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



# Control Techniques Guidelines for Offset **Lithographic Printing and Letterpress Printing ii**  This page intentionally left blank.**iii EPA 453/R-06-002**  **September 2006**



# Control Techniques Guidelines for **Offset Lithographic Printing and Letterpress Printing** 

**Sector Policies and Programs Division Office of Air Quality Planning and Standards** 

**U.S. Environmental Protection Agency**

**RTP, NC iv**  This page intentionally left blank.**v**

TABLE OF CONTENTS

**I. Introduction.......................................**  **...........................................Page 1**

**II. Background and Overview ....................... ...................................Page 2** 

**III. Applicability ................................. ...............................................Page**  **3**

**IV. Process Description and Sources of VOC Emission s..................Page 6**  **A. Offset Lithography**

**1. Inks**

**2. Fountain Solution 3. Cleaning Materials**  **B. Letterpress Printing**

**1. Inks 2. Cleaning Materials** 

**V. Available Control Options ....................... ....................................Page 9** 

**A. Inks**

**B. Fountain Solution C. Cleaning Materials**  **D. Existing State and Local Regulations**

**VI. Recommended Control Options................... ................................Page 13**  **A. Heatset Web Offset Lithographic and Heatset Lett erpress Inks and**  **Dryers**

**B. Fountain Solution C. Cleaning Materials** 

**VII. Cost Effectiveness of Recommended Control Options ..**  **.............Page 17**

**VIII. Factors to Consider in Determining VOC Emissions fr**  **om Offset Lithographic Printing and Letterpress Printing ....**  **.......................Page 18**

**A. Ink Oil Retention** 

**B. Retention of Low VOC Composite Vapor Pressure Clean**  **ing Materials in Shop Towels** 

**C. Carryover of VOC from Automatic Blanket Wash and Fo**  **untain Solution to Offset Lithographic Heatset Dryers** 

**D. Capture of Petroleum Ink Oil in Heatset Dryers** 

**E. Methods 25 and 25A** 

**IX. References.........................................**  **...........................................Page 21 vi**  TABLE OF CONTENTS (continued)

**Appendix A Access to 1993 draft CTG, 1994 ACT, and**  **2005 TSD ..............Page 22**

**Appendix B State and Local Regulations for Offset Lithographi**  **c Printing ....Page 24 Agency, Rule Number and Applicability** 

**Fountain Solution Limits**

**Appendix C State and Local Regulations for Letterpress Printin**  **g .................Page 36**

**Appendix D**

**Estimated Costs Associated with the Recommendations Contained in the**  **Control Techniques Guideline for Offset Lithographi c Printing and**  **Letterpress Printing............................... .......................................Page 38** I. Introduction

**Clean Air Act (CAA) section 172(c)(1) provides tha t state implementation plans**  **(SIPs) for nonattainment areas must include “reason ably available control measures”**  **(RACM), including “reasonably available control tec hnology” (RACT), for sources of**  **emissions. Section 182(b)(2) provides that for cer tain nonattainment areas, States must** 

**revise their SIPs to include RACT for sources of VO C emissions covered by a control**  **techniques guidelines (CTG) document issued after N ovember 15, 1990 and prior to the** 

**area’s date of attainment.**

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

**Act.**

**CAA section 183(e) directs EPA to list for regulat ion those categories of products**  **that account for at least 80 percent of the VOC emi ssions, on a reactivity-adjusted basis,**  **from consumer and commercial products in areas that violate the NAAQS for ozone (i.e.,**  **ozone nonattainment areas). EPA issued the list on March 23, 1995, and has revised the**  **list periodically.** See **60 FR 15264 (March 23, 1995);** see also **71 FR 28320 (May 16, 2006), 70 FR 69759 (Nov. 17, 2005); 64 FR 13422 (Ma**  **r. 18, 1999). Offset lithographic printing and letterpress printing are included on t**  **he current section 183(e) list.**

**This CTG addresses both the offset lithographic pr inting industry and the**  **letterpress printing industry. Although offset lit hographic printing and letterpress**  **printing are two distinct product categories on the section 183(e) list, they have many**  **similarities in the types of inks and cleaning mate rials used, the sources of VOC**  **emissions, and the controls available to address th ose emissions. We therefore address**  **both categories in this CTG.**

**The CTG is intended to provide state and local air pollution control authorities**  **information that should assist them in determining RACT for volatile organic compounds**  **(VOCs) for offset lithographic printing and letterp ress printing. In developing this CTG,**  **EPA, among other things, evaluated the sources of V OC emissions from these printing**  **industries and the available control approaches for addressing these emissions, including**  **the costs of such approaches. Based on available i nformation and data, EPA provides**  **recommendations for RACT for offset lithographic pr inting and letterpress printing.** 

**States can use the recommendations in this CTG to inform their own** 

**determination as to what constitutes RACT for VOCs for offset lithographic printing and**  **letterpress printing in their particular nonattainm ent areas. The information contained in**  **this document is provided only as guidance. This g uidance does not change, or substitute**  **for, applicable sections of the CAA or EPA’s regula tions; nor is it a regulation itself.**  **This document does not impose any legally binding r equirements on any entity. It** **2**

**provides only recommendations for state and local a ir pollution control agencies to**  **consider in determining RACT. State and local poll ution control agencies are free to**  **implement other technically-sound approaches that a re consistent with the CAA and**  **EPA’s implementing regulations.**

**The recommendations contained in this CTG are base d on data and information**  **currently available to EPA. These general recommen dations may not apply to a**  **particular situation based upon the circumstances o f a specific source. Regardless of**  **whether a State chooses to implement the recommenda tions contained herein through**  **State rules, or to issue State rules that adopt dif ferent approaches for RACT for VOCs for**  **offset lithographic printing and letterpress printi ng, States must submit their RACT rules**  **to EPA for review and approval as part of the SIP p rocess. EPA will evaluate the rules**  **and determine, through notice and comment rulemakin g in the SIP process, whether they**  **meet the RACT requirements of the Act and EPA’s reg ulations. To the extent a State**  **adopts any of the recommendations in this guidance into its State RACT rules, interested**  **parties can raise questions and objections about th e substance of this guidance and the**  **appropriateness of the application of this guidance to a particular situation during the**  **development of the State rules and EPA’s SIP approv al process.** 

**CAA section 182(b)(2) provides that a CTG issued a fter November 15, 1990 and** 

**before the date of attainment must include the date by which States must submit SIP**  **revisions in response to the CTG. States subject t o section 182(b) should submit their**  **SIP revisions within one year of the date of issuan ce of this final CTG. States subject to**  **CAA section 172(c)(1) may take action in response t o this guidance, as necessary to** 

**attain.**

II. Background and Overview

**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 information to help clarify those commen ts, 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. See** 

**References 1 and 2 in the reference section for the full citation to these documents.** 

**The 1993 draft CTG and 1994 ACT (see Appendix A) p rovide a thorough**  **discussion of the offset lithographic printing indu stry, the nature of VOC emissions from**  **that industry, available control technologies for a ddressing such emissions, the costs of**  **available control options, and other items. In lar ge part, the recommended approaches for**  **RACT in this document are similar to those proposed in 1993. EPA developed the**  **recommended approaches contained in this document a fter reviewing existing state and**  **local VOC emission reduction approaches, reviewing the 1993 draft CTG and 1994 ACT,**  **and considering information obtained since issuance of the ACT.** 

**As noted above, letterpress printing and offset li thographic printing have several**  **important similarities, including similar sources o f VOC emissions and similar available** **3**

**VOC control approaches. In light of these similari ties, EPA relied heavily on the** 

**substantial data and information included in the 19 93 draft CTG and 1994 ACT for offset**  **lithographic printing in formulating the recommenda tions for RACT in this document for**  **the letterpress printing industry.**

**The remainder of this document is divided into sev en sections. Section III**  **describes the scope of sources to which this CTG ap plies. Section IV provides a**  **summary of the processes associated with the offset lithographic printing and letterpress**  **printing industries and identifies the sources of V OC emissions from those processes.**  **Section V describes the available control approache s for addressing VOC emissions from**  **this source category and summarizes state and local regulatory approaches for addressing**  **such emissions. Section VI provides our recommenda tions for RACT for offset**  **lithographic printing and letterpress printing. Se ction VII discusses the cost-effectiveness**  **of the recommended control approaches. Section VII I presents factors to consider in**  **assessing VOC emissions from offset lithographic pr inting and letterpress printing.**  **References are provided in Section IX.**

III. Applicability

**This CTG provides control recommendations for reduc ing VOC emissions**  **stemming from the use of fountain solutions, cleani ng materials and inks in offset**  **lithographic printing and cleaning materials and in ks in letterpress printing. This section**  **addresses EPA’s recommendations as to the scope of entities to which the RACT**  **recommendations in this CTG should apply. As expla ined above, this document is**  **guidance and provides information for States to con sider in determining RACT. When**  **State and local pollution control agencies develop RACT rules, they may elect to adopt**  **control approaches that differ from those described in this document and/or promulgate**  **applicability criteria that differ from those recom mended here.** 

**In terms of applicability, we recommend that the co ntrol recommendations**  **discussed in this CTG for cleaning materials and fo untain solutions apply to any offset**  **lithographic printing operation where the emissions associated with all aspects of that**  **operation equal or exceed 6.8 kg/day (15 lb/day) ac tual emissions of VOC, or an**  **equivalent level, before consideration of controls. 1**  **As noted below, the cleaning control approaches recommended in this CTG include limitati**  **ons on the VOC composite vapor pressure of cleaning materials and limits on the VO**  **C content of cleaning materials, with an exclusion of 110 gallons per year of cleaning ma**  **terials which meet neither the low VOC composite vapor pressure recommendation nor the**  **lower VOC content recommendation, and work practices. We further re**  **commend that the recommendations concerning fountain solution, which are described i**  **n detail below, not be applied to sheet-fed presses with maximum sheet size 11x17 inc**  **hes or smaller, or to any press with**

**1 “Lithographic printing” means a printing process**  **where the image and non-image areas are chemically differentiated; the image area is oil receptive and**  **the non-image area is water receptive. This method differs**  **from other printing methods, where the image is a r aised or recessed surface. “Offset lithographic pri**  **nting” means a printing process that transfers the ink fil**  **m from the lithographic plate to an intermediary su rface**  **(blanket), which, in turn, transfers the ink film t o the substrate.** **4**

**total fountain solution reservoir of less than 1 ga llon because for these presses. EPA** 

**recommends these exclusions because the recommended VOC (alcohol or alcohol**  **substitute) content levels associated with such pre sses would yield a small emission**  **reduction relative to the cost of achieving that re duction (e.g., changing and maintaining**  **rollers).**

**Similarly, we recommend that the control approaches for cleaning materials**  **discussed in this CTG apply to any letterpress prin ting operation where the emissions**  **associated with all aspects of that operation equal or exceed 6.8 kg/day (15 lb/day) actual**  **emissions of VOC, or an equivalent level, before co nsideration of controls.**  **2 As noted**  **below, these control recommendations include limita tions on the VOC composite vapor**  **pressure of cleaning materials and limits on the VO C content of cleaning materials, with**  **an exclusion of 110 gallons per year of cleaning ma terials which meet neither the low**  **VOC composite vapor pressure recommendation nor the lower VOC content**  **recommendation, and work practices.**

**In developing their RACT rules, State and local age ncies should consider**  **carefully the facts and circumstances of the affect ed sources in their States. As noted**  **above, States can adopt the above recommended 15 lb /day actual emissions of VOC**  **applicability criterion before consideration of con trols, or an equivalent applicability**  **level expressed on a monthly basis (e.g., 450 lb/mo nth) or 12-month rolling basis (e.g., 3**  **tons per 12-month rolling period), or they can deve lop other applicability criteria that**  **they determine are appropriate considering the fact s and circumstances of the sources in**  **their particular nonattainment areas. EPA will rev iew the State RACT rules in the**  **context of the SIP revision process.**

