MONTEREY BAY UNIFIED AIR POLLUTION CONTROL DISTRICT


RULE 430 LEATHER PROCESSING OPERATIONS
Adopted May 25, 1994; Revised January 15, 1997.

CONTENTS

PART 1 GENERAL

1.1 Purpose
1.2 Applicability
1.3 Exemptions
1.4 Effective Dates
1.5 References

PART 2 DEFINITIONS

2.1 As Applied
2.2 Combined Efficiency
2.3 Exempt Compounds
2.4 High-volume Low-pressure (HVLP) Spray
2.5 Leather Treatment
2.6 Leather Treatment Process
2.7 Ozone Depleting Compounds
2.8 Specialty Treatments
2.9 Toxic Air contaminants
2.10 VOC Content
2.11 Volatile Organic Compound (VOC)
2.12 Water-based Leather Treatments

PART 3 REQUIREMENTS

3.1 Requirements for VOC Content and Application Method
3.2 Restricted Formulations
3.3 Restricted Clean-up Solvents
3.4 Storage in Closed Containers
3.5 Incidental Emissions

PART 4 RECORD-KEEPING REQUIREMENTS

4.1 Daily Material Usage Record
4.2 Record-keeping Requirements for Emission Control Equipment
4.3 Monthly Summary
4.4 Book of Formulas

PART 5 TEST METHODS 8

5.1 VOC Content of Leather Treatment Materials
5.2 Quantity of Exempt Compounds
5.3 Control Efficiency
5.4 Capture Efficiency
5.5 Additional Source Testing Requirements


PART 1 GENERAL

1.1 Purpose

The purpose of this Rule is to limit the emissions of volatile organic compounds (VOCs) during the use, application, or drying of VOC-containing leather treatment materials and solvents used in leather processing facilities, operations, and processes.

1.2 Applicability

The provisions of this Rule shall apply to facilities, operations, and processes where leather is treated with volatile organic compounds or with materials that contain VOCs unless the operations are specifically exempt. As of May 25, 1994, Salz Leathers of Santa Cruz is the only known affected source.

1.3 Exemptions

Leather processing operations at facilities emitting less than 20 tons per year of VOCs and which are subject to Rules 416 (Organic Solvents) and 429 (Applications of Non-architectural Coatings), are exempt from this Rule.

1.4 Effective Dates

This Rule as most recently revised shall be effective on January 15, 1997.

1.5 References

The requirements of this Rule are derived from Section 182 (b)(2) of the federal Clean Air Act. Related or referenced District Rules include: 101 (Definitions); 416 (Organic Solvents); 429 (Applications of Non-architectural Coatings); and 1101 (Ozone Depleting Compounds).

PART 2 DEFINITIONS

2.1 As Applied

The condition of a coating after dilution just prior to application to the leather.

2.2 Combined Efficiency

For a control technology, the capture efficiency multiplied by the control efficiency, expressed as an overall weight percent.

2.3 Exempt Compounds

As defined in District Rule 101 (Definitions). The exempt compound content of a leather treatment material or clean-up solvent shall be determined pursuant to the provisions of Section 5.2 of this Rule.

2.4 High-volume Low-pressure (HVLP) Spray

A coating application technique that uses a spray gun that operates with an air pressure that does not exceed ten pounds per square inch gauge.

2.5 Leather Treatment

Any liquid material applied onto or impregnated into leather to beautify, protect, or give a finished appearance or quality to the leather, including, but not limited to: lacquers, oils, resins, stains, and top coats. For the purpose of determining compliance with this Rule, the chemical composition of designated leather treatment materials is required to be verified with technical data sheets in a book of formulas according to Section 4.4.

2.6 Leather Treatment Process

Any operation where leather treatment materials are applied or cured, including material application and the heating, drying or storage of treated leather.

