### Chapter 3 : Impact Assessment of Proposed Amended Rule 1130 Final Staff Report

Authority

- The SCAQMD Governing Board obtains its autho rity to adopt, amend or repeal rules and regulations from Health and Safety Code §§ 40000, 40001, and 40440.

Clarity

- The SCAQMD Governing Board finds and determines that Proposed Amended Rule 1130 is written and displayed so that the meaning can be easi ly understood by persons directly affected by it.

Consistency

– The SCAQMD Governing Board finds and determines that Proposed Amended Rule 1130 is in harmony with, and not in conflict with or contradictory to, existing statutes, court decisions, or federa l or state regulations.

Non

- Duplication

– The SCAQMD Governing Board has determined that Proposed Amended Rule 1130 do es not impose the same requirement as any existing state or federal regulation, and the proposed amendment is necessary and proper to exe cute the powers and duties granted to, and imposed upon, the SCAQMD

.

Reference

- In adopting this proposed amendment, the SCAQMD Governing Board references the following statutes which SCAQMD hereby implements, interprets or makes specific: Health and Saf ety Code Sections 40001 and 40440

.

COMPARATIVE ANALYSIS California Health and Safety Code Section 40727.2 requires the comparative analysis with any federal or other SCAQMD rules that apply to the same equipment or source type as the proposed amendments. The proposed amendments codify existing practices at graphic arts operations that are subject to Rule 1130. As such, the proposed amended rule does not impose a new emissi on limit or standard, make an existing emission limit or standard more stringent, or impose new or more stringent monitoring, reporting, or recordkeeping requirements and therefore a comparative analysis pursuant to Health and Safety Code Section 40727.2 i s not required

DRAFT CONCLUSIONS AND RECOMMENDATIONS Staff recommends that Certifying the Final Environmental Assessment (EA) for Proposed Amended Rule 1130

– Graphic Arts and Amending Rule 1130

- Graphic Arts to update Rule 1130 with the control measures recommended by the U nited S tates Environmental Protection Agency’s (U.S. EPA) Control Techniques Guidelines (CTG) for Offset Lithographic Printing and Letterpress Printing (EPA 453/R

- 06

- 002) and Flexible Package Printing (EPA 453/R

- 06

- 003)

.

PUBLIC COMMENTS AND RESPONSES Staff held the public workshop for Proposed Amended Rule 1130 on Thursday, February 6, 2014. The following comments were made at the public workshop and staff responses to th os e comments are shown below

.

Stakeholder Comment #1:

Pr ohibition of Material

– how does it apply to fountain solutions?


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### Chapter 3 : Impact Assessment of Proposed Amended Rule 1130 Final Staff Report

Staff response:
The intent of the provision is to apply to graphic arts material as recommended for use. Fountain solutions are not part of the graphic arts materials definition. Additional ly, the provision applies to the VOC content of the graphic arts materials as applied , or “press

- ready”

.



### Stakeholder Comment #2: Lithographic plates can be made of paper or polymer in addition to metal.


### Staff response: Staff revised the staff report by removing the word “ metal ” to reflect the intent of your comment

.



### Stakeholder Comment #3:
Sheet fed and Web

- fed are subsets of offset lithographic printing, not types of offset lithographic printing.


### Staff response: Staff has revised the staff report to address the intent of your comment by replacing the word “ types” with
“subset

. ”



### Stakeholder Comment #4: Fountain solutions come in one step and two step formulations. The PDSR describes the one step formulation
and should address th e two step formulations. Some lithographic printing on plastic has faced challenges with lower VOC content fountain solutions, but the PIA believes the CTG limits are achievable.


### Staff response: Staff agrees and has revised the staff report by adding addi tional language describing the one

- step and two

- step fountain solutions.



### Stakeholder Comment #5: The description of the alternative emission control system should differentiate between heat

- set and non

- heat

- set inks. Also, heat

- set letterpress printing may need to be specifically included as identified by the CTG.


