SUPPLEMENTAL BASIS STATEMENT 

Chapter 161 Graphic Arts - Lithography and Letterpress Printing 

March 18, 2010 

COMMENTORS: 

(1) Anne Arnold 

EPA Region I 

1 Congress Street 

Suite 1100 

Boston, Mass 

(2 ) Mark Flannery 

Printing Industries of New England (PINE) 

5 Crystal Road 

Southborough, MA 01772-1758 

(3) Steve Whipple Environmental Consultant for 

Dingley Press 

119 Lisbon Street 

Lisbon, ME 04250 

1) Comment on Applicability Section 1 .B: EPA recommends that for sheet-fed and coldset 

printing operations Maine use the EPA/industry agreed upon applicability threshold of: 64 

gallons per month or equivalently, 768 gallons per year of fountain solution, fountain solution 

additives and cleaning solution purchased or used. Likewise, for heatset printing operations we 

recommend that Maine use the EPA/Industry agreed upon applicability weight threshold of 450 

pounds per month or equivalently, 5400 pounds per year of ink, cleaning solution, fountain 

solution and fountain solution additives purchased or used. (Commentor #1) 

Response: The suggested changes in the applicability threshold have been incorporated in 

Section 113 . 

2) Comment on Applicability Section 1B and Record-keeping 5A(7) : The proposed 

Chapter 161 rule does not clearly state the record-keeping requirements for facilities that 

are exempt from the control requirements of the rule due to not meeting the applicability 

threshold listed in section 1.11 . Exempted facilities should keep monthly records, for a specified 

period of time, documenting the quantities of cleaning solution, fountain solution, fountain 

solution additives, and ink used to demonstrate that they fall below the applicability thresholds in 

section 1 .B. (Commentor #1) 

Response: The suggested change for recordkeeping by exempt facilities has been incorporated 

as follows . 

New language: 

113 . This regulation applies to any Offset Lithography (Heatset, Sheet Fed or Coldset) and 

Letterpress printing operation 

(1) whose maximum actual emissions are greater than three tons of VOCs per rolling 12 

month period; 
(2) for non-heatset printing operations, whose total volume of cleaning solution alcohol 

fountain solution, alcohol substitutes, coatings and ink purchased or used in any 30 

_day rolling period is greater than 64 gallons per month, or equivalently, 768 gallons 

in any 12 month rolling period; or 

(3) for heatset printing operations whose total weight of heatset inks cleaning solution 

fountain solution and fountain solution additives purchased or used in any 30 day 

rolling period is greater than 450 pounds per month or equivalently, 5400 pounds per 

12 month rolling period. 

Any person claiming exemption pursuant to this subsection shall record and maintain 

monthly operational records sufficient to demonstrate compliance as specified in 

Subsection 5A(7) of this Chapter. 

SA(7) Exempted printing operations shall maintain monthly purchase records and 

Material Safety Data Sheets (MSDS) for each process chemical as used to comply 

with the Occupational Safety and Health Administration's Hazard Communication 

Standard, 29 CFR 1910 .1200. The records shall document the quantities and VOC 

content of cleaning solution, fountain solution alcohol, fountain solution alcohol 

substitutes, coatings, and ink used to demonstrate that the printing operation falls 

below the applicability thresholds in section 1B, or as specified in a BACT analysis 

included in an air emission license . The records shall be maintained onsite for six 

years. 

3) Comment on Applicability Section 1C : Dingley Press is the only Maine facility, 

currently issued an air emission license and is subject to more stringent BACT 

requirements. In their current license mandated testing schedule they are not required to 

test again until December 31, 2011. Practically, Dingley has met all the substantive conditions 

of the rule but has not incorporated some of the details such as documenting negative pressure in 

the dryer and would like to incorporate this is the next regularly scheduled test event which will 

take place in the fall of 2011 . We suggest an amendment to Section 1 C to accommodate that 

currently planned testing schedule. (Commentor #3) 

Response : This change was incorporated into the rule as shown below. The air emission license 

specifies the ongoing testing time frame for this facility and provides an adequate means to 

address this concern. 

1C. Any owner or operator of an offset lithographic or letterpress printing operation, who is 

subject to this Chapter, must demonstrate compliance by 12 months from the effective 

date of this Chapter. For a source that commences operation after the effective date of 

this Chapter, the owner or operator must determine compliance status by 12 months after 

the date on which the source commences operation. Any owner or operator of an offset 

lithog)raphic or letterpress printing operation who is subject to this Chapter and has a 

BACT analysis included in an air emission license must demonstrate compliance 

pursuant to their air emission license conditions . 

