BOARD MEETING DATE: September 13, 1996 AGENDA NO. 33
Proposal:
Amend Rule 1171 - Solvent Cleaning Operations
Synopsis:
Proposed Amended Rule 1171 will establish VOC and solvent va-por pressure limits that will reduce VOC emissions 20.5 tons per day by year 2010 through greater use of aqueous cleaning tech-nologies as well as acetone blend formulations. The proposed VOC limits will be effective January 1999, to allow sufficient time for facilities to convert to newer cleaning processes.
Committee:
Not applicable.
Recommended Action:
1. Certify the CEQA Final Subsequent Environmental Assessment (EA) for the proposed amendments in accordance with the attached Resolution.2. Adopt the Statement of Findings, Statement of Overriding Considerations, and Mitigation Monitoring Plan in accordance with the attached Resolution. 1.
3. Amend Rule 1171 - Solvent Cleaning Operations in accordance with the attached Resolution.
James M. Lents, Ph.D.
Executive Officer
Background
Rule 1171 - Solvent Cleaning Operations, represents the single largest emission reduction rule which would have been subsumed by VOC RECLAIM, an emissions trading program. The VOC RECLAIM program, which had been under development since 1991, included about 1,200 companies that used paints, coatings, solvents, and adhesives. As proposed, this emissions trading program would have reduced VOC emissions by 20.8 tons per day by 2005. In January 1996, the AQMD Governing Board decided to stop work on VOC RECLAIM and directed staff to expeditiously proceed with the development of other VOC emission reduction rules to meet our AQMP commitments. Rule 1171 is the first and the largest emission reduction rule proposal in this category. Both VOC RECLAIM and Proposed Amended Rule 1171 would have produced comparable VOC emission reductions by 2010. However, they differ in applicability and focus of control strategy. While VOC RECLAIM was designed for about 1,200 larger companies that used a variety of VOC products, this rule proposal is focused on solvent cleaning operations at any facility, irrespective of its size or permitting status. Therefore, Rule 1171, as proposed, will reduce VOC emissions from over 30,000 companies within the jurisdiction of the AQMD.
Rule 1171 - Solvent Cleaning Operations was originally adopted on August 2, 1991, and further amended on May 8, 1995. The primary purpose of the rule is to reduce the emissions of Volatile Organic Compounds (VOCs) from solvent cleaning activities during the production, repair, maintenance, or servicing of products, tools, machinery, and general work areas. Such cleaning may be performed at auto repair facilities, garages and service stations, printing shops, metal fabrication facilities, electronics manufacturing facilities and other businesses. The rule does not apply to certain 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, institutional, or janitorial cleaning.
Prior to the adoption of Rule 1171 in 1991, each Regulation XI - Source Specific Standards rule contained provisions for solvent cleaning. The development of Rule 1171 unified such requirements, but introduced different solvent cleaning categories including general cleaning, repair and maintenance cleaning, cleaning of coating and adhesive application equipment, and cleaning of ink application equipment. Each solvent cleaning category was subject to prescribed VOC and/or vapor pressure limits. In addition, the devices and methods used for solvent cleaning operations were required to meet specific requirements.
Rule 1171 was amended in May 1995 to alleviate SIP deficiencies cited by the federal EPA and to addressrectify industry concerns. The amendments did not achieve additional VOC emission reductions. This action was largely administrative in nature and included addresseding specialty cleaning operations (e.g., medical device manufacturing) and the refinedment and clarifiedcation of rule language (e.g., test methods and definitions).
Proposal
Based on extensive AQMD study and supporting CARB data, the emission inventory for cleaning operations subject to Rule 1171 is projected at 35.9 tons per day of VOCs from permitted and unpermitted sources in both the industrial and commercial sectors. The proposed amendments to Rule 1171 will achieve VOC emissions reduction of 20.5 tons per day by 2010 or a 46% reduction in the future Rule 1171 VOC emission inven-tory.
The proposed emission abatements reflect staff�s technical assessment regarding low-VOC solvent cleaning materials available today. Aqueous cleaners containing no VOCs or minimal VOCs (< 50 grams per liter) are used successfully in repair and maintenance cleaning in various equipment including parts washers and remote reservoir cleaners. Aqueous cleaning materials cost less than their high-VOC organic solvent counterparts currently in use, although some aqueous cleaners may require heating, resulting in higher energy costs. The extended bath life of such cleaners also minimizes hazardous waste and its associated costs. Overall, the conversion from petroleum-based solvent cleaners to aqueous cleaners is driven by the resulting cost savings. Some key issues in the wide-scale employment of water-based cleaning systems include water resources, hazardous waste, and water quality.
Acetone, which has been delisted as a VOC, is used successfully in certain handwipe cleaning operations. Conversion to acetone costs no more than petroleum solvents cur-rently in use. Health and safety considerations are the key issues in employing acetone as a cleaning solvent, which is more acceptable in blends and diluted solutions than in its pure form.
A Rule 1171 Advisory Panel was formed at the outset of this rulemaking effort back in January 1996 with experts from the solvent cleaning industry including manufacturers, vendors and consultants. AQMD staff met with the panel on several occasions to gather and discuss relevant information and technologies involving solvent cleaning operations prior to drafting a rule proposal. Three public meetings, noticed in newspapers pursuant to applicable law, were held to solicit public input relative to the staff rule proposal. Staff has met several times with individual companies and persons who requested pri-vate meetings with the AQMD to discuss Proposed Amended Rule 1171. Staff also vis-ited various facilities to observe first-hand a variety of cleaning processes including op-erations at facilities that have successfully converted to low- and zero-VOC cleaning materials.
