# Mojave Desert Air Quality Management District

Final 

# Staff Report Amendments to Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric Coatings

Adopted on September 28, 2009

14306 P ARK 

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### , V ICTORVILLE 

### , CA 92392-2310

P HONE 

### : (760) 245-1661 F AX 

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Final Staff Report, 01/21/10 

### FINAL STAFF REPORT TABLE OF CONTENTS Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric Coati ngs

I. PURPOSE OF STAFF REPORT .....................

................................................... .................... 1 II. EXECUTIVE SUMMARY...........................

................................................... ....................... 1 III. STAFF RECOMMENDATION ........................

................................................... .................. 2 IV. LEGAL REQUIREMENTS CHECKLIST .................

................................................... ........ 3 V. DISCUSSION OF LEGAL REQUIREMENTS.............

................................................... ..... 4 A. REQUIRED ELEMENTS/FINDINGS......................

................................................... ...... 4 1. State Findings Required for Adoption of Rules & Regulations ..................................... 4 a. Necessity.......................................

................................................... ........................... 4 b. Authority.......................................

................................................... ........................... 4 c. Clarity .........................................

................................................... ............................. 4 d. Consistency.....................................

................................................... ......................... 4 e. Non-duplication .................................

................................................... ...................... 5 f. Reference .......................................

................................................... .......................... 5 g. Public Notice & Comment, Public Hearing.........

................................................... .... 5 2. Federal Elements (SIP Submittals, Other Federal Submittals)....................................... 6 a. Satisfaction of Underlying Federal Requirements.

................................................... .. 6 b. Public Notice and Comment .......................

................................................... ............. 6 c. Availability of Document ........................

................................................... ................ 6 d. Notice to Specified Entities ....................

................................................... ................. 7 e. Public Hearing ..................................

................................................... ....................... 7 f. Legal Authority to Adopt and Implement..........

................................................... ...... 7 g. Applicable State Laws and Regulations Were Follo wed............................................ 7 B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS ....... ..................................... 7 C. ECONOMIC ANALYSIS ...............................

................................................... ................ 9 1. General.........................................

................................................... ................................ 9 2. Cost Effectiveness..............................

................................................... .......................... 9 D. ENVIRONMENTAL ANALYSIS (CEQA)...................

................................................... . 9 E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS ............. ...................................... 10 1. Potential Environmental Impacts.................

................................................... .............. 10 2. Mitigation of Impacts...........................

................................................... ...................... 10 3. Alternative Methods of Compliance...............

................................................... ........... 10 F. PUBLIC REVIEW...................................

................................................... ...................... 10 VI. TECHNICAL DISCUSSION ........................

................................................... ................... 10 A. SOURCE DESCRIPTION..............................

................................................... ............... 10 B. EMISSIONS .......................................

................................................... ........................... 12 C. CONTROL REQUIREMENTS............................

................................................... ......... 12 D. PROPOSED RULE SUMMARY...........................

................................................... ....... 13 E. SIP HISTORY .....................................

................................................... .......................... 14 1. SIP History....................................

................................................... ............................ 14 a. SIP in the San Bernardino County Portion of MDAQ MD ....................................... 14 b. SIP in the Riverside County Portion of the MDAQM D........................................... 14TC-2 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 2. SIP Analysis....................................

................................................... ........................... 15 Appendix A - Iterated Version......................

................................................... ........................... A-1 Appendix B - Public Notice Documents...............

................................................... ................... B-1 Appendix C - Public Comments and Responses.........

................................................... ............. C-1 Appendix D - California Environmental Quality Act D ocumentation ....................................... D-1 Appendix E - Bibliography..........................

................................................... .............................E-1MDAQMD Rule 1117 – Graphic Arts 1

Final Staff Report, 01/21/10 

### FINAL STAFF REPORT Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric Coati ngs

I. PURPOSE OF STAFF REPORT

A staff report serves several discrete purposes. I ts primary purpose is to provide a summary and background material to the members of the Governing Board. This allows the members of the Governing Board to be fully informed before making any required decision. It also provides the documentation necessary for the Governing Board to make any findings, which are required by law to be made prior to the approval or adoption of a document. In addition, a staff report ensures that the correct procedures and proper docu mentation for approval or adoption of a document have been performed. Finally, the staff r eport provides evidence for defense against legal challenges regarding the propriety of the app roval or adoption of the document.

II. EXECUTIVE SUMMARY

The Mojave Desert Air Quality Management District ( MDAQMD) has the authority pursuant to California Health and Safety Code (H&S Code) §40702 to adopt, amend or repeal rules and regulations. The MDAQMD is proposing to amend Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric Coatings for inclusion in the current rulebook.

H&S Code §39614(d) requires the MDAQMD to adopt the most readily available, feasible and cost-effective local control measures for Particula te Matter (PM) as contained on a list developed by the California Air Resources Board (CARB). CARB has identified on its list of local control measures several items related to graphic arts as p otentially feasible. In the “List and Implementation Schedule for District Measures to Re duce PM Pursuant to Health & Safety Code §39614(d)” the District identified one of these mea sures as requiring further evaluation. The District has evaluated the availability, feasibilit y and cost-effectiveness of applying this PM control measure related to graphic arts within the MDAQMD. The proposed Reasonably Available Control Measures (RACT) limits were found to have a maximum Volatile Organic Compounds (VOC) cost effectiveness limit of no more than $576 per ton of VOC (2008 dollars). The District finds this to be feasible and cost eff ective as required by H&S Code §3961(d).

Additionally, the Federal Clean Air Act (FCAA) requ ires areas designated non-attainment and classified moderate and above to implement RACT for sources subject to Control Technology Guidelines (CTG) documents issued by United States Environmental Protection Agency (USEPA) for “major sources” of VOCs and oxides of n itrogen (NO X ) which are ozone precursors. The District adopted the 8-Hour Reasonably Available Control Technology – St ate Implementation Plan Analysis (RACT SIP Analysis) August, 2006 which committed to amending current RACT for graphic arts operations. The MDAQ MD has a graphic arts RACT rule which was approved into the SIP in 1996 (61 FR 18962), bu t this rule does not cover all possible paper surface coating CTG source categories, such as offs et lithographic printing. A RACT rule is technically required for all portions of this CTG s ource category. The District also reviewed three CTGs that were in draft form at the time of a doption of the RACT SIP Analysis . The2 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 MDAQMD is now proposing to update Rule 1117 - Graphic Arts to reflect current paper, film, foil, and fabric surface coating RACT.

The proposed amendments to Rule 1117 address both t he PM Analysis and RACT SIP Analysis commitments. The proposed amendments expand the ap plicability of the rule; updates definitions; updates VOC content limits for differe nt graphic arts product categories; updates VOC emission control system limits; updates solvent cleaning operation limits; and, updates exemptions, recordkeeping and test methods.

III. STAFF RECOMMENDATION

Staff and the Technical Advisory Committee recommen d that the Governing Board of the Mojave Desert Air Quality Management District (Dist rict) adopt the proposed amendments to Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric Coat ings and approve the appropriate CEQA documentation. This action is nec essary to address the commitments made by the District in the List and Implementation Schedule for District Measu res to Reduce PM Pursuant to Health & Safety Code §39614(d) and the RACT SIP Analysis

. The Governing Board of the Mojave Desert Air Qualit y Management District amended Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric Coati ngs on September 28, 2009

.MDAQMD Rule 1117 – Graphic Arts 3

Final Staff Report, 01/21/10 IV. LEGAL REQUIREMENTS CHECKLIST

The findings and analysis as indicated below are re quired for the procedurally correct amendments to Rule 1117 – G raphic Arts and Paper, Film, Foil and Fabric Coatin gs . Each item is discussed, if applicable, in Section V. Co pies of related documents are included in the appropriate appendices.

FINDINGS REQUIRED FOR RULES & REGULATIONS:

X Necessity

X Authority

X Clarity

X Consistency

X Non-duplication

X Reference

X Public Notice & Comment

X Public Hearing

REQUIREMENTS FOR STATE IMPLEMENTATION PLAN SUBMISSION (SIP):

X Public Notice & Comment

X Availability of Document

X Notice to Specified Entities (State, Air Districts, USEPA, Other States)

X Public Hearing

X Legal Authority to adopt and implement the document.

X Applicable State laws and regulations were followed. ELEMENTS OF A FEDERAL SUBMISSION:

X Elements as set forth in applicable Federal law or regulations.

CALIFORNIA ENVIRONMENTAL QUALITY ACT REQUIREMENTS (CEQA):

N/A Ministerial Action

X Exemption

N/A Negative Declaration

N/A Environmental Impact Report

X Appropriate findings, if necessary.

X Public Notice & Comment

SUPPLEMENTAL ENVIRONMENTAL ANALYSIS (RULES & REGULATIONS ONLY):

X Environmental impacts of compliance.

N/A Mitigation of impacts.

N/A Alternative methods of compliance.

OTHER:

X Written analysis of existing air pollution control requirements

X Economic Analysis

X Public Review4 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 V. DISCUSSION OF LEGAL REQUIREMENTS

A. REQUIRED ELEMENTS/FINDINGS

This section discusses the State of California stat utory requirements that apply to the amendments to Rule 1117. These are actions that ne ed to be performed and/or information that must be provided in order to amend the rule in a procedurally correct

manner.
1. State Findings Required for Adoption of Rules & Regulations:

Before adopting, amending, or repealing a rule or r egulation, the District Governing Board is required to make findings of nec essity, authority, clarity, consistency, non-duplication, and reference based u pon relevant information presented at the hearing. The information below is provided to assist the Governing Board in making these findings.

a. Necessity:

The amendments to Rule 1117 are necessary to addres s the commitments made by the District in the List and Implementation Schedule for District Measures to Reduce PM Pursuan t to Health & Safety Code §39614(d) and the RACT SIP Analysis

. b. Authority:

The District has the authority pursuant to Californ ia Health and Safety Code (H&S Code) §40702 to adopt, amend or re peal rules and regulations.

c. Clarity:

The amendments to Rule 1117 are clear in that they are written so that the persons subject to the rule can easily und erstand the meaning.

d. Consistency:

The amendments to Rule 1117 are in harmony with, an d not in conflict with or contradictory to any State law or regulation, Federal law or regulation, or court decisions. USE PA has issued five CTGs which have an impact on Rule 1117: CTG f or Flexible Package Printing (EPA 453/R-06-003, 2006/09); CTG f or Offset Lithographic Printing and Letterpress Printing (EPA 453/R-06-02, 2006/09); CTG for Paper, Film, and Foil Coatings (E PA 453/R-07- 003, 2007/09); CTG for Control of VOCs from Existin g Stationary Sources – Volume II; Surface Coating of Cans, Coils , Paper, Fabrics, Automobiles and Light-Duty Trucks (EPA 450 /2-77-008,MDAQMD Rule 1117 – Graphic Arts 5

Final Staff Report, 01/21/10 1977/05); and, CTG for Control of VOCs from Existin g Stationary Sources – Volume III: Graphic Arts-Rotogravure and Flexography (EPA 450/2-78-033, 1978/12). The CTGs establish re quirements and emission limits for VOCs but do not directly im plement them. Most of these emission limits have been previously included in Rule 1117 and the few which were not originally inc luded are being added by the amendments, therefore the amendm ents are not in conflict or inconsistent with the CTGs.

There are two Federal New Source Performance Standa rds (NSPS) that apply to Rule 1117: 40 CFR 60 Subpart QQ (Sta ndards of Performance for the Graphic Arts Industry: Publicat ion Rotogravure Printing; and 40 CFR 60 Subpart RR (Sta ndards of Performance for Pressure Sensitive Tape and Label S urface Coating Operations. The amendments are not in conf lict with either NSPS.

There are three Maximum Achievable Performance Stan dards (MACTs) that apply to graphic arts; Subpart KK (Nat ional Emission Standards for the Printing and Publishing Industry); Subpart OOOO (Fabric Printing, Coating and Dyeing); and, Subpart JJJJ (National Emissions Standards for Haza rdous Air Pollutants: Paper and other Web Coating). The amen dments are not in conflict with the MACT standards.

e. Non-duplication:

The amendments to Rule 1117 do not impose the same requirements as any existing state or federal law o r regulation because the District is adopting this rule in respo nse to H&S Code §39614(d) and federal VOC RACT requirements.

f. Reference:

The District has the authority pursuant to H&S Code §40702 to adopt, amend or repeal rules and regulations. The District is required to adopt readily available, feasible and cost-effec tive control measures for particulate matter from a list of pote ntial local control measures promulgated by CARB pursuant to H&S Code §39614(d).

g. Public Notice & Comment, Public Hearing:

Notice for the public hearing for the proposed amen dments to Rule 1117 was published 08/26/2009. See Appendix “B” fo r a copy of the public notice. See Appendix “C” for copies of comments, if any, and District responses.6 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 2. Federal Elements (SIP Submittals, Other Federal Submittals).

