Agenda Date: October 11, 2012

Prepared By: Bruce Springsteen, Compliance and Enforcement Manager

Topic: Adoption of Amended Rule 235, Adhesives, and Rule 239, 

Graphic Arts Operations. (Public Hearing/Action)

Action Requested:

1) Conduct a Public Hearing regarding the proposed adoption of amended Rule 235, 

Adhesives, and Rule 239, Graphic Arts Operations.

2) Adopt Resolutions #12-10 (Attachment #1) and #12-11 (Attachment #2), thereby 

approving the amended rules as revisions to the District Rules and Regulations and to 

the State Implementation Plan; and approving all of the required “Findings and 

Recommendations” found in the Staff Reports (Attachments #3 and #4).

Discussion:

The District is proposing amendments to two (2) rules which limit volatile organic 

compound (VOC) emissions:

Rule 235, Adhesives, was last amended by the District on April 8, 2004. Today’s 

proposed amendments are based on the U.S. EPA’s “Control Techniques Guidelines 

for Miscellaneous Industrial Adhesives,” (EPA 453/R-08-005), dated September 

2008, and establishes consistency with other local Air District rules. 

Rule 239, Graphic Arts Operations, was last amended by the District on April 8, 

2004. Today’s proposed amendments are based on the U.S. EPA’s “Control 

Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing,” 

(EPA-453/R-06-002), dated September 2006, and establish consistency with other 

local Air District rules. 

The rule amendments are required as part of the District’s State Implementation Plan (SIP) 

commitment to implement measures to reduce sources of ozone precursors; and associated 

requirements to implement Best Available Retrofit Control Technology under California 

Health and Safety Code Section 40919, and “every feasible measure” under California 

Health and Safety Code Section 40914. These result from the District’s non-attainment 

designation for ground level ozone.

The proposed amended rules, background documents, and letters requesting comments were 

mailed to all impacted sources, including those with District permits to operate as well as 

other affected sources known to the District. A public notice of the scheduled public hearing 

was published in the Auburn Journal on September 9, 2012. The public notice, proposed 

Board Agenda

Public Hearing/Action
PCAPCD Agenda Item

October 11, 2012

Page 2

amended rules, and background documents were posted on the District website.

The District has worked closely with the U.S. EPA, California Air Resources Board, and 

affected sources during development of the amended rules to ensure that once adopted, the 

rules will receive approval into the SIP. The District received comments from the U.S. EPA 

on the amended rules. The comments, attached to the staff reports, have been addressed in the 

final proposed amendments.

Fiscal Impact:

The cost effectiveness of the proposed rule amendments have been determined to be 

acceptable by the U.S. EPA, and other Air Districts that have implemented the control 

Techniques Guidelines (CTG) requirements. The Rule 235, Adhesives, amendments are not 

projected to result in economic hardship to any adhesives users or manufacturer within the 

District, including one (1) facility with a District permit to operate. The Rule 239, Graphic 

Arts Operations, amendments are not projected to result in economic hardship to any graphic 

arts operations within the District, including seven (7) shops with District permits to operate.

Recommendation:

The purpose of the Board Hearing is to consider public testimony regarding the proposed 

amended rules and to consider whether the amended rules should be adopted.

The District recommends and requests that the Board:

1) Approve all the Findings found in the Staff reports of Attachments #3 and #4.

2) Adopt Resolutions #12-10 (Attachment #1) and #12-11 (Attachment #2), thereby 

approving amended Rule 235 and Rule 239 as revisions to the District Rules and 

Regulations and to the State Implementation Plan.

Attachment(s) #1: Resolution #12-10, Adoption of Amended Rule 235, Adhesives

#2: Resolution #12-11, Adoption of Amended Rule 239, Graphic Arts 

Operations

#3: Staff Report for Amended Rule 235, Adhesives

#4: Staff Report for Amended Rule 239, Graphic Arts Operations
ATTACHMENT #1

Subject:

Resolution #12-10, Adoption of Amended Rule 235
ATTACHMENT #2

Subject:

Resolution #12-11, Adoption of Amended Rule 239
ATTACHMENT #3

Staff Report

Amendment of Rule 235, Adhesives
ATTACHMENT #4

Subject:

Staff Report

Amendment of Rule 239, Graphic Arts Operations