EL DORADO COUNTY AIR QUALITY MANAGEMENT DISTRICT

RULE 231 - GRAPHIC ARTS OPERATIONS
(Adoption Date: September 27, 1994)

231.1 GENERAL

  1. PURPOSE: To limit the emission of volatile organic compounds from graphic arts operations.
  2. EXEMPTIONS:
    1. This rule, with the exception of Section 231.5 A., shall not apply to any graphic arts facility which emits less than 660 pounds of volatile organic compounds per calendar month from all graphic arts operations, including surface preparation and cleanup solvents, and excluding graphic arts operations addressed in Section 231.1 B.2. Records required by Section 231.5 A., shall be maintained by all facilities to demonstrate their exemption status.
    2. This rule, with the exception of Section 231.5 A., shall not apply to graphic arts operations used exclusively for research, laboratory analysis or determination of product quality and commercial acceptance, such as proof presses or other proofing systems, provided that total VOC emissions from all such equipment do not exceed 300 pounds per calendar month per facility. Records required by Section 231.5 A., shall be maintained by these facilities to demonstrate their exemption status.

231.2 DEFINITIONS

  1. APPROVED EMISSION CONTROL SYSTEM REQUIREMENTS: A system for reducing emissions of volatile organic compounds, approved by the Air Pollution Control Officer
  2. COATING: The application of a uniform layer of material across the entire width of a substrate. Those machines which have both coating and printing units are considered to be performing a graphic arts operation.
  3. CONTROL DEVICE: Equipment such as an incinerator or adsorber used to prevent air pollutants from reaching the ambient air.
  4. CONVERTING OPERATION: Coating, waxing, laminating, extrusion coating and printing, for fabrication of base materials. The base materials are then used to produce wraps, bags, and other preformed packages.
  5. DOCTOR BLADE: A steel blade used to scrape excess ink from a printing plate.
  6. DRYING OVEN: An oven used to hasten the process of drying printed or coated material.
  7. FLEXIBLE PACKAGING INDUSTRY: Establishments that convert materials consisting of light gauge papers, plastic films, cellulosic films such as cellophane, thin gauge metal sheets such as aluminum foil or steel foil, and combinations thereof into a variety of product packages.
  8. FLEXOGRAPHIC PRINTING: A printing operation in which words, designs, or pictures are applied to a substrate by means of a roll printing technique in which a raised pattern is applied to an image carrier made of rubber or other elastomeric materials mounted on a steel matting cylinder. The image is then printed directly from the raised pattern to the substrate.
  9. FOUNTAIN SOLUTION: The solution applied to the image plate to maintain the hydrophilic properties of the nonimage areas and to keep the nonimage area free from ink.
  10. GRAPHIC ARTS OPERATIONS: Publication gravure, packaging gravure, web-feed wallpaper screen printing, specialty gravure, flexographic printing operations, lithographic printing operations, letterpress printing operations, or any coating or laminating operation that manufactures flexible packaging material for the packaging industry. Coating operations which are performed by a machine having only coating units and no printing units are not graphic arts operations.
  11. GRAVURE PRINTING: An intaglio printing operation in which the ink is transferred from minute etched wells which comprise the image on a plate to the substrate which is supported by an impression roller, with excess ink removed from the plate by a doctor blade.
  12. INTAGLIO PRINTING: A printing operation done from a plate in which the image is etched or engraved into the surface.
  13. LAMINATING OPERATIONS: A process of composing two or more layers of material to form a single multiple-layer sheet by using adhesive as the bonding agent.
  14. LETTERPRESS PRINTING: A printing operation in which the image area is raised relative to the nonimage area and the ink is transferred to the paper directly from the image surface.
