Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free.

Customer Service Hotline: 1-800-438-2474

DATE: 3/26/15

SUBJECT: Memo to the Docket: Approval and Promulgation of Air Quality Implementation 

Plans; Pennsylvania; Adoption of Control Techniques Guidelines for Offset 

Lithographic Printing and Letterpress Printing; Flexible Package Printing; and 

Adhesives, Sealants, Primers, and Solvents

FROM: Ellen Schmitt, Project Officer /s/ 

Office of Air Program Planning

TO: File for Docket EPA-R03-OAR-2015-0166

On Tuesday, February 3, 2015, Joseph Schulingkamp, on behalf of Ellen Schmitt, requested 

confirmation from Pennsylvania Department of Environmental Protection (PADEP) that certain 

definitions were not included in the State Implementation Plan (SIP) revision. In the State’s submittal 

letter, PADEP indicated that the proposed changes to the regulatory language to be incorporated into the 

SIP were contained in Annex A of the State’s proposed rulemaking notice. However, certain provisions 

of the proposed Annex A were revised based on comments received during the public comment period, 

and therefore incorporating the proposed Annex A would be inappropriate as these changes would be 

omitted. In addition, the Annex A contained in the State’s final form rulemaking contained definitions 

in the revised 25 Pa Code 121.1 that were not relevant to the proposed action. As described by Susan 

Hoyle, Air Quality Program Specialist of PADEP, these non-relevant definitions were included because 

the Pennsylvania Legislative Reference Bureau included these terms as “before” and “after” terms to 

give location to the terms and definitions that were to be added. Ms. Hoyle also stated that there was no 

reason for the EPA to approve these “before” and “after” terms into the Pennsylvania SIP.

A copy of the email conversation and the discussed attachment with in-line revisions are attached to this 

memo. A copy of the final regulations to be incorporated into the Pennsylvania SIP has been included 

in the “Incorporation by Reference” section of this docket. 

Attachments:

Email messages between Joseph Schulingkamp and Susan Hoyle; dated 2/3/15 4:32 PM, 2/5/15 6:35

PM, and 2/9/15 8:36 AM.

In-line revisions discussed in email messages.
1

Schulingkamp, Joseph

From: Schulingkamp, Joseph

Sent: Monday, February 09, 2015 8:36 AM

To: 'Hoyle, Susan'

Cc: Epps, Joyce; Furlan, Kristen M.; Van Orden, Dean; kdalal@pa.gov

Subject: RE: Offset Lith. SIP revision question

Categories: Record Saved - Shared

Susan,

Thanks for the clarification on those two definitions, I figured they were just before and after definitions to provide

placement.  As to the other three you mentioned, I figured those (in addition to some others I saw) weren’t part of the

pertinent regulations and were also ‘before’ and ‘after’ definitions, but since they’re already ‘in the SIP’ and they’re

exactly the same it really doesn’t matter if they are included or not.

In case you’re wondering why I bothered you with this, when we approve things into the SIP we incorporate something

by reference (typically an ‘as approved’ final regulation) as the state wishes it to appear in their SIP.  Since we here at

EPA are still stuck in the stone age, our paper dockets are what legally controls, so what ever gets put into the

“incorporate by reference” section of our rulemaking docket becomes part of the SIP.  (Some of our states provide an

entirely separate document in their SIP submittal that only has the “as approved final regulation to be incorporated into

the SIP” just so we don’t accidentally incorporate something by mistake.  This is generally the safest way to go, but we

can IBR the final rules like we have in the past for PA, the only problem is all that discussion, summary, response to

comments, and those ‘before’ and ‘after’ definitions all get incorporated as well, from a legal perspective)   

In this instance I figured PA wouldn’t want these two definitions in the SIP so I couldn’t put the final rule’s Annex A in our

IBR section, and I couldn’t put the proposed rule’s Annex A since there were a few things that changed in the final form

rule (but yes, the proposed rule did help me identify which definitions were ‘before’ and ‘after’ and which were

intended to be put in the SIP).  So here’s what I’ll do – I’ll take the word document I sent you (without “vehicle” and

“heavy duty diesel engine”) and use that for our IBR section.  All the other definitions that aren’t pertinent to the

regulations won’t matter since they’re already in the SIP, and this way it’ll be clear that only the added/revised portions

of the regs will be incorporated into the SIP.

