150
Barbara Kanegsberg
16924 Livorno Dr., Pacific Palisades, CA 90272
(310) 459-3614 • fax (310) 459-3624
Barbara@Bfksolutions.com • www.Bfksolutions.com
Barbara Kanegsberg, President
Ed Kanegsberg, Vice President
DATE:
March 13, 2011
TO:
Gene Pettingill
State of Delaware
Department of Natural Resources and Environmental Control
gene.pettingill@state.de.us
FROM:
Barbara Kanegsberg
Ed Kanegsberg
SUBJECT:
Comments, Stakeholder Review Draft 082710B GMP, OTC Model
Rule for Solvent Degreasing 2011
Table of Contents
1 Summary ....................................................................................................................... 2
2 Definition of solvent ..................................................................................................... 2
3 Cleaning agent options .................................................................................................. 2
3.1 Aqueous cleaning options ...................................................................................... 3
4 Exemptions ................................................................................................................... 4
4.1 Process control option for high-value products ..................................................... 4
4.2 Example, inapplicable exemption .......................................................................... 5
4.3 Management of VOC-exempt NESHAP Solvents ................................................ 5
5 Cleaning equipment ...................................................................................................... 5
5.1 Suggest changing Airless/Airtight to: Qualified Contained Cleaning System ...... 5
5.1.1 Proviso: Aqueous Cleaning Systems .............................................................. 6
5.2 Remove “vacuum” from the definition of airless/airtight...................................... 6
5.3 Background: airless/airtight systems ..................................................................... 6
5.3.1 Historical perspective, rule development ........................................................ 6
5.3.2 Airless System Performance ........................................................................... 7
5.3.3 Additional equipment options are essential .................................................... 7
5.4 Encourage “NESHAP-like” controls and solvent monitoring for high-value
processes. ........................................................................................................................ 7
6 Appendices .................................................................................................................... 7
6.1 References .............................................................................................................. 7
6.2 Qualifications of BFK Solutions LLC ................................................................... 8
Kanegsberg comments to OTC
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1 Summary
As we discussed recently, we understand the urgency to obtain improved air quality
throughout the Ozone Transport Commission (OTC) region. We appreciate the
opportunity to comment on this impressive project.
We have provided some suggestions to build on the California approach, particularly
those portions of the OTC Model Rule for Solvent Degreasing 2011 that have been
adapted or transcribed from SCAQMD Rule 1122. Our rationale is to help the OTC
develop a scientifically-based, transparent, and defensible model rule that can be adopted
or adapted to individual state requirements. The model rule in its current format calls for
an upper limit of 25 g/L VOC content for cleaning agents and adopts the airless/airtight
cleaning system definition from SCAQMD Rule 1122. Exemption categories also appear
to follow the wording used in Rule 1122.
We suggest that the rule be modified in terms of the solvent options available, the
description of acceptable cleaning equipment, and the nature of exemptions. We also
suggest approaches to making the Model Rule more holistic and to avoid unintended
consequences. Specifically, Rule 1122 also deals with control of NESHAP solvents, and
we strongly suggest that, without countermanding Congressional action, you honor the
intent of that action and protect communities and workers by building on Rule 1122.
There may be an understandable presumption that if there were complaints in the
SCAQMD area, you would have heard them. You may not have heard the complaints.
We have. Industry continues to exit the area. Rule 1122 has left the manufacturing
remaining in Southern California with few if any options for critical cleaning
applications. Our suggestions are geared to designing a realistic, holistic model rule, one
that is protective of the environment, neighborhoods, and workers.
2 Definition of solvent
We suggest that a description covering solvent, or cleaning solvent, or cleaning agent be
added to the definitions section. Based on informal discussions, there appears to be some
confusion as to whether or not the model rule is meant to cover aqueous blends or
microemulsions as opposed to unblended solvents and solvent blends. Many cleaning
agents that are marketed as aqueous may contain significant levels of VOCs.
3 Cleaning agent options
An upper limit of 25 g/L VOC content does not provide adequate cleaning agents for
manufacturing. With few exceptions, the available solvents that have been declared
negligibly reactive at the Federal level are not sufficiently aggressive against soils of
interest. Many are used as carriers and/or to inert more effective, but often flammable,
VOC solvents. In some cases, the blends or azeotropes are predominantly VOCs. 150
g/L with reasonable containment during the process would be a realistic achievable goal
for cleaning agents. Further, fostering the use of solvents with an exceedingly low vapor
Kanegsberg comments to OTC
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pressure as a discriminator is very often not a technically acceptable approach. Such
cleaning agents often require extensive rinsing to avoid unacceptable surface residue.
