pennsylvania 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

SECRETARY 

November 15, 2013 

Mr. Shawn M. Garvin 

Regional Administrator 

U.S. Environmental Protection Agency, Region III 

1650 Arch Street (Mail Code: 3RAOO) 

Philadelphia, PA 19103-2029 

Dear Mr. Garvin: 

Enclosed for your approval is a revision to Pennsylvania's State Implementation Plan (SIP) 

pertaining to the adoption by Allegheny County Health Department (ACHD) in June 2013 of 

Control Techniques Guidelines (CTGs) promulgated by the U.S. Environmental Protection 

Agency (EPA) in 2008 for Offset Lithographic Printing and Letterpress Printing; Flexible 

Packaging Printing; and Industrial Solvent Cleaning Operations. The CTGs constitute 

Reasonably Available Control Technology (RACT) for the covered processes. The revision is 

identified as revision No. 68 to the Maintenance Plan for ACHD's internal tracking. 

The ACHD is a local health agency organized under Local Health Administration Law, Act 315 

of August 24, 1951, P.L. 1304, as amended, whose powers and duties include the enforcement of 

laws relating to public health within Allegheny County. The ACHD has an air pollution control 

program that has been approved by the Department of Environmental Protection in accordance 

with Section 12 of the Air Pollution Control Act. 

I have enclosed a hard copy and a compact disc of the supplemental SIP submittal materials 

which consist of the supplemental SIP submittal documents, documentation of public hearing 

and comment period, and the comment and response document. I certify that the electronic files 

are exact duplicates of the hard copies. 

The Commonwealth followed all of the procedural requirements of the State's laws and 

constitution in conducting and completing the adoption/issuance of the SIP revision. 

Thank you for your attention to this matter. Should you have any questions concerning this SIP 

revision, please contact Joyce E. Epps, Director of Air Quality, by e-mail at jeepps@pa.gov or 

by telephone at 717.787.9702. You may also contact James E. Thompson, Manager, Air Quality 

Program of the ACHD, by e-mail atjthompson@achd.net or by telephone at 412.578.7963. 

Sincerely, 

(J 

(__ 

E. Christopher Abruzzo 

Acting Secretary 

Enclosures 

Rachel Carson State Office Building 1 P.O. Box 2063 1 Harrisburg, PA 17105-2063 

717.787.2814 . t5'J Pnnted on Recycled Paper Q]Cf www .depweb.state. pa. us 
Mr. Shawn M. Garvin 

cc: Joyce Epps 

James Thompson, ACHD 

Diana Esher, EPA Region III 

-2-
COUNTY OF 

1\h, ....... ,-ef! Er:-.:t, 1 )iN-1.'1tlt 

Lkp~1 t.:111 vi' h!Wif\"lnmcnraJ Plt'ltC~:ck-n 

OIH'UI!IJ of Ai•· Q\:Aiit · 

rtochcl CIIIIUJII B\dhllng 

10ll Markel Stre~L P.O 00x 8JS68 

Harri.-bur;.. PA 1?105-8468 

£X11• \ •1.: f-'p",)•: 

ALLEGHE NY 

F.1'1Cl~ ~l't :1 f'JtXf CO!=Y &B:f ln 0:='13C:l d t!pli<:l.lc.' 1,1f lhjf Npq l''Jl)>' On a l'l'!!U?ulc; dj¥ h 

St!CI'abft.!\d( tHe fCinni of:t rew-:slon rc :\lkghrn ... Ccvnt) 's pur1iv:. .,~r the 1\-rut:.)h\UU..t 'S ~ t<' 

Jr~.pbn..'!ttt*.i<!O f~itw, tOr ~h.~ A~.;~1:-~· ;~ d \bin!l'na·ce ,.( :\c j ll<'U' (),.ftllt N:t.~ior.tl 

Ambknl AU Q.M1ly ~t.l.llltlh- (luq,'!S :It: "Jt d-:1.: \.Xl, 4 i• P'<llh .. 1i,ln (\,. ur~ Rults U'..:i 

R.c~ rid ((lt.OI.y Or.Jimlna: lf\?)t2 ~~ n!'alcl Ito ~!J..IM Ml it~11~i~·~ (,l;s t nr 

Off$« IJ tt~~r·k Pt1ntfAg .and l.ettap~ Prifttf•Je r to-lbk P\Xb~•R Pri•tm,; u d 

ft~ ,frbl ~ttU t""kanl•t Opcratioru-S~6CII'l'fi !IM.I!tl. ,!105.11 . end 2 105.8.: 

rn~ iw :- M \llol:ll '"~'C~rt~nc;<ira;X:t..: M>!'-~1'"0! r~l:uk-ns .tt S«wn ZIOS.I I. This: SIP 

t":'\is.kr. ft ~ tr<ki.t'li! ..s t'Ut iDkmr.l R:,., ·!:Jioo 6f 

·~ l'JIP KC\uicln wa:; the n~J~t cf 02 ~Jbti; cC1"'...me:t: p«iod (~ Ju y :!0. ;c 10 t:."1ti1 .".tl.Jtii.St 

20. :tiJ )(} tlttr "·''\' uf f•~ pt•b!ic ·•t:;tuntt· ft v.-:t<; :i(l(l'''''t-.1 b)- the RMn! nHfc-.. '\tl fin May 4., 20 1.. 

rnl!4'tt'd b;, Cl,l\..tl; C .;v..&:iJ oo .:vt:.t)2:!. 2•)1 3, appt,..,•::d JttlCI ;IJV'(-.1 l'ly the All;;fl<:n) l(lu:uy 

Chi'-·( x~1. ti ~ ~t.m to.: a} 29. :o 13, 4-!td b::eamc ~n~cli ~ e um~ ¥. :ol 3. 

