South Coast Air Quality Management District
South Coast Air Quality Management District
BOARD MEETING DATE: December 6, 2002 AGENDA NO. 41
Amend Rule 1122 – Solvent Degreasers
SYNOPSIS:
The proposed amendment will extend the sunset date for the exemption in (k)(1)(D) for degreasers with open-top surface areas less than 1.0 square foot, or with a capacity of less than 2 gallons, and used only for electrical, high precision optics or electronics applications; or aerospace and military applications for cleaning solar cells, laser hardware, space vehicle components, fluid systems, and components used solely in research and development programs, or laboratory tests in quality assurance laboratories. In addition, rule language is being modified to clarify rule intent.
COMMITTEE:
Stationary Source, October 25, 2002, 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
In March 1979, the Board adopted Rule 1122 - Solvent Degreasers primarily to control and reduce VOC emissions from solvent degreasing operations. The rule establishes both equipment and operating requirements for any type of solvent degreasing operations. Industries subject to the provisions of Rule 1122 include any industrial, commercial or institutional facility that operates degreasing equipment that removes contaminants as part of their production process. Recent amendments to the rule would further reduce VOC emissions and also include the control of toxic air emissions from the use of NESHAP halogenated solvents in degreasing operations.
Currently, the rule provides a limited exemption, under section (k)(1)(D), that allows the continued use of high-VOC solvents until January 1, 2003 for specific cleaning applications. The exemption applies only to small batch-loaded cold cleaners and vapor degreasers with open-top surface areas less than 1 square foot, or with a capacity of less than 2 gallons. In addition, such equipment must be used only for electrical, high precision optics or electronics applications; or aerospace and military applications for cleaning solar cells, laser hardware, space vehicle components, fluid systems, or components used solely in research and development programs, or laboratory tests in quality assurance laboratories.
In addition, Rule 1122 requires the AQMD to perform a technology assessment in the year 2002 to determine whether it is necessary to continue the limited exemption in section (k)(1)(D) beyond 2003. In order to comply with this requirement, staff conducted numerous site visits to facilities affected by the exemption to determine existing cleaning methods and any advancement in cleaning technology achieved since the exemption was added to the rule in 1997. The study concluded that significant progress has been made in successfully transitioning to aqueous cleaners and exempt solvents in many cleaning applications (including military and aerospace cleaning). The study also indicated that successful transitioning to aqueous cleaners and exempt solvents may also necessitate some process changes. Such process changes have to be designed and evaluated by each facility on a case-by-case basis, and longer times are typically needed to evaluate the results. The study also identified certain cleaning applications where aqueous systems and exempt solvents may have limitations. Thus, based on these findings, AQMD staff has proposed to extend the limited exemption beyond 2003 provided the cleaning solvent does not contain NESHAP halogenated solvents. A report prepared by AQMD staff, entitled "Technology Assessment for Exempt Cleaning under Rule 1122 - Solvent Degreasers", discusses in detail staff's findings, conclusions, and recommendations pertaining to the small degreaser exemption.
Legislative Authority
The California legislature created the AQMD in 1977 (The Lewis-Presley Air Quality Management Act, Health and Safety Code Section 40400 et seq.) as the agency responsible for developing and enforcing air pollution control rules and regulations in the Basin. By statute, the AQMD is required to adopt an AQMP demonstrating compliance with all state and federal ambient air quality standards for the Basin [California Health and Safety Code Section 40460(a)]. Furthermore, the AQMD must adopt rules and regulations that carry out the AQMP [California Health and Safety Code Section 40440(a)].
Proposal
Staff is proposing to extend the exemption provided to small batch-loaded cleaners or vapor degreasers identified in section (k)(1)(D) of Rule 1122 to January 1, 2005. The new sunset date will provide additional time for facilities utilizing the exemption to continue with their research and testing efforts in finding alternative cleaning methods that would meet their cleaning requirements. At the same time, it will allow these facilities to remain in compliance with the rule requirements during this period. In addition, staff is proposing to add language to the existing exemption in section (k)(1)(D) clarifying that, after January 1, 2003, the limited exemption applies only to specific degreasing equipment using cleaning materials that contain no NESHAP halogenated solvents.
A definition for high precision optic is being proposed for inclusion in the rule in order to clarify rule intent. Staff is also proposing that the AQMD perform another technology assessment by the year 2004 to determine whether it is necessary to continue the exemption listed in section (k)(1)(D).
The VOC emissions associated with the exemption are small (31 pounds per day or approximately 0.015 tons per day).
Public Process
Health and Safety Code §40440.7(a) requires that a formal public workshop be held whenever a proposed rule will significantly affect air quality or emissions limitations. The proposed amendment to Rule 1122 does not have any significant effect on air quality or emissions limitations; therefore, no formal public workshop was held for this rule amendment. However, a Public Consultation Meeting was held on October 30, 2002 at the AQMD headquarters in order to present information and solicit suggestions regarding Proposed Amended Rule (PAR) 1122. Responses to public comments received during this meeting are included in this package as Attachment B.
Staff worked with the affected facilities during the technology assessment process and solicited inputs during the development of the rule proposal. A Public Hearing notice was published in accordance with the requirements of Health and Safety Code §40440.5.
Comparative Analysis
The Board finds pursuant to California Health and Safety Code §40727.2 that PAR 1122 does not impose a new emission limit or standard, make an existing emission limit or standard more stringent, or impose new or more stringent monitoring, reporting or recordkeeping requirements.
California Environmental Quality Act (CEQA) Analysis
Pursuant to 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 public review, concluded that the proposed amendments to Rule 1122 would not have any significant adverse effect on the environment. Responses to public comments received on the Draft EA during the public review period are included in the Final EA. The Final EA is included as part of the attached package for the public hearing on the proposed amendments.
Socioeconomic Assessment
The proposed amendment to Rule 1122 will not result in increased costs to the affected industries and, therefore, will have no socioeconomic impact. Accordingly, a socioeconomic analysis is not included with this proposal.
AQMP and Legal Mandates
The California Health and Safety Code requires the AQMD to adopt an Management PlanAQMP 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 amendment to Rule 1122 does not have a significant impact on air quality or emissions limitations and, therefore, will not affect the ozone attainment strategy outlined in the AQMP.
Implementation Plan
Staff will continue to monitor the development of alternative cleaning methods by the affected industries. Another technology assessment will be conducted by 2004 in order to determine whether it is necessary to retain the exemption.
Resource Impact
Current AQMD resources are sufficient to implement the proposed amendments to Rule 1122 with no budget impact.
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