UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

For

EPA’s Direct Final Rulemaking

For the

California State Implementation Plan

Mojave Desert Air Quality Management District, 

Rule 1117, Graphic Arts and Paper, Film, Foil and Fabric Coatings

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

October, 2011
2

Agency: Mojave Desert Air Quality Management District

(MDAQMD)

SIP Approved Rule: Rule 1117 – Graphic Arts

Adopted – June 22, 1994

Submitted – July 13, 1994

EPA Approved - April 30, 1996 (61 FR 18962)

Subject of this TSD: Rule 1117 – Graphic Arts and Paper, Film, Foil and 

Fabric Coatings

Amended – September 28, 2009

Submitted – July 20, 2010

RULE SUMMARY - MDAQMD Rule 1117, Graphic Arts and Paper, Film, Foil 

and Fabric Coatings, was amended both in response to the California Health and 

Safety Code §40702 and to the requirement of areas designated non-attainment 

and classified moderate to implement RACT as defined by the Control 

Technology Guidelines (CTG) for “major sources” of Volatile Organic 

Compounds (VOCs) and Nitrous Oxide Compounds (NOx). The modifications to 

Rule 117, Graphic Arts include:

1. Changed the title from Graphic Arts to Graphic Arts and Paper, Film, Foil 

and Fabric Coatings.

2. Revised the Applicability and Purpose sections to include additional paper, 

film, foil and fabric coating categories.

3. Updated definitions to make the rule more comprehensive, clear and 

applicable.

4. Added VOC limits for several new categories of coatings and solvents and 

overall capture and control efficiencies for main processes.

5. Included new application and solvent cleaning methods.

6. Added work practice requirements as defined in the CTGs.

7. Changed exemptions from a minimum VOC emission basis to specific 

graphic processes, like digital printing operations, and minimum quantities 

of inks. 

8. Revised monitoring and recordkeeping to address specific types of 

materials and processes.

9. Added test methods for specific content and for transfer, capture and 

control efficiencies.

10. Added an overall violation provision when multiple test methods are 

employed and there is a violation of one method.

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 

Deficiencies, EPA Region 9, August 21, 2001), and State Implementation 

Plans, General Preamble for the Implementation of Title I of the Clean Air 
3

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 CTG titled Flexible Package Printing (EPA 453/R06-003, September 2006); CTG titled Offset Lithographic Printing and 

Letterpress Printing (EPA 453/R-06-002, September 2006); CTG titled 

Paper Film and Foil Coatings (EPA 453/R-07-003, September 2007); 

OAQPS Guideline titled Control of VOCs from Existing Stationary Sources 

– Volume II: Surface Coating of Cans, Coils, Paper, Fabric s, Automobiles 

and Light-Duty Trucks (EPA 450/2-77-008,May 1977); OAQPS Guideline

titled Control of VOCs from Existing Stationary Sources – Volume VIII: 

Graphic Arts-Rotogravure and Flexography(EPA 450/2-78-033, December 

1978) and CTG titled Industrial Cleaning Solvents (EPA 453/R-06-

001,September 2006) and other districts’ analogous rules for this category 

were used as the basis for RACT including: San Joaquin Valley Unified Air 

Pollution Control District (SJVUAPCD) Rule 4607, Graphic Arts and Paper, 

Film, Foil and Fabric Operations amended December 18, 2008, Bay Area 

Air Quality Management District (BAAQMD) Rule 8-20, Graphic Arts 

Printing and Coating Operations, amended November 19, 2008 and 

Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 

450, Graphic Arts Operations, revised October 23, 2008.

3. SIP Relaxation – CAA §110(l) prohibits EPA from approving any SIP 

revision that would interfere with any applicable requirement concerning 

attainment and reasonable further progress (RFP) or any other applicable 

requirement of the CAA. In addition, CAA §193 prohibits the modification of 

any SIP-approved control requirement in effect before November 15, 1990, 

in a nonattainment area.

Enforceability - The testing, recordkeeping, monitoring and other rule 

requirements, along with the additional caveat for multiple test methods, generally 

ensure that the submitted rule can be enforced. 

