                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                  REGION III
	1650 Arch Street
	Philadelphia, Pennsylvania  19103

DATE:	

SUBJECT:	Technical Support Document for Pennsylvania's Adoption of Control Technique Guidelines from:  Offset Lithographic Printing and Letterpress Printing, Flexible Package Printing, and Adhesives, Sealants, Primers, and Solvents

FROM:	Ellen Schmitt, Environmental Scientist  /s/  3/12/15
            Office of Air Program Planning 

TO:	File

THRU: 	Marilyn Powers, Acting Associate Director   /s/    3/12/15
            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 certain 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 technique guideline (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 adhesives, sealants, primers, and 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 provided recommendations for RACT for VOCs from offset lithographic printing, letterpress printing, flexible package printing, and adhesives, sealants, primers, and solvents.  States can follow the CTGs or adopt more restrictive standards.

In 1993, EPA published a draft CTG for offset lithographic printing.  See 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.  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 three new CTGs entitled Control Techniques Guidelines for Offset Lithographic and Letterpress Printing (EPA 453/R-06-002; September 2006), Control Techniques Guidelines for Flexible Package Printing (EPA 453/R-06-003; September 2006), and Control Techniques Guidelines for Industrial Cleaning Solvents (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 VOCs 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.

B.  STATE SUBMITTAL 

On January 12, 2011, Pennsylvania submitted a SIP revision to meet the RACT requirements for the adhesives, sealants, primers, and solvents source category; this SIP revision was approved by EPA on September 26, 2012.  See 77 FR 59090.  Specifically, Pennsylvania submitted 25 Pa Code 129.51 (Sources of VOCs), 129.77 (Control of emissions from the use or application of adhesives, sealants, primers and solvents), and 130.701  -  708 (under Subchapter D, Adhesives, sealants, primers and solvents).    

On August 27, 2014, Pennsylvania Department of Environmental Protection (PADEP) submitted to EPA SIP revisions which adopt EPA's CTG recommendations for offset lithographic printing and letterpress printing, flexible package printing, and adhesives, sealants, primers, and solvents with a number of changes.  The SIP revisions include the revised 25 Pa Code 129.67 and new sections 25 Pa Code 129.67a and 129.67b.  The SIP revisions also include revisions to 25 Pa Code 121.1 to include related definitions and conforming revisions to 25 Pa Code 129.51, 129.77, and 130.703.  The revisions are summarized below.  The August 2014 revisions do not affect the prior approval of the January 2011 SIP revision as meeting the RACT requirements for the adhesives, sealants, primers, and solvents source category as approved on September 26, 2012.  

I.  Flexible Package Printing  -  25 Pa Code 129.67a

This section establishes emission limits, recordkeeping and housekeeping requirements, as well as exemptions.  Exemptions to particular provisions of 25 Pa Code 129.67a are described with those particular provisions, whereas exemptions to the entire 129.67a section are described separately.

   a) Applicability

   This section applies to the owner or operator of a flexible package printing press, including rotogravure printing and flexographic printing, where one or more of the following apply:

   1.          An individual flexible packaging printing press has potential emissions from the dryer, before consideration of add-on controls, of at least 25 tons per year (tpy) of VOCs from inks, coatings and adhesives combined;
         
   2.          The total actual VOC emissions from all inks, coatings and adhesives combined from all flexible packaging printing presses and all VOC emissions from related cleaning activities at the facility are equal to or greater than 450 pounds (204.1 kilograms) per month or 2.7 tons (2,455 kilograms) per 12-month rolling period, before consideration of add-on controls; or 
         
   3.          The total actual VOC emissions from all inks, coatings and adhesives combined from all flexible packaging printing presses and all VOC emissions from related cleaning activities at the facility are less than 450 pounds (204.1 kilograms) per month or 2.7 tons (2,455 kilograms) per 12-month rolling period, before consideration of add-on controls.

   This section does not apply in the case where VOCs from adhesives are not used or applied on or with a flexible packaging printing press; these may be regulated under 25 Pa Code  129.52b, 129.77, or 130, Subchapter D.  This section supersedes the requirements of a RACT permit issued to the owner or operator of a source subject to this section prior to January 1, 2015, under 25 Pa Code 129.91  -  129.95 to control, reduce, or minimize VOCs from a flexible packaging printing press, except to the extent the RACT permit contains more stringent requirements.  
   
   b) Emission Limits
   
   This section establishes emission limits, recordkeeping and housekeeping requirements, as well as exemptions.  Emissions of VOCs from flexible package printing operations may not be permitted unless one or more of the following are met:

      1. For individual inks, coatings, or adhesives the VOC content, as applied, on a single press, must be equal to or less than either 0.16 pounds (lbs) VOC per pound of material or 0.8 lbs VOC per pound material solid, or both, as applied.
         
         For calculating the VOC content when expressed in units of weight of VOC per weight of material solids the following formula should be used:
         
                                   VOCB=WoWn
         
         Where:
           VOCB = VOC content in lb VOC/lb of solids as applied or kg VOC/kg of solids as applied
           Wo = Weight percent of VOC (Wv -Ww -Wex)
           Wv = Weight percent of total volatiles (100%-weight percent solids)
           Ww = Weight percent of water
           Wex = Weight percent of exempt solvents
           Wn = Weight percent of solids of the as applied ink, coating or adhesive
         
      2. The daily weighted-average VOC content meets the 0.16 lbs VOC per lb material or 0.8 lbs VOC per lb material solids limits above, in which case the use of averaging to meet the VOC content limits is available for use on a single flexible packaging printing press using the following formula:
         
                                        i=tnCiVi
                               VOCw= ___________
                                         Vt
         
