BOARD MEETING DATE: July 7, 2006
AGENDA NO. 36
PROPOSAL:
Amend Rule 1171 – Solvent Cleaning Operations
SYNOPSIS:
The proposed amendment will delay the compliance date for the use of low-VOC clean-up solvents on ink application equipment used in lithographic/letterpress printing (except newsprint), screen printing and ultraviolet/electron beam inks by 18 months to January 1, 2008. Additional time is necessary to allow further testing and industry transition to new cleaning materials. However, staff proposes to implement the 100 gram per liter VOC limit for clean-up solvents for ink application equipment used for lithographic printing on newsprint starting July 1, 2006 and allow the use of cleaners with 650 grams per liter of VOCs for automatic roller and blanket clean up systems (lithographic printing) until December 31, 2007. The Board will also make infeasibility findings for the extended compliance dates.
COMMITTEE:
Stationary Source, April 28, 2006 and June 23, 2006, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
- Certifying the CEQA Final Subsequent Environmental Assessment for the proposed amendments.
- Amending Rule 1171 – Solvent Cleaning Operations.
Barry R. Wallerstein, D.Env.
Executive Officer
Introduction
The Governing Board continued the June public hearing on PAR 1171 to the July 7, 2006 meeting in order for staff to re-evaluate specific issues raised during the public hearing pertaining to ultraviolet/electron beam (UV/EB) ink application equipment and lithographic printing on newsprint. Representatives of the printing industry have requested for a higher interim VOC limit for solvents used in handwipe cleaning of UV ink application equipment including those used for the clean up of EB ink application equipment. Industry argued that the current cleaners meeting the interim VOC limit of 500 grams per liter for these cleaning categories increase cleaning time and cause damage to the press rollers. For printing on newsprint, industry requested for a delay in the implementation of the 100 gram per liter VOC limit to give adequate time to address clean up of other press parts such as pipe rollers. Furthermore, industry needed clarification on the definition of newsprint as well as the facilities that fall under this subcategory.
After several discussions with members of the printing industry, staff has reconsidered its earlier proposal and agreed to raise the interim VOC limit from 500 to 650 grams per liter for the clean up of UV/EB ink application equipment. Staff has also modified the definition of newsprint, as requested by industry, and clarified applicability of rule requirement for lithographic printing on newsprint.
Background
Rule 1171 – Solvent Cleaning Operations was adopted on August 2, 1991 to reduce VOC emissions from the use of solvents and solvent wastes generated during the production, repair, maintenance, or servicing of products, tools, machinery, and general work areas. In October 1999, the rule established two-tiered VOC limits to reduce VOC emissions from all solvent cleaning activities. Tier I was implemented on December 1, 2001 and reduced VOC emissions by 6 tons per day. The Tier II VOC limits had an original implementation date of July 1, 2005, but subject to the completion of technology assessments to determine the feasibility of such limits. The VOC emission reduction expected from Tier II limits was estimated to be 9 tons per day in 2005.
During the past few years, AQMD implemented most of the Tier II VOC limits in Rule 1171. In August 2002, the amendment of Rule 1171 accelerated by two and one-half years the reduction of 1.94 tons per day of VOC emissions from general solvent cleaning activities. During that time, many available low-VOC cleaning materials were already meeting the Tier II VOC limit of 25 grams per liter for general cleaning applications. On July 1, 2005, AQMD implemented the Tier II VOC limits for cleaning of electrical apparatus/electronic components and coating/adhesive application equipment. The technology assessments for these specific solvent cleaning applications, completed in August 2003, concluded that new and existing low-VOC cleaning technologies that meet the Tier II limits could be used for these cleaning applications.
With the implementation of most of the Tier II limits, the only remaining VOC limits are those established for the cleaning of ink application equipment used for lithography/letterpress, screen printing, and ultraviolet/electron beam (UV/EB) inks. In May 2005, Rule 1171 was amended to extend the compliance date for the Tier II VOC limits for these remaining cleaning applications to July 1, 2006 to allow extended field testing of potential alternative cleaners. At the same time, an interim VOC limit of 500 grams per liter was established for these solvent cleaning activities beginning July 1, 2005.