**The above recommended 15 lb/day threshold is consis tent with the applicability**  **threshold contained in many previous CTGs. 3**  **It is also consistent with the purpose of the section 183(e) program. In section 183(e), Congres**  **s directed EPA to assist States in achieving VOC emission reductions from consumer and**  **commercial products. These products individually may result in relatively smal**  **l amounts of VOC emissions, but, in the aggregate, they contribute significantly to ozo**  **ne formation in nonattainment areas. Given the nature of the products and sources at iss**  **ue here, we believe that the 15 lb/day**

**actual VOC emissions before consideration of contro ls applicability threshold or**  **equivalent is appropriate for offset lithographic p rinting and letterpress printing materials.** 

**For purposes of determining whether the recommended 15 lb/day actual VOC**  **emissions applicability threshold or an equivalent threshold is met at a given facility, we**  **recommend that an offset lithographic printer consi der emissions from all offset** 

**2 “Letterpress printing” means a printing process**  **in which the image area is raised relative to the n on**  **image area and the paste ink is transferred to the substrate directly from the image surface.** 

**3 - See. e.g.,**  Model Volatile Organic Compound Rules for Reasonabl y Available Control Technology: Planning for Ozone Nonattainment Pursuant to Title I of the Clean Air Act **, dated June 1992 (establishing the 15 lb of VOC per day applicability threshold fo**  **r coating applications for eleven industries, inclu ding,**  **automobile and light duty truck coating operations and coating of cans, coil, paper, fabric, vinyl, me**  **tal furniture, large appliances, magnet wire, miscellan**  **eous metal parts, and flat wood paneling). 5** 

**lithographic printing operations, including related cleaning activities at the facility prior**  **to controls. Similarly, we recommend that a letter press printer should consider emissions**  **from all letterpress printing operations, including related cleaning operations at the**  **facility prior to controls, in evaluating whether t he 15 lb/day actual emissions**  **applicability threshold or an equivalent threshold has been met.** 

**We recommend a different applicability threshold fo r the RACT**  **recommendations in this CTG relating to heatset web offset lithographic printing and**  **letterpress printing operations. Specifically, we recommend applying the add-on control**  **recommendations for heatset web offset lithographic printing operations and heatset web**  **letterpress printing operations only to those press es with potential to emit from the dryer,**  **prior to controls, of at least 25 tpy of VOC (petro leum ink oil) from heatset inks. We**  **recommend providing printers with the option of usi ng an enforceable limitation on**  **potential emissions to keep an individual press bel ow this 25 tpy potential to emit**  **threshold. Guidance on limiting potential to emit from printing operations is provided in**  **the Technical Support Document (TSD) for Title V Pe rmitting of Printing Facilities (see**  **Appendix A). We believe add-on control for heatse t presses with potential to emit below**  **25 tpy is too costly for the emission reduction tha t would be achieved.** 

**We also recommend excluding heatset presses used f or book printing and**  **excluding heatset presses with maximum web width of 22 inches or less from the add-on** 

**control recommendations. We believe add-on control for such heatset presses is too**  **costly for the emission reduction that would be ach ieved.** 

**We estimate that there are approximately 6,700 off set lithographic printing** 

**facilities in current ozone nonattainment areas tha t meet the 15 lb/day actual VOC**  **emissions (before controls) applicability threshold described above. We derived this**  **number based on available information concerning th e offset lithographic printing**  **industry. Specifically, in the 1993 draft CTG, we estimated that, as of the early 1990s,**  **there were approximately 34,500 offset lithographic printing facilities in ozone** 

**nonattainment areas. We have information concernin g the percentage of the U.S.**  **population residing in nonattainment areas in the 1 990 and 2000 Census. We believe it is**  **reasonable to use these population figures to estim ate the number of offset lithographic**  **printing facilities in current nonattainment areas (i.e., areas based on the April 2004**  **designations). Specifically, given the percentage of U.S. population in ozone**  **nonattainment areas in 1993, and the percentage of U.S. population in ozone**  **nonattainment areas today, we estimate that 30,500 offset lithographic printing facilities** 

**are located in current ozone nonattainment areas. In the 1993 draft CTG, 78 percent of**  **the model facilities emitted less than 15 lb/day be fore controls. Applying this percentage**  **to the number of offset lithographic printing facil ities in current ozone nonattainment**  **areas, about 6,700 facilities emit 15 lb VOC per da y or more. Based on a similar**  **assessment, we estimate that less than 700 heatset web offset lithographic printing** 

**facilities in current ozone nonattainment areas hav e individual presses that are potentially**  **affected by the 25 tpy potential to emit threshold described above.** **6 We have limited information on the number of letter**  **press printing facilities in ozone nonattainment areas. In 1992, however, EPA’s**  **Office of Pollution Prevention and Toxics issued a report**  **3 which estimates that there are 21,000 facilities na**  **tionwide that are engaged in letterpress printing operations. Based**  **on the percentage of the U.S. population in ozone nonattainment areas in 1990 and**  **the percentage of U.S. population in ozone nonattainment areas in 2000), we estimate tha**  **t approximately 11,000 of these**

**facilities are located in current ozone nonattainme nt areas (based on April 2006**  **designations). In light of the similarities betwee n letterpress and offset lithographic**  **printing and the lack of specific data relevant to letterpress printers, we assume that**  **approximately 80 percent of the letterpress facilit ies in current ozone nonattainment areas**  **emit less than 15 lb of VOC per day and would there fore not be affected by this CTG.**  **Applying this percentage to the number of letterpre ss printing facilities in current ozone**  **nonattainment areas, about 2,200 facilities emit 15 lb/day actual VOC emissions (before**  **controls) or more. There are very few heatset lett erpress facilities anywhere in the U.S.** 

IV. Process Description and Sources of VOC Emission s

**A. Offset Lithography**

**Offset lithography is a planographic method of prin ting. The term**  **“planographic” denotes that the printing and non-pr inting areas are in the same**  **plane on the surface of a thin metal lithographic p late. To maintain the distinction**  **between the areas on the lithographic plate, the im age 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 i s transferred from the lithographic**  **plate to a rubber-covered, intermediate “blanket” c ylinder and then transferred**  **from the blanket cylinder to the substrate. The of fset lithographic process is used**  **for a broad range of printing applications, includi ng books, magazines,**  **periodicals, labels and wrappers, catalogs and dire ctories, financial and legal**  **documents, business forms, advertising brochures, n ewspapers, newspaper inserts,**  **charts and maps, calendars, tickets and coupons, gr eeting cards, and stamps.** 

**There are two types of offset lithography character ized 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 res ult from the evaporation of**  **components of the inks, fountain solutions, cleanin g materials and other**  **miscellaneous materials such as varnishes, coatings and glues. For a more**  **complete description of these industry processes, r efer to the 1993 draft CTG.** **7 1**  . Inks

**Offset lithographic printing inks are composed of p igments, vehicles,**  **binders, and other additives. Offset lithographic inks are paste inks.**  **Pigments provide the desired color and contain organic and i**  **norganic materials. The vehicle is a solvent that carries pigment and binde**  **rs, and is usually composed of petroleum oils and vegetable oils. Binders fix the**  **pigment to the substrate and are composed of organic resins and polymers or oils and**  **resins. Additives include waxes, lubricants, and driers.** 

**Heatset web inks require heat to set the ink. Coldset web (also called non**  **heatset web) and sheet-fed inks dry by absorption i nto the substrate or by** 

**oxidation.**

**Heatset web inks may contain up to 45 percent VOCs (ink oils). In heatset**  **web lithographic printing, 20 percent of the petrol eum ink oils and essentially all**  **of the vegetable ink oils are retained in the subst rate and dry ink film. The**  **remaining 80 percent of the petroleum ink oil is vo latilized in and then exhausted**  **from the dryer. Since the vegetable ink oil does n ot volatilize in the dryer, the**  **amount of vegetable ink oil that can be used in hea tset web offset lithographic**  **inks is very limited. If there is too much vegetab le oil in a heatset web offset**  **lithographic ink, the ink will not dry properly.**

**The petroleum ink oils in sheet-fed and coldset web inks have higher**  **boiling points than the ink oils in heatset inks. Coldset web inks usually contain**  **below 35 percent VOC. Most sheet-fed inks contain below 25 percent VOC. In**  **sheet-fed and coldset web offset lithographic print ing, 95 percent of the petroleum**  **ink oils and essentially all of the vegetable oils are retained in the substrate and**  **dry ink film. The remaining 5 percent of petroleum ink oils is volatilized and**  **emitted. Because of the high level of ink oil rete ntion, emissions from sheet-fed**  **and coldset web offset lithographic inks are inhere ntly very low.** 

**Some radiation (ultra-violet light or electron beam ) cured materials are**  **also used. Some printers use these materials in li eu of the heatset web printing**  **process and others use them in conjunction with hea tset web, coldset web or**  **sheet-fed printing processes. Radiation cured mate rials generate minimal VOC**  **emissions. Ultra-violet lamps or electron beam gen erators are used to dry and** 

**cure these materials.**

**Varnishes are unpigmented offset lithographic inks. They are applied on**  **offset lithographic presses in the same manner (i.e ., using a lithographic printing**  **plate, fountain solution and blanket cylinder) as o ffset lithographic ink. Heatset**  **varnishes are unpigmented heatset inks. The emissi ons generated by heatset**  **varnishes are similar in nature to the emissions ge nerated by heatset inks and they** 

**can be controlled in the same manner. Sheet-fed an d coldset web varnishes are**  **unpigmented sheet-fed and coldset web inks. Sheet- fed and coldset web** **8 varnishes exhibit the same high level of ink oil re**  **tention and generate the same inherently low emissions as sheet-fed and coldset w**  **eb inks. The coatings used on offset lithographic presses are predominantly water**  **based or radiation (ultra-violet or electron beam) cured materials which generate mi**  **nimal VOC emissions. We recommend that varnishes and coatings used on offse**  **t lithographic printing presses be considered part of the offset lithograph**  **ic printing process and that the**

**recommendations described below in section VI for h eatset web offset**  **lithographic inks and dryers apply equally to varni shes. We recommend that**  **varnishes and coatings used on offset lithographic printing presses not be**  **considered as a separate process (e.g., paper coati ng).** 

**2** . Fountain Solution

**Fountain solution is applied to the lithographic pl ate to render the non**  **image areas unreceptive to ink. Since offset litho graphic printing inks are oil**  **based, the fountain solution is water-based. The f ountain solution contains small**  **amounts of gum Arabic or synthetic resins, acids, a nd buffer salts to maintain the**  **pH of the solution, and a wetting agent or “dampeni ng aid” to enhance the**  **spreadability of the fountain solution across the p late. The dampening aid reduces** 

**the surface tension of water as well as increases v iscosity.** 

**Isopropyl alcohol traditionally has been used as a dampening aid. Other**  **alcohols such as ethanol and n-propyl alcohol may a lso be used. Before the**  **1980’s, the concentration of alcohol in the fountai n solution was sometimes as**  **high as 35 percent, with the concentration in most presses falling between 15 and**  **20 percent. Over the last 20 years, printers have greatly reduced the alcohol** 

**content of fountain solution. Also in the last 20 years, non-alcohol dampening**  **aids have been developed. These alcohol substitute s are typically glycol ethers or**  **ethylene glycol, and achieve the same purpose as al cohol.** 

**3.** Cleaning Materials

**Cleaning materials are used to remove excess printi ng inks, oils, and**  **residual paper from press equipment. These materia ls are typically mixtures of**  **organic (often petroleum-based) solvents. The cleaning material may be a solvent**  **such as kerosene (which contains numerous organics) , or a specific mixture of**  **individual solvents. Cleaning materials are used t o wash the blankets, rollers, and**  **outside of presses, and to remove residues of exces s ink between color changes.**  **Cleaning may be done manually, for example using sh op towels, or using an**  **automatic blanket wash systems. 9** 

**B. Letterpress Printing**

**1.** Inks

**Letterpress inks are similar to offset lithographic inks. They are paste inks**  **containing petroleum oils or vegetable oils. Both sheet-fed and web presses are**  **used for letterpress printing.**