I’m almost finished the draft proposal and technical support document so hopefully this will get published (relatively)

soon.  Thanks again for all your help!   

From: Hoyle, Susan [mailto:shoyle@pa.gov] 

Sent: Thursday, February 05, 2015 6:35 PM 

To: Schulingkamp, Joseph 

Cc: Epps, Joyce; Furlan, Kristen M.; Van Orden, Dean; kdalal@pa.gov 

Subject: RE: Offset Lith. SIP revision question 

Joe, 

Thank you for contacting me with your question concerning the PA DEP submittal of the offset 

lithography/flexible printing/adhesives SIP revision. 

I reviewed pages 1-8 of your attachment. 
2

The two terms and definitions, “heavy duty diesel engine” and “vehicle,” only appear in the offset 

lithography/flexible printing/adhesives SIP revision submittal because the Pennsylvania Legislative 

Reference Bureau included those terms in the Pennsylvania Bulletin final rulemaking Annex A as the 

“before” and “after” terms to give location to the terms and definitions that were added and revised in 

the offset lithography/flexible printing/adhesives final rulemaking. There is no reason for the EPA to 

approve these two terms into the Pennsylvania SIP for purposes of the offset lithography/flexible 

printing/adhesives SIP revision. 

Please note that the terms “limited access space,” “liquid service,” and “process” are also not part of 

the offset lithography/flexible printing/ adhesives SIP revision submittal. These three terms also only 

appear in the offset lithography/flexible printing/adhesives SIP revision submittal because the 

Pennsylvania Legislative Reference Bureau included those terms in the Pennsylvania Bulletin final 

rulemaking Annex A as the “before” and “after” terms to give location to the terms and definitions that 

were added and revised in the offset lithography/flexible printing/ adhesives final rulemaking. 

For reference, I have excerpted the paragraph from the transmittal letter that describes the material 

that should be included in the SIP revision. 

Proposed changes to regulatory language in the approved SIP for §§ 121.1, 129.51, 129.67, 129.77 and 130.703 are 

shown in the proposed rulemaking notice Annex A. Additions are noted in boldface text; deletions are noted with 

boldface and bracketed text. Changes from proposed language to final language for existing SIP language were made 

for § 121.1. These changes are described in the preamble to the final rulemaking under Section E, "Summary of 

Final-Form Rulemaking and Changes from Proposed to Final-Form Rulemaking. " No changes from proposed 

language to final language were made for §§ 129.51, 129.67, 129.77 and 130.703 

(44 Pa. B. 3929, 3951).

Please let me know if you have questions or if I can be of further assistance. 

Susan 

Susan Hoyle | Air Quality Program Specialist 

Environmental Protection | Air Quality 

Rachel Carson State Office Building 

400 Market Street | Hbg PA 17105 

Phone: 717.772.2329 | Fax: 717.772.2303 

www.dep.state.pa.us 

From: Schulingkamp, Joseph [mailto:Schulingkamp.Joseph@epa.gov] 

Sent: Tuesday, February 03, 2015 4:32 PM 

To: Hoyle, Susan 

Subject: Offset Lith. SIP revision question 

Hi Susan,

I have a quick question for you about the offset lithography/flexible printing/adhesives SIP revision that I’ve inherited

from Chris Cripps – (revising 121.1, 129.51, 67, 77, and 130.703, and adding new regs 129.67a and 67b).  I want to

clarify, for the record, that PA does not intend for certain definitions from 121.1 to be included in the PA SIP.
3

As I was looking through the definitions listed for 121.1 of PA’s final rule (44 PaB 3929) and comparing them to what’s

currently “in the SIP” I noticed that 2 of the definitions in Annex A of the final rule aren’t currently “in the SIP” (‘heavy‐

duty diesel engine’ and ‘vehicle’).  I also noticed that other various definitions listed in the final rule were in the SIP and

there were no changes – these aren’t really a problem since they would just be “re‐SIPPed” as is.  The problem really is

just those 2 definitions since they aren’t currently in the SIP.   

