ATTACHMENT E

E

- 1 AIR POLLUTION CONTROL DISTRICT

COUNTY OF SAN DIEGO

PROPOSED AMENDMENTS TO RULE 6 7

. 16

– GRAPHIC ARTS OPERATIONS AND RELATED CHANGES TO

RULE 11

– EXEMPTIONS FROM RULE 10 PERMIT REQUIREMENTS



### WORKSHOP REPORT

A workshop notice was mailed to facilities con ducting graphic arts operations

, and

manufacturers , suppliers, and distributors of printing inks and other graphic arts materials in San Diego County that may be subject to proposed amended Rule 67.16

– Graphic Arts Operations

. The corresponding proposed revisions to Rule 11

– Exemptions from Rule 10 Permit Requirements

, were also mailed to the entities mentioned above . Notices were also mailed to the U.S. Environmental Protection Agency (EPA), the California Air Resources Board (ARB), all

Economic Develo pment Corporations and Chambers of Commerce in San Diego County , and other interested parties.

The workshop was held on January 13, 2011 , and was attended by 1 1 people. Writ ten comments
were also received after the workshop. The workshop comments and Sa n Diego County Air Pollution Control ( District ) responses are as follows:

Rule 67.16

– Graphic Arts Operations

1. WRITTEN COMMENT

Proposed amended Rule 67.16 should include an exemption for the cleaning of UV lamps and reflectors or electron beam pro cessors. The lamps and reflectors are extremely sensitive and require special cleaning materials.

DISTRICT RESPONSE

The District agrees. T he proposed amended rule has been revised as suggested

.

2. WRITTEN COMMENT

An exemption should be provided fo r cleaning materials used for the stripping of cured inks, coatings and adhesives.

DISTRICT RESPONSE

The District agrees. The proposed amended rule has been revised as suggested

.Wor kshop Report

Rules 67.16 & 11

E

- 2 3. WRITTEN COMMENT

The d efinition of " digital printing operation " sho uld list specific technologies that are presently

used in the digital printing industry.

DISTRICT RESPONSE

The District disagrees. The term “digital printing operation” is broadly defined to encompass all digital printing technologies that exist now or could exist in the future.

4. WRITTEN COMMEN T

Screen printing inks with a volatile organic compound ( VOC ) content limit of 450 g rams /liter (g/l) should be included in the proposed rule as a separate ink category.

DISTRICT RESPONSE

A screen printin g ink category is not warranted at this time. According to District information there are no screen printing facilities in San Diego County that have VOC emissions exceeding

the permit exemption threshold of Rule 11 (less than 15 lbs per day)

, which is th e same as an applicability threshold of Rule 67.16. The District intends to amend Rule 11 in the near future and require smaller size facilities to obtain permits to operate. This will provide necessary information regarding the magnitude of VOC emission s from screen printing operations in the

county.

5. WRITTEN COMMENT

Rule 67.16 should have a separate category for adhesives used in graphic arts industry.

DISTRICT RESPONSE

The District agrees. The proposed amended rule has been revised to esta blish a VOC content

limit of 150 grams/liter for adhesives , which is consistent with requirements of several California

air districts

.

6. WRITTEN COMMENT

The VOC content limit for fountain solutions should be 80 g/l . The rule also should include a

se parate VOC content limit of 100 g/l if a refrigerated chiller is used.Wor kshop Report

Rules 67.16 & 11

E

- 3 DISTRICT RESPONSE

The proposed VOC content limits for fountain solutions have been revised to more fully align

with EPA's Control Techniques Guidelines ( CTG ) for lithographic and le tterpress printing

. Specifically, the District proposes allowing fountain solutions containing up to 5% VOC by

volume ( alcohol s or alcohol substitute s ) or up to 8.5% VOC ( alcohol or alcohol substitute )

, provided the fountain solution is refr igerated to be low 60 o F (15.5 o C). These percentage limits equate to approximately 50 g/l and 85 g/l , respectively

.

7

. WRITTEN COMMENT

Rule 67.16 should include an exemption for digital printing equipment used in research and development operations.

DISTRICT RESPON SE

The District agrees that research and development operations should be exempt and has revised the proposed amended rule accordingly

. This exemption includes both conventional and digital graphic arts operations conducted for purposes of research and d evelopment

. The definition of research and development is provided in existing District Rule 11.