We n: c~ l11111 rl·: Vcnn~y anin L>tpamnem (If En''U'O!;tr.tc:nlal f't'lll<:cli.,.'ll •'IJPW''t lb.il 1\':.,i-rioo 

and li>:Wtln:l \be I-'<'~P¢f copy <~oo:l <hsk ll' the ~ I.S f.: I-':\ ~~,.., , Il l whh 1\ ~e"•um l\d, f)n ~'" 

al'I'I'O\'td IJ ;t\.1tl h!tH: ;m y un~. o;;x:~e n•ll •tw 011 !h.· o\W) o/,.:1 hd .. w ••' i!lllllii i"O: 111 

j ll)llut~JY•J...u:.hd.ntl,. 

-- ----------- A&.LIH,.HIE.NYCOII"'"TY H i.'\LTU D•PAFrM~..n • Alit 0VAUT'r .. ?tOCitAM 

:1-,. · :T S""f;£~TBIJL.:.of1(;t,7 • P~Eo..~:O• ""A. H,o<K; I tt l 

~ .. o-.e•"';"'· ~.'&.0::1\:3 · I .-.~o. 41'2.o!o7• ... 0t.u. 
 

 

 

Revision to ALLEGHENY COUNTY’S portion of the 

PENNSYLVANIA STATE IMPLEMENTATION PLAN 

For the 

Attainment and Maintenance of the National
 

Ambient Air Quality Standards
 

Revision Tracking No. 68
 

Allegheny County Health Department
 

Rules and Regulations
 

Article XXI, Air Pollution Control 

Changes to Article XXI Sections in the SIP:
 

§2105.11 Graphic Arts Systems, 

§2105.80 Control of VOC Emissions from Offset Lithographic Printing and 

Letterpress Printing, 

§2105.81 Control of VOC Emissions from Flexible Package Printing, and 

§2105.82 Control of VOC Emissions from Industrial Solvent Cleaning Operations
 

1
 
 

 

 

 

 

Table of Contents 

1. Changes to Article XXI Rules and Regulations: 

§2105.11, Graphic Arts Systems (SIP Change);
 

§2105.80, Control of VOC Emissions from Offset Lithographic Printing and 

Letterpress Printing (SIP Change);
 

§2105.81, Control of VOC Emissions from Flexible Package Printing (SIP
 

Change);
 

§2105.82, Control of VOC Emissions from Industrial Solvent Cleaning 

Operations (SIP Change)
 

2. Technical Support Document 

3. Documentation of Public Hearing and Certifications 

Public hearing notice 

Transmittals of hearing notice to EPA & PA DEP 

Proof of publication of notice of hearing 

Certification of hearing 

Summary of Comments and responses 

Certification of approval and adoption 

2
 
 

 

 

 

 

 

 

 

 

 

 

1. Article XXI Changes 

ALL NEW TEXT
 

§ 2105.80 CONTROL OF VOC EMISSIONS FROM OFFSET LITHOGRAPHIC 

PRINTING AND LETTERPRESS PRINTING 

a.	 Applicability. Beginning January 1, 2012, this section applies to the owner or operator 

of an offset lithographic printing and/or letterpress printing operation, where the total 

actual VOC emissions from all offset lithographic printing and letterpress printing 

operations, with two exceptions, including related cleaning activities, at that facility are 

equal to or greater than 15 pounds (6.8 kilograms) per day or 2.7 tons (2,455 kilograms) 

per twelve month rolling period. These exceptions include heatset web offset 

lithographic printing operations and heatset web letterpress printing operations, for which 

this section only applies to those presses with potential to emit from the dryer, prior to 

controls, of at least 25 tons (22,680 kilograms) of VOC (petroleum ink oil) from heatset 

inks per twelve month rolling period. 

b.	 Limitations. A person may not cause or permit the emission into the outdoor
 

atmosphere of VOCs from an offset lithographic printing and/or letterpress printing
 

operation unless one of the following limitations is met:
 

1.	 The VOC content for heatset web offset lithographic printing contains 1.6 percent 

alcohol or less (by weight), on-press (as-applied) in the fountain or the following 

equivalents: 

A.	 3.0 percent alcohol or less (by weight) on-press (as-applied) in the 

fountain solution provided the fountain solution is refrigerated to below 

60°F (15.5°C); or 

B.	 5.0 percent alcohol substitute or less (by weight) on-press (as-applied) and 

no alcohol in the fountain solution. 

2.	 The VOC content for sheet-fed offset lithographic printing contains 5.0 percent 

alcohol or less (by weight), in the fountain or the following equivalents: 

A.	 8.5 percent alcohol or less (by weight) on-press (as-applied) in the 

fountain solution provided the fountain solution is refrigerated to below 

60°F (15.5°C); or 

B.	 5.0 percent alcohol substitute or less (by weight) on-press (as-applied) and 

no alcohol in the fountain solution. 

3
 
 

 

 

 

 

 

 

 

 

3.	 The VOC content for cold web lithographic printing contains 5.0 percent alcohol 

substitute or less (by weight) on-press (as-applied) and no alcohol in the fountain 

solution. 

4.	 The overall weight of VOC emitted to the atmosphere is reduced through the use 

of a chiller condenser or an oxidizer for heatset web offset lithographic printing or 

heatset web letterpress printing as follows: 

A.	 The overall control efficiency for a chiller condenser shall be no less than 

90 percent; or 

B.	 The overall control efficiency for an oxidizer shall be no less than 95 

percent; or 

C.	 VOC outlet concentration is reduced to less than 20 ppmv on a dry basis. 

5.	 Use cleaning materials with a VOC composite vapor pressure less than 10mm Hg 

at 68°F (20°C) or cleaning materials containing less than 70 weight percent VOC. 