The way the SIP revision was submitted EPA would “SIP” the Annex A portion of the final rule, (including the 2

definitions).  I assume including these 2 definitions in the SIP is not what PA would like done, so attached I’ve copied the

Annex A portion of the final rule into a word document and struckout the various definitions in 121.1 that I believe PA

would not want in this SIP revision.  All the definitions that are struck out, except the previously mentioned 2 are already

“in the SIP” and don’t necessarily have to be added again.  The 2 definitions I mentioned are NOT in the SIP, and unless

PA would like to add them now, they should not be included in the SIP revision.

Please confirm that pages 1‐8 of this attachment are the correct definitions of 121.1 that PA would like to include in the

SIP (assuming you agree with my tracked changes).  Sorry for pestering you about this, but I didn’t want to just

incorporate the entire Annex A into the SIP if that’s not what was meant to be done.  I’ll be out of the office tomorrow

but I’ll be back on Thursday, so just let me know if you have any questions!

Joe

Joseph Schulingkamp, EIT 

Air Program Planning Office 

EPA Region III 

(215) 814-2116
TITLE 25. ENVIRONMENTAL PROTECTION

PART I. DEPARTMENT OF ENVIRONMENTAL PROTECTION

Subpart C. PROTECTION OF NATURAL RESOURCES

ARTICLE III. AIR RESOURCES

CHAPTER 121. GENERAL PROVISIONS

§ 121.1. Definitions.

The definitions in section 3 of the act (35 P. S. § 4003) apply to this article. In addition, the 

following words and terms, when used in this article, have the following meanings, unless the 

context clearly indicates otherwise:

* * * * *

Airtight cleaning system—A solvent cleaning machine that is automatically operated and seals 

at a differential pressure no greater than 0.50 psig, prior to the introduction of solvent or solvent 

vapor into the cleaning chamber and during all cleaning and drying cycles.

Alcohol—A chemical compound consisting of the hydroxyl (OH) group attached to an alkyl 

radical and having the general formula CnH2n+1OH, such as ethanol, n-propanol and isopropyl 

alcohol.

Alcohol substitute—Nonalcohol additives that contain VOCs and are used in the fountain 

solution including ethylene glycol and glycol ethers. Some additives are used to reduce the 

surface tension of water and others are added to prevent piling (ink build up). 

Allegheny County air basin—Allegheny County.

* * * * *

As applied—

(i) The VOC and solids content of a coating, adhesive, sealant, adhesive primer, sealant 

primer, surface preparation solvent or cleanup solvent that is actually used to coat the substrate.

(ii) The term includes the contribution of materials used for in-house dilution of the coating.

(iii) For purposes of §§ 129.67a and 129.67b (relating to control of VOC emissions from 

flexible packaging printing presses; and control of VOC emissions from offset lithographic 

printing presses and letterpress printing presses), the VOC concentration of an ink, coating, 

adhesive, fountain solution or cleaning solution at the time it is actually used on a printing press.

As supplied—

(i) The VOC and solids content of a coating, adhesive, sealant, adhesive primer, sealant 

primer, surface preparation solvent or cleanup solvent as sold and delivered to the end user.
(ii) For purposes of §§ 129.67a and 129.67b, the VOC concentration of an ink, coating, 

adhesive, fountain solution or cleaning solution that is purchased for use on a printing press.

* * * * *

Baseline actual emissions—The rate of emissions, in tpy, of a regulated NSR pollutant, as 

determined in accordance with § 127.203a(a)(4) (relating to applicability determination).

Batch—

(i) For purposes of § 129.67b, a supply of fountain solution or cleaning solution that is 

prepared and used without alteration until completely used or removed from the printing process.

(ii) The term includes:

(A) A supply of fountain solution or cleaning solution prepared in a discrete amount.

(B) A supply of fountain solution that is continuously blended with an auto mix unit.

(C) A supply of cleaning solution that is blended and delivered to a press by use of an 

automatic blanket or roller wash system.

Batch vapor cleaning machine—

(i) A vapor cleaning machine in which individual parts or a set of parts move through the 

entire cleaning cycle before new parts are introduced into the cleaning machine.

