No. 41825 (Change in Proposed Rule): Rule R307-351. Graphic Arts

DAR File No.: 41825
Filed: 10/05/2017 11:36:31 AM

RULE ANALYSIS

Purpose of the rule or reason for the change:

The rule changes are being proposed in response to comments received during the public comment period. The amendments to this rule strengthen the area source coating rules. These amendments will help further reduce Volatile Organic Compound (VOC) emissions and will be part of the upcoming Serious PM2.5 State Implementation Plan (SIP).

Summary of the rule or change:

Several changes were made throughout Rule R307-351 as a result of public comments. These changes include adding a compliance schedule for affected sources, adding a definition for medical device, adding an exemption for medical devices and their packaging, and adding clarifying language throughout the rule. (EDITOR'S NOTE: The original proposed amendment upon which this change in proposed rule (CPR) was based was published in the July 1, 2017, issue of the Utah State Bulletin, on page 132. Underlining in the rule below indicates text that has been added since the publication of the proposed rule mentioned above; strike-out indicates text that has been deleted. You must view the CPR and the proposed amendment together to understand all of the changes that will be enforceable should the agency make this rule effective.)

Statutory or constitutional authorization for this rule:

• Subsection 19-2-104(1)(a)

Anticipated cost or savings to:

the state budget:

There is no cost or savings to the state budget as a result of these changes because the changes do not change the way the rule impacts the state.

local governments:

There is no cost or savings to local governments as a result of these changes because the changes do not affect the way the rule impacts local governments.

small businesses:

The extension of the exemption for medical devices and their packaging may lead to savings for small businesses; however, it is difficult to determine the amount of the savings to be realized. The other changes would not result in additional costs.

persons other than small businesses, businesses, or local governmental entities:

Persons other than small businesses, businesses, or local government entities will not be impacted by these changes because the rule does not apply to them.

Compliance costs for affected persons:

There will be no added compliance costs because of these changes. The changes, the added compliance schedule for affected sources, added definition for medical device, added exemption for medical devices and their packaging, and clarifying language, do not result in additional compliance costs because the requirements of the rule otherwise remain unchanged.

Comments by the department head on the fiscal impact the rule may have on businesses:

The extension of the exemption for medical devices and their packaging may lead to savings for businesses; however, it is difficult to determine the amount of the savings to be realized. The other changes will have no fiscal impact on any businesses because the changes do not modify any of the existing requirements within the rule.

Alan Matheson, Executive Director

The full text of this rule may be inspected, during regular business hours, at the Office of Administrative Rules, or at:

Environmental Quality
Air QualityRoom Fourth Floor
195 N 1950 W
SALT LAKE CITY, UT 84116-3085

Direct questions regarding this rule to:

• Mat Carlile at the above address, by phone at 801-536-4116, by FAX at 801-536-4136, or by Internet E-mail at [e-mail]

Interested persons may present their views on this rule by submitting written comments to the address above no later than 5:00 p.m. on:

This rule may become effective on:

12/01/2017

Authorized by:

Bryce Bird, Director

RULE TEXT

R307. Environmental Quality, Air Quality.

R307-351. Graphic Arts.

R307-351-1. Purpose.

The purpose of R307-351 is to limit volatile organic compound (VOC) emissions from graphic arts printing operations.

 

R307-351-2. Applicability.

[R307-351 applies to graphic arts printing operations that use a combined 450 gallons or more of all VOC-containing materials per year and are located in Box Elder, Cache, Davis, Salt Lake, Utah, Tooele, or Weber counties.](1) R307-351 applies to graphic arts printing operations located in Box Elder, Cache, Davis, Salt Lake, Utah, Tooele and Weber counties.

(2) Before September 1, 2018, R307-351 applies to graphic arts printing operations that emit 2.7 tons or greater per year of VOC emissions.

(3) Effective September 1, 2018, R307-351 shall apply to graphic arts printing operations that use a combined 450 gallons or more of all VOC-containing materials per year.

 

R307-351-3. Exemptions.

(1) The provisions of R307-351 shall not apply to graphic arts materials that have a VOC content of less than 25 g/L , minus water and exempt VOCs, as applied.

