BOARD MEETING DATE: November 7, 2003
AGENDA NO. 29
Amend Rule 1171 – Solvent Cleaning Operations
SYNOPSIS:
The proposed amendment will eliminate the exemption for solvents used in the cleaning of architectural coatings application equipment, and it will establish a low-VOC content limit and a compliance date for the use of these materials. This cleaning application is currently exempt from all provisions of Rule 1171. The amendment reflects advances in low-VOC cleaning technology. Minor clarifications in rule language are also proposed.
COMMITTEE:
Stationary Source, September 26, 2003, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
- Certifying the CEQA Final Environmental Assessment (EA) for the proposed amendments.
- Amending Rule 1171 – Solvent Cleaning Operations.
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Rule 1171 – Solvent Cleaning Operations, a key component of AQMD’s ozone reduction strategy, was adopted on August 2, 1991 to reduce VOC emissions from solvent cleaning activities during the production, repair, maintenance, or servicing of products, tools, machinery, and general work areas. Subsequent rule amendments expanded the scope of the rule to cover all solvent cleaning operations at all facilities, and established lower VOC limits for all solvent cleaning categories. Facilities that operate and maintain machinery or must remove organic material as part of the production and maintenance process are subject to the rule.
The October 8, 1999 rule amendment established lower VOC content limits for the cleaning of coating and adhesive application equipment such as spray guns, rollers, and brushes used in wood and metal coatings operations, automotive refinishing, etc. The current VOC content limit in Rule 1171 for such cleaning application is 550 grams per liter of material. By July 1, 2005, the VOC content limit is reduced to 25 grams per liter of material and relies mostly on the development of alternative cleaners using VOC-exempt solvents. However, Rule 1171 currently exempts the clean-up of architectural coating application equipment from all provisions of the rule. High-VOC solvents such as mineral spirits and lacquer thinners are most widely used for removing solvent-borne architectural coatings from application equipment. Exempt solvents are also used by contractors to remove solvent-borne architectural coatings. For waterborne coatings, water is used to clean the coating application equipment.
Architectural coatings and clean-up solvents represent one of the largest non-mobile sources of VOC emissions in the Basin. The 2003 AQMP includes control measure CM#2003CTS-07 which seeks to further reduce VOC emissions from various architectural coating categories and thinning and clean-up solvents used in this industry. In addition, CM#2003CTS-10 (P1) seeks to reduce emissions from industrial solvent and coating applications. The proposed amendment to Rule 1171 will implement the clean-up solvent portion of the CM#2003CTS-07 and the CTS-10 (P1) by setting a low VOC content limit for solvents used in cleaning architectural coating application equipment.
Proposal
Staff is proposing to eliminate the rule exemption for the cleaning of architectural coating application equipment by establishing a sunset date of June 30, 2005 for the exemption. Additionally, staff is proposing a VOC content limit of 25 grams per liter of material for this cleaning application starting on July 1, 2005. This VOC limit is identical to the 2005 rule requirement for all other coating and adhesive application equipment. The proposed amendment covers business operations only and excludes homeowner or consumer cleaning activities.
Proposed Amended Rule 1171 will reduce VOC emissions through the use of commercially-available near-zero or zero-VOC solvent formulations (exempt solvents) or development of new cleaning materials and/or technologies. Input from users and case studies conducted thus far demonstrate the effectiveness of these clean-up solvents with architectural coatings. Additional testing is currently being conducted to further validate their effectiveness with industrial maintenance coatings, which have been the most challenging to clean. Staff anticipates a continued increase in the use of readily available compliant solvents to meet the 2005 VOC requirement. In addition, staff is confident that the trend towards low-VOC solvents will continue and that more compliant materials will be available when the new VOC limit takes effect in 2005.
Staff estimates that the proposed amendment will achieve VOC emission reductions of seven and one-half tons per day in 2005. Other proposed amendments to Rule 1171 are as follows:
- modify the exemption language pertaining to clean-up solvents with VOC content of no more than 25 grams per liter;
- clarify the table of VOC limits to reflect the most current limits applicable for each solvent cleaning activity; and
- add minor clarifications to rule language.
