Proposal:

Set Hearing July 11, 1997 to Amend Rule 1122 - Solvent Degreasers

Synopsis:

Proposed Amended Rule 1122 will establish VOC limits of 50 g/l for cleaning materials used in cold cleaners; or alternatively, require the use of airless or air-tight cleaning systems. Work practice and design requirements are also proposed for cold cleaners, vapor degreasers and airless and air-tight cleaning systems. VOC emission reductions of 40.2 tons/day are expected by year 2010, mostly through greater use of aqueous cleaning technologies in batch-loaded cold cleaners, at a cost-effectiveness of $1400 per ton of VOCs reduced.

Committee:

Stationary Source, June 20, 1997, scheduled for review.

Recommended Action:

Set Hearing July 11, 1997 to Amend Rule 1122 - Solvent Degreasers.

James M. Lents, Ph.D.
Executive Officer

Background

Rule 1122 - Solvent Degreasers, requires both equipment and operating standards for solvent degreasing operations at a wide variety of commercial, industrial and major manufacturing businesses. This rule covers one of the largest sources of VOC emissions in the South Coast Air Basin (Basin), and affects industries ranging from small machine shops to the largest aerospace corporations. The 1997 AQMP targets a reduction of 36 tons/day of VOC emissions from this source category by 2010, for the attainment of federal clean air standards. This rule proposal forms a cornerstone of the AQMD’s VOC reduction strategy.

Solvent cleaning and degreasing are carried out at machine shops; metal forming, manufacturing, and finishing shops; electronics and electrical industries; optical, medical, and precision equipment manufacturers, plastic fabricators, and aerospace industries, to name a few. Any facility that operates degreasing equipment to remove dirt, grease, and other contaminants as part of their manufacturing process is subject to Rule 1122. This rule was first adopted in March 1979 and revised five times between 1979 and 1991. The last amendment in April 1991 clarified the text, improved work practice requirements, eliminated certain rule exemptions and expanded the rule to include smaller cold cleaners. However, the existing rule has no VOC emission or concentration limitation and very small degreasers or solvents with very low VOC concentrations are exempted from the rule.

Solvent degreasing is usually carried out in batch-loaded cold cleaners or open-top vapor degreasers, which are baths containing a solvent in the liquid or vapor phase, respectively. When the solvent is used as a liquid, the part to be cleaned is lowered into and raised from the bath, and allowed to drain and dry. When the solvent is used as a vapor, the hot vapors condense on the cold article, transferring the dirt and grease to the solvent which is flushed away. Batch-loaded cold cleaners and open-top vapor degreasers using halogenated solvents have served the needs for degreasing for the vast majority of businesses in the past. Conveyorized degreasers using mechanical systems to move the parts and more sophisticated airless or air-tight systems, costing considerably more, are also prevalent for specific applications.

Degreasing solvents are commonly halogenated solvents that contain chlorine and other chemicals, and may be classified as VOCs or VOC-exempt, depending on their photochemical reactivity. Some of the most common chlorinated solvents, such as 1,1,1-trichloroethane (TCA) and chlorofluorocarbons (CFCs) have been found to destroy ozone molecules in the upper stratosphere which protect life on earth from dangerous ultraviolet radiation. These ozone depleting compounds (ODCs) are being phased out. Other common solvents, including perchloroethylene (perc) and methylene chloride (MCL), are potentially toxic compounds and listed as Hazardous Air Pollutants (HAPS) in the Clean Air Act. Recognizing the danger of HAPs in common degreasing usage, USEPA promulgated the National Emission Standards for HAPs (NESHAP) for halogenated solvents in November 1994. The federal rule regulates emissions of TCA, perc, MCL, carbon tetrachloride, trichloroethylene, and chloroform from degreasers, of which only the last two chemicals are considered VOCs while the remaining four compounds are VOC-exempt. The NESHAP requirements will be fully applicable to all existing degreasers from December 2, 1997.

Besides halogenated chemicals, degreasing solvents include: traditional aliphatic hydrocarbons such as napthas, mineral spirits, and kerosene; aromatic hydrocarbons such as toluene and xylene; and organic solvents such as ethyl alcohol, isopropyl alcohol, methyl ethyl ketone, and acetone. All of the above examples, with the sole exception of acetone, are highly reactive for the formation of lower atmospheric ozone, and are therefore considered VOCs. None of them appear on the list of ODCs.

Proposal

AQMD’s emissions inventory, in conjunction with CARB data, indicate that 42.3 tons/day of VOCs were emitted from degreasing operations in the Basin in 1993. This excludes perc (to be declared VOC-exempt by the AQMD). Batch-loaded cold cleaners were responsible for 39.5 tons/day of VOC emissions, with the rest being attributed to vapor degreasers and conveyorized cold cleaners. The staff proposal is expected to reduce 32.3 tons/day of VOC emissions by 1999, if adopted and implemented as proposed. This is equivalent to a 76% emission reduction from degreasers. Assuming an annual growth rate in emissions of 2% from 1999 to 2010, the 2010 emission reduction is expected to be 40.2 tons/day. The average cost-effectiveness of the proposed controls is expected to be $1,400 per ton of VOC reduced.

The proposed emission abatements largely reflect staff’s technical assessment regarding the acceptance of low-VOC and aqueous cleaners as substitutes for high VOC- solvents in cold cleaners. Therefore, effective January 1999, it is proposed to limit the VOC content of cleaning materials in cold cleaners to 50 g/l, as used. Options are also provided to use high-VOC material in very tightly controlled systems such as air-tight or airless batch cleaning machines. The current practice of controlling VOC emissions from vapor degreasers through condensers, freeboard heights, and freeboard chillers is continued. These requirements are further augmented by a superheated vapor zone (or a secondary freeboard chiller) and an automated parts handling system operated at limited speeds. In view of these stringent controls, high-VOC solvents may continue to be used in vapor degreasers.

