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, 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
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.
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 (i.e., newspaper), staff will
implement the 100 gram per liter VOC limit for roller wash, blanket wash,
and on-press components beginning July 1, 2006. Many newspaper facilities
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.
Other proposed amendments to Rule 1171 are as follows:
Ø Add a definition for newsprint to clarify rule intent;
Ø Establish a new completion date for the technology assessment;
Ø Clarify the exemption for aerosol products; and
Ø 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.
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 §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 Subsequent EA, and 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 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 474
KB)
Summary of Proposal
Rule Development Process
Key Contacts List
Resolution
Proposed Rule Language
Final Staff Report
Final Subsequent Environmental Assessment
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