BOARD MEETING

DATE: January 12, 1996

AGENDA NO. 15

REPORT: Feasibility of Monthly Recordkeeping for Flexographic, Gravure, Letterpress, and Lithographic Printing Operations

SYNOPSIS: On September 8, 1995, the Board directed staff to evaluate the feasibility of monthly recordkeeping for Rule 1130 - Graphic Arts printing operations. This report indicates that monthly recordkeeping may be viable for part of the industry but some enforcement issues still need to be resolved. In addition, it recommends that pursuit of monthly recordkeeping be postponed until after the VOC RECLAIM recordkeeping protocols and requirements are adopted. This report also identifies several simplified daily recordkeeping procedures that may be used by segments of the printing industry.

RECOMMENDED ACTION

1. Receive and file this report

James M. Lents, Ph.D.

Executive Officer

PL:JB:FL

Attachment

A. Feasibility of Monthly Recordkeeping for Rule 1130 - Graphic Arts

_____________________________________________________________________

On September 8, 1995, the Printing Industries of California (PIC) requested the Board to have staff investigate the feasibility of allowing monthly recordkeeping for flexographic, gravure, letterpress, and lithographic printing operations. The Board directed staff to conduct the necessary evaluation and report back on January 12, 1996. On November 16, 1995, staff briefed the Stationary Source Committee regarding their preliminary findings.

The report concludes that pursuit of monthly recordkeeping for small non-RECLAIM lithographic printers should be postponed until after the VOC RECLAIM recordkeeping protocols and requirements are adopted. Significant effort is being spent in developing simplified and enforceable recordkeeping criteria for VOC RECLAIM and the work completed under that program may be able to be used to streamline recordkeeping for a few hundred permitted printers. In order to accomplish this objective, a number of rule amendments will be needed. Details are described in the staff report.

Currently, 750 printing facilities are permitted. Most printers in the basin (circa 1,750 facilities) are very small and are exempt from needing a permit under Rule 219.

A simplified recordkeeping system, based on quarterly reports, is under development for VOC RECLAIM. The following table indicates the number and types of facilities proposed for this system.

Printing Facility Universe
	Number of Permitted Facilities	Number In VOC RECLAIM(Mass Cap w/Quarterly Records)
Lithographic	564	126
Flexographic	167	48
Gravure	8	5
Letterpress	11	1
Total	750	180

The staff report assesses the opportunities to use a monthly recordkeeping system for those printers where "supplied" materials have the same VOC content as the materials "applied". The viable use of monthly records to determine rule compliance is based on whether the materials are mixed or thinned before use. The next table summarizes the results of the analysis.

Monthly Recordkeeping
	Number of Non-RECLAIM Permitted Facilities	Viable Candidate
Lithographic	438	Possible
Flexographic	119	Not Feasible for Most
Gravure	3	Very Few
Letterpress	10	Very Few
Total	570	---

This report identifies several simplified daily recordkeeping procedures that may be used by segments of the printing industry. AQMD staff has developed a simplified, computerized, daily recordkeeping spread sheet for printers to use. This Microsoft Excel software-based program is available to interested printers at no charge.

Staff will continue to work with the Printing Industries of California to develop, evaluate, and implement simplified recordkeeping systems for the printing industry.