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TECHNICAL SUPPORT DOCUMENT 

Revisions to the Texas State Implementation Plan 

Title 30 Environmental Quality Part 1 

Chapter 115 - Control of Air Pollution from Volatile Organic Compounds 

Subchapter E – Solvent Using Processes 

Division 4 – Offset Lithographic Printing Rules 

§§ 115.440 – 115.449 

SIP Revision, in full: 

Rule Project No. 2008-019-115-EN on April 5, 2010 

SIP Revisions, in part: 

Project No. 2009-017-SIP-NR on April 6, 2010 

Project No. 2009-021-SIP-NR on April 6, 2010 

January 22, 2014 

FOR FURTHER INFORMATION CONTACT: Ms. Ellen Belk, United States 

Environmental Protection Agency Region 6, Air Planning Section (6PD-L), 1445 Ross 

Avenue, Dallas, Texas 75202-2733, (214) 665-2164. 
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Table of Contents 

This TSD has the following sections: 

I. Summary 

II. Background 

A. RACT and CTGs 

B. Offset Lithography 

C. Purpose of this Action 

D. The CTG Source Category Addressed in this Action 

E. Texas’ SIP Revisions Addressed in this Action 

III. Evaluation of Texas’ Rule Revisions and RACT Analysis Addressed in this 

Action 

A. Comparison of CTG Requirements and Texas’ Rule Revisions 

Letterpresses 

Heatset Offset Lithographic Presses 

Fountain Solution 

Cleaning Solution 

Monitoring, Recordkeeping, and Testing Requirements 

Non-Substantive Revisions 

B. Texas’ Rule Revisions by Section 

C. Comparison of RACT Requirements and Texas’ RACT Assessments for HGB 

and DFW 

IV. Conclusion 

Appendix A: Control Techniques Guideline Documents Issued by EPA in 2006, 2007 

and 2008 

Appendix B: Excerpt from Texas’ 2010 HGB Attainment Demonstration SIP Submittal 

Appendix C: Excerpt from Texas’ DFW RACT Update SIP Submittal 

 
Page 3 of 26

I. Summary 

This Technical Support Document (TSD) concerns our review of the Reasonable 

Available Control Techniques related provisions of the 30 TAC Chapter 115 for Volatile 

Organic Compounds addressing the requirements of the Control Techniques Guidelines 

(CTG) for Offset Lithographic Printing operations. These control requirements and rule 

revisions apply to offset lithographic printing lines located in the following areas: 

Houston-Galveston-Brazoria (HGB), Dallas-Fort Worth (DFW), and El Paso, and address 

RACT for offset lithographic printing operations in HGB and DFW. The EPA has 

previously approved Texas’ rule revisions and Reasonably Available Control Technology 

(RACT) analyses for Volatile Organic Compounds (VOCs) and Oxides of Nitrogen 

(NOx) into Texas’ State Implementation Plan (SIP) under the 1-Hour and 1997 8-Hour 

ozone standard1. This TSD addresses three Texas SIP Revisions, the first in full and the 

other two in part, as follows: Texas VOC Control Technique Guidelines Update; 2010 

HGB Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard; 

and 2010 DFW RACT, Rule, and Contingency SIP Revision. 

 

1 Recent related rulemaking actions for Texas related to VOC CTGs include a final action published April 

2, 2013 (78 FR 19599) and a proposed action published January 9, 2014 (79 FR 1612). 
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II. Background 

A. RACT and CTGs 

Clean Air Act (CAA) section 172(c)(1) provides that state implementation plans 

(SIPs) for nonattainment areas must include reasonably available control measures 

including “reasonably available control technology” (RACT) for sources of emissions. 

The EPA has defined RACT as the lowest emissions limitation that a particular source is 

capable of meeting by the application of control technology that is reasonably available, 

considering technological and economic feasibility. See 44 FR 53761, September 17, 

1979. Section 172(c)(1) of the Act requires that SIPs for nonattainment areas “provide 

for the implementation of all reasonably available control measures as expeditiously as 

practicable (including such reductions in emissions from existing sources in the area as 

may be obtained through the adoption, at a minimum, of reasonably available control 

technology) and shall provide for attainment of the primary National Ambient Air 

Quality (NAAQS) standards.” 

Section 182(b)(2) of the Act requires states to submit a SIP revision and 

implement RACT for moderate and above ozone nonattainment areas. For a Moderate, 

Serious, or Severe Area a major stationary source is one which emits, or has the potential 

to emit, 100, 50, or 25 tons per year (tpy) or more of VOCs or NOx, respectively. See 

CAA sections 182(b), 182(c), and 182(d). The EPA provides states with guidance 

concerning what types of controls could constitute RACT for a given source category 

through the issuance of Control Techniques Guidelines (CTG) and Alternative Control 

Techniques (ACT) documents. See 

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/index.htm (URL dating May 23, 2012) for a 

listing of EPA-issued CTGs and ACTs for VOC. In this action, we assume that 

consistency with the CTG represents RACT. 

Under CAA section 183(b), EPA is required to periodically review and, as 

necessary, update CTGs. For the offset lithographic printing source category, on 

November 8, 1993, EPA published a draft CTG for offset lithographic printing (58 FR 

59261). After reviewing comments on the draft CTG and soliciting additional 
Page 5 of 26

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 

2006, 2007 and 2008 EPA issued a number of CTGs, including one for Offset 

Lithographic Printing and Letterpress Printing which provided recommendations for 

RACT for these sources. 

In accordance with the 2006, 2007 and 2008 CTGs, Texas revised its Chapter 115 

regulations to address these VOC RACT control measures. The revisions to Chapter 115 

regulations that correspond to the 2006 EPA-issued CTG for Offset Lithographic Printing 

and the related RACT analysis for both HGB and DFW is the subject of this rulemaking 

action. 

Table 1 shows the source category addressed in this action, the CTG document 

issued by EPA, and the corresponding Texas rules which address these particular CTG 

control requirements. 

Table 1 

CTG Category, EPA Reference Document, and Corresponding Texas Rules 

Source 

Category 

CTG Reference Document Chapter 115, 

Fulfilling RACT 

Offset 

Lithographic 

Printing 

Control Techniques Guidelines for Offset 

Lithographic Printing and Letterpress Printing, 

EPA-453/R-06-002-September 2006

§115.440 – 449 

The corresponding sections of Chapter 115 for the source category identified in 

Table 1 above will be evaluated later in this document. See Appendix A for a list of the 

2006, 2007, and 2008 CTG’s (Lithographic Printing Materials is included in the second 

CTG listed in Group II). 

