ATTACHMENT C

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COUNTY OF SAN DIEGO

AIR POLLUTION CONTROL DISTRICT

COMPARATIVE ANALYSIS OF

PROPOSED AMENDMENTS TO RULE 67.16 – GRAPHIC ARTS OPERATIONS

STATUTORY REQUIREMENTS

Prior to adopting, amending, or repealing a rule or regulation, California Health and Safety Code 

Section 40727 requires findings of necessity, authority, clarity, consistency, non-duplication, and 

reference, as defined therein. As part of the consistency finding and to ensure proposed rule 

requirements do not conflict with or contradict other District or federal regulations, Health and 

Safety Code Section 40727.2(a) requires the District to perform a written analysis identifying 

and comparing the air pollution control standards and other provisions of proposed amended

Rule 67.16 with existing or proposed District rules and guidelines and existing federal rules, 

requirements, and guidelines applying to the same source category.

ANALYSIS

Proposed Rule 67.16 applies to any person who conducts graphic arts operations and associated 

cleaning operations. There are two federal guidelines published by the U.S. Environmental 

Protection Agency (EPA) that apply to these processes: Control Techniques Guidelines for 

Offset Lithographic Printing and Letterpress Printing, and Control Techniques Guidelines for 

Flexible Package Printing (CTGs).

In addition, District New Source Review (NSR) Rule 20.2 - Non-Major Stationary Sources, also 

applies to any new or modified graphic arts operation that would be subject to amended

Rule 67.16. Rule 20.2 requires that any non-major new or modified emission unit that has a 

post-project potential to emit of 10 pounds/day or more of volatile organic compounds (VOC) be 

equipped with Best Available Control Technology (BACT). For graphic arts operations, BACT 

is identified as either use of an add-on emission control system, or if such system is 

demonstrated to be not cost-effective, compliance with the requirements of Rule 67.16. 

Proposed amended Rule 67.16 will take effect (for new or modified sources) six months after the 

date of rule adoption. Since amended Rule 67.16 contains VOC content limits for fountain 

solutions, cleaning materials, and adhesives that are more stringent than the existing rule, these 

limits will become the new BACT requirements.

CONCLUSION

As shown in Table 1, there are no conflicts or contradictions between proposed amended Rule 

67.16 and EPA's Control Technique Guidelines. Furthermore, there are no contradictions

between the proposed amended rule and the District’s NSR Rule 20.2 BACT requirements.
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TABLE 1 – COMPARATIVE ANALYSIS

Items for 

Comparison

Proposed Amended

Rule 67.16

CTG for Lithographic &

Letterpress Printing

CTG for Flexible 

Packaging Printing 

Applicability

Exemptions

VOC Content 

Limits for Inks 

Adhesives & 

Fountain 

Solutions, as 

applicable

1. Continuous web or single 

sheet fed graphic arts 

printing, processing, 

laminating or drying 

operations.

2. All cleaning operations 

associated with graphic arts 

operations.

1. Stationary sources emitting 

 < 15 lbs/VOCs/day for each 

calendar month, excluding 

digital printing operations,.

2. Large digital printing 

operations as defined 

provided that specified 

records are kept. 

 

3. Manufacture of proofing 

systems, solar window film, 

heat applied , water slide 

and ceramic decals; 

development process in 

preparation of lithographic 

printing plates; blanket 

repair material, preservative 

oils application from handheld aerosol containers; 

stripping of cured inks, 

coatings and adhesives; 

cleaning of UV lamps and 

EB processors.

1. 300 g/liter less water and 

less exempt compounds for 

graphic arts materials 

excluding adhesives;

2. 150 g/liter for adhesives;

3. VOC concentration not to 

exceed 5 vol.% for fountain 

solutions, or 8.5 vol.% if they 

are refrigerated below 60oF.

Offset lithographic printing 

and letterpress printing 

operations using inks, 

cleaning solutions and 

F fountain solutions.

1. Offset lithographic or 

letterpress printing 

operation where VOC 

emissions from fountain 

solutions and cleaning 

materials in all aspects of 

that operation are 15 lbs per 

day or less.

2. Add-on control is not 

required for heat seat 

letterpress or offset 

lithographic printing with 

VOC emissions of 25 tpy or 

less.

1. No VOC content limits 

for inks or adhesives 

because their emissions are 

very low.

2. Alcohol content of 

fountain solutions < 5vol.%,

or < 8.5% if refrigerated 

below 60oF.

Flexible packaging printing 

operations using VOC 

containing inks, adhesives, 

coatings and cleaning 

materials.

1. Flexible packaging 

printing operation where 

VOC emissions from 

cleaning materials are 

15 lbs per day or less.

2. Add-on control is not 

required for presses with 

PTE less than 25 tpy of 

VOCs from inks, adhesives 

and coatings.

For presses emitting than 

25 tpy or more, the VOC 

content limit for inks, 

coatings & adhesives is 

160 g VOC/kg of material 

applied, or add-on control as 

specified below.
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Items for 

Comparison

Proposed Amended

Rule 67.16

CTG for Lithographic &

Letterpress Printing

CTG for Flexible 

Packaging Printing 

VOC Content 

Limits for 

Cleaning 

Materials

1. VOC content is less than 

100 g/liter, or

2. Total VOC vapor pressure 

is less than 5 mm Hg at 20oC.

1. VOC content is less than 

70 weight percent, or

2. Composite VOC vapor 

pressure is less than 10 mm 

Hg at 20oC.

Work Practice 

Recommendations

Add-on 

Emission 

Control

Equipment

Use of add-on control 

equipment (85% overall 

control efficiency) in lieu of 

complying with VOC content 

limits

Add-on control on heatset 

web offset lithographic 

presses emitting 25 tpy of 

VOCs or more with 90-95% 

overall efficiency

Add-on emission control on 

presses with the PTE for an 

individual press is higher 

than 25 tpy. With 65% to 

80% overall efficiency,

depending on the date of 

installation

Recordkeeping Current list of each graphic 

arts materials and associated 

cleaning material used, with 

the VOC content, monthly 

purchase records, and monthly 

or daily usage records. 

Records must be kept for at 

least 3 years. 

N/A N/A

Test Methods 1. EPA Test Method 24

2. SCAQMD Method 304

3. Various test methods for 

determining VOC content of 

inks, efficiency of add-on 

emission control, and exempt 

compound content.

N/A N/A