SOLVENT CLEANING TECHNICAL PANEL UPDATE (SCAQMD RULE 1171)

As reported in previous newsletters, the South Coast Air Quality Management District commissioned an on-going study to assess the feasibility of using lower VOC cleaners. In response to concerns from printers about the efficacy and practicality of conversion to compliant cleaners, the study has focused on the printing industry.

The 1999 amendments to Rule 1171—Solvent Cleaning Operations—established a 100 grams per liter VOC limit by July 2005 for various operations such as lithographic printing, letterpress printing, Ultraviolet and Electron Beam printing. The rule also incorporated a technology assessment to verify the availability compliant cleaners. The Printing industry expressed concern over the implementation of the 100 grams per liter limits and requested “interim” limits of 500 grams per liter for the July 2005 deadline for various categories. The District agreed to the interim limits, which took effect on July 1, 2005.

A technical panel meeting was recently convened to discuss test results from the testing conducted by the Institute for Research and Technical Assistance (IRTA). The alternatives presented were: soy based cleaners, acetone/mineral spirit blends, acetone/glycol ether blends, waterbased cleaners and waterbased/acetone blends.

IRTA concluded that cleaners for printing plates, metering rollers and dampening rollers can comply with a limit of 100 grams per liter. The organization also reported that alternatives meeting the 100 gram per liter requirements were available except for 1) roller washes for conventional ink on two color presses for printing on plastic and 2) roller and blanket washes for white UV curable ink for printing on plastic. A limit of 200 grams per liter was recommended.

Over 100 company representatives presented results of a survey sponsored by the Printing Industry Association representing over 1,000 printing presses. The survey was based on printers’ experience with the 500 gram per liter cleaners. Industry representatives cited the following problems with the proposed alternatives:

• Oily buildup on rollers
• Greater paper usage
• Difficulty in inking up
• Color fluctuations during runs
• Unevenness of color
• Conductivity of water
• Higher consumption of solvent cleaner
• Increased towel usage
• Blanket swell
• Longer cleaning times
• Allergic reactions/rashes experienced by operators

AQMD staff commented that the survey results came as a surprise and asked to form a smaller sub-committee to discuss possible solutions to the problems. IRTA has initiated a new project focusing on cleanup of UV and EB materials with a target of 25 grams per liter.

A number of ATI’s printer clients have expressed their dissatisfaction with the new, low-VOC washes. Many say they are using a lot more of the new products, in comparison to the old washes.

HAZARDOUS WASTE MANIFEST SYSTEM STREAMLINED

Hazardous waste generators and transporters are required to use the Uniform Hazardous Waste Manifest system to track a waste’s progress from a generator through treatment, storage, and disposal. The Environmental Protection Agency estimates that 139,000 businesses shipping approximately 12 million tons per year of hazardous waste will be impacted by the changes.

In an effort to save waste handlers and regulators time and money, the Environmental Protection Agency has standardized the Uniform Hazardous Waste Manifest form. The agency hopes the new system will reduce many of the variabilities in state manifest requirement. Waste handlers with multi-state operations will be allowed to register and use their own manifest forms everywhere they do business. The same Manifest form will be used in every jurisdiction beginning July 2006.

STATEWIDE PORTABLE EQUIPMENT REGISTRATION PROGRAM

In 1997 the Air Resources Board adopted a registration program for portable equipment. The program allows engines and equipment units to receive a registration with the state and operate throughout California without the need to get individual permits from local air districts. A portable engine is an internal combustion engine designed and capable of being carried or moved from one location to another and does not remain at a location for more than 12 consecutive months. Engines used to propel mobile equipment or motor vehicles are not eligible for the program.
Examples of portable engines eligible for registration include:

• Cranes
• Pumps
• Welding
• Well drilling
• Wood chippers
• Tactical support equipment
• Power generation
• Diesel pile-driving hammers
• Service or work-over rigs
• Dredges on boats or barges
• Compressors

Examples of equipment units eligible for registration include:

• Confined and unconfined abrasive blasting operations
• Concrete batch plants
• Sand and gravel screening, rock crushing and pavement crushing and recycling operations
• Tub grinders and trommel screens

Portable engines that can meet eligibility requirements follow:

1. The engine is certified. A certified engine is one which has been tested by the U.S. Environmental Protection Agency or the Air Resources Board and meets the federal off-road engine emission standards.
2. Until December 31, 2005 a “resident” engine. A resident engine is one which was located in California during the period of July 1, 2003 and July 1, 2004.
3. A controlled engine. A controlled engine is one which meets the spark-ignition engine standards (found in Table 1 of the PERP regulation), an engine retrofitted with a Clean Cam technology kit, or an engine which is equipped with a selective catalytic reduction system.

Portable equipment units registered in the program must comply with Best Available Control Technology requirements. Additionally the equipment is limited to 82 pounds per day of particulate matter (less than 10 microns), an annual limit of 10 tons per year for any criteria pollutant and recordkeeping requirements.

