BOARD MEETING DATE: February 6, 2009
AGENDA NO. 30

PROPOSAL:

Enforcement Discretion for Clean-up of Ultraviolet/Electron Beam (UV/EB) Inks, On-Press Screens, and Photocurable Resins from Stereolithography Equipment and Models in Rule 1171 - Solvent Cleaning Operations and Rule 1122 – Solvent Degreasers

SYNOPSIS:

Prior amendments to Rules 1171 and 1122 had extended the effective dates for the use of low-VOC cleanup solvents for UV/EB inks, on-press screens, and stereolithography equipment to December 31, 2008. A recently completed evaluation by the printing industry concluded that the currently available solvents do not meet industry’s performance criteria. Consequently, industry has requested an extension of the compliance date to allow additional time for reformulation and testing. Staff plans to propose amendments to Rules 1171 and 1122 to the Board at the earliest possible date to address this request. In the meantime, staff proposes to exercise enforcement discretion for the low-VOC limits that went into effect January 1, 2009.

COMMITTEE:

Stationary Source, January 23, 2009, Reviewed

RECOMMENDED ACTIONS:

Receive and file this report.
 

Barry R. Wallerstein, D.Env.
Executive Officer

Background

Rule 1171 – Solvent Cleaning Operations and Rule 1122 – Solvent Degreasers control primarily VOC emissions generated from the use of solvents for removing contaminants from products, tools, machinery, equipment and general work areas during production, maintenance and/or repair activities. Past amendments to these rules have achieved more than 90% VOC emission reductions or about 77 tons per day through greater use of aqueous cleaning technologies, VOC-exempt solvents, and the development of new low-VOC cleaning materials. However, certain cleaning applications that typically have overall low volumes continue to use high-VOC solvents due to lack of low-VOC alternative cleaners that meet performance criteria.

The February 2008 amendment to Rule 1171 extended, until January 1, 2009, the compliance date for the use of 100 gram per liter formulations for cleanup of UV/EB inks in lithographic printing, and on-press screens and automatic screen reclamation in screen printing operations. The delay was necessary to allow additional time for the printing industry to test new formulations, and transition to the new cleaning materials. Since then, printers and solvent formulators have been working together to develop and test compliant solvent formulations in actual production environment. The Printing Industries of California (PIC) and the Specialty Graphic Imaging Association (SGIA) have periodically submitted to AQMD progress reports pertaining to the test program.

In regard to stereolithography, Rules 1171 and 1122 allow a limited exemption from the 25 gram per liter VOC limit for clean-up solvents used in photocurable resins from stereolithography equipment and models. Such exemption ended last January 1, 2009.

Similar to the printing industry, manufacturers of stereolithography equipment and resins have conducted research work to identify alternative cleaning solvents that would satisfy cleaning requirements. Results indicated that water-based cleaners, VOC-exempt solvents and other solvent blends failed to meet established performance criteria.

In December 2008, industry representatives informed AQMD that low-VOC alternative solvents with equal performance characteristics are not available at this time for cleaning UV/EB inks, on-press screens, and stereolithography equipment and models. In addition, industry requested AQMD to further delay implementation of the applicable low-VOC limits in Rules 1171 and 1122 for these solvent cleaning applications.

Staff agrees that additional time is needed to fully develop compliant cleaning materials and will initiate rule amendment process for Rules 1171 and 1122.
 

Proposal

Considering the low-VOC limits took effect on January 1, 2009, staff intends to exercise enforcement discretion for the applicable VOC limits in Rules 1171 and 1122 for clean-up of UV/EB inks, on-press screens in screen printing, and photocurable resins from stereolithography equipment and models. In the interim period, the cleaning materials used for the clean-up of UV/EB inks will not exceed 650 g/l and materials used on on-press screens in screen printing will not exceed 500 g/l VOC and for cleaning materials used with stereolithography equipment will not exceed 900 g/l. Staff will publish a facility operator advisory to clearly delineate the actions outlined above. The VOC emissions from the affected solvent cleaning activities are estimated to be 0.2 ton per day. Rule amendments will be presented to the Board as soon as possible pursuant to applicable California Health and Safety Codes.
 

Resource Impact

Current AQMD resources are sufficient with no additional fiscal impact.