PLACER COUNTY

AIR POLLUTION CONTROL DISTRICT

STAFF REPORT

RULE 239

GRAPHIC ARTS OPERATIONS 

PROPOSED RULE AMENDMENTS

October 11, 2012
Staff Report – Revision to Rule 239

October 11, 2012

Page 1

BACKGROUND

The Placer County Air Pollution Control District (District) jurisdiction is Placer County. Placer 

County is located in northern California, bordering Sacramento County to the west and the State 

of Nevada on the east. Placer County is divided into three different air basins: the Sacramento 

Valley Air Basin (SVAB); the Mountain Counties Air Basin (MCAB); and the Lake Tahoe Air Basin 

(LTAB). The portions of Placer County in the SVAB and MCAB are included in the Sacramento 

Federal Ozone Non-Attainment Area (SFONA). The SFONA has been classified as “severe” 

non-attainment for the National Ambient Air Quality Standard (NAAQS) for eight-hour ozone, as 

well as non-attainment with the State of California Ambient Air Quality Standard for ozone. The 

U.S. Environmental Protection Agency’s (EPA) Phase 2 Ozone Rule, contained in 40 CFR 51.912 

and 70 FR 71612, in accordance with Clean Air Act (CAA) Amendments of 1990, Sections 

182(b)(2) and 182(f), requires that areas that are classified as moderate non-attainment or higher 

must demonstrate in a State Implementation Plan (SIP) that their rules fulfill Reasonably 

Available Control Technology (RACT) requirements for volatile organic compound (VOC) and 

nitrogen oxides (NOx) which are ozone precursors. The implementation of RACT requires, at a 

minimum, District rules covering source categories with RACT guidance documents, which 

include all EPA-issued Control Techniques Guidelines (CTG’s), where there are such sources 

that operate in the District.

District Rule 239, Graphic Arts Operations, limits VOC emissions from graphic art operations in 

the District. The rule was originally adopted on November 3, 1994. It has been subsequently 

amended four times, with the latest on April 8, 2004. This latest version has not been SIPapproved. The most recent SIP approval was on November 13, 1998 (63 FR 63410) for the rule 

amended on February 13, 1997.

In September 2006, the EPA issued a CTG for graphic arts operations (“Control of Volatile 

Organic Compound Emissions from Offset Lithographic and Letterpress Printing”, EPA-453/R-06-

002). The current District Rule 239, adopted on April 8, 2004, does not fully address these 

requirements. Thus, the District is proposing amendments to Rule 239 to meet RACT SIP 

obligations through implementation of all CTG requirements.

The District has seven (7) permitted non-major sources in the category of graphic arts operations.

The business names for these sources are:

• Auburn Journal

• Auburn Printers

• GKM Corporation 

• J & M Printing

• Master Color

• Paul Baker Printing Company

• Sir Speedy Printing 

This Staff Report addresses amendments that are proposed to Rule 239. 

DISCUSSION

Rule 239 amendments were made based on a review of the CTG, and to establish consistency 

with local Air District rules. We reviewed local Air District rules including:

• Sacramento Metro AQMD Rule 450, Graphic Arts Operations, last amended on October 

23, 2008. 
Staff Report – Revision to Rule 239

October 11, 2012

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• San Joaquin Valley APCD Rule 4607, Graphic Arts and Paper, Film, Foil and Fabric 

Coatings, last amended on December 18, 2008.

• El Dorado, Rule 231, Graphic Arts Operations, last amended on September 27, 1994.

We also reviewed rules from other Air Districts including:

• South Coast AQMD Rule 1130, Graphic Arts, last amended on October 8, 1999

• Bay Area AQMD Regulation 8, Rule 20, Graphic Arts Printing and Coating Operations, 

last amended on November 19, 2008.

• San Diego County APCD, Rule 67.16, Graphic Arts Operations, last amended on May 9, 

2012.

• Ventura County APCD, Rule 74.19, Graphic Arts, last amended on June 14, 2011.

These Districts are designated as non-attainment areas for the Federal national ambient air 

quality standard for ozone. Thus, they also are required to implement CTGs in their rules.

Proposed Rule amendments, in underline/strikeout format, are shown in Attachment #1. Specific 

changes to the Rule include:

Section 100. General

Section 102. Applicability. Subsections 102.1 and 102.2 provisions are combined into one 

section.

Section 104. Exemptions. Changes to the section include:

Section 104.1. General. Section 104.1.1 expired on April 8, 2005, thus it is deleted. 

The phrase “after April 8, 2005” contained in Subsection 104.1.2 no longer applied and 

is removed. 

Section 104.2. Proof Presses and/or Research and Test Development Operations. This 

section expired on April 8, 2005, thus it is deleted. 

Section 104.7. Aerosol Adhesives – Graphic Arts Operations. For clarification, “other 

than screen printing” is added to specify that this exemption for aerosol adhesives is 

only applicable to graphic arts operations other than screen printing.