Submittals to USEPA are required to include various elements depending upon the type of document submitted and the underlying f ederal law that requires the submittal. The information below indicates which e lements are required for the amendments to Rule 1117 and how they were satisfied

. a. Satisfaction of Underlying Federal Requirements:

The FCAA requires areas designated non-attainment a nd classified moderate and above to implement RACT for sources su bject to CTG documents issued by EPA for “major sources” of VOCs and NO X that are ozone precursors. The District adopted t he RACT SIP Analysis August, 2006 which committed to amending current RACT for graphic arts operations. The MDAQMD has a graphic arts RACT rule which was approved into the SIP in 1 996 (61 FR 18962), but this rule does not cover all possible p aper surface coating CTG source categories, such as offset litho graphic printing, letterpress printing, and screen printing . A RACT rule is technically required for all portions of this CTG s ource category. USEPA directed the District to evaluate San Joaquin Valley Air Pollution Control District (SJVAPCD) Rule 4607 – Graphic Arts and Paper, Film, Foil, and Fabric Operations (12/18/08), Bay Area Air Quality Management District (BAAQMD) Rule 8-20 – Graphic Arts Printing and Coating Operations (11/19/08), and Sacramento Metropolitan Air Quality Management Dist rict (SMAQMD) Rule 450 Graphic Arts Operations (10/23/08) as RACT rules. SJVAPCD Rule 4607 was used as a basis for the amendments to Rule 1117 – Graphic Arts and Paper, Film, Foil, and Fabric Operations.

b. Public Notice and Comment:

Notice for the public hearing for the proposed amen dments to Rule 1117 was published 08/26/2009. See Appendix “B” fo r a copy of the public notice. See Appendix “C” for copies of comments, if any, and District responses.

c. Availability of Document:

Copies of the proposed amendments to Rule 1117 and the accompanying draft staff report were made available to the public on 08/18/09. The proposed amendments were reviewed by the Technical Advisory Committee (TAC), a committee con sisting of a variety of regulated industry and local governmen tal entities, on 09/14/09.MDAQMD Rule 1117 – Graphic Arts 7

Final Staff Report, 01/21/10

d. Notice to Specified Entities:

Copies of the preliminary draft Rule 1117 were sent for initial industry review on 05/26/2009. Copies of the propo sed amendments to Rule 1117 and the accompanying draft staff report were sent to all affected agencies. The proposed a mendments were sent to CARB and USEPA on 08/20/09.

e. Public Hearing:

A public hearing to consider the proposed amendment s to Rule 1117 was held on 09/28/2009.

f. Legal Authority to Adopt and Implement:

The District has the authority pursuant to H&S Code §40702 to adopt, amend, or repeal rules and regulations, and to do such acts as may be necessary or proper to execute the duties imposed upon the District.

g. Applicable State Laws and Regulations Were Follo wed:

Public notice and hearing procedures pursuant to H& S Code §§40725-40728 have been followed. See Section (V)( A)(1) above for compliance with state findings required pursuan t to H&S Code §40727. See Section (V)(B) below for compliance wi th the required analysis of existing requirements pursuant to H&S Code §40727.2. See Section (V)(C) for compliance with e conomic analysis requirements pursuant to H&S Code §40920.6 . See Section (V)(D) below for compliance with provisions of the California Environmental Quality Act (CEQA).

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS

H&S Code §40727.2 requires air districts to prepare a written analysis of all existing federal air pollution control requirements that app ly to the same equipment or source type as the rule modified by the district.

The USEPA has issued several recent CTGs which have an impact on Rule 1117. These CTGs were issued after the adoption of the RACT SIP Analysis . The CTG for Flexible Package Printing (EPA 453/R-06-003, September 2006) provides recommendations for reducing VOC emissions from inks, coatings, adhesiv es and cleaning materials used in flexible packaging printing. The CTG for Offset Li thographic Printing and Letterpress Printing (EPA 453/R-06-02, September 2006) provides control recommendations for reducing VOC emissions stemming from the use of fou ntain solutions, cleaning materials and inks in offset lithographic printing and cleani ng materials and inks in letterpress printing. The CTG for Paper, Film, and Foil Coatin gs (EPA 453/R-07-003, September 2007) provides control recommendations for reducing VOC emissions stemming from8 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 the use of coatings in paper, film and foil surface coating operations. Coating performed on, or in-line with, any offset lithographic, scree n, letterpress, flexographic, rotogravure, or digital printing press is part of a printing pro cess and is not part of the paper, film, and foil coating category.

Four CTGs were addressed in the RACT SIP Analysis. The Control of VOCs from Existing Stationary Sources – Volume I; Control Met hods for Surface-Coating Operations (EPA 450/2-76-028, November 1976), altho ugh often listed with the CTGs for historical reasons, this document does not defi ne RACT for any source. It is a compilation of control techniques (pursuant to USEP A comment). The Control of VOCs from Existing Stationary Sources – Volume II; Surfa ce Coating of Cans, Coils, Paper, Fabrics, Automobiles and Light-Duty Trucks (EPA 450 /2-77-008, May 1977) provides levels of VOC for all coatings put on paper, pressu re sensitive tapes regardless of substrate (including paper, fabric or plastic film) and related web coating processes on plastic film such as typewriter ribbons, photograph ic film, and magnetic tape. The Control of VOCs from Existing Stationary Sources – Volume III: Graphic ArtsRotogravure and Flexography (EPA 450/2-78-033, 1978 /12) deals with VOC emission from the graphic arts operations which utilize inks containing VOCs (does not apply to offset lithography or letterpress printing). The C ontrol of VOC Emissions from Ink and Paint Manufacturing Processes (EPA-450/3-92-013, Ap ril 1992) deals with emission control techniques and cleaning practices throughou t the manufacturing process of inks. The CTGs establish requirements and emission limits for VOCs but do not directly implement them. Therefore, rule adoption at the lo cal level and submission as a SIP revision is necessary to implement these requiremen ts. In addition, most of these emission limits have been previously included in Ru le 1117 and the remainder are proposed for inclusion by the amendments, therefore the amendments are not in conflict or inconsistent with the CTGs.

There are two Federal New Source Performance Standa rds (NSPS) that apply to Rule 1117: 40 CFR 60 Subpart QQ (Standards of Performan ce for the Graphic Arts Industry: Publication Rotogravure Printing; and 40 CFR 60 Sub part RR (Standards of Performance for Pressure Sensitive Tape and Label S urface Coating Operations). The amendments are not in conflict with either NSPS. N SPS standards are generally adopted by reference within the MDAQMD (see Rule 900) and a pply only to newer stationary sources as specified in the NSPS. The amendments a pply RACT level control to all existing stationary sources which in most cases is the same level as that imposed by the NSPS standard. Please note that a new major statio nary source in this source category would require Best Available Control Technology (BA CT) pursuant to the provisions of New Source Review (Regulation XIII) and thus would be subject to potentially more stringent requirements than those contained in eith er of the NSPSs or amended Rule 1117.

There are three Maximum Achievable Performance Stan dards (MACTs) that apply to graphic arts; Subpart KK (National Emission Standar ds for the Printing and Publishing Industry); Subpart OOOO (Fabric Printing, Coating a nd Dyeing); and, Subpart JJJJ (National Emissions Standards for Hazardous Air Pol lutants: Paper and other Web Coating). The amendments are not in conflict with the MACT standards. MACTMDAQMD Rule 1117 – Graphic Arts 9

Final Staff Report, 01/21/10 standards are imposed upon existing sources pursuan t to the provisions of Rule 1520 – Control of Toxic Air Contaminants from Existing Sou rces . Thus, many of the existing sources are already subject to the same level of co ntrol for certain chemicals as that specified in amended 1117. Please note that any ne w or modified stationary source in this category would require a Toxic New Source Revi ew analysis as part of its permitting process (see Rule 1320) and would thus acquire the same level of control as that provided for by amended 1117.

C. ECONOMIC ANALYSIS

1. General

Rule 1117 is equivalent to San Joaquin Valley Unifi ed Air Pollution Control District Rule 4607 – Graphic Arts and Paper, Film, Foil and Fabric Coati ngs that was determined by USEPA to be RACT (67 FR 4299), th erefore cost effectiveness is not required. However, these amen dments have been analyzed for VOC cost effectiveness in response to state req uirements (see below).

2. Cost Effectiveness

Bay Area Air Quality Management District (BAAQMD) e stablished a cost effectiveness of $576 per ton VOC reduced 1 . In their staff report, SJVUAPCD determined that their cost assumptions paralleled t hose of BAAQMD. The District finds that the BAAQMD analysis is applicab le to this amendment action and presents this value as the cost effectiveness o f the rule. This value is deemed feasible for VOC by the District.

D. ENVIRONMENTAL ANALYSIS (CEQA)

Through the process described below the appropriate CEQA process for the amendments to Rule 1117 was determined.

1. The amendments to Rule 1117 meet the CEQA defini tion of “project”. They are not “ministerial” actions.

2. The amendment of Rule 1117 is exempt from CEQA r eview because it will not create any adverse impacts on the environm ent. The requirements in the amendments to Rule 1117 are more stringent than the currently existing requirements (see more detailed discussion in Rule Summary §(D)) in that: rule applicability is expanded to include current CTG so urce categories; definitions are updated to make the rule more comprehensive, reflec t the current applicability of the rule, and provide additional clarity; VOC limit s for various categories of coatings and solvent coating operations have been i ncluded; work practice requirements have been added; and, the monitoring a nd recordkeeping, and test method sections have been strengthened. In additio n, ink and coatings satisfying

1 BAAQMD Staff Report “Proposed Amendments to BAAQMD Regulation 8, Rule 20: Graphic Arts Printing and Coating Operations (October 2008) pg 15.10 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 the limits contained in the rule are readily availa ble in commerce and have been shown not to cause either additional usage of the c oatings themselves or of cleaning solvents. Other air districts have adopte d similar rules and neither they nor USEPA has identified increased usage of inks, c oatings or solvents as an issue in supporting documentation.

Therefore, no adverse environmental effects are for eseen from the amendments. Copies of the documents relating to CEQA can be fou nd in Appendix “D”.

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS

1. Potential Environmental Impacts

There are no potential adverse environmental impact s of compliance with the adoption of Rule 1117. Rule 1117 will expand the a pplicability of the rule to include all CTG categories for paper, film, foil an d fabric; will impose additional controls on VOC emissions from inks, coatings, adhe sives, fountain solutions, and solvent cleaning; and will increase the overall cap ture and control efficiency of emission control systems. Inks and coatings comply ing with the rule limits are readily available in commerce and should not cause additional usage of the coatings themselves or of cleaning solvents. No ex isting facility in this source category within the MDAQMD currently has an emissio n control system and the MDAQMD does not expect the installation of such dir ectly as the result of the amendments to the rule primarily due to the high av ailability of compliant inks and coatings. In fact, the MDAQAMD suspects that a high percentage of the facilities in this source category are already usin g compliant inks and coatings due to the availability and the fact that most such ink s and coatings are purchased within the South Coast Air Quality Management Distr ict.

2. Mitigation of Impacts

N/A

3. Alternative Methods of Compliance

N/A

F. PUBLIC REVIEW

See Staff Report Section (V)(A)(1)(g) and (2)(b), a s well as Appendix “B”

VI. TECHNICAL DISCUSSION

A. SOURCE DESCRIPTION

Rule 1117 will be amended to include all CTG catego ries for paper, film, foil and fabric coating operations. The rule will be applicable to all graphic arts printing operations;MDAQMD Rule 1117 – Graphic Arts 11

Final Staff Report, 01/21/10 paper, film, foil and fabric printing operations; a s well as, the use, storage and disposal of solvents associated with these operations.

Graphic arts printing operations include lithograph ic printing, letterpress printing, digital printing, screen printing, and flexible packaging p rinting (rotogravure and flexographic).

Lithography refers to a plane-o-graphic method of p rinting in which the image areas attract ink and the non-image areas repel ink. Mos t lithography is offset which means the image is transferred from the plate to a rubber bla nket, and then printed (offset) from the blanket onto the paper.

Letterpress Printing is a method where the image ar ea is raised relative to the non-image area of the printing plate. The plate is inked and pressed onto the substrate allowing the ink to be transferred to the substrate directly fro m the image surface.

Digital printing encompasses a variety of technolog ies all of which are based on the same distinguishing characteristics. Digital printing t echnologies do not require a physical master, stencils, screens or plates, but instead ut ilize digital data to control the deposition of ink, toner, or dye to create images. Digital pr inting is a print on demand technology, which includes, but is not limited to, various form s of inkjet, thermography, electrophotography, ionography, and magnetography.

Screen Printing is a method in which a printing med ium, such as ink, is forced through a web or fabric that has a stenciled image area that allows the ink to pass through the mesh to create the image. The stencil openings determin e the form and dimension of the imprint.

Flexible packaging refers to any package or part of a package the shape of which can be readily changed. Flexible packaging includes, but is not limited to, bags, pouches, liners, and wraps utilizing paper, plastic, film, aluminum foil, metalized or coated paper or film, or any combination of these materials 2

. Gravure Printing, also known as rotogravure, is an intaglio printing operation in which the ink is transferred from minute etched wells on a cylinder to the substrate, which is supported by an impression roller with excess ink r emoved from the cylinder by a doctor blade.

Flexographic Printing is the application of an imag e to a substrate by means of a roll printing technique in which the pattern is applied to an image carrier made of rubber or other elastomeric materials. The image to be print ed is raised above the carrier surface.