(2) A graphic arts printing operation may use up to 55 gallons of cleaning materials per year that do not comply with the VOC composite vapor pressure requirement or the VOC content requirement in R307-351-5(4).

(3) The provisions of R307-351 shall not apply to medical devices and their packaging.

 

R307-351-4. Definitions.

The following additional definitions apply to R307-351:

"Alcohol" means any of the following compounds, when used as a fountain solution additive for offset lithographic printing: ethanol, n-propanol, and isopropanol.

"Alcohol Substitute" means a non-alcohol additive that contains VOCs and is used in the fountain solution.

"Cleaning materials and solutions" means a liquid solvent or solution used to clean the operating surfaces of a printing press and its parts. Cleaning materials and solutions include, but are not limited to blanket wash, roller wash, metering roller cleaner, plate cleaner, impression cylinder washes, rubber rejuvenators, and other cleaners used for cleaning a press, press parts, or to remove dried ink or coating from areas around the press.

"Blanket" means a synthetic rubber material that is wrapped around a cylinder used in offset lithography to transfer or "offset" an image from an image carrier.

"Control system" means the combination of capture and control devices used to reduce emissions to the atmosphere.

"Flexographic printing" means the application of words, designs, and pictures to substrate by means of a roll printing technique in which the pattern to be applied is raised above the printing roll and the image carrier is made of rubber or other elastomeric materials.

"Fountain solution" means a mixture of water and other volatile and non-volatile chemicals and additives that wets the non-image area of a lithographic printing plate so that the ink is maintained within the image areas.

"Graphic arts materials" means any inks, coatings, or adhesives, including added thinners or retarders, used in printing or related coating or laminating processes.

"Graphic arts printing" means the application of words and images using the offset lithographic, letterpress, rotogravure, or flexographic printing process.

"Heatset" means an offset lithographic printing or letterpress printing operation in which the ink solvents are vaporized by passing the printed surface through a dryer.

"Letterpress printing" means a method where the image area is raised relative to the non-image area and the ink is transferred to the substrate directly from the image surface.

"Non-heatset", also called coldset, means an offset lithographic printing or letterpress printing operation in which the ink dries by oxidation and/or absorption into the substrate without use of heat from dryers. For the purposes of this rule, use of an infrared heater or printing conducted using ultraviolet-cured or electron beam-cured inks is considered non-heatset.

"Medical device" means an instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent or other similar article including any component or accessory, that is intended for use in the diagnosis of disease or other conditions or in the cure, mitigation, treatment, or prevention of disease, or is intended to affect the structure or any function of the body. For the purpose of this rule, a medical device shall also include associated manufacturing or assembly apparatus.

"Offset lithographic printing" means a plane-o-graphic method in which the image and non-image areas are on the same plane and the ink is offset from a plate to a rubber blanket, and then from the blanket to the substrate.

"Printing operation" means the application of words, designs, or pictures on a substrate. All units in a machine which have both coating and printing units shall be considered as performing a printing operation.

"Rotogravure printing" means the application of words, designs, and pictures to a substrate by means of a roll printing technique that involves a recessed image area in the form of cells.

"Web" means a continuous roll of substrate.

 

R307-351-5. VOC Content Limits.

(1) No owner or operator shall apply graphic arts materials with a VOC content greater than the amounts specified in Table 1 or Table 2, unless the owner or operator uses an add-on control device as specified in R307-351-6.

 

TABLE 1

VOC Limits
(values in gram of VOC per liter, minus water and
exempt solvents (compounds not classified as VOC as defined in R307-101-2)

 Graphic Art Material                               VOC Limit (g/L) 
 
Adhesive                                                 150 
Coating                                                  300 
Flexographic Fluorescent Ink                              300 
Flexographic Ink-Non-Porous Substrate                     300 
Flexographic Ink-Porous Substrate                         225 
Gravure Ink                                              300 
Letterpress Ink                                          300 
Offset Lithographic Ink                                  300 
Heatset Web Offset Litographic ink                       300 
Heatset Web Offset Lithographic Ink: 
          Used on Book Presses and Presses 
          Less Than 22 Inches in Diameter                400 
 
          Used on Presses With Potential to Emit Less 
          Than 10 Tons/Year                             400

 

(2) No owner or operator shall apply fountain solution, including additives with a VOC content greater than the amounts specified in Table 2, unless the owner or operator uses an add-on control device as specified in R307-351-6.

