UPDATE ON SCAQMD
Some New Provisions Effective in December
The South Coast Air Quality Management District (SCAQMD) has three rules that regulate cleaning solvents. The first rule, Rule 1171 "Solvent Cleaning Operations," regulates solvents used for handwipe cleaning and solvents used in parts cleaners. The second rule, Rule 1122 "Solvent Degreasers," regulates solvents used in vapor degreasers and batch loaded cold cleaners. The third rule, Rule 1124 "Aerospace Assembly and Component Manufacturing Operations," regulates aerospace handwipe cleaning. All of these rules have been modified over the few years and some new provisions have become effective recently.
Rule 1124 was amended in September 2001. It now contains a provision that states "a person shall not atomize any solvent into open air." This means that companies with aerospace operations that involve spray VOC solvent cleaning must find another way of cleaning. The same prohibition on spraying solvents was included in Rule 1171 for non-aerospace cleaning operations many years ago.
Rule 1122 was also amended in September 2001. It bans the use of open top vapor degreasers using toxic solvents like trichloroethylene (TCE), methylene chloride (METH) and perchloroethylene (PERC) on January 1, 2003. Companies that wish to continue using these chlorinated solvents must purchase an airless/airtight cleaning system. Otherwise companies must use a cleaning solvent with 25 grams per liter VOC or less. More than 200 open top vapor degreasers with toxic solvents are still being used in the Basin and nearly all of them rely on PERC. The alternative most likely to be adopted by these companies to comply with the rule is water based cleaning systems.
During the regulatory development, many solvent and degreaser equipment suppliers argued that vapor degreasers were regulated by the Halogenated Solvents Cleaning NESHAP and they believed that regulation was stringent. They opposed any further regulation of toxic solvents by SCAQMD. Recent inspections by EPA and SCAQMD, however, found that virtually no companies with open top vapor degreasers are in compliance with the NESHAP.
Rule 1122 also calls for a ban on open top vapor degreasers using solvents with a VOC content greater than 25 grams per liter by January 1, 2006. This will affect companies using degreasers with n-propyl bromide (see article in this issue on nPB), isopropyl alcohol and blends of VOC solvents with HCFC-225, HFC-43-10 and the HFEs. Companies using these solvents should begin investigating alternatives.
In January of 1999, a provision of Rule 1122 became effective. It required companies using batch loaded cold cleaners (BLCCs) and conveyorized cold cleaning units to adopt cleaners that had a VOC content of 50 grams per liter or less. The recent amendment of the rule requires the cleaners to have an even lower VOC content, 25 grams per liter, by January 1, 2003. Companies using BLCCs and conveyorized cold cleaners should investigate their current cleaner and ensure that it has a VOC content of 25 grams per liter. If it does not, the company should begin testing alternatives that do meet the rule requirements.
Rule 1122 contains an exemption for BLCCs and vapor degreasers with open top surface areas that are less than one square foot or with a capacity of two gallons or less that use VOC solvents for various types of cleaning operations. Some of the operations covered by the exemption are electrical, high precision optics or electronics cleaning and solar cell, laser and fluid system cleaning. This exemption expires in January 2003 so companies using solvents with a VOC content of more than 25 grams per liter should begin investigating alternatives.
Rule 1171 was amended in October of 1999. It further regulated several categories of cleaning. The regulation reduced the allowed VOC content of cleaning agents on December 1, 2001 and July 1, 2005. The December 1, 2001 date has already passed and companies using the affected operations should ensure they are meeting the new VOC limits.
Three of the major regulated categories in Rule 1171 are electrical apparatus components and electronic components, adhesives and coatings application equipment and ink application equipment. The table below summarizes the December 1, 2001 limits for some of the Rule 1171 categories
|Product Cleaning During Manufacture or Surface Preparation||
|Product Cleaning During Manufacture-Electrical Apparatus Components & Electronic Components||
|Cleaning of Coatings or Adhesives Application Equipment||
|Cleaning of Ink Application Equipment||
|Speciality Flexographic Printing||
|Roller Wash-Step 1||
|Roller Wash-Step 2, Blanket Wash and On-Press Components||
|Removable Press Components||
Companies with general handwipe cleaning operations were required to use solvents with 70 grams per liter VOC content or less several years ago. In December of 2001, the limit declined to 50 grams per liter. Companies with handwipe operations should check the VOC content of their cleaners to ensure they are in compliance with the rule.