Stringency – Rule 1117 is generally as stringent as the relevant CTGs and 

analogous rules in other nonattainment areas that we have approved as RACT 

(74 FR 52894). Therefore, we believe Rule 1117 also fulfils CAA RACT 

requirements for affected sources. 

SIP Relaxation – The District has lowered the limits for several categories of 

graphic arts inks, coatings and adhesives and has increased the overall capture 

and control efficiency for all processes. We propose to determine that our approval 

of the submittal would comply with CAA §110(l) because the amended rule is more 

stringent than the rule previously approved into SIP and would not interfere with 

the ongoing process for ensuring that requirements for RFP and attainment of the 

NAAQS are met. 
4

EPA ACTION - EPA staff recommends a full approval of Rule 1117 pursuant to 

CAA §110(k) (4) and §301(a). 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION –

1. Section B, Definitions:

a. Subsection (20) – “Doctor Blade” – Consider removing the word 

“steel” as there are doctor blades that are not steel.

b. Subsection (25) – Please correct spelling error in the word 

“Electrophotography”

c. Subsection (27) - “Exempt Compound” - Consider adding “VOC” 

or, as SJVUAQMD has done, adding “Organic” before “Compound” 

to more succinctly describe the exempt compound.

d. Subsection (56) – “Liquid Leak” should apply to all coatings, ink and 

solvents. Consider deleting the word “Solvent” to more accurately 

describe a liquid leak. This will also make the definition of “NonLeaking Container” in subsection (68) more comprehensive.

e. Subsection (110) “Wash Primer” – For clarity, please rephrase the 

definition to: “A material that contains no more than 5 percent, by 

weight, solid materials, and that is used to clean and/or to activate 

surfaces of paper or fabric.”

2. Section F, Test Methods:

a. Subsection (2) – Please add the date December 13, 1991 to ARB 

Method 422.

b. Subsection (4) - Please revise SCAQMD Test Method 318 to Test 

Method 318-95 and add the date, July 1996, after the title. 

Additionally, please note that the use of this method for metals other 

than aluminium requires validation.

ADDITIONAL REFERENCES -

1. MDAQMD Rule 1117, Graphic Arts and Paper, Film, Foil and Fabric 

Coatings, as submitted on July 20, 2010.

2. MDAQMD Rule 1117, Graphic Arts, adopted June 22, 1994.

3. SJVUAPCD Rule 4607, Graphic Arts and Paper, Film, Foil and Fabric 

Operations amended December 18, 2008

http://www.valleyair.org/rules/currntrules/r4607.pdf

4. BAAQMD Rule 8-20, Graphic Arts Printing and Coating Operations,

amended November 19, 2008.

http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/Rule

s%20and%20Regs/reg%2008/rg0820.ashx?la=en

5. SMAQMD Rule 450, Graphic Arts Operations, revised October 23, 2008.

http://www.airquality.org/rules/rule450.pdf
5

6. “Control Techniques Guidelines for Industrial Cleaning Solvents,” EPA 

453/R-06-001,September 2006

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r-06-

001_ind_cleaning_solvents.pdf

7. “Control Techniques Guidelines for Offset Lithographic Printing and 

Letterpress Printing,” EPA 453/R-06-002, September 2006.

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r-06-

002_litho_letterpress_printing.pdf

8. “Control Techniques Guidelines for Flexible Package Printing,” EPA 453/R06-003, September 2006.

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r-06-

003_flexible_package_printing.pdf

9. “Control Techniques Guidelines for Paper Film and Foil Coatings,” EPA 

453/R-07-003, September 2007

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200709_voc_epa453_r-07-

003_paper_film_coating.pdf

10. OAQPS Guideline “Control of VOCs from Existing Stationary Sources –

Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles 

and Light-Duty Trucks,” EPA 450/2-77-008, May 1977

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/197705_voc_epa450_2-77-

008_surface_coatings(v2).pdf

11. OAQPS Guideline “Control of VOCs from Existing Stationary Sources –

Volume III: Graphic Arts-Rotogravure and Flexography,” EPA 450/2-78-

033, December 1978

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/197812_voc_epa450_2-78-

033_graphic_arts(v8).pdf 

12. “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

13. “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