ENCLOSURE 1

COMMONWEALTH OF VIRGINIA

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION

PROVISIONS AFFECTED

REVISION C09

CONCERNING

VOC EMISSION STANDARDS, PRINTING

(9VAC5 CHAPTER 40)

Adoption Date: June 19, 2015

Effective Date: February 1, 2016

The following table lists the specific provisions of the attached regulations that will be 

used to implement the State Implementation Plan (SIP). Highlighted provisions are 

included for information purposes only and are not to be construed as part of the 

Commonwealth's SIP, nor are any provisions directly related to the highlighted 

provisions to be considered as part of the SIP. A copy of the actual regulation 

submitted for approval and incorporation by reference into the Virginia SIP is included 

in Enclosure 2; details concerning the specific provisions that are not to be included in 

the Virginia SIP are noted in this copy.

CHAPTER 40 EXISTING STATIONARY SOURCES

PART II Emission Standards

ARTICLE 53 EMISSION STANDARDS FOR LITHOGRAPHIC PRINTING

PROCESSES (RULE 4-53)

9VAC5-40-7800 Applicability and designation of affected facility (modified)

ARTICLE 56 EMISSION STANDARDS FOR LETTERPRESS PRINTING

OPERATIONS IN THE NORTHERN VIRGINIA VOLATILE 

ORGANIC COMPOUND EMISSIONS CONTROL AREA, 8-HOUR 

OZONE STANDARD (RULE 4-56)

9VAC5-40-8380 Applicability and designation of affected facility (added)

9VAC5-40-8382 Definitions (added)

9VAC5-40-8384 Standard for volatile organic compounds (added)

9VAC5-40-8386 Standard for visible emissions (added)

9VAC5-40-8388 Standard for fugitive dust/emissions (added)

9VAC5-40-8390 Standard for odor (added)

9VAC5-40-8394 Standard for toxic pollutants (added)

9VAC5-40-8396 Compliance (added)
9VAC5-40-8398 Compliance schedule (added)

9VAC5-40-8400 Test methods and procedures (added)

9VAC5-40-8410 Monitoring (added)

9VAC5-40-8412 Notification, records, and reporting (added)

9VAC5-40-8414 Registration (added)

9VAC5-40-8416 Facility and control equipment maintenance or malfunction (added)

9VAC5-40-8418 Permits (added)

ARTICLE 56.1 EMISSION STANDARDS FOR OFFSET LITHOGRAPHIC

PRINTING OPERATIONS IN THE NORTHERN VIRGINIA 

VOLATILE ORGANIC COMPOUND EMISSIONS CONTROL AREA, 

8-HOUR OZONE STANDARD (RULE 4-56.1)

9VAC5-40-8420 Applicability and designation of affected facility (added)

9VAC5-40-8422 Definitions (added)

9VAC5-40-8424 Standard for volatile organic compounds (added)

9VAC5-40-8426 Standard for visible emissions (added)

9VAC5-40-8428 Standard for fugitive dust/emissions (added)

9VAC5-40-8430 Standard for odor (added)

9VAC5-40-8432 Standard for toxic pollutants (added)

9VAC5-40-8434 Compliance (added)

9VAC5-40-8436 Compliance schedule (added)

9VAC5-40-8438 Test methods and procedures (added)

9VAC5-40-8440 Monitoring (added)

9VAC5-40-8450 Notification, records, and reporting (added)

9VAC5-40-8460 Registration (added)

9VAC5-40-8470 Facility and control equipment maintenance or malfunction (added)

9VAC5-40-8480 Permits (added)

TEMPLATES\SIP-REG\REG01

SIP\NONATTN PLANS\2016\C09-SIP-1.DOC
COMMONWEALTH OF VIRGINIA PAGE 1 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

9VAC5 CHAPTER 40

EXISTING STATIONARY SOURCES

PART II

Emission Standards

ARTICLE 53

Emission Standards for

Lithographic Printing Processes (Rule 4-53)

9VAC5-40-7800. Applicability and designation of affected facility.

A. Except as provided in subsections C, D, and E of this section, the affected 

facility to which the provisions of this article apply is each lithographic printing process 

which that uses a substrate other than a textile.

B. The provisions of this article apply only to sources of volatile organic 

compounds in volatile organic compound emissions control areas designated in 9VAC5-

20-206.

C. Exempted from the provisions of this article are facilities offset lithographic 

printing operations in the Northern Virginia Volatile Organic Compound Emissions Control 

Area whose potential to emit is less than 10 tons per year of volatile organic compounds, 

provided the emission rates are determined in a manner acceptable to the board. All 

volatile organic compound emissions from printing inks, coatings, cleaning solutions, and 

fountain solutions shall be considered in applying the exemption levels specified in this 

subsection. Provisions applicable to offset lithographic printing operations in the Northern 

Virginia Volatile Organic Compound Emissions Control Area are provided in Article 56.1

[ of this part ] (9VAC5-40-8420 et seq.) [ of this part ].

D. Exempted from the provisions of this article are facilities in all volatile organic 

compound emissions control areas, other than the Northern Virginia Volatile Organic 

Compound Emissions Control Area, whose potential to emit is less than 100 tons per 

year of volatile organic compounds, provided the emission rates are determined in a 

manner acceptable to the board. All volatile organic compound emissions from printing 

inks, coatings, cleaning solutions, and fountain solutions shall be considered in applying 

the exemption levels specified in this subsection.

E. The provisions of this article do not apply to the following:

1. Printing processes used exclusively for determination of product quality 

and commercial acceptance provided:

a. The operation is not an integral part of the production process;
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STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

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 equipment using waterbased chemistry to develop silver halide images.

3. Platemaking equipment using water-based chemistry 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 cylinder width of 26 inches 

or less.

ARTICLE 56

Emission Standards for Letterpress Printing Operations in the Northern Virginia Volatile 

Organic Compound Emissions Control Area, 8-hour Ozone Standard (Rule 4-56)

9VAC5-40-8380. Applicability and designation of affected facility.

A. The affected facility to which the provisions of this article apply is any letterpress 

printing operation at a stationary source where the actual emissions of volatile organic 

compounds (VOCs) from all aspects of letterpress printing operations, including related 

cleaning activities, before the consideration of controls, are equal to or exceed 3.0 tons 

per 12-month rolling period. 

B. The provisions of this article apply only to sources of VOCs located in the 

Northern Virginia VOC Emissions Control Area designated in subdivision 1 a of 9VAC5-

20-206.

9VAC5-40-8382. Definitions.

A. For the purpose of applying this article in the context of the regulations for the 

control and abatement of air pollution and related uses, the words or terms shall have the 

meanings given them in subsection C of this section.

B. Unless otherwise required by context, all terms not defined in this section shall 

have the meanings given them in 9VAC5-170 (Regulation for General Administration), 

9VAC5-10 (General Definitions), or commonly ascribed to them by recognized 

authorities, in that order of priority.
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STATE AIR POLLUTION CONTROL BOARD

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C. Terms defined.