Companies that manufacture electronic devices with handwipe operations can no longer use isopropyl alcohol (IPA) in their cleaning processes. Companies using IPA should examine alternatives.
Most solvents offered for cleaning coating and adhesive spray guns are mineral spirits and blends of mineral spirits with other VOC solvents or MEK, toluene and xylene or blends of these chemicals. These solvents and blends no longer meet the rule requirement of 550 grams per liter.
Most flexographic printers are already using water cleaning systems or non-solvent cleaning processes. These companies should check their cleaners and make sure they meet the new level of 50 grams per liter.
Screen printing companies generally use very high VOC solvent blend cleaners that contain mineral spirits, glycol ethers, toluene, xylene and MEK. Effective December 2001, they must use cleaners with a much lower VOC content of 750 grams per liter.
Lithographic printing companies must be using cleaners with 50 grams per liter or less for cleaning their off-press equipment. This is a new requirement and the VOC content of the allowed cleaners is very low. These printing companies must also be using blanket and roller wash solvents with a VOC content of between 600 and 800 grams per liter currently.
Many specialty flexographic printers are already using water-based cleaners. These companies would easily comply with the new VOC content level of 600 grams per liter.
For questions on the regulatory
requirements of the three rules, call IRTA. For companies that
wish to identify, test and implement alternatives, call IRTA for
DRY CLEANERS ARGUE FOR CONTINUED USE OF PERC
Several months ago, the South Coast Air Quality Management District (SCAQMD) proposed a phaseout of perchloroethylene (PERC) dry cleaning machines. The original proposal would have required existing PERC users to stop using the chemical in dry cleaning machines by 2011. The District held several meetings to solicit input from the dry cleaning industry and modified the proposed phaseout. Under the current revised proposal, the District would allow dry cleaning equipment with primary and secondary controls to operate with PERC until 2018.
Over the last 10 years or so, there has been increasing pressure on dry cleaners from landlords and regulatory agencies to convert away from PERC. Most dry cleaners have contaminated sites. At one time, it was permissible to discharge separator water to the sewer and this practice led to the contamination of nearly all sites where PERC cleaning machines were used. At this stage, many landlords are refusing to renew leases for dry cleaners unless the cleaners agree to use an alternative cleaning solvent. Some dry cleaners with contaminated sites have been forced to clean them up and this is a very expensive undertaking. Over time, many other dry cleaners may be forced to pay for cleanup of contaminated sites. The regulatory agencies now have very stringent regulations on emissions of PERC, a suspect carcinogen and on separator water and hazardous waste disposal.
It is not clear why a dry cleaner would want to purchase a new PERC machine and risk liability and constant regulatory pressure. There are now a number of alternatives available. In particular, the new high flash point petroleum machines are being increasingly adopted by dry cleaners. The industry is very familiar with petroleum solvent which has been used by some dry cleaners for decades. The new machines for use with the higher flashpoint petroleum solvents are very tight and emissions are low. In addition, the cost of the petroleum machines is now comparable to PERC machines. Dry cleaners, by opting to purchase a petroleum machine instead of a PERC machine, can avoid future liability from their workers and for site contamination. It does not seem reasonable that dry cleaners would want to purchase new PERC machines that would threaten their livelihood.
On the one hand, petroleum is a less aggressive solvent than PERC so it does not clean as well. On the other hand, because it is a less aggressive solvent, petroleum can clean more delicate items like drapes, furs and suedes. Petroleum is also more convenient because colors can be mixed during cleaning.
The bottom line is that smart dry cleaners should want to convert away from PERC as soon as they need to purchase a new machine. It should not be a hardship on any dry cleaner to adopt an alternative by 2018.