         Where:
           VOCw = The daily weighted average VOC content, as applied, of all inks, coatings and adhesives combined used on a single flexible packaging printing press, in lb VOC/gal of coating solids
           n = The number of different inks, coatings and adhesives used each day on the single flexible packaging printing press
           Vi = The volume of solids for each ink, coating and adhesive, as applied, used each day on the single flexible packaging printing press, in gallons
           Ci = The VOC content of each ink, coating and adhesive, as applied, used each day on the single flexible packaging printing press, in lb VOC/gal coating solids
           Vt = The total volume of solids for all inks, coatings and adhesives combined, as applied, used each day on the single flexible packaging printing press, in gallons
         
      3. The overall weight of VOCs emitted to the atmosphere is reduced through the use of vapor recovery or oxidation or another method that is acceptable under chapter 129.51(a) (relating to general).  The overall control efficiency of a control system may not be less than that listed in Table 1.
         

         Table 1  -  Overall Control Efficiency Requirement of a Control System on a Single Flexible Packaging Printing Press with Potential Emissions >= 25 tpy of VOC Before Control
             Control System
Overall Control
Efficiency Requirement
                   Printing Press
First Installation Date[1]
            Air Pollution Control Device
First Installation Date[1]

                                   Prior to 
                                 On or after 
                                   Prior to 
                                 On or after 
                                       
                                March 14, 1995*
                                March 14, 1995*
                                January 1, 2015
                                January 1, 2015
                                    >= 65%
                                       X
                                       
                                       X
                                       
                                    >= 70%
                                       X
                                       
                                       
                                       X
                                    >= 75%
                                       
                                       X
                                       X
                                       
                                    >= 80%
                                       
                                       X
                                       
                                       X
      [1] First installation date is the first date of operation for a source or a control device. This date does not change if the source or control device is moved to a new location or if the control device is later used to control a new source.
      * March 14, 1995, is the date of the proposed 1996 NESHAP for the printing and publishing industry.
         
      4. The Department has issued a plan approval, operating permit or Title V permit to the owner or operator prior to January 1, 2015, establishing a Federally-enforceable limitation to limit the potential emissions of VOC from the flexible packaging printing press below 25 tpy before consideration of add-on controls.
         
   c) Compliance and Monitoring Requirements

   For add on air pollution control devices for a flexible packaging printing press the following requirements must be followed:
   
               1.          The control device shall be equipped with the applicable monitoring equipment and shall be installed, calibrated, operated and maintained according to manufacturer's specifications at all times the add-on air pollution control device is in use.
                       a.          For non-catalytic thermal oxidizers the minimum combustion or operating temperature must be continuously monitored and the temperature reading must be recorded at least once every 15 minutes while operating.
                       b.          For catalytic thermal oxidizers the inlet gas temperature must be continuously monitored and the temperature reading must be recorded every 15 minutes while operating.  Additionally, a catalyst activity test should be performed a minimum of once per rolling 2-year period.
                       c.          For a control device other than a non-catalytic or catalytic thermal oxidizer, the parameters specific to the control device must be continuously monitored and the parameters must be recorded every 15 minutes while operating.  It must also be: (1) Approved by the DEP, (2) operated continuously while the source is operating, and (3) operate with a 3-hour average temperature not lower than 50°F below the average temperature demonstrated during the most recent compliant source test approved by the DEP.

   d) Recordkeeping and Reporting Requirements

   The owner or operator of a printing press subject to this section must maintain sufficient records to demonstrate compliance with this section and may include purchase, use, production, and other records.  These records must be maintained onsite for two years unless a longer period is required by a plan approval or operating permit.
   
         1.          For add-on air pollution control devices, the owner or operator must maintain records of: (1) Temperature reading of the control device, (2) maintenance performed on the device and monitoring equipment, including date and type of maintenance performed, and (3) catalyst activity test, if applicable
         
         2.          For owners and operators not using an add-on air pollution control device, the owner or operator must maintain records of the as applied VOC content of inks, coatings, and adhesives sufficient to demonstrate compliance with the emission limits described above in section II(b)(1 and 2).

         3.          For owners and operators that claim an exemption, the owner or operator must maintain records that demonstrate that the press or facility is exempt.

   e) Work practice requirements for cleaning activities

   Owners and operators of an offset lithographic printing press or a letterpress printing press must comply with the following work practices for cleaning activities at the facility:
         
         1.          Store all VOC-containing cleaning solutions, waste cleaning solutions and used shop towels in closed containers.
         
         2.          Ensure that mixing vessels and storage containers used for VOC-containing cleaning solutions, waste cleaning solutions and used shop towels are kept closed at all times, except when depositing or removing these solutions or shop towels.

         3.          Minimize spills of VOC-containing cleaning solutions and waste cleaning solutions and clean up spills immediately.

         4.          Convey VOC-containing cleaning solutions, waste cleaning solutions and used shop towels from one location to another in closed containers or pipes.

   These requirements apply to the following activities: (1) Cleaning of ink, coating, or adhesive from a press; (2) cleaning of ink, coating, or adhesive from press parts, including press parts that have been removed from the press for cleaning; and (3) cleaning of ink, coating, or adhesive from areas around a press.  The requirements do not apply to the following activities: (1) Cleaning electronic components of a press, (2) cleaning in pre-press operations (i.e. platemaking), (3) cleaning in post-press operations (i.e. binding), (4) using janitorial supplies for general cleaning, and (5) the use of parts washers or cold cleaners at a flexible packaging printing facility.

