed in August 2006,

concluded the implementation date should be extended until January 1, 2008. Recently, in

February 2008, the SCAQMD reported the implementation of the 100 grams per liter limit

for the cleanup of lithographic ink application equipment using UV/EB inks, and the cleanup

of on-press screens and screen reclamation using automatic cleaning equipment in screen

printing needed to be delayed. The SCAQMD revised Rule 1171 to delay the implementation

of these limits until January 1, 2009. Therefore, staff worked with the EPA, ARB and printing

industry to establish a limit for these categories. Staff is proposing to lower the VOC content

limit to 238 grams per liter effective 2011. This limit was based on a partial pressure limit

referenced in the EPA’s Control Technique Guidelines for Offset Lithographic Printing and

Letterpress Printing (September 2006). Similarly to SJVAPCD, staff project this will allow

time for the feasibility of the 100 gram per liter limit to be assessed. If the SCAQMD

determines the limit is not feasible the YSAQMD will be able to re-open Rule 2.31 before the

compliance deadline to re-assess the limits.

 

Staff is proposing to replace the current vapor pressure requirements with lower VOC

content limits. Vapor pressure affects the rate at which a solvent evaporates and does not

directly impact the total quantity of mass emissions produced. Staff feels lowering the limits

on the VOC content will more effectively reduce VOC emissions, allow the emissions to be

more accurately quantified, while allowing companies to have more flexibility in choosing

compliant solvents.

Staff is proposing to make minor changes to the language in Section 302 Cleaning Devices

and Methods Requirements, to clarify requirements. Staff is removing language establishing

an implementation date since the date has already passed and the requirements are

currently in effect. Other changes include specifying containers described in Section 303.2,

must be closed. In addition language in Section 302.4 has been amended to clarify any

cleaning device or mechanism the APCO will allow must result in comparable emission

limits, to limits established in Table 1.

Staff is proposing to add Section 303 Cleaning Devices - General Requirements. This

section was added to clarify good work practice requirements for sources using cleaning

devices outlined in Section 302. These requirements were in the rule previously in former

Section 303 Remote Reservoir Cold Cleaners. Previously Rule 2.31 exempted any

equipment subject to Rule 2.24 Solvent Cleaning Operations (Degreasing). Rule 2.31 no

longer exempts the equipment, although the District knows of no equipment besides remote

reservoir cleaners, operating in the District that would have been subject to Rule 2.24.

Therefore, the District is generalizing some of the requirements to include other equipment

types now subject to Rule 2.31. 

Staff is proposing to add Section 304 Cleaning Devices - Requirements for Equipment Using

Solvents with a High VOC Content. This section will only be applicable to sources using

solvents over 50 grams per liter in a batch loaded cold cleaner. Other equipment subject to

federal requirements still need to comply with federal standards. Requirements for batch

loaded cold cleaners were previously outlined in Rule 2.24 and the equipment was exempted

from Rule 2.31. Rule 2.24 did not include any limits for solvents used in degreasers. Rule

2.31 is establishing standards for solvents used in any cleaning operations and is no longer
Staff Report - Organic Solvent Rules May 5, 2008

Page 14

exempting degreasers from the rule. District staff feels this is a more effective way of

controlling emissions from this source category than the former operation and equipment

requirements of Rule 2.24. However, some categories will still allow higher VOC content

limits for solvents used. The District is therefore carrying over some of the operation and

equipment requirements from Rule 2.24 to Rule 2.31 for batch loaded cold cleaners. If a

facility is using a solvent with a VOC content greater than 50 grams per liter, they are not

required to use a batch-loaded cold cleaner. They can use any of the methods or devices

listed in Section 302 and would not be subject to Section 304 if they were using some other

type of a device to comply such as an airless/airtight cleaning system.

Staff is proposing to amend requirements outlined in former Section 303 Remote Reservoir

Cold Cleaners. District staff is proposing to clarify all requirements for operating remote

reservoir cleaners is in addition to complying with VOC content limits established in Table

1. As previously discussed, Staff is proposing to move previous sections 303.4 and 303.5

to section 303 Cleaning Devices - General Requirements. Staff is proposing to remove

requirements for limiting the draft rate in work rooms pertaining to remote reservoir cold

cleaners. The requirement for the draft rate does not affect any emissions from the cleaners.

In addition, the District believes requirements affecting work room conditions should not be

addressed by the District unless necessary. The District is also proposing to add additional

requirements for remote reservoir cleaners that were previously addressed in Rule 2.24.

Some of the requirements are outdated and do not apply to equipment using aqueous

solutions therefore these requirements will only effect remote reservoir cleaners using

solvents with a VOC content greater than 50 grams per liter. Other proposed changes

include replacing degrease with clean in Section 303.4 for clarity. 

Staff is proposing to replace Section 304 Storage and Disposal, with Sections 306 -Storage

and Disposal -General. Section 306, outlines general work practice requirements for

materials containing VOCs.

Staff is proposing to add Section 304 Spray Equipment - Cleanup. This section will outline

requirements for cleaning spray equipment. This section is not applicable to operators using

solvents with a VOC content of less than 25 grams per liter.

Staff is proposing to amend Section 305 Emission Control System. Staff is proposing to add

language clarifying the system must be approved by the APCO. Staff is also proposing to

add language stating that the system is approvable if it meets the requirements outlined in

the individual source specific prohibitory rule. This will allow for consistency in requirements

for facilities opting to use a single emission control device for the entire process including

surface preparation and cleanup. 

Staff is proposing to replace former Section 306 General Prohibitions with Section 307

General Prohibitions. Section 307 states a solvent can not be atomized unless it is vented

to a control device. Requirements in former Section 306.2 will be incorporated into Section

401 Prohibition of Specification. 

 Section 400 Administrative Requirements
Staff Report - Organic Solvent Rules May 5, 2008

Page 15

Staff is proposing to add Section 401 Prohibition of Specification, for consistency with other

rules. Staff is proposing to renumber the remaining requirements.

Staff is proposing to add Section 402 Compliance Statement for consistency with other rules.

Similar requirements are already in place in individual rules.

Staff is proposing to add Section 403 Operation and Maintenance Plan (O&M Plan). The

District is proposing to require any person using an emission control device to have an

approved plan outlining operation and maintenance procedures to demonstrate compliance

with the rule requirements. The plan must also include record keeping provisions in

compliance with the rule’s record keeping requirements. District approval of an emission

control device will require an approved plan. There are currently no sources using an

approved emission control device for compliance so an implementation date is not

necessary. 

Section 500 Monitoring and Records

Staff is proposing to amend Section 501 to clarify rule requirements. Staff is proposing to

list the specific information the District will require from operations subject to this rule. Staff

is also adding section 501.3 requiring copies of the manufacturers product data sheet or

material safety data sheet to be available to the District. This is already being required by

the District and is consistent with requirements in source specific District rules. The District

is clarifying rule language specifying records keeping will be required on a monthly basis,

with the exception of records required for emission control systems, and any records needed

for burden of proof to verify the eligibility of an exemption.

Staff is proposing to separate the record keeping requirements for approved emission

control systems. A detailed description of information required by the District is now outlined

in this section. Record keeping for these systems will be required on a daily basis.

Staff is proposing to add Sections 503 Burden of Proof and 504 Reporting. Section 503

establishes any operator claiming an exemption to the rule are required to maintain

documents supporting the claim. Document may include product sheets, or a MSDS of any

product used or other records such as product usage. This will allow the District to verify any

facility claiming any of the exemptions. Reporting requirements were already established in

the Rule and placing them in a separate section facilitates rule clarity.

Section 600 Test Methods

Test method procedures were moved from Section 502 Test Methods to Section 600 Test

Methods. Section 600 was created for consistency with District rule structure. 

Staff is proposing the addition of Section 601 General. This section contains standard

language applicable to all rules. Staff is also proposing to add Section 603 Exempt

Compounds and Section 608 Spray Gun Cleaning Systems.

Staff is proposing to add Section 604 Calculation of VOC content. This section details the
Staff Report - Organic Solvent Rules May 5, 2008

Page 16

determination of VOC content for materials limited by this rule.

Staff is proposing to modify Sections 606 Capture Efficiency and 607 Control Efficiency

formerly Sections 502.2 and 502.3 respectively. Staff is proposing to update these test

methods in accordance with the EPA Region IX’s “Guidance Document for Correcting

Common VOC & Other Rule Deficiencies.” In addition, Staff is proposing to add Section 607

Overall Capture and Control Efficiency. This section includes the calculation used to

determine the capture and control efficiency for emission control systems.

Staff is proposing to remove Sections 502.5 and 502.6 because these test methods are no

longer applicable if the requirements for vapor pressure and workroom draft rate are

removed. 

Rule 1.1 General Provisions and Definitions

Section 200 Definitions

Staff is proposing to add standard definitions for Air Pollution Control Officer (APCO),

American Society of Testing Methods, California Air Resources Board, and United States

Environmental Protection Agency. 

Rule 2.24 Solvent Cleaning Operations (Degreasing)

Staff is proposing to repeal this rule, effective 7/1/2009 when the first phase of the of the

new solvent standards in Rule 2.31 go into effect. Rule 2.24 is one of the earlier rules

adopted by the District to establish standards for solvent use for degreasers. Currently, the

only sources within the YSAQMD subject to Rule 2.24 are those using remote reservoir cold

cleaners. The District does not require permits for remote reservoir cleaners, but these

cleaners are also subject to the provisions of Rule 2.31. Rule 2.31 outlines updated

standards for the operation of remote reservoir cleaners. Staff is proposing to remove the

exemption for other types of degreasers from Rule 2.31, with the exception of degreasers

with an open top surface area of 1.0 square foot or less, with a capacity of 2.0 gallons or

less, using unheated nonhalogenated solvent exclusively, or degreasing operations subject

to 40 CFR Part 63 Subpart T -National Emission Standards for Halogenated Solvent

Cleaning. Therefore, any source using a solvent for surface preparation or cleanup will be

subject to the standards of Rule 2.31 Surface Preparation and Cleanup. Rule 2.31 limits the

VOC content for solvents used in all cleaning operations and also outlines District approved

cleaning devices and methods. The only approvable methods for cleaning will be those that

result in emissions limits equivalent or lower than those proposed in Rule 2.31. 

Rule 2.25 Metal Parts and Products Coating Operations

Section 100 General

Staff is proposing to amend the language in Section 102 Applicability for consistency with

other rules. Staff is also revising the applicability to include any person selling or distributing

coatings subject to the provisions of the rule for clarity. Rule 2.25 includes provisions in
Staff Report - Organic Solvent Rules May 5, 2008

Page 17

Section 402 Compliance Statement directed at persons selling or distributing coatings or

strippers subject to the rule. 

Staff is proposing to regroup the exemptions in this section into different categories for clarity

and consistency with other rules. Many of the exemptions listed are for portions of the rule

not the entire rule. Clustering the exemptions from different sections of the rule together,

allows for quick identification of the sections of the rule the exemption is for. 

In addition, staff is proposing to clarify the exemption from coating limits for limited quantities

of coating. Any facility claiming this exemption must apply to do so and must have District

approval prior to using a low quantity of a non-compliant coating per District policy.

Staff is also proposing to remove any reference to compliance dates that have already

passed.

Section 200 Definitions

Staff is proposing to streamline definitions for exempt compound, volatile organic compound,

and high-volume, low-pressure system for clarity and to make the language consistent with

other District rules. Staff is proposing to add standard definitions for control device, dip coat,

electrostatic application, emission control system, flow coat, roll coater, stripping, surface

preparation and cleanup, touch-up coating and volatile organic compound content. Staff is

proposing to remove the definition for enclosed gun washer as requirements are no longer

in the rule.

 

Section 300 Standards

Staff is proposing to remove the asterisk from Section 301 Table 1 to increase clarity. The

asterisk statement is not consistent with the definition for pretreatment wash primer.

Staff is proposing to modify the Section 302 Application Methods. Staff is proposing to add

Section 302.7 to outline the criteria used for the approval of the use of other application

methods. 

Staff is proposing to add Section 303 Stripper Limits. Stripping has previously been

categorized inconsistently throughout District rules. Some rules have incorporated stripping

with surface preparation, whereas others have categorized them separately. The District

added definitions for the two terms to clarify they are considered two separate categories.

The District added stripping limits which were previously categorized with surface

preparation for this rule. The requirements remain as originally intended by the rule.

Staff is proposing to revise former Section 303 Add-On Controls, to establish clearer

guidelines for emission control equipment. Staff is proposing to modify language for

consistency with terms used in the applicable test methods. Staff replaced overall efficiency

with capture and control efficiency, defined in the test method section. The requirements

remain unchanged and will be placed in Section 304 Emission Control System.
Staff Report - Organic Solvent Rules May 5, 2008

Page 18

Staff is proposing to modify former Section 304 Surface Preparation and Clean-up Solvents

into two sections, Section 305 Storage and Disposal -General, and Section 306

Requirements for Surface Preparations and Cleanup Materials. Section 305 outlines general

work practice requirements for materials containing VOCs. Section 306 has been added to

clearly point to Rule 2.31 for all applicable requirements for Surface Preparation and

Cleanup.

Section 400 Administrative Requirements

Staff is proposing to remove language establishing implementation dates for requirements

already in effect, and reorder requirements for consistency with other District rules.

Staff is proposing to add stripper to Section 401 Prohibition of Specification and Section 402

Compliance Statement Requirement since they are regulated by the rule. Staff is also

proposing to modify the language in Section 402 Compliance Statement Requirements for

consistency with other rules. Section 600 specifies how VOC content is to be calculated for

coatings and strippers per the Rule’s definition of VOC content.

Staff is proposing to remove Sections 404 Calculation for determination of VOC content per

volume of coating and 405 Calculation for determination of VOC content per volume of

surface preparation or cleanup material. District staff is proposing to include the calculation

for VOC content for coatings in Section 600 for consistency with other District rules.

Calculations for surface preparation and cleanup materials are outlined in Rule 2.31. Rule

2.25 will reference Rule 2.31 for all requirements pertaining to surface preparation and

cleanup. 

Staff is proposing to add Section 404 Operation and Maintenance Plan (O&M Plan). The

District is proposing to require any person using an approved emission control device to

have an approved plan outlining operation and maintenance procedures to demonstrate

compliance with the rule requirements. The plan must also include record keeping provisions

in compliance with the rule’s record keeping requirements. District approval of an emission

control device will require an approved plan. There are currently no sources using an

approved emission control device for compliance so an implementation date is not

necessary. 

Section 500 Monitoring and Records

Staff is proposing to divide record keeping requirements into separate sections to streamline

the rule. Requirements are now in Section 501 Record Keeping - General, 502 Record

Keeping - Emission Control Systems and 503 Reporting. In addition, staff is proposing to

remove the requirements for record keeping pertaining to surface preparation and cleanup.

Detailed record keeping for surface preparation and cleanup is now outlined in Rule 2.31.

Staff is adding references to strippers and solvents where necessary to clarify record

keeping provisions for their use. 

Section 600 Test Methods
Staff Report - Organic Solvent Rules May 5, 2008

Page 19

Test method procedures were moved from Section 502 to Section 600. Section 600 was

created for consistency with District rule structure. 

Staff is proposing the addition of Section 601 General. This section contains standard

language applicable to all rules. Staff is also proposing to modify Section 603 Exempt

Compounds. Section 601 now outlines procedures for alternative test methods so reference

to alternative test methods was removed from Section 603. 

Staff is proposing to add Section 604 Calculation of VOC content. This section details the

determination of VOC content for materials limited by this rule. The section clearly states

whether the VOC content will exclude water and exempt compounds.

Staff is proposing to update the ASTM methods in Sections 605. 

Staff is proposing to update Section 608 to the correct citation of the applicable test method.

Staff is also proposing to delete Section 502.10 Spray Gun Cleaning Systems. This test

method is now in Rule 2.31, which outlines requirements for all cleaning methods.

Staff is proposing to modify Sections 609 Capture Efficiency and 610 Control Efficiency

formerly Sections 502.5 and 502.7 respectively. Staff is proposing to update these test

methods in accordance with the EPA Region IX’s “Guidance Document for Correcting

Common VOC & Other Rule Deficiencies.” In addition Staff is proposing to add Section 611

Overall Capture and Control Efficiency. This section includes the calculation used to

determine the capture and control efficiency for emission control systems.

Rule 2.26 Motor Vehicle and Mobile Equipment Coating Operations

Section 100 General

Staff is proposing to add Section 102 Applicability for consistency with other rules.

Staff is proposing to regroup the exemptions from the entire rule into one section. Clustering

the exemptions from different sections of the rule together, allows for quick identification of

the sections of the rule the exemption is for.

Section 200 Definitions

Staff is proposing to streamline definitions for exempt compound, volatile organic compound,

and high-volume, low-pressure system for clarity and to make the language consistent with

other District rules. Staff is proposing to add standard definitions for control device, emission

control system, surface preparation and cleanup, and volatile organic compound content.

Section 300 Standards

Staff is proposing to amend Section 301.1 and 301.2 by removing requirements for emission

control systems. Section 303 Emission Control System will be added to clarify requirements
Staff Report - Organic Solvent Rules May 5, 2008

Page 20

for control equipment used to achieve rule compliance. Language in the new Section 303

was streamlined for consistency with other District rules and applicable test methods. The

requirements remain unchanged. The subsequent Sections were renumbered. 

Staff is proposing to amend Section 302.3 to clarify the intent of the requirement. Staff is

proposing to replace the language specifying an alternate coating equipment must

demonstrate a transfer efficiency of 65% or better with alternate coating equipment must

have a transfer efficiency equivalent to or greater than other approved application methods

listed in Rue 2.26. This allows alternate equipment to be used in the District that has been

determined to be equivalent by an established test method. The application method must

be approved in writing by the APCO. In a letter dated January 26, 2005, changing the

requirement for transfer efficiency from a minimum of 65% to equipment capable of

achieving equivalent of better transfer efficiency than HVLP equipment was discussed. The

letter stated “EPA would not object to such a change to YSAQMD Rule 2.26.”

Staff is proposing to replace former Section 303 Surface Preparation and Cleanup Solvent

with Sections 304 -Storage and Disposal General, and Section 305 -Requirements for

Surface Preparation and Cleanup Materials. Section 304, outlines general work practice

requirements for materials containing VOCs. Section 305 has been added to clearly point

to Rule 2.31 for all applicable requirements for Surface Preparation and Cleanup. 

Former Section 304 Small Production/Utility bodies, will be removed since the exemption has

been moved to the exemption section.

Staff is proposing to clarify Section 308 Precoat Limitation, by specifying the time period the

usage of primer surfacer will be quantified over.

Section 400 Administrative Requirements

Staff is proposing to modify the language in Section 401 Prohibition of Specification, for

consistency with other rules.

Staff is proposing to modify the language in Section 402 Prohibition of Sale, by replacing air

pollution abatement equipment with emission control system for consistency with rule

terminology.

Staff is proposing to modify Section 403 Compliance Statement Requirement for

consistency. Section 600 specifies how VOC content is to be calculated for materials subject

to the rule, per the Rule’s definition of VOC content.

Staff is proposing to add Section 404 Operation and Maintenance Plan (O&M Plan). The

District is proposing to require any person using an approved emission control device to

have an approved plan outlining operation and maintenance procedures to demonstrate

compliance with the rule requirements. The plan must also include record keeping provisions

in compliance with the rule’s record keeping requirements. District approval of an emission

control device will require an approved plan. There are currently no sources using an

approved emission control device for compliance so an implementation date is not

necessary. 
Staff Report - Organic Solvent Rules May 5, 2008

Page 21

Staff is also proposing to remove any reference to compliance dates that have already

passed.

