MBUAPCD RULE 430 LEATHER PROCESSING OPERATIONS                                    
LAST REVISED 05/25/94
                                    
                                    REGULATION IV
                                     PROHIBITIONS
          *컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴*
          RULE 430  LEATHER  PROCESSING  OPERATIONS
          *컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴컴*

          Adopted May 25, 1994


                                       CONTENTS

          PART 1  GENERAL..............................................2
            
            1.1   Purpose..............................................2
                  
            1.2   Applicability........................................2
                  
            1.3   Exemptions...........................................2
                  
            1.4   Effective Dates......................................2
                  
            1.5   References...........................................3
                  

          PART 2  DEFINITIONS..........................................3
            
            2.1   As Applied...........................................3
                  
            2.2   Combined Efficiency..................................3
                  
            2.3   Exempt Organic Compounds.............................3
                  
            2.4   Group I Compounds....................................3
                  
            2.5   Group II Compounds...................................3
                  
            2.6   Group III Compounds..................................4
                  
            2.7   High-volume Low-pressure (HVLP) Spray................4
                  
            2.8   Leather Treatment....................................5
                  
            2.9   Leather Treatment Process............................5
                  
            2.10    Ozone Depleting Compounds..........................5
                    
            2.11    Specialty Treatments...............................5
                    
            2.12    VOC Content........................................5
                    
            2.13    Volatile Organic Compound (VOC)....................5
                    

          PART 3  REQUIREMENTS ........................................6
            
            3.1   Requirements for VOC Content and Application Method..6
                  
            3.2   Restricted Formulations..............................7
                  
            3.3   Restricted Clean-up Solvents.........................7
                  
            3.4   Storage in Closed Containers.........................7
                  
            3.5   Incidental Emissions.................................7
                  

          PART 4  RECORD-KEEPING REQUIREMENTS..........................7
            
            4.1   Daily Material Usage Record..........................7
                  
            4.2   Recordkeeping Requirements for Emission Control
                  Equipment............................................8
                  
            4.3   Monthly Summary......................................8
                  
            4.4   Book of Formulas.....................................9
                  

          PART 5  TEST METHODS.........................................9
            
            5.1   VOC Content of Leather Treatment Materials...........9
                  
            5.2   Quantity of Exempt Organic Compounds.................9
                  
            5.3   Control Efficiency...................................9
                  
            5.4   Capture Efficiency..................................10
                  
            5.5   Additional Source Testing Requirements..............10
                  




          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 100 tons per year of VOCs and which are subject to
                Rules 416 and 429, are exempt from this Rule.


          1.4   Effective Dates

                The requirements of this Rule shall be effective on August
                25, 1994.  Other effective dates for specific requirements
                are given in Part 3.


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                                    REGULATION IV
                                     PROHIBITIONS
          1.5   References

                The requirements of this Rule are derived from Section 182
                (b)(2) of the federal Clean Air Act.



          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 Organic Compounds

                Group III compounds, as defined in Section  below.  The
                exempt organic compound content of a leather treatment
                material or clean-up solvent shall be determined under the
                provisions of Section  of this Rule.


          2.4   Group I Compounds

                Organic 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.


          2.5   Group II Compounds

                Stratospheric ozone depleting compounds including, but not
                limited to:

                1,1,1-trichloroethane,
                trichlorofluoromethane (CFC-11),
                dichlorodifluoromethane (CFC-12),
                chlorodifluoromethane (HCFC-22),
                1,1,1-trichloro-2,2,2-trifluoroethane (CFC-113),
                1-chloro-1,1-difluoro-2-chloro-2,2-difluoroethane (CFC-
                114),
                chloropentafluoroethane (CFC-115),
                2,2-dichloro-1,1,1-trifluoroethane (HCFC-123),
                1,1-dichloro-1-fluoroethane (HCFC-141b),
                1-chloro-1,1-difluoroethane (HCFC-142b), and
                2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124).


