UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for EPA’s Proposed Rulemaking

for the California State Implementation Plan

Rule 1130 Graphic Arts ; Rescission of Rule 1128

, Paper, Fabric and F ilm Coating Operations

Prepared by: Vanessa Graham Reviewed by: Andrew Steckel

A ugust 20151 RULE IDENTIFICATION

Agency: Antelope Valley Air Quality Management District ( AV AQM D)

SIP

- Approved Rule: South Coast Air Quality Management District (S CAQMD)

R ule 11 30

– Graphic Arts Adopted

– September 8 , 1995

Submitted

– October 13 , 1995 Approved

– October 31, 1995 ( 60 FR 55312 )

South Coast Air Quality Management District (SCAQMD)

Rule 1128

– Paper, Fabric, and Film Coating Operations Adopted

– Fe bruary 7, 1992

Submitted

– September 14, 1992 Approved

– December 20, 1993 ( 58 FR 66286 )

Subject of this TSD: AVAQM D Rule 11 30

– Graphic Arts Adopted

– November 19, 2013

Submitted

– May 13, 2014

AVAQM D Rule 1128

– Paper, Fabric, and Film Coating Ope rations

Rescinded

– November 19, 2013

Submitted

– May 13, 2014

BACKGROUND

– Prior to July 1, 1997, the area regulated by AVAQMD was contained within the SCAQMD boundaries. On July 1, 1997, the Antelope Valley Air Pollution Control District (AVAPCD) wa s created and took over responsibilities for the jurisdiction of the Los Angeles County portion of the Mojave Desert Air Basin. Rules and regulations of the SCAQMD were retained until the AVAPCD governing board adopted, rescinded or amended these rules. Therefore, SCAQMD Rule s 1128 and 1130 , adopted by SCAQMD in 1992 and 1995, and approved by EPA in 1993 and 1995 respectively, became part of the AVAPCD SIP

. On January 1, 2002, the Antelope Valley Air Quality Management District (AVAQMD) was created to

re place AVAPCD.

The AVAQMD is classified as severe nonattainment with respect to the 1997 and 2008 8

- hour

ozone National Ambient Air Quality Standards (NAAQS). The proposed amendments of Rule

1130 were submitted largely to satisfy Federal Reasonably Avail able Control Technology ( RACT ) requirements pursuant to Clean Air Act (CAA) section 182(b)(2)

. AVAQM D is rescinding Rule
1128, because it is now superseded by redundan t requirements in revised Rule 1130. AVAQMD’s recession only applies to AVAQMD Rule 112 8, and has no effect on SCAQMD Rule 1128

.

RULE SUMMARY

– R ule 11 30 limit s volatile organic compound ( VOC ) emissions largely by limiting the VOC content of coatings and solvents used in graphic a rts printing processes including lithographic

, flexographic, letterpress, gravure and d igital , in addition to coating2 o perations for paper, f abric film and f oil. Revisions to the SIP

- approved version of Rule 1130 include the following:

1. More stringent VOC content limits for graphic arts product categories and solve nt cleaning operations in : Section (C) Table 1

– VOC Content Limits for Adhesives, Coatings and Inks ; Table 2

– VOC Content Limits for Fountain Solutions ; Table 3

– VOC Content Limits for Flexographic Specialty Ink ; and Table 5

– VOC Content Limits for

Sol vent Cleaning

.

2. Capture and control efficiency requirements were strengthened in S ection (C) Table 4

– VOC Emission Control System Overall Capture and Control Efficiency

.

3. Solvent cleaning operations have been strengthened. Section (C) (7) adds more spe cific VOC limits for solvent operations beyond the provisions of District Rule 1171

– Solvent Cleaning Operations

.

4. General R ecordkeeping requirements pursuant to District Rule 109

– Recordkeeping for Volatile Organic Compounds have been strengthened and c larified with the addition of Section (E) Recordkeeping Requirements. Digital Printing recordkeeping requirements

have been added.