"Cleaning materials" means any washes, cleaners, solvents, or rejuvenators 

that are used to remove excess printing inks, oils, and residual paper from a press, press 

equipment, or press parts, or used to remove dried ink from areas around a press. 

Cleaning materials include solvents and cleaners used for manual cleaning, and cleaning 

solutions used by automatic cleaning systems such as roller wash and type wash. 

Cleaning materials do not include cleaners used for cleaning electronic components of a 

press, pre-press cleaning operations (e.g., platemaking), post-press cleaning operations 

(e.g., binding), cleaning supplies such as detergents used to clean the floor (other than to 

remove dried ink from areas around a press), and cleaning performed in parts washers 

and cold cleaners subject to Article 47 (9VAC5-40-6820 et seq.) of Part II of 9VAC5-40 

(Existing Stationary Sources).

"Composite partial vapor pressure" means the sum of the partial pressures 

of the compounds defined as volatile organic compounds. Composite partial vapor 

pressure is calculated as follows:

where:

Wi = Weight of the "i"th VOC compound, in grams.

Ww = Weight of water, in grams.

We = Weight of exempt compound, in grams.

MWi = Molecular weight of the "i"th VOC compound, in grams/gram-mole.

MWw = Molecular weight of water, in grams/gram-mole.

MWe = Molecular weight of exempt compound, in grams/gram-mole.

PPc = VOC composite partial pressure at 20°C, in millimeters of mercury (mm Hg).

VPi = Vapor pressure of the "i"th VOC compound at 20°C, in mm Hg.

"First installation date" means the date that a control device is first installed 

for the purpose of controlling emissions. The first installation date does not change if the 

control device is later moved to a new location or installed on a different press. 
COMMONWEALTH OF VIRGINIA PAGE 4 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

"Heatset" means a printing process in which heat from a dryer is used to 

evaporate ink oils from the substrate.

"Letterpress printing" means a printing process in which the image area is 

raised relative to the nonimage area and paste ink is transferred to the substrate 

directly from the image surface.

"Letterpress printing operation" means one or more [ letterpress ] printing 

processes employing letterpress printing on [ letterpress ] printing presses and the 

related processes necessary to directly support the operation of those presses 

including, but not limited to, cleaning, pre-press, and post-press operations. 

"Non-heatset" means a printing process in which the printing inks are set 

and dried by absorption or oxidation rather than heat. For the purposes of this article, UVcured and electron beam-cured inks are considered non-heatset.

"Press" means a printing production assembly composed of one or more 

units to produce a printed substrate (sheet or web).

"Printing" means a photomechanical process in which a transfer of text, 

designs, and images occurs through contact of an image carrier with a substrate.

"Printing process" means any operation or system wherein printing ink or a 

combination of printing ink and surface coating is applied, dried, or cured and that is 

subject to the same emission standard. A printing process may include any equipment 

that applies, conveys, dries, or cures inks or surface coatings, including, but not limited to, 

flow coaters, flashoff areas, [ air presses, digital output devices, heaters, ] dryers, drying 

areas, and ovens.

"Sheet-fed" means a printing process in which individual sheets of substrate 

are fed into the press sequentially.

"Theoretical potential to emit" means for the purposes of this article the 

maximum capacity of a letterpress printing process to emit VOC and shall be based on 

emissions at design capacity or maximum production and maximum operating hours 

(8,760 hours/year) before add-on controls, unless the [ heatset web offset lithographic

letterpress ] printing process is subject to state and federally enforceable permit 

conditions that limit production rates or hours of operation.

"12-month rolling period" means a period that is determined monthly and 

consists of the previous 12 consecutive calendar months.

"Unit" means [ for the purposes of this article ] the smallest complete 
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STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

printing component, composed of an inking [ and dampening ] system, of a [ letterpress ] 

printing press.

"VOC" means volatile organic compound.

"Web" means a continuous roll of printing substrate.

9VAC5-40-8384. Standard for volatile organic compounds.

A. No owner or other person shall use or permit the use of any letterpress printing 

press, letterpress printing process, or other letterpress printing operation that is subject to 

this article unless that press, process, or operation meets the requirements of this section.

B. The following provisions apply to each dryer on each heatset web letterpress 

printing process, except that these provisions do not apply to (i) any heatset web 

letterpress printing process with a theoretical potential to emit less than 25 tons per year 

of VOC [ (petroleum ink oil) ] from the dryer, prior to controls; (ii) any heatset web 

letterpress printing process used exclusively for book printing; or (iii) any heatset web 

letterpress printing process with a maximum web width of 22 inches or less. These 

provisions also do not apply to non-heatset web letterpress printing processes or to 

sheet-fed letterpress printing processes.

1. VOC emissions from the heatset web letterpress printing process dryer 

shall be controlled as follows:

a. The dryer shall operate at a lower air pressure than the pressroom 

air pressure at all times when the printing process is operating;

b. Exhaust air from the dryer shall be collected and sent to a control 

device that operates at all times when the printing process is operating.

c. For a control device whose first installation date is prior to [ (insert 

effective date of this article) February 1, 2016 ], the control device shall reduce VOC 

emissions in the dryer air exhaust by at least 90%.

d. For a control device whose first installation date is on or after 

[ (insert effective date of this article) February 1, 2016 ], the control device shall reduce 

VOC emissions in the dryer air exhaust by at least 95%. 

2. Where the heatset web letterpress printing process control device inlet 

VOC concentration is too low to achieve the control device efficiency requirements 

specified in subdivisions 1 c and 1 d of this subsection or there is no identifiable 

measurable inlet, the control device shall reduce the VOC concentration of the heatset 

web letterpress printing process dryer exhaust air to 20 parts per million volume (ppmv) or 
COMMONWEALTH OF VIRGINIA PAGE 6 of 26

STATE AIR POLLUTION CONTROL BOARD

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less, as hexane on a dry basis.

3. Federally enforceable limitations on (i) the VOC [ (petroleum ink oil) ] 

content of inks and coatings applied [ prior to the dryer ] , (ii) the total amounts of inks and 

coatings applied, (iii) the press application rates of inks and coatings, or (iv) the hours of 

press operation may be used to meet the 25 ton per year exception to this subsection. 

C. Cleaning materials used at each letterpress printing operation shall meet one 

of the following limits, as applied [ , except that 110 gallons of cleaning materials that 

meet neither limit may be used per 12-month rolling period ]:

1. A VOC content of 70% by weight; or

2. A composite vapor pressure of 10 mm Hg at 20°C.

[ The use of cleaning materials not meeting the limits in subdivision 1 or 2 of this 

subsection is permitted provided that the quantity of cleaning material used does not 

exceed 110 gallons over any 12-month rolling period. ]

D. The following work practices shall be implemented:

1. Cleaning materials, inks, and coatings containing VOCs shall be kept in 

closed containers at all times unless filling, draining, or performing cleaning operations.

2. Shop towels, sponges and other manual cleaning aids (i) that have 

been used for picking up excess ink and other coatings containing VOCs or (ii) that 

have been used with cleaning materials containing VOCs shall be kept in closed 

containers.

3. Spills of cleaning materials, fountain solution, inks, varnishes, and other 

coatings containing VOCs shall be minimized and shall be cleaned up promptly. 

