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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX AIR DIVISION




Technical Support Document 
for
EPA's Rulemaking
for the
California State Implementation Plan

Yolo-Solano Air Quality Management District Rule 2.29 
Graphic Arts Printing Operations 




                              
Prepared by: Shaye Hong
Reviewed by: Doris Lo 

January 2021





RULE IDENTIFICATION 
Agency
Yolo-Solano Air Quality Management District 

SIP Approved Rule
Rule 2.29  -  Graphic Arts Printing Operations
Adopted  -  May 25, 1994
Submitted  -  November 30, 1994
EPA Approved  -  August 21, 1998 (63 FR 44792)

Subject of this TSD
Rule 2.29  -  Graphic Arts Printing Operations 
Amended - July 11, 2018
Submitted  -  August 20, 2018

Completeness Finding
Determination of Completeness Letter: August 23,2018


BACKGROUND 

The Yolo-Solano Air Quality Management District (YSAQMD) regulates a portion of the Sacramento Metropolitan Air Basin, which is designated and classified as a "Severe" nonattainment area for the 2008 8-hour National Ambient Air Quality Standards (NAAQS)  and "Moderate" for 2015 8-hr ozone NAAQS (see 40 CFR section 81.305). For ozone nonattainment areas classified as Moderate or above, the Clean Air Act (CAA) requires that the State submit State Implementation Plan (SIP) provisions to require implementation of reasonably available control technology (RACT) (see CAA 182(b)(2) and 182(f)).  
Rule 2.29 was approved into the SIP on August 20, 1998 (63 FR 44792). Minor amendments were made and submitted to CARB in 1997 and 2008. These revisions were not submitted to the EPA. On February 3, 2017, the EPA published a Finding of Failure to Submit (82 FR 9158) because the YSAQMD had not submitted a RACT SIP for the 2008 Ozone NAAQS demonstrating RACT for various Control Techniques Guidelines (CTG) categories including the graphic arts categories.  EPA Region 9 provided comments to the YSAQMD on June 23, 2014, to address the Control Technique Guidelines for Offset Lithographic Printing and Letterpress Printing (EPA-453/R-06-003). Comments were also provided on May 22, 2018, to update requirements for fountain solution storage to meet the CTG and record keeping time to be consistent with Title V standards. This rule submittal revises fountain solution VOC limits to meet the CTG, fountain solution storage temperature to meet the CTG, and record keeping time to be consistent with Title V standards.

RULE SUMMARY 

The purpose of Rule 2.29 is to reduce VOC emissions from graphic arts operations. This includes but is not limited to the prepress and press operations, and the cleaning materials and processes associated with any digital, screen, gravure, letterpress, flexographic and lithographic printing process, including any related coating and laminating processes. Rule 2.29 establishes VOC content limits and workplace standards. It also describes related recordkeeping, reporting, and monitoring requirements. Rule 2.29 does not apply to digital printing operations, aerosol adhesives, or stripping of cured coatings, adhesives, or inks. 

Before YSAQMD's amendments in July 2018, there were about a dozen facilities operating under a permit for graphic arts printing operations within Yolo-Solano.

Changes from the approved SIP rule include:

Section 100 
102  -  Added applicability section which specifies that the rule applies to all graphic arts operations or any person who sells or distributes graphic arts materials. 
110 - Amended small-user exemption to exempt facilities permitted to emit less than 1,200 lbs VOC per calendar quarter. Previously, the exemption exempted facilities that emitted less than 400 lbs of VOC in any month.
111-113  -  Removed exemption for laboratory and experimental operations. Added exemptions for digital printing, aerosol adhesives, and stripping or cured coatings, adhesives, and inks.
            
Section 200 
Added definitions for Aerosol Adhesive, Digital Printer, Digital Printing Operations, Electrophotography, Emission Control System, Exempt Compounds, Ink Jet, Ionography, Magnetography, Pantone Inks, Resists, Surface Preparation, Volatile Organic Compound (VOC) Content, and Thermography.
Amended definitions for VOC which now refers to definitions as described in Rule 1.1 Provisions and Definitions instead of listing out all exempt compounds. 
            
