AN ENVIRONMENTAL NEWSLETTER FOR THE INDUSTRY

More stringent requirements for solvent cleaning operations

Industry uses solvents during cleaning for repair, maintenance and servicing products, tools machinery and general work areas. These activities fall under the South Coast Air Quality Management District’s Rule 1171 entitled “Solvent Cleaning Operations.” Recently, SCAQMD amended the rule requiring companies to lower the Volatile Organic Compound (VOC) limits for general repair and maintenance operations to 50 grams per liter. These limits became effective in January of this year.

The District is now proposing a new amendment, which would affect additional categories. The proposed requirements are based on the use of aqueous, semi-aqueous or VOC exempt materials and would reduce VOC emissions by over 5 tons per day by the year 2002 and nearly 8 additional tons per day by the year 2004. The overall reductions would total 13 tons per day by the year 2004.

The District is also proposing to delete the vapor pressure requirements for solvent cleaners. Staff believes that the vapor pressure has no role in the quantity of mass emissions produced but only signifies the rate at which the solvents evaporate.

During a public workshop, the staff outlined some of the proposed requirements as follows:
Cont. on Page 3

ACETONE, REGULATIONS AND WORKPLACE

With the EPA decision to exempt acetone as a Volatile Organic Compound (VOC), the industry and the regulators are looking at the solvent as a compliant alternative, which meets industry’s needs. However, acetone’s flammability merits a careful evaluation prior to its use.

Also known as Dimethyl Ketone and 2-Propanone, acetone is often used for cleaning and degreasing in the manufacture of plastics, fibers, drugs and other industries. It is a colorless liquid with a sweet smell. Acetone’s flash point of 00 F (-180 C) makes it an extremely flammable solvent.

In 1995, the EPA evaluated acetone’s ozone-forming properties and determined that it should not be considered a VOC. The agency listed acetone in its Significant New Alternatives Program (SNAP) as an acceptable substitute to ozone-depleting compounds and Hazardous Air Pollutants (HAPs). Local air Districts like the SCAQMD incorporated this decision in their rules and defined acetone as an “Exempt Compound.” Previously companies had to pay emissions fees based on their acetone usage. The “exempt” definition means that emission fees no longer apply.

Presently, upcoming VOC regulations take into consideration the availability of acetone as a compliant substance. Furthermore, the number of chemical formulations incorporating acetone is increasing as acetone emerges as an attractive alternative to other regulated materials.

Acetone is not a priority pollutant under the federal Clean Water Act but if discharged into wastewater may need to be accounted for on a case-by-case basis. Under the Resource
Cont. on Page 2

WHAT’S NEW WITH BACT?

For the past few years, the SCAQMD has been working with the EPA on developing a mechanism to update the Best Available Control Technology Guidelines (BACT). EPA has made a policy determination that allows the guidelines to be updated as frequently as permits are issued. That is, a new BACT determination can be made when the permitting agency becomes aware of the “new BACT.” This usually happens at the time of permitting.

For applicants in the South Coast Basin, a BACT evaluation is triggered at 1 pound per day or more of criteria pollutants emissions. The permitting engineer then researches all decisions made in the country and applies the Lowest Achievable Emission Rate (LAER).

The problem was that agencies throughout the country did not have a mechanism for informing each other of BACT determinations. SCAQMD and the EPA have been dealing with the issue of improving communications. The SCAQMD holds monthly meetings to inform the regulated community about new BACT determinations. Some of the most recent “BACT listings” are:

  • Equipment Category BACT Listing
  • Spray Booth, Wood Furniture High solids stain, waterborne sealer, acetone sealer
  • Flow coater, dip coater Ultraviolet cured sealers and roller coater and topcoats
  • Gas Turbines Catalytic oxidation andabsorption with regeneration
  • Refinery Heater Selective Catalytic Reduction System

The District has moved away from “bright line” BACT determinations. Individual BACT determinations will be done on a case-by-case basis and the final decision will be made by the permitting engineer. The applicant does have an appeal recourse through the BACT Review Committee. According to SCAQMD BACT staff, the listings are intended to report what technologies are currently available. It will be up to the applicant and the permit engineer to resolve issues of applicability at the time of permitting.

Have you filed your Emissions Report?

Who is required to file?

  • Facilities in the Annual Operating Permit Emission Fee Program; those are companies who pay annual emissions for permitted equipment. Such facilities are subject to AQMD Rule 301(e) and are required to file;
  • Facilities emitting 4 tons or more per year of criteria pollutants (VOCs, NOx, SOx, CO, PM, Specific Organics);
  • Facilities which had emissions of specific Toxic Air Contaminants or ozone depleting compounds listed in form TAC;
  • Facilities that received a 1998-99 Annual Emissions Report Package.

What if I missed the deadline?
The SCAQMD 1998-99 Annual Emissions Report was due August 31 of this year. If a facility missed the deadline and owed an emission fee, late payment penalties in the form of a percentage of the emission fees will apply. The penalties are set forth in AQMD Rule 301(E)(8)(B) and are as follows:

Payment received Penalties

  • Less than 30 days after 8/31/99 5% of fees due
  • 30 to 90 days after 8/31/99 15% of fees due
  • 91 days to 1 year after 8/31/99 25% of fees due
  • More than 1 year after 8/31/99 50% of fees due

After submitting my report I found out I estimated emissions incorrectly

Companies who paid their emissions fees on time but underestimated their emissions, which resulted in underpayment to SCAQMD, can re-submit the report subject to underpayment penalties. If the underpayment is corrected within one year from the filing deadline and more than 90% of the amount due was paid, there are no penalties. However, if payment was less than 90% of the amount due, the penalty is 15% of the underpayment amount. When the underpayment is determined more than one year after the deadline, a 50% penalty applies.