II.  Offset Lithographic Printing and Letterpress Printing  -  25 Pa Code 129.67b 

This section establishes emission limits, recordkeeping and housekeeping requirements, as well as exemptions.  Exemptions to particular provisions of 25 Pa Code 129.67b are described with those particular provisions, whereas exemptions to the entire 129.67b section are described separately.

   a) Applicability
   
   This section applies to the owner or operator of an offset lithographic printing and/or letterpress printing operation, if the press is:  
   
      1. A single heatset web offset lithographic printing press or heatset web letterpress printing press that has potential emissions from the dryer, before consideration of add-on controls, of at least 25 tpy of VOCs from all heatset inks (including varnishes), coatings and adhesives combined.
         
      2. One or more letterpress printing presses if the total actual VOC emissions from all inks (including varnishes), coatings and adhesives combined from all letterpress printing presses and all VOC emissions from related cleaning activities at the facility are equal to or greater than 450 pounds (204.1 kilograms) per month or 2.7 tons (2,455 kilograms) per 12-month rolling period, before consideration of add-on controls.

      3. One or more offset lithographic printing presses if the total actual VOC emissions from all inks (including varnishes), coatings, adhesives and fountain solutions combined from all offset lithographic printing presses and all VOC emissions from related cleaning activities at the facility are equal to or greater than 450 pounds (204.1 kilograms) per month or 2.7 tons (2,455 kilograms) per 12-month rolling period, before consideration of add-on controls.

      4. One or more offset lithographic printing presses and one or more letterpress printing presses if the total actual VOC emissions from all inks (including varnishes), coatings, adhesives and fountain solutions combined and all VOC emissions from related cleaning activities at the facility are equal to or greater than 450 pounds (204.1 kilograms) per month or 2.7 tons (2,455 kilograms) per 12-month rolling period, before consideration of add-on controls.

      5. The total actual VOC emissions from all inks (including varnishes), coatings, adhesives and fountain solutions combined from all offset lithographic printing presses, all letterpress printing presses and all VOC emissions from related cleaning activities at the facility are less than 450 pounds (204.1 kilograms) per month and 2.7 tons (2,455 kilograms) per 12-month rolling period, before consideration of add-on controls.

   This section does not apply in the situation where VOCs from adhesives are not used or applied on or with an offset lithographic printing press or a letterpress printing press.  In these situations VOCs from adhesives may be regulated under either chapter 129.77 or chapter 130.  This section also supersedes the requirements of a RACT permit issued to the owner or operator of a source prior to January 1, 2015, under 25 Pa Code 129.91  -  129.95 (relating to stationary sources of NOx and VOCs) to control, reduce or minimize VOCs from an offset lithographic printing press or a letterpress printing press, or both, except to the extent the RACT permit contains more stringent requirements.  

   b) Emission limits
   
   Emission limits of VOCs from offset lithographic printing and/or letterpress printing operations are as follows:

      1. The VOC content for cleaning solutions must have a VOC composite partial vapor pressure less than 10 millimeters of mercury at 68°F (20°C) and/or must have a VOC content less than 70% by weight.  Where one or more cleaning solutions does not meet either limit, the cleaning solution is limited to 110 gallons per year, combined, of all cleaning solutions that exceed those limits.
         
      2. The VOC content for fountain solutions must:
            a.             For each heatset web offset lithographic printing press, the as applied solution must have a VOC content of 1.6% or less by weight, 3% or less by weight if the solution is refrigerated below 60°F (15.5°C), 5% or less by weight and contains no alcohol, or another method that achieves a level of control equal to or better than the previous methods. 
            b.             For each sheet-fed offset lithographic printing press, the as applied solution must have a VOC content of 5% or less by weight, 8.5% or less by weight if the solution is refrigerated below 60°F (15.5°C), 5% or less by weight and contains no alcohol, or another method that achieves a level of control equal to or better than the previous methods.
            c.             For each non-heatset web offset lithographic printing press, the as applied solution must have a VOC content of 5% or less by weight and contains no alcohol.
 
      3. The VOC content for heatset web offset lithographic printing presses and heatset web letterpress printing presses must not be emitted to the atmosphere from the heatset dryer unless the overall weight of VOCs is reduced through the use of vapor recovery or oxidation or another authorized method.  The control efficiency of an add-on control device must meet either:
            a.             At least 90% if installed before January 1, 2015, or
            b.             At least 95% if installed after January 1, 2015.
         
         The installation date is the first date of operation for a source or a control device and does not change if the source or control device is moved to a new location or if the control device is later used to control a new source.  Alternatives may be used if approved by the Department of Environmental Protection and only if, (1) the inlet VOC concentration to the control device is so low that compliance with the 90% or 95% efficiency is not achievable or the press is using a combination dryer and oxidizer or other control equipment configuration that does not have an inlet that meets the requirement for testing as specified, and (2) the minimum outlet VOC concentration that the unit can achieve, does not exceed 20 parts per million (ppm) as hexane (40 ppm as propane) on a dry basis.