 For the 1-hour ozone standard, Texas had previously met RACT for VOC 

sources. For the HGB area, as part of a 1-Hour ozone attainment demonstration plan, we 

stated that Texas has met RACT for VOC sources (70 FR 58136, October 5, 2005, and 71 

FR 52676, September 6, 2006). Similarly, for the DFW area, as part of a 1997 8-Hour 

ozone attainment demonstration plan, we stated that Texas has met RACT for VOC 

sources (74 FR 1903, January 14, 2009). 
Page 6 of 26

 The HGB Area was designated as Severe for the 1997 8-Hour ozone NAAQS. 

See 73 FR 56983, October 1, 2008. Thus, per section 182(d) of the CAA, a major 

stationary source in the HGB Area is one which emits, or has the potential to emit, 25 tpy 

or more of VOCs or NOx. 

On April 30, 2004, the EPA designated the DFW area as a moderate 

nonattainment area under the 1997 8-hour ozone standard, with an attainment date of 

June 15, 2010 (see 69 FR 23858). However, the DFW area failed to attain the 1997 ozone 

standard by June 15, 2010, and was therefore reclassified as a serious ozone 

nonattainment area (see 75 FR 79302, December 20, 2010).2

 Thus, per section 182(b) of 

the CAA, a major stationary source in the DFW Area is one which emits, or has the 

potential to emit, 50 tpy or more of VOCs or NOx. 

B. Offset Lithography 

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 rubbercovered, 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. 

 2 On April 30, 2012, the EPA promulgated designations under the 2008 ozone standard (see 77 

FR 30088, published May 21, 2012). In that action, the EPA designated Collin, Dallas, Denton, Ellis, 

Johnson, Kaufman, Parker, Rockwall, Tarrant and Wise counties as a moderate ozone nonattainment area. 

This action does not address the nonattainment area for the 2008 ozone standard. 
Page 7 of 26

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. (2006 CTG, p.6). 

C. Purpose of this Action 

This rulemaking addresses changes to Texas’ VOC rules affecting offset lithographic 

printing sources in the Dallas Fort Worth (DFW) and Houston Galveston Brazoria (HGB) 

1997 8-hour ozone nonattainment areas and also El Paso. Further discussion will focus 

on the HGB and DFW 1997 8-hour ozone nonattainment areas because of the CTG 

requirements and RACT for these areas. The HGB Area consists of Brazoria, Chambers, 

Fort Bend, Galveston, Harris, Liberty, Montgomery and Waller counties; the DFW Area 

consists of Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and 

Tarrant counties. 

These rule revisions reduce the VOC content limits on fountain solutions used by sources 

that were subject to the previous Chapter 115 rules. These rules also limit the VOC 

content of fountain and cleaning solutions used by certain sources that were exempt from 

the previous Chapter 115 rules. 

In offset lithographic printing, VOC emissions result from the evaporation of components 

of the ink, fountain solution and cleaning solution. These rule revisions reduce the VOC 

content limits on fountain solutions used by offset lithographic printing operations 

previously subject to Chapter 30 TAC Chapter 115, Subchapter E, Division 4 regulations. 

These rules also limit the VOC content of fountain and cleaning solutions used by smaller 

offset lithographic printing operations that were exempt under previous rules. 
Page 8 of 26

Previous Chapter 115 rules provided limits for the VOC content of fountain and cleaning 

solutions used by offset lithographic printing lines when uncontrolled as follows: 

in the DFW area: sources with combined VOC emissions of at least 50 tons per 

calendar year (tpy) 

in the HGB area: sources with combined VOC emissions of at least 25 tpy. 

For the major sources which were previously subject to the Chapter 115 rules mentioned 

above (sources with VOC emissions of at least 50 tpy in DFW, or sources with VOC 

emissions of at least 25 tpy in HGB), these revisions continue to limit the VOC content 

limits for fountain solutions and continue to limit the VOC content of cleaning solution 

used at these printing sources in the DFW and HGB areas. The rule revisions affecting 

these sources were implemented by the State beginning March 1, 2011. 

Additionally, for smaller sources at a facility with combined VOC emissions of at least 3 

tpy when uncontrolled, these revisions expand requirements in the DFW and HGB areas 

to limit the content of fountain and cleaning solutions used by offset lithographic printing 

lines. The rule revisions affecting these sources were implemented by the State 

beginning March 1, 2012. 

In general, these rule revisions require the owner or operator of an affected offset 

lithographic printing line to reduce the VOC content of the fountain solution and the 

cleaning solution used in the printing process. To reduce the VOC content of the 

fountain solution, these rule revisions provide several compliance options including: 

reducing the alcohol content of the refrigerated solution; further reducing the alcohol 

content of the unrefrigerated solution; or using reformulated materials to eliminate 

alcohol in the solution. To reduce the VOC content of the cleaning solution, these rule 

revisions also provide several options, including using low-VOC cleaning solutions; 

using low-VOC cleaning solution in conjunction with work practice standards; or using 

low vapor pressure cleaning solutions in conjunction with work practice standards. 
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The discussion in section III of this TSD, Evaluation of Texas’ Rule Revisions and 

RACT Analysis Addressed in this Action, provides additional detail regarding the rule 

revisions and RACT analysis for HGB and DFW, and covers the following topics: 

 Letterpresses 

 Heatset Offset Lithographic Presses 

 Fountain Solution 

 Cleaning Solution 

Monitoring, Recordkeeping, and Testing Requirements 

 Non-Substantive Revisions. 

