UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Proposed Rulemaking

for the

California State Implementation Plan

Rule 1130 Graphic Arts;

Rescission of Rule 1128, Paper, Fabric and Film Coating Operations

Prepared by: Vanessa Graham

Reviewed by: Andrew Steckel

August 2015
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RULE IDENTIFICATION

Agency: Antelope Valley Air Quality Management District (AVAQMD)

SIP-Approved Rule: South Coast Air Quality Management District (SCAQMD)

Rule 1130 – Graphic Arts

Adopted – September 8, 1995

Submitted – October 13, 1995

Approved – October 31, 1995 (60 FR 55312)

South Coast Air Quality Management District (SCAQMD)

Rule 1128 – Paper, Fabric, and Film Coating Operations

Adopted – February 7, 1992

Submitted – September 14, 1992 

Approved – December 20, 1993 (58 FR 66286)

Subject of this TSD: AVAQMD Rule 1130 – Graphic Arts

Adopted – November 19, 2013

Submitted – May 13, 2014

AVAQMD Rule 1128 – Paper, Fabric, and Film Coating 

Operations

Rescinded – November 19, 2013

Submitted – May 13, 2014

BACKGROUND – Prior to July 1, 1997, the area regulated by AVAQMD was contained within 

the SCAQMD boundaries. On July 1, 1997, the Antelope Valley Air Pollution Control District 

(AVAPCD) was created and took over responsibilities for the jurisdiction of the Los Angeles 

County portion of the Mojave Desert Air Basin. Rules and regulations of the SCAQMD were 

retained until the AVAPCD governing board adopted, rescinded or amended these rules. 

Therefore, SCAQMD Rules 1128 and 1130, adopted by SCAQMD in 1992 and 1995, and 

approved by EPA in 1993 and 1995 respectively, became part of the AVAPCD SIP. On January 

1, 2002, the Antelope Valley Air Quality Management District (AVAQMD) was created to 

replace AVAPCD.

The AVAQMD is classified as severe nonattainment with respect to the 1997 and 2008 8-hour 

ozone National Ambient Air Quality Standards (NAAQS). The proposed amendments of Rule 

1130 were submitted largely to satisfy Federal Reasonably Available Control Technology (RACT)

requirements pursuant to Clean Air Act (CAA) section 182(b)(2). AVAQMD is rescinding Rule 

1128, because it is now superseded by redundant requirements in revised Rule 1130. AVAQMD’s 

recession only applies to AVAQMD Rule 1128, and has no effect on SCAQMD Rule 1128.

RULE SUMMARY – Rule 1130 limits volatile organic compound (VOC) emissions largely by 

limiting the VOC content of coatings and solvents used in graphic arts printing processes

including lithographic, flexographic, letterpress, gravure and digital, in addition to coating 
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operations for paper, fabric film and foil. Revisions to the SIP-approved version of Rule 1130

include the following:

1. More stringent VOC content limits for graphic arts product categories and solvent 

cleaning operations in: Section (C) Table 1 – VOC Content Limits for Adhesives, 

Coatings and Inks; Table 2 – VOC Content Limits for Fountain Solutions; Table 3 – VOC 

Content Limits for Flexographic Specialty Ink; and Table 5 – VOC Content Limits for 

Solvent Cleaning. 

2. Capture and control efficiency requirements were strengthened in Section (C) Table 4 –

VOC Emission Control System Overall Capture and Control Efficiency.

3. Solvent cleaning operations have been strengthened. Section (C) (7) adds more specific 

VOC limits for solvent operations beyond the provisions of District Rule 1171 – Solvent 

Cleaning Operations.

4. General Recordkeeping requirements pursuant to District Rule 109 – Recordkeeping for 

Volatile Organic Compounds have been strengthened and clarified with the addition of 

Section (E) Recordkeeping Requirements. Digital Printing recordkeeping requirements

have been added.