Section 104.2. Stripping of Cured Inks, Coatings, or Adhesives. A specific exemption is

added for strippers, as contained in other District rules. This is consistent with (no 

change from) the requirements of the current existing rule which indirectly exempts 

strippers from VOC limits because there are no specific limits stated for strippers and 

strippers are not included in the Solvent Cleaner sub-categories.

Section 104.8. Fountain Solutions. As recommended by the CTG and contained in 

other District rules, an exemption from VOC content limits for fountain solutions is added 

when facility wide total potential to emit VOC emissions before control is less than 450 

lb/month.

Section 104.5. Prepress Operations. For clarification, the cleaning or processing of 

color scanners, plate processors, film cleaning and plate developers is added to this 

exemption. 
Staff Report – Revision to Rule 239

October 11, 2012

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Section 104.9. Blanket Repair Materials. A small quantity exemption is added for 

blanket repair materials when used in containers of four ounces or less, as contained in 

other District rules.

Section 104.10. Heatset Web Offset Lithographic Printing and Heatset Web Letterpress 

Printing. This new section exempts these specific operations from needing add-on 

control requirements contained in new Section 302.1 when potential to emit VOC 

emissions are less than 25 tons per year.

Section 200. Definitions

Definitions that are eliminated include: lithographic and letter press printing, other cleaning,

Volatile organic compound (VOC) as supplied, Volatile organic compound (VOC) as applied. 

Definitions that are added include: Adhesive, Aerosol Adhesive, Alcohol, Blanket, Blanket 

repair material, Cured ink, cured coating, or cured adhesives, Heater or dryer, Ink jet, 

Removable press component, Stripping, Roller wash, VOC content. 

Definitions that are amended include: Blanket and roller washes, Fugitive emissions, Graphic 

arts operations, Gravure printing, Lithographic printing, Metering roller, Noncompliant 

material, Offset printing, Prepress operations.

Section 300. Standards

Section 301. General Requirements. This section is deleted since it is redundant to other 

sections already contain in the rule.

Section 301. VOC Content Limits for Materials used in Graphic Arts Operations. This section 

was previously numbered Section 302. Additional changes to the section include: 

• Section 301.1, VOC Content for Inks, Coatings, and Adhesives, The VOC content 

limit for the Sign Ink/Coating subcategory was reduced to from 500 g/l to 400 g/l. 

The VOC content limit for the Extreme Performance Ink/Coating subcategory was 

reduced from 800 g/l to 400 g/l. These changes are based on EPA 

recommendations and other Air District rules.

• Section 301.2, VOC Content for Fountain Solution Materials. Fountain solution 

category and subcategories are modified, and applicable VOC content limits are 

lowered, based on the CTG recommendations.

• Section 301.4. A new section that prohibits the use of fountain solutions containing 

alcohol on coldset web offset lithographic presses is added based on the CTG 

recommendations.

Section 303. Emission Control Equipment. This section has been renumbered to Section 

302. Other changes to the section include:

• Section 302.1. Heatset Web Offset Lithographic or Letterpress. Add-on control 

requirements for this category are added to meet the CTG recommendations.

• Section 302.2. Alternative Emissions Control Equipment. A title is added to the 

section for clarification. Subsections 303.2.2 through 303.2.4 are added to specify

combined overall capture and control system efficiency requirements rather than 

separate control and capture efficiency requirements, as required by the CTG. 

Subsections 303.2.1 and 303.2.1, which contained the current capture and control 

methods are deleted.
Staff Report – Revision to Rule 239

October 11, 2012

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Section 304. Cleaning and Storage Requirements. This section is renumbered to Section 

303. Changes to this section include:

• Section 303.1. For cleaning solvents, for a couple of subcategories, VOC content

limits and VOC composite partial vapor pressure limits are lowered to 670 g/l and 10 

mm Hg respectively. This is to meet CTG recommendations of VOC content of less 

than 70% by weight (equivalent to a VOC concentration of 670 g/l) and partial 

pressure of less than 10 mm Hg.

• Section 304.2. Lithographic and Letter Press Printing, Other Cleaning. This section,

which restricts the quantity of monthly usage of “other” cleaning solutions in 

comparison to blanket and roller wash usage, is eliminated. This requirement 

effectively produces no benefit since the VOC content limit in g/l for “other” cleaners 

is identical to the limit for blanket and roller washes.

Section 400. Administrative Requirements

Section 401. Operation and Maintenance Plan. This section is moved to Section 302.2.5. 

Section 403. Calculation for Determining VOC Composite Partial Pressure. This section is 

moved to Section 262. 

Section 404. Calculation for Determining VOC content of Material Excluding Water and 

Exempt compounds. This section is moved to Section 264.1. 

Section 405. Calculation for Determining VOC Content of Material Including Water and 

Exempt Compounds. This section is moved to Section 264.2. 