(ii) The term includes solvent cleaning machines, such as ferris wheel cleaners or cross rod 

machines, that clean multiple loads simultaneously and are manually loaded.

(iii) The term does not include machines which do not have a solvent/air interface, such as 

airless and airtight cleaning systems.

* * * * *

CPDS—Certified Product Data Sheet—

(i) For purposes of wood furniture manufacturing operations under §§ 129.101—129.107 

(relating to wood furniture manufacturing operations), documentation furnished by a coating 

supplier or an outside laboratory for a coating, strippable spray booth coating or solvent that 

provides the VOC content as pounds of VOC per pound of coating solids calculated from data 

measured using the EPA Reference Method 24 or an equivalent or alternative method. Batch 

formulation data may be used if it is demonstrated to the satisfaction of the Administrator of the 

EPA that the coating does not release additional VOC as reaction byproducts during the cure. 

The VOC content stated should represent the maximum VOC emission potential of the coating, 

strippable spray booth coating or solvent.
(ii) For purposes of printing operations under § 129.67b, documentation furnished by an ink 

supplier or an outside laboratory for an ink, fountain solution, cleaning solution or solvent that 

provides the VOC content calculated from data measured using the EPA Reference Method 24 or 

an equivalent or alternative method approved by the Department. The VOC content stated should 

represent the maximum VOC emission potential of the ink, fountain solution, cleaning solution 

or solvent.

* * * * *

Cleaning operation—Spray-gun, hand-wipe and flush cleaning operations.

Cleaning solution—A liquid solvent or solution used to remove ink, including dried ink, and 

debris from the operating surfaces of a printing press and its parts. The term includes a blanket 

wash, impression cylinder wash, roller wash, metering roller cleaner, plate cleaner, rubber 

rejuvenator and other cleaners used for cleaning a press or press parts or to remove dried ink or 

coating from areas around the press.

Cleaning solvent—A liquid material used for hand-wipe spray gun or flush cleaning. The term 

includes solutions that contain VOCs.

* * * * *

Fleet average—For the purposes of motor vehicles subject to Pennsylvania's Clean Vehicles 

Program requirements, a motor vehicle manufacturer's average vehicle emissions of all NMOG 

emissions from vehicles which are produced and delivered for sale in this Commonwealth in any 

model year.

Flexible packaging—

(i) A package or part of a package, such as a bag, pouch, liner or wrap, the shape of which can 

be readily changed. Flexible packaging may be made of paper, plastic, film, aluminum foil, 

metalized or coated paper, metalized or coated film, or other material.

(ii) The term includes a shrink-wrap label or wrapper printed on or in-line with a flexible 

packaging printing press.

(iii) The term does not include folding cartons or other rigid packaging or self-adhesive 

labels.

Flexible packaging printing press—A printing press used for the production of printed flexible 

packaging materials using flexographic printing or rotogravure printing, or both.

Flexible primer—A primer applied to aerospace vehicles or components that meets flexibility 

requirements such as those needed for adhesive bond primed fastener heads or on surfaces 

expected to contain fuel. The flexible coating is required because it provides a compatible, 

flexible substrate over bonded sheet rubber and rubber-type coatings as well as a flexible bridge 
between the fasteners, skin and skin-to-skin joints on outer aircraft skins. This flexible bridge 

allows more topcoat flexibility around fasteners and decreases the chance of the topcoat cracking 

around the fasteners. The result is better corrosion resistance.

* * * * *

Fossil fuel fired—The combustion of fossil fuel or, if in combination with any other fuel, 

fossil fuel comprises 51% or greater of the annual heat input on a Btu basis.

Fountain solution—A mixture of water, volatile and nonvolatile chemicals and one or more 

additives that reduce the surface tension of the water so that the mixture spreads easily across the 

printing surface of a lithographic plate. The mixture wets the nonimage area so that the printing 

ink is maintained within the image area.

(i) Alcohols, specifically isopropyl alcohol, and alcohol substitutes, including ethylene glycol 

and glycol ethers, are the most common VOC additives used.