Offset lithographic printing and letterpress printi ng are two distinct product categories under section 183(e) of the CAA, but have many simi larities in the types of inks and cleaning materials used, and controls available to control emissions. The offset lithographic process is used in many printing appli cations, including books, magazines, periodicals, labels and wrappers, catalogs and dire ctories, financial and legal documents,

2 Control Techniques Guidelines for Flexible Packagi ng Printing, EPA 453/R-06-003, September 2006, pg.5

.12 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 business forms, advertising brochures, newspapers a nd inserts, charts and maps, calendars, tickets and coupons, greeting cards, and stamps. The paper, film and foil coatings product category listed under section 183( e) of the CAA includes coatings that are applied to paper, film, or foil surfaces in the manufacturing of several major product types for the following industry sectors: pressure sensitive tape and labels (including fabric coated for use in pressure sensitive tapes a nd labels); photographic film; industrial and decorative laminates; abrasive products (includ ing fabric coated for use in abrasive products); and flexible packaging (including coatin g of non-woven polymer substrates for use in flexible packaging). This category also inc ludes coatings applied during miscellaneous coatings operations for several produ cts including: corrugated and solid fiber boxes; die-cut paper paperboard, and cardboar d; converted paper and paperboard not elsewhere classified; folding paperboard boxes, including sanitary boxes; manifold business forms and related products; plastic asepti c packaging; and carbon paper and inked ribbons 3

. MDAQMD Rule 1117 currently applies to any packaging rotogravure; publication rotogravure, or flexographic printing operation; an d, to the manufactures of any ink, coating, or adhesive containing VOC which is sold, offered for sale, or supplied for use in graphic arts operations in the MDAQMD. The applica bility of Rule 1117 is for amendment to include all CTG categories for paper, film, foil and fabric coating operations as well as the manufacture of any ink, coating, or adhesive containing VOC which is sold, offered for sale, or supplied for us e in Graphic Arts and Paper, Film, Foil and Fabric Coating Operations in the District.

Several facilities in the MDAQMD have operations po tentially affected by the change in applicability of the rule. The Daily Press operate s an offset lithographic printing press that was previously exempted from the requirements of Rule 1117. There are approximately 50 screen printing operations that ar e potentially subject to the amended rule which were also previously exempted. There is a potential future facility which may manufacture and print packaging materials for a fut ure beverage bottling plant which may also be subject to the rule.

B. EMISSIONS

The amendments to Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric Coatings do not cause the release of additional air contamin ants, or create any adverse environmental impacts because the amended rule prop oses a more stringent applicability, as well as, more stringent VOC limits for all categ ories, including solvent cleaning operations, than the existing rule.

C. CONTROL REQUIREMENTS

Please see section (C)(1) through (C)(12) of the ru le (see Appendix “A”) for control requirements. Control requirements are in the form of VOC limits for the various inks, coatings, adhesives, fountain solutions, and solven ts for various graphic arts operations

3 Control Techniques Guidelines for Paper, Film and Foil Coatings, EPA 453/R-07-003, September 2007, pg . 5.MDAQMD Rule 1117 – Graphic Arts 13

Final Staff Report, 01/21/10 and paper, film, foil and fabric operations. Appro ved VOC emission control system limits, approved coating application equipment, and work practices are also specified.

D. PROPOSED RULE SUMMARY

This section gives a brief overview of the amendmen ts to Rule 1117. The iterated rule version is contained in Appendix “A” of this staff report.

Proposed amendments to Rule 1117 were designed to e nable the District to comply with the provisions of H&S Code §39614(d) that requires the adoption of the most readily available, feasible and cost-effective control meas ures for PM as set forth on a list developed by CARB. 4 This list was developed based on rules, regulatio ns, and programs existing in California as of 01/01/04. There is on e South Coast Air Quality Management District (SCAQMD) Rule listed as potential local co ntrol measures contained in the CARB document. Specifically, Appendix B of the CAR B document Proposed List of Measures to Reduce Particulate Matter , Strategy I – Coating Measures (Measures reduce VOC) 70, refers to this SCAQMD rule amendment of 10 /08/99: Rule 1130 – Graphic Arts . The District has analyzed this SCAQMD Rule to de termine if the measures they contained were readily available, feasible and cost -effective for implementation within the MDAQMD. The VOC limits contained in the SCAQMD rule were determined to be cost effective and have been incorporated in the am endments to Rule 1117.

Section (A) has been amended to include all CTG cat egories for paper, film, foil and fabric coating operations, and digital printing ope rations.

Section (B) definitions are updated. Definitions h ave been included to make the rule more comprehensive, reflect the current applicabili ty of the rule, and provide additional clarity.

Section (C) requirements have been modified to incl ude specific VOC limits: inks, coatings and adhesives (Table 1); fountain solution s (Table 2); flexographic specialty ink (Table 3); screen printing inks, coatings, and adhe sives (Table 4); paper, film, foil, fabric coating and wash primer (Table 5); emission control system overall capture and control efficiency (Table 6); and, solvent cleaning (Table 7). Coating application equipment is specified in section (C)(7), and work practices are specified in (C)(12).

Section (D) has been updated to be more comprehensi ve and to reflect the applicability of the rule. The section has also been reorganized fo r clarity.

Section (E) has been updated to reflect the applica bility. Recordkeeping requirements have been strengthened and clarified. Digital prin ting recordkeeping requirements have been added, but this category is otherwise exempted from the requirements of the amendments.

4 A copy of the CARB “Proposed List of Measures to R educe Particulate Matter – PM10 and PM2.5 (Implementation of Senate Bill 656, Sher 2003) and attendant staff report may be found at: http://www.arb.ca.gov/pm/pmmeasures/pmmeasures.htm

.14 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 Section (F) has been updated to reflect the applica bility.

Various format changes were made for consistency wi th current MDAQMD rule format, as well as correction of typographical errors and s everal grammatical changes.

E. SIP HISTORY

1. SIP History

a. SIP in the San Bernardino County Portion of MDAQ MD

On July 1, 1993 the MDAQMD was formed pursuant to s tatute. Pursuant to statute it also retained all the rules and regulations of the SBCAPCD until such time as the Governing Board of the MDAQMD wished to adopt, amend or rescind such rules . The MDAQMD Governing Board, at its very first meeting, reaffirmed all the rules and regulations of the SBCAPCD. Rule 1117 was a new rule adopted by the MDAQMD on 06/22/1994 in res ponse to a SIP-Call made by USEPA. This version of the rule was submitted for inclusion in the SIP on 07/13/1994 an d was approved into the SIP on 04/30/96 (61 FR 18962). This versi on of the rule is the current version in the SIP.

b. SIP in the Riverside County (Blythe/Palo Verde V alley) Portion of the MDAQMD

One of the provisions of the legislations which cre ated the MDAQMD allowed areas contiguous to the MDAQMD boundaries and within the same air basin to leave t heir current air district and become a part of the MDAQMD. On July 1, 1994 the area commonly known as the Palo Verde Valley in Riv erside County, including the City of Blythe, left SCAQMD a nd joined the MDAQMD. Since USEPA adopts SIP revisions in Califo rnia as effective within the jurisdictional boundaries of l ocal air districts, when the local boundaries change the SIP as approve d by USEPA for that area up to the date of the change remains as the SIP in that particular area. Upon annexation of the Blythe/Pal o Verde Valley the MDAQMD acquired the SIP prior to July 1, 1994 t hat was effective in the Blythe/Palo Verde Valley. Therefo re, the SIP history for the Blythe/Palo Verde Valley Portion of the MDAQMD is based upon the rules adopted and approved for th at portion of Riverside County by SCAQMD. SCAQMD adopted Rule 11 30 – Graphic Arts on 10/03/1980 and subsequently amended the rule on 02/01/1985, 05/05/1989, 02/02/1990, 03/02/1990, 04/ 06/1990, 06/01/1990, 11/02/1990, 12/07/1990, 08/02/1991, 03/ 06/1992, 07/09/1993, and on subsequent dates to the annexati on of the Blythe/Palo Verde Valley. The 03/06/1992 is the ve rsion of RuleMDAQMD Rule 1117 – Graphic Arts 15

Final Staff Report, 01/21/10 1130 that was given limited approval and limited di sapproval in the SIP on 04/14/1994 (59 FR 17697). This version of Rule 1130 should have been effective in the SIP for the Blyth e/Palo Verde Valley portion of SCAQMD upon annexation into the M DAQMD. It is presumed that the current version of Rule 111 7 in the MDAQMD Rule Book is not applicable to the Blythe/Pa lo Verde Valley area of Riverside County as this rule was ad opted on 06/22/1994, just prior to the annexation of this ar ea.
SCAQMD adopted Rule 1130.1 – Screen Printing Operations on 08/02/1991 and subsequently amended the rule on 07/ 09/1993 and 12/13/1996. This rule was submitted for inclusion in the SIP but it is presumed there was no action taken and the submi ssion was withdrawn effective 08/27/1996 (61 FR 43976). Ther efore, Rule 1130.1 is not in the SIP for the Blythe/Palo Verde Valley portion of the MDAQMD.

2. SIP Analysis.

The District will request that CARB submit the amen dments of Rule 1117 to replace the SIP versions in effect in the San Berna rdino County portion of the MDAB and the Blythe/Palo Verde Valley portion of Ri verside County. This submission is necessary because there are two diffe rent SIP versions currently in effect within the MDAQMD.

Since there are previously existing SIP rules for t his category the District will request that they be superseded. In order to repla ce existing SIP rules the District is required to show that the amendments are not les s stringent than the provisions currently in the SIP. The rule is more stringent t han the prior rules because it has been amended to include all CTG categories for pape r, film, foil and fabric coating operations. The VOC limits for inks, adhes ives, coatings, fountain solutions, solvents and emission control systems ar e more stringent than previous rule versions (MDAQMD Rule 1117 and SCAQMD Rule 113 0).16 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 This page intentionally left blank.MDAQMD Rule 1117 – Graphic Arts A-1

Final Staff Report, 01/21/10 

### Appendix “A” Rule 1117 – Graphic Arts and Paper, Film, Foil and Fabric Coati ngs Iterated Version

The iterated version is provided so that the change s to an existing rule may be easily found. The manner of differentiating text is as follows:

1. Underlined text identifies new or revised language.

2. Lined out text identifies language which is being deleted.

3. Normal text identifies the current language of t he rule which will remain unchanged by the adoption of the proposed amendments.

4. [Bracketed italicized text] is explanatory material that is not part of the pr oposed language. It is removed once the proposed amendmen ts are adopted.A-2 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 This page intentionally left blank.( Adopted: 06/22/94; Amended: mm/dd/yy)

MDAQMD Rule 1117 1117-1 Graphic Arts d2, 09/01/09 

# RULE 1117 Graphic Arts and Paper, Film, Foil And Fabric Coatings

(A) General

(1) Purpose : To reduce emissions of vola tile organic compounds (VOC) from packaging rotogravure, publication rotogravure, and flexographic printing operations.

(a) To reduce emissions of Volatile Organic Compoun ds (VOC) from Graphic Arts Printing Operations, Digital Printing Operations, and Paper, Film, Foil or Fabric Coating Operations. [Derived from SJVUAPCD Rule 4607 §1.0]

(2) Applicability . The provisions of this rule apply to: [Restated in each subsection for clarity]

(a) Any packaging rotogravure, publication rotogravure, or flexographic printing operation.

(a) This rule is applicable to any Graphic Arts Pri nting Operations, Digital Printing Operations, and Paper, Film, Foil or Fabri c Coating Operation and to the Solvent cleaning materials and processes associated with such Operations. [Derived from SJVUAPCD Rule 4607 §2.0]

(b) Any This rule is applicable to any person who manufactures any ink, coating, or adhesive Ink, Coating, or Adhesive containing VOC which is sold, offered for sale, or supplied for use in packaging rotogravure, publicat ion rotogravure, or flexographic printing operations Graphic Arts and Paper, Film, Foil and Fabric Coating Operations in the District. [Restated for clarity]



### (B) Definitions

For the purposes of this rule, the following defini tions shall apply: [New rule definitions are derived from SJVUAPCD Rule 4607 unless otherwis e indicated]

(1) " Coating ": A thin layer of material applied to a substrate in a relatively unbroken film.

(2) " Exempt Compounds ": Any of the following compounds:

methane,1117-2 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, ammonium carbonate, 1,1,1

- trichloroethane, methylene chloride, trichlorofluoromethane (CFC

- 11), dichlorodifluoromethane (CFC

- 12), chlorodifluoromethane (HCFC

- 22), trifluoromethane (HFC

- 23), 1 ,1,1

- trichloro

- 2,2,2

- trifluoroethane (CFC

- 113), 1

- chloro

- 1,1

- difluoro

- 2

- chloro

- 2,2

- difluoroethane (CFC

- 114), chloropentafluoroethane (CFC

- 115), 2,2

- dichloro

- 1,1,1

- trifluoroethane (HCFC

- 123), 2

- chloro

- 1,1,1,2

- tetrafluoroethane (HCFC

- 124), pentafluoroethane (HFC

- 125), 1,1,2,2

- tetrafluoroethane (HFC

- 134), 1,1,1,2

- tetrafluoroethane (HFC

- 134a), 1,1

- dichloro

- 1

- fluoroethane (HCFC

- 141b), 1

- chloro

- 1,1

- difluoroethane (HCFC

- 142b), 1,1,1

- trifluoroethane (HFC

- 143a), 1,1

- difluoroethane (HFC

- 152a),

and the following four

classes of perfluorocarbon (PFC) compounds:

(i) cyclic, branched, or linear, completely fluorinated alkanes, (ii) cyclic, branched, or linear, completely fluorinated ethers with no unsaturations, (iii) cyclic, branched, or linear, completely fluorinated tertiary amines with no unsaturations, and (iv) saturated perfluorocarbons containing sulfur with s ulfur bonds only to carbon and fluorine.

