### SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

FINAL STAFF REPORT

Proposed Amended Rule 11 30

- Graphic Arts

MAY 2014

Deputy Executive Officer, Planning, Rul e Development, and Area Sources Elaine Chang, Dr. PH

Assistant Deputy Executive Officer, Planning, Rul e Development, and Area Sources Philip M. Fine, Ph.D.

Planning and Rules Manager, Planning, Rule Development, and Area Sources Naveen Berry

______________________________________________________________________________ AUTHOR: Don Hopps AQ Specialist REVIEWED BY: David Ono Program Supervisor Laki Tisopulos, Ph.D., P. E. Assistant Deputy Executive Officer Karin Manwaring Senior Deputy District Counsel

CONTRIBUTORS: Jeff Inabinet AQ Specialist/CEQA Shah Dabirian AQ Specialist/Socio economicsSOUTH COAST AIR QUAL ITY MANAGEMENT DISTR ICT GOVERNING BOARD

CHAIRMAN: DR. WILLIAM A. BURKE Speaker of the Assembly Appointee

VICE CHAIRMAN: DENNIS YATES Mayor, Chino Cities of San Bernardino MEMBERS: MICHAEL D. ANTONOVIC H Supervisor, Fifth District County of Los Angeles

BEN BENOIT Mayor Pro Tem , Wildomar Cities of Riverside County

JOHN J. BENOIT Supervisor, Fourth District County of Riverside

JOE BUSCAINO Councilmember, Fifteen th District City of Los Angeles

MICHAEL A. CACCIOTTI Councilmember , South Pasadena Cities of Los Angeles County/Eastern Region

JOSIE GONZALES Supervisor, Fifth District County of San Bernardino

JOSEPH K. LYOU, P h

. D. Governor’s Appointee

JUDITH MITCHELL Mayor , Rolling Hills Estates Cities of Los Angeles County/Western Region

SHAWN NELSON Supervisor, Fourth District County of Orange

DR. CLARK E. PARKER, SR. Senate Rules Appointee

MIGUEL A. PULIDO Mayor, Santa Ana Cities of Orange County

EXECUTIVE OFFICER: BARRY R. WALLERSTEIN, D. ENV.TABLE OF CONTENTS

EXECUTIVE SUMMARY
E

XECUTIVE S UMMARY

................................ ................................ ................................ ................................ ............................. ES

- 1

CHAPTER 1

– BACKGROUND ON PROPOS ED AMENDED RULE 1130
I NTRODUCTION

................................ ................................ ................................ ................................ ................................ .............. 1

- 1

R

EGULATORY H ISTORY

................................ ................................ ................................ ................................ ............................... 1

- 1

A

FFECTED F ACILITIES

................................ ................................ ................................ ................................ ................................ .. 1

- 1

O

FFSET L ITHOGRAPHY P ROCESS D ESCRIPTION

................................ ................................ ................................ ....................... 1

- 2

CHAPTER 2: SUMMARY O F PROPOSED AMENDED R ULE 1130
O

VERVIEW : P ROPOSED A MENDMENT TO R ULE 1130

................................ ................................ ................................ ............. 2

- 1

S UBDIVISION ( A

) P URPOSE AND A PPLICABILITY

................................ ................................ ................................ ...................... 2

- 1

S UBDIVISION ( B ) D EFINITION S

................................ ................................ ................................ ................................ .................... 2

- 1

S UBDIVISION ( C ) R EQUIREMENTS

................................ ................................ ................................ ................................ ............... 2

- 4

S UBDIVISION ( D ) P ROHIBITION OF S PECIFICATION AND S ALE

................................ ................................ ................................ 2

- 8

S UBDIVISION ( F

) R ULE 442 A PPLICABILITY

................................ ................................ ................................ .............................. 2

- 9

S UBDIVISION ( G ) E MISSION R EDUCTION C REDITS

................................ ................................ ................................ ................... 2

- 9

S UBDIVISION ( H ) T EST M ETHODS

................................ ................................ ................................ ................................ ............... 2

- 9

S UBDIVISION ( I ) E XEMPTIONS

................................ ................................ ................................ ................................ ................... 2

- 1 2

CHAPTER 3 : IMPACT ASSESSMENT OF PROPOSED AMENDED RULE 1130
E

MISSION I MPACT A SSESSMENT

................................ ................................ ................................ ................................ ................. 3

- 1

C OST A NALYSIS

................................ ................................ ................................ ................................ ................................ ............ 3

- 1

C ONTROL D EVICE E FFICIENCY

................................ ................................ ................................ ................................ ................... 3

- 1

F

OUNTAIN S OLUTIONS

................................ ................................ ................................ ................................ ................................ . 3

- 1

S TORAGE OF C ERTAIN N ON

- C OMPLIANT VOC

- CONTAINING M ATERIALS

................................ ................................ .......... 3

- 1

I NCREMENTAL C OST

- E

FFEC TIVENESS

................................ ................................ ................................ ................................ ..... 3

- 1 2

C

ALIFORNIA E NVIRONMENTAL Q UALITY A CT (CEQA)

................................ ................................ ................................ ........ 3

- 2

S OCIOECONOMIC I MPACT A SSESSMENT

................................ ................................ ................................ ................................ .... 3

- 2

D RAFT F INDINGS UNDER C ALIFORNIA H EALTH AND S AFETY C ODE 40727

................................ ................................ ........ 3

- 2

C OMPARATIVE A NALYSIS

................................ ................................ ................................ ................................ ........................... 3

- 3

D RAFT C ONCLUSIONS AND R ECOMMENDATIONS

................................ ................................ ................................ ................... 3

- 3

P

UBLIC C OMMENTS AND R ESPONSES

................................ ................................ ................................ ................................ ........ 3

- 3

REFERENCES

................................ ................................ ................................ ................................ ..... R

- 1

A

PPENDIX A

- VOC E MISSION C ALCULATION M ETHODOLOGY FOR L ITHOGRAPHIC P RINTING O PERATIONS

............. A

- 1

A

PPENDIX B

- D ETERMINING C OLLECTION E FFICIENCIES FOR A IR P OLLUTION C ONTROL S YSTEMS S ERVING H

EAT

- S ET L ITHOGRAPHIC P RINTING P RESSES

................................ ................................ ................................ .......................... B

- 1

LIST OF TABLES
T

ABLE 1

- SIC C ODES U SED FOR PAR1130

................................ ................................ ................................ .............................. 1

- 1

T

ABLE 2

- P ERMITTED E QUIPMENT AND P ERCENTAGE D ISTRIBUTION

................................ ................................ ................. 1

- 1

T

ABLE 3

– P ROPOSED T ABLE O F S TANDARDS I

................................ ................................ ................................ ....................... 2

- 4

T

ABLE 4

- C ONVERSION OF P ERCENTAGE OF VOC V ALUES TO M ASS /V OLUME VOC V ALUES

................................ ...... 2

- 5

T

ABLE 5

– P ROPOSED T ABLE O F S TANDARDS II

................................ ................................ ................................ .................... 2

- 6 7

iEXECUTIVE SUMMARYExecutive Summary Final Staff Report

EXECUTIVE SUMMARY
Rule 1130

– Graphic Arts

- is a source specific rule that was adopted to limit Volatile Organic Compound (VOC) emissions associated with graphic arts operations. The rule applies to any person who supplies, s ells, markets, offers for sale, distributes, applies or solicits the applica tion of graphic art materials for use in any graphic arts operation in the District

. Rule 1130 was adopted on October 3, 1980 and has been subsequently amended fourteen times; t he most recent amendment was October 8, 1999.