Key Issues
One of the issues raised by industry was the importance of relative reactivity of solvents in controlling the formation of ozone. It was argued that use of acetone, the most likely solvent substitute as a result of the proposed amendment, may result in the formation of more ozone due to its high evaporation rate even though it has lower reactivity compared to mineral spirits. It was suggested that the AQMD look at reactivity as a VOC control strategy.
Staff believes that reactivity-based regulatory approaches have a lot to offer as potential VOC/ozone control strategies. As a result, the 1997 and 1999 revisions to the AQMP and Rule 1113 carry explicit commitments to study such novel approaches. However, because of the limited amount of information available regarding reactivity of many VOC materials including those used in solvent cleaning, establishing a reactivity-based approach for Rule 1171 is not viable at this time. The AQMD and CARB have initiated studies with UC Riverside to refine VOC reactivity data including mineral spirits. Until these studies are completed and sufficient information is available, the AQMD will continue to use a mass-based VOC control strategy. Although the maximum incremental reactivity of mineral spirits is highly uncertain and currently under evaluation by UC Riverside, a review of available information indicates that mineral spirits are three times more reactive than acetone. The usage of acetone, on the other hand, is expected to increase only slightly, approximately 10 percent, due to its higher evaporation rate (compared to mineral spirits) as indicated by the case studies included in the staff report; therefore, the use of acetone-based cleaners is an effective ozone-reducing strategy. Furthermore, the ozone-reducing benefits of PAR 1171 are expected to be even greater if one considers that many users will opt for solutions of acetone and other available VOC-exempt solvents with lower evaporation rates compared to that of pure acetone.
Another issue has been raised concerning the effectiveness of compliant materials in cleaning up architectural coating application equipment. Staff believes that compliant technology is currently available and cost effective. Input from existing users and case studies conducted demonstrate the effectiveness of compliant cleaning materials. During the rule development process, staff has identified compliant solvents that can effectively clean coating application equipment. The AQMD survey of painting contractors showed that VOC-exempt solvents are currently being used to remove solvent-borne architectural coatings. A study conducted by an AQMD contractor indicated that alternative cleaning materials can be used as substitute for high-VOC solvents. In addition, a solvent formulator has successfully developed and tested a compliant solvent blend for those hard-to-remove coatings. Research efforts are on-going in the development and testing of low-VOC cleaners. The AQMD is working with other facilities in testing other alternative cleaners to further validate their cleaning effectiveness. Staff believes that more effective compliant cleaning materials will be available when the new VOC limit takes effect in 2005.
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 1171 - Solvent Cleaning Operations. The Draft EA, which was made available for a 30-day review period, concluded that the proposed amendments to Rule 1171 would not have any significant adverse effect on the environment. The Final EA, which includes responses to comments made on the draft document, is included as part of the attached package for the public hearing on the proposed amendments.
Socioeconomic Impact Assessment
Proposed amendments to Rule 1171 would potentially impact industries engaged in manufacturing paint and industrial/commercial end users of clean-up solvents for architectural coatings. The former belongs to the industry of chemical and allied products (SIC 2851 or NAICS 325510), and the latter are a part of the industry of painting and paper hanging (SIC 1721 or NAICS 235210). The total annualized cost of the proposed amendments is projected to be $5.70 million. The AQMD’s regional economic model estimates that approximately 19 jobs could be created annually in the four-county area between 2005 and 2020. However, this level of change is considered within the "noise" of the modeling.
AQMP and Legal Mandates
The California Health and Safety Code requires the AQMD to adopt an AQMP to meet state and federal ambient air quality standards in the Basin. In addition, the California Health and Safety Code require that the AQMD adopt rules and regulations that carry out the objectives of the AQMP. The proposed changes to Rule 1171 are consistent with the AQMP (CM#2003CTS-07 and CM#2003CTS-10) and the consent decree to meet state and federal requirements.
Implementation Plan
Staff will continue its outreach efforts on Rule 1171 to inform the general public of the changes to the solvent cleaning regulation. Notices will be sent to the sources affected by these amendments, including solvent suppliers.
Resource Impact
Current AQMD resources are sufficient to implement the proposed Rule 1171 amendments with no additional budget impact.
Summary of Proposal
Rule Development Process
Key Contacts List
Resolution
Proposed Rule Language
Staff Report
Final Environmental Assessment
Socioeconomic Assessment
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