UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA’s Notice of Proposed Rulemaking and Direct Final Rule

for the

California State Implementation Plan

South Coast Air Quality Management District

Rule 1122, Solvent Degreasers

Prepared by: Francisco Dóñez

October 2005

AGENCY NAME:		South Coast Air Quality Management District (SCAQMD)

SUBMITTED RULE:	Rule 1122, Solvent Degreasers

				Adopted: October 1, 2004

				Submitted: January 13, 2005

				Complete: February 16, 2005

PREVIOUS RULE		No other versions of Rule 1122 have been submitted to

SUBMITTALS:		EPA as a revision to the State Implementation Plan (SIP).

SIP-APPROVED RULE:	Rule 1122, Solvent Degreasers 

				Adopted: July 11, 1997

				Submitted: September 8, 1997

				Approved: April 2, 1999 (64 FR 15922)

RULE SUMMARY

SCAQMD Rule 1122 applies to all persons who own or operate batch-loaded
cold cleaners, open-top vapour degreasers, all types of conveyorized
degreasers, and air-tight and airless cleaning systems that carry out
solvent degreasing operations with a solvent containing Volatile Organic
Compounds (VOCs) or with a NESHAP halogenated solvent.  The most recent
rule amendments reflect the findings of a technology assessment to
evaluate an exemption for certain small degreasers.

Revisions to Rule 1122

Submitted Rule 1122 makes the following changes to the SIP-approved
rule.  Unless otherwise noted, section references apply to the version
of the rule submitted on January 13, 2005.

Section (k)(1)(C) extends the sunset date for the existing exemption
for small-sized degreasers to June 1, 2005.

Section (k)(1)(D) exempts from the rule small degreasers, used in
specific cleaning applications, that are vented to an emission
collection and control system.

Section (k)(1)(E) contains a limited exemption for small degreasers used
only for cleaning electronic components designed to travel over 100
miles above the earth’s surface.

Section (k)(1)(F) provides a permanent exemption for small degreasers
used for research and development/quality assurance programs.

Section (k)(2)(H) extends the exemption for the cleaning of photocurable
resins from stereolithography equipment and models to December 31. 2008.

Section (h)(7) lists compliance test methods for determining the
efficiency of a VOC emission collection and control system.

Additional minor rule language clarifications.



RULE EVALUATION

Generally, SIP rules must be enforceable (see section 110(a) of the
CAA), must require Reasonably Available Control Technology (RACT) for
major sources in ozone nonattainment areas (see section 182(a)(2)(A)),
and must not relax existing requirements (see sections 110(l) and 193).
The SCAQMD regulates an extreme ozone nonattainment area (see 40 CFR
part 81) and Rule 1122 must fulfill RACT. 

Documents used to evaluate the rule include the following: EPA’s
Issues Relating to VOC Regulation Cutpoints, Deficiencies, and
Deviations (May 25, 1988, the “Bluebook”); and EPA Region IX’s
Guidance Document for Correcting Common VOC and Other Rule Deficiencies
(August 21, 2001, the “Little Bluebook”).

Submitted Rule 1122 is consistent with these documents and EPA SIP
approval criteria.  The revised rule contains more stringent criteria
for exempting small degreasers from the rule.  Except for some narrowly
defined applications, small degreasers may only be exempted if they are
vented to a VOC emission control system.  The rule fulfills RACT and all
other requirements mentioned above.

Net Effect on Emissions

No emissions reductions are expected from this rule revision.  According
to the SCAQMD, the VOC emissions associated with the small degreaser
exemptions will continue to be 25 pounds per day.

RECOMMENDED ACTION

I recommend full approval of submitted Rule 1122 under Section 110(k) of
the Clean Air Act to replace the SIP-approved version of Rule 1122.

ATTACHMENTS

SCAQMD Rule 1122, Solvent Degreasers, adopted October 1, 2004.

SCAQMD Rule 1122, Solvent Degreasers, adopted September 8, 1997.

U.S. EPA. Issues Relating to VOC Regulation Cutpoints, Deficiencies, and
Deviations. May 25, 1988 (the "Bluebook," cover only).

U.S. EPA Region IX. Guidance Document for Correcting Common VOC & Other
Rule Deficiencies. August 21, 2001 (the "Little Bluebook," cover only). 

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