BOARD MEETING DATE: May 6, 2005
AGENDA NO. 39

Amend Rule 1171 – Solvent Cleaning Operations

SYNOPSIS:

The proposed amendments will implement the recommendations from a technology assessment of low-VOC cleaning materials. With respect to the cleaning of ink application equipment used for lithographic/letterpress printing, screen printing and ultraviolet/electron beam inks, staff proposes to delay by one year the July 1, 2005 compliance date and establish an interim limit. Additional time is necessary to fully assess the impact of promising new formulations on print quality, equipment life and costs. Staff proposes to extend and add limited exemptions for certain specialized cleaning categories. Other minor amendments are also being proposed. The Board will also make infeasibility findings for the limited exemptions and extended compliance dates.

COMMITTEE:

Stationary Source, March 25, 2005, Reviewed

RECOMMENDED ACTION:

Adopt the attached resolution:

1. Certifying the CEQA Final Subsequent Environmental Assessment for the proposed amendments.
    
2. Amending Rule 1171 – Solvent Cleaning Operations.

Barry R. Wallerstein, D.Env.
Executive Officer

Background

Rule 1171 – Solvent Cleaning Operations was adopted on August 2, 1991 to reduce VOC emissions from the use of solvents and solvent wastes generated during the production, repair, maintenance, or servicing of products, tools, machinery, and general work areas. Industries subject to the provisions of the rule include facilities that operate and maintain machinery or must remove organic material as part of the production process.

The October 1999 amendment of Rule 1171 established two-tiered VOC content limits for all solvent cleaning activities. Tier I was implemented on December 1, 2001, and had an equivalent VOC emission reduction of 6 tons per day from solvent cleaning activities. The second tier has a compliance date of July 1, 2005, with an estimated emission reduction of 9 tons per day. These emission reductions were expected to be achieved through greater use of aqueous cleaning technologies and VOC-exempt solvents, or through the development of new low-VOC cleaning materials. A technology assessment was required for specific cleaning categories in order to determine the feasibility of the Tier II VOC limits for these categories.

In August 2002, Rule 1171 was further amended to accelerate the reduction of 1.94 tons per day of the VOC emissions expected in 2005 from general solvent cleaning activities by two and one-half years starting in 2003. During that time, many available low-VOC cleaning materials were already meeting the Tier II VOC limit of 25 grams per liter for general cleaning applications. Consequently, the 2005 compliance date for the 25 grams per liter VOC limit for general cleaning applications was advanced to January 1, 2003.

As mentioned earlier, the 1999 rule amendment called for the completion of technology assessments for several cleaning categories in order to determine the progress in technology development, relative to the 2005 VOC limits, and assess whether future amendments are necessary. Currently, technology assessments have been completed for the following cleaning categories: the cleaning of electrical apparatus/electronic components; coating/adhesive application equipment; and the cleaning of certain ink application equipment. A report outlining the finding and recommendations of the study is available.

However, the technology assessment for ink application equipment used for lithography/letterpress, screen printing, and ultraviolet/electron beam (UV/EB) ink is still ongoing. Preliminary test results on new solvent formulations are promising and indicate that the 2005 limits are achievable, but extended field testing is needed to determine if there are compatibility problems associated with the use of alternative cleaners over time. Staff expects the study to be completed in November 2005.

Proposal

Staff is proposing to delay by one year the implementation of low-VOC limits originally scheduled for July 1, 2005 for the cleaning of lithographic/letterpress printing, screen printing, and UV/EB ink application equipment. However, an interim VOC limit is being proposed for these cleaning applications to take advantage of existing products in the market with lower VOC content than the current rule limit. This proposal allows the AQMD to take a portion of the VOC emission reductions originally projected from these cleaning applications now rather than at the completion of the technology assessment.

In addition, staff is proposing to implement the recommendations in the technology assessments for those cleaning applications where studies have been completed. PAR 1171 will provide limited exemptions for the cleaning of adhesive application equipment used in thin metal laminating processes, and for the clean-up of electronic/electrical cables. Additional exemptions are being proposed for the following cleaning applications: touch-up cleaning of certain printed circuit boards; the cleaning of metering rollers, dampening rollers and printing plates; and the clean-up of application equipment used for applying solvent-borne fluoropolymer coatings. Staff is also proposing to prohibit the use of methylene chloride and perchloroethylene in solvent cleaning activities by eliminating the general prohibition exemption for these solvents. Other proposed amendments to Rule 1171 are as follows:

• Modify rule applicability to include toxic air contaminants;
• Extend the exemption for stereolithography and UV/EB lamps;
• Modify rule language pertaining to test methods for determining the efficiency of emission control systems;
• Remove obsolete rule provisions; and
• Add rule language clarifications.