SCAQMD PLANS TO MODIFY ADHESIVES RULE TO BAN METHYLENE CHLORIDE
At the IRTA adhesives meeting on November 7, 2001 (see article in this issue), a South Coast Air Quality Management District (SCAQMD) representative indicated that the District plans to modify Rule 1168 "Adhesive and Sealant Applications" early in 2002. The District has found that a few applications require exemptions and these will be added to the rule. In addition, the District plans to ban the use of methylene chloride (METH) based adhesives in the Basin.
In September 2000, the SCAQMD amended Rule 1168 to include a prohibition of sale. This prohibition became effective on September 1, 2001 and it made it illegal for adhesive formulators and distributors to sell adhesives with a VOC content that exceeds the levels specified in the rule. In the past, the rule made it illegal only for the user of the adhesive if the VOC content exceeded the specified limits. Once the September 2000 prohibition became effective, adhesive suppliers stopped selling adhesives with high VOC content but they converted many of their customers to METH based adhesives. Because METH is exempt from VOC regulations, the sale of adhesives containing METH was not prohibited in the rule.
Over the last year or so, many companies that were using high VOC adhesives have converted to METH based adhesives. Since METH is a suspect carcinogen and regulated as a toxic, this is not a good outcome. When the District realized that this conversion had occurred, they decided to amend the rule once again to ban METH based adhesives. The SCAQMD plans to hold a workshop to discuss these changes in January, 2002.
Alternative adhesives that are not based on METH or on high VOC content are available. These include water-based adhesives or acetone based adhesives. Acetone is exempt from VOC regulations and is very low in toxicity.
Companies that want more information on the alternative adhesives should call IRTA at (310) 453-0450.
n-PROPYL BROMIDE DEFINITELY A REPRODUCTIVE TOXIN
Some time ago, one of the producers of n-propyl bromide (nPB), Great Lakes Chemical, decided to stop production of the chemical and recommended an exposure level of 10 ppm for companies still using the chemical. Another chemical producer, AtoFina, decided not to produce nPB for solvent use because they believed that in those applications "exposures cannot easily be kept under control;" the company concluded that the exposure level of nPB in humans should not exceed 5 ppm.
The Occupational Safety and Health Administration (OSHA) and the National Institute for Occupational Safety and Health (NIOSH) nominated nPB and a contaminant in nPB, 2-bromopropane (2BP), for reproductive toxicity and carcinogenicity testing. Those tests have been initiated. Results of a Japanese animal study indicated that nPB was a reproductive toxin. More recently, an animal study conducted by an industry group in the U.S. was completed and the results of this study agreed generally with the results of the Japanese study.
The National Toxicology Program, the National Institute of Environmental Health Sciences and the Center for the Evaluation of Risks to Human Reproduction has completed an evaluation of nPB and 2-BP. The group assembled a panel of experts to review the available toxicity data and a meeting of this group was held on December 5 through December 7, 2001. The conclusions of the group are available in draft form and they state that "results provide convincing evidence that 1-BP is a reproductive toxicant." nPB is also known as 1-BP.
EPA's Significant New Alternatives Policy (SNAP) program is evaluating the toxicity of nPB and 2-BP and is expected to publish a notice in the Federal Register early in 2002. The SNAP office has the authority under the Clean Air Act to establish a recommended exposure level for the chemicals.
The California Department of Health Services Hazard Evaluation System & Information Service (HESIS) group is also evaluating the toxicity of nPB. HESIS is convinced that the chemical poses a threat to workers and is planning to issue a Hazard Alert in California.
nPB is currently used in cleaning and adhesive applications. In Southern California, some companies are using the chemical for vapor degreasing. There are alternatives to nPB in vapor degreasing and companies should identify, test and implement these alternatives as quickly as possible. There are also alternatives to nPB in adhesive applications and companies should work on adopting alternatives in this area as well. There is no doubt that the chemical is a reproductive toxin and companies still using nPB are risking liability if they continue to use it.