Section 500 Monitoring and Records

Staff is proposing to move test methods out of Section 500 Monitoring and Records to

Section 600 Test Methods, for consistency with other District rules. Subsequent sections

were renumbered. 

In addition, Staff is proposing to amend former Section 507 Records by dividing it into three

sections 501 Record Keeping - General, 502 Record Keeping - Emission Control Systems,

503 Burden of Proof and Section 504 reporting. The requirements outline record keeping

requirements for each category and requirements for surface preparation and cleanup were

removed. Section 503 was added to ensure any person subject to an exemption maintain

any necessary records. 

Staff is proposing to remove the requirements for record keeping pertaining to surface

preparation and cleanup. Detailed record keeping for surface preparation and cleanup is

now outlined in Rule 2.31.

Section 600 Test Methods

Test method procedures were moved from Section 500 to Section 600. Section 600 was

created for consistency with District rule structure. 

Staff is proposing the addition of Section 601 General. This section contains standard

language applicable to all rules.

Staff is proposing to change analysis of samples to VOC content for consistency.

Staff is proposing to update the test methods by removing former Section 603 Determination

of Emissions and adding Section 603 Exempt Compounds and Section 604 Exempt

Compounds -Methyl Acetate, Acetone, T-Butyl Acetate and Parachlorobenzotrifluoride. Staff

is also adding Section 605 Calculation of VOC Content, and 606 Calculation of VOC Content

of Coating System. These sections in conjunction with Section 602 will be used to determine

compliance with requirements.

Staff is proposing to modify Sections 609 Capture Efficiency and 610 Control Efficiency

formerly Sections 502.5 and 502.7 respectively. Staff is proposing to update these test

methods in accordance with the EPA Region IX’s “Guidance Document for Correcting

Common VOC & Other Rule Deficiencies.” In addition Staff is proposing to add Section 611

Overall Capture and Control Efficiency. This section includes the calculation used to

determine the capture and control efficiency for emission control systems.

Staff is proposing to update the ASTM method in Section 612.

Rule 2.29 Graphic Arts Printing Operations
Staff Report - Organic Solvent Rules May 5, 2008

Page 22

Section 100 General

Staff is proposing to amend the rule purpose and add Section 102 Applicability section for

consistency with other rules.

Staff is proposing to delete Section 110.1. This Section outlines requirements that are no

longer in effect.

Staff is proposing to remove language establishing an implementation date for the

exemptions since the date has already passed and the requirements are currently in effect.

Section 200 Definitions

Staff is proposing to streamline definitions for volatile organic compound for clarity and to

make the language consistent with other District rules. Staff is proposing to add standard

definitions for emission control system, exempt compounds, pantone inks, surface

preparation and cleanup, and volatile organic compound content. 

Section 300 Standards

Staff is proposing to amend Section 301.2 for clarity and consistency with other District rules.

Staff is proposing to replace collection with capture so the language is consistent with

language used in the test methods section. 

Staff is proposing to amend Section 302 Flexographic, Gravure, Letterpress, and

Lithographic Requirements by separating the requirements into two sections in order to

clarify the section contained more than one requirement.

Staff is also proposing to modify Section 304 Emission Control System, by replacing the

language with standard language for emission control systems for consistency with test

methods and other District rules. In addition, staff is proposing to add the requirements for

a temperature gauge from former Section 503 Emission Control System Monitoring, to

Section 304 Emission Control System. Staff is also clarifying the requirement by specifying

it is only for systems utilizing combustion.

Staff is proposing to replace Section 305 Solvent Evaporative Loss Minimization with

Sections 305 Storage and Disposal -General, and Section 306 Requirements for Surface

Preparation and Cleanup Materials. Section 305, outlines general work practice

requirements for materials containing VOCs. Section 306 has been added to clearly point

to Rule 2.31 for all applicable requirements for Surface Preparation and Cleanup. 

Staff is also proposing to remove any reference to compliance dates that have already

passed.

Section 400 Administrative Requirements

Staff is proposing to add Section 401 Prohibition of Specification, for consistency with other
Staff Report - Organic Solvent Rules May 5, 2008

Page 23

rules. Staff is proposing to renumber the remaining requirements.

Staff is proposing to remove surface preparation and cleanup solvent from the requirements

of Section 402. Requirements for the labeling of solvents used in surface preparation and

cleanup are addressed in Rule 2.31.

Staff is also proposing to remove any reference to compliance dates that have already

passed.

Section 500 Monitoring and Records

Staff is proposing to move test methods out of Section 500 Monitoring and Records to

Section 600 Test Methods for consistency with other District rules.

Staff is proposing to divide record keeping requirements into separate sections to streamline

the rule. Requirements are now in Section 501 Record Keeping - General, 502 Record

Keeping - Emission Control Systems and 503 Reporting. In addition, staff is proposing to

remove record keeping requirements for surface preparation and cleanup solvents.

Requirements for record keeping for surface preparation and cleanup are addressed in Rule

2.31.

Section 600 Test Methods

Test method procedures were moved from Section 500 to Section 600. Section 600 was

created for consistency with District rule structure. 

Staff is proposing the addition of Section 601 General. This section contains standard

language applicable to all rules.

Staff is proposing to modify the test method headers for consistency with other rules.

Staff is proposing to add Section 605 Calculation of VOC content. This section details the

determination of VOC content for materials limited by this rule. The section clearly states

whether the VOC content will exclude water and exempt compounds.

Staff is proposing to modify Sections 606 Capture Efficiency and 607 Control Efficiency

formerly Sections 504.5 and 504.4. Staff is proposing to update these test methods in

accordance with the EPA Region IX’s “Guidance Document for Correcting Common VOC

& Other Rule Deficiencies.” In addition, staff is proposing to add Section 608 Overall Capture

and Control Efficiency. This section includes the calculation used to determine the capture

and control efficiency for emission control systems.

Rule 2.30 Polyester Resin Operations

Section 100 General

Staff is revising the applicability to include any person selling or distributing gelcoat or

polyester resin material subject to the provisions of the rule for clarity. Rule 2.30 includes
Staff Report - Organic Solvent Rules May 5, 2008

Page 24

provisions in Section 402 Compliance Statement directed at persons selling or distributing

gel coats or polyester resin material subject to the rule. 

Section 200 Definitions

Staff is proposing to streamline definitions for volatile organic compound and high-volume

low-pressure for clarity and to make the language consistent with other District rules. Staff

is proposing to add standard definitions for control device, exempt compounds and surface

preparation and cleanup. Staff is proposing to remove the definition for grams of VOC per

liter of material because that applies to materials used for surface preparation and cleanup

which will be addressed in Rule 2.31.

Section 300 Standards

Staff is proposing to modify the language in Section 301.1 for clarity. Staff is not proposing

any changes to the requirements in this section.

Staff is proposing to modify Section 301.4, by moving the requirements for an emission

control system to Section 303 Emission Control Systems. Section 303 will have standard

language clarifying the requirements for these systems.

 

Staff is proposing to remove Section 302 Cleaning Material Requirements. Cleaning material

requirements will be subject to Rule 2.31. The proposed requirements for Rule 2.31 will not

allow for the use of solvents with a VOC content of greater than 1.7 pounds per gallon as

applied when the new limits take affect in 2009. Staff is proposing to delete the section

because there are currently no permitted sources subject using a solvent reclamation

system for compliance with this Section and the requirements will be obsolete once the limits

take affect. 

Staff is proposing to Replace Section 303 Storage and Disposal Requirements with Sections

304 Storage and Disposal -General and Section 305 Requirements for Surface Preparation

and Cleanup Materials. Section 305, outlines general work practice requirements for

materials containing VOCs. Section 306 has been added to clearly point to Rule 2.31 for all

applicable requirements for Surface Preparation and Cleanup. 

Staff is proposing to delete former Section 304 Compliance Dates, because the dates have

already passed and the section is obsolete.

Section 400 Administrative Requirements

Staff is proposing to add Section 403 Operation and Maintenance Plan (O&M Plan). The

District is proposing to require any person using an approved emission control device to

have an approved plan outlining operation and maintenance procedures to demonstrate

compliance with the rule requirements. The plan must also include record keeping provisions

in compliance with the rule’s record keeping requirements. District approval of an emission

control device will require an approved plan. There are currently no sources using an

approved emission control device for compliance so an implementation date is not

necessary. 
Staff Report - Organic Solvent Rules May 5, 2008

Page 25

Section 500 Monitoring and Records 

Staff is proposing to move test methods out of Section 500 Monitoring and Records to

Section 600 Test Methods for consistency with other District rules.

Staff is proposing to remove record keeping requirements for surface preparation and

cleanup solvents. Requirements for record keeping for surface preparation and cleanup are

addressed in Rule 2.31.

Section 600 Test Methods

Staff is proposing to add Section 601 General, containing standard language applicable to

all rules.

Staff is proposing to replace the test method described in former Section 501 Test Methods,

with Section 602 Emission Rate, referencing the test method to be used for the emission

rate determination. The District does not describe specific test methods in any other test

method section.

Staff is proposing to add Sections 603 Capture Efficiency and 604 Control Efficiency. Staff

is proposing to update these test methods in accordance with the EPA Region IX’s

“Guidance Document for Correcting Common VOC & Other Rule Deficiencies.” In addition,

staff is proposing to add Section 605 Overall Capture and Control Efficiency. This section

includes the calculation used to determine the capture and control efficiency for emission

control systems.

Staff is proposing to delete former Sections 501.3, 501.4 and 501.5. The test methods cited

in these sections were to demonstrate compliance with former Section 302 Cleaning Material

Requirements. Since staff is proposing to delete this section the test methods are no longer

relevant.

Rule 2.33 Adhesive Operations

Section 100 General

Staff is proposing to amend the rule purpose and applicability section for consistency with

other rules. Staff is proposing to amend language in the applicability section by replacing

references to specific products with general language. By generalizing the applicability, the

rule will apply to any product associated with adhesives and allows rule language to clarify

requirements for specific categories. This format will more accurately represent the changes

in rule structure. The rule applies to all operations associated with adhesives, but will not

contain specific requirements for certain categories such as surface preparation and

cleanup, just language referencing Rule 2.31, which will specify the standards for this

category.

Section 110 Exemptions

Staff is proposing to restructure the exemptions, for clarity and consistency with other District
Staff Report - Organic Solvent Rules May 5, 2008

Page 26

rules. Staff is proposing to divide the exemptions into separate categories, general and

limited. General exemptions are exempt from the entire rule and limited exemptions are

exempt from the standard sections, but are still subject to the provisions in the remaining

sections such as test methods and record keeping. 

Staff is proposing to delete some of the language from Section 110.6 former Section 110.8.

This language is not necessary with the addition of the definition for medical device to

Section 200. 

Staff is proposing to add a limited exemption for stripping from the requirements in Section

300 Standards for Strippers. Currently, stripping is included in Table 3 with requirements for

surface preparation and cleanup. The table includes VOC content limits for solvents used

in the stripping of adhesives or sealants on wood and lists ‘no limit’ for solvents used for the

stripping of adhesives or sealants from all other material. The table includes vapor pressure

requirements for each category. The VOC content limit for strippers used on wood products

is included in Rule 2.39 Wood Products Coating Operations. Staff is proposing to remove

vapor pressure requirements since vapor pressure affects the rate at which a solvent

evaporates and does not directly impact the total quantity of mass emissions produced. The

other rule standards in Section 300 of Rule 2.33, do not currently apply to strippers, and the

stripping of adhesives has an exemption in Rule 2.31 Surface Preparation and Cleanup.

Section 200 Definitions

Staff is proposing to streamline definitions for exempt compounds, low-solids material,

surface preparation and volatile organic compound for clarity and to make the language

consistent with other District rules. Staff is proposing to add standard definitions for adhesive

product, control device, emission control system, medical device, and volatile organic

compound content. Staff is proposing to delete the definition for APCO, high pressure

laminate, stripper and undersea-based weapon systems. Deleted definitions are either not

used in the rule or will be listed in Rule 1.1 General Provisions and Definitions.

Section 300 Standards

Staff is proposing to amend Section 301 Material Limits, for consistency with the definitions

added to Section 200. The procedures used for the calculations have been included in the

definition section, for consistency with other District rules. The methods of calculation have

not been altered. In addition, staff is proposing to delete the column of limits effective in

1997 from Tables 1 & 2. Any limits that were only listed in the effective 1997 column will be

placed in the remaining effective 2004 column.

Staff is proposing to amend the VOC content limits for plastic cement welding primers from

450 g/ to 550 g/l because the limit of 450 g/l is currently not technologically feasible.

SCAQMD had adopted a technology forcing limit for this category that never went into effect

due to the inability of the industry to meet this limit. SCAQMD currently has a limit of 550 g/l

that went into effect 7/1/05 for this category. 

Staff is proposing to replace former Section 302 Solvent Use, with Sections 304 Storage and

Disposal -General, and Section 305 Requirements for Surface Preparation and Cleanup
Staff Report - Organic Solvent Rules May 5, 2008

Page 27

Materials. Section 304, outlines general work practice requirements for materials containing

VOCs. Section 305 has been added to clearly point to Rule 2.31 for all applicable

requirements for Surface Preparation and Cleanup. 

Staff is proposing to revise Section 303 Emission ControlSystem, formerlySection 305 VOC

Collection and Control Systems, to establish clearer guidelines for emission control

equipment. Staff is proposing to modify language for consistency with terms used in the

applicable test methods. The requirements remain unchanged. 

Staff is proposing to remove Sections 306 Prohibition of Supply or Sale and 307 Prohibition

of Specification. These requirements will be placed in Section 400, Administrative

Requirements. 

Section 400 Administrative Requirements

Staff is proposing to remove Section 401, Compliance Date because the compliance date

has already passed. Subsequent sections will be renumbered. Compliance dates will also

be removed from Section 402 Container Labeling.

Staff is proposing to add Section 401 Prohibition of Specification and Section 402 Prohibition

of Supply or Sale for consistency with other District rules.

Staff is proposing to move Section 403 Calculation of VOC Content as Applied to Section

607 Calculation of VOC Content. Former Section 403.3 will remain as Section 404

Notification Requirements. 

Staff is proposing to remove Section 404 Calculation of Composite Vapor Pressure. Staff

is proposing to remove all vapor pressure requirements from the rule therefore this section

is no longer applicable. 

Staff is proposing to remove Section 405 Approved Collection and Control System. The

requirement for APCO approval is incorporated in Section 303 Emission Control System.

Staff is proposing to amend Section 405 Collection and Control System Efficiency, formerly

Section 406. Staff is removing the equations for overall VOC collection and control efficiency

since the equation has been added to Test Methods. The section will include language

pointing to the test method section. 

Staff is proposing to add Section 403 Operation and Maintenance Plan (O&M Plan). The

District is proposing to require any person using an approved emission control device to

have an approved plan outlining operation and maintenance procedures to demonstrate

compliance with the rule requirements. The plan must also include record keeping provisions

in compliance with the rule’s record keeping requirements. District approval of an emission

control device will require an approved plan. There are currently no sources using an

approved emission control device for compliance so an implementation date is not

necessary. 

Section 500 Monitoring and Records
Staff Report - Organic Solvent Rules May 5, 2008

Page 28

Staff is proposing to amend the language in Section 501 Record Keeping - General. The

language clarifies operations subject to record keeping requirements. Language clarifies

every operation is subject to the record keeping provisions unless it is listed in Section 110-

General Exemptions and is exempt from all rule requirements. In addition, staff is proposing

to remove all requirements for recording composite partial pressure, since vapor pressure

limits will no longer be included in the rule. Staff also removed any reference to Table 3. 

Section 600 Test Methods

Staff is proposing to move requirements from Section 600 Test Methods, to Section 601

General for consistency with other District rules.

Staff is proposing to add Section 607 Calculation of VOC content. This section details the

determination of VOC content for materials limited by this rule. The section clearly states

whether the VOC content will include or exclude water and exempt compounds.

Staff is proposing to remove all references to Table 3 since the table will be removed. In

addition, staff is proposing to remove former Sections 605 Determination of Composite

Vapor Pressure, and 606 Determination of Single Component Compound Vapor Pressure.

Staff is proposing to modify Sections 608 Capture Efficiency and 609 Control Efficiency

formerly Sections 603 and 604 respectively. Staff is proposing to update these test methods

in accordance with the EPA Region IX’s “Guidance Document for Correcting Common VOC

& Other Rule Deficiencies.” In addition Staff is proposing to add Section 610 Overall Capture

and Control Efficiency. This section includes the calculation used to determine the capture

and control efficiency for emission control systems.

Rule 2.35 Pharmaceutical Manufacturing Operations

Section 100 General

Staff is proposing to amend the language in Section 110 Exemption - Small Facilities to

clarify the requirements.

Section 200 Definitions

Staff is proposing to streamline the definition for volatile organic compound for clarity and

to make the language consistent with other District rules. Staff is proposing to add standard

definitions for control device, emission control system, pharmaceutical product, surface

preparation and cleanup, and volatile organic compound content.Staff is proposing to delete

the overall control efficiency definition since the calculation is detailed in Section 600. 

Section 300 Standards

Staff is proposing to replace Section 309, with Sections 309 Materials Containing VOCs, and

310 Requirements for Surface Preparation and Cleanup Materials. Section 309 outlines

general work practice requirements for materials containing VOCs. Section 310 has been
Staff Report - Organic Solvent Rules May 5, 2008

Page 29

added to clearly point to Rule 2.31 for all applicable requirements for Surface Preparation

and Cleanup. 

Section 400 Administrative Requirements

Staff is proposing to remove former Section 401 Compliance Schedule since the

compliance dates have already passed.

Staff is proposing to add Section 404 Operation and Maintenance Plan (O&M Plan). The

District is proposing to require any person using an approved emission control device to

have an approved plan outlining operation and maintenance procedures to demonstrate

compliance with the rule requirements. The plan must also include record keeping provisions

in compliance with the rule’s record keeping requirements. District approval of an emission

control device will require an approved plan.

Section 500 Monitoring and Records 

Staff is proposing to move former Section 504 Test Methods into Section 600. Consequently,

former Section 505 Solvent Waste/Residue Disposal Record will be renumbered to Section

504. 

Section 600 Test Methods

Staff is proposing to restructure the rule outline for consistency with other District rules. The

District wants to streamline the rules so the sections are the same from rule to rule. Staff is

proposing to move all test methods into Section 600, Test Methods.

Staff is proposing the addition of Section 601-General. This section contains standard

language applicable to all rules.

Staff is proposing to modify Sections 605 Capture Efficiency and 606 Control Efficiency

formerly Sections 504.5 and 504.3 respectively. Staff is proposing to update these test

methods in accordance with the EPA Region IX’s “Guidance Document for Correcting

Common VOC & Other Rule Deficiencies.” In addition, staff is proposing to add Section 607

Overall Capture and Control Efficiency. This section includes the calculation used to

determine the capture and control efficiency for emission control systems.

Rule 2.39 Wood Products Coating Operations

Section 100 General

Staff is proposing to remove references to surface preparation and cleanup from Section

101 Purpose. 

Staff is proposing to add language to Section 102 Applicability, to specify the rule applies

to the use of strippers used on wood products not stripper use in general. Staff is also

revising the applicability to include any person selling or distributing coatings or strippers

subject to the provisions of the rule for clarity. Rule 2.39 includes provisions in Section 402
Staff Report - Organic Solvent Rules May 5, 2008

Page 30

Compliance Statement directed at persons selling or distributing coatings or strippers subject

to the rule. 

Staff is proposing to remove redundant language from Section 110.5. 

In addition, staff is proposing to move Section 112 Exemption -Wood Paneling into Section

110.6. 

Section 200 Definitions

Staff is proposing to streamline the definitions for exempt compound, high-volume, lowpressure and volatile organic compound for clarity and to make the language consistent with

other District rules. Staff is proposing to add standard definitions for control device, emission

control system, surface preparation and cleanup` and volatile organic compound content.