One should note that the transition to the 500 gram per liter interim limit was not challenge-free. During the first few months following the implementation of the interim VOC limit, the printing industry reported difficulties in finding compliant solvents that would meet their cleaning requirements. This was a surprise because the printing industry did not anticipate performance problems with the use of cleaning materials that were meeting the 500 gram per liter VOC limit. Staff’s initial field evaluations and contacts with individual press operators revealed serious performance issues, such as poor print quality and oily residue left on rollers and blankets, associated with the first generation of reformulated products (500 grams per liter or less VOC) made available immediately after the July 1, 2005 effective date. However, new cleaner formulations have progressively improved and printers now have a better feel of the cleaning materials that meet the 500 gram per liter VOC limit. Currently, the printers’ remaining concerns center on the oily residue and longer cleaning times as a result of using the reformulated solvents.
As discussed earlier, implementation of the Tier II VOC limits for the cleaning of ink application equipment used for lithographic/letterpress, screen printing, and UV/EB inks depends on the completion of a technology assessment. Staff had anticipated that the study would be completed by November 2005, but unforeseen circumstances caused a delay in the completion of the technology assessment. As of today, field testing (including extended testing) of potential alternative cleaning materials has been completed. A draft report presenting the results of the testing program has recently been submitted for staff review.
Proposal
Staff is proposing to delay the implementation of the 100 gram per liter VOC limit for the cleaning of lithographic/letterpress printing (except newsprint), screen printing, and UV/EB ink application equipment by 18 months. The technology assessments to support the VOC limits for these cleaning applications are not complete. The new proposed compliance date is January 1, 2008. In addition, PAR 1171 will extend the limited exemption for the cleaning of metering rollers, dampening rollers and printing plates, as well as the cleaning of UV/EB lamps and reflectors. Staff is also proposing to temporarily raise the VOC limit for solvents used in automatic roller and blanket clean up systems from 500 to 650 grams per liter until December 31, 2007. This will provide facilities additional time to address printing-related problems associated with the use of reformulated cleaning materials meeting the 500 gram per liter limit in automatic roller and blanket clean up systems.
For lithographic printing on newsprint, staff is proposing to implement the 100 gram per liter VOC limit for roller wash, blanket wash, and on-press components beginning July 1, 2006. Many newspaper facilities and other printers that print on newsprint have successfully converted to alternative cleaning materials that meet the 100 gram per liter VOC limit. The successful use of these low-VOC solvents indicates that these cleaning materials are already technically and economically feasible for this printing application.
Staff is also recommending to raise the interim VOC limit from 500 to 650 grams per liter for the clean up of UV/EB ink application equipment. Staff has also modified the definition of newsprint to clarify the applicability of the requirement for lithographic printing on newsprint.
Other proposed amendments to Rule 1171 are as follows:
- Establish a new completion date for the technology assessment;
- Clarify the exemption for aerosol products; and
- Remove outdated rule requirements.
PAR 1171 will delay by 18 months the emission reduction of 2.48 tons per day expected in 2006 from lithographic/letterpress printing (except newsprint), screen printing, and UV/EB inks. This emission reduction represents the remainder of the Tier II reductions of 9 tons per day originally projected in 1999.
Key Issues
One of the issues raised by the printing industry pertains to the problems in meeting the interim VOC limit (500 grams per liter) for presses equipped with automatic roller and blanket cleaning systems. According to industry representatives, these low-VOC solvents (500 grams per liter or less VOC) are difficult or even impossible to utilize on automatic clean up systems. Many printers have had to dismantle or shut-off these systems and clean by hand because the existing cleaners do not work well with automatic clean up systems.
AQMD agrees that the current cleaners (500 grams per liter or less VOC) do not work well at the present time on most presses equipped with automatic cleaning systems. However, some printers have made progress in being able to use low-VOC solvents on automatic blanket wash systems, although still with some difficulty. To provide additional time in addressing these difficulties, staff is proposing to temporarily raise the current VOC limit for this cleaning application to 650 grams per liter, as recommended by industry, effective on the date of adoption of PAR 1171. The target VOC limit of 100 grams per liter in 2008 remains the same.
In addition, the printing industry has requested an 18-month extension of the compliance date for the use of the 100 gram per liter clean up solvents on lithographic/letterpress printing, screen printing and UV/EB inks, rather than the 12-month extension originally proposed by staff, based on problems experienced during the transition to the reformulated cleaners meeting the 500 g/l interim VOC limit. This will allow industry sufficient time to work with the new formulations and transition over to the new cleaning materials.
Although better compliant products are now available that minimize many of the printing-related problems, there are remaining concerns that must be dealt with. Upon review of the draft reports recently submitted on the results of the technology assessment for these printing applications, staff has reconsidered its earlier proposal and is now proposing to extend the effective date by 18 months. This extension will allow sufficient time for industry to formulate, test and transition to the new cleaning materials that meet the future VOC limit.