(3) " (1) “Adhesive” – A material that is applied for the primary purpose of bonding two surfaces together by surface attachment . Adhesives may be used to facilitate the attachment of two surfaces or substa nces in varying degrees of
permanence. [Derived from BAAQMD Rule 8-20 §8-20-237]

(2) “Aerosol Product” – A hand-held, non-refillable container that expels a pressurized Solvent-containing product by means of a Propellant induced force.

(3) “Application Equipment” – A device, including, but not limited to, a spray gun, brush, roller, and a printing press, used to apply Adhesives, coatings, or Inks.MDAQMD Rule 1117 1117-3

Graphic Arts d2, 09/01/09 (4) “Bench Scale Project” – A project (other than a t a Research and Development facility) that is operated on a small scale, such a s one capable of being located on a laboratory bench top.

(5) “Blanket” – A synthetic rubber mat used to tran sfer or ”offset” an image from a printing plate to paper or other substrate, commonl y used in Offset Lithography.

(6) “Blanket Repair Material” – The material used i n Offset Lithographic Printing to correct low spots in the press Blanket. [Changed for consistency]

(7) “Blanket Wash” – A Solvent used to remove Ink f rom the Blanket of a press.

(8) “California Air Resources Board (CARB)” – The C alifornia State Air Resources Board the powers and duties of which are described in Part 2 of Division 26 of the California Health & Safety Code (commencing with se ction 39500). [Derived from MDAQMD Rule 1133]

(9) “Capture Efficiency (CE)” – In percent, is the ratio of the weight of the VOC in the effluent stream entering the Control Device to the weight of VOC emitted from the Operation, both measured simultaneously, a nd can be calculated by the following equation:

100 ×      

=

e c W W Efficiency Capture

Where:

Wc = weight of VOC entering Control Device We = weight of VOC emitted from the Operation

(10) “Coating” – The application of a uniform layer of material across the entire width of a substrate. Those machines which have both Coa ting and printing units should be considered as performing a printing Opera tion. Coating applications that are not performed in association with a printi ng Operation are considered Coating Operations and are not Graphic Arts Printin g Operations.

(11) “Coating Line” –A series of Coating applicator s, flash-off areas, and any associated curing/drying equipment between one or m ore unwind/feed stations and one or more rewind/cutting stations.

(12) “Control Device” – Equipment such as an incine rator or adsorber, or cooler/condenser filtration used to prevent air pol lutants from being emitted into the atmosphere.

(13) “Control Device Efficiency” – In percent, is t he ratio of the weight of the VOC removed by the Control Device from the effluent str eam entering the Control Device to the weight of the VOC in the effluent str eam entering the Control1117-4 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 Device, both measured simultaneously, and can be ca lculated by the following equation: 

## ( ) 100 ×      

− =

c

d c W W W Efficiency Device Control

Where:

Wc = Weight of VOC entering Control Device Wd = Weight of VOC discharged from the Control Devi ce
(14) “Conventional Printing Operations” – Those pri nting Operations that utilize physical masters, stencils, screens or plates durin g the printing process. Conventional Printing Operations use technologies i ncluding but not limited to Offset Lithographic, Flexographic , Gravure, Letterpress, and Screen Printing ":

. (15) “Cured Adhesive, Cured Coating, or Cured Ink” – An Adhesive, Coating, or Ink that is dry to the touch.

(16) “Die Coater (or Slit Coater)” – A type of Appl ication Equipment that coats an object by flowing Coatings through a slit directly onto the object moving past the slit.

(17) “Digital Printer” – A printing device that use s a computer-driven machine to transfer an electronic image to a substrate through the use of Inks, toners, or other graphic materials. Digital printing technologies i nclude, but are not limited to, various forms of Ink Jet, Thermography, Electrophot ography, Ionography, and Magnetography.

(18) “Digital Printing Operations” – Those Operatio ns that do not use a physical master, stencils, or plates but use digital data to control the deposition of Ink, toner, or dye to create images.

(19) “Dip Coater” – A type of Application Equipment that coats an object by submerging the object in a vat of Coating, and subs equently withdrawing the object and draining off the excess Coating.

(20) “Doctor Blade” – A steel blade used to scrape excess Ink from a printing plate or Inking cylinder.

(21) “Dryer” – A hot air, high velocity system used to dry Inks on printed or coated substrate.

(22) “Dye Sublimation” – An imaging process that va porizes colorant with heat and pressure, and deposits it onto a substrate in order to simulate a continuous tone image. Dye Sublimation is a digital printing techn ology.MDAQMD Rule 1117 1117-5

Graphic Arts d2, 09/01/09 (23) “Electron Beam Ink” – Ink that, when exposed t o electron energy, crosslinks or solidifies in milliseconds.

(24) “Electron Charge Deposition Printing” – See Io nography [Clarification provided for ease of use]

(25) “Electrophotograpy” – A digital printing techn ology that works by recording an image on a drum in the form of an electrostatic cha rge, which is then transferred to the substrate. Electrophotography includes such technologies as laser printers, xerography, and Liquid Electrophotography.

(26) “Electrostatic Application” – A method of appl ying Coating whereby atomized paint droplets are charged and subsequently deposit ed on the substrate by electrostatic attraction.

(27) “Exempt Compound” – Those compounds listed in 40 Code of Federal Regulations (CFR) 51.100(s)(1). [Derived from MDAQMD Rule 1162, correction of typographical error ]

(28) “Extreme Performance Ink/Coating” – An Ink or Coating used in Screen Printing on a Non-Porous Substrate that is designed to resis t or withstand any of the following:

(a) More than two years of outdoor exposure; or

(b) Exposure to industrial-grade chemicals, Solvent s, acids, detergents, oil products, cosmetics, temperatures exceeding 170oF, vacuum-forming, embossing or molding. [Removed unnecessary word]

(29) “Fabric Coating” – Any decorative or protectiv e Coating or reinforcing material applied or impregnated into textile fabric, vinyl c oated textile fabric, or vinyl sheets.

(30) “Film Coating” – A Coating applied in a Web Co ating process on any film substrate other than paper or fabric, including but not limited to typewriter ribbons, photographic film, magnetic tape, and meta l foil gift wrap, but excluding Coatings applied to packaging used exclusively for food and health care products for human or animal consumption.

(31) “Fine Arts Painting” – Any unique visual repre sentation, consisting of paint, Ink, or other media, hand applied to a substrate of canv as, wood, paper, metal, or other material.

(32) “Flexible Packaging” – Any package or part of a package the shape of which can readily be changed. Flexible Packaging includes, b ut is not limited to, bags, pouches, liners, and wraps utilizing paper, plastic , film, aluminum foil, metalized or coated paper or film, or any combination of thes e materials.1117-6 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 (33) “Flexographic Printing” – The application of words, designs, or pictures to a substrate by means of a roll printing technique in which the pattern to be is applied is raised above the prin ting roll and the to an image carrier is made of rubber or other elastomeric material. The image to be printed is raised above the carrier surface, while the non-ima ge area is not raised.

(4) " (34) “Flow Coater” – A Coating application system w ith no air supplied to the nozzle and where paint flows over the part and the excess Coating drains back into the collection system.

(35) “Foam Coater” – A Coating application system t hat coats an object by flowing foam through holes or a slit directly onto the obje ct moving underneath it.

(36) “Foil Coating” – A Coating applied in a Web Co ating process on any foil substrate other than paper or fabric, including but not limited to typewriter ribbons, photographic film, magnetic tape, and meta l foil gift wrap, but excluding Coatings applied to packaging used exclusively for food and health care products for human and animal consumption.

(37) “Fountain Solution” – Solution composed mainly of water and contains at least one of the following materials: etchants such as mi neral salts; hydrophilic gums; or other additives, which is applied to the image p late to maintain the hydrophilic properties of the non-image areas.

(38) “ Fugitive Emissions ": ” – Uncollected emissions of VOC from any portion of the printing, coat or lami nating operation. Coating or Laminating Operation other than from the Dryer. [Correction of typographical error]

(5) " (39) “ Grams of VOC per Liter of Ink, Coating (or Ink or

, Adhesive ), Excluding , or Wash Primer Less Water and Less Exempt Compounds " (VOC Content ): ) ” – The weight of VOCs emitted during use, coating Coating , curing or drying per combined volume of VOC and coating (or ink or adhesive) of Ink, Coating, Adhesive, or Wash Primer solids and can be calculated by the following equat ion:

Grams VOC ( less water & exempt compounds) = W s - W w - W es Liter of Coating V m - V w - V es

( ) 

## ( ) ( )      

−

− − − =

es w m es w s compounds exempt and water less V V V W W W Coating of Liter VOC GramsMDAQMD Rule 1117 1117-7

Graphic Arts d2, 09/01/09

Where: W s = weight of volatile compounds

, in grams

W w = weight of water

, in grams W es = weight of exempt compounds Exempt Compounds, in

grams V m = volume of material

, in liters V w = volume of water

, in liters V es = volume of exempt compounds Exempt Compounds, in liters

(6) " Gravure Printing ": An intaglio printing operation in which the ink

(40) Grams of VOC Per Liter of Material” – The weig ht of VOC per volume of material and to be calculated by the following equa tion: [Clarification] 

## ( ) 

    

− − =

m es w s V W W W Material of Liter per VOC of Grams

Where: W s = weight of volatile compounds, in grams

W w = weight of water, in grams W es = weight of Exempt Compounds, in grams V m = volume of materials, in liters

(41) “Graphic Arts Coating” – The application of a uniform layer of material across the entire width of a substrate. Those machines wh ich perform both Coating and printing should be considered as performing a print ing Operation. For purposes of this rule, digital printing is not considered a Graphic Arts Coating Operation. [Correction of typographical errors]

(42) “Graphic Arts Printing Operations” – Those Ope rations employing Conventional Printing Operations, or any Coating or Laminating p rocess associated with Conventional Printing Operations to produce publish ed products and packages. Solvent cleaning Operations performed in order to p roduce published products and packages are considered to be part of Graphic A rts Printing Operations.

(43) “Gravure Printing” – An Intaglio Printing Oper ation in which the Ink is transferred from minute etched wells on a plate cylinder to the substrate, which is supported by an impression roller, with excess ink Ink removed from the cylinder by a d octor blade Doctor Blade

.

(7) " Ink Additive ": That solvent which is added to printing inks to reduce viscosity.

(8) " (44) “Hand Application Method” – A method of applyi ng a Coating to a substrate using manually held, non-mechanically ope rated equipment. Such1117-8 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 equipment includes paintbrushes, hand rollers, caul king guns, trowels, spatulas, syringe daubers, rags, and sponges.

(45) “Heatset Ink” – A quick-drying Ink in which th e Solvents are vaporized by passing the printed surface through a heater or Ove n.
(46) “High-Volume, Low-Pressure (HVLP) Spray Equipm ent” – Equipment used to apply materials by means of a spray gun which is de signed and intended to be operated, and which is operated, between 0.1 and 10 .0 psig of air atomizing pressure, measured dynamically at the center of the air cap and the air horns. Transfer efficiency specified in section (C)(7)(h). Using same definition as SJVUAPCD rule]

(47) “Ink” – A pigmented and/or dyed liquid or past e used in a graphic arts operation typically for printing, impressing, or transferring an image onto a substrate. [Derived from BAAQMD Rule 8-20 § 8-20-239]

(48) “Ink Jet” – A digital printing technology in w hich Ink is ejected through printheads onto a substrate to create an image.

(49) “Intaglio Printing” – Printing done from a pla te or cylinder in which the image is sunk below (etched or engraved into) the surface.

(50) “Ion Deposition Printing” – See Ionography [Clarification provided for ease of use]

(51) “Ionography” – A digital printing technology t hat utilizes a directed array of ions to create a charge on a nonconductive surface to cr eate an image. Ionography can also be known as ion deposition or electron charge deposition printing.

(52) “Key System Operating Parameters” – Those para meters necessary to ensure compliance with (C)(6), including, but not limited to, temperature, pressure drop, and air flow rate.

(53) “ Lamination ": ” – A process of bonding two or more layers of materia l to form a single

, multiple

- layer sheet by using an adhesive Adhesive

.

(9) " (54) “ Letterpress printing ": Printing” – A printing method where the image area is raised relative to the non

- image area and the ink Ink is transferred to the paper directly from the image surface.