9VAC5-40-8386. Standard for visible emissions.

The provisions of Article 1 (9VAC5-40-60 et seq.) of Part II of 9VAC5-40 (Existing 

Stationary Sources) apply.

9VAC5-40-8388. Standard for fugitive dust/emissions.

The provisions of Article 1 (9VAC5-40-60 et seq.) of Part II of 9VAC5-40 (Existing 

Stationary Sources) apply.

9VAC5-40-8390. Standard for odor.
COMMONWEALTH OF VIRGINIA PAGE 7 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

The provisions of Article 2 (9VAC5-40-130 et seq.) of Part II of 9VAC5-40 (Existing 

Stationary Sources) apply.

9VAC5-40-8394. Standard for toxic pollutants.

The provisions of Article 4 (9VAC5-60-200 et seq.) of Part II of 9VAC5-60 

(Hazardous Air Pollutant Sources) apply.

9VAC5-40-8396. Compliance.

A. The provisions of 9VAC5-40-20 (Compliance) apply.

B. [ An If requested by the board, an ] emission test of the control device installed 

on a heatset web letterpress printing process dryer shall be performed to demonstrate 

compliance with the provisions of 9VAC5-40-8384 B [ and 9VAC5-40-8398 ] . The 

negative dryer pressure shall be established during the initial test using an airflow 

direction indicator, such as a smoke stick or aluminum ribbons, or a differential 

pressure gauge. [ The board may accept the results of an emission test conducted prior 

to February 1, 2016 if the owner or operator provides information and data that 

demonstrate that the test demonstrated compliance with the provisions of 9VAC5-40-

8384 B. ]

C. [ Once initial compliance has been demonstrated with the heatset web 

letterpress printing process dryer control requirements of 9VAC5-40-8384 B through 

performance testing of an catalytic or thermal oxidation control device, continuing

Continuing ] compliance with the heatset web letterpress printing process dryer control 

requirements in 9VAC5-40-8384 B shall be demonstrated for the catalytic or thermal 

oxidation control device by monitoring the control device in accordance with 9VAC5-40-

8410 B. The owner shall maintain the [ 3-hour three-hour ] average of the monitored 

temperature at a temperature no less than 50°F below the [ 3-hour three-hour ] average 

temperature that was recorded during the most recent performance test during which 

compliance was demonstrated. [ In the absence of performance test results acceptable 

to the board that provide dryer control device temperatures that demonstrate continuing 

compliance with the requirements in 9VAC5-40-8384 B, control device temperatures that 

demonstrate compliance with manufacturer recommendations may be considered by the 

board to demonstrate compliance with heatset web offset letterpress printing process 

dryer control requirements in 9VAC5-40-8384 B. ]

[ D. A portion of the volatile organic compounds contained in inks and cleaning 

solution is retained in the printed web and in the shop towels used for cleaning. When 

applicable, the following retention factors may be used in determining volatile organic 

compounds emissions from letterpress printing operations:

1. A 20% volatile organic compound retention factor may be used for 
COMMONWEALTH OF VIRGINIA PAGE 8 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

petroleum ink oils contained in heatset inks that are printed on absorptive substrates, 

meaning that 80% of the VOC (petroleum ink oil) in the ink is emitted during the printing 

process and is available for capture and control by an add-on pollution control device.

2. A 100% volatile organic compound retention factor may be used for 

vegetable ink oils contained in heatset inks that are printed on absorptive substrates, 

meaning that none of the VOC (vegetable ink oil) in the ink is emitted during the printing 

process and available for capture and control by an add-on pollution control device.

3. A 95% volatile organic compound retention factor may be used for 

petroleum ink oils contained in sheet-fed and non-heatset web inks printed on 

absorptive substrates, meaning that 5.0% of the VOC (petroleum ink oil) in the ink is 

emitted during the printing process.

4. A 100% volatile organic compound retention factor may be used for 

vegetable ink oils contained in sheet-fed and non-heatset web inks printed on 

absorptive substrates, meaning that none of the VOC (vegetable ink oil) in the ink is 

emitted during the printing process.

5. A 50% volatile organic compound retention factor may be used for 

cleaning solution VOC in shop towels for those cleaning solutions with a volatile organic 

compounds composite vapor pressure of no more than 10 millimeters of mercury (Hg) 

at 20°C (68°F) provided that the cleaning materials and used shop towels are kept in 

closed containers. 

E. A portion of the volatile organic compounds contained in inks is captured for 

control by add-on air pollution control equipment. When applicable, the following 

capture efficiencies may be used in determining volatile organic compounds emissions 

from letterpress printing operations:

1. A 100% volatile organic compound capture efficiency may be used for 

VOC (petroleum ink oils) from oil-based paste inks and oil-based paste varnishes 

(coatings) when the dryer is demonstrated to be operating at negative pressure relative 

to the surrounding pressroom.

2. Conventional letterpress inks and varnishes are paste-type materials. If 

other types of inks or coating materials are used on a letterpress press (e.g., fluid inks 

or coatings), capture efficiency testing shall be conducted for the VOC from these other 

materials if the printer wants to take into account the effect that the dryer controls have 

on VOC emissions from these other types of inks or coatings. ]

9VAC5-40-8398. Compliance schedule.

The owner shall comply with the provisions of this article as expeditiously as 
COMMONWEALTH OF VIRGINIA PAGE 9 of 26

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REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

possible but in no case later than [ (insert a date corresponding to the first day of the 

12th month after the effective date of this article) February 1, 2017 ].

9VAC5-40-8400. Test methods and procedures.

A. The provisions of 9VAC5-40-30 (Emission testing) apply.

B. The following EPA test methods shall be used to demonstrate compliance 

with the heatset web letterpress printing process dryer control device control 

requirements in 9VAC5-40-8384 B. 

1. Reference Method 1 or 1A, as appropriate, shall be used to select the 

sampling sites. 

2. Reference Method 2, 2A, 2C, or 2D, as appropriate, shall be used to 

determine the velocity and volumetric flow rate of the exhaust stream.

3. Reference Method 3 or 3A, as appropriate, shall be used to determine 

the concentration of O2 and CO2.

4. Reference Method 4 shall be used to determine moisture content.

5. Reference Methods 18, 25, or 25A shall be used to determine the VOC 

concentration of the dryer exhaust stream entering and exiting the control device, 

unless the alternate limit in 9VAC5-40-8384 B 2 is being met, in which case only the 

VOC concentration of the dryer exhaust control device outlet shall be determined. 

6. Reference Method 25A shall be used to determine the dryer exhaust 

control device inlet and outlet VOC concentrations when the control device outlet 

concentration is less than 50 [ ppmv parts per million volume (ppmv) ] VOC as carbon.

7 If the control device is an oxidizer, the combustion chamber temperature 

or catalyst bed inlet temperature corresponding to destruction efficiencies that meet the 

requirements of 9VAC5-40-8384 B shall be recorded. 

C. The VOC content of as-applied inks, coatings, and cleaning materials shall be 

determined using Reference Method 24.

