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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 Polluti on from Volatile Or ganic 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.Page 2 of 26 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 A ddressed in this Action
III. Evaluation of Texas’ Rule Revisions and RACT Anal ysis 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 Guidel ine 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 SubmittalPage 3 of 26 I. Summary

This Technical Support Document (TSD) c oncerns 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 operati ons. These control requirements and rule revisions apply to offset lit hographic printing lines locate d in the following areas: Houston-Galveston-Brazoria (HGB), Dallas-Fo rt Worth (DFW), and El Paso, and address RACT for offset lithographic printing ope rations in HGB and DFW. The EPA has previously approved Texas’ rule revisions and Reasonably Availabl e Control Technology (RACT) analyses for Volatile Organic Co mpounds (VOCs) and Oxides of Nitrogen (NOx) into Texas’ State Implemen tation Plan (SIP) under the 1-Hour and 1997 8-Hour
ozone standard 1 . This TSD addresses three Texas SIP Revisions, the first in full and the other two in part, as follow s: Texas VOC Control Techni que Guidelines Update; 2010
HGB Attainment Demonstra tion 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).Page 4 of 26 II. Background

A. RACT and CTGs

Clean Air Act (CAA) section 172(c)(1) pr ovides that state implementation plans (SIPs) for nonattainment areas must incl ude reasonably available control measures including “reasonably available control techno logy” (RACT) for sources of emissions.
The EPA has defined RACT as the lowest emi ssions limitation that a particular source is capable of meeting by the application of contro l 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 th at SIPs for nonattainment areas “provide for the implementation of all reasonably ava ilable control measures as expeditiously as practicable (including such reductions in emi ssions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasonabl y available control technology) and shall provide for attainme nt 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 oz one nonattainment areas. For a Moderate, Serious, or Severe Area a major stationary so urce 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 c onstitute RACT for a given source category through the issuance of Contro l Techniques Guidelines (CTG ) and Alterna tive 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 require d 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 additionalPage 5 of 26 information to help clarify those comment s, 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 categor y 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 Ma terials is included in the second CTG listed in Group II). For the 1-hour ozone standard, Texa s had previously met RACT for VOC sources. For the HGB area, as part of a 1-H our 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 th e 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 Seve re 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 whic h 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 st andard, 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 therefor e 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 th e 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 met hod of printing. The term “planographic” denotes that the printing and non-printing areas are in the same pl ane on the surface of a thin metal lithographic plate. To mainta in the distinction be tween the areas on the lithographic plate, the image area is rendere d oil receptive, and the non-image area is rendered water receptive. Offset lithography is an indi rect printing method; that is, ink is not transferred directly to a substrate. Rather, ink is tr ansferred from the lithographic plate to a rubbercovered, intermediate “blanket” cylinder and th en transferred from th e blanket cylinder to the substrate. The offset lithographic pro cess is used for a broad range of printing applications, including books, magazines, pe riodicals, labels and wrappers, catalogs and directories, financial and legal document s, 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 lithogra phy 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 prin ting, continuous rolls of substrate material are fed to the press and rewound or cut to size after printing. VOC emissions from offset lithographic printing resu lt 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 Texa s’ 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 nona ttainment areas because of the CTG requirements and RACT for these areas. The HGB Area consists of Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Mont gomery and Waller c ounties; 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 a nd 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 f ountain and cleaning solu tions used by smaller offset lithographic printing operations that were exempt under previous rules.Page 8 of 26 Previous Chapter 115 rules provided limits fo r the VOC content of fountain and cleaning solutions used by offset lithographic printi ng 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 combin ed 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 l east 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 a nd 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 expa nd requirements in the DFW and HGB areas
to limit the content of fountai n and cleaning solutions used by offset lithographic printing lines. The rule revisions affecting thes e sources were implemented by the State beginning March 1, 2012.

In general, these rule revisions require th e owner or operator of an affected offset lithographic printing line to reduce the VOC content of th e fountain solution and the cleaning solution used in the printing pro cess. To reduce the VOC content of the fountain solution, these rule revisions provi de 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 cleani ng solution, these rule revisions also provide several options, in cluding using low-VOC cleaning solutions; using low-VOC cleaning solution in conjunction with work pr actice standards; or using low vapor pressure cleaning solutions in c onjunction with work practice standards.Page 9 of 26 The discussion in section III of this TSD, Evaluation of Texas’ Rule Revisions and RACT Analysis Addressed in this Action, prov ides additional detail regarding the rule revisions and RACT analysis for HGB and DFW, and covers th e 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 recl assification of the ar ea from moderate