   This section also establishes emission limit exemptions including:
   1.          For fountain solutions:
         a. For sheet-fed offset lithographic printing presses with maximum sheet size of 11x17 inches or smaller
         b. For an offset lithographic printing press with total fountain solution reservoir of less than 1 gallon
            
   2.          For heatset web offset lithographic printing presses and heatset web letterpress printing presses:
         a. If the press is used for book printing,
         b. If the press has a maximum web width of 22 inches or less, or
         c. If the press is operated with one or more of the following inks:
                 i.                Waterborne coatings,
                 ii.                Ultra-violet light or electron beam radiation cured materials,
                 iii.                Sheet-fed or non-heatset web inks, or
                 iv.                Sheet-fed or non-heatset web varnishes.

   a) Compliance and Monitoring Requirements
   
      1. For add on air pollution control devices for heatset web offset lithographic printing press or heatset web letterpress printing press must comply with the following:
            a.             The control device shall be equipped with the applicable monitoring equipment and shall be installed, calibrated, operated and maintained according to manufacturer's specifications at all times the add-on air pollution control device is in use.
                    i.                For non-catalytic thermal oxidizers the minimum combustion or operating temperature must be continuously monitored and the temperature reading must be recorded at least once every 15 minutes while operating.
                    ii.                For catalytic thermal oxidizers the inlet gas temperature must be continuously monitored and the temperature reading must be recorded every 15 minutes while operating.  Additionally, a catalyst activity test should be performed a minimum of once per rolling 2-year period.
                    iii.                For a control device other than a non-catalytic or catalytic thermal oxidizer, the parameters specific to the control device must be continuously monitored and the parameters must be recorded every 15 minutes while operating.  It must also be: (1) Approved by the DEP, (2) operated continuously while the source is operating, (3) operate with a 3-hour average temperature not lower than 50°F below the average temperature demonstrated during the most recent compliant source test approved by the DEP, and (4) negative dryer pressure should be established during the initial test using an air flow direction indicator.

      2. For fountain solutions, compliance shall be demonstrated with one or more of the following:
            a.               Analysis of a sample of the as applied fountain solution for VOC content using EPA Reference Method 24, as revised.
            b.             Maintain Material Data Safety Sheets (MSDS), Certified Product Data Sheets (CPDS), or other data provided by the manufacturer of the fountain solution that indicates the VOC content.
            c.             Calculation of the VOC content of the as applied solution that combines the analytical VOC content data from Reference Method 24 for each of the concentrated components used to prepare the solution
                    i.                The VOC content data for each of the concentrated components must be combined in the proportions in which they are mixed to make the as applied solution
                    ii.                The VOC content should be calculated once for each recipe.  The recipe name, VOC content of each concentrated component, and mix ratio shall be recorded in a logbook.
                    iii.                Reference Method 24 analysis may be performed by the supplier of the components, the results of which can be provided to the owner of the affected press.
            d.             Measurement of the recirculating reservoir temperature of a refrigerated as applied solution with a thermometer (or other temperature detection device) capable of reading to 0.5°F (0.28°C).  The temperature of the refrigerated fountain solution containing alcohol should be maintained below 60°F (15.5°C) at all times.  The temperature shall be continuously monitored and recorded at least once per operating day.
            e.             Monitoring of the as applied solution for alcohol concentration or VOC content with one or more of the following instruments:
                    i.                A refractometer or a hydrometer to monitor the fountain solution alcohol concentration. The instrument must be (1) corrected for temperature once every 8-hour shift, (2) have a visual, analog, or digital readout with an accuracy of 0.5%, and (3) be calibrated with a standard solution for the type of alcohol used.
                    ii.                A conductivity meter to determine the VOC content of the solution referenced to the conductivity of the incoming water.
            f.             Other methods to determine compliance with the VOC content limits, if the owner or operator requests approval of the alternative method, demonstrates the alternative method provides results that accurately determines the VOC content, and the DEP provides approval.
            
      3. For cleaning solutions, compliance with the VOC content limit or VOC composite partial vapor pressure limit shall be met with one or more of the following methods:
            a.             Analysis of a sample of as applied solution for VOC content using Method 24
            b.             Use of the equation for composite partial vapor pressure
            c.             Use of the methods in section 129.67b(k) for VOC composite partial vapor pressure for a single component of a solution
            d.             Maintenance of MSDS, CPDS, or other data provided by the manufacturer of the as applied solution
            e.             Calculation of the VOC content, VOC composite partial vapor pressure, or both, of the as applied solution that combines the Method 24 VOC content data or analytical VOC composite partial vapor pressure data for each of the components used in the solution.
                    i.                The VOC content data for each of the concentrated components must be combined in the proportions in which they are mixed to make the as applied solution
                    ii.                The VOC content should be calculated once for each recipe.  The recipe name, VOC content of each concentrated component, and mix ratio shall be recorded in a logbook.
                    iii.                Reference Method 24 analysis may be performed by the supplier of the components, the results of which can be provided to the owner of the affected press.
            f.             Another method to determine compliance with the VOC content limits if the owner or operator requests approval of the alternative method, demonstrates the alternative method provides results that accurately determines the VOC content, and the DEP provides approval.

   b) Reporting and Recordkeeping requirements
   
   The owner or operator of a printing press subject to this section must maintain sufficient records to demonstrate compliance with this section and may include purchase, use, production, and other records.  These records must be maintained onsite for two years unless a longer period is required by a plan approval or operating permit.
   
      1. For add-on air pollution control devices, the owner or operator must maintain records of: (1) Temperature reading of the control device, (2) maintenance performed on the device and monitoring equipment, including date and type of maintenance performed, and (3) catalyst activity test, if applicable
         
      2. For all printing presses, 
            a.             The following parameters for each press ready blanket, roller or other cleaning solution: (1) Name and identification number for the blanket, roller, or other cleaning solution, (2) the VOC content (weight %) or VOC composite partial vapor pressure of each cleaning solution as applied, (3) the volume of each cleaning solution used, if the owner or operator is using cleaning solutions which exceed a composite partial vapor pressure of 10 millimeters of mercury at 68°F or has a VOC content greater than 70% by weight, and (4) records of cleaning solution monitoring
            b.             For fountain solutions owners and operators are required to maintain records of the VOC content (weight %) and other records of fountain solution monitoring as required.
         