(10) " (55) “Line” – The minimum equipment which is requir ed for the application, drying, and/or curing of Inks, Ultraviolet Inks, an d/or Coatings on a substrate,MDAQMD Rule 1117 1117-9

Graphic Arts d2, 09/01/09

including the Ink and/or Coating applicators and dr ying systems, and associated Ink and Coating agitation and delivery systems.

(56) “Liquid Leak” – A visible Solvent leak from a container at a rate of more than three drops per minute, or a visible liquid mist.

(57) “Liquid Electrophotography (LEP)” – A digital printing technology that records a latent electrostatic image on a photoconductive sur face, such as a drum or belt. The image created by applying toner to the charged areas of the photoconductor is electrically transferred to an intermediate surface . In a second transfer process, the image is released from the Blanket surface to t he final substrate, cooling rapidly as the substrate passes between the Blanket and an impression drum, causing the image to “peel off” the Blanket and be affixed to the substrate. This Operation repeats itself on the one printing statio n for every color separation in the image.

(58) “ Lithographic printing ": Printing” – Printing by a planographic method in which the image and non

- image areas are on the same plane.

(11) " (59) “Magnetography” – A digital printing technolog y whereby an image is printed using a magnetic toner, electromagnetic wri te heads, and magnetic fields on an imaging drum.

(60) “Maintenance Cleaning” – A Solvent cleaning Op eration or activity carried out to keep tools, machinery, equipment (excluding Ink, Co ating, or Adhesive Application Equipment) or general work areas in cle an and good operational condition.

(61) “Manufacturing Process” – The process of makin g goods or articles by hand or by machine.

(62) “Matte Finish Ink” – A Specialty Ink which is applied on Non-Porous Substrates in Flexographic Printing Operations and contains at least five percent by weight silicon dioxide flattening agent. [Clarification and consistency with definition of Specialty Ink]

(63) “Metallic Finish Ink” – A Ink which is applied on Non-Porous Substrates in Flexographic Printing Operations and contains at le ast 28 percent by weight elemental metal particles.

(64) “Metallic Ink” – A Specialty Ink containing at least 50 grams of elemental metal particles per liter of Ink (0.4 lb/gal) as applied and which is not used in the manufacture of an electronic circuit. [Clarification and consistency with definition of Specialty Ink]

(65) “Non-Absorbent Container” – A container made o f non-porous material that does not allow the migration of Solvents through it.1117-10 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 (66) “Non-Atomized Solvent Flow” – Solvents in the form of a liquid stream without the introduction of any Propellant.

(67) “Non-Heatset Ink” – An Ink which dries by oxid ation and/or absorption into the substrate without use of heat from Dryers or Ovens.

(68) “Non-Leaking Container” – A container without Liquid Leak.

(69) “Non-Porous” – Any substrate whose surface pre vents penetration by water, including but not limited to foil, polyethylene, po lypropylene, cellophane, metalized polyester, nylon, and polyethylene tereph thalate (mylar), paper or paperboard coated with non-porous surface. Clay co ated printing paper as defined by the American Paper Institute Classificat ion System, and paperboard coated with clay to prevent water penetration, shal l be considered Non-Porous.

(70) “ Offset Lithographic Printing ": ” – A planographic method in which the image and non

- image areas are on the same plane and where the ink Ink is transferred from an image plate on one cylinder to an image blanket Blanket on a different cylinder. The ink Ink

is finally transferred from the image blanket Blanket to the surface to be printed.

(12) " Oven ": (71) “On-Press Component” – A part, component, or a ccessory of a press that is cleaned while still being physically attached to the press.

(72) “Operation” – Any physical action resulting in a change in the location, form, or physical properties of a material, or any chemical action resulting in a change in the chemical composition or the chemical or physica l properties of a material.

(73) “Operator” – Includes but is not limited to an y person who owns, leases, supervises, or operates a facility and/or equipment

. (74) “Oven” – A heating chamber which uses heat, ultraviolet (UV ) radiation, or electron beam (EB) radiation to bake, cure, polymer ize, or dry a surface coati ng Coating

.

(13) " (75) “ Packaging Gravure ": Gravure printing ” – Gravure Printing on paper, paperboard, foil, film or other substrates which ar e to be used to produce containers or packages.

(14) " (76) “ Pantone Color ": A printing ink Ink” – An Ink created for color matching by combination of process inks Process Inks

.

(15) " Printing Ink ": Any fluid or viscous composition used in printi ng, impressing, or transferring an image onto a substrate.MDAQMD Rule 1117 1117-11

Graphic Arts d2, 09/01/09 (16) " (77) “Paper Coating” – Any Coating applied on or im pregnated into paper, including, but not limited to, Adhesive tapes and l abels, book covers, post cards, office copier paper, drafting paper, and pressure s ensitive tapes.

(78) “Plastisizer” – A material used to keep plasti c material soft and viscous.

(79) “Plastisol” – A Coating that is a liquid dispe rsion of small particles of resins and Plastisizers that are fused to become a plastic.

(80) “Porous” – A substrate whose surface does not prevent penetration by water, including but not limited to, paper, paperboard, an d any paper product coated with a porous material.

(81) “ Process Ink ": ” – The hues yellow, magenta, and cyan, plus black use d in the four-color print process.

(17) " (82) “Proof Press” – A press used only for printing a sample copy of a graphic art product to check the quality of print, color re production and editorial content.

(83) “Propellant” – Any gas, including air, in a pr essure container for expelling the contents when the pressure is released.

(84) “ Publication rotogravure ": Gravure print ing on paper Gravure” – Gravure Printing on a substrate which is subsequently formed into books, magazines , catalogues, brochures, directories, newspaper supplements or ot her types of printed material.

(18) " (85) “Removable Press Component” – A part, componen t, or accessory of a press that is physically attached to the press but is disassembled and removed from the press prior to being cleaned. Rollers, Bl ankets, metering rollers, fountains, impression cylinders and plates shall no t be considered as Removable Press Components.

(86) “Repair Process” – The process of returning a damaged object or an object not operating properly to good condition.

(87) “Research and Development” – A facility or por tion thereof used to further the development of useful materials, devices, systems, or methods, including, but not limited to, design, development, and improvement of prototypes and processes. Research and Development does not include the Manuf acturing Process itself.

(88) “Resists” – Inks that are Screen Printed to fo rm the required patterns, alphabets, numerals, designs, or symbols on the surface of the substrate; protect the Screen Printed or covered surface from the subsequent appl ication of etching or plating1117-12 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 solution; and are later removed from the substrate by a resist stripper. Resist applications include, but are not limited to, etche d electronic circuits, display screens, chemical milling of parts, nameplates and signage.

(89) “Roll Coater” – A type of Application Equipmen t in which a series of mechanical rollers form a thin Coating film on the surface of a roller, which is subsequently applied to a substrate by moving the substrate unde rneath the roller.

(90) “Roller Wash” – A Solvent used to remove Ink f rom the rollers of a press.

(91) “ Screen Printing ": ” – A process where the printing ink Ink passes through a web Web or a fabric to which a refined form of stencil has been applied. The stencil openings determine the form and dimensions of the imprint.

(19) " Volatile Organic Compounds (VOCs) ": Any compoun d containing at least one atom of carbon, except exempt organic compounds.

(92) “Screen Printing Metallic Ink” – An Ink used i n Screen Printing that contains greater than 50 grams of elemental metal per liter (0.4 lb/gal) of Ink as applied.

(93) “Sign Ink/Coating” – An Ink or Coating used in Screen Printing indoor and outdoor signs (excluding structural components) and murals, including lettering enamels, poster colors, copy blockers, and bulletin enamels.

(94) “Slit Coater” – See Die Coater [Added for clarification and ease of use]

(95) “Solvent” – Any liquid containing a volatile o rganic compound or combination of volatile organic compounds, which is used as a dilu ent, thinner, dissolver, viscosity reducer, cleaning agent, or for other sim ilar uses. [Derived from SJVUAPCD Rule 4663 §3.36]

(96) “Solvent Flushing” – The use of a Solvent to r emove uncured Adhesives, uncured Inks, uncured Coatings, or contaminants from the in ternal surfaces and passages of equipment by flushing Solvent, by a Non-Atomized Solvent Flow, through the equipment.

(97) “Specialty Flexographic Printing” – A Flexogra phic Printing on polyethylene or polypropylene food packaging, fertilizer bags, or l iquid-tight food containers.

(98) “Specialty Gravure Printing” – Printing that u ses the gravure process for production of wall and floor covering, decorated ho usehold paper products such as towels and tissues, cigarette filter tips, vinyl upholstery, woodgrains, and a wide variety of other products.MDAQMD Rule 1117 1117-13

Graphic Arts d2, 09/01/09 (99) “Specialty Ink” – An Ink that is applied only on Non-Porous Substrates in Flexographic Printing Operations, and is either:

(a) A Metallic Ink that contains at least 28 percen t elemental metallic powder, by weight; or

(b) A matte finish Ink containing at least 5 percen t silicon dioxide flattening agent, by weight.

(100) “Stripping” – The use of Solvent to remove ma terial such as Cured Adhesives, Cured Inks, cured or dried paint, cured or dried pa int residue or temporary protective Coating.

(101) “Substrate Retention Factor” – A fraction, ex pressed in percent, of VOCs in lithographic Inks which is retained in the substrat e when the Inks dry by adsorption or absorption.

(102) “Surface Preparation” – The removal of contam inants from a surface prior to the application of Coatings, Inks, or Adhesives or befo re proceeding to the next step of a Manufacturing Process.

(103) “Thermography” – A digital printing technolog y that creates an image via a chemical reaction that occurs when portions of a th ermal-coated substrate are subjected to heat. Thermographic technologies incl ude but are not limited to thermal wax transfer, multi-bit thermal wax transfe r, and Dye Sublimation.

(104) “Thin Film UV Ink” – An Ultraviolet Ink for w hich <0.2 g will cover an area of ≥ 225 cm 2 (35 in 2 ), using the following formula: [Derived from EPA Method 24]

c D A F C × × =

Where: A = area of substrate in cm 2 (or in 2 ) C = amount of Ink added to the substrate in g D c = density of Ink in g/cm 3 (or g/in 3 ) F = manufacturer’s recommended film thickness in cm (or in)

(105) “Thinner” – A Solvent that is used to dilute Coatings or Inks to reduce viscosity, color strength, and/or solids, or to modify drying conditions. [Clarification]

(106) “Ultraviolet (UV) Ink” – An Ink which dries b y polymerization reaction by ultraviolet or electron beam radiation.

(107) “USEPA” – The United States Environmental Pro tection Agency, the Administrator of the USEPA and his or her authorize d representative. [Derived from MDAQMD Rule 1165]1117-14 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 (108) Volatile Organic Compound (VOC) – Any compoun d of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, met allic carbides or carbonates, and ammonium carbonate, which participates in atmos pheric photochemical reactions and those compounds listed in 40 CFR 51.1 00(s)(1). [Derived from MDAQMD Rule 1162]

(109) “Wash Primer” – A material used to clean and/ or to activate surfaces of paper or fabric that contains no more than 5 percent, by wei ght, solid materials.

(110) “Waste Solvent Material” – Any Solvent which may contain dirt, oil, metal particles, sludge, and/or waste products, or wiping material containing VOCs including, but not limited to, paper, cloth, sponge , rag, or cotton swab used in Solvent cleaning.

(111) “Water Slide Decal” – A decal that is Screen Printed onto treated paper stock and is removable from the stock by the dissolution of a n underlying water- soluble Adhesive or similar carrier.

(112) “Web” – A continuous sheet of substrate.

(113) “Web Feed” – An automatic system which suppli es substrate from a Web.

(114) “Web Splicing Adhesive” – An Adhesive used to join two continuous rolls of substrate materials.

(115) “Wipe Cleaning” – A Solvent cleaning activity performed by hand rubbing an absorbent material such as a rag, paper, sponge, br ush, or cotton swab containing Solvent.


### (C) Requirements

(1) No packaging rotogravure, publication rotogravure, or flexographic printing operation shall use any inks, coatings, or adhesive s unless the grams of VOC per liter of coating (or ink or adhesive), excluding wa ter and exempt Compounds, as applied , is less than 300 grams per liter (2.5 lbs/gallon)

.
(2 (1) Graphic Arts Printing Operation [Derived from SJVUAPCD Rule 4607 §5.1]

(a) An Operator performing a Graphic Arts Operation , not subject to (C)(2), (C)(3), (C)(4), and (C)(5), shall not use graphic a rts materials containing VOC in excess of the limits in Table 1 and Table 2, in accordance with the effective date.