Section 300
301 Combined flexographic, gravure, letterpress, and lithographic requirements into one set of standards. 
302 - Lowered VOC content limit for fountain solutions to 100g/L to meet CTG requirements and added VOC limit for resists.
303  -  Increased required overall capture and control efficiency from 75% on a mass basis to 95% by weight.
304 - Added "Storage and Disposal- General" to replace the former section 305.3 and now requires that containers be non-adsorbent and non-leaking in addition to being closed at all times except while in use.
305 - Changed "Solvent Evaporative Loss Minimization" section to "Requirements for Surface Preparation and Cleanup materials" which refers to SIP approved Rule 2.31 Surface Preparation and Clean Up containing more stringent and specific requirements for solvents used for surface preparation and cleanup. 
306  -  Added prohibition of sale section which prohibits the supply, sale, solicit, or offer of any material for use in graphic arts operations that does not comply with the standards in section 300 of this rule.  
            
Section 400
         Added prohibition of specification section to state that a person shall not specify the use of inks, coatings, adhesives, or fountain solutions in graphic arts operations that do not meet the requirements of this rule. Requirements of this section applies to all written and oral contracts.
         
Section 500
501.1 - Expanded to specifically list out record keeping requirements including material name and manufacturer, application method, coating category and mix ratio, and actual VOC content and regulatory VOC content.
503 - Changed requirement for records to be maintained from 2 years to 5 years
            
Section 600
603 - "VOC Content-UV Inks" updated to call out specific method (test method D5403-93 (2013)
604 - "Exempt Compounds" updated from ASTM D4457-85 to ASTM D4457-02 (2008)
609 "Metal Content" updated from South Coast Air Quality Management District's Spectrographic Method 311 to South Coast Air Quality Management District's Method 318-95 Determination of Weight Percent Elemental Metal in Coating by X-Ray Diffraction
EVALUATION CRITERIA  -  The following criteria were used to evaluate the submitted rule. 

1.Enforceability  -  CAA §110(a)(2)(A) requires SIPs to "include enforceable emission limitations and other control measures, means, or techniques . . .  as may be necessary or appropriate to meet the applicable requirements of [the CAA]." In addition, CAA §172(c)(6) requires that nonattainment area SIPs "include enforceable emission limitations, and such other control measures means or techniques . . . as well as schedules and timetables for compliance, as may be necessary or appropriate to provide for attainment of such standard in such area by the applicable attainment date . . . ." The Bluebook (Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, EPA, May 25, 1988) and the Little Bluebook (Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate compliance with the CAA §110(a)(2)(A) requirement for enforceability. 

2.Stringency  -  SIPs must require RACT for each category of sources covered by a
      Control Technique Guideline (CTG) document as well as each major source of NOx or VOCs in ozone nonattainment areas classified as Moderate or above (see sections 182(b)(2) and 182(f)). EPA's CTGs titled, "Control of Volatile Organic Emissions from Existing Stationary Sources- Volume VIII: Graphic Arts Rotogravure and Flexography" (EPA-450/2-78-033, December 1978), "Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing" (EPA 453/R-06-002, September 2006), and other state and local rules for this category were used to help evaluate the rule for compliance with the RACT requirements of CAA §182(b)(2) and §182(f).
      
      3.SIP Revisions  -  CAA §110(l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirement concerning attainment or reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA §193 prohibits the modification of any SIP-approved control requirement in effect before November 15, 1990, in a nonattainment area, unless the modification ensures equivalent or greater emission reductions of the relevant pollutant(s).
      
EPA EVALUATION  -  A summary of our evaluation of the three criteria follows.