(ii) Nonvolatile additives include mineral salts and hydrophilic gums.

Freeboard ratio—

(i) For a cold cleaning machine or batch vapor cleaning machine, the distance from the liquid 

solvent in the idling mode to the top edge of the cleaning machine divided by the smaller 

dimension of the cleaning machine.

(ii) For an operating in-line vapor cleaning machine, the distance from the solvent/air 

interface to the bottom of the entrance or exit opening, whichever is lower, as measured during 

the idling mode.

* * * * *

Heat input—Heat derived from the combustion of fuel in a NOx affected source. The term 

does not include the heat derived from preheated combustion air, recirculated flue gas or exhaust 

from another source or combination of sources.

Heatset—An operation in which heat is required to evaporate ink oils from the printing inks 

that are applied to the substrate.

Heatset ink—Printing ink that is set and dried with the use of heat.

Heavy-duty diesel engine—A diesel engine that is used to propel a motor vehicle with a 

GVWR of greater than 14,000 pounds.

* * * * *

Commented [JS1]: This one is not in the current SIP
Lease custody transfer—The transfer of produced crude oil or condensate, after processing or 

treating in the producing operations, from storage tanks or automatic transfer facilities to 

pipelines or other forms of transportation.

Letterpress printing—A printing process in which the image area of the plate is raised relative 

to the nonimage area and the paste ink is transferred to the substrate directly from the image 

surface. The substrate can be fed to the press as either an individual sheet or a rolled web.

Limited access space—Internal surfaces or passages of an aerospace vehicle or component to 

which coatings cannot be applied without the aid of an airbrush or a spray gun extension for the 

application of coatings.

Liquid service—Equipment which processes, transfers or contains a VOC or mixture of VOCs 

in the liquid phase.

Lithographic plate—The plate used in lithographic or offset lithographic printing which has 

chemically differentiated image and nonimage areas so that the printing ink adheres to the image 

areas. 

Lithographic printing—A printing process in which the image and nonimage areas are in the 

same plane on the surface of a lithographic plate. The image and nonimage areas are chemically 

differentiated; the image area is oil receptive and the nonimage area is water receptive. The 

substrate can be fed to the press as either an individual sheet or a rolled web.

Low RVP gasoline—Gasoline that has an RVP of 7.8 pounds per square inch or less as 

determined in accordance with the appropriate sampling and testing methodologies in 40 CFR 

Part 80, Appendix E (relating to test for determining Reid vapor pressure (RVP) of gasoline and 

gasoline-oxygenate blends).

* * * * *

Noncommercial fuel—A gaseous or liquid fuel generated as a byproduct or waste product 

which is not specifically produced and manufactured for sale. A mixture of noncommercial and a 

commercial fuel oil where at least 50% of the heat content is derived from the noncommercial 

fuel portion is considered a noncommercial fuel.

Non-heatset—A lithographic or letterpress printing process in which the printing inks, 

including varnishes, are set and dried by absorption or oxidation of the ink oils rather than by 

evaporation with heat. These non-polymerization processes are also known as ''coldset'' 

processes. Polymerization processes including the use of an infrared dryer, ultraviolet curing or 

electron beam curing are also considered non-heatset operations.

Nonmembrane roof installation/repair adhesive—
(i) An adhesive intended by the manufacturer for use in the installation or repair of 

nonmembrane roofs and that is not intended for the installation of prefabricated single-ply 

flexible roofing membrane.

(ii) The term includes:

(A) Plastic or asphalt roof cement.

(B) Asphalt roof coating.

(C) Cold application cement.

* * * * *

OTC MOU—Ozone Transport Commission Memorandum of Understanding—The 

memorandum of understanding signed by representatives of ten states and the District of 

Columbia as members of the Ozone Transport Commission on September 27, 1994.

Offset lithographic printing—A printing process in which the image and nonimage areas are 

in the same plane on the surface of a lithographic plate and the image and nonimage areas are 

chemically differentiated. The ink film is transferred from the lithographic plate to an 

intermediary surface, typically a rubber-covered cylinder called a blanket, which in turn transfers 

the ink film to the substrate. The substrate can be fed to the press as either an individual sheet or 

a rolled web.