Staff is proposing to delete definitions for capture efficiency, cleanup material, control

efficiency, emission unit, enclosed gun washer, surface preparation material and touch-up

coating. Calculations for capture efficiency and control efficiency will now be detailed in

Section 600 Test Methods. Emission unit and touch-up coating are not used in the rule.

Section 300 Standards

Staff is proposing to remove any reference to compliance dates that have already passed.

Staff is proposing to move former Section 301 Application Requirements to after the coating

requirements. The sections will be renumbered as needed. Staff is also making minor

changes to the section language and headings. Staff is proposing to modify the language

in Sections 301 Coating Limits for New Wood Product and 302 Coating Limits for

Refinishing, Repairing, Preserving, or Restoring Wood Products for clarity and consistency

with other rules. Staff is also proposing to place the requirements in a Table format.

Staff is proposing to modify the language in Section 305 Emission Control Equipment, for

consistency with other rules. The calculation for control efficiency will be placed in Section

600 Test Methods. Monitoring requirements will be placed in Section 500 Monitoring and

Records.

Staff is proposing to replace former Section 306 Requirements for Surface Preparation and

Cleanup Solvent with Sections 306 Storage and Disposal -General, and Section 307

Requirements for Surface Preparation and Cleanup Materials. Section 306 outlines general

work practice requirements for materials containing VOCs. Section 307 has been added to

clearly point to Rule 2.31 for all applicable requirements for Surface Preparation and

Cleanup. 

Section 400 Administrative Requirements

Staff is proposing to remove language establishing implementations date for requirements

already in effect, and reorder requirements for consistency with other District rules.

Staff is proposing to add Section 401 Prohibition of Specification for consistency with other
Staff Report - Organic Solvent Rules May 5, 2008

Page 31

rules.

Staff is also proposing to modify the language in Section 402 Compliance Statement

Requirement formerly Section 401 Labeling Requirements - VOC Content by deleting

references to surface preparation and cleanup.

Staff is proposing to remove Sections 402 Calculation for Determining Volatile Organic

Compound Composite Partial Vapor Pressure, 403 Calculation for Determining Weight of

VOC per Volume of Coating, Less Water and Less Exempt Compounds and 404 Calculation

For Determination of VOC Content per Volume of Material. These calculations will be placed

in Section 600 Test Methods.

Section 500 Monitoring and Records

Staff is proposing to break Section 501 Usage records into two Sections, Section 501

Records -General and Section 502 Additional records -Emission Control Systems. General

records are applicable to all operators including those with emission control systems. Section

502 will outline the additional requirements for operators using emission control systems. 

Staff is proposing to increase the record retention time for all records from two to five years

therefore the exception for Federal Operating Permits is no longer needed. 

Test methods will be removed from Section 503 Test Methods and placed in Section 600

Test Methods.

Section 600 Test Methods

Staff is proposing the addition of Section 601 General. This section contains standard

language applicable to all rules. Staff is also proposing to delete all references to materials

used for surface preparation and cleanup.

Staff is proposing to add Section 605 Calculation of VOC content. This section details the

determination of VOC content for materials limited by this rule. The section clearly states

whether the VOC content will include or exclude water and exempt compounds.

Staff is proposing to modify Sections 610 Capture Efficiency and 611 Control Efficiency

formerly calculations were placed in Section 200 Definitions. Staff is proposing to update

these test methods in accordance with the EPA Region IX’s “Guidance Document for

Correcting Common VOC & Other Rule Deficiencies.” In addition, staff is proposing to add

Section 612 Overall Capture and Control Efficiency. This section includes the calculation

used to determine the capture and control efficiency for emission control systems.

III. COMPARISON WITH OTHER APPLICABLE REGULATIONS AND REQUIREMENTS

CH&SC Section 40727.2 requires districts to perform a comparative alternative analysis of

any new control standard. Specifically, the District is required to prepare a written analysis

(usually in the form of a matrix) that identifies all existing federal air pollution control

requirements, including, but not limited to emission control standards constituting best
Staff Report - Organic Solvent Rules May 5, 2008

Page 32

available control technology (BACT) that applies to the same equipment or source type as

the rule or regulation proposed for adoption or modification by the District. In addition, the

analysis shall identify any other District rule, regulation, or guideline that applies to the same

equipment or source type.

There are National Emission Standards for Hazardous Air Pollutants (NESHAPS)

requirements for halogenated solvent cleaning using batch vapor, in-line vapor, in-line cold,

and batch cold solvent cleaning machines. There is no equipment subject to these

requirements currently operating in the District. Therefore the District is proposing to

withdraw Rule 2.24. Any source subject to the NESHAP requirements of 40 CFR Part 63

Subpart T- Halogenated Solvents Emissions from Solvent Cleaning are exempt from Rule

2.31 requirements. Therefore, amendments to Rule 2.31, will not apply to any source

regulated by the standards and are therefore not in conflict with the federal regulations.

In addition, the District is proposing to move all solvent requirements for surface preparation

and cleanup into Rule 2.31, thereby eliminating overlapping or inconsistent requirements

with any other District rule. 

There are standards such as BACT that apply to solvent cleaning operations. BACT for

solvent cleaning operations was determined from the SCAQMD document, “BACT

Guidelines for Non-Major Polluting Facilities”, to be compliance with SCAQMD Rule 1171.

Element for

Comparison

Specific Category Proposed District

Rule 2.31

BACT

2009 2011

Exemptions Cleaning operations

using materials less

than 25 g/liter of

VOCs

Cleaning operations

using materials less

than 25 g/liter of

VOCs

Averaging Provisions None None

Units VOC g/l or lb/gal VOC g/l or lb/gal

Emission LimitsProduct CleaningGeneral 50 g/l 25 g/l 25 g/l

Electrical/Electronic

Components

500 g/l 100 g/l 100 g/l

Medical Devices and

Pharmaceuticals

800 g/l 800 g/l 800 g/l for most

processes
Staff Report - Organic Solvent Rules May 5, 2008

Element for

Comparison

Specific Category Proposed District

Rule 2.31

BACT

2009 2011

Page 33

Emission LimitsRepair and

Maintenance

Cleaning

General 50 g/l 25 g/l 25 g/l

Electrical/Electronic

Components

900 g/l 100 g/l 100 g/l

Medical Devices and

PharmaceuticalsTools/Equip.

800 g/l 800 g/l 800 g/l for most

processes

Medical Devices and

PharmaceuticalsGeneral

600 g/l 600 g/l 600 g/l

Emission Limits Cleaning of Coatings

or Adhesives Appl.

Equip.

50 g/l 25 g/l 25 g/l

Emission LimitsCleaning of Ink

Application

Equipment

General- Other Inks 100 g/l

and 3

mm HG

25 g/l 25 g/l

Medical Devices and

Pharmaceuticals

810 g/l 810 g/l Not applicable for this

category

Flexographic Printing NA 100 g/l 25 g/l

Gravure PrintingPublicationNA 100 g/l 100 g/l

Other 100 g/l &

3 mm Hg

25 g/l 25 g/l

Lithographic Printing 900 g/l

and 25

mm Hg

100 g/l 25-500 g/l

Screen Printing 500 g/l 100 g/l 500 g/l

UV Ink/Electron

Beam Ink

650 g/l 100 g/l 650 g/l

Specialty

Flexographic

NA 100 g/l 100 g/l

Cleaning Polyester

Resin Appl. Equip.

50 g/l 25 g/l 25 g/l
Staff Report - Organic Solvent Rules May 5, 2008

Element for

Comparison

Specific Category Proposed District

Rule 2.31

BACT

2009 2011

Page 34

Emission Limits Alternative

Compliance

Exempt solvents, use

of emission control

equip. collect 90%

(printing 70%)

destroy 95% or

Prohibitory Rule

requirements

Exempt solvents, use

of emission control

equip. meeting

collection and control

efficiencies. Collect

90% destruc 95% or

output < 50 ppm or

meet Prohibitory Rule

limits -printing 70%

collection destruction

95%

Cleaning Device and

method

Requirements

Wipe cleaning,

closed

container/spray

bottles, approved

devices, remote

reservoir, nonatomized flow,

solvent flushing

Wipe cleaning,

closed

container/spray

bottles, approved

devices, remote

reservoir, nonatomized flow,

solvent flushing 

Operating

Parameters and

Work Practice

Requirements

General No solvent atomizing,

application

equipment

requirements

No solvent atomizing,

application

equipment

requirements

Storage and Disposal Closed nonabsorbent, nonleaking containers for

solvent and solvent

laden materials

Closed nonabsorbent, nonleaking containers for

solvent and solvent

laden materials

Monitoring,

Reporting, and

Record keeping

Requirements

Record keeping of

solvent usage, and

control equipment.

Daily records for

control equipment,

monthly for solvent

usage

Record keeping of

solvent usage, and

control equipment.

Daily records for

control equipment,

monthly for solvent

usage
Staff Report - Organic Solvent Rules May 5, 2008

Page 35

IV. IMPACTS OF THE PROPOSED RULE

Emissions Impacts

The ARB maintains an emission inventory of pollutants emitted from different source

categories. The source categories are assigned emission inventory codes (EIC) describing

the general emission group, the specific operation, and material. The District reviewed the

categories applying to solvent cleaning or solvent degreasing. According to the 2005

emissions inventory, for the Yolo-Solano District, solvent cleaning and degreasing for all

categories, including printing and architectural coatings, account for approximately 329 tons

of VOC per year. District staff estimates proposed rule amendments will result in a reduction

of 278 tons of VOC per year as described below.

The inventory relevant to solvent cleaning is broken down into four general categories:

degreasing, coatings and related process coatings, architectural coatings and printing.

These categories include sources that are subject to the regulations but may not be required

to have a permit with the District.

The District compiled all emission data from the 2005 emissions inventory for the different

categories and compared current VOC limits with proposed VOC limits for each category.

From this information, the District determined the percent of emission reductions for each

specific category. The District then applied this figure to the baseline emissions from the

inventory. This established the VOC emissions reductions from each applicable category.

Sample calculations are shown below. For full calculations see Appendix B. 

1. Degreasing. The degreasing category includes cold cleaners, spray guns, vapor

cleaners, and hand wiping. The proposed amendments would lower the allowable

VOC content limit for general cold cleaning to 50 grams per liter and then to 25

grams per liter. Current VOC solvent limits for most processes range from 900-950

grams per liter. The limits for the cleaning of polyester resin application equipment

are currently 200 grams per liter or 1100 grams per liter with a restricted partial

pressure. According to the SCAQMD 1999 Staff Report for Proposed Amendments

to Rule 1171 -Solvent Cleaning Operations, the cleaning of polyester resin

application equipment accounted for approximately 2% of possible cold cleaning and

the cleaning of application equipment. Staff assumed that was representative of the

contribution of emissions from the cleaning of polyester resin application equipment

to the total emissions for degreasing. Emissions for the cleaning of polyester resin

application equipment was then calculated separately due to the difference in VOC

reductions from this category. Emission estimates for vapor cleaning were not

included in the actual calculation since the District does not believe there are any

vapor degreasers in the District. Emission limits for hand wiping includes several

categories. The solvent limits for each category vary depending on the specific

process. The proposed limit for general cleaning is 50 g/l and eventually 25 g/l with

higher limits for specialized categories. The District estimated emissions from this

category by breaking it down into two categories: those that will have higher VOC

limits including medical devices, pharmaceuticals and electrical and electronic

components and all other miscellaneous categories. Emissions from medical devices
Staff Report - Organic Solvent Rules May 5, 2008

Page 36

pharmaceuticals and electrical and electronic components, were approximated by

reviewing the 1999 Staff Report for Proposed Amendments to Rule 1171 for

SCAQMD. The District determined the percent contribution from each of these

categories to the total emissions from product cleaning & surface preparation and

repair and maintenance for SCAQMD. The District conservatively applied the percent

contributions to the hand wiping category. These categories are assumed to have

similar starting VOC limits and proposed VOC limits as the District is proposing for

these categories. The emissions from the remaining miscellaneous categories were

determined by applying a conservative emission reduction figure of 81%. The

emission reduction figure was based on the average of the lowest possible reduction

and the highest. 

Sample Calculation

The 2005 emission inventory for cold cleaning totaled 0.472 tons of VOC per day.

Proposed VOC solvent limits will be 25 grams per liter. Emission reductions from

cold cleaning can be calculated as follows: (0.472 - (0.02 * 0.472)) * [1 - (25/900)] =

0.450 tons of VOCs per day. Emission reductions from the cleaning of polyester

resin application equipment can be calculated as follows: (0.02 * 0.472) * [1 -

(200/900)] = 0.008 tons of VOCs per day. 

Sample Calculation

The 2005 emission inventory for degreasing -handwiping totaled 0.067 tons of VOC

per day. SCAQMD’s product cleaning and surface preparation for medical devices

and pharmaceuticals had a baseline of 0.76 tons/day, representing 7% of

SCAQMD’s emissions total for product cleaning and surface preparation and repair

& maintenance. Reductions for this category were expected to reduce emissions by

0.08 tons/day or by 11%. Emission reductions from product cleaning and surface

preparation for medical devices and pharmaceuticals can be calculated as follows:

(0.067 * 0.07) * (0.11) = 0.0005 tons of VOCs per day.

2. Coatings and Related Process Coatings. The coatings and related process

coatings categories include emissions from both thinning and cleaning. The District

estimated the emissions from solvent cleaning to be 40% and the remaining 60%

would be attributed to thinning. The emission reductions for these categories are

then determined using the same methodology described above. 

Sample Calculation

The 2005 emission inventory for cleaning and surface coatings totaled 0.110 tons

of VOC per day. It was assumed 40% accounted for cleaning. Current VOC solvent

limits are 900 grams per liter. Proposed VOC solvent limits will be 25 grams per liter.

Emission reductions from process coating categories can be calculated as follows:

(0.110 * 0.40) * [1 - (25/900)] = 0.043 tons of VOCs per day.

3. Architectural Coatings. Emissions from architectural coatings were calculated

based on the assumption solvent currently used contains 770 g/l of VOC per liter of

material.

 Sample Calculation

The 2005 emission inventory for architectural coatings totaled 0.146 tons of VOC per
Staff Report - Organic Solvent Rules May 5, 2008

Page 37

day. Proposed VOC solvent limits will be 25 grams per liter. Emission reduction for

the category can be calculated as follows: (0.146) * [1 - (25/770)] = 0.141 tons of

VOCs per day.

4. Printing. The proposed amendments will establish limits in specific categories for

printing. These limits are based on the limits established by SCAQMD. The

emissions inventory for solvent usage from printing operations groups all categories

together. The 1999 Staff Report for Proposed Amendments to Rule 1171 for

SCAQMD reported emissions from each printing category. The District assumed the

percent contribution from each category would approximate emission contributions

from each category for Yolo-Solano. 

Sample Calculation

The 2005 emission inventory for printing operations totaled 0.105 tons of VOC per

year. Proposed VOC solvent limits will vary according to category. Roller

wash/blanket emissions represents 53% of SCAQMD’s emission inventory for

solvents usage in printing operations. Accordingly, it is assumed wash/blanket

emissions are approximately 53% of YSAQMD’s total solvent emissions for printing

operations. Emission reduction for the category can be calculated as follows: (0.105

* 0.53) * [1 - (100/900)] = 0.049 tons of VOCs per day. The total emission reductions

from the printing operations categories total 0.081 tons per day.

In response to comments from the EPA, ARB and public workshops, the District

worked with the EPA, ARB and printing industry to establish an alternative limit for

the lithographic/letterpress and ultraviolet categories. The alternative limits were

calculated based on the assumption referenced on page 17 in the EPA’s Control

Technique Guidelines for Offset Lithographic Printing and Letterpress Printing

(September 2006), using cleaning materials from a solvent with a VOC composite

partial vapor pressure less than 10 mm Hg at 20EC with good work practices results

in an emission reduction comparable to using cleaning materials containing less than

30 weight percent VOC. 

Sample Re-calculation

Emission reductions for the lithographic/letterpress and ultraviolet ink categories

were then re-calculated based on a corresponding VOC content limit using a

representative blanket wash solvent density of 6.6 pounds per gallons (792 grams

per liter). The calculation used is as follows 0.3 x 792 = 238 grams of VOC per liter

of solvent. This VOC limit was then used to to calculate emission reductions for the

lithographic/letterpress and ultraviolet ink categories. Emission reductions

wash/blanket were re-calculated as follows: (0.105 * 0.53) * [1 - (238/900)] = 0.041

tons of VOCs per day. The total emission reductions from the printing operations

categories adjusted equals 0.071 tons per day.

Cost Effectiveness

CH&SC Section 40703 requires the District, in the process of the adoption of any rule or

regulation, to consider and make public its findings related to the cost effectiveness of the

rule. Cost effectiveness for rulemaking purposes is calculated by dividing the cost of air

pollution controls required by the rule by the amount of air pollution reduced.
Staff Report - Organic Solvent Rules May 5, 2008

Page 38

The costs for the proposed revisions can be broken down into the following categories: the

costs associated with converting to aqueous cleaning systems, and lower VOC content limits

for solvents used in various cleaning operations. The majority of the costs associated with

the rule development will be from facilities converting to aqueous cleaning systems to

comply with the lower limits.

Aqueous Cleaning Systems

The conversion from solvent cleaning degreasers to aqueous cleaning systems has been

completed in the BAAQMD, SJVAPCD, SCAQMD, and SMAQMD. Costs for the conversion

to aqueous systems are based on the staff reports for these rule efforts, a study completed

by the Institute for Research and Technical Assistance’s Pollution Prevention Center (IRTA)

for the EPA and Santa Barbara County Air Pollution Control District, and cost information

provided by equipment suppliers. 

The costs associated with converting equipment include the equipment costs, costs of

products used, and operating costs. Traditional solvent units are generally leased from

waste management companies who service the equipment. Equipment, chemicals, and

disposal costs are all included in the service charge. Costs for aqueous cleaning include

specifically, the cost of the aqueous system, solution costs, disposal costs for spent

solutions and/or filters, filter costs, electricity costs and labor costs. Initial equipment costs

for aqueous units vary depending on the type of machine, size of the unit, and features. The

following table demonstrates the range for the different aqueous systems. 

Aqueous Equipment

System

Cost of Equipment

Sink-on-a-drum $328 - $3,000

Immersion unit $800 - $4,200

Enzyme system $1,000 - $2,400

Spray cabinet $1,600 - $6,400

Ultrasonic unit $2,700 - $12,000

The study performed by IRTA included a cost comparison for different case studies related

to converting to aqueous cleaning systems. The report concluded a cost savings for facilities

operating aqueous cleaning systems. The lower costs were attributed to the longer life of the

aqueous solutions, and labor savings. The longer life of aqueous solutions meant both the

amount of cleaning solution used decreased and there was less spent solution to dispose

of. Labor savings were reported from the conversions to enzyme systems and automated

units. Similarly, SCAQMD reported an overall cost savings for the conversion to aqueous

systems based on material savings and disposal savings. Material savings were determined

from overall costs of compliant solutions. Most compliant solutions are sold in concentrated

quantities. Taking into account the cost of the material when diluted and the longer bath life

of the aqueous solutions, the costs savings outweigh increased costs of equipment or

energy.
Staff Report - Organic Solvent Rules May 5, 2008

Page 39

The SJVAPCD analyzed the conversion to aqueous systems evaluating different scenarios

including, facilities with a single solvent degreaser switching to a single aqueous sink on a

drum, facilities with a single degreaser switching to an enzyme-cleaning unit, facilities with

a single degreaser switching to a batch loaded aqueous unit larger in size, and facilities with

two solvent degreasers switching to one batch loaded aqueous cleaning unit. The SJVAPCD

further broke down each scenario taking into account the usage of the unit. The analysis

was made based on the following assumptions: the annual compliance cost includes annual

operation and maintenance costs as well as annualized capitol costs, concentrated aqueous

solutions are diluted with water and the cost of water is insignificant, handling of aqueous

baths is included in the calculations, aqueous solutions are more effective when heated and

any costs are included in the annual compliance cost, labor costs vary by equipment,

aqueous baths last longer and require less change out than traditional solvents, seventy

percent of solvent is recycled and the remaining thirty percent are emissions. The costs and

cost effectiveness are reported as follows.