Section 407. Calculation for Determining VOC Emissions for Stationary Sources Including 

those exempt pursuant to section 104.1, 104.2 and 104.7, Sections 104.2 is eliminated from 

the title since it expired on April 8, 2005. 

Section 500. Monitoring and Record

Section 501. Recordkeeping. Recordkeeping requirement of the percentage of Lithographic 

and Letter Press, Other Cleaning materials requirement is deleted since it is no longer 

required by the Rule. Also, Subsections 501.3.3 and 501.3.4 are added to ensure adequate 

usage records. 

Section 502. Test methods. Section 502.4, Determination of Control Efficiency, is deleted.

Further, applicable test methods references are updated to the most approved current 

versions.

Miscellaneous

Additional miscellaneous changes were made for readability and conformance with the CTG

which have no impact on the compliance requirements of the Rule.

ANALYSIS
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October 11, 2012

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The following Analysis and the subsequent Findings are intended to address the requirements set 

forth in the Health and Safety Code relating to adoption of a new or amended District Rule, as well as 

other State statutes referenced herein.

1. Cost-Effectiveness of a Control Measure

California Health & Safety Code (H&S) Section 40703 requires a District to consider and 

make public “the cost-effectiveness of a control measure”. The compliance costs are 

associated with replacing existing graphic arts and cleaning products with VOC content that 

meets the amended rule limits, as well as new work practice and recordkeeping 

requirements. Graphics arts products that meet proposed VOC content limits are wellestablished to be readily available at the same price points as products that will become 

non-compliant when the proposed amendments will become effective on October 11, 2012. 

The cost effectiveness has been determined to be acceptable by the EPA and other Air 

Districts that have already implemented the CTG requirements. EPA concluded that CTG 

requirements actually produce a cost saving ranging from $700 to $1,500 per year for 

each printing operation. The graphic arts operations located within the District are not 

expected to be significantly affected (no adverse impacts on the profitably of business) by 

the proposed rule changes.

2. Socioeconomic Impact

H&S Section 40728, in relevant part, requires the Board to consider the socioeconomic 

impact of any new or amended rule if air quality or emission limits are significantly affected. 

Numerous existing graphic arts shop operations are already operating in compliance with 

the amended rule standards.

3. Environmental Review and Compliance

California Public Resources Code Section 21159 requires an environmental analysis of 

the reasonably foreseeable methods of compliance should be conducted. Compliance of 

the proposed rule amendment is expected to be achieved by the replacement of current 

graphic arts products with compliant compounds. Application of these compliant 

compounds will generally result in less VOC emissions from the graphic arts activities. 

Therefore, the proposed rule amendment will reduce emissions from sources and will not 

cause any significant adverse effects on the environment. Staff has concluded that no 

adverse environmental impacts will be caused by compliance with the proposed rule 

amendment.

According to the above conclusion, Staff finds that the proposed rule amendment is 

exempt from the California Environmental Quality Act (CEQA) because: (1) it can be 

seen with certainty that there is no possibility that the activity in question may have a 

significant adverse effect on the environment (CEQA Guidelines §15061(b)(3)), and (2) it 

is as an action by a regulatory agency for protection of the environment (Class 8 

Categorical Exemption, CEQA Guidelines §15308).

FINDINGS

A. Necessity: The adoption of proposed amended Rule satisfies the objective of the District 

to implement “Control Techniques Guidelines” for the reduction of VOCs to achieve 

attainment with ambient air standards for ozone, and meets the District’s requirements to 

implement “every feasible measure” and “Best Available Retrofit Control Technology” as 

required under California Health and Safety Code Sections 40919 and 40914.
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B. Authority: California Health and Safety Code, Sections 40000, 40001, 40701, 40702, 

40716, 41010, and 41013, are provisions of law that provide the District with the authority 

to adopt this proposed amended Rule.

C. Clarity: There is no indication, at this time, that the proposed amended Rule is written in 

such a manner that persons affected by the Rule cannot easily understand them.

D. Consistency: The proposed amended Rule is in harmony with, and not in conflict with or 

contradictory to, existing statutes, court decisions, or state or federal regulations.

E. Non-duplication: The proposed amended Rule does not impose the same requirements 

as an existing state or federal regulation.

F. Reference: All statutes, court decisions, and other provisions of law used by the District

in interpreting this proposed amended Rule are incorporated into this analysis and this 

finding by reference.

SUMMARY

Rule 239, Graphic Arts Operations, has been amended to address the control guidance contained in the 

U.S. EPA’s CTG for Graphic Arts issued in September 2006 (EPA-453/R-06-002).
ATTACHMENT #1

Subject:

District response to the U.S. EPA comments on

Rule 239, Graphic Arts Operations
ATTACHMENT #2

Subject:

Strikeout Rule 239, Graphic Arts Operations