Staff conducted an internal review of Rule 1130 to determine if the existing rule met all the
recommendation s specified 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)

. As a part of the 2012 AQMP development, s taff found inconsist e ncies between the CTG and Rule 1130 and
recommend s amend ing Rule 1130 to ensure the level of stringency in the applicable CTGs

.

The proposed amendment partially implements the 2012 AQMP, Control Measure CTS

- 02

- Further Emission Reductions from Miscellaneous Coatings, Adhesives, Solvents and Lubricants

an d the Reasonably Available Control Measures (RACM) Demonstration of Appendix VI . Since local affected operations already comply with the requirements, the proposed amendments are not expected to achieve additional VOC reductions.

PROPOSAL
The amendment to Rule 1130 proposes making changes to improve consistency with the CTGs applicable to printing operations regulations by amending the overall add

- on control device efficiency requirements and VOC content limits for fountain solutions. The proposed
amend ment further adds prohibition of storage of non

- compliant VOC

- containing materials at a worksite, removes obsolete rule language, updates definitions for consistency with other District rules, adds an exemption for graphic arts materials that have a VOC co ntent of no more than 10 g/L, as applied, and makes minor corrections and clarifications.

CEQA In accordance with the California Environmental Quality Act (CEQA), the SCAQMD is the Lead Agency and has prepared a Draft Environmental Assessment (EA) to analy ze environmental impacts from the proposed project pursuant to its certified regulatory program (SCAQMD Rule 110). The Draft EA includes a project description and analysis of potential adverse environmental impacts that could be generated from the propose d project. Comments focusing on issues relative to the environmental analysis for the proposed project will be were accepted during a 30

- day public review and comment period beginning February 25, 2014, and ending 5 p.m. on March 26, 2014.

SOCIO

- ECONOMIC The proposed amendments codify existing practices at graphic arts operations that are subject to Rule 1130. As such, there will no additional costs or other socioeconomic impacts.

Proposed Amended Rule 1130 ES

- 1 May 2014RULE 1130

– GRAPHIC ARTS

CHAPTER 1: BACKGROUND ON PROPOSED AMENDED RULE 1130

ο Introduction

ο Regulatory History

ο Affected Facilities

ο Offset Lithography Process DescriptionChapter 1: Background on Proposed Amended Rule 1130 Final Staff Report

INTRODUCTION
Rule 1130

– Graphic Arts is a source specific rule that was adopted to limit Volatile Organic Compound (VOC) emissions associated with graphic arts operations. The rule applies to any person who solicits , specifie s, offers for sale, sells, or distributes graphic arts materials for use in
the District

. This rule amendment is driven by inconsistencies identified between Rule 1130 with
the United States Environmental Protection Agency’s (U.S. EPA) C ontrol Techniques Guidelines (CTG) for Offset Lithographic Printing and Letterpress Printing (EPA 453/R

- 06

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

- 06

- 003)

.

REGULATORY HISTORY
Rule 1130 was adopted on October 3 , 19 8 0 and has been subsequently amended fourt een times.
The most recent amendment was on October 8

, 1999

, which further reduced VOC emissions, required higher efficiencies for add

- on controls , eliminate d the small user exemption, and specif ied retention factors for lithographic inks.

AFFECTED INDUSTRIES
Rule 1130 is applicable to any person who solicits, specifies , offers for sale, sell s , or distributes

gr aphic arts materials for use in the District. Using the Standard Industrial Classification (SIC) codes, s taff conducted a search in the Automated Equipment Inventory Systems (AEIS) database
to find industries that conduct graphic arts operations. Table 1 shows the following SIC codes that apply to this proposed rule amendmen t

.
TABLE 1

– SIC CODES USED FOR PAR1130

PAR1130

- SIC CODE S USED

2399 5112 2731 7336 2711
2672 2732 3993 2396 2761
3089 2753 7384 2754 9999
7011 2771 3569 2741 2759
2260 3199 2750 2329 2752

2893 2721 2782 2751

Using the SIC codes in Table 1

, staff surveyed the active facilities with active permits in AEIS for
all graphic arts printing operations and categorized the active permits per county as shown in Table
2

.
TABLE 2

– PERMIT TED EQUIPMENT AND PERCENTAGE DISTRIBUTION

COUNTY NUMBER OF P ERMIT S PERCENTAGE

Los Angeles county 403 6 9 % Orange county 1 46 2 5 % Riverside county 31 4 % San Bernardino county 1 5 2 %
SCAQMD Jurisdiction 58 7 100%

Proposed Amended Rule 1130 1

- 1 May 2014Chapter 1: Background on Proposed Amended Rule 1130 Final Staff Report

However, there are some printing operations with low emissions potential that are exempt from permit ting based on District Rule 219

– Equipment Not Requiring a Written Permit Pursuant To Regulation II but would continue to be subject to Rule 1130

.

OFFSET LITHOGRAPHY PROCESS DESCRIPTION
Of fset lithography is a common printing process that is used to produce large volumes of brochures, books, magazine s , posters and newspapers and is the primary focus of the proposed
amendment

. Offset lithography is a planographic method of printing which means that the printing
and non

- printing areas are in the same plane on the surface of a thin lithographic plate. The inked image is transferred, or offset, from the plate to a rubber blanket cylinder and from that, to the

su bstrate

. The ink that is transferred to the lithographic plate contains the image area , which
receive s the oil based ink, and the non

- image area , which is wetted with a water based solution,
called the fountain solution, that provides a film that repels the ink . Since oil and water don’t mix, the image area is transferred to the printing surface of the s u bstrate whereas the non

- image a re as do not rece i ve ink and thus no ink transfer occurs. There are two subsets of offset lithography printing and they are characterized by the way they are fed into the press, sheet

- fed and web

- fed printing. Both sheet

- fe d and web

- fed printing inks dry by a combination of absorption and
oxidation

.

Sheet

- Fed Offset Lithographic Printing Process
Sheet

- fed printing refers to feeding individual sheet s of paper or other substrate to the press.
Sheet

- fed operations consist of a lithographic plate in which oil

- based ink and water based
fountain solutions are use d for the printing operation. Sheet

- fed printing generally consists of
short

- run operations for products such as magazines, brochures, letter heading and other similar
ty pe printing.

Web

- Fed Offset Lithographic Printing Process
Web

- fed printing refers to feeding rolls of paper or other substrate to the press. Web

- fed printing
consist s of a lithographic plate in which oil

- based ink and water based fountain solutions are us e d for the printing process . Web

- fed printing generally consist of large volume run operations that
can be run at high speeds for products such as magazines, brochures, letter heading and other similar type printing. There are two subsets for web

- fed off set lithographic printing presses , heatset and coldset.

Heatset Offset Web Presses Heatset offset web presses are used for both coated and non

- coated substrates such as magazines, catalogs, inserts and other medium

- to

- high volume production runs where the inks dr y by evaporation due to the application of heat. The typical process uses a coated web that is fed into the press, ink is applied to the substrate and the ink dries by the heat applied by a dryer

. The heated substrate is then cooled down by ch illed rollers which are used to set the ink.