5. Work practices from the Control Technique s Guidelines ( CTG ) have been incorporated into the provisions of Section (C)(11)

.

6. The provisions of Rule 1128

– Paper, Fabric and Film Coating Operations have been incorporated into the revised version of Rule 1130. No part of Rule 1128 has been omitted, except those sections tha t have been superseded by date. These minor changes do not relax

the r equirements

.

The proposed amendments were submitted in part to satisfy Federal RACT requirements detailed in applicable CTG

.

RULE EVALUATION CRITERIA

– We primarily used the following criteria to evaluate the

submitted rule:

1. Enforceabi lity

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

.

2. Rule Stringency

– AVAQMD regulates a n area classified as s evere nonattainment for

both the 1997 and 2008 8 hour ozone NAAQS

, 40 C.F.R. § 81.305. U nder CAA section 182(b )(2), ozone nonattainment areas classified as moderate or above must implement

RACT for all VOC sources covered by a CTG document and all major sources of VOCs.3 Lithographic, flexographic, letterpress and gravure printing are all covered by CTG

documents.

3. SIP Relaxation

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

- approved control requirement in effect before November 15, 1990, in a nonattainment area.

In applying these criteria to the submitted rule, we referred to the following guidance and policy documents.

• State Implementation Plans; General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 28, 1992).

• Final Rule To Implement the 8

- Hour Ozone NAAQS

– Phase 2 , 70 FR 71612 ( No v. 25, 2005).

• CTG for Flexible Package Printing (EPA 453/R

- 06

- 003, September 2006).

• CTG for Offset Lithographic Printing and Letterpress Printing (EPA 453/R

- 06

- 0 0 2, September 2006).

• CTG for Paper, Film, and Foil Coatings (EPA 453/R

- 07

- 003, September 200 7 ).

• Control of Volatile Organic Emissions from Stationary Sources Volume VIII: Graphic

Arts

- Rotogravure and Flexography (EPA 450/2

- 78

- 033, December 1978).

• Alternative Control Techniques Document, Offset Lithographic Printing ( ACT, EPA

453/R

- 94

- 054 June 1994)

.

E PA EVALUATION

– A summary of our evaluation of the three criteria follows :

Enforceability

– Monitoring, reporting and recordkeeping (MRR) requirements of Rule 1130 have been improved in several respects, including:

• Previous recordkeeping requirements specified a two year onsite record retention. Section (E) (7) now requires record retention for five years.

• Rule 1130 S ection (E)(5) now requires recordkeeping for Digital Printing Operations meeting specified parameters.

• Test methods have been updated.

The MRR and other requirements generally ensure that the submitted Rule 11 30 is sufficiently

clear and enforceable consistent with CAA section 110(a) (2)(A)

.

Stringency

– The submitted rule is as stringent as t he following EPA 2006 /2007 CTGs that general ly define presumptive RA CT for this activity nationwide.

• CTG for Flexible Package Printing (EPA 453/R

- 06

- 003, September 2006).4 • CTG for Offset Lithographic Printing and Letterpress Printing (EPA 453/R

- 06

- 0 0 2, September 2006).

• CTG for Paper, Film, and Foi l Coatings (EPA 453/R

- 07

- 003, September 200 7 ).

.

AVAQMD’s staff report states that San Joaquin Valley Air Pollution Control District ( SJVAPCD ) Rule 4607

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

, approved October 15, 2009 ( 74 FR 52984 ) was used as a basis for the amendments to Rule 1130

– Graphic

Arts

. 1

AVAQMD Rule 1130 is largely consistent with the relevant CTGs and analogous rules including

SJVAPCD Rule 4607 and those identified in the “Additional References” section below. As a

resu lt, we have determined that this rule fulfills RACT requirements.

