Back

PROPOSAL:

Amend Rule 1130 - Graphic Arts

SYNOPSIS:

Proposed amendments to Rule 1130 would further reduce VOC emissions from graphic art operations. Revisions respond to ARB comments and also seek additional reduction opportunities. PAR 1130 would lower the allowable VOC content for flexographic printing inks on porous substrates, fountain solutions and adhesives; require higher efficiencies for add-on controls; limit the proof press exemption; and eliminate the small user exemption. The proposed amendment would also specify retention factors for lithographic inks and incorporate other clarifications.

COMMITTEE:

Stationary Source, August 20, 1999, Reviewed

RECOMMENDED ACTION:

Adopt the attached resolution:

1. Certifying the CEQA Final Environmental Assessment (EA) for Proposed Amended Rule 1130 – Graphic Arts;
2. Making certain findings; and
3. Amending Rule 1130 – Graphic Arts.

Barry R. Wallerstein, D.Env.
Executive Officer

Background

Rule 1130 – Graphic Arts, controls VOC emissions from the use of inks, coatings, fountain solutions and adhesives in the printing industry by: (1) limiting the VOC content of these products; (2) requiring that solvent cleaning operations comply with Rule 1171 – Solvent Cleaning Operations; and (3) by requiring the use of add-on control equipment for printing materials that exceed the limits specified. The current rule covers four areas of the graphic arts industries: lithography, flexography, gravure and letterpress printing.

The printing industry engages primarily in commercial printing, business forms, book printing, bookbinding, printing trade services, engraving and platemaking. A wide variety of printed products are available from corrugated boxes, plastic, foil, and coated paper bags, newspapers and magazines, to annual reports, pharmaceutical and cosmetics packaging and high-end advertisements. Such a broad range of product line dictates that the types of inks, coatings, adhesives, and fountain solutions are equally as broad. Sheet-fed, web heatset, web non-heatset, quickset, rubberbased, metallic, matte, fluorescent, vegetable, ultraviolet, electron beam, alcohol, alcohol-free, hot melt, re-moistenable, and emulsions are only a partial list of the types of inks, coatings, fountain solutions and adhesives used.

There are approximately 850 companies subject to this rule. The emissions inventory is approximately 4.0 tons of VOC per day. The largest sector is lithographic printing and it represents over 70 percent of the universe of sources and accounts for approximately the same percentage of the VOC emissions inventory. Flexography is second in order of magnitude with a 20-percentile range for both emissions and number of facilities. Letterpress and gravure round out the last few percent, respectively.

Currently exempted from this rule are inks applied to solar films, heat-applied decals, ceramics, circuit boards, laminations of fiberglass, metal, small container blanket repair materials, sterilization indicating inks, limited use of matte and metallic inks, and small emitters.

This proposed amended rule addresses several concerns raised by the ARB in its November 1997 correspondence to the District. The ARB concludes that graphic arts regulation in the South Coast Air Basin does not meet all feasible measures available to control VOC emissions from printing operations. AQMD Staff evaluated the state of current technology and agrees with ARB that VOC limits for fountain solutions and adhesives can be reduced, and that overall efficiencies for add-on control equipment can be increased. In addition, exemption standards for proof presses and small emitters can be more refined and limited. To further reduce emissions, establishment of a new VOC limit for flexographic inks used on porous substrates is proposed.

Proposal

Effective January 1, 2000, the staff proposal will

• Divide flexographic printing operations into three separate categories as inks applied to porous and nonporous substrates, and fluorescent inks, and the VOC limit for inks applied to porous substrates will be lowered from 300 gm/l to 225 gm/l. A separate category of fluorescent inks is established and the VOC limit remains at 300 gm/l.

