EL DORADO COUNTY AIR QUALITY MANAGEMENT DISTRICT
RULE 235 - SURFACE PREPARATION AND CLEANUP
(Adopted: June 27, 1995)
- PURPOSE: The purpose of this rule is to limit
the emission of volatile organic compounds (VOC) from solvent cleaning operations, and from the storage and disposal
of materials used in solvent cleaning operations.
- APPLICABILITY: This rule applies to any owner
or operator of any facility that uses VOC-containing materials in the production, repair, maintenance, or servicing
of parts, products, tools, machinery, equipment, or general work areas or that stores and/or disposes of VOC-containing
materials used in solvent cleaning operations.
- EXEMPTION, SMALL USER: The provisions of Section
235.3 A. of this rule shall not apply to facilities that use 10 gallons or less of solvents, as defined in Section
235.2 Z. of this rule in any one calendar year provided that daily use does not exceed one liter.
- EXEMPTION, SOLVENT CLEANING OPERATIONS: Cleaning
carried out in batch-loaded cold cleaners, open-top vapor degreasers, conveyorized degreasers, or film cleaning
machines which are subject to Rule 225 ORGANIC SOLVENT CLEANING AND DEGREASING OPERATIONS, are not subject to the
provisions of Section 235.3 of this rule.
- EXEMPTION, DRY CLEANING OPERATIONS: Dry cleaning
operations subject to Rule 218 PERCHLOROETHYLENE DRY CLEANING OPERATIONS, are not subject to the provisions of
Section 235.3 of this rule.
- EXEMPTION, WIPE CLEANING: Wipe cleaning is
not subject to the provisions of Section 235.3 A. when carried out for any of the applications listed below.
- Cleaning of solar cells, laser hardware, and high precision optics.
- Cleaning for: conducting performance laboratory tests on coatings, adhesives, or inks;
research and development programs; and laboratory tests in quality assurance laboratories.
- Cleaning of polycarbonate plastics.
- EXEMPTION, AUTOMATED SPRAY EQUIPMENT SYSTEMS:
Internal cleaning of the tips of automated spray equipment systems, except for robotic systems, and cleaning with
spray bottles or containers described in Section 235.3 B.2. of this rule, are not subject to the provisions of
Section 235.3 E.1. of this rule.
- EXEMPTION, AEROSOL PRODUCTS: Cleaning with
aerosol products shall not be subject to the provisions of Sections 235.3 A. and 235.3 E.1. of this rule if 160
fluid ounces or less per day per facility of aerosol products are used.
- EXEMPTION, HIGH-PRECISION OPTICS: Cleaning
of cotton swabs to remove cottonseed oil before cleaning of high-precision optics shall not be subject to the provisions
of Section 235.3 A. of this rule.
- EXEMPTION, JANITORIAL CLEANING: Janitorial
cleaning is not subject to the provisions of Section 235.3 of this rule.
- EXEMPTION, CURED COATINGS: The stripping of
cured coatings, cured adhesives, and cured inks is not subject to the provisions of Section 235.3 of this rule.
- EXEMPTION, PROHIBITORY RULES: Any process which
is regulated by the District under Rule 230 Automotive Refinishing Operations or Rule 237 Wood Products Coatings
is not subject to the requirements of this rule.
- AEROSOL PRODUCT: A hand-held, non-refillable
container which expels pressurized product by means of a propellant-induced force.
- APPURTENANCES: Accessories to an architectural
structure, including, but not limited to: hand railings, cabinets, bathroom and kitchen fixtures, fences, rain-gutters
and down-spouts, window screens, lamp-posts, heating and air conditioning equipment, other mechanical equipment,
large fixed stationary tools and concrete forms.
- CURED COATINGS, CURED INKS, AND CURED ADHESIVES:
Coatings, inks, and adhesives which are dry to the touch.