**Sheet-fed letterpress presses use coldset inks. Mo st web letterpress**  **equipment use coldset inks. These letterpress inks are similar in composition and**  **behavior to sheet-fed and coldset web lithographic inks. In sheet-fed and coldset**  **web letterpress printing, 95 percent of the petrole um ink oils and essentially all of**  **the vegetable oils are retained in the substrate an d dry ink film. The remaining 5**  **percent of petroleum ink oils is volatilized and em itted. Because of the high level**  **of ink oil retention, emissions from sheet-fed and coldset web letterpress inks are**  **inherently very low.**

**There are also some heatset web letterpress printer s. Heatset letterpress**  **ink is similar to heatset lithographic ink with 20 percent of the petroleum ink oils**  **and essentially all of the vegetable ink oils retai ned in the substrate and dry ink**  **film. The remaining 80 percent ink oil is volatili zed in and then exhausted from**  **the dryer. Since the vegetable ink oil does not v olatilize in the dryer, the amount**  **of vegetable ink oil that can be used in heatset le tterpress inks is very limited. If**  **there is too much vegetable oil in a heatset letter press ink, the ink will not dry**  **properly.**

**2.** Cleaning Materials

**Cleaning materials are used to remove excess printi ng inks, oils, and**  **residual paper from press equipment. The cleaning materials used for letterpress**  **printing are similar to those used in offset lithog raphic printing. These materials**  **are typically mixtures of organic (often petroleum- based) solvents.** 

V. Available Control Options

**There are three main sources of VOC emissions from offset lithographic printing:**  **(1) evaporation of VOC (petroleum ink oils) from th e inks; (2) evaporation of VOC from**  **the fountain solution; and (3) evaporation of VOC f rom the cleaning materials. There**  **are two main sources of VOC emissions from letterpr ess printing: (1) evaporation of**  **VOC (petroleum ink oils) from the inks and (2) evap oration of VOC from the cleaning** 

**materials. 10**  **The three mechanisms to reduce VOC emissions from o ffset lithographic printing**  **and letterpress printing are as follows:**

• **Add-on controls,**

• **Process modifications or work practices, and**

• **Material reformulation or substitution.**

**A. Inks**

**Inks are a significant source of VOC emissions from heatset web offset**  **lithographic printing and heatset letterpress print ing. In these processes, heat is**  **applied in a dryer to set the inks. As a result of the heating process, about 80**  **percent of the petroleum ink oil (VOC) is volatiliz ed in the dryer. The remaining**  **20 percent of petroleum ink oil and all of the vege table ink oil is retained in the**  **substrate and dry ink film.**

**Most heatset web offset lithographic printing dryer s are equipped with**  **control devices such as a thermal oxidizer, catalyt ic oxidizer, or chiller condenser**  **(condenser filter). These same control devices can also be used on heatset**  **letterpress dryers. These control devices signific antly reduce VOC emissions**  **from heatset web printing. Oxidizers are more widely used than condenser filters,**  **with catalytic oxidizers being slightly more popula r than thermal oxidizers.**  **At the time the 1993 draft CTG was being developed, ne**  **w oxidizers generally were capable of achieving 95 percent**  **or greater destruction efficiency, but chiller condensers were only capable of achieving 90 percen**  **t.**

**Oxidizers and condenser filters may not be able to achieve the above**  **stated destruction or recovery efficiencies when th e VOC concentration of the**  **stream entering the control device is too low. Oxi dizers tend to have a rather**  **constant outlet concentration around 20 ppmv as com pound. As a result, an**  **oxidizer that achieves 90 percent destruction effic iency at inlet concentrations**  **above 200 ppmv as compound may not be able to achie ve this level of destruction**  **efficiency at inlet concentrations below 200 ppmv a s compound. Similarly, an**  **oxidizer that achieves 95 percent destruction effic iency at inlet concentrations**  **above 400 ppmv as compound may not be able to achie ve this level of destruction**  **efficiency at inlet concentrations below 400 ppmv a s compound. Print jobs (e.g.,**  **book printing) with light coverage will yield low i nlet concentrations. In addition,**  **there are several instances, such as sources utiliz ing combined dryers and control** 

**devices that do not have an identifiable measurable inlet where the only option** 

**available is to measure the outlet concentration to demonstrate compliance.** 

**Some printers use radiation (ultra-violet light or electron beam) cured**  **materials in lieu of the heatset web printing proce ss. These radiation cured**  **materials generate minimal VOC emissions. 11**  **Some reduction in VOC emissions from heatset web of fset lithographic**  **inks and heatset letterpress inks could be achieved by increasing the use of**  **vegetable oil and decreasing the use of petroleum o il. Since only very limited**  **amounts of vegetable oil can be used in heatset ink s, only a small emission** 

**reduction could be achieved and we do not believe t his reduction would be cost** 

**effective.**

**The VOC emissions from sheet-fed and coldset web li thographic inks and**  **sheet-fed and coldset web letterpress inks are inhe rently very low. First, these** 

**inks are lower VOC-content inks than heatset web in ks. Second, 95 percent of the**  **petroleum ink oil and essentially all of the vegeta ble ink oil in sheet-fed and**  **coldset web inks do not evaporate and are retained in the substrate and dry ink**  **film. Because only a small percentage of the sheet -fed and coldset web ink oils**  **evaporate, VOC emissions associated with these inks are small.** 

**Some reduction in VOC emissions from sheet-fed and coldset web inks**  **could be achieved by increasing the use of vegetabl e oil and decreasing the use of**  **petroleum oil. Since 95 percent of the petroleum o il is retained, only a small** 

**emission reduction could be achieved and we do not believe this reduction would** 

**be cost-effective.**

**The limited VOC emissions that occur from sheet-fed and coldset web**  **offset lithographic inks are diffuse and spread ove r a large area. These emissions** 

**are not amenable to add-on control. This is in cont rast to the emissions associated**  **with heatset offset web lithographic inks and heats et web letterpress inks, as the**  **petroleum oils in those inks volatilize in a dryer and are more amenable to add-on**  **control because they are emitted in a more concentr ated form from a discrete** 

**source.**

**B. Fountain Solution**

**Fountain solutions can be the source of a significa nt portion of the VOC**  **emitted by offset lithographic printing operations. Historically, alcohols such as**  **isopropyl alcohol, n-propyl alcohol and ethanol wer e used as the dampening aid.** 

**Before the 1980’s, the concentration of alcohol in the fountain solution**  **was sometimes as high as 35 percent, with the conce ntration in most presses**  **falling between 15 and 20 percent. Over the last 2 0 years, printers have greatly** 

**reduced the alcohol content of fountain solution.**

**Cooling a fountain solution that contains isopropyl alcohol is a process**  **modification that reduces VOC emissions by reducing the evaporation of the**  **alcohol. Refrigerated circulators are available th at can cool the fountain solution**  **to a pre-set temperature of 55 to 60 oF. Refrigera tion also gives operators better** 

**control of ink emulsification and hot weather scumm ing, and stabilizes the**  **ink/water balance by minimizing alcohol evaporation . Refrigeration of fountain** **12 solution trays has been shown to reduce alcohol con**  **sumption by as much as 44**

**percent.**

**In addition, many printers have reduced VOC emissio ns by switching to**  **alcohol substitutes, most commonly certain glycol e thers. These additives have**  **higher boiling points and lower volatilities than t raditional dampening aids. The**  **additives are incorporated in small quantities (fro m 2 to 4 ounces in 1 gallon of**  **water) to produce a final, mixed fountain solution that is usually**  **less than 3 weight percent VOC.** 

**C. Cleaning Materials**

**Cleaning materials can be the source of a significa nt portion of the VOC**  **emitted by offset lithographic printing and letterp ress printing operations. The**  **keys to reducing VOC emissions from offset lithogra phic printing and letterpress**  **printing cleaning materials are reducing the compos ite vapor pressure or VOC**  **content of the material used, and work practices.**

**Cleaning materials with VOC composite vapor pressur e less than 10**  **millimeters of mercury (mm Hg) at 20 oC have been u sed successfully by many**  **printers for blanket washing and other cleaning act ivities. Low VOC composite**  **vapor pressure materials generate less VOC emission s than higher vapor pressure**  **cleaning materials. As noted in the ACT document, cleaning materials with VOC**  **composite vapor pressure less than 10 millimeters o f mercury (mm Hg) at 20 oC**  **when used in conjunction with good work practices a chieve a comparable**  **emission reduction to cleaning materials containing 30 weight percent VOC. For**  **certain cleaning activities, such as metering rolle r cleaning or removing dried ink,**  **higher vapor pressure cleaning materials may be req uired.** 

**The VOC composite vapor pressure of a cleaning mate rial is a weighted**  **average of the vapor pressures of the VOC component s of that cleaning material.**  **The vapor pressure of each VOC component is weighte d by the mole fraction of**  **that VOC component in the whole cleaning material i ncluding non-VOC**  **components such as water or exempt compounds. Wate r and exempt compounds**  **thereby reduce the VOC composite vapor pressure of cleaning materials in which**  **they are present.**

**Water-miscible cleaning materials with less than 30 weight percent VOC**  **were developed and tested for offset lithographic p rinting in the early 1990’s.** 

**These materials were recommended as RACT in the 199 3 draft CTG. These**  **materials did not provide adequate performance and therefore they are not being**  **used by the offset lithographic printing industry t oday.** 

**There are some water-miscible or exempt solvent con taining cleaning**  **materials that contain 70 weight percent VOC or les s in use today. These lower**  **VOC content materials are capable of performing man y of the tasks, such as** **13 metering roller cleaning, which cannot be performed**  **with low VOC composite vapor pressure cleaning materials. A small number**  **of cleaning tasks cannot be carried out with low VOC composite vapor pressure c**  **leaning materials or reduced VOC content cleaning materials.** 

**Work practices such as keeping solvent containers c losed except when**  **filling, draining or conducting cleaning operations , and keeping used shop towels**  **in closed containers also reduce VOC emissions. Ty pically, 50 percent of a**  **cleaning material with composite vapor pressure les s than 10 mm Hg at 20 oC will**  **remain in used shop towels if the used towels are k ept in closed containers.** 

**D. Existing State and Local Regulations**

**In researching available control approaches for add ressing VOC emissions**  **associated with offset lithographic printing and le tterpress printing, EPA reviewed**  **existing state and local regulatory approaches. Se venteen states or local areas**  **have VOC emission regulations for offset lithograph ic printing operations. Five**  **states or local areas have regulations for letterpr ess printing operations. These**  **rules generally limit the alcohol or alcohol substi tute content of fountain solutions**  **(for offset lithographic printers only) and the com posite vapor pressure or VOC**  **content of cleaning materials, and require control of heatset dryer exhaust. The**  **tables in Appendices B and C list and describe the regulations that EPA reviewed.** 

VI. Recommended Control Options

**Recommendations for controlling VOC emissions from heatset inks, fountain**  **solution, and cleaning materials used in offset lit hographic printing operatons, and for**  **controlling VOC emissions from heatset inks and cle aning materials used in letterpress**  **printing operations are as follows:**

**A. Heatset web offset lithographic and heatset lett erpress inks and dryers** 

**The recommended level of control for VOC emissions from heatset dryers** 

**is tied to the first installation date of the contr ol device. The first installation date**  **for a control device does not change if it is later moved to a new location. For**  **example, a brand new control device first installed in 1992 is moved to a new** 

**location in 1998 – the first installation date for this control device is still 1992.** 

**The first installation date for a control device do es not change if it is later used to**  **control a new press. For example, a brand new heat set press is installed in 2009**  **and emissions from this press are controlled by a c ontrol device that was first** 

**installed in 2002 - the first installation date fo r this control device is still 2002.** 

**The recommended level of control for VOC emissions from heatset dryers**  **is 90 percent control efficiency for a control devi ce whose first installation date**  **was prior to the effective date of a State RACT rul e issued after the date of this** 

**CTG. The recommended level of control for VOC emis sions from heatset dryers** **14 is 95 percent control efficiency for a control devi**  **ce whose first installation date**

