UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX AIR DIVISION

Technical Support Document

for EPA’s Direct Final Rulemaking

for the California State Implementation Plan

Placer County Air Pollution Control District,

Rule 2 39 , Graphic Arts Operations

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

Dec ember 201 3 2

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RULE IDENTIFICATION

Agency: Placer County Air Pollution Control District ( P C APCD)
SIP

- Approved Rule: Rule 239
– Graphic Arts Operations Adopted
– November 3, 1994
A mend ed
– February 13, 1997
Submitted
– August 1, 1997 Approved
– November 13, 1998 (63 FR 63410) Subject of this TSD: Rule 2 39
– Graphic Arts Operations
Amended
– October 11, 2012
Submitted
– February 6, 2013

RULE SUMMARY
– PCAPCD Rule 2 39 limit s the emissions of Volatile Organic Compounds (VOCs) from graphic arts operations in the District. It had been previously adopted and revised and approved by EPA into the State Implementation Plan (SIP). However, that version of the rule did not fully address EPA’s 2006 Control Techniques Guideline ( CTG ), Control of VOC Emissions from Offset Lithographic and Letterpress Printing ( EPA

- 453/R

- 06

- 002) , and California Air Resources Board’s (CARB) 1992 Graphic Arts Printing Operations Compliance Assistance Manual which recommends limits based on South Coast Air Quality Management District’s (SCAQMD) Rules 1130 , Graphic Arts, and 1130.1 , Screen Printing Operations , Bay Area Air Quality Management District (BAAQMD) Rule 20
, Graphic Arts P rinting and Coating Operations, and Ventura County Air Pollution Control District’s (VCAPCD) Rule 74.19 , Graphic Arts

. In Section 100, partial e xemptions for facilities emitting less than 660 pounds of
VOC and for Pro of Presses and/or Research and T est Dev elopment Operations
and a full exemption for Screen Printing Operations were deleted

. E xemptions for Stripping of Cured Inks, Provisions covered in Rule 219, Organic Solvents, Coatings or Adhesives, Business and Personal Printers, Aerosol Adhesi v es for Sc reen Printing and Graphic Arts Operations, Fountain Solution s , B l anket Repair Material s 3

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and Heatset Web Offset Lithogr aphic Printing and Heatset Web L etterpress Printing
were added. In Section 200, Definitions, several definitions were revised for clarity

. D efinitions
for Aerosol Adhesive; Alcohol; Application Equipment; Blanket; Blanket Repair Material; Blanket Washes; Closed Container; Cured Ink, Cured Coating, or Cured Adhesives; Electronic Circuit; Embossing, Extreme Performance Ink/Coating; Heater

or Dryer; Heat Bending; Heatset Ink; Ink Jet; Inflating; Maintenance Cleaning; Material; Mechanically Formed Products; Metallic Ink; Metering Roller; Noncompliant Material; Overlay; Prepress Operations; Printing; Printing Ink; Proof Press; Proof Press Compone nt; Refrigerated Chiller; Removable Press Component; Repair Cleaning; Roller Wash; Sign Ink/Coating; Solvent Cleaning; Specialty Flexographic Printing; Stationary Source; Stripping; Substrate; Ultraviol et Ink; Vacuum

- forming; VOC Composite Partial Pressure ; VOC Content ; Water Slide Decals; and Wipe Cleaning were added. Definitions for Capture Efficiency ; Control Device Efficiency; Doctor Blade, Itaglio Printing, Packaging Gravure Printing; Porous Substrate; Production Unit; Publication Gravure Printing; Spe cialty Gravure Printing; VOC
Content of Fountain Solut ions, Makeup Solvents, Surface P reparations Solvents and Cleaning Solvents ; and VOC of Inks, Coatings and Adhesives were deleted. Actual VOC limits for Inks, Coatings and Adhesives and for Fountain Sol ution Materials were added in Section 300. Requirements for Emission Control Equipment were added and Cleaning and Storage Requirements were expanded to include limits for specific cleaning materials. Section 400 was revised to delete the previous Operati on and Maintenance Plan and Compliance Statement Requirements and add Product Information requirements as well as calculations for determining Percent Control Efficiency, VOC Mass Emission Rate and VOC Emissions for Stationary Sources. Section 500 now inc ludes a List of Material which includes the information required for each type of material and the Usage Records subsection has been revised for
clarification and to include more product information. Recordkeeping of Emission Control Equipment was added an d the Duration of Records was revised to include 4

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records for sources subject to the Federal Operating Permit Program. The Test methods of subsection 502 were expanded to include Determination of VOC Composite Partial Pressure, Determination of Vapor Pressu re and Determination of
Metal Content in Inks tests. The Sacramento Region has been designated as a severe nonattainment area for the federal ozone standard by the EPA. The District is therefore required to meet
RACT.

EPA EVALUATION

- The following crit eria were used to evaluate the submitted
R ule: Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988) and the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate compliance with the CAA §110(a)(2)(A) requirement for enforceability.