      3. For owners and operators that claim an exemption, the owner or operator must maintain records that demonstrate that the press or facility is exempt.

   c) Work practice requirements for cleaning activities

   Owners and operators of an offset lithographic printing press or a letterpress printing press must comply with the following work practices for cleaning activities at the facility:
         
   1.          Store all VOC-containing cleaning solutions, waste cleaning solutions and used shop towels in closed containers.
         
   2.          Ensure that mixing vessels and storage containers used for VOC-containing cleaning solutions, waste cleaning solutions and used shop towels are kept closed at all times, except when depositing or removing these solutions or shop towels.

   3.          Minimize spills of VOC-containing cleaning solutions and waste cleaning solutions and clean up spills immediately.

   4.          Convey VOC-containing cleaning solutions, waste cleaning solutions and used shop towels from one location to another in closed containers or pipes.

   These requirements apply to the following activities: (1) Cleaning of a press, including blanket washing, roller washing, plate cleaners, metering roller cleaners, impression cylinder cleaners and rubber rejuvenators; (2) cleaning of press parts, including press parts that have been removed from the press for cleaning; and (3) cleaning of ink, coating or adhesive from areas around a press.  The requirements do not apply to the following activities: (1) Cleaning electronic components of a press, (2) cleaning in pre-press operations (i.e. platemaking), (3) cleaning in post-press operations (i.e. binding), (4) using janitorial supplies for general cleaning, and (5) the use of parts washers or cold cleaners at an offset lithographic printing or a letterpress printing facility.
   
   a) Vapor Pressure Calculations
   
   Composite partial vapor pressure of organic compounds in cleaning solutions shall be determined by either (1) quantifying the amount of each compound in the blend using gas chromatographic analysis, or (2) using the following equation:

                                  i=1nWiVPiMWi
                      PPc= ______________________________
                              WVMWW+e=1kWeMWe+i=1nWiMWi

   Where:
     PPc = VOC composite partial vapor pressure at 20°C, in mm mercury
     Wi = Weight of the "i"h VOC compound, in grams
     Ww = Weight of water, in grams
     We = Weight of the "e"th exempt compound, in grams
     MWi = Molecular weight of the "i"th VOC compound, in grams per g-mole, as given in chemical reference literature
     MWw = Molecular weight of water, in grams per g-mole (18 grams per g-mole)
     MWe = Molecular weight of the "e"th exempt compound, in grams per g-mole, as given in chemical reference literature
     VPi = Vapor pressure of the "i"th VOC compound at 20°C, in mm mercury, as determined by subsection (k)
   
   For determining the vapor pressure of a single component in cleaning solutions, the following methods may be used: (1) An appropriate and current American Society for Testing and Materials (ASTM) test method with written approval by DEP, and/or (2) the most recent edition of one or more of four identified reference books or an additional source approved by DEP.
   
   b) VOC Retention Factors And Capture Efficiency Factors

   A portion of the VOCs contained in the ink or cleaning solution, or both, is retained in the printed web substrate or in the shop towels used for cleaning.  The following VOC emission retention factors can be used, as applicable:
   
      1. A 20% VOC emission retention factor for a petroleum ink oil-based heatset ink printed on an absorptive substrate.  This means that 80% of the petroleum ink oil content is emitted as VOC during the printing process and is available for capture and control by an add-on air pollution control device.  The petroleum ink oil content of a heatset ink may be determined from formulation data included on a CPDS or MSDS.
         
      2. A 95% VOC emission retention factor for a petroleum ink oil-based non-heatset web or non-heatset sheet-fed ink.  This means that 5% of the petroleum ink oil content is emitted as VOC during the printing process and is available for capture and control by an add-on air pollution control device.  The petroleum ink oil content of a non-heatset web or non-heatset sheet-fed ink may be determined from formulation data included on a CPDS or MSDS.

      3. A 100% VOC emission retention factor for vegetable ink oil-based heatset and non-heatset inks.

      4. A 50% VOC emission retention factor for low VOC composite vapor pressure cleaning solutions in shop towels if both of the following conditions are met: (1) The VOC composite vapor pressure of the cleaning solution is less than 10mm mercury at 20°C (68°F), and (2) the cleaning solutions and used shop towels are kept in closed containers.

   A portion of the VOCs contained in one or more of the ink, fountain solution, or automatic blanket wash materials is captured in the press dryer for control by the add-on air pollution control device.  The following capture efficiency factors can be used, as applicable:
   
      1. A 100% VOC emission capture efficiency for volatilized ink oils for oil-based heatset paste inks and varnishes if, (1) the press dryer is operating at negative pressure relative to the surrounding pressroom, and (2) the air flow is into the press dryer.
         
      2. A 70% VOC emission capture efficiency for a fountain solution that contains an alcohol substitute.

      3. A 40% VOC emission capture efficiency for an automatic blanket wash if the VOC composite vapor pressure of the cleaning solution is less than 10mm Hg at 20°C (68°F).