Table 1MDAQMD Rule 1117 1117-15

Graphic Arts d2, 09/01/09 VOC Content Limits for Inks, Coatings and Adhesives

Material Grams of VOC per liter

(lb/gal), less water and less exempt compounds, as applied, effective through July 31, 2010 Grams of VOC per liter (lb/gal), less water and less Exempt Compounds, as applied, effective on and after August 1, 2010 Flexographic Ink on Porous Substrates 300 (2.5) 225 (1.88)

All other Inks 300 (2.5) 300 (2.5) Coatings 300 (2.5) 300 (2.5) Adhesives 300 (2.5) 150 (1.25) Web Splicing Adhesives 300 (2.5) 150 (1.25)

Table 2
VOC Content Limits for Fountain Solutions

Fountain Solution Percent VOC by volume, effective on and after August 1, 2010
Heatset Web Offset Lithographic 1.6

Coldset Web Offset Lithographic 5.0
Sheet-fed Offset Lithographic with maximum sheet size greater than 11 x 17 inches 5.0

All other presses 8.0

(2) Flexographic Specialty Ink [Derived from SJVUAPCD Rule 4607 §5.2]

(a) An Operator using a Flexographic Printing Opera tion shall not use a Specialty Ink in excess of the VOC limit in Table 3 , and shall not use more than two (2) gallons of Specialty Inks in a ca lendar day and 120 gallons of Specialty Inks in a calendar year.1117-16 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 Table 3

VOC Content Limits for Flexographic Specialty Ink

Material Grams of VOC per liter (lb/gal), less water and less exempt compounds, as applied, effective on and after August 1,

2010 Metallic Ink 460 (3.8) Matte Finish Ink 535 (4.5) Metallic Ink and Matte Finish Ink on Flexible Package Printing 383 (3.2)

(b) On and after August 1, 2010, facilities with th e potential to emit or with actual emissions of at least 10 tons VOC in any cal endar year shall not use Specialty Inks with VOC content greater than 300 gr ams VOC per liter, less water and Exempt Compounds, as applied.

(3) Coldset Web Offset Lithographic Fountain Soluti on [Derived from SJVUAPCD Rule 4607 §5.3]

(a) On and after August 1, 2010, an Operator perfor ming coldset Web Offset Lithographic Printing shall use Fountain Solution t hat is five percent alcohol substitute or less, by weight, and shall ha ve no alcohol in the Fountain Solution.

(4) Screen Printing Operation [Derived from SJVUAPCD Rule 4607 §5.4]

(a) An Operator using a Screen Printing Operation s hall not use graphic arts materials in excess of the VOC content limits, as a pplied, in Table 4.

Table 4

VOC Content Limits for Screen Printing Inks, Coatin gs, and Adhesives

Material Grams of VOC per liter (lb/gal), less

water and less Exempt Compounds on and after August 1, 2010 Inks and Coatings, including Extreme Performance, Metallic and Sign/Ink 400 (3.3)

Adhesives 150 (1.25) Resists 600 (5.0) (5) Paper, Film, Foil, or Fabric Coating Operations [Derived from SJVUAPCD Rule 4607 §5.5]

(a) An Operator using a Paper, Film, Foil, or Fabri c Coating Operation shall not use any Coating or Wash Primer in excess of the VOC content limits, as applied, in Table 5.MDAQMD Rule 1117 1117-17

Graphic Arts d2, 09/01/09 Table 5 VOC Content Limits of Paper, Film, Foil, or Fabric Coating and Wash Primer

Material VOC Content Limit,

effective through July 31,

2010 VOC Content Limit,

effective on and after August 1, 2010

Coating 300 gm/liter (2.5 lb/gal)

of Coating, less water and less Exempt Compounds 265 gm/liter (2.2 lb/gal)

of Coating, less water and less Exempt Compounds

Wash Primer 300 gm/liter (2.5 lb/gal)

of Coating, less water and less Exempt Compounds 265 gm/liter (2.2 lb/gal)

of Coating, less water and less Exempt Compounds
Plastisols

__ 20 gm/liter (0.16 lb/gal)

(b) On and after August 1, 2010, an Operator perfor ming pressure sensitive tape and label surface Coating Operations shall not use any VOC content materials or combinations of materials that exceed a VOC content of either 0.20 kg of VOC/kg of solids (0.20 lb VOC/lb of solids), as applied, or an additional limit of 0.067 kg VOC/kg of Coatin g (0.067 lb of VOC/lb of Coating), as applied.

(6) Approved VOC Emission Control System [Derived from SJVUAPCD Rule 4607 §5.6]

(a) Heatset Web Offset Lithographic or Letterpress

On or after August 1, 2010, an Operator performing Heatset Web Offset Lithographic or Letterpress Printing that has great er than 25 tpy potential to emit prior to controls shall use an add-on Contr ol Device on the Dryers, as follows: [Correction of typographical error]

(i) Heatset Web offset lithographic or letterpress printer Control Device installed on or prior to July 31, 2010 shall have an overall capture and control efficiency of 90 percent. [Typographical correction and format change for consistency] (ii) Heatset Web offset lithographic or letterpress printer Control Device installed on or after August 1, 2010 shall h ave an overall capture and control efficiency of 95 percent. [Format consistency]

(b ) In lieu of the requirements of Subsection (C)(1), (C)(2), (C)(3), (C)(4) and (C)(5), emissions of VOC may be controlled by an emission c apture and control system, which reduces VOC emissions to the atmosphe re, provided that:1117-18 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 (a) Averaged over any period of continuous operation no t to exceed 24 hours, the control device reduces the VOC emissions delive red from the capture system to the control device by at least 90 percent , by weight; and,

(b) Averaged over any period of continuous operation no t to exceed 24 hours, the combined effects of the capture and control system shall provide an overall emission reduction efficiency of at least:

(i) 75 percent, by weight, for publication rotogravure, or

(ii) 65 percent, by weight, for packaging rotogravure, o r

(iii) 60 percent, by weight, for flexogr aphic printing operations; and,

(i) The VOC emission control system is approved, in writing, by the Air Pollution Control Officer (APCO). [Typographical correction]

(ii) During continuous operation, not to exceed 24 hours, the VOC emission control system shall have a minimum overal l VOC capture and control efficiency as specified in Tabl e 6, in accordance with the corresponding effective date;

Table 6 VOC Emission Control System Overall Capture and Con trol Efficiency

Process Overall VOC capture

and control efficiency %, by weight, effective through July 31, 2010 Overall VOC capture

and control efficiency %, by weight, effective on and after August 1, 2010 Flexible Package Printing (All Technologies) 65% 80%

Publication Gravure 75% 85% Flexographic Printing Operations 60% n/a
Other Printing Operations n/a 75%
Paper, Film, Foil, or Fabric Coating Operations n/a 90%

(c) The collection system shall vent all drying oven Oven exhaust to the control device Control Device and shall have one or more inlets for collection o f fugitive emissions Fugitive Emissions ; and,MDAQMD Rule 1117 1117-19

Graphic Arts d2, 09/01/09

(d) During any period of operation of a thermal inc inerator, combustion temperature shall be continuously monitored; and,

(e) During any period of operation of a catalytic i ncinerator, exhaust gas temperature shall be continuously monitored; and,

(f) Appropriate permit(s) for the emission capture and control system are obtained pursuant to District regulations.

(3) Materials containing VOCs shall be stored in nonabs orbent, nonleaking containers, w hich shall be kept closed except when adding or rem oving material or during cleaning operations.

(4) (g) The VOC emission control system shall reduce VO C emissions, at all times, to a level that is not greater than the emis sions which would have been achieved through the use of compliant material s, compliant equipment or compliant work practices in Sections ( C)(1), (C)(2), (C)(3), (C)(4), (C)(5), and (C)(8).

(7) Coating Application Equipment [Derived from SJVUAPCD Rule 4607 §5.7]

No Operator shall apply Coatings unless Coatings a re applied with equipment operated according to manufacturer’s specifications , and only by the use of one of the following types of Coating Application Equipmen t:

(a) Flow Coater;

(b) Roll Coater;

(c) Dip Coater:

(d) Foam Coater;

(e) Die Coater;

(f) Hand Application Methods; or

(g) High-volume, low-pressure (HVLP) spray for air dried Coatings.

(i) For HVLP spray guns manufactured prior to Janua ry 1, 1996, the end user shall demonstrate that the gun meets HVLP spray equipment standards. Satisfactory proof will be eit her in the form of manufacturer's published technical material or b y a demonstration using a certified air pressure tip ga uge, measuring the air atomizing pressure dynamically at the cente r of the air cap and at the air horns.1117-20 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 (ii) A person shall not sell or offer for sale for use within the District any HVLP spray gun without a permanent marking deno ting the maximum inlet air pressure in psig at which the gun will operate within the parameters specified in (B)(46).

(h) Other Coating application methods which are dem onstrated to the APCO to be capable of achieving at least 65 percent tran sfer efficiency as determined in accordance with Section (F). Prior w ritten approval from the APCO shall be obtained for each alternative met hod used.

(i) In lieu of complying with Section (C)(7)(a) thr ough (C)(7)(h), an Operator may control emissions from the Coating Application Equipment with a VOC emission control system that meets the requirem ents of Section (C)(6).

(8) Solvent Cleaning [Derived from SJVUAPCD Rule 4607 §5.8]

(a) An Operator shall not use Solvents for cleaning Operations that exceed the VOC content limits specified in Table 7 in accordan ce with the corresponding effective date.MDAQMD Rule 1117 1117-21

Graphic Arts d2, 09/01/09 Table 7 VOC Content Limits for Solvent Cleaning

Type of Solvent Cleaning Operation VOC Content Limit grams of VOC/liter of material (Lb/gal), effective on and after July 1, 2011 [Date changed for consistency with BAAQMD requirement at request of commenter] A. Product Cleaning During Manufacturing Process; or Surface Preparation for Coating, Ink, or Adhesive Application 25 (0.21)

B. Repair and Maintenance Cleaning 25 (0.21) C. Cleaning of Coating or Adhesive Application Equipment 25 (0.21)
D. Cleaning of Ink Application Equipment 1. General 25 (0.21) 2. Flexographic Printing 25 (0.21) 3. Specialty Flexographic Printing 100 (0.83) 4. Gravure Printing a. Publication 100 (0.83) b. Packaging 25 (0.21) 5. Lithographic (Offset) or Letterpress Printing a. Roller Wash - Step 1 100 (0.83) b. Roller Wash - Step 2; Roller Wash - not specified; Blanket Wash, and On-Press Components 100 (0.83)

c. Removable Press Components 25 (0.21) 6. Screen Printing 100 (0.83) 7. Ultraviolet Ink/Electron Beam Ink Application Equipment (except Screen Printing) 100 (0.83)

(b)

(b) The following cleaning Operations may be perfor med outside of an APCO-approved VOC emission control system and using Solvent with VOC content greater than 25 g/L:

(i) Wipe Cleaning; (ii) Application of Solvent from hand-held spray bo ttles from which Solvents are dispensed without a Propellant induced force;1117-22 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 (iii) Non-Atomized Solvent Flow method in which the clean ing Solvent is collected in a container or a collection system which is closed except for Solvent collection openings and, if nece ssary, openings to avoid excessive pressure build-up inside the con tainer; or (iv) Solvent Flushing method in which the cleaning Solve nt is discharged into a container that is closed except f or Solvent collection openings and, if necessary, openings to avoid excessive pressure build-up inside the container. The dischar ged Solvent from the equipment must be collected into container s without atomizing into the open air. The Solvent may be flu shed through the system by air or hydraulic pressure, or by pump ing.

(c) Solvent shall not be atomized into the open air unless it is vented to a VOC emission control system that complies with Sect ion (C)(6). This provision shall not apply to printing Operations wh ere the roller or Blanket Wash is applied automatically and the clean ing of nozzle tips of automated spray equipment systems, except for robot ic systems, and cleaning with spray bottles or containers described in Section (C)(8)( b )(ii). [Correction of typographical error]

(d) An Operator shall not use VOC-containing materi als to clean spray equipment used for the application of Coatings, Adh esives, or Ink, unless an enclosed system or equipment that is proven to b e equally effective at controlling emissions is used for cleaning. If an e nclosed system is used, it must totally enclose spray guns, cups, nozzles, bow ls, and other parts during washing, rinsing and draining procedures, an d it must be used according to the manufacturer’s recommendations and must be closed when not in use.

(e) In lieu of complying with the provisions of Sec tions (C)(8)(a) through (C)(8)(d), an Operator may control emissions from c leaning Operations with an APCO-approved VOC emission control system t hat meets the requirements of Section (C)(6).

(9) An Operator shall store or dispose of fresh or spent Solvents, Waste Solvent Materials, Coatings, Adhesives, catalysts, Thinners , and Ink in Non-Absorbent, Non-Leaking Containers, which shall be kept closed except when adding or removing material, during cleaning Operations, or w hen the container is empty.

(10) VOC material wastes (including but not limited to liquid wastes, rags, and packaging) shall be disposed of in a manner consist ent with Federal, State, and local hazardous waste regulations.

(5) (11) The manufacturer of any ink, coating, or adhesive Ink, Coating, or Adhesive, except Thin Film UV Ink, which is sold, offered for sale, or supplied for use in packaging rotogravure, publica tion rotogravure, orMDAQMD Rule 1117 1117-23

Graphic Arts d2, 09/01/09 flexographic printing operations Packaging Gravure, Publication Gravure,

or Flexographic Printing Operations in the District shall include the following information on the product container or a data sheet Material Safety Data Sheet (MSDS) supplied with the product: [Thin Film UV Inks are exempted because there is no method for determi ning VOC content. ASTM D 5403-93, Standard Test Methods for Volatile Content of Radiation Curable Materials, is not applicable]

(a) Material name, manufacturer identification, spe cific mixing instructions, density, and VOC content, as applied.

