UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

For

EPA’s Proposed Rulemaking

For the

California State Implementation Plan

Ventura County Air Pollution Control District, 

Rule 74.20, Adhesives and Sealants

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

May 2013
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Agency: Ventura County Air Pollution Control District (VCAPCD)

SIP Approved Rule: Rule 74.20 – Adhesives and Sealants

Adopted – June 8, 1993

Revised – January 11, 2005

Submitted – April 26, 2005

EPA Approved – November 24, 2008 (73 FR 70883)

Subject of this TSD: Rule 74.20 – Adhesives and Sealants

Revised – September 11, 2012

Submitted – April 22, 2013

RULE SUMMARY - VCAPCD Rule 74.20, Adhesives and Sealants, was amended 

to implement an All Feasible Measure as required by the California Clean Air Act 

(Health and Safety Code §40914) in order to attain the ozone ambient air quality 

standard. Rule 74.20 was also amended to comply with the federal reasonably 

available control technology (RACT) established in the 2008 Control Technique 

Guideline (CTG) for Miscellaneous Industrial Adhesives,

1 CTG for Industrial 

Cleaning Solvents2and the State of California Air Resources Board (CARB) 

Determination of Reasonably Available Control Technology and Best Available 

Retrofit Control Technology (BARCT) for Adhesives and Sealants.

3

 

1. EPA-453/R-08-005 Control Techniques Guidelines for Miscellaneous Industrial Adhesives, 

September 2008.

2. EPA-453/R-06-001 Control Techniques Guidelines for Industrial Cleaning Solvents, September 

2006.

3. State of California Air Resources Board (CARB) Determination of Reasonably Available Control 

Technology and Best Available Retrofit Control Technology (BARCT) for Adhesives and Sealants, 

December 1998.
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The modifications to Rule 74.20, Adhesives and Sealants include:

1. Revised the Substrate Surface Preparation limits in Section B-4 to expire on 

December 1, 2012 with an effective date of December 1, 2012 for the new 

limit of 25 grams/liter for a general substrate surface preparation category. 

Inkjet printer head assemblies will continue to have a 200 grams/liter limit. 

2. Stated that partial pressure is not a valid metric for Reactive Organic 

Compounds (ROC)-containing materials after the effective date of December 

1, 2012 in Section B-5. 

3. Clarified the storage requirements for ROC-containing materials in Section 

B-6.

4. Revised the Adhesive Spray Application Equipment Cleaning limits to expire 

on December 1, 2012 with an effective date of December 1, 2012 for the 

new limit of 25 grams/liter for ROC-containing spray application equipment 

cleaning materials in Section B-7.

5. Removed control equipment parameters that are redundant to the statement 

that the equipment be approved by the Air Pollution Control Officer (APCO)

in Section B-8.

6. Removed the already-expired 2005 effective date for sell-through of noncomplying adhesives in Section C-6. 

7. Clarified recordkeeping requirements in Section D.

8. Added titles and EPA approved version dates for all non-EPA test methods

in Section E.

9. Added or revised definitions in Section G to provide clarity and 

completeness. 

EPA EVALUATION - The following criteria were used to evaluate the submitted 

rule. 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation Cutpoints, 

Deficiencies, and Deviations, EPA, May 25, 1988), the Little Bluebook 

(Guidance Document for Correcting Common VOC & Other Rule 
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Deficiencies, EPA Region 9, August 21, 2001), and State Implementation 

Plans, General Preamble for the Implementation of Title I of the Clean Air 

Amendments of 1990 (57 FR 13498, April 16, 1992) were used to help 

evaluate compliance with the CAA §110(a)(2)(A) requirement for 

enforceability. 

