DEADLINE TO MEET REQUIREMENTS FOR SOLVENT CLEANING FOR COATINGS AND ADHESIVES APPLICATION EQUIPMENT APPROACHES

Effective July 1, 2005 solvents containing more than 25 grams per liter of Volatile Organic Compounds (VOCs) will not be allowed in the South Coast District, for the cleanup of coatings, adhesives and polyester resin material application equipment.

The use of VOC-containing materials in solvent cleaning operations is regulated under SCAQMD Rule 1171-Solvent Cleaning Operations. The rule applies to all persons who perform clean up with VOC formulations. One branch of the rule pertains to coating and adhesive application equipment. Examples of application equipment include: spray guns, brushes, rollers, sponges as well as any appurtenants that are part of the equipment, such as process lines. If you or your customers would like a list of the suppliers of these low VOC cleaners please contact ATI.

EPA DELISTS COMPOUNDS

The U.S. Environmental Protection Agency formally delisted ethylene glycol monobutyl ether (EGBE) as a Hazardous Air Pollutant and t-butyl acetate (TBAC) as a Volatile Organic Compound. The action was a result of requests to EPA from the American Chemistry Council and Lyondell Chemicals to exempt the substances.

EGBE is commonly known as 2-butoxyethanol or butyl cellosolve. EGBE is used in hydraulic fluids, waterbased inks and coatings, varnishes, paints, dry cleaning compounds, textiles, cosmetics, cleaning solvent blends and in fountain solutions as alcohol substitutes. Based on the available information concerning the potential hazards of and projected exposures to EGBE, the U.S. EPA concluded that there are “adequate data on the health and environmental effects [of EGBE] to determine that emissions,
ambient concentrations, bioaccumulation, or deposition of the substance
may not reasonably be anticipated to cause adverse effects to human health or
adverse environmental effects.”

EGBE is still considered a Volatile Organic Compound (and will be regulated as such) and remains on the Toxic Release Inventory list of chemicals. Usages greater than 10,000 pounds trigger a requirement to file a “Form R” report, which must be submitted to EPA. EPA also declined to rule as to what happens to a facility that is considered a major source for Hazardous Air Pollutants because of EGBE, but would now be a minor source due to the delisting. EPA is expected to issue guidance or a regulation in a future action.

TBAC is used in pharmaceutical and pesticide manufacturing as well as a solvent in a myriad of applications. EPA has concluded that the compound is “negligibly reactive” and should not be considered a VOC. The agency reports that a number of manufacturers of paints, inks and adhesives have indicated that if TABC were excluded from regulation as a VOC, they would use it in their products in place of other compounds that are as much as 20 to 30 times more likely to form ground-level ozone, or smog.

PRINTING INDUSTRY ASSOCIATION HOSTS WORKSHOP ON TECHNOLOGY ASSESSMENT FOR CLEANING OF LITHOGRAPHIC PRINTING EQUIPMENT

Several months ago, the South Coast Air Quality Management District commissioned a study to look into the feasibility of low VOC solvents for lithographic printing. The project was prompted by concerns from industry regarding the commercial availability of low VOC products and their effective practical use in the production line. Amendments of Rule 1171 (Solvent Cleaning) set future VOC limits contingent on a technical assessment. The SCAQMD committed to relax the limits, if the technical assessment found that certain limits were not achievable.

Some of the limits being looked at will tentatively become effective in 2005 and are as follows:

Test results presented during the PIA workshop, were compiled by the Institute for Research and Technical Assistance (IRTA), one of the three independent contractors hired by the District to conduct the study. The other two contractors are the University of Tennessee and the Graphic Arts Technical Foundation. The District hired 3 contractors in the hopes of having a well-balanced approach.

The Printing Industry Association recently hosted a half-day seminar to discuss the study and its potential impacts on printers. Various printers, as well as other trade associations attended the seminar which, included presentations from South Coast Air Quality Management District staff, the Institute for Research and Technical Assistance (IRTA) and printers who have been participating in the study. IRTA staff reported that they have currently been testing various (Acetone, soy based, water based and custom blends) low VOC solvents on sheetfed and web fed printing presses. Substrates include paper, coated paper, metal and plastic. The study encompassed soy, solventborne, Ultraviolet, Electron Beam ink types, air dry as well as heat set. IRTA has asked that the SCAQMD grant additional time for extended field testing in order to explore equipment compatibility issues such as swelling of the rollers and blankets caused by some of the low VOC cleaners.