Usage Annual Cost Cost-Effectiveness 

($/ton of VOC

reduced)

Converting one solvent degreaser to an aqueous unit:

Low usage $546 $12,937

Average Usage $903 $8,560

High Usage $1393 $6,603

Converting one solvent degreaser to an enzyme unit:

Low usage $368 $8,132

Average Usage $430 $3,805

High Usage $468 $2,068

Converting one solvent degreaser to an automated aqueous unit:

Low usage $128 $9,436

Average Usage $238 $2,316

High Usage $788 $3,832

Converting two solvent degreasers to automated aqueous units:

Low usage -$112* -$2,557*

Average Usage -$362* -$3,308*

High Usage -$412* -$1,883*

* The negative sign indicates a cost savings.
Staff Report - Organic Solvent Rules May 5, 2008

Page 40

The cost effectiveness analysis performed by the SJVAPCD is based on requiring cleaning

solutions to comply with a VOC content limit of 50 grams per liter. Requiring facilities to

utilize cleaning solutions with a VOC content limit of 25 grams per liter will only minimally

change the cost-effectiveness. The costs associated with lowering the VOC content limit for

cleaning solutions from 50 grams per liter to 25 grams per liter is negligible because the

difference is generally a matter of dilution. However, there are larger emission reductions

resulting in less associated costs per amount of VOC reduced. 

General Cleaning / Other Cleaning Operations

The costs associated with lowering the VOC content of cleaning solutions varies depending

on the category and specific cleaning process. Most cleaning operations use some type of

wipe cleaning for surface preparation and cleanup. There is no equipment costs for

switching to aqueous cleaners for this category. Costs accrued are based on the cost of the

replacement cleaners. Replacement cleaners include aqueous solutions, exempt

compounds, or blends. The costs of aqueous solutions are generally higher than traditional

solvents, however they are sold in concentrated form. Dilution ratios vary depending on the

product, and typically range from 1-40% solution in water. When diluted, the cost of the

aqueous solution can be less than the cost for traditional solvents.

The SCAQMD reported costs of traditional solvents to range from $4 to $20 per gallon and

replacement solvents from $2 to $40 per gallon. The BAAQMD reported the average cost

for conventional solvents to be $12.25 per gallon and $5.97 per gallon for replacement

solutions with a median price between $2.31 and $2.40 per gallon after dilution.

Medical and Pharmaceutical

There are no costs associated with the addition of the medical and pharmaceutical cleaning

categories. The limits allow for the use of Isopropyl Alcohol (IPA) to meet requirements for

sanitization. Acetone, bleach and solvent blends can be used for other cleaning. The cost

effective analysis performed by Jack Faucett for the SJVAPCD calculated compliance costs

to be about the same.

Printing Industry

The costs associated with the VOC content limits affecting the printing industry were based

on methodologies used by SCAQMD in their 1999 Staff Report for Proposed Amended Rule

1171. The SCAQMD determined the costs from the reductions in each category based on

emission inventory data from a baseline year. The SCAQMD reported the baseline inventory,

current VOC limits, future VOC limits, and emission reductions expected from the new limits.

The SCAQMD used these figures to determine the amount of solvent used for each

category. The SCAQMD determined the difference in cost from replacements solvents and

applied it to the solvent usage. The amount of replacement solvent used was assumed to

be equivalent. The SCAQMD determined the cost increase from each category and divided

that by the projected emissions reduced. The YSAQMD used the emission inventory data

from the 2005 Emission Inventory. The District determined the emissions contributed from

individual categories by assuming the same percentage contribution from each category as

SCAQMD. The YSAQMD corrected any differences in emission reductions expected from

any category that had a different emission reduction expected due to differing VOC content
Staff Report - Organic Solvent Rules May 5, 2008

Page 41

limits. The District conservatively determined the costs effectiveness for this category is

$4,877 per ton of VOC reduced. This analysis did not take into account potential savings

reported by industry using low VOC solvents. One source has reported the cost per volume

of low VOC material to be 30-70% less than traditional solvents. Other savings reported was

cleanup was 40-60% faster. Another cost savings was paper consumption costs was

reduced by 12% because less make-ready paper was required. Industry reported the

frequency the roller needed to be replaced decreased by 50%. 

Architectural Coatings

Proposed amendments to Rule 2.31 would require cleaning solutions used for architectural

application equipment to comply with a VOC content of 25 grams per liter. Costs associated

would be the difference in price with high-VOC cleaners and low-VOC cleaners. District staff

followed methodologies used by SCAQMD and SJVAPCD to determine the costeffectiveness. SCAQMD reported the average cost of high-VOC solvent cleaner at $5 per

gallon. The costs of replacement cleaner ranged from $6-$21 per gallon. The District

approximated the annual baseline usage of solvents, and assumed more replacement

cleaner would be required due to the decreased volatility of replacement cleaners such as

acetone, acetone blends and methyl acetate. The cost effectiveness was then calculated by

dividing the net cost increase by the expected emission reductions from this category.

Annual

Usage

(gallons/yr)

Cost per

Gallon ($)

Annual Cost

($/yr)

Net Cost

Increase 

($/yr)

Cost

Effectiveness

($/ton VOC

reduced)

High VOC

Solvent

17,223 $5 $86,115

Low Cost

Replacement

18,945 $6 $113,672 $27,557 $535

High Cost

Replacement

18,945 $21 $397,851 $311,736 $6,057

Socioeconomic Impacts

CH&SC Section 40728.5 (a) requires the District, in the process of the adoption of any rule

or regulation, to consider the socioeconomic impact if air quality or emission limits may be

significantly affected. However, districts with a population of less than 500,000 persons are

exempt from the provisions of Section 40728.5 (a). The District’s population is estimated

to be approximately 320,000 and well below the 500,000 person threshold. Therefore, a

socioeconomic analysis for this rulemaking is not required. 

Incremental Cost Effectiveness

CH&SC Section 40920.6 requires an assessment of the incremental cost-effectiveness for

proposed regulations relative to ozone, Carbon Monoxide (CO), Sulfur Oxides (SOx),

Nitrogen Oxides (NOx), and their precursors. Incremental cost-effectiveness is defined as

the difference in control costs divided by the difference in emission reductions between two

potential control options that can achieve the same emission reduction goal of a regulation.
Staff Report - Organic Solvent Rules May 5, 2008

Page 42

The proposed amendments result in a VOC reduction of approximately 0.77 tons per day.

There is no other viable control option that can achieve the same amount of emission

reductions. Therefore, the incremental cost-effectiveness analysis does not apply.

Impacts to the District

The proposed amendments are expected to result in an increased workload for the

permitting and compliance sections to implement and enforce the regulations. District

expects that existing staff can absorb the increased work load.

V. ENVIRONMENTAL IMPACTS OF METHODS OF COMPLIANCE

California Public Resource Code Section 21159 requires the District to perform an

environmental analysis of the reasonably foreseeable methods of compliance. The analysis

must include the following information for the proposed amendments to Rules 1.1, 2.25,

2.26, 2.29, 2.30, 2.31, 2.33, 2.35, and 2.39, and the proposed repeal of Rule 2.24.

1. An analysis of the reasonably foreseeable environmental impacts of the methods of

compliance.

2. An analysis of the reasonably foreseeable mitigation measures.

3. An analysis of the reasonably foreseeable alternative means of compliance with the

rule or regulation.

Table 1 lists all reasonably foreseeable compliance methods, the environmental impacts of

those methods, and measures that could be used to mitigate the environmental impacts.
Staff Report - Organic Solvent Rules May 5, 2008

Page 43

TABLE 1. Environmental Impacts, Mitigation Measures, and Alternatives

Compliance

Methods

Reasonably Foreseeable

Environmental Impacts

Reasonably Foreseeable

Mitigation Measures

Using available

exempt solutions

or aqueous

solutions

Air Quality Impacts: All compliance

methods are aimed at lowering VOC

emissions

No mitigation necessary

Water Impacts: Compliance methods will

not increase potential water impacts.

Disposal of spent solutions containing

hazardous substances is not allowed in

public sewer systems

Continued use of proper

treatment and disposal

methods for spent solutions as

required by law

Human Health Impacts: Solvents may be

replaced with more toxic compounds,

however with less emissions of VOCs

there is expected to be less emissions of

Hazardous Air Pollutants (HAPs)

Compliance with OSHA safety

guidelines reduces any

potential impact

Solid Waste Disposal Impacts:

Compliance methods will not increase

potential solid waste disposal impacts.

Spent solutions used for cleaning can

contain hazard waste from materials

cleaned. The hazardous waste has to be

properly disposed of and can not be

legally discharged in public sewer

systems. Contaminants from the

materials cleaned must be disposed of

properly regardless if the solution used

was a solvent or an aqueous solution.

Contractors provide waste handling

services for both spent aqueous and

solvent solutions

Continued use of proper

treatment and disposal

methods for spent solutions

Noise Impacts: Implementation and use

of some recommended aqueous cleaning

systems have potential to increase noise

levels that would effect persons in the

vicinity of the cleaning system

Cleaning system components,

including noise buffering

devices can be used. Proper

installation and proper safety

equipment would result in a

less than significant impact

This analysis demonstrates the adoption of amendments to Rules 1.1, 2.25, 2.26, 2.29, 2.30,

2.31, 2.33, 2.35, and 2.39, will not have a significant effect on the environment or humans
Staff Report - Organic Solvent Rules May 5, 2008

Page 44

due to unusual circumstances. In addition, the amendments to proposed Rules 1.1, 2.25,

2.26, 2.29, 2.30, 2.31, 2.33, 2.35, and 2.39, are an action taken to protect the environment.

Therefore, staff have determined that the project is categorically exempt from the

requirements of the CEQA pursuant to Section 15308, Actions by Regulatory Agencies for

Protection of the Environment. Staff prepared a Notice of Exemption (NOE) to meet the

CEQA Guidelines (Attachment B).

VI. REGULATORY FINDINGS

Section 40727(a) of the CH&SC requires that prior to adopting or amending a rule or

regulation, an air district’s board make findings of necessity, authority, clarity, consistency,

nonduplication, and reference. The findings must be based on the following:

1. Information presented in the District’s written analysis, prepared pursuant to CH&SC

Section 40727.2;

2. Information contained in the rulemaking records pursuant to CH&SC Section 40728;

and

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

The required findings are:

Necessity: The rules amendments are required in order to meet the state’s Best Available

Retrofit Control Technology requirements (section 40919(a)(3) of the CH&SC) and “every

feasible measures” requirement (Section 40914 of the CH&SC) for reducing organic

compound emissions from solvent cleaning operations. (CH&SC Section 40727 (b)(1)).

Authority: The District is authorized to adopt rules and regulations by CH&SC, Sections

40001, 40702, 40716, 41010 and 41013. (CH&SC Section 40727 (b)(2)).

Clarity: District staff have reviewed the proposed rules and determined they can be easily

understood by the affected industries. In addition, the record contains no evidence that the

persons directly affected by the rules cannot understand the rule. (CH&SC Section

40727(b)(3)).

Consistency: The proposed rules do not conflict with and is not contradictory to, existing

statutes, court decisions, or state or federal regulations. (CH&SC Section 40727(b)(4)).

Non-Duplication: The proposed rules do not duplicate any state laws or regulations,

regarding the attainment and maintenance of state and federal air quality limits. (CH&SC

Section 40727(b)(5)).

Reference: The District must refer to any statute, court decision, or other provision of law

that the District implements, interprets, or makes specific by adopting, amending or

repealing the rule. The proposed rule is consistent with the provisions of the CAA and the

CH&SC.
Staff Report - Organic Solvent Rules May 5, 2008

Page 45

VII. PUBLIC COMMENTS AND STAFF RESPONSES

Staff held two public workshops on March 12, 2008 and March 13, 2008, to discuss the

proposed amendments to the rules. Notification was sent to surrounding Air Districts, City

Managers within the District, building/planning/community development departments within

the District, all city and county libraries within the District and all District Board members. In

addition, notices were sent to all permitted sources including coating operations, printing

operations, pharmaceuticals, and manufacturing facilities. Notices were sent to suppliers and

distributors of solvent products and cleaning equipment, trade groups, and unpermitted

sources potentially affected including auto repair shops, motorcycle / boat / recreational /

fleet vehicle repair, painting contractors, paint dealers, limited farms and other potential

sources generating hazardous waste. The workshop notice was published in the Vacaville

Reporter, River News Herald (Rio Vista area), Dixon Tribune, Daily Democrat (Woodland

area), and Davis Enterprise newspapers. A copy of the public workshop notice, the draft staff

report, and draft rule language were posted on the District’s web page.

Public Workshop -March 12, 2008

The public workshop on March 12, 2008 was attended by one (1) representative from the

United Stated Post Office, one (1) representative from the Printing Industry Association, one

(1) representative from Holt of California, one (1) representative from the City of Davis, one

representative from HMC Enterprises, one (1) representative from the Woodland Joint

Unified School District, one (1) representative from Leer West, one (1) representative from

Johnson & Johnson (ALZA), and one (1) staff member from the Sacramento Metropolitan

Air Quality Management District (SMAQMD).

District Staff will attempt to paraphrase the verbal comments that were discussed during the

workshop and respond to each comment.

Comment 1. Please clarify the proposed changes to the specialty flexographic and

gravure printing limits in Section 301 of Rule 2.31. 

Response 1. As discussed during the Rule 2.31 rule review, the current limits of 100

grams/liter and 3 mm Hg will be placed in the table for specialty flexographic

and gravure (publication) categories. Staff is not proposing any changes to

the VOC content limits for these categories.

Comment 2. Why is the District proposing to decrease the VOC content limits in Section

301 of Rule 2.31 to 50 grams per liter for general coatings when South

Coast’s limits are at 100 grams per liter? 

Response 2. The District is proposing a two tier decrease in VOC content limits for

solvents used for surface preparation and cleanup. The District is proposing

different limits for different categories based on limits established by the

SCAQMD. Limits for solvents that do not fit in any specific category will be

limited by the general category. The District is proposing to lower the VOC

content limits for solvents in the general category to 50 grams per liter by July

2009, and 25 grams per liter by January 2011. The SCAQMD already
Staff Report - Organic Solvent Rules May 5, 2008

Page 46

requires a 25 gram per liter VOC content limit for this category. 

Comment 3. The printing industry feels it is more effective to lower vapor pressure

requirements than the VOC content of solvents in the printing industry. There

is concern with the safety of some of the alternative solvents being tested to

meet compliance with the standards set by SCAQMD. The printing industry

is still struggling to meet the limits set by the SCAQMD. Industry needs time

to adjust to alternative products. Please consider putting a VOC content limit

for solvents used for lithographic and letterpress of 650 grams per liter

effective July 2009. Industry would benefit from a step down approach rather

than such a big decrease. The step down would allow the industry time to

adjust to the lower VOC solvents.

Response 3. The District originally revised the VOC content requirements to include a

vapor pressure limit as well for the printing industry. However, the District

removed those vapor pressure limits at the request of the ARB and replaced

with a corresponding VOC content limit. The District revised the requirements

and placed a VOC content limit of 650 grams per liter for lithographic and

letterpress effective July 2009.

Comment 4. Why is the District proposing to increase record retention to five years? It is

draconian to require daily records for five years especially for smaller

operations. Three years is sufficient. Title V requirements should not be

required for non Title V sources. Lesser record keeping is an incentive to stay

out of the Title V program. 

Response 4. The District originally proposed the five year record retention for consistency.

The District will not change the record keeping requirement from two years

to five years for non Title V sources.

Comment 5. In the rules, the language describing the requirements for emission control

systems is confusing. Suggests replacing ‘capture and control’ with capture

and destruction. 

Response 5. The language used by the District is consistent with other agencies. The

District will keep ‘capture and control’.

Comment 6. Companies emitting less than 30 pounds per day are exempt from Rule 2.29

and are not subject to the current requirements in Rule 2.29 for surface

preparation and cleanup. How do these companies comply with the

requirements for surface preparation and cleanup?

Response 6. The requirements of Rule 2.31 are applicable to all sources regardless if they

are subject to individual prohibitory rules. Even if a company is exempt from

Rule 2.29 they still are subject to rule 2.31. In addition, companies exempt

from individual prohibitory rules does not translate to being exempt from

permitting in general. 

Comment 7. Does the District expect to lose revenue by lowering their usage limits and
Staff Report - Organic Solvent Rules May 5, 2008

Page 47

updating the exemptions?

Response 7. The District does not take its own revenue into consideration when proposing

rule amendments.

Comment 8. Why is the District requesting facilities to record the density of solvents used

for surface preparation and cleanup? The requirement makes sense for inks

but not for solvents. The source may not be able to provide that information

because the density is not always on the MSDS. Why does the District need

the density? 

Response 8. The District will remove the requirement for suppliers to make available the

density of the solvents they supply. The density is not needed since the

suppliers are required to provide the VOC content.

Comment 9. Does the five year record retention requirement apply to both permitted and

non-permitted sources? Is record keeping supposed to be monthly or daily?

Response 9. The requirement for record keeping is applicable to anyone subject to the

rule, both permitted and non-permitted sources. The rule is proposing

monthly record keeping requirements for most sources. Sources using

emission control equipment to comply with the rule standards will be required

to keep records on a daily basis.

Comment 10. When the vapor pressure requirements are removed from the rules, will there

still be permit conditions with vapor pressure requirements?

Response 10. Permit conditions reflect rule requirements and/or engineering evaluations.

Currently the District includes vapor pressure requirements in permit

conditions for surface preparation and cleanup subject to vapor pressure

requirements in the prohibitory rules. For categories that will no longer be

subject to vapor pressure requirements, the conditions will eventually be

removed from the permit. However, if vapor pressure requirements were

used or assumed in the engineering evaluation conditions on the permit may

still include vapor pressure requirements. 

Comment 11. Please clarify exemption 112.3 (Rule 2.31), what does the District consider

automatic blanket wash to be?

Response 11. Many machines have a system that automatically applies roller or blanket

wash, versus presses which require the roller or blanket wash to be manually

applied. Exemption 112.3, exempts these automatic system from Section

307 General Prohibitions. Section 307 prohibits solvents to be atomized

unless vented to an air pollution control system. The exemption is in Rule

2.31 to clarify the use of these system is not prohibited by Section 307. 

Comment 12. It was suggested the District delay the implementation of the requirements

increasing record retention from two to five years in order to give affected

sources time to build up their records so they would not be in violation of the
Staff Report - Organic Solvent Rules May 5, 2008

Page 48

rule when the five year requirement goes into effect. 

Response 12. The District is no longer proposing to increase record retention to five years

for non Title V sources.

Comment 13. When will permits get updated to reflect the new requirements? 

Response 13. Permits are generally updated when they are renewed or modified. District

workload will dictate the completion of the updating process. However,

enforcement will begin when the rules go into effect regardless of whether

the permits have been updated to reflect the new requirements. The district

is planning on sending out compliance advisories when the new limits go into

effect.

Comment 14. How do the new requirements affect fleet companies?

Response 14. The requirements affect all sources subject to Rule 2.31. Generally fleet

companies do not require permits, but they still are subject to the

requirements of Rule 2.31. Fleet companies were included in the noticing

because many use parts washer for cleaning. Rule 2.31 will require all parts

washers to use aqueous solvents. 

