UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

For

EPA’s Direct Final Rulemaking

For the

California State Implementation Plan

San Diego County Air Pollution Control District, 

Rule 67.16, Graphic Arts Operations

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

June, 2012
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Agency: San Diego County Air Pollution Control District (SDCAPCD

or District)

SIP Approved Rule: Rule 67.16 – Graphic Arts Operations

Adopted and Effective– May 15, 1996

Submitted – October 18, 1996

EPA Approved – March 27, 1997 (62 FR 14639)

Subject of this TSD: Rule 67.16 – Graphic Arts Operations

Adopted – November 9, 2011

Effective – May 9, 2012

Submitted – February 23, 2012

RULE SUMMARY – SDCAPCD Rule 67.16, Graphic Arts Operations, is a rule that 

applies to graphic arts, digital printing and laminating and drying operations. The 

primary purpose for the District’s amending Rule 67.16 is to ensure ongoing compliance 

with federal Reasonably Available Control Technology (RACT) requirements applicable 

to the printing industry. 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 and large digital printing operations were added to the rule’s 

exemptions with the provision that specific recordkeeping be applied.

SDCAPCD regulates an ozone nonattainment subpart 1 area for the 8-hour ozone 

national ambient air quality standard (NAAQS)1and SDCAPCD has designed Rule 

67.16 partly to address the requirements for ozone non-attainment areas as described 

in Clean Air Act (CAA) §182. Both federal and state laws require the District to 

implement rules that regulate emissions of ozone precursors – VOCs and oxides of 

nitrogen. Amended rule 67.16 serves to reduce VOC emissions, principally by reducing

the VOC content limit for fountain solutions, cleaning solvents and adhesives used in 

printing operations. Other means designed to reduce VOC emissions are 

the option of using control equipment and the usage recordkeeping requirements for 

coatings with VOC content.

 

1. 40 CFR 81.
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There are sixteen graphic arts facilities subject to Rule 67.16 in San Diego County and it 

is estimated that the amendments to the rule will reduce VOC emissions by 16% or 

approximately 10.5 tons per year.2

EPA EVALUATION CRITERIA - The following criteria were used to evaluate the 

submitted rule. 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation Cutpoints, 

Deficiencies, and Deviations, EPA, May 25, 1988) and the Little Bluebook 

(Guidance Document for Correcting Common VOC & Other Rule Deficiencies,

EPA Region 9, August 21, 2001) were used to evaluate compliance with the CAA 

§110(a)(2)(A) requirement for enforceability.

2. Stringency – We have compared Rule 67.16 against previous Rule 67.16, CARB’s 

Compliance Assistance Program for Graphic Arts Printing Operations, June 1992

and relevant national guidance including EPA’s Control Technique Guidelines 

(CTG) titled, Control Techniques Guidelines for Offset Lithographic Printing and 

Letterpress Printing, September 2006 (EPA-453/R-06-002), Control Techniques

Guidelines for Flexible Package Printing, September 2006 (EPA-453/R-06-003),

Control Techniques Guidelines for Industrial Cleaning Solvents, September 2006

(EPA 453/R-06-001), South Coast Air Quality Management District (SCAQMD) 

Rule 1130, Graphic Arts, amended October 8, 1999, SCAQMD Rule 1171, 

Solvent Cleaning Operations, amended February 1, 2008, Bay Area Air Quality 

Management District (BAAQMD) Rule 8-20, Graphic Arts Printing and Coating 

Operations, amended March 3, 1999 and other state and local rules for this 

category to help evaluate the RACT requirements of CAA §182(b)(2) and §182(f).

3. SIP Relaxation –SIP submittals must comply with CAA §110(l) and §193 regarding 

SIP relaxations. We have evaluated this SIP revision to determine whether it 

would interfere with any applicable requirement concerning attainment and 

reasonable further progress (RFP) or any other applicable requirement of the Act 

(CAA 110(l)) or modify, in a nonattainment area, any SIP-approved control 

requirement in effect before November 15, 1990 (CAA §193).