A newspaper printer participated in the study by trying a cleaner with a VOC content of 90 grams per liter to clean their soy based inks currently being used for newsprint. They were reportedly satisfied with the cleaner and plan to convert their cleanup operation.

A printer of newspaper inserts reported unsuccessful trials with soy based cleaners on their heatset web offset press. While dissatisfied with the oily residual film the cleaners left behind, no negative impacts on the blankets and rollers were reported. The rubber hoses used to dispense the cleaners showed signs of deterioration such as cracking and swelling.

Another facility prints on metal and plastic substrates with soy based inks. The company reported that an acetone blend solvent with a VOC content of 100 grams per liter worked satisfactorily. They also experimented with a cleaner designed for UV inks but it did not meet their requirements.

A user of solvent borne inks printing on metal, tried soybased cleaners, which apparently deteriorated the rollers. Further testing will be necessary at this facility.

The SCAQMD print shop prints on recycled paper and coated paper with solvent borne inks. They tried a soy based cleaner but the staff was not satisfied with the oily film left behind. Waterbased cleaners were not suitable because they resulted in lint on the rollers. Acetone blends proved to be effective cleaners but have a strong odor. The District staff is currently investigating ways of masking the odor as well as the potential damage to the equipment.

District staff may be proposing rule amendments in the early parts of 2005. At this time, a formal rulemaking course has not been set but District staff is considering less stringent interim limits.

STATE ADOPTS TOXIC CONTROL MEASURE FOR STATIONARY COMPRESSION IGNITION ENGINES

The California Air Resources Board (ARB) has adopted a control measure for new and in-use stationary compression ignition engines. The requirements, which have been several years in the making, stemmed from the state’s Diesel Risk Reduction Plan. Elements in the plan, originally adopted in the year 2000, called for diesel particulate matter reductions by the year 2010. More stringent standards for new engines, use of low-sulfur diesel fuel (clean diesel) and diesel emission control strategies were identified as tactics to achieve emission reductions.

The ARB defines a “stationary engine” as an engine that remains at a location in a facility for more than 12 months. An “in-use” engine is one that is installed before January 1, 2005. All engines installed after January 1, 2005 are considered “new.”

By July 1, 2005, owners and operators of existing engines rated greater than 50 brake horse power hour (bhp) must submit to the local air district, information regarding their engines. All stationary diesel engines greater than 50 bhp must use clean fuels by January 1, 2006. Examples of clean fuels include: CARB diesel, compressed natural gas and/or alternative fuels certified by ARB. In-use emergency standby engines and prime engines are not allowed to increase criteria pollutant emissions (NOx, SOx, CO) in order to reduce diesel PM emissions. Additionally, new emergency and prime engines must meet the current Off-Road Compression Ignition Engine Standards.

As a result of comments from industry and the public, the ARB made the following modifications to the original regulatory language:

• Local air districts can approve “reasonable limited delays” from the fuel requirement to use up fuel purchased before the ATCM becomes effective
• A near-school “buffer zone” of 500 feet has been included to prohibit non-emergency operation of engines during school hours unless the engine meets clean standards
• Modified requirements for engines operating under demand response programs, including interruptible service contracts and the rolling blackout reduction program
• Allowance of local air district discretion in requiring an hour-meter with different display specifications than those specified in the control measure
• The compliance date for the clean fuel and fuel additive requirements was extended from January 1, 2005 to January 1, 2006 and for owners and operators of four or more engines (pre-1989 model years) in the same district, from January 1, 2006 to July 1, 2006