**was on or after the effective date of a State RACT rule issued after the date of this** 

**CTG.**

**We recommended a 90 percent control efficiency in t he 1993 draft CTG**  **and this efficiency is currently required by most s tate and local regulations for**  **heatset web offset lithography. At the time the 19 93 draft CTG was being**  **developed, new oxidizers generally were capable of achieving 95 percent**  **or greater destruction efficiency, but chiller condens**  **ers were only capable of achieving 90 percent. For a variety of reasons, i**  **ncluding the 90 percent control efficiency recommendation in the 1993 draft CTG and**  **the 90 percent control efficiency requirement in most existing state and l**  **ocal regulations, some oxidizers first installed between 1993 and the publication of**  **this CTG may not be achieving 95 percent control device efficiency. We do not re**  **commend retroactively requiring these oxidizers to achieve 95 percent con**  **trol device efficiency.**

**To accommodate situations where the inlet VOC conce ntration is so low**  **that a 90 or 95 percent efficiency may not be achie vable, we recommend**  **providing an outlet concentration alternative. Spe cifically we recommend**  **providing an option to reduce the control device ou tlet concentration to 20 ppmv**  **as hexane on a dry basis to accommodate situations where the inlet VOC**  **concentration is low, or there is no identifiable m easurable inlet.** 

**As explained above in section III, we recommend app lying the above** 

**recommended levels of control to individual heatset web offset lithographic**  **printing presses with potential to emit from the dr yer, prior to controls, of at least**  **25 tpy of VOC (petroleum ink oil). We also recomme nd applying the above** 

**recommended levels of control to individual heatset web letterpress printing**  **presses with potential to emit from the dryer, prio r to controls, of at least 25 tpy of**  **VOC (petroleum ink oil). We recommend providing pr inters with the option of**  **using an enforceable limitation on potential emissi ons to keep an individual**  **heatset press below this 25 tpy potential to emit t hreshold. This equates to using**  **inks and coatings which contain less than 31.25 tpy VOC (petroleum ink oil)**  **because of the 20 percent ink oil retention. We al so recommend excluding heatset**  **presses used for book printing and excluding heatse t presses with maximum web** 

**width of 22 inches or less from the add-on control recommendations.** 

**We believe that control of a press that is above th e 25 tpy threshold will**  **generally be cost effective. Control of a press th at is below the 25 tpy threshold,**  **presses used for book printing, and presses with ma ximum web width of 22**  **inches or less will generally not be cost effective**

**.**

**We are not recommending control of VOC emissions fr om sheet-fed or**  **coldset web inks, sheet-fed or coldset web varnishe s, waterborne coatings or**  **radiation (ultra-violet light or electron beam) cur ed materials used on offset** **15 lithographic presses or letterpress presses. The V**  **OC emissions from these materials are already low and they are not amenable**  **to add-on control.**

**B. Fountain Solution**

**We recommend the following approaches for controlli ng VOC emissions** 

**from fountain solution. These recommended levels o f control were recommended**  **in the 1993 draft CTG and are required by certain e xisting state and local**  **regulations.**

• **Heatset Web Offset Lithographic Printing**

**The recommended level of control for VOC emissions from on-press**  **(as-applied) fountain solution for heatset web offs et lithographic**  **printing is 1.6 percent alcohol (by weight) in the fountain or**  **equivalent. There are at least three different app roaches for achieving**  **this level of control. The first approach involves reducing the on-press**  **(as-applied) alcohol content to 1.6 percent alcohol or less (by weight).**  **The second approach involves using 3 percent alcoho l or less (by**  **weight) on-press (as-applied) in the fountain solut ion if the fountain**  **solution is refrigerated to below 60oF (15.5oC). The third approach**  **involves using 5 percent alcohol substitute or less (by weight) on-press**  **(as-applied) and no alcohol in the fountain solutio n.** 

• **Sheet-fed Offset Lithographic Printing**

**The recommended level of control for VOC emissions from on-press**  **(as-applied) fountain solution for sheet-fed printi ng is equivalent to 5**  **percent alcohol (by weight) in the fountain or equi valent. There are at**  **least three different approaches for achieving this recommended level**  **of control. The first approach involves reducing t he on-press (as**  **applied) alcohol content to 5.0 percent alcohol or less (by weight).**  **The second approach involves using 8.5 percent alco hol or less (by**  **weight) on-press (as-applied) in the fountain solut ion provided the**  **fountain solution is refrigerated to below 60oF (15 .5 oC).**  **The third approach involves using 5 percent alcohol substitut**  **e or less (by weight) on-press (as-applied) and no alcohol in the**  **fountain solution. This recommendation does not apply to sheet-fed pre**  **sses with sheet size of 11 inches by 17 inches or smaller, and does**  **not apply to any press with total fountain solution reservoir of les**  **s than 1 gallon.**

• **Coldset Web Offset Lithographic Printing**

**The recommended level of control for VOC emissions from fountain**  **solution for coldset web is 5 percent alcohol subst itute or less (by**  **weight) on-press (as-applied) and no alcohol in the fountain solution.** **16 As explained more fully in Section III above, we re**  **commend applying the control recommendations for offset lithographic pri**  **nting fountain solution to any offset lithographic printing operation where the em**  **issions associated with all aspects of that operation equal or exceed 6.8 kg/da**  **y (15 lb/day) actual emissions of VOC, or an equivalent level, before consideratio**  **n of controls. State and local agencies may adopt different applicability criteria**  **in their regulations. States should craft their applicability criteria in their**  **State RACT rules based on**

**consideration of the facts and circumstances of the facilities in their particular** 

**nonattainment areas.**

**We recommend that these control recommendations for fountain solution**  **not be applied to sheet-fed presses with maximum sh eet size 11x17 inches or**  **smaller, or to any press with total fountain soluti on reservoir of less than 1 gallon.**  **For these presses, the recommended VOC (alcohol or alcohol substitute) content**  **levels would yield a small emission reduction relat ive to the cost of achieving that**  **reduction (e.g., changing and maintaining rollers).**

**C. Cleaning Materials**

**The following recommendations apply to blanket wash ing, roller washing,**  **plate cleaners, metering roller cleaners, impressio n cylinder cleaners, rubber**  **rejuvenators, and other cleaners used for cleaning a press, press parts, or to**  **remove dried ink from areas around a press. EPA re commends that when States**  **develop RACT rules in response to the Industrial Cl eaning Solvents CTG, see**  **EPA 453/R-06-001 (Sept. 2006), they consider exclud ing from those rules the**  **activities noted in the prior sentence, which are c overed by this CTG. See 71 FR**  **44540. In addition, the recommendations for cleani ng materials provided below**  **do not apply to cleaners used on electronic compone nts of a press, pre-press**  **cleaning operations (e.g., platemaking), post-press cleaning operations (e.g.,**  **binding), cleaning supplies (e.g., detergents) used to clean the floor (other than**  **dried ink) in the area around a press, or cleaning performed in parts washers or** 

**cold cleaners.**

**We recommend using cleaning materials with a VOC co mposite vapor**  **pressure less than 10 mm Hg at 20 oC or cleaning ma terials containing less than**  **70 weight percent VOC. We believe this combination of material** 

**recommendations will reduce VOC emissions and allow for use of a mix of**  **materials capable of achieving all of the covered c leaning tasks. Cleaning**  **materials with low VOC composite vapor pressure hav e been used successfully**  **by many printers for blanket washing and other clea ning activities. Many of the**  **cleaning tasks that cannot be carried out with low VOC composite vapor pressure**  **cleaning materials can be carried out with reduced VOC content cleaning**  **materials. We also recommend excluding 110 gallons per year of cleaning**  **materials which meet neither the low VOC composite vapor pressure**  **recommendation nor the lower VOC content recommenda tion because a small** **17 number of cleaning tasks cannot be carried out with**  **low VOC composite vapor pressure cleaning materials or reduced VOC content**  **cleaning materials.**

**We also recommend that the following work practices be employed:**  **keeping cleaning materials and used shop towels in closed containers. In the**  **ACT document, EPA noted that using cleaning materia ls with a VOC composite**  **partial vapor pressure less than 10 mm Hg at 20 oC in conjunction with good**  **work practices would result in an emission reductio n that is comparable to using**  **cleaning materials that contain less than 30 weight percent VOC.** 

**As explained more fully in Section III above, we re commend applying the**  **above control recommendations for offset lithograph ic printing cleaning**  **materials to any offset lithographic printing opera tion where the emissions**  **associated with all aspects of that operation equal or exceed 6.8 kg/day (15**  **lb/day) actual emissions of VOC, or an equivalent l evel, before consideration of**  **controls. Similarly, we recommend applying the abo ve control recommendations**  **for letterpress printing cleaning materials to any letterpress printing operation**  **where the emissions associated with all aspects of that operation equal or exceed**  **6.8 kg/day (15 lb/day) actual emissions of VOC, or an equivalent level, before**  **consideration of controls. State and local agenci es may adopt different**  **applicability criteria in their regulations. States should craft their applicability** 

**criteria in their State RACT rules based on conside ration of the facts and**  **circumstances of the facilities in their particular nonattainment areas.** 

VII. Cost Effectiveness of Recommended Control Opt ions

**In the 1993 draft CTG, EPA estimated baseline emiss ions from the offset**  **lithographic printing industry in ozone nonattainme nt areas, based on 1990 data, to be**  **820,000 tons per year (with 62,000 tpy coming from ink, 631,000 tpy from fountain**  **solution and 126,000 tpy from cleaning). In the 19 93 draft CTG, EPA also conducted a**  **model plant analysis, in which it evaluated VOC emi ssions associated with different**  **kinds of printing processes, the VOC emission reduc tion capabilities of various control**  **options, and the costs of such controls. The model plants were developed to represent a**  **range of sizes and emissions. See Appendix A (desc ribing model plant analysis and**  **EPA’s VOC emission reduction and cost estimates).**

**Commenters on the 1993 draft CTG asserted that the alcohol content (17 percent)**  **used to generate this estimate was too high and tha t the assumed ratio of fountain solution**  **usage to ink usage was also too high. Baseline VOC emissions from fountain solution**  **may have been overestimated in 1993 by a factor of 2 to 3, which would mean that**  **industrywide baseline emissions in 1990 ranged from approximately 400,000 to 500,000**  **tpy. As for letterpress printers, we have limited emissions information for this industry.**  **Based on available information, we estimate that VO C emissions from the letterpress**  **printing industry as of 1990 were about 28,000 tons per year.** **18 We believe that the model plant analysis in the 199**  **3 draft CTG is representative of current operations in the offset lithographic pr**  **inting industry and current control options. The significant control approaches addres**  **sed in the 1993 draft CTG are the same approaches that are available today, and those**  **approaches continue to represent the most effective means of controlling VOC emissions f**  **rom offset lithographic printers. We also believe that the model plant analysis accur**  **ately presents the costs associated with the control approaches identified in the 1993**  **document. We recognize, however, that the costs in that draft document are presented**  **in first quarter 1990 dollars and must be adjusted to represent current costs. Accordingl**  **y, for purposes of estimating the cost effectiveness of the recommended control approaches**  **in this document, we escalated the 1990 costs in the 1993 draft CTG, to 2005 costs usi**  **ng a cost index. 4**  **The escalated costs are presented in Table 1 below. (See Appendix D fo**  **r additional cost information.)**

Table 1. Cost Effectiveness Values for Recommended Control Approaches

for Offset Lithographic Printing

Control Technique $ Per Ton VOC Removed a

Control of VOC from heatset inks 2,010

Control of VOC from fountain solutions estimated savings b

Control of VOC from cleaning materials 855

a Costs from 1990 are escalated to 2005 costs by use of a Marshall and Swift Equipment Cost Index (Chemical Engineering Magazine).

b **Reduction in alcohol use or conversion to alcohol s ubstitutes results in a cost savings.** 

**Because of the similarities between offset lithogra phic printing and letterpress printing in**  **terms of the nature of the processes at issue, the sources of VOC emissions and available**  **control approaches, it is reasonable to assume that the cost-effectiveness estimates in** 

**Table 1 for control of VOC from heatset inks and co ntrol of VOC from cleaning**  **materials apply equally to the letterpress printing industry.** 

VIII. Factors to Consider in Determining VOC Emiss ions from Offset Lithographic Printing and Letterpress Printing

**This section provides a summary of some of the rec ommendations EPA has**  **previously made to States concerning factors that m ay be considered in determining**  **VOC emissions from offset lithographic printing and letterpress printing operations.**  **These factors are important for a number of reasons including determining whether a**  **facility or a press exceeds the applicability thres holds recommended in this CTG or other**  **applicability thresholds that a state may consider including in its regulations. The factors** 

