Air Pollution Control Board

San Diego County Air Pollution Control District

AGENDA ITEM

Governing Body

GREG COX

First District

DIANNE JACOB

Second District

PAM SLATER-PRICE

Third District

RON ROBERTS

Fourth District

BILL HORN

Fifth District

Documentum Version 3.1

DATE: November 9, 2011 AP01

TO: Air Pollution Control Board

SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO 

RULE 67.16 – GRAPHIC ARTS OPERATIONS AND RELATED 

AMENDMENTS TO RULE 11 – EXEMPTIONS FROM RULE 10 PERMIT 

REQUIREMENTS (DISTRICT: All)

SUMMARY: 

Overview

The Air Pollution Control Board is requesting to adopt proposed amendments to Rule 

67.16, which limits emissions of volatile organic compounds from inks, cleaning 

solvents, and other graphics arts materials used in printing operations. Volatile organic 

compounds emitted into the atmosphere contribute to the formation of ozone, which at 

elevated levels can impact public health. Despite substantial air quality improvement 

over the past two decades, San Diego County has not yet attained state and federal air 

quality standards for ozone.

The amendments, if adopted, will reduce the allowable amount of volatile organic 

compounds in fountain solutions, cleaning solvents, and adhesives used in printing 

operations, consistent with recent federal guidelines and existing requirements of 

several air districts in California. The amendments help fulfill state and federal 

requirements to update rules as necessary to reflect the current state of air pollution 

control technology.

In addition, related amendments are proposed for Rule 11 (Exemptions from Rule 10 

Permit Requirements) pertaining to the digital printing industry. Digital printing is an 

evolving technology that in many cases uses inks and other materials containing 

volatile organic compounds, although the extent of emissions is currently unknown. 

The proposed amendments to Rule 11 exempt digital printing operations from air 

quality permits but require large operations (as defined) to keep records on the use of 

inks and cleaning solvents as specified in Rule 67.16. These records will enable future 

assessment of emission levels and the potential need for pollution control requirements 

specific to the digital printing industry.
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO RULE 

67.16 – GRAPHIC ARTS OPERATIONS AND RELATED AMENDMENTS 

TO RULE 11 – EXEMPTIONS FROM RULE 10 PERMIT REQUIREMENTS 

(District: All)

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Recommendation(s)

AIR POLLUTION CONTROL OFFICER

1. Find that the adoption of amendments to Rule 67.16 and Rule 11 is categorically 

exempt from the provisions of the California Environmental Quality Act pursuant 

to California Code of Regulations, Title 14, Section 15308, as an action taken to 

assure the protection of the environment, where the regulatory process involves 

procedures for protection of the environment, and pursuant to California Code of 

Regulations Title 14, Section 15061(b)(3), since it can be seen with certainty that 

there is no possibility that the activity in question may have a significant effect on 

the environment.

2. Adopt the resolution entitled Resolution Adopting Amendments to Rule 67.16 –

Graphic Arts Operations of Regulation IV and Related Amendments to Rule 11 –

Exemptions from Rule 10 Permit Requirements of Regulation II of the Rules and 

Regulations of the San Diego County Air Pollution Control District..

Fiscal Impact

The proposed amendments to Rule 67.16 and Rule 11 will be implemented and 

enforced with existing staff and will not have a fiscal impact on the Air Pollution 

Control District.

Business Impact Statement

Adopting the proposed amendments to Rule 67.16 will not adversely impact the 

business community. The proposed graphics arts and cleaning materials with a lower 

content of volatile organic compounds are widely available and equally priced, or only 

marginally more expensive. Many printing facilities already comply with the proposed 

amendments. Furthermore, the amendments will not take effect for six months, 

allowing time to deplete existing inventories of non-compliant materials.

No additional permit requirements will result from the amendments to Rule 11. Thus, 

this action will not adversely impact the business community.

Advisory Board Statement

At its meeting on August 10, 2011, with a quorum present, the Air Pollution Control 

District Advisory Committee voted 3 to 1 in support of the Air Pollution Control 

District’s recommendations.

BACKGROUND:

San Diego County does not currently meet the National and State Ambient Air Quality Standards 

for ozone and therefore is classified as an ozone nonattainment area. National and state laws 

require the San Diego County Air Pollution Control District (District) to implement rules that 

reduce emissions of ozone precursors – volatile organic compounds (VOCs) and oxides of 

nitrogen.
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO RULE 

67.16 – GRAPHIC ARTS OPERATIONS AND RELATED AMENDMENTS 

TO RULE 11 – EXEMPTIONS FROM RULE 10 PERMIT REQUIREMENTS 

(District: All)

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Existing Rule 67.16 regulates VOC emissions from inks, cleaning solvents, and other graphic 

arts materials used in printing operations. The rule was adopted in 1988 and last revised in 1996. 

The primary objective in amending Rule 67.16 is to ensure ongoing compliance with federal 

Reasonably Available Control Technology (RACT) requirements applicable to the printing 

industry. The proposed amendments comply with federal Control Techniques Guidelines for 

printing operations, recently issued by the U.S. Environmental Protection Agency (EPA). 

Accordingly, amended Rule 67.16 will implement current RACT as required by the federal Clean 

Air Act.

The proposed amendments to Rule 67.16 reduce the VOC content limit for fountain solutions 

(used to repel ink from non-printing areas) from 15% to 5%, or to 8.5% if the fountain solution is 

chilled to reduce evaporation of VOCs into the atmosphere. The VOC content limit for cleaning 

solvents is reduced from 200 grams/liter to 100 grams/liter. Alternatively, a facility may use 

cleaning solvents with a low vapor pressure (low evaporation rate). The VOC content limit of 

adhesives is reduced from 300 grams/liter to 150 grams/liter.