NEW SCAQMD RULE TO IMPACT FACILITIES NEAR SCHOOLS

The South Coast Air Quality Management District is seeking public comment on a proposal to promulgate a new, more stringent rule, for sources of air toxics located near schools and possibly other sensitive receptors. The initiative stems from a 2003 White Paper titled “Potential Control Strategies to Address Cumulative Impacts from Air Pollution.” The White Paper was published by the SCAQMD in collaboration with industry groups and the public. Amending Rule 1401- New Source Review of Toxic Air Contaminants to make the risk requirements more stringent for new or relocated facilities near existing schools and other sensitive receptors was one of the strategies identified. Rather than amending the existing rule, the District has chosen to develop Rule 1401.1-Requirements for New and Relocated Facilities Near Schools. Proposed Rule 1401.1 would require a facility-wide cancer risk level of one-in-one million and acute and chronic hazard indices of 1.0 at the school.

District staff committed to a two-step hearing process to identify key policy issues prior to moving on with rulemaking. Staff reports that initially the project will “address existing schools and may later be expanded to address other sensitive receptors, such as medical facilities and commercial day care centers.”

SCAQMD permitting data (over a six year period) shows that 12,000 new or relocated facilities had potential toxic emissions. Out of this group, 316 facilities were located near schools. One hundred and one (101) of these facilities submitted 487 permit applications and were found to have potential toxic emissions. Spray booths comprised 69% of the universe of sources in question.

Staff currently seeks public review and comments. They will then return to the Governing Board for a pre-hearing to highlight policy issues for further discussion.

CITY AND COUNTY GOVERNING BODIES ENCOURAGED TO INCLUDE AIR QUALITY ISSUES IN THEIR GENERAL PLANS

California state law requires each city and county to adopt a General Plan, which addresses community development goals and the distribution of future public and private land use. General plans must address seven elements:

1. Land use
2. Circulation
3. Housing
4. Conservation
5. Open space
6. Noise
7. Safety

Local government usually addresses air quality issues via the land use or conservation provisions of their general plans. However, they have the option of adopting additional elements to address topics such as air quality.

In an effort to encourage “equitable policymaking and enforcement to protect the health of all residents…” the SCAQMD has prepared a guidance document for cities and counties. The guidance document is not a mandate and is designed to help local governing bodies develop a separate air quality element or update an existing element. The main focus is to encourage local government to integrate air quality objectives, policies and strategies in other elements of their general plan. More specifically, the guidance document calls for attention to the relationship between land use and air quality to protect public health and minimize impacts on existing land use patterns and future land use development. Government bodies are encouraged to ensure that “land use plans are implemented to adequately separate sources of air pollution from sensitive receptors such as schools and hospitals.” Perchloroethylene dry cleaners, diesel engines, auto body shops, metal plating facilities, gasoline stations, wood refinishing facilities, warehouses and railyards represent a sample of sources that may emit odors or toxic air contaminants. Additionally, the SCAQMD report urges local government to serve as “advocates” for their city’s residents by investigating and mitigating the health impacts of projects such as facility expansions.

Furthermore, the guidance document addresses a myriad of issues such as transportation, stationary sources of pollution, reduction of particulate matter emissions, energy conservation and public awareness and education. The document is in draft form and will be released to the public once approved by the District’s Governing Board.

RECLAIM UP FOR AMENDMENTS

SCAQMD staff proposes changes to Regulation XX-Regional Clean Air Incentives Market. Said changes are expected to achieve additional Nitrogen Oxides (NOx) reductions and address requirements to demonstrate Best Available Retrofit Control Technology in accordance with the state Health & Safety Code.

Specifically, District staff recommends removal of trading restrictions for power producing facilities, adding an alternative method of compliance demonstration for equipment with high oxygen content in the exhaust, adjusting the testing schedule for equipment operating sporadically and allowing transmission of Continuous Emission Monitoring System (CEMS) data through the AQMD’s website.

The original proposal called for 7.7 tons of NOx reduction, across the board, by the year 2010. Industry groups would prefer a 2 ton per day reduction in 2007 and the same amount in 2008 with a zero reduction in 2009. Industry has also asked the District for additional time to achieve reductions. District staff continues the dialogue with industry to explore their concerns. The rule amendments will go to the Board for deliberations on January 7, 2005.