**described below and other relevant factors are disc ussed in the 1993 draft CTG, the 1994**  **ACT and the 2005 Printing TSD.**

**A. Ink Oil Retention**

**Heatset Inks – We recommend using a 20 percent VOC retention factor**  **for petroleum ink oils and a 100 percent retention factor for vegetable ink oils in**  **heatset inks. The VOC emissions, before considerat ion of any control, from a** **19 heatset ink would therefore be 80 percent of the pe**  **troleum ink oil content. The petroleum ink oil content of a heastet ink can be d**  **etermined from formulation data (e.g., technical data sheet or material safety**  **data sheet). We believe that a**

**Method 24 test of a heatset ink will volatilize the petroleum ink oils and will not**  **volatilize the vegetable ink oils.**

**Sheet-fed and coldset web inks - We recommend usin g a 95 percent VOC**  **retention factor for petroleum ink oils and a 100 p ercent retention factor for**  **vegetable ink oils in sheet-fed and coldset web ink s. The VOC emissions from a**  **sheet-fed or coldset web ink would therefore be 5 p ercent of the petroleum ink oil**  **content. The petroleum ink oil content of a sheet- fed or coldset web ink can be**  **determined from formulation data (e.g., technical d ata sheet or material safety**  **data sheet). We believe that an EPA Method 24 test of a sheet-fed or coldset web**  **ink will volatilize the petroleum ink oils and will not volatilize the vegetable ink**  **oils. The ASTM method D6419 (Standard Test Method for Volatile Content of**  **Sheet-Fed and Coldset Web Offset Printing Inks) is a more precise method for**  **determining the volatile (petroleum ink oil) conten t of sheet-fed and coldset web** 

**inks than ASTM D2369 which is referenced in EPA Met hod 24.** 

**B. Retention of Low VOC Composite Vapor Pressure Cl eaning Materials in**  **Shop Towels**

**We recommend using a 50 percent VOC retention fact or for low VOC**  **composite vapor pressure cleaning materials in shop towels where (1) VOC**  **composite vapor pressure of the cleaning material i s less than 10 mm Hg at 20 oC,**  **and (2) cleaning materials and used shop towels are kept in closed containers.** 

**C. Carryover of VOC from Automatic Blanket Wash and Fountain Solution**  **to Offset Lithographic Heatset Dryers**

**We recommend using a 40 percent VOC carryover (cap ture) factor for**  **automatic blanket washing when the VOC composite va por pressure of the**  **cleaning material is less than 10mm Hg at 20°C.**

**We recommend using a 70 percent VOC carryover (cap ture) factor for** 

**alcohol substitutes in fountain solution.**

**D. Capture of Petroleum Ink Oil in Heatset Dryers**

**For heatset web offset lithographic presses and hea tset web letterpress**  **presses, we believe capture efficiency for VOC (pet roleum ink oils) from oil**  **based paste inks and oil-based paste varnishes (coa tings) can be demonstrated by**  **showing that the dryer is operating at negative pre ssure relative to the surrounding** **20 pressroom. We recommend that as long as the dryer**  **is operated at negative pressure, the capture efficiency for VOC from the h**  **eatset lithographic inks and varnishes (coatings) formulated with low volatility**  **ink oils can be assumed to be 100 percent of the VOC (ink oils) volatilized in th**  **e dryer. We do not recommend conducting a capture efficiency test in this situat**  **ion.**

**Conventional heatset lithographic inks and varnishe s are paste-type** 
**materials. The VOC in these materials are oils wit h high boiling points, which**  **volatilize only within the dryer. Some ink oils, n ominally 20 percent, are not** 

**volatilized and remain in the substrate. If other t ypes (e.g., fluid type) of coating**  **materials are used on a heatset lithographic press or a heatset letterpress press, we**  **recommend that capture efficiency testing be conduc ted for the VOC from these**  **other materials if the printer wants to take into a ccount the effect that the dryer**  **controls have on VOC emissions from these other typ es of coatings. The most**  **common other types of coatings materials used on he atset presses are waterbased**  **or radiation (ultra-violet light or electron beam) cured materials which generate** 

**minimal VOC emissions.**

**E. Methods 25 and 25A**

**We recommend using EPA Method 25A in lieu of EPA Me thod 25 for**  **determining the destruction efficiency of an oxidiz er (inlet and outlet**  **concentrations) when:**

**• An exhaust concentration of 50 or less parts per million volume**  **(ppmv) as carbon (C1) is required to comply with th e applicable**  **standard; • The inlet concentration and the required level o**  **f control results in an exhaust concentration of 50 or less ppmv as C1;**  **or • The high efficiency of the control device alone**  **results in an exhaust concentration of 50 or less ppmv as C1.** 

**In situations where M25 is not viable, such as thos e described in section 1.1 of**  **M25, we recommend the use of M25A on both the inlet and outlet.** **21**

IX. References

**1. Guideline Series: Control of Volatile Organic C ompound Emissions from Offset**  **Lithographic Printing. Draft. U.S. Environmental Protection Agency. Research**  **Triangle Park, NC. September 1993.**

**2. Alternative Control Techniques Document: Offset Lithographic Printing. EPA**  **453/R-94-054. U.S. Environmental Protection Agency . Research Triangle Park,** 

**NC. June 1994.**

**3. Use Cluster Analysis of the Printing Industry. O ffice of Pollution Prevention and** 

**Toxics. Office of Pollution Prevention and Toxics. May 1992.** 

**4. Marshall and Swift Equipment Cost Index. Chemic al Engineering Magazine.**  **McGraw-Hill. ( www.che.com**  **)**

**5. Model Volatile Organic Compound Rules for Reasonabl**  **y Available Control Technology: Planning for Ozone Nonattainment Pursua**  **nt to Title I of the Clean Air Act. U.S. Environmental Protection Agency. Rese**  **arch Triangle Park, NC.**

**June 1992.**

**6. Technical Support Document (TSD) for Title V Permit**  **ting of Printing Facilities, Office of Air Quality Planning and Standards, U.S.**  **Environmental Protection Agency, Research Triangle Park, NC 27711, January 2**  **005. 22**  

## Appendix A

**Access to 1993 draft CTG, 1994 ACT, and 2005 TSD**

**Guideline Series: Control of Volatile Organic Comp ound Emissions from Offset**  **Lithographic Printing. Draft. U.S. Environmental Protection Agency. Research**  **Triangle Park, NC. September 1993.**

**Available as a separate item in docket EPA-HQ-OAR-2 006-0536 and on the internet** 

**at http://www.epa.gov/ttn/atw/print/draftlithoctg.pdf** 

**.**

**Alternative Control Techniques Document: Offset Lit hographic Printing.**  **EPA 453/R-94-054. U.S. Environmental Protection Ag ency. Research Triangle**  **Park, NC. June 1994.**

**Available as a separate item in docket EPA-HQ-OAR-2 006-0536 and on the internet** 

**at http://www.epa.gov/ttn/atw/print/lact.pdf** 

**.**

**Technical Support Document (TSD) for Title V Permit ting of Printing Facilities,**  **Office of Air Quality Planning and Standards, U.S. Environmental Protection**  **Agency, Research Triangle Park, NC 27711, January 2 005.** 

**Available as a separate item in docket EPA-HQ-OAR-2 006-0536 and on the internet** 

**at http://www.epa.gov/ttn/oarpg/t5/memoranda/tsd.pdf** 

**. 23**  This page intentionally left blank.**24** 

## Appendix B

**State and Local Regulations for Offset Lithographic Printing** 

**Agency, Rule Number and Applicability**

**State or Local Agency**  **Offset**

**Lithography Applicability** 

**Bay Area Air Quality**  **Management**

**District Regulation 8** 

**Rule 20 http://www.baaqmd.gov/dst/regulations/rg0820.pdf** 

**8-20-110 175 lb VOC per month** 

**San Joaquin Valley** 

**Unified Air**

**Pollution**

**Control**

**District Rule 4607 –** 

**Graphic Arts No cutoff** 

**http://www.valleyair.org/rules/currntrules/r4607.pd f**  **2.0 Applicability This rule is applicable to any graphic arts printin**  **g operation, to any paper or fabric coating operation, to the organic s**  **olvent cleaning, and to the storage and disposal of solvents and waste solv**  **ent materials associated with such operations as defined in Secti**  **on 3.0 of this rule. San Diego**  **County Air**

**Pollution**

**Control**

**District Rule 67.16 –** 

**Graphic Arts Operations**  **http://www.sdapcd.org/rules/rules/Reg4pdf/R67-16.pd f** 

**(1) The provisions of Sections (d) and (e) of this rule shall not apply to**  **stationary sources which emit less than an average of 15 lbs (6.8 kg) of**  **volatile organic compounds (VOCs) from all graphic arts operations per**  **day of operation for each calendar month.**

**South Coast Air Quality**  **Management**

**District Rule 1130 –** 

**Graphic Arts,**

**Rule 1171 –**

**Solvent Cleaning**  **Operations http://www.aqmd.gov/rules/reg/reg11/r1130.pdf** 

**no cutoff**

**Delaware CAP 24.47 –**

**Offset Lithographic**  **Printing http://www.dnrec.state.de.us/air/aqm_page/docs/pdf/**  **reg_24.pdf**

**15 lb/day 2. This Section does not apply to any offset lithog**  **raphic printing facility whose total actual volatile organic compound (VOC)**  **emissions from all lithographic printing operations (including emissio**  **ns from cleaning solutions used on lithographic printing presses) ar**  **e less than 6.8 kilograms (kg) (15 pounds [lb]) VOCs per day before**  **the application of capture systems and control devices.** 

**or maintains a maximum dryer exhaust outlet concent ration of 20 parts**  **per million by volume (ppmv) as methane (as C1), wh ichever is less**  **stringent when the press is in operation. 25** 

**Georgia 391-3-1-02**

**Provisions. Amended,**  **(2)(ddd) -**

**VOC**

**Emissions**

**from Offset Lithography**  **25 tpy**

**100 tpy 3. The requirements of this subsection shall apply**  **to facilities with VOC emissions exceeding 25 tons per year and located in**  **the counties of Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, F**  **ayette, Forsyth, Fulton, Gwinnett, Henry, Paulding and Rockdale and**  **to facilities with potential VOC emissions exceeding 100 tons per year**  **and located in the counties of Bartow, Carroll, Hall, Newton, Spalding**  **, and Walton.**

**Illinois 35.215.408 –**

**(Heatset Web),** 

**35.218.407 –**

**Lines on and**

**after March 15, 1996, and** 

**35.219.407 –**

**Lines on and**

**after March 15, 1996**  **Old rule?**

**http://www.ipcb.state.il.us/documents/dsweb/Get/Doc ument-11924/**  **Section 215.408 Heatset Web Offset Lithographic Pri nting**  **a) No owner or operator of a heatset web offset lit hographic printing**  **facility, located in Cook, DuPage, Kane, Lake, Maco upin, Madison,**  **McHenry, Monroe, St. Clair or Will County, emitting over 100 tons/year**  **of organic material, in the absence of pollution co ntrol equipment, may**  **cause or allow the operation of a heatset web offse t press unless:**  **1) An incinerator system is installed and operated that oxidizes at least**  **90 percent of the organic materials (measured as to tal combustible**  **carbon) in the dryer exhaust airstream to carbon di oxide and water; or**  **2) The fountain solution contains no more than eigh t (8) percent, by**  **weight, of volatile organic material and a condensa tion recovery system**  **is installed and operated that removes at least 75 percent of the non**  **isopropyl alcohol organic materials from the dryer exhaust airstream.**  **b) No owner or operator of a heatset web offset lit hographic printing**  **facility, located in a county other than Cook, DuPa ge, Kane, Lake,**  **Macoupin, Madison, McHenry, Monroe, St. Clair or Wi ll County,**  **emitting over 100 tons/year of organic material, in the absence of**  **pollution control equipment, may cause or allow the operation of a**  **heatset web offset press unless the fountain soluti on contains no more**  **than eight (8) percent, by weight, of volatile orga nic material.**  **(Source: Added at 11 Ill. Reg. 16706, effective Sep tember 30, 1987)** 

