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 74.19, Graphic Arts 

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

October 2012
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Agency: Ventura County Air Pollution Control District (VCAPCD)

SIP Approved Rule: Rule 74.19 – Graphic Arts

Adopted – August 11, 1992

Revised – November 11, 2003

Submitted – April 26, 2005

EPA Approved – October 25, 2005 (70 FR 61561)

Subject of this TSD: Rule 74.19 – Graphic Arts 

Revised – June 14, 2011

Submitted – September 27, 2011

RULE SUMMARY - VCAPCD Rule 74.19, Graphic Arts, 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 74.19 was also amended to comply with the federal reasonably available 

control technology (RACT) established in the 2006 Control Technique Guideline 

(CTG) for Offset Lithographic Printing and Letterpress Printing. The modifications to 

Rule 74.19, Graphic Arts include:

1. Revised the applicability of the rule’s provisions in subsection A-2 to include 

manufacturers and suppliers outside the district. 

2. Removed 1993 ROC limits in subsection B-1 and adopted the April 1, 2002 

limits for Inks, Coating and Adhesives. 

3. Removed the 1993 ROC limits and revised the effective date of April 1, 

2002 limits to January 1, 2012 for Fountain Solutions in subsection B-2. 

Added a table for limits effective January 1, 2012 for Fountain Solutions and

a requirement for temperature sensors for refrigerated chillers.

4. Removed 2002 ROC limits for cleaning solutions in subsection B-3 and 

replaced this with a table of new limits based on grams/liter and composite 
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partial pressure effective until January 1, 2012. Added a table with more 

stringent limits effective after January 1, 2012.

5. Removed the already-expired 2002 effective date for prohibiting the use of 

Methylene Chloride in subsection B-4.

6. Increased the overall capture and control efficiency for an emission capture 

and control system in subsection B-6 from 75% to 80%.

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

8. Added subsection B-10 to prohibit the specification of graphic arts products 

not meeting the limits of the rule.

9. Added exemptions in subsections C-2 and C-3 for digital printing operations, 

proof presses, pre-press operations, blanket-repair operations, aerosol 

coating products and specific cleaning solvents.

10. Revised the recordkeeping requirements in subsection D-2 for Fountain 

Solutions, effective January 1, 2012.

11. Removed the provision for making recordkeeping a part of Permit to Operate

in section D.

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

in Section E.

13. 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 

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

enforceability. 

2. Stringency –The EPA’s CTG titled Industrial Cleaning Solvents (EPA 453/R06-001,September 2006) and CTG titled Offset Lithographic Printing and 

Letterpress Printing (EPA 453/R-06-002, September 2006). Other districts’

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

Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 

450, Graphic Arts Operations, revised October 23, 2008, Bay Area Air 

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

Coating Operations, amended November 19, 2008 and San Joaquin Valley 

Unified Air Pollution Control District (SJVUAPCD) Rule 4607, Graphic Arts 

and Paper, Film, Foil and Fabric Operations amended December 18, 2008.

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 Graphic Arts are analogous to 

that of SMAQMD’s rule 450. The exception is that this VCAPCD rule does not 

require the recording of density of ink as SMAQMD’s Rule 450 does and the density 

of coatings, inks, adhesives, fountain solutions, and solvents as SJVUAPCD’s Rule 

4607 does. All test methods for specific compounds, inks and means to determine 

overall capture and control efficiencies also generally resemble those analogous 

RACT rules. The additional exemptions are generally similar to those exempted in

SJVUAPCD’s Rule 4607. These parameters and the additional statement for 

multiple test methods, generally ensure that the submitted rule can be enforced. 
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Therefore, we propose to determine that submitted Rule 74.19 is sufficiently clear 

and enforceable.

Stringency – In the June 2009 Technical Support Document (TSD) for SJVUAPCD 

Rule 4607 it was determined that this rule demonstrated RACT because it is as 

stringent as the three current CTGs and, as a nonattainment area, generally 

SJVUAPCD rules have among the most stringent stationary source requirements 

nationwide. VCAPCD’s Rule 74.19 closely resembles SJVUAPCD’s Rule 4607 for 

VOC limits for coating, inks and adhesives and for solvent cleaning activities. 

VCAPCD’s Rule 74.19 resembles SMAQMD’s Rule 450 for VOC limits for fountain 

solution materials. In general, the application methods and work practices of 

VCAPCD’s Rule 74.19 are comparable to both SJVUAPCD’s Rule 4607 and 

SMAQMD’s Rule 450. In addition, prohibiting the specification of graphic arts 

materials that do not meet the rule’s limits was added to make the rule more 

stringent. 

The definition of VOC, 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”

1

, 

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.

 

1. 40 CFR 51.100(s)(5)
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SIP Relaxation – The new submittal generally complies with CAA §110(l) and §193 

regarding SIP relaxations. All previous VOC limits have been lowered and several 

new categories have been added for both the fountain solutions and cleaning 

solvents. The combined efficiency requirement for other types of printing processes 

was also increased from 75% to 80%. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION –

1. Section D, Recordkeeping Requirements:

a. Subsection 1 and 2 – Add the requirement to include density to the 

data required for these materials.

2. Section E, Test Methods:

a. Subsection 5 – Please add the complete title, Determination of Volatile 

Organic Compounds in Emissions from Stationary Sources and the 

EPA approval date, December 13, 1991, to ARB Method 422.

b. Subsection 6 - Please revise SCAQMD Test Method 316B to Test 

Method 316-91.

EPA ACTION - EPA staff recommends a full approval of Rule 74.19 pursuant to 

CAA §110(k) (4) and §301(a). 

ADDITIONAL REFERENCES -

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

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

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

November 19, 2008.

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

es%20and%20Regs/reg%2008/rg0820.ashx?la=en
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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. SCAQMD Rule 1171, Solvent Cleaning Operations, amended May 1, 2009

http://www.aqmd.gov/rules/reg/reg11/r1171.pdf

5. “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

6. “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

7. “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

8. “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