A facility can file a refund request when overestimating of the emissions resulted in overpayment to AQMD. The refund request must be submitted in writing as set forth in Rule 301. Form A can also be used to request refunds associated with the current reporting period.

Special circumstances

In some cases, facilities may be able to avoid late penalties even if they file a late emissions report. The AQMD has a Fee Review Committee to handle appeals, extensions and other special situations. When requesting an exemption from late penalties, it is important to provide all relevant documentation to support the validity of the request.

Printing Industry faces new VOC limits

The printing industry is regulated by SCAQMD Rule 1130—Graphic Arts. In response to comments by the Air Resources Board, the SCAQMD plans to reduce the VOC content thresholds for adhesives, fountain solutions and increase add-on control equipment efficiencies. Some exemptions will also be eliminated.

The staff proposal includes a reduction in VOC limits for porous substrate flexographic inks from the current 300 grams per liter to 225 grams per liter, effective January 1, 2000. Inkjet printing will be brought into the rule with a VOC limit of 650 grams per liter. Fountain solutions will be reduced to 80 grams per liter from the current 100 grams per liter. A 100 gram/liter fountain solution will be allowed if it is refrigerated. The highest reduction in the proposal will affect adhesives, which will be reduced by 50% from the current 300 grams/liter to 150 grams/liter. SCAQMD staff commented that the limits are based on the availability of waterborne technology but that other technologies such as energy cure processes will comply with the proposed requirements.

Add-on control efficiencies, which can be used in lieu of low VOC products, will be modified as well:

  • Activity Current control Control Efficiency efficiency effective 1/1/2000
  • Publication Gravure 75% 85%
  • Flexo,Litho,Letterpress Packaging Gravure 67% 75%
  • Inkjet Printing none 85%

Other changes include deleting the small user exemption, establishing a limited exemption for postage stamp cancellation ink and limiting the current proof press exemption to fountain solutions.

The District estimates that 900 facilities with daily emissions of 3.95 tons per day (total inventory) are subject to the rule. The staff reports that the emissions reductions achieved by the amendments amount to 0.56 tons per day.

ACETONE, REGULATIONS (CONT.)

Conservation and Recovery Act (RCRA) acetone may be considered a hazardous waste depending on local regulations.

Due to its fire hazard characteristics, acetone poses a dangerous fire risk. This is a concern many businesses have when considering the switch to acetone. The concern is increased when the material is to be stored next to electrical equipment which cause sparks. Acetone’s flammability hazard must be taken into consideration for purposes of building codes as well as fire codes. There may be storage requirements, depending on the amount of material stored.

The “de-listing” of acetone as a VOC serves as a strong incentive for businesses as well as chemical manufacturers to include the compound in their operations. Many factors, such as acetone’s high flammability and applicability of other regulatory programs should be taken into consideration when making the decision to convert.

MORE STRINGENT REQUIREMENTS (CONT.)

  • Category Current Limit Proposed Limit Proposed Limit (grams/liter) 7/1/02 (grams/liter) 7/1/04 (grams/liter)
  • Product Cleaning/Surface Preparation
  • General 70 50 25
  • Electronics/ Electrical Apparatus 900 500 100
  • Medical Devices/ Pharmaceuticals 900 800 800
  • Repair and Maintenance
  • General 50 50 25
  • Electronics/ Electrical Apparatus 900 900 100
  • Medical Devices/ Pharmaceuticals
  • Tools/Equipment 900 800 800
  • General Work 900 600 600
  • Ink Application Equipment
  • General 100 50 25
  • Flexographic Printing 100 50 25
  • Gravure Printing (publication) 900 750 100
  • Gravure Printing (packaging) 100 50 25
  • Screen Printing 1070 750 100
  • Ultraviolet Inks 800 800 100
  • Specialty Flexo 810 600 100
  • Polyester Resin Application Equip. 50 50 25
  • Coating/Adhesive Application Equip. 950 550 25
  • Ink Application Equip. 100 50 25
  • Litho/Letterpress Roller Wash- Step 1 900 600 100
  • Litho/Letterpress Roller Wash _ Step 2 & Blanket Wash & On-Press Components 900 800 100
  • Removable Parts 900 50 25

Methyl Acetate, Parachlorobenzotrifluoride (PCBTF) and Acetone are some of the potential replacement solvents listed by SCAQMD as compliant with the proposed rule limits. Industry has expressed concern over the cost of some of the replacement solvents.

The proposed rule also calls for a technology assessment in the year 2003. This is another area of concern for the industry representatives who argue that the technology assessment should be conducted before the limits are set in the rule and not after the fact, as it is currently proposed.

The proposal has received little support from industry groups such as The Printing Industries of America, the Flexographic Technical Association, RadTech North America, the Screenprinting Graphics Imaging Association and company representatives. Speakers objected that some aqueous materials tend to damage