BOARD MEETING DATE: October 6, 2006
AGENDA NO. 34

PROPOSAL:

Direct the Executive Officer to Implement and Enforce the 100 gram per liter VOC Limit for Lithographic Printing on Newsprint or Amend Rule 1171 Relative to Newsprint

SYNOPSIS:

At the July 14, 2006 meeting, the Board adopted PAR 1171 but directed staff to further evaluate portions of the rule that are applicable to newsprint and exercise enforcement discretion to not enforce the 100 gram per liter limit against newsprint operations in the interim.  Staff has completed its evaluation, and is recommending to proceed with the implementation and enforcement of the 100 gram per liter VOC limit for clean up solvents for ink application equipment used for lithographic printing on newsprint.

COMMITTEE:

Stationary Source, September 22, 2006, Reviewed

RECOMMENDED ACTION:

Direct the Executive Officer to implement and enforce the 100 gram per liter VOC limit for lithographic printing on newsprint.

Barry R. Wallerstein, D.Env.
Executive Officer

Background

At the July 14, 2006 meeting, the Board adopted PAR 1171.  However, in response to concerns expressed by the representative of the Los Angeles Times, the Board directed staff to exercise enforcement discretion in implementing the 100 gram per liter VOC limit already in effect for clean up solvents used in lithographic printing on newsprint until September 8, 2006.  The Board further directed staff to investigate the issue and report its findings to the Stationary Source Committee prior to the Governing Board meeting on September 8, 2006.  Because the Stationary Source Committee was unable to hear the staff recommendation prior to the September 8, 2006 Board meeting, discussion of the item was then continued to the October 6, 2006 Board meeting. 

Key Issue and Staff Evaluation

During the July 14, 2006 Board meeting, the representative of the Los Angeles Times requested a delay in the implementation of the 100 gram per liter solvent VOC limit, until January 1, 2008, for lithographic printing on newsprint.  According to the company, the cleaning materials meeting the 100 gram per liter VOC limit have not been demonstrated to be effective in cleaning certain press components such as pipe rollers, ink rails, and ink trains.  The company is also concerned about potential compatibility problems with the use of low-VOC solvents. 

Staff’s recommendation to implement the 100 grams per liter VOC limit for lithographic printing on newsprint was based on the conclusions from the District-funded technology assessment conducted after the future limit was adopted by this Board in 1999.  During the 2001 design phase for the technology assessment for this rule, the printing industry’s technical research arm, the Graphic Arts Technical Foundation (GATF), concluded that 2005 compliant low-VOC materials were already being used successfully for cleaning by this sector of the lithographic printing industry.  Field studies of these cleaning materials were subsequently verified by the Institute for Research and Technical Assistance (IRTA) and IRTA concluded that cost-effective cleaning materials were available that cleaned well and did not affect print quality.

The non-compliance issue was first raised by the Los Angeles Times in May of this year.  Following the July 14, 2006 Board meeting, staff conducted a field evaluation at the Los Angeles Times facility.  During this field visit, the company acknowledged that it had not conducted any testing of available cleaning materials prior to the July 1, 2006 compliance date and that it needs more time to identify and test compliant products. However, it is important to note that the company has been operating in compliance with the 100 gram per liter limit for more than 5 years by cleaning while the presses are idle.[1]  The non-compliance issue is introduced by the fact that the company wishes to change its method of cleaning to clean pipe rollers while the presses are at a slow speed and with the web (newsprint) in place.  This necessitates finding new formulations.  Staff recommended to the company that by using its current cleaning practices, it can remain in compliance and at the same time test new formulations for an indefinite period of time. 

Staff also visited other newsprint publishing facilities (The Press-Enterprise, The Wall Street Journal, The San Bernardino Sun (teleconference), Freedom Press/Orange County Register and Vertis Publishing Co.) that use the same equipment and inks.  Staff verified that all of these facilities are already complying with the 100 gram per liter VOC limit for cleaning presses with the web (newsprint) in place.  These facilities have been using compliant products for varying periods of time from several months to 3 years for cleaning press components including pipe rollers, ink rails, and ink trains.  None of these facilities have raised compatibility issues with the use of compliant products.  Staff is also aware of one facility (non-newspaper) that prints on newsprint substrates and has been using clean up solvents with VOC content less than 100 grams per liter for more than 3 years.  Staff has provided the Los Angeles Times information on the availability and performance of compliant cleaning materials.

