BOARD MEETING DATE: October 1, 2004
AGENDA NO. 29
Amend Rule 1122 – Solvent Degreasers
SYNOPSIS:
Rule 1122 currently provides a limited exemption that allows the use of high-VOC solvents for small-sized degreasers that are used in certain types of cleaning applications. This exemption will expire after January 1, 2005. The proposed amendment to Rule 1122 will allow a permanent, conditional exemption for certain specialized cleaning categories. Minor clarifications are also being proposed.
COMMITTEE:
Stationary Source, August 27, 2004, 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 primarily to control VOC emissions from solvent degreasing operations. The rule establishes both equipment and operating requirements for any type of solvent degreasing operation conducted at industrial, commercial or institutional facilities.
Previous amendments to the rule significantly lowered the VOC emissions from degreasing operations by requiring the use of ultra-low (25 g/l or less) VOC cleaning materials in batch-loaded cold cleaners. Rule 1122, however, still provides a limited exemption, under section (k)(1)(D), that allows for the continued use of high-VOC solvents in small-sized degreasers used for certain types of cleaning applications (mostly for military and aerospace) until January 1, 2005. This exemption, which has been in the rule since 1997, was extended in 2002 to give industry additional time for research and testing of compliant alternative cleaning technologies.
Staff conducted a technology assessment early this year in order to evaluate the progress made by the affected facilities in finding alternative cleaning systems. A technical panel, comprised of representatives from industries directly affected by the exemption, was formed to assist AQMD staff in reviewing existing cleaning technologies as well as evaluating the need for the exemption beyond the existing sunset date of January 1, 2005.
The Technology Assessment concluded that many companies have successfully converted to alternative solvents for most cleaning applications covered by the exemption, particularly in high-precision optics, laser hardware, electrical applications, and fluid systems. Staff believes that most companies currently using the small-degreaser exemption can readily convert to alternative cleaners such as acetone, aqueous solutions, and soy-based cleaners. However, cleaning of high-reliability electronic components using low-VOC cleaners has not been completely successful at this point. A few companies engaged in such cleaning activities continue to use high-VOC solvents until acceptable replacements are found. A report prepared by AQMD staff entitled "Final Report for 2004 Technology Assessment for Small Degreaser Exemption under Rule 1122 - Solvent Degreasers," dated July 27, 2004, discusses in detail staff's findings, conclusions, and recommendations pertaining to the small degreaser exemption (see Appendix A of Staff Report).
The proposed amendment to Rule 1122 reflects the findings and recommendations in the Technology Assessment. In addition, PAR 1122 incorporates some of the recommendations by the Technical Panel regarding alternative rule compliance options after the small-sized degreaser exemption expires in 2005. The proposed amendment does not implement any AQMP control measure nor does it have any emission reduction objective.
Proposal
Staff is proposing to add an alternative compliance option for small-sized degreasers used for cleaning applications specified in the existing exemption in section (k)(1)(D). Staff’s proposal will allow the existing exemption to continue beyond the sunset date provided such degreasing equipment is vented to a VOC emission control device. This proposal is consistent with the recommendation of the Technical Panel. Additionally, in order to give facilities that choose to use the control device option enough time for purchase, permitting and installation of the control equipment, staff is proposing to extend the sunset date for the current exemption to June 1, 2005.
PAR 1122 will also add a permanent exemption for small-sized degreasers used for research and development or laboratory tests in quality assurance laboratories. Furthermore, staff is proposing a limited exemption for small-sized degreasers that are used only for cleaning high-reliability electronic components for space applications. Other proposed amendments to Rule 1122 include:
- extending the exemption for cleaning stereolithography equipment and models;
- addition of a compliance test method for determining the efficiency of the control equipment; and
- adding minor rule language clarifications.
Key Issues
One of the issues raised by industry was the impact of the 22 pounds per month per facility VOC limit on the few manufacturers that will make use of the electronic component exemption for space applications, particularly those facilities that are undergoing consolidation of operations. It was argued that the proposed emission limit is inadequate to meet ongoing consolidation of operations from multiple facilities to one facility. In addition, industry argued that since the current exemption allows emissions of up to 33 pounds per month per piece of equipment, the proposed limit should be on a "per equipment basis" instead of on a "per facility" basis.
Staff believes that the proposed limit of 22 pounds per month per facility is adequate to support the cleaning requirements for electronic components used for space applications. The limit proposed by staff was derived using the latest emissions data provided by the affected facilities. To address the consolidation issue, staff has modified the proposed exemption language to allow higher emission limits for facilities that consolidate their operations. Specifically, the staff proposal will allow an exemption level of 44 pounds total per month for two facilities consolidating at least 85% of each of their VOC emissions into one, and 66 pounds total per month for more than two facilities consolidating at least 85% of their VOC emissions into one.
Another issue has been raised regarding the proposed compliance date for facilities choosing to install control equipment as a compliance option. Some industry members expressed concern that the proposed compliance date (90 days from expected date of adoption) does not provide adequate time for the affected facilities for purchase, permitting and installation of the control device.
Staff agrees that the compliance date, as originally proposed, may not provide sufficient time for certain (Title V) facilities opting to use a control device to meet the rule requirements. Currently, permit applications from Title V facilities require a 45-day review by the U.S. EPA before AQMD can issue the permits. As a result, staff’s current proposal has been modified to extend the compliance date to June 1, 2005 in order to give facilities additional time to comply with the rule if the control device option is selected.
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. 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
The proposed amendments to Rule 1122 would affect 13 facilities. These facilities belong to the industries of satellite circuit boards and optics (NAICS 334220), prisms and lenses (NAICS 333314), electronic components (334418), and electronic capacitor (NAICS 334414). Eleven out of 13 facilities are located in Los Angeles County and the remaining two in Orange County. Out of 13 affected facilities, only two facilities are expected to purchase carbon adsorbers to control VOC emissions. The total annualized cost of the proposed amendments is estimated at $21,305. However, a less expensive option such as an automatic batch-format cleaning/defluxing system for cleaning electronic circuit boards may be available to two of the 13 facilities, thus resulting in a lower compliance cost. The proposed amendments are not expected to result in any significant socioeconomic impacts.
AQMP and Legal Mandates
The California Health and Safety Code require 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 require 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 its outreach efforts on Rule 1122 to inform the general public of the changes to the solvent degreasing regulation.
Resource Impact
Current AQMD resources are sufficient to implement the proposed Rule 1122 amendments with no additional budget impact.
Summary of Proposal
Rule Development Process
Key Contacts List
Resolution
Proposed Rule Language
Staff Report
Final Environmental Assessment
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