SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

FINAL STAFF REPORT

Proposed Amended Rule 1130 - Graphic Arts

MAY 2014

Deputy Executive Officer,

Planning, Rule Development, and Area Sources

Elaine Chang, Dr. PH

Assistant Deputy Executive Officer,

Planning, Rule Development, and Area Sources

Philip M. Fine, Ph.D.

Planning and Rules Manager,

Planning, Rule Development, and Area Sources

Naveen Berry

______________________________________________________________________________

AUTHOR: Don Hopps AQ Specialist

REVIEWED BY: David Ono Program Supervisor

Laki Tisopulos, Ph.D., P. E. Assistant Deputy Executive Officer

Karin Manwaring Senior Deputy District Counsel

CONTRIBUTORS: Jeff Inabinet AQ Specialist/CEQA

Shah Dabirian AQ Specialist/Socioeconomics
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

GOVERNING BOARD

CHAIRMAN: DR. WILLIAM A. BURKE

Speaker of the Assembly Appointee

VICE CHAIRMAN: DENNIS YATES

Mayor, Chino

Cities of San Bernardino

MEMBERS:

MICHAEL D. ANTONOVICH 

Supervisor, Fifth District

County of Los Angeles

BEN BENOIT

Mayor Pro Tem, Wildomar

Cities of Riverside County

JOHN J. BENOIT

Supervisor, Fourth District

County of Riverside

JOE BUSCAINO

Councilmember, Fifteenth District

City of Los Angeles 

MICHAEL A. CACCIOTTI

Councilmember, South Pasadena

Cities of Los Angeles County/Eastern Region

JOSIE GONZALES

Supervisor, Fifth District

County of San Bernardino

JOSEPH K. LYOU, Ph. D.

Governor’s Appointee

JUDITH MITCHELL

Mayor, Rolling Hills Estates

Cities of Los Angeles County/Western Region

SHAWN NELSON

Supervisor, Fourth District

County of Orange

DR. CLARK E. PARKER, SR.

Senate Rules Appointee

MIGUEL A. PULIDO

Mayor, Santa Ana

Cities of Orange County

EXECUTIVE OFFICER: BARRY R. WALLERSTEIN, D. ENV.
TABLE OF CONTENTS

EXECUTIVE SUMMARY

EXECUTIVE SUMMARY ............................................................................................................................................................. ES-1

CHAPTER 1 – BACKGROUND ON PROPOSED AMENDED RULE 1130

INTRODUCTION .............................................................................................................................................................................. 1-1

REGULATORY HISTORY ............................................................................................................................................................... 1-1

AFFECTED FACILITIES .................................................................................................................................................................. 1-1

OFFSET LITHOGRAPHYPROCESS DESCRIPTION ....................................................................................................................... 1-2

CHAPTER 2: SUMMARY OF PROPOSED AMENDED RULE 1130

OVERVIEW:PROPOSED AMENDMENT TO RULE 1130 ............................................................................................................. 2-1

SUBDIVISION (A)PURPOSE AND APPLICABILITY ...................................................................................................................... 2-1

SUBDIVISION (B)DEFINITIONS .................................................................................................................................................... 2-1

SUBDIVISION (C)REQUIREMENTS ............................................................................................................................................... 2-4

SUBDIVISION (D)PROHIBITION OF SPECIFICATION AND SALE ................................................................................................ 2-8

SUBDIVISION (F)RULE 442APPLICABILITY .............................................................................................................................. 2-9

SUBDIVISION (G)EMISSION REDUCTION CREDITS ................................................................................................................... 2-9

SUBDIVISION (H)TEST METHODS ............................................................................................................................................... 2-9

SUBDIVISION (I)EXEMPTIONS ................................................................................................................................................... 2-12

CHAPTER 3: IMPACT ASSESSMENT OF PROPOSED AMENDED RULE 1130

EMISSION IMPACT ASSESSMENT ................................................................................................................................................. 3-1

COST ANALYSIS ............................................................................................................................................................................ 3-1

CONTROL DEVICE EFFICIENCY ................................................................................................................................................... 3-1

FOUNTAIN SOLUTIONS ................................................................................................................................................................. 3-1

STORAGE OF CERTAIN NON-COMPLIANT VOC-CONTAINING MATERIALS.......................................................................... 3-1

INCREMENTAL COST-EFFECTIVENESS ..................................................................................................................................... 3-12

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) ........................................................................................................ 3-2

SOCIOECONOMIC IMPACT ASSESSMENT .................................................................................................................................... 3-2

DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY CODE 40727 ........................................................................ 3-2

COMPARATIVE ANALYSIS ........................................................................................................................................................... 3-3

DRAFT CONCLUSIONS AND RECOMMENDATIONS ................................................................................................................... 3-3

PUBLIC COMMENTS AND RESPONSES ........................................................................................................................................ 3-3

REFERENCES ..................................................................................................................................... R-1

APPENDIX A-VOCEMISSION CALCULATION METHODOLOGY FOR LITHOGRAPHIC PRINTING OPERATIONS ............. A-1

APPENDIX B -DETERMINING COLLECTION EFFICIENCIES FOR AIR POLLUTION CONTROL SYSTEMS SERVING

HEAT-SET LITHOGRAPHIC PRINTING PRESSES..........................................................................................................................B-1

LIST OF TABLES

TABLE 1-SICCODES USED FOR PAR1130 .............................................................................................................................. 1-1

TABLE 2-PERMITTED EQUIPMENTAND PERCENTAGE DISTRIBUTION ................................................................................. 1-1

TABLE 3–PROPOSED TABLE OF STANDARDS I ....................................................................................................................... 2-4

TABLE 4-CONVERSION OF PERCENTAGE OF VOCVALUES TO MASS/VOLUME VOCVALUES ...................................... 2-5

TABLE 5–PROPOSED TABLE OF STANDARDS II .................................................................................................................... 2-67

i
EXECUTIVE SUMMARY
Executive Summary Final Staff Report

EXECUTIVE SUMMARY

Rule 1130 – Graphic Arts - is a source specific rule that was adopted to limit Volatile Organic 

Compound (VOC) emissions associated with graphic arts operations. The rule applies to any 

person who supplies, sells, markets, offers for sale, distributes, applies or solicits the application

of graphic art materials for use in any graphic arts operation in the District. Rule 1130 was 

adopted on October 3, 1980 and has been subsequently amended fourteen times; the most recent 

amendment was October 8, 1999.

Staff conducted an internal review of Rule 1130 to determine if the existing rule met all the 

recommendations specified by the United States Environmental Protection Agency’s (U.S. EPA) 

Control Techniques Guidelines (CTG) for Offset Lithographic Printing and Letterpress Printing 

(EPA 453/R-06-002) and Flexible Package Printing (EPA 453/R-06-003). As a part of the 2012 

AQMP development, staff found inconsistencies between the CTG and Rule 1130 and 

recommends amending Rule 1130 to ensure the level of stringency in the applicable CTGs.

The proposed amendment partially implements the 2012 AQMP, Control Measure CTS-02-

Further Emission Reductions from Miscellaneous Coatings, Adhesives, Solvents and Lubricants

and the Reasonably Available Control Measures (RACM) Demonstration of Appendix VI. Since 

local affected operations already comply with the requirements, the proposed amendments are 

not expected to achieve additional VOC reductions. 

PROPOSAL

The amendment to Rule 1130 proposes making changes to improve consistency with the CTGs 

applicable to printing operations regulations by amending the overall add-on control device 

efficiency requirements and VOC content limits for fountain solutions. The proposed 

amendment further adds prohibition of storage of non-compliant VOC-containing materials at a 

worksite, removes obsolete rule language, updates definitions for consistency with other District 

rules, adds an exemption for graphic arts materials that have a VOC content of no more than 10 

g/L, as applied, and makes minor corrections and clarifications.

CEQA

In accordance with the California Environmental Quality Act (CEQA), the SCAQMD is the 

Lead Agency and has prepared a Draft Environmental Assessment (EA) to analyze 

environmental impacts from the proposed project pursuant to its certified regulatory program 

(SCAQMD Rule 110). The Draft EA includes a project description and analysis of potential 

adverse environmental impacts that could be generated from the proposed project. Comments 

focusing on issues relative to the environmental analysis for the proposed project will bewere 

accepted during a 30-day public review and comment period beginning February 25, 2014, and 

ending 5 p.m. on March 26, 2014.

SOCIO-ECONOMIC

The proposed amendments codify existing practices at graphic arts operations that are subject to 

Rule 1130. As such, there will no additional costs or other socioeconomic impacts.

Proposed Amended Rule 1130 ES-1 May 2014
RULE 1130 – GRAPHIC ARTS

CHAPTER 1: BACKGROUND ON PROPOSED AMENDED RULE 1130

ο Introduction

ο Regulatory History

ο Affected Facilities

ο Offset Lithography Process Description
Chapter 1: Background on Proposed Amended Rule 1130 Final Staff Report

INTRODUCTION

Rule 1130 – Graphic Arts is a source specific rule that was adopted to limit Volatile Organic 

Compound (VOC) emissions associated with graphic arts operations. The rule applies to any 

person who solicits, specifies, offers for sale, sells, or distributes graphic arts materials for use in 

the District. This rule amendment is driven by inconsistencies identified between Rule 1130 with 

the United States Environmental Protection Agency’s (U.S. EPA) Control Techniques Guidelines 

(CTG) for Offset Lithographic Printing and Letterpress Printing (EPA 453/R-06-002) and Flexible 

Package Printing (EPA 453/R-06-003).

