## PLACER COUNTY AIR POLLUTION CONTROL DISTRICT



# STAFF REPORT

RULE 2 3 9

GRAPHIC ARTS OPERATIONS

PROPOSED RULE AMENDMENT S

October 11 , 2012Staff Report

– Revision to Rule 2 39 October 11, 2012 Page 1

BACKGROUND

The Placer County Air Pollution Control District (District) jurisdiction is Placer County . Placer County is located in northern California, bordering Sacramento County to the west and the State of Nevada on the east. Placer County is divided into three different air basins: the Sacramento Valley Air Basin (SVAB); the Mountain Counties Air Basin (MCAB); and th e Lake Tahoe Air Basin (LTAB). The portions of Placer County in the SVAB and MCAB are included in the Sacramento Federal Ozone Non

- Attainment Area (SFONA). The SFONA has been classified as “severe”

non

- attainment for the National Ambient Air Quality Standard (NAAQS) for eight

- hour ozone, as well as non

- attainment with the State of California Ambient Air Quality Standard for ozone. The U.S. Environmental Protection Age ncy’s (EPA) Phase 2 Ozone Rule

, contained in 40 CFR 51.912 and 70 FR 71612 , in accordance with Clean Air Act (CAA) Amendments of 1990, Sections 182(b)(2) and 182(f)

, requires that areas that are classified as moderate non

- attainment or higher must demonstrate in a State Implementation Plan (SIP) that their rules fulfill Reasonably Available Control Technology (RACT) requirements for volatile organic compou nd (VOC) and nitrogen oxides (NOx) which are ozone precursors . The implementation of RACT requires, at a minimum, District r ules covering source categories with RACT guidance documents, which include all EPA

- issued Control Technique s Guideline s (CTG ’s ) , w here there are such sources that operate in the District.

District Rule 23 9

, Gra phic Arts Operations , limits VOC emissions from graphic art operations in the District . The r ule was originally adopted on November 3, 1994

. It has been subsequently amended four times, with the latest on April 8, 2004. This latest version has not been SIP

approved. The most recent SIP approval was on November 13 , 199 8 ( 63 FR 63410 ) for the rule amended on February 13, 1997

.
In September 2006, t he EPA issued a CTG for graphic arts operations ( “Control of Volatile Organic Compound Emissions from Offset Litho graphic and Letter press Printing ”

, EPA

- 453/R

- 06

- 002). Th e current District Rule 239, adopted on April 8, 2004, does not fully address these requirements. Thus, the District is proposing amendments to Rule 23 9 to meet RACT SIP obligations through implementation of all CTG requirements

.

The District has seven ( 7 ) permitted non

- major sources in the category of graphic arts operations. The business names for these sources are:

**•** Auburn Journal

**•** Auburn Printers

**•** GKM Corporation

**•** J & M Printing

**•** Master Color

**•** Paul Baker Printing Company

**•** Sir Speedy Printin g

This Staff Report addresses amendments that are proposed to Rule 23 9

.

DISCUSSION

Rule 23 9 amendments were m ade based on a review of the CTG

, and to establish consistency with local Air D istric t rules

. We reviewed local Air District rules including :

**•** Sacramento Metro AQMD Rule 450, Graphic Arts Operations , last amended on October 23, 2008.Staff Report

– Revision to Rule 2 39 October 11, 2012 Page 2

**•** San Joaquin Valley APCD Rule 4607, Graphic Arts and Paper, Film, Foil and Fabric Coatings , las t amended on December 18, 2008.

**•** El Dorado, Rule 23 1

, Graphic Arts Operations , last a mended on September 27, 1994

.
We also reviewed rules from other Air Districts including:

**•** South Coast AQMD Rule 1130, Graphic Arts , last amended on October 8, 1999

**•** Bay Area AQMD Regulation 8, Rule 20, Graphic Arts Printing and Coating O perations

, last amended on November 19, 2008.

**•** San Diego County APCD , Rule 67. 16

, Graphic Arts Operations

, last amended on May 9

, 20 12

.

**•** Ventura County APCD, Rule 74.19, Graphic Arts

, last amended on June 14, 2011.

These Districts are designated as non

- attainment areas for the Federal national ambient air quality standard for ozone. Thus , they also are required to implement CTGs in their rules.

Proposed Rule amendments, in underline/strikeout format, are shown in Attachment #1. Specific changes to the Rule include:

Section 100. General

Section 102. Applicability

. Subsection s 102.1 and 1 02 .2 provisions are combined into one section

.

Section 104. Exemptions

. Changes to the section include:

Section 104.1. General

. Section 104.1.1 expired on April 8, 2005, thus it is deleted

. The phrase “after April 8, 2005” contained in Sub section 104.1.2 no longer applied and is removed

.

Section 104.2. Proof Presses and/or Research and Test Development Operations

. This section expired on April 8, 2005 , thus it is deleted

.

Section 104. 7

. Aerosol Adhesives

– Graphic Arts Operations

. For clarification, “ other than screen printing” is added to specify that this exemption for aerosol adhesives is only applicable to graphic arts operations other than screen printing.

