Control measure SS-13, Surface Preparation and Cleanup Standards for Metal Parts Coating, is the second of these control measures to be brought before the Board. It is intended to reduce the emissions from the use of organic solvents in cleaning and preparing surfaces for coating, primarily through wipe cleaning where solvent is applied to a cloth. The amendments will limit the VOC content of solutions used in these activities. The proposed requirements are similar to those adopted in the South Coast, San Joaquin Valley, and Sacramento air districts.

The proposed amendments will set VOC standards for solvents used to wipe-clean surfaces for coating, to clean parts or products for sale or use, or to clean application equipment or tools. The proposed standard for each rule is 50 grams VOC per liter of cleaning solution (0.42 lb/gal). The standards will go into effect June 1, 2003. Various exemptions are included in each rule, tailored to the specific nature of each industry. The proposed amendments will reduce emissions of VOC by 2.1 tons per day. In addition, the proposed amendments clarify and unify some language throughout the rules.

The proposed amendments will reduce VOC emissions at a cost of $192 per ton, among the most cost effective of District regulations. A socioeconomic analysis was prepared by Applied Development Economics of Berkeley, California, as required by Health and Safety Code §40728.5. It examines the effect of the proposal on employment and the regional economy, including the impacts on small businesses, and concludes that the impacts would be insignificant. Health and Safety Code §40920.6 requires an analysis of the relative costs of incremental control options that meet the emission reduction targets. As the use of low-VOC cleaning solutions is the only option identified, this analysis is not required.

A CEQA analysis has been prepared by Jones and Stokes of Sacramento, California. The analysis shows that the proposed amendments would not have any significant adverse environmental impacts. Attached is a Negative Declaration for the proposed amendments pursuant to Public Resources Code § 21080(c) and CEQA Guidelines 15070 et seq.

A minor change has been made in Rules 19 and 31 since the public notice for the hearing was published and the rules were sent to ARB. Staff intended to include an exemption for the preparation of surfaces for adhesive bonding of dissimilar substrates in Rules 19, 31, and 43, but the exemption was inadvertently omitted from the exemptions in Section 8-19-137 and 8-31-127. The attached copies of Rule 19 and Rule 31 include the exemptions. Under Health and Safety Code §40726, changes from the publicly noticed text can be made as long as they are not “so substantial as to significantly affect the meaning of the proposed rule or regulation.” The changes are not substantial, and all analyses of rule impacts were based on versions of Rules 19, 31, and 43 that incorporated these exemptions.

The draft amendments were discussed at a public workshop in May, 2002. Staff then received comments and met with affected parties in development of the final regulatory language. The final proposal and CEQA negative declaration were also circulated for public comment.

The proposed amendments, a staff report, the socioeconomic analysis, the CEQA negative declaration and the initial study are attached.

Respectfully submitted,

Ellen Garvey

Air Pollution Control Officer