REGULATORY HISTORY

Rule 1130 was adopted on October 3, 1980 and has been subsequently amended fourteen times. 

The most recent amendment was on October 8, 1999, which further reduced VOC emissions, 

required higher efficiencies for add-on controls, eliminated the small user exemption, and specified

retention factors for lithographic inks.

AFFECTED INDUSTRIES

Rule 1130 is applicable to any person who solicits, specifies, offers for sale, sells, or distributes 

graphic arts materials for use in the District. Using the Standard Industrial Classification (SIC) 

codes, staff conducted a search in the Automated Equipment Inventory Systems (AEIS) database 

to find industries that conduct graphic arts operations. Table 1 shows the following SIC codes that 

apply to this proposed rule amendment.

TABLE 1 – SIC CODES USED FOR PAR1130

PAR1130 - SIC CODES USED

2399 5112 2731 7336 2711

2672 2732 3993 2396 2761

3089 2753 7384 2754 9999

7011 2771 3569 2741 2759

2260 3199 2750 2329 2752

2893 2721 2782 2751

Using the SIC codes in Table 1, staff surveyed the active facilities with active permits in AEIS for 

all graphic arts printing operations and categorized the active permits per county as shown in Table 

2.

TABLE 2 – PERMITTED EQUIPMENT AND PERCENTAGE DISTRIBUTION

COUNTY NUMBER OF

PERMITS PERCENTAGE

Los Angeles county 403 69%

Orange county 146 25%

Riverside county 31 4%

San Bernardino county 15 2%

SCAQMD Jurisdiction 587 100%

Proposed Amended Rule 1130 1-1 May 2014
Chapter 1: Background on Proposed Amended Rule 1130 Final Staff Report

However, there are some printing operations with low emissions potential that are exempt from 

permitting based on District Rule 219 – Equipment Not Requiring a Written Permit Pursuant To 

Regulation II but would continue to be subject to Rule 1130.

OFFSET LITHOGRAPHY PROCESS DESCRIPTION

Offset lithography is a common printing process that is used to produce large volumes of 

brochures, books, magazines, posters and newspapers and is the primary focus of the proposed 

amendment. Offset lithography is a planographic method of printing which means that the printing 

and non-printing areas are in the same plane on the surface of a thin lithographic plate. The inked 

image is transferred, or offset, from the plate to a rubber blanket cylinder and from that, to the 

substrate. The ink that is transferred to the lithographic plate contains the image area, which

receives the oil based ink, and the non-image area, which is wetted with a water based solution, 

called the fountain solution, that provides a film that repels the ink. Since oil and water don’t mix, 

the image area is transferred to the printing surface of the substrate whereas the non-image areas 

do not receive ink and thus no ink transfer occurs. There are two subsets of offset lithography 

printing and they are characterized by the way they are fed into the press, sheet-fed and web-fed 

printing. Both sheet-fed and web-fed printing inks dry by a combination of absorption and 

oxidation.

Sheet-Fed Offset Lithographic Printing Process

Sheet-fed printing refers to feeding individual sheets of paper or other substrate to the press. 

Sheet-fed operations consist of a lithographic plate in which oil-based ink and water based 

fountain solutions are used for the printing operation. Sheet-fed printing generally consists of 

short-run operations for products such as magazines, brochures, letter heading and other similar 

type printing.

Web-Fed Offset Lithographic Printing Process

Web-fed printing refers to feeding rolls of paper or other substrate to the press. Web-fed printing 

consists of a lithographic plate in which oil-based ink and water based fountain solutions are used

for the printing process. Web-fed printing generally consist of large volume run operations that 

can be run at high speeds for products such as magazines, brochures, letter heading and other 

similar type printing. There are two subsets for web-fed offset lithographic printing presses, 

heatset and coldset. 

Heatset Offset Web Presses

Heatset offset web presses are used for both coated and non-coated substrates such as magazines, 

catalogs, inserts and other medium-to-high volume production runs where the inks dry by 

evaporation due to the application of heat. The typical process uses a coated web that is fed into 

the press, ink is applied to the substrate and the ink dries by the heat applied by a dryer. The 

heated substrate is then cooled down by chilled rollers which are used to set the ink.

Proposed Amended Rule 1130 1-2 May 2014
Chapter 1: Background on Proposed Amended Rule 1130 Final Staff Report

Coldset (non-heatset) Offset Web Presses

Coldset offset web presses, also known as non-heatset web presses, are typically used for uncoated 

substrates such as newspaper where the ink dries by absorption into the paper and by evaporation. 

However, some coldset presses may use ultraviolet or electron beam inks that cure by ultraviolet or 

electron beam polymerization for generally higher quality printing products. In some cases, a 

coldset press may be fitted with heat dryers that have the capability to print color pages heatset and 

also print white pages coldset. For the purposes of Rule 1130, ultraviolet and electron beam 

curable inks are examples of non-heatset inks and can be used on heatset web,and non-heatset web, 

and sheet-fed presses.

Flexographic Printing

Flexographic printing is direct rotary printing using a rubber or polymer printing plate with raised 

images. The ink is applied to the plate by an anilox roller consisting of minute etched cells, which 

hold ink and transfer ink to the flexible printing plate. A doctor blade that swipes excess ink from 

the roller, controls ink deposition. Most flexographic presses are web-fed and capable of printing 

four-color work on a continuous stream of substrate.

Letterpress Printing

Letterpress is high-speed quality printing and the a method of printing is the same as flexographic 

printing. That is, where the image areas are raised above the printing plate although the raised 

images are metal, rather than elastomeric non-image areas.

Gravure Printing

Gravure or rotogravure printing is a method of printing that uses Aan engraved negative 

cylinderaccomplishes gravure printing. The roller has tiny cells and dots of various sizes and 

depths. Ink is applied by another roller or bath and a flexible metal doctor blade screeds scrapes 

excess ink leaving only the cells or dots with coverage. Paper is fed between the inked printing 

cylinder and an impression roller coated with a resilient blanket. This method of printing produces 

high quality. Both sheet-fed and web-fed configurations are used.

Offset Lithographic Inks

Offset Lithographic printing inks are paste inks and contain pigments, vehicles, binders and other 

additives. The pigments contain the desired color, the vehicle is the solvent that carries the 

pigment and binder, the binders fix the pigment to the substrate and the additives contain waxes, 

lubricants and driers. The inks are generally composed of also contain petroleum and vegetable 

oils. Some printing operations may use varnishes, essentially an ink without pigmentation. 

Heatset inks may contain up to 45% VOCs. In heatset web lithographic printing, 20% of the 

petroleum ink oils and essentially all of the vegetable ink oils are retained in the substrate and dry 

ink film. The remaining 80% of the petroleum ink oil is volatilized in and then exhausted from the 

dryer. Since the vegetable ink oil does not volatilize in the dryer, the amount of vegetable ink oil 

that can be used in heatset web offset lithographic inks is very limited. If there is too much 

vegetable oil in a heatset web offset lithographic ink, the ink will not dry properly. Coldset inks 

typically contain below 35% VOC and sheet-fed inks contain below 25% VOC. In sheet-fed and 

Proposed Amended Rule 1130 1-3 May 2014
Chapter 1: Background on Proposed Amended Rule 1130 Final Staff Report

coldset web offset printing, 95% of the petroleum ink oils and essentially all of the vegetable oils

are absorbed into the substrate and dried ink film. The remaining 5% of the petroleum ink oil is 

volatilized and emitted to atmosphere. Ultraviolet and electron beam energy cured inks are 

normally lower VOC-containing inks. In the South Coast AQMD jurisdiction, the coatings are 

predominately water based or energy cured materials having low VOC emissions.

SCAQMD guideline for calculating emissions for annual reporting pursuant to Rule 304 – Fees 

“VOC Emission Calculation Methodology for Lithographic Printing Operations – December 

2011” (see Appendix A) outlines the use of the aforementioned parameters, as well as additional 

considerations for annual emission reporting purposes.

Fountain Solution

Fountain solutions are used in the offset lithographic printing process and are primarily composed

of water with certain additives to moisten the non-image area of the lithographic plate in order to 

keep ink from depositing (and thus printing) in areas where the ink is not wanted. Since offset 

lithographic inks are oil based and the fountain solution water based, the fountain solution renders 

the non-image areas unreceptive to ink and thus the ink is not transferred. The fountain solution 

contains a small amount of gum Arabic or synthetic resins, acids, and buffer salts to maintain the 

pH of the solution. Alcohols, including isopropanol, n-propanol and ethanol, are typically added 

to the water to lower the surface tension and increase the viscosity of the fountain solution. The 

alcohol substitute based fountain solutions are formulated using no alcohol and are typically glycol 

ethers or ethylene glycol ethers for lower VOC emissions but still provide the same purpose 

function as the alcohol containing fountain solutions. Fountain solutions are packaged as either a 

“one-step” or “two-step” product. Fountain solutions consist of a concentrate of chemicals that are

mixed with a large volume of water, typically 2 to 6 ounces of concentrate to one gallon of water, 

and alcohol or alcohol substitute, generally requiring two steps to make a press-ready solution. 