**Kansas 28-19-76 –**

**Lithography Printing**  **Operations http://www.kdheks.gov/bar/download/AIRREGS2005new.p**  **df**

28-19-76. Lithography printing operations. **(a) The provisions of this regulation shall apply to al**  **l offset lithography printing facilities with a potential contaminant em**  **ission rate of volatile organic compounds (VOC) equal to or more than 100 t**  **ons per year. The potential contaminant emission rate calculations ma**  **y include federally enforceable permit conditions.**  **(b) The provisions of this regulation do not apply to:**  **(1) printing on fabric, metal or plastic; (2) sheet fed lithographic presses with cylinder wi**  **dths of 26 inches or less; or**  **(3) web lithographic presses with cylinder widths o f 18 inches or less.**  **(c) Any owner or operator of an offset lithographic printing press subject**  **to this regulation Maryland 26.11.19.11 –** 

**Lithographic Printing**  **http://www.dsd.state.md.us/comar/26/26.11.19.11.htm**

**no cutoff for some items, 100 lb/day from web press es for heatset dryer**  **control, 18 inch width for sheet fed ftn soln limit s** **26**

**Massachusetts 310 CMR**

**7.26 – (24)**

**Non-Heatset Operations,**  **(27) Printers**

**with Heatset**

**Presses or**

**Non conforming**  **Operations Complex, but less than major** 

**http://www.mass.gov/dep/service/regulations/310cmr0 7.pdf** 

**Missouri 10 CSR 10-**

**2.340 and 10**

**CSR 10- 5.442, Control** 

**of Emissions**

**from Lithographic**  **Printing 2.340 Kansas City** 

**http://www.sos.mo.gov/adrules/csr/current/10csr/10c 10-2.pdf**  **(B) This regulation shall apply to installations th at have calculated actual**  **volatile organic compound (VOC) emissions for a kno wn number of**  **crewed hours, increased by the amount by weight of VOCs whose**  **emission into the atmosphere is prevented by the us e of air pollution**  **control devices and extrapolated to eight thousand seven hundred**  **sixty (8,760) hours per year equal to or greater th an one hundred (100)**  **tons per year from offset lithographic printing pre sses after**  **December 9, 1991. The following factors shall be ta ken into** 

**consideration unless an alternative**

**5.442 St. Louis http://www.sos.mo.gov/adrules/csr/current/10csr/10c**  **10-5.pdf (B) This rule shall apply only to installations des**  **cribed in subsection (2)(A) which have ever had the potential to emit VO**  **Cs equal to or greater than one hundred (100) tons per year. Once**  **the installation exceeds the applicability level of this rule, it sh**  **all remain subject to this rule even if its potential emissions drop below the**  **applicability**

**level. (C) This rule shall not apply to printing on fabric**  **, metal or plastic.**

**New Hampshire**  **Env-A**

**1204.37 – Applicability** 

**Criteria and Compliance** 

**Standards http://www.des.state.nh.us/Rules/pdf/env-a1200.pdf** 

**(a) A source whose offset lithographic printing ope rations have**  **combined TPEs during any consecutive 12-month perio d after December**  **31, 1989 which equal or exceed 50 tons of VOCs shal l be subject to the**  **provisions of this section.**

**(cy) "Theoretical potential VOC emissions" (TPEs) m eans the emissions**  **of VOCs that would have occurred prior to the appli cation of add-on**  **controls required by a federally enforceable rule o r document issued**  **prior to January 1, 1990, based on one of the follo wing:** 

**(1) Continuous operation of 8760 hours per year und er**  **maximum production capacity, which for coating and graphic arts sources includes coatings and inks wit**  **h the highest VOC content used in practice by the source**  **during 1993 and 1994 or the 2-year period most representat**  **ive of normal production rates; or**  **(2) Hours of operation, process conditions, or both that are**  **limited by federally enforceable permit conditions; 27** 

**New York 6 Part 234 –**

**Graphic Arts http://www.dec.state.ny.us/website/regs/part234.htm**  **l**

**NYC metro (b) Any packaging rotogravure, publication rotograv**  **ure, flexographic, offset lithographic printing process or screen prin**  **ting process at any facility located in the New York City metropolitan**  **area, regardless of its annual potential to emit volatile organic compounds**  **, must comply with this Part according to the following schedule.**  **(3) . . . Any offset lithographic printing process which was constructed**  **on or before September 1, 1988 regardless of annual potential to emit**  **must have demonstrated compliance with this Part by May 15, 1991.**  **(4) Any owner or operator of a packaging rotogravur e, publication**  **rotogravure, flexographic or offset lithographic pr inting process which**  **was constructed after September 1, 1988 must have d emonstrated**  **compliance with this Part upon start-up. Lower Orange County metro**  **(c) Any owner or operator of a packaging rotogravur e, publication**  **rotogravure, flexographic or offset lithographic pr inting process or**  **screen printing process at any facility located in the Lower Orange**  **County metropolitan area must comply with this Part according to the**  **following schedule: (3) Any owner or operator of a packaging rotogravu**  **re, publication rotogravure, flexographic, offset lithographic prin**  **ting process or screen printing process at any facility for which the annu**  **al potential to emit volatile organic compounds from all sources regardl**  **ess of process type, but excluding combustion installations, at the faci**  **lity equal or exceed 25**

**tons must:**
**Rest of state (d) Any owner or operator of a packaging rotogravu**  **re, publication rotogravure, f1exographic, offset 1ithographic prin**  **ting process, or screen printing process at any facility located out**  **side the New York City metropolitan area and Lower Orange county metropoli**  **tan area must comply with this Part according to the following sc**  **hedule: (3) Any owner or operator of a packaging rotogravur**  **e, publication rotogravure, flexographic, offset lithographic prin**  **ting process, or screen printing process at any facility for which the annu**  **al potential to emit volatile organic compounds from all sources regardl**  **ess of process type, but excluding combustion installations, at the faci**  **lity equal or exceed 50**

**tons must:**

**North**

**Carolina 15A NCAC** 

**02Q.0803 – Coating,** 

**Solvent Cleaning,**  **Graphic Arts Operations**  **This is a title V exclusionary rule, not a RACT rul e** 

**http://daq.state.nc.us/rules/rules/Q0800.pdf**

**Mecklenburg County VOC rules (nothing on litho)** http://tinyurl.com/peemj**28**

**Tennessee 1200-3-18.43**

**– Offset Lithographic**  **Printing Operations**  **http://www.state.tn.us/sos/rules/1200/1200-03/1200- 03-18.pdf** 

1200-3-18-.43 OFFSET LITHOGRAPHIC PRINTING

OPERATIONS. **(1) Applicability of this rule is as follows: (a) This rule applies to offset lithographic printi**  **ng operations in Davidson, Rutherford, Shelby, Sumner, Williamson, a**  **nd Wilson**

**Counties. (b) The emission limits of this rule do not apply t**  **o offset lithographic printing operations within any facility whose poten**  **tial VOC emissions from all offset lithographic printing operations wi**  **thin the facility are less than 100 tons of volatile organic compounds (VOC’s)**  **per year. Texas 30 Section** 

**115.442 –**

**Control Requirements**  **http://www.tceq.state.tx.us/assets/public/legal/rul es/rules/pdflib/115e.pdf** 

**starts at 115.440**

§115.449. Counties and Compliance Schedules. **(a) In El Paso County, all offset lithographic prin ting presses shall be in**  **compliance with §§115.442, 115.443, 115.445, and 11 5.446 of this title**  **(relating to Control Requirements; Alternate Contro l Requirements;**  **Testing Requirements; and Monitoring and Recordkeep ing**  **Requirements) as soon as practicable, but no later than November 15,** 

**1996. (b) In Collin, Dallas, Denton, and Tarrant Counties**  **, all offset lithographic printing presses on a property which,**  **when uncontrolled, emit a combined weight of volatile organic compound**  **(VOC) equal to or greater than 50 tons per calendar year,**  **shall be in compliance with §§115.442, 115.443, 115.445, and 115.446 of th**  **is title as soon as practicable, but no later than December 31, 2000.**  **(c) In Collin, Dallas, Denton, and Tarrant Counties , all offset**  **lithographic printing presses on a property which, when uncontrolled,**  **emit a combined weight of VOC less than 50 tons per calendar**  **year, shall be in compliance with §§115.442, 115.44 3, 115.445, and**  **115.446 of this title as soon as practicable, but n o later than one year,**  **after the commission publishes notification in the** Texas Register **of its determination that this contingency rule is necessary as a result of**  **failure to attain the national ambient air quality standard (NAAQS) for**  **ozone by the attainment deadline or failure to demo nstrate**  **reasonable further progress as set forth in the 199 0 Amendments to the**  **Federal Clean Air Act (FCAA), §172(c)(9). (d) In Brazoria, Chambers, Fort Bend, Galveston, Ha**  **rris, Liberty, Montgomery, and Waller Counties, all offset lithogr**  **aphic printing presses on a property which, when uncontrolled, emi**  **t a combined weight of VOC equal to or greater than 25 tons per**  **calendar year, shall be in compliance with §§115.442, 115.443, 115.445,**  **and 115.446 of this title as soon as practicable, but no later than Dec**  **ember 31, 2002. (e) In Brazoria, Chambers, Fort Bend, Galveston, Ha**  **rris, Liberty, Montgomery, and Waller Counties, all offset lithogr**  **aphic printing presses on a property which, when uncontrolled, emi**  **t a combined weight of VOC less than 25 tons per calendar year,**  **shall be in compliance with §§115.442, 115.443, 115.445, and 11**  **5.446 of this title as soon as practicable, but no later than one year,**  **after the commission publishes notification in the**  Texas Register **of its determination that this contingency rule is necessa**  **ry as a result of failure to attain the NAAQS for ozone by the attainment dea**  **dline 29** 

**Virginia 9 VAC 5-40-**

**7820 –**

**Standard for**

**Volatile Organic**  **Compounds http://www.deq.virginia.gov/air/regulations/air40.h**  **tml**

**see article 53 9VAC5-40-7800. Applicability and designation of aff**  **ected facility. A. Except as provided in subsections C, D, and E of**  **this section, the affected facility to which the provisions of this a**  **rticle apply is each lithographic printing process which uses a substrat**  **e other than a textile. B. The provisions of this article apply only to sou**  **rces of volatile organic compounds in the Northern Virginia or Richmond Vola**  **tile Organic Compound Emissions Control Area designated in 9VAC5**  **-20-206. C. Exempted from the provisions of this article are**  **facilities in the Northern Virginia Volatile Organic Compound Emissio**  **ns Control Area whose potential to emit is less than 10 tons per ye**  **ar of volatile organic compounds, provided the emission rates are determin**  **ed in a manner acceptable to the board. All volatile organic compo**  **und emissions from printing inks, coatings, cleaning solutions, and fo**  **untain solutions shall be considered in applying the exemption levels spec**  **ified in this**

**subsection. D. Exempted from the provisions of this article are**  **facilities in the Richmond Volatile Organic Compound Emissions Contro**  **l Area whose potential to emit is less than 100 tons per year of**  **volatile organic compounds, provided the emission rates are determin**  **ed in a manner acceptable to the board. All volatile organic compo**  **und emissions from printing inks, coatings, cleaning solutions, and fo**  **untain solutions shall be considered in applying the exemption levels spec**  **ified in this**

**subsection. E. The provisions of this article do not apply to t**  **he following: 1. Printing processes used exclusively for determin**  **ation of product quality and commercial acceptance provided:**  **a. The operation is not an integral part of the pro duction process;**  **b. The emissions from all product quality printing processes do not**  **exceed 400 pounds in any 30 day period; and c. The exemption is approved by the board.**  **2. Photoprocessing, typesetting, or imagesetting eq uipment using water**  **based chemistry to develop silver halide images. 3. Platemaking equipment using water-based chemistr**  **y to remove unhardened image-producing material from an exposed**  **plate. 4. Equipment used to make blueprints.**  **5. Any sheet-fed offset lithographic press with a c ylinder width of 26** 