Depending on the few VOC-exempt compounds that are available is unrealistic. One of
the few VOC-exempt chemicals that are useful in cleaning applications, HCFC 225, is an
ozone depleting compound (ODC) and will be phased out of production on January 1,
2015. HCFC 225 has low to moderate solvency and is sometimes blended with VOCs. It
is not clear that local California industry has a readily available replacement.
Acetone is also used extensively in the SCAQMD area. Many aerosol products have
been reformulated to contain acetone along with a small amount of a VOC; the VOC is
actually doing the job. Acetone evaporates exceedingly rapidly; therefore, a great deal is
emitted to the environment. It is reasonable to expect that emitting large amounts of a
compound, even one with low, but not zero, relative reactivity, will have a negative
impact on air quality. In addition, with the change to acetone comes potential safety
issues due to the exceedingly low flashpoint of acetone and, in some cases, also with
issues of potential unanticipated worker exposure problems of blended of acetone-based
blended products (1)
3.1 Aqueous cleaning options
Well-designed aqueous cleaning processes are appropriate and successful for many
applications. At the same time, there are recurrent, erroneous assertions that aqueous
cleaning agents will solve all environmental, safety, and manufacturing problems and that
effective aqueous cleaning agents containing ever-decreasing levels of VOCs can be
formulated. Formulations with less than a 25 g/L VOC content often do not perform well
for critical manufacturing applications.
A leading formulator and supplier of aqueous cleaning agents for electronics assemblers
estimates that 150 g/L VOC as applied is typical of what is needed to deflux (clean)
today’s densely-populated, closely-spaced electronics assemblies. While we have not
done a complete survey of suppliers of cleaning agents, the 150 g/L VOC level seems
realistic. (By the way, it is essential to list the VOC level “as applied” or “as used,” so
that cleaning chemistries can be shipped in concentrated form.)
Regulatory edict cannot change technical reality. While cleaning can sometimes be
avoided and while water alone can be used in some applications, using very low VOC
aqueous cleaning agents is impractical and ineffective in many instances. The wetting
capability and solvency properties are not sufficient for removal of soil from ornate parts
or closely-spaced components. Very high cleaning forces, high temperatures, and long
cleaning times are required. If we consider the steps in the cleaning process to consist of
wash, rinse, and dry, using very low VOC aqueous cleaners often involves strong forces
such as high pressure spray and/or ultrasonics. These forces, heat, and time tend to
increase emissions, not to mention the higher worker exposure to process chemicals and
higher energy usage. Rinsing is generally needed to remove cleaning agent residue; this
results in more air emissions and uses additional energy. The drying step involves still
Kanegsberg comments to OTC
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additional significant energy usage. The rework and reject rate for ineffective processes
leads to even more environmental, safety, and economic problems.
The 25 g/L VOC limitation means that many aqueous cleaning chemistries can no longer
be used in the SCAQMD area. This has had an impact on Southern California industry.
Manufacturers that remain in the SCAQMD area are often so constricted in chemistries
that can be used that they can accept only a subset of potential projects. For example, an
electronics assembler chooses only those that can be accomplished with no significant
use of cleaning chemistry.
“Some contract manufacturers are understandably sensitive to the limitations in their process options. For
example, one group, that asks not to be identified, looks for projects that can be completed successfully with
technology that can be readily adopted in a stringent regulatory climate. They clean with deionized water,
not with surfactants or other cleaning chemicals; they select applications that use water soluble fluxes. (2)”
4 Exemptions
We suggest you make the exemptions more general than they are, rather than copy the
SCAQMD wording. We suggest that the Model Rule simply list some of potential
exemptions that individual states might want to expand on. Transcribing process or
product exemptions that are found in Southern California regulations is not a reasonable
approach. Based on our recollection, most of those exemptions were developed 10 to 15
years ago and represent the results of efforts by advocates and companies. Attempts were
made to address manufacturing issues of the day and to enable some companies to meet
then-current contracts. These exemptions are not necessarily appropriate to the current
needs of East Coast companies.
Based on interchanges with clients and colleagues in the OTC region, many
manufacturing operations could be reasonably classified as critical cleaning or cleaning
of high-value product, not general cleaning. A great deal of the non-critical cleaning has
moved overseas. Therefore, most might be able to present valid reasons for individual
exemption from State rules; and they would be likely to do so rather than attempt to
comply with very costly regulations.
Another concern we have is that under Rule 1122, a manufacturing facility would have to
be completely devoted to the exempt process in order to obtain an exemption. Many
companies are either job shops or they have diversified product lines; some of those
products might be for exempt categories, others might not. This is a difficult problem.