8

. WRITTEN COMMENT

Rule 67.16 should include an exemption for materials used for cleaning of precision electro

optical components used in digital printin g operations

.

DISTRICT RESPONSE

The District agrees. The proposed amended rule has been revised to include a definition of preci sion electro

- optical components and an exemption for materials used to clean them

.

9. WRITTEN COMMENT

The definition of a " large d igital printing op eration " needs clarification. This definition should

state that the specified print capacity threshold s appl y to each individual printer, not to the entire operation.

DISTRICT RESPONSE

The District agrees and has revised the definition accordingly. Specifically, a "large digital

p rinting o peration " is defined as a n operation where the print capacity of any individual printer using solvent

- based inks is 1,000 ft 2 /hr or higher; or an operation where the print capacity of anyWor kshop Report

Rules 67.16 & 11

E

- 4 in dividual printer using water

- based or UV inks is 10,000 ft 2 /hr or higher. Such an operation is subject only to the record keeping requirements of Section (f) , whereas s maller digital printing operations are completely exempt from the rule

.

10

. WORKSHO P COMMENT

Do water

- based ink s also include soy based inks ?

DISTRICT RESPONSE

No. Soy based inks do not contain a ny water

. In addition to soybean oil

, they may also contain pigments, resins and waxes.

11

. WORKSHOP COMMENT

Does the exemption for digital printing operations refer to a single equipment unit

, or the entire operation?

DISTRICT RESPONSE

The exemption for digital printing operations is based on a printing capacity of a single equipment unit (i.e.

, individual printer). If a facility h as several digital printing lines the records required by the Subsection (b)(2) need to be kept only for the printing line that includes a printer using solvent based inks with a capacity of 1000 ft 2 /hr or higher, or a printer using water

- based

or UV inks with a capacity of 10,000 ft 2 /hr or higher.

12. WORKSHOP COMMENT

Current Rule 67.16

, Subsection b(1)

, exempts graph ic arts operations emitting less than an average 15 lbs of VOCs per day. Does this exemption apply to digital printing operations wit h an equipment print capacity of 10,000 ft 2 /hr or more if it emits less than 15 lbs VOC per day?

DISTRICT RESPONSE

No, because the magnitude of VOC emissions from digital printing operations is not known at

this time. The e xemption in Subsection (b)(1) applies only to conventional (analog) graphic arts operations, such as lithography, fle xography, rotogravure, etc. Digital printing on a commercial

scale is a comparatively new technology and there currently are not enough data to estimate

emissions from these operations. This is the reason why digital printing is treated separately in proposed amended Rule 67.16. Therefore, the District is proposing that the largest digital printing operations, as defined , will be exempt from the rule provided that the records specified in Section (f) are kept. Such stipulation would allow the District to estimate whether VOCWor kshop Report

Rules 67.16 & 11

E

- 5 emissions from digital printing operations are significant enough to justify any emission control requirements

.

1 3

. WORKSHOP COMMENT

If a digit al equipment has a print capacity specified in the definition of a "large digital printing operation

, " does t his mean that the facility is exempt from the rule and the only requirement is to keep records as described in Subsection (f)(4) of the rule ?

DIST RICT RESPONSE

Yes , although s trictly speaking a large digital printing operation is not exempt from Rule 67.16

. Rather, i t is exempt from the emission standards and some other specified provisions of the rule

, but is still subject to the record keeping r equirements specified in Subsection (f)(4 ).

1 4

. WORKSHOP COMMENT

If adhesives are used in a large digital prin ting operation, would such use affect the operation exemption status?

DISTRICT RESPONSE

No. L arge digital printing operations are exempt fr om the rule 's emission standards

, regardless

of whether adhesives are used

. S uch operations are only subject to the record keeping requirements of Subsection (f)(4)

. T hese records must be kept for all VOC

- containing materials

, including adhesives.

1 5

. WORKSHOP COMMENT

Would Rule 67.21 (Adhesive s and Sealants Application Operations) apply to printing operations ?

DISTRICT RESPONSE

No. Rule 67.21 , Subsection (a)(4)

, specifically exempts adhesive application operations that are subject to Rule 67.16

.