EPA EVALUATION - The following is EPA’s analysis of the rules based on the 

evaluation criteria:

1. Enforceability - In general, Rule 67.16 is enforceable because it is clear and 

requires appropriate recordkeeping in section (f) and testing in section (g). 

 

2. Agenda Item Memo to the Air Pollution Control Board for Public Hearing to adopt amendments to Rule 67.16 

and 11 , November 9, 2011.
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Test methods have been updated to include the most current EPA methods as 

well as recent SCAQMD and American Society for Testing and Materials (ASTM) 

test methods that have been approved by EPA. 

2. Stringency – The submitted rule generally has more stringent emission limits 

than the two 2006 CTG’s and is consistent with analogous requirements in other 

areas, such as the SCAQMD Rule 1130, Graphic Arts and Rule 1171, Solvent 

Cleaning Operations and BAAQMD 8-20, Graphic Arts Printing and Coating 

Operations.

The CTG’s basically require the 15 lb/day VOC emissions limit with no specific 

limits for material categories. Other districts have listed more graphic art material 

categories with some categories both greater than and some below the 

SDCAPCD 300 grams/liter limitFor the most part, we believe these other rules 

are not significantly more stringent than SDCAPCD Rule 67.16.

The cleaning solutions are also listed in various categories in other district rules 

and have limits both greater than and lower than SDCAPCD’s 100 grams/liter 

limit. Although both Control Techniques Guidelines for Offset Lithographic 

Printing and Letterpress Printing and Control Techniques Guidelines for Flexible 

Package Printing refer to the Control Techniques Guidelines for Industrial

Cleaning Solvents for cleaning materials, flexible packaging printing, lithographic 

printing and letterpress printing are exempt from the 50 grams/liter VOC limit for 

cleaning solvents. 

3. SIP Relaxation – Rule 67.16’s primary changes that represent strengthening are 

the lowered VOC limit for adhesives from 300 grams/liter to 150 grams/liter, the 

lowered limit of the fountain solution VOC limit from 15% by volume to 5% by 

volume and a new 8.5% VOC by volume for a new category of fountain solutions 

refrigerated below 60oF. In addition, the cleaning solution limit was lowered from 

200 grams/liter to 100 grams/liter and the vapor pressure of cleaning material 

was lowered from 45 mm Hg to 5 mm Hg. 

The exemption of large digital printing operations, provided specific 

recordkeeping is met, was made to, “...allow the District to estimate the 

magnitude of VOC emissions from digital printing and clarify whether further

control is appropriate.”3It is assumed that the VOC emissions are below the 

permit requirement threshold of 15 lbs/day calculated on a monthly basis as 

specified in SDCAPCD Rule 11, Exemptions From Rule 10 Permit Requirements, 

 

3. Socioeconomic Impact Assessment for Proposed Amended Rule 67-16, Graphic Arts Operations
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Adopted November 9, 2011 and effective May 9, 2012. Digital printing is any 

printing completed via digital files, not restricted to short runs and is able to 

provide variable printing such as incorporating data directly for a compact 

database and printing not using traditional methods of film or printing plates.4

Digital printing is a relatively new technology and the VOCs emitted have not 

been regulated by other districts nor are the emissions addressed by any printing 

CTGs. For these reasons we do not consider adding the digital printing 

exemption a relaxation of the rule, but rather an attempt to establish a new 

benchmark for an evolving technology. 

Therefore, we propose to determine that an approval of the submittal would 

comply with CAA sections 110(l) and 193 because (1) the proposed SIP revision 

would not interfere with the on-going process for ensuring that requirements for 

RFP and attainment of the NAAQS are met, and (2) the submitted SIP revisions 

are more stringent than the existing SIP requirements.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION –

The following revisions are not currently the basis for rule disapproval, but are 

recommended for the next time the rule is amended: 

1. In subsection (b)(3)(vi), please correct the reference to the definition of large 

digital printing operations from (c) (12) to (c) (13).