- ELECTRONIC ASSEMBLY: All portions of an assembly,
including circuit board assemblies, printed wire assemblies, printing wiring boards, soldered joints, ground wires,
bus bars, and other electrical fixtures, except for the actual cabinet in which the assembly is housed.
- EXEMPT COMPOUNDS: The following compounds are
exempt from the definition of VOC in Section 235.2 HH:
- Carbon Dioxide
- Carbon Monoxide
- Carbonic Acid
- Metallic Carbides or Carbonates
- Ammonium Carbonate
- Methylene Chloride
- Dichlorotrifluoroethane (HCFC-123)
- 2-Chloro-1,1,1,2-tetrafluoroethane (HCFC-124)
- Trichlorofluoromethane (CFC-11)
- Dichlorodifluoromethane (CFC-12)
- Trichlorotrifluoroethane (CFC-113)
- Dichlorotetrafluoroethane (CFC-114)
- Chloropentafluoroethane (CFC-115)
- Pentafluoroethane (HFC-125)
- 1,1,2,2-Tetrafluoroethane (HFC-134)
- Tetrafluoroethane (HFC-134a)
- Dichlorofluoroethane (HCFC-141b)
- Chlorodifluoroethane (HCFC-142b)
- 1,1,1-Trifluoroethane (HFC-143a)
- Chlorodifluoromethane (HCFC-22)
- Trifluoromethane (HFC-23)
- 1,1-Difluoroethane (HFC-152a)
- Parachlorobenzotrifouride (PCBTF)
- Volatile cyclic and linear methyl siloxanes (VMS)
- The following four classes of perfluorocarbon compounds:
- Cyclic, branched, or linear, completely fluorinated alkanes.
- Cyclic, branched, or linear, completely fluorinated ethers, with no unsaturations.
- Cyclic, branched, or linear, completely fluorinated tertiary amines, with no unsaturations.
- Sulfur-containing perfluorocarbons with no unsaturations and with sulfur bonds only
to carbon and fluorine. Perfluorocarbon compounds shall be assumed to be
absent from a product or process unless a manufacturer or facility operator identifies the specific compounds and
the amounts present in the product or process and provides a validated test method which can be used to quantify
the identified compounds.
- FACILITY: A business or businesses engaged
in solvent cleaning operations which are owned or operated by the same person or persons and are located on the
same or contiguous parcels.
- FLEXOGRAPHIC PRINTING: The method in which
the image area is raised relative to the non-image area and utilies flexible rubber or other elastomeric plate
and rapid drying liquid inks.
- GRAMS OF VOC PER LITER OF MATERIAL: The weight
of VOC per volume of material and can be calculated by the following equation:
= ( WS
- WW - WES )/ VM
GRAPHIC ARTS: All screen, gravure, letterpress,
flexographic, and lithographic printing processes.
GRAVURE PRINTING: An intaglio process in which
the ink is carried in minute etched or engraved wells on a roll or cylinder. The excess ink is removed from the
surface by a doctor blade.
JANITORIAL CLEANING: The cleaning of building
or facility components, such as the floor, ceiling, walls, windows, doors, stairs, bathrooms, etc.
LETTERPRESS PRINTING: The method in which the
image area is raised relative to the nonimage area and the ink is transferred to the paper directly from the image
LITHOGRAPHIC PRINTING: A plane-o-graphic method
in which the image and nonimage areas are on the same plane.
LIQUID LEAK: A visible liquid solvent leak
from a container at a rate of more than three (3) drops per minute, or a visible liquid mist.
MAINTENANCE CLEANING: A solvent cleaning operation
carried out to keep parts, products, tools, machinery, equipment excluding application equipment, or general work
areas in clean and good operational condition.
MANUFACTURING PROCESS: The process of making
goods or articles by hand or by machinery.
NON-ABSORBENT CONTAINERS: Containers made of
nonporous material which do not allow the migration of the liquid solvent through them.