(b) The VOC content of inks, coatings Inks (except Thin Film UV Ink), Coatings , and adhesives Adhesives expressed as defined in Subsection (B)( 5 3 9 ) [Correction of typographical error]

.

(12) Work Practices [Specific work practices added in response to USEPA comments, derived from EPA-453/R-06-002, CTG for Offset Litho graphic Printing and Letterpress Printing (September 2006), EPA 453/R-07 -003, CTG for Paper, Film, and Foil Coatings (September 2007) and EPA 453/R-06 -003, CTG for Flexible Packaging Printing (September 2006)]

(a) An Operator shall properly use and properly ope rate all graphic arts printing technologies as directed and/or specified by the manufacturer of the printer or graphic arts material.

(b) Solvent containers and mixing tanks must be kep t closed or covered except when filling, draining, or conducting cleani ng operations.

(c) Used shop towels, rags and wipes shall be kept in closed containers.

(d) Spray guns shall be cleaned in an enclosed syst em. [Reworded for consistency with prior work practice sections]

(e) Recycled solvents shall be used for cleaning if available and practical. [Reworded for consistency with prior work practice sections]

(f) Cleaning materials shall be conveyed from one l ocation to another in closed containers or pipes. [Reworded for consistency with prior work practice sections]


### (D) Exemptions1117-24 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 

### (1) The requirements of Subsections (C)(1) and (C)(2) s hall not apply to graphic arts f acilities which emit less than 2500 pounds of VOC i n any month from printing, coating, and adhesive operations. Once a facility becomes subject to Subsections (C)(1) and (C)(2) by exceeding this threshold, it w ill remain subject to these provisions even i f its emissions later fall below the applicability threshold.

(2) Screen Printing.

(3) Letterpress Printing.

(4) Lithographic Printing.

(1) The requirements of this rule, except for the recordkeeping requirements of section (E)(6), shall not apply to the following Op erations except for Paper, Film, Foil, or Fabric Coating Operations:

(a) Effective through July 31, 2010, any Graphic Ar ts Printing Operation which emits less than 400 pounds of VOC per calenda r month. [Derived from SJVUAPCD Rule 4607 §4.1.1, typographical corre ction]

(b) On or after August 1, 2010, any Graphic Arts Pr inting Operation that emits less than 200 pounds of VOC per 12 rolling co nsecutive calendar months. [Derived from SJVUAPCD Rule 4607 §4.1.2]

[Relocated to (D)(2)] (2) The requirements of this rule shall not apply t o: [Derived from SJVUAPCD Rule 4607 §4.3]

(a) Proof Presses;

(b) The application of Coatings and use of cleaning Solvents in creating Fine Art Paintings;

(c) Stripping of Cured Coatings, Cured Adhesives, a nd Cured Inks, except the Stripping of such materials from spray Application Equipment;

(d) Cleaning Operations in printing pre-press or gr aphic arts pre-press areas, including the cleaning of film processors, color sc anners, plate processors, films, and plates. [Removed redundant wording]

(e) Blanket Repair Materials used in containers of four (4) fluid ounces or less. [Derived from SJVUAPCD Rule 4607 §4.1.3]

(f) Digital Printers and Digital Printing Operation s except for recordkeeping requirements in section (E)(5) . [Derived from SJVUAPCD Rule 4607 §4.1.4]MDAQMD Rule 1117 1117-25

Graphic Arts d2, 09/01/09

(g) Screen Printing of Waterslide Decals. [Derived from BAAQMD Rule 8- 20, §8-20-118]

(3) The provisions of section (C) shall not apply t o the application of Adhesives and Coatings via Aerosol Products. [Derived from SJVUAPCD Rule 4607 §4.4]

(4) This rule shall not apply to laboratory tests o r analyses, Bench Scale, or Research and Development Projects. [Derived from SJVUAPCD Rule 4607 §4.5]

(5) This rule shall not limit the VOC content of Th in Film UV Inks.(6) Cleaning materials with a VOC composite vapor pressure less than 8 mm Hg at 20o C are exempt from section (C)(8)(a) of this rule. [Derived from EPA-453/R-06-001, Control Techniques Guidelines: Industrial Cleaning Solvents (September 2006)]

. 

### (E) Monitoring and Records

Unless otherwise noted, all VOC content and density values recorded pursuant to the requirements of this rule shall be for the material as applied. Packaging rotogravure, publication rotogravure, Graphic Arts and flexographic printing operatio ns Paper, Film, Foil and Fabric Coating Operations subject to this rule shall maintain the following records and information:

(1) For each ink, coating, and adhesive Ink, Coating, and Adhesive, Fountain Solution, Wash Primer, and Solvent in use and in storage:

(a) a A Material Safety Data Sheet (MSDS) or product data sheet or material list giving material name, manufacturer identification, specific mixing instructions , and density ; and

(b) VOC content as applied.

(2) Compliant Materials Records [Changes derived from SJVAPCD Rule 4607 §6.1.2]

If only inks, coatings Inks, Coatings , and adhesives Adhesives meeting the specification found in Subsection (C )(1 ) are used:

(a) Records on a daily basis showing the amount of ink Ink used. Ink use records shall be maintained using one of the follow ing options: [Monthly changed1117-26 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 back to daily at suggestion of USEPA. Had been cha nged to monthly to reflect SJVAPCD rule requirements.]

(i) Group the quantity of all inks Inks used and note identify the highest maximum VOC content figure and use the lowest minimum density figure from all the inks. of 1,010 gm/liter (8.44 lb/gal) ;

(ii) Itemize each ink Process Inks and pantone color Pantone Inks separately and use the specific VOC content and density value for each

.

(b) Records on a daily basis showing the amount of coatings Process Ink, and adhesives used. the highest VOC content and the maximum density of 1,010 gm/liter (8.44 lb/gal) for Pantone Inks; (iii) Report Process Inks and Pantone Inks separate ly and use the maximum VOC content and minimum density value f or both process and Pantone Inks, or use the density o f 1,010 gm/liter (8.44 lb/gal) for Pantone Inks; or (iv) Itemize each coating and adhesive Ink and Pantone Ink and use the specific VOC content and density value for each.

(3) If inks, coatings, or adhesives (b) Records on a daily basis showing the amount of Coatings,Adhesive, Wash Primer, and Solve nt (including cleaning Solvent) used. Itemize each Coating, Adhe sive, Wash Primer, and Solvent and use the specific VOC content and de nsity value for each. [Correction of typographical omission]

(c) Record, on a daily basis, the type, amount, and percent VOC by volume of Fountain Solution used. [Derived from SJVAPCD Rule 4607 §6.1.2.3]

(3) Non-Compliant Materials Records [Changes derived from SJVAPCD Rule 4607 §6.1.3]

If Inks, Coatings, Adhesives, Fountain Solutions, W ash Primers, and Solvents (including non-compliant cleaning Solvent) which do not meet the specifications found in Subsection (C )(1 ) are used and compliance is achieved through the use of add-on emission control equipment pursuant to (C)(6) :

(a) Records on a daily basis showing the type and a mount of inks, coatings, and adhesives used. Such records shall itemize eac h ink, coating, and adhesive Inks, Coatings, Adhesives, Fountain Solutions, Wash Primers, andMDAQMD Rule 1117 1117-27

Graphic Arts d2, 09/01/09

Solvents (including non-compliant cleaning Solvent) usedand itemized using the specific VOC content and density value for each.

(b) Daily records of key system operating and maintenance parameters Key System Operating Parameters which will demonstrate continuous operation Operation and compliance of the emission control device Control Device during periods of emission producing activities. Key system operating parameters Key System Operating Parameters are those necessary to ensure compliance with VOC capture and control requirements pursuant to (C)(6) (including but not limited to temperatures, pressures, and flow rates) . Such records shall be kept in the form and manner as prescribed by the APCO.

(4) Records for Flexographic Specialty Inks [Derived from SJVAPCD Rule 4607 §6.1.4]

If flexographic Specialty Inks are used pursuant to section (C)(2), record, on a daily basis, the type and amount of each Specialty Ink us ed.(5) Digital Printing Records [Derived from SJVAPCD Rule 4607 §6.1.6]

(a) On or after August 1, 2010, Digital Printing Op erations shall keep records in accordance with (E)(5)(b) for each Digital Print er that: [Clarification]

(i) Uses Solvent-based Inks and has a print capacit y of 1,000 ft 2 /hr or

more; or (ii) Uses water-based Inks, or UV Inks and has a pr int capacity of 10,000 ft 2 /hr or more,

(b) Operators with printers Subject to Section (E)( 5)(a) shall keep the following records:

(i) A current file of Inks, Coatings, Adhesives, an d Solvents in use and in storage. The file shall include a MSDS or pr oduct data sheet showing the material name, manufacturer's name, VOC content as applied, specific mixing instructions, and density. (ii) Monthly records of the type, and amount of eac h Ink, Coating, and/or Adhesive used. (iii) Monthly records of the type, and amount of So lvent used for thinning the Ink, Coating, or Adhesive, and for cle aning.

(6) If the facility is claiming exempt status pursuant to Subsection (D )(1 ), the facility shall maintain adequate records on a month ly basis to demonstrate the exempt status. The Operator who becomes subject to the emission limits/standards of this rule through loss of exemp tion in Section (D) shall not operate the subject equipment, except as requir ed for obtaining a new1117-28 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 or modified Permit-to-Operate, until the Operator d emonstrates that the Operation is in full compliance with the requiremen ts of this rule.

( 5 7 ) Any record required or produced pursuant to this rule shall be retained on site for a minimum of five years and shall be made available to the APCO

, CARB, or USEPA upon request.

[See section (C)(11), duplicative.] (8) Determination of VOC Emissions from Inks Used in a Lithographic Printing Operation [Derived from SJVAPCD Rule 4607 §6.3]

For the purposes of determining compliance with emi ssions limits, and determining eligibility for exemption under Section (D)(1) of this rule, the amount of VOC emitted from Heatset and Non-Heatset Inks us ed shall be discounted by the following Substrate Retention Factors: 20 perce nt for Heatset Inks and 95 percent for Non-Heatset Inks. These Substrate Rete ntion Factors shall not be used when determining compliance of Inks with appli cable VOC content limits specified in this rule, and Heatset and Non-Heatset lithographic Inks shall meet the VOC content limits specified in Section (C)(1), Table 1.


### (F) Test Methods

(1) Measurement of the VOC content of inks, coatings, a nd adhesives, except as specified in subsection (F)(2), shall be conducted and reported in accordance with EP A Reference Method 24 and ARB Method 432 for determ ination of exempt compounds as necessary. Perfluorocarbon compounds shall be assumed to be absent from a product or process unless a manufactu rer or facility operator identifies the specific individual co mpounds (from the broad classes of perfluorocarbon compounds) and the amounts present in the product or process and identifies a validated test method which can be used to quantify the specific compounds.

(2) Measurement of the VOC content of publication rotogravure inks shall be conducted and reported in accordance with EPA Refer ence Method 24A and ARB Method 432 for determination of exempt compounds as necessary.

(3) Emissions of VOC as specified in Subsection (C)(2) shall be measured as prescribed by e ither EPA Reference Method 25 or EPA Reference Meth od 25A, for determining organic emissions, and EPA Referenc e Method 18, for quantifying emissions of exempt compounds.

(4) The capture and control efficiency of air pollution control equipment, as specifi ed in Subsection (C)(2), shall be determined using app licable methods in 40 CFR 52.741.MDAQMD Rule 1117 1117-29

Graphic Arts d2, 09/01/09 The VOC content of materials subject to the provisi ons of this rule and overall capture and control efficiency of VOC emission control syst ems shall be determined by the following test methods specified in Sections (F)(1) through (F)(7), or alternative test methods approved by the APCO, USEPA, and CARB. [Derived from SJVUAPCD Rule 4607 §6.4]

(1) Except for UV Inks, the VOC content of Inks, Adhesi ves, Fountain Solutions, Solvents and Coatings shall be determined by using EPA Method 24 or 24A as applicable. The VOC content of UV Inks, except for Thin Film UV Inks, shall be determined by using American Society of Testing and Materials (ASTM) D5403- 93 (2007) (Test Methods for Volatile Content of Rad iation Curable Materials).

(2) Exempt Compound Content: Exempt compound content sh all be determined by using ARB Method 432, “Determination of Dichloromet hane and 1,1,1- Trichlorethane in Paints and Coatings,” September 1 2, 1989; ARB Method 422 “Determination of Volatile Organic Compounds in Emi ssion from Stationary Sources,” January 22, 1987; or, South Coast Air Qua lity Management District (SCAQMD) Method 303-91 “Determination of Exempt Com pounds,” August 1, 1996.

(3) The content of silicon dioxide as a flattening agen t in a Matte Finish Ink shall be determined by using the latest EPA approved revisio n of ASTM D717-86 (Standard Test Methods for Analysis of Magnesium Si licate Pigment).

(4) The metal content of Metallic Inks shall be determi ned by SCAQMD Test Method 318, (Determination of Weight Percent Elemen tal Metal In Coatings by X-Ray Diffraction).