          2.6   Group III Compounds

            2.6.1   Compounds that have insignificant effects on ozone
                    generation or destruction including:

                  trifluoromethane (HFC-23),
                  1,1,1,2-tetrafluoroethane (HFC-134a),
                  pentafluoroethane (HFC-125),
                  1,1,2,2-tetrafluoroethane (HFC-134),
                  1,1,1-trifluoroethane (HFC-143a),
                  1,1-difluoroethane (HFC-152a),

            2.6.2   and the following classes of perfluorocarbons:

              2.6.2.1   cyclic, branched, or linear, completely fluorinated
                        alkanes;
              2.6.2.2   cyclic, branched, or linear, completely fluorinated
                        ethers with no unsaturations;
              2.6.2.3   cyclic, branched, or linear, completely fluorinated
                        tertiary amines with no unsaturations; and
              2.6.2.4   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 individual
                  compounds (from the broad classes of perfluorocarbon
                  compounds) and the amounts present in the product or
                  process and provides a validated test method which can be
                  used to quantify the specific compounds.


          2.7   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.


          2.8   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 .


          2.9   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.


          2.10    Ozone Depleting Compounds

                Group II compounds, as defined in Section  above.


          2.11    Specialty Treatments

                Leather treatment materials having VOC content greater than
                5.8 pounds per gallon, as applied.  Specialty treatments
                include waterproofing treatments, stains for Latigo
                leathers, and special coatings for refinishing or reworking
                leather.


          2.12    VOC Content

                The weight of volatile organic compounds per volume of
                leather treatment material, as applied.  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 organic compounds.  The VOC content
                shall be determined according to the provisions of Section
                of this Rule.


          2.13    Volatile Organic Compound (VOC)

                Any compound containing at least one atom of carbon,
                except: methane, carbon monoxide, carbon dioxide, carbonic
                acid, metallic carbides or carbonates, ammonium carbonate,
                methylene chloride, Group II and Group III compounds.


          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   By the dates specified in the table below, 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:



               Material        8/25/94      1/1/95       1/1/96

               Oil
                               7.5          5.8          3.5

               Resin
                               1.3          1.0          0.5

               Stain
                               7.5          5.0          3.5

               Top Coat
                               4.0          2.0          2.0

               Waterproof
               Resin           2.0          2.0          2.0

               Waterproof Top
               Coat            4.0          2.0          2.0

               Specialty
               Treatments      7.5          7.5          7.5



            3.1.2   Effective January 1, 1995, 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   The following methods shall be used to minimize VOC
                    emissions: roll coating for oil application and
                    photoelectric controlled spray guns for the application
                    of other VOC-containing leather treatments.

            3.1.4   Effective January 1, 1995, leather treatment materials
                    may not be applied to leather unless applied by the use
                    of one of the following methods: roll coating,
                    photoelectric controlled spray guns, flow coating, dip
                    coating, or high-volume low-pressure (HVLP) spray.


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                                    REGULATION IV
                                     PROHIBITIONS
          3.2   Restricted Formulations

                A leather treatment material shall not be formulated with
                Group I compounds (toxic air contaminants) or Group II
                compounds (stratospheric ozone depleting compounds).


          3.3   Restricted Clean-up Solvents

            3.3.1   Group I or Group II compounds shall not be used as
                    clean-up solvents for leather treatment processes or
                    equipment.

            3.4.2   Materials having VOC content of greater than 0.6 pounds
                    per gallon 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 following data for each
                    day:

              4.1.4.1   the amount of VOCs from all specialty treatment
                        materials used;

              4.1.4.2   the amount of VOCs from all other designated
                        leather treatment materials used;

              4.1.4.3   the amount of VOCs used as clean-up or testing
                        materials; and

              4.1.4.4   a summation of the amount of VOCs emitted from all
                        operations in the facility.


          4.2   Recordkeeping 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 ; and

            4.3.2   clean-up solvents.


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                                    REGULATION IV
                                     PROHIBITIONS
          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
                VOC content of materials.



          PART 5  TEST METHODS


          5.1   VOC Content of Leather Treatment Materials

                For the purposes of compliance with this Rule, the VOC
                content of leather treatment materials and clean-up
                solvents 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 Organic Compounds

                For the purposes of compliance with this Rule, the quantity
                of exempt organic compounds in leather treatment materials
                and clean-up solvents 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.


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                                    REGULATION IV
                                     PROHIBITIONS
          5.4   Capture Efficiency

                The capture efficiency of control equipment shall be
                determined using EPA Capture Efficiency Test Protocols as
                contained in 40 Code of Federal Regulations Part 52.741
                (iii).


          5.5   Additional Source Testing Requirements

                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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