Tier II VOC limits that will be implemented on July 1, 2005 are expected to achieve VOC emission reductions of 5.27 tons per day even with the one-year delay in the implementation of certain VOC limits. The delayed emission reductions of 2.52 tons per day are anticipated in 2006. These emission reductions are part of the Tier II reductions of 9 tons per day in 2005, originally projected during the 1999 rule amendment, that were subject to technology assessments. As mentioned previously, the 2002 amendment of Rule 1171 accelerated 1.94 tons per day of the Tier II VOC emission reductions.

Key Issues

An issue was raised regarding the limited availability of products that meet the interim VOC limit for cleaning UV/EB inks. The UV/EB industry has claimed that it is given only one product meeting the proposed 500 gram per liter interim limit, which may work well for manual equipment, but has not yet been tested on equipment with automatic wash systems. The industry, thus, is opposed to an interim limit and supports retaining the current limit of 800 grams per liter until further study is completed.

Staff believes that the proposed interim limit of 500 grams per liter is achievable for cleaning UV/EB ink application equipment. The information staff received from solvent suppliers and printers indicates that products are readily available that meet the interim limit for this application. Additionally, several solvent suppliers have indicated that they do not foresee any problems with using existing 500 gram per liter cleaners on manual or automatic blanket wash systems. Furthermore, industry input indicates that existing high-VOC products can be readily reformulated to meet the interim VOC limit. Facilities need to test these products in order to identify a cleaner that best meets their cleaning requirements. Staff is confident that more products will be available that meet the 500 gram per liter interim VOC limit for UV/EB ink application equipment.

California Environmental Quality Act (CEQA) Analysis

AQMD staff has reviewed Proposed Amended Rule 1171 pursuant to state CEQA Guidelines §15002 (k)(3) and the AQMD’s Certified Regulatory Program (Rule 110). A Draft Subsequent Environmental Assessment (EA) was prepared, pursuant to CEQA Guidelines §15252, and circulated for a 45-day public review and comment period from February 9, 2005 to March 25, 2005. The project will result in a delay of VOC emission reductions that will exceed the SCAQMD’s daily significance operational threshold and, thus, adverse air quality impacts have been determined to be significant. No other environmental topic area is considered to have an adverse impact as a result of the proposed project. No public comment letters were received on the Draft Subsequent EA, and minor modifications were made to the Draft Subsequent EA so it is now a Final Subsequent EA. Changes to the project description are minor and do not change the conclusions made in the Draft Subsequent EA or increase the environmental impact analyzed in the Draft Subsequent EA. Pursuant to CEQA Guidelines §15073.5(c)(2), recirculation is not necessary since the information provided does not result in new avoidable significant effects.

Socioeconomic Impact Assessment

The California Health and Safety Code Section 40440.8 requires an assessment of the socioeconomic impacts of the adoption, amendment, or repeal of a rule or regulation that will significantly affect air quality or emissions limitations. The proposed amendments to Rule 1171 - Solvent Cleaning Operations will not result in increased costs to the affected industries and, therefore, will have no adverse socioeconomic impacts.

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 1999 amendment of Rule 1171 implemented a control measure from the 1997 AQMP (CM#97ADV-CLNG) to meet state and federal requirements. The proposed changes to Rule 1171 delays part of the 2005 VOC emission reductions expected from the 1999 rule amendment; however, it would not affect the overall attainment strategy. Rule 1171 is part of the 1999 SIP settlement agreement which requires the Board to make findings of infeasibility when granting exemptions or delays in implementation of the 2005 limits. Appropriate findings are included in the Board Resolution for this item.

Implementation Plan

Staff will continue its outreach efforts on Rule 1171 to inform the affected sources, including solvent suppliers, of the changes to the solvent cleaning regulation.

Resource Impact

Current AQMD resources are sufficient to implement the proposed Rule 1171 amendments with no budget impact.

Attachments

1. Summary of Proposal
2. Rule Development Process
3. Key Contacts List
4. Resolution
5. Rule Language
6. Staff Report
7. Final Subsequent Environmental Assessment

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