UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	June 17, 2014

SUBJECT:	Technical Support Document for Allegheny County’s Adoption of
Control Techniques Guidelines for Offset Lithographic Printing and
Letterpress Printing; Flexible Package Printing; and Industrial Solvent
Cleaning Operations for Control of Volatile Organic Compound Emissions

			/s/    

FROM:	Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO:	File

			/s

THRU: 	Cristina Fernandez, Associate Director 

Office of Air Program Planning

A.  BACKGROUND  

Section 172(c)(1) of the Clean Air Act (CAA) provides that state
implementation plans (SIPs) for nonattainment areas must include
reasonably available control measures (RACM), including reasonably
available control technology (RACT), for sources of emissions.  Section
182(b)(2)(A) provides that for certain nonattainment areas, States must
revise their SIPs to include RACT for sources of volatile organic
compound (VOC) emissions covered by a control techniques guidelines
(CTG) document issued after November 15, 1990 and prior to the area’s
date of attainment. 

The United States Environmental Protection Agency (EPA) defines RACT as
“the lowest emission limitation that a particular source is capable of
meeting by the application of control technology that is reasonably
available considering technological and economic feasibility.” (44 FR
53761, Sept. 17, 1979).  In subsequent Federal Register notices, EPA has
addressed how states can meet the RACT requirements of the CAA. 

CTGs are intended to provide state and local air pollution control
authorities information that should assist them in determining RACT for
VOCs from various sources, including offset lithographic printing and
letterpress printing; flexible package printing; and industrial cleaning
solvents.  In developing these CTGs, EPA, among other things, evaluated
the sources of VOC emissions from the industry and the available control
approaches for addressing these emissions, including the costs of such
approaches.  Based on available information and data, EPA provides
recommendations for RACT for VOCs from offset lithographic printing and
letterpress printing; flexible package printing; and industrial cleaning
solvents.

In 1993, EPA published a draft CTG for offset lithographic printing. (58
FR 59261). After reviewing comments on the draft CTG and soliciting
additional information to help clarify those comments, EPA published an
alternative control techniques (ACT) document in June 1994 that provided
supplemental information for States to use in developing rules based on
RACT for offset lithographic printing.  In December 1978, EPA published
a CTG for graphic arts (rotogravure printing and flexographic printing)
that included flexible package printing.  In 1994, EPA developed an ACT
document for industrial cleaning solvents.  After reviewing the
1978/1993/1994 CTGs and ACTs for these industries, conducting a review
of currently existing state and local VOC emission reduction approaches
for these industries, and taking into account any information that has
become available since then, EPA developed new CTGs entitled Control
Techniques Guidelines for Offset Lithographic and Letterpress Printing
(Publication No. EPA 453/R-06-002; September 2006); Control Techniques
Guidelines for Flexible Package Printing (Publication No. EPA
453/R-06-003; September 2006); Control Techniques Guidelines for
Industrial Cleaning Solvents (Publication No. EPA 453/R-06-001;
September 2006).

The CTG recommendations may not apply to a particular situation based
upon the circumstances of a specific source.  Regardless of whether a
State chooses to implement the recommendations contained within the CTGs
through State rules, or to issue State rules that adopt different
approaches for RACT for VOCs for offset lithographic printing and
letterpress printing, flexible package printing, and industrial solvent
cleaning operations, States must submit their RACT rules to EPA for
review and approval as part of the SIP process.  EPA will evaluate the
rules and determine, through notice and comment rulemaking in the SIP
process, whether they meet the RACT requirements of the CAA and EPA’s
regulations.

Description of Offset Lithographic Printing and Letterpress Printing

Offset lithography is a planographic method of printing.  The term
“planographic” denotes that the printing and non-printing areas are
in the same plane on the surface of a thin metal lithographic plate.  To
maintain the distinction between the areas on the lithographic plate,
the image area is rendered oil receptive, and the non-image area is
rendered water receptive.