NON-ATOMIZED SOLVENT FLOW: The use of a solvent
in the form of a liquid stream without atomization to remove uncured adhesives, uncured inks, uncured coatings,
and contaminants from an article.
NON-LEAKING CONTAINERS: Containers without
PERSON: Any individual, firm, association,
organization, partnership, business, trust, corporation, company, contractor, supplier, installer, user or owner,
or any state or local governmental agency or public district or any other officer or employee thereof. PERSON also
means the United States or its agencies to the extent authorized by Federal law.
PRINTING: Any operation in the graphic arts
that imparts color, design, alphabet, or numerals on a substrate.
REMOTE RESERVOIR COLD CLEANER: A cleaning device
in which liquid solvent is pumped from a solvent container to a sink-like work area and the solvent from the sink-like
area drains into an enclosed solvent container while parts are being cleaned.
REPAIR CLEANING: A solvent cleaning operation
or activity carried out during a repair process.
REPAIR PROCESS: The process of returning a
damaged object or an object not operating properly to good condition.
SCREEN PRINTING: A process in which the printing
ink passes through a web or fabric to which a refined form of stencil has been applied. The stencil openings determine
the form and dimensions of the imprint.
SOLVENT: A VOC-containing liquid used to perform
solvent cleaning operations.
SOLVENT CLEANING: The removal of loosely held
uncured adhesives, uncured inks, uncured coatings, and contaminants which include, but are not limited to, dirt,
soil, and grease from parts, products, tools, machinery, equipment, and general work areas. Each distinct method
of cleaning in a cleaning process which consists of a series of cleaning methods shall constitute a separate solvent
SOLVENT CONTAINER: That part of a cleaning
device that holds the solvent.
SOLVENT FLUSHING: The use of solvent to remove
uncured adhesives, uncured inks, uncured coatings, or contaminants from the internal surfaces and passages of the
equipment by flushing solvent through the equipment.
STRIPPING: The removal of cured inks, cured
adhesives, and cured coatings.
SURFACE PREPARATION: The removal of contaminants
such as dust, soil, oil, grease, etc., prior to coating, adhesive, or ink applications.
ULTRAVIOLET INKS: Inks which dry by polymerization
reaction induced by ultraviolet radiation.
VOC COMPOSITE PARTIAL PRESSURE: The sum of
the partial pressures of the compounds defined as VOCs. VOC composite partial pressure is calculated as follows:
- DVOC = Grams of VOC per liter of material
- WS = Weight of volatile compounds in grams
- WW = Weight of water in grams
- WES = Weight of exempt compounds in grams
- VM = Volume of material in liters
VOLATILE ORGANIC COMPOUND (VOC): Any chemical
compound containing at least one atom of carbon, excluding exempt compounds.
WIPE CLEANING: The method of cleaning a surface
by physically rubbing it with a material such as a rag, paper, or a cotton swab moistened with a solvent.
- PPC = VOC composite partial pressure at 20oC, in mm
- HgVPi = Vapor pressure of the "i"th VOC compound at 20oC, in mm
- HgWi = Weight of the "i"th VOC compound, in grams
- WW = Weight of water, in grams
- WE = Weight of exempt compound, in grams
- MWi = Molecular weight of the "i"th VOC compound, in g/(g-mole)
- MWW = Molecular weight of water, in g/(g-mole)
- MWE = Molecular weight of exempt compound, in g/(g-mole)
- SOLVENT REQUIREMENTS: A person shall not use
a solvent to perform solvent cleaning operations, including the use of cleaning devices or methods, unless the
solvent complies with the applicable requirements set forth below:
- On or after January 1, 1996, the solvents used on substrates during the manufacturing
process or for surface preparation prior to coating, adhesive, or ink applications shall have a VOC content of
70 grams or less of VOC per liter of material.
- On and after January 1, 1996, the solvents used for maintenance and repair cleaning
shall have a VOC content of 900 grams or less of VOC per liter of material and a VOC composite partial pressure
of 20 mm Hg or less at 20oC (68oF).