Comment 15. Is the servicer/manufacturer responsible for letting the buyer know what the

VOC content of the solvent is in the products? What if they put in a

noncompliant product?

Response 15. Per section 402, any person who sells or distributes solvents subject to Rule

2.31 must provide the VOC content of the solvent used. This includes any

person who provides solvents for parts washers. In addition Section 401,

prohibits any one to specify the use of a noncompliant solvent. Therefore it

is a violation of the rule for one party to require another party to use a

noncompliant product.

Comment 16. Are there any other products besides parts washers that the fleet industry

may use that are subject to the rule? 

Response 16. Any product that is used for surface preparation and cleanup is subject to the

rule. Other products may be subject to the requirements. Some common

products used such as aerosol brake cleaner are exempt from the VOC

content limits and application requirements of Rule 2.31, if 160 oz or less are

used per day. These products are considered consumer products and are

regulated by CARB.

Comment 17. Per exemption 115 (Rule 2.31) we could only use a maximum of 14 cans of

IPA aerosol per day, do we not have to track this anymore?

Response 17. Exemption 115 was not removed from the rule it was moved and is now in

Section 113. The exemption limits a facility to 160 oz or less per day however

it equates to the size of containers a facility uses. The use of these products
Staff Report - Organic Solvent Rules May 5, 2008

Page 49

are still subject to the other administrative and record keeping requirements.

The facility still needs to track the usage. 

Comment 18. What if we use more than 160 oz per day? 

Response 18. The rule limits the use to 160 oz per day, if any more is used it is a violation

of the rule and subject to enforcement.

Comment 19. What is the threshold for VOC emissions per month for a graphic arts

permit?

Response 19. District Rule 3.2 Exemptions outlines equipment/process that do not require

a permit. Section 110.2 is applicable to graphic arts operations and states

any surface coating operations using a combined total of one gallon or less

per day of coating material and solvent does not require a permit. The

threshold to determine the applicability of Rule 2.29 Graphic Arts Printing

Operations is currently 400 pounds of VOC emissions in any month. The 400

pounds per month includes any emissions from solvents used for surface

preparation and cleanup. 

Comment 20. Would the District consider moving the category ‘General’ in the table

(Section 301 of Rule 2.31) from the top to the bottom of the table? It makes

more sense for process order. 

Response 20. The District moved the section to the bottom of the table to increase clarity.

Comment 21. Please clarify how exemption 110.5 (Rule 2.26 ) relates to stenciling. How do

the rules apply to stenciling?

Response 21. Rule 2.26 Motor Vehicle and Mobile Equipment Coating Operations exempts

graphic design applications from the provisions of the rule. Graphic arts

application is defined in Section 210 and includes the application of logos,

letters, numbers and graphics to a painted surface with or without the use of

a template. This exemption does not specify any application method.

However Rule 2.25 Metal Parts and Products Coating Operations, exempts

stencil coatings but specifies stencil coatings are brushed or rolled on. Rule

2.26 also has an exemption for touch-up operations, which is defined by

Section 231 as a coating applied by brush, air brush, or hand held, nonrefillable aerosol cans to repair minor surface damage and imperfections less

that four square feet. 

Public Workshop -March 13, 2008

The public workshop on March 13, 2008 was attended by one (1) representative from the

United States Post Office, one (1) representative from the Printers’ Service, one (1)

representative from Simonton Windows, two (2) representative from Carwen Printing and

one (1) staff member from the Sacramento Metropolitan Air Quality Management District

(SMAQMD).
Staff Report - Organic Solvent Rules May 5, 2008

Page 50

District Staff will attempt to paraphrase the verbal comments that were discussed during the

workshop and respond to each comment.

Comment 1. The printing industry feels it is more effective to lower vapor pressure

requirements than the VOC content of solvents used in the printing industry.

There is concern with the safety of some of the alternative solvents being

tested to meet compliance with the standards set by SCAQMD. Acetone is

not an reasonable alternative, as it is no better for the environment and

worker exposure is an issue. Many of the other alternative products are not

safe for the workers exposed to them and are hard to dispose of. The low

VOC content solvents have no BTU content and have to be handled as

hazardous waste. As the printing industry is still struggling to meet the limits

set by the SCAQMD, the proposed step down to 650 grams per liter by 2009

would give industry time to adjust to the alternative products. Industry needs

time to adjust to alternative products.

Response 1. The District originally revised the VOC content requirements to include a

vapor pressure limit as well for the printing industry. However, the District

removed those vapor pressure limits at the request of the ARB and replaced

with a corresponding VOC content limit. The District revised the requirements

and placed a VOC content limit of 650 grams per liter for lithographic and

letterpress effective July 2009.

Comment 2. Are there any Gravure facilities within the YSAQMD?

Response 2. The District is not aware of any gravure facilities in the District.

Comment 3. In reference to the footnote under the table in Section 301 of Rule 2.31, what

kind of solvent is used in the solvent reclamation system?

Response 3. The footnote referenced the current limits for solvents used for surface

preparation and cleanup with polyester resin operations. Currently, the limit

is 200 grams per liter, but allows solvents with a higher VOC content to be

used if a solvent reclamation is used. The District is not requiring the use of

a solvent reclamation system for solvents with a lower VOC content. The

District has removed this footnote because currently no facilities are using a

reclamation system to comply with the current limits.

Comment 4. Are the requirements of Section 307 (Rue 2.31) applicable to consumer

products and spray cans?

Response 4. Aerosol/consumer products are not subject to Section 307. For clarification,

the District has added Section 307 to the list of the rule sections aerosol

products are not subject to found in Section 113.

Comment 5. Are all Districts trying to be consistent with these rules? Which counties fall

under the Yolo-Solano AQMD?

Response 5. As discussed, the limits proposed in Rule 2.31 are based on limits adopted
Staff Report - Organic Solvent Rules May 5, 2008

Page 51

by the SCAQMD. Other Districts have adopted similar requirements including

the SJVAPCD, BAAQMD and SMAQMD. The District has jurisdiction over all

of Yolo County and the northeast portion of Solano County, from Vacaville

on the west to Rio Vista on the south.

Comment 6. Most VOC emissions are from the blanket wash. There are automatic blanket

systems that use prepacs or pre-saturated cloth that eliminate excess

cleaning solution. This technology is available with many newer models of

presses. This method is environmentally friendly and generally cost effective.

Response 6. The District appreciates the information on this technology.

Written Comments

EPA

The EPA reviewed the draft language and submitted preliminary comments on March 17,

2008. The comment letter is included in Appendix E. Following is the District’s response to

the comments submitted.

Response #1: The District appreciates the EPA’s support in lowering the VOC content limits

for solvents used for surface preparation and cleanup. 

Response #2: The definition for VOC composite partial pressure will remain in Rule 2.31.

Response #3: The District has revised the language for O&M Plans.

Response #4: A definition for general work surfaces has been added.

Response #5 & 6:

The requested changes were made to the table and footnotes. The only

difference was the general requirements section was moved to the end of the

table so the category was changed to industry not specified above.

ARB

ARB reviewed the draft language and submitted comments on April 3, 2008. The comment

letter is included in Appendix E. Following is the District’s response to the comments

submitted.

Rule 2.25

Response #1, 2 & 3:

As discussed, the District’s intent during this rule revision is to address

surface preparation and clean up. The District has committed to re-opening

this rule to address all other rule requirements, such as, exemptions, coating

limits, and stripper limit requirements.

Response #4: The District is not proposing to reference the latest ASTM version as the EPA

has not yet approved this version.
Staff Report - Organic Solvent Rules May 5, 2008

Page 52

Response #5: The District has updated the test method sections referencing the latest EPA

approved ASTM method.

Rule 2.26

Response #6: As discussed, the District’s intent during this rule revision is to address

surface preparation and clean up. The District has committed to re-opening

this rule to address all other rule requirements, such as, exemptions, coating

limits, and stripper limit requirements.

Rule 2.29

Response #7 & 8:

As discussed, the District’s intent during this rule revision is to address

surface preparation and clean up. The District has committed to re-opening

this rule to address all other rule requirements, such as, exemptions, coating

limits, and stripper limit requirements.

Response #9: The District has revised the language to specify the applicable sections.

Response #10:

The District is not proposing to reference the latest ASTM version as the EPA

has not yet approved this version.

Rule 2.31

Response #11:

The District will revisit this limit when the SCAQMD’s limit takes effect.

Rule 2.39

Response #12, 13 & 14:

As discussed, the District’s intent during this rule revision is to address

surface preparation and clean up. The District has committed to re-opening

this rule to address all other rule requirements, such as, exemptions, coating

limits, and stripper limit requirements.

EPA

The EPA reviewed the language and submitted final comments on April 9, 2008. The

comment letter is included in Appendix E. Following is the District’s response to the

comments submitted.

Rule 2.24 Solvent Cleaning Operations (Degreasing)

Sections d.2 and d.2.a:

The District is proposing to add to Rule 2.31, Section 304 Cleaning Devices -

Requirements for Equipment Using Solvents with a High VOC Content. This

section will be applicable to batch loaded cold cleaners using a solvent with

a VOC content greater than 50 grams per liter. These devices will be

required to use a cover that can be easily opened with one hand. Currently

the District is unaware of this equipment type operating in the District. The

District is requiring low VOC content for most cleaning categories. The
Staff Report - Organic Solvent Rules May 5, 2008

Page 53

District feels this will control emissions more effectively than equipment

requirements.

Section d.4: The District is not proposing to include a requirement for permanent

conspicuous labels listing the operating requirements for degreasing

equipment. This requirement would only be relevant for emission control from

large degreasers using high VOC solvents. Any such equipment would

require a permit from the District which would list the operating conditions.

The District feels this would be as effective for enforceability.

Sections d.5.a. and d.5.c:

These conditions were added to Section 304. 

Sections d.5.d.1 through d.5.d.4:

These conditions were added to Section 305 Remote Reservoir Cold

Cleaners. Because some of the conditions are not appropriate for aqueous

remote reservoir cleaners, these requirements were added only for remote

reservoir cleaners using solvents with a VOC content greater than 50 grams

per liter.

Section e.1 and e.5 through e.7:

District staff added Section 303 Cleaning Devices - General Requirements.

This Section outlines general requirements for the cleaning devices

described in Section 302. These conditions were previously only applicable

to remote reservoir cleaners but are now proposed in 303. Staff’s

assessment is Section 303.2 has the same intent as Section e.1. Sections

e.5 through e.7 have been added to Section 304.

Rule 2.25, Metal Parts and Products Coating Operations

Section 112 and 300:

As discussed, the District’s intent during this rule revision is to address

surface preparation and clean up. The District has committed to re-opening

this rule to address all other rule requirements, such as, exemptions, coating

limits, and stripper limit requirements.

Section 113.1:The District currently has a definition for mold-seal coating in Rule 2.25.

Table1: The footnote has been removed from Rule 2.25.

Section 302: The District added definitions for dip coat, electrostatic applications, flow

coat, and roll coat. The rule currently has a definition for hand coat. The

District amended the language in Section 302 to specify other methods

approved must have an equivalent transfer efficiency to HVLP.

Rule 2.30, Polyester Resin Operations

Section 301.1:The language was amended for clarity.
Staff Report - Organic Solvent Rules May 5, 2008

Page 54

Section 402: The language referencing an equivalent level was removed.

Rule 2.35, Pharmaceutical Manufacturing Operations

The District is delaying the submittal of this rule into the SIP until the District

evaluates the rule with respect to the CTG. However, the District is

presenting the proposed rule to the Board for adoption on May 14, 2008. If

the District board adopts the rule the requirements will go into effect upon

adoption. 

Rule 2.39, Wood Coatings 

Section 600: The District moved all calculations out of the definition sections of the rules

and into Section 600. Section 600 does not cite the specific calculations

previously found in Rule 2.39's definition section. The District proposed

changes to the capture efficiency and control efficiency sections based on

approved language found in SJVAPCD’s rules. The language is consistent

with the guidance Document for Correcting Common VOC & Other Rule

Deficiencies (August 2001). 

Section 111 and 300:

As discussed, the District’s intent during this rule revision is to address

surface preparation and clean up. The District has committed to re-opening

this rule to address all other rule requirements, such as, exemptions, coating

limits, and stripper limit requirements.

Table 1: The footnotes have been removed from the table. The definition for

conversion varnish was amended to clarify a conversion varnish would still

be classified as a conversion varnish if it was used as a self sealing system.

The contents of the second footnote were moved back to a separate section.

Printing Industries of California

Written comments were submitted by the printing Industries of California. The comment

letter is included in Appendix E. Following is the District’s response to the comments

submitted.

The District is deleting Section 110.1. The Requirements in this section were only in effect

until January 1, 1995.

The District is not proposing to include the ink retention factors in Rule 2.29 at this time since

the rule is scheduled to be re-opened to address all other rule requirements. The District

encourages the participation of the printing industry during the next rule development.

The District has made some changes to the table in Section 301 of Rule 2.31 to make it

easier to follow. The District has added the requested step down limit for the lithographic and

letterpress categories. 

The requirement for solvent suppliers to provide the density of applicable solvents to the
Staff Report - Organic Solvent Rules May 5, 2008

Page 55

purchaser has been removed.

The EPA recommends records to be retained for a five year period, however this is not an

approvability issue. The EPA will accept a minimum record retention period of two years.

The District will keep the record retention period of two years for all non Title V facilities for

these rules. 

Simonton Windows

Written comments were submitted by Simonton Windows. The comment letter is included

in Appendix E. Following is the District’s response to the comments submitted.

The District has reviewed rules for surface preparation and cleanup currently in effect in

other Districts. The District reviewed technology assessments and did not find any

exceptions to this source category. The District will continue to work with Simonton Windows

to find alternatives that will meet the proposed requirements. 

Johnson and Johnson (ALZA)

Written comments were submitted by Johnson and Johnson (ALZA). The comment letter is

included in Appendix E. Following is the District’s response to the comments submitted.

The District has corrected the typo in the table in Section 301 of Rule 2.31. The table listed

an 800 grams per liter VOC content limit for solvents used for the cleaning of application

equipment for the medical devices and pharmaceutical categories. The staff report had

included the limit of 810 grams per liter for this category.

Printers’ Service

Written comments were submitted by the printing Industries of California. The comment

letter is included in Appendix E. Following is the District’s response to the suggestions

submitted.

The District appreciates the information on the prepacs including the costs to convert or

retrofit presses. The District will continue to follow this technology.

 

The District has added a step down limit to the proposed requirements in Rule 2.31. The rule

will include interim limits of 650 grams per liter by 2009 for the lithographic and letterpress

and ultraviolet categories. An interim limit of 500 is proposed for the screen printing

category.

ALZA

Additional written comments were submitted by ALZA on April 30, 2008. The comment letter

is included in Appendix E. Following is the District’s response to the suggestions submitted.

The District has worked closely with ALZA throughout this rule development. In lieu of the

recent information ALZA may start the manufacturing of the transdermal patch, the District

is committed to continue to work with ALZA to determine the best controls and the feasibility
Staff Report - Organic Solvent Rules May 5, 2008

Page 56

of compliance with the proposed limits. The District added an exemption for the use of ethyl

acetate from the requirements of Section 301. Therefore, the District is proposing to keep

the proposed compliance dates for the limits proposed.

ARB

ARB reviewed the proposed language and submitted comments on May 2, 2008. The

comment letter is included in Appendix E. Following is the District’s response to the

comments submitted.

Rule 2.25

Response #1, 2 & 3:

As discussed, the District’s intent during this rule revision is to address

surface preparation and clean up. The District has committed to re-opening

this rule to address all other rule requirements, such as, exemptions, coating

limits, and stripper limit requirements.

Rule 2.29

Response #4 & 5:

As discussed, the District’s intent during this rule revision is to address

surface preparation and clean up. The District has committed to re-opening

this rule to address all other rule requirements, such as, exemptions, material

requirements.

Rule 2.31

Response #6:

The District has revised the limits in the table. The District replaced the partial

pressure VOC limits with representative VOC limits in the

lithographic/letterpress and ultraviolet ink categories. The District is

committed to revisiting these categories before the effective date of 2011 to

determine if the lower limits are achievable at that time. 

Rule 2.35

Response #7, 8 & 9:

As discussed, the District’s intent during this rule revision is to address

surface preparation and clean up. The District has committed to re-opening

this rule to address and clarify all other rule requirements, such as,

exemptions, definitions and record keeping requirements.

Rule 2.39

Response #10-13:

As discussed, the District’s intent during this rule revision is to address

surface preparation and clean up. The District has committed to re-opening

this rule to address and clarify all other rule requirements, such as,

exemptions, coating limits, stripper and record keeping requirements.

VIII. REFERENCES

1. Electronic Code of Federal Regulations, Title 40, Part 63 -National Emission
Staff Report - Organic Solvent Rules May 5, 2008

Page 57

Standards for Hazardous Air Pollutants for Source Categories (Current June 14,

2007).

2. Environmental Protection Agency, Control Techniques Guidelines for Offset

Lithographic Printing and Letterpress Printing (September 2006).

3. Environmental Protection Agency, Region IX, Guidance Document For Correcting

Common VOC & Other Rule Deficiencies (August 2001).

4. Bay Area Air Quality Management District Regulation 8, Organic Compounds Rule

4, General Solvent and Surface Coating Operations (October 16, 2002).

5. Bay Area Air Quality Management District Regulation 8, Organic Compounds Rule

16, Solvent Cleaning Operations (October 16, 2002).

6. Bay Area Air Quality Management District Staff Report Proposed Amendments to

BAAQMD Regulation 8, Rule 16: Solvent Cleaning Operations (September 2002).

7. Bay Area Air Quality Management District Staff Report Proposed Amendments to

Regulation 8, Rule 4: General Solvent and Surface Coating Operations, Regulation

8, Rule 14: Surface Coating of Large Appliances and Metal Furniture, Regulation 8,

Rule 19: Surface Coating of Miscellaneous Metal Parts and Products, Regulation 8,

Rule 31: Surface Coating of Plastic Parts and Products, Regulation 8, Rule 43:

Surface Coating of Marine Vessels (September 13, 2002).

8. Institute for Research and Technical Assistance, Pollution Prevention Center. WaterBased Parts Washer Systems: Case Study Conversions Prepared for U.S.

Environmental Protection Agency and Santa Barbara County Air Pollution Control

District (December 11, 1998).

9. Sacramento Metropolitan Air Quality Management District, Rule 466 -Solvent

Cleaning (May 23, 2002).

10. Sacramento Metropolitan Air Quality Management District, Staff Report Rule 454 -

Degreasing Operations And Rule 466 Solvent Cleaning (May 23, 2002).

11. Sacramento Regional 8-Hour Ozone Attainment Plan Proposed Control Measured

Draft (October 2006).

12. San Joaquin Valley Air Pollution Control District Draft Staff Report Proposed

amendments to the organic solvent cleaning sections of the following rules: Rule

4603 (Surface Coating of Metal Parts and Products), Rule 4604 (Can and Coil

Coating Operations), Rule 4605 (Aerospace Assembly and Component Coating

Operations), Rule 4606 (Wood Products Coating Operations) Rule 4607 (Graphic

Arts), Rule 4602 (Motor Vehicles and Mobile Equipment Coating Operations-Phase

II), Rule 4653 (Adhesives), Rule 4661 (Organic Solvents), Rule 4662 (Organic

Solvent Degreasing Operations), Rule 4663 (Organic Solvent Cleaning, Storage, and

Disposal), Rule 4684 (Polyester Resin Operations) (October 31, 2006 and June 18,

2007).
Staff Report - Organic Solvent Rules May 5, 2008

Page 58

13. San Joaquin Valley Air Pollution Control District Final Staff Report Proposed

amendments to the organic solvent cleaning sections of the following rules: Rule

4603 (Surface Coating of Metal Parts and Products), Rule 4604 (Can and Coil

Coating Operations), Rule 4605 (Aerospace Assembly and Component Coating

Operations), Rule 4606 (Wood Products Coating Operations) Rule 4607 (Graphic

Arts), Rule 4602 (Motor Vehicles and Mobile Equipment Coating Operations-Phase

II), Rule 4653 (Adhesives), Rule 4661 (Organic Solvents), Rule 4662 (Organic

Solvent Degreasing Operations), Rule 4663 (Organic Solvent Cleaning, Storage, and

Disposal), Rule 4684 (Polyester Resin Operations) (August 16, 2007).

