| AGENDA: 15 | ||
| BAY AREA AIR QUALITY MANAGEMENT DISTRICT Memorandum |
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| To: | Chairperson Attaway and Members of the Board |
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| From: | Ellen Garvey Air Pollution Control Officer |
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| Date: | October 9, 2002 | |
| Re: | Public Hearing on Proposed Amendments to Regulation 8, Rule 16 (Solvent Cleaning Operations), and on approval of a Negative Declaration pursuant to the California Environmental Quality Act | |
| RECOMMENDED ACTION: |
| Adopt proposed amendments to Regulation 8, Rules 16 and approve a Negative Declaration pursuant to the California Environmental Quality Act (CEQA) for this rule-making activity. |
| BACKGROUND |
| The proposed amendments would implement control measure SS-14, Aqueous (Water-Based) Solvents from the Bay Area 2001 Ozone Attainment Plan. This is the third control measure from the plan to be brought before the Board. The measure will reduce VOC emissions in the Bay Area by 2.2 tons per day. With its adoption, the District will have achieved 8.05 tons of the 8.2 ton-per-day reduction that it committed to achieving from the seven stationary source control measures in the plan. Additional reductions will come from other measures to be brought to the Board this year and next year.
This measure is similar in many respects to the wipe cleaning measure also before the Board. Like that measure, this measure is intended to reduce the emissions from the use of organic solvents, this time in cold solvent tanks such as those typically found in auto repair shops. 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. |
| DISCUSSION |
| Cleaning of parts in most maintenance and repair operations, such as those found in auto repair shops, has traditionally used organic solvents in a sink-type cleaner. A part is cleaned by soaking it in solvent or by directing a solvent stream over the part. Traditional solvents, such as mineral spirits, evaporate into the atmosphere and are precursors to ozone formation. Many alternatives to these traditional solvents have been developed in response to pollution prevention programs around the country. These alternatives have been widely tested and proven effective. Switching to alternative solvents in appropriate cleaning applications will result in a reduction in VOC emissions.
Regulation 8, Rule 16 sets standards for equipment using vaporized, heated, or cold solvent to clean parts and surfaces. The rule sets standards for equipment used in solvent cleaning and for operators performing solvent cleaning tasks. Rule 16 was previously amended in 1998 to encourage the use of low-VOC cleaners. Each facility was allowed to retain a single high-VOC cleaner and any high-VOC cleaners for which it obtained a District permit. Other solvent cleaners were required to switch to low-VOC solutions. The 1998 amendments introduced the use of aqueous cleaning solutions to the industry, and forced users to think about the necessity for multiple pieces of equipment. In addition, the permitted cold cleaners enabled staff to gather information about the appropriateness of this technology. This proposal will require the use of low-VOC content cleaning solutions for repair and maintenance cleaning. The proposed standard is 50 grams VOC per liter of cleaning solution (0.42 lb/gal). The standards will go into effect June 1, 2003. The amendments provide certain exemptions from the standards based on a technical evaluation of substrate needs and limitations, such as for cleaning of aerospace components, medical devices, optics and electrical components and for research and development operations. As an alternative to aqueous solutions, the use of volatile methyl siloxanes, a class of compounds that are neither reactive, toxic, or ozone depleting, is allowed. The amendments also provide definitions, compliance options, recordkeeping requirements and reference test methods. In addition, the proposed amendments clarify and unify some language throughout the rule. The proposed amendments will reduce VOC emissions at a cost of $1,664 per ton, which is among the most cost effective of District regulations, though not as cost effective as the wipe cleaning measure from the plan, SS-13. A socioeconomic analysis of the costs to industry was prepared by Applied Development Economics of Berkeley, California, as required by Health and Safety Code §40728.5. It examined the effect of the proposal on employment and the regional economy, including the impacts on small businesses, and concluded that the impacts would be insignificant. A CEQA analysis has been prepared by Jones and Stokes of Sacramento, California, concluding 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. The draft amendments were discussed at a public workshop in June, 2002. Staff then received comments and met with affected parties in order to develop the final regulatory language. The final proposal and CEQA negative declaration have been circulated for public comment. The proposed amendments, a staff report, the socioeconomic analysis, and the CEQA negative declaration and initial study are attached. Respectfully submitted,
Ellen Garvey Air Pollution Control Officer |
Prepared by: M.K. Carol Lee
Reviewed by: Peter Hess
| Proposed Amendments to Regulation 8, Rule 16 |
| Staff Report |
| CEQA Document |
| Socioeconomic Report |