OK, I don't know the background to this document, but I'd like to offer 
a few thoughts out of the box.

I had a second and third take on the subject title of this thread. Who 
the hell transports ozone and how can one transport an unstable and 
highly reactive allotrope and why? In fact, this thread has nothing 
direct to do with ozone but with VOCs. So where does ozone come into it? 
If there is a mix of VOCs and NOx in the atmosphere, solar irradiance, 
notably in the UV region of the spectrum, may create a photochemical 
reaction with ozone and smog as by-products. This tropospheric ozone is 
a distinct health hazard because, in excess, it can oxidise lung tissue, 
causing cumulative destruction, leading to emphysema, pulmonary fibrosis 
etc.

It is obviously desirable to reduce the causal agents, VOCs and NOxs. 
Both these are present naturally. Natural VOCs come largely from the 
decomposition of vegetable matter and emissions from aromatic plants 
(terpenes, terpenoids etc., read pine forests, herbal maquis, fruit 
growing etc.). Natural NOxs are emitted by soils, forest/bush fires, 
lightning and possibly pulse plants. These need not concern us and they 
form a baseline concentration. Even in places with an unfavourable 
topography, such as the LA basin/valleys, the resultant natural ozone 
concentration in summer would not constitute a hazard.

This leaves man-made VOCs and NOxs. Undoubtedly, the greatest source of 
both these is the internal combustion engine and its fuel. This is 
probably where the word 'transport' in the subject comes from. VOCs from 
evaporation of the fuel and from unburnt fuel and other organic 
by-products from the exhaust (no, catalytic converters are not 100% 
efficient at oxidising them!). NOx from reactions between atmospheric 
nitrogen and oxygen in the cylinders and the catalytic converter (same 
remark!). Other anthropogenic NOx sources are the combustion of fuel of 
all types, ore smelting, chemical fertilisers, explosives, solid fuel 
rocketry etc.

OK, now for the nitty-gritty. VOCs in our industry. In effect, there are 
at least two definitions of Volatile Organic Compound. The European one 
states (my interpretation of the definition) that a VOC is any 
carbon-based organic substance whose vapour pressure exceeds a given 
threshold at 25°C. The threshold (can't remember the actual figure 
offhand) is very low, indeed, and all our solvents largely exceed it, so 
there is no wriggle-room. This is a clear, scientific, definition but it 
has one weakness. It does not take into account that there may be some 
substances, such as heavy MW PEGs or similar, that have a vapour 
pressure below the threshold at 25°C but have a much higher VP at the 
temperature at which they are used. These may be used, e.g., in 
"VOC-free" fluxes and pastes, but they emit VOCs joyfully at soldering 
temperatures. I won't go into VOCs formed or emitted when non-VOCs, such 
as polymerised epoxy resins, are heated to soldering temperatures (or 
lower). The subject is clearly pricklier than the official definition 
implies.

The other definition, I regret to say, is much worse and, AFAIK, is 
unique to the USA (sorry, guys). It is governed by no real definition 
but lists of substances deemed to be VOCs, including some catch-alls, 
and some political exemptions for no scientific reason (no doubt the 
result of lobbying). "The other NESHAP solvents regulated under Subpart 
T (perchloroethylene, 1,1,1-trichloroethane and methylene chloride) are 
exempt compounds under federal and most state guidelines and are not
considered VOC and are not regulated under the OTC Solvent Degreaser 
Model Rule". OUCH! This is, frankly speaking, a travesty of just 
rule-making. These solvents ARE VOCs, whether you like it or not. I 
admit these exemptions are decades old, but there has been plenty of 
time for them to be eliminated.

Another point is what happens when someone introduces a new solvent? Are 
they automatically exempt if they do not fit into a list or a category?

Note that at least two solvents mentioned in the document are banned 
(CTC and 1,1,1-TCA) because they are ozone-depleting substances under 
the Montreal Protocol. Do not confuse ozone depletion in the 
stratosphere with ozone generation in the lower troposphere. There is 
absolutely no relationship between the two phenomena.

The crux of the matter is that we must keep emissions of all VOCs to an 
absolute minimum, whether they be "exempt" or not, as a measure of 
health protection. The document gives guidelines for the hardware to 
minimise them but makes no mention of what is probably the most 
important factor: the training of the operator. Tight-fitting lids are 
useless if they are propped up against the side of the degreaser. Taking 
the workpiece from cold solvent, through the vapour zone and the 
refrigerated freeboard, in 5 seconds because he is in a hurry is useless 
(and a waste of solvent).