The South Coast Air Quality Management District (SCAQMD) recently modified Rule 1122, the regulation that affects vapor degreasing (see article in this issue). The rule bans the use of open top vapor degreasers containing solvents with a VOC content above 25 grams per liter in 2006. nPB has a much higher VOC content and can no longer be used except in an airless/airtight degreaser at that time. Because many alternatives are available, companies should convert away from the chemical and they should do it soon instead of waiting until the rule becomes effective.
The SCAQMD also modified Rule 1168, the regulation that affects adhesives. The District added a prohibition of sale that became effective in September, 2001 (see article in this issue). Adhesive formulators and distributors are no longer able to offer for sale adhesives that have higher VOC content than allowed by the rule. This means that nPB cannot be used in adhesive formulations in the South Coast Basin. Vendors are no longer selling nPB based adhesives in Southern California.
For information on alternatives to nPB in cleaning or adhesive applications, call IRTA at (310) 453-0450.
IRTA ADHESIVES MEETING SPURS DISCUSSION ABOUT METHYLENE CHLORIDE AND n-PROPYL BROMIDE
Over the last three years, IRTA and the University of Tennessee have been working on a project sponsored by EPA's Design for the Environment Program. The project focused on adhesives used in foam fabrication, upholstered furniture manufacture and mattress manufacture. The aim of the project was to evaluate the cost and performance of alternative adhesives and to investigate the risks of the different adhesive types to workers and to the community.
In 1997, the Occupational Safety and Health Administration (OSHA) finalized a regulation on methylene chloride (METH), one of the chemicals that was widely used in adhesives. OSHA lowered the Permissible Exposure Level (PEL) for METH from 500 to 25 ppm. The regulation also established an action level at 12.5 ppm; companies with worker exposure above this level are required to perform monitoring and medical surveillance. The EPA sponsored project was motivated by the METH regulation and its aim was to evaluate and compare METH adhesives and alternative adhesives.
IRTA assembled a working group during the project that included representatives from companies that use adhesives, companies that formulate and sell adhesives, trade associations of various types, regulatory agencies and the environmental community. A meeting of about 30 of the working group members was held on November 7, 2001 at Southern California Edison's CTAC facility. The purpose of the meeting was for IRTA and the University of Tennessee to present the results of the project analysis and to receive comments from the working group.
In foam fabrication, there are a range of adhesive types that were considered. These include methylene chloride (METH), n-propyl bromide (nPB), acetone, acetone/heptane and water-based adhesives. The project results indicated that larger companies and companies in California had adopted water-based and acetone adhesives. Smaller companies, largely in the Southeastern United States, had adopted nPB based adhesives. Throughout the country, there are still many smaller foam fabricators that are continuing to use METH adhesives.
The project findings indicated that the cost of using the alternative adhesives in foam fabrication was roughly the same. The cost of nPB adhesives was higher but some companies that adopted these adhesives implemented practices to minimize their adhesive use at the same time. The project findings also indicated that the risk posed by the use of all of the solvent based adhesives was high. The risk posed by the use of METH and nPB adhesives was higher than the risk posed by acetone adhesives. METH is a suspect carcinogen and nPB is a reproductive toxin and may also be a carcinogen (see article on nPB in this issue). The risk posed by the use of water-based adhesives was the lowest.
There was considerable discussion
at the working group meeting about the continued use of METH and
nPB adhesives by many smaller companies. A few of the adhesive
vendors at the meeting do sell METH and nPB adhesives and they
indicated that they would continue to do so unless a regulatory
agency banned the chemicals. A representative from the South
Coast Air Quality Management District (SCAQMD) indicated that
the District planned to ban the use of METH in adhesives over
the next several months (see article on the regulation in this
issue). In the rest of the country, METH would be regulated only
by OSHA and OSHA enforcement of the regulation has not been rigorous.
A representative of the EPA Significant New Alternatives Policy
(SNAP) program indicated that his group would soon publish a proposed
regulation on nPB that would establish a worker exposure level
(see article in this issue) but the regulation would not ban use
of the chemical.