  15. LINE: The minimum equipment which is required for the application and/or curing of inks and/or coatings on a substrate, including the ink and/or coating applicators and heating oven(s) and associated ink and coating mixing equipment.
  16. LITHOGRAPHIC PRINTING: A printing operation in which the image and nonimage areas exist in the same plane. The nonimage area is treated chemically so that only the image areas will be printed onto the substrate.
  17. NONHEATSET INK: An ink which dries primarily by oxidation and absorption into the substrate without the use of heat from dryers or ovens, used primarily in lithographic and letterpress printing.
  18. NONPOROUS SUBSTRATE: Any substrate other than paper or paperboard, including but not limited to foil, polyethylene, polypropylene, cellophane, metalized polyester, nylon and polyethylene terephthalate (mylar), but not including wood, metal, or ceramic materials.
  19. OFFSET PRINTING: A lithographic printing operation in which the image area is transferred, or offset, to another surface, and then printed onto the substrate.
  20. PACKAGING GRAVURE PRINTING: A gravure printing operation on paper, paperboard, foil, film or other substrates which are to be used to produce containers or packages.
  21. POROUS SUBSTRATE: Paper or paperboard.
  22. PRODUCTION UNIT: A ream of paper, consisting of 500 sheets of paper.
  23. PUBLICATION GRAVURE PRINTING: A gravure printing operation on paper which is subsequently formed into books, magazines, catalogs, brochures, directories, newspaper supplements or other publication material.
  24. SCREEN PRINTING: A printing operation in which the printing ink passes through a refined form of stencil to a web or fabric. The stencil openings determine the form and dimension of the imprint.
  25. SPECIALTY GRAVURE PRINTING: A gravure printing operation for production of wall and floor covering, decorated household paper products such as towels and tissues, cigarette filter tips, vinyl upholstery, gift wrap, and woodgrains.
  26. VOLATILE ORGANIC COMPOUNDS (VOC): Compounds which contain at least one atom of carbon, except for the following compounds considered exempt from the definition of VOC, whose presence shall be determined in accordance with Section 231.5 B.:
    1. methane (CH4)
    2. carbon dioxide (CO2)
    3. carbon monoxide (CO)
    4. carbonic acid ((CO(OH)2)
    5. metallic carbides (M-C) or carbonates (M-CO3)
    6. ammonium carbonate ((NH4)HCO3(NH4)CO2NH2)
    7. 1,1,1-trichloroethane (methyl chloroform)
    8. methylene chloride (dichloromethane)
    9.  trichlorofluoromethane (CFC-11)
    10. dichlorodifluoromethane (CFC-12)
    11. chlorodifluoromethane (HCFC-22)
    12. trifluoromethane (HFC-23)
    13. 1,1,1-trichloro-2,2,2-trifluoroethane (CFC-113)
    14. 1,2-dichloro-1,1,2,2-tetrafluoroethane (CFC-114)
    15. chloropentafluoroethane (CFC-115)
    16. 2,2-dichloro-1,1,1-trifluoroethane (HCFC-123)
    17. 2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124)
    18. pentafluoroethane (HFC-125)
    19. 1,1,2,2-tetrafluoroethane (HFC-134)
    20. 1,1,1,2-tetrafluoroethane (HFC-134a)
    21. 1-dichloro-1-fluoroethane (HCFC-141b)
    22. 1-chloro-1,1-difluoroethane (HCFC-142b)
    23. 1,1,1-trifluoroethane (HFC-143a)
    24. 1,1-difluoroethane (HFC-152a)
    25. The following classes of perfluorocarbon compounds:
      1. Cyclic, branched, or linear, completely fluorinated alkanes,
      2. Cyclic, branched, or linear, completely fluorinated ethers, with no unsaturations,
      3. Cyclic, branched, or linear, completely fluorinated tertiary amines with no unsaturations.
      4. Sulfur-containing perfluorocarbons with no unsaturations and with sulfur bonds only to carbon and fluorine. Perfluorocarbon compounds will be assumed to be absent from a product or process unless a manufacturer or facility operator identifies the specific individual compounds (from the broad classes of perfluorocarbon compounds) and the amounts present on the product or process and provides an EPA approved test method which can be used to quantify the specific compounds.
  27. WEB: A continuous sheet of substrate that is printed on web-fed printing presses.
  28. WEB-FEED: An automatic system on a printing press which supplies a web substrate to the printing unit.