Historically, the alcohol was added in amounts of up to 25% of the solution to provide wetting to 

the dampening rollers and the non-image areas of the printing plates and, due to the amount of 

alcohol used, could not be packaged with the concentrate. With lower alcohol or alcohol substitute 

requirements, combining the concentrate with the wetting agent as a single or one-step formulation 

became available.

On larger presses, Tthe “press-ready” fountain solution is stored in a reservoir which is a collection 

tank that serves to hold the fountain solution while it is continuously recirculated from the 

reservoir to the fountain trays used at the printing working area. Smaller presses do not use a 

recirculation system, but dispense the fountain solution from small containers that are affixed to 

the press. The fountain tray simply holds a small amount of fountain solution and by constant 

recirculation; the fountain solution not only provides a film for non ink retention but also serves to 

cool the lithographic plate printing unit. The fountain solution reservoir typically is equipped with 

cooling coils for refrigeration of the fountain solution. The reservoir volume does not include the 

volume of the trays or any other additional containers such as mixing units.

Proposed Amended Rule 1130 1-4 May 2014
Chapter 1: Background on Proposed Amended Rule 1130 Final Staff Report

Clean-up materials

Printing operations use clean-up materials to remove printing inks, oils and residual paper 

filaments from the press equipment during and after operations. Clean-up materials are generally 

organic, however due to the VOC requirements of Rule 1171 – Solvent Cleaning Operations, many 

new cleaning materials are now manufactured from low-VOC materials such as aqueous and soy 

based materials.

Emissions Control Systems

Emission control systems are used in some graphic arts operations to reduce VOC emissions. The

emission control system is another major strategy in the reduction of VOCs from offset 

lithographic printing operations. The capture system consists of equipment capable of collecting 

the emissions generated from the printing process and transferring the emissions to a control 

device. The control device is generally a thermal oxidizer or catalytic oxidizer and is used to 

destroy the emissions. 

The CTG recommended 90% control efficiency in the 1993 draft CTG and 95% control efficiency 

for a control device for equipment that was installed after the date of the current CTG, September 

2006. The current version of Rule 1130 requires overall efficiency for flexography, packaging 

gravure, lithography and letterpress printing to be 75% or greater overall control efficiency 

(publication gravure requires 85% control device efficiency). 

Staff identified 29 active permitted air pollution control devices in the AEIS records, all of which 

meet the recommended CTG levels.

The CTG does not recommend capture and control of VOC emissions from sheet-fed or coldset

web inks because the VOC emissions from these operations are already low, are not amenable to 

add-on control and inks can meet the lower VOC content limits. Fountain solutions containing 

VOCs alcohol can be controlled by refrigerated cooling coils in the fountain reservoir where the 

temperature is of the fountain solution is maintained at 55 degrees Fahrenheit or less to control 

volatilization. 

In lieu of requiring a source test to determine the collection efficiency, the SCAQMD allows

companies to use a collection (capture) efficiency default value of 99.5 percent for heat-set

lithographic printing, provided the operator can demonstrate that there is always sufficient air flow 

into the dryer through all the dryer’s openings (excluding the exhaust stack) to prevent emissions 

from escaping the dryer during normal operations. This approach reflects the CTG determination 

that heatset lithographic printing inks, which are paste-like in nature with an initial high boiling 

point, volatilize only in the dryer. Lacking any physical evidence to the contrary (such as visible 

emissions emanating from the dryer), an operator can make this demonstration by showing that the 

pressure inside the dryer is always negative (lower) relative to the static pressure of the press room 

by either of the methods specified in the SCAQMD’s “Compliance Advisory – Determining 

Collection Efficiencies for Air Pollution Control Systems Serving Heat-Set Lithographic Printing 

Presses, 1997.” Appendix B includes a copy of this advisory.

Proposed Amended Rule 1130 1-5 May 2014
RULE 1130 – GRAPHIC ARTS

CHAPTER 2: SUMMARY OF PROPOSED AMENDED RULE 1130

ο Overview: Proposed Amendment to Rule 1130

ο Subdivision (a) Purpose and Applicability

ο Subdivision (b) Definitions

ο Subdivision (c) Requirements

ο Subdivision (d) Prohibition of Specification and Sale

ο Subdivision (g) Emission Reduction Credits

ο Subdivision (h) Test Methods

ο Subdivision (i) Exemptions
Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

OVERVIEW: PROPOSED AMENDMENT TO RULE 1130

The proposed amendment incorporates certain CTG recommendations applicable to printing 

operations not included in the current rule that pertain to the overall add-on control device 

efficiency and VOC content requirements for fountain solutions. The proposed amendment 

further adds prohibition of storage of non-compliant VOC-containing materials at a worksite, 

removes obsolete rule language, updates definitions for consistency with other District rules, 

adds a rule exemption for graphic arts materials that have a VOC content of no more than 10 g/L, 

as applied, and makes minor corrections and clarifications, including associated section 

renumbering.

Subdivision (a) Purpose and Applicability

Staff proposes the following revisions to subdivision (a) to further clarify the purpose and 

applicability:

“The purpose of this rule is to reduce emissions of vVolatile oOrganic cCompounds (VOC) 

emissions from graphic arts operations. The This rule applies to any persons performing graphic 

arts operations or who solicit, specify, offer for sale, sell, or distribute supplies, sells, offers for sale, 

markets, manufactures, blends, repackages, stores at a worksite, distributes, applies or solicits the 

application of graphic arts materials for use in the District.”

Subdivision (b) Definitions

Staff proposes the following revision to the definition “Aerosol Coating Product” to make it 

consistent with the “Aerosol Coating Product” definition in other Regulation XI rules.

“(1) AEROSOL COATING PRODUCT is a pressurized coating product containing 

pigments or resins that dispenses product ingredients by means of a propellant, and 

is packaged in a disposable can for hand-held application, or for use in specialized 

equipment for ground marking and traffic- marking applications.”

Staff proposes to add new definitions to the rule to define “Alcohol” and “Alcohol Substitute”:

“(2) ALCOHOL is an organic compound that contains a hydroxyl (OH) group and is 

used in the fountain solution to reduce the surface tension and increase the viscosity 

of water to prevent piling (ink build-up). For purposes of this rule, alcohol 

includes, but is not limited to, isopropyl alcohol (isopropanol), n-propanol and 

ethanol.”

“(3) ALCOHOL SUBSTITUTE is an additive that contains VOCs but no alcohol and is 

used in the fountain solution to reduce the surface tension and increase the viscosity

of water to prevent piling (ink build-up).”

Staff proposes the following revision to the definition “Coating” to make it consistent with the 

“Coating” definition in other Regulation XI rules.

Proposed Amended Rule 1130 2-1 May 2014
Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

“(24) COATING is a layer of material which is applied to a substrate surface in order to 

beautify, protect, or provide a barrier to such surface in a relatively unbroken 

film.“

Staff proposes to add a new definition to the rule to define “Energy Curable Coatings, Inks and 

Adhesives” to provide clarity to energy curable graphic arts materials, and replace references to 

UV and EB materials with the definition thoughout the rule. 

“(8) ENERGY CURABLE COATINGS, INKS and ADHESIVES are single-component 

reactive products that cure upon exposure to visible-light, ultra-violet light or to an 

electron beam. The VOC content of thin film Energy Curable COATINGS, INKS 

and ADHESIVES may be determined by manufacturers using ASTM Test Method 

7767-11 “Standard Test Method to Measure Volatiles from Radiation Curable 

Acrylate Monomers, Oligomers, and Blends and Thin Coatings Made from Them.”

Staff proposes the following correction to the definition “Flexographic Printing”, “Fountain 

Solution” and “Letterpress Printing” by hypenating the word “nonimage” to “non-image.”

“(11) FLEXOGRAPHIC PRINTING is a printing method utilizing a flexible rubber or 

other elastomeric plate in which the image area is raised relative to the nonimage

non-image area.”

“(1013) FOUNTAIN SOLUTION is the solution used in offset lithographic printing which is 

applied to the image plate to maintain the hydrophilic properties of the nonimage

non-image areas. It is primarily water and contains at least one of the following 

materials: etchants such as mineral salts; hydrophilic gums; or VOC additives to 

reduce the surface tension of the solution.”

“(1821) LETTERPRESS PRINTING is a printing process in which the image area is raised 

relative to the nonimage non-image area and the ink is transferred to the substrate 

directly from the image surface.”

Staff proposes to correct a spelling error in the definition “Graphic Arts Operations.” The 

misspelled word is shown as “Opertions” and will be changed to “Operations”, then the word 

“offset” will be added to lithographic printing processes.