(5) Determination of emissions of VOC from spray gun cl eaning systems shall be made using SCAQMD method "General Test Method for D etermining Solvent Losses from Spray Gun Cleaning Systems," October 3, 1989.

(6) The transfer efficiency of alternative Coating appl ication methods shall be determined in accordance with the SCAQMD method “Sp ray Equipment Transfer Efficiency Test Procedure for Equipment User,” May 24, 1989.

(7) Determination of Overall Capture and Control Effici ency of VOC Emission Control Systems

(a) The Capture Efficiency of a VOC emission control sy stem’s collection device(s) shall be determined according to EPA’s “G uidelines for Determining Capture Efficiency,” January 9, 1995 an d 40 CFR 51, Appendix M, Test Methods 204-204F, as applicable.

(b) The control efficiency of a VOC emission control sy stem’s VOC Control Device(s) shall be determined using EPA Test Method s 2, 2A, or 2D for1117-30 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 measuring flow rates and EPA Test Methods 25, 25A, or 25B for measuring total gaseous organic concentrations at t he inlet and outlet of the Control Device(s). EPA Method 18 or ARB Method 422 shall be used to determine the emissions of Exempt Compounds.

(c) For VOC emission control systems that consist of a single VOC emission collection device connected to a single VOC emissio n Control Device, the overall capture and control efficiency shall be cal culated by using the following equation: 

# [ ] 100 /

, Control

Capture Control Capture CE

CE CE ×

=

Where:

CE Capture,Control = Overall Capture and Control Efficiency, in percen t
CE Capture = Capture Efficiency of the collection device, in p ercent, as determined in Section (F)(7)(a) CE Control = Control Efficiency of the Control Device, in perc ent, as determined in Section (F)(7)(b).

(d) The following equation shall be used to determi ne if the minimum required overall capture and control efficiency of an emission control system is at an equivalent or greater level of VOC reduction as would be achieved using compliant materials, equipment, or w ork practices, as stated in Section (C)(6)(g).

100 1 1
1 , ,

, ×    

 

   

 

   

 

   

 

     

− 

    

−
×

− =

c LWC Max n Max LWn

Max LWn LWc

D

VOC D VOC

VOC VOC CE

Where:

CE = Minimum Required Overall Capture and Control E fficiency, percent

VOC LWc = VOC Limit, less water and less Exempt Compounds

VOC LWn,Max = Maximum VOC content of noncompliant Ink (or Coati ng or

Adhesive) used in conjunction with a Control Device , less water and less Exempt Compounds

D n,Max = Density of Solvent, reducer, or Thinner contained in

the noncompliant Ink (or Coating or Adhesive), cont ainingMDAQMD Rule 1117 1117-31

Graphic Arts d2, 09/01/09 the maximum VOC content of the multi-component Ink (or Coating, or Adhesive) printing Line

D

c = Density of corresponding Solvent, reducer, or Thinner used in the compliant Ink (or Coating, or A dhesive) system = 880 gm/liter. (8) When one or more test method or set o f test methods are specified for any testing, a violation of any requirement of this rule established by any one of the specified test methods or set of test method s shall constitute a violation of the rule. [Derived from MDAQMD Rule 1165 and added in respons e to USEPA suggestion as a provision when multiple test method s are provided.]

[SIP: Submitted as amended mm/dd/yy on mm/dd/yy; Ap proved: 4/30/96, 61 FR 18962, 40 CFR 52.220(c)(198)(I)(E)(2)]1117-32 MDAQMD Rule 1117 Graphic Arts d2, 09/01/09 This page intentionally left blank.MDAQMD Rule 1117 – Graphic Arts B-1

Final Staff Report, 01/21/10 

### Appendix “B” Public Notice Documents

1. Proof of Publication – Daily Press 08/26/2009 2. Proof of Publication – Riverside Press Enterpris e 08/26/2009B-2 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 This page intentionally left blank.MDAQMD Rule 1117 – Graphic Arts B-3

Final Staff Report, 01/21/10B-4 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10MDAQMD Rule 1117 – Graphic Arts C-1

Final Staff Report, 01/21/10 

### Appendix “C” Public Comments and Responses

1. Email from Catherine F. Jacobsen, Ph. D., DABT, 3M Materials, 06/25/2009 2. Email from USEPA, 06/25/2009 3. Letter from Marci Kinter, SGIA, 06/26/2009 4. Email from Harry Pontious, Victorille Daily Press, 06/29/2009 5. Email from Catherine F. Jacobsen, Ph. D., DABT, 3M Materials, 07/09/2009 6. Letter from Marci Kinter, SGIA, 07/20/2009 7. Email from Catherine F. Jacobsen, Ph. D., DABT, 3M Materials, 07/28/2009 8. CARB comment letter, 09/03/2009C-2 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 This page intentionally left blank.MDAQMD Rule 1117 – Graphic Arts C-3

Final Staff Report, 01/21/10 2 1 Comment Letter 1C-4 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 District response to Comment Letter 1

1. Section (C)(10) appears numbered correctly in the p reliminary draft. All numbering will be verified in final rule version for accuracy. Th e requirements of (C)(11) and (C)(11)(b) have been modified to exclude thin film inks becaus e there is no approved method to determine VOC content, and exemption (D)(5) has bee n added. 2. The cross reference in section (C)(11)(b) was in correct and has been changed to the proper reference of (B)(38).MDAQMD Rule 1117 – Graphic Arts C-5

Final Staff Report, 01/21/10 Comment Letter 2

1C-6 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 3

4 2MDAQMD Rule 1117 – Graphic Arts C-7

Final Staff Report, 01/21/10 District response to Comment Letter 2

1. Section (C)(12) – Work Practices was added with the work practice requirements for cleaning operations as described in the CTGs. 2. Recordkeeping requirements in section (E)(2)(a), (b ) and (c) were returned to “daily.” 3. Section (E)(2)(a)(i) was re-worded to clarify the i ntended meaning. 4. Section (F)(8) was added to clarify that a violatio n determined by any listed test method shall constitute a violation of the rule.C-8 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 Comment Letter 3

1

2

3MDAQMD Rule 1117 – Graphic Arts C-9

Final Staff Report, 01/21/10 4C-10 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10MDAQMD Rule 1117 – Graphic Arts C-11

Final Staff Report, 01/21/10 District response to Comment Letter 3

1. Subsections (D)(1)(c), (d) and (e) have been moved to section (D)(2) which is more appropriate and clear for those reading the rule. The District believes that (D)(1)(a) and (b) should remain as placed. 2. The District believes that the requirement of secti on (D)(2)(f) (digital printing operations) is appropriately located in the exemption section r ather than the applicability section to remain consistent with typical rule format used in the District. 3. The effective date of solvent cleaning VOC limits i n Table 7 has been changed to July 2011 for consistency with Bay Area Air Quality Mana gement District rule requirement as requested. 4. The District does not feel that a separate VOC limi t is necessary for Screen printing wipe cleaning as this method of clean-up is adequately a ddressed in section (C)(8)(b).C-12 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 Comment Letter 4

1MDAQMD Rule 1117 – Graphic Arts C-13

Final Staff Report, 01/21/10 District response to Comment Letter 4

1. Exemption (D)(6) has been added for cleaning mat erials with a VOC composite vapor pressure less than 8 mm Hg at 20 C which is consist ent with the Industrial Solvent Cleaning CTG. This will allow the operator to comp ly with all the VOC requirements of the rule.C-14 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 Comment Letter 5

1MDAQMD Rule 1117 – Graphic Arts C-15

Final Staff Report, 01/21/10 District response to Comment Letter 5

1. Definition (B)(101) – Thin Film UV Ink, has been added pursuant to EPA Method 24, 11.1.5, 12.1, and 12.2.C-16 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 Comment Letter 6

1

2MDAQMD Rule 1117 – Graphic Arts C-17

Final Staff Report, 01/21/10 District response to Comment Letter 6

1. The District concurs with the clarification request ed and these sections were relocated to (D)(2). 2. The District concurs that the exemption can be expa nded to include all cleaning solvents with a vapor pressure of 8 mm Hg for consistency wi th the CTG for Industrial Cleaning Solvents.C-18 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 Comment Letter 7

1MDAQMD Rule 1117 – Graphic Arts C-19

Final Staff Report, 01/21/10C-20 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 District response to Comment Letter 7

1. Typographical errors in definition (B)(101) were ma de as noted. The markup does obscure the equal portion of the greater than or eq ual to symbol.MDAQMD Rule 1117 – Graphic Arts C-21

Final Staff Report, 01/21/10 Comment Letter 8C-22 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 1MDAQMD Rule 1117 – Graphic Arts C-23

Final Staff Report, 01/21/10 District response to Comment Letter 8

1. The District has no operation that is subject to the 300 g/L limit. Therefore there will be no change (or increase) of VOC emissions due to thi s language. In addition, there is no practical difference between “less than 300” and “3 00 or less.” The proposed language is consistent with graphic arts regulation language us ed statewide and determined to be Federal RACT.C-24 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 This page intentionally left blank.MDAQMD Rule 1117 – Graphic Arts D-1

Final Staff Report, 01/21/10 

### Appendix “D”

California Environmental Quality Act

Documentation

1. Notice of Exemption, San Bernardino County 2. Notice of Exemption, Riverside CountyD-2 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 This page intentionally left blank.MDAQMD Rule 1117 – Graphic Arts D-3

Final Staff Report, 01/21/10D-4 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10MDAQMD Rule 1117 – Graphic Arts E-1

Final Staff Report, 01/21/10 

### Appendix “E” Bibliography

The following documents were consulted in the prepa ration of this staff report.

Statutes and Regulations

EPA-450/2-76-028 (1976/11) – Control of Volatile Or ganic Emissions from Existing Stationary Sources – Volume I: Control Methods for Surface Coa ting Operations

EPA-450/2-77-008 (1977/05) – Control of Volatile Or ganic Emissions from Existing Stationary Sources – Volume II: Surface Coating of Cans, Coils , Paper, Fabrics, Automobiles, and LightDuty Trucks

EPA-450/2-78-033 (1978/12) – Control of Volatile Or ganic Emissions from Existing Stationary Sources – Volume III: Graphic Arts-Rotogravure and Flexography

EPA-450/3-92-013 (1992/04) – Control of VOC Emissio ns from Ink and Paint Manufacturing Processes

EPA 453/R-06-002 2006/09 – Control Techniques Guide lines for Offset Lithographic Printing and Letterpress Printing

EPA 453/R-06-003 – Control Techniques Guidelines fo r Flexible Packaging Printing

EPA 453/R-07-003 – Control Techniques Guidelines fo r Paper, Film, and Foil Coatings

40 CFR 63 – National Emission Standards for Hazardo us Air Pollutants; Paper and other Web Coating; Proposed Rule (September 13, 2000)

40 CFR 63 – National Emission Standards for Hazardo us Air Pollutants; Printing, Coating, and Dyeing of Fabrics and other Textiles; Final Rule (M ay 29, 2003)

40 CFR 63 Subpart KK – National Emissions Standards for the Printing and Publishing Industry

40 CFR 63 Subpart QQ – Standards of Performance for the Graphic Arts Industry: Publication Rotogravure Printing

40 CFR 63 Subpart RR – Standards of Performance for Pressure Sensitive Tape and Label Surface Coating Operations

Local Air Districts

Regulation 8, Rule 20: Graphic Arts Printing and Co ating Operations (Bay Area Air Quality Management District, amended November 19, 2008)E-2 MDAQMD Rule 1117 – Graphic Arts Final Staff Report, 01/21/10 Staff Report for Proposed Amendments to Regulation 8, Rule 20: Graphic Arts Printing and Coating Operations (Bay Area Air Quality Management District, October 2008)

Rule 450 – Graphic Arts Operations (Sacramento Metr opolitan Air Quality Management District, amended 10/23/2008)

Rule 4607 – Graphic Arts and Paper, Film, Foil and Fabric Coatings (San Joaquin Valley Air Pollution Control District, amended 12/18/2008)

Attachments for Agenda Item regarding Rule 4607 ame ndments (San Joaquin Valley Air Pollution Control District, 12/18/2008)

Rule 1130 – Graphic Arts (South Coast Air Quality M anagement District, March 6, 1992)

Rule 1130 – Graphic Arts (South Coast Air Quality M anagement District, October 8, 1999)

Attachments for Agenda Item Regarding Rule 1130 – G raphic Arts (South Coast Air Quality Management District, October 8, 1999)

SIP Citations

Rule 1130 (South Coast Air Quality Management Distr ict, for Blythe/Palo Verde Valley) 58 FR 50884, Limited approval/limited disapproval of 03/06/92 version 59 FR 17697, Finalizing Limited approval, limited disapproval of 03/06/92 version 60 FR 55312/55314/55354, Approval of Rule 1130

Rule 1130.1 (South Coast Air Quality Management Dis trict, for Blythe/Palo Verde Valley) 61 FR 43976, Withdrawal

Rule 1117 (Mojave Desert Air Quality Management Dis trict) 61 FR 18962

Miscellaneous

EPA Method 24 – Determination of Volatile Matter Co ntent, Water Content, Density, Volume Solids, and Weight Solids of Surface Coatings.