1 6

. WORKSHOP COMMENT

Would the exemption from Rule 67.16

, provided by Subsection (b)(1) for stationary sources that emit less than an average 15 lbs/day of operation for each calendar month

, remain in the rule?Wor kshop Report

Rules 67.16 & 11

E

- 6 DISTRICT RESPONSE

Yes . A t this time the exemption will remain as it complies with federal requirements specified in

EPA 's Control Technique Guide lines for lithographic, letterpress

, and flexible package printing operations. Please also see District Response to Comment 36 , regarding planned fut ure consideration of lowering the exemption threshold.

1 7

. WORKSHOP COMMENT

W ould it be possible to provide the exemptio n in Subsection (b) (1) in terms of monthly rather than daily VOC emissions ? Sometimes, production may vary from day to day, and it i s difficult

to estimate average daily emissions

.

DISTRICT RESPONSE

The exemption in Subsection (b) (1) is based on average daily VOC emissions per each calendar

month. Emission calculations for each individual day are not required under this provision. The average daily emissions may be determined by dividing monthly emissions by the number of operating days in a calendar month.

1 8

. WORKSHOP COMMENT

Does the rule apply to color or black

- and

- white digital equipment?

DISTRICT RESPONSE

The rule and the proposed exemptions appl y to both types of digital equipment

.

1 9

. WORKSHOP COMMENT

VOC content limits for cleaning materials may be too stringent, specifically in the case of the high speed web application equipment. W ater

- based solvents that me et these limits also require applying water as a rinsing agent to remove paper residue. If a low

- grade paper is used with high speed web equipment, the equipment can be down for a long period of time due to flying or

loose material. In this case

, the use of a water

- based solvent will result in significant problems

. Because jobs are run for days at a time and there is no opportunity to stop and rinse rubber components, the loose material remain s on these components and causes rubber swelling

, which

l eads to major equipment failures.Wor kshop Report

Rules 67.16 & 11

E

- 7 DISTRICT RESPONSE

Proposed amended Rule 67.16 does not mandate the use of water

- based cleaning materials. It

allows the use of VOC

- containing cleaning materials with a VOC vapor pressure of 5 mm Hg at

20 o C or less. The s e materials are available in the market place and are already being used in some graphic arts operations in San Diego County.

20

. WORKSHOP COMMENT

Proposed Rule 67.16 prohibits the use of alcohols in fountain solutions. There are no air districts

in Ca lifornia that have such provision

. The federal CTG offers three different approaches to

reduce emissions from fountain solutions. One of them prohibits the use of alcohols. It seems

that this is the most extreme approach.

DISTRICT RESPONSE

The propose d amended rule has been revised to allow limited use of alcohols in fountain solutions (pursuant to federal guidelines), as described in District Response to Comment 6.

2 1

. WORKSHOP COMMENT

A lcohol substitute s are also VOCs and are toxic.

DISTRICT RESPONSE

The District acknowledges that alcohol substitutes are VOCs and are toxic in some cases

. However, pursuant to federal guidelines, the proposed amended rule limits the concentration of

alcohol or alcohol substitutes in fountain solutions to 5% or less (or up to 8.5% if refrigerated)

. Their use is allowed because m any alcohol substitutes

, such as ethylene glycol ethers

, have a high boiling point and evaporate much slower than conventional additive s such as isopropyl

alcohol.

In addition, if a fac ility uses materials containing toxic air contaminants, it may become subject

to a toxic air contaminant risk assessment analysis pursuant to District Rule 1200 (Toxic Air

Contaminants

– New Source Review)

. If the result of this analysis show s that a leve l of toxic air

contaminant emissions is higher than the specified threshol d, the facility must reduce its emissions according to Rule 1200 requirements

.

2 2

. WORKSHOP COMMENT

Is it poss ible to allow an alcohol to be used in small amounts if a fountain so lution is chilled? Some printing jobs require a small amount of alcohol to be present in fountain solution.Wor kshop Report

Rules 67.16 & 11

E

- 8 DISTRICT RESPONSE

Yes. The proposed amended rule has been revise d to allow the use of fountain solutions with

8 .5 % of alcohols or less if the fo untain solution is refrigerated to below 60 o F (15.5 o C).

2 3

. WORKSHOP COMMENT

Would the District consider an exemption for the UV ink application equipment cleaning?