D. Prior RACT Actions in HGB and DFW 

DFW 1-Hour Ozone RACT. In the four core counties which comprised the DFW 1-hour 

ozone nonattainment area, Collin, Dallas, Denton, and Tarrant Counties, Texas 

previously adopted rules to address RACT requirements for all source categories covered 

by EPA CTGs, and to address major sources at the moderate area major source threshold 

of 100 tpy. The EPA approved these rules as meeting VOC RACT for a moderate 1-hour 

ozone nonattainment area (60 FR 12438). The reclassification of the area from moderate 

to serious for the 1-hour ozone standard, on February 18, 1998 (63 FR 8128), required 

Texas to ensure that RACT was in place on non-CTG sources in the four core counties 

down to 50 tpy. Texas submitted a SIP to address this requirement and EPA approved 

this SIP submission as meeting the 1-hour ozone VOC RACT requirements for the DFW 

1-hour ozone “serious” nonattainment area on January 14, 2009 (74 FR 1903)3

. This 

action approved Texas’ certification that RACT was in place on non-CTG sources down 

to 50 tpy. 

 

3 This 1-hour action was initially proposed for approval on January 18, 2001 (66 FR 4756). Although we 

received no comments on that proposal, we never took final action. In our proposal July 14, 2008, we reopened the comment period on the 2001 proposed action for 1-hour ozone serious area RACT 

requirements, again received no comments, and then took final action on it on January 14, 2009, in the 

same rulemaking where we finalized action on the VOC RACT 1997 8-hour ozone proposal.. 
Page 10 of 26

Offset lithographic printers are primarily minor sources of VOCs but due to their 

numbers constitute a significant source of emissions in a nonattainment area. As part of 

its efforts to achieve reasonable further progress and to attain the one hour standard in the 

HGB and DFW areas, Texas adopted rules for offset lithographic printers. 

DFW 8-Hour Ozone RACT. On April 30, 2004, EPA published the 8-hour ozone 

designations and the Phase 1 Rule for implementing the 1997 8-hour ozone standard (69 

FR 23858 and 69 FR 23951); the Phase 2 Rule was published November 29, 2005 (70 FR 

71612). These EPA actions designated the DFW area as nonattainment for the 8-hour 

ozone standard, and established RACT requirements for the DFW nonattainment area 

which included the following nine counties: Collin, Denton, Dallas, Tarrant (these four 

constituted the 1-hour ozone nonattainment area and are referred to as the four core 

counties), and Ellis, Johnson, Kaufman, Parker and Rockwall. Texas submitted a SIP 

revision which extended VOC control requirements to facilities located in Ellis, Johnson, 

Kaufman, Parker, and Rockwall counties, requiring subjected affected VOC sources in 

these five counties to the same emissions limitation, control, monitoring, testing, 

recordkeeping, and reporting requirements in effect in the four core counties; this 

revision was approved by EPA on July 17, 2008 (73 FR 40972). 

In September 2006, EPA issued, for the first time, a CTG for offset lithography. Under 

182(b)(2)(C), Texas was required to evaluate its rules for consistency with the guidance 

in the CTG and develop any necessary revisions. 

E. Texas’ SIP Revisions Included in this Action 

This action addresses three Texas SIP revisions, the first in its entirety, and the second 

two in part: 
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Texas VOC Control Technique Guidelines Update4

Rule Project No. 2008-019-115-EN 

Amendments: §§115.440, 115.442, 115.443, 115.445, 115.446, 115.449 

New: §115.441 

Date Adopted by Texas: March 10, 2010 

Effective Date for Texas: April 1, 2010 

Submittal Date: April 5, 2010 

Date Received by EPA: April 10, 2010. 

2010 HGB Attainment Demonstration SIP Revision for the 1997 Eight-Hour 

Ozone Standard5

Project No. 2009-017-SIP-NR 

Date Adopted by Texas: March 10, 2010 

Effective Date for Texas: April 1, 2010 

Submittal Date: April 6, 2010 

Date Received by EPA: April 9, 2010. 

2010 DFW RACT, Rule, and Contingency SIP Revision6

Project No. 2009-021-SIP-NR 

Date Adopted by Texas: March 10, 2010 

Effective Date for Texas: April 1, 2010 

Submittal Date: April 6, 2010 

Date Received by EPA: April 12, 2010. 

Throughout this TSD, these three Texas submittals will be referred to as “VOC CTG 

Update: Offset Lithographic Printing”, “2010 HGB AD with RACT” and “2010 DFW 

Update with RACT”, respectively. 

This action addresses the “VOC CTG Update: Offset Lithographic Printing” in full. 

Also, this action addresses part of the “2010 HGB AD Including RACT” and part of the 

“2010 DFW Update Including RACT”. For each, it addresses the part related to RACT 

for Offset Lithographic Printing. 

III. Evaluation of Texas’ SIP Revisions Addressed in this Action 

The source category identified in Table A above, Offset Lithographic Printing, is 

discussed in detail below for purposes of comparison with the CTG Reference Document, 

and RACT requirements. A comparison of the requirements with the rule revisions in the 

 

4

 Referred to as “VOC CTG Update: Offset Lithographic Printing” throughout this document. 

5

 Referred to as “2010 HGB AD Including RACT” throughout this document 

6

 Referred to as “2010 DFW Update including RACT” throughout this document. 
Page 12 of 26

“VOC CTG Update: Offset Lithographic Printing” is presented below, followed by a 

discussion of the rule revisions by section. 

A. Comparison of CTG Requirements and Rule Revisions 

Letterpresses 

The 2006 CTG addresses controlling VOC emissions from letterpress printing. This SIP 

revision does not include rule changes for letterpress printing sources because review of 

the point source emissions inventory, Title V Permits and central registry databases did 

not identify any letterpresses that would be subject to the CTG recommended controls. 

Heatset Offset Lithographic Presses 

The 2006 CTG recommends requiring an add-on air pollution control device on each 

individual heatset web offset-lithographic press with the uncontrolled potential to emit at 

least 25 tpy from ink oils volatilized in the dryer. In addition, the CTG recommends 

increasing the control efficiency requirement from 90% to 95% for control devices 

installed after the rule effective date. Based on this, for heatset presses, the State found 

and EPA agrees that the existing rules are at least as effective as or more effective than 

the 2006 CTG recommendations. 

For control devices installed before the effective date of the rule, in the HGB area, the 

existing Chapter 115 rules either meet or exceed EPA’s recommendations for control 

devices installed before the effective date of the rule. Similarly, in the DFW area, the 

existing Chapter 115 rules for control on heatset presses either meet or exceed the CTG 

recommendation for control devices. 