**inches or less.**

**Wisconsin NR 422.142 –**

**Lithographic Printing, NR** 

**423.035 –**

**Industrial Cleaning**  **Operations http://www.legis.state.wi.us/rsb/code/nr/nr422.pdf** 

NR 422.142 Lithographic printing. (1) **APPLICABILITY. (a) This section applies to all lithographic printi**  **ng presses at any facility which is located in the county of Kenosha, Kewaunee**  **, Manitowoc, Milwaukee, Ozaukee, Racine, Sheboygan, Washington o**  **r Waukesha and**

**which has maximum theoretical emissions of VOCs fro m all**  **lithographic printing presses at the facility great er than or equal to 755.7**  **kilograms (1666 pounds) in any month. (b) To determine VOC emissions under par. (a), the**  **VOC content of a lithographic ink shall be multiplied by 0.8 for a h**  **eatset ink, or multiplied by 0.05 for a non−heatset ink, to account for VOC r**  **etention on the**

**substrate. 30** 



### Fountain Solution Limits

**1) San Joaquin Valley Unified Air Pollution Control District**  **Effective 9/17/2000 – 8 percent VOC by volume as ap plied** 

**2) San Diego County Air Pollution Control District 15 percent by volume VOC as applied** 

**3) South Coast Air Quality Management District Effective January 1, 2000 – 80 grams per liter VOC**  **as applied or 100 grams per liter as applied if a refrigerated chille**  **r is used**

**4) Bay Area AQMD 8 percent VOC by volume** 

**5) Delaware** For heatset web presses **: 1.6 percent or less by volume or 3 percent or less by volume if the fountain solution is refriger**  **ated to less than 15.6 oC (60 oF)**

For non-heatset web presses **: alcohol content in the fountain solution shall be eliminated; non-alcohol additives or alcoh**  **ol substitutes may be used to accomplish the total elimination of alcohol use** 

For sheet-fed presses **: 5 percent or less by volume or 8.5 percent or les s**  **by volume if the fountain solution is refrigerated to below 15.6 oC (60 oF)** 

Any type of offset lithographic printing press **is in compliance if the only VOC’s in the fountain solution are in non-alco**  **hol additives or alcohol**

**substitutes so that the concentration of VOCs’ in t he fountain solution is 3 percent**  **or less by weight. (The fountain solution shall not contain any alcohol.)** 

**6) Georgia 8 percent or less by volume VOC** 

**7) Illinois 8 percent or less VOC by weight** 

**8) Kansas Continuously contain 10 percent or less by weight o**  **f alcohol (alcohol is defined as isopropanol or isopropyl alcohol) or fou**  **ntain solution is refrigerated to a temperature of 55 oF or less for alcohol-based so**  **lutions 31**  **9) Maryland 8.5 percent isopropyl alcohol by weight; fountain s**  **olution is refrigerated to maintain a temperature of less than 55 oF if iso**  **propyl alcohol is used**

**10) Massachusetts** For facilities that will not have a usage rate of a ll VOC-containing compounds exceeding 670 gallons per calendar month or a facility-wide emission rate of VOC exceeding 2.5 tons per calenda r month **:**

Non-heatset **: for web presses installed on or after May 1, 1998 , the**  **fountain solution shall not contain any alcohol.**

Sheet-fed presses with cylinder widths greater than 21 inches **: 3 percent alcohol by volume, or 5 percent alcohol b**  **y volume and fountain solution refrigerated to a temperature of**  **less than 60 oF.**

Sheet-fed presses with cylinder widths less than or equal to 21

inches **: 5 percent alcohol by volume**

Newspaper printing **– 0 percent alcohol**

**Any VOC-containing additive other than alcohol shal l be limited** 

**to a mix ratio that will result in a VOC concentrat ion in the**  **fountain solution, excluding alcohol, equal to or l ess than 2.5**  **percent volume by alcohol.**

For facilities with the potential to emit, before t he application of air pollution control equipment, equal to or greater th an 50 tons per year of VOC (310 CMR 7.18(25)(a):

Sheet-fed offset lithographic press using propanol in fountain

solution **: 5 percent VOC by volume as applied or 8 percent V OC**  **by volume as applied with fountain solution refrige rated to a**  **temperature below 60 oF**

Web fed offset lithographic press using propanol in fountain

solution **: 1.6 percent VOC by volume as applied or 3 percent VOC**  **by volume as applied with fountain solution refrige rated to a**  **temperature below 60 oF**

Non-heatset web-fed offset lithographic press **: 0 percent propanol and maintain a total VOC concentration of**  **2.5 percent or less by weight** **32** Propanol Substitute Requirements **: Any person subject to 310 CMR 7.18(25)(a), who owns, leases, operates, or con**  **trols an offset lithographic press with fountain solution with prop**  **anol substitutes, containing a concentration of VOC in the fountain s**  **olution at 3.0 percent by volume or less, shall be considered in c**  **ompliance with**

**the VOC emission limitations for fountain solutions contained in**  **310 CMR 7.18(25).**

**For** large printers 1 and midsize printers 2 : **The following standards apply to midsize and large printers, except that they do not apply to the foun**  **tain solution in a press with a fountain solution reserv**  **oir that holds less than or equal to one gallon.** 

Web-fed Presses **: fountain solution shall not contain any alcohol.**

Sheet-fed Presses **: a. unrefrigerated fountain solution containing alco**  **hol shall contain no more than 5 percent VOC by weight, inclu**  **ding but not limited to alcohol, and;**  **b. refrigerated fountain solution containing alcoho l shall**  **contain no more than 8 percent VOC by weight, inclu ding**  **but not limited to alcohol, and shall be refrigerat ed to a**  **temperature of less than 60° F.**

1 Large printer **- a printer that uses a total of more than 3,000 gallons of cleanup solution and inks/coatings/adhes**  **ives with a VOC content greater than 10 percent by weight as ap**  **plied, per rolling12 month period, where incidental material,**  **ink used in non heatset offset lithographic printing, waterbased**  **ink/coating/adhesive, plastisol and ultraviolet ink are excluded** 

**from this calculation**

2 Midsize printer **- a printer that uses a total of more than 275 and**  **no more than 3000 gallons of cleanup solution and inks/coatings/adhesives with a VOC content greater**  **than 10 percent by weight as applied, per rolling 12 month**  **period, or that uses a total of more than 55 gallons of alcohol per**  **rolling 12 month period and a total of no more than 3000 gallons of**  **cleanup solution, and inks/coatings/adhesives with a VOC co**  **ntent greater than 10 percent by weight as applied, per rolling 1**  **2 month period, where incidental material, ink used in non-heatset**  **offset lithographic printing, water-based ink/coating/adhe**  **sive, plastisol**

**and ultraviolet ink are excluded from this calculat ion** 

**11) Missouri** (Kansas City) **10 percent or less alcohol by weight and fountain solution**  **refrigerated to 55 oF or less for alcohol based sol utions** **33** (St. Louis) heat set web **: 1.6 percent or less by volume of alcohol, or 3 percent or less by volume of alcohol and fountain s**  **olution is refrigerated to a temperature of 60 oF or less, or 5 percent or less**  **by volume of alcohol substitutes**

(St. Louis) sheet-fed **: 5 percent or less by volume of alcohol, or 8.5 percent or less by volume of alcohol and fountain s**  **olution is refrigerated to a temperature of 60 oF or less, or 5 percent or less**  **by volume of alcohol substitutes**

**or combination of alcohol and alcohol substitutes**

(St. Louis) non-heatset web **: 5 percent or less by volume of alcohol substitutes, or 5 percent or less by volume of a co**  **mbination of alcohol and**

**alcohol substitutes**

**12) New Hampshire**

Heatset web **: 1.6 percent or less by weight, or 3 percent or le ss by weight**  **if the fountain is refrigerated to a temperature be low 60 oF, or 5 percent or less by**  **weight if the fountain solution contains no alcohol**

Sheet-fed **: 5 percent VOC or less by weight, or VOC content o f 8.5**  **percent or less by weight if the fountain solution is refrigerated to a temperature** 

**below 60 oF**

Fountain solution used in a non-heatset web-fed off set lithographic printing process, including both newspaper and non- newspaper facilities,

**shall contain no alcohol and the concentration of t otal VOC’s shall not exceed 5**  **percent by weight in the final solution.**

**13) New York 10 percent or less by weight of VOC** 

**14) North Carolina**

**None found**

**15) Tennessee**

Heatset web **: 1.6 percent VOC by volume as applied, or 3 percen t VOC**  **by volume as applied if the fountain solution is re frigerated to less than 60 oF, or**  **4.6 percent VOC by volume as applied and use no alc ohol in the fountain**  **solution, or 6 percent VOC by volume as applied if the fountain solution is**  **refrigerated to less than 60 oF and use no alcohol in the fountain solution** 

Non-heatset web **: No owner or operator of a non-heatset web offset printing press subject to this rule shall apply any**  **fountain solution that contains alcohol, nor shall any fountain solution be applied**  **unless the VOC content is equal to or less than 5 percent by weight of the fo**  **untain solution as applied. 34**  Sheet-fed **: 5 percent VOC by volume as applied, or 8.5 percen t by volume**  **as applied is the fountain solution is refrigerated to less than 60 oF** 

**16) Texas**

Heatset web **: Any person who owns or operates a heatset web off set**  **lithographic printing press that uses alcohol in th e fountain solution shall maintain**  **total fountain solution alcohol to 5.0 percent or l ess by volume. Alternatively, a**  **standard of 10.0 percent or less by volume alcohol may be used if the fountain**  **solution containing alcohol is refrigerated to less than 60 degrees Fahrenheit.** 

Nonheatset web newspaper **: Eliminate the use of alcohol in the fountain**

**solution. Non-alcohol additives or alcohol substitu tes can be used to accomplish** 

**the total elimination of alcohol use.**

Nonheatset web non-newspaper **: 5.0 percent or less by volume or 10.0 percent or less by volume alcohol may be used if th**  **e fountain solution is refrigerated to less than 60 oF.** 

Sheet fed **: 10.0 percent or less by volume or 12.0% or less b y volume**  **alcohol may be used if the fountain solution is ref rigerated to less than 60 oF.** 

**Any person who owns or operates any type of offset lithographic printing**  **press shall be considered in compliance with the fo untain solution limitations of**  **this paragraph if the only VOCs in the fountain sol ution are in nonalcohol**  **additives or alcohol substitutes, so that the conce ntration of VOCs in the fountain**  **solution is 3.0 percent or less by weight. The foun tain solution shall not contain**  **any isopropyl alcohol.**

**17) Virginia**

Heatset web **: a. When the fountain solution contains alcohol:**  **(1) The fountain solution shall contain no more tha n a daily**  **average of 1.6 percent volatile organic compounds b y weight; or**  **(2) The temperature of the fountain solution shall be maintained at** 

**or below 60 oF and the fountain solution shall cont ain no more than**  **a daily average of 3.0 percent volatile organic com pounds by**  **weight; or**

**b. When the fountain solution contains no alcohol, the fountain solution**  **shall contain no more than a daily average of 5.0 p ercent volatile organic**  **compounds by weight.**

Non-heatset web presses and each newspaper presses **: the fountain**

**solution shall contain no alcohol and shall contain no more than a daily**  **average of 5.0 percent volatile organic compounds b y weight.** **35** Sheet-fed press **: a. The fountain solution shall contain no more than**  **a daily average of 5.0 percent volatile organic compounds by weight; or**  **b. The temperature of the fountain solution shall b e maintained at or below** 

**60 oF and the fountain solution shall contain no mo re than a daily average**  **of 8.5 percent volatile organic compounds by weight**

**.**

**18) Wisconsin** Heatset web presses **: any person who owns or operates a heatset web lithographic printing press shall, when printing on**  **a substrate other than metal, metal-foil or plastic, use a fountain solution whic**  **h has a VOC content as applied of no more than one of the following:**  **a. 1.6 percent by weight if the fountain solution contains any restricted**  **alcohol and is not refrigerated to 60 oF or less. b. 3.0 percent by weight if the fountain solution**  **contains any restricted alcohol and is refrigerated to 60°F or less.**  **c. 5.0 percent by weight if the fountain solution contains no restricted** 