Offset lithography is an indirect printing method; that is, ink is not
transferred directly to a substrate.  Rather, ink is transferred from
the lithographic plate to a rubber-covered, intermediate “blanket”
cylinder and then transferred from the blanket cylinder to the
substrate.  The offset lithographic process is used for a broad range of
printing applications, including books, magazines, periodicals, labels
and wrappers, catalogs and directories, financial and legal

documents, business forms, advertising brochures, newspapers, newspaper
inserts, charts and maps, calendars, tickets and coupons, greeting
cards, and stamps.  There are two types of offset lithography
characterized by the method in which the substrate is fed to the press. 
In sheet-fed printing, individual sheets of paper or other substrate are
fed to the press.  In web printing, continuous rolls of substrate
material are fed to the press and rewound or cut to size after printing.
 VOC emissions from offset lithographic printing result from the
evaporation of

components of the inks, fountain solutions, cleaning materials and other
miscellaneous materials such as varnishes, coatings and glues.

Letterpress inks are similar to offset lithographic inks.  They are
paste inks containing petroleum oils or vegetable oils.  Both sheet-fed
and web presses are used for letterpress printing.  Sheet-fed
letterpress presses use coldset inks.  Most web letterpress equipment
use coldset inks.  These letterpress inks are similar in composition and
behavior to sheet-fed and coldset web lithographic inks.  In sheet-fed
and coldest web letterpress printing, 95 percent of the petroleum ink
oils and essentially all of the vegetable oils are retained in the
substrate and dry ink film.  The remaining 5 percent of petroleum ink
oils is volatilized and emitted.  Because of the high level of ink oil
retention, emissions from sheet-fed and coldset web letterpress inks are
inherently very low.  

There are three main sources of VOC emissions from offset lithographic
printing:  

(1) evaporation of VOCs (petroleum ink oils) from the inks; (2)
evaporation of VOCs from

the fountain solution; and (3) evaporation of VOCs from the cleaning
materials.  There

are two main sources of VOC emissions from letterpress printing: (1)
evaporation of

VOCs (petroleum ink oils) from the inks, and (2) evaporation of VOCs
from the cleaning

materials.

Description of Flexible Package Printing

Flexible packaging refers to any package or part of a package, the shape
of which can be readily changed.  Flexible packaging includes, but is
not limited to, bags, pouches, liners, and wraps utilizing paper,
plastic, film, aluminum foil, metalized or coated paper or film, or any
combination of these materials.  Flexible package manufacturers are
sometimes referred to as "converters."  The word "converted" in this use
is an industry-specific term that refers to the fact that flexible
packaging materials start out as rolls of paper or foil, or beads of
plastic resin, and are "converted" into a package or roll of packaging
material.  Printing on flexible packaging is almost entirely conducted
by rotogravure and wide-web flexographic printing.

Printing, coating, and laminating may all be performed on or in-line
with a flexible package printing press; and these activities are
included in the source category. One portion of the flexible packaging
industry provides fully printed packaging materials (designated
"preformed specialty bags") to contract packagers.  Another portion
provides combination or laminated materials (designated converted wrap)
for printing and/or final packing by captive packaging operations.
Applying coatings is a major capability of flexible packaging
converters.  So, the same facilities may be used to manufacture
non-packaging materials such as gift wraps and hot stamp foils. The
industry makes a distinction between labels and wrappers, which are
package components, and a product that becomes the entire package and
should be called a flexible package.  Any printing of shrink-wrap labels
or wrappers conducted on or in-line with a flexible package printing
press is also considered to be included under the flexible packaging
source category.  Printing of self-adhesive labels would not be
considered flexible packaging.  Rigid packaging printing operations are
often co-located with flexible package printing operations.  Folding
cartons, some labels and wrappers, gift wraps, wall coverings, vinyl
products, decorative laminates, floor coverings, tissue products, and
miscellaneous specialty products are not considered flexible packaging.

There are two types of printing processes used by flexible package
printing facilities: (1) rotogravure printing; and (2) flexographic
printing.  And there are two main sources of VOC emissions from flexible
package printing for both rotogravure and flexographic: (1) evaporation
of VOC from inks, coatings, and adhesives, and (2) evaporation of VOCs
from cleaning materials.

There are two approaches to reducing VOC emissions from inks, coatings,
and adhesives used in the flexible package printing industry: (1)
adding/improving add-on controls, and (2) material reformulation or
substitution.  The first approach includes improving capture and/or
control systems or adding control systems where none are in use. 
Capture and control can be addressed separately, although in many cases,
improved capture is achieved through an increase in the amount of air
handled and can necessitate up-grades to existing control devices.  The
second approach, focusing on pollution prevention, is to substitute low
VOC or VOC-free materials for materials (inks, coatings, and adhesives)
presently in use.

