UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

For
EPA ’ s Proposed Rulemaking

For the California State Implementation Plan

Ventura County Air Pollution Control District ,

Rule 74.19 , Graphic Arts

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

October 201 2 2



Agency: Ventura County Air Pollution Control District ( VCAPC D)

SIP Approved Rule : Rule 74.19
– Graphic Arts Adopted – August 11 , 199 2
Revised – November 11, 2003 Submitted
– April 26, 2005 EPA Approved – October 25, 2005 ( 70 FR 61561 )

Subject of this TSD: Rule 74.19
– Graphic Arts
Revis ed – June 14 , 20 11 Submitted
– September 27 , 201 1

RULE SUMMARY

- VCAPCD Rule 74.19 , Graphic Arts , was amended to implement an All Feasible Measure as required by the California Clean Air Act ( Health and Safety Code § 40 914 ) in order to attain the ozone ambient air quality standard. Rule 74.19 was also amended to comply with the federal reasonably available control technology (RACT) established in the 2006 Control Technique Guideline (CTG) for Offset Lithographic Printing and Letterpress Printing

. The modifications to
Rule 74.19 , Grap hic Arts include:
1. Revised the a pplicability of the rule’s provisions in subsection A

- 2 to include manufacturers and suppliers outside the d istrict.
2. Removed 1993 ROC limits in subsection B

- 1 and adopted the April 1, 2002
limits for Inks, Coating and Adhesives. 3. Removed the 1993 ROC limits and revised the effective date of April 1, 2002 limits to January 1, 2012 for Fountain Solutions in subsection B

- 2.
Add ed a table for limits effective January 1, 2012 for Fountain Solutions and a requirement for temperature sensors for refrigerated chillers

. 4. Removed 2002 ROC limits for cleaning solutions in subsection B

- 3 and replaced this with a table of new limits based on grams/liter and composite 3

 partial pressure effective until January 1, 2 01 2

. Added a table with more stringent limits effective after January 1, 2012.
5. Removed the already

- expired 2002 effective date for prohibiting the use of Methylene Chloride in subsection B

- 4. 6. Increased the overall capture and control efficiency for an emission capture and control system in subsection B

- 6 from 75% to 80%

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

. 8. Added subsection B

- 10 to prohibit the specification of graphic arts products not meeting the limits of the rule. 9. Adde d exemption s in subsections C

- 2 and C

- 3 for digital printing operations, proof presses, pre

- press operations, blanket

- repair operations, aerosol coating products and specific cleaning solvents. 10. Revis ed the recordkeeping requirements in subsection D

- 2 for Fountain Solutions, effective January 1, 2012.
11. Removed the provision for making recordkeeping a part of Permit to Operate
in section D

. 12. Added titles and EPA approved version dates for all non

- EPA test methods in Section E. 13. Added or revised definitions in section G to provide clarity and completeness.

EPA EVALUATION

- The following criteria were used to evaluate the submitted
rule.

1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988), the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001), and State Implementation Plans, Gen

eral Preamble for the Implementation of Title I of the Clean Air Amendments of 1990 (57 FR 13498, April 16, 1992) were used to help 4

 evaluate compliance with the CAA § 110(a)(2)(A) requirement for enforceability.

2. Stringency
– The EPA’s CTG titled Industrial Cleaning Solvents ( EPA 453/R

06

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

- 06

- 00 2 , September 2006 )

. Other district s’ analogous rules for this category were used as the basis for RACT including: Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 450, Graphic Arts Operation s , revised October 23, 2008 , Bay Area A ir Quality Management District ( BAAQMD) Rule 8

- 20, Graphic Arts Printing and Coating Operations

, amended Nov e mber 19 , 2008 and San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) Rule 4607, Graphic Arts and Paper, Film, Foil and Fabric Operations amended December 18, 2008

.

3. SIP Relaxation – We have evaluated this SIP revision to determine whether it would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the
Act ( CAA §110(l)) or modify, in a nonattainme nt area, any SIP

- approved control requirement in effect before November 15, 1990 (CAA §193).

