BOARD MEETING DATE: March 7, 2008
AGENDA NO. 36

PROPOSAL:

Amend Rule 1125 – Metal Container, Closure, and Coil Coating Operations

SYNOPSIS: 

The proposed amendments reduce the allowable VOC content for food and beverage can end sealing compounds, and sets new limits on a grams of VOC per liter of material basis for inkjet inks and make-up solvents.

COMMITTEE: 

Stationary Source, February 15, 2008, Reviewed

RECOMMENDED ACTION:

Adopt the attached resolution:

1. Certifying the Environmental Assessment for the proposed amendments to Rule 1125 – Metal Container, Closure, and Coil Coating Operations;
2. Amending Rule 1125 – Metal Container, Closure, and Coil Coating Operations.
    

Barry R. Wallerstein, D.Env.
Executive Officer

Background

Rule 1125, as adopted in 1979 and revised in 1995, controls VOC emissions resulting from the application of coatings, end sealing compounds, lubricants, and inks used to manufacture and decorate metal containers, closures, and coils. The technology assessment conducted in 2005 by staff did not identify any potential for further emission reductions from this source category, but did point out that inkjet printing was inadequately addressed within the current rule. Reevaluation of this source category as part of this rule making effort, however revealed the potential for further emission reductions from food and beverage can-related end sealing compounds. This proposed amendment will implement, in part, control measure MCS-07 of the 2007 Air Quality Management Plan (AQMP) resulting in an estimated 0.3 ton per day reduction in VOC emissions.

Proposal

Staff proposes to establish VOC limits for inkjet ink and makeup solvent on a material basis as follows:

• Inkjet Ink – 250 grams per liter
• Thermochromic Inkjet Ink – 700 grams per liter
• General Make-Up Solvent – 250 grams per liter
• Thermochromic Inkjet Make-Up Solvent – 800 grams per liter

These limits are based on the available low-VOC technology for this type of printing. The inks and make-up solvents for the specialized printing process cannot be successfully formulated to the VOC limit for inks currently in Rule 1125. The low-volume usage of inkjet inks and make-up solvents will result in a 3 pound per day District-wide VOC emission reduction foregone.

Staff also proposes to reduce the allowable VOC content for food and beverage can related end sealing compounds to an achieved in practice level of 20 grams of VOC per liter from 440 grams of VOC per liter. In addition, staff has added definitions and clarifying language. The amendments will result in emission reductions estimated at 0.3 ton per day of VOC.

AQMP and Legal Mandates

The California Health and Safety Code requires the AQMD to adopt an Air Quality Management Plan (AQMP) to meet state and federal ambient air quality standards with the South Coast Air Basin. In addition, California Health and Safety Code requires the AQMD to adopt rules and regulations that carry out the objectives of the AQMP

California Environmental Quality Act

Staff has reviewed the proposed amendments to Rule 1125 – Metal Container, Closure and Coil Coating Operations. Pursuant to the California Environmental Quality Act (CEQA) and AQMD Rule 110, an Environmental Assessment (EA) is prepared for proposed amended Rule 1125 and has been circulated for a thirty-day public review period. Responses to any comments on the Draft EA have been prepared and incorporated into the EA.

Socioeconomic Impact

The proposed inkjet/inkdot and make-up solvent limits allow use of current inkjet technology for their users, thereby resulting in no change to existing operations. There would be no additional costs associated with complying with a lower VOC limit for end sealing compounds since the lower limit codifies the existing practice. Overall, the proposed amendments would result in no costs to the affected facilities.

Resource Impacts

The proposed amendments can be addressed with existing resources.

Attachments (exe 1.2mb)

1. Summary of Proposed Amendments
2. Rule Development Process
3. Key Contacts List
4. Resolution
5. Rule Language
6. Final Staff Report
7. Environmental Assessment