The cleaning materials apply to blanket washing, roller washing, plate cleaners, 

metering roller cleaners, impression cylinder cleaners, rubber rejuvenators, and 

other cleaners used for cleaning a press, press parts, or to remove dried ink from 

the areas around a press. The cleaning materials provided do not apply to 

cleaners used on electric components of a press, pre-press cleaning operations, 

post-press operations, cleaning supplies used to clean the floor, other than dried 

ink, in the area around a press, or cleaning performed in parts washers or cold 

cleaners. 

6.	 A combination of the methods listed in Paragraphs 1 through 5. 

c.	 Records. A facility, regardless of the facility’s annual emission rate, which contains 

offset lithographic printing and/or letterpress printing operations, shall maintain records 

sufficient to demonstrate compliance with this section. At a minimum, a facility shall 

maintain daily records of: 

1.	 The following parameters for each ink and other component as supplied: 

A.	 The name and identification number of each ink, or component; 

B.	 The volume used; 

C.	 The total volume of all the inks used in the offset lithographic printing and 

letterpress printing operation; 

D.	 The mix ratio; 

E.	 The density or specific gravity; 

F.	 If used, the temperature of the fountain solution. 

The records shall be maintained for 2 years and shall be submitted to the Department on a 

schedule reasonably prescribed by the Department. 

4
 
 

 

 

 

 

 

 

d.	 Exempt Solvents. The solvents methyl chloroform (1,1,1-trichloroethane) and 

methylene chloride are exempt from control under this Section. No offset lithographic 

printing operation or letterpress printing operation which seeks to comply with this 

Section through the use of an exempt solvent may be included in any alternative standard 

approved pursuant to this Article. 

e.	 Exempt Other. The following shall be exempt from the limitations set by Subsection b: 

1. Sheet-feed presses with sheet size of 11 inches (27.9 centimeters) by 17 inches 

(43.2 centimeters) or smaller, or to any sheet-feed press with total fountain 

solution reservoir of less than one gallon (3.8 liters). 

2.	 Heatset presses used for book printing or heatset presses with maximum web 

width of 22 inches (55.9 centimeters) or less are excluded from the add-on control 

of either a chiller condenser or an oxidizer. 

3.	 110 gallons (416 liters) per year of cleaning materials, or less, which meet neither 

the low VOC composite vapor pressure limitation nor the lower VOC content 

limitation and work practices. 

f.	 Housekeeping. The following work practices for cleaning materials apply to the owner 

or operator of an offset lithographic printing and letterpress printing operation: 

1.	 Store all VOC-containing cleaning materials and used shop towels in closed 

containers. 

2.	 Ensure that ink, fountain solution and cleaning material storage containers are 

kept closed at all times except when depositing or removing those materials. 

3.	 Minimize spills of VOC-containing inks, fountain solutions and cleaning 

materials, cleaning up spills immediately. 

4.	 Convey VOC-containing inks, fountain solutions and cleaning materials from one 

location to another in closed containers or pipes. 

5.	 Minimize VOC emissions during cleaning of storage and conveying equipment. 

g.	 Measurements. Measurements of the volatile fraction of inks and fountain solution, and 

of volatile organic compound emissions shall be performed according to the applicable 

procedures established in § 2107.04 of this Article. 

5
 
 

 

 

 

 

 

 

 

 

 

NEW TEXT in 

BOLD and ITALIC 

§ 2105.11 GRAPHIC ARTS SYSTEMS 

a.	 This Section applies to sources whose rotogravure and flexographic printing presses in 

themselves, or in combination with any surface coating operations subject to the 

provisions of Section 2105.10 of this Article (relating to Surface Coating Processes), 

have a potential uncontrolled emission rate of 1000 pounds or more per day or 100 tons 

or more per year of volatile organic compounds, including emissions from solvents used 

for clean up and purging. No person shall operate, or allow to be operated, any source to 

which this Section applies, unless one of the following emission limitations is met: 

1.	 The volatile fraction of the ink, as applied to the substrate, contains 25.0 percent 

by volume or less of VOC and 75.0 percent by volume or more of water; 

2.	 The ink, as applied to the substrate, contains 60.0 percent by volume or more of 

solid material; or 

3.	 There is in operation a carbon adsorption system, an incinerator system, or an 

alternate volatile organic compound emission control system which recovers or 

destroys at least 90 percent by weight of the volatile organic compounds entering 

the system. 

b.	 Any person who seeks to comply with the requirements of this Section through the 

installation and operation of an emission control system as provided by Paragraph a.3 

above shall operate such emission control system in conjunction with an emission capture 

system which is designed and operated consistent with good engineering practice and 

which achieves a contemporaneous, overall reduction in volatile organic compound 

emissions from each ink/press of at least: 

1.	 75.0 percent from publication rotogravure processes; 

2.	 65.0 percent from other rotogravure processes; and, 

3.	 60.0 percent from flexographic printing processes. 

c.	 Presses which are used only to check the quality of the image formation of newly etched 

or engraved printing cylinders are exempted from this Section provided the aggregate
 

emissions from the presses do not exceed 400 pounds in any 30 day running period.
 

6
 
 

 

 

 

 

 

d. Exempt Solvents. 

The solvents methyl chloroform (1,1,1-trichloroethane) and methylene chloride are 

exempt from control under this Section. No graphic arts process which seeks to comply 

with this Section through the use of an exempt solvent may be included in any alternative 

standard approved pursuant to this Article. 

e. Measurements. 

Measurements of the volatile fraction of inks and of volatile organic compound emissions 

shall be performed according to the applicable procedures established in § 2107.04 of this 

Article. 

f. Exempt Other. 