Additional issues were also raised at the June public hearing on PAR 1171. According to representatives from the printing industry, the limited number of cleaners meeting the interim VOC limit of 500 grams per liter for cleaning UV/EB ink application equipment leave residue on rollers and blankets leading to longer cleaning time. In certain cases, these cleaners have also caused early deterioration of press rollers resulting in increased maintenance cost to the printer. Consequently, industry has requested AQMD to raise the interim VOC limit for solvents used in handwipe cleaning of UV ink application equipment including those used for the clean up of EB ink application equipment. In addition, industry requested for an 18-month delay in the implementation of the 100 gram per liter VOC limit for lithographic printing on newsprint to allow adequate time to address the clean up of other press parts such as pipe rollers. Industry also needed clarification on the definition of newsprint as well as facilities that fall under this subcategory.
After several discussions with members of the printing industry, staff has reconsidered its original proposal and agreed to raise the interim VOC limit from 500 to 650 grams per liter for the clean up of UV/EB ink application equipment. This translates to 48 pounds per day of delayed emission reduction. The new proposal expands the number of alternative cleaners that may provide acceptable results to UV/EB printers and at the same time allow industry to focus its efforts in finding cleaners that meet the future VOC limit of 100 gram per liter.
For lithographic printing on newsprint, staff has clarified that the 100 gram per liter VOC limit that takes effect on July 1, 2006 applies to both newspaper and non-newspaper printers that use newsprint as a substrate. Furthermore, staff emphasized that alternative cleaners are successfully being used in lithographic printing on newsprint at newspaper and non-newspaper facilities for cleaning ink application equipment including pipe rollers. Staff has modified the definition of newsprint, as requested by industry.
California Environmental Quality Act (CEQA) Analysis
AQMD staff has reviewed Proposed Amended Rule 1171 pursuant to state CEQA Guidelines §15002 (k)(3) and the AQMD’s Certified Regulatory Program (Rule 110). A Draft Subsequent Environmental Assessment (SEA) was prepared, pursuant to CEQA Guidelines §15252, and circulated for a 45-day public review and comment period from April 5, 2006 to May 19, 2006. The project will result in a delay of VOC emission reductions that will exceed the SCAQMD’s daily significance operational threshold and, thus, adverse air quality impacts have been determined to be significant. No other environmental topic area is considered to have an adverse impact as a result of the proposed project. No public comment letters were received on the Draft SEA,and modifications were made to the Draft SEA so it is now a Final SEA. The primary change to the proposed project since the release of the Draft SEA is the temporary increase of the VOC content limit to 650 grams per liter for ultraviolet ink/electron beam ink application equipment and automatic roller and blanket cleaning systems for 18 months before lowering to 100 grams per liter by January 1, 2008. The potential emission increase from the change in required VOC content limit was analyzed as part of Alternative C in the Draft SEA and, therefore, does not change the conclusions made in the Draft SEA or worsen the environmental impact analyzed in the Draft SEA. Pursuant to CEQA Guidelines §15088.5, recirculation is not necessary since the information provided does not result in new avoidable significant effects.
Socioeconomic Impact Assessment
The proposed amendments to Rule 1171 - Solvent Cleaning Operations will not result in increased costs to the affected industries and, therefore, will have no adverse socioeconomic impacts.
AQMP and Legal Mandates
The California Health and Safety Code requires the AQMD to adopt an Air Quality Management Plan to meet state and federal ambient air quality 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 1999 amendment of Rule 1171 implemented a control measure from the 1997 AQMP (CM#97ADV-CLNG) to meet state and federal requirements. The proposed changes to Rule 1171 delays part of the VOC emission reductions expected from the 1999 rule amendment; however, it would not affect the overall attainment strategy. Rule 1171 is part of the 1999 SIP settlement agreement which requires the Board to make findings of infeasibility when granting exemptions or delays in implementation of the 2006 VOC limits. Appropriate findings are included in the Board Resolution for this item.
Implementation Plan
Staff will continue its outreach efforts on Rule 1171 to inform the affected sources, including solvent suppliers, of the changes to the solvent cleaning regulation.
Resource Impact
Current AQMD resources are sufficient to implement the proposed Rule 1171 amendments with no additional fiscal impact.
Attachments
(EXE 478kb)
Summary of Proposal
Rule Development Process
Key Contacts List
Resolution
Proposed Rule Language
Final Staff Report
Final Subsequent Environmental Assessment