2.7 Ozone Depleting Compounds

As defined in District Rule 1101 (Ozone Depleting Compounds), any of the following: chlorofluorocarbons, hydrochlorofluorocarbons, halons, methyl chloroform (1,1,1-trichloroethane), and carbon tetrachloride.

2.8 Specialty Treatments

Leather treatment materials having a VOC content greater than 5.8 pounds per gallon, as applied; or any oil, resin, stain, top coat, waterproof resin, or waterproof top coat having a VOC content, as applied, greater than the limit in Table 3.1.1 for that class of leather treatment material. Specialty treatments include, but are not limited to, waterproofing treatments, stains for Latigo leathers, and special coatings for refinishing or reworking leather.

2.9 Toxic Air contaminants

Compounds that have been identified as toxic air contaminants by the Scientific Review Panel for the California Air Resources Board, or by the United States Environmental Protection Agency after public review and comment, including, but not limited to, methylene chloride.

2.10 VOC Content

The weight of volatile organic compounds per volume of leather treatment material, as applied.

2.10.1 For any water-based leather treatment material, the value used for the weight of leather treatment material to calculate the VOC content shall exclude water and exempt compounds; the value for the volume shall exclude exempt compounds. The VOC content shall be determined according to the provisions of Section 5.1.1 of this Rule; the water and exempt compound content shall be determined according to the provisions of Section 5.2.1 of this Rule.

2.10.2 For any other class of leather treatment material, the values used for the weight and volume of leather treatment material that are used to calculate the VOC content shall not include water or exempt compounds. The VOC content shall be determined according to the provisions of Section 5.1.2 of this Rule; the exempt compound content shall be determined according to the provisions of Section 5.2.2 of this Rule.

2.11 Volatile Organic Compound (VOC)

As defined in District Rule 101 (Definitions).

2.12 Water-based Leather Treatments

Leather treatment materials containing at least 10 percent water by volume as applied. The amount of water shall be determined according to the provisions of Section 5.2.1 of this Rule.

PART 3 REQUIREMENTS

3.1 Requirements for VOC Content and Application Method
Any leather processing facility shall comply with the following requirements:

3.1.1 Leather treatment materials shall be formulated so that the VOC content of each material does not exceed the following limits in pounds per gallon of material as applied:

TABLE 3.1.1

MATERIAL

VOC

Content in Pounds per Gallon

VOC

Content in Grams per Liter

Oil

3.5

420

Resin

0.5

60

Stain

3.5

420

Top Coat

2.0

240

Waterproof Resin

2.0

240

Waterproof Top Coat

2.0

240

Specialty Treatments

7.5

900

Any oil, resin, stain, top coat, waterproof resin, or waterproof top coat that does not meet the VOC content limit in table 3.1.1 for that material shall be considered a specialty treatment.

3.1.2 The combined emissions of VOCs from the application of all specialty treatments at a facility shall not exceed 30 tons per year.

3.1.3 Leather treatment materials may not be applied to leather unless applied by the use of one of the following methods: roll coating for oil application; and photoelectric controlled spray guns, flow coating, dip coating, or high-volume low-pressure (HVLP) spray for the application of other VOC-containing leather treatments.

3.2 Restricted Formulations
A leather treatment material shall not be formulated by replacing VOCs used as the carrier or diluent with toxic air contaminants or stratospheric ozone depleting compounds.

3.3 Restricted Clean-up Solvents

3.3.1 Toxic air contaminants or stratospheric ozone depleting compounds shall not be used as clean-up solvents for leather treatment processes or equipment.

3.3.2 Materials having VOC content of greater than 0.6 pounds per gallon (72 grams per liter) shall not be used as clean-up solvents for leather treatment processes, excluding cleaning of equipment used for application of leather treatment materials.

3.4 Storage in Closed Containers
All materials which contain VOCs, including leather treatment materials, solvents, and clean-up wastes, shall be kept in containers that are closed except when filling or emptying.