The owner or operator of a flexible package printing press subject to § 2105.81 

CONTROL OF VOC EMISSIONS FROM FLEXIBLE PACKAGE PRINTING, is no 

longer subject to all subparagraphs of § 2105.11 GRAPHIC ARTS SYSTEMS, and 

shall be subject to all subparagraphs of § 2105.81 CONTROL OF VOC EMISSIONS 

FROM FLEXIBLE PACKAGE PRINTING as of January 1, 2012. 

7
 
 

 

 

 

 

 

 

 

 

 

 

 

 

ALL NEW TEXT
 

§ 2105.81 CONTROL OF VOC EMISSIONS FROM FLEXIBLE PACKAGE PRINTING 

a.	 Applicability. Beginning January 1, 2012, this section applies to the owner or operator 

of a flexible packaging printing press, including rotogravure printing and flexographic 

printing, where the total actual VOC emissions from all flexible package printing press 

operations, including related cleaning activities, at the facility are equal to or greater than 

15 pounds (6.8 kilograms) per day or 2.7 tons (2,455 kilograms) per twelve month rolling 

period. 

1.	 The limits from § 2105.11 Graphic Arts System no longer apply to flexible 

package printing presses, as of January 1, 2012. 

b.	 Limitations. A person may not cause or permit the emission into the outdoor
 

atmosphere of VOCs from a flexible package printing press unless one of the following
 

limitations is met:
 

1.	 The overall control efficiency shall be no less than 80 percent. 

2.	 The VOC content of materials (inks, coatings and adhesives) used on a single 

press shall not be greater than 0.8 lb VOC per lb solids applied. 

3.	 The VOC content of materials (inks, coatings and adhesives) used on a single 

press shall not be greater than 0.16 lb VOC per lb materials applied. 

c.	 Records. A facility, regardless of the facility’s annual emission rate, which contains a 

flexible package printing press, shall maintain records sufficient to demonstrate 

compliance with this section. At a minimum, a facility shall maintain daily records of: 

1.	 The following parameters for each material, ink, coating, adhesive and other 

component as supplied: 

A.	 The name and identification number of each material, ink, coating and 

adhesive; 

B.	 The volume used; 

C.	 The mix ratio; 

D.	 The density or specific gravity; 

E.	 The weight percent of total volatiles, water, solids, and exempt solvents; 

F.	 The VOC content of the materials (inks, coatings and adhesives) used on a 

single press per weight of solids or materials applied. 

8
 
 

 

 

 

 

 

The records shall be maintained for 2 years and shall be submitted to the Department on a 

schedule reasonably prescribed by the Department. 

d.	 Exempt Solvents. The solvents methyl chloroform (1,1,1-trichloroethane) and 

methylene chloride are exempt from control under this Section. No flexible package 

printing operation which seeks to comply with this Section through the use of an exempt 

solvent may be included in any alternative standard approved pursuant to this Article. 

e.	 Housekeeping. The following work practices for cleaning materials apply to the owner 

or operator of a flexible printing press: 

1.	 Store all VOC-containing cleaning materials and used shop towels in closed 

containers. 

2.	 Ensure that ink, coating, adhesive and cleaning material storage containers are 

kept closed at all times except when depositing or removing those materials. 

3.	 Minimize spills of VOC-containing inks, coatings, adhesives and cleaning 

materials, cleaning up spills immediately. 

4.	 Convey VOC-containing inks, coatings, adhesives and cleaning materials from 

one location to another in closed containers or pipes. 

5.	 Minimize VOC emissions during cleaning of storage and conveying equipment. 

f.	 Measurements. Measurements of the volatile fraction of inks, and of volatile organic 

compound emissions shall be performed according to the applicable procedures 

established in § 2107.04 of this Article. 

9
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ALL NEW TEXT
 

§ 2105.82 CONTROL OF VOC EMISSIONS FROM INDUSTRIAL SOLVENT 

CLEANING OPERATIONS 

a.	 Applicability. Beginning January 1, 2012, this section applies to the owner or operator 

of a facility, where the total actual VOC emissions from all of the industrial solvent 

cleaning operations at that facility are equal to or greater than 15 pounds (6.8 kilograms) 

per day or 2.7 tons (2,455 kilograms) per twelve month rolling period. This regulation 

applies to any facility that employs solvent materials in industrial solvent cleaning 

operations during the production, repair, maintenance, or servicing of parts, products, 

tools, machinery, equipment, or general work areas, and stores and/or disposes of these 

solvent materials. 

The provisions of this rule shall not apply to cleaning operations in the following source 

categories listed for regulation under Section 183(e) of the Clean Air Act: 

1.	 Aerospace coatings; 

2.	 Wood furniture coatings; 

3.	 Shipbuilding and repair coatings; 

4.	 Flexible package printing materials; 

5.	 Lithographic printing materials; 

6.	 Letterpress printing materials; 

7.	 Flat wood paneling coatings; 

8.	 Large appliance coatings; 

9.	 Metal furniture coatings; 

10.	 Paper, film, and foil coatings; 

11.	 Plastic parts coatings; 

12.	 Miscellaneous metal parts coatings; 

13.	 Fiberglass boat manufacturing materials; 

14.	 Miscellaneous industrial adhesives; or 

15.	 Auto and light-duty truck assembly coatings. 

b.	 Limitations. A person may not cause or permit the emission into the outdoor
 

atmosphere of VOCs from industrial solvent cleaning operations unless one of the
 

following limitations is met:
 

1.	 The solvent complies with the applicable VOC Content Limitation Table 2105.82; 

10
 
 

 

 

 

 

 

2.	 The owner or operator of a facility that is subject to this rule shall employ only the 

following cleaning devices and methods: 