We do not have all of the answers. Requiring two production lines may be possible for
some manufacturers; but it may be onerous and unachievable for small companies with
limited space and limited financial resources. For such manufacturing facilities, perhaps
cleaning systems such as are discussed in section 5.4 might be appropriate.
4.1 Process control option for high-value products
For those applications that could justify an exemption, VOC reduction could still be
achieved by requiring emission controls equivalent to those for NESHAP solvents. This
Kanegsberg comments to OTC
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would avoid an all-or-nothing approach that could allow manufacturers claim a need for
exemption and then to use highly emissive processes. Please refer to Section 5.4
4.2 Example, inapplicable exemption
Film processing is an example of where simply excising portions of SCAQMD rules is
not an appropriate extrapolation. A wholesale exemption of the processing of motion
picture film would seem inappropriate in an overall model rule, especially one geared for
areas outside of Southern California. The use of digital media has increased. Where
chemical processing is required, many companies use VOC exempt compounds that are
not hazardous air pollutants combined with very powerful ultrasonics have been found to
provide acceptable cleaning results. “Wet gate processing” uses perchloroethylene
(PCE) to print film and to transcribe film to other media; and some companies still use
PCE for cleaning. PCE is important for wet gate processing because of its unique optical
properties. However, PCE is also VOC exempt. The OTC Model Rule is exempting a
category that largely uses VOC-exempt compounds.
4.3 Management of VOC-exempt NESHAP Solvents
We must emphasize that the use of PCE needs to by addressed by the OTC; it is
apparently not covered in the current model rule. The SCAQMD rule is more holistic in
that it specifically includes the use of all NESHAP solvents, exempt and non-exempt.
Under the Model Rule, PCE and methylene chloride (MC) could be used in a more
emissive manner than could relatively benign VOC solvents and many aqueous VOC
blends. We understand that Congress has chartered the OTC to take steps that should
decrease the level of tropospheric ozone. However, a more holistic model rule, one that
could be more readily-adapted by individual states, could be developed without
countermanding instructions from Congress. Perhaps discussion of controls for VOCexempt NESHAP solvents could be worded as suggestions or reminders. This is
important, particularly given the strong influence of Rule 1122.
5 Cleaning equipment
5.1 Suggest changing Airless/Airtight to: Qualified Contained
Cleaning System
Wherever the term “airless/airtight” is used is used in the Model Rule, except in the
wording of the definition of airless/airtight itself, we suggest that the Rule refer to
“Qualified Contained Cleaning Systems.” A definition should be added for a “Qualified
Contained Cleaning Systems”. This new definition could read:
“Qualified Contained Cleaning Systems” means an airless, airtight system or any other
system to be used with high-VOC cleaning agents. Such systems must meet the
definition of a Permanent Enclosure (PE) by EPA Method 204 or operationally meet
emission standards for a Temporary Total Enclosure (TTE) criteria per EPA Methods 204
Kanegsberg comments to OTC
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through 204F or per SCAQMD “Protocol for Determination of Volatile Organic
Compounds (VOC) Capture Efficiency.” There must be sufficient public disclosure of
the design to show that a system meets standards for PE. Alternatively, there must be
sufficient public disclosure of data to demonstrate that the system meets the
requirements for a TTE.
Suppliers of an airless, airtight system or any other system for high-VOC processes
would then have to demonstrate that the design meets the definition of a PE or a TTE.
Such a definition would be more appropriate and inclusive than that of airless/airtight.
Even more important, manufacturers of all cleaning systems to be classified as a
“Qualified Contained Cleaning Systems” should be required to provide third party,
published, publicly-available data and/or pertinent supporting information.
5.1.1 Proviso: Aqueous Cleaning Systems
Depending on the VOC limits that are set, aqueous systems may or may not meet the
EPA Methods or SCAQMD Protocol and may require alternative approaches to VOC
control. Time does not permit us to fully discuss issues of aqueous cleaning systems.
5.2 Remove “vacuum” from the definition of airless/airtight
Airless and airtight systems are a subset of what we have redefined as “Qualified
Cleaning Systems.” However, the word “vacuum” should be removed from the phrase
“vacuum drying.” The reason is that many if not most airtight systems do not and/or
cannot use vacuum drying. Further, we consider the use of the term vacuum to be a
misnomer. It would be more appropriate to use the term “reduced pressure” rather than
“airless” systems. Many of these cleaning systems may meet the definition of a
Permanent Total Enclosure in EPA Method 204.
5.3 Background: airless/airtight systems
5.3.1 Historical perspective, rule development
The current definition of airless/airtight was added to SCAQMD Rule 1122
approximately a decade ago based on input from some equipment manufacturers.