231.3 STANDARDS

  1. Any person operating equipment for packaging gravure printing, specialty gravure printing, wall-paper screen printing, flexographic printing, lithographic printing, letterpress printing, and any related coating or laminating operations on porous or nonporous substrates, including detergent packages, shall comply with one of the following requirements:
    1. Use only low-VOC inks, coatings, adhesives, and fountain solutions as specified in Section 231.3 B., of this rule, or
    2. Install and operate on the line, an approved emission control system pursuant to Section 231.3 C., with a control device efficiency of at least 95 percent on a mass basis and an emission collection efficiency of at least 70% on a mass basis, or
  2. LOW-V0C INK, COATING, ADHESIVE, AND FOUNTAIN SOLUTION REQUIREMENTS: Any person choosing to comply with this rule through the use of low-VOC inks, coatings, adhesives, or fountain solutions shall comply with the following requirements:
    1. Use only inks, coatings, or adhesives, which contain, on an as-applied basis, 300 grams or less of VOC per liter of material (2.5 pounds per gallon), less water and compounds exempt from thedefinition of VOC. VOC content for inks, coatings, and adhesives shall be determined using the appropriate test method pursuant to Section 231.5 B., and the following equation:

        (Wm - Ww - Wex) / (Vm - Vw - Vex)

        Where:
        Wm = weight of all volatile compounds in grams or pounds
        Ww = weight of water in grams or pounds
        Wex = weight of compounds exempt from the definition of VOC, in grams or pounds
        Vm = volume of material in liters or gallons
        Vw = volume of water in liters or gallons
        Vex = volume of compounds exempt from the definition of VOC, in liters or gallons
         

    2. Use only fountain solutions which contain, on an as-applied basis, 116 grams or less of VOC per liter of material. VOC content for fountain solutions, as well as makeup solvents and surface preparation and cleanup solvents, shall be determined using the appropriate test method pursuant to Section 231.5 B., and the following equation:

        (Wm - Ww - Wex) / (Vm)

        Where:
        Wm = weight of all volatile compounds in grams or pounds
        Ww = weight of water in grams or pounds
        Wex = weight of compounds exempt from the definition of VOC, in grams or pounds
        Vm = volume of material in liters or gallons
         

  3. APPROVED EMISSION CONTROL SYSTEM REQUIREMENTS: A system for reducing emissions of volatile organic compounds, approved by the Air Pollution Control Officer, and which satisfies the following conditions:
    1. It includes a control device and collection system designed and operated to achieve the efficiencies specified in Section 231.3 A.2., at all times during normal operation of the line being controlled; and
    2. It includes a collection system which vents all drying oven exhaust to the control device.
  4. SURFACE PREPARATION AND CLEANUP SOLVENTS: Any person using surface preparation and cleanup solvents for graphic arts operations shall comply with the following requirements:
    1. Do not use open containers for the storage or disposal of VOC containing cloth or paper. All Volatile Organic Compound (VOC) containing materials are required to be stored in closed containers.
    2. Do not store unused or waste volatile organic compounds in open containers. All Volatile Organic Compounds (VOC) containing materials are required to be stored in closed containers.

231.4 ADMINISTRATIVE REQUIREMENTS

  1. COMPLIANCE SCHEDULE, LITHOGRAPHIC (INCLUDING OFFSET) AND LETTERPRESS PRINTING OPERATIONS: Any person using lithographic or letterpress printing operations shall be in compliance with the requirements of this rule by MARCH 27, 1995.
  2. OPERATION AND MAINTENANCE PLAN: Any person using an approved emission control device pursuant to Section 231.3 C., as a means of complying with this rule, as provided in Section 231.3 A., must submit, with the application for Authority to Construct, pursuant to Rule 501, General Permit Requirements, an Operation and Maintenance Plan for the emission control device to the Air Pollution Control Officer for approval. Plans for emission control devices installed as of SEPTEMBER 27, 1994, if not previously submitted, must be submitted by MARCH 27, 1995 and receive approval of the Air Pollution Control Officer. The Plan shall specify operation and maintenance procedures which will demonstrate continuous operation of the emission control device during periods of emissions-producing operations. The Plan shall also specify which records must be kept to document these operation and maintenance procedures. These records shall comply with the requirements of Sections 231.5 A.3., and 231.5 A.4. The Plan shall be implemented upon approval of the Air Pollution Control Officer.
  3. COMPLIANCE STATEMENT REQUIREMENT: The manufacturer or distributor of all inks, coatings, adhesives, fountain solutions, makeup solvents, and surface preparation and cleanup solvents which are sold for use in graphic arts operations within the District shall include on product data sheets a designation of both the as-supplied VOC content (prior to any recommended dilution) and the as-applied VOC content (based on any recommended dilution) of each material. The VOC content of inks, coatings, and adhesives shall be given pursuant to Section 231.3 B.1. The VOC content of fountain solutions, makeup solvents, and surface preparation and cleanup solvents shall be given pursuant to Section 231.3 B.2.