“(1316) GRAPHIC ARTS OPERTIONS OPERATIONS are gravure, letterpress, 

flexographic, and offset lithographic printing processes or related coating or 

laminating processes.”

Staff proposes the following revisions to the definition “Heatset Ink” to clarify the type of ink 

and to properly refer to the equipment as web-fed, not web-feed and revise the description of 

dryers as hot air high velocity dryers.

Proposed Amended Rule 1130 2-2 May 2014
Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

“(1619) HEATSET INK is an offset lithographic printing ink used on continuous webfeedfed printing presses that are equipped with hot air high velocity dryers. The ink 

dries or sets by heat induced evaporation of the ink oils and subsequent chilling of 

the ink by chill rolls.”

Staff proposes to revise the “Lithographic Printing” definition by adding “Offset” to be 

consistent with the CTG, hypenate non-image, remove metal lithographic plate since the plates 

can be made of many non-metal materials and incorporate additional rule language to enhance 

the current definition, and update all similar references to lithographic printing throughout the 

rule.

“(2526) OFFSET LITHOGRAPHIC PRINTING is a planographic printing process in which 

the image and areas are on the same plane of a thin lithographic plate and are 

chemically differentiated. The ink film is transferred from the lithographic plate to 

an intermediary surface, a rubber covered cylinder called a blanket, which, in turn, 

transfers the ink to the substrate. This printing process differs from other printing 

processes where the image is typically printed from a raised or recessed surface.”

“(2224) NON-HEATSET INK is an offset lithographic printing ink that sets and dries by 

absorption into the substrate, and hardens by ambient air oxidation that may be 

accelerated by the use of infrared light sources. For the purposes of this definition 

ultraviolet and electron-beam energy curable inks are examples of non-heatset 

inks.”

Staff proposes the following revisions to the definition “Matte Finish Ink” and “Metallic Ink” to 

clarify the type of printing ink and then change the word “applied” to the word “used”, to be 

consistent with the applicability purposes of this rule.

“(2022) MATTE FINISH INK is a flexographic printing ink which is applied used on nonporous substrates in flexographic printing operations and contains at least five (5) 

percent by weight silicon dioxide flattening agent.”

“(2123) METALLIC INK is a flexographic printing ink which is applied used on non-porous 

substrates in flexographic printing operations and contains at least 28 percent by 

weight elemental metal particles.”

Staff proposes the following revision to the definition “Solvent Cleaning” to make it consistent 

with the “Solvent Cleaning” definition in other Regulation XI rules.

“(3437) SOLVENT CLEANING is the removal of loosely held uncured adhesives, uncured 

inks, uncured coatings, and contaminants including, but not limited to, dirt, soil, and 

Proposed Amended Rule 1130 2-3 May 2014
Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

grease from parts, products, tools, machinery, equipment and general work areasis 

as defined in Rule 1171 – Solvent Cleaning Operations.”

Staff proposes to add the title of the referenced rule (Rule 102) to the current definition.

“(3639) VOLATILE ORGANIC COMPOUND (VOC) is as defined in Rule 102 - Definition 

of Terms.”

Staff proposes to correct the term “Web-Feed” to “Web-Fed.” The current version of Rule 1130 

specifies “WEB-FEED” but the term is actually “WEB-FED.”

“(3740) WEB-FEED WEB-FED is an automatic system which supplies substrate from a 

continuous roll, or from an extrusion process.”

Subdivision (c) Requirements

Paragraph (c)(1) – VOC Content of Graphic Arts Materials

Staff is proposing to enhance the clarity of the current rule language by detailing the actions 

prohibited under this provision. In addition, the required VOC content limits are displayed in a 

table, to be consistent with the formatting used in other SCAQMD rules. The revision is shown 

below.

“No person shall supply, sell, offer for sale, market, manufacture, blend, package, repackage, 

distribute, apply or solicit the application of any graphic arts material, including any VOCcontaining materials added to the original graphic arts materials, for use in the District, which 

contains a total VOC in excess of the VOC content limits specified set-forth in the Table of 

Standards I below:”

TABLE 3 – PROPOSED TABLE OF STANDARDS I

TABLE OF STANDARDS I

VOC CONTENT LIMITS

Grams of VOC Per Liter of Coating, Ink or Adhesive, Less Water 

And Less Exempt Compounds

GRAPHIC ART MATERIAL Current Limit

(g/L)

Adhesive 150

Coating 300

Flexographic Fluorescent Ink 300

Flexographic Ink: Non-Porous Substrate 300

Flexographic Ink: Porous Substrate 225

Gravure Ink 300

Letterpress Ink 300

Offset Lithographic Ink 300

Proposed Amended Rule 1130 2-4 May 2014
Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

Paragraph (c)(2) – VOC Content of Fountain Solutions

Staff proposes to delete obsolete rule language from Paragraph (c)(2), make revisions to the 

existing rule language to enhance clarity and introduce a new Table of Standards II, to combine 

the VOC limits of the fountain solutions that are used for the various types of printing methods 

in offset lithographic printing operations. 

The current version of Rule 1130 limits fountain solution to 100 grams per liter of VOC provided 

the fountain solution is refrigerated and maintained at 55 degrees Fahrenheit or less, or if used at 

room temperature(ambient), to 80 grams per liter of VOC. 

The CTG recommends a percentage of alcohol or alcohol substitute when calculating the VOCs 

for either room temperature or refrigerated fountain solutions and type of printing method. Staff 

converted the CTG recommended mass percentage limits to a gram per liter limit, consistent 

with SCAQMD VOC content terminology.

Table-4 shows the recommended weight percent values and equivalent VOC content in grams 

per liter, based on standard unit conversion and product material densities.

TABLE 4 - CONVERSION OF PERCENTAGE OF VOC VALUES TO 

MASS/VOLUME VOC VALUES – BASED ON CTG RECOMMENDATIONS

FOUNTAIN SOLUTION

CTG

RECOMMENDATION

(weight percent)

EQUIVALENT

(g/L)

Heatset Web Offset Lithographic

At Room Temperature 1.6% 16

Heatset Web Offset Lithographic

Using Refrigerated Chiller 3.0% 30

Heatset Web Offset Lithographic

Using Alcohol Substitute 5.0% 50

Sheet-fed Offset Lithographic

At Room Temperature 5.0% 50

Sheet-fed Offset Lithographic

Using Refrigerated Chiller 8.5% 85

Sheet-fed Offset Lithographic

Using Alcohol Substitute 5.0% 50

Non-Heatset Web Offset Lithographic

Using Alcohol Substitute 5.0% 50

Table-5 shows the updated VOC content requirements in the proposed amendment. Staff 

reviewed commercially available fountain solutions and found 90% of the fountain solution 

Proposed Amended Rule 1130 2-5 May 2014
Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

concentrate products already meet the most restrictive 16 g/L limit when mixed with water per 

the products technical data sheet recommendations. The VOC content of the fountain solution 

concentrate can substantially be affected by the amount of dilution water added; the typical 

dosage identified was 4 to 6 fluid ounces of fountain solution concentrate per gallon of water. 

With the exception of just three products, the fountain solutions that calculated in the excess of 

16 g/L VOC could be used at lower concentration. In fact, staff determined that when using the 

lowest concentrate limit proposed by the product manufacturer, 98% of the products were 

calculated to be under 16 g/L of VOC. Two of the three fountain solutions that could not meet 

the 16 g/L VOC limit for a heatset press using fountain solution at room temperature could meet 

the limit for a heatset press using refrigerated fountain solutions. The one product which 

calculated at 41 g/L VOC could still be used for the other categories shown in Table 5. Some 

printing operations may also require additives, defoamers, bactericides and other components 

that may also contain VOC. Since the rule for VOC content is “as applied” the operator may 

have to adjust the mixture to keep the fountain solution within the rules specified VOC content 

limits. Staff believes that the CTG recommended fountain solution limits reflect existing 

operational practices.

Staff proposes to eliminate the current language in subparagraph (c)(2)(A), in lieu of the Table of 

Standards II, and add new language to subparagraph (c)(2)(B) to provide clarification that 

alcohol containing fountain solutions would be prohibited for use in non-heatset web-fed 

operations. Table 5 shows the VOC limits for the fountain solutions, and the new VOC limits 

that will become effective on July 1, 2014. The VOC limits are “as applied” on-press:

“(A) Through December 31, 1999, no No person shall apply any in any graphic arts 

operation any fountain solution, including any VOC-containing materials added to 

the original fountain solution, which contains a total VOC in excess of 100 grams 

per liter of material fountain solution, including any VOC-containing materials 

added to the original fountain solution as applied, shall be: for use in a graphic 

arts operation within the District unless the VOC content in the fountain solution, 

as applied, complies with the applicable VOC limits set-forth in the Table of 

Standards II below.”