1. The analysis of as-supplied materials may be performed by the 

manufacturer or the supplier. Formulation information from the manufacturer may be 

used in lieu of Reference Method 24 analysis unless the board or the owner has reason 

to believe that the formulation information provided by the manufacturer is inaccurate. 

2. The owner may use VOC content information provided by the 
COMMONWEALTH OF VIRGINIA PAGE 10 of 26

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REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

manufacturer or supplier, such as the container label, the product data sheet, or the [ 

MSDS sheet Safety Data Sheet (SDS) ] to document the VOC content of the assupplied material.

3. If cleaning materials are diluted by the owner prior to use, a calculation 

that combines the as-supplied VOC content information provided by the manufacturer 

or supplier, the VOC content of the diluent, and the proportions in which they are mixed 

may be used to make a determination of VOC content of the as-applied cleaning 

material in lieu of Reference Method 24.

4. The owner shall conduct Reference Method 24 testing of any asapplied cleaning material used for letterpress printing operations at any time at the 

board's request. The owner shall be prepared to sample as-applied fountain solution or 

cleaning materials at all times.

D. The VOC composite partial vapor pressure of cleaning solutions shall be 

determined using the formula provided in 9VAC5-40-8382 C or by an appropriate test 

method approved by the board.

1. The determination VOC composite partial vapor pressure for assupplied cleaning solutions may be performed by the manufacturer or the supplier. The 

determination of as-applied composite vapor pressure based upon the manufacturer's 

instructions for dilution may be performed by the manufacturer or supplier.

2. The owner may use VOC composite partial vapor pressure information 

provided by the manufacturer or supplier, such as the container label, the product data 

sheet, or the [ Material Safety Data Sheet (MSDS) Safety Data Sheet (SDS) ] to 

document the VOC composite partial vapor pressure of the as-supplied or as-applied 

cleaning materials.

3. The following provisions apply to the determination of VOC composite 

partial vapor pressure for cleaning materials that are diluted by the owner prior to use:

a. If the dilution is made according to the manufacturer's 

instructions, the VOC composite partial vapor pressure for the as-applied cleaning 

material provided by the manufacturer or supplier may be used.

b. If a dilution is made and an as-applied VOC composite partial 

vapor pressure has not been provided by the manufacturer or supplier, or if the dilution 

is not made according to the manufacturer's instructions, then the owner shall 

determine the VOC composite partial vapor pressure using the calculation method 

provided in 9VAC5-40-8382 C or by an appropriate test method approved by the board.

4. The owner shall conduct testing of any as-applied cleaning materials 
COMMONWEALTH OF VIRGINIA PAGE 11 of 26

STATE AIR POLLUTION CONTROL BOARD

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used for letterpress printing operations at any time at the board's request. The owner 

shall be prepared to sample as-applied cleaning materials at all times.

9VAC5-40-8410. Monitoring.

A. The provisions of 9VAC5-40-40 (Monitoring) apply.

B. Periodic monitoring of letterpress printing operations shall be conducted as 

follows:

1. The temperature of a catalytic or thermal oxidation control device shall 

be monitored at least once every 15 minutes while the printing process is operating, 

and that temperature shall be recorded by an analog or digital recording device.

a. For a catalytic oxidizer, the dryer exhaust temperature upstream 

of the catalyst bed shall be monitored and recorded.

b. For a thermal oxidizer, the combustion chamber temperature of 

the oxidizer shall be monitored and recorded.

2. Catalyst bed material in a catalytic oxidation control device shall be 

inspected annually for general catalyst condition and any signs of potential catalyst 

depletion. Sampling and evaluation of the catalyst bed material shall be conducted 

whenever the results of the inspection indicate signs of potential catalyst depletion or 

poor catalyst condition based on manufacturer's recommendations, but not less than 

once per year.

3. If a heatset web letterpress printing process is interlocked to ensure 

that the control device is operating and airflow is present when the printing process is 

operating, then periodic monitoring of dryer air flow is not required. If no interlock is 

present, then the printing process dryer air flow shall be verified and recorded once per 

operating day.

9VAC5-40-8412. Notification, records, and reporting.

The provisions of 9VAC5-40-50 (Notification, records and reporting) apply.

9VAC5-40-8414. Registration.

The provisions of 9VAC5-20-160 (Registration) apply.

9VAC5-40-8416. Facility and control equipment maintenance or malfunction.

The provisions of 9VAC5-20-180 (Facility and control equipment maintenance or 
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malfunction) apply.

9VAC5-40-8418. Permits.

A permit may be required prior to beginning any of the activities specified [ below in 

this section ] if the provisions of 9VAC5-50 (New and Modified Stationary Sources) and 

9VAC5-80 (Permits for Stationary Sources) apply. Owners contemplating such action 

should review those provisions and contact the appropriate regional office for guidance on

whether those provisions apply.

1. Construction of a facility.

2. Reconstruction (replacement of more than half) of a facility.

3. Modification (any physical change to equipment) of a facility.

4. Relocation of a facility.

5. Reactivation (re-startup) of a facility.

6. Operation of a facility.

ARTICLE 56.1

Emission Standards for Offset Lithographic Printing Operations in the Northern Virginia 

Volatile Organic Compound Emissions Control Area, 8-hour Ozone Standard (Rule 4-

56.1)

9VAC5-40-8420. Applicability and designation of affected facility.

A. The affected facility to which the provisions of this article apply is any offset 

lithographic printing operation at a stationary source where the actual emissions of 

volatile organic compounds (VOCs) from all aspects of offset lithographic printing 

operations, including related cleaning activities, before the consideration of controls are 

equal to or exceed 3.0 tons per 12-month rolling period. 

B. The provisions of this article apply only to sources of VOCs located in the 

Northern Virginia VOC Emissions Control Area designated in subdivision 1 a of 9VAC5-

20-206.

9VAC5-40-8422. Definitions.

A. For the purpose of applying this article in the context of the regulations for the 

control and abatement of air pollution and related uses, the words or terms shall have the 
COMMONWEALTH OF VIRGINIA PAGE 13 of 26

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meanings given them in subsection C of this section.

B. Unless otherwise required by context, all terms not defined in this section shall 

have the meanings given them in 9VAC5-170 (Regulation for General Administration), 

9VAC5-10 (General Definitions), or commonly ascribed to them by recognized 

authorities, in that order of priority.

C. Terms defined.

"Alcohol" means any of the following compounds when used as a fountain 

solution additive: ethanol, n-propanol, and isopropanol.

"Alcohol substitute" means any nonalcohol additive that contains volatile 

organic compounds and is used in the fountain solution.

"Batch" means a supply of fountain solution [ or cleaning solution ] that is 

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

process.

"Cleaning materials" means any washes, cleaners, solvents, or rejuvenators 

that are used to remove (i) excess printing inks, oils, and residual paper from a press, 

press equipment, or press parts or (ii) dried ink from areas around a press. Cleaning 

materials include solvents and cleaners used for manual cleaning and cleaning solutions 

used by automatic cleaning systems such as blanket wash, plate cleaner, metering roller 

cleaner, impression cylinder washes, rubber rejuvenators, and roller wash. Cleaning 

materials do not include cleaners used for cleaning electronic components of a press, 

pre-press cleaning operations (e.g., platemaking), post-press cleaning operations (e.g., 

binding), cleaning supplies such as detergents used to clean the floor (other than to 

remove dried ink from areas around a press), and cleaning performed in parts washers 

and cold cleaners subject to Article 47 (9VAC5-40-6820 et seq.) of Part II of 9VAC5-40

(Existing Stationary Sources). 