Section 104. 2

. Stripping of Cured Inks, Coatings, or Adhesives

. A specific exemption is added for strippers, as contained in other District rules. This is consistent with (no change from ) the requirements of the current existing ru le which indirectly exempts strippers from VOC limits because there are no specific limits stated for stripper s and strippers are not in cluded in the Solvent Cleaner sub

- categories

.

Section 104.8. Fountain Solutions

. As recommended by the CTG and contained in other District rules, an exemption from VOC content limits for fountain solutions is added when facility wide total potential to emit VOC emissions before control is less than 450 lb/month

.

Section 104.5

. Prepress Operations

. For clarification, the cleaning or processing of color scanners, plate processors, film cleaning and plate developers is added to this exemption

.Staff Report

– Revision to Rule 2 39 October 11, 2012 Page 3

Section 104.9. Blanket Repair Materials

. A small quantity exemption is added for blanket repair materials when used in containers of four ounces or less , as contained in other District rules.

Section 104. 10

. Heatset Web Offset Lithographic Printing and He atset Web Letterpress Printing . This new section exempts these specific operations from needing add

- on control requirements contained in new Section 302.1 when potential to emit VOC emissions are less than 25 tons per year.

Section 200. Definitions

Definitions that are eliminated include: lithographic and letter press printing, other cleaning

, V olatile organic compound ( VOC ) as supplied

, V olatile organic compound ( VOC ) as applied

.

Definitions that are added include: Adhesive, Aerosol Adhesive, Al cohol, Blanket

, B lanket repair material

, Cured ink, cur ed coating, or cured adhesives, H eater or dryer

, Ink jet

, R emovable press component

, Stripping, Roller wash , VOC content.

Definitions that are amended include: B lanket and roller washes

, Fugitive emissions, Graphic
art s operations, Gravure printing, L ithographic printing

, Metering roller, Noncompliant material

, O ffset printing

, P repress operations

.

Section 300. Standards

Section 301. General R equirements

. This section is deleted since it is redundant to other sections already contain in the rule

.

Section 30 1

. VOC Content Limits for Materials used in Graphic Arts Operations

. This section was previously numbered S ection 302 . Additional c hanges to the section include:

**•** Section 301.1, VOC Content for Inks, Coatings, and Adhesives

, The VOC content limit for the Sign Ink/Coating sub category was reduced to from 500 g/l to 400 g/l

. T he VOC content limit for the Extreme Performance I nk /Coating sub catego ry was reduced from 800 g/l to 400 g/l

. These changes are based on EPA recommendations and other Air District rules

.

**•** Sectio n 301.2, VOC Content for Fountain Solution Materials

. F ountain solution

c ategory and subcategories are modified, and applicable VOC content limits are lowered

, based on the CTG re commendations

.

**•** Section 301.4 . A new section that prohibits the use of fountain solut ions containing alcohol on cold set web offset lithographic presses is added based on the CTG recommendations

.

Section 30 3

. E mis sion Control Equipment. This section has been renumbered to Section 302 . Other changes to the section include :

**•** Section 30 2 .1. Heatset Web Offset Lithographic or Letterpress

. Add

- on control requirements for this category are added to meet the CTG recommendations.

**•** Section 30 2

. 2

. Alternative Emissions Control Equipment

. A title is added to the section for clarification. S ubsections 303. 2.2 through 303.2 .4 are added to specify combined overall capture and control system efficiency requirements rather than separate control and c apture efficiency requirements

, as required by the CTG. S ubsections 30 3 .2.1 and 303.2. 1 , which contained the current capture and control methods are deleted.Staff Report

– Revision to Rule 2 39 October 11, 2012 Page 4

Section 304

. Cleaning and Storage R equirements

. This section is renumbered to Section 303 . C hanges to this section include :

**•** Section 30 3 .1

. For cleaning solvents, for a couple of subcategories

, VOC content limits and VOC composite partial vapor pressure limits are lowered to 6 7 0 g/l and 10 mm Hg respectively

. This is to meet CTG recommendations of VOC content of less than 70% by weight (equivalent to a VOC concentration of 6 7 0 g/l) and partial pressure of less than 10 mm Hg

.

**•** Section 304 .2. Lithographic and Letter Press Printing, Other Cleaning

. This section

, which restricts the quantity of mo nthly usage of “other” cleaning solutions in compariso n to blanket and roller wash us age, is eliminated. This requirement effectively produces no benefit since the VOC content limit in g/l for “other” cleaners is identical to the limit for blanket and rol ler washes.

Section 400. Administrative Requirements

Section 401 . Operation and Maintenance Plan

. This section is moved to Section 302.2

. 5.

Section 403. Calculation for Determining VOC Composite Partial Pressure

. This section is moved to Section 262

.

Section 40 4

. C alculation for D etermining VOC content of Material Excluding Water and E xempt compounds

. This section is moved to Section 26 4 .1

.

