South Coast Air Quality Management District
South Coast Air Quality Management District
BOARD MEETING DATE: August 17, 2001 AGENDA NO. 32
Amend Rule 1122 – Solvent Degreasers
SYNOPSIS:
The proposed amendments are designed to further reduce VOC and NESHAP halogenated solvent emissions from degreasing operations. For VOC cold cleaners and vapor degreasers, the amendments will lower the material VOC limit to 25 g/l. For NESHAP degreasers, changes are proposed to the equipment requirements. In addition, rule language is being modified to delete obsolete requirements, add new definitions, and clarify exemptions.
COMMITTEE:
Stationary Source, June 22, 2001 and July 27, 2001, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
- Certifying the CEQA Final Environmental Assessment (EA) for the proposed amendments.
- Amending Rule 1122 - Solvent Degreasers.
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Rule 1122 - Solvent Degreasers was adopted on March 2, 1979 to control and reduce VOC emissions from degreasing operations. Degreasers using NESHAP halogenated solvents are currently excluded from the rule, but are subject to the federal NESHAP requirements for halogenated solvent cleaners. The rule establishes both equipment and operating requirements for any facility that operates using either VOCs or NESHAP degreasing equipment that removes contaminants as part of their production process.
The 1997 amendment to Rule 1122 called for the use of aqueous cleaning materials, low-VOC solvents, or airless/air-tight equipment as primary control methods in reducing VOC emissions from solvent degreasing operations. Many facilities have converted to aqueous cleaning or other alternative cleaning methods, as evidenced by the decline in population of vapor degreasers during the last several years. In spite of advancements in aqueous cleaning technology, there are still about 251 facilities that continue to use vapor degreasers with high-VOC solvents or NESHAP halogenated solvents.
Since the adoption of amended Rule 1171 in 1996 and Rule 1122 in 1997, more than 150 Clean Air Solvents have been certified and over 70% of which has a VOC content of 25 g/l or less. The proposed amendments are designed to further lower the VOC content in the solvent materials to reflect the current technology and to minimize the toxic emissions from solvent degreasing operations.
Proposal
The proposed amendments to Rule 1122 will further control emissions of VOC and reduce toxic air contaminants from solvent degreasing operations. Proposed Amended Rule 1122 will lower the material VOC limit for cold cleaning operations from 50 grams per liter to 25 grams per liter, as used, by January 1, 2003. For VOC vapor degreasing operations, the proposed amendment will require the use of solvents with a VOC content of no more than 25 grams per liter, as used, effective January 1, 2006. The use of airless/air-tight cleaning systems remains as an additional compliance option. A limited small user exemption is also provided for aerospace related vapor degreasing operations.
Staff proposes to amend the applicability section of the rule to include halogenated solvents that are subject to the federal NESHAP rule for halogenated solvent cleaners. This allows the AQMD to regulate the NESHAP solvents used in degreasing operations. Proposed Amended Rule 1122 will require the use of an airless/air-tight cleaning system when performing degreasing with NESHAP halogenated solvents. This requirement will come into effect on January 1, 2003.
The proposed amendments also allow the use of an alternative cleaning system that achieves equivalent emission reductions to that of the airless/air-tight system, provided such alternative system is approved by AQMD, CARB, and the USEPA.
In addition, the other proposed amendments will:
Staff estimates that the proposed amendments will achieve a reduction in toxic air contaminants of 0.81 tons per day in 2003, and a cumulative VOC emission reduction of 3.17 tons per day in 2006, with 3.1 tons per day by 2003.
Public Process
During the development of PAR 1122, staff worked with a Technical Advisory Panel. Other persons affected by the proposal attended these meetings and also provided input to the development of this proposal. This Technical Panel was comprised of representatives from affected facilities, equipment manufacturers, chemical manufacturers and distributors, environmentalists and consultants. The Los Angeles County Sanitation District, the Department of Toxic Substances Control and the California Air Resources Board also had representation on this panel. Ten Technical Advisory Panel meetings were held. The first Public Workshop was held on June 29, 2000. A second Public Workshop was held on May 30, 2001 to consider an expanded staff proposal, developed in response to comments received at the first workshop. A Public Consultation Meeting was held on July 11, 2001.
Key Issues
A number of issues were raised and addressed during the rule development process. These include:
The first three issues have been addressed through provisions in the proposed amended rule. Staff believes that for most processes subject to this rule, compliant technology is currently available and cost effective. For VOC open-top vapor degreasers, the proposed amendments represent a balanced approach that gives businesses additional time to evaluate options for compliance and to amortize previous investments in equipment. Staff is also committed to conduct a technology assessment in 2005 to determine progress toward implementation of alternative cleaning systems. NESHAP solvents are regulated as part of this proposal due to the toxic risk posed by these facilities and the availability of standard, relatively inexpensive cleaning technology. Finally, staff has provided for alternative compliance methods and has recommended exemptions for certain processes where compliance options are not presently known to be available.
