UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	August 18, 2011

SUBJECT:	Technical Support Document – State of Delaware – Control of
Volatile Organic Compound Emissions from Offset Lithographic Printing
and Letterpress Printing 

				/s/

FROM:	Rose Quinto, Environmental Engineer

		Office of Air Program Planning

TO:		File

				/s/

THRU: 	Cristina Fernandez, Associate Director

Office of Air Program Planning

A.  BACKGROUND

On May 25, 2011, the Delaware Department of Natural Resources and
Environmental Control (DNREC) submitted a State Implementation Plan
(SIP) revision pertaining to the control of volatile organic compound
(VOC) emissions from offset lithographic printing and letterpress
printing (7 DE Admin Code 1124, Section 47.0).  The purpose of this SIP
revision is to conform to the new Control Techniques Guidelines (CTG)
issued by Environmental Protection Agency (EPA) in September 2006 (CTG
for Offset Lithographic Printing and Letterpress Printing,
EPA-453/R-06-002).  This CTG provides control options to reduce VOC
emissions stemming from the use of fountain solutions, cleaning
materials and inks in offset lithographic printing, and cleaning
materials and inks in letterpress printing.

Section 182(b)(2) of the Clean Air Act (CAA) requires all ozone
nonattainment areas, including Delaware, to update relevant regulations
for reasonably available control technology (RACT) controls for emission
sources covered by EPA’s CTG and to submit the regulations to EPA as 
SIP revisions.  Section 47.0 (Offset Lithographic Printing) under 7 DE
Admin Code 1124 (Control of VOC Emissions) was originally developed in
1994 after EPA issued a CTG in 1993 for the control of VOC emissions
from the offset lithographic printing industry.  (See docket
EPA-HQ-OAR-2006-0536).  In September 2006, EPA updated its CTG for the
offset lithographic printing industry by adding control requirements for
letterpress printing operations.  DNREC revised Section 47.0 in early
2010 to reflect the new requirements in EPA’s 2006 CTG. DNREC’s
revision to Section 47.0 expanded the control of VOC emissions to
include letterpress printing presses.

B.  STATE SUBMITTAL

Summary of the SIP Revision

Delaware’s amendments to Section 47.0 (Offset Lithographic Printing),
add letterpress printing provisions to conform to the new CTG issued by
EPA in September 2006 (EPA-453/R-06-002).

This CTG addresses both the offset lithographic printing industry and
the letterpress printing industry since they have similarities in the
types of inks and cleaning materials used, the sources of VOC emissions,
and the controls available to address those emissions.

The title of Section 47.0 was amended to add “and Letterpress
Printing.”  This SIP revision applies to any offset lithographic or
letterpress printing press.  The owner or operator of any offset
lithographic or letterpress printing press shall comply with the
provisions of Section 47.0 on and after April 11, 2011 (effective date
of this SIP revision).  Except for existing permitted sources, a
one-year transition period for facilities to comply with the new
requirements is specified.

Definition of “letterpress printing” was added and “dampening
system” was deleted.  The following definitions were amended:  (1)
cleaning solution – added “including dried ink,” (2) lithography
– added “or lithographic printing,” (3) non-heatset – added
“or coldest,” (4) offset – added “lithographic printing,” and
(5) total actual VOC emissions added “and letterpress printing
operations, including VOC emissions from cleaning materials and
activities.”  

Section 47.0 sets up a level of control for VOC emissions from heatset
dryers of 90 percent control efficiency for a control device (1993 CTG).
 In addition to this provision, this SIP revision sets up a new and more
stringent 95 percent reduction standard for those control systems
installed after April 11, 2011.  The VOC content of a fountain solution
containing alcohol substitutes or non-alcohol additives is established
with proper recordkeeping and the manufacturer’s technical information
of the VOC content of the concentrated alcohol substitute and included
in facility records. 

Another amendment to Section 47.0 is providing flexibility for
facilities to locate unspecified temperature monitoring devices for
control systems; that is, at the outlet of the control device or at a
location approved by PADEP and EPA.

C.  EPA EVALUATION

This regulation will reduce VOC emissions from offset lithographic
printing and letterpress printing operations.  7 DE Admin Code 1124,
Section 47.0 meets the requirement of a RACT rule for the offset
lithographing printing and letterpress printing CTG category.

D.  CONCLUSIONS AND RECOMMENDED AGENCY ACTION

Amendments to the control of VOC emissions from offset lithographic
printing and letterpress printing (7 DE Admin Code 1124, Section 47.0)
adopted by the State of Delaware will result in the reduction of VOC
emissions from the affected sources.  Section 47.0 meets the applicable
requirements of the CAA and the applicable EPA regulations, guidance and
policy and can be approved.  This SIP revision will help Delaware in
attaining compliance with the 8-hour ozone NAAQS.

EPA’s approval of the SIP revisions is recommended.        

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