UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Placer County Air Pollution Control District, 

Rule 239, 

Graphic Arts Operations

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

December 2013
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RULE IDENTIFICATION

Agency: Placer County Air Pollution Control District (PCAPCD)

SIP-Approved Rule: Rule 239 – Graphic Arts Operations

Adopted – November 3, 1994

Amended – February 13, 1997

Submitted – August 1, 1997

Approved – November 13, 1998 (63 FR 63410)

Subject of this TSD: Rule 239 – Graphic Arts Operations

Amended – October 11, 2012

Submitted – February 6, 2013

RULE SUMMARY – PCAPCD Rule 239 limits the emissions of Volatile Organic 

Compounds (VOCs) from graphic arts operations in the District. It had been 

previously adopted and revised and approved by EPA into the State Implementation 

Plan (SIP). However, that version of the rule did not fully address EPA’s 2006 

Control Techniques Guideline (CTG), Control of VOC Emissions from Offset 

Lithographic and Letterpress Printing (EPA-453/R-06-002), and California Air 

Resources Board’s (CARB) 1992 Graphic Arts Printing Operations Compliance 

Assistance Manual which recommends limits based on South Coast Air Quality 

Management District’s (SCAQMD) Rules 1130, Graphic Arts, and 1130.1, Screen 

Printing Operations, Bay Area Air Quality Management District (BAAQMD) Rule 20, 

Graphic Arts Printing and Coating Operations, and Ventura County Air Pollution 

Control District’s (VCAPCD) Rule 74.19, Graphic Arts.

In Section 100, partial exemptions for facilities emitting less than 660 pounds of 

VOC and for Proof Presses and/or Research and Test Development Operations 

and a full exemption for Screen Printing Operations were deleted. Exemptions for 

Stripping of Cured Inks, Provisions covered in Rule 219, Organic Solvents, Coatings 

or Adhesives, Business and Personal Printers, Aerosol Adhesives for Screen 

Printing and Graphic Arts Operations, Fountain Solutions, Blanket Repair Materials
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and Heatset Web Offset Lithographic Printing and Heatset Web Letterpress Printing

were added. 

In Section 200, Definitions, several definitions were revised for clarity. Definitions 

for Aerosol Adhesive; Alcohol; Application Equipment; Blanket; Blanket Repair 

Material; Blanket Washes; Closed Container; Cured Ink, Cured Coating, or Cured 

Adhesives; Electronic Circuit; Embossing, Extreme Performance Ink/Coating; Heater 

or Dryer; Heat Bending; Heatset Ink; Ink Jet; Inflating; Maintenance Cleaning; 

Material; Mechanically Formed Products; Metallic Ink; Metering Roller; Noncompliant 

Material; Overlay; Prepress Operations; Printing; Printing Ink; Proof Press; Proof 

Press Component; Refrigerated Chiller; Removable Press Component; Repair 

Cleaning; Roller Wash; Sign Ink/Coating; Solvent Cleaning; Specialty Flexographic 

Printing; Stationary Source; Stripping; Substrate; Ultraviolet Ink; Vacuum-forming; 

VOC Composite Partial Pressure; VOC Content; Water Slide Decals; and Wipe 

Cleaning were added. Definitions for Capture Efficiency; Control Device Efficiency; 

Doctor Blade, Itaglio Printing, Packaging Gravure Printing; Porous Substrate; 

Production Unit; Publication Gravure Printing; Specialty Gravure Printing; VOC 

Content of Fountain Solutions, Makeup Solvents, Surface Preparations Solvents and 

Cleaning Solvents; and VOC of Inks, Coatings and Adhesives were deleted. 

Actual VOC limits for Inks, Coatings and Adhesives and for Fountain Solution 

Materials were added in Section 300. Requirements for Emission Control 

Equipment were added and Cleaning and Storage Requirements were expanded to 

include limits for specific cleaning materials. 

Section 400 was revised to delete the previous Operation and Maintenance Plan 

and Compliance Statement Requirements and add Product Information requirements 

as well as calculations for determining Percent Control Efficiency, VOC Mass 

Emission Rate and VOC Emissions for Stationary Sources. 

Section 500 now includes a List of Material which includes the information required 

for each type of material and the Usage Records subsection has been revised for

clarification and to include more product information. Recordkeeping of Emission 

Control Equipment was added and the Duration of Records was revised to include 
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records for sources subject to the Federal Operating Permit Program. The Test 

methods of subsection 502 were expanded to include Determination of VOC 

Composite Partial Pressure, Determination of Vapor Pressure and Determination of 

Metal Content in Inks tests. 

