South Coast Air Quality Management District

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 updated resolution:

1. Certifying the CEQA Final Environmental Assessment (EA) for the proposed amendments.
   
   

2. Amending Rule 1122 – Solvent Degreasers (including Alternative B).

Barry R. Wallerstein, D.Env.
Executive Officer

Background

The Governing Board continued the August public hearing on PAR 1122 to the September 21, 2001 meeting. The Board has closed the public testimony on this rule except for the testimony on the definition of "airless/air-tight cleaning system" found in paragraph (b)(5) of PAR 1122. The proposed definition, as contained in the original August 17, 2001 Hearing package made available to the public prior to the meeting, is included in this Board package as Alternative A.

However, prior to the August 2001 Board meeting, the AQMD staff received requests from several equipment manufacturers to add the word "vacuum" to the proposed definition of airless/air-tight cleaning system to clarify the original intent of the rule. The manufacturers argued that the term "airless/air-tight" is widely accepted by industry as a vacuum cleaning system. Since this addition is consistent with staff’s intent, we agreed that it is necessary to clarify the original meaning without making material changes to the definition, and presented the change as a staff proposed amendment to the proposed definition, included here as Alternative B, during the August 2001 Board meeting. The AQMD staff views an airless/air-tight system as a cleaning system that operates under vacuum with no air/solvent or air/vapor interface, which is consistent with the BACT guidelines for this type of equipment.

A representative of a non-vacuum, sealed cleaning system manufacturer opposed the AQMD staff's proposed change stating that it would adversely impact the company he represents, and that adding the word "vacuum" into the "airless/air-tight" definition would preclude equipment that is equally less polluting. It was further argued that the change to the definition was being made very late in the rulemaking process.

The AQMD staff emphasized that for other cleaning systems or types of equipment that do not meet the definition but achieve equivalent emission reductions as that of an airless/air-tight system, PAR 1122 provides the use of an approved alternative cleaning system as a compliance option. These systems must undergo certification testing to demonstrate equivalent emission reductions to those of vacuum-operated airless/air-tight systems, and be approved by U.S. EPA, CARB, and AQMD to be considered equivalent. Understanding the concern regarding the potential length of this approval process, the AQMD staff is committed to work closely with manufacturers to seek expeditious approval.

Supervisor Mikels proposed during the Board meeting that an asterisk be used by the word "vacuum" that would not preclude any system or technology that would meet the same emission reductions. Alternative C presented in this package would implement this approach. However, staff is concerned that adding an asterisk to a definition to provide equivalency may unintentionally cloud the definition and adversely affect rule enforceability. Moreover, CARB and U.S. EPA approval would still be required.

To date, test data and equipment certification indicate that airless/air-tight systems under vacuum achieve the emission reduction objectives of PAR 1122. One such system is designated by the U.S. EPA as Lowest Achievable Emission Rate (LAER). Another system has been issued a Certified Equipment Permit under the AQMD's Certified Equipment Program for vapor degreasers. Based on the technical analysis staff has performed, it is appropriate to clarify the airless/air-tight system definition to those that operate under a vacuum because they achieve intended reductions and such addition avoids potential misinterpretation.

Staff Recommendation

In light of the concern about how the definition will be interpreted, and the desire to encourage the development of alternative cleaning systems, staff is recommending that the Board approve the proposed change to the definition of the airless/air-tight cleaning system, included here as Alternative B, as well as clarify language in the Board Resolution (see page 4 of Resolution). Such language notes "BE IT FURTHER RESOLVED that the AQMD Governing Board directs the AQMD staff to work closely with manufacturers of non-vacuum air-tight systems or any other cleaning systems who wish to demonstrate equivalent emission reductions pursuant to subdivision (f) of this rule, in order to expedite review and approval by CARB and the U.S. EPA for such systems. Staff shall also propose amendments to Rule 1122, if equivalency is demonstrated, and no expeditious approval is forthcoming. The equivalency demonstration shall take into consideration quantity of load and load cycle." The intent of this proposed resolution language is to ensure expeditious regulatory approval for alternative cleaning systems that achieve equivalent reductions. Staff believes that these recommendations will best address this issue raised at the August Board meeting.

Additional Information

Staff provided a videotape of the August hearing to Board Members who were not present at the hearing for their review, and to facilitate their ability to participate in the continued hearing in this matter.

Attachments

Alternative A
Alternative B
Alternative C
Updated Resolution
Updated Rule Language
Board Package dated August 17, 2001

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