"Composite partial vapor pressure" means the sum of the partial pressures 

of the compounds defined as volatile organic compounds. Composite partial vapor 

pressure is calculated as follows:

where:

Wi = Weight of the "i"th VOC compound, in grams.
COMMONWEALTH OF VIRGINIA PAGE 14 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

Ww = Weight of water, in grams.

We = Weight of exempt compound, in grams.

MWi = Molecular weight of the "i"th VOC compound, in grams/gram-mole.

MWw = Molecular weight of water, in grams/gram-mole.

MWe = Molecular weight of exempt compound, in grams/gram-mole.

PPc = VOC composite partial pressure at 20°C, in millimeters of mercury (mm Hg).

VPi = Vapor pressure of the "i"th VOC compound at 20°C, in mm Hg.

"First installation date" means the date that a control device is first installed 

for the purpose of controlling emissions. The first installation date does not change if the 

control device is later moved to a new location or installed on a different press. 

"Fountain solution" means any mixture of water, volatile and nonvolatile 

chemicals, and additives applied to a lithographic plate to repel ink from the nonimage 

area on the plate.

"Heatset" means a printing process in which heat from a dryer is used to 

evaporate ink oils from the substrate.

"Heatset web offset lithographic printing dryer" means the dryer or dryers 

installed as part of a heatset web offset lithographic printing process that dries [ or cures ] 

inks or surface coatings.

"Lithographic printing" means a planographic printing process in which the 

image and nonimage areas are chemically differentiated with the image area being oil 

receptive and the nonimage area being water receptive. This process differs from other 

printing processes, where the image is a raised or recessed surface.

"Non-heatset" means a printing process in which the printing inks are set 

and dried by absorption or oxidation rather than heat. For the purposes of this article, UVcured and electron beam-cured inks are considered non-heatset.

"Offset lithographic printing" means a printing process that transfers the 

ink film from the lithographic plate to an intermediary surface (blanket), which, in turn, 

transfers the ink film to the substrate.
COMMONWEALTH OF VIRGINIA PAGE 15 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

"Offset lithographic printing operation" means one or more printing 

processes employing offset lithographic printing on [ offset lithographic ] printing 

presses and includes the related processes necessary to directly support the operation 

of those offset lithographic printing processes including, but not limited to, pre-press 

and post-press operations. Varnishes, glues, and other coatings that are applied by an 

offset lithographic printing process are part of offset lithographic printing operations and 

are not considered as a separate process (e.g., paper coating). 

"Press" means a printing production assembly composed of one or more 

units to produce a printed substrate (sheet or web).

"Printing" means a photomechanical process in which a transfer of text, 

designs, and images occurs through contact of an image carrier with a substrate.

"Printing process" means any operation or system wherein printing ink or a 

combination of printing ink and surface coating is applied, dried, or cured and that is 

subject to the same emission standard. A printing process may include any equipment 

that applies, conveys, dries, or cures inks or surface coatings, including, but not limited to, 

flow coaters, flashoff areas, [ air presses, digital output devices, fountain solutions, 

heaters, ] dryers, drying areas, and ovens.

"Sheet-fed" means a printing process in which individual sheets of substrate 

are fed into the press sequentially.

"Theoretical potential to emit" means for the purposes of this article the 

maximum capacity of a heatset web offset lithographic printing process to emit VOC and 

shall be based on emissions at design capacity or maximum production and maximum 

operating hours (8,760 hours/year) before add-on controls, unless the heatset web offset 

lithographic printing process is subject to state and federally enforceable permit 

conditions that limit production rates or hours of operation.

"12-month rolling period" means a period that is determined monthly and 

consists of the previous 12 consecutive calendar months.

"Unit" means the smallest complete printing component, composed of an 

inking [ and dampening ] system, of a printing press.

"VOC" means volatile organic compound.

"Web" means a continuous roll of printing substrate.

9VAC5-40-8424. Standard for volatile organic compounds.

A. No owner or other person shall use or permit the use of any offset lithographic 
COMMONWEALTH OF VIRGINIA PAGE 16 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

printing press, offset lithographic printing process, or other offset lithographic printing 

operation that is subject to this article unless that press, process, or operation meets the 

requirements of this section.

B. Except as provided in subdivision 3 of this subsection, the following provisions 

apply to each heatset offset lithographic printing process at a facility whose potential to 

emit is greater than or equal to 10 tons per year of VOC, provided that the emission rates 

are determined in a manner acceptable to the board. All VOC emissions from printing 

inks, coatings, cleaning solutions, and fountain solutions shall be considered in 

determining the potential to emit for this subsection.

1. VOC emissions from the heatset web offset lithographic printing process 

dryer shall be controlled as follows:

a. The dryer shall operate at a lower air pressure than the pressroom 

air pressure at all times when the printing process is operating.

b. Exhaust air from the dryer shall be collected and sent to a control 

device that operates at all times when the printing process is operating.

c. The control device shall reduce VOC emissions in the dryer air 

exhaust by at least 90%.

2. Where the heatset web offset lithographic printing process control device 

inlet VOC concentration is too low to achieve the control device efficiency requirements 

specified in [ subdivisions subdivision ] 1 c of this subsection or there is no identifiable 

measurable inlet, the control device shall reduce the VOC concentration of the heatset 

web offset lithographic printing process dryer exhaust air to 50 parts per million volume 

(ppmv) or less, as carbon (minus methane and ethane).

3. The provisions in subdivisions 1 and 2 of this subsection do not apply to 

the following:

a. Any heatset web offset lithographic printing process with a 

theoretical potential to emit of 25 tons per year of VOC [ (petroleum ink oil) ] or more from 

the heatset web offset lithographic printing dryer. VOC standards for heatset web offset 

lithographic printing process with a theoretical potential to emit of 25 tons per year of VOC 

[ (petroleum ink oil) ] or more are provided in subsection C of this section. 

b. Printing processes used exclusively for determination of product 

quality and commercial acceptance provided:

(1) The operation is not an integral part of the production 

process;
COMMONWEALTH OF VIRGINIA PAGE 17 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

(2) The emissions from all product quality printing processes 

do not exceed 400 pounds in any 30-day period; and

(3) The exemption is approved by the board.

c. Photoprocessing, typesetting, or imagesetting equipment using 

water-based chemistry to develop silver halide images.

d. Platemaking equipment using water-based chemistry to remove 

unhardened image-producing material from an exposed plate.

e. Equipment used to make blueprints.

f. Any sheet-fed offset lithographic press with a cylinder width of 26 

inches or less.