Proposed Amended Rule 1130 2-6 May 2014
Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

TABLE 5 – PROPOSED TABLE OF STANDARDS II

TABLE OF STANDARDS II

VOC CONTENT LIMITS

Grams of VOC Per Liter of Material

FOUNTAIN SOLUTION 1/1/2000 7/1/2014

(g/L) (g/L)

Heatset Web-Fed

Using Alcohol without Refrigerated Chiller 80 16

Using Alcohol with Refrigerated Chiller 100 30

Using Alcohol Substitute 80 50

Sheet-Fed

Using Alcohol without Refrigerated Chiller 80 50

Using Alcohol with Refrigerated Chiller 100 85

Using Alcohol Substitute 80 50

Non-Heatset Web-Fed

Using Alcohol Substitute without Refrigerated Chiller 80 50

Using Alcohol Substitute with Refrigerated Chiller

(A) no greater than 80 grams per liter of material, or

(B) no greater than 100 grams per liter of material, if a refrigerated chiller is used.The 

use of alcohol containing fountain solutions is prohibited for use in non-heatset 

web-fed operations.

“Paragraph(c)(3) – Solvent Cleaning Operations; Storage and Disposal of VOC containing 

Materials

Staff is proposing the following revision to enhance the clarity of paragraph (c)(3) to make it 

consistent with other Regulation XI rules.

“(3) Solvent Cleaning Operations; Storage and Disposal of VOC-containing Materials.

Solvent cleaning of application equipment, parts, products, tools, machinery, 

equipment, general work areas, and the storage and disposal of VOC-containing 

materials used in cleaning operations and the storage and disposal of VOCcontaining materials used in cleaning operations are subject to the provisions of

shall be carried out pursuant to Rule 1171 - Solvent Cleaning Operations.”

Paragraph(c)(4) – Prohibition of Storage

Staff proposes to add additional rule language to address the storage of graphic arts material that

have VOC content limits in excess of the specified VOC content limits pursuant to paragraph 

Proposed Amended Rule 1130 2-7 May 2014
Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

(c)(1). Although staff believes facilities currently meet the VOC content requirements of 

paragraph (c)(1) an effective date of July 1, 2014 is proposed to allow time for internal worksite 

review of existing storage and inventory areas for compliance assurance purposes.

“(4) Effective July 1, 2014, a person shall not store any graphic arts material at a 

worksite for use in the District which contains VOC in the excess of the VOCcontent limits specified in paragraph (c)(1).”

Paragraph(c)(5) – Approved Emission Control System

Staff proposes to update the Approved Emission Control System requirements to align the CTG 

to reflect the same control efficiency requirement as in other Regulation XI rules. The proposed 

revised rule language is as follows:

Approved Emission Control System

“(5) A person may comply with the provisions of paragraph (c)(1) and (c)(2) by using an 

emission control system to reduce VOC emissions provided such system is first 

approved in writing by the Executive Officer and meet the following requirements:

(A) The control device reduces VOC emissions from an emissions collection system 

by at least 95 percent, by weight, or the output of the air pollution control 

device is no more than 50 PPM by volume calculated as carbon with no 

dilution; and

(B) The owner/operator demonstrates that the emission collection system collects at 

least 90 percent, by weight, of the VOC emissions generated by the sources 

emissions.”

Paragraph (c)(5) – Alternative Emission Control Plan

Staff proposes to revise paragraph (c)(5) to clarify rule language as follows:

“(5) Alternative Emission Control Plan”

A person may comply with the provisions of paragraphs (c)(1) or (c)(2) by means of 

an approved Alternative Emission Control Plan (AECP) pursuant to Rule 108 -

Alternative Emission Control Plans.”

Subdivision (d) Prohibition of Specification and Sale

Paragraph (d)(2)

Staff is proposing the following revisions to paragraph (d)(2) to clarify the actions a person may 

not partake in during a graphic arts operation and correct the reference of the applicable 

subparagraph.

“(2) No person shall supply, offer for sale, sell, market, blend, package, repackage, 

manufacture or distribute, ordistribute directly to an end-user for use in the District

any graphic arts material for use in the District which, when applied as supplied or 

Proposed Amended Rule 1130 2-8 May 2014
Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

thinned or reduced according to the manufacturer's recommendation for 

application, does not meet the applicable VOC limits in paragraph (c)(1) or 

subparagraph (i)(11)(C) (i)(4)(C) for the specific application.”

Paragraph (d)(3)

Staff is proposing to add a new paragraph to clarify a manufacturer’s responsibility to the 

labeling requirements with Rule 443.1 and to clarify the “prohibition of sales” provision in the 

District.

“(3) The prohibition of sales and use as specified in paragraphs (d)(1) and (d)(2) shall 

not apply to any manufacturer of graphic arts materials, provided that the 

manufacturer has complied with the labeling requirements of Rule 443.1 – Labeling 

of Materials Containing Organic Solvents, and the product is not sold directly to a 

user located in the District, or the product was sold to an independent distributor or 

a sales outlet located in the District that is not a subsidiary of, or under the control 

of the manufacturer, and was informed in writing by the manufacturer about the 

compliance status of the product with Rule 1130.”

Subdivision (f) – Rule 442 Applicability

Staff is proposing the following revision to enhance the clarity of this subdivision.

“Any graphic arts operations subject to this rule which is exempt exempted from all 

or a portion of the VOC limits of this rule shall comply with the provisions of Rule 

442.”

Subdivision (g) – Emission Reduction Credits

The rule language for Emission Reduction Credits should be updated to be consistent with other

Regulation XI rules. Staff is proposing to delete the current rule language and replace it with the 

following revised rule language.

“(g) Emission Reduction Credits

Facilities that use matte finish and metallic inks shall not receive emission 

reduction credit(s) pursuant to SCAQMD Rule 1309 above those emission 

reduction credit(s) that the facility would have received if it was operated with 

coatings having a VOC content of no more than 300 grams per liter, less water and 

less exempt compounds irrespective of the VOC limits specified in paragraph 

(i)(4)(C).”

Subdivision (h) - Test Methods

Subparagraph (h)(1)(A)

Staff is proposing the following revisions to refine the rule language in subparagraphs (h)(1)(A) 

and (h)(1)(B) and subparagraphs (h)(2)(A) and (h)(2)(B), to make the rule language consistent 

with other Regulation XI rules.

Proposed Amended Rule 1130 2-9 May 2014
Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

“(A) United States Environmental Protection Agency (U. S. EPA) Reference Test Method 

24, (Determination of Volatile Matter Content, Water Content, Density, Volume 

Solids, and Weight Solids of Surface Coatings, Code of Federal Regulations, Title 

40, Code of Federal Regulations Part 60, Appendix A). The exempt compounds' 

content shall be determined by District South Coast Air Quality Management’s 

(SCAQMD) Laboratory Test Method 302 (Distillation of Solvents from Paints, 

Coatings and Inks) and 303 (Determination of Exempt Compounds) contained in 

the District SCAQMD’s "Laboratory Methods of Analysis for Enforcement 

Samples" manual; or ”

Subparagraph (h)(1)(B)

Staff proposes to refine the rule language by including the title name of the test method and 

make the rule language consistent with other Regulation XI rules, as follows.

“(B) SCAQMD District Test Method 304 [Determination of Volatile Organic 

Compounds (VOCs) in Various Materials] contained in the District SCAQMD’s 

"Laboratory Methods of Analysis for Enforcement Samples" manual.”

Subparagraph (h)(2)(A)

Staff proposes to refine the rule language by including the title name of the test methods and 

make the rule language consistent with other Regulation XI rules, as follows.

“(A) United States Environmental Protection Agency (U.S. EPA) Reference Test Method 

24A, (Title 40, Code of Federal Regulations Part 60, Appendix ADetermination of

Volatile Matter Content and Density of Publication Rotogravure Inks and Related 

Publication Rotogravure Coatings, Code of Federal Regulations Title 40, Part 60, 

Appendix A). The exempt compounds' content shall be determined by District 

SCAQMD’s Laboratory Test Method 303 (Determination of Exempt Compounds) 

contained in the District SCAQMD’s "Laboratory Methods of Analysis for 

Enforcement Samples" manual; or”

Subparagraph (h)(1)(B)

Staff proposes to refine the rule language by making the rule language consistent with other 

Regulation XI rules, as follows.

“(B) SCAQMD District Test Method 304 [Determination of Volatile Organic 

Compounds (VOCs) in Various Materials] contained in the District SCAQMD’s 

"Laboratory Methods of Analysis for Enforcement Samples" manual.”

Paragraph (h)(3) – Exempt Perfluorocarbon Compounds

Staff proposes to refine the rule language by making the rule language consistent with other 

Regulation XI rules. First, the list of classes of compounds has been formatted to a semi-bulleted 

list for easier reading. Then staff incorporated minor revisions to provide enhanced clarity of the 

rule language.

Proposed Amended Rule 1130 2-10 May 2014
Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

“The following classes of compounds: 

Cyclic, branched, or linear, completely fluorinated alkanes; 

Cyclic, branched, or linear, completely fluorinated ethers with no unsaturations; 

Cyclic, branched, or linear, completely fluorinated tertiary amines with no 

unsaturations; and 

Sulfur-containing perfluorocarbons with no unsaturations and with sulfur bonds only to 

carbon and fluorine,

will be analyzed as exempt compounds for compliance with subdivision (c) and subparagraph 

(i)(11)(C) (i)(4)(C), only at such time as when manufacturers specify which individual 

compounds are used in the ink and coating formulations. and identify the test methods, which, 

prior to such analysis, have been approved byIn addition, the manufacturers must identify with

the U.S. EPA, CARB, and the District that SCAQMD approved test methods, which can be 

used to quantify the amounts of each exempt compound.”