Based on the results of the field visits and further discussions with press component and cleaning material vendors, staff has concluded that products are readily available that meet the 100 gram per liter VOC limit for cleaning on-press components including pipe rollers, ink rails, and ink trains.  In addition, other facilities with similar operations are already using compliant products with no compatibility issues; therefore, the request to delay implementation of the 100 gram per liter is not justifiable.

Staff Recommendation

Staff is recommending that the Board direct the Executive Officer to implement and enforce the 100 gram per liter VOC limit for cleaning relative to lithographic printing on newsprint.  Staff believes that this recommendation is consistent with the results of the field evaluations which reflect current industry cleaning practices as it pertains to lithographic printing on newsprint.

Staff has attached a detailed analysis of the technical issues presented by the Los Angeles Times.

California Environmental Quality Act (CEQA) Analysis

The proposed amendments to Rule 1171 adopted by the Board at its July 14, 2006 meeting were evaluated by AQMD staff in a Draft Subsequent Environmental Assessment (SEA) in accordance with the certified regulatory program (Article 17 of CEQA Guidelines) codified in the AQMD Rule 110.  The Draft SEA was circulated for a 45-day public review and comment period from April 5, 2006 to May 19, 2006.  The Draft SEA considered and evaluated a reasonable range of feasible alternatives in accordance with CEQA Guidelines §15126.6.  The three alternatives in the Draft SEA are viable options to the proposed project and all, or parts, of these alternatives can be chosen by the decision-making body (e.g., SCAQMD Governing Board) to become the proposed project.  Alternative A was the No Project Alternative to the proposed project.  Alternative B would extend the final VOC content limits requirement for two years, July 1, 2008, for lithographic/letterpress, screen printing and UV/EB applications and provide a one-year delay, to July 1, 2007, for newsprint applications.  Alternative C would allow an increase in the current VOC limit from 500 g/l to 650 g/l for lithographic/letterpress, screen printing and UV/EB applications and delay the final compliance date to July 1, 2008.  No public comment letters were received and minor modifications were made to the Draft SEA so it became a Final SEA.  The Final SEA was certified at the July 14, 2006 Governing Board meeting.  Should the Board choose one or a portion of one of the CEQA alternatives, no further environmental analysis would be necessary as the impacts of the project alternatives were previously analyzed and circulated for public review and comment in the Draft SEA.

Attachment
Analysis of Compliance Issues Raised by the Los Angeles Times

ANALYSIS OF COMPLIANCE ISSUES RAISED

 BY THE LOS ANGELES TIMES

A field evaluation was conducted at the Los Angeles Times, Grand Ave. facility on July 24, 2006.  The newspaper allowed their press operators to perform initial testing of two compliant formulations currently in use by other newspapers in the industry.  This testing and a meeting with environmental staff of the newspaper on that day provided staff with a better understanding of their cleaning process and any specific cleaning needs.  Staff followed with similar field visits to four other newspaper and news insert printing facilities that are already compliant with the limit of 100 grams per liter.  Staff has concluded that the company can comply with the limit of 100 grams per liter and staff has offered to work with the company to identify formulations and provide other technical support in this effort.

The following presents staff’s technical conclusions/responses with respect to the listed technical issues surrounding the request of the Los Angeles Times that printers printing on newsprint be granted an extension of time for meeting the 100 grams per liter limit found in Rule 1171, Solvent Cleaning Operations.

There are no technical distinctions between that of printing on newsprint versus other paper substrates.  This type of printing has the same long-term compatibility concerns as commercial printers.

Staff disagrees with this assumption.  There are two technical distinctions that have made the cleaning of newspaper ink application equipment easier since compliant formulations first became available for use in newspaper printing several years ago.  First, the definition of “clean” is less precise because the quality of the printed material is less demanding than that of other lithographic printing.  Second, the inks are less viscous and are of a non-drying nature.  These characteristics make them easier to clean. 

The district’s contractors, the Graphic Arts Technical Foundation (GATF) and IRTA agreed following their own testing that benchmark material for coldset web offset printing on newsprint and coldset web offset printing on uncoated paper already met the 100 g/l target limit.  Furthermore, these conclusions were discussed at the working group meetings on PAR 1171 several years ago and confirmed at the recent September 21, 2006 technical meeting, at which the contractors also agreed that these cleaners were already technically and economically feasible for the newsprint sector of lithographic printing. 

Of unique additional concern to newspapers is the cleaning of pipe rollers, a solvent application where there is only one reference in the District’s study.  IRTA could not find compliant formulations (for these rollers) when they tested at our Chatsworth facility in 2001.  Water-based formulations do not work because they destroy the web that is in place at the pipe rollers.  Furthermore, ink rails were not tested by IRTA.