The continued use of METH and nPB adhesives places workers and community members that live in the areas surrounding foam fabrication facilities at risk. Most of the people at the meeting knew of many companies using METH adhesives but everyone agreed that none of the plants they knew of were in compliance with the OSHA regulation. The action that will be taken by SCAQMD will prevent the use of METH adhesives in Southern California but will not prevent it elsewhere. The SCAQMD regulation already has a provision that prevents the use of nPB adhesives in Southern California. Again, however, there are no regulations at all on the chemical in the rest of the country.
IRTA and the University of Tennessee have prepared three draft documents. These include a cost and performance analysis, a risk assessment and an executive summary. The draft documents will be revised over the next few months and they will be available. IRTA has also prepared three case study documents that summarize the conversions of foam fabricators, upholstered furniture manufacturers and mattress manufacturers. To obtain copies of the documents, contact IRTA at (310) 453-0450.
IRTA HAS SUCCESSFUL BATCH LOADED COLD CLEANING CONFERENCE
Case Studies on Conversions Available From IRTA
IRTA arranged and held a conference on alternatives to VOC and toxic solvents used in batch loaded cold cleaning operations. The conference was co-sponsored by EPA Region IX, Cal/EPA's Department of Toxic Substances Control, the South Coast Air Quality Management District, Los Angeles County Sanitation Districts and Los Angeles City Bureau of Sanitation. It was held at Southern California Edison's CTAC facility in Irwindale on November 15.
The conference featured displays by several vendors and it drew about 90 attendees from companies seeking alternatives, air, wastewater, hazardous waste and worker exposure regulatory agencies and vendors offering alternative equipment and formulations.
The conference speakers provided an update on the regulations. One issue that prompted considerable discussion was the inadequacy of Material Safety Data Sheets (MSDSs). Company representatives complained that MSDSs commonly had limited and probably incorrect information and that this was a constant source of frustration.
Other speakers were representatives from companies that had made successful conversions to alternatives. One of the issues that was discussed at some length was the conversion away from petroleum based lubricants to alternative lubricants. One company representative indicated that his company had recently converted most of their machines to a semi-synthetic lubricant which is water dilutable. He stated that cleaning with water-based cleaners is easier and less costly than if his company had continued to use petroleum based lubricants. IRTA is conducting a new project on alternative lubricants (see article in this issue) and would like to identify volunteer companies that have an interest in making a lubricant conversion.
IRTA handed out a case study document to all the attendees. It featured the conversions of 11 companies, many of them speakers at the conference. Each of the case studies describes the company briefly, the batch loaded cold cleaning operation(s), the cleaner used originally by the company and the alternative system(s) adopted by the company. They also include a cost comparison of the original and alternative cleaning systems.
If you want copies of the case study document or the detailed report for the project, contact IRTA at (310) 453-0450.
IRTA SEEKING PLATING FACILITIES FOR PERC DEGREASER CONVERSION PROJECT
In September 2001, the South Coast Air Quality Management District (SCAQMD) amended Rule 1122 "Solvent Degreasers." One of the amendments affects open top vapor degreasers. The rule essentially bans the use of open top vapor degreasers that rely on certain toxic solvents including trichloroethylene (TCE), methylene chloride (METH) and perchloroethylene (PERC) after January 1, 2003. Companies that wish to continue using these solvents must purchase an airless/airtight degreaser.
Very few companies in the Basin use TCE or METH in vapor degreasing operations but more than 200 use PERC. To comply with the January 1, 2003 ban date, most companies will convert to alternatives rather than purchase expensive airless/airtight degreasers. Nearly all will adopt water-based cleaning processes.
IRTA is beginning a project sponsored by several of IRTA's Pollution Prevention Center partners including EPA Region IX, Cal/EPA's Department of Toxic Substances Control, Los Angeles County Sanitation Districts and Los Angeles City Bureau of Sanitation. The aim of the project is to work with and assist ten plating facilities currently using PERC degreasers in converting to alternatives to comply with SCAQMD Rule 1122. In many cases, these facilities are small businesses with limited resources and time to focus on cleaning conversions. IRTA is seeking platers in the jurisdiction of the Los Angeles County Sanitation Districts and Los Angeles City Bureau of Sanitation to participate in the project. IRTA would offer technical assistance to participating companies free of charge.