to serious for the 1-hour ozone standar d, 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 a ddress 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 comm ents, and then took fi nal 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 reasonabl e 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 impl ementing 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 DF W area as nonattainment for the 8-hour
ozone standard, and established RACT re quirements for the DFW nonattainment area
which included the following nine counties: Collin, Denton, Dallas, Tarrant (these four

constituted the 1-hour ozone nona ttainment area and are referr ed to as the four core
counties), and Ellis, Johnson, Kaufman, Parker and Rockwall. Texas submitted a SIP
revision which extended VOC control requiremen ts to facilities located in Ellis, Johnson,
Kaufman, Parker, and Rockwall counties, requi ring subjected affected VOC sources in

these five counties to the same emissi ons limitation, control, monitoring, testing,
recordkeeping, and reporting re quirements 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 Texa s SIP revisions, the first in its entirety, and the second two in part:Page 11 of 26 Texas VOC Control Technique Guidelines Update 4 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 Standard 5 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 C ontingency SIP Revision 6 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 subm ittals will be referred to as “VOC CTG Update: Offset Lithographi c 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 Revisi ons 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 ru le 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 Prin ting” 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 emissi ons from letterpress printing. This SIP revision does not include rule changes for lett erpress 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 uncont rolled potential to emit at least 25 tpy from ink oils vol atilized in the dryer. In addition, the CTG recommends increasing the control efficiency requirem ent from 90% to 95% for control devices
installed after the rule effective date. Base d on this, for heatset presses, the State found and EPA agrees that the existing rules are at le ast as effective as or more effective than
the 2006 CTG recommendations.

For control devices installed before the effec tive 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 heatse t presses either meet or exceed the CTG
recommendation for control devices.

For control devices installe d after the effective date of the rule, the 2006 CTG recommendation to require a 95% control effici ency was determined by the State to be no more stringent than the existing rules which re quire 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 uncontro lled) 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, thatPage 13 of 26 the existing rule “is effectively more string ent than the CTG recommended threshold for
installation of control devi ces 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 recomme nds setting the control effi ciency requirement of the control equipment based on the first installation date of the equipment, regardless of the
location. The State intenti onally 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 pr actical enforceability issues for commission investigator s with regard to verifying th e first installation date of the control equipment”. Because the 2006 CT G recommendation has the potential to be less stringent that the State’s existing polic y, EPA finds that it is within the State’s discretion not to adopt this recommendation.

Fountain Solution The 2006 CTG recommends limiting the fount ain solution content to 5.0% alcohol substitutes or less by weight and no al cohol in the fountain solution.

For major sources, the previous Chapter 115 rules contained an option limiting the
fountain solution content to 3.0% alcohol subs titutes or less by weight and no alcohol in the fountain solution for printing operations lo cated 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 st ringent 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 im pact of these regulations. These options
for smaller sources include the 2006 CTG r ecommendation to limit the fountain solution
content to 5% alcohol substitutes or less by weight and no alcohol in the fountainPage 14 of 26 solution. Additionally, the compliance date for smaller sources was extended to March 1, 2012 to provide additional time for these facili ties to determine the most cost-effective compliance strategies and to im plement 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 th e VOC content of the cleaning solutions used in the printing proce ss and provide several options for complying, including the following: using low-VOC cl eaning solutions; using low-VOC cleaning solution in conjunction with work practice standards; or using low vapor pressure cleaning solutions in conjunction with work pr actice standards. These revisions retain the existing Chapter 115 rule requiring a cleaning solution content limit of 70% by volume in conjunction with work practice stan dards as an option. Also, these revisions retain the previously existing Chapter 115 op tion to limit the cleaning solution content to 50% VOC by volume. Because the existing ru les were determined to be at least as stringent as the 2006 CTG recommendations, TC EQ included these options to retain the flexibility afforded to owners and operators s ubject to the previous rules. Because this strategy is at least as stri ngent at the CTG recommendati ons, EPA finds this approach acceptable.

The 2006 CTG also recommends specific work practices for cleaning solutions used by offset lithographic printing lines with uncontro lled potential to emit at least 3.0 tpy of
VOC. These rule revisions include the CT G’s recommended work practice standards for cleaning solutions.

Monitoring, Recordkeeping, and Testing Requirements All affected sources are requi red to comply with monitori ng, recordkeeping, and testing requirements to demonstrate continuous complia nce 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 Draf ting Manual”, dated September 2008.