Proposed Amended Rule 1130 1

- 2 May 2014Chapter 1: Background on Proposed Amended Rule 1130 Final Staff Report

Coldset (non

- heatset) Offset Web Presses
Coldset offset web presses , also known as non

- heatset web presses, are typically used for uncoated
substrates such as newspaper where the ink dries by absorption into the paper and by evaporation. However, some cold s et presses may use ultraviolet or electron beam inks that cure by ultraviolet or electron beam polymerization for generally higher quality printing products. In some cases, a coldset press may be fitted with heat dryers t hat have the capability to print color pages heatset and also print white pages cold s et. For the purposes of Rule 1130, ultraviolet and electron beam curable inks are examples of non

- heatset inks and can be used on heatset web, and non

- heatset web

, and sheet

- fed presses

.
Flexographic Printing Flexographic printing is direct rotary printing using a rubber or polymer printing plate with raised images. The ink is applied to the plate by an anilox roller consisting of minute etched cells, which
ho ld ink and transfer ink to the flexible printing plate. A doctor blade that swipes excess ink from the roller, controls ink deposition. Most flexographic presses are web

- fed and capable of printing
four

- color work on a continuous stream of substrate.

Let terpress Printing Letterpress is high

- speed quality printing and the a method of printing is the same as flexographic printing. That is, where the image areas are raised above the printing plate although the raised images are metal, rather than elastomeric non

- image areas

.

Gravure Printing Gravure or rotogravure printing is a method of printing that use s A a n engraved negative cylinder accomplishes gravure printing . The roller has tiny cells and dots of various sizes and depths. Ink is applied by another roller or bath and a flexible metal doctor blade screeds scrapes excess ink leaving only the cells or dots with coverage. Paper is fed between the inked printing cylinder and an impression roller coated with a resilient blanket. This method of pr inting produces high quality. Both sheet

- fed and web

- fed configurations are used.

Offset Lithographic Inks Offset Lithographic printing inks are paste inks and contain pigments, vehicles, binders and other additives. The pigments contain the desired color, the vehicle is the solvent that carries the pigment and binder, the binders fix the pigment to the substr ate and the additives contain waxes,
lubricants and driers. The inks are generally composed of also contain petroleum and vegetable
oils. Some printing operations may use varnishes, essentially an ink without pigmentation

. Heatset inks may contain up to 45% VOCs. In heatset web lithographic printing, 20 % of the petroleum ink oils and essentially all of the vegetable ink oils are retained in the substrate and dry ink film. The remaining 80% of the petroleum ink oil is volatilized in and then exhausted f rom the dryer. Since the vegetable ink oil does not volatilize in the dryer, the amount of vegetable ink oil that can be used in heatset web offset lithographic inks is very limited. If there is too much vegetable oil in a heatset web offset lithographic ink, the ink will not dry properly . Coldset inks typically contain below 35% VOC and sheet

- fed inks contain below 25% VOC. In s heet

- fe d and

Proposed Amended Rule 1130 1

- 3 May 2014Chapter 1: Background on Proposed Amended Rule 1130 Final Staff Report

c oldset web offset printing, 95% of the petroleum ink oil s and essentiall y all of the vegetable oil s are absorbed into the substrate and dr i ed ink film. The remaining 5% of the petroleum ink oil is volatilized and emitted to atmosphere. Ultraviolet and electron beam energy cured inks are normally lower VOC

- containing inks. In the South Coast AQMD jurisdiction, the coatings are predominately water based or energy cured materials having low VOC emission s

.

SCAQMD guideline for calculating emissions for annua l reporting pursuant to Rule 304

– Fees

“ VOC Emission Calculation Meth odology for Lithographic Printing Operations

– December
2011 ” (see Appendix A) outlines the use of the aforementioned parameters, as well as additional
considerations for annual emission reporting purposes

.

Fountain Solution
Fountain solution s are used in the offset lithographic printing process and are primarily composed
of water with certain additives to moisten the non

- image area of the lithographic plate in order to keep ink from depositing (and thus printing) in areas where the ink is not wanted

. Sinc e offset lithographic inks are oil based and the fountain solution water based, the fountain solution renders
the non

- image areas unreceptive to ink and thus the ink is not transferred. The fountain solution contains a small amount of gum Arabic or synth e t ic resins, acids, and buffer salts to maintain the pH of the solution

. Alcohol s, including isopropanol, n

- propanol and ethanol, are typically added
to the water to lower the surface tension and increase the viscosity of the fountain solution

. The
alcohol substitute based fountain solutions are formulated using no alcohol and are typically glycol ethers or ethylene glycol ethers for lower VOC emissions but still provide the same purpose function as the alcohol containing fountain solutions. Fou ntain solutions are packaged as either a

“ one

- step ” or “ two

- step ” product . Fountain solutions consist of a concentrate of chemicals that are mixed with a large volume of water, typically 2 to 6 ounces of concentrate to one gallon of water,
and alcohol or alcohol substitute

, generally requiring two step s to make a press

- ready solution. Historically

, the alcohol was added in amounts of up to 25% of the solution to provide wetting to the dampening rollers and the non

- image areas of the printing p lates an d

, due to the amount of alcohol used, could not be packaged with the concentrate

. With lower alcohol or alcohol substitute requirements, combin in g the concentrate w i th the wetting agent as a single or one

- step formulation
became available

.

On larger pres ses, T t he “press

- ready” fountain solution is stored in a reservoir which is a collection tank that serves to hold the fountain solution while it is continuously recirculated from the reservoir to the fountain trays used at the printing working area. Smaller presses do not use a
recirculati on system , but dispense the fountain solution from small containers that are affixed to the press. The fountain tray simply hold s a small amount of fountain solution and by constant recirculation; the fountain solut ion not only provid es a film for non ink reten t ion but also serves to
cool the lithographic plate printing unit . The fountain solution reservoir typically is equipped with cooling coils for refrigeration of the fountain solution. The reservoir volume does not include the volume of the trays or any other additional containers such as mixing units.

Proposed Amended Rule 1130 1

- 4 May 2014Chapter 1: Background on Proposed Amended Rule 1130 Final Staff Report

Clean

- up materials Printing operations use clean

- up materials to remove printing inks, oils and residual paper
filaments from the press equipment during and a fter operations

. C lean

- up material s are generally organic

, however due to the VOC requirements of Rule 1171

– Solvent Cleaning Operations , many new cleaning materials are now manufactured from low

- VOC materials such as aqueous and soy
based materials.

Emi ssions Control System s Emission control systems are used in some graphic arts operations to reduce VOC emissions . The emission control system is another major strategy in the reduction of VOCs from offset lithographic printing operations. The capture system consists of equipment capable of collecting the emissions generated from the printing process and transferring the emissions to a control device. The control device is generally a thermal oxidizer or catalytic oxidizer and is used to
de stroy the emissions

.

The CTG recommend ed 90% control efficiency in the 1993 draft CTG and 95% control efficiency for a control device for equipment that was installed after the date of the current CTG, September 2006. The current version of Rule 1130 require s overall efficiency for flexography, packaging gravure, lithography and letterpre ss printing to be 75% or greater overall control efficiency (publication gravure require s 85% control device efficiency)

.

Staff identified 29 active permitted air pollution control devices in the AEIS records, all of which
meet the recommended CTG level s.

The CTG does not recommend capture and control of VOC emissions from sheet

- fed or cold set web inks because the VOC emissions from these operations are already low

, are not amenable to
add

- on control and inks can meet the lower VOC content limits

. Fountain solution s containing
VOCs alcohol can be controlled by re fr igerated cooling coils in the fountain reservoir where the temperature is of the fountain solution is maintained at 55 degrees Fahrenhe i t or less to control
volatilization.