4) Comment on Applicability Section 1D: Section 1D should be reworded as follows in order 

to stay consistent with the definitions provided in Section 2 of this rule: 
1 D. Any facility that becomes or is currently subject to these provisions because its 

emissions, before controls, equal or exceeds 3 tons per rolling twelve month period or, 

greater than 768 gallons of cleaning solutions, alcohol fountain solution, alcohol 

substitutes and heatset ink purchased or use per 12 month rolling period, will remain 

subject to the provisions for three years after the emissions fall below and remain below 

the 3 tons per year applicability threshold. (Commentor #2) 

Response: Per AG recommendations, the language has been changed for clarification purposes 

as shown below. The three tons of VOC emissions is equivalent to the product thresholds that 

were identified in 1B. Those equivalent product thresholds approved by EPA were included in 

1B to simplify the recordkeeping process for small printing operations. 

1D. Any printing operation that is subject to this Chapter due solely to exceeding the 

applicability threshold of three tons of VOC emissions per year in subsection 1 B and 

whose VOC emissions subsequently fall below that applicability threshold for a rolling 

12 month period will remain subject to the requirements of this Chapter for three years 

following the conclusion of that 12 month rolling period. The printing operation will 

become subject to this Chapter anew upon exceeding any applicability threshold set forth 

in subsection 113 . 

5) Comments on Definitions Section 2 E and F, and Emission Control Limits Section 3B(4): 

There are some differences in the way the control device requirements in this new rule 

conflict with procedures currently in place as BACT license requirements for the Dingley 

Press facility. (Commentor #3) 

Response: The following definitions and modifications to allow for optional BACT/CAM 

protocol were added to the rule in Sections 2 and 3B(4) : 

2E. BACT. "BACT" means Best Available Control Technology as defined in Definitions 

Regulation 06-096 CMR 100 (last amended December 24-2005) . 

2F. CAM. "CAM" means Compliance Assurance Monitoring as described in 40 CFR 

Part 64. . 

3B (4)An owner or operator of a heatset lithographic or heatset letter press printing press 

and dryer(s) equipped with a control system shall maintain the dryer air pressure lower 

than the pressroom air pressure at all times the press is operating; and ensure that : 

(a) The capture system and control device are operated at all times that the printing press 

is in operation; and the manufacturer's minimum recommended operating 

temperature for the control device or licensed limit or as otherwise specified in a 

BACT or CAM analysis included in a license issued after 1997 shall be maintained 

whenever the presses are in operation, and 

(b) The control device is equipped with the applicable monitoring equipment specified in 

Section 4 Compliance Test methods, and the monitoring equipment is installed, 

calibrated, operated, and maintained according to the manufacturer's specifications or 

as otherwise specified in a BACT or CAM analysis included in a license issued after 

1997 at all times the control device is in use . 
6) Comment on Emission Control Limits Section 3A(4): This suggested language may help 

adjust limits to accommodate scalable need of small verses larger facilities : 

Section 3A(4). Cleaning Solution Limits: For non - press or press parts cleaning processes, a 

facility is allowed to use a maximum 110 gallons of higher VOC content cleaning solvents for 

each .press line at the facility within any consecutive twelve month period. (Commentor #3) 

Response: This change was not incorporated into the rule because it would alter the applicability 

threshold beyond the levels that are specified by the EPA CTG limits . 

7) Comment on Compliance Test Methods Section 4A(3)(e): Dingley requests some 

modifications to the control system testing requirements in this rule. (Commentor #3) 

a) Pursuant to the Dingley Press 1997 BACT/CAM analysis and EPA method 25 and 25A, stack 

testing protocol has previously allowed for modification of probe temperature to prevent 

condensation and the risk of fire damage. Dingley Press very often uses Method 18 testing to 

determine methane (exempt VOC) concentration and subtract this from the VOC measurement. 

b) The testers typically heat the lines to about 320 degrees F but the requirement to at least match 

the flue gas temperature may be challenging . Functionally APCC and DEP stack testers have 

worked this out. APCC uses very hot (350+) sample lines to minimize/eliminate condensation to 

ensure accurate results . This is all disclosed in the stack testing protocol reviewed and approved 

by DEP on a case by case basis. 

Response: To maintain as much flexibility as possible for other facility ; the AG has 

recommended the following changes in order to ensure the process meets license and EPA 

requirements, yet prevents fire damage concerns. 

4A(3)(e) 

(iii) US EPA Method 25 specifies a minimum probe temperature of two hundred sixtyfive degrees Fahrenheit. The probe shall be heated to at least the temperature required 

to prevent condensation as specified in the stack test protocol required by the 

governing air emission license, or otherwise approved in writing by the Department 

and EPA. 

(iv) US EPA Method 25A specifies a minimum temperature of two hundred twenty 

degrees Fahrenheit for the sampling components leading to the analyzer . The 

sampling components and flame ionization detector block shall be heated to at least 

the temperature required to prevent condensation as specified in the stack test 

protocol required by the air emission license, or otherwise approved in 

writing by the Department and EPA. 