IRTA tested pipe rollers at 2 locations: (1) at a local newspaper insert printing facility and (2) at the San Bernardino Sun printing facility.  As detailed in the IRTA test report, in each case, because water-based cleaners dissolve the web, the contractor successfully tested a soy-based cleaner on pipe rollers and ink trays.

While it is true that IRTA did not specifically test ink rails, the contractor and our staff have found other newsprint printing facilities which successfully clean the rails with compliant materials.  One of these materials appeared to clean the rails during initial testing on July 24.  Since the ink rail surfaces are made of the same materials as the ink trays, no problems should be anticipated.

Other newspapers in this area are experiencing difficulties, such as the Wall Street Journal.

Staff has observed compliant cleaning materials in use at the printing facilities for the Riverside Press Enterprise, the Wall Street Journal, the Orange County Register and at a newspaper insert publisher, Vertis.  Staff held a teleconference with the San Bernardino Sun.  In each case, facility representatives have all indicated that these materials are compatible with their processes and that any problems were overcome with further testing or minor process adjustments.

The sheer size of our presses, about three stories high, compound the cleaning challenges.  Also, there are”catastrophic failure” reports from users that the cleaning materials leave residues and cause permanent swelling of the rubber compromising blankets and ink rollers.

Staff has specifically asked newsprint printers if they have experienced these failures and all have emphatically stated that they have not.  One report of a catastrophic failure has been claimed at one commercial printing facility but there is no evidence that this is caused by low-VOC solvent cleaning materials.  This issue is not at all related to newsprint printing.

We should have the same extension of time, 18 months,  that was granted to the rest of the industry to resolve their outstanding issues.  We cannot begin to test formulations because it will take at least 6 months for initial compatibility testing to be completed.

Staff cannot support this request.  First, it is our understanding that the company is currently using compliant blanket cleaning materials and is satisfied with these cleaners such that the company has withdrawn its request for an extension of time for blanket cleaning.  The company’s remaining concerns are now limited to cleaning rollers, ink trays and ink rails.

Second, in recent field visits to newspaper printers, staff found two facilities that actually converted to the available 100 g/l cleaning materials after only a 3 week testing period just prior to the July 1, 2006 deadline in the proposed rule.  The facilities have no compatibility issues and are comfortable with the performance of these materials.  The roller manufacturers have indicated to us that they have no concerns for compatibility since other newsprint printers have used these materials extensively over longer periods of time without problems.

The LA Times representative indicated at our recent meeting on July 24, 2006 and at the Stationary Source Committee meeting on September 22, 2006 that the rush of his schedule in the last 6 months overwhelmed his time that should have been devoted to tracking the proposed amendment.  Staff informed him that AQMD is more than willing to assist him in making up for that time.

One suggestion we have is that the company continue its current practice of cleaning the pipe rollers during periods when the presses are idle and the web is “out.”  This allows the company to continue using a water-based, compliant blanket cleaner on the rollers without breaking the web.  The company can test compliant materials and remain in compliance until the testing program is complete.

For on-press components including pipe rollers, the following is a list of compliant products that are currently being used for such applications.  We provided this list to the company and urged their representative, Mr. Mark Anderson, to investigate and test them as soon as possible.  These materials are: C & W Autowash 142-11, Pressroom Solution Low-VOC Wash 6502 and Anchor/Lithkemko’s Autowash XP.

Staff has concluded that the company can be in compliance by October 6, 2006 for the following primary reasons:

1. The company has been operating in compliance for more than 5 years by cleaning with the web out while the presses are idle, using a water-based formulation;
2. On-press parts such as pipe rollers, blankets and other rollers have all been successfully cleaning at similar publishing operations for periods of time sufficient with no reported compatibility problems; and
3. All other newspaper printers are currently in compliance with the 100 g/l VOC limit in the rule.

Staff has offered assistance to this company in finding compliant products.

[1] In 2003, The Los Angeles Times received one of the U.S. Environmental Protection Agency’s “44 Western Environmental Heroes” awards for innovative use of alternative, lower toxicity cleaners than the cleaning agents used by other lithographic printers.  In granting the award, EPA stated that “(the company) demonstrated that alternative cleanup solvents can be used effectively on a daily basis and that their use reduces emissions of toxics and volatile organic compounds, worker exposure, hazardous waste generation and wastewater discharges.”