   
III.  Other Revisions 

In addition to adding the regulations previously discussed, Pennsylvania is also revising 25 Pa Code 121.1 (Definitions), 25 Pa Code 129.51 (General), 25 Pa Code 129.67 (Graphic arts systems), 25 Pa Code 129.77 (Control of emissions from the use or application of adhesives, sealants, primers and solvents), and 25 Pa Code 130.703 (Exemptions and exceptions).  The revisions to sections 121.1, 129.51, 129.67, 129.77, and 130.703 are being made to better define each relevant section and to ensure the correct applicability for each printing operation.

   a) Revisions to 121.1 (Definitions)
   
   The following new definitions were included in the revisions to 25 Pa Code 121.1 (Definitions):
   
      * Alcohol  -  A chemical compound consisting of the hydroxyl (OH) group attached to an alkyl radical and having the general formula CnH2n+1OH, such as ethanol, n-propanol, and isopropyl alcohol.
      * Alcohol substitute  -  Nonalcohol additives that contain VOCs and are used in the fountain solution including ethylene glycol and glycol ethers.  Some additives are used to reduce the surface tension of water and others are added to prevent piling (ink build up). 
      * Batch  - 
           (i)  For purposes of §129.67b, a supply of fountain solution or cleaning solution that is prepared and used without alteration until completely used or removed from the printing process.
           (ii)  The term includes:
            (A)  A supply of fountain solution or cleaning solution prepared in a discrete amount.
            (B)  A supply of fountain solution that is continuously blended with an auto mix unit.
            (C)  A supply of cleaning solution that is blended and delivered to a press by use of an automatic blanket or roller wash system.
      * Cleaning solution  -  A liquid solvent or solution used to remove ink, including dried ink, and debris from the operating surfaces of a printing press and its parts.  The term includes a blanket wash, impression cylinder wash, roller wash, metering roller cleaner, plate cleaner, rubber rejuvenator and other cleaners used for cleaning a press or press parts or to remove dried ink or coating from areas around the press.
      * Flexible packaging  - 
           (i)  A package or part of a package, such as a bag, pouch, liner or wrap, the shape of which can be readily changed.  Flexible packaging may be made of paper, plastic, film, aluminum foil, metalized or coated paper, metalized or coated film, or other material.
           (ii)  The term includes a shrink-wrap label or wrapper printed on or in-line with a flexible packaging printing press.
           (iii)  The term does not include folding cartons or other rigid packaging or self-adhesive labels.
      * Flexible packaging printing press  -  A printing press used for the production of printed flexible packaging materials using flexographic printing or rotogravure printing, or both.
      * Fountain solution  -  A mixture of water, volatile and nonvolatile chemicals and one or more additives that reduce the surface tension of the water so that the mixture spreads easily across the printing surface of a lithographic plate.  The mixture wets the nonimage area so that the printing ink is maintained within the image area.
           (i)  Alcohols, specifically isopropyl alcohol, and alcohol substitutes, including ethylene glycol and glycol ethers, are the most common VOC additives used.
           (ii)  Nonvolatile additives include mineral salts and hydrophilic gums.
      * Heatset  -  An operation in which heat is required to evaporate ink oils from the printing inks that are applied to the substrate.
      * Heatset ink  -  Printing ink that is set and dried with the use of heat.
      * Letterpress printing  -  A printing process in which the image area of the plate is raised relative to the nonimage area and the paste ink is transferred to the substrate directly from the image surface.  The substrate can be fed to the press as either an individual sheet or a rolled web.
      * Lithographic plate  -  The plate used in lithographic or offset lithographic printing which has chemically differentiated image and nonimage areas so that the printing ink adheres to the image areas. 
      * Lithographic printing  -  A printing process in which the image and nonimage areas are in the same plane on the surface of a lithographic plate.  The image and nonimage areas are chemically differentiated; the image area is oil receptive and the nonimage area is water receptive.  The substrate can be fed to the press as either an individual sheet or a rolled web.
      * Non-heatset  -  A lithographic or letterpress printing process in which the printing inks, including varnishes, are set and dried by absorption or oxidation of the ink oils rather than by evaporation with heat.  These non-polymerization processes are also known as "coldest" processes.  Polymerization processes including the use of an infrared dryer, ultraviolet curing or electron beam curing are also considered non-heatset operations.
      * Offset lithographic printing  -  A printing process in which the image and nonimage areas are in the same plane on the surface of a lithographic plate and the image and nonimage areas are chemically differentiated.  The ink film is transferred from the lithographic plate to an intermediary surface, typically a rubber-covered cylinder called a blanket, which in turn transfers the ink film to the substrate.  The substrate can be fed to the press as either an individual sheet or a rolled web.
      * Printing press  -  The equipment used to apply words, pictures or designs to a sheet or continuous substrate of paper, plastic or other material.  The equipment must include at least one printing work station.  The following equipment, if present, is also considered part of the term:
           (i)  One or multiple unwind or feed sections.
           (ii)  A series of individual work stations, which may include inboard and outboard work stations.  A work station that employs another technology, including surface coating, is considered part of the printing press if the station is capable of printing or coating on the same substrate and if the work station is physically connected as part of the printing press.
           (iii)  A dryer associated with a work station.
           (iv)  A rewind, stack or collection section.
      * Sheet-fed printing  -  A printing process in which individual sheets of substrate are fed sequentially to the printing press.
      * Varnish  -  For purposes of §129.67b, an unpigmented offset lithographic ink which is used or applied on an offset lithographic printing press in the same manner as a pigmented offset lithographic ink. The term includes a heatset varnish, sheet-fed varnish and non-heatset varnish.
      * Web printing  -  A printing process in which continuous rolls of substrate material are fed to the printing press and rewound or cut to size after printing.
   The following definitions were revised in 25 Pa Code 121.1 (Definitions); additions are identified as underlined and deletions are identified in [brackets]:
   
