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PROPOSAL:

Backstop and Annual Audit Procedures for Rule 1122 - Solvent Degreasers

SYNOPSIS:

The Governing Board amended Rule 1122 – Solvent Degreasers in July 1997 to require cleaning materials used in cold cleaners to meet a VOC limit of 50 g/l from January 1999. In response to public testimony, the Governing Board also directed staff to develop annual audit procedures and backstop provisions to ensure compliance with the future effective VOC limits of Rule 1122, and report back to the Board. This report fulfills the Governing Board directive.

COMMITTEE:

Not Applicable.

RECOMMENDED ACTION:

Receive & File this report.

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

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).

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 – Solvent Degreasers.

Rule 1122 was first adopted in March 1979 and revised six times between 1979 and 1997. The latest amendments to the rule reflected 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, the VOC content of cleaning materials in cold cleaners is limited 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 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.

At the July 1997 public hearing, environmental organizations expressed concern regarding the implementation of the future effective VOC limits of Rule 1122 for small, unpermitted cold cleaners, which produce most of the emissions from this source category. As a result, the Governing Board directed staff to develop backstop and audit procedures for future implementation purposes and report back to the Governing Board within 12 months.

Backstop and Audit Procedures

The compliance plan will include a periodic audit program to determine the state of compliance for batch-loaded cold cleaners with respect to the 50 grams VOC per liter of material requirement of Rule 1122 – Solvent Degreasers, effective January 1999. The audit is intended to be conducted in the second half of 1998, and annually thereafter. As part of the implementation program staff will also provide public outreach and technical assistance to businesses. The degree of compliance found through audits will determine the necessity for backstop provisions.

Area sources subject to the new cold cleaning requirements will be identified through Standard Industrial Classification (SIC) code information. Once facility information is obtained, owners or operators will be mailed informative brochures from AQMD, EPA, and water quality agencies, including a list of cleaning options that are readily available for use and a suppliers list. After mail notification, approximately 1,000 companies will be notified of AQMD’s intent to conduct a field audit. About 8,000 companies will be surveyed by telephone and asked a set of standard questions relating to rule compliance. Inspectors and small business assistance staff will be used to complete the audit over a four-month period. At the end of the audit, results will be analyzed to determine the status of compliance.

If the audit shows a low compliance rate with Rule 1122 – Solvent Degreasers, additional steps to increase compliance may need to be taken including reopening the rule to include the prohibition of sales of non-compliant products and a registration process for suppliers of cleaning materials. If the audit shows the use of compliant materials to be problematic on certain operations, limited exemptions may be recommended. Compliance may also be enhanced by potentially revising Rule 219 – Equipment Not Requiring a Written Permit Pursuant to Regulation II, to include permitting requirements. Other backstop measures may also be developed in consultation with the public and affected industries, if excessive non-compliance is found through periodic audits and inspections.

Resource Impacts

Existing AQMD resources are sufficient to continue to implement the proposed plan with no impact on the budget.

Attachments

Summary of Proposed Compliance Plan

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