A.	 Wipe cleaning; 

B.	 Closed containers or hand held spray bottles from which solvents are 

applied without a propellant-induced force; 

C.	 Cleaning equipment which has a solvent container that can be and is 

closed during cleaning operations, except when depositing and removing 

objects to be cleaned, and is closed during non-operation with the 

exception of maintenance and repair to the cleaning equipment itself; 

D.	 Remote reservoir cleaner, if the operator of the cleaner complies with all 

of the following: 

i.	 Prevents solvent vapors from escaping from the solvent container 

by using such devices as a cover or a valve when the remote 

reservoir is not being used, cleaned or repaired. 

ii. Directs solvent flow in a manner that will prevent liquid solvent 

from splashing outside of the remote reservoir cleaner. 

iii. Does not clean porous or absorbent materials, such as cloth, 

leather, wood or rope. 

iv. Uses only solvent containers free of all liquid leaks. Auxiliary 

equipment, such as pumps, pipelines or flanges, shall not have any 

liquid leaks, visible tears or cracks. Any liquid leak, visible tear or 

crack detected shall be repaired within one calendar day, or the 

leaking section of the remote reservoir cold cleaner shall be 

drained of all solvent and shut down until it is replaced or repaired. 

E.	 Non-atomized solvent flow method where the cleaning solvent is collected 

in a container or a collection system which is closed except for solvent 

collection openings and, if necessary, openings to avoid excessive 

pressure build-up inside the container; or 

F.	 Solvent flushing method where the cleaning solvent is discharged into a 

container which is closed except for solvent collection openings and, if 

necessary, openings to avoid excessive pressure build-up inside the 

container. The discharged solvent from the equipment must be collected 

into containers without atomizing into the open air. The solvent may be 

flushed through the system by air or hydraulic pressure or by pumping. 

11
 
 

 

 

 

 

 

 

 

 

 

3.	 The owner or operator of a facility that is subject to this rule is prohibited from 

atomizing any solvent unless the emissions are vented to VOC emission control 

equipment that meet the requirements of Paragraph b.5 of this rule. 

4.	 All VOC containing solvents used in solvent cleaning operations shall be stored in 

non-absorbent, non-leaking containers which shall be kept closed at all times 

except when filling or emptying. Cloth and paper moistened with VOC 

containing solvents shall be stored in closed, non-absorbent, non-leaking 

containers. 

5.	 In lieu of complying with the requirements of Paragraphs b.1 and b.2 of this rule 

for an industrial solvent cleaning operation, the owner or operator of a facility that 

is subject to this rule may comply with this rule by installing and operating VOC 

emission control equipment for the industrial solvent cleaning operation. The 

VOC emission control equipment shall comply with all of the following 

requirements: 

A.	 A capture efficiency of at least 90 percent, by weight, for the VOC 

emissions. 

B.	 Either a destruction/removal efficiency of at least 95 percent, by weight, 

for the VOC emissions, or an outlet concentration of less than 20 ppmv, 

on a dry basis, for the VOC emissions. 

7.	 In lieu of complying with the requirements in Paragraph b.1 of this rule, the 

owner or operator of a facility may use solvents or solvent solutions for industrial 

cleaning operations which have a VOC composite partial vapor pressure of less 

than or equal to 8mm of Hg at 68°F (20°C). 

c.	 Records. A facility, regardless of the facility’s annual emission rate, which is subject to 

any of the VOC content limitations specified in this rule, shall maintain records sufficient 

to demonstrate compliance with this section. At a minimum, a facility shall maintain 

daily records of: 

1.	 The following parameters for each industrial solvent cleaner and other component 

as supplied: 

A.	 The name and identification number of each industrial solvent cleaning 

material and the associated industrial cleaning activity; 

B.	 The volume of each solvent used in the industrial solvent cleaning 

operation; 

C.	 The total volume of all the solvents used in the industrial solvent cleaning 

operation; 

D.	 The mix ratio; 

E.	 The density or specific gravity; 

12
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

F.	 The VOC content, based upon applicable procedures established in 

§ 2107.04 of this Article, of each industrial solvent cleaning material, as 

employed or the VOC composite partial vapor pressures of the solvents or 

solvent solutions used in the industrial solvent cleaning operation. 

2.	 The VOC content of each industrial solvent cleaner as supplied. 

3.	 The VOC content of each industrial solvent cleaner as applied. 

The records shall be maintained for 2 years and shall be submitted to the Department on a 

schedule reasonably prescribed by the Department. 

d.	 Exempt Solvents. The solvents methyl chloroform (1,1,1-trichloroethane) and 

methylene chloride are exempt from control under this Section. No industrial solvent 

cleaning operation which seeks to comply with this Section through the use of an exempt 

solvent may be included in any alternative standard approved pursuant to this Article. 

e.	 Exempt Other. The following industrial solvent cleaning operations shall be exempt 

from the limitations set by Subsection b: 

1.	 The following industrial solvent cleaning operations are exempt from all the 

requirements of this rule: 

A.	 Janitorial cleaning, including graffiti removal. 

B.	 Stripping of cured coatings, cured ink, or cured adhesives. 

C.	 Cleaning operations in printing pre-press or graphic arts pre-press areas, 

including the cleaning of film processors, color scanners, plate processors, 

film cleaning and plate cleaning. 

2.	 The following industrial solvent cleaning operations are exempt from the VOC 

content limitations specified in Paragraph b.1 of this rule: 

A.	 Cleaning of solar cells, laser hardware, scientific instruments and high 

precision optics. 

B.	 Cleaning conducted as part of the following: performance laboratory tests 

on coatings, adhesives or inks; research and development programs; and 

laboratory tests in quality assurance laboratories. 