B. Rule Revisions by Section

Texas’ VOC CTG Update submittal dated Ap ril 5, 2010 identifies the new and amended sections of Chapter 115 pertaining to Of fset 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 combina tion 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 re visions 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 re quirements. This section also defines terms used in offset lithographic printing operations . Such definitions provi de for consistency in application and enforcement of the rules. For complia nce 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 c ontrol 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 perPage 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 ar e 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 Met hods 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 schedu le for the offset lithographic printing press sources subject to th ese 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 FRPage 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 recommenda tions 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 es tablished in sections 115.440-429 for Offset Lithographic Printing represent RACT for th is sector under the 8-Hour ozone NAAQS. (See 70 FR 71612, November 29, 2005, regarding permissible approaches for determining whether a State’s le vel of control meets RACT.)

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

In the spring of 2010, Texas submitted th e 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 a ll source categories covered by EPA CTGs, and to address major sources at the modera te 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 so urces 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 47 56). 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 pr inting rules 8 . 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 fede rally approved and adopt ed to meet the 1-
hour ozone standard. Texas evaluated whether these regulations cons titute 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 tw o 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 certa in regulations or sources. TSD Appendix B contains excerpts from Texas’s HGB submitta l 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 re lied on EPA’s May 18, 2006 RACT Q and A
document 9 . See the 2010 HGB AD, Appendix D, section 3.3.2.4; see also 2010 DFW RACT, Rule, and Continge ncy 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 covere d by Control Technique Guidelines (CTG)
and Alternative Control T echnique (ACT) documents.

 Identify applicable regula tions that implement RACT.

 Certify that the existing level of contro ls for the 1-hour ozone standard equals RACT under the 8-hour ozone standard, or

8 See Section II. C. Texas’ SIP Revisions Addr essed 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 app licable in certain cases, or

 Identify potential RACT revisions necessary to implement RACT.

By approving RACT under the 1-hour oz one 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 m eet the lowest emissions limitation that a particular source is capable of meeting by th e application of cont rol 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 RA CT 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 NAA QS). 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, findi ng that these control measures result in the lowest emissions limitation that a partic ular source is capable of meeting through application of control technology that is reasonably availabl e, 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 RA CT Q and A document, the framework identified above, and Texas’ ce rtification of its RA CT analysis (a permissible approach per 70 FR 71612, November 29, 2008 -Final Rule to Implement the 8-Hour OzonePage 20 of 26 NAAQS), we find that the 30 TAC Chapter 115 control requirements meet RACT for
VOC sources identified in Table 1 of th is 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 a nd 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 AdhesivesPage 22 of 26 Appendix B Excerpt from Texas’ 2010 HGB Attainment Demonstration SIP Submittal Appendix D: RACT 10

3.3.2.4 Offset Lithographic and Letterpress Printing Concurrent with this SIP revision, the TC EQ 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. Th e adopted Chapter 115 rulemaking reduces the VOC content of the founta in solutions and cleaning solutions used by offset lithographic printing operations, and expands the rule applicability to include smaller offset lithographic printing sources that were previ ously exempt from these rules. The TCEQ determined that no letterpress printing operati ons 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 c ontrol 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 implemen ting the 2006 CTG recommendations with the potential for backsliding, enforceability considera tions, 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 pr inting 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 th e 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 conten t 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 equipm ent 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 effici ency requirements with the first installation date of the control device regardless of where th e 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 po licy may also create significant practical D-7 enforceability issues for TCEQ investigator s with regard to verifying the firs t 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 maximu m 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 oper ations 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 ru les 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 Submittal 11

Dallas-Fort Worth Reasonably Avai lable 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 Chapte r 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 fountai n solutions and cleaning solutions used by offset lithographic printing operations and expands rule applicability to include smaller offset lithographic printing sources that were pr eviously 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 fo r 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 conti ngency plan adopted within this DFW RACT, Rule, and Contingency SIP Revision. To maintain integr ity of the attainment demonstration, this SIP revision allocates emission reductions from flee t 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 TC EQ 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 smalle r 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 TC EQ 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 fountai n solutions and cleaning solutions used by offset lithographic printing operations, and expands rule applicability to include smaller offset lithographic printing sources that were previ ously 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 consider ations, and possible impacts to sources that have already complied with the existing rules.
In several instances the adopted Chapter 115 cont ent 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. Th e 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 Chapte r 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 indivi dual 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 c ontrol devices, with a control efficiency of at least 90 percent, to be installed on heatset o ffset 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 heatsetPage 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 recomme ndations with regard to the applicability threshold for this control requirement. A dditionally, 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 equipm ent first installed before the effective date of rules implementing the CTG to have an overa ll 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 w ith the first installation date of the control device regardless of where the equipment was inst alled. 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 requ iring add-on controls and implementing the EPA's recommended approach would penalize opera tions 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 effe ctive 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.