DISTRICT RESPONSE

No, t his exemption is not necessary. M aterials for UV ink applicat ion equipment cleaning that comply with the vapor pressure limits in the proposed amended rule (Subsection (d)(2)(ii)) are presently available.

2 4

. WORKSHOP COMMENT

Subsection (e)(1 ) (ii) specifie s that an " emission collection system which captures and transports emissions generated by graphic arts operations ...” Can this provision be clarified to mean that it would be a control device for a particular unit rather than an entire operation?

DISTRICT RESPONSE

Subsection (e)(1)(ii) has been clarified to s tate that the emission collection system may be

installed to capture emissions from an " applicable " graphic arts operation. This operation may

include any equipment or materials in use

, such as printing press es
, inks , etc.

2 5

. WORKSHOP COMMENT

In the original definition of " g raphic arts operations

, " the terms “process” and “operation ” seem to be interchangeable. Using the word “process” to define a graphic arts operation will make the

definition clearer.

DISTRICT RESPONSE

The District agrees. The definition has been revised as suggested

.Wor kshop Report

Rules 67.16 & 11

E

- 9 2 6

. WORKSHOP COMMENT

Some facilities us e 60 different inks per month , making emissions calculations difficult

. Would

the District approve using the highest VOC content of the ink used to calculate emissions fro m all inks? The Printing Industry Association has a video that addresses every potential case of

record keeping for VOC

- containing graphic arts materials and all the necessary calculations.

DISTRICT RESPONSE

The District has reviewed the information pro vided in the video and agrees that the highest VOC

content of inks may be used to calculate VOC emissions. However, this methodology overestimates the actual emissions from the facility. In addition, t here may be cases when a facility has a permit condit ion with daily emission limits pursuant to New Source Review rules

, such as 10 lbs of VOC per day. In this situation

, it would be advisable to use an it emized method

of calculations

, which is also discussed in the video.

2 7

. WORKSHOP COMMENT

It is diff icult sometimes to calculate the actual usage of ink s or other materials

, especially in cases where small amounts of them are used for each operation. Would purchase records be acceptable to the District?

DISTRICT RESPONSE

Yes. However, using purchas e records may result in an overestimate (significant in some cases)

of VOC emissions from a facility. Therefore, i t is advisable also to keep dispensing and /or inventory records, and the records of inks and oth er materials recycled or sent to disposal

ser vices in the end of each month or each year. These records will help the facility determine the

amount of VOC

- containing materials used, and therefore the facility’s emissions.

2 8

. WORKSHOP COMMENT

Would there be a way to correlate material usage using other operational parameters, without having to actually weigh or track a small amount of material?

DISTRICT RESPONSE

Yes. Please see the District R esponse to the previous c omment

.Wor kshop Report

Rules 67.16 & 11

E

- 10 2 9

. WORKSH O P COMMENT

Existing Subs ection (f)(2 ) requires a facility to maintain " daily or monthly " records of material

usage

. Is this a choice of the facility? Does the District generally require monthly records?

DISTRICT RESPONSE

A facility may choose whether to keep monthly or daily records , unless daily records are required pursuant to conditions on the facility's permit

. For example , if the facility is subject to

New Source Review requirements

, it may be limited to a certain amount of VOC emissions per day. Accordingly, the Permit to Operate may have a condition to keep daily usage records of

VOC

- containing materials . In this case

, the mo re stringent requirement will apply

, and the facility must keep daily records.

30

. WORKSHOP COMMENT

What is the intent of S ubsection (f)(3)(ii)? Is this for compliance with c apture efficiency requirements ? If so , how would one keep daily records of capture efficiency?

DISTRICT RESPONSE

Subsection (f)(3)(ii) does not require keeping daily records of capture efficiency. The intent of

this subsection is to ensure that add

- on emission control equipment operates properly at all time s when VOC

- emitting activities take place. Therefore, a facility has to keep daily records of " key

system operating parameters " such as " temperature, pressure and/ or flow rate " for an entire

system, i.e.

, for both the emission s collection and control equipment

. If the key operating

parameters do not deviate from those specified in the District

- approved Operation and Maintenance plan as required by the rule or as specified in a Permit to Operate , then the entire emission control system (including its capture efficiency) operates properly.

3 1

. WORKSHOP COMMENT

Why is South Coast Air Quality Management District (SCAQMD) Test Method 304 included in

Subs ection (g)(1)?