Paragraph (h)(4) - Determination of Efficiency of Emission Control Systems

Subparagraph (h)(4)(A)

Staff proposes to refine the rule language in paragraph (h)(4) by making the rule language 

consistent with other Regulation XI rules. This will include the elimination of clauses (i), (ii), 

and (iii).

“(A) The capture efficiency of an emission control system as defined specified in 

paragraph (b)(25) shall be determined by a minimum of three sampling runs 

subject to the data quality objective (DQO) presented in the by the procedures 

presented in U.S. EPA technical guideline document, "Guidelines for Determining 

Capture Efficiency, January 9, 1995". Individual capture efficiency test runs 

subject to the USEPA technical guidelines shall be determined by:Notwithstanding 

the test methods specified by the Guidelines, any other method approved by the U.S. 

EPA, CARB and the SCAQMD Executive Officer may be substituted.

Subparagraph (h)(4)(B)

Staff proposes to refine the rule language in subparagraph (h)(4)(B) by making the rule language 

consistent with other Regulation XI rules.

“(B) The efficiency of the control device efficiency of an the emission control system as 

defined specified in paragraph (b)(36) and the VOC content in the control device 

exhaust gases, measured and calculated as carbon, shall be determined by U.S. 

EPA Test Methods 25, 25A, or District SCAQMD Method 25.1 (Determination of 

Total Gaseous Non-Methane Organic Emissions as Carbon) or SCAQMD Method 

25.3 (Determination of Low Concentration Non-Methane Non-Ethane Organic 

Compound Emissions from Clean Fueled Combustion Sources) as applicable. U.S. 

EPA Test Method 18, or CARB Method 422 shall be used to determine emissions of 

exempt compounds.”

Proposed Amended Rule 1130 2-11 May 2014
Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

Paragraph (h)(5) – Equivalent Test Methods

Staff proposes to refine the rule language in paragraph (h)(5) by making the rule language 

consistent with other Regulation XI rules.

“(5) Equaivalent Test Methods

Other test methods determined by the staffs of the Districtto be equivalent by the 

Executive Officer, CARB, and the U. S. EPA, to be equivalent to the test methods 

specified in this rule, and approved in writing by the District Executive Officer may 

also be used.”

Paragraph (h)(7) – Test Methods Dates

Staff proposes to revise the rule language in paragraph (h)(7) to be consistent with other 

Regulation XI rules.

“(7) Test Methods Dates

All test methods referenced in this section subdivision shall be the most recently

approved versions. The Executive Officer may update test methods as necessary to 

reflect the most accurate method available, provided the method does not affect the 

stringency of the ruleby the appropriate governmental entities.”

Subdivision (i) Exemptions

Staff proposes to reformat subdivision (i) to update section numbering and to move the 

exemption for Aerosol Coating Products and adding a new exemption for graphic arts materials 

that have 10 g/L of VOC or less. Graphic arts materials do not include materials used in 

cleaning operations.

“(i) Exemptions

(1) The provisions of this rule shall not apply to: [...]

(I) Aerosol coating products

(J) Graphic arts materials that have a VOC content of no more than 10 g/L or 

equivalent, less water and less exempt compounds, as applied.”

Staff is proposing to include an exemption from Rule 1130 provisions for graphic arts materials 

with a VOC content of 10 g/L or less. Given the uncertainties in the methods for determining 

VOC content at these low levels for some materials, staff proposes to allow for alternative 

equivalent metrics to determine the VOC content. For instance, for reactive coatings, an 

alternative calculation includes a determination of 99% solids content or greater by weight. It is 

noted that formulation data may be obtained by staff to estimate the VOC content of these nearzero VOC products.

Staff is then proposing to relocate the emissions threshold and associated record keeping for 

metalic and matte finish inks of paragraph (i)(11) to a new paragraph (i)(5) and change the 

Proposed Amended Rule 1130 2-12 May 2014
Chapter 2: Summary of Proposed Amended Rule 1130 Final Staff Report

records retention requirement from two years to five years. The revised rule language is shown 

below.

“(5) Facilities operating under the provisions of paragraph (i)(4) whose actual 

emissions exceed ten (10) tons in any calendar year shall:

(A) henceforth be subject to the requirements of paragraph (c)(1).

(B) In addition to the requirements of subdivision (e), facilities shall retain 

records of purchase orders and invoices of VOC-containing materials for 

a minimum of five (5) years.”

Staff is proposing to add new rule language to provide an exemption for storage of graphic arts 

materials that exceed the VOC limits in paragraph (c)(1) provided the VOCs from those graphic 

arts materials are collected and controlled by an emissions control system, consistent with 

SCAQMD VOC rules.

“(6) The provision of paragraph (c)(1) shall not apply to a worksite that stores graphic 

arts materials provided such graphic arts materials are vented exclusively to 

printing systems equipped with an approved emission control system pursuant to

the requirements of paragraph (c)(5).”

Finally, staff proposes to add new language to provide rule relief for sheet-fed presses that have a 

sheet size no larger than 11 inches by 17 inches, or if the total fountain solution reservoir 

capacity is one gallon or less as recommended by the CTG. However, this exemption can only 

be met if the sheet-fed presses, having a sheet size no larger than 11 inches by 17 inches, or if the 

total fountain solution reservoir capacity is one gallon or less, uses a fountain solution with a 

VOC content of no more than 80 grams per liter of material, as applied, or if using a refrigerated 

chiller, no more than 100 grams per liter of material, as applied. The new language will appear 

in paragraph (i)(8) as follows.

“(8) The provisions of paragraph (c)(2) shall not apply to sheet-fed offset presses that 

have a sheet size no larger than 11 inches by 17 inches, or any offset press if the 

total solution reservoir capacity is one gallon or less, provided the VOC content of 

the fountain solution used contains no more than 80 grams per liter of material, as 

applied, or if using a refrigerated chiller, no more than 100 grams per liter of 

material, as applied.”

Proposed Amended Rule 1130 2-13 May 2014
RULE 1130 – GRAPHIC ARTS

CHAPTER 3: IMPACT ASSESSMENT OF PROPOSED AMENDED RULE 1130

ο Emission Impact Assessment

ο Cost Analysis

ο Control Device Efficiency

ο Fountain Solutions

ο Storage Of Non-Compliant VOC-Containing Materials

ο Incremental Cost-Effectiveness

ο California Environmental Quality Act (CEQA)

ο Socioeconomic Impact Assessment

ο Draft Findings under California Health and Safety Code 40727

ο Comparative Analysis

ο Draft Conclusions and Recommendations

ο Public Comments and Responses
Chapter 3: Impact Assessment of Proposed Amended Rule 1130 Final Staff Report

EMISSION IMPACT ASSESSMENT

The proposed amendment is not expected to result in emission reductions.

COST ANALYSIS

The proposed amendments to Rule 1130 is not expected to have a net cost impact since industry will 

be able to continue business as usual and operate their equipment subject to Proposed Amended Rule 

1130 in a similar manner to the current rule. 

CONTROL DEVICE EFFICIENCY

The proposed amendment seeks to change the add-on control device efficiency requirement from 75% 

overall to the CTG recommended 95% control and 90% capture efficiency. Staff has analyzed the data 

for the 29 control units in the South Coast AQMD jurisdiction and found that all of them will meet the 

new revised limit. The typical overall control device efficiency for the control units operating in the 

District is 96.2%. Therefore, staff believes there will be no cost impact on industry for this revision.

FOUNTAIN SOLUTIONS

The proposed amendment seeks to align the VOC requirements in Rule 1130 with the recommended 

VOC requirements in the U.S. EPA Control Techniques Guidelines for fountain solutions. Staff 

believes there would be a no cost impact to industry for the EPA recommended VOC limit changes. 

Staff conducted a survey of fountain solutions on the internet and found that out of 169 fountain 

solutions, 152 met the most restrictive VOC limit, the heatset web-fed without a refrigerated chiller (16 

grams per liter). Typically, the technical data sheets for manufacturers of fountain solutions 

recommend anywhere from 2 to 4 ounces of the fountain solution to be mixed with one gallon of 

water. Staff used the highest dosages to calculate the VOC content of the fountain solutions and even

at the maximum dosage for fountain solution staff still found 152 fountain solutions will meet the most 

restrictive VOC limit. This data shows that industry has been using products that already comply with 

the new adjusted VOC limits and should not pose a cost impact to industry. 