3.5 Incidental Emissions All materials which contain VOCs, including media into which VOCs have been absorbed or adsorbed by emissions control devices and all forms of VOCs to be recovered, recycled or disposed, shall be handled, stored and transported so that emissions of VOCs to the atmosphere, soil, groundwater, or any other environmental media are minimized.

PART 4 RECORD-KEEPING REQUIREMENTS

4.1 Daily Material Usage Record

A record of daily VOC usage shall be maintained for each day that leather is processed.

4.1.1 The record shall be in a format which is approved by the District.

4.1.2 The record shall be signed at the end of each shift or at the end of each day by the responsible operator or facility manager.

4.1.3 The record shall be kept on a daily basis and made available upon request for inspection by the District for five years from the date of each entry.

4.1.4 The record shall provide the amount of VOCs from all specialty treatment materials used

4.2 Record-keeping Requirements for Emission Control Equipment
Any person using an emission control system as a means of complying with this Rule shall maintain daily records of key 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 percent reduction requirements such as temperatures, pressures and flowrates.

4.3 Monthly Summary
A monthly summary of daily emission amounts shall be generated for every calendar month and shall be submitted on a quarterly basis to the District within 45 days from the end of each calendar quarter. The summary shall include the amount of VOCs used each month from the use of:

4.3.1 each class of leather treatment materials regulated by Section 3.1.1; and

4.3.2 clean-up solvents and testing materials.

4.4 Book of Formulas
A book of designated leather treatment material formulas shall be maintained at the facility and provided to the District upon request. Revisions to the book of formulas shall be submitted to the District on a quarterly basis. The book shall contain such treatment designations and technical data sheets for stock and brand name chemicals and mixtures used to formulate each designated treatment so that the estimates of daily emissions may be verified. Technical data sheets may include Manufacturers Safety Data Sheets and other manufacturers' specifications concerning the VOC content of materials. The book of formulas may be provided to the District in a District-approved electronic format or in a computer-based media which is compatible with the District's computer systems.

PART 5 TEST METHODS

5.1 VOC Content of Leather Treatment Materials

5.1.1 The VOC content of any water-based leather treatment materials subject to this Rule shall be determined using Bay Area Air Quality Management District Method 31 (Determination of Volatile Organic Compounds in Paint Strippers, Solvent Cleaners and Low-Solids Coatings).

5.1.2 The VOC content of any other class of leather treatment materials and clean-up solvents subject to this Rule shall be determined using EPA Method 24 (Determination of Volatile Matter Content, Water Content, Density, Volume Solids, and Weight Solids of Surface Coatings) in 40 Code of Federal Regulations Part 60, Appendix A.

5.2 Quantity of Exempt Compounds

5.2.1 The quantity of exempt compounds and water in water-based leather treatment materials subject to this Rule shall be determined using Bay Area Air Quality Management District Method 31 (Determination of Volatile Organic Compounds in Paint Strippers, Solvent Cleaners and Low-Solids Coatings).

5.2.2 The quantity of exempt compounds in any other class of leather treatment materials and clean-up solvents subject to this Rule shall be determined using California Air Resources Board Test Method 432 (Determination of Dichloromethane and 1,1,1-Trichloroethane in Paints and Coatings).

5.3 Control Efficiency
The control efficiency of air pollution control equipment shall be determined using EPA Methods 2, 2A, 2C, or 2D for measuring flow rates and EPA Methods 25, 25A, or 25B for measuring the total gaseous organic concentrations at the inlet and outlet of the control device as contained in 40 Code of Federal Regulations Part 60, Appendix A.

5.4 Capture Efficiency
The capture efficiency of control equipment shall be determinedaccording to EPA's technical document, "Guidelines for Determining Capture Efficiency," January 9, 1995.

5.5 Additional Source Testing Requirements
In addition to using EPA and California Air Resources Board-approved standard test methods, any source testing shall also be performed in compliance with the District Source Testing Procedures Manual for any emission control equipment used as a means of complying with this Rule.

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