Stringency

- Rule 2 39 was evaluated against EPA’s CTG titled, “Control Techniques Guidelines: Control of VOC Emissions from Offset Lithographic and Letterpress Printing ( EPA

- 453/R

- 06

- 002 , Sept ember 2006 ) to evaluate the RACT requirements of CAA § 182(b)(2). Rule 239 was also compared to other Districts’ rules for graphic arts operations

.

SIP Relaxation

- We have evaluated this SIP revision to determine whether it would interfere with any applicable requirement concerning attainment and reasonable further progress (R FP) or any other applicable requirement of the Act (CAA § 110(l)) or modify, in a nonattainment area, any SIP

- approved control requirement in effect before November 15, 1990 (CAA § 193).

RULE EVALUATION 5

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Enforceability

- P CAPCD ’s Rule 2 39 specifies clear, unambiguous terminology that closely resembles the definitions of VCAPCD Rule 74.19, Graphic Arts

. Each type of graphic art coating, adhesive and solvent is described in section 200 and distinguished from other categories that are clearly delineated in the limits table s in
section 301 and 303

. Cleaning and storage requirements are clearly described in
section 30 3

. Whil e the Emission Control System r equirements of section 30 2 do not specify equipment, they do clearly indicate the required parameters. Th e requirement for monitoring and for submitting records in section 500 further strengt hens this
R ule’s enforceability

. Test methods are similar to those in SMAQMD’s Rule 466

.

Stringency

- PC APC D’s Rule 239, Graphic Arts Operations, is large ly consistent
with the EPA CTG: Control of VOC Emissions from Offset Lithographic and Letterpress Printing and other current rules by other Districts

. As a result, we believe this Rule fulfil l s RACT requirements.

Relaxation

- We propose to determine that our approval of the submittal would comply with CAA § § 110(l) and 193 because the proposed rule will not interfere with the ongoing process for ensuring that the requirements for RFP and attainment of the National Ambient Air Qua lity Standards (NAAQS) are met and because the

em ission limits in the submitted R ule are more stringent than the existing SIP

approved control requirements that they would replace.

RULE DEFICIENCIES
– We have identified no deficiencies in submitted Rule 2 39 ’s that would interfere with approval of this Rule

.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION
– The following revisions a re not currently the basis for R ule disapproval, but we encourage PCAPCD to consider these recommendations the next time the R u le is amended: 6

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1. W e r ecommend that the exempt solutions and operations in subsections 104.1, General E xceptions, 104.7, Aerosol Adhesives
– Graphic Arts Operations, 104.8, Fountain Solutions and 104.10, Heatset Web Offset Lithographic Printing and Heatset Web Letterpress Printing , be required to have daily reporting instead of monthly reporting as described in subsections 501.3.2, 502.3.3 and 501.3.4.
2. Consider lowering the solvent cleaning limits in subsection 303.1 to the lower limits required in SCAQMD Rule 1171, Solvent Cleaning Operations, effective 1/1/2010. We recommend the following solvent limits:

Material Type Actual VOC Content g/l (lb/gal) General (e.g maintenance, repair, wipe) cleaning 25(0.21)

Application Equipment Cleaning General (not specifically listed below) 25(0.21) Lithographic and Letter Press Printing, Blanket and Roller Washes and Other
On

- Press Components 100(.83)

Lithographic and Letter Press Printing, Other Cleaning 25(0.21)

Screen Printing 100(.83) Flexographic Printing 25(0.21) Specialty Flexographic Printing 100(.83) Ultraviolet Inks (except Screen Printing) 100(.83)

EPA ACTION

- EPA staff recomm ends an approval of Rule 2 39 pursuant to CAA §110(k) (4) and §301(a). 7

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ADDITIONAL REFERENCES
– 1. PCAPCD Rule 2 39
– Graphic Arts Operations , amended February 13 , 1997.
2. PCAPCD Rule 2 39
– Graphic Arts Operations , amended Octo ber 11, 20 12 , submitt ed February 6 , 201 3

. 3. SCAQMD Rule 11 30
– Graphic Arts, Amended October 8, 1999.
4. SCAQMD 1130.1
– Screen Printing Operations, Amended December 13,
1996.
5. SCAQMD Rule 1171
– Solvent Cleaning Operations, amended May 1, 2009.
6. S D APCD Rule 67.16
– Graphic Arts Operations , A dopt ed Nov ember 9 , 20 11, Effective May 9, 2012

. 7. VCAPCD Rule 74.19
– Graphic Arts, Revised June 14, 2011.
8. Control Techniques Guidelines (CTG): Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing , EPA 435/R

- 06

- 00 2 , September, 2006. http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/200609_v oc_epa453_r

- 06

- 002_litho_letterpress_printing.pdf
9. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001. http://www.epa.gov/Region09/air/sips/littlebluebook2001.pdf