SIP Revisions

– AVAQMD’s 20 13 amendment improved the earlier version s of R ules 1128 and

1130 by revising the structure and requirements to be more aligned with the CTGs. Many new definitio ns were included to provide for additional clarity. VOC limits for p reviously unregulated categories were added. VOC content limits, r ecordkeeping and t est m ethod requirements were improved

. A ll substantive requirements of Rule 1128 were incorporated in to the amended

version of Rule 1130. We therefore propose to determine that our approval of revised Rule 1130

and re scission of Rule 1128 would comply with CAA sections 110(l) and 193 because the se actions ( 1 ) will insure equivalent or greater emi ssion r eductions of VOCs, and (2 ) will not

interfere with the on

- going process for ensuring that requirements for RFP and attainment of the NAAQS are met.

RULE DEFICIENCIES

– We have identified no deficiencies in submitted Rule 1130 sufficient for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

– The following recommendations are not currently the basis for rule di sapproval, but we encourage AVAQMD to incorporate them the next time the rule is amended:

1. (C)(5)(i) Re quirements for Coating Applications

– Paragraph (i) allows use of other coating application methods that are capable of “achiev i ng at least 65 percent Transfer Efficiency ” using the test method in Section (H)(8). The test method in Section (H)(8) only appl ies to spray equipment , which appears to duplicate Section (C)(5)(h) allowance

for alternatives to high

- volume low

- pressure ( HVLP) sp ray equipment. AVAQMD may want to review the applicability of Section (C)(5)(i) the next time the rule is amended.

See SCA QMD Rule 1128 Section (C) (6)(H)

. 2. (E) (3) Non

- compliant M aterials R ecords

- Please add the following: “ Violations of the requirement are considered to separate violations for each day. ”

3. An editorial error in section (G), Emission Reduction Credits (ERC) , seems to allow sources to claim permit offsets for flexographic coatings above 300 g/l. AVAQMD’s

1 Final Staff Report, Amendment of Rule 1130

– Graphic Arts and Resci ssion of Rule 1128

– Paper, Fabric and Film Coating Operations, Adopted on November 19, 2013, page 2.5 email dated April 30, 2015 2 confirms that there are no flexographic printing operations in

the District , and that no facility has used this provision. Noneth eless, please correct or

delete this provision at the next rule revision.

4. (H) Test Methods (1)

- Include the Ti tle for EPA Test Method 24 (Determination of Volatile Matter Content, Water Content, Density Volume Solids, and Weight Solids of

Surface Coatin gs ) and EPA Test Method 24A (Determination of Volatile Matter Content and Density of Printing Inks and Related Coatings)

. 5. (H) Test Methods (2) and (5)

- The Little Blue Book recommends that references to EPA

approved ASTM methods should include the full ti tle and date of the version being specified.

EPA ACTION

– The submitted revised Rule 11 30

, and rescinded Rule 1128 adequately address the relevant CAA criteria for the reasons discussed above. As a result, EPA staff recommends a full approval of Rule 11 30 and the rescission of Rule 1128 pursuant to CAA section 110(k)(3).

A DDITIONAL REFERENCES

• San Joaquin Valley Air Pollution Control Dis trict (SJVAPCD) Rule 4607 Graphic Arts and Paper, Film, Foil and Fabric Coatings, approved October 15, 2009

, 74 FR 5289 4

.

• SCAQMD Rule 1128 Paper, Fabric and Film Coating Operat ions, approved May 4, 1999

, 64 FR 23774

.

• SCAQMD 11 30 Graphic Arts approved September 23, 2000

, 65 FR 55201

.

• AVAQMD Rule 109 Recordkeeping f or Volatile Organic Compounds approved March 1,

2012 77 FR 1 2495

.

• AVAQMD Rule 1171 Solvent Cleaning Operations, approved May 24, 2001

, 66 FR

28666.

• Email from Tracy Walters, Lead Air Quality Planner AVA QM D, to Vanessa Graham

dated April 30, 2015

2 Email from Tracy Walters, Lead Air Quality Planner AVA QM D , to Vanessa Graham dated April 30, 2015

.