In addition, the proposed rule amendments address the issue of estimating VOC emissions from 

digital printing operations, which are not presently quantified. The amendments exempt digital 

printing operations but require facilities using high-capacity digital printing equipment, as 

defined, to keep monthly or daily records of the amounts of inks and cleaning solvents used and 

their VOC content. Information obtained as a result of this provision will allow the District to 

evaluate the potential necessity of VOC emissions control at digital printing operations and 

whether to continue the record keeping requirements.

The proposed rule amendments also update the test methods for determining the VOC content of 

graphic arts and cleaning materials and the overall efficiency of emission control systems. In 

addition, the amendments include updated and new definitions, including those for digital 

printing operations.

There are 16 facilities in San Diego County that are currently subject to Rule 67.16, with total 

VOC emissions from printing operations of approximately 64 tons/year. The rule amendments 

will reduce VOC emissions by approximately 10.5 tons/year or 16%.

In conjunction with the proposed exemption in Rule 67.16 for digital printing operations, 

corresponding amendments to Rule 11 (Exemptions from Rule 10 Permit Requirements) are also 

proposed. The amendments will exempt digital printing operations from air quality permit 

requirements—in fact, no such operations currently have an air quality permit—but will require 

facilities using high-capacity digital printing equipment to keep records as specified in 

Rule 67.16.

Rule 67.16 addresses federal requirements and therefore is included in the State Implementation 

Plan (SIP). Upon its adoption, the amended rule will be submitted to EPA as a SIP revision.
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO RULE 

67.16 – GRAPHIC ARTS OPERATIONS AND RELATED AMENDMENTS 

TO RULE 11 – EXEMPTIONS FROM RULE 10 PERMIT REQUIREMENTS 

(District: All)

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Socioeconomic Impact Assessment

Section 40728.5 of the State Health and Safety Code requires the District to assess the 

socioeconomic impacts when adopting, amending, or repealing a rule that will significantly affect 

air quality or emission limitations. The assessment must include an evaluation of small business 

impacts. The proposed amendments to Rule 67.16 contain new, lower VOC emission limitations 

for graphic arts materials and cleaning agents used in printing operations. Accordingly, a 

Socioeconomic Impact Assessment has been prepared (Attachment B), which shows that the rule 

amendments will not have significant economic impact on the affected industry, including small 

business.

Environmental Statement

The amendment of Rule 67.16 and 11 are exempt from the California Environmental Quality Act 

(CEQA) pursuant to California Code of Regulations, Title 14, Section 15308, as an action taken 

to assure the protection of the environment, where the regulatory process involves procedures for 

protection of the environment. In this case, this action is being taken in response to federal and 

state requirements to reduce emissions of VOCs in order to achieve ambient air quality standards. 

Additionally, this action is also exempt pursuant to California Code of Regulations Title 14, 

Section 15061(b)(3), since it can be seen with certainty that there is no possibility that the 

activity in question may have a significant effect on the environment. Many affected facilities 

already comply with the proposed requirements and compliant materials are widely available and 

in use.

Linkage to the County of San Diego Strategic Plan

The County's five-year strategic plan includes an Environment Initiative to ensure environmental 

preservation and enhance quality of life. Proposed amendments to Rule 67.16 will codify the use 

of graphic arts materials with lower emissions of volatile organic compounds without negatively 

impacting the local business community. The rule balances air quality preservation, public 

health protection, and economic development needs.
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO RULE 

67.16 – GRAPHIC ARTS OPERATIONS AND RELATED AMENDMENTS 

TO RULE 11 – EXEMPTIONS FROM RULE 10 PERMIT REQUIREMENTS 

(District: All)

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ATTACHMENT(S)

Attachment A – Resolution Adopting Amendments to Rule 67.16 – Graphic Arts Operations of 

Regulation IV and Related Amendments to Rule 11 – Exemptions from Rule 10 

Permit Requirements of Regulation II of the Rules and Regulations of the San 

Diego County Air Pollution Control District

Attachment B – Socioeconomic Impact Analysis

Attachment C – Comparative Analysis

Attachment D – Incremental Cost Effectiveness Analysis

Attachment E – Workshop Report

Attachment F – Rule 67.16 Change Copy

Attachment G – Rule 11 Change Copy
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO RULE 

67.16 – GRAPHIC ARTS OPERATIONS AND RELATED AMENDMENTS 

TO RULE 11 – EXEMPTIONS FROM RULE 10 PERMIT REQUIREMENTS 

(District: All)

AGENDA ITEM INFORMATION SHEET

REQUIRES FOUR VOTES: [] Yes [X] No

WRITTEN DISCLOSURE PER COUNTY CHARTER SECTION 1000.1 REQUIRED

[] Yes [X] No

PREVIOUS RELEVANT BOARD ACTIONS:

May 15, 1996 (APCB #2), Amendment of Rule 67.16 – Graphic Arts Operations; April 25, 2007 

(APCB #1), Amendment of Rule 11 – Exemptions from Rule 10 Permit Requirements

BOARD POLICIES APPLICABLE: N/A

BOARD POLICY STATEMENTS: N/A

MANDATORY COMPLIANCE: N/A

ORACLE AWARD NUMBER(S) AND CONTRACT AND/OR REQUISITION 

NUMBER(S): N/A

ORIGINATING DEPARTMENT: Air Pollution Control District

OTHER CONCURRENCE(S): N/A

CONTACT PERSON(S):

ROBERT J. KARD

Name Name

(858) 586-2700

Phone Phone

(858) 586-2701

Fax Fax

O-176

Mail Station Mail Station

Robert.Kard@sdcounty.ca.gov

E-mail E-mail