         *          As applied  - 
           (i)  The VOC and solids content of a coating, adhesive, sealant, adhesive primer, sealant primer, surface preparation solvent or cleanup solvent that is actually used to coat the substrate.
           (ii)  The term includes the contribution of materials used for in-house dilution of the coating.
           (iii)  For purposes of §§129.67a and 129.67b (relating to control of VOC emissions from flexible packaging printing presses; and control of VOC emissions from offset lithographic printing presses and letterpress printing presses), the VOC concentration of an ink, coating, adhesive, fountain solution or cleaning solution at the time it is actually used on a printing press.
         *          As supplied  - 
           (i)  The VOC and solids content of a coating, adhesive, sealant, adhesive primer, sealant primer, surface preparation solvent or cleanup solvent as sold and delivered to the end user.
           (ii)  For purposes of §§129.67a and 129.67b, the VOC concentration of an ink, coating, adhesive, fountain solution or cleaning solution that is purchased for use on a printing press.
         * CPDS  -  Certified Product Data Sheet  - 
           (i)  For purposes of wood furniture manufacturing operations under §§129.101  -  129.107 (relating to wood furniture manufacturing operations), documentation furnished by a coating supplier or an outside laboratory for a coating, strippable spray booth coating or solvent that provides the VOC content as pounds of VOC per pound of coating solids calculated from data measured using the EPA Reference Method 24 or an equivalent or alternative method.  Batch formulation data may be used if it is demonstrated to the satisfaction of the Administrator of the EPA that the coating does not release additional VOC as reaction byproducts during the cure.  The VOC content stated should represent the maximum VOC emission potential of the coating, strippable spray booth coating or solvent.
           (ii)  For purposes of printing operations under §129.67b, documentation furnished by an ink supplier or an outside laboratory for an ink, fountain solution, cleaning solution or solvent that provides the VOC content calculated from data measured using the EPA Reference Method 24 or an equivalent or alternative method approved by the Department.  The VOC content stated should represent the maximum VOC emission potential of the ink, fountain solution, cleaning solution or solvent.
         * Paper, film or foil coating or paper, film or foil surface coating  -  Coatings applied in a continuous, uniform layer to paper, film or foil surfaces, and pressure-sensitive tapes, regardless of substrate.  The coatings are applied to provide a covering, finish or functional or protective layer to the substrate, saturate a substrate for lamination or provide adhesion between two substrates for lamination.
           (i)  The term includes coatings used in web coating processes on the following substrates:
            (A)  Pressure sensitive tapes and labels, including fabric coated for use in pressure sensitive tapes and labels.
            (B)  Plastic and photographic films.
            (C)  Industrial and decorative laminates.
            (D)  Abrasive products, including fabric coated for use in abrasive products.
            (E)  Flexible packaging, including coating of nonwoven polymer substrates for use in flexible packaging, if the coating is not applied on or in-line with a flexible packaging printing press.
            (F)  Those used in miscellaneous coating operations, including the following:
         *          Process  -  A method, reaction or operation in which materials are handled or whereby materials undergo physical change  -  that is, the size, shape, appearance, temperature, state or other physical property of the material is altered  -  or chemical change  -  that is, a substance with different chemical composition or properties [are] is formed or created.  The term includes all of the equipment, operations and facilities necessary for the completion of the transformation of the materials to produce a physical or chemical change.  There may be several processes in series or parallel necessary to the manufacture of a product.
         *          Rotogravure printing  -  The application of words, designs and pictures to a substrate by means of a roll printing technique which involves an intaglio or recessed image area in the form of cells.
   
   b) Revisions to 129.51 (General)
   
   Revisions to this section include: (1) The removal of an outdated reference to 129.70, and the addition of references to new sections 129.67a and 129.67b; (2) the clarification that the test methods in chapter 139 should be followed to monitor compliance with the emission requirements of section 129.51 unless otherwise set forth in chapter 129; (3) the clarification of the records to be kept and the amount of time they should be kept; and (4) the redesignation of section 129.51(d)(3) to 129.51(e) which clarifies that owners or operators claiming an exemption to this section should maintain records to demonstrate such exemption.  
   
   c) Revisions to 129.67 (Graphic arts systems)
   
   Revisions to this section account for the new requirements of section 129.67a and 129.67b.  They also clarify that an owner or operator of a flexible packaging printing press who was required to install a control device under 129.67 prior to June 28, 2014 is subject to both the requirements of 129.67 and the new requirements of 129.67a.  However, owner or operators subject to 129.67a by virtue of meeting the threshold of 25 tpy of potential emissions of VOC (before the consideration of add-on controls) is not subject to 129.67 because the requirements of 129.67a are more stringent than those in 129.67.
   
   d) Revisions to 129.77 (Control of emissions etc.)
   
   Revisions to this section include revising 129.77(k)(2) to clarify that 129.77 does not apply to the use or application of adhesives, sealants, adhesive primers, and sealant primers that are subject to other regulations in chapters 129 or 130.
   
   e) Revisions to 130.703 (Exemptions and exceptions)
   
   Revisions to this section include revising 130.703(a)(2) to clarify that 130.703 does not apply to the use or application of adhesives, sealants, adhesive primers, and sealant primers that are subject to other regulations in chapters 129 or 130.
   

C.  EPA'S EVALUATION

I.  Flexible Package Printing  -  25 Pa Code 129.67a

Section 129.67a closely mirrors the CTG for flexible package printing press operations with the exception of a few minor details.  The CTG recommends that the controls considered should apply to printing presses that have potential emissions of 25 tpy of VOCs before consideration of add-on controls.  The CTG also recommends establishing various controls based on the total actual VOC emissions before consideration of add-on controls, and sets the threshold for actual emissions at 450 lbs per month or 3 tons per 12-month rolling period.  PADEP has adopted these applicability thresholds with the exception of the 3 tons per 12-month rolling period for actual VOC emissions; instead, PADEP is using 2.7 tons per 12-month rolling period in order to stay consistent with other PADEP regulations and historical usage.  Thus, PADEP is more stringent in this minor change from the CTG.