8) Comments on Section 5A Recordkeeping : 

a) Dingley Press is concerned about the added expense of operating the thermal oxidizers 

and its catalytic oxidizer with the new 3-hr temperature averaging requirements specified in 

this draft rule. The facility's license requirements currently allow recording and downloading 

data every few seconds with no averaging requirements. To meet the new requirements would 

require Dingley to purchase and implement a new and expensive software program that would 
calculate the averaging times. In addition, their existing protocol shuts the system down as soon 

as temperature limits are exceeded; it is therefore more protective of air quality . (Commentor #3) 

b) The temperature parameters specified in the rule are atypical for the current operating 

system and are not appropriate for use as the required system shutdown threshold . This is 

tricky because Dingleys RTOs (thermal oxidizers) were each required by BACT after 1997 and 

some of the monitoring conditions have been amended over the years by Chapter 115 and 140 

licensing actions including CAM. We believe that for minor modifications it is possible that DEP 

issue BACT conditions without EPA review/approval . (Commentor #3) 

c) In addition, Dingley is currently making changes to its control configuration and may not 

use its catalytic oxidizer much, if at all, over the next few years. We request DEP add an 

alternative testing timeframe for this system based on usage. (Commentor #3) 

Response: Dingley Press is subject to BACT, a more stringent level of air emission control . The 

BACT analysis and air emission license protocol currently in place for this facility are more 

protective of air quality than RACT requirements specified in Chapter 161 and have, therefore, 

been incorporated into the rule to accommodate these concerns. A recordkeeping protocol based 

on oxidizer system usage is a reasonable and cost effective strategy and has been incorporated 

into the rule and additional clarification in the form of a note was added to reduce confusion for 

facilities that operate both types of systems. 

5Alb 

(ii) For thermal oxidizers, for each day of operation of the press: 

A log or record using a shorter averaging period approved in writing by the 

Commissioner and EPA, and as applicable, documenting any shutdowns trig eg red by 

an oxidizer shutdown threshold temperature as otherwise specified in a BACT 

analysis or CAM requirement included in an air emissions license after 1997: and 

5A1(c) 

(ii) For catalytic oxidizers, for each day of operation of the press : 

A log or record using a shorter averaging period approved in writing by the 

Commissioner and EPA, and as applicable, documenting any shutdowns triggered by 

an oxidizer shutdown threshold temperature as otherwise specified in a BACT 

Analysis or CAM requirement included in an air emissions license after 1997; and 

Note: For thermal oxidizers, an owner or operator must comply with either subsection 

(1)(b)(i) or (1)(b)(ii), but must also comply with subsection (1 (b)(iii) . 

For catalytic oxidizers, an owner or operator must comply with either subsection 

(l)(c)(i or (1)(c) ii , but must also comply with subsection (1 )(c)(iii) . 

5A(1)(d) For catalytic oxidizers, the catalyst bed material shall be inspected annually, 

for years in which the unit is operated for at least 1000 hours, for general catalyst 

condition and any signs of potential catalyst depletion. The owner or operator shall 

also collect a representative sample of the catalyst from the oxidizer, per 

manufacturer's recommendations, and have it tested to evaluate the catalyst's 

capability to continue to function at or above the required control efficiency. An 

evaluation of the catalyst bed material shall be conducted whenever the results of the 

inspection indicate signs of potential catalyst depletion or poor catalyst condition 
based on manufacturer's recommendations, but not less than once every five years, 

ret;ardless of usage. 

9) Comment on the Recordkeeping Section 5A(2)(a): The correct reference in Section 

5A(2)(a) should be 4B(4) of the rule instead of the previously numbered 3 B(4). (Commentor 

#2) 

Response: The suggested correction has been incorporated . 

10) Comment on Recordkeeping, paragraph 5A(4) - The terminology "non-heatset web 

offset" was removed from paragraph 5A(4) in order to capture the recordkeeping of any 

type of lithographic press that does not use a recipe log or that alters a batch of fountain 

solution . If the Department prefers to keep a separate paragraph for non-heatset web offset 

lithographic printing, item (b) should be removed because alcohol is not allowed in fountain 

solutions for non-heatset web offset lithographic printing . A separate paragraph for heatset web 

or sheet-fed offset lithographic printing presses should include items (a through (e) as written 

since alcohol is allowed in the fountain solutions for these types of presses . (Commentor #3) 

Response: The suggested terminology has been clarified to cover both alcohol and alcohol 

substitute processes yet avoid further redundancy in the rule as follows . 

5A 

(4) The owner or operator of a subject non h°a's°' web offset lithographic printing press 

not maintaining a recipe log in accordance with Section 5 A(3) above, shall maintain 

records for each batch of fountain solution prepared for use in the press, including: 

(a) The volume and VOC content of M concentrated alcohol substitute, added to 

make a batch of fountain solution, based upon the manufacturer's laboratory 

analysis using US EPA Method 24. 

(b) The volume of any alcohol added to make each batch of fountain solution .