Comment Log Display

Request for CARB action.

Southern California Edison Company is concerned that your current
Consumer Product Regulation is severely limiting, or denying, our
ability to provide safe electrical service to our customers.  Our
workers must use clean non-conducting tools to work on energized
and non-energized (at that time) electrical equipment.  The tools
and electrical equipment need to be clean, dry, and without
residue after the cleaning process.  There is a real need
for limited use of denatured alcohol.  Since you have opened the
Consumer Product Regulation, we believe this is the time for
regulatory relief.

Denatured alcohol, at this time, is the only solvent we have
available for use in cleaning electrical equipment and the
cleaning of tools etc. used in the repair and maintenance of our
electrical equipment.  SCE can use the product we have on hand, in
aerosol format, for a limited use through period according to Title
17.   We request an exemption be put into the CARB regulations
similar to the one in SCAQMD Rule 1171.  The CARB
restriction on the use of solvents less than 45% VOC by weight for
Electrical Cleaning in Title 17 is detrimental and unsafe for our
employees.   The exemption that is requested would be based on
SCAQMD Rule 1171 (h) (4):

We suggest it should read:

"Cleaning with aerosol products shall not be subject to the 45%
VOC by weight restriction if 160 fluid ounces or less of
non-compliant aerosol products are used per day, per facility."

Denatured alcohol is needed for the cleaning of our electrical
apparatus because it does not damage electrical component
insulation systems, it displaces/eliminates and does not add
moisture which can cause the insulation systems to fail, and it 
does not leave a residue which can cause high voltage electrical
tracking which leads to equipment failure.  We do not have a
substitute clean up with these features.

Continuity of electricity supply, and minimization of electric
equipment failure, is too critical to the economy of California,
compared to the marginal air quality benefit to be obtained from
elimination of the VOCs from denatured alcohol used in critical
cleaning of the utility infrastructure.

At this time there is a serious conflict between the definitions
of VOC, the regulations, and exemptions between CARB and the local
air districts. Most of our concern is in the SCAQMD, although we
operate in nine districts across the state.  We also are having
trouble with manufacturers of VOC solvent and coating componds in
getting them to design and provide usable compliant product.
California utilities make up a small share of the
market and we do not have leverage to force research and
production of the coatings and solvents needed peculiar to our
industry.

We therefore request that CARB include in your VOC definition all
of the "exempt compounds' found in the SCAQMD Rule 102 VOC
definition?  This would hopefully allow manufacturers to produce
more low VOC compliant "green" chemical products for the
California market without the current conflicting regulations at
the state/local levels.

Please contact me if you desire additional information.

Martin W. Ledwitz
Manager, Air Quality
Southern California Edison

Phone: 626-302-9538
FAX:   626-302-9130
e-mail: martin.ledwitz@sce.com