July 14, 1995

South Coast Air Quality

Management District Board

Set a Public Hearing to Amend

Rule 1130 - Graphic Arts

INTRODUCTION

Rule 1130 - Graphic Arts regulates volatile organic compounds (VOC) from graphic arts operations which include lithographic, flexographic, letterpress, and gravure printing processes and related coating and laminating processes. Rule 1130 was first adopted on October 3, 1980 and was last amended on July 9, 1993.

On April 13, 1994, the United States Environmental Protection Agency (USEPA) partially approved and partially disapproved the March 6, 1992, version of the rule. The March 6, 1992, version was partially approved because it was considered a substantial improvement over the rule currently approved under the State Implementation Plan. However, the rule was also partially disapproved because (1) the current VOC limits for flexographic metallic and matte finish inks exceed the limits specified in the USEPA's "Control Technique Guideline (CTG)" for this industry, and (2) the overall control device efficiency for publication gravure is lower than the efficiency required under the CTG.

If an amended version of Rule 1130 is not submitted to and approved by the USEPA by November 12, 1995, the USEPA may impose mandatory actions beginning with a 2:1 offset requirement for new or modified facilities. These actions may result in financial hardships to the regulated community. This rule amendment is proposed to incorporate all the corrections required by the USEPA to approve the rule and some other changes suggested by the industry, the AQMD staff, and the USEPA.

The other amendments proposed by USEPA, AQMD staff and the industry are: 1) addition of a rule "Purpose and Applicability" section, 2) deletion of the exempt compound list and addition of a reference to Rule 102 - Definition of Terms which includes an exempt compound list, 3) lowering the minimum metal content requirement in flexographic metallic inks from 35% to 28% by weight, 4) lowering the VOC limit for flexographic metallic ink from 485 grams per liter (gm/liter) to 460 gm/liter, 5) addition of an equivalency equation for determining the required overall efficiency of a control device when one is used in conjunction with non-compliant materials, 6) elimination of the 500 gm/liter maximum VOC limit for non-compliant graphic arts materials used in conjunction with emission control systems, 7) elimination of the use of emission control systems and alternative emission control systems for exempt flexographic metallic and matte finish inks, 8) addition of a prohibition of sale and specification provision, 9) addition of a Rule 442 (Usage of Solvents) applicability statement, 10) addition of a maximum 300 gm/liter VOC limit for emission reduction credit calculations for flexographic matte finish and metallic inks, 11) revision of test methods and language clarification, 12) addition of an exemption from prohibition of sale and specification provision, and 13) addition of a limitation of total facility-wide potential VOC emissions to ten tons per year for facilities using the flexographic metallic and matte finish ink exemption.

The proposed amendments will have no significant impact on emission limitations or air quality. In addition, no adverse socioeconomic impacts are expected for the majority of facilities currently regulated by Rule 1130. It is possible that up to fifty facilities that operate emission control devices could incur significant additional costs (up to $20,000 per year) due to additional testing requirements specified by USEPA. Staff will work with these facilities to try to minimize these additional costs.

CONCLUSIONS

AQMD staff has concluded with certainty that the proposed amendments will not have a significant adverse impact on the environment because the amendments are not expected to change emissions, emission reductions, the type or number of control equipment, or the number of end-users regulated by the rule. Therefore, Proposed Amended Rule 1130 is exempt from the California Environmental Quality Act (CEQA) pursuant to state CEQA Guidelines Section - 15002 (k)(1) [AQMD CEQA Guidelines Section 1.2 (k)(1)]. The proposed amendments are also exempt from CEQA pursuant to state CEQA Guidelines Section 15061 (b)(3) - Review for Exemption [SCAQMD CEQA Guidelines Section 5.1 (b)(3)], and state CEQA Guidelines Section 15308 - Class 8 - Actions by Regulatory Agencies for the Protection of the Environment [AQMD CEQA Guidelines Section 19.12]. The Notice of Exemption will be filed with the county clerks immediately following the adoption of the proposed amendments.

This recommendation is to schedule a Public Hearing for Proposed Amended Rule 1130. A Public Workshop was held for this rule on April 25, 1995. The Public Hearing is scheduled for September 8, 1995. As per the Notice of Public Hearing, written comments will be accepted through August 1, 1995. All written comments received by this date will be reviewed and responded to by staff in the final Public Hearing Staff Report for the rule.

THEREFORE, IT IS RECOMMENDED THAT YOUR BOARD

--Set a public hearing September 8, 1995 to amend Rule 1130 - Graphic Arts

Respectfully,

James M. Lents, Ph.D.

Executive Officer

PL:WJF:FEL:AL

Attachments