2. Stringency – The EPA’s CTGs titled Miscellaneous Industrial Adhesives, 

(EPA 453/R-08-005, September 2008) and Industrial Cleaning Solvents 

(EPA 453/R-06-001, September 2006) and CARB’s Determination of 

Reasonable Available Control Technology (RACT) and Best Available Retrofit 

Control Technology (BARCT) for Adhesives and Sealants (December 1998)

were used to establish RACT for adhesives and sealants. Other districts’

analogous rules for this category were used as the basis for RACT including:

South Coast Air Quality Management District (SCAQMD) Rule 1168, 

Adhesive and Sealant Applications, amended January 7, 2005, and San 

Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) Rule 4653, 

Adhesives and Sealants, amended September 16, 2010.

3. SIP Relaxation – We have evaluated this SIP revision to determine whether it 

would interfere with any applicable requirement concerning attainment and 

reasonable further progress (RFP) or any other applicable requirement of the 

Act (CAA §110(l)) or modify, in a nonattainment area, any SIP-approved 

control requirement in effect before November 15, 1990 (CAA §193).

Enforceability - The recordkeeping requirements for Adhesives and Sealants are 

generally analogous to that of SCAQMD’s rule 1168 and SJVUAPCD’s rule 4653. All 

test methods resemble the CARB’s Determination of RACT and BARCT for 

Adhesives and Sealants. Unlike the SJVUAPCD and SCAQMD rules, transfer 

efficiency is not specifically addressed in this rule. Only an adhesive spray application 

is discussed in this rule and the 25 grams/liter solvent limit restricts the VOC 

emissions for cleaning this type of equipment. Capture efficiency is adequately 
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defined and the minimum percentage of 85 percent is the same as the 2008 CTG 

and SJVUAPCD’s rule. Therefore, we propose to determine that submitted Rule 

74.20 is sufficiently clear and enforceable.

Stringency – We believe Rule 74.20 generally meets RACT. Overall, it is as stringent 

as, and in many cases more stringent than, the 2008 CTG and CARB’s 1998 

“Determination of RACT and BARCT for Adhesives and Sealants”. The only 

exception is the Plastic Solvent Welding (PVC) limit of 510 grams per liter which is 

slightly higher than the CTG 500 grams per limit for Plastic Solvent Welding (except 

ABS). VCAPCD’s Rule 74.20 closely resembles SCAQMD’s Rule 1168 for VOC 

limits for adhesives, adhesive primers, sealants and sealant primers and for solvent 

cleaning activities. VCAPCD’s Rule 74.20 also addresses limits for adhesive strippers 

which the CTG, CARB determination and other district rules do not. However, this 

rule does not specify application methods. 

Other exceptions in which this rule meets the CTG or the CARB RACT/BARCT limit,

but is not as stringent as other SIP rules are:

 Top and Trim Adhesive with a limit of 540 grams/liter: There are no

similar categories in with the CTG or CARB Determination of RACT and 

BARCT although the CTG indicates an 850 grams/liter limit for Motor 

Vehicle Adhesive. Both SCAQMD Rule 1168 and AVAQMD Rule 1168 

have 250 grams/liter limits for this same category. However, the one 

source which emits VOCs from this category emits 500 lbs/year, well 

under the 15 lbs/year allowed by the CTG.

 ABS Welding with a limit of 400 grams /liter: Although this limit resembles 

the limits in the CTG and the CARB Determination of RACT and BARCT, 

both SCAQMD Rule 1168 and AVAQMD Rule 1168 have 325 grams/liter 

limits for this same category. 

 Other Plastic Welding with a limit of 500 grams/liter: This limit is equal to 

the CTG and lower than the CARB Determination of RACT and BARCT 
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but SBAPCD Rule 353, SCAQMD Rule 1168, SJVUAPCD Rule 4653 and 

AVAQMD Rule 1168 have established limits of 250 grams/liter for this 

category.

 Plastic Welding Primer with a limit of 650 grams/liter: While this limit is 

equivalent to that of the CTG, it exceeds the 510 grams/liter limit of the 

CARB Determination of RACT and BARCT, is considerably higher than the 

400 grams/liter limit for proposed PCAPCD Rule 235 and for SJVUAPCD 

Rule 4653 and is somewhat higher than the 550 grams/liter limit of 

SCAQMD Rule 1168 and AVAQMD Rule 1168. 