      1. Enforceability  -  To help ensure enforceability, the rule requirements and applicability are clear, and the monitoring, recordkeeping, reporting and other provisions sufficiently ensure that affected sources and regulators can consistently evaluate and determine compliance with Rule 2.29.
      
      Section 100 of this rule clearly states the requirements for smaller use exemption. Definitions added to section 200 of this rule help to clarify what is considered graphic arts operations as well which operations and are exempt.  The updated standards and added tables in section 300 specify VOC content standards for graphic arts and screen-printing operations related products and material types. Minor updates to test methods referenced in section 600 include appropriate monitoring and test methods. The rule revisions do not negatively impact the enforceability of the rule, thus, the rule remains enforceable.  

      2. Stringency  -  The submitted rule is as stringent as EPA's 1997 and 2006 CTGs: "Control Technique Guidelines for Offset Lithographic Printing and Letterpress Printing" and "Control of Volatile Organic Emissions from Existing Stationary Sources  -  Volume VII: Graphic Arts-Rotogravure and Flexography." 
      
      In addition, rule comparison was performed against the following:
Maricopa Air Quality Department Rule 337, "Graphic Arts," revised August 17, 2011
Placer County Air Quality Management District Rule 239, "Graphic Arts Operations," amended October 11, 2012
Sacramento Metropolitan Air Quality Management District Rule 450, "Graphic Arts," amended August 23, 2008
South Coast Air Quality Management District Rule 1130, "Graphic Arts," amended May 2, 2014
            
      We found YSAQMD Rule 2.29 is equally stringent. As a result, we propose to determine that this rule fulfills RACT requirements. 
      
      3. SIP Revisions  -  We propose to determine that our approval of the submittal would comply with CAA §§110(l) and 193 because (1) the proposed SIP revision would not interfere with any CAA requirements, including requirements for RFP and attainment of the NAAQS, and (2) the emission limits in the submitted rule are more stringent than the existing SIP-approved control requirements that they would replace.


ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION  -  The following revisions are not currently the basis for rule disapproval but are recommended for the next time the rule is amended. 

Correct the typographical error in section 209 to say "Electrophotography" instead of "Electophotography." 
Section 501.1 refers to actual VOC content and regulatory VOC content. Add definitions for actual VOC and regulatory VOC content to distinguish between the two.

EPA ACTION - The submitted Rule 2.29 strengthens the SIP, and YSAQMD did not associate any VOC emission reductions with the rule revision. The rule meets the relevant CAA § 110 and part D requirements. Therefore, EPA staff recommends approval of Rule 2.29 pursuant to CAA §§ 110(k)(3) and 301(a). 

REFERENCES  

"Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations," (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.
"Guidance Document for Correcting Common VOC & Other Rule Deficiencies," (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.
"Control of Volatile Organic Emissions from Solvent Metal Cleaning," EPA-450/2-77-022, November 1977. 
Control Techniques Guidelines for Flexible Package Printing," EPA 453/R-06-003, September 2006. 
"Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing." EPA 453/R-06-002, September 2006.
"Control of Volatile Organic Emissions from Existing Stationary Sources- Volume VIII: Graphic Arts-Rotogravure and Flexography," EPA-450/2-78-033, December 1, 1978.
YSAQMD Proposed Amendments to Rule 2.29 Final Staff Report, July 2, 2018.
Maricopa Air Quality Department Rule 337, "Graphic Arts", revised August 17, 2011, SIP approved February 9, 1998 (63 FR 6489).
South Coast Air Quality Management District Rule 1130, "Graphic Arts", amended May 2, 2014 and approved into the SIP July 14, 2015 (80 FR 40915).
Placer County Air Quality Management District Rule 239, "Graphic Arts Operations", amended October 11, 2012, SIP approved March 14, 2013 (79 FR 14178).
Sacramento Metropolitan Air Pollution Control District Rule 450, "Graphic Arts", amended August 23, 2008, SIP approved April 9, 2010 (75 FR 18068).