14. San Joaquin Valley Air Pollution Control District Rule 4661 Organic Solvents (Draft

October 31, 2006).

15. San Joaquin Valley Air Pollution Control District Rule 4662 Organic Solvent

Degreasing Operations (Draft October 31, 2006).

16. San Joaquin Valley Air Pollution Control District Rule 4663 Organic Solvent Cleaning,

Storage, and Disposal (Draft October 31, 2006).

17. South Coast Air Quality Management District Attachment 1 to the Governing Board

Resolution for Proposed Amended Rule1171 Solvent Cleaning Operations: Findings

and Statement of Overriding Consideration (January, 2008).

18. South Coast Air Quality Management District Rule 1171 Solvent Cleaning (Amended

July 14, 2006, Amended February 1, 2008).

19. South Coast Air Quality Management District Staff Report for Proposed Amended

Rule 1171 -Solvent Cleaning Operations (September 27, 1999, June 2006, February

2008).

20. State of California. California Air Resources Board, 2005 Emission Inventory.

21. State of California. California Air Resources Board, ARB Solvent Evaporation

Methodologies -Architectural Coatings and Cleaning/Thinning solvents (Revised

October 2003).

22. State of California. California Air Resources Board, California Air Pollution Control

Laws 2007 Edition.

23. U.S. Environmental Protection Agency, Aqueous P arts Cleaning Best Environmental

Practices for Auto Repair (November 1999).

24. Ventura County Air Pollution Control District Rule 74.6 -Surface Cleaning and

Degreasing (Revised 11/11/03).

25. Ventura County Air Pollution Control District Proposed Amended Standards -APCD

Rule 74.6, Surface Cleaning and Degreasing, and Rule 74.6.1, Batch Loaded Vapor

Degreasers. And Related Proposed Revisions to: Rule 23.F, Exemptions From
Staff Report - Organic Solvent Rules May 5, 2008

Page 59

Permit, Rule 74.12 Surface Coating of Metal Parts and Products, Rule 74.13,

Aerospace Assembly and Component Manufacturing Operations, Rule 74.19,

Graphic Arts, Rule 74.19.1 Screen Printing Operations, Rule 74.24, Marine Coating

Operations, Rule 74.30, Wood Products Coatings, And the Proposed Repeal of

Existing Rule 74.6.3., Conveyorized Degreasers (November 11, 2003).
ATTACHMENT A

PROPOSED RULE 1.1 GENERAL PROVISIONS AND DEFINITIONS

PROPOSED RULE 2.31 SURFACE PREPARATION AND CLEANUP

PROPOSED RULE 2.25 METAL PARTS AND PRODUCTS COATING

OPERATIONS

PROPOSED RULE 2.26 MOTOR VEHICLE AND MOBILE EQUIPMENT

COATING OPERATIONS

PROPOSED RULE 2.29 GRAPHIC ARTS PRINTING OPERATIONS

PROPOSED RULE 2.30 POLYESTER RESIN OPERATIONS

PROPOSED RULE 2.33 ADHESIVE OPERATIONS

PROPOSED RULE 2.35 PHARMACEUTICAL MANUFACTURING

OPERATIONS

RULE 2.39 WOOD PRODUCTS COATING OPERATIONS

STRIKE-OUT UNDERLINE VERSIONS
ATTACHMENT B

EMISSION CALCULATIONS



ATTACHMENT C

NOTICE OF EXEMPTION FROM CEQA GUIDELINES
Notice of Exemption

To: G Office of Planning and Research

1400 Tenth Street., Room 121

Sacramento, CA 95814

G County Clerk : County Clerk

County of Yolo Solano County

625 Court Street Room 105 675 Texas Street, Ste. 1900

Woodland, CA 95695 Fairfield, CA 94533

From: Yolo-Solano Air Quality Management District

1947 Galileo Court, Suite 103

Davis, CA 95618

Project Title: Revision of Rule 1.1, General Provisions and Definitions; Rule 2.25, Metal Parts and

Products Coating Operations; Rule 2.26, Motor Vehicle and Mobile Equipment

Coating Operations; Rule 2.29, Graphic Arts Printing Operations; Rule 2.30,

Polyester Resin Operations; Rule 2.31, Surface Preparation and Cleanup; Rule 2.33,

Adhesive Operations; Rule 2.35 Pharmaceutical Manufacturing Operations; Rule

2.39, Wood Products Coating Operations; and the Rescission of Rule 2.24, Solvent

Cleaning Operations (Degreasing)

Project Location: Yolo-Solano Air Quality Management District

Project description: The Yolo-Solano Air Quality Management District (District) is proposing to amend

the solvent cleaning portions of the aforementioned rules to lower VOC content

limits for solvents used for surface preparation and clean up, and establish consistent

requirements for the storage and disposal of the solvents. 

Name of Public Agency Approving Project: Yolo-Solano Air Quality Management District

Name of Person or Agency Carrying Out Project: Yolo-Solano Air Quality Management District

Exempt Status:

G Ministerial

G Emergency Project

: Categorical Exemption (CEQA Guidelines Section 15308, Action by Regulatory Agency for

Protection of the Environment)

G Statutory Exemption

Reason why project is exempt: The revision of Rules 1.1, 2.25, 2.26, 2.29, 2.30, 2.31, 2.33, 2.35and

2.39, and the rescission of Rule 2.24 is an action taken to protect the

environment and is therefore exempt from CEQA because it

constitutes a Class 8 categorical exemption pursuant to CEQA

Guidelines 15308.

Lead Agency Contact Person: Mat Ehrhardt, Air Pollution Control Officer

Telephone Number: (530) 757-3650

Signature: Date: Title: 
Notice of Exemption

To: G Office of Planning and Research

1400 Tenth Street., Room 121

Sacramento, CA 95814

: County Clerk G County Clerk

County of Yolo Solano County

625 Court Street Room 105 675 Texas Street, Ste. 1900

Woodland, CA 95695 Fairfield, CA 94533

From: Yolo-Solano Air Quality Management District

1947 Galileo Court, Suite 103

Davis, CA 95618

Project Title: Revision of Rule 1.1, General Provisions and Definitions; Rule 2.25, Metal Parts and

Products Coating Operations; Rule 2.26, Motor Vehicle and Mobile Equipment

Coating Operations; Rule 2.29, Graphic Arts Printing Operations; Rule 2.30,

Polyester Resin Operations; Rule 2.31, Surface Preparation and Cleanup; Rule 2.33,

Adhesive Operations; Rule 2.35 Pharmaceutical Manufacturing Operations; Rule

2.39, Wood Products Coating Operations; and the Rescission of Rule 2.24, Solvent

Cleaning Operations (Degreasing)

Project Location: Yolo-Solano Air Quality Management District

Project description: The Yolo-Solano Air Quality Management District (District) is proposing to amend

the solvent cleaning portions of the aforementioned rules to lower VOC content

limits for solvents used for surface preparation and clean up, and establish consistent

requirements for the storage and disposal of the solvents. 

Name of Public Agency Approving Project: Yolo-Solano Air Quality Management District

Name of Person or Agency Carrying Out Project: Yolo-Solano Air Quality Management District

Exempt Status:

G Ministerial

G Emergency Project

: Categorical Exemption (CEQA Guidelines Section 15308, Action by Regulatory Agency for

Protection of the Environment)

G Statutory Exemption

Reason why project is exempt: The revision of Rules 1.1, 2.25, 2.26, 2.29, 2.30, 2.31, 2.33, 2.35and

2.39, and the rescission of Rule 2.24 is an action taken to protect the

environment and is therefore exempt from CEQA because it

constitutes a Class 8 categorical exemption pursuant to CEQA

Guidelines 15308.

Lead Agency Contact Person: Mat Ehrhardt, Air Pollution Control Officer

Telephone Number: (530) 757-3650

Signature: Date: Title: 
ATTACHMENT D

RESOLUTION NO. 08-05
RESOLUTION NO. 08-05

RESOLUTION AMENDING YOLO-SOLANO AIR QUALITY MANAGEMENT

DISTRICT RULES; 

1.1 GENERAL PROVISIONS AND DEFINITIONS

2.25 METAL PARTS AND PRODUCTS COATING OPERATIONS

2.26 MOTOR VEHICLE AND MOBILE EQUIPMENT COATING OPERATIONS

2.29 GRAPHIC ARTS PRINTING OPERATIONS

2.30 POLYESTER RESIN OPERATIONS

2.31 SURFACE PREPARATION AND CLEANUP

2.33 ADHESIVE OPERATIONS

2.35 PHARMACEUTICAL MANUFACTURING OPERATIONS

2.39 WOOD PRODUCTS COATING OPERATIONS

WHEREAS, California Health and Safety Code section 40702 provides that an air quality

management district shall adopt rules and regulations, and do such acts as may be necessary or proper

to execute the powers and duties granted to, and imposed upon, the district by Division 26 of the

Health and Safety Code; and

WHEREAS, Health and Safety Code section 40727 provides that before adopting, amending,

or repealing a rule or regulation, a district board shall make findings of necessity, authority, clarity,

consistency, nonduplication, and reference, based upon information developed pursuant to section

40727.2, information in the rulemaking record maintained pursuant to section 40728, and relevant

information presented at the public hearing required by section 40725; and

WHEREAS, section 15308 of the CEQA Guidelines provides that actions taken by regulatory

agencies as authorized by state law to assure the maintenance, restoration, or enhancement of the

environment where the regulatory process involves procedures for protection of the environment, are

categorically exempt from CEQA review (Class 8 Categorical Exemption); and

WHEREAS, California Health and Safety Code sections 39002 and 4000 provides that an

air quality management district shall have the responsibility to control air pollution from all sources

other than vehicular sources; and

WHEREAS, the District Rule 2.25, Metal Parts and Products Coating Operations; Rule 2.26,

Motor Vehicle and Mobile Equipment Coating Operations; Rule 2.29, Graphic Arts Printing

Operations; Rule 2.30, Polyester Resin Operations; Rule 2.31, Surface Preparation and Cleanup; Rule

2.33, Adhesive Operations; Rule 2.35, Pharmaceutical Manufacturing Operations; and Rule 2.39,

Wood Products Coating Operations, are being proposed for amendments and Rule 2.24, Solvent

Cleaning Operations (Degreasing), is being proposed for recision to meet the requirements of Health

and Safety Code sections 40914 and 40920;
NOW, THEREFORE, BE IT RESOLVED that the Board of Directors of the Yolo-Solano

Air Quality Management District hereby finds, authorizes, directs and declares as follows:

1. The Board of Directors has considered and hereby adopts by reference the staff report

prepared in this matter.

2. The Board of Directors makes the following findings pursuant to Health and Safety

Code section 40727:

a. Necessity: Information in the District’s rulemaking record maintained pursuant

to Health and Safety Code section 40728 demonstrates a need for amending

Rules 1.1, 2.25, 2.26, 2.29, 2.30, 2.31, 2.33, 2.35, and 2.39, and rescinding

Rule 2.24.;

b. Authority: Health and Safety Code section 40702 permits the District to

amend District Rules 1.1, 2.25, 2.26, 2.29, 2.30, 2.31, 2.33, 2.35, and 2.39,

and rescind Rule 2.24;

c. Clarity: District Rule Rules 1.1, 2.25, 2.26, 2.29, 2.30, 2.31, 2.33, 2.35, and

2.39, as amended are written so that their meaning can be easily understood

by the persons directly affected by them;

d. Consistency: District Rules 1.1, 2.25, 2.26, 2.29, 2.30, 2.31, 2.33, 2.35, and

2.39, as amended and the rescission of Rule 2.24 are in harmony with, and not

in conflict with or contradictory to, existing statutes, court decisions, or state

or federal regulations;

e. Nonduplication: District Rules 1.1, 2.25, 2.26, 2.29, 2.30, 2.31, 2.33, 2.35, and

2.39, as amended and the rescission of Rule 2.24 do not impose the same

requirements as an existing state or federal regulation;

f. Reference: District Rules 1.1, 2.25, 2.26, 2.29, 2.30, 2.31, 2.33, 2.35, and 2.39

are consistent with provisions of the Clean Air Act.

3. The Board of Directors finds that the District has complied with the procedural

requirements set forth in Chapters 6 and 6.5 of Part 3 of Division 26 of the Health and

Safety Code.

4. The Board of Directors finds that amending District Rules 1.1, 2.25, 2.26, 2.29, 2.30,

2.31, 2.33, 2.35, and 2.39, and rescinding Rule 2.24 is an action taken by a regulatory

agency as authorized by state law to assure the maintenance, restoration, or

enhancement of the environment where the regulatory process involves procedures for

protection of the environment, and is therefore categorically exempt from CEQA

review as a Class 8 Categorical Exemption.

5. The Board of Directors hereby amends District Rule 1.1, General Provisions and

Definitions; Rule 2.25, Metal Parts and Products Coating Operations; Rule 2.26,

Motor Vehicle and Mobile Equipment Coating Operations; Rule 2.29, Graphic Arts

Printing Operations; Rule 2.30, Polyester Resin Operations; Rule 2.31, Surface

Preparation and Cleanup; Rule 2.33, Adhesive Operations; Rule 2.35, Pharmaceutical

Manufacturing Operations; and Rule 2.39, Wood Products Coating Operations, and

rescinds Rule 2.24, Solvent Cleaning Operations (Degreasing), as set forth in Exhibit

1 (Attachment A of the Staff Report), which is attached and incorporated by reference.

The amendment is effective May 14, 2008.
PASSED AND ADOPTED by the Board of Directors of the Yolo-Solano Air Quality

Management District this 14th day of May, 2008, by the following vote:

Ayes:

Noes:

Absent:

Abstain:

____________________________________

John Vasquez, Chair

Board of Directors

Yolo-Solano Air Quality Management District

Attest: Approved as to Form:

____________________ _____________________ ____ 

Kay Mahorney, Clerk Hope Welton, District Counsel

Board of Directors
ATTACHMENT E

WRITTEN COMMENTS RECEIVED
From: <Chilingaryan.Sona@epamail.epa.gov>

To: <nfletcher@ysaqmd.org>

Date: 3/17/2008 11:57:13 AM

Subject: Fw: EPA Comments on Yolo-Solano Rule 2.31

----- Forwarded by Sona Chilingaryan/R9/USEPA/US on 03/17/2008 11:55 AM

-----

 

 Andrew 

 Steckel/R9/USEPA 

 /US To 

 smclaughlin@ysaqmd.org, 

 03/17/2008 11:48 mguzzett@arb.ca.gov 

 AM cc 

 Sona Chilingaryan/R9/USEPA/US@EPA 

 Subject 

 EPA Comments on Yolo-Solano Rule 

 2.31 

 

 

 

 

 

 

 

 (Embedded image moved United States Environmental Protection Agency

 to file: pic22316.jpg) Region IX 

 75 Hawthorne Street 

 San Francisco, CA 94105-3901 

 

March 17, 2008

Transmittal of EPA Rule Review Comments

 

 

 To: Susan McLaughlin, Yolo-Solano Air Quality Management District 

 

 smclaughlin@ysaqmd.org 

 

 

 

 Mike Guzzetta, California Air Resources Board 

 

 mguzzett@arb.ca.gov 

 

 

 
 

 

 

 

 From: Andrew Steckel, Rulemaking Office Chief 

 

 steckel.andrew@epa.gov 

 

 

 

 

 

 

 

 Re: Rule 2.31, Surface Preparation and Clean-up, dated February

29, 2008 

 

 

We are providing comments based on our preliminary review of the draft

rule identified above. Unless otherwise indicated, paragraph numbers

refer to the draft rule referenced above. Please direct any questions

about our comments to me at (415) 947-4115 or to Sona Chilingaryan at

(415) 972-3368.

1. We commend and support the District for lowering solvent limits in

several categories to 50 g/L effective 7/1/2009 and 25 g/L effective

1/1/2011.

2. The definition for VOC composite partial pressure is struck-out in

Section 234. However, some current limits in the Section 301 VOC table

still include composite partial pressure limits. Please retain this

definition in the new version of the rule.

3. Section 403 includes requirements for an Operation and Maintenance

(O&M) Plan. We recommend that the District insert language to require

sources not only to submit, but also to maintain, up-to-date O & M

Plans. Moreover, Section 403 states that the "O & M Plan shall be

implemented upon approval of the APCO." We recommend that the District

replace this language with something like "Any person using an approved

emission control device must fully comply with all O & M Plans submitted

for approval, even if such O & M Plans have not yet been approved,

unless notified in writing by the APCO."

4. Under "Medical Devices and Pharmaceuticals," the VOC content limit

table in Section 301 includes a category for "General Work Surfaces." We

recommend that the rule define "general work surfaces." The definition

from South Coast's Rule 1171 can be used.

5. We recommend that the following changes be made to the VOC content

table in Section 301:

 To clarify that a general VOC limit of 50 g/L becomes effective on
 7/1/2009 and a VOC limit of 25 g/L becomes effective on 1/1/2011,

 please change the word "Industry" to something like "All Categories

 Not Listed Below."

 Under the "Cleaning of Application Equipment," please change "Inks"

 to "Printing Operations."

 From conversations with District staff, we understand that the

 current and interim limits for Specialty Flexographic and Gravure

 (Publication) Printing are 100 g/L. Please insert this in the table.

 To be consistent with other sections of the table, please change the

 word "Other" under "Inks" in the "Cleaning of Application Equipment"

 section of the rule to "General."

6. We recommend the following changes be made to the footnotes to the

VOC content table in Section 301:

 The VOC content table has a 200 g/L current limit for product

 cleaning at polyester resin operations and a 200 g/L current limit

 for cleaning of application equipment at polyester resin operations.

 As an alternative to these limits, Footnotes 1 and 3 allow solvents

 with a higher VOC content if a solvent reclamation system is used.

 To ensure the enforceability of these provisions, we recommend that 

 the District spell out these requirements in greater detail in the 

body of the rule, not just in footnotes. Alternatively, the District 

could remove the footnotes. From conversations with District staff, 

we understand that the District has no polyester resin operations 

that use solvent reclamation systems.

 The VOC content table has a 950 g/L current limit for the cleaning 

of application equipment in coating and adhesives operations. 

Footnote 2 limits the solvent content to 200 g/L if an enclosed 

system is not in use. To clarify rule requirements, we recommend that

the District create two categories in the VOC content table for the

cleaning of application equipment in coating and adhesive operations:

one category for enclosed systems with a 950 g/L limit and another

category for systems that are not enclosed with a 200 g/L limit.
1.