We recommend that the lower limits for these four categories be considered for the 

next revision of this rule.

The definition of VOC in Section G, Subsection 74, referencing the definition in 

VCAPCD’s Rule 2, does not comply with the 40 CFR 51.100(s)(5) which exempts 

t-butyl acetate (TBAc) except for recordkeeping, emissions reporting, photochemical 

dispersion monitoring and inventory requirements which apply to VOC. However, we 

do not believe that omitting the requirement for recordkeeping, emissions reporting, 

photochemical dispersion modeling and inventory requirements of the exempt 

compound TBAc is sufficient basis to disapprove this rule. It is our conclusion that 

“...TBAc will not be VOC for purposes of VOC emissions limitations or VOC content 

requirements,”

4 which are the basis for compliance with this rule by a facility. In 

addition, the State will continue to assume the responsibility for the reporting, 

modeling and inventory requirements.

Based on the discussion above, we propose to determine that submitted Rule 74.20

fulfills RACT requirements and is sufficiently stringent.

SIP Relaxation – The new submittal generally complies with CAA §110(l) and §193 

regarding SIP relaxations. In this revision, only the “All Other” Substrate Surface 

 

4. 40 CFR §51.100(s)(5).
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Preparation category VOC limit has been lowered from 70 grams/liter to 25 

grams/liter and the cleaning of adhesive spray application equipment is limited to 

solvents containing 25 grams/liter VOC. 

Therefore, we propose to determine that submitted Rule 74.20 has not relaxed the 

SIP rule in conflict with CAA sections 110(l) or 193.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION –

1. Section B, Requirements: We recommend that the following limits be 

considered as discussed above: 

b. 250 grams/liter for Top and Trim Adhesive

c. 325 grams/liter for ABS Welding 

d. 250 grams/liter for Other Plastic Welding

e. 400 grams/liter for Plastic Welding Primer

2. Section C, Exemptions:

Subsection 5 – SCAQMD’s Rule 1168 removed the exemption for “a facility 

that demonstrates that the total volume of non-compliant adhesive, adhesive 

primers, adhesive bonding primers, sealants, and sealant primers is less than 

55 gallons per facility per rolling 12-month period.” September 1, 2001.

SJVUAPCD’s Rule 4653 exempts a stationary source that “uses 20 gallons 

or less of adhesives products in a calendar year.” Please consider either 

eliminating this exemption effective within a reasonable time period or 

lowering the de minimus limit to 20 gallons per facility per rolling 12 

consecutive months. 

2. Section E, Test Methods:

Subsection 2 – Please add the complete title for ASTM D4457-91: Standard 

Test Method for Determination of Dichloromethane and 1,1,1-Trichloromethane 

in Paints and Coatings by Direct Injection into Gas Chromatograph.
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EPA ACTION - EPA staff recommends a full approval of Rule 74.20 pursuant to 

CAA §110(k) (4) and §301(a). 

ADDITIONAL REFERENCES -

1. SCAQMD Rule 1168, Adhesive and Sealant Applications, amended January 

7, 2005. http://www.aqmd.gov/rules/reg/reg11/r1168.pdf

2. SJVUAPCD Rule 4653, Adhesives and Sealants, amended September 16, 

2010. http://www.valleyair.org/rules/currntrules/r4653.pdf

3. Control Techniques Guidelines for Miscellaneous Industrial Adhesives, EPA 

453/R-08-005, September 2008

http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/200809_v

oc_epa453_r-08-005_miscellaneous_industrial_adhesives.pdf

4. Control Techniques Guidelines: Industrial Solvents, EPA-453/R-06-001, 

September 2006.

http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/200609_v

oc_epa453_r-06-001_ind_cleaning_solvents.pdf

5. State of California Air Resources Board Determination of Reasonably 

Available Control Technology and Best Available Retrofit Control Technology 

for Adhesives and Sealants, December 1998.

http://www.arb.ca.gov/ractbarc/adhfinal.pdf

6. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” 

(a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf

7. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.

http://www.epa.gov/region9/air/sips/littlebluebook2001.pdf