SAN DIEGO COUNTY AIR POLLUTION CONTROL DISTRICT

RULE 67.16 - GRAPHIC ARTS OPERATIONS
(Effective 10/18/88: Rev. Adopted & Effective 5/15/96)

(a) APPLICABILITY

1. This rule is applicable to all continuous web or single sheet fed graphic arts printing, processing, laminating or drying operations.
   
   
2. Operations subject to this rule shall not be subject to Rule 66.
   
   

(b) EXEMPTIONS

1. The provisions of Sections (d) and (e) of this rule shall not apply to stationary sources which emit less than an average of 15 lbs (6.8 kg) of volatile organic compounds (VOCs) from all graphic arts operations per day of operation for each calendar month. It is the responsibility of any person claiming an exemption pursuant to Subsection (b)(1) to maintain daily or monthly records as specified in Section (f) of this rule necessary to establish average daily emissions and to make this information available to the District upon request. The average daily emission levels shall be determined by recording and taking into account the number of operational days per given month.
   
   
2. The provisions of Sections (d), (e), and (f) of this rule shall not apply to:

   (i) All proofing systems.

   (ii) Manufacture of:

   (A) Solar control window film,

   (B) Heat applied transfer decals,

   (C) Ceramic decals manufactured for firing above 800¡F, or

   (D) Water slide decals.

   (iii) Printing on ceramic or circuit boards.

   (iv) Embossing and foil stamping which do not use materials containing VOC.

   (v) Coating operations subject to Rule 67.5, Paper, Film and Fabric Coating Operations.

   (vi) Development process associated with the preparation of lithographic printing plates.

   (vii) Blanket repair material applied from non-refillable aerosol containers of four ounces or less.

(c) DEFINITIONS (Rev. Effective 5/15/96)

For the purpose of this rule the following definitions shall apply:

1. "Coating" in the graphic arts means a layer of material applied to a substrate in a relatively unbroken film.
2. "Exempt Compound" means the same as defined in Rule 2. (Rev. Effective 5/15/96)
3. "Exterior Marking" means any outdoor sign printed, coated or laminated by any of the graphic arts methods.
4. "Flexographic Printing" means a letterpress method utilizing flexible rubber or other elastomeric plate.
5. "Fountain Solution" means the solution which is applied to the image plate to maintain the hydrophilic properties of the non-image areas.
6. "Graphic Arts" means all screen, gravure, letterpress, flexographic and lithographic printing processes, or related coating, or laminating processes including laboratory or experimental processes and coating of flexible packaging materials for food or health care products.
7. "Graphic Arts Line" means printing application equipment, coating equipment, laminating equipment, flash-off areas, ovens, conveyors or other equipment operating in an uninterrupted series to produce graphic arts using graphic art materials.
8. "Graphic Arts Material" means any inks, coatings, adhesives, fountain solutions, thinners, or retarders used in printing or related coating or laminating processes.
9. "Gravure Printing" means an intaglio process in which the ink is carried in minute etched or engraved wells on a roll or cylinder, with excess ink being removed from the surface by doctor blade.
10. "Lamination" means a process of composing two or more layers of material to form a single multiple layer sheet by using adhesive.
11. "Letterpress Printing" means a method where the image area is raised relative to the non-image area and the ink is transferred to the paper directly from the image surface.
12. "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.
13. "Printing" means any operation that imparts color, design, alphabet or numerals on a substrate.
14. "Printing Ink" means any fluid or viscous composition used in printing, impressing or transferring an image onto a substrate.
    
    
15. "Proofing System" means a system used only to check the quality or print color reproduction and editorial content and includes proof presses and/or off-press proofing lines.
    
    
16. "Publication Gravure" means a gravure printing on paper substrate which is subsequently used to form books, magazines, catalogues, brochures, directories, and newspaper supplements or other printed material.
    
    
17. "Screen Printing" means a process where the printing ink passes through a web or a fabric to which a refined form of stencil has been applied. The stencil openings determine the form and dimensions of imprint.
    
    
18. "Stationary Source" means the same as is defined in Rule 20.1.
    
    
19. "Volatile Organic Compound (VOC)" for the purpose of this rule means any volatile compound containing at least one atom of carbon, excluding methane, carbon monoxide, carbon dioxide, carbonic acid, ammonium carbonate, metallic carbides and carbonates, and exempt compounds which may be emitted to the atmosphere during the application of and/or subsequent drying or curing of graphic arts materials or cleaning materials subject to this rule. VOC content of graphic arts material, except for thinners and cleaning materials, is expressed in grams of VOC per liter of material as applied, minus water and minus exempt compounds. VOC content of thinners and cleaning materials is expressed in grams of VOC per liter of material.
    
    
20. "Web-fed" means an automatic system which supplies substrate from a continuous roll or from an extrusion process.
    
    

(d) STANDARDS

1. Graphic Arts Material
   
   

   A person shall not operate any printing or graphic arts process unless:

   (i) Only graphic arts materials containing less than 300 grams of VOC per liter (2.5 lbs/gal) as applied, less water and exempt compounds are used; and

   (ii) Only fountain solutions containing no more than 15% by volume VOC, as applied, are used.