In lieu of r equiring a source test to determine the collection efficiency, the SCAQMD allow s companies to use a collection (capture) efficiency default value of 99.5 percent for heat

- set lithographic printing, provided the operator can demonstrate that there is always sufficient air flow into the dryer through all the dryer’s openings (excluding the exhaust stack) to prevent emissions from escaping the dryer during normal operations. This approach reflects the CTG determination that heatset lithographic printing inks, which are paste

- like in nature with an initial high boiling point, volatilize only in the dryer. Lacking any physical evidence to the contrary (such as visible emissions emanating from the dryer) , an operator can make this demonstration by showing that the pressure inside the dryer is always negative (lower) relative to the static pressure of the press room by either of the methods specified in the SCAQMD ’s “ Compliance Advisory

– Determining
Colle ction Efficiencies for Air Pollution Control Systems Serving Heat

- S et Lithographic Printing

Presses

, 1997

. ” Appendix B includes a copy of this advisory

. Proposed Amended Rule 1130 1

- 5 May 2014RULE 1130

– GRAPHIC ARTS

CHAPTER 2: SUMMARY OF PROPOSED AMENDED RULE 1130

ο Overview: Proposed Amendment to Rule 1130

ο Subdivision (a) Purpose and Applicability

ο Subdivision (b) Definition s

ο Subdivision (c) Requirements

ο Subdivision (d) Prohibition of Specification and Sale

ο Subdivision (g) Emission Reduction Credits

ο Subdivision (h) Test Methods

ο Subdivision (i) ExemptionsChapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

OVERVIEW: PROPOSED AMENDMENT TO RULE 1130 The proposed amendment incorporates certain CTG recommendations applicable to printing operations not included in the current rule that pertain to the overall add

- on control device efficiency and VOC content requirements for fountain solutions. The proposed amendment further adds prohibition of storage of non

- compliant VOC

- containing materials at a worksite, removes obsolete rule language, updates definitions for consistency with other District rules, adds a rule exemption for graphi c arts materials that have a VOC content of no more than 10 g/L, as applied, and makes minor corrections and clarifications , including associated section renumbering

.



### Subdivision (a) Purpose and Applicability
Staff proposes the following revisions to subdivision (a) to further clarify the purpose and applicability:

“The purpose of this rule is to reduce emissions of v V olatile o O rganic c C ompound s (VOC)

emissions from graphic arts operations. The This rule applies to any person s performing graphic arts operations or who solicit, specify, offer for sale, sell, or distribute supplies, sells, offers for sale, markets, manufactures, blends, repackages, stores at a worksite, distributes, applies or solicits the application of graphic arts materials for use in the District .”



### Subdivision (b) Definitions Staff proposes the following revision to the definition “ Aerosol Coating Product ” to make it
consistent with the “ Aerosol Coating Product ” definition in other Regulation XI rules.

“ (1) AEROSOL COATING PRODUCT is a pressurized coating product containing pigments or resins that dispenses product ingredients by means of a propellant, and is packaged in a disposable can for hand

- held application, or for use in specialized equipme nt for ground marking and traffic

- marking applications.”

Staff proposes to add new definition s to the rule to define “ Alcohol ” and “ Alc oh ol Substitute ” :

“ (2) ALCOHOL is an organic compound that contains a hydroxyl (OH) group and is used in the fountain solution to reduce the surface tension and increase the viscosity of water to prevent piling (ink build

- up) . For purposes of this rule, alcohol includes, but is not limited to, isopropyl alcohol (isopropanol), n

- propanol and
ethanol.”

“ (3) ALCOHOL SUBSTI TUTE is an additive that contains VOCs but no alcohol and is used in the fountain solution to reduce the surface tension and increase the viscosity of water to prevent piling (ink build

- up).”

Staff proposes the following revision to the definition “ Coatin g ” to make it consistent with the

“ Coating ” definition in other Regulation XI rules.

Proposed Amended Rule 1130 2

- 1 May 2014Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

“ ( 2 4 ) COATING is a layer of material which is applied to a substrate surface in order to beautify, protect, or provide a barrier to such surface in a relatively unbroken film.“

Staff proposes to a dd a new definition to the rule to define “ Energy Curable Coatings, Inks and
Adhesives ” to provide clarity to energy curable graphic arts materials , and replace reference s to
UV and EB materials with the definition thoughout the rule

. “(8) ENERGY CURABLE COATINGS, INKS and ADHESIVES are single

- component reactive products that cure upon exposure to visible

- light, ultra

- violet light or to an electron beam. The VOC content of thin film Energy Curable COATINGS, INKS
and ADHESIVES ma y be determined by manufacturers using ASTM Test Method
7767

- 11 “ Standard Test Method to Measure Volatiles from Radiation Curable Acrylate Monomers, Oligomers, and Blends and Thin Coatings Made from Them.”

Staff proposes the following correction to the definition “ Flexographic Printing ” , “Fountain Solution” and “Letterpress Printing” by hypenating the word “ nonimage ” to “ non

- image .”

“(11) FLEXOGRAPHIC PRINTING is a printing method utilizing a flexible rubber or other elastomeric plate in which the image area is raised relative to the nonimage

non

- image area.”

“ ( 10 13 ) FOUNTAIN SOLUTION is the solution used in offset lithographic printing which is applied to the image plate to maintain the hydrophilic properties of the nonimage

non

- image areas. It is primarily water and contains at least one of the following materials: etchants such as mineral salts; hydrophilic gums; or VOC additives to reduce the surface tension of the solution.”

“( 18 21) LETTERPRESS PRINTING is a printing process in which the image area is raised
relative to the nonimage non

- image area and the ink is transferred to the substrate directly from the image surface.”

Staff proposes to correct a spelling error in the definition “ Graphic Arts Operations. ” T he misspelled word is shown as “ Opertions ” and will be changed to “ Operations ”

, then the word
“offset” will be added to lithographic printing processes.

“ ( 13 16 ) GRAPHIC ARTS OPERTIONS OPERATIONS are gravure, letterpress, flexographic, and offset lithographic printing processes or related coating or laminating processes.”

Staff proposes the following revision s to the definition “ Heatset Ink ” to clarify the type of ink and to properly refer to the equipment as web

- fed, not web

- feed and revise the description of dryers as hot air high veloc ity dryers.

Proposed Amended Rule 1130 2

- 2 May 2014Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

“ ( 16 19 ) HEATSET INK is an offset lithographic printing ink used on continuous web

feed fed printing presses that are equipped with hot air high velocity dryers. The ink dries or sets by heat induced evaporation of the ink oils and subsequent chilling of the ink by chill rolls .”

Staff proposes to revise the “ Lithographic Printing ” definition by adding “ Offset ” to be consistent with the CTG, hypenate non

- image, remove metal lithographic plate since the plates can be made of many non

- metal materials and incorporate additional rule language to enhance
the current definition , and update all similar references to lithographic printing throughout the
rule

.

“ ( 25 26 ) OFFSET LITHOGRAPHIC PRINTING is a planographic printing process in which the image and areas are on the same plane of a thin lithographic plate and are chemically differentiated. The ink film is transferred from the lithographic plate to an intermediary surface, a rubber covered cylinder called a blanket, which, in turn, transfers the ink to the substrate. This printing process differs from other printing processes where the image is typically printed from a raised or recessed surface.”

“( 22 24 ) NON

- HEATSET INK is an offset lithographic printing ink that sets and dries by absorption into the substrate, and hardens by ambient air oxidation that may be accelerated by the use of infrared light sources. For the purposes of this definition
ultraviolet and electron

- beam energy curable inks ar e examples of non

- heatset
inks.”

