UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

For

EPA ’ s Direct Final Rulemaking

For the California State Implementation Plan

Mojave Desert Air Quality Management District

, Rule 1117

, Graphic Arts and Paper, Film, Foil and Fabric Coatings

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

Octo ber

, 201 12

Agency: Mojave Desert Air Quality Management District ( MDAQM D)

SIP Approved Rule : Rule 1117

– Graphic Arts

A dopt ed

– June 22 , 1994
Submitted

– J ul y 13 , 199 4 EPA Approved

- April 30, 1996 (61 FR 18962)

Subject of this TSD: Rule 1117

– Graphic Arts and Paper, Film, Foil and Fabric Coatings

Amended

– September 28, 2009

Submitted

– July 20

, 201 0

RULE SUMMARY

- MDAQM D Rule 1117

, Graphic Arts and Paper, Film, Foil and Fabric Coatings

, was amended both in response to the California Health and Safety Code § 40702 and to the requirement of areas designated non

- attainment

and classified moderate to implement RACT as defined by the Control Technology Guidelines (CTG) for “major sources” of Volatile Organic Compounds (VOCs) and Nitrous Oxide Compounds (NOx). The modifications to Rule 117, Graphic Arts include:

1. Changed the title from Graphic Arts to Graphic Arts and Paper, Film, Foil and Fabric Coatings

. 2. Revised the Applicability and Purpose sections to include additional paper, film, foil and fabric coating categories.

3. Update d definitions to make the rule more comprehensive, clear and applicable.

4. Added V OC limits for several new categories of coatings and solvent s and overall capture and control efficiencies for main processes

. 5. Included new application and solvent cleaning methods.

6. Added w ork practice requirements as defined in the CTGs

. 7. Changed exemptions from a minimum VOC emission basis to specific graphic processes , like digital printing operations, and minimum quantities

of inks

. 8. Revis ed m onitoring and recordkeeping to address specific types of materials and processes

. 9. Added test methods for specific content and for transfer, capture and

control efficiencies.

10. Added an overall violation provision when multiple test methods are employed and there is a violation of one method.

EPA EVALUATION

- The following criteria were used to evaluate the submitted

rule.

1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988), the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001), and State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air3 Amendments of 1990 (57 FR 13498, April 16, 1992) were used to help evaluate compliance with the CAA § 110(a)(2)(A) requirement for enforceability.

2. Stringency

– The EPA’s CTG titled Flexible Package Printing (E PA 453/R

06

- 003, September 2006); CTG titled Offset Lithographic Printing and Letterpress Printing (EPA 453/R

- 06

- 00 2

, September 2006); CTG titled Paper Film and Foil Coatings (E PA 453/R

- 07

- 003, September 2007);
OAQPS Guideline titled Control of VOCs from E xisting Stationary Sources

– Volume II: Surface Coating of Cans, Coils, Paper , Fabric s, Automobiles and Light

- Duty Trucks (EPA 450/2

- 77

- 008,May 1977); OAQPS Guideline

titled Control of VOCs from Existing Stationary Sources

– Volume V III: Graphic Arts

- Roto gravure and Flexography (EPA 450/2

- 78

- 033, December 1978) and CTG titled Industrial Cleaning Solvents ( EPA 453/R

- 06

- 001,September 2006 ) and other district s’ analogous rules for this category

were used as the basis for RACT including: San Joaquin Valley Unified Air
Pollution Control District ( SJ V UAPCD ) Rule 46 07

, Graphic Arts and Paper, Film, Foil and Fabric Operations amended Dec ember 18

, 200 8 , Bay Area

A ir Quality Management District ( BAAQMD) Rule 8

- 20, Graphic Arts Printing and Coating Operations

, amen ded Nov ember 19 , 2008 and Sacramento Metropol itan A ir Quality Management District ( SM AQMD) Rule

450

, Graphic Arts Operation s

, revised Octo ber 23 , 2008.

3. SIP Relaxation

– CAA § 110(l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA § 193 prohibits the modifi cation of any SIP

- approved control requirement in effect before November 15, 1990,

in a nonattainment area.

Enforceability

- The testing, recordkeeping , monitoring and other rule requirements , along with the additional caveat for multiple test methods, generally

ensure that the submitted rule can be enforced.