C.	 Cleaning of paper-based gaskets and clutch assemblies where rubber is 

bonded to metal by means of an adhesive. 

D.	 Cleaning of cotton swabs to remove cottonseed oil before cleaning of high 

precision optics. 

E.	 Medical device and pharmaceutical facilities using up to 1.5 gallons 

(5.7 Liters) per day of solvents. 

F.	 Cleaning of adhesive application equipment used for thin metal 

laminating. 

G.	 Cleaning of electronic or electronic cables. 

13
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

H.	 Touch-up cleaning performed on printed circuit boards where surface 

mounted devices have already been attached. 

I.	 Cleaning of coating and adhesive application processes utilized to 

manufacture transdermal drug delivery product using less than three 

gallons per day of ethyl acetate. 

J.	 Cleaning of application equipment used to apply coatings on satellites and 

radiation effect coatings. 

K.	 Cleaning of application equipment used to apply solvent borne 

fluoropolymer coatings. 

L.	 Cleaning of ultraviolet or electron beam adhesive application. 

M.	 Cleaning of sterilization indicating ink application equipment if the 

facility employs less than 1.5 gallons (5.7 Liters) per day of solvents for 

such cleaning. 

N.	 Cleaning of metering rollers, dampening rollers and printing plates. 

O.	 Cleaning of polyester resin application equipment for sources subject to 

40 CRF Part 63, Subpart WWWW. 

3.	 The following industrial solvent cleaning operations are exempt from the 

requirements of Paragraph b.3 of this rule: 

A.	 Cleaning of the nozzle tips of automated spray equipment systems, except 

for robotic systems. 

B.	 Cleaning with spray bottles or containers described in Subparagraph b.2.B 

of this rule. 

C.	 Printing operations where the roller shall be exempt from the requirements 

of Paragraphs b.1 and b.3 of this rule if the facility employs 1.25 gallons 

[one hundred sixty fluid ounces (4.7 Liters)] or less of the aerosol products 

per day. 

f.	 Housekeeping. The following work practices for cleaning materials apply to the owner 

or operator of an industrial solvent cleaning operation: 

1.	 Store all VOC-containing cleaning materials and used shop towels in closed 

containers. 

2.	 Ensure that mixing and storage containers used for industrial solvent cleaning 

operations are kept closed at all times except when depositing or removing those 

materials. 

3.	 Minimize spills of VOC-containing industrial solvent cleaners, and cleaning 

materials, cleaning up spills immediately. 

4.	 Convey VOC-containing industrial solvent cleaners and cleaning materials from 

one location to another in closed containers or pipes. 

5.	 Minimize VOC emissions during cleaning of storage and conveying equipment. 

14
 
 

 

g.	 Measurements. Measurements of the volatile fraction of industrial solvent cleaners, and 

of volatile organic compound emissions shall be performed according to the applicable 

procedures established in § 2107.04 of this Article. 

15
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 2105.82 

Emission Limits of VOCs for Industrial Solvent Cleaning Operations 

VOC Content Limitation as employed 

Industrial Solvent Cleaning Operation lbs VOC per gal kg VOC per liter 

1.	 Product cleaning during manufacturing 

process or surface preparation for coating, 

adhesive, or ink application 

(a) General	 0.42 0.050 

(b) Electrical apparatus components and 0.83 0.099 

electronic components 

(c) Medical devices and pharmaceuticals 6.7	 0.80 

2.	 Repair and maintenance cleaning 

(a) General	 0.42 0.050 

(b) Electrical apparatus components and 0.83 0.099 

electronic components 

(c) Medical devices and pharmaceuticals 

(i) Tools, equipment and machinery 6.7	 0.80 

(ii) General work surfaces 5.0	 0.60 

3.	 Cleaning of coating or adhesive 0.42 0.050 

4.	 Cleaning of ink application equipment: 

(a) General	 0.42 0.050 

(b) Flexographic printing	 0.42 0.050 

(c) Gravure printing 

(i) Publication	 0.83 0.099 

(ii) Packaging	 0.42 0.050 

(d) Screen printing	 4.2 0.50 

(e) Ultraviolet ink and electron beam ink 4.2 0.50 

application equipment, except screen printing 

(f) Specialty flexographic printing 0.83	 0.099 

5.	 Cleaning of polyester resin application equipment 0.42 0.050 

not subject to 40 CRF Part 63 Subpart WWWW 

16
 
 

 

 

 

 

2. Technical Support Document 

Summary of Change 

The changes to these sections of Article XXI add three Control Techniques Guidelines (CTG) 

categories as three regulations. Changes were also made to an existing regulation, adding 

subsection f. Exempt Other. 

§2105.11, Graphic Arts Systems (SIP Change);
 

§2105.80 Control of VOC Emissions from Offset Lithographic Printing and
 

Letterpress Printing (SIP Change);
 

§2105.81 Control of VOC Emissions from Flexible Package Printing (SIP Change);
 

§2105.82 Control of VOC Emissions from Industrial Solvent Cleaning Operations
 

(SIP Change)
 

The CTG categories for Offset Lithographic Printing and Letterpress Printing, Flexible Package 

Printing, and Industrial Cleaning Solvents were issued by the EPA in 2006. The EPA has 

mandated that these CTGs become regulations, written by Local or State Air Pollution Control 

Agencies. 

The regulation changes to section §2105.11, and the addition of regulations §2105.80, §2105.81 

and §2105.82 to Article XXI constitute a change to the Allegheny County portion of the 

Pennsylvania State Implementation Plan (SIP) for the control of ozone with respect to those 

sections. 

