### ATTACHMENT C

C

- 1 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 C ode 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 Dis trict 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 p roposed 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 a ssociated cleaning operations

. There are two federal guidelines published b y the U.S. Environmental

Protection A gency (EPA ) that apply to these processes: Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing, and Control Techniques Guidelines for

F lexible 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 n on

- 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 eit her use of an add

- on emission control system, or if such system is

demonstrated to be not cost

- effective, compliance with the re quirements 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 be come the new BACT requirements.

CONCLUSION

As shown in Ta ble 1, there are no conflicts or cont radictions between proposed amended Rule

67.16 and EPA 's Control Technique Guidelines. Furthermore, t here are no contradiction s between the proposed amended rule and the District’s NSR Rule 20.2 BACT requirements.

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- 2 TAB LE 1

– COMPARATIVE ANALYSIS

Items for Comparison Proposed Amended

Rule 67.16 CTG for Lithographic &

Letterpress Printing CTG for Flexible Packaging Printing

Applicability

Exemptions

V OC Content

Limits for Inks

Adhesives &

Fountain

S olutions , 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. M anufacture of proofing

systems, sola r window film, heat applied , water slide

and ceramic decals; development process in preparation of lithographic printing plates; blanket repair material

, preservative oils application from hand

held aerosol containers; stripping of cured inks, coatings and adhesives; cleaning of UV l amps 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 ref rigerated below 60 o F. Offset lithographic printing and letterpress printing operations using inks, cleaning solutions and

F fountain solutions

.

1. Offset lithographic or letterpress printi ng operation where VOC

emissions fro m fountain

solu tions 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 < 5 vol.%

,

or < 8.5% if refrigerated

below 60 o F

. Flexible packaging printing operations using VOC containing inks, adhesives, coatings and cleaning

material s.

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 fr om 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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- 3

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 20 o C. 1. VOC content is less than 70 weight percent, or

2. Composite VOC vapor pressure is less than 10 mm Hg at 20 o C. Work Practice

Recommendations

Add

- on Emission

Control Equipment U se 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 th e 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, e fficiency of add

- on emission control , and exempt compound content. N/A N/A