Agenda Date: October 11, 2012

Prepared By: Bruce Springsteen

, Compliance and Enforcement Manager

Topic: Adoption of Amended Rule 235, Adhesive s
, and Rule 239,

Graphic Art s Operations . (Public Hearing/Action)

Action Requested:

1) Conduct a Public Hearing regarding the proposed adoption of amended Rule 235,

Adhesive s , and Rule 239, Graphic Art s Operations

.

2) Adopt Resolutions #12

- 10 (Attachment #1) and #12

- 11 (Attachment #2), thereby

a pproving the amended rules as revisions to the District Rules and Regulations and to the State Implementation Plan ; and a pproving all of the required “Findings and

Recommendation s” found in the Staff Reports ( Attachments #3 and # 4 )

.

Discussion :

The District is proposing amendments to two (2) rules which limit volatile organic compound (VOC) emissions:

Rule 235, Adhesive s , was l ast amended by the District on April 8, 2004

. Today’s proposed amendments are based on the U.S. EPA’s “Control Techniques Guidelines

for Miscellaneous Industrial Adhesives ,” (EPA 453 /R

- 08

- 005), dated September 2008, and establishes consistency with other local Air District rules.

Rule 239, Graphic A rts Operations , was l ast amended by the District on April 8,

2004. Today’s proposed amendments are based on the U.S. EPA’s “Control Techniques Guideline s for Offset Lithographic Printing and Letterpress Printing ,” ( EPA

- 453/R

- 06

- 002 ), dated September 2006

, and establish consistency with other

local Air District rules.

The rule amendments are required as part of the District’s State Implementation Plan (SIP) commitment to implement measures to reduce sources of ozone precursors; and associated requirements to implement Best Available Retrofit Control Technology under California Health and Safety Code Section 40919, and “every feasible measure” under California Health and Safety Code Section 40914. Th ese result from the District’s non

- attainment designation f

or ground level ozone.

The proposed amended rules, background documents, and letter s requesting comments were mailed to all impacted sources, including those with District permits to operate as well as

other affected sources known to the District. A publi c notice of the scheduled public hearing was published in the Auburn Journal on September 9, 2012

. The p ublic notice , proposed 

## Board Agenda

Public Hearing/ActionPCAPCD Agenda Item

October 11, 2012 Page 2

amended rules, and background documents were posted on the District website. The District has worked closely with the U.S. EPA, California Air Resources Board, and affected sources during development of the amended rules to ensure that once adopted, the

rules will receive approval into the SIP. The District received comments from t he U.S. EPA

on the amended rules. The comments, attached to the staff reports, have been addressed in the final proposed amendments.

Fiscal Impact:

The cost effectiveness of the proposed rule amendments ha ve been determined to be acceptable by the U.S. EPA

, and other Air Districts that have implemented the control

Techn iques Guidelines ( CTG ) requirements. The Rule 235, Adhesives

, amendments are not projected to result in economic hardship to any adhesives users or manufacturer within the

District

, including one (1) facility with a District permit to operate. The Rule 239, Graphic

Arts O perations

, amendments are not projected to result in economic hardship to any graphic arts operations within the District, including seven (7) shops with District per mits to operate.

Recommendation:

The purpose of the Board Hearing is to consider public testimony regarding the proposed amended rules and to consider whether the amended rules should be adopted.

The District recommends and requests that the Board: 1) Appr ove all the Findings found in the Staff reports of Attachments # 3 and # 4

.

2) Adopt Resolutions #12

- 10 (Attachment #1 ) and #12

- 11 (Attachment #2), thereby approving amended Rule 235 and Rule 239 as revisions to the District Rules and Regulations and to the State Implementation Plan.

Attachment(s) #1: Resolution #12

- 10, Adoption of Amended Rule 235, Adhesives

#2 : Resolution #12

- 11, Adoption of Amended Rule 239, Graphic Arts Operations

# 3: Staff Report for Amended Rule 235, Adhesives

# 4: Staff Report for Amended Rule 239, Graphic Arts Operations

### ATTACHMENT #1

Subject:

Resolution # 12

- 10 , Adoption of Amended Rule 235

### ATTACHMENT #2

Subject:

Resolution #12

- 11, Adoption of Amended Rule 239

### ATTACHMENT #3

Staff Report

Amendment of Rule 235

, Adhesives

### ATTACHMENT #4

Subject:

Staff Report

Amendment of Rule 239

, Graphic Arts Operations