STATE OF CALIFORNIA

ENVIRONMENTAL PROTECTION AGENCY

AIR RESOURCES BOARD

P. O. Box 2815

Sacramento, California 95812

April 3, 2008

Transmittal

of

ARB Staff Rule Review Comments

To: Ms. Susan McLaughlin 

Air Quality Engineer

Yolo Solano Air Quality Management District

Telephone Number: (530) 757-3667

e-mail: Smclaughlin@ysaqmd.gov

From: Alex Krichevsky, (916) 324-6222

e-mail: akrichev@arb.ca.gov

The following draft rules, which were considered at a public workshop held by your District

staff on March 13, 2008, were received by us on March 4, 2008, for our review:

Rule 1.1 General Provisions and Definitions

Rule 2.25 Metal Parts and Products Coating Operations

Rule 2.26 Motor Vehicle and Mobile Equipment Coating Operations

Rule 2.29 Graphic Arts Printing Operations

Rule 2.30 Polyester Resin Operations

Rule 2.31 Surface Preparations and Cleanup 

Rule 2.33 Adhesive Operations

Rule 2.35 Pharmaceutical Manufacturing Operations

Rule 2.39 Wood Products Coating Operations

We have reviewed the rules and have the comments on the following pages

On April1, 2008, Ms. Stephanie Lee of our Strategy Evaluation Section, 

Measures Assessment Branch, Stationary Source Division, discussed the comments with you. You

stated that the intent of the rules revision was to address solvent cleaning only. ARB understands

that YSAQMD will reopen some of these rules at a later date to address exemptions, coating limits,

and stripper limit requirements.

We received the rules after the ARB/CAPCOA protocol date. When we receive draft rules at least

30 days before a workshop, our staff is afforded sufficient time to conduct a thorough,

comprehensive review and you will likely receive our comments well before the workshop.
If you have any questions about our comments, please contact Mr. James Nyarady, Manager of the

Strategy Evaluation Section, at (916) 322-8273.

Rule review comments are on the following pages
Date: April 3, 2008

Air Resources Board Staff Comments on

Yolo Solano Air Quality Management District

Draft Rules 1.1, 2.25, 2.26, 2.29, 2.30, 2.31, 2.33, 2.35, and 2.39

Rule 1.1 General Provisions and Definitions

We have no comments on this rule.

Rule 2.30 Polyester Resins Operations

We have no comments on this rule.

Rule 2.33 Adhesive Operations

We have no comments on this rule.

Rule 2.25 Metal Parts and Products Coating Operations

9. Section 112: The provisions of Section 301 do not apply to the use of up to 50 gallons per

year of non-compliant coatings, as approved by the APCO. San Diego County Air Pollution

Control District (SDCAPCD) Rule 67.3 Section (b) and San Luis Obispo County Air

Pollution Control District (SLOAPCD) Rule 411 Section (c)(2)(a) limit this exemption to 20

gallons per year. We recommend changing this exemption to read as follows: The provisions

of Section 301 shall not apply to the use of up to twenty gallons per year of non-compliant

coatings, as approved in writing by the APCO.

2. Section 301: The VOC content limit for “Baked Extreme Performance” is 420 g/l. Antelope

Valley Air Pollution Control District (AVAPCD) Rule 1107 Section (C)(2), Kern County Air

Pollution Control District (KCAPCD) Rule 410-4 Section (IV)(A), Mojave Desert Air Quality

Management District (MAQMD) Rule 1115 Section (2)(a)(i), SLOAPCD Rule 411 Section (D)(1),

and Ventura County Air Pollution Control District (VCAPCD) Rule 74-12 Section (B)(1) limit the

VOC content to 360 g/l. We recommend that the District include this lower limit in the rule. 

3. Section 301: The VOC content limit for “Baked Pretreatment Wash Primer” is 420 g/l. 

VCAPCD Rule 74-12 Section (B)(1) limits the VOC content to 275 g/l. We recommend that the

District include this lower limit in the rule. The VOC content limit for “Air Dried Pretreatment

Wash Primer” is 420 g/l. VCAPCD Rule 74-12 Section (B)(1) limits the VOC content to 340 g/l. 

We recommend that the District include this lower limit in the rule.

4. Section 603: This section references ASTM Test Method D 4457-85. This test method has

been replaced by ASTM Test Method D 4457-02(2008). We recommend changing this reference to

reflect the most current version of the ASTM Test Method.

5. Section 605: This section references ASTM Test Method D 1613-85. This test method has

been replaced by ASTM Test Method D 1613-06. We recommend changing this reference to reflect

the most current version of the ASTM Test Method.
Rule 2.26 Motor Vehicle and Mobile Equipment Coating Operations

6. Section 612: This section references ASTM Test Method D 1613-85. This test method has

been replaced by ASTM Test Method D 1613-06. We recommend changing this reference to reflect

the most current version of the ASTM Test Method.

Rule 2.29 Graphic Arts Printing Operations

7. Section 110.2: This section exempts any graphic arts printing operation which emits less

than 400 pounds of VOC per calendar month, including emissions from solvent cleaning. Ventura

County Air Pollution Control District (VCAPCD) Rule 74.19 contains a current exemption limit of

200 pounds per rolling 12-month period. We recommend that the District lower the exemption level

to 200 pounds per rolling 12-month period. By lowering the exemption level, more sources will be

subject to the rule.

8. Section 302.2: This section has a VOC content limit of 100 g/l for fountain solution.

VCAPCD Rule 74-19 Section (b)(2), South Coast Air Quality Management District (SCAQMD)

Rule 1130 Section (C)(2), and Sacramento Metropolitan Air Quality Management District

(SMAQMD) Rule 450 Section (301.2) have VOC limits of 80 g/l for fountain solution and 100 g/l

for refrigerated fountain solution. We recommend the district incorporate these lower limits.

9. Section 304: This provision states that an emission control device may be used in lieu of the

applicable provisions of Section 300. This could be confusing to operators as there are emission

control system requirements listed in 301.2. We recommend changing the provision to read as

follows:

In lieu of complying with the applicable provisions of Sections 302 and 303, an

operator may use a VOC emission control system that controls emissions from

the source operation provided the following conditions are met:

10. Section 604: This section references ASTM Test Method D 4457-85. This test method has

been replaced by ASTM Test Method D 4457-02(2008). We recommend changing this reference to

reflect the most current version of the ASTM Test Method.

Rule 2.31 Surface Preparations and Cleanup

11. Section 301: The VOC content for Ultraviolet Inks is a technology forcing limit. The South

Coast Air Quality Management District (SCAQMD) recently extended the effective date of this limit

from January 1, 2008, to January 1, 2009. The Yolo-Solano Air Quality Management District’s limit

for Ultraviolet Inks is effective January 1, 2011. ARB recommends that the District revisit this limit

when the SCAQMD’s limit takes effect. 

Rule 2.39 Wood Products Coating Operations

12. Section 111: Sources using less than 55 gallons per year are exempt from the requirements of

this rule. Bay Area Air Quality Management District (BAAQMD) Rule 2-32 Section (111), El

Dorado County Air Quality Management District (EDAQMD) Rule 237 Section (B), San Joaquin

Valley Unified Air Pollution Control District (SJVUAPCD) Rule 4606 Section (4.1.2), and Santa
Barbara County Air Pollution Control District (SBAPCD) Rule 351 Section (B)(5) limit this

exemption to 20 gallons per year. We recommend lowering the exemption from 55 gallons per year

to 20 gallons per year. 

13. Section 300: The VOC limit for “High-Solid Stain” is 350 g/l. EDAQMD Rule 237 Section

(237.3)(A)(1), SJVUAPCD Rule 5606 Section (5.1), SBAPCD Rule 351 Section (D)(1), and

Ventura County Air Pollution Control District (VAPCD) 

Rule 74-30 (B)(1) all have a limit of 240 g/l for High-Solid Stain. We recommend that the

District include this lower limit in the rule. The VOC limit for Sealer is 275 g/l. VAPCD Rule 74-

30 Section (B)(1) has a limit of 240 g/l for this category. We suggest that the District include this

lower limit in the rule. 

14. Section 303: The VOC limit for strippers is 350 g/l. San Diego County Air Pollution Control

District (SDAPCD) Rule 67-11 Section (d)(5)(i) has a limit of 200 g/l for strippers. We recommend

that the district include this lower limit in the rule.
From: <Chilingaryan.Sona@epamail.epa.gov>

To: "Susan McLaughlin" <SMcLaughlin@ysaqmd.org>, "Nancy Fletcher"

<NFletcher@ysaqmd.org>

Date: 4/9/2008 4:10:27 PM

Subject: Fw: EPA Comments on Yolo-Solano Solvent Requirements

Hi Nancy and Susan,

These are the final version of our comments that you should feel free to

reference.

Best,

S.

----- Forwarded by Sona Chilingaryan/R9/USEPA/US on 04/09/2008 04:08 PM

-----

 

 Andrew 

 Steckel/R9/USEPA 

 /US To 

 smclaughlin@ysaqmd.org, 

 04/09/2008 04:07 mguzzett@arb.ca.gov 

 PM cc 

 Sona Chilingaryan/R9/USEPA/US@EPA 

 Subject 

 EPA Comments on Yolo-Solano 

 Solvent Requirements 

 

 

 (Embedded image moved United States Environmental Protection Agency 

 to file: pic29942.jpg) Region IX 

 75 Hawthorne Street 

 San Francisco, CA 94105-3901 

 

April 09, 2008

Transmittal of EPA Rule Review Comments

 

 To: Susan McLaughlin, Yolo-Solano Air Quality Management District 

 smclaughlin@ysaqmd.org 

 Mike Guzzetta, California Air Resources Board 

 mguzzett@arb.ca.gov 
 

 From: Andrew Steckel, Rulemaking Office Chief 

 steckel.andrew@epa.gov 

 Re: The Following Draft Rules Dated February 29, 2008: 2.24, 2.25, 2.26, 

 2.29, 2.30, 2.31, 2.33, 2.35, and 2.39 

We are providing comments based on our preliminary review of the draft

rules identified above. We commend and support the District's efforts to

lower solvent limits and obtain additional emission reductions. We thank

District staff for meeting with us several times over the past few weeks

to discuss the rule revisions and our comments. We understand that the

District plans to re-open Rule 2.26, Motor Vehicle and Mobile Equipment

Coating Operations, Rule 2.29, Graphic Arts Printing Operations, and

Rule 2.33, Adhesive Operations, in the coming year. We further

understand that the District wishes to focus on the solvent provisions

in these rules in this current project and have only reviewed the

portions of these rules that pertain to solvents and surface preparation

and clean-up. We will more fully review Rules 2.26, 2.29, and 2.33 as

they are re-opened. Unless otherwise indicated, paragraph numbers below

refer to the draft rules referenced above. Please direct any questions

about our comments to me at (415) 947-4115 or to Sona Chilingaryan at

(415) 972-3368.

Rule 2.24, Solvent Cleaning Operations (Degreasing)

The district is proposing to repeal Rule 2.24. Rule 2.24 has been

approved into the SIP. In order to avoid problematic SIP relaxation, we

recommend that the District add the following provisions from Rule 2.24

to Rule 2.31:

Section d.2: "An apparatus or cover which prevents the solvent from

evaporating when not processing work in the degreaser."

Section d.2.a: "For cold solvent cleaning, if the initial boiling point

of the solvent as defined by ASTM D-1078-78 is less than 248oF (120oC)

or if the solvent is heated, or if the solvent is agitated, then the

cover must be designed so that it can be opened and closed easily with

one hand."

Section d.4: "A permanent conspicuous label, which lists the appropriate

operating requirementsY"

Section d.5.a: "For cold solvent cleaning, if the initial boiling point

of the solvent as defined by ASTM D-1078-78 is less than 248oF (120oC)

or if the solvent is heated above 50oC, then one of the following

control devices shall be used: a. A freeboard such that the freeboard

ratio is greater than or equal to 0.75..."

Section d.5.c: "For cold cleaning degreasing, if the solvent initial

boiling point as defined by ASTM D-1078-78 is less than 248oF (120oC)
then the drainage facility must be internal so that the parts are

enclosed under the cover while draining. The drainage facility may be

external for applications where an internal type cannot fit the cleaning

system."

Section d.5.d.1 through Section d.5.d.4:"...d. Remote reservoir cold

cleaners shall be equipped with the following devices: 1. A tank or

sink-like work area which is sloped sufficiently to preclude pooling of

solvent; and 2. A single drain hole, less than 100 square centimeters

(15.5 square inches) in area, for the solvent to flow from the sink into

the enclosed reservoir; and 3. A freeboard height of at least six inches

(14 cm); and 4. A cover for the drain when no work is being processed in

the degreaser."

Section e.1, and e.5 through e.7: "...e. Any person who employs solvent

metal cleaning (degreasing) must conform, unless otherwise exempted by

this rule to the following operating requirements: 1. Operate and

maintain the degreasing equipment and emission control equipment in

proper working order...5. Drain cleaned parts for at least 15 seconds

after cleaning or until dripping ceases. (Cold solvent cleaning only) 6.

If using a solvent flow, use only a continuous, fluid stream (not a

fine, atomized, or shower type spray) at a pressure which does not cause

liquid solvent to splash outside of the solvent container. 7. Perform

solvent agitation, where necessary, through pump recirculation,

ultrasonics, or by means of a mixer. Do not use air agitation of the

solvent bath."

Rule 2.25, Metal Parts and Products Coating Operations

Per Section 112, sources that apply 50 gallons or less of coatings per

year are exempt from the coating limits in Section 301. As ARB notes in

their April 3, 2008 comments, there are several other districts with

regulations with comparable exemption for sources that apply 20 gallons

or less of coatings per year. We support ARB's recommendation to change

Section 112 to exempt sources that use up to twenty gallons of coatings

a year.

ARB also notes in their comments that several districts have lower

limits for "Baked Extreme Performance" coating, "Baked Pretreatment

Wash Primer," and "Air Dried Pretreatment Wash Primer." We support ARB's

recommendation to lower the limit for "Baked Extreme Performance"

coating to 360 g/l, to lower the limit for "Baked Pretreatment Wash

Primer" to 275 g/l, and to lower the limit for "Air Dried Pretreatment

Wash Primer" to 340 g/l.

Section 113.1 exempts the application of mold-seal coatings from the

requirements in Section 302. Please define mold-seal coatings. See

Section (b)(36) of South Coast Rule 1107 for potential draft language.

The footnote for APretreatment Wash Primers@ in Section 301, Table 1

seems to indicate that a coating can fall under this category regardless

of solids content. However, Definition 222 specifies that a pretreatment

wash primer is a coating that contains no more than 12 percent solids by

weight. To enhance rule clarity, please include all the coatings that

are considered APretreatment Wash Primers@ for the purposes of Table 1

in the definition for this category.

Section 302 requires that coatings be applied with properly operated
equipment and with one of six application methods specified in Sections

302.1 through 302.6. However, the only application method that is

defined in the rule is HVLP spray equipment in Section 302.1. Please add

definitions for electrostatic application, flow coat, dip coat, roll

coat, and hand coat or hand application methods. These definitions can

be taken from the District=s Rule 2.39, Wood Products Coating

Operations.

Section 302 also allows sources to use "other high transfer efficiency

application equipment which has been approved, in writing, by the APCO."

In order to remove director's discretion and to improve the

enforceability of this provision, we recommend that the District change

Section 302 to require that sources use either one of the application

methods in Sections 302.1 through 302.6 or a method that has been

demonstrated to the APCO to be capable of achieving a transfer

efficiency equivalent or better than HVLP spray equipment.

Rule 2.30, Polyester Resin Operations

Please describe the requirements for monomer content in Section 301.1

more clearly. See Section 5.1.1.1 in San Joaquin Rule 4684 for draft

language.

Section 402 allows sources to use gel coats and polyester resin

materials that do not meet the limits and requirements of this rule if

emissions are controlled to an equivalent level. Please clarify how

sources would calculate the amount of emissions that would need to be

controlled in order to meet the requirements of this section.

Rule 2.31, Surface Preparation and Cleanup

See comments on Rule 2.24 above.

Rule 2.35, Pharmaceutical Manufacturing Operations

EPA=s 1978 CTG for the Manufacture of Synthesized Pharmaceutical

Products recommends several controls. Please clarify whether the

provisions of Rule 2.35 are equivalent to the controls listed in the

following sections on page 1-5 and 1-6 of the CTG: 1(c), 2(a), 2(b), 3,

and 4.

Rule 2.39, Wood Coatings

The District is proposing to remove the definitions for capture and

control efficiency from Rule 2.39. We recommend that the District retain

these definitions and insert them, as applicable, in the other rules in

this rulemaking project as well. To ensure that the requirements in the

rule related to overall capture and control efficiency are enforceable,

it is important to specify the appropriate way of calculating capture

efficiency and control efficiency.

Section 111 exempts sources using less than 55 gallons of wood product

coatings and strippers per year. As ARB notes in their comments, several

Districts limit similar exemptions to 20 gallons per year. We support

ARB=s recommendation to lower this exemption from 55 gallons per year to

20 gallons per year.

ARB=s comments also note that other Districts have lower limits for
AHigh-Solid Stain@ and ASealer.@ We concur with ARB=s recommendation to

lower the limit for AHigh-Solid Stain@ and "Sealer" in Table 1 to 240

g/l.

Section 303.1 requires that strippers contain less than 350 g/l of VOC

per liter of material. ARB=s comments note that SDAPCD Rule 67-11 has a

200 g/l limit for strippers. We concur with ARB=s recommendation to

include this lower limit for strippers.

A footnote for conversion varnish in Table 1 indicates that even when

used as a self sealing system, conversion varnish coatings are not

subject to the lower sealer limit in Table 1. To enhance rule clarity,

please include the contents of this footnote in the definition of

conversion varnish in Section 209.

A footnote for sealers in Table 1 allows sources to apply sealers with a

higher VOC content than the table limit if the topcoat used on the same

wood product has a certain VOC content. In order to enhance the

enforceability of this provision, please include it in a section of the

rule.
Printing Industries of California

5800 South Eastern Avenue, Suite 400 

Los Angeles. CA 90040

Telephone: (323) 728-9500

Fax Number: (323) 724-2327

March 19, 2008

Ms. Nancy Fletcher

Assistant Air Quality Engineer

Yolo/Solano Air Quality Management District

1947 Galileo Court, Suite 103

Davis, CA 95618

Dear Ms. Fletcher: 

This statement is respectfully submitted to the Yolo/Solano Air Quality Management District ("District") by the

Printing Industries of California in response to proposed amended Rule 2.31 ("Surface Preparation and

Cleanup").

Printing Industries of California (PIC) is the government affairs arm of the three printing industry trade

associations in the state. The combined membership of the three affiliates is approximately 2,800 companies,

employing over 80,000 workers and generating over $10 billion in shipments. 

PIC has been involved with the South Coast Air Quality Management District's Technology Assessment for

printing in Rule 1171 from beginning to end. At each step, we have supported SCAQMD efforts, through its

consultants, to identify and develop low-VOC technologies for lithographic, screen and UV printing operations. 

There was much disagreement about the conclusions drawn from the Technology Assessment. The first issue

was the type of companies involved in the assessment; the second was the claim that the companies

converted to the low-VOC solvent. On the following page, I have listed those companies and the purported

outcome of testing the low-VOC solvents. 

Here is the truth of the assessment. The L.A. Times, San Bernardino Sun and J.S. Paluch Co. are newspaper

printers. All three use soy ink-almost always black-and print on highly porous substrates. The first two

converted to Mirachem, a water-based cleaner some years ago. The last company has much shorter runs; the

soy-based solvent left residue (and thus drips and slinging of solvent). The company never converted to the

test solvent. 

 

W hile identified as a sheetfed press, Nelson Nameplate has two manual presses that print on metal and

plastic, one sheet at a time. This isn't a typical (or often even thought of) as a sheetfed press. 

PIP, SCAQMD Print Shop, City of Santa Monica, and Presslink have small Diddi or GTO Presses. Two-PIP

and Presslink-never completed testing. Santa Monica uses soy ink-generally black-and doesn't have to clean

often. SCAQMD has purchases a new press since the assessment, and we don't know what cleanup solvent

is being used.