For control devices installed after the effective date of the rule, the 2006 CTG 

recommendation to require a 95% control efficiency was determined by the State to be no 

more stringent than the existing rules which require control devices with an efficiency of 

at least 90% to be installed on all heatset offset lithographic presses located at a facility 

with combined VOC emissions (when uncontrolled) of at least 50 tpy in the DFW area 

and at least 25 tpy in the HGB area. Based on this, the State found, and EPA agrees, that 
Page 13 of 26

the existing rule “is effectively more stringent than the CTG recommended threshold for 

installation of control devices based on 25 tpy of VOC from the dryer because the 

majority of emissions (approximately 75%) come from sources other than the dryer”. 

Additionally, the 2006 CTG recommends setting the control efficiency requirement of the 

control equipment based on the first installation date of the equipment, regardless of the 

location. The State intentionally did not revise its SIP to incorporate this 

recommendation due to a concern that “such a policy may encourage the installation of 

older less efficient equipment and could also create significant practical enforceability 

issues for commission investigators with regard to verifying the first installation date of 

the control equipment”. Because the 2006 CTG recommendation has the potential to be 

less stringent that the State’s existing policy, EPA finds that it is within the State’s 

discretion not to adopt this recommendation. 

Fountain Solution 

The 2006 CTG recommends limiting the fountain solution content to 5.0% alcohol 

substitutes or less by weight and no alcohol in the fountain solution. 

For major sources, the previous Chapter 115 rules contained an option limiting the 

fountain solution content to 3.0% alcohol substitutes or less by weight and no alcohol in 

the fountain solution for printing operations located on a property in the DFW area with 

combined VOC emissions of at least 50 tpy when uncontrolled and in the HGB area with 

combined VOC emissions of at least 25 tpy when uncontrolled. Major printing sources 

that were previously subject to this more stringent limit, continue to be subject to the 

limits of 3.0% alcohol substitutes or less by weight and no alcohol in the fountain 

solution to avoid backsliding. 

For small businesses, this SIP revision offers several options which are consistent with 

the 2006 CTG to help mitigate the financial impact of these regulations. These options 

for smaller sources include the 2006 CTG recommendation to limit the fountain solution 

content to 5% alcohol substitutes or less by weight and no alcohol in the fountain 
Page 14 of 26

solution. Additionally, the compliance date for smaller sources was extended to March 1, 

2012 to provide additional time for these facilities to determine the most cost-effective 

compliance strategies and to implement any necessary changes. 

Cleaning Solution 

The 2006 CTG recommends limiting the VOC content of cleaning solutions used in 

offset lithographic printing operations. It recommends 70.0% VOC by weight in 

conjunction with work practice standards. These rule revisions require the owner or 

operator of an affected offset lithographic printing line to reduce the VOC content of the 

cleaning solutions used in the printing process and provide several options for complying, 

including the following: using low-VOC cleaning solutions; using low-VOC cleaning 

solution in conjunction with work practice standards; or using low vapor pressure 

cleaning solutions in conjunction with work practice standards. These revisions retain 

the existing Chapter 115 rule requiring a cleaning solution content limit of 70% by 

volume in conjunction with work practice standards as an option. Also, these revisions 

retain the previously existing Chapter 115 option to limit the cleaning solution content to 

50% VOC by volume. Because the existing rules were determined to be at least as 

stringent as the 2006 CTG recommendations, TCEQ included these options to retain the 

flexibility afforded to owners and operators subject to the previous rules. Because this 

strategy is at least as stringent at the CTG recommendations, EPA finds this approach 

acceptable. 

The 2006 CTG also recommends specific work practices for cleaning solutions used by 

offset lithographic printing lines with uncontrolled potential to emit at least 3.0 tpy of 

VOC. These rule revisions include the CTG’s recommended work practice standards for 

cleaning solutions. 

Monitoring, Recordkeeping, and Testing Requirements 

All affected sources are required to comply with monitoring, recordkeeping, and testing 

requirements to demonstrate continuous compliance with the content limits in these rule 

revisions. 
Page 15 of 26

Non-Substantive Revisions 

In addition to the revisions described above to implement RACT for offset lithographic 

printing, these revisions include grammatical, stylistic, and various other non-substantive 

changes to update the rule in accordance with current requirements, to improve 

readability, to establish consistency in the rules, and to conform to standards in the 

“Texas Legislative Council Drafting Manual”, dated September 2008. 

B. Rule Revisions by Section 

Texas’ VOC CTG Update submittal dated April 5, 2010 identifies the new and amended 

sections of Chapter 115 pertaining to Offset Lithographic Printing, §§115.440 – 449. The 

proposed changes are shown in a red-line, strike-out format in the proposed rule revisions 

which were published in the Texas Register on October 9, 2009, (34 TexReg 7015 - 

7029). The proposed revisions, in combination with the response to comments, are 

indicated in the adopted rules which were published in the Texas Register on March 26, 

2010 (35 TexReg 2579 – 2598). A discussion of the revisions by section is included in 

this part of the TSD. For additional detail, please see the Texas submittal. 

Section 115.440 sets forth applicability for the counties in which offset lithographic 

printing sources are subject to these control requirements. This section also defines terms 

used in offset lithographic printing operations. Such definitions provide for consistency in 

application and enforcement of the rules. For compliance dates see §115.549. 

Section 115.441 states which offset lithographic printing processes are exempt for 

compliance with the emission specifications of pounds of VOC per gallon of coating. 

See §115.442. This section will facilitate inspection and enforcement of the rule. 

Section 115.422 establishes control requirements with which offset lithographic printing 

lines will need to comply. Establishing control requirements provides for lowering VOC 

emissions. 

Section 115.423 provides for an alternative means of control for offset lithographic 

printing operations. Emissions calculations shall be based on the pounds of VOC per 
Page 16 of 26

gallon of solids for all affected coatings. This section provides for operational flexibility 

for operations. 

Section 115.424 – there is no section 115.424. 

Section 115.425 establishes what test methods are to be used for testing requirements of 

the offset lithographic printing operations. These methods include: Test Methods 1-4, 

Test Method 24, Test Method 25, Test Methods 25A or 25B (40 Code of Federal 

Regulations (CFR) Part 60, Appendix A), and EPA guidelines series document 

“Procedures for Certifying Quantity of Volatile Organic Compounds (VOC) Emitted by 

Paint, Ink, and Other Coatings,” EPA-450/3-84-019, as in effect December, 1984; and 

additional test procedures described in 40 Code of Federal Regulations (CFR) 60.444. 