C. Except as provided in subdivisions [ 3, ] 4 [ , ] and 5 of this subsection, the 

following provisions apply to each heatset web offset lithographic printing process with a 

theoretical potential to emit of 25 tons per year of VOC [ (petroleum ink oil) ] or more from 

the dryer. These provisions do not apply to non-heatset web offset lithographic printing 

processes or to sheet-fed offset lithographic printing processes.

1. VOC emissions from the heatset web offset lithographic printing process 

dryer shall be controlled as follows:

a. The dryer shall operate at a lower air pressure than the pressroom 

air pressure at all times when the printing process is operating.

b. Exhaust air from the dryer shall be collected and sent to a control 

device that operates at all times when the printing process is operating.

c. For a control device whose first installation date is prior to [ (insert 

effective date of this article) February 1, 2016 ], the control device shall reduce VOC 

emissions in the dryer air exhaust by at least 90%.

d. For a control device whose first installation date is on or after 

[ (insert effective date of this article) February 1, 2016 ], the control device shall reduce 

VOC emissions in the dryer air exhaust by at least 95%.

2. Where the heatset web offset lithographic printing process control device 

inlet VOC concentration is too low to achieve the control device efficiency requirements 

specified in subdivisions 1 c and 1 d of this subsection or there is no identifiable 

measurable inlet, the control device shall reduce the VOC concentration of the heatset 
COMMONWEALTH OF VIRGINIA PAGE 18 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

web offset lithographic printing process dryer exhaust air to 20 parts per million volume 

(ppmv) or less, as hexane on a dry basis.

3. Federally enforceable limitations on (i) the VOC [ (petroleum ink oil) ]

content of inks, varnishes, and other coatings applied [ prior to the dryer ] ; (ii) the total 

amounts of inks, varnishes, and other coatings applied; (iii) the press application rates of 

inks, varnishes, and other coatings; or (iv) the hours of press operation may be used to 

meet the 25 ton per year exception to this subsection. 

4. The provisions of subdivisions 1 and 2 of this subsection do not apply to 

(i) any heatset web offset lithographic printing process constructed on or [ (insert effective 

date of this article) February 1, 2016 ] and used exclusively for book printing, or (ii) any 

heatset web offset lithographic printing process constructed on or after [ (insert effective 

date of this article) February 1, 2016 ] with a maximum web width of 22 inches or less. 

5. The heatset web offset lithographic printing process dryer control device 

provisions of subdivision 1 d of this subsection do not apply to (i) any heatset web offset 

lithographic printing process used exclusively for book printing; or (ii) any heatset web 

offset lithographic printing process with a maximum web width of 22 inches or less.

D. The following provisions shall apply to fountain solution applied to each offset 

lithographic printing press, except that these provisions shall not apply to (i) sheet-fed 

offset lithographic printing processes with a sheet size of 11 inches by 17 inches or 

smaller or (ii) sheet-fed offset lithographic printing processes with a total fountain solution 

reservoir of less than one gallon.

1. For each heatset web press:

a. When the fountain solution contains alcohol:

(1) The fountain solution, as applied, shall contain no more 

than 1.6% volatile organic compounds by weight; or

(2) The temperature of the fountain solution shall be 

maintained at or below 60°F and the fountain solution, as applied, shall contain no more 

than 3.0% VOCs by weight; or

b. When the fountain solution contains no alcohol, the fountain 

solution, as applied, shall contain no more than 5.0% VOCs by weight.

2. For each non-heatset web press, the fountain solution, as applied, shall 

contain no alcohol and shall contain no more than 5.0% VOCs by weight.

3. For each sheet-fed press:
COMMONWEALTH OF VIRGINIA PAGE 19 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

a. The fountain solution, as applied, shall contain no more than 5.0% 

VOCs by weight; or

b. The temperature of the fountain solution shall be maintained at or 

below 60°F and the fountain solution, as applied, shall contain no more than 8.5% VOCs 

by weight.

E. Cleaning materials used at each offset lithographic printing operation shall 

meet one of the following limits, as applied:

1. A VOC content of 30% by weight; or

2. A composite vapor pressure of 10 mm Hg at 20°C (68°F).

[ The use of cleaning materials not meeting the limits in subdivision 1 or 2 of this 

subsection is permitted provided that the quantity of cleaning material used does not 

exceed 110 gallons over any 12-month rolling period. ]

F. The following work practices shall be implemented.

1. Cleaning materials, fountain solution, inks, varnishes, and coatings 

containing VOCs shall be kept in closed containers at all times unless filling, draining, or 

performing cleaning operations.

2. Shop towels, sponges, and other manual cleaning aids that (i) have 

been used for picking up excess ink, fountain solution, varnishes, and other coatings 

containing VOCs or (ii) have been used with cleaning materials containing VOCs shall 

be kept in closed containers.

3. Spills of cleaning materials, fountain solution, inks, varnishes, and other 

coatings containing VOCs shall be minimized and shall be cleaned up promptly. 

9VAC5-40-8426. Standard for visible emissions.

The provisions of Article 1 (9VAC5-40-60 et seq.) of Part II of 9VAC5-40 (Existing 

Stationary Sources) apply.

9VAC5-40-8428. Standard for fugitive dust/emissions.

The provisions of Article 1 (9VAC5-40-60 et seq.) of Part II of 9VAC5-40 (Existing 

Stationary Sources) apply.

9VAC5-40-8430. Standard for odor.
COMMONWEALTH OF VIRGINIA PAGE 20 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

The provisions of Article 2 (9VAC5-40-130 et seq.) of Part II of 9VAC5-40 (Existing 

Stationary Sources) apply.

9VAC5-40-8432. Standard for toxic pollutants.

The provisions of Article 4 (9VAC5-60-200 et seq.) of Part II of 9VAC5-60 

(Hazardous Air Pollutant Sources) apply. 

9VAC5-40-8434. Compliance.

A. The provisions of 9VAC5-40-20 (Compliance) apply.

B. [ An If requested by the board, an ] emission test of the control device installed 

on a heatset web offset lithographic printing process dryer shall be performed to 

demonstrate compliance with the provisions of 9VAC5-40-8424 B and C [ and 9VAC5-40-

8436 ] . The negative dryer pressure shall be established during the initial test using an 

airflow direction indicator, such as a smoke stick or aluminum ribbons, or a differential 

pressure gauge. [ The board may accept the results of an emission test conducted prior 

to the compliance date specified in 9VAC5-40-8436 if the owner or operator provides 

information and data that demonstrate that the test demonstrated compliance with the

provisions of 9VAC5-40-8424 B and C. ] 

C. [ Once initial compliance has been demonstrated with the heatset web offset 

lithographic printing process dryer control requirements of 9VAC5-40-8424 B and C 

through performance testing of an catalytic or thermal oxidation control device, continuing

Continuing ] compliance with the heatset web offset lithographic printing process dryer 

control requirements in 9VAC5-40-8424 B and C shall be demonstrated for the catalytic 

or thermal oxidation control device by monitoring the control device in accordance with 

9VAC5-40-8440 B 3, B 4, and B 5. The owner shall maintain the [ 3-hour three-hour ]

average of the monitored temperature at a temperature no less than 50°F below the [ 3-

hour three-hour ] average temperature that was recorded during the most recent 

performance test during which compliance was demonstrated. [ In the absence of 

performance test results acceptable to the board that provide dryer control device 

temperatures that demonstrate continuing compliance with the requirements in 9VAC5-

40-8424 B and C, control device temperatures that demonstrate compliance with

manufacturer recommendations may be considered by the board to demonstrate 

compliance with heatset web offset lithographic printing process dryer control 

requirements in 9VAC5-40-8424 B and C. ] 

[ D. A portion of the volatile organic compounds contained in inks and cleaning 

solution is retained in the printed web and in the shop towels used for cleaning. When 

applicable, the following retention factors may be used in determining volatile organic 

compounds emissions from offset lithographic printing operations:
COMMONWEALTH OF VIRGINIA PAGE 21 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

1. A 20% volatile organic compound retention factor may be used for 

petroleum ink oils contained in heatset inks that are printed on absorptive substrates, 

meaning that 80% of the VOC (petroleum ink oil) in the ink is emitted during the printing 

process and is available for capture and control by an add-on pollution control device.