231.5 MONITORING AND RECORDS

  1. USAGE RECORDS: Effective MARCH 27, 1995, any person subject to this rule, including facilities claiming exemption under Sections 231.1 B.1., and 231.1 B.2., shall comply with the following requirements:
    1. The person shall maintain a current list of inks, coatings, adhesives, fountain solutions, makeup solvents (reducers, thinners), and surface preparation and cleanup solvents which states the VOC content of each, on an as-applied (press-ready) basis. The VOC content of inks, coatings, and adhesives shall be given pursuant to Section 231.3 B.1. The VOC content of fountain solutions, makeup solvents, and surface preparation and cleanup solvents shall be given pursuant to Section 231.3 B.2. For persons using graphic arts materials exceeding the VOC limits specified in Section 231.3 B., and using a control system pursuant to Section 231.3 C., daily records shall be maintained of the type and volume of graphic arts materials used.
    2. For persons using graphic arts materials which comply with the VOC limits specified in Section 231.3 B., records shall be maintained on a monthly basis, showing the type and volume of inks, coatings, adhesives, fountain solutions, and makeup solvents used, and solvents or other materials used for surface preparation, cleanup, or ink, coating, or adhesive removal.
    3. Such records shall be maintained on-site for two years and made available for review by the Air Pollution Control Officer upon request.
    4. Records as required by the Operation and Maintenance Plan in Section 231.4 B., shall be maintained by the source on a daily basis.
    5. Any person using Section 231.3 A.3., as a means of complying with this rule shall maintain the records stipulated in Section 231.5 A.2., on a daily basis, instead of monthly. In addition, the person shall maintain daily records of the number of production units produced per day.
  2. TEST METHODS
    1. ANALYSIS OF SAMPLES: Measurement of the volatile content in adhesives, coatings, fountain solutions, makeup solvents, surface preparation and cleanup solvents, and all inks (except as provided for in Section 231.5 B.2.) shall be made in accordance with EPA Method 24. EPA Method 24A shall be used for testing publication rotogravure inks.
    2. ANALYSIS OF SAMPLES, NONHEATSET POLYMERIZING LITHOGRAPHIC OR LETTERPRESS INKS: Measurement of the volatile content shall be made in accordance with EPA Method 24. All components of the sample must be weighed in the proper proportion into the analysis container and mixed together, with the mixture then being allowed to stand for at least one hour, but no more than 24 hours, prior to being oven-dried at 110 degrees C for 1 hour.
    3. DETERMINATION OF EXEMPT COMPOUNDS: Exempt compounds, as listed in Section 231.2 Y., shall be determined in accordance with ASTM D 4457-85 or ARB Method 432. If any of the perfluorocarbons are being claimed as exempt compounds, the person making the claim must state in advance which compounds are present, and the EPA-approved test method used to make the determination of these compounds.
    4. DETERMINATION OF CONTROL DEVICE EFFICIENCY: Control efficiency of control equipment shall be determined in accordance with EPA Method 25.
    5. DETERMINATION OF COLLECTION SYSTEM EFFICIENCY: Collection efficiency of the collection system shall be determined in accordance with EPA Guidelines for Developing Capture Efficiency Protocols, 55 Federal Register 26865, June 29, 1990.