5. Work practices from the Control Techniques Guidelines (CTG) have been incorporated 

into the provisions of Section (C)(11).

6. The provisions of Rule 1128 – Paper, Fabric and Film Coating Operations have been 

incorporated into the revised version of Rule 1130. No part of Rule 1128 has been omitted, 

except those sections that have been superseded by date. These minor changes do not relax 

the requirements. 

The proposed amendments were submitted in part to satisfy Federal RACT requirements detailed 

in applicable CTG.

RULE EVALUATION CRITERIA – We primarily used the following criteria to evaluate the 

submitted rule:

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

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

Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, 

August 21, 2001) were used to help evaluate compliance with the CAA §110(a)(2)(A) 

requirement for enforceability. 

2. Rule Stringency – AVAQMD regulates an area classified as severe nonattainment for

both the 1997 and 2008 8 hour ozone NAAQS, 40 C.F.R. § 81.305. Under CAA section 

182(b)(2), ozone nonattainment areas classified as moderate or above must implement 

RACT for all VOC sources covered by a CTG document and all major sources of VOCs.
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Lithographic, flexographic, letterpress and gravure printing are all covered by CTG 

documents. 

3. SIP Relaxation – CAA section 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 

section 193 prohibits the modification of any SIP-approved control requirement in effect 

before November 15, 1990, in a nonattainment area.

In applying these criteria to the submitted rule, we referred to the following guidance and 

policy documents.

• State Implementation Plans; General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 

28, 1992).

• Final Rule To Implement the 8-Hour Ozone NAAQS – Phase 2, 70 FR 71612 (Nov. 25, 

2005).

• CTG for Flexible Package Printing (EPA 453/R-06-003, September 2006).

• CTG for Offset Lithographic Printing and Letterpress Printing (EPA 453/R-06-002, 

September 2006).

• CTG for Paper, Film, and Foil Coatings (EPA 453/R-07-003, September 2007).

• Control of Volatile Organic Emissions from Stationary Sources Volume VIII: Graphic 

Arts-Rotogravure and Flexography (EPA 450/2-78-033, December 1978).

• Alternative Control Techniques Document, Offset Lithographic Printing (ACT, EPA453/R-94-054 June 1994).

EPA EVALUATION – A summary of our evaluation of the three criteria follows:

Enforceability – Monitoring, reporting and recordkeeping (MRR) requirements of Rule 1130 

have been improved in several respects, including:

• Previous recordkeeping requirements specified a two year onsite record retention. Section 

(E)(7) now requires record retention for five years.

• Rule 1130 Section (E)(5) now requires recordkeeping for Digital Printing Operations 

meeting specified parameters. 

• Test methods have been updated.

The MRR and other requirements generally ensure that the submitted Rule 1130 is sufficiently 

clear and enforceable consistent with CAA section 110(a) (2)(A).

Stringency – The submitted rule is as stringent as the following EPA 2006/2007 CTGs that 

generally define presumptive RACT for this activity nationwide. 

• CTG for Flexible Package Printing (EPA 453/R-06-003, September 2006).
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• CTG for Offset Lithographic Printing and Letterpress Printing (EPA 453/R-06-002, 

September 2006).

• CTG for Paper, Film, and Foil Coatings (EPA 453/R-07-003, September 2007). .

AVAQMD’s staff report states that San Joaquin Valley Air Pollution Control District 

(SJVAPCD) Rule 4607 – Graphic Arts and Paper, Film, Foil and Fabric Operation, approved 

October 15, 2009 (74 FR 52984) was used as a basis for the amendments to Rule 1130 – Graphic 

Arts.

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AVAQMD Rule 1130 is largely consistent with the relevant CTGs and analogous rules including 

SJVAPCD Rule 4607 and those identified in the “Additional References” section below. As a 

result, we have determined that this rule fulfills RACT requirements.