Proposed Amended Rule 1122 contains simplified recordkeeping and reporting requirements for demonstration of compliance. Minimum records are required to be kept at monthly intervals by a business operator to ascertain monthly VOC emissions from degreasers. Forms for this purpose are included in this proposal. Cleaning material containing less than 50 g/l of VOCs, as used, are conditionally exempt from all rule requirements.

Provisions for encouraging the use of Clean Air Solvents are incorporated in Proposed Amended Rule 1122, following their successful application in Rule 1171 - Solvent Cleaning Operations. All Clean Air Solvents, as defined in Rule 102 - Definitions, are proposed to be exempted from this rule, as long as they continue to meet the Clean Air Solvent criteria. The existing Rule 1122 exemption for small batch-loaded cold cleaners with open-top areas under one square foot and solvent usage of less than one gallon/day has been modified. The newly proposed exemption is valid until January 1, 2003, and retains the one square foot size criteria but requires a solvent usage of less than five gallons per calendar month for any high-VOC solvent, and for electrical or electronic degreasing applications only. This limited exemption includes both cold cleaners and vapor degreasers. Proposed Amended Rule 1122 also exempts the use of two VOCs, namely trichloroethylene and chloroform in degreasers, since they are controlled as HAPs by the federal NESHAP for halogenated solvent cleaners.

The proposed revisions to Rule 1122 are based on studies conducted by staff during the development of VOC RECLAIM in 1995; the development of amendments to Rule 1171 in 1996; and recommendations from the Rule 1122 Advisory Committee (Committee) which included equipment manufacturers, solvent suppliers, users, and consultant from the solvent degreasing industry. AQMD staff met with the Committee several times, starting October 1996, conducted independent investigation and site visits, and held one public meeting which was noticed in newspapers pursuant to applicable law, to solicit comments and suggestions relative to the staff proposal. Staff would like to thank all members of the Committee for their insights and recommendations that form the technical basis of this regulatory proposal.

Policy Issues

Staff has estimated the number of cold cleaners used within the Basin at about 23,000, with only 100 degreasers being subject to the AQMD’s permitting requirement. The vast majority of such equipment consist of small tanks at unpermitted facilities. VOC emission reductions projected in the staff’s analysis are predicated on the successful conversion to low-VOC, aqueous, or VOC-exempt solvents for general degreasing applications. This transition requires close and careful orchestration between the manufacturers, suppliers, and users, with active support of regulatory agencies and trade associations.

While staff has proposed to simplify the recordkeeping requirements, they are still subject to USEPA’s approval, which is pending. Initial discussion with the USEPA staff has been encouraging and such simplification is expected to meet with federal approval. This proposal encourages conversion to low-and non-VOC products by eliminating recordkeeping burdens for such usage.

AQMP & Legal Mandate

The California Health and Safety Code requires the AQMD to adopt an AQMP demonstrating compliance with all state and federal ambient air quality standards for the Basin. Furthermore, the AQMD is required to adopt rules and regulations that implement the AQMP. Proposed Amended Rule 1122 represents the implementation of Control Measure 97CTS-02N of the 1997 AQMP.

CEQA & Socioeconomic Analysis

Rule 1122 is within the scope of the previously approved 1997 AQMP, whose Final Program Environmental Impact Report (EIR) adequately describes the project for the purposes of CEQA. In addition, the AQMD will also use the Rule 1171 Final Environmental Assessment (EA), as the CEQA document for the proposed project, since Rules 1122 and 1171 are essentially the same in terms of potential environmental impacts. The AQMD has provided a 30-day notification of its intent to use these previously prepared CEQA documents. Copies of the 1997 AQMP Final Program EIR and the Rule 1171 Final EA are available for public review and comment and can be obtained from the AQMD’s Public Information Center at (909) 396-3600.

Implementation Plan

Staff plans to conduct intensive outreach efforts to introduce low-VOC and non-VOC cleaning systems at affected businesses with the help of equipment manufacturers, solvent suppliers, trade and commerce associations, local government agencies, and other interested parties. It is expected that many small business owners may need AQMD’s assistance in finding an acceptable solution for their degreasing needs. Staff has been involved in building such technology bridges as part of the Board mandated public outreach effort for implementation of Rule 1171 since September 1996. A similar effort is envisioned in this area.

The potential water quality impacts that may result from the implementation of Proposed Amended Rule 1122 are similar to those that may be expected from the implementation of Rule 1171, both based on a worst-case scenario. These potential impacts were disclosed in both the Rule 1171 Final EA and the 1997 AQMP EIR. As part of the mitigation plan to be adopted for Rule 1122, staff will conduct a public outreach program, similar to that underway for Rule 1171, to educate and inform the affected public about the proper handling and disposal of waste solvents and spent aqueous baths. This effort will include the local sanitation districts, the regional water quality control boards, and the state toxic control agency, in addition to the AQMD staff. The assistance of trade associations and business groups will be sought to make this project successful.

Resource Impacts

AQMD has sufficient resources to implement the proposed revisions to Rule 1122 without any additional budget impact.

Attachments:

Summary of Proposed Amendments
Rule Development
Key Contact List
Key Issues and Responses
Draft Rule Language
Draft Staff Report