2. A 100% volatile organic compound retention factor may be used for 

vegetable ink oils contained in heatset inks that are printed on absorptive substrates, 

meaning that none of the VOC (vegetable ink oil) in the ink is emitted during the printing 

process and available for capture and control by an add-on pollution control device.

3. A 95% volatile organic compound retention factor may be used for 

petroleum ink oils contained in sheet-fed and non-heatset web inks printed on 

absorptive substrates, meaning that 5.0% of the VOC (petroleum ink oil) in the ink is 

emitted during the printing process.

4. A 100% volatile organic compound retention factor may be used for 

vegetable ink oils contained in sheet-fed and non-heatset web inks printed on 

absorptive substrates, meaning that none of the VOC (vegetable ink oil) in the ink is 

emitted during the printing process.

5. A 50% volatile organic compound retention factor may be used for 

cleaning solution VOC in shop towels for those cleaning solutions with a volatile organic 

compounds composite vapor pressure of no more than 10 millimeters of mercury (Hg) 

at 20°C (68°F) provided that the cleaning materials and used shop towels are kept in 

closed containers. 

E. A portion of the volatile organic compounds contained in inks, fountain 

solutions, and automatic blanket washes is captured for control by add-on air pollution 

control equipment. When applicable, the following capture efficiencies may be used in 

determining volatile organic compounds emissions from offset lithographic printing 

operations:

1. A 40% volatile organic compound capture efficiency may be used for 

automatic blanket washing when the VOC composite vapor pressure of the cleaning 

material is less than 10 millimeters of mercury (Hg).

2. A 70% volatile organic compound capture efficiency may be used for 

alcohol substitutes in fountain solutions.

3. A 100% volatile organic compound capture efficiency may be used for 

VOC (petroleum ink oils) from oil-based paste inks and oil-based paste varnishes 

(coatings) when the dryer is demonstrated to be operating at negative pressure relative 

to the surrounding pressroom.
COMMONWEALTH OF VIRGINIA PAGE 22 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

4. Conventional heatset lithographic inks and varnishes are paste-type

materials. If other types of inks or coating materials are used on a heatset lithographic 

press (e.g., fluid inks or coatings), capture efficiency testing shall be conducted for the 

VOC from these other materials if the printer wants to take into account the effect that 

the dryer controls have on VOC emissions from these other types of inks or coatings. ]

9VAC5-40-8436. Compliance schedule.

The owner shall comply with the provisions of this article as expeditiously as 

possible but in no case later than [ (insert a date corresponding to the first day of the 

12th month after the effective date of this article) February 1, 2017 ].

9VAC5-40-8438. Test methods and procedures.

A. The provisions of 9VAC5-40-30 (Emission testing) apply.

B. The following EPA test methods shall be used to demonstrate compliance 

with the heatset web offset lithographic printing process dryer control device control 

requirements in 9VAC5-40-8424 B and C. 

1. Reference Method 1 or 1A, as appropriate, shall be used to select the 

sampling sites. 

2. Reference Method 2, 2A, 2C, or 2D, as appropriate, shall be used to 

determine the velocity and volumetric flow rate of the exhaust stream.

3. Reference Method 3 or 3A, as appropriate, shall be used to determine 

the concentration of O2 and CO2.

4. Reference Method 4 shall be used to determine moisture content.

5. Reference Methods 18, 25, or 25A shall be used to determine the VOC 

concentration of the dryer exhaust stream entering and exiting the control device, 

unless the alternate limit in 9VAC5-40-8424 B 2 or C 2 is being met, in which case only 

the VOC concentration of the dryer exhaust control device outlet shall be determined. 

6. Reference Method 25A shall be used to determine the dryer exhaust 

control device inlet and outlet VOC concentrations when the control device outlet 

concentration is less than 50 [ ppmv parts per million volume (ppmv) ] VOC as carbon.

7 If the control device is an oxidizer, the combustion chamber temperature 

or catalyst bed inlet temperature corresponding to destruction efficiencies that meet the 

requirements of 9VAC5-40-8424 B or C, as appropriate, shall be recorded. 
COMMONWEALTH OF VIRGINIA PAGE 23 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

C. The VOC content of as-applied inks, varnishes and other coatings, fountain 

solutions, and cleaning materials shall be determined using Reference Method 24.

1. The analysis of as-supplied materials may be performed by the 

manufacturer or the supplier. Formulation information from the manufacturer may be 

used in lieu of Reference Method 24 analysis unless the board or the owner has reason 

to believe that the formulation information provided by the manufacturer is inaccurate. 

2. The owner may use VOC content information provided by the 

manufacturer or supplier, such as the container label, the product data sheet, or the [ 

MSDS sheet Safety Data Sheet (SDS) ] to document the VOC content of the assupplied material.

3. If fountain solution or cleaning materials are diluted by the owner prior 

to use, a calculation that combines the as-supplied VOC content information provided 

by the manufacturer or supplier, the VOC content of the diluent, and the proportions in 

which they are mixed may be used to make a determination of VOC content of the asapplied fountain solution or cleaning material in lieu of Reference Method 24.

4. The owner shall conduct Reference Method 24 testing of any asapplied fountain solution or cleaning material used for offset lithographic printing 

operations at any time at the board's request. The owner shall be prepared to sample 

as-applied fountain solution or cleaning materials at all times.

D. A thermometer or other temperature detection device capable of reading the 

temperature of the fountain solution to within 0.5°F shall be used to determine 

compliance with fountain solution temperature requirements in 9VAC5-40-8424 D.

E. The VOC composite partial vapor pressure of cleaning solutions shall be 

determined using the formula provided in 9VAC5-40-8422 C or by an appropriate test 

method approved by the board.

1. The determination VOC composite partial vapor pressure for assupplied cleaning solutions may be performed by the manufacturer or the supplier. The 

determination of as-applied composite vapor pressure based upon the manufacturer's 

instructions for dilution may be performed by the manufacturer or supplier.