17
 
 

 

3. Documentation of Public Hearing and Certifications 

Notice of Public Hearing
 

Transmittals of hearing notice to EPA & PA DEP
 

Proof of publication of notice of hearing
 

Certification of hearing
 

Summary of Comments and responses
 

Certification of approval and adoption
 

18
 
 

 

 

 

 

 

NOTICE OF PUBLIC HEARING
 

FOR PROPOSED AMENDMENTS TO
 

ALLEGHENY COUNTY HEALTH DEPARTMENT RULES AND REGULATIONS
 

ARTICLE XXI, AIR POLLUTION CONTROL
 

The Allegheny County Board of Health will hold a public hearing on Friday, August 20, 2010, 

at 10:00 AM, Building #7 First Floor Conference Room, Clack Health Center, 301 39th Street, 

Pittsburgh, PA 15201 to take testimony on the following proposed modifications to Allegheny 

County Health Department Article XXI and County Ordinance 16782: 

Revision to or addition of the following Article XXI sections as they relate to Control 

Techniques Guidelines: 

§2105.11, Graphic Arts Systems; 

§2105.80, Control of VOC Emissions from Offset Lithographic Printing and Letterpress 

Printing; 

§2105.81, Control of VOC Emissions from Flexible Package Printing; 

§2105.82, Control of VOC Emissions from Industrial Solvent Cleaning Operations. 

The proposed changes to §2105.11 and the additional regulations §2105.80, 

§2105.81, §2105.82, will be incorporated as a revision to Allegheny County’s portion 

of the Pennsylvania State Implementation Plan for the control of ozone. 

Copies of the proposed amendments may be examined beginning Tuesday, July 20, 2010, at the 

Allegheny County Law Library, Room 921 City-County Building, Grant Street, Pittsburgh, PA 

15219, from 8:30 AM to 5:00 PM; at the Allegheny County Health Department Library, 

Building 7, Clack Health Center, from 8:30 AM until 3:30 PM Monday thru Friday; on the 

Allegheny County Health Department web site: www.achd.net; or by calling 412-578-8120 to 

request a mailed printed copy. 

Oral testimony must be pre-scheduled by calling 412-578-8008 no less than 24 hours in advance 

of the public hearing. Speakers will be limited to five minutes and should bring a written copy 

of their comments. 

The Board will accept written testimony beginning Tuesday, July 20, 2010, and concluding 

Friday, August 20, 2010, by mail to: 

Board of Health 

3333 Forbes Avenue 

Pittsburgh, PA 15213 

By email to BOH@achd.net 

By Fax to 412-578-8325 

19
 
/SIGNED/
 

20
 
/SIGNED/
 

21
 
/SIGNED/
 

22
 
23
 

No._ 1'cm'··------

Proof of Publicarion of Notice In Pitlsburgh l'osr-C:ozctte 

Vl'ldc:r Aa No 587. Approved May 16, 1~9~ PL 178-l. ns Ja5-t nm~nded by l No 409 o(Septcmbef'29. 19S1 

C,..,mrt~~;lm•ullh of Pwn9~1 ... auua .. Couury of All~h<-ny, ss ....£.,:\.t(lhmmtd , bt'11'11 Jul)' •wOtn, d~ i('l!>et a~ la)'l th.tt the 

Plftlbut&b Pott+O.u.cuc. n nt"'~Sp.IP¢1'" Of$CR<r:lt c:•rc:l.fhi!IOI\ puhliWed •n tbe Cuy 01 Utl1urjl;l~. Cc>.mt)' lind Cflll\lt)an'"-leahb a((!l~1d, W&S 

ctcitblr1flltd .,, 1'99l by I be. mt1gu1g or tbt Pittsb1.111;h Post·GIIzeuc 11 nd Sun· I t legrlf)h tliiCS 'flle Ptnibut,h ~ •od the: Pi&ll>bWJ,b POR· 

o .. .t(IIC and ~uo- fclc~mpb Wll$ ~bhshoed In J96() ~~~d th<t Pin.sbu(i)t Post..ODUCie wu Cl(lb-I•~C'd •n 19n b)' the mtrjpftl of lhe 

rlnabura.h Ci t.CU~ CJI.olblltbcd in 17'&6 nnd the Pi&Uburc;h Ptnt~ t$(.1bb$h«< m 1842' $111(0 14'h•Ch date lhe UJd P'eastll,ltJ;}I Pa..-G~uttc llu 

beoD ~aul11rty iuutd m 4-ll•d ('.ounty " 1h:u a copy of SAid pri11ted noticr Of pubUC-ItU(MI •• IMlKhed httt1o c:qctly ulhe Mmt \11"21$ 

pnnled and publiJhet.l '" dle n: 'at odlltOn$ •nd ""l.ltt of the t.1'd Pti1JbiiiP PQ\.t.Q.azcck .1 

l'lt'~llilptJ o1,eenl!•·•l dreuiutlot\ on the foUowing da!cs, viz: 

~or J\•'l· nao 

Afli:tnt l\utht'1 cleSK*'f tiiJII tte/$he •S ar. agent for lhe PG Pub)i!!;blng Company, • eorpcnaoo ltt'd pobh~ of the Pt&Ubw-P Pou.oamw .. 

l)\.al1 US I\!Oh •KCJII, flll"i.lnt IJ dl.l1)' IIUthor1v:d to \'tnfy lhe fore~UIJ SQ1tflte'OI uJWr t'tlftl. thM .rf'LU'II tt; IOIIOIC::MI~ G.-.~~ m.at~a 

u1 th.: •lore ' n•d OOI•t:e ar publication. and tbo1 an allegauons i:n lk ior-<"gOJOC sttllftatllt as to IJnW". plate .and chlrx1rr of Jlllbi.C:tUOD An 