DISTRICT RESPONSE

Subsection (g )(1) lists the test methods that must be used to determine the VOC content of

various graphic arts materials. SCAQMD Test 304 may be used for graphic arts materials such as thinners, where EPA Test Method 24 is not applicable

.Wor kshop Report

Rules 67.16 & 11

E

- 11 3 2

. WORKSHOP COMMENT

Woul d the EPA Test Method 24 be used for determining the VOC content of cleaning materials?

DISTRICT RESPONSE

No. EPA Method 24 is not applicable for determin ing the VOC content of cleaning materials. Currently, there are other test methods developed by th e SCAQMD or other air districts and approved by EPA that use gas chromatography often combined with mass

- spectrometry.

3 3

. WORKSHOP COMMENT

Are SCAQMD Test Methods 313 and 308 nationally approved?

DISTRICT RESPONSE

Yes, these methods are approved by E PA. They are listed on EPA 's and SCAQMD 's website s

.

3 4

. WORKSHOP COMMENT

Do es the District have a contact at EPA regarding the Test Methods?

DISTRICT RESPONSE

EPA 's Emission Measurement C enter (EMC) in North Carolina is responsible for Test Methods

. EMC's staff directory is available at www.epa.gov/ttn/emc/staffdir.html , and contacts ar e Candace Sorrell at (919) 541

- 1064 or Ray Merrill at ( 919 ) 541

- 5225.

3 5

. WORKSHOP COMMENT

Some facilities use preservative oils sprayed from aerosol containers on press rollers when the equipment is turned off for an extended period of time to prevent the ink hardening during non

operating period s . The amount of oils used is very low, about a few ounces per d ay. Can such operations be exempt from the rule?

DISTRICT RESPONSE

Yes. This exemption has been added to the proposed rule amendments

.Wor kshop Report

Rules 67.16 & 11

E

- 12 3 6

. ARB COMMENT

The exemption for small operations is too broad. It allows operations emitting over 450 pounds

of VOC per month to be exempt from regulation. Other air districts in California have much lower exemption level s , such as 200 pounds VOC per rolling 12

- month period

. ARB

recommend s reducing the exemption level in Rule 67.16. By lowering the exemption lev el, more sources will be subject to the rule and additional emission reductions will be achieved.

DISTRICT RESPONSE

The proposed amendments to Rule 67.16 address federal Reasonably Available Control Technology (RACT) requirements specified in EPA 's CTGs for both flexographic and lithographic printing operations. The exemption level in the rule complies with EPA guidelines and is not proposed for amendment at this time

.

As noted above, lower emission operations that are currently exempt from Rule 67.16 are also exempt from Rule 11 permit requirements. In the future, t he District is planning to consider

amend ing Rule 11 to reduc e the exemption level for graphic arts operations , thereby requiring permits for facilities with lower VOC emissions

. This will enable an assessment of presently

non

- permitted sources and their VOC emissions to determine whether lowering the Rule 67.16 exemption level is warranted

.

It should be noted that existing Rule 67.16 exempts a stationary source that emits less than an

ave rage of 15 lbs per operating day for each calendar month. It is unrealistic to assume that the companies in San Diego County operate 30 days in a calendar month. Many of them, according

to District information

, operate only 2

- 3 days per week, i.e.

, about 9

- 14 days per month

.

3 7

. ARB COMMENT

The VOC content limit in Section (d) for all graphic arts materials is 300 g/l (less water and less exempt compounds). This limit may be high for some graphic arts materials, particularly

adhesives

.

DISTRICT RESP ONSE

The District agrees. A VOC content limit of 150 g/l for adhesives has been added to the rule.

3 8

. ARB COMMENT

ARB recommends providing separate VOC content limits for screen printing operations.Wor kshop Report

Rules 67.16 & 11

E

- 13 DISTRICT RESPONSE

Please see District R esponse to Comment 4.

39

. ARB COMMENT

Subsection (d)(1) (ii ) indicates a VOC content limit of 5% by volume for fountain solutions, with

no alcohols to be used. Per the EPA’s CTGs for Offset Lithographic Printing and Letterpress Printing (September 2006), this l imit should be 5% VOC by weight, not volume, provided no

alcohol is used in the fountain solution.