Stringency

– Rule 1117 is generally as stringent as the relevant CTGs and analogous rules in other nonattainment areas that we have approved as RACT ( 74 FR 52894 ). Therefore, we believe Rule 11 17 also fulfils CAA RACT requirements for affected sources.

SIP Relaxation

– The District has lowered the limits for several categories of graphic arts inks, coatings and adhesives and has increased the overall capture and control efficiency for all processes. We propose to determine that our approval of the submittal would comply with CAA § 110(l) because the amended rule is more stringent than the rule previously approved into SIP and would not interfere with the ongoing process for ensuring that requirements for RFP and attainment of the
NAAQS are met

.4

EPA ACTION

- EPA staff recommends a full approval of Rule 1117 pursuant to CAA §110(k) (4) and §301 (a).

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

–

1. Section B, Definitions:

a. Subsection (20)

– “Doctor Blade”

– Consider remov ing t he word
“steel” as there are doctor blades that are not steel.

b. Subsection (2 5)

– Please c orrect spelling error in the word “Electrophotography”

c. Subsection (27)

- “Exempt Compound”

- Consider adding “VOC” or, as SJVUAQMD has done, adding “O rganic” before “Compound” to more succinctly describe the exempt compound

. d. Subsection (56)

– “ Liquid L eak ” should apply to all coatings, ink and solvents. Consider deleting the word “Solvent” to more accurately describe a liquid leak. This will also make the definition of “Non

Leaking Container” in subsection (68) more comprehensive.

e. Subsection (110) “Wash Pr imer”

– For clarity, please rephrase the definition to: “A material that contains no more than 5 percent, by weight, solid materials, and that is used to clean and/or to activate surfaces of paper or fabric.”

2. Section F, Test Methods:

a. Subsection (2)

– Please add the date December 13, 1991 to ARB

Method 422.

b. Subsection (4)

- Please revise SCAQMD Test Method 318 to Test

Method 318

- 95 and add the date, July 1996, after the title. Additionally, please note that the use of this method for metals other than aluminium requires validation.

ADDITIONAL REFERENCES

-

1. MDAQMD Rule 1117

, Graphic Arts and Paper, Film, Foil and Fabric Coatings , as submitted on July 20, 2010

.

2. MDAQMD Rule 1117, Graphic Arts

, adopted June 22, 1994

.

3. S JVUAPCD Rule 4607, Graphic Arts and Paper, Film, Foil and Fabric Operations amended December 18, 2008 http://www.valleyair.org/rules/currntrules/r4607.pdf

4. BAAQMD Rule 8

- 20, Graphic Arts Printing and Coating Operations, amended November 19, 2008. http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/Rule s%20and%20Regs/reg%2008/rg0820.ashx?la=en

5. SMAQMD Rule 450, Graphic Arts Operations , revised October 23, 2008. http://www.airquality.org/rules/rule450.pdf5

6. “Control Techniques Guidelines for Industrial Cleaning Solvents,” EPA
453/R

- 06

- 001,September 2006 http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r

- 06

- 001_ind_cleaning_solvents.pdf

7. “Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing,” EPA 453/R

- 06

- 00 2 , September 2006

. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r

- 06

- 002_litho_letterpress_printing.pdf

8. “Control Techniques Guidelines for Flexible Package Printing,” EPA 453/R

06

- 003, September 2006. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r

- 06

- 003_flexible_package_printing.pdf

9. “Control Techniques Guidelines for Paper Film and Foil Coatings,” EPA

453/R

- 07

- 003, September 2007 http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200709_voc_epa453_r

- 07

- 003_paper_film_coating.pdf

10. OAQPS Guideline “Control of VOCs from Existing Stationary Sources

– Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles and Light

- Duty Trucks,” EPA 450/2

- 77

- 008, May 1977 http://www.epa.gov/ttn/naaqs/ozone/ctg_act/197705_voc_epa450_2

- 77

- 008_surface_coatings(v2).pdf

11. OAQPS Guideline “Control of VOCs from Existing Stationary Sources

– Volume III: Graphic Arts

- Rotogravure and Flexography,” EPA 450/2

- 78

- 033, December 1978 http: //www.epa.gov/ttn/naaqs/ozone/ctg_act/197812_voc_epa450_2

- 78

- 033_graphic_arts(v8).pdf

12. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988. http://www.epa.gov/ttn/naaqs/ozone/ozonetech/v oc_bluebook.pdf

13. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001. http://www.epa.gov/region9/air/sips/littlebluebook2001.pdf