Enforceability

- The recordkeeping requirements for Graphic Arts are analogous to that of S MA QMD’s rule 4 50. The exception is that this VCAPCD rule does not require the recording of density of ink as SMAQMD ’s Rule 450 does and the density of coatings, inks, adhesives, fountain solutions, and solvents as SJVUA PC D’s Rule
4607 does

. All test methods for specific compounds, inks and means to determine overall capt ure and control efficiencies also general ly resemble those analogous RACT rule s

. The additional exemptions are generally similar to those exempted in SJVUA PC D’s Rule 4607. These parameters and the additional statement for multiple test methods, generally ensure that the submitted rule can be enforced. 5



Therefore, we propose to determine that submitted Rule 74.19 is sufficiently clear and enforceable.

Stringency
– In the June 2009 Technical Support Document (TSD) for SJVUA PC D Rule 4607 it was determined that this rule demonstrated RACT because it is as stringent as the three current CTGs and, as a nonattainment area, generally SJVUA PC D rules have among the most stringent stationary source requirements
nationwide. VCAPCD’s Rule 74.19 closely resembles SJVU A PC D’s Rule 4607 for VOC limits for coating, inks and adhesives and for solvent cleaning activities

. VCAPCD’s Rule 74.19 resembles SMAQMD’s Rul e 450 for VOC limits for fountain
solution m aterials

. In general, the application methods and work practices of
V CAPCD’s Rule 74.19 are comparable to both SJVUA PC D’s Rule 4607 and SMAQMD’s Rule 450. In addition, prohibiting the specification of graphic arts materials that do not meet the rule’s limits was added to make the rule more stringent. The definition of VOC, referencing the definiti on in VCAPCD’s Rule 2, does not comply with the 40 CFR 51.100(s) (5) which exempts t

- butyl acetate (TBAc) except for recordkeeping, emissions reporting, photochemical dispersion monitoring and inventory requirements which apply to VOC. However, we do not believe that omitting the requirement for recordkeeping, emissions reporting, photochemical dispersion mode ling and inventory requirements o f the exempt compound TBAc is sufficient basis to disapprove this rule. It is our conclusion that “...TBAc will not be VOC for purpos es of VOC emissions limitations or VOC content requirements ” 1
, which are the basis for compl iance with this rule by a facility. In addition, the State will continue to assume the responsibility for the reporting, modeling and inventory requirements.

1 . 40 CFR 51.100(s)(5) 6



SIP Relaxation
– The new submittal generally complies with CAA § 110(l) and § 193 regarding SIP relaxations. All previous VOC limits have been lowered and several new categories have been added for both the fountain solutions and cleaning
solvents

. The combined efficiency requirement for other types of printing processes was also increased from 75% t o 80%.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION
– 1. Section D , Recordkeeping Requirements :

a. Subsection 1 and 2 – Add the requirement to include density to the data required for these materials

. 2. Section E , Test Methods:

a. Subsection 5 – Please add the complete title, Determination of Volatile Organic Compounds in Emissions from Stationary Sources and the EPA approval date , December 13, 1991 , to ARB Method 422.
b. Subsection 6

- Please revise SCAQMD Test Method 31 6B to Test Method 31 6

- 9 1

.

EPA ACTION

- EPA staff recommends a full approval of Rule 74.19 pursuant to CAA §110(k) (4) and §301(a).

ADDITIONAL REFERENCES

- 1. SMAQMD Rule 450, Graphic Arts Operations, revised October 23, 2008. http://www.airquality.org/rules/rule450.pdf
2. BAAQMD Rule 8

- 20, Graphic Arts Printing and Coating Operations, amended November 19, 2008. http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/Rul es%20and%20Regs/reg%2008/rg0820.ashx?la=en 7

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3. SJVUAPCD Rule 4607, Graphic Arts and Paper, Film, Foil and Fabric Operations amended December 18, 2008 http://www.valleyair.org/rules/currntrules/r4607.pdf
4. SCAQMD Rule 1171, Solvent Cleaning Operations, amended May 1, 2009 http://www.aqmd.gov/rules/reg/reg11/r1171.pdf
5. “Control Techniques Guidelines for Industrial Cleaning Solvents,” EPA 453/R

- 06

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

- 06

- 001_ind_cleaning_solvents.pdf 6. “Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing,” EPA 453/R

- 06

- 00 2 , September 2006

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

- 06

- 002_litho_letterpress_printing.pdf
7. “Issues Relating to V OC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988. http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf 8. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Blueb ook), EPA Region 9, August 21, 2001. http://www.epa.gov/region9/air/sips/littlebluebook2001.pdf