The Sacramento Region has been designated as a severe nonattainment area for 

the federal ozone standard by the EPA. The District is therefore required to meet 

RACT. 

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

Rule:

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 help evaluate compliance with the CAA 

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

Stringency - Rule 239 was evaluated against EPA’s CTG titled, “Control Techniques 

Guidelines: Control of VOC Emissions from Offset Lithographic and Letterpress 

Printing (EPA-453/R-06-002, September 2006) to evaluate the RACT 

requirements of CAA §182(b)(2). Rule 239 was also compared to other Districts’ 

rules for graphic arts operations. 

SIP Relaxation - 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).

RULE EVALUATION
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Enforceability - PCAPCD’s Rule 239 specifies clear, unambiguous terminology that 

closely resembles the definitions of VCAPCD Rule 74.19, Graphic Arts. Each type of 

graphic art coating, adhesive and solvent is described in section 200 and 

distinguished from other categories that are clearly delineated in the limits tables in 

section 301 and 303. Cleaning and storage requirements are clearly described in 

section 303. While the Emission Control System requirements of section 302 do not 

specify equipment, they do clearly indicate the required parameters. The requirement 

for monitoring and for submitting records in section 500 further strengthens this 

Rule’s enforceability. Test methods are similar to those in SMAQMD’s Rule 466. 

Stringency - PCAPCD’s Rule 239, Graphic Arts Operations, is largely consistent 

with the EPA CTG: Control of VOC Emissions from Offset Lithographic and 

Letterpress Printing and other current rules by other Districts. As a result, we believe 

this Rule fulfills RACT requirements.

Relaxation - We propose to determine that our approval of the submittal would 

comply with CAA §§ 110(l) and 193 because the proposed rule will not interfere with 

the ongoing process for ensuring that the requirements for RFP and attainment of 

the National Ambient Air Quality Standards (NAAQS) are met and because the

emission limits in the submitted Rule are more stringent than the existing SIPapproved control requirements that they would replace.

RULE DEFICIENCIES – We have identified no deficiencies in submitted Rule 239’s 

that would interfere with approval of this Rule.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – The 

following revisions are not currently the basis for Rule disapproval, but we encourage 

PCAPCD to consider these recommendations the next time the Rule is amended:
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1. We recommend that the exempt solutions and operations in subsections 

104.1, General Exceptions, 104.7, Aerosol Adhesives – Graphic Arts 

Operations, 104.8, Fountain Solutions and 104.10, Heatset Web Offset 

Lithographic Printing and Heatset Web Letterpress Printing, be required to 

have daily reporting instead of monthly reporting as described in subsections 

501.3.2, 502.3.3 and 501.3.4. 

2. Consider lowering the solvent cleaning limits in subsection 303.1 to the lower 

limits required in SCAQMD Rule 1171, Solvent Cleaning Operations, effective 

1/1/2010. We recommend the following solvent limits:

Material Type Actual VOC Content g/l (lb/gal)

General (e.g maintenance, repair, 

wipe) cleaning

25(0.21)

Application Equipment Cleaning

General (not specifically listed below) 25(0.21)

Lithographic and Letter Press Printing, 

Blanket and Roller Washes and Other 

On-Press Components 

100(.83)

Lithographic and Letter Press Printing, 

Other Cleaning

25(0.21)

Screen Printing 100(.83)

Flexographic Printing 25(0.21)

Specialty Flexographic Printing 100(.83)

Ultraviolet Inks (except Screen 

Printing)

100(.83)

EPA ACTION - EPA staff recommends an approval of Rule 239 pursuant to CAA 

§110(k)(4) and §301(a). 
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ADDITIONAL REFERENCES –

1. PCAPCD Rule 239 – Graphic Arts Operations, amended 

 February 13, 1997.

2. PCAPCD Rule 239 – Graphic Arts Operations, amended October 11, 2012, 

submitted February 6, 2013.

3. SCAQMD Rule 1130 – Graphic Arts, Amended October 8, 1999.

4. SCAQMD 1130.1 – Screen Printing Operations, Amended December 13, 

1996.

5. SCAQMD Rule 1171 – Solvent Cleaning Operations, amended May 1, 2009.

6. SDAPCD Rule 67.16 – Graphic Arts Operations, Adopted November 9, 2011, 

Effective May 9, 2012.

7. VCAPCD Rule 74.19 – Graphic Arts, Revised June 14, 2011.

8. Control Techniques Guidelines (CTG): Control Techniques Guidelines for 

Offset Lithographic Printing and Letterpress Printing, EPA 435/R-06-002, 

September, 2006.

http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/200609_v

oc_epa453_r-06-002_litho_letterpress_printing.pdf

9. “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