### Staff response: The Alternative Emission Control System is based on the collection system and the control device and reference to the SCAQMD compliance advisory and treatment for heatset litho graphic printing has been included as an appendix to the report

. Staff add ed additional language to describe flexographic, letterpress and gravure printing processes in the draft staff report. Letterpress printing is defined in the rule and Table of Stan dards I also specifies the VOC content limit for inks used in letterpress operations. The rule also accommodates a person using the Heatset letter printing process with inks that exceed the VOC content limits in the Table of Standards I provided all the g raphic arts materials are vented exclusively to an approved emission control
system or if operating under an approved Alternative Emission Control Plan.



### Stakeholder Comment #6:
We need to have the SCAQMD 1997 Compliance Advisory related to heatset lithography and control device capture efficiency directly addressed as part of this rule amendment. 

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### Chapter 3 : Impact Assessment of Proposed Amended Rule 1130 Final Staff Report

Staff response: Staff agrees and has included the 1997 Compliance Advisory in Appendix B of the Draft Staff Report.



### Stakeholder Comment #7:
The c ontrol device control efficiencies noted in the PDSR seem low.


### Staff response: Staff obtained the control device efficiencies from engin e ering applications for the initial permits a given facility applied for. The control device efficiencies are based o n source test result s . Some of the source tests are dated
and the older equipment may not perform as efficiently as the newer equipment that is avai l a b le today

. Even at an average of 96.6% efficiency, the lowest being 92.1% efficient, all control efficiencies combined with a capture efficiency default of 99.5% are well with the required 86% overall control efficiency limit , based on SCAQMD records

.



### Stakeholder Comment #8:
The term “non

- compliant” with respect to prohibited storage should either b e defined or replaced with cross

referencing citations for clarification.


### Staff response:
The comment refers to the phrase “Storage of Certain Non

- Compliant VOC

- Containing Materials” shown in chapter 3, page 3

- 1 of the Preliminary Draft Staff Report. The PDSR stated that the proposed amendment would prohibit storage of certain non

- compliant VOC

- containing materials at a worksite. To provide clarity,

s taff revised the language to read that the prohibition of certain VOC

- containing materials at a worksite t hat do not meet the VOC limits specified in the Table of Standards I [Rule 1130 paragraph (c)(1)]. Staff also added

an additional sentence to indicate that graphic arts materials that are “ not compliant ” but used exclusively in conjunction with an approv ed emissions control system are not subject to the prohibition

.



### Stakeholder Comment #9: Staff uses “radiation curable” in both the Proposed Amended Rule and the Preliminary Draft Staff Report. The industry term is actually “energy curable”. Please upda te the proposed amend rule and the draft staff report


### Staff Response: Staff has made the requested change in the Preliminary Draft Staff Report by changing “radiation cured” to “energy cured” throughout the draft staff report. In addition, staff has added a new definition to Proposed Amended Rule 1130 for “ENERGY CURABLE COATINGS, I NKS AND ADHESIVES.”



### Stakeholder Comment #10: Industry would like to raise the low

- VOC content material exemption from 10 g/L to 20 g/L to account for errors and conservative reporting of VOC

- content for energy curable graphic arts materials

. 

### Staff Response: The 10 g/L VOC content limit is consistent with other VOC rules and programs pertaining to the near

- zero VOC technology , and represents the current super

- compliant VOC content level. In addition, the definition for energy curable includes reference to ASTM Test M ethod 7767

- 11 “Standard Test Method to Measure Volatiles



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### Chapter 3 : Impact Assessment of Proposed Amended Rule 1130 Final Staff Report

from Radiation Curable Acrylate Monomers, Oligomers, and Blends and Thin Coatings Made from Them” which staff believe s should address the concerns raised by this comment. Staff is proposing to include an exemption from Rule 1130 provisions for graphic arts materials with a VOC content of 10 g/L or less. Given the uncertainties in the methods for determining VOC content at these low levels for some materials, staff proposes to allow for alternative equivalent metrics to determine the VOC content. For instance, for reactive coatings, an alternative calculation includes a determination of 99% solids content or greater by weight

. It is noted that formulation data may be obtained by staff to estimate the VOC content of these near

- zero VOC products

.



### Stakeholder Comment #11:

We r equest a delay in the effective date for storage of non

- compliant materials, possibly 3 months.


