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NOTICE OF PUBLIC WORKSHOP AND CEQA SCOPING MEETING
PROPOSED RULE 1144 – LUBRICANTS AND RUST INHIBITORS
Tuesday, September 23, 2008
1:30 p.m.
South Coast Air Quality Management District Headquarters
21865 Copley Drive, Diamond Bar, CA 91765
Auditorium
PURPOSE OF THE MEETING
The South Coast Air Quality Management District (AQMD) has scheduled a public workshop to
solicit information and suggestions from the public on Proposed Rule (PR) 1144 – Lubricants
and Rust Inhibitors.
PR 1144 will be considered for adoption by the AQMD Governing Board at a public hearing
tentatively scheduled for December 5, 2008. This public workshop and CEQA scoping session
will allow comments and discussion of PR 1144 with all public members including potentially
impacted stakeholders and other interested parties.
AIR QUALITY OBJECTIVE
The air quality objective of PR 1144 is to reduce VOC emissions from the use of lubricants and
rust inhibitors. PR 1144 will implement Control Measure CTS-01 from the 2007 AQMP. These
potential VOC emission reductions are necessary for the AQMD to attain state and federal air
quality standards for this region.
SUMMARY OF PROPOSED RULE
The proposed rule would apply to suppliers and users of lubricants and rust inhibitors used in the
manufacture and assembly of products and parts. Affected facilities and operations include but
are not limited to steel tube and spring manufacturers, steel mills, aerospace manufacturers,
automobile part manufacturers and rebuilders and machine shops including broaching, drilling,
drawing, heading, honing, forging, milling, stamping, tapping, threading and turning operations.
The proposed rule will include the following key provisions;
· Establish a VOC content limit on a grams per liter of material basis for the use of lubricantsand rust inhibitors.
· Prohibit the sale of lubricants and rust inhibitors, except those subject to California AirResources Board consumer products regulation found in Title 17 of the California Code of
Regulations, beginning at Section 94507, unless they meet applicable VOC limits.
· Require containers for lubricants and rust inhibitors to display the VOC content as suppliedand after recommended dilution.
CALIFORNIA ENVIRONMENTAL QUALITY ACT
Pursuant to the California Environmental Quality Act (CEQA) and AQMD Rule 110, appropriate
documentation will be prepared to analyze any potential adverse environmental impacts
associated with PR 1144. Comments received at the public workshop and CEQA scoping
meeting will be considered when preparing the CEQA document.
Comments or suggestions regarding environmental impacts from the proposed project should be
directed to:
James Koizumi
Planning, Rule Development & Area Sources
SCAQMD
21865 Copley Drive
Diamond Bar, CA 91765
Phone: (909) 396-3234
Email: jkoizumi@aqmd.gov
SUBMISSION OF DOCUMENTS OR COMMENTS
The public is requested to send documents, studies, data, reports, comments and any other
information relevant to PR 1144 by October 3, 2008 to:
Mike Morris
Planning, Rule Development & Area Sources
21865 Copley Drive
Diamond Bar, CA 91765
Phone: (909) 396-3282
Email: mmorris@aqmd.gov
SUPPORTING DOCUMENTS AND OTHER RELEVANT INFORMATION
The following supporting documents are available on the AQMD website at
http:/www.aqmd.gov/rules/proposed.html:
Preliminary Draft PAR 1144
Preliminary Draft Staff Report for PAR 1144
Copies of the above documents may also be obtained from:
Ms. Lourdes Cordova Martinez
Public Information Center
SCAQMD
21865 Copley Drive
Diamond Bar, CA 91765
Phone: (909) 396-2039
Email: lcmartinez@aqmd.gov
SCAQMD Proposes New Rule
Metalworking Industry in the Crosshairs
BACKGROUND
The South Coast Air Quality Management District (AQMD), a quasi-governmental agency that regulates air quality in the
AQMD freely admits that this new rule will not have much effect on smog, certainly nothing that the average person will notice. Frankly, to use their words, they have ”picked all the low-hanging fruit already”. They are desperate for every little bit of VOC reduction, real or otherwise, so that they can demonstrate to the US EPA that they are doing something to improve air quality. Furthermore, since our industry did not effectively fight the cleaning regulations they figure we are an easy target.
OPERATIONS AFFECTED
EVERY shop that cuts, grinds, forms, stamps, or rolls metal will be regulated in some manner. The proposed new rule will limit the VOC (volatile organic compound) content of metalworking fluids to 25 grams per liter. The key types of fluids most affected and/or prohibited will be vanishing films (stamping), low viscosity stamping oils, carbide and high speed grinding oils, rolling oils, aluminum cutting oils, honing oils, lapping compounds, and all types of RP, especially those used in the tubing industry. Coolants (water soluble, synthetic, and semi-synthetic) will also be regulated, as they will have a legally mandated minimum dilution ratio. As a supplier, we will be prohibited from selling non-compliant fluids and will be forced to test our products, at a cost of $10,000.00 to $50,000.00.
OUR POSITION
We believe that this regulation is unnecessary and will add needless costs and burdens to any industry already struggling to survive and prosper. It will limit your ability to choose the best fluid for your job, and will create opportunities for your competitors, both domestic and foreign, to take your jobs away from you.
WHAT YOU CAN DO
There is a Public Workshop Tuesday, Sept. 23, at the AQMD headquarters. BE THERE! If you cannot attend in person, please write the AQMD. They need to know we cannot take much more of this senseless over regulation.
Many customers have told us they are leery of going to this Workshop because the AQMD will immediately inspect them. Frankly, 99% of the time they already know all about you. DO NOT BE PARALYZED BY FEAR! Our industry needs you to stand tall and tell AQMD how this regulation, as currently written, will place your jobs at further risk and once again adds another onerous regulation in these difficult and challenging times. Rule 1144, if enacted as-is, will place you at a competitive disadvantage with no real gain to the environment.
We have posted the meeting notice on the front page of our website:
www.wsdodgeoil.com
For further information, please call us. We will be happy to fax a copy of the meeting notice to you, and will answer any questions.
President Vice President Sales