- On and after January 1, 1996, the solvents used for cleaning coatings or adhesives
application equipment shall have a VOC content of 950 grams or less of VOC per liter of material and a VOC composite
partial pressure of 35 mm Hg or less at 20oC
- On and after January 1, 1996, the solvents used for cleaning polyester resin application
equipment shall comply with one of the limits specified below:
- a. The solvent shall have a VOC content of 200 grams or less of VOC per liter of material;
- b. The solvent shall have a VOC content of 1100 grams or less of VOC per liter and
a VOC composite partial pressure of 1.0 mm Hg or less at 20oC (68oF); or
- c. A solvent reclamation system shall be used if the solvent exceeds the limits of
Sections 235.3 A.4.a. and 235.3 A.4.b., and the solvent usage at the facility exceeds four gallons on any one day.
The reclamation system shall operate at least at 80 percent efficiency, on a mass basis. The solvent residues for
on-site reclamation systems shall not contain more than 20 percent VOC, by weight.
- On and after January 1, 1996, the solvent used for cleaning of ink application equipment
in graphic arts shall meet the limits specified below:
- a. The solvents used in screen printing shall have a VOC content of 1070 grams or
less of VOC per liter of material and a VOC composite partial pressure of 5 mm Hg or less at 20oC (68oF).
- b. The solvents used in lithographic and letterpress printing not subject to the provisions
of Section 235.3 A.5.d shall have a VOC content of 900 grams or less of VOC per liter of material and a VOC composite
partial pressure of 25 mm Hg or less at 20oC
- c. The solvents used in graphic arts printing operations not subject to the provisions
of Sections 235.3 A.5.a., 235.3 A.5.b., or 235.3 A.5.d. shall have a VOC content of 100 grams or less of VOC per
liter of material and a VOC composite partial pressure of 3 mm Hg or less at 20oC (68oF).
- d. The solvents used in graphic arts printing operations, except screen printing to
remove ultraviolet inks from application equipment, shall have a VOC content of 800 grams or less of VOC per liter
of material and a VOC composite partial pressure of 33 mm Hg or less at 20oC (68oF).
- On and after January 1, 1996, the solvents used for manufacturing or maintenance cleaning
of electronic assemblies shall have a VOC content of 900 grams or less of VOC per liter of material and a VOC composite
partial pressure of 33 mm Hg or less at 20oC
- CLEANING DEVICES AND METHODS REQUIREMENTS:
On or after January 1, 1996, a person shall not perform solvent cleaning operations unless one of the following
cleaning devices or methods is used:
- Wipe cleaning;
- Spray bottles or containers with a maximum capacity of 16 fluid ounces from which
solvents are applied without a propellant
- Cleaning equipment which has a solvent container that can be, and is, closed during
cleaning operations, except when depositing and removing objects to be cleaned, and is closed during nonoperation
with the exception of maintenance and repair to the cleaning equipment itself;
- Non-atomized solvent flow method where the cleaning solvent is collected in a container
or a collection system which is closed except for solvent collection openings and, if necessary, openings to avoid
excessive pressure build-up inside the container; or,
- Solvent flushing method where the cleaning solvent is discharged into a container
which is closed except for solvent collection openings and, if necessary, openings to avoid excessive pressure
build-up inside the container. The discharged solvent from the equipment must be collected into containers without
atomizing into the open air. The solvent may be flushed through the system by air
or hydraulic pressure, or by pumping.
- STORAGE AND DISPOSAL: All VOC-containing materials
used in solvent cleaning operations, regardless of their VOC-content, such as solvents, and cloth and paper moistened
with solvents, shall be stored in non-absorbent, non-leaking containers which shall be kept closed at all times
except when filling or emptying.