**alcohol.**

Non-heatset web presses **: any person who owns or operates a non-heatset web lithographic printing press shall, when printin**  **g on a substrate other than metal, metal-foil or plastic, use a fountain soluti**  **on which has a VOC content as applied of no more than 5.0 percent by weight and w**  **hich contains no restricted**

**alcohol.**

Sheet-fed presses **: any person who owns or operates a sheet-fed lithographic printing press shall, when printing on**  **a substrate other than metal, metal-foil or plastic, use a fountain solution whic**  **h has a VOC content as applied of no more than one of the following:**  **a. 5.0 percent by weight. b. 8.5 percent by weight if the fountain solution i**  **s refrigerated to 60 oF or**

**less.**

Metal, metal-foil or plastic substrates **: any person who owns or operates any lithographic printing press shall, when printin**  **g on a metal, metal-foil or plastic substrate, use a fountain solution which ha**  **s a VOC content as applied of no more than one of the following:**  **a. 13.5 percent by weight if the fountain solution contains any restricted**  **alcohol and is refrigerated to 60 oF or less. b. Not more than 1.6 percent by weight if the fount**  **ain solution contains any restricted alcohol and is not refrigerated to 6**  **0 oF or less or 5.0 percent by weight if the fountain solution contains no rest**  **ricted alcohol for**

heatset web **; not more than a VOC content as applied of 5.0 per cent by**  **weight and which contains no restricted alcohol for** non-heatset **web; and not more than a VOC content as applied of 5.0 perce**  **nt by weight for** sheet-fed presses

**. 36**  

## Appendix C

**State and Local Regulations for Letterpress Printin g** 

Letterpress State and Local Rules – Ink VOC Content Limits

State Ink VOC Content Limit (lb/gal as applied, les s water) **San Diego**

**Rule 67.16 2.5** 

**San Joaquin Valley 1** 

**Rule 4607 2.5** 

**South Coast 1** 
**Rules 1130 (printing) and 1171 (cleaning) 2.5** 

**Massachusetts 310 CMR 7.26 – (25)**  **2.5**

**Wisconsin 2** 
**NR 423.035 (cleaning) ----** 

**1. This limit is expressed as lb/gal as applied, le ss water and less exempt compounds.**  **2. Wisconsin only has rules for industrial solvent cleaning operations.** 

Letterpress State and Local Rules – Cleaning Soluti ons

State Cleaning Solution

VOC Content

Limit (grams/liter) Cleaning Solution VOC

Composite Partial Vapor Pressure, millimeters of mercury (mm Hg) at 20 oC Cleaning Solution

VOC Content Limit (lb/gal)

**San Diego 1**  **200 45 San Joaquin**  **Roller Wash – Step 1 600 10 5.0** 

**San Joaquin Roller Wash – Step 2,** **Blanket Wash, and On press Components**  **800 10 6.7**

**San Joaquin**

**Removable Press Components**  **50 10 0.42**

**South Coast Roller Wash – Step 1**  **500 4.2**

**South Coast Roller Wash – Step 2,** **Blanket Wash, and On press Components**  **500 4.2**

**South Coast Removable Press Components**  **25 0.21**

**Massachusetts 25 Wisconsin On-press**  **Components 2** 

**Wisconsin Removable Press Components**  **50 0.42**

**1. Total vapor pressure 2. A maximum VOC content of 30% by weight** **37** This page intentionally left blank.**38** 

## Appendix D

**Estimated Costs Associated with the Recommendations Contained in the**  **Control Techniques Guidelines for Offset Lithograph ic Printing and** 

**Letterpress Printing**

**This appendix presents the estimated costs associat ed with implementing the**  **recommendations in the CTG for controlling volatile organic compounds (VOCs)**  **emissions from offset lithographic printing and let terpress printing facilities in ozone**  **nonattainment areas. As explained in the CTG, the C TG is guidance for State and local**  **pollution control agencies to use in determining “r easonably available control**  **technology” (RACT) for VOCs from offset lithographi c printing and letterpress printing.**  **State and local pollution control agencies are free to adopt the recommendations**  **contained in the CTG, or implement other technicall y-sound approaches for RACT,**  **provided those approaches are consistent with the C AA and EPA’s implementing**  **regulations. Accordingly, there is necessarily so me uncertainty in any prediction of**  **costs and emission impacts associated with the reco mmendations contained in the CTG.**  **For purposes of this analysis, we assume that all s tates will adopt the recommendations in** 

**the CTG.**

**Costs are presented below for installing and opera ting control equipment to**  **reduce VOC emissions from heatset dryers, and for r educing emissions from cleaning**  **through the use of low VOC composite vapor pressure (less than or equal to 10mm Hg at**  **20 degrees C) and low VOC content (less than 70 wei ght percent VOC) cleaning** 

**materials.**

Estimated nationwide total annual cost of CTG recom mendations for offset lithographic printing - heatset dryers

**The nationwide total annual cost of the CTG recomme ndations for offset lithographic**  **printing heatset dryers is estimated to be $33 mill ion.** 

**As shown in Tables 1 through 3, this is based on es timates in the 1993 draft CTG with**  **adjustments made for the number of facilities in no nattaiment areas today versus 1993,**  **2005 dollars versus first quarter 1990 dollars and the number of facilities already**  **achieving the recommendations in this CTG today ve rsus the number of facilities**  **achieving the 1993 draft recommendations in 1993. 39** 

**Table 1**

Col A Col B Col C Col D Col E

B*53/60 B*0.4 C*0.2

heatset

litho

model plants #

facilities

in

nonatt

areas in

1993

draft

CTG #

facilities

in

nonatt

areas today #

facilities

in

nonatt

areas in

1993

w/o dryer

controls #

facilities

in

nonatt

areas today

w/o dryer

controls

A-I 77 68 30 14

A-II 122 108 48 22

A-III 319 282 127 57

A-IV 308 272 123 55

**Table 1 Notes**

**In 1993, 60 percent of US population was in ozone n onattainment areas. Today, 53**  **percent of US population is in ozone nonattainment areas.** 

**In 1993, 60 percent of heatset dryers were assumed to already be controlled and 40**  **percent were assumed to be uncontrolled. Today, 80 percent of heatset dryers are**  **assumed to already be controlled and 20 percent are assumed to be uncontrolled.** **40**

**Table 2**

Col A Col B Col C Col D Col E

B/C D*1.36

Heatset

litho

model plants total annual

cost from

1993 draft

CTG Table

E-1 # of

facilities installing

controls

in 1993 total

annual

cost of

control

per facility (1st quarter

1990 dollars) total

annual

cost of

control

per facility (2005 dollars)

A-I $1,513,392 30 $50,446 $68,607 A-II $4,433,742 48 $92,370 $125,623 A-III $20,464,574 127 $161,138 $219,148 A-IV $27,614,987 123 $224,512 $305,336

**A cost escalation factor of 1.36 was used to conver t first quarter 1990 dollars to 2005** 

**dollars.**

**Table 3**

Col A Col B Col C Col D

B*C

Heatset

litho

model plants # facilities

in nonatt

areas today w/o dryer

controls total

annual

cost of

control

per facility (2005 dollars) total annual

cost of

control (2005 dollars)

A-I 14 $68,607 $960,499

A-II 22 $125,623 $2,763,699

A-III 57 $219,148 $12,491,447

A-IV 55 $305,336 $16,793,504 TOTAL $33,009,150**41**

Estimated nationwide total annual cost of CTG recom mendations for offset lithographic printing – cleaning

**The nationwide total annual cost of the CTG recomme ndations for cleaning associated**  **with offset lithographic printing is estimated to b e $18 million.** 

**As shown in Tables 4 through 6, this is based on es timates in the 1993 draft CTG with**  **adjustments made for the number of facilities in no nattaiment areas today versus 1993,**  **2005 dollars versus first quarter 1990 dollars and the number of facilities already**  **achieving the recommendations in this CTG today. 42** 

**Table 4**

Col A Col B Col C Col D Col E

B*53/60 D*0.4

model plants #

facilities

in

nonatt

areas in

1993

draft

CTG #

facilities

in

nonatt

areas today #

facilities

in

nonatt

areas today

above

cutoff # facilities in

nonatt areas today above

cutoff and not already meeting cleaning

recommendations

heatset

A-I 77 68 68 27

A-II 122 108 108 43

A-III 319 282 282 113

A-IV 308 272 272 109

coldset

web

B-I 158 140 140 56

B-II 535 473 473 189
B-III 1,198 1,058 1,058 423

B-IV 397 351 351 140

sheet fed
C-I 14,362 12,686 0 0
C-II 12,131 10,716 0 0
C-III 2,624 2,318 2,318 927
C-IV 1,733 1,531 1,531 612

newspaper
D-I 419 370 0 0

D-II 93 82 82 33

D-III 42 37 37 15

D-IV 21 19 19 7

D-V 8 7 7 3

D-VI 4 4 4 1**43**

**Table 4 Notes**

**In 1993, 60 percent of US population was in ozone n onattainment areas. Today, 53**  **percent of US population is in ozone nonattainment areas.** 

**The two smallest size sheet-fed model facilities an d the smallest size newspaper model**  **facility do not exceed the 15 lb/day cutoff.**

**In 1993, no facilities were assumed to be meeting t he draft recommendations for**  **cleaning. Today, at least 60 percent of facilities are assumed to already be meeting the**  **recommendations for cleaning because over 60 percen t of the nonattainment area**  **population is in areas which already have state or local VOC rule for offset lithography.** **44**

**Tabl e 5** 

Col A Col B Col C Col D Col E

B/C D*1.36

Model plants total annual

cost from

1993 draft

CTG Table E-3 (1st quarter 1990 dollars) # facilities in nonatt

areas in 1993 draft

CTG total annual cost of

control per facility (1st quarter 1990 dollars) total annual cost of

control per facility (2005 dollars)

Heatset A-I $84,080 77 $1,092 $1,485
A-II $292,755 122 $2,400 $3,263
A-III $1,529,563 319 $4,795 $6,521
A-IV $2,685,126 308 $8,718 $11,856

coldset

web B-I $172,527 158 $1,092 $1,485
B-II $1,283,805 535 $2,400 $3,264
B-III $5,744,251 1,198 $4,795 $6,521
B-IV $3,461,022 397 $8,718 $11,856

sheet fed C-I $6,323,589 14,362 $440 $599
C-II $10,682,559 12,131 $881 $1,198
C-III $9,242,778 2,624 $3,522 $4,790
C-IV $12,971,678 1,733 $7,485 $10,180

newspaper D-I $276,729 419 $660 $898
D-II $184,266 93 $1,981 $2,695
D-III $151,639 42 $3,610 $4,910
D-IV $151,639 21 $7,221 $9,820
D-V $119,409 8 $14,926 $20,300
D-VI $96,514 4 $24,129 $32,815

**Table 5 Notes**

**A cost escalation factor of 1.36 was used to conver t first quarter 1990 dollars to 2005** 

**dollars. 45** 

**Table 6**

Col A Col B Col C Col D

B*C

Model plants # facilities in

nonatt areas today above

cutoff and not already meeting cleaning

recommendations total

annual

cost of

control

per facility (2005 dollars) total annual

cost of control (2005 dollars)

heatset

A-I 27 $1,485 $40,403

A-II 43 $3,263 $140,679

A-III 113 $6,521 $735,006

A-IV 109 $11,856 $1,290,293

coldset

web

B-I 56 $1,485 $82,905

B-II 189 $3,264 $616,911

B-III 423 $6,521 $2,760,304

B-IV 140 $11,856 $1,663,136

sheet fed

C-I 0 $440 $0

C-II 0 $881 $0

C-III 927 $4,790 $4,441,463

C-IV 612 $10,180 $6,233,324

newspaper
D-I 0 $660 $0

D-II 33 $2,695 $88,546

D-III 15 $4,910 $72,868

D-IV 7 $9,820 $72,868

D-V 3 $20,300 $57,380

D-VI 1 $32,815 $46,378

TOTAL $18,342,463**United States Environmental Protection** **Agency Office of Air Quality Planning and Standards** **Sector Policies and Programs Division Research Triangle Park, NC** **Publication No. EPA 453/R-06-002 September 2006**