DISTRICT RESPONSE

Fountain solutions come from the suppliers as liquid concentrates. It is more practical to use a volume percent to describe a VOC limit for fountain solutions because it is easier to measure the

volume rather than the weig ht of a liquid

. In addition, s ince fountain solutions are made by diluting a liquid concentrate with water

, often using a 1:10 ratio, the final product is a n aqueous sol ution with a low concentration of VOCs. The numerical difference between volume and weight percent concentration s in such case will be negligible.

4 0

. ARB COMMENT

Subsections (d)(2)(i) and (d)(2)(ii ) specify that cleaning material must have a VOC conte nt of less than 100 grams per liter or a total vapor pressure of 5mm of Hg at 20 o C or less. ARB

recommend s a VOC limit for cleaning operations of 25 g/l , with exceptions made for certain cleaning operations based on BAAQMD Rule 8

- 20.

DISTRICT RESPONSE

The proposed amendments to Rule 67.16 are designed to satisf y federal requirements for implementing RACT , as defined by EPA's CTGs. (Accordingly, the amended rule will be

submitted to EPA

, through ARB

, along with the District's pending Ozone State Implem entation

Plan (SIP) .) The emission limits for cleaning materials provided in the proposed amended rule comply with those federal requirements.

4 1

. ARB COMMENT

ARB recommend s a ban on cleaners containing methylene chloride

, as provided in other air

dist ricts ’ rule

.Wor kshop Report

Rules 67.16 & 11

E

- 14 DISTRICT RESPONSE

The District disagrees. Methylene chloride is an exempt compound and therefore is not subject

to Rule 67.16 , which regulates emissions of ozone

- forming VOCs. The District does not have the jurisdiction to prohibit the us e of any exempt compounds. Since methylene chloride is a toxic air contaminant, its use and allowable emissions are regulated by National Emission Standards for Hazardous Air Pollutants and by District Rule 1200 (Air Toxic Contaminants

– New Source Review ).

There were no EPA comments on proposed amend ments to Rule 67.16.

Rules 11

– Exemptions from Rule 10 Permit Requirements

1

. WORKSHOP COMMENT

Section (d)(11) of Rule 11 includes both terms

- "operation" and "equipment." Is it correct to

assume th at the term "operation" encompasses the entire printing process?

DISTRICT RESPONSE

Yes, this assumption is correct. Section (d)(11) of Rule 11 historically specified exemptions from permit requirements for both printing equipment and printing operatio ns. For clarity, this section’s heading will be revised to read, “Printing and Reproduction Equipment and Operations

. ” Please refer also to the definition of a Graphic Arts Operation in proposed amended Rule 67.16 that specifically includes the entire gr aphic arts process

.

2

. EPA COMMENT

EPA recommends that the District submit this version of Rule 11 as a revised part of the SIP. This will make it easier to keep track of different versions of Rule 11 submitted to EPA.

DISTRICT RESPONSE

The Distric t agrees. Rule 11, with amended Section (d)(11), will be submitted to EPA as a SIP

revision.Wor kshop Report

Rules 67.16 & 11

E

- 15 3

. EPA COMMENT

If a proposed amended Rule 11 contains any additional exemptions that may have emission impacts, these impacts should be addressed in the Distr ict’s submittal. In addition, the exemptions in Rule 11 should be consistent with the exemptions in Rule 67.16.

DISTRICT RESPONSE

Section (d)(11) of Rule 11 contains new exemptions from permit requirements for digital printing operations, consistent wit h the exemptions in the proposed amended Rule 67.16.

“Large” digital printing operations as defined in Rule 67.16 are exempt from permit requirements, provided that the facility keeps specified records. Smaller digital printing operations commonly perf ormed in homes, schools, business offices, etc. will be completely exempt from permit requirements.

Digital printing on a commercial scale is a comparatively new technology and its VOC emissions are not yet quantified. The proposed record keeping require ment will provide the data for estimating VOC emissions from large scale digital printing operations.

It is expected, however, that emission impacts from this exemption, if any, will not be significant. Many digital printing operations use dry inks and t oners, UV inks

, or low VOC

water

- based inks and solvents. Some digital printing equipment is also equipped with internal VOC capture and recycling devices.

There were no ARB comments on proposed amendments to Rule 11.

NY:jlm

07/06/11