The flexible package printing press CTG recommends limiting the VOC content of inks, coatings, and adhesives to either 0.16 lbs VOC per lb material applied or 0.8 lbs VOC per lb material solids as applied.  The CTG allows for the calculation of a daily weighted-average VOC content of all inks, coatings, and adhesives in order to meet the 0.16 and 0.8 lb VOC limits.  For add-on controls the CTG recommends the overall control efficiency to be between 65% and 80% depending on the first installation date as previously described in Table 1.  

The flexible package printing press CTG also recommends work practice standards for cleaning activities which include: (1) Storing all VOC-containing cleaning solutions, waste cleaning solutions and used shop towels in closed containers, (2) ensuring that mixing vessels and storage containers used for VOC-containing cleaning solutions, waste cleaning solutions and used shop towels are kept closed at all times, (3) minimizing spills of VOC-containing cleaning solutions and waste cleaning solutions and cleaning up spills immediately, and (4) conveying VOC-containing cleaning solutions, waste cleaning solutions and used shop towels from one location to another in closed containers or pipes. 

PADEP has adopted these emission limits and work practice standards as recommended in the flexible package printing CTG.  In addition to these recommendations, PADEP has also adopted various compliance, monitoring, recordkeeping, and reporting requirements as discussed in section B.I of this technical support document (TSD).  Therefore, EPA finds that the requirements of 25 Pa Code 129.67a are equivalent to the recommendations of the flexible package printing press CTG, and thus meet the RACT requirements of CAA section 182(b)(2)(A).

II.  Offset Lithographic Printing and Letterpress Printing  -  25 Pa Code 129.67b

Section 129.67b closely mirrors the CTG for offset lithographic and letterpress printing operations with the exception of a few minor details.  The CTG recommends that the controls discussed should apply to: (1) A heatset web offset lithographic printing press or heatset web letterpress printing press that has potential emissions from the dryer of 25 tpy of VOCs before consideration of add-on controls; (2) all letterpress printing and offset lithographic printing if the total actual VOC emissions are equal to or greater than 450 lbs per month or 3 tons per rolling 12-month period; and (3) if the total actual VOC emissions from all lithographic printing presses, letterpress printing presses, and related cleaning activities is less than 450 lbs per month and 3 tons per 12-month rolling period.  PADEP has adopted these applicability thresholds with the exception of the 3 tons per 12-month rolling period for actual VOC emissions; instead, PADEP is using 2.7 tons per 12-month rolling period in order to stay consistent with other PADEP regulations and historical usage.  Thus, PADEP is more stringent in this minor change from the CTG.

The lithographic printing press and letterpress printing press CTG recommends emission limits for cleaning solutions, fountain solutions used on heatset web offset and sheet-fed offset lithographic printing presses, heatset web offset lithographic and heatset web letterpress printing presses.  The CTG also allows for exceptions for certain fountain solutions and certain uses, inks, coatings, and varnishes for heatset web offset lithographic and heatset web letterpress printing presses.  

The lithographic printing press and letterpress printing press CTG also recommends work practice standards for cleaning activities and VOC retention and efficiency factors as discussed in sections B.II.(e) and B.II.(g) of this TSD, respectively.  

PADEP has adopted these emission limits, work practice standards, and VOC retention and efficiency factors as recommended in the lithographic printing press and letterpress printing press CTG.  In addition to these recommendations, PADEP has also adopted various compliance, monitoring, recordkeeping, and reporting requirements as discussed in section B.II of this TSD.  Therefore, EPA finds that the requirements of 25 Pa Code 129.67b are equivalent to the recommendations of the lithographic printing press and letterpress printing press CTG, and thus meet the RACT requirements of CAA section 182(b)(2)(A).

III.  Other Revisions 

As previously discussed, Pennsylvania is also revising 25 Pa Code 121.1 (Definitions), 129.51 (General), 129.67 (Graphic arts systems), 129.77 (Control of emissions from the use or application of adhesives, sealants, primers and solvents), and 130.703 (Exemptions and exceptions).  The revisions to section 121.1 include relevant definitions required to carry out new subsections 129.67a and 129.67b.  The revisions to 129.51, 129.67, 129.77, and 130.703 are necessary in order to better define the applicability of the relevant requirements to the various source categories.  These particular revisions affect the regulations that were previously adopted to meet the CTG recommendations for adhesives, sealants, primers, and solvents source categories.  See 77 FR 59090 (September 26, 2012).  The revisions to these regulations will not affect EPA's prior determination that they meet the RACT requirements for adhesives, sealant, primers, and solvents.  Therefore, EPA finds that the revised provisions of 25 Pa Code 129.51, 129.67, 129.77, and 130.703 continue to meet the RACT requirements of CAA section 182(b)(2)(A) for adhesives, sealant, primers, and solvents.


D.  RECOMMENDED AGENCY ACTION

Pennsylvania has adopted the standards and recommendations of the CTGs for offset lithographic printing and letterpress printing, flexible package printing, and industrial solvent cleaning operations, and is requesting that EPA amend the Pennsylvania SIP to reflect these revisions.  The maximum benefit from these amendments will be provided during the ozone season when VOCs readily combine with NOx to form ground-level ozone.  

As a whole, these revisions will meet the RACT requirements for Pennsylvania for the flexible packaging printing materials, offset lithographic printing materials, and letterpress printing materials source categories.  In addition, these revisions will continue to meet the RACT requirements of the adhesives, sealants, primers, and solvents source category as approved on September 26, 2012.  See 77 FR 59090.  Therefore, it is recommended that these revisions to the Pennsylvania SIP be approved by EPA as meeting the RACT requirements of CAA section 182(b)(2)(A) for the flexible packaging printing materials, offset lithographic printing materials, and letterpress printing materials source categories.  