- CONTROL EQUIPMENT: In lieu of complying with
the requirements in Sections 235.3 A., 235.3 B., or 235.3 E.1. of this rule, a person may comply by using collection
and control systems in association with the solvent cleaning operation subject to this rule provided:
- The collection system collects at least 90 percent, by weight, of the emissions generated
by the solvent cleaning operation; and the control system reduces VOC emissions from the emission collection system
by at least 95 percent, by weight; or
- The collection system collects at least 90 percent, by weight, of the emissions generated
by the solvent cleaning operation; and, the output of the control system is less than 50 parts per million weight
(ppmw), calculated as carbon with no dilution.
- GENERAL PROHIBITIONS:
- On or after January 1, 1996, a person shall not atomize any solvent into open air.
- On or after January 1, 1996, a person shall not specify or require any person to use
solvent or equipment subject to the provisions of this rule that do not meet the requirements of this rule.
235.4 MONITORING AND RECORDS
- RECORDS: Records shall be maintained pursuant
to this Section, for all applications subject to this rule, including those exempted under Sections 235.1 C. through
235.1 L. of this rule, except for cleaning operations performed with a solvent which has a water content of 98
percent or more, by weight, or a VOC composite partial pressure of 0.1 mm Hg or less at 20oC (68oF). Each owner
or operator of a facility subject to the provisions of this rule shall collect and record all information necessary
to demonstrate daily compliance with the requirements of Section 235.3 of this rule or with the exemption conditions
of Sections 235.1 C. through 235.1 L. of this rule, and shall maintain this information at the facility for a period
of five years. The information shall be collected and recorded monthly, and shall be made available to the Air
Pollution Control Officer upon request. The information shall include, but not limited to, the following:
- Identification of each solvent cleaning operation and other process at the facility
subject to this rule. The identification shall include location, permit number (if applicable), description of
activity, and substrate type;
- The amount and type of each VOC-containing material used at each operation and process,
including exempt compounds. Use of amounts of one pint per week or less may be recorded on a monthly basis;
- The VOC content of each VOC-containing material;
- The vapor pressure of each VOC-containing material; and,
- Any person using an emission control system pursuant to the provisions of Section
235.3 E. as a means of complying with this rule, shall maintain daily records of key system operating and maintenance
procedures which will demonstrate continuous operation and compliance of the emission control device during periods
of emission producing activities. Key system operating parameters are those necessary to ensure compliance with
the requirements of Section 235.3 A.
- TEST METHODS: For the purpose of this rule,
the following test methods shall be used. Other test methods determined to be equivalent and approved in writing
by the District, Air Resources Board, and the US Environmental Protection Agency may also be used. VOC emissions
or other parameters determined to exceed any limits established by this rule through
the use of any of the following test methods shall constitute a violation of this rule.
- The VOC content of materials subject to the provisions of this Rule shall be determined
by EPA Reference Test Method 24 (40 CFR 60, Appendix A).
- The efficiency of the emissions collection system shall be determined by the EPA method
described at 40 CFR 52.741(a)(4)(iii).
- The efficiency of the control device shall be determined by the EPA method described
at 40 CFR 52.741(a)(4)(iv). The VOC content measured and calculated as carbon in the control device shall be determined
by EPA Reference Test Method 25 or 25A (40 CFR 60, Appendix A).
- The identity of components in solvents shall be determined by ASTM method E168-67,
E169-87, or E260-85; or, by using manufacturer's reported solvent composition, upon approval of the Air Pollution
- Vapor pressure of a VOC shall be determined by ASTM Test Method D 2879-86 or may be
obtained from a published source such as: Boublik, T., V. Freid and E. Hala, "The
Vapor Pressure of Pure Substances", Elsevier Scientific Publishing Co.,
New York (1973), Perry's Chemical Engineer's Handbook,
McGraw-Hill Book Company (1984), CRC Handbook of Chemistry and Physics, Chemical Rubber Publishing Company (1986-87), and Lange's
Handbook of Chemistry, John A. Dean, editor, McGraw-Hill Book Company (1985).