 

TABLE 2

VOC Limits
(values in gram of VOC per liter, minus water and
exempt solvents (compounds not classified as VOC as defined in R307-101-2), as applied

   
 Graphic Art Material                                     VOC Limit (g/L) 
 
Heatset Web-Fed 
          Alcohol without Refrigerated Chiller                16 
          Alcohol with Refrigerated Chiller                   30 
          Alcohol Substitute                                  50 
Sheet-Fed 
          Alcohol without Refrigerated Chiller                50 
          Alcohol with Refrigerated Chiller                   85 
          Alcohol Substitute                                  50 
Non-Heatset Web-Fed 
          All Alcohol Substitutes                             50

 

(3) Alcohol containing fountain solutions shall not be used in non-heatset web-fed operations.

(4) Cleaning materials with a VOC composite vapor pressure of less than 10 mm Hg at 68 degrees Fahrenheit or cleaning materials containing less than 50 percent VOC by weight shall be used.

 

R307-351-6. Add-on Controls Systems Operations.

(1) If an add-on control system is used, the owner or operator shall install and maintain the add-on emission control system in accordance with the manufacturer recommendations.

(a) Control devices for individual heatset web offset lithographic printing presses and individual heatset web letterpress printing press dryers that were installed prior to January 1, 2017, must maintain a 90% or greater control efficiency. Similar control devices installed after January 1, 2017, must maintain a 95% or greater control efficiency.

(b) Control devices for individual flexographic printing presses and individual rotogravure printing presses shall comply with a 90% or greater overall control efficiency.

(c) As an alternative to the control efficiency, the control device outlet concentration may be reduced to 20 ppmv as hexane on a dry basis to accommodate situations where the inlet VOC concentration is low or there is no identifiable measurable inlet. The control outlet concentration shall be determined using EPA Method 25A.

(d) The capture efficiency of a VOC emission control system's VOC collection device for flexographic and rotogravure presses shall be determined according to EPA's "Guidelines for Determining Capture Efficiency," January 9, 1995 and 40 CFR Part 51, Appendix M, Methods 204-204F, as applicable.

(e) The capture efficiency of a VOC emission control system's VOC collection device for a heatset web offset press shall be determined by demonstrating that the airflow in the dryer is negative to the surrounding pressroom during the initial test using an air flow direction indicator, such as a smoke stick or aluminum ribbons, or differential pressure gauge.

(f) The control efficiency of a VOC emission control system's VOC control device shall be determined using test methods in Appendices A-1, A-6, and A-7 to 40 CFR Part 60, for measuring flow rates, total gaseous organic concentrations, or emissions of exempt compounds, as applicable.

(g) An alternative test method may be substituted for the preceding test methods after review and approval by the EPA Administrator.

 

R307-351-7. Work Practices.

(1) Control techniques and work practices shall be implemented at all times to reduce VOC emissions. Control techniques and work practices include:

(a) Keeping cleaning materials, used shop towels, and solvent wiping cloths in closed containers; and

(b) Minimizing spills of VOC-containing cleaning materials.

 

R307-351-8. Recordkeeping.

(1) The owner or operator shall maintain records of the following:

(a) Records that demonstrate compliance with R307-351. Records must include, but are not limited to, inventory and product data sheets of all graphic arts materials and cleaning solutions subject to R307-351.

(b) If an add-on control device is used, records of key system parameters necessary to ensure compliance with R307-351-6. Key system parameters include, but are not limited to, temperature, pressure, flow rates, and an inspection schedule. Key inspection parameters shall be in accordance with the manufacturer's recommendations, and as required to demonstrate that operations provide continuous emission reduction from the source during all periods that the operations cause emissions from the source.

(2) All records shall be maintained for a minimum of 2 years.

(3) Records shall be made available to the director upon request.

 

KEY: air pollution, graphic arts, VOC, printing operations

Date of Enactment or Last Substantive Amendment: 2017

Authorizing, and Implemented or Interpreted Law: 19-2-104(1)(a)