2. Cleanup of Equipment
   
   

   A person shall not use materials containing VOC's for the cleanup of equipment used in graphic arts operations unless:

   (i) The cleaning solvent has a VOC content of less than 200 grams per liter of material; or

   (ii) The total VOC vapor pressure of the material is 45 mm of Hg at 20¡C or less; or

   (iii) A system is used that totally encloses the component parts being cleaned during the washing, rinsing, and draining processes; or

   (iv) The cleaning solvent is transferred through the application equipment, without exposure to air, into a container which has in place an apparatus or cover which completely covers the container and has no visible holes, breaks, openings or separations between adjoining components of the container or container cover. Containers may be equipped with vents provided such vents are necessary to comply with applicable fire and safety codes.

(e) CONTROL EQUIPMENT

1. In lieu of complying with the provisions of Subsection (d)(1), a person may use an air pollution control system which:
   
   

   (i) Has been installed in accordance with an Authority to Construct; and

   (ii) Includes an emission collection system which captures and transports organic gaseous emissions to an air pollution control device; and

   (iii) Has a combined VOC emissions capture and control device efficiency of at least 85 percent by weight.

2. A person subject to the requirements of this section shall submit to the Air Pollution Control Officer for approval an Operation and Maintenance (O&M) plan for the proposed emission control device and emission collection system. Such plan shall:
   
   

   (i) Identify all key system operating parameters. Key system operating parameters are those necessary to ensure compliance with Subsection (e)(1)(iii), such as temperature, pressure, and/or flow rate.

   (ii) Include proposed inspection schedules, anticipated ongoing maintenance, and proposed recordkeeping practices regarding the key system operating parameters.

3. The Operation and Maintenance plan must be submitted to the Air Pollution Control Officer and receive approval prior to operation of the air pollution control equipment. A person subject to the requirements of this section shall implement the plan on approval of the Air Pollution Control Officer.
   
   

(f) RECORDKEEPING

Any person applying graphic arts materials shall maintain records in accordance with the following requirements:

1. Maintain a current list of graphic arts materials containing VOC's such as inks, adhesives, thinners, retarders, fountain solutions and cleaning materials in use which provides data necessary to evaluate compliance, including, but not limited to:
   
   

   (i) Type of graphic arts material or cleaning material used;

   (ii) Dilution ratio of mixed components;

   (iii) VOC content and/or vapor pressure of each graphic arts material and cleaning material, as applied.

2. Maintain daily or monthly records showing the amount of each graphic arts material used including, but not limited to, inks, adhesives, thinners, retarders, fountain solutions and cleaning solutions.
   
   
3. Any person using control equipment pursuant to Section (e) of this rule shall:
   
   

   (i) For all graphic arts materials not in compliance with Subsection (d)(1) of this rule, maintain daily records of the amount of each material used; and

   (ii) Maintain daily records sufficient to document continuous compliance with Subsection (e)(1)(iii), including records of key system operating parameters as approved in the Operation and Maintenance plan.

   These records shall be retained on site for at least three years and shall be made available to the District upon request.

(g) TEST METHODS

1. Measurements of VOC content subject to Section (d) of this rule shall be conducted and reported in accordance with EPA Test Method 24 (40 CFR 60, Appendix A) as it exists on September 20, 1994, and ASTM Test Method D 4457-85 for determination of dichloromethane and 1,1,1-trichloroethane in paints and coatings by direct injection into a gas chromatograph.
   
   
2. Measurements of VOC content of rotogravure publication inks subject to Section (d) of this rule shall be conducted and reported in accordance with EPA Test Method 24A (40 CFR 60, Appendix A) as it exists on September 20, 1994, and ASTM Test Method D 4457-85 for determination of dichloromethane and 1,1,1,-trichloroethane in paints and coatings by direct injection into a gas chromatograph.
   
   
3. Measurements of VOC emissions subject to Section (e) of this rule shall be conducted in accordance with EPA Methods 18, and 25 or 25A (40 CFR 60, Appendix A) as they exist on September 20, 1994. Test procedures shall be performed in accordance with a protocol approved by the Air Pollution Control Officer.
   
   
4. Measurements of vapor pressures of VOC containing compounds pursuant to Subsection (d)(2)(ii) of this rule shall be calculated using the District's "Procedure for Estimating the Vapor Pressure of a Solvent Mixture," as it exists on September 20, 1994. If the vapor pressure of the liquid mixture is in excess of the limit specified in Subsection (d)(2)(ii), the vapor pressure shall be determined in accordance with ASTM Test Method D 2879-83, "Vapor Pressure-Temperature Relationship and Initial Decomposition Temperature of Liquids by Isoteniscope."
   
   
5. Measurements of VOC content pursuant to Subsection (d)(1)(ii) shall be conducted and reported in accordance with ASTM Standard Recommended Practices for General Gas Chromatography Procedures, E 260-85.
   
   
6. Perfluorocarbon (PFC) compounds and other exempt compounds shall be assumed to be absent from a coating, cleaning, or surface preparation material subject to this rule unless a manufacturer of the material or a facility operator identifies the specific individual compound(s) and the amount(s) present in the material and provides an EPA and ARB approved test method which can be used to quantify the specific compounds.