Summary of Proposed Amendments:
The staff proposal will:
Reactivity
Some providers of petroleum-based cleaning solvents and cleaning systems have opposed the staff-recommended lower VOC grams/liter limit based on the feasibility of aqueous or low VOC (<50 grams/liter) cleaning solvents and systems. The AQMD has been asked to consider the reactivity of a hydrocarbon-based or petroleum-based solvent in lieu of a total volume reduction of VOCs as currently proposed. The use of reactivity as a regulatory tool has been debated at the local, state, and national level for over twenty years. Reactivity of a solvent refers to its ozone forming potential. Reactivity issues were thoroughly assessed during the VOC RECLAIM rule development process over a period of several years. The results were inconclusive. Although it is inappropriate to delay VOC emission reductions based on this concern, it may be appropriate to study the issue further if new information not analyzed in previous AQMD study efforts is brought forward.
Market Forces
The transition from petroleum-based cleaning solvents to aqueous or low-VOC (<50 grams/liter) cleaning solvents and systemsers may impact the competitiveness among vendors and suppliers of cleaning materials. SuppliersVendors of aqueous cleaning materials are already penetrating the repair and maintenance cleaning marketplace. , albeit slowly, andT this proposal, ifafter adoptedion, is expected to accelerate the transition from higher VOC emitting petroleum-based cleaning solvents to low-VOC or aqueous cleaning materials. National suppliersVendors of petroleum-based solvents may, therefore, lose some of their market share to smaller, local suppliers of aqueous cleaning systems. On the other hand, existing suppliers of petroleum-based cleaning systems may retain their market share by continuing to provide full service to their clients that includinges, supply of equipment and compliant cleaning materials, and pickup and disposal of the resulting waste. The final outcome, in this respect, is dependent on market forces in the future.
AQMP and Legal Mandates
The California Health and Safety Code requires the AQMD to adopt an AQMP 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 Rule 1171 emissions inventory is estimated at 35.9 tons per day of VOCs. This figure is based on: (1) 1993 emissions data reported by the affected permitted industry; (2) CARB emission inventory data for permitted and unpermitted sources in this emission category; (3) VOC RECLAIM emission inventory work; (4) DistrictAQMD AEIS data; and (5) a soon- to -be -released independent emission inventory study of solvent cleaning operations in California by an ARB contractor (PECHAN). Based on current activity levels, no increase in the Rule 1171 inventory is assumed until 1999. With an AQMP growth rate of 2% per year from 1999 to 2010, the unregulated emissions inventory would grow to 44.6 tons per day in 2010. The rule’s impact on the current emission inventory and this growth will produce an estimated emission reduction of 20.5 tons per day. The estimated change in emissionspicture is depicted graphically below.
CEQA
Pursuant to California Environmental Quality Act (CEQA) and the AQMD’s Certified Regulatory Program (Rule 110), staff has prepared a FinalDraft Subsequent Draft Subsequent Environmental Assessment (EA) for Proposed Amended Rule 1171. The Final Subsequent EA has been released for a 45-day public review period. All comments received on the Draft Subsequent EA have been responded to in the Final Subsequent EA.
The environmental topics analyzed in the Draft Subsequent EA were air quality, water resources, hazards, public services (fire departments), and energy resources. The analysis concluded that the proposed amendments may result in significant adverse air quality and water resource impacts.
The potential air quality impacts would be due to increased NOx emissions associated with the electrical requirements to heat water-based cleaning systems. While it is unlikely that electric generating facilities would need to generate additional electricity to account for the potential incremental increased demand, the significant determination is based on a worst-case scenario.
As is currently the case with organic solvent-based cleaning operations, water-based cleaning activities may lead to adverse impacts on water resources if not handled properly. This potential impact may be exacerbated by the proposed rule amendments, since some vendors of water-based cleaning solvents advertiseing that their products areas being sewer safe. Accordingly, the proposed amendments may result in significant adverse water quality impacts even though: 1) proper disposal would preclude this effect, and 2) some organic solvent-based cleaning operators may currently be illegally disposing of spent cleaning materials. These potential water impacts are governed by state and federal laws that are implemented by local sanitation districts. They are required to periodically monitor the water quality to iensure that the water is within discharge limits.
As a result of the determination of significance and a finding that sanitation districts may be able to mitigate some potential impacts, a Statement of Findings and a Statement of Overriding Considerations and a Mitigation Monitoring Plan has been will be prepared for the Governing Board’s review prior to the public hearing for the proposed amendments.
Socioeconomic Assessment
The socioeconomic assessment found that adoption of the proposed amendments to Rule 1171 would provide a cost savings to the affected industry of approximately estimated at $4.5 million annually. While compliance with the 50-gram-per-liter VOC content limit would increase equipment and operation costs, the savings in materials and disposal costs would more than offset these. The $4.5 million annual savings would be achieved in the categories of Surface Preparation and General Cleaning, and Remote Reservoir Cleaning. Other cleaning categories are expected to comply with the amendments by switching to acetone, aqueous cleaners, or lower vapor pressure solvents, with no increase in costs.
Implementation Plan
Source training classes will be scheduled to assist facilities in will be trained to implementing the proposed revisions to Rule 1171. Notices will be sent to thevarious sources affected by these amendments. Staff will conduct special outreach efforts to inform the general public about this solvent cleaning regulation.
Resource Impact
Current AQMD resources are sufficient to implement the proposed Rule 1171 amendmentsrule amendmentswith noegative budget impact.
Attachments
Summary of Key Issues
Rule Development Process
Key Contacts List
Resolution
Rule Language
Staff Report
Socioeconomic Assessment
Final Subsequent Environmental Assessment