Moreover, I could go on-and-on about the assessment. Here, however, is the proper conclusion: As you read

through the study, you find that only a handful of companies were identified as having converted or are

converting to low VOC solvents. However, converting and testing are two different things. The Printery is a

case in point. The study said that it converted to Soy Gold 2500. However, after using the solvent for nearly

three months, the company experienced all the usual problems with vegetable based material-drips, slinging
of solvent, blinding of plates. The Printery had to bring in higher VOC solvents to remove the soy solvent from

the rollers, and the company has struggled to find alternative low-VOC solvent to clean its presses.

W hile the above discussion may seem unrelated to Rule 2.29, it is extremely relevant since, at the workshop,

it was mentioned by staff deferred to the South Coast Air Quality Management District's Technology

Assessment as the basis of the proposed amendments. 

Comments on Proposed Rule 2.29

Sections 1.10.1 and 1.10.2

The first section (1.10.1) allows for an exemption excluding cleanup solvent while the second exemption

(1.10.2) allows for an exemption including cleanup solvent. 

W hile the statements are clear, they probably will lead to confusion of the regulated community. W e have a

daily exemption in one place, excluding cleanup solvent, and monthly exemption right below, including cleanup

solvent. In the latter case, does the exemption also include cleanup solvent? It should since the District is

using it in the calculation for monthly emissions. 

Section 1.10.3 refers to the test method used in calculating VOC from non-heatset inks. However, there is no

allotment for the retention factor of either heatset or nonheatset inks. W e understand that these are allowed

administratively, but since the District is allowing exemptions for ink and fountain solution emissions, it only

makes sense, as most other districts, to include the ink retention factors in Rule 2.29. 

W e ask that this be done at this time, since the rule is open for amendment, and the factors are critical in

determining VOC emissions from inks. 

Table 1 is somewhat difficult to read. We suggest that the table be replicated along the lines of the South

Coast. Moreover, we suggest that the limit of the VOC content for lithographic and letterpress be stepped

down: from the current 900 grams/liter to 650 grams/liter on July 1, 2009, and then to 100 grams/liter on

January 1, 2011. 

The rationale is simple: it is easier to learn to work with these alternative solvent by stepping-down the VOC

limit than in one step. 

Section 402.4 

Delete the density requirement for cleanup solvent. It is not used in recordkeeping calculations, even though it

may appear on data or product information sheets. 

Section 504 

Reduce the proposed five year period to a three year period for keeping records.

There is nothing in United State Environmental Protection Agency guidelines that require that require five

years of records for small sources. The five years applies to Title V sources. 

Thank you in advance for the consideration you may give my requests. If you have any questions, please feel

free to call me. 

Sincerely, 

G. M. Bonetto, Ph.D.

VP Government Affairs 
March 20, 2008

Ms. Susan McLaughlin, Supervising Air Quality Engineer

Yolo-Solano Air Quality Management District

1947 Galileo Court, Suite 103

Davis, CA 95617

RE: Comments on Draft Proposed Amendments to Rule 2-31

Dear Ms McLaughlin,

With this letter, Simonton Windows in Vacaville is submitting comments on the proposed

amendments to Rule 2-31, Surface Preparation & Cleanup. Simonton has concerns with the

proposed VOC content limits as they apply to Simonton’s facility and the schedule for

implementation of the proposed limits.

Simonton uses solvents subject to the standards in the General Category of Table 1 of draft amended

rule. For this category, the draft rule includes a significant drop in the VOC content limit from 200

g/l to 25 g/l. The primary solvent currently in use at Simonton has a VOC content of 80 g/l.

Considerable research and testing of similar products was performed to locate this solvent with only

the current solvent passing all required performance marks. Some of these are, in no particular order:

1. Must leave no residue

2. Low toxicity

3. Low VOC

4. Safe to handle, store, use, etc.

During research and testing of alternative products, many low VOC products were examined; however, most failed in one

or more of the performance marks. The main failings were:

5. Remaining residues (some even after follow-up cleaning)

6. Flammability of acetone-containing solvents

Soy-based solvents are one class of low-VOC solvents. Simonton’s experience with soy-based solvents is that they leave

residues that cannot be easily cleaned, even with a follow-up cleaning with another solvent.

Acetone-based solvents are another class of low-VOC solvents. Acetone is highly flammable and volatile, which causes

worker exposure issues and worker safety issues.

Therefore, Simonton proposes the first reduction level in General Category of Table 1 be 100 g/l, and the second level be

50 g/l.

At this time, Simonton is not aware of an alternative solvent that meets even the 50 g/l standard while meeting

Simonton’s minimum performance standards for no residue, low toxicity, low flammability, etc. However, Simonton

believes such solvents with a VOC content of 50 g/l may become available in the future. Therefore, in conjunction with

the proposed General Category VOC content limits of 100 g/l and 50 g/l, Simonton proposes that the 50 g/l level be

required no earlier than December 31, 2009. This is expected to allow adequate time for manufacturers to develop

suitable products and for Simonton to conduct performance testing.

Thank you for your consideration. Simonton Windows appreciates the opportunity to provide comments on the draft

amendments to Rule 2-31, Surface Preparation & Cleanup. Simonton is available to discuss these comments and

concerns in more detail. Please contact Nathan Ladd at (707) 446-7600 at your convenience.
Sincerely,

Nathan Ladd

EHS Manager

Simonton Windows
Dear Nancy,

It was my pleasure meeting you last week. After reviewing the District's proposed amendments to Rule 2.31,

Surface Preparation and Cleanup we noticed: 

! The VOC content limit for cleaning of application equipment in the "Medical Devices and Pharmaceuticals"

category is incorrectly listed as 800 g/L (ref: Table 1, page 15 of February 29, 2008 redline version of Rule

2.31). The correct limit for this category should be 810 g/L based on the District's February 29, 2008 staff

report (ref: page 31). Please correct this error.

If you have any questions, feel free to contact me at (707) 453-3508.

Warmest Thanks, 

Toykea Jones

Engineer

Global Pharmaceutical Supply Group

A Johnson & Johnson Company

Office: 707-453-3508

Mobile: 757-639-1138



Date: April 30, 2008

To: Susan McLaughlin, YSAQMD, smclaughlin@ysaqmd.org

Nancy Fletcher, YSAQMD, NFletcher@ysaqmd.org

Subject: Comments on Proposed Amendments to Rule 2.31 (Surface Preparation and Cleanup)

Dear Ms. McLaughlin and Ms. Fletcher:

Alza is writing to comment on the District’s proposed amendments to Rule 2.31, Surface Preparation

and Cleanup (proposed draft: (http://www.ysaqmd.org/documents/Rule2.31_Proposed.pdf).

We respectfully request that the District consider the following revisions to Rule 2.31:

1. Add an exemption from the VOC limits for pharmaceutical cleaning solvents that is similar to

Sacramento Metropolitan Air Quality Management District’s Rule 460 (Adhesives and Sealants) and

South Coast Air Quality Management District Rule 1171 (Solvent Cleaning Operations), Section (g)(5)(A):

1. SMAQMD Rule 460, Section 110.11, exempts, from the VOC requirements in Rule 460

Section 303, ethyl acetate used to clean adhesive application equipment when the equipment is used

in the manufacturing of transdermal drug delivery products, and fewer than 3 gallons per day of ethyl

acetate, averaged over a calendar month, are used. (http://www.airquality.org/rules/rule460.pdf,

amended 11/30/2000) 

1. SCAQMD Rule 1171, Section (g)(5)(A), exempts, from VOC requirements, “Cleaning of coating and adhesive

application processes utilized to manufacture transdermal drug delivery product using less than 3 gallons per day of ethyl

acetate averaged over a 30 calendar day period.” (http://www.aqmd.gov/rules/reg/reg11/r1171.pdf, amended

2/1/2008). 

We would also like to clarify the interpretation that the 3-gallon daily average limits apply to net as

opposed to gross ethyl acetate emissions.

The proposed exemptions above are necessary to accommodate the unique cleaning

requirements of transdermal patch manufacturing at our Vacaville facility. 

2. Revise the effective date to 1/1/2011 from 7/1/2009 for the proposed 800 g/L VOC limit in

Table 1 for solvent used to clean “Medical Devices and Pharmaceuticals” (all categories). Due to

Federal Drug Administration (FDA) requirements, Alza will be required to perform thorough testing

and validation prior to altering the cleaning solvent composition and/or cleaning process used for the

manufacture of pharmaceutical products. This testing and validation must be performed to ensure

that cleaning changes do not affect product quality or patient safety. A 7/1/2009 effective date is

unrealistic given the anticipated validation requirements. Alza believes that the net air quality

impact from delaying the effective date will be negligible as the estimated emissions from the use of

ethyl acetate are anticipated to be less than several hundred pounds between 7/1/2009 and 1/1/2011. 

Although there is no guarantee that an acceptable substitute cleaning solvent can be identified in this

time period, additional time to investigate alternatives will help ensure continued compliance.

Thank you for the opportunity to provide comments. 
Feel free to contact me at 707-453-3305 if you have questions.

Erol Odabasi
1.

STATE OF CALIFORNIA

ENVIRONMENTAL PROTECTION AGENCY

AIR RESOURCES BOARD

P. O. Box 2815

Sacramento, California 95812

May 2, 2008

Transmittal

of

ARB Staff Rule Review Comments

To: Ms. Susan McLaughlin 

Air Quality Engineer

Yolo Solano Air Quality Management District

Telephone Number: (530) 757-3667

e-mail: Smclaughlin@ysaqmd.gov

From: Alex Krichevsky, (916) 324-6222

e-mail: akrichev@arb.ca.gov

The following proposed rules, which are scheduled for a public hearing to be held by your

District Board on May 14, 2008, were received by us on April 14, 2008, for our review:

Rule 1.1 General Provisions and Definitions

Rule 2.25 Metal Parts and Products Coating Operations

Rule 2.26 Motor Vehicle and Mobile Equipment Coating Operations

Rule 2.29 Graphic Arts Printing Operations

Rule 2.30 Polyester Resin Operations

Rule 2.31 Surface Preparations and Cleanup 

Rule 2.33 Adhesive Operations

Rule 2.35 Pharmaceutical Manufacturing Operations

Rule 2.39 Wood Products Coating Operations

We have reviewed the rules and have the comments on the following pages

On April 18, 2008, Ms. Stephanie Lee of our Strategy Evaluation Section, 

Measures Assessment Branch, Stationary Source Division, discussed the comments with you. You

stated that the intent of the rules revision was to address solvent cleaning only. ARB understands

that YSAQMD will reopen some of these rules at a later date to address exemptions, coating limits,

and stripper limit requirements.

If you have any questions about our Comments 1, 2, 3, 4, 5, 6, 10, 11, and 12, please contact Mr.

James Nyarady, Manager of the Strategy Evaluation Section, 

at (916) 322-8273. 
If you have any questions about our Comments 7, 8, 9, and 13, please contact Mr. Carl Brown,

Manager of the Stationary Source Enforcement Section, Stationary Source Enforcement Branch,

Enforcement Division, at (916) 327-3529.

Rule review comments are on the following 4 pages
Date: May 2, 2008

Air Resources Board Staff Comments on

Yolo Solano Air Quality Management District

Proposed Rules 1.1, 2.25, 2.26, 2.29, 2.30, 2.31, 2.33, 2.35, and 2.39

Rule 1.1 General Provisions and Definitions

We have no comments on this rule.

Rule 2.26 Motor Vehicle and Mobile Equipment Coating Operations

We have no comments on this rule.

Rule 2.30 Polyester Resins Operations

We have no comments on this rule.

Rule 2.33 Adhesive Operations

We have no comments on this rule.

Rule 2.25 Metal Parts and Products Coating Operations

1. Section 112: The provisions of Section 301 do not apply to the use of up to 50 gallons per year

of non-compliant coatings, as approved by the APCO. San Diego County Air Pollution Control

District (SDCAPCD) Rule 67.3 Section (b) and San Luis Obispo County Air Pollution Control

District (SLOAPCD) Rule 411 Section (c)(2)(a) limit this exemption to 20 gallons per year. We

recommend changing this exemption to read as follows: The provisions of Section 301 shall not

apply to the use of up to twenty gallons per year of non-compliant coatings, as approved in writing

by the APCO.

2. Section 301: The VOC content limit for “Baked Extreme Performance” is 420 g/l. Antelope

Valley Air Pollution Control District (AVAPCD) Rule 1107 Section (C)(2), Kern County Air

Pollution Control District (KCAPCD) Rule 410-4 Section (IV)(A), Mojave Desert Air Quality

Management District (MAQMD) Rule 1115 Section (2)(a)(i), SLOAPCD Rule 411 Section (D)(1),

and Ventura County Air Pollution Control District (VCAPCD) Rule 74-12 Section (B)(1) limit the

VOC content to 360 g/l. We recommend that the District include this lower limit in the rule. 

3. Section 301: The VOC content limit for “Baked Pretreatment Wash Primer” is 420 g/l. 

VCAPCD Rule 74-12 Section (B)(1) limits the VOC content to 275 g/l. We recommend that the

District include this lower limit in the rule. The VOC content limit for “Air Dried Pretreatment

Wash Primer” is 420 g/l. VCAPCD Rule 74-12 Section (B)(1) limits the VOC content to 340 g/l. 

We recommend that the District include this lower limit in the rule.

Rule 2.29 Graphic Arts Printing Operations
4. Section 110.2: This section exempts any graphic arts printing operation which emits less

than 400 pounds of VOC per calendar month, including emissions from solvent cleaning. Ventura

County Air Pollution Control District (VCAPCD) Rule 74.19 contains a current exemption limit of

200 pounds per rolling 12-month period. We recommend that the District lower the exemption level

to 200 pounds per rolling 12-month period. By lowering the exemption level, more sources will be

subject to the rule.

5. Section 302.2: This section has a VOC content limit of 100 g/l for fountain solution.

VCAPCD Rule 74-19 Section (b)(2), South Coast Air Quality Management District (SCAQMD)

Rule 1130 Section (C)(2), and Sacramento Metropolitan Air Quality Management District

(SMAQMD) Rule 450 Section (301.2) have VOC limits of 80 g/l for fountain solution and 100 g/l

for refrigerated fountain solution. We recommend the district incorporate these lower limits.

Rule 2.31 Surface Preparations and Cleanup

6. Section 301: The VOC content for Ultraviolet Inks is a technology forcing limit. The South

Coast Air Quality Management District (SCAQMD) recently extended the effective date of this limit

from January 1, 2008, to January 1, 2009. The Yolo-Solano Air Quality Management District’s limit

for Ultraviolet Inks is effective January 1, 2011. ARB recommends that the District revisit this limit

when the SCAQMD’s limit takes effect. 

The VOC content limits that take effect on 7/1/2009 and 1/1/2011 allow the operator to

comply with either a mass based (g/l) VOC content limit or a partial pressure VOC limit. The partial

pressure VOC limits would allow operators to use solvents that exceed the mass based (g/l) VOC

limit. The SCAQMD confirmed that they are enforcing the 100 g/l VOC limit for lithographic and

letterpress cleanup that became effective 1/1/2008. Additionally, the Printing Industries of

California Association stated that the 100 g/l VOC limit for lithographic and letterpress cleanup was

feasible for SCAQMD’s 1/1/2008 effective date in a letter to the SCAQMD on August 28, 2007. 

Therefore, ARB recommends removing the partial pressure limits.

Rule 2.35 Pharmaceutical Manufacturing Operations

7. Section 206: This section uses words such as prescription-drug, analgesic, decongestant,

antihistamine, cough suppressant, vitamin, mineral and herb in defining Pharmaceutical Product.

These words were not defined prior to their use in this section.

8. Section 301.1: The terms/phrases such as distillation column, reactor, crystallizer, and

centrifuge were used without first defining them in the rule or providing any reference in the rule

where these words were defined. To improve the enforceability of this rule, we suggest that the

district include the definition of those words in the rule. We have provided some definitions for the

District’s consideration:

Vitamin: An organic compound required as a nutrient in tiny amounts by an organism. A

compound is called a vitamin when it cannot be synthesized in sufficient quantities by an organism,

and must be obtained from the diet. 
Drug: A drug is any chemical substance that, when absorbed into the body of a living

organism, alters normal bodily function, or a chemical substance used in the treatment, cure,

prevention, or diagnosis of disease or used to otherwise enhance physical or mental well-being.

Prescription Drug: A prescription drug is a licensed medicine that is regulated by

legislation to require a prescription by a board certified medical professional before it can be

obtained. The term prescription drug is used to distinguish between licensed drugs and overthe–counter drugs, which can be obtained without a prescription. 

Analgesic: An analgesic is the group of drugs commonly known as pain relievers

Decongestant: A decongestant is a broad class of medications used to relieve nasal

congestion.

Chemical Reactor: A chemical reactor is a device for containing and controlling a chemical

reaction.

Distillation Column: Distillation Column also known as Fractionating Column is a

laboratory piece of equipment used to separate vaporized mixtures of liquid compounds whose

vaporization temperatures or volatilities are very close.

Crystallizer: Crystallization is a process in which a chemical compound, dissolved in a

given solvent, precipitates under certain conditions to allow successive separation between the

phases.

Centrifuge: A centrifuge is a piece of equipment, generally driven by a motor, which puts a

compound object in a rotation around a fixed point with the aim of using densities to separate the

contents

The definition of the remaining words could be found in chemical and pharmaceutical

handbooks.

9. Section 505: This section requires all records to be kept for two years and be made available

to the APCO upon request. While this requirement may be appropriate for small and nontitle V

sources, it does not satisfy the record keeping requirements of Title V...Because some of the sources

may be subject to Title V requirement, we suggest that this subsection be modified to incorporate

Title V record keeping and record retention requirements. To improve the stringency of this rule, we

suggest that this section be modified to read as follows: All records required by this rule shall be

maintained onsite for at least five years and made available to the APCO or his/her representative

upon request.

Rule 2.39 Wood Products Coating Operations

10. Section 111: Sources using less than 55 gallons per year are exempt from the requirements of

this rule. Bay Area Air Quality Management District (BAAQMD) Rule 2-32 Section (111), El

Dorado County Air Quality Management District (EDAQMD) Rule 237 Section (B), San Joaquin

Valley Unified Air Pollution Control District (SJVUAPCD) Rule 4606 Section (4.1.2), and Santa

Barbara County Air Pollution Control District (SBAPCD) Rule 351 Section (B)(5) limit this

exemption to 20 gallons per year. We recommend lowering the exemption from 55 gallons per year

to 20 gallons per year. 

11. Section 300: The VOC limit for “High-Solid Stain” is 350 g/l. EDAQMD Rule 237 Section

(237.3)(A)(1), SJVUAPCD Rule 5606 Section (5.1), SBAPCD Rule 351 Section (D)(1), and

Ventura County Air Pollution Control District (VAPCD) 

Rule 74-30 (B)(1) all have a limit of 240 g/l for High-Solid Stain. We recommend that the

District include this lower limit in the rule. 
The VOC limit for “Sealer” is 275 g/l. VAPCD Rule 74-30 Section (B)(1) has a limit of 240

g/l for this category. We suggest that the District include this lower limit in the rule. 

12. Section 303: The VOC limit for strippers is 350 g/l. San Diego County Air Pollution Control

District (SDAPCD) Rule 67-11 Section (d)(5)(i) has a limit of 200 g/l for strippers. We recommend

that the district include this lower limit in the rule.

13. Section 503: This section requires all records to be kept for two years and be made available

to the APCO upon request. While this requirement may be appropriate for small and nontitle V

sources, it does not satisfy the record keeping requirements of Title V. Because some of the sources

may be subject to Title V requirement, we suggest that this subsection be modified to incorporate

Title V record keeping and record retention requirement. To improve the stringency of this rule, we

suggest that this section be modified to read as follows: All records required by this rule shall be

maintained onsite for at least five years and made available to the APCO or his/her representative

upon request.