Staff proposes the following revision s to the definition “ Matte Finish In k ” and “ Metallic Ink ” to clarify the type of printing ink and then change the word “ applied ” to the word “ used ”

, to be consistent with the applicabil ity purposes of this rule.

“ ( 20 22 ) MATTE FINISH INK is a flexographic printing ink which is applied used on non

porous substrates in flexographic printing operations and contains at least five (5) percent by weight silicon dioxide flattening agent.”

“ ( 21 23 ) METALLIC INK is a flexographic printing ink which is applied used on non

- porous substrates in flexographic printing operations and contains at least 28 percent by weight elemental metal particles.”

Staff proposes the following revision to the definiti on “ Solvent Cleaning ” to make it consistent
with the “ Solvent Cleaning ” definition in other Regulation XI rules.

“ ( 34 37 ) SOLVENT CLEANING is the removal of loosely held uncured adhesives, uncured inks, uncured coatings, and contaminants including, but not limited to, dirt, soil, and

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grease from parts, products, tools, machinery, equipment and general work areas is as defined in Rule 1171

– So lvent Cleaning Operations .”

Staff proposes to add the title of the referenced rule (Rule 102) to the current definition.

“ ( 36 39 ) VOLATILE ORGANIC COMPOUND (VOC) is as defined in Rule 102

- Definition of Terms .”

Staff proposes to correct the term “ Web

- Feed ” to “Web

- Fed.” The current version of Rule 1130 specifies “ WEB

- FEED ” but the term is actually “ WEB

- FED .”

“ ( 37 40 ) WEB

- FEED WEB

- FED is an automatic system which supplies substrate from a continuous roll, or from an extrusion process.”



### Subdivision (c) Requirements Paragraph (c)(1)

– VOC Content of Graphic Arts Materials Staff is proposing to enhance the clarity of the current rule language by detailing the actions prohibited under this provision

. In addition, the required VOC content limits are displayed in a
table , to be consistent with the formatting used in other SCAQMD rules . The revision is shown
below

. “No person shall supply, sell, offer for sale, market, manufacture, blend, package, repackage,
distribute

, apply or solicit the application of any graphic arts material, including any VOC

containing materials added to the original graphic arts materials, for use in the District

, which

contains a total VOC in excess of the VOC content limits specified set

- forth in the Table of
Standards I belo w: ”

TABLE 3

– PROPOSED TABLE OF STANDARDS I

TABLE OF STANDARDS I

VOC CONTENT LIMITS Grams of VOC Per Liter of Coating, Ink or Adhesive, Less Water And Less Exempt Compounds

GRAPHIC ART MATERIAL Current Limit ( g/L )

Adhesive 150
Coating 300
Flexographic Fluorescent Ink 300
Flexographic Ink: Non

- Porous Substrate 300
Flexographic Ink: Porous Substrate 225

Gravure Ink 300
Letterpress Ink 300
Offset Lithographic Ink 300

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Paragraph (c)(2)

– VOC Content of Fountain Solutions Staff proposes to delete obsolete rule language from Paragraph (c)(2)

, make revisions to the existing rule language to enhance clarity and introduce a new Table of Standards II, to combine
the VOC limits of the fountain solutions that are used for the various types of prin ting methods in offset lithographic printing operations

.

The current version of Rule 1130 limits fountain solution to 100 grams per liter of VOC provided the fountain solution is refrigerated and maintained at 55 degrees Fahrenheit o r less , or if used at room temperature(ambient), to 80 grams per liter of VOC

.

The CTG recommends a percentage of alcohol or alcohol substitute when calculating the VOCs
for either room temperature or refrigerated fountain solutions and type of printing method . S taff

convert ed the CTG recommended mass percentage limits to a gram per liter limit, consist e nt with SCAQMD VOC content terminology

.

Table

- 4 shows the recommended weight percent values and equivalent VOC content in grams per liter, based on standard unit conversion and product material densities

.
TABLE 4

- CONVERSION OF PERCENTAGE OF VOC VALUES TO
MASS /VOLUME VOC VALUES

– BASED ON CTG RECOMMENDATIONS

FOUNTAIN SOLUTION CTG
RECOMMENDATION (weight percent) EQUIVALENT ( g /L)

Heatset Web Offset Lithographic
At Room Temperature 1.6% 16

Heatset Web Offset Lithographic Using Refrigerated Chiller 3.0% 30

Heatset Web Offset Lithographic Using Alcohol Substitute 5.0% 50

Sheet

- fed Offset Lithographic At Room Temperature 5.0% 50

Sheet

- fed Offset Lithographic Using Refrigerated Chiller 8.5% 85

Sheet

- fed Offset Lithographic Using Alcohol Substitute 5.0% 50

Non

- Heatset Web Offset Lithographic Using Alcohol Substitute 5.0% 50

Table

- 5 shows the updated VOC content requirements in the proposed amendment

. Staff
reviewed commercially available fountain solutions and found 90% of the fountain solution

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concentrate products already me e t th e most restrictive 16 g/L limit when mixed with water per the products technical data sheet recommendations . The VOC content of the fountain solution

concentrate can substantially be affected by the amount of dilution water added ; the typical dosage identified was 4 to 6 fluid ounces of fountain solution concentrate per gallon of water. With the exception of just three products, the fountain solutions that calculate d in the excess of 16 g/L VOC c ould be used at lower concentration. In fact, staff determined that when using the lowest concentrate limit proposed by the product manufacturer, 98% of the products were calculated to be under 16 g/L of VOC. T wo of the three fountain solutions that could not meet the 16 g/L VOC limit for a heatset press using fountain solution at room temperature could meet the limit for a heatset press using refrigerated fountain so lutions. The one product which
calculated at 41 g/L VOC could still be used for the other categories shown in Table 5

. Some printing operations may also require additives, de foamers , bactericides and other components that may also contain VOC. Since the rule for VOC content is “as applied” the operator may have to adjust the mixture to keep the fountain solution within the rules specified VOC content
limits. S taff believes that the CTG recommended fountain solution limits reflect existing operational pr actices.

Staff proposes to eliminate the current language in subparagraph (c)(2)(A), in lieu of the Table of Standards II, and add new language to subparagraph (c)(2)(B) to provide clarification that alcohol containing fountain solutions would be prohibit ed for use in non

- heatset web

- fed operations. Table 5 shows the VOC limits for the fountain solutions, and the new VOC limits that will become effective on July 1, 2014. The VOC limits are “ as applied ” on

- press :

“ (A) Through December 31, 1999, no No pers on shall apply any in any graphic arts operation any fountain solution, including any VOC

- containing materials added to the original fountain solution , which contains a total VOC in excess of 100 grams per liter of material fountain solution, including any VOC

- containing materials added to the original fountain solution as applied, shall be : for use in a graphic arts operation within the District unless the VOC content in the fountain solution

, as applied, complies with the a pplicable VOC limits set

- forth in the Table of
Standards II below. ”

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TABLE 5

– PROPOSED TABLE OF STANDARDS II

TABLE OF STANDARDS II

VOC CONTENT LIMITS Grams of VOC Per Liter of Material

FOUNTAIN SOLUTION 1/1/2000 7/1/2014 ( g/L ) ( g/L )

Heatset Web

- Fed Using Alcohol without Refrigerated Chiller 80 16 Using Alcohol with Refrigerated Chiller 100 30 Using Alcohol Substitute 80 50

Sheet

- Fed Using Alcohol without Refrigerated Chiller 80 50 Using Alcohol with Refrigerated Chiller 100 85 Using Alcohol Substitute 80 50

Non

- Heatset Web

- Fed Using Alcohol Substitute without Refrigerated Chiller 80 50 Using Alcohol Substitute with Refrigerated Chiller

(A) no greater than 80 grams per liter of material, or

(B) no greater than 100 grams per liter of material, if a refrigerated chiller is used. The use of alcohol containing fountain solutions is prohibited for use in non

- heatset
web

- fed operations.