2. In subsection (d)(1)(i) please consider listing specific categories and lowering the 

limits to those values in SCAQMD’s Rule 1130 subsection (c) (1). Similarly, 

consider listing specific cleanup solvents and applying the limit values for graphic 

arts cleaning materials indicated in SCAQMD’s Rule 1171 subsection (c) (1) (D).

3. For consistency, please add “adhesives” in the types of materials for which a 

current list will be maintained, in subsection (f)(1)(i): “Type of graphic arts 

materials, adhesives, fountain solutions or cleaning materials used;”

4. For compliance with The Little Blue Book directives, and for accurateness, 

please correct the following in section (g):

a. In subsection (g)(1), please change the reference to EPA Test method 24

to (40 CFR 60, Appendix A-7) and, for consistency, please remove the 

date, 9/1/1995. Please specify SCAQMD Test Method 304-91, add the 

title, “Determination of Volatile Organic Compounds (VOC) in Various 

Materials” and correct the date to “February, 1996”

b. In subsection (g)(2), please correct the EPA Test Method 24 to (40 CFR 

60, Appendix A-7) and, for consistency, delete the date 8/6/1993.

c. In subsection (g)(3), please correct the dates for SCAQMD’s test method 

313-91 from 2/1/1993 to June,1993 and for SCAQMD test method 313-91 

from 2/1/1993 to February, 1993.

 

4. EIIP Volume II, Chapter 15, Preferred and Alternate Methods for Estimating Air Emissions From the Printing, 

Packaging, and Graphic Arts Industry, May 2002, page 15.2-3
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d. In subsection (g)(4), please correct the title for the District’s “Procedure for 

Estimating the Vapor Pressure of VOC Mixtures” to the District’s “County 

of SDAPCD’s Procedures for Estimating the Vapor Pressure of VOC 

Mixtures.” Similarly, please correct the title of the ASTM method in the 

same subsection to “Standard Test Method for Vapor PressureTemperature Relationship and Initial Decompensation Temperatures of 

Liquids by Isoteniscope.”

e. In subsection (g)(6), please correct the dates for SCAQMD’s test method 

303-91 from 8/1/1993 to August,1993.

f. In subsection (g)(7), please correct the reference to EPA Test Method 25 

A and /or 18 to (40 CFR 60, Appendix A-7 and A-6) and remove the date 

9/25/1996. Similarly, change the reference to EPA Test Methods 204 and 

204A through 204F to (40 CFR 51, appendix M) and remove the date 

6/4/97. 

EPA ACTION – The rule largely fulfills the relevant CAA §110 and Part D requirements. 

EPA staff recommends approval of Rule 67.16 pursuant to CAA §110(k)(3) and 

§301(a).

ATTACHMENTS -

1. SDAPCD Rule 67.16, Graphic Arts Operations, Adopted November 9, 2011 and 

Effective May 9, 2012.

2. SDAPCD Rule 67.16, Graphic Arts Operations, Adopted and Effective May 15, 

1996.

ADDITIONAL REFERENCES –

1. EPA’s Control Techniques Guidelines for Industrial Cleaning Solvents (EPA 

453/R-06-001), September 2006

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r-06-

001_ind_cleaning_solvents.pdf

2. EPA’s Control Techniques Guidelines for Offset Lithographic Printing and 

Letterpress Printing (EPA-453/R-06-002) September 

2006http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r-06-

002_litho_letterpress_printing.pdf

3. EPA’s Control Techniques Guidelines for Flexible Package Printing 

(EPA-453/R-06-003) September 2006

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r-06-

003_flexible_package_printing.pdf

4. CARB’s Compliance Assistance Program “Graphic Arts Printing Operations 

Technical Manual”, June 1992

5. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” 

(a.k.a., Bluebook), EPA OAQPS, May 25, 1988.

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf
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6. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” 

(a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.

http://www.epa.gov/Region09/air/sips/littlebluebook2001.pdf