Proposal:
Amend Rule 1130.1 - Screen Printing Operations
Synopsis:
Proposed amendments will address concerns raised by the industry, ink manufacturers, and staff by creating higher VOC limits for various screen printing operations and postponing the implementation of the lower VOC limit for extreme performance applications. The amendments will result in a permanent emission reduction loss of 0.13 ton per day and delay the 0.28 ton per day emission reduction associated with extreme performance applications from 1998 to 2003.
Committee:
Stationary Source, December 5, 1996, Reviewed.
Recommended Action:
James M. Lents, Ph.D.
Executive Officer
Background
Rule 1130.1 - Screen Printing Operations regulates emissions of VOCs from screen printing operations. Screen prints are created by passing printing materials (inks, coatings, or adhesives) through stenciled screens. Products produced include T-shirts, indoor and outdoor signs, posters, decals, printed circuit boards, banners, and skateboards. There are approximately 3,000 to 4,000 screen printers operating in the AQMD.
Prior to the adoption of Rule 1130.1 on August 2, 1991, screen printers were subject to the requirements of Rule 1130 - Graphic Arts. At the request of the screen printing industry, Rule 1130.1 was developed to reflect the vast array of inks and substrates used by the industry. The original rule required the use of low-VOC screen printing materials to minimize VOC emissions from screen printing operations. The VOC limits for screen printing materials were established for specific products, substrates, and general categories and took effect on July 1, 1992. The rule also contained many technology-forcing VOC limits with a future implementation date of January 1, 1995. These effective dates were developed through the combined efforts of ink manufacturers, screen printers, the Screenprinting & Graphic Imaging Association International and AQMD staff. At the time Rule 1130.1 was adopted, it was estimated that implementation of the July 1, 1992 and January 1, 1995 VOC limits would result in an emission reduction of 3.07 tons per day.
While the vast majority of screen printers complied with the July 1, 1992 VOC limits, approximately 200 screen printers requested and received variances from the AQMD Hearing Board during the second half of 1992. Based on the testimony provided at the hearings and independent investigations, AQMD staff determined that, for certain applications, compliant inks with acceptable performance characteristics were either not available or the available compliant technology was not cost-effective. The rule was amended on July 9, 1993 to reflect the available feasible technology. In this amendment, the VOC limits were increased for those products and substrates for which compliant inks were either unavailable or cost prohibitive. However, most of the final technology-forcing limits, which were to become effective on January 1, 1995, were not changed. This approach was taken to encourage ink manufacturers to aggressively pursue the development of low-VOC inks and, in the interim, allow screen printers and ink manufacturers to comply with the rule. Based on changes included in the amendment, the emission reductions associated with the rule were revised from 3.07 to 2.76 tons per day.
Due to the development of new screen printing materials, compliance with the January 1, 1995 rule limits was possible for many applications. However, there were certain products, substrates, and screen printing materials for which compliance was not achievable because either compliant screen printing materials with the required performance characteristics had not been developed or the compliant technology was cost prohibitive. As a result, six major ink manufacturers were granted product variances for specific screen printing materials and applications in late 1994 and early 1995. These product variances are scheduled to expire in December 1996. Most of the screen printed products covered under these variances are made of plastics. However, products made of other substrates such as metal and man-made textiles are also included in these variances.
The quantity of inks used on the products covered by the variances in the AQMD is relatively low. As a result, there is very little incentive for resin manufacturers and ink formulators to develop compliant inks. Moreover, VOC emissions associated with these products are low. Thus, AQMD staff is proposing to increase the limits for these products without any future technology-forcing limits. AQMD staff is also proposing to delay the January 1, 1998 limit of 3.3 lbs/gal for the extreme performance category until January 1, 2003. As a result of these proposed amendments, the emission reductions due to the implementation of this rule are being revised to 2.63 tons per day. To date, the rule has resulted in an emission reduction of 2.35 tons per day which is 76% of the emission reduction originally proposed in 1991.
Proposal
The following changes are proposed:
1. Increase the current limit of 400 gms/liter to 800 gms/liter effective December 13, 1996 for the following screen printed products, substrates, and screen printing materials.
2. Increase the existing VOC limit of 400 gms/liter to 600 gms/liter for printing on glass and metal for decorative purposes. This limit will be consistent with the existing limit for printing on glass and metal for specification purposes.
3. Increase the existing VOC limit of 600 gms/liter to 800 gms/liter for dyes used on unsealed aluminum substrates.
4. Increase the existing VOC limit of 400 gms/liter to 540 gms/liter for fluorescent inks. Fluorescent inks glow brighter than conventional inks when exposed to the same light and are used on posters and banners.
5. Increase the existing 400 gms/liter VOC limit to 745 gms/liter for fine detail loose-leaf binder ink and loose-leaf binder metallic inks. The fine detail loose-leaf binder inks are used on loose-leaf binders to print very small graphics on darker backgrounds and loose-leaf binder metallic inks are inks which contain at least 50 grams of elemental metal particles per liter of ink as applied.
6. Delay the future 400 gms/liter limit for extreme performance inks from January 1, 1998 to January 1, 2003.
7. Restrict the high-VOC serigraph ink usage to 10% (by volume) of the total serigraph inks used at a facility, on a monthly basis.
8. Establish a minimum control device efficiency at 95% by weight.
9. Include the capture efficiency test methods revised by the USEPA.
10. Establish that all test methods referenced in the rule shall be the most recent versions approved by the AQMD, ARB, and USEPA.
11. Delete the reference to variances granted by the AQMD Hearing Board from the rule because USEPA does not recognize these variances.
In addition, staff has added a rule "Purpose" section, modified the "Applicability" section, added a reference to the exempt compound list in Rule 102 - Definition of Terms, and improved the rule language by adding, deleting, and refining definitions.
Increasing the VOC limits will result in a permanent emission reduction loss of approximately 0.13 ton per day. Additionally, delaying the extreme performance future limit to the year 2003 will result in a delay of the associated 0.28 ton per day emission reduction.
AQMP
The 1994 AQMP contained control measure CM #94CTS-I for further emission reductions from the screen printing industry. During the development of the 1997 AQMP, it was determined that further emission reductions from this industry may not be cost-effective. For this reason, the control measure for this industry is proposed to be included in the "Further Evaluation Measures" category.
CEQA
The AQMD has reviewed the proposed amendments to Rule 1130.1 pursuant to CEQA and has prepared a Draft Subsequent Environmental Assessment (SEA). The Draft SEA analyzed the potential adverse environmental impacts associated with the proposed project and was circulated for a 45-day public review and comment period which ended on November 8, 1996. No comments were received on the Draft SEA and it is now a Final SEA. Minor changes were made to the Draft SEA which are noted using strikethrough and underline.
Socioeconomic Analysis
Socioeconomic analysis indicates that no adverse socioeconomic impacts are expected from the proposed amendments to Rule 1130.1.
Implementation Plan
Staff is working with industry to help screen printers understand the rule more clearly and comply with its requirements. At the request of industry, staff has already developed a guideline on obtaining an extreme performance classification approval. This document has been available to screen printers since early December, 1996.
Resource Impact
Existing AQMD resources will be sufficient to implement the proposed changes to this rule with no impact on the budget.
Summary of Proposed Amendment
Rule Development Flow Chart
Key Contacts
Key Issues and Responses
Resolution
Rule Language
Staff Report
CEQA Analysis