Offset vehicle—A light-duty vehicle which has been certified by California as set forth in 13 

CCR, Division 3, Chapter 1.

* * * * *

Paper, film or foil coating or paper, film or foil surface coating—Coatings applied in a 

continuous, uniform layer to paper, film or foil surfaces, and pressure-sensitive tapes, regardless 

of substrate. The coatings are applied to provide a covering, finish or functional or protective 

layer to the substrate, saturate a substrate for lamination or provide adhesion between two 

substrates for lamination.

(i) The term includes coatings used in web coating processes on the following substrates:

(A) Pressure sensitive tapes and labels, including fabric coated for use in pressure sensitive 

tapes and labels.

(B) Plastic and photographic films.

(C) Industrial and decorative laminates.

(D) Abrasive products, including fabric coated for use in abrasive products.
(E) Flexible packaging, including coating of nonwoven polymer substrates for use in flexible 

packaging, if the coating is not applied on or in-line with a flexible packaging printing press.

(F) Those used in miscellaneous coating operations, including the following:

* * * * *

Printed interior panel—A panel on which the grain or natural surface is obscured by filler and 

basecoat upon which a simulated grain or decorative pattern is printed.

Printing press—The equipment used to apply words, pictures or designs to a sheet or 

continuous substrate of paper, plastic or other material. The equipment must include at least one 

printing work station. The following equipment, if present, is also considered part of the term:

(i) One or multiple unwind or feed sections.

(ii) A series of individual work stations, which may include inboard and outboard work 

stations. A work station that employs another technology, including surface coating, is 

considered part of the printing press if the station is capable of printing or coating on the same 

substrate and if the work station is physically connected as part of the printing press.

(iii) A dryer associated with a work station.

(iv) A rewind, stack or collection section.

Process—A method, reaction or operation in which materials are handled or whereby 

materials undergo physical change—that is, the size, shape, appearance, temperature, state or 

other physical property of the material is altered—or chemical change—that is, a substance with 

different chemical composition or properties is formed or created. The term includes all of the 

equipment, operations and facilities necessary for the completion of the transformation of the 

materials to produce a physical or chemical change. There may be several processes in series or 

parallel necessary to the manufacture of a product.

* * * * *

Rotogravure printing—The application of words, designs and pictures to a substrate by means 

of a roll printing technique which involves an intaglio or recessed image area in the form of cells.

* * * * *

Sheet rubber installation—

(i) The process of applying sheet rubber liners by hand to metal or plastic substrates to protect 

the underlying substrate from corrosion or abrasion.

(ii) The term includes laminating sheet rubber to fabric by hand.
Sheet-fed printing—A printing process in which individual sheets of substrate are fed 

sequentially to the printing press.

Shutdown—For purposes of §§ 129.301—129.310, the period of time during which a glass 

melting furnace is taken from an operational to a non-operational status by allowing it to cool 

down from its operating temperature to a cold or ambient temperature as the fuel supply is turned 

off.

* * * * *

Vapor up control switch—A thermostatically controlled switch which shuts off or prevents 

condensate from being sprayed when there is no vapor. On in-line vapor cleaning machines, the 

switch also prevents the conveyor from operating when there is no vapor.

Varnish—For purposes of § 129.67b, an unpigmented offset lithographic ink which is used or 

applied on an offset lithographic printing press in the same manner as a pigmented offset 

lithographic ink. The term includes a heatset varnish, sheet-fed varnish and non-heatset varnish.

Vehicle—A highway vehicle powered by an internal combustion engine with fewer than nine 

seating positions for adults.

* * * * *

Waxy, heavy-pour crude oil—A crude oil with a pour point of 50°F or higher as determined by 

the American Society of Testing and Materials Standard D 97-66, ''Test for Pour Point of 

Petroleum Oils.''

Web printing—A printing process in which continuous rolls of substrate material are fed to the 

printing press and rewound or cut to size after printing.

Wet fastener installation coating—A primer or sealant applied to aerospace vehicles or 

components by dipping, brushing or daubing on fasteners which are installed before the coating 

is cured.

* * * * *

Commented [JS2]: Not in the current SIP