However, this input was clearly not comprehensive. Based on our records of iterations of
Rule 1122, the concept of “vacuum drying” was not inserted until the final iteration of the
2001 rulemaking amendment process. We consider that including “vacuum drying” in
the definition to be counterproductive to the development and adoption of valid, nonemissive cleaning equipment. For example, drying can be accomplished by “pushing”
the solvent off of the product rather than by “pulling” it off at reduced pressure.
Additional valid approaches to containment are available and still more may be
developed.
Kanegsberg comments to OTC
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While the definition of “airless/airtight” was adopted in the 2001 version of Rule 1122;
the reference to EPA Method 204 test methods did not occur until a subsequent revision,
even though EPA Method 204 appears to have been available since the mid-1990’s.
5.3.2 Airless System Performance
Airless systems are viable options. Based on pragmatic experience with individual
clients, many “airless” systems do an excellent job of solvent containment. We have
communicated experiences of manufacturers in presentations and publications; we have
also outlined one case study in our “Handbook for Critical Cleaning;” and a chapter is
devoted to such systems (3). However, airless systems require a substantial capital
investment; they have a large footprint; proper operation involves up-front and on-going
employee education; and they require significantly more upkeep than a standard open top
system. Airless systems can be a good answer; they are not the only answer.
5.3.3 Additional equipment options are essential
It is important to provide the option to use cleaning technologies other than airless
systems, even though they are largely excluded from use in the SCAQMD area. The
technical rationale for this exclusion eludes us. It should also be noted that, “airless” or
“vacuum” systems cannot be used with all solvents or in all cleaning processes. Many
reputable equipment manufacturers consider low flashpoint solvents to be incompatible
with “airless” systems. In addition, high frequency (over 100 KHz) ultrasonic cleaning is
used for more and more manufacturing processes; these designs require a reduced tank
wall thickness. The decreased thickness of the tank wall makes it impractical to use
reduced pressure with higher frequency ultrasonics.
5.4 Encourage “NESHAP-like” controls and solvent monitoring
for high-value processes.
Examples of high value applications include military, aeronautics, medical, and micro
components or products.
Rather than provide a blanket exemption for such high-value applications, it seems more
productive for a model rule to encourage “NESHAP-like” cleaning equipment along with
solvent monitoring. Such a tactic would allow industry to use effective cleaning agents
and would provide greater flexibility in permitting.
6 Appendices
6.1 References
(1) R. Harrison et. al., Morbidity and Mortality Weekly Report, Center for Disease
Control, Vol. 50, No. 45, p 1011, 2001.
Kanegsberg comments to OTC
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(2) Kanegsberg, B. and E. Kanegsberg, “Southern California Defluxing – Learning
Locally, Manufacturing Globally, PLUS, October, 2010.
(3) Kanegsberg, B. and E. Kanegsberg, editors, “Handbook for Critical Cleaning,”
CRC Press 2011.
6.2 Qualifications of BFK Solutions LLC
We are independent cleaning consultants; and we are the industry leaders in critical
cleaning consultants. Our company, BFK Solutions LLC, was founded in 1994. We have
decades of experience in the field of critical and industrial product cleaning.
We are editors of the “Handbook For Critical Cleaning,” CRC Press. The book was
recently revised and expanded to a two volume second edition (2011). We have
conducted numerous public and private seminars and tutorials for groups such as USC
School of Periodontics, UCLA, National Manufacturing Week, NIST, Cal/OSHA, IPC,
SMTA and the International Thermal Spray Association as well as industries involved
with critical applications such as aerospace component, electronics assembly, precision
optics and medical device manufacture. We are members of the Continuing Education
and Outreach Faculty at the UCLA/UC Irvine Southern California Education and
Research Center. We have well over 100 publications in cleaning and contamination
control. Barbara is a recipient of a U.S. EPA Stratospheric Ozone Protection award. We
participate in Cal/OSHA advisory committee meetings. We contribute columns that
appear regularly in technical publications in the U.S. and in Europe. These include
critical cleaning and contamination control columns for “Controlled Environments
Magazine,” a column covering business updates that appears for “Process Cleaning
Magazine,” a column covering metal finishing issues for “Galvanotechnik,” and one
covering electronics assembly concerns for “PLUS.”
As independent consultants, our projects are not contingent on the sale of cleaning agents
or cleaning equipment. The above comments and observations provided to the OTC are
not funded by cleaning agent or cleaning equipment manufacturers or suppliers. Please
do not hesitate to contact us if you would like more complete statements of our
qualifications or if you would like additional technical information or reports.
Kanegsberg comments to OTC
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