BOARD MEETING DATE: September 10, 1999 AGENDA NO. 3
PROPOSAL:
Set Public Hearing October 8, 1999 to Amend Rule 1171 – Solvent Cleaning Operations
SYNOPSIS:
The proposed amendments will implement the AQMP control measure for solvent cleaning operations by decreasing VOC limits for four major cleaning categories: product cleaning and surface preparation; repair and maintenance cleaning; cleaning of coating and adhesive application equipment; and cleaning of ink application equipment. The proposed amendments will also establish and define five new solvent cleaning categories and VOC limits for blanket wash, on-press components, pharmaceutical products, removable press components and roller wash. Lastly, the proposed amendments will include certain exemptions to address industry concerns.
COMMITTEE:
Stationary Source, August 20, 1999, Reviewed
RECOMMENDED ACTION:
Set a Public Hearing October 8, 1999 to Amend Rule 1171 – Solvent Cleaning Operations.
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Rule 1171 – Solvent Cleaning Operations, is a key component of South Coast Air Quality Management District’s ozone reduction strategy. The rule was originally adopted on August 2, 1991, and further amended between 1995-1997. The primary purpose of the rule is to reduce VOC emissions and stratospheric ozone-depleting or global-warming compounds from all solvent cleaning activities. The rule, however, does not apply to solvent cleaning operations that are governed by other AQMD rules including solvent degreasers (Rule 1122) and the cleaning of aircraft components (Rule 1124), nor does it apply to residential or janitorial cleaning.
The 1996 rule amendment established lower VOC limits for specific cleaning categories and encouraged greater use of aqueous cleaning technologies and exempt solvents. On January 1, 1999, Rule 1171 required all solvent cleaning materials used in repair and maintenance operations to contain no more than 50 grams of VOC per liter of cleaning solvent. The solvents meeting this limit are generally water-based or aqueous cleaners that contain little or no VOCs. However, each of these available aqueous solvents has specific applicability and is only efficient if used correctly in proper applications. While this represents a significant reduction in VOC emissions, further reductions in solvent cleaning emissions are called for in the AQMP (CM#97ADV-CLNG) to meet state and federal requirements.
During the last several years, a large number of cleaning materials have been formulated as viable replacements for organic solvents. Low-VOC aqueous materials have been successfully substituted for solvent-based cleaners in many industrial and commercial applications. Furthermore, the growing list of VOC exempt compounds, such as acetone, methyl acetate, etc., provides an added opportunity to reduce VOC emissions.
Proposal
The proposed amendments to Rule 1171 will further implement the AQMP control measure for solvent cleaning operations. Proposed amended Rule 1171 seeks to lower the VOC limits for certain solvent cleaning activities through the use of aqueous or semi-aqueous technologies, exempt compound substitution, or possibly the development of new cleaning materials or technologies.
Staff proposes to lower the material VOC limits for four major cleaning categories: product cleaning and surface preparation; repair and maintenance cleaning; cleaning of coating and adhesive application equipment; and cleaning of ink application equipment. The proposal is structured in a step-down approach with the first reduction taking effect on July 1, 2002. This initial step does not entail drastic reduction in VOC contents. In many cases, existing low-VOC formulations can be readily substituted today.
The second phase of the reduction occurs on July 1, 2005 where the VOC limits are substantially lower than many of the materials used today. However, staff is confident that the six-year lead time is sufficient enough for the broad development of effective and safe compliant materials.
Staff estimates that the proposed VOC limits will achieve VOC emissions reductions of over six tons per day in 2002, and about nine tons per day in 2005. These translate to a 79% cumulative reduction in the 1999 VOC emissions inventory for Rule 1171.
The proposal also includes technology assessments to be performed by the District by the year 2004 to assess the technology and progress of low-VOC formulations to meet the 2005 VOC limits. The District will conduct technology assessment for the following cleaning categories:
After each technology assessment, the Executive Officer shall report to the Governing Board as to the progress in technology development and whether future amendments are necessary.
The other proposed amendments to the rule will:
California Environmental Quality Act (CEQA) Analysis
Pursuant to the California Environmental Quality Act (CEQA) and the AQMD’s Certified Regulatory Program (Rule 110), the AQMD has prepared a Draft Environmental Assessment (EA) for Proposed Amended Rule 1171 - Solvent Cleaning Operations. The analysis concludes that implementation of the proposed project would not result in significant adverse environmental impacts. The Draft EA has been released for a 30-day public review period ending September 20, 1999. Comments on the environmental analysis received during the review period will be responded to in the Final EA. Copies of the Draft EA can be obtained by calling the AQMD’s Public Information Center at (909) 396-3600.
It should be noted that subsequent to the release of the Draft EA, the proposed amendments were slightly modified. The proposed 2004 VOC content limits are now proposed for 2005. This modification has no adverse environmental effects and does not alter the conclusions set forth in the Draft EA.
Socioeconomic Assessment
Both permitted and non-permitted sources are affected by the proposed amendments. The permitted sources belong mostly to the industries of manufacturing, auto repair services, medical, and retail sector. The non-permitted sources include nearly all the industries in the local economy. The total cost impact from lowering the VOC limits of these categories is estimated at $11.5 million annually. It is estimated that approximately 445 jobs will be forgone annually.
AQMP and Legal Mandates
The California Health and Safety Code requires the AQMD to adopt an Air Quality Management Plan to meet state and federal ambient air quality standards in the Basin. In addition, the California Health and Safety Code requires that the AQMD adopt rules and regulations that carry out the objectives of the AQMP. The proposed changes to Rule 1171 are consistent with the guidelines set in the AQMP (CM#97ADV-CLNG) to meet state and federal requirements.
Implementation Plan
Staff will conduct outreach efforts to inform the general public of the changes to the solvent cleaning regulation. Notices will be sent to the sources affected by these amendments. Furthermore, staff will continue to conduct public outreach regarding water quality issues associated with the rule.
Resource Impact
Current AQMD resources are sufficient to implement the proposed Rule 1171 amendments with no budget impact.
Summary of Proposal
Key Issues and Responses
Rule Development Process
Key Contacts List
Proposed Rule Language
Draft Staff Report
Draft Environmental Assessment
Draft Socioeconomic Assessment
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