Description of Industrial Cleaning Solvent Operations

This category of consumer and commercial products includes the
industrial cleaning solvents used by many industries. It includes a
variety of products that are used to remove contaminants such as
adhesives, inks, paint, dirt, soil, oil, and grease.  Contaminants are
removed from parts, products, tools, machinery, equipment, vessels,
floors, walls, and other work production related work areas for a
variety of reasons including safety, operability, and to avoid product 
contamination.  The cleaning solvents used in these (unit) operations
are, in many cases, generally available bulk solvents that are used for
a multitude of applications not limited to cleaning.  For example,
petroleum distillates may be used as a cleaning solvent, as a paint
thinner, or as an ingredient used in the manufacture of a coating, such
as paint. Because a portion of all solvents evaporate during use, such
solvent-based cleaning materials result in large amounts of emissions of
VOC.

Although the industrial cleaning solvent product category includes a
variety of different products with differing VOC contents, and although
these products are used in different ways by a wide range of industries,
there are several basic approaches to achieve VOC emission reductions.
First, the users of the products can control emissions through work
practices targeted at the activities and sources of emissions specific
to the user’s industry (e.g., keeping solvent containers covered,
properly storing and disposing of used shop towels and solvent, etc.).
Second, users can also reduce overall VOC emissions through solvent
substitution (e.g., use of low - VOC, no -VOC, or low -vapor pressure
solvents).  They can also reduce VOC emissions by using add-on controls,
modifying equipment, or upgrading to using a lower emitting cleaning
technology.

B.  STATE SUBMITTAL

On November 15, 2013, Pennsylvania Department of Environmental
Protection (PADEP) submitted to EPA a SIP revision concerning the
adoption of the EPA CTGs for offset lithographic printing and
letterpress printing; flexible package printing; and industrial cleaning
solvent operations in Allegheny County.  EPA develops CTGs as guidance
on control requirements for source categories.  States can follow the
CTGs or adopt more restrictive standards.  Allegheny County is adopting
EPA’s CTG standards for offset lithographic printing and letterpress
printing; flexible package printing; and industrial cleaning solvent
operations.  These regulations are contained in the Allegheny County
Health Department (ACHD) Rules and Regulations, Article XXI, Air
Pollution Control sections 2105.80, 2105.81, and 2105.82.  This SIP
revision also includes a revision to an existing regulation for graphic
arts systems in section 2105.11.  The revisions are summarized below.

 

I.  Offset Lithographic Printing and Letterpress Printing 

This section applies to the owner or operator of an offset lithographic
printing and/or letterpress printing operation, where the total actual
VOC emissions from all offset lithographic printing and letterpress
printing operations are equal to or greater than 15 pounds (6.8
kilograms) per day or 2.7 (2,455 kilograms) per twelve month rolling
period.  Exceptions include heatset web offset lithographic printing
operations and heatset web letterpress printing operations, for which
this section only applies to those presses with potential to emit from
the dryer at least 25 tons (22,680 kilograms) of VOC per twelve month
rolling period.

This section establishes emission limits, recordkeeping and housekeeping
requirements, as well as exemptions.  Emission limits of VOCs from
offset lithographic printing and/or letterpress printing operations are
as follows:

The VOC content for heatset web offset lithographic printing contains
1.6 percent alcohol or less (by weight), on-press (as-applied) in the
fountain or 3.0 percent alcohol or less (by weight) on-press
(as-applied) in the fountain solution or 5.0 percent alcohol or less
on-press and no alcohol in the fountain solution.

The VOC content for sheet-fed offset lithographic printing contains 5.0
percent alcohol or less (by weight), in the fountain or 8.5 percent
alcohol or less on-press in the fountain solution or 5.0 percent alcohol
substitute or less on-press and no alcohol in the fountain solution.

The VOC content for cold web lithographic printing contains 5.0 percent
alcohol substitute or less on-press and no alcohol in the fountain
solution.

The overall weight of VOC emitted to the atmosphere is reduced through
the use of a chiller condenser or an oxidizer for heatset web offset
lithographic printing or heatset web letterpress printing if 

The overall control efficiency for a chiller condenser shall be no less
than 90 percent; or

The overall control efficiency for an oxidizer shall be no less than 95
percent; or

VOC outlet concentration is reduced to less than 20 ppmv on a dry basis.