STORAGE OF CERTAIN NON-COMPLIANT VOC-CONTAINING MATERIALS

The proposed amendment prohibits storage of VOC-containing materials at a worksite that do not meet 

the VOC limits specified in the Table of Standards I [Rule 1130 paragraph (c)(1)]. The rule proposal 

includes an exemption to this prohibition provided that the graphic arts materials are vented 

exclusively to an approved emissions control system. Staff believes there would be no cost impact to 

this change because a facility conducting graphic arts operations has no operational need for noncompliant VOC containing materials at their worksite and because the proposed amendment does not 

change the VOC content requirement for any currently stored graphic arts materials. This proposed 

rule language has been added to make the rule consistent with other VOC regulating rules. 

The remaining changes in this proposed amendment are to remove obsolete rule language, update 

definitions for consistency with other District rules, add two new definitions and make minor 

corrections and clarifications will have no cost or emissions impact.

Proposed Amended Rule 1130 3-1 May 2014
Chapter 3: Impact Assessment of Proposed Amended Rule 1130 Final Staff Report

INCREMENTAL COST-EFFECTIVENESS

Under Health and Safety Code § 40920.6, the SCAQMD is required to perform an incremental cost 

analysis when adopting a Best Available Retrofit Control Technology (BARCT) rule or feasible 

measure required by the California Clean Air Act. To perform this analysis, the SCAQMD must (1) 

identify one or more control options achieving the emission reduction objectives for the proposed rule, 

(2) determine the cost effectiveness for each option, and (3) calculate the incremental cost 

effectiveness for each option. To determine incremental costs, the SCAQMD must “calculate the 

difference in the dollar costs divided by the difference in the emission reduction potentials between 

each progressively more stringent potential control option as compared to the next less expensive 

control option.” TheStaff reviewed the 2006 CTG along with other current standards throughout the 

state and determined that PAR 1130 represents BARCT for graphic arts operations because there are 

no other more stringent limits available. PAR 1130 does not implement a more restrictive BARCT 

because the amendment reflects existing practices and technology and therefore does not achieve 

additional will not result in emission reductions. Because the proposed amendments to Rule 1130 

dodoes not implement a more restrictive BARCT or feasible control measure, and therefore and 

therefore no incremental cost analysis is required under Health and Safety Code § 40920.6 is 

inapplicable.

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)

In accordance with the California Environmental Quality Act (CEQA), the SCAQMD is the Lead 

Agency and has prepared a Draft Environmental Assessment (EA) to analyze environmental impacts 

from the proposed project pursuant to its certified regulatory program (SCAQMD Rule 110). The 

Draft EA includes a project description and analysis of potential adverse environmental impacts that 

could be generated from the proposed project. Comments focusing on issues relative to the 

environmental analysis for the proposed project will be accepted duringThe Draft EA was circulated 

for a 30-day public review and comment period beginning February 25, 2014, and ending 5 p.m. on 

March 26, 2014. Responses to any comments on the Draft EA received during the public review and 

comment period will be prepared and incorporated into the Final EA.

SOCIOECONOMIC IMPACT ASSESSMENT

The proposed amendments codify existing practices at graphic arts operations that are subject to Rule 

1130. As such, there are no additional costs or other socioeconomic impacts anticipated and no 

socioeconomic analysis is required under Health and Safety Code Section 40728.5.

DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY CODE 40727

The draft findings include necessity, authority, clarity, consistency, non-duplication and reference, as 

defined in Health and Safety Code Section §40727. The draft findings are as follows:

Necessity - The SCAQMD Governing Board finds and determines that Proposed Amended Rule 1130,

Graphic Arts, is necessary to make Rule 1130 consistent with the suggested control device efficiencies 

and the recommended VOC limits for fountain solutions with United States Environmental Protection 

Agency’s (U.S. EPA) Control Techniques Guidelines (CTG) for Offset Lithographic Printing and 

Letterpress Printing (EPA 453/R-06-002) and Flexible Package Printing (EPA 453/R-06-003).

Proposed Amended Rule 1130 3-2 May 2014
Chapter 3: Impact Assessment of Proposed Amended Rule 1130 Final Staff Report

Authority - The SCAQMD Governing Board obtains its authority to adopt, amend or repeal rules and 

regulations from Health and Safety Code §§ 40000, 40001, and 40440.

Clarity - The SCAQMD Governing Board finds and determines that Proposed Amended Rule 1130 is

written and displayed so that the meaning can be easily understood by persons directly affected by it.

Consistency – The SCAQMD Governing Board finds and determines that Proposed Amended Rule

1130 is in harmony with, and not in conflict with or contradictory to, existing statutes, court decisions, 

or federal or state regulations.

Non-Duplication – The SCAQMD Governing Board has determined that Proposed Amended Rule 

1130 does not impose the same requirement as any existing state or federal regulation, and the 

proposed amendment is necessary and proper to execute the powers and duties granted to, and imposed 

upon, the SCAQMD.

Reference - In adopting this proposed amendment, the SCAQMD Governing Board references the 

following statutes which SCAQMD hereby implements, interprets or makes specific: Health and 

Safety Code Sections 40001 and 40440.

COMPARATIVE ANALYSIS

California Health and Safety Code Section 40727.2 requires the comparative analysis with any federal 

or other SCAQMD rules that apply to the same equipment or source type as the proposed amendments. 

The proposed amendments codify existing practices at graphic arts operations that are subject to Rule 

1130. As such, the proposed amended rule does not impose a new emission limit or standard, make an 

existing emission limit or standard more stringent, or impose new or more stringent monitoring, 

reporting, or recordkeeping requirements and therefore a comparative analysis pursuant to Health and 

Safety Code Section 40727.2 is not required

DRAFT CONCLUSIONS AND RECOMMENDATIONS

Staff recommends that Certifying the Final Environmental Assessment (EA) for Proposed Amended 

Rule 1130 – Graphic Arts and Amending Rule 1130 - Graphic Arts to update Rule 1130 with the 

control measures recommended by the United States Environmental Protection Agency’s (U.S. EPA) 

Control Techniques Guidelines (CTG) for Offset Lithographic Printing and Letterpress Printing (EPA 

453/R-06-002) and Flexible Package Printing (EPA 453/R-06-003).

PUBLIC COMMENTS AND RESPONSES

Staff held the public workshop for Proposed Amended Rule 1130 on Thursday, February 6, 2014. The 

following comments were made at the public workshop and staff responses to those comments are 

shown below.

Stakeholder Comment #1:

Prohibition of Material – how does it apply to fountain solutions?

Proposed Amended Rule 1130 3-3 May 2014
Chapter 3: Impact Assessment of Proposed Amended Rule 1130 Final Staff Report

Staff response:

The intent of the provision is to apply to graphic arts material as recommended for use. Fountain solutions are 

not part of the graphic arts materials definition. Additionally, the provision applies to the VOC content of the 

graphic arts materials as applied, or “press-ready”.

Stakeholder Comment #2:

Lithographic plates can be made of paper or polymer in addition to metal.

Staff response:

Staff revised the staff report by removing the word “metal” to reflect the intent of your comment.

Stakeholder Comment #3:

Sheet fed and Web-fed are subsets of offset lithographic printing, not types of offset lithographic printing.

Staff response:

Staff has revised the staff report to address the intent of your comment by replacing the word “types” with

“subset.”

Stakeholder Comment #4:

Fountain solutions come in one step and two step formulations. The PDSR describes the one step formulation 

and should address the two step formulations. Some lithographic printing on plastic has faced challenges with 

lower VOC content fountain solutions, but the PIA believes the CTG limits are achievable.

Staff response:

Staff agrees and has revised the staff report by adding additional language describing the one-step and two-step 

fountain solutions. 

Stakeholder Comment #5:

The description of the alternative emission control system should differentiate between heat-set and non-heat-set 

inks. Also, heat-set letterpress printing may need to be specifically included as identified by the CTG.

Staff response:

The Alternative Emission Control System is based on the collection system and the control device and reference 

to the SCAQMD compliance advisory and treatment for heatset lithographic printing has been included as an 

appendix to the report. Staff added additional language to describe flexographic, letterpress and gravure 

printing processes in the draft staff report. Letterpress printing is defined in the rule and Table of Standards I 

also specifies the VOC content limit for inks used in letterpress operations. The rule also accommodates a 

person using the Heatset letter printing process with inks that exceed the VOC content limits in the Table of 

Standards I provided all the graphic arts materials are vented exclusively to an approved emission control 

system or if operating under an approved Alternative Emission Control Plan.

Stakeholder Comment #6:

We need to have the SCAQMD 1997 Compliance Advisory related to heatset lithography and control device 

capture efficiency directly addressed as part of this rule amendment.

Proposed Amended Rule 1130 3-4 May 2014
Chapter 3: Impact Assessment of Proposed Amended Rule 1130 Final Staff Report

Staff response:

Staff agrees and has included the 1997 Compliance Advisory in Appendix B of the Draft Staff Report.

Stakeholder Comment #7:

The control device control efficiencies noted in the PDSR seem low. 

Staff response:

Staff obtained the control device efficiencies from engineering applications for the initial permits a given facility 

applied for. The control device efficiencies are based on source test results. Some of the source tests are dated 

and the older equipment may not perform as efficiently as the newer equipment that is available today. Even at 

an average of 96.6% efficiency, the lowest being 92.1% efficient, all control efficiencies combined with a 

capture efficiency default of 99.5% are well with the required 86% overall control efficiency limit, based on 

SCAQMD records.