Adoption of these approved Test Methods will provide for federally enforceable 

mechanism for Chapter 115. 

Section 115.426 sets forth what parameters are to be monitored and what records are to 

be maintained by the owner or operator of each offset lithographic printing press source. 

Among the monitored parameters are the material data sheets, and the quantity and type 

of each coating and solvent consumed during the specified averaging period. Records 

shall be maintained for at least two years and shall be made available upon request by 

representatives of the executive director, EPA, or any local air pollution control agency 

establishes. 

Section 115.427 – there is no section 115.427. 

Section 115.428 – there is no section 115.424.8 

Section 115.429 sets forth the compliance schedule for the offset lithographic printing 

press sources subject to these control requirements. 

Sections 115.440 – 429 provide for lowering of VOC emissions from this sector and 

represent RACT for both the HGB and DFW areas. For the HGB area, we have 

previously stated that VOC and NOx RACT requirements under the ACT are in place for 

the HGB area for the 1-hour ozone NAAQS (HGB: 71 FR 52676, September 6, 2006). 

For the DFW area, EPA previously approved VOC rules as meeting RACT for the 1-hour 

ozone NAAQS as follows: for a moderate 1-hour ozone nonattainment area (60 FR 
Page 17 of 26

12438, March 7, 1995), and for a serious 1-hour ozone nonattainment area (74 FR 1903, 

January 14, 2009)7. 

We have compared Texas’ rule revisions to the CTG recommendations and found that 

these control measures are consistent with, or at least as stringent as, those described in 

EPA’s Control Techniques Guidelines for Offset Lithographic Printing and Letterpress 

Printing, EPA-453/R-06-002-September 2006. 

Based on EPA’s May 18, 2006 RACT Q and A document, the framework described 

above, and TCEQ’s certification in its 2010 submittals (April 6, 2010 SIP submittals for 

HGB and DFW: “2010 HGB AD Including RACT”, and “2010 DFW Update Including 

RACT”), we find that the requirements established in sections 115.440-429 for Offset 

Lithographic Printing represent RACT for this sector under the 8-Hour ozone NAAQS. 

(See 70 FR 71612, November 29, 2005, regarding permissible approaches for 

determining whether a State’s level of control meets RACT.) 

C. Comparison of RACT Requirements and Texas’ RACT Assessments for 

HGB and DFW 

In the spring of 2010, Texas submitted the rulemaking “VOC CTG Update: Offset 

Lithographic Printing”, as well as separate RACT assessments for the HGB and DFW 

 

7

 In the four core counties, which comprised the 1-hour ozone nonattainment areas, Texas previously 

adopted rules to address RACT requirements for all source categories covered by EPA CTGs, and to 

address major sources at the moderate area major source threshold of 100 tpy. The EPA approved these 

rules as meeting VOC RACT for a moderate 1-hour ozone nonattainment area (60 FR 12438). The 

reclassification of the area from moderate to serious for the 1-hour ozone standard, on February 18, 1998 

(63 FR 8128), required Texas to ensure that RACT was in place on non-CTG sources down to 50 tpy. 

Texas submitted a SIP to address this requirement and we proposed to approve the SIP submission as 

meeting the 1-hour ozone serious area VOC RACT requirement for the DFW 1-hour ozone nonattainment 

area on January 18, 2001 (66 FR 4756). Although we received no comments on that proposal we never 

took final action on that proposal. In our proposal July 14, 2008, we re-opened the comment period on that 

proposed action for 1-hour ozone serious area RACT requirements. On January 14, 2009, our final rule on 

that 2008 proposal, we fully approved the DFW are SIP as meeting the RACT requirement for VOCs for 

both the 1-hour and 1997 8-hour ozone nonattainment area. 
Page 18 of 26

areas, “2010 HGB AD Including RACT” and “2010 DFW Update Including RACT” with 

an analysis of the offset lithographic printing rules8. The RACT assessment for HGB 

was included in a SIP revision of April 6, 2010 (Project No. 2009-017-SIP-NR), and the 

RACT assessment for DFW was included in a separate SIP revision submitted on the 

same date (Project No. 2009-021-SIP-NR). In those submittals, Texas evaluated its 

existing RACT regulations which were federally approved and adopted to meet the 1-

hour ozone standard. Texas evaluated whether these regulations constitute RACT for the 

new 8-hour ozone NAAQS and determined that the regulations do meet RACT 

requirements. Texas’ 8-Hour ozone RACT analysis demonstrates that RACT 

requirements have been satisfied by one of two methods as follows: a) certification that 

previously required RACT controls for the 1-hour ozone standard represent RACT for 8-

hour ozone implementation purposes, or, where necessary, as is the case for this CTG, 

through b) new or revised RACT rules for certain regulations or sources. TSD Appendix 

B contains excerpts from Texas’s HGB submittal related to offset lithographic printing 

(2010 HGB AD, Appendix D, section 3.3.2.4, April 6, 2010); TSD Appendix C has 

excerpts from the DFW submittal (2010 DFW RACT, Rule, and Contingency, sections 

4.2.1.2 and 4.3.1.3 and Appendix A section 3.1.4, April 6, 2010). In making its 8-Hour 

ozone RACT determination, Texas also relied on EPA’s May 18, 2006 RACT Q and A 

document9. See the 2010 HGB AD, Appendix D, section 3.3.2.4; see also 2010 DFW 

RACT, Rule, and Contingency sections 4.2.1.2 and 4.3.1.3 and Appendix A section 3.1.4. 

Accordingly, the framework for Texas’ RACT SIP determination is to: 

 Identify all source categories covered by Control Technique Guidelines (CTG) 

and Alternative Control Technique (ACT) documents. 

 Identify applicable regulations that implement RACT. 

 Certify that the existing level of controls for the 1-hour ozone standard equals 

RACT under the 8-hour ozone standard, or 

 

8 See Section II. C. Texas’ SIP Revisions Addressed in this Action for more information. 9

 A memorandum dated May 18, 2006, from William T. Harnett, Director, Air Quality Policy Division to 

Regional Air Division Directors, titled “RACT Qs & As – Reasonably Available Control Technology 

(RACT): Questions and Answers” (EPA’s May 18, 2006 RACT Q and A document) explains the 

relationship of the 1-Hour RACT and the 1997 8-Hour RACT in the form of a series of questions and 

answers. This document is available at http://www.epa.gov/ttn/oarpg/t1/memoranda/ractqanda.pdf (URL 

dating June 12, 2012). 
Page 19 of 26

 Declare that sources covered by a CTG and ACT do not exist within the state 

and/or that RACT is not applicable in certain cases, or 

 Identify potential RACT revisions necessary to implement RACT. 

