PROPOSAL:

Report on the AQMD/California Trucking Association Implementation Study Regarding Rule 1171 - Solvent Cleaning Operations

SYNOPSIS:

On September 13, 1996, the Board amended Rule 1171 and also directed staff to conduct an implementation study with the California Trucking Association (CTA) to address their concerns regarding aqueous cleaning systems for the repair and maintenance of heavy-duty trucks. The study has now been concluded and the report indicates that water-based cleaning systems are effective in the repair and maintenance of heavy-duty trucks. Staff will continue to work with CTA member companies by providing information and assistance in selecting the appropriate water-based technology.

COMMITTEE:

Stationary Source, November 21, 1997, Reviewed

RECOMMENDED ACTION:

Direct staff to:

1. Provide public outreach and technical assistance to affected CTA member companies in order to meet the January 1999 compliance deadline of Rule 1171 - Solvent Cleaning Operations;

2. Address any implementation and compliance issues relative to the availability and selection of the appropriate water-based technology for heavy-duty truck repair and maintenance; and

3. Provide a status report to the Board on the implementation of Rule 1171 - Solvent Cleaning Operations for heavy-duty truck repair and maintenance activities, no later than November 1998.

Barry R. Wallerstein, D.Env.
Acting Executive Officer

Background

Rule 1171 - Solvent Cleaning Operations, is a key component of the AQMD’s ozone reduction strategy, as it controls VOC emissions from numerous uses of solvents in industrial, commercial, and general purpose cleaning activities (not including degreasers). The rule was last amended in September 1996 to lower the VOC content limits of solvents in several usage categories, including the repair and maintenance category. Effective January 1999, Rule 1171 requires cleaning materials used in repair and maintenance operations to contain no more than 50 grams of VOC per liter of cleaning solvent. The most common and effective cleaners that meet this criteria are water-based or aqueous cleaners that contain little or no VOCs.

At the September 1996 public hearing, the California Trucking Association (CTA) expressed concern regarding the effectiveness of aqueous cleaners in the repair and maintenance of heavy-duty trucks. The Governing Board, therefore, directed staff to conduct a field study with CTA to test the effectiveness of aqueous cleaning technology and report back to the Board no later than July 1997. In a later action, the Board extended the reporting date to December 1997 to complete ongoing field tests.

The study has now been completed. The results and staff recommendations are presented in this board letter, with additional information contained in the attached staff report.

Implementation Study

The AQMD staff met with the CTA staff on several occasions to plan the field testing, data gathering, and objectives of the study. The staff also met with equipment vendors and solvent suppliers to obtain their cooperation and assistance. It was decided to test a representative number of heavy-duty truck repair stations with different aqueous cleaning systems currently available on the market, in an actual shop environment for 6 to 8 weeks, and analyze the findings from these "real world" situations. The objective was to determine the performance of aqueous cleaning systems in actual heavy-duty truck repair and maintenance.

The CTA selected 24 heavy-duty truck repair shops to participate in the testing, and 12 manufacturers and distributors of aqueous cleaning systems offered cleaning fluids and cleaning equipment at no cost for the study. Test procedures and test protocols were developed and agreed upon prior to initial testing.

Beginning May 1997, the participating site operators removed or disabled their petroleum solvent cleaners and began using the aqueous systems, containing no more than 50 gm VOC per liter of solvent, in their normal course of business.

Three types of data were collected in the study: performance data recorded by the mechanics during actual part cleaning; on-site interviews of mechanics and shop managers conducted by AQMD staff; and a written survey of the facility operator’s experience conducted by the CTA at the end of testing.

Results

A significant amount of data was obtained to properly evaluate the performance of aqueous cleaning systems in actual heavy-duty truck repair and maintenance. It was determined that over 90% of truck parts were properly cleaned with water-based systems. Less than 10% of parts cleaned were found unacceptable by the mechanics for a variety of reasons. The latter types of "hard to clean" parts may require additional "pre-soaking" to loosen contaminants, a different cleaning chemistry, or simply proper heating and agitation of the aqueous solvent. Not all cleaning solvents are expected to function alike, and the study was not intended to rank the cleaning efficacy or recommend specific cleaners available in the marketplace. However, the vast majority of parts cleaned with aqueous solvents were found acceptable by the end users.

Data indicated that aqueous cleaning systems took longer to clean parts as compared with high-VOC petroleum-based cleaners. However, the majority of mechanics did not see this as a problem since it did not impact the total elapsed time for a repair job.

The site interviews and the CTA survey results were in good agreement. They both confirmed that the majority of heavy-duty truck repair shops found the aqueous systems to be acceptable for their needs. Only 2 out of 24 facilities polled responded that they were not satisfied with the aqueous systems tested in this study. Staff believes that other aqueous systems, when used properly, would be found acceptable by these 2 facility operators.

It is interesting to note that 5 of the 24 facilities participating in the study are reported to have purchased or leased aqueous systems for use already, thus meeting the January 1999 rule requirement today. CTA member companies have thus expressed their commitment towards environmentally cleaner products that get the job done. Their willingness and acceptance to work with the AQMD staff on this issue is laudable and noteworthy.

Conclusions and Recommendations

Testing shows that aqueous cleaners are effective in cleaning heavy-duty truck parts in repair and maintenance shops. Proper selection and optimization of the cleaning system may be necessary in a few cases for "hard to clean" parts.

Staff would like to assist CTA member companies in their search for the appropriate aqueous cleaning technology that meets the particular needs of the facility. Such assistance may involve public outreach and informational meetings, meetings with solvent vendors and equipment suppliers, and compliance assistance with local water quality and waste disposal regulations. Staff will continue with actual field studies to resolve any other "hard to clean" issues brought to their attention by the heavy-duty trucking industry. Staff is also committed to working with CTA to resolve any compliance issues that may arise relative to the January 1999 compliance deadline of Rule 1171.

Finally, staff will provide a status report on the implementation of the rule requirements to the Governing Board no later than November 1998, for heavy-duty truck repair and maintenance activities.

Attachments

Staff Report

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