SIP Revisions – AVAQMD’s 2013 amendment improved the earlier versions of Rules 1128 and 

1130 by revising the structure and requirements to be more aligned with the CTGs. Many new

definitions were included to provide for additional clarity. VOC limits for previously unregulated 

categories were added. VOC content limits, recordkeeping and test method requirements were 

improved. All substantive requirements of Rule 1128 were incorporated into the amended 

version of Rule 1130. We therefore propose to determine that our approval of revised Rule 1130 

and rescission of Rule 1128 would comply with CAA sections 110(l) and 193 because these 

actions (1) will insure equivalent or greater emission reductions of VOCs, and (2) will not 

interfere with the on-going process for ensuring that requirements for RFP and attainment of the 

NAAQS are met.

RULE DEFICIENCIES – We have identified no deficiencies in submitted Rule 1130 sufficient 

for EPA to propose less than full approval. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – The 

following recommendations are not currently the basis for rule disapproval, but we encourage 

AVAQMD to incorporate them the next time the rule is amended:

1. (C)(5)(i) Requirements for Coating Applications – Paragraph (i) allows use of other 

coating application methods that are capable of “achieving at least 65 percent Transfer 

Efficiency” using the test method in Section (H)(8). The test method in Section (H)(8) 

only applies to spray equipment, which appears to duplicate Section (C)(5)(h) allowance 

for alternatives to high-volume low-pressure (HVLP) spray equipment. AVAQMD may 

want to review the applicability of Section (C)(5)(i) the next time the rule is amended. 

See SCAQMD Rule 1128 Section (C) (6)(H). 

2. (E)(3) Non-compliant Materials Records - Please add the following: “Violations of the 

requirement are considered to separate violations for each day.” 

3. An editorial error in section (G), Emission Reduction Credits (ERC), seems to allow 

sources to claim permit offsets for flexographic coatings above 300 g/l. AVAQMD’s 

 

1 Final Staff Report, Amendment of Rule 1130 – Graphic Arts and Rescission of Rule 1128 – Paper, Fabric and 

Film Coating Operations, Adopted on November 19, 2013, page 2.
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email dated April 30, 20152 confirms that there are no flexographic printing operations in 

the District, and that no facility has used this provision. Nonetheless, please correct or 

delete this provision at the next rule revision. 

4. (H) Test Methods (1) - Include the Title for EPA Test Method 24 (Determination of 

Volatile Matter Content, Water Content, Density Volume Solids, and Weight Solids of 

Surface Coatings) and EPA Test Method 24A (Determination of Volatile Matter Content 

and Density of Printing Inks and Related Coatings).

5. (H) Test Methods (2) and (5) - The Little Blue Book recommends that references to EPAapproved ASTM methods should include the full title and date of the version being 

specified.

EPA ACTION – The submitted revised Rule 1130, and rescinded Rule 1128 adequately address

the relevant CAA criteria for the reasons discussed above. As a result, EPA staff recommends a 

full approval of Rule 1130 and the rescission of Rule 1128 pursuant to CAA section 110(k)(3). 

ADDITIONAL REFERENCES

• San Joaquin Valley Air Pollution Control District (SJVAPCD) Rule 4607 Graphic Arts 

and Paper, Film, Foil and Fabric Coatings, approved October 15, 2009, 74 FR 52894.

• SCAQMD Rule 1128 Paper, Fabric and Film Coating Operations, approved May 4, 1999,

64 FR 23774.

• SCAQMD 1130 Graphic Arts approved September 23, 2000, 65 FR 55201.

• AVAQMD Rule 109 Recordkeeping for Volatile Organic Compounds approved March 1, 

2012 77 FR 12495.

• AVAQMD Rule 1171 Solvent Cleaning Operations, approved May 24, 2001, 66 FR 

28666.

• Email from Tracy Walters, Lead Air Quality Planner AVAQMD, to Vanessa Graham 

dated April 30, 2015

 

2 Email from Tracy Walters, Lead Air Quality Planner AVAQMD, to Vanessa Graham dated April 30, 2015.