By approving RACT under the 1-hour ozone standard (HGB: 71 FR 52676, September 6, 

2006; DFW: 60 FR 12438, March 7, 1995; 74 FR 1903, January 14, 2009)6

, we found 

that control measures in 30 TAC Chapter 115 meet the lowest emissions limitation that a 

particular source is capable of meeting by the application of control technology that is 

reasonably available, considering technological and economic feasibility. In EPA’s May 

18, 2006 RACT Q and A document, EPA recommends a State certify after review that its 

regulations continue to represent RACT for the 1997 8-Hour ozone NAAQS. The 

certification approach is in agreement with the 70 FR 71612, November 29, 2005 (Final 

Rule to Implement the 8-Hour Ozone NAAQS). We have also approved that VOC 

control measures in 30 TAC Chapter 115 meet RACT under the 8-Hour ozone standard 

for selected industries in the HGB Area on April 2, 2013 at 78 FR 19599. Also, see 2010 

HGB AD, Appendix D, sections 3.1 and 3.3, as well as 2010 DFW RACT, Rule, and 

Contingency sections 4.2, 4.3 and Appendix A. 

The EPA had previously approved Texas’ SIP for RACT for HGB and DFW for VOC 

and NOx under the 1-Hour ozone standard, finding that these control measures result in 

the lowest emissions limitation that a particular source is capable of meeting through 

application of control technology that is reasonably available, considering technological 

and economic feasibility. 

On April 2, 2013 (78 FR 19599) we finalized approval of RACT for several VOC 

emitting sectors in the HGB Area under the 1997 8-Hour ozone National Ambient Air 

Quality Standard (NAAQS). 

Based on the CTG and EPA’s May 18, 2006 RACT Q and A document, the framework 

identified above, and Texas’ certification of its RACT analysis (a permissible approach 

per 70 FR 71612, November 29, 2008 -Final Rule to Implement the 8-Hour Ozone 
Page 20 of 26

NAAQS), we find that the 30 TAC Chapter 115 control requirements meet RACT for 

VOC sources identified in Table 1 of this document in the HGB and DFW 1997 8-Hour 

ozone nonattainment areas. Therefore, by implementing the 30 TAC Chapter 115 control 

requirements, Texas has the 8-Hour RACT in place for VOC sources identified in Table 

1 in the HGB and DFW areas. 
Page 21 of 26

Appendix A 

Control Techniques Guideline Documents Issued by EPA 

in 2006, 2007 and 2008 

Group II (71 FR 58745, October 5, 2006) 

Flexible Packaging Printing Materials 

Lithographic Printing Materials and Letterpress Printing Materials 

Industrial Cleaning Solvents 

Flat Wood Paneling Coatings 

Group III (72 FR 57215, October 9, 2007) 

Paper, Film, and Foil Coatings 

Metal Furniture Coatings 

Large Appliance Coatings 

Group IV (73 FR 58481, October 7, 2008) 

Miscellaneous Metal and Plastic Parts Coatings 

Auto and Light-Duty Truck Assembly Coatings 

Fiberglass Boat Manufacturing Materials 

Miscellaneous Industrial Adhesives 

 
Page 22 of 26

Appendix B 

Excerpt from Texas’ 2010 HGB Attainment Demonstration SIP Submittal 

Appendix D: RACT10

3.3.2.4 Offset Lithographic and Letterpress Printing

Concurrent with this SIP revision, the TCEQ adopted revisions to 30 TAC Chapter 115, 

Subchapter E, Division 4 to implement the EPA's 2006 Offset Lithographic and Letterpress 

Printing CTG D-6 recommendations that represent RACT in the HGB area. The adopted Chapter 

115 rulemaking reduces the VOC content of the fountain solutions and cleaning solutions used by 

offset lithographic printing operations, and expands the rule applicability to include smaller offset 

lithographic printing sources that were previously exempt from these rules. The TCEQ 

determined that no letterpress printing operations meeting the applicability criteria recommended 

in the CTG document are located in the HGB area. Therefore, the TCEQ provides a negative 

declaration for the Letterpress Printing CTG source category.

The TCEQ maintains that the overall VOC control level in the adopted Chapter 115, 

Subchapter E, Division 4 rules is equivalent to or more stringent than the EPA's 2006 CTG 

recommendations and sufficient to fulfill RACT for offset lithographic printing operations. 

The TCEQ must balance arbitrarily implementing the 2006 CTG recommendations with the 

potential for backsliding, enforceability considerations, and the possible impacts to sources that 

have already complied with the existing rules. 

In several instances the adopted Chapter 115 content limits are more stringent than EPA's 2006 

CTG recommendations. The 2006 CTG recommendations include limiting the VOC content of 

cleaning solutions used in offset lithographic printing operations to 70 percent VOC by weight 

in conjunction with work practice standards. The adopted Chapter 115 rules retain the more 

stringent cleaning solution content limit of 70 percent VOC by volume in conjunction with 

work practice standards. Assuming the VOC in the cleaning solvent used is kerosene, the VOC 

referenced in the 2006 CTG, the adopted Chapter 115 content limit of 70 percent VOC by 

volume for cleaning solutions is equivalent to 66 percent VOC by weight. EPA's 2006 CTG 

also recommends limiting the fountain solution content to five percent alcohol substitutes or 

less by weight and no alcohol in the fountain solution. To prevent potential backsliding for 

sources already required to comply with these state regulations, the adopted Chapter 115 rules 

retain the more stringent fountain solution content limit of three percent alcohol substitutes or 

less by weight and no alcohol in the fountain solution. 