Effective September 1, 2005, PERP registered generators may not provide power to the electric utility grid, stationary sources, or stationary equipment, except during unforeseen loss of power, maintenance and repair operations, electrical upgrade operations, operations where specific frequency or current requirements are not available and remote operations.

Recent changes include the addition of a five-year renewal cycle option, the allowance of identical replacement for mechanical breakdown only and the removal of the requirement to submit annual reports to the ARB. After January 1, 2010, portable diesel-fueled engines registered in the program must be certified engines.

ARB FEE INCREASE FOR NON-VEHICULAR SOURCES, CONSUMER PRODUCTS AND ARCHITECTURAL COATINGS

The Air Resources Board adopted fee increases for 1) facilities that emit 250 tons or more annually of any non-attainment pollutant or precursor 2) consumer products or architectural coating manufacturers for which the total sales resulted in VOC emissions of 250 tons or more during a calendar year. The agency will charge $105.25 per ton of VOC emissions. Industry organizations consider this a “significant increase” over last year’s fee of $94.03 and the year before of $86.55. Industry representatives estimate that the fees range from $14,000 to $750,000 per year. Companies have 60 days from receipt of ARB notification to confirm their emissions estimate.

PROPOSED CHANGES TO METAL PARTS AND PRODUCTS REGULATION (SCAQMD RULE 1107)

The South Coast Air Quality Management District proposed changes to Rule 1107–Coating of Metal Parts and Products — to lower VOC emissions from the affected categories. The rule affects all original factory-applied finishes to various metals such as steel, aluminum, copper, brass and special alloys. The rule had not been amended since 1998 whereby the emission reductions were achieved by reducing the general VOC limit for single component coatings from 340 grams per liter to 275 grams per liter. The 1998 amendments also eliminated the one-gallon per day facility-wide exemption allowing the use of noncompliant coatings.

Technology Assessment
SCAQMD staff conducted a technology review in order to determine the feasibility of lowering some of the VOC limits within Rule 1107. The technologies addressed were: waterborne, high solids, powder and UV curable. The District reported that the high solids metal coatings contain greater than 60 percent by volume of solids. They are generally low-molecular weight polymers, which require less solvent to achieve the proper viscosity and are either two-component (which cure at ambient temperature) or single-component (which cure with heat). These materials are normally applied in film builds 2 to 6 mils thick and therefore, are not suitable for applications requiring decorative appearance. Staff reports that “A wider window of flexibility is needed for this industry to provide for both decorative and functional coatings.”

The technology review also looked into the feasibility of conversion to waterborne coatings (polyurethanes, acrylics, alkyds, vinyls, silicone emulsions). The review concluded that catalyzed waterborne polyurethanes can perform better than their solvent borne counterparts. The staff projects that substitution with water reducible alkyds, waterborne acrylics and waterborne polyurethanes will be the likely choice.

Highlighting the experience by the automotive refinish market with parachlorobenzotrifluoride (PCBTF), AQMD staff believes that gloss and performance requirements can be met with PCBTF formulations (zinc primers, epoxies, and ultraviolet light resistant urethane topcoats). The addition of tertiary butyl acetate (TBAc) to the exempt list by EPA is expected to spark the formulation of TBAc coatings, which will be compliant and have acceptable performance characteristics.

Powder coatings, which can have VOC contents ranging from 0.05% to 3% by weight, can also be a compliant alternative. Epoxy, polyester and acrylic powder coatings are the most common thermosetting powders. The analysis showed that epoxy powders work well for interior applications (shelving, bathroom fixtures, office and kitchen furniture, business machines, home appliances) but do not perform as well for outdoor applications because they become “chalky” when exposed to ultraviolet light. Acrylic powder coatings can be more suitable for outdoor applications which require gloss, hardness or flexibility. The higher cost per pound for some powder coatings can be offset by the gain in coverage due to their 100 percent solid content. Hazardous waste disposal fees are also reduced with powder coatings, since waste powders can be baked into a cube and are not reportable wastes. Sole of the limitations of powder coatings include cross contamination between colors and difficulty in covering sharp corners, which typically repel the charged coating particles.

UV coatings consisting of monomers, oligomers, photoinitiators and additives are available for use in clear tubing, conduit finishing, door hardware, plumbing and can & coil industries. The UV coatings are available in liquid as well as powder form.

Based on the availability of various coating systems, staff believes there is an “opportunity to obtain emission reductions for some of the more broadly used coatings such as extreme high-gloss and prefabricated architectural component coatings.”

Proposed Amendments
The following table lists the current coating categories regulated by Rule 1107
(* indicates new amendment)

Table 1. VOC limits in grams per liter (less water and less exempt compounds) for Rule 1107

The proposal will also delete the current high transfer efficiency exemptions for small use and coating specific exemptions. The staff estimates that 1,530 facilities may be subject to the changes, resulting in an emissions reduction of 0.80 tons per day of VOCs.