As a final discussion point, absorbent materials are forbidden, 
according to the document. Can a printed circuit assembly be considered 
as non-absorbent? Firstly, there are some very fine capillary spaces 
which will not let vapours escape. Secondly, the very structure of FR-4 
is absorbent/adsorbent. Take any carefully solvent-cleaned assembly 
having gone through the vapour zone to reach asymptotic temperature and 
then left in the freeboard for 10 minutes and put it in a vacuum chamber 
with a weighed carbon filter. I think you will be surprised at the 
increase in weight of the filter, perhaps as much as 10 mg/cm² of board 
after 30 minutes. These emissions are not, of course, covered by this 
document.

Just some thoughts...

Brian

On 19/08/2011 21:38, Mike Buetow wrote:
> Lamar is exactly right. (See page 1 of the draft
> http://otcair.org/upload/Documents/Meeting%20Materials/OTC%20Solvent%20Degreaser%20Model%20Rule%20for%202011%20STAKEHOLDER%20REVIEW%20DRAFT%20082710B%20GMP%20clean.pdf
> .)
>
>
>
> The problem as I see it is that the precision cleaning industry (read: ours)
> is getting lumped in with some others, to our detriment. But it�s important
> to note that the EPA seems open to being shown that the numbers proposed are
> too rigid.
>
>
>
> *From:* Lamar Young [mailto:[log in to unmask]]
> *Sent:* Friday, August 19, 2011 2:26 PM
> *To:* TechNet E-Mail Forum; Mike Buetow
> *Subject:* Re: [TN] ozone transport rules
>
>
>
> The 25 g/L limit refers to the VOC content of the materials.  Lowering the
> VOC content on materials should reduce ozone (maybe).
>
> Lamar Young
> Specialty Coating Systems, Inc.
> 7645 Woodland Dr.
> Indianapolis, IN 46278
> (317) 244-1200 Ext. 276
> www.scscoatings.com
>
>
>
> From:        Mike Buetow<[log in to unmask]>
> To:<[log in to unmask]>
> Date:        08/19/2011 02:16 PM
> Subject:        Re: [TN] ozone transport rules
> Sent by:        TechNet<[log in to unmask]>
> ------------------------------
>
>
>
>
> Doug,
>
>
>
> The rules specifically cover ozone. What the EPA is trying to do is reduce
> ground-level smog. A big contributor to that, as I understand it, are VOCs.
>
>
>
> Mike
>
>
>
>
>
> *From:* [log in to unmask]
> [mailto:[log in to unmask]<[log in to unmask]>
> ]
> *Sent:* Friday, August 19, 2011 2:05 PM
> *To:* TechNet E-Mail Forum; Mike Buetow
> *Subject:* Re: [TN] ozone transport rules
>
>
>
>
> Mike,
> Are you talking ozone emissions or VOC emissions?  I suspect the latter.
>
> And I would agree about the hallucinogenic basis of the numbers.  Same kind
> of crack-smoking, meth inhaling numbers that got us RoHs.
>
> Doug Pauls
>
> *Mike Buetow<[log in to unmask]>*
> Sent by: TechNet<[log in to unmask]>
>
> 08/19/2011 12:59 PM
>
> Please respond to
> TechNet E-Mail Forum<[log in to unmask]>; Please respond to
> Mike Buetow<[log in to unmask]>
>
> To
>
> <[log in to unmask]>
>
> cc
>
> Subject
>
> [TN] ozone transport rules
>
>
>
>
>
>
> Not sure if any of you have been following this, but the US EPA is proposing
> lowering the ozone emissions limit cap to 25 grams/liter in the Northeast
> and Mid-Atlantic states. This is in line with the California rules, and what
> we are hearing is that most cleaning chemistries that are formulated special
> for California manufacturers are not as robust as ones used in other
> locales. The EPA says lowering the limits will cut healthcare costs by $120
> billion to $290 billion a year by 2014 � or more than 10% of the total
> annual US health care spend. (Just the range in that estimate suggests some
> serious drug ingestion on the part of those responsible, in my opinion.)
> Frankly, I would be more concerned that the major defense contractors all
> move to Texas.
>
>
>
> There is a meeting near BWI Airport in early September. I strongly suggest
> you forward this info to your company environmental compliance officer(s)
> and make sure they submit comments and/or attend.
>
>
>
> http://circuitsassembly.com/cms/news/11552-ozone-rules-debated-
>
>
>
>
>
> Best,
>
> Mike
>
>
>
> Mike Buetow
>
> Circuits Assembly
>
> w/m 617-327-4702
>
> Twitter: @mikebuetow
>
>
>
>>>> The CIRCUITS ASSEMBLY EMS Directory -- over 2,100 listings, in Excel
> www.circuitsassembly.com/dems<<<
>
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