The following is a discussion of the remaining key issues.
Compliance Schedule - Open Top Vapor Degreasers
Members of the working group are not in agreement over the compliance deadlines in the proposal. Environmentalists have expressed concern that since less polluting materials and equipment are currently available, staff should consider moving up the proposed deadlines. They believe that lowering the VOC limits earlier can prevent increases in VOC emissions from NESHAP users in search of alternatives. If it is not technically feasible, environmentalists have asked that the burden of proof be placed on the businesses to show that alternatives have been adequately researched and sufficiently tested, such as a report describing the testing, cleanliness standards and the results and conclusions. On the other hand, certain companies have made investments to upgrade their open-top vapor degreasers in order to comply with the 1999 rule requirements. They state that there is not enough -time to recoup their earlier investments. Staff has taken several measures to address these issues. First of all, the deadline for cold cleaners and NESHAP degreasers is set in 2003, where the majority of the emission reductions will take place. Second, staff is confident that the current industry trend will direct the conversion toward aqueous systems where feasible. Staff analysis indicates that most of current NESHAP applications can be converted to aqueous systems. The conversion activity will be monitored closely through documentation of BACT evaluations for vapor degreasers and survey of equipment suppliers. To allow for amortization of investments, final VOC reductions for open top vapor degreasers are proposed for 2006 to give businesses sufficient time to find alternatives.
Technical Feasibility-High Precision Applications
Other concerns have been raised concerning technical feasibility, particularly for high precision applications. First, concern has been raised regarding the merit of reducing emissions from open-top vapor degreasing with an inventory of 0.07 tons per day of VOC. Since the basin still exceeds the health based air quality standards, all reductions that are technically feasible and cost-effective need to be achieved.
Second, some businesses are concerned about the safe and effective use of water-based products on some space-based components, particularly printed circuit boards. Staff has observed circuit board cleaning in simple dishwasher units and in more automated systems as well. Visits to two local aqueous cleaning system manufacturers have confirmed that aqueous cleaning is technically feasible and cost-effective in these applications. However, staff does recognize that some applications may present technical or logistical obstacles to compliance. Consequently, staff has proposed a compliance date of January 2006 to allow additional time to explore viable compliance options and is committed to complete a technology assessment in 2005 to examine any outstanding compliance issues. In addition, a small user exemption is provided for aerospace related vapor degreasing operations (e.g., space vehicles or satellite components) to ensure critical cleaning requirements are met. Staff will continue to provide technical assistance to companies in searching for compliance options.
California Environmental Quality Act (CEQA) Analysis
Pursuant to the California Environmental Quality Act (CEQA) and the AQMD’s Certified Regulatory Program (Rule 110), staff has prepared an Environmental Assessment (EA) for Proposed Amended Rule 1122 - Solvent Degreasers. The Draft EA, which was made available for a 30-day review period, concluded that the proposed amendments to Rule 1122 would not have any significant adverse effect on the environment. No comments were received on the Draft EA. The Final EA is included as part of the attached package for the public hearing on the proposed amendments.
Socioeconomic Assessment
The proposed amendments would affect 334 permitted open-top vapor degreasers (OTVDs) at 245 facilities that currently use NESHAPs, VOC, and low-VOC (50 g/l) solvents. The majority of the affected OTVDs belong to the manufacturing industries. The amendments will also affect about 19,000 non-permitted cold cleaners using solvents with VOC limits of 50 grams per liter. The cold cleaners cover almost all of the industries in the local economy.
To comply with the amendments, the affected facilities are expected to convert to airless/air-tight systems, aqueous cleaners, or switch to ultra-low-VOC (25 grams/liter) solvents. The total annual compliance costs for implementing the 2003 and 2006 requirements are estimated to be $224,995 and $130,749, respectively. The average annual cost of compliance over a ten-year period is estimated at $316,520. The cost-effectiveness of the proposed amendments is $92 per ton of VOC reduced.
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 1122 are consistent with the guidelines set in the 1997 AQMP, as amended in 1999 (CTS-08) to meet state and federal requirements. The AQMD Air Toxics Control Plan contains stationary control strategy AT-STA-04 - Reduction of Toxic Air Contaminant Emissions from Solvent Cleaning/Degreasing Operations, which calls for reduction of emissions of perchloroethylene, a toxic air contaminant and possible human carcinogen.
Implementation Plan
Staff will continue the on-going implementation efforts on Rule 1122 with outreach to the sources affected by these amendments, including equipment/solvent suppliers. Furthermore, staff will continue to conduct public outreach and coordination regarding water quality issues associated with the rule.
Resource Impact
Current AQMD resources are sufficient to implement the proposed Rule 1122 amendments with no budget impact.
Summary of Proposal
Key Issues and Responses
Rule Development Process
Key Contacts List
Resolution
Proposed Rule Language
Staff Report
Final Environmental Assessment
Socioeconomic Assessment
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