“ Paragraph(c)(3)

– Solvent Cleaning Operations; Storage and Disposal of VOC containing
Materials Staff is proposing the following revision to enhance the clarity of paragraph (c)(3) to make it consistent with other Regulation XI rules.

“ (3) Solvent Cleaning Operations; Storage and Disposal of VOC

- containing Materials

. Solvent cleaning of application equipment, parts, products, tools, machinery, equipment, general work areas, and the storage and disposal of VOC

- containing materials used in cleaning operations and the storage and disposal of VOC

containing materials used in cleaning operations are subject to the provisions of shall be carried out pursuant to Rule 1171

- Solvent Cleaning Operations. ”

Paragraph(c)(4)

– Prohibition of Storage Staff proposes to add additional rule language to address the storage of graph ic arts material t hat
have VOC content limit s in excess of the specified VOC content limits pursuant to paragraph

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(c)(1). Although staff believes facilities currently meet the VOC content requirements of paragraph (c) ( 1 ) a n effective date of July 1, 2014 is proposed to allow time for internal worksi t e review of ex isting storage and inventory a reas for compli a nce assurance purposes.

“(4) Effective July 1, 2014, a person shall not store any graphic arts material at a worksite for use in the District which contains VOC in the excess of the VOC

content limits specified in paragraph (c)(1).”

Paragraph(c)( 5 )

– Approved Emission Control System Staff proposes to update the Approved Emission Control System requirements to align the CTG
to reflect the same control efficiency requirement as in other Regulation XI rules. The proposed revised rule language is as follows:

Approved Emission Control System

“ ( 5 ) A person may comply with the provisions of paragraph (c)(1) and (c)(2) by using an emission control system to reduce VOC emissions provided such system is first approved in writing by the Executive Officer and meet the following requirements:

(A) The control device reduces VOC emissions from an emissions collection system by at least 95 percent, by weight, or the output of the air pollution control device is no more than 50 PPM by volume calculated as carbon with no dilution; and

(B) The owner/operator demonstrates that the emission collection system collects at least 90 percent, by weight, of the VOC emissions gen erated by the sources
emissions.”

Paragraph (c)( 5 )

– Alternative Emission Control Plan Staff proposes to revise paragraph (c)( 5 ) to clarify rule language as follows:

“ (5) Alternative Emission Control Plan ” A person may comply with the provisions of paragraphs (c)(1) or (c)(2) by means of

an approved Alternative Emission Control Plan (AECP) pursuant to Rule 108

- Alternative Emission Control Plans .”



### Subdivision (d) Prohibition of Specification and Sale

Paragraph (d)(2) Staff is proposing the following revisions to paragraph (d)(2) to clarify the actions a person may not partake in during a graphic arts operation and correct the reference of the applicable

s ubparagraph.

“ (2) No person shall supply, offer for sale, sell, market, blend, package, repackage, manufacture or distribute

, ordistribute directly to an end

- user for use in the District any graphic arts material for use in the District which, when applied as supplied or

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thinned or reduced accord ing to the manufacturer's recommendation for application, does not meet the applicable VOC limits in paragraph (c)(1 ) or subparagraph (i)(11)(C) (i)(4)(C) for the specific application. ”

Paragraph (d)(3) Staff is proposing to add a new paragraph to clarify a manufacturer’s responsibility to the labeling requirements with Rule 443.1 and to clarify the “ prohibition of sales ” provision in the
District.

“ (3) The prohibition of sales and use as specified in par agraphs (d)(1) and (d)(2) shall not apply to any manufacturer of graphic arts materials, provided that the manufacturer has complied with the labeling requirements of Rule 443.1

– Labeling of Materials Containing Organic Solvents, and the product is not so ld directly to a user located in the District, or the product was sold to an independent distributor or a sales outlet located in the District that is not a subsidiary of, or under the control of the manufacturer, and was informed in writing by the manufac turer about the compliance status of the product with Rule 1130. ”



### Subdivision (f)

– Rule 442 Applicability Staff is proposing the following revision to enhance the clarity of this subdivision.

“Any graphic arts operations subject to this rule which is exempt exempted from all or a portion of the VOC limits of this rule shall comply with the provisions of Rule
442.”



### Subdivision (g)

– Emission Reduction Credits The rule language for Emission Reduction Credits should be updated to be consistent with other Regulation XI rules

. Staff is proposing to delet e the current rule language and replac e it with the following revised rule language.

“ (g) Emission Reduction Credits Facilities that use matte finish and metallic inks shall not receive emission
reduction credit(s) pursuant to SCAQMD Rule 1309 above those emission reduction credit(s) that the facility would have received if it was operated with coatings having a VOC content of no more than 300 grams per liter, less water and less exempt compounds irrespecti ve of the VOC limits specified in paragraph ( i )( 4 ) (C) .”



### Subdivision ( h )

- Test Methods Subparagraph (h)(1) (A)
Staff is propos ing the following revision s to refine the rule language in sub paragraphs (h)(1)(A)
and (h)(1)(B) and subparagraphs (h)(2)(A) and (h)(2)(B)

, to make the rule language consistent with other Regulation XI rules.

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“(A) United States Environmental Protection Agency (U. S. EPA) Reference Test Method 24, (Determination of Volatile Matter Content, Water Content, Density, Volume Solids, and Weight Solids of Surface Coatings, Code of Federal Regulations, Title 40, Code of Federal Regulations Part 60, Appendix A). The exempt compounds' content shall be determined by District South Coast Air Quality Management’s (SCAQMD) Laboratory Test Method 302 (Distillation of Solvents from Paints, Coatings and Inks) and 303 (Determination of Exempt Compounds) contained in
the District SCAQMD’s "Laboratory Methods of Analysis for Enforcement Samples" manual; or ”

Subparagraph (h)(1)(B) Staff proposes to refi ne the rule language by including the title name of the test method and make the rule language consistent with other Regulation XI rules , as follows

.

“ (B) SCAQMD District Test Method 304 [Determination of Volatile Organic Compounds (VOCs) in Various Materials] contained in the District SCAQMD’s "Laboratory Methods of Analysis for Enforcement Samples" manual. ”

Subparagraph (h)(2)(A) Staff proposes to refine the rule language by including the title name of the test methods and make the rule language consistent with other Regulation XI rules , as follows

. “(A) United States Environmental Protection Agency (U

. S

. EPA) Reference Test Method 24A, (Title 40, Code of Federal Regulations P art 60, Appendix A Determination of Volatile Matter Content and Density of Publication Rotogravure Inks and Related Publication Rotogravure Coatings, Code of Federal Regulations Title 40, Part 60, Appendix A) . The exempt compounds' content shall be determi ned by District SCAQMD’s Laboratory Test Method 303 (Determination of Exempt Compounds)
contained in the District SCAQMD’s "Laboratory Methods of Analysis for Enforcement Samples" manual; or”

Subparagraph (h)(1)(B) Staff proposes to refine the rule languag e by mak ing the rule language consistent with other Regulation XI rules , as follows

. “(B) SCAQMD District Test Method 304 [Determination of Volatile Organic Compounds (VOCs) in Various Materials] contained in the District SCAQMD’s "Laboratory Methods of Analysis for Enforcement Samples" manual.”