Plating companies in the city or county of Los Angeles that are interested in working on the project should contact Katy Wolf at IRTA at (310) 453-0450.
PROJECT ON ALTERNATIVE OILS
Seeks Participating Companies
IRTA has received a grant from EPA under the Environmental Justice Pollution Prevention (EJP2) program to assist companies in testing and converting to alternatives to traditional petroleum based lubricants. Many companies with cutting, stamping, honing or forming operations have older machines and are using petroleum lubricants.
Petroleum lubricants are diluted with kerosene or mineral spirits in about a 10 to one ratio of solvent to oil. The kerosene or mineral spirits are classified as VOC solvents and emissions can contribute to smog. The SCAQMD may eventually regulate these emissions. In many cases, the use of petroleum lubricants generates toxic mists that expose workers. The Occupational Safety and Health Administration is setting standards for exposure to these mists. Many petroleum lubricants have extreme pressure additives called chlorinated paraffins and some of these chemicals are classified as carcinogens. The European Union is in the process of banning certain chlorinated paraffins in these products.
Alternatives to traditional petroleum lubricants are available. Semi-synthetic and synthetic lubricants are used widely in new machines and they are diluted with water rather than with mineral spirits or kerosene. Use of these materials can make it easier to use water-based cleaners for cleaning the parts. Vegetable oils are also available as alternatives to petroleum lubricants. These oils are based on natural products like soy or canola.
The aim of IRTA's new EPA EJP2 project is to work with companies to assist them in converting from petroleum to alternative lubricants. Conversion will reduce VOC emissions, eliminate dangerous mists and eliminate the use of chlorinated paraffin additives. IRTA plans to investigate all of the issues involved in the conversion during the project. Issues like cost, recycling capability and formation of bacteria will be evaluated.
IRTA is seeking companies that would like to participate in the project. Candidates include companies that have recently converted to alternative lubricants, companies that are in the process of converting to alternative lubricants or companies that would like to test and convert to alternative lubricants. IRTA staff will assist these companies in the conversion and in analyzing and comparing the costs of the original and alternative systems.
Companies that would like to participate in the project should contact Katy Wolf at IRTA at (310) 453-0450.
NEW SENATE BILL WILL REDUCE DISPOSAL COST FOR AUTO REPAIR SHOPS
In September, California Senate Bill (SB) 271 was approved by the Governor. It allows "parts cleaning solvents, including aqueous cleaning solvents" to be manifested under new procedures that should be less costly for users of water-based cleaners in repair and maintenance cleaning operations.
In the past, mineral spirits parts cleaning solvents could be handled through a so-called milk run procedure if they were not classified as RCRA hazardous waste. Water-based cleaners, however, could not be handled through the milk run procedure. SB 271 changes the law to allow spent water-based cleaners that are not classified as RCRA hazardous waste to be handled through this new procedure.
The milk run manifest procedure permits a licensed hauler of the waste to consolidate all the similar waste types in a milk run; the hauler can use one manifest for all of the combined waste and is not required to issue a manifest to each generator. This should lower the cost of hauling the spent water-based cleaners used in parts cleaning in auto repair and industrial facilities.
Most of the waste generated from repair and maintenance cleaning operations is not likely to be classified as RCRA hazardous waste. Thus most companies can take advantage of the new procedures. Companies that generate RCRA hazardous waste in quantities less than 100 kilograms per month (about 26 gallons of water cleaning waste) can also take advantage of the milk run manifesting procedure. Parts cleaners often contain less than 26 gallons so companies that change out one parts cleaner in a month (assuming it holds 26 gallons or less) can benefit from the reduced hauling cost.
For questions regarding the new
bill, call IRTA at (310) 453-0450.