Section 40 5

. Calculation for D etermining VOC Content of Material Including Water and Exempt C ompounds

. This section is moved to Section 26 4 .2

.

Section 40 7. Calculation for Determining VOC Emissions for Stationary Sources I ncluding those ex empt pursuant to section 104.1, 104.2 and 104.7

, Sections 104. 2 is eliminated from the title since it expired on April 8 , 2005

.

Section 500. Monitoring and Record

Section 50 1. Recordkeeping

. Recordkeeping requirement of the percentage of Lithographic and Letter Press, Other Cleaning materials requirement is deleted since it is no longer required by the R ule. Also, Subsections 501.3.3 and 501.3.4 are added to ensure adequate usage records.

Section 502. T est methods

. Section 502.4, Determination of Control Efficiency, is deleted.

Further, applicable test methods references are updated to the most approved current versions.

Miscellaneous

Additional miscellaneous changes were made for readability and conformance with the CTG which have no impact on the compliance requirements of the Rule.

ANALYSISStaff Report

– Revision to Rule 2 39 October 11, 2012 Page 5

The following Analysis and the subsequent Findings are intended to address the requirements set forth in the Health and Safety Code relating to adoption of a new or amended District Rule, as well as other State statutes referenced herein.

1. Cost

- Effectiveness of a Control Measure

California Health & Safety Code (H&S) Section 40703 requires a District to consider and make public “the cost

- effectiveness of a control measure”. The compliance costs are associated with replacing existing graphic arts and cleaning products with VOC content that meets the amended rule limits, as well as new work practice and recordkeeping requirements

. Graphics arts products that meet proposed VOC content limits are well

established to be readily available at the same price points as produ cts that will become

non

- complia nt when the proposed amendments will beco me effective on October 11, 2012

. The cost effectiveness has been determined to be acceptable by the EPA and other Air Districts that have already implemented the CTG requirements

. EPA concluded that CTG requirements actually produce a cost saving ranging from $700 to $1,500 per year for each printing operation

. T he graphic arts operations located within the District are not expected to be significantly affected (no adverse impacts on t he profitably of business) by the proposed rule changes

.

2. Socioeconomic Impact

H&S Section 40728, in relevant part, requires the Board to consider the socioeconomic impact of any new or amended rule if air quality or emission limits are significantly affected. N umerous existing graphic arts shop operations are already operating in compliance with the amended rule standards.

3. Environmental Review and Compliance

California Public Resources Code Section 21159 requires an environmental analysis of the reasonably foreseeable methods of compliance should be conducted. Compliance of the proposed rule amendment is expected to be achieved by the replacement of current graphic arts products with compliant compounds. Application of these compliant compounds will generally result in less VOC emissions from the graphic arts activities. Therefore, the proposed rule amendment will reduce emissions from sources and will not cause any significant adverse effects on the environment. Staff has concluded that no ad verse environmental impacts will be caused by compliance with the proposed rule amendment.

According to the above conclusion, Staff finds that the proposed rule amendment is exempt from the California Environmental Quality Act (CEQA) because : (1) it can b e seen with certainty that there is no possibility that the activity in question may have a significant adverse effect on the environment (CEQA Guidelines §15061(b)(3))

, and (2) it is as an action by a regulatory agency for protection of the environment (C lass 8 Categorical Exemption, CEQA Guidelines §15308).

FINDINGS

A. Necessity : The adoption of proposed amended Rule satisfies the objective of the District to implement “ Control Techniques Guidelines ” for the reduction of VOCs to achieve attainment with ambient air standards for ozone, and meets the District’s requirements to implement “every feasible measure” and “Best Available Retrofit Control Technology” as required under California Health and Safety Code Sections 40919 and 40914.Staff Report

– Revision to Rule 2 39 October 11, 2012 Page 6

B. Authority : Californ ia Health and Safety Code, Sections 40000, 40001, 40701, 40702, 40716, 41010, and 41013, are provisions of law that provide the District with the authority
to adopt this proposed amended R ule.

C. Clarity : There is no indication, at this time, that the propos ed amended R ule is written in such a manner that persons affected by the R ule cannot easily understand them.

D. Consistency : The proposed amended Rule is in harmony with, and not in conflict with or contradictory to, existing statutes, court decisions, or st ate or federal regulations.

E. Non

- duplication : The proposed amended Rule does not impose the same requirements as an existing state or federal regulation.

F. Reference : All statutes, court decisions, and other provisions of law used by the District in interpreting this proposed amended Rule are incorporated into this analysis and this finding by reference.

SUMMARY

Rule 2 3 9

, Graphic Arts O perations , has been amended to address the control guidance contained in the U.S. EPA’s CTG for Graphic Arts issued in September 200 6 (EPA

- 453/R

- 06

- 002).

### ATTACHMENT # 1

Subject:

District response to the U.S. EPA comments on

Rule 23 9

, Graphic Arts Operations

### ATTACHMENT # 2

Subject:

Strikeout Rule 23 9

, Graphic Arts Operations