The TCEQ maintains that the adopted Chapter 115 rules for heatset offset lithographic presses 

are at least as stringent as the EPA's 2006 CTG recommended controls. The EPA's CTG 

recommends an add-on air pollution control device be required on each individual heatset offset 

 

10 Excerpt from Texas’ 2010 HGB Attainment Demonstration SIP Revision for the 1997 EightHour Ozone Standard: 

Project No. 2009-017-SIP-NR 

Date Adopted by Texas: March 10, 2010 

Effective Date for Texas: April 1, 2010 

Date Submitted by Texas: April 6, 2010.
Page 23 of 26

lithographic press with the uncontrolled potential to emit 25 tpy of VOC or more from the dryer. 

The Chapter 115 rule require control devices, with a control efficiency of at least 90 percent, to 

be installed on heatset offset lithographic presses on a property in the HGB area with total 

uncontrolled VOC emissions of at least 25 tpy, which includes VOC emissions from ink oils 

evaporated by the press dryer and VOC in fountain and cleaning solutions. In Table 5-1 of the 

1993 draft Offset Lithographic Printing CTG, the EPA estimates that 26 percent of the total 

uncontrolled VOC emissions from heatset offset lithographic printing operations are emitted 

from the press dryer. Based on EPA's assumption, an individual heatset press located on a 

property with total uncontrolled VOC emissions of 25 tpy would emit less than 7 tpy of VOC 

from the press dryer. Therefore, the Chapter 115 rules are effectively more stringent than the 

EPA's 2006 CTG RACT recommendations with regard to the applicability threshold for this 

control requirement. Additionally, the EPA's 2006 CTG recommended exempting heatset 

presses used for book printing and heatset presses with a maximum web width of 22 inches or 

less from the add-on control device requirements. The existing Chapter 115 regulations do not 

exempt these sources from the control requirements and the TCEQ has not adopted these 

exemptions into the revised rule. 

The EPA's CTG recommends requiring control equipment first installed before the effective date 

of rules implementing the CTG to have an overall control efficiency of 90 percent and control 

equipment first installed after the effective date of rules implementing the CTG to have an 

overall control efficiency of 95 percent. The TCEQ disagrees with the EPA's CTG 

recommendation to correlate control device efficiency requirements with the first installation 

date of the control device regardless of where the equipment was installed. The TCEQ contends 

imposing this policy may encourage the installation of older, less efficient equipment and may 

create potential backsliding issues. The policy may also create significant practical D-7 

enforceability issues for TCEQ investigators with regard to verifying the first installation date of 

the control equipment. 

Regardless of the first installation date of the device, the EPA recommends providing the 

alternative option to reduce the control device outlet concentration to 20 parts per million by 

volume (ppmv) as hexane on a dry basis to accommodate situations where the inlet VOC 

concentration is too low to demonstrate the 90 or 95 percent control efficiency. The Chapter 

115 rules provide affected owners or operators of a heatset offset lithographic printing press the 

option to operate a control device to reduce VOC emissions from the press dryer exhaust vent 

by 90 percent by weight or maintain a maximum dryer exhaust outlet VOC concentration of 20 

ppmv. The Chapter 115 alternative concentration limit is substantially preferable because it 

encourages VOC emission reductions without requiring add-on controls and implementing the 

EPA's recommended approach would penalize operations who were able to achieve the 20 

ppmv limit without the installation of expensive add-on control devices. 

Based on this analysis, the TCEQ determined that the adopted Chapter 115 rules for offset 

lithographic printing operations provide an overall VOC control level that is at least equivalent 

to the 2006 CTG recommendations and are more effective and enforceable. Therefore, the 

revised Chapter 115, Subchapter E, Division 4 rules are sufficient to fulfill RACT for offset 

lithographic printing operations in the HGB area. 

 
Page 24 of 26

Appendix C 

Excerpt from Texas’ DFW RACT Update SIP Submittal11

Dallas-Fort Worth Reasonably Available Control Technology Update, 

30 Texas Administrative Code Chapter 117 Rule Revision Noninterference Demonstration, 

and Modified Failure-to-Attain Contingency Plan State Implementation Plan Revision

4.2.1.2. 30 TAC Chapter 115 VOC Rule Revision (Rule project 2008-019-115-EN) 

The TCEQ has adopted revisions to 30 TAC Chapter 115, Subchapter E, Division 4 to implement 

the EPA's 2006 Offset Lithographic and Letterpress Printing CTG recommendations that 

represent RACT in the DFW area concurrent with this SIP revision. The adopted Chapter 115 

rulemaking reduces the VOC content of the fountain solutions and cleaning solutions used by 

offset lithographic printing operations and expands rule applicability to include smaller offset 

lithographic printing sources that were previously exempt from these rules. 

Additional information on the offset lithographic printing rule revision is contained in the 

preamble for TCEQ Rule project 2008-019-115-EN. Additional information on the RACT 

Adopted March 10, 2010 4-1 DFW RACT, Rule, and Contingency SIP Revision analysis of the 2006 

Offset Lithographic and Letterpress Printing CTG can be found in Appendix A: DFW Reasonably 

Available Control Technology Analysis Update. 

Because the commission revised Chapter 115 rules to include RACT requirements for offset 

lithographic printing sources, the state VOC rule for those sources is no longer available for use 

as a measure in the contingency plan for the DFW 1997 eight-hour ozone attainment 

demonstration. Therefore, the offset lithographic printing rule is no longer identified as a 

measure in the modified failure-to-attain contingency plan adopted within this DFW RACT, Rule, 

and Contingency SIP Revision. To maintain integrity of the attainment demonstration, this SIP 

revision allocates emission reductions from fleet turnover to replace the contingency reduction 

removed with the offset lithographic printing rule measure, as more specifically described in 

Section 4.6: Contingency Measures, of this SIP revision. 

4.3.1.3. CTG Documents that Represent RACT for the DFW Area 

Concurrent with this SIP revision, the TCEQ adopted revisions to 30 TAC Chapter 115, 

Subchapter E, Division 4 to implement the EPA's 2006 Offset Lithographic and Letterpress 

Printing CTG recommendations that represent RACT in the DFW area (TCEQ Rule Project 

2008-019-115-EN). The adopted Chapter 115 rulemaking reduces the VOC content of the 

fountain solutions and cleaning solutions used by offset lithographic printing operations and 

expands the rule applicability to include smaller offset lithographic printing sources that were 

previously exempt from these rules. The overall VOC control level in the adopted Chapter 115 

rules is equivalent to or more stringent than the EPA's 2006 CTG recommendations and sufficient 

to fulfill RACT for offset lithographic printing operations in the DFW area. 