Paragraph (h)(3)

– Exempt Perfluorocarbon Compounds Staff proposes to refine the rule language by making the rule language consistent with other Regulation XI rules . First, the list of classes of compounds has be en formatted to a semi

- bulleted list for easier reading. Then staff incorporated minor revisions to provide enhanced clarity of the rule language

.

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- 10 May 2014Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

“The following classes of compounds: Cyclic , branched, or linear, completely fluorinated alkanes; Cyclic , branched, or linear, completely fluorinated ethers with no unsaturations; Cyclic , branched, or linear, completely fluorinated tertiary amines with no unsaturations; and Sulfur

- containing perfluorocarbons with no unsaturations and with sulfur bonds only to carbon and fl uorine,

will be analyzed as exempt compounds for compliance with subdivision (c) and subparagraph (i)(11)(C) (i)(4) (C) , only at such time as when manufacturers specify which individual compounds are used in the ink and coating formulations

. and identify the test methods, which, prior to such analysis, have been approved by In addition, the manufacturers must identify with
the U

. S

. EPA, CARB, and the District that SCAQMD approved test methods, which can be used to quantify the amount s of each exempt compound. ”
Paragraph (h)(4)

- Determination of Efficiency of Emission Control Systems Subparagraph (h)(4)(A) Staff proposes to refine the rule language in paragraph (h)(4) by making the rule language consistent with other Regulation XI rule s. This will include the elimination of clauses (i), (ii), and (iii).

“ (A) The capture efficiency of an emission control system as defined s pecified in paragraph (b)( 2 5 ) shall be determined by a minimum of three sampling runs subject to the data quality objective (DQO) presented in the by the procedures presented in U

. S

. EPA technical guideline document, "Guidelines for Determining Capture Efficiency, January 9, 199 5 ". Individual capture eff iciency test runs subject to the USEPA technical guidelines shall be determined by: Notwithstanding the test methods specified by the Guidelines, any other method approved by the U.S. EPA, CARB and the SCAQMD Executive Officer may be substituted.

Subparagra ph (h)(4)(B) Staff proposes to refine the rule language in subparagraph (h)(4)(B) by making the rule language consistent with other Regulation XI rules.

“ (B) The efficiency of the control device efficiency of an the emission control system as defined specified in paragraph (b)( 3 6 ) and the VOC content in the control device exhaust gases, measured and calculated as carbon, shall be determined by U

. S

. EPA Test Methods 2 5 , 2 5 A, or District SCAQMD Method 2 5 .1 (Determination of
Total Gaseous Non

- Methane Organic Emissions as Carbon) or SCAQMD Method
2 5 .3 (Determination of Low Concentration Non

- Methane Non

- Ethane Organic Compound Emissions from Clean Fueled Combustion Sources) as applicable. U

. S

. EPA Test Meth od 18, or C ARB Method 422 shall be used to determine emissions of exempt compounds.”

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Paragraph (h)( 5 )

– Equivalent Test Methods Staff proposes to refine the rule language in paragraph (h)(5) by making the rule language consistent with other Regulation XI rules.

“ (5) Equaivalent Test Methods
Other test methods determined by the staffs of the District to be equivalent by the Executive Officer

, C ARB, and the U

. S

. EPA

, to be equivalent to the test methods specified in this rule, and approved in writing by the District Executive Officer may also be used.”

Paragraph (h)(7)

– Test Methods Dates Staff proposes to revise the rule language in paragraph (h)(7) to be consistent with other Regulation XI rules.

“(7) Test Methods Dates All test methods referenced in this section subdivision shall be the most recent ly approved version s. The Executive Officer may update test methods as necessary to reflect the most accurate method available, provided the method does not affect the stringe ncy of the rule by the appropriate governmental entities .”



### Subdivision (i) Exemptions Staff proposes to reformat subdivision (i) to update section numbering and to move the exemption for Aerosol Coating Products and adding a new exemption for graphic arts materials that have 10 g/L of VOC or less

. Graphic arts materials do not include materials used in cleaning operations.

“(i) Exemptions (1) The provisions of this rule shall not apply to: [...] (I) Aerosol coating products (J) Graphic arts materials that have a VOC content of no more than 10 g/ L or equivalent

, less water and less exempt compounds, as applied.”

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.

Staff is then proposing to relocate the emissions thr eshold and associated record keeping for
metalic and matte finish inks of paragraph (i)(11) to a new paragraph (i)(5) and c hange the

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- 12 May 2014Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

records retention requirement from two years to five years. The revised rule language is shown
below.

“ (5) Facilities operating under the provisions of paragraph (i)(4) whose actual emissions exceed ten (10) tons in any calendar year shall:

(A) henceforth be subject to the requirements of paragraph (c)(1). (B) In addition to the requirements of subdivision (e), facilities shall retain records of purchase orders and invoices of VOC

- containing materials for a minimum of five (5) years. ”

Staff is propos ing to add new rule language to provide an exemption for storage of graphic arts
materials that exceed the VOC limits in par agraph (c)(1) provided the VOCs from those graphic
arts materials are collected and controlled by an emissions control system , consistent with SCAQMD VOC rules

.

“ (6) The provision of paragraph (c)(1) shall not apply to a worksite that stores graphic
arts materials provided such graphic arts materials are vented exclusively to printing systems equipped with an approved emission control system pursuant to the requirements of paragraph (c)( 5 ). ”

Finally, staff proposes to add new language to prov ide rule relief for sheet

- fed presses that have a sheet size no larger than 11 inches by 17 inches

, or if the total fountain solution reservoir capacity is one gallon or less as recommended by the CTG. However, this exemption can only
be met if the sheet

- fed presses, having a sheet size no larger than 11 inches by 17 inches

, or if the total fountain solution reservoir capacity is one gallon or less, uses a fountain solution with a VOC content of no more than 80 grams per liter of material, as applied, or i f using a refrigerated chiller, no more than 100 grams per liter of material, as applied. The new language will appear in paragraph (i )(8) as follows

.

“ (8) The provisions of paragraph (c)(2) shall not apply to sheet

- fed offset presses that
have a sheet size no larger than 11 inches by 17 inches

, or any offset press if the total solution reservoir capacity is one gallon or less

, provided the VOC content of the fountain solution used contains no more than 80 grams per liter of material, as applied, or if u sing a refrigerated chiller, no more than 100 grams per liter of material, as applied.”

Proposed Amended Rule 1130 2

- 13 May 2014RULE 1130

– GRAPHIC ARTS

CHAPTER 3 : IMPACT ASSESSMENT OF PROPOSED AMENDED RULE 1130

ο Emission Impact Assessment

ο Cost Analysis

ο Control Device Efficiency

ο Fountain Solutions

ο Storage Of Non

- Compliant VOC

- Containing Materials

ο Incremental Cost

- Effectiveness

ο California Environmental Quality Act (CEQA)

ο Socioeconomic Impact Assessment

ο Draft Findings under California Health and Safety Code 40727

ο Comparative Analysis

ο Draft Conclusions and Recommendations

ο Public Comments and ResponsesChapter 3 : Impact Assessment of Proposed Amended Rule 1130 Final Staff Report

EMISSION IMPACT ASSESSMENT
Th e proposed amendment is not expected to result in emission reductions

.