Use cleaning materials with a VOC composite vapor pressure less than 10
mm HG at 68 degrees F or cleaning materials containing less than 70
weight percent VOC.  

A combination of the methods listed in Paragraphs 1 through 5.

II.  Flexible Package Printing

This section applies to the owner or operator of a flexible package
printing press, including rotogravure printing and flexographic
printing, where the total actual VOC emissions from all flexible package
printing press operations, including related cleaning activities, at the
facility are equal to or greater than 15 pounds (6.8 kilograms) per day
or 2.7 tons (2,455 kilograms) per twelve month rolling period.  The
limits from section 2105.11, Graphic Arts System, no longer apply to
flexible package printing presses.

This section emission limits, recordkeeping and housekeeping
requirements, as well as exemptions.  Emission limits of VOCs from
flexible package printing operations are as follows:

The overall control efficiency shall be no less than 80 percent.

The VOC content of materials (inks, coatings, and adhesives) used on a
single press shall not be greater than 0.8 pound (lb) VOC per lb solids
applied.

The VOC content of materials (inks, coatings, and adhesives) used on a
single press shall not be greater than 0.16 lb VOC per lb materials
applied.

III.  Industrial Solvent Cleaning Operations 

This section applies to the owner or operator of a facility, where the
total actual VOC emissions from all of the industrial solvent cleaning
operations at the facility are equal to or greater than 15 pounds (6.8
kilograms) per day or 2.7 tons (2,455 kilograms) per twelve month
rolling period.  This regulation applies to any facility that employs
solvent materials in industrial solvent cleaning operations during the
production, repair, maintenance, or servicing of parts, products, tools,
machinery, equipment, or general work areas, and stores and/or disposes
of these solvent materials.  This section establishes emission limits
(Table 1), recordkeeping and housekeeping requirements, as well as
exemptions.

Table 1:  Emission Limits of VOCs for Industrial Solvent Cleaning
Operations

	VOC Content Limitation 

Industrial Solvent Cleaning Operation	lbs VOC per gallon (gal)	Kilograms
(kg) VOC per / liter (l)

 Product cleaning during manufacturing process or surface preparation
for coating, adhesive, or ink application



General	0.42	0.050

Electrical apparatus components and electronic components	0.83	0.099

Medical devices and pharmaceuticals	6.7	0.80

Repair and maintenance cleaning



General	0.42	0.050

Electrical apparatus components and electronic components	0.83	0.099

Medical devices and pharmaceuticals



Tools, equipment and machinery	6.7	0.80

General work surfaces	5.0	0.60

Cleaning of coating or adhesive	0.42	0.050

Cleaning of ink application equipment



 General	0.42	0.050

Flexographic printing	0.42	0.050

 Gravure printing



Publication	0.83	0.099

Packaging	0.42	0.050

(d) Screen printing	4.2	0.50

(e) Ultraviolet ink and electron beam ink application equipment, except
screen printing	4.2	0.50

(f) Specialty flexographic printing	0.83	0.099

Cleaning of polyester resin application equipment not subject to 40 CFR
Part 63 Subpart WWWW	0.42	0.050



IV.  Additional Revision

In addition to adopting the CTGs discussed above, section 2105.11,
Graphic Arts Systems, is being amended and added to the Allegheny County
portion of the Pennsylvania SIP.  Paragraph f, Exempt Other, is being
added and reads as follows:  The owner or operator of a flexible package
printing press subject to section 2105.81, Control of VOC Emissions From
Flexible Package Printing, is no longer subject to all subparagraphs of
section 2105.11, Graphic Arts Systems, and shall be subject to all
subparagraphs of section 2105.81, Control of VOC Emissions from Flexible
Package Printing as of January 1, 2012.

C.  EPA EVALUATION AND RECOMMENDED AGENCY ACTION

Allegheny County has adopted the standards and requirements of the CTGs
for offset lithographic printing and letterpress printing, flexible
package printing, and industrial solvent cleaning operations, and is
amending the Pennsylvania SIP to reflect these amendments.  The maximum
benefit from these amendments will be provided during the ozone season
when VOCs readily combine with NOx to form ground-level ozone. 
Therefore, this revision will help Pennsylvania attain and maintain the
NAAQS for ozone and EPA approval of the SIP revision is recommended.

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