Stakeholder Comment #8:

The term “non-compliant” with respect to prohibited storage should either be defined or replaced with crossreferencing citations for clarification.

Staff response:

The comment refers to the phrase “Storage of Certain Non-Compliant VOC-Containing Materials” shown in 

chapter 3, page 3-1 of the Preliminary Draft Staff Report. The PDSR stated that the proposed amendment 

would prohibit storage of certain non-compliant VOC-containing materials at a worksite. To provide clarity, 

staff revised the language to read that the prohibition of certain VOC-containing materials at a worksite that do 

not meet the VOC limits specified in the Table of Standards I [Rule 1130 paragraph (c)(1)]. Staff also added 

an additional sentence to indicate that graphic arts materials that are “not compliant” but used exclusively in 

conjunction with an approved emissions control system are not subject to the prohibition.

Stakeholder Comment #9:

Staff uses “radiation curable” in both the Proposed Amended Rule and the Preliminary Draft Staff Report. The 

industry term is actually “energy curable”. Please update the proposed amend rule and the draft staff report

Staff Response:

Staff has made the requested change in the Preliminary Draft Staff Report by changing “radiation cured” to 

“energy cured” throughout the draft staff report. In addition, staff has added a new definition to Proposed 

Amended Rule 1130 for “ENERGY CURABLE COATINGS, INKS AND ADHESIVES.” 

Stakeholder Comment #10:

Industry would like to raise the low-VOC content material exemption from 10 g/L to 20 g/L to account for 

errors and conservative reporting of VOC-content for energy curable graphic arts materials.

Staff Response:

The 10 g/L VOC content limit is consistent with other VOC rules and programs pertaining to the near-zero VOC 

technology, and represents the current super-compliant VOC content level. In addition, the definition for 

energy curable includes reference to ASTM Test Method 7767-11 “Standard Test Method to Measure Volatiles 

Proposed Amended Rule 1130 3-5 May 2014
Chapter 3: Impact Assessment of Proposed Amended Rule 1130 Final Staff Report

from Radiation Curable Acrylate Monomers, Oligomers, and Blends and Thin Coatings Made from Them”

which staff believes should address the concerns raised by this comment. Staff is proposing to include an 

exemption from Rule 1130 provisions for graphic arts materials with a VOC content of 10 g/L or less. Given the 

uncertainties in the methods for determining VOC content at these low levels for some materials, staff proposes 

to allow for alternative equivalent metrics to determine the VOC content. For instance, for reactive coatings, an 

alternative calculation includes a determination of 99% solids content or greater by weight. It is noted that 

formulation data may be obtained by staff to estimate the VOC content of these near-zero VOC products.

Stakeholder Comment #11:

We request a delay in the effective date for storage of non-compliant materials, possibly 3 months.

Staff Response:

Staff agrees and has provided the requested three month delay in the rule for prohibited storage of “noncompliant” materials and for fountain solutions. The new VOC limits shown in the Table of Standards II will 

become effective on July 1, 2014, in order to provide a short transition period for the new standard.

The following were received after the close of comment period.

Stakeholder Comment #12:

Section (c)(4) Acceptable formula for calculating overall efficiency is proposed to be removed. Concern that 

this will give individual permit engineers and inspectors the freedom to decide how efficiency is calculated and 

the ability to cite the facility arbitrary.

Staff Response:

The proposed amended rule includes a reformatting of the language pertaining control efficiency. The formula 

remains the same.

Stakeholder Comment #13:

Section (c)(4) VOC emissions reduction system must be approved in writing by the Executive Officer. Need 

clarification – does a permit constitute written approval or is does (sic) the Executive Officer need to provide an 

approval letter? See SCAQMD Rule 102, definitions: Executive Officer means the Executive Officer or 

designee of the South Coast Air Quality Management District.

Staff Response:

Issuance of a permit for the emission reduction system is considered written approval by the Executive Officer.

Stakeholder Comment #14:

Section (c)(4)(B) The owner/operator demonstrates that the emissions collection systems collects at least 90 

percent, by weight, of the VOC emissions generated by the source emission. What methods of demonstration of 

the emission system are acceptable in order to achieve 90% by weight reduction of VOC emissions –- will 

showing negative dryer pressure suffice? The reduction in emissions generated note “by the source emissions”. 

Does this pertain to only the select VOC reduction from either (c)(1) and (c)(2) or does the proposed standard 

Proposed Amended Rule 1130 3-6 May 2014
Chapter 3: Impact Assessment of Proposed Amended Rule 1130 Final Staff Report

include all VOC emissions generated at the source including ink, fountain solution, and auxiliary operations 

such as cleaning and adhesive application?

Staff Response:

The collection efficiency is determined in accordance with the test methods outlined in paragraph (h)(4) of the 

proposed amended rule for complying with paragraph (c)(1) or (c)(2) for those materials that exceed the VOC 

content limits as applicable. Paragraph (h)(5) allows use of equivalent methods provided they have been 

approved by SCAQMD, CARB and the U.S. EPA. Finally, for heatset lithographic inks, the approach described 

in Appendix B of this staff report can be used as an acceptable equivalent method for capture efficiency, which 

includes a demonstration of negative air pressure. Cleaning operations are subject to Rule 1171 – Solvent 

Cleaning Operations.

Stakeholder Comment #15:

Section (c)(4) No mention is made allowing 70% capture and 30% fugitive per CTG. Recommend adoption of 

CTG Part VIII.C. Carryover of VOC from Automatic Blanket Wash and Fountain Solution to Offset 

Lithographic Heatset Dryers. We recommend using a 40 percent VOC carryover (capture) factor for automatic 

blanket washing when the VOC composite vapor pressure of the cleaning material is less than 10 mm Hg at 20°

C. We recommend using a 70 percent VOC carryover (capture) factor for alcohol substitutes in fountain 

solution. No mention of manual blanket wash retention allowances in CTG. Recommended adoption of CTG 

Part VIII.B. Retention of Low VOC Composite Vapor Pressure Cleaning Materials in Shop Towels. We 

recommend using a 50 percent VOC retention factor for low VOC composite vapor pressure cleaning materials 

in shop towels where (1) VOC composite vapor pressure of the cleaning material is less than 10 mm Hg at 20°

C, and (2) cleaning materials and used shop towels are kept in closed containers.

Staff Response:

All clean-up operations are deferred to SCAQMD Rule 1171 – Solvent Cleaning Operations. Rule 1171 

requires any cleaning solution for press clean-up to have no more than 25 g/L of VOC as applied. Rule 1171 

also requires all solvent/VOC-containing cleaning solution hand towels to be kept in sealed containers when not 

being used. The emission calculations, including use of retention factors, have previously been incorporated 

into the annual emissions reporting guidelines, included as Appendix A – VOC Emission Calculation 

Methodology for Lithographic Printing Operations of this staff report, for emission reporting purposes.

Proposed Amended Rule 1130 3-7 May 2014
References Final Staff Report

REFERENCES

SCAQMD Staff Report, Proposed Amended Rule 1130 – Graphic Arts, July 1999.

SCAQMD Staff Report, Comparison and Analysis of: Control Techniques Guidelines for Offset 

Lithographic Printing and Letterpress, EPA-433/R-06-002 2006/09, March 2011.

SCAQMD Staff Report, Comparison and Analysis of: Control Techniques Guidelines for Flexible 

Package Printing, EPA-433/R-06-003 2006/09, March 2011.

Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing, EPA-433/R06-002 2006/09, September 2006, U. S. Environmental Protection Agency RTP, NC

Control Techniques Guidelines for Flexible Package Printing, EPA-433/R-06-003 2006/09, September 

2006, U. S. Environmental Protection Agency RTP, NC

INTERNET MATERIAL:

http://en.wikipedia.org/wiki/Offset_printing

http://www.aqmd.gov/aer/Updates/VOCEmissCalcuMethLithoPrint.pdf

http://www.aqmd.gov/bact/PartD-10-3-2008.pdf

http://www.aqmd.gov/aqmp/2012aqmp/Final-February2013/AppVI.pdf

Proposed Amended Rule 1130 R-1 May 2014
APPENDIX A – VOC Emission Calculation Methodology for Lithographic Printing 

Operations – December 2011
Appendix A Final Staff Report

Proposed Amended Rule 1130 A-1 May 2014
Appendix A Final Staff Report

Proposed Amended Rule 1130 A-2 May 2014
Appendix A Final Staff Report

Proposed Amended Rule 1130 A-3 May 2014
Appendix A Final Staff Report

Proposed Amended Rule 1130 A-4 May 2014
APPENDIX B – Compliance Advisory - Determining Collection Efficiencies for Air 

Pollution Control Systems Serving Heat-Set Lithographic Printing 

Presses
Appendix B Final Staff Report

Proposed Amended Rule 1130 B-1 May 2014
Appendix B Final Staff Report

Proposed Amended Rule 1130 B-2 May 2014