COST ANALYSIS The proposed amendments to Rule 1130 is not expected to have a net cost impact since industry will
be able to continue business as usual and operate their equipment subject to Proposed Amended Rule
1130 in a similar manner to the current r ule

.

CONTROL DEVICE EFFICIENCY The proposed amendment seeks to change the add

- on control device efficiency requirement from 75% overall to the CTG recommended 95% control and 90% capture efficiency

. Staff has analyzed the data
for the 2 9 control units in the South Coast AQMD jurisdiction and found that all of them will mee t the new revised limit. The typical overall control device efficiency for the control units operating in the
District is 96. 2 %. Therefore, staff believes there will be no cost impact on industry for this revision.

FOUNTAIN SOLUTIONS The proposed amendm ent seeks to align the VOC requirements in Rule 1130 with the recommended VOC requirements in the U.S. EPA Control Techniques Guidelines for fountain solutions. Staff
believes there would be a no cost impact to industry for the EPA recommended VOC limit changes. Staff conducted a survey of fountain solutions on the internet and found that out of 169 fountain
solutions , 152 met the most restrictive VOC limit

, the heatset web

- fed without a refrig erated chiller ( 16 grams per liter )

. Typically, the technical data sheets for manufacturers of fountain solutions recommend anywhere from 2 to 4 ounces of the fountain solution to be mixed with one gallon of water. Staff used the highest dosages to calcu late the VOC content of the fountain solutions and even at the maximum dosage for fountain solution staff still found 152 fountain solutions will me e t the most restrictive VOC limit . This data shows that industry has been using products that already compl y with the new adjusted VOC limits and should not pose a cost impact to industry.

STORAGE OF CERTAIN NON

- COMPLIANT VOC

- CONTAINING MATERIALS
The proposed amendment prohibit s storage of 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)]

. The rule proposal includes an exemption to this prohibition provided that the graphic arts materials are vented exclusively to an approved emissions contr ol system. Staff believes there would be no cost impact to this change because a facility conducting graphic arts operations ha s no operational need for non

compliant VOC containing materials at their worksite and because the proposed amendment does not

c hange the VOC content requirement for any currently stored graphic arts materials. This proposed rule language has been added to make the rule consistent with other VOC regulating rules.

The remaining changes in this proposed amendment are to remove obsolete rule language, update definitions for consistency with other District rules, add two new definitions and mak e minor
corrections and clarifications will have no cost or emissions impact.

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INCREMENTAL COST

- EFFECTIVENESS Under Health and Safety Code § 40920.6, the SCAQMD is required to perform an incremental cost analysis when adopting a Best Available Retrofit Control Technology (BARCT) rule or feasible measure required by the California Clean Air Act. To perform this analysis, the SCAQMD must (1) identify one or more control options achieving the emission reduction objectives for the proposed rule, (2) determine the cost effectiveness for each option, and (3) calculate the incremental cost effectiveness for each option. To determine incremental co sts, the SCAQMD must “calculate the difference in the dollar costs divided by the difference in the emission reduction potentials between each progressively more stringent potential control option as compared to the next less expensive control option.” Th e Staff reviewed the 2006 CTG along with other current standards throughout the state and determined that PAR 1130 represents BARCT for graphic arts operations because there are no other more stringent limits available. PAR 1130 does not implement a more r estrictive BARCT because the amendment reflects existing practices and technology and therefore does not achieve
additional will not result in emission reductions . Because the proposed amendments to Rule 1130
do does not implement a more restrictive BARCT or feasible control measure, and therefore and
therefore no incremental cost analysis is required under Health and Safety Code § 40920.6 is inapplicable

.

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) In accordance with the California Environmental Quality Act (CEQA), the SCAQMD is the Lead Agency and has prepared a Draft Environmental Assessment (EA) to analyze environmental impacts from the proposed project pursuant to its certified regulatory program (SCAQMD Rule 110). The Draft EA includes a project description and analysis of potential adverse environmental impacts that could be generated from the proposed project. Comments focusing on issues relative to the environmental analysis for the proposed project will be accepted during The Draft EA was circulated
for a 30

- day public review and comment period beginning February 25, 2014, and ending 5 p.m. on March 26, 2014. Responses to any comments on the Draft EA received during the public review and comment period will be prepared and incorporated into the Final EA.

SOCIOECONOMIC IMPACT ASSESSMENT The proposed amendments codify existing practices at graphic arts operati ons that are subject to Rule 1130. As such, there are no additional costs or other socioeconomic impacts anticipated and no socioeconomic analysis is required under Health and Safety Code Section 40728.5.

DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY CODE 40727 The draft findings include necessity, authority, clarity, consistency, non

- duplication and reference, as defined in Health and Safety Code Section §40727. The draft findings are as follows:

Necessity

- The SCAQMD Governing Board finds and determines that Proposed Amended Rule 1130, Graphic Arts , is necessary to make Rule 1130 consistent with the suggested control device efficiencies
and the recommended VOC limits for fountain solutions with United States Environme ntal 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)

. Proposed Amended Rule 1130 3

- 2 May 2014Chapter 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?

Proposed Amended Rule 1130 3

- 3 May 2014Chapter 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.
Proposed Amended Rule 1130 3

- 4 May 2014Chapter 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

Proposed Amended Rule 1130 3

- 5 May 2014Chapter 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

Proposed Amended Rule 1130 3

- 6 May 2014Chapter 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.

Proposed Amended Rule 1130 3

- 7 May 2014References Final Staff Report

REFERENCES

SCAQMD Staff Report, Proposed Amended Rule 1130

– Graphic Arts

, July 1999

.

SCAQMD Staff Report, Comparison and Analysis of: Control Techniques Guidelines for Offset Lithographic Printing and Letterpress, EPA

- 4 3 3/R

- 06

- 002 2006/09, March 2011

.

SCAQMD Staff Report, Comparison and Analysis of: Control Techniques Guidelines for Flexible Package Printing, EPA

- 4 3 3/R

- 06

- 003 2006/09, March 2011

.

Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing, EPA

- 4 3 3/R

06

- 002 2006/09, September 2006, U. S. Environmental Protection Agency RTP, NC

Control Techniques Guidelines for Flexible Package Printing, EP A

- 4 3 3/R

- 06

- 003 2006/09, September 2006, U. S. Environmental Protection Agency RTP, NC

INTERNET MATERIAL : http://en.wikipedia.org/wiki/Offset_printing
http://www.aqmd.gov/aer/Updates/VOCEmissCalcuMethLithoPrint.pdf
http://www.aqmd.gov/bact/PartD

- 10

- 3

- 2008.pdf
http://www.aqmd.gov/aqmp/2012aqmp/Final

- February2013/AppVI.pdf

Proposed Amended Rule 1130 R

- 1 May 2014

### APPENDIX A

– 

### VOC Emission Calculation Methodology for Lithographic Printing Operations

– December 2011Appendix A Final Staff Report

Proposed Amended Rule 1130 A

- 1 May 2014Appendix A Final Staff Report

Proposed Amended Rule 1130 A

- 2 May 2014Appendix A Final Staff Report

Proposed Amended Rule 1130 A

- 3 May 2014Appendix A Final Staff Report

Proposed Amended Rule 1130 A

- 4 May 2014

### APPENDIX B

– 

### Compliance Advisory

- 

### Determining Collection Efficiencies for Air Pollution Control Systems Serving Heat

- Set Lithographic Printing PressesAppendix B Final Staff Report

Proposed Amended Rule 1130 B

- 1 May 2014Appendix B Final Staff Report

Proposed Amended Rule 1130 B

- 2 May 2014