"'" c 

• fti ........ C~ 

s .. oro 10 lllld ~~btd bdm-rtc t.ltit 41y of 

July IS.lOIO 

~fQ!$c.;ll 

~u <iaefl"lEI( ~t.~a,.,Ptboc 

Cc,OI PC$t:u~n., lo~CV_,'Y 

M'"fCo'n!lUSivt"'~ll$ Jll~ l\ 201, 

STATEMENT Of ADVEJ!TtStNG COSTS 

ALCTY HBALTH-LEG~-PORBES AVE 

.TANBT NORKUS 

3 333 PORBS:S AVB 

PITTSBURGH PA 1S213 

1 o PG PubllShi.ng COmp.'ID)' 

To1ot ----------Sl07,10 

Pu blisher'> Receipt for Advertising Costs 

•• 

• i>Ubilsher ol ll1e P111sbuijlh Post-Gazdte, an~ of g,:nernl ei!alilhOD, 

M the ofo'""'d ad,atwng .and pubhcanoo coSlS <!nd ccmfics !bat tM samt h:l•e 

Ki P';.Jbilllrfi.J. ~). • C«pon!»erJ. Pulthlfiloef of 

'-'t~ P0:-Galtnr.l. Nh"'iJ)Ia~ ~ Gttml Cttul.ltiM 

By 

-
24
 

Revision 68 

SIP Submittal for Control Techniques Guidelines (CTG) 

Certification of Hearing 

Shaun Vozar deposes and says that he is an Air Pollution Control Engineer n of the Air 

Quality Program of the Allegheny County Health Department and hereby certifies that a 

Public Hearing was held on August 20, 2010 on the proposed amendment to the County's 

portion of the Pennsylvania State Implementation Plan that would add three regulations 

to Anicle XXJ; the regulation revisions and SIP amendments address three CTG 

categories as three regulations: §2105.80 Control of VOC Emissions from Offset 

Lithographic Printing and Letterpress Printing Processes, §2105.81 Control of VOC 

Emissions from Flexible Package Printing, and §2105.82 Control of VOC Emissions 

from Industrial Solvent Cleaning Operations; changes were made to an existing 

regulation, §2105.11 Graphic Arts Systems, adding subsection f. Exempt Other; that the 

opportunity for written comments was given in accordance with the requirements of 40 

CFR 51.1 02; that notice of such hearing was given by publication in a newspaper of 

general circulation on July 15, 20 10; and to the best of his knowledge, belief and 

understanding, such proceedings were in full compliance with all applicable State and 

Federal laws, regulations, and other requirements. 

~\/, Shaun 

Air Pollution 

Vozar, 

Contro

~ l Engineer U 

Air Quality Program 

Allegheny County Health Department 

Date 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Comment and Response Document for the Proposed SIP Revision 68
 

Regulation Changes for Ozone Control Techniques Guidelines
 

August 20, 2010 Public Hearing
 

1.	 Comment: The strike-out of the existing Graphic Arts (GA) system regulation 

at 2105.11, would cause an existing facility that has publication 

rotogravure presses, along with other surface coating processes that 

have a potential to emit greater than or equal to 100 tpy would no 

longer be regulated because they are not covered by the new 

flexible package printing regulation, because their product is not 

flexible packages, it's magazines, or books, or etc. 

Commenter: Deborah Wehr, Pennsylvania Department of Environmental Protection 

Response: So there is no applicability gap, ACHD will not strike-out the existing 

Graphic Arts Systems regulation, §2105.11. ACHD will add a clause to 

§2105.11 Graphic Arts Systems, under new subsection f. Exempt Other. 

This clause will state that any owner or operator of a flexible package 

printing press subject to §2105.81 Control of VOC Emissions from 

Flexible Package Printing, is no longer subject to §2105.11 Graphic Arts 

Systems, and shall be subject to all subparagraphs of regulation §2105.81 

Control of VOC Emissions from Flexible Package Printing as of 

January 1, 2012. 

2.	 Comment: ACHD needs to change the Applicability Dates of the CTGs to coincide 

with the PADEP. 

Commenter: ACHD 

Response:	 The Applicability Dates were changed from April 1, 2011 to January 1, 

2012 to coincide with the PADEP. 

25
 
CERTIFICATION of APPROVAL and ADOPTION 

To the best of my information, and I certify that the 

Sections 21 2105.81 and 2105.82 to, and the amendments to Section 2105.11 

Article XXI, Rules and Regulations of the 

Pollution Control, and Ordinance No. 16782 of 

County Department, Air 

County of Allegheny, adopted by the 

Allegheny County Board of Health on May 20 ll, enacted by the Allegheny County Council on 

May 22, 2013 (Ordinance 14-13-0R), approved by the Allegheny County Chief Executive on 

May 29, 2013, and effective June 8, 2013, as a revision to the County's Portion of the 

Pennsylvania State Implementation Plan for the Attainment and Maintenance of the National 

Ambient Air Quality Standards, were duly and properly enacted as prescribed by the Local 

Health Administration Law and the Second Class County Charter Law, and as such, are fully and 

legally enforceable by the Allegheny County Health Department and the County of Allegheny as 

provided for by the within authority. 

Michael A. Parker 

Assistant Solicitor 

Allegheny County Health Department 

COMMONWEALTH OF PENNSYLVANIA) 

COUNTY OF ALLEGHENY ) ='----

, 2013, 

Michael A. Parker before me, the undersigned authority, satisfactorily 

proven to me to be the person whose name appears above, and did in my presence execute the 

above certification for the purposes contained therein. 

WHEREFORE, I have hereunto set my hand and official seal the 

NOTARIAl. SEAL 

JANET M NORKUS 

Public 

aou!nun CITY, AllEGHENY COUNTY 

My Commission 29, 2015