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

Authority - The SCAQMD Governing Board obtains its authority 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 easily 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 federal or state regulations.

Non-Duplication – The SCAQMD Governing Board has determined that Proposed Amended Rule 

1130 does not impose the same requirement as any existing state or federal regulation, and the 

proposed amendment is necessary and proper to execute 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 

Safety 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 emission 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 is 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 United States 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 those comments are 

shown below.

Stakeholder Comment #1:

Prohibition 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. Additionally, 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 the 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 additional 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 lithographic printing has been included as an 

appendix to the report. Staff added 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 Standards 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 graphic 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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Staff response:

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

Stakeholder Comment #7:

The control device control efficiencies noted in the PDSR seem low. 

Staff response:

Staff obtained the control device efficiencies from engineering applications for the initial permits a given facility 

applied for. The control device efficiencies are based on source test results. Some of the source tests are dated 

and the older equipment may not perform as efficiently as the newer equipment that is available 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 be defined or replaced with crossreferencing 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, 

staff revised the language to read that the prohibition of certain VOC-containing materials at a worksite that 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 approved 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 update 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, INKS 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 Method 7767-11 “Standard Test Method to Measure Volatiles 

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from Radiation Curable Acrylate Monomers, Oligomers, and Blends and Thin Coatings Made from Them”

which staff believes 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 request 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 “noncompliant” 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 removed. 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 approval 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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include all VOC emissions generated 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 

proposed 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. Finally, 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 Solution 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 70 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 Materials 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.

Proposed Amended Rule 1130 3-7 May 2014