• Reduce the VOC content for fountain solutions from 100 gm/l to 80 gm/l, while adding the option to use 100 gm/l fountain solutions provided the fountain is refrigerated to 55 degrees Fahrenheit or less;

• Reduce the VOC content for adhesives from 300 gm/l to 150 gm/l;

• Increase the requirements for overall add-on control equipment efficiency for publication gravure printing from 75 percent to 85 percent;

• Increase the requirements for overall add-on control equipment efficiency for flexographic, lithographic, packaging gravure and letterpress printing from 67 percent to 75 percent;

• Establish retention factors in the rule for lithographic ink oils as 95% for coldset printing inks and 20% for heatset printing inks. This is consistent with emission factors found in the Control Technology Guidelines for Offset Lithographic Printing published by the US EPA. Heatset printing will not encompass lithographic inks that are subject to infrared and ultraviolet light sources or electron beam generators. These will be considered coldset processes by definition;

• Limit the proof press exemption to the use of fountain solutions;

• Delete the small emitter exemption of 8 pounds of VOC per day at a facility and create a small postage stamp cancellation ink exemption, limited to no more than 60 pounds of VOC emissions per calendar month; and

• Clarify some existing rule language.

Policy Issues

Staff initially intended to establish a new standard for inkjet printing inks. However, further staff review and public input indicate that there is no immediate need to address this source category under this rule at this time. This relatively new source category is currently very small and covered under Rule 442 – Usage of Solvent. Additional time is needed to fully assess its potential diversity and establish appropriate limits. Therefore, this ink category has been removed from the proposed amended rule.

AQMP and Legal Mandates

The California Health and Safety Code requires the AQMD to adopt an Air Quality Management Plan (AQMP) to meet state and federal ambient air standards in the Basin. In addition, the California Health and Safety Code requires that the AQMD adopt rules and regulations that carry out the objectives of the AQMP. The 1997 AQMP does not contain a short-term measure to further control graphic arts operations. Nevertheless, the rule is proposed for amendment in order to address ARB concerns, and to obtain additional emission reductions where feasible. Any surplus emission reductions will be credited toward long-term AQMP reduction goals. In addition, with respect to 1994 State Implementation Plan (SIP), the proposed amendments, in conjunction with other existing regulatory programs, implement the 1994 SIP that applies to the graphic arts industry. Actual emission reductions from this rule amendment are 0.22 ton/day. The cost effectiveness of these reductions is $8,600 per ton of VOC reduced. Due to the revision of coldset lithographic ink oil retention factor an inventory reduction is estimated in the amount of 0.34 ton/day. Total emission reductions from the proposed amendments are therefore 0.56 ton/day.

CEQA

Pursuant to the California Environmental Quality Act (CEQA) and the AQMD’s Certified Regulatory Program (Rule 110), the AQMD has prepared an Environmental Assessment (EA) for Proposed Amended Rule 1130 – Graphic Arts. No comments on the environmental analysis were received.

The socioeconomic report for this proposed amendment to Rule 1130 – Graphic Arts is prepared and is attached to this Staff Report. The proposed amendments are projected to result in an annual cost of $836,463, which is not expected to result in regionally significant socioeconomic impacts. Based on the annual cost being less than $1 million dollars, no significant job impacts are expected and they would be so small as to be within the margin of uncertainty of the regional economic model. In addition, no job impact analysis is required because the amendments will not significantly affect air quality or emission limitations (Health & Safety Code Section 40440.8).

Implementation Plan

Staff will continue current inspection practices to facilities subject to Rule 1130. However, elimination of the small use exemption would cause certain changes in field inspection practices. Printing industry stakeholders and its association have been involved with the rule development process. Staff will continue to work with them to disseminate regulatory and compliance information. Any smaller operations will be informed of the amendments by mail, outreach, Internet posting on the AQMD website and any other applicable AQMD small business assistance programs.

Resource Impacts

Implementation of the proposed amendments is not expected to have impacts on staff or fiscal resources.

Attachments

A. Summary of Proposed Amendments
B. Rule Development Process
C. Key Contacts List
D. Resolution
E. Rule Language
F. Staff Report
G. Environmental Assessment

/ / /