### Staff Response: Staff agrees and has provided the requested three month delay in the rule for prohibited storage of “non

compliant” materials and for fountain solutions. The new VOC limits shown in the Table of Standards II will become effective on July 1, 2014 , in order to provide a short transition period for the new standard

.



### The following were received after the close of comment period.

Stakeholder Comment #12: Section (c)(4) Acceptable formula for calculating overall efficiency is proposed to be r emoved. Concern that this will give individual permit engineers and inspectors the freedom to decide how efficiency is calculated and the ability to cite the facility arbitrary.



### Staff Response: The proposed amended rule includes a reformatting of the language pertaining control efficiency. The formula
remains the same.



### Stakeholder Comment #13: Section (c)(4) VOC emissions reduction system must be approved in writing by the Executive Officer. Need
clarification

– does a permit constitute written app roval or is does (sic) the Executive Officer need to provide an approval letter? See SCAQMD Rule 102, definitions: Executive Officer means the Executive Officer or designee of the South Coast Air Quality Management District.



### Staff Response: Issuance of a permit for the emission reduction system is considered written approval by the Executive Officer.



### Stakeholder Comment #14: Section (c)(4)(B) The owner/operator demonstrates that the emissions collection systems collects at least 90 percent, by weight, of the VOC emissions generated by the source emission. What methods of demonstration of the emission system are acceptable in order to achieve 90% by weight reduction of VOC emissions



### – - will showing negative dryer pressure suffice? The reduction in emissions generated note “by the source emissions”. Does this pertain to only the select VOC reduction from either (c)(1) and (c)(2) or does the proposed standard



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### Chapter 3 : Impact Assessment of Proposed Amended Rule 1130 Final Staff Report

include all VOC emissions g enerated at the source including ink, fountain solution, and auxiliary operations such as cleaning and adhesive application?



### Staff Response: The collection efficiency is determined in accordance with the test methods outlined in paragraph (h)(4) of the

pro posed amended rule for complying with paragraph (c)(1) or (c)(2) for those materials that exceed the VOC content limits as applicable. Paragraph (h)(5) allows use of equivalent methods provided they have been approved by SCAQMD, CARB and the U.S. EPA. Fi nally, for heatset lithographic inks, the approach described in Appendix B of this staff report can be used as an acceptable equivalent method for capture efficiency, which includes a demonstration of negative air pressure. Cleaning operations are subject to Rule 1171

– Solvent Cleaning Operations.



### Stakeholder Comment #15: Section (c)(4) No mention is made allowing 70% capture and 30% fugitive per CTG. Recommend adoption of CTG Part VIII.C. Carryover of VOC from Automatic Blanket Wash and Fountain Solu tion to Offset Lithographic Heatset Dryers. We recommend using a 40 percent VOC carryover (capture) factor for automatic blanket washing when the VOC composite vapor pressure of the cleaning material is less than 10 mm Hg at 20 ° C. We recommend using a 7 0 percent VOC carryover (capture) factor for alcohol substitutes in fountain solution. No mention of manual blanket wash retention allowances in CTG. Recommended adoption of CTG Part VIII.B. Retention of Low VOC Composite Vapor Pressure Cleaning Materia ls in Shop Towels. We recommend using a 50 percent VOC retention factor for low VOC composite vapor pressure cleaning materials in shop towels where (1) VOC composite vapor pressure of the cleaning material is less than 10 mm Hg at 20 ° C, and (2) cleaning materials and used shop towels are kept in closed containers.



### Staff Response:
All clean

- up operations are deferred to SCAQMD Rule 1171

– Solvent Cleaning Operations. Rule 1171 requires any cleaning solution for press clean

- up to have no more than 25 g/L of VOC as applied. Rule 1171 also requires all solvent/VOC

- containing cleaning solution hand towels to be kept in sealed containers when not being used. The emission calculations, including use of retention factors, have previously been incorporated
into the annual emissions reporting guidelines, included as Appendix A

– VOC Emission Calculation Methodology for Lithographic Printing Operations of this staff report, for emission reporting purposes.



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