 

11 Excerpt from Texas’ DFW RACT, Rule, and Contingency SIP Revision: 

Project No. 2009-021-SIP-NR 

Date Adopted by Texas: March 10, 2010 

Effective Date for Texas: April 1, 2010 

Date Submitted by Texas: April 6, 2010. 
Page 25 of 26

APPENDIX A: 

DALLAS-FORT WORTH 

REASONABLY AVAILABLE CONTROL TECHNOLOGY 

ANALYSIS UPDATE 

3.1.4. Offset Lithographic and Letterpress Printing 

Concurrent with this SIP revision, the TCEQ adopted revisions to 30 TAC Chapter 115, 

Subchapter E, Division 4 to implement the EPA's 2006 Offset Lithographic and Letterpress 

Printing CTG recommendations that represent RACT in the DFW area. The adopted Chapter 115 

rulemaking reduces the VOC content of the fountain solutions and cleaning solutions used by 

offset lithographic printing operations, and expands rule applicability to include smaller offset 

lithographic printing sources that were previously exempt from these rules. The TCEQ 

determined that no letterpress printing operations meeting the applicability criteria recommended 

in the CTG document are located in the DFW area. Therefore, the TCEQ provides a negative 

declaration for the Letterpress Printing CTG source category. 

In its analysis of the EPA's 2006 Offset Lithographic and Letterpress Printing CTG 

recommendations, the TCEQ must balance the VOC control level in the adopted Chapter 115, 

Subchapter E, Division 4 rules and potential for backsliding from implementing the 2006 CTG 

recommendations, along with enforceability considerations, and possible impacts to sources that 

have already complied with the existing rules. 

In several instances the adopted Chapter 115 content limits are more stringent than EPA's 2006 

CTG recommendations. The 2006 CTG recommends include limiting the VOC content of 

cleaning solutions used in offset lithographic printing operations to 70 percent VOC by weight in 

conjunction with work practice standards. The adopted Chapter 115 rules retain the more 

stringent cleaning solution content limit of 70 percent VOC by volume in conjunction with work 

practice standards. Assuming the VOC in the cleaning solvent used is kerosene, the VOC 

referenced in the 2006 CTG, the adopted Chapter 115 content limit of 70 percent VOC by volume 

for cleaning solutions is equivalent to 66 percent VOC by weight. EPA's 2006 CTG also 

recommends limiting the fountain solution content to 5 percent alcohol substitutes or less by 

weight and no alcohol in the fountain solution. To prevent potential backsliding for sources 

already required to comply with these state regulations, the adopted Chapter 115 rules retain the 

more stringent fountain solution content limit of 3 percent alcohol substitutes or less by weight 

and no alcohol in the fountain solution. 

The adopted Chapter 115 rules for heatset offset lithographic presses are at least as stringent as 

the EPA's 2006 CTG recommended controls. The EPA's CTG recommends an add-on air 

pollution control device be required on each individual heatset offset lithographic press with the 

uncontrolled potential to emit 25 tons per year (tpy) of VOC or more from the dryer. The rules in 

Chapter 115, Subchapter E, Division 4, require control devices, with a control efficiency of at 

least 90 percent, to be installed on heatset offset lithographic presses on a property in the DFW 

area with total uncontrolled VOC emissions of at least 50 tpy, which includes VOC emissions 

from ink oils evaporated by the press dryer and VOC in fountain and cleaning solutions. In Table 

Table 5-1: Model Plant Product Use and Baseline (Uncontrolled) Volatile Organic Compounds 

(Average Tons Per Year), of the 1993 draft Offset Lithographic Printing CTG, the EPA estimates 

that 26 percent of the total uncontrolled VOC emissions from heatset offset lithographic printing 

operations are emitted from the press dryer. Based on EPA's assumption, an individual heatset 
Page 26 of 26

press located on a property with total uncontrolled VOC emissions of 50 tpy would emit less than 

13 tpy of VOC from the press dryer. Therefore, the Chapter 115 rules are effectively more 

stringent than the EPA's 2006 CTG RACT recommendations with regard to the applicability 

threshold for this control requirement. Additionally, the EPA's 2006 CTG recommended 

exempting heatset presses used for book printing and heatset presses with a maximum web width 

of 22 inches or less from the add-on control device requirements. The existing Chapter 115 

regulations do not exempt these sources from the control requirements and the TCEQ has not 

adopted these exemptions into the revised rule. 

The EPA's CTG recommends requiring control equipment first installed before the effective date 

of rules implementing the CTG to have an overall control efficiency of 90 percent and control 

equipment first installed after the effective date of rules implementing the CTG to have an overall 

control efficiency of 95 percent. The TCEQ disagrees with the EPA's CTG recommendation to 

correlate control device efficiency requirements with the first installation date of the control 

device regardless of where the equipment was installed. Imposing this policy may encourage the 

installation of older, less efficient equipment and may create potential backsliding issues. The 

policy may also create significant practical enforceability issues for TCEQ investigators with 

regard to verifying the first installation date of the control equipment. 

Regardless of the first installation date of the device, the EPA recommends providing the 

alternative option to reduce the control device outlet concentration to 20 parts per million by 

volume (ppmv) as hexane on a dry basis to accommodate situations where the inlet VOC 

concentration is too low to demonstrate the 90 or 95 percent control efficiency. The Chapter 115 

rules provide affected owners or operators of a heatset offset lithographic printing press the 

option to operate a control device to reduce VOC emissions from the press dryer exhaust vent by 

90 percent by weight or maintain a maximum dryer exhaust outlet VOC concentration of 20 

ppmv. The Chapter 115 alternative concentration limit is substantially preferable because it 

encourages VOC emission reductions without requiring add-on controls and implementing the 

EPA's recommended approach would penalize operations who were able to achieve the 20 ppmv 

limit without the installation of expensive add-on control devices. 

Based on this analysis, the TCEQ determined that the adopted Chapter 115 rules for offset 

lithographic printing operations provide an overall VOC control level that is at least equivalent to 

the 2006 CTG recommendations and are more effective and enforceable. Therefore, the revised 

Chapter 115, Subchapter E, Division 4 rules are sufficient to fulfill RACT for offset lithographic 

printing operations in the DFW area.