BOARD MEETING DATE: February 1, 2008
AGENDA NO. 34
PROPOSAL:
Amend Rule 1171 – Solvent Cleaning Operations
SYNOPSIS:
The proposed amendment will delay by one year the compliance date for the use of low-VOC solvents for cleaning of ultraviolet or electron beam inks from lithographic printing ink application equipment, for the cleanup of on-press screens and screen reclamation using automatic cleaning equipment in screen printing. Additional time is needed for industry to develop more compliant materials and conduct further tests in the production environment. PAR 1171 expands the rule’s applicability and proposes new requirements for solvent suppliers. Clarifying rule language and removal of outdated rule provisions are also being proposed.
COMMITTEE:
Stationary Source, November 16, 2007 and January 18, 2008, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
1. Certifying the CEQA Final Subsequent Environmental Assessment for the proposed amendments.
2. Amending Rule 1171 – Solvent Cleaning Operations.
Barry R. Wallerstein, D.Env.
Executive Officer
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. Past amendments to this rule have achieved VOC emission reductions of more than 30 tons per day through greater use of aqueous cleaning technologies, VOC-exempt solvents, and the development of new low-VOC cleaning materials. The last two amendments to Rule 1171 in May 2005 and July 2006 extended the compliance date for the use of 100 gram per liter formulations for the cleanup of ink application equipment used in lithographic and screen printing. The original compliance date for the 100 gram per liter VOC limit was July 1, 2005, as established during the 1999 rule amendment. The additional time allowed the printing industry and solvent formulators to evaluate the results of the District-funded technology assessments conducted to support the 100 gram per liter VOC limit, develop and further test new formulations, and transition to the new cleaning materials. The industry has been largely successful in this effort.
During the past 18 months, the printing industry, solvent formulators, and the AQMD have been working together to further develop and test compliant solvent formulations in the actual production environment. Test results have indicated success in the performance of low-VOC cleaning materials for most cleaning applications in lithographic and screen printing. The exceptions are: (1) lithographic ultraviolet/electron beam (UV/EB) ink application equipment, and (2) cleanup of on-press screens and screen reclamation using automatic cleaning equipment. Industry believes that more time is needed to find suitable compliant formulations for these specific cleaning applications.
Consequently, industry requested the AQMD to delay the compliance date for the use of 100 gram per liter cleaning materials for UV/EB ink application equipment, and for cleanup of specific cleaning applications in screen printing. The additional time will allow industry to conduct further tests of compliant cleaning materials.
Proposal
First, staff is proposing to delay by one year the implementation of the 100 gram per liter VOC limit for the following specific solvent cleaning activities:
- Cleanup of lithographic ink application equipment using UV/EB inks; and
- Cleanup of on-press screens and screen reclamation using automatic cleaning equipment in screen printing.
Staff’s proposal supports the printing industry’s position that additional time is needed to fully develop compliant cleaning materials. For the same reason, staff is also proposing to extend by one year the limited exemption for the cleaning of metering rollers, dampening rollers and printing plates in lithographic UV/EB ink application equipment, including the cleaning of UV/EB lamps and reflectors.
Second, in an effort to improve compliance in the field and to assist solvent users in understanding how to comply with the rule, staff is also proposing to expand the rule applicability to include solvent suppliers. Newly proposed amendments to Rule 1171 that affect solvent suppliers as well as operators are as follows:
- Add clarifying language for solvent supplier, full service solvent provider, on-press screen cleaning, screen reclamation, and removable press component;
- Include new recordkeeping requirements for solvent suppliers;
- Require operators to maintain, and for solvent suppliers to provide, correct written instructions if dilution is necessary to meet applicable VOC limits;
- Add labeling requirements for solvent cleaning materials pursuant to Rule 443.1 – Labeling of Materials Containing Organic Solvents; and
- Add rule language prohibiting full service solvent providers from aiding, abetting or assisting a solvent cleaning operation to use a supplied solvent in a non-compliant manner.
Finally, staff has removed outdated rule requirements pertaining to technology assessments and the limited exemption for UV/EB adhesive application equipment.
PAR 1171 will delay by one year the emission reduction of 0.21 tons per day of VOC expected in 2008 from UV/EB ink application equipment, on-press screen cleaning and screen reclamation using automatic cleaning equipment in screen printing. This emission reduction represents the remainder of the Tier II reductions of 9 tons per day originally projected in 1999.
Industry has committed to work closely with staff and to provide detailed progress reports on the testing program. Staff in turn, will provide quarterly progress reports to the Stationary Source Committee with results and findings.
It is important to note that a major milestone has been achieved by the industry. For cleanup of lithographic ink application equipment using conventional inks and screen reclamation (manual) in screen printing, the VOC limit of 100 grams per liter takes effect beginning January 1, 2008 as currently required in Rule 1171. The expected VOC emission reduction from these cleaning applications is 2.30 tons per day beginning year 2008. This achievement is commendable and represents a truly cooperative and focused approach by the affected industry as a whole.
Key Issues
One of the issues raised pertains to the definition of solvent supplier. Industry needed clarification on the applicability of the new rule requirements for solvent suppliers to home improvement retailers or hardware stores and to solvent suppliers located outside the AQMD or California. Staff has modified the solvent supplier definition to clarify that these retailers would fall under the rule if such retailers sell and deliver or arrange to deliver solvent cleaning materials to a solvent cleaning operation in the District. The staff report also contains language to clarify rule intent.
Secondly, staff’s earlier proposed amendment to Rule 1171 included a requirement that solvent suppliers maintain a file of dilution instructions provided to their customers for every product delivery to better ensure compliance with the VOC limits “as applied” by the users. Staff agreed with industry concerns that this requirement is too onerous and has redesigned the requirements to assign responsibility both to the operators to keep a copy of the correct dilution instructions and to solvent suppliers to provide these written instructions upon customer request. The staff report lists various ways for making the dilution instructions available to the user including the solvent supplier’s website.
The last issue pertains to the solvent suppliers’ request for adequate lead time to comply with the recordkeeping and written dilution instruction requirements. Staff is proposing an implementation date of July 1, 2008 for these provisions of the rule.
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 (EA) was prepared, pursuant to CEQA Guidelines §15162 and §15252 because the proposed project constitutes a modification of a previously approved project that was analyzed in a Final EA that was certified by the AQMD Governing Board in October 1999. The Draft Subsequent EA was circulated for a 45-day public review and comment period from November 21, 2007 to January 4, 2008. 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. One public comment letter was received on the Draft Subsequent EA, and responses to the comment letter can be found in the Final Subsequent EA. Minor modifications were made to the Draft Subsequent EA so it is now a Final Subsequent EA. Changes to the project description are minor and do not change the conclusions made in the Draft Subsequent EA or increase the environmental impact analyzed in the Draft Subsequent EA. Pursuant to CEQA Guidelines §15073.5(c)(2), 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 delay part of the VOC emission reductions expected from the 1999 rule amendment; however, this would not affect the overall attainment strategy.
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. In addition, enforcement discretion will be exercised beginning January 1, 2008 for the affected cleaning applications until the Board takes action on the proposed rule amendments.
Resource Impact
Current AQMD resources are sufficient to implement the proposed Rule 1171 amendments with no additional fiscal impact.
Attachments (EXE 1567 kb)
- Summary of Proposal
- Rule Development Process
- Key Contacts List
- Resolution and Attachment to the Resolution
- Proposed Rule Language
- Final Staff Report
- Final Subsequent Environmental Assessment