2. The owner may use VOC composite partial vapor pressure information 

provided by the manufacturer or supplier, such as the container label, the product data 

sheet, or the [ Material Safety Data Sheet (MSDS) Safety Data Sheet (SDS) ] , to 

document the VOC composite partial vapor pressure of the as-supplied or as-applied 

cleaning materials.
COMMONWEALTH OF VIRGINIA PAGE 24 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

3. The following provisions apply to the determination of VOC composite 

partial vapor pressure for cleaning materials that are diluted by the owner prior to use:

a. If the dilution is made according to the manufacturer's 

instructions, the VOC composite partial vapor pressure for the as-applied cleaning 

material provided by the manufacturer or supplier may be used.

b. If a dilution is made and an as-applied VOC composite partial 

vapor pressure has not been provided by the manufacturer or supplier, or if the dilution 

is not made according to the manufacturer's instructions, then the owner shall 

determine the VOC composite partial vapor pressure using the calculation method 

provided in 9VAC5-40-8422 C.

4. The owner shall conduct testing of any as-applied cleaning materials 

used for offset lithographic printing operations at any time at the board's request. The 

owner shall be prepared to sample as-applied cleaning materials at all times.

9VAC5-40-8440. Monitoring.

A. The provisions of 9VAC5-40-40 (Monitoring) apply.

B. Periodic monitoring of offset lithographic printing operations shall be conducted 

as follows:

1. The alcohol concentration of offset lithographic printing process 

fountain solution shall be monitored with a hydrometer, equipped with temperature 

correction or with readings adjusted for temperature, and recorded at least once per 

shift or once per batch, whichever is longer. A standard solution shall be used to 

calibrate the hydrometer for the type of alcohol used in the fountain.

2. The temperature of refrigerated fountain solution shall be measured at 

the recirculating tank at least once per operating day.

3. The temperature of a catalytic or thermal oxidation control device shall 

be monitored at least once every 15 minutes while the printing process is operating, 

and that temperature shall be recorded by an analog or digital recording device.

a. For a catalytic oxidizer, the dryer exhaust temperature upstream 

of the catalyst bed shall be monitored and recorded.

b. For a thermal oxidizer, the combustion chamber temperature of 

the oxidizer shall be monitored and recorded.

4. Catalyst bed material in a catalytic oxidation control device shall be 
COMMONWEALTH OF VIRGINIA PAGE 25 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

inspected annually for general catalyst condition and any signs of potential catalyst 

depletion. Sampling and evaluation of the catalyst bed material shall be conducted 

whenever the results of the inspection indicate signs of potential catalyst depletion or 

poor catalyst condition based on manufacturer's recommendations, but not less than 

once per year.

5. If a heatset web offset lithographic printing process is interlocked to 

ensure that the control device is operating and airflow is present when the printing 

process is operating, then periodic monitoring of dryer air flow is not required. If no 

interlock is present, then the printing process dryer air flow shall be verified and 

recorded once per operating day.

9VAC5-40-8450. Notification, records, and reporting.

The provisions of 9VAC5-40-50 (Notification, records, and reporting) apply.

9VAC5-40-8460. Registration.

The provisions of 9VAC5-20-160 (Registration) apply.

9VAC5-40-8470. Facility and control equipment maintenance or malfunction.

The provisions of 9VAC5-20-180 (Facility and control equipment maintenance or 

malfunction) apply.

9VAC5-40-8480. Permits.

A permit may be required prior to beginning any of the activities specified [ below in 

this section ] if the provisions of 9VAC5-50 (New and Modified Stationary Sources) and 

9VAC5-80 (Permits for Stationary Sources) apply. Owners contemplating such action 

should review those provisions and contact the appropriate regional office for guidance on

whether those provisions apply.

1. Construction of a facility.

2. Reconstruction (replacement of more than half) of a facility.

3. Modification (any physical change to equipment) of a facility.

4. Relocation of a facility.

5. Reactivation (re-startup) of a facility.

6. Operation of a facility.
COMMONWEALTH OF VIRGINIA PAGE 26 of 26

STATE AIR POLLUTION CONTROL BOARD

REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION (9VAC5 CHAPTER 40)

TEMPLATES\NOIRA\REG-PRO

REG\DEV\C09-REG-FIN.DOC
1

ENCLOSURE 2

CERTIFICATION OF PUBLIC PARTICIPATION ACTIVITIES

AND COMPLIANCE WITH

STATE ADMINISTRATIVE PROCEDURES

As required by 40 CFR 51.102 and Section 2.1 of Appendix V of 40 CFR Part 51, the 

following information regarding public participation activities and compliance with state 

administrative procedures is provided.

PUBLIC PARTICIPATION ACTIVITIES

As required by 40 CFR Part 51.102(a), the public was given notice of the opportunity to 

submit written comments and attend a public hearing concerning a proposed revision to 

the Commonwealth of Virginia State Implementation Plan. The notice was provided in 

the Washington Times (for the National Capital Interstate Air Quality Control Region), 

along with the location of the proposal for public inspection, on January 12, 2015. The 

attached copy of the notice provides the evidence required by Section 2.1(f) of 

Appendix V of 40 CFR Part 51.

As required by 40 CFR 51.102(a), the hearing to accept public comment concerning the 

proposed revision was held at the Department of Environmental Quality, Northern 

Virginia Regional Office, 13901 Crown Court, Woodbridge Virginia, at 11:00 a.m. on 

February 26, 2015. As required by 40 CFR 51.102(f) and Section 2.1(g) of Appendix V 

of 40 CFR Part 51, the hearing was held in accordance with the information found in the 

public notice, and according to the state's laws and the requirements of 40 CFR 51.102.

The Regional Administrator for the U.S. Environmental Protection Agency was notified 

of the hearing, as was each local air pollution control agency which will be significantly 

affected by the revision and is located in the affected Air Quality Control Regions. In 

addition, the District of Columbia, Maryland and Tennessee, which share affected 

interstate Air Quality Control Regions with Virginia, were notified of the hearing. These 

notifications follow the requirements of 40 CFR Part 51.102(d)(3), (4) and (5).

COMPLIANCE WITH STATE ADMINISTRATIVE PROCEDURES

As required by Section 2.1(b) of Appendix V of 40 CFR Part 51, the regulation 

amendments were published in the Virginia Register of Regulations on November 30, 

2015 after being duly adopted by the State Air Pollution Control Board on June 19, 

2015, certified by the Office of the Attorney General as within the Board’s statutory 

authority on June 22, 2015 and thus fully enforceable under Virginia law, and submitted 

to the Virginia Registrar on behalf of the Board by the Department of Environmental 

Quality as a true and accurate copy of the duly adopted regulation on October 29, 
2

2015, providing the evidence required by Section 2.1(b) and (e) of Appendix V of 40 

CFR Part 51. As required by Section 2.1(d) of Appendix V of 40 CFR Part 51, a copy of 

the actual regulation submitted for approval and incorporation by reference into the 

Commonwealth of Virginia State Implementation Plan is attached, along with the 

effective date of February 1, 2016.

Only those provisions of the final regulation which are not marked out on the attached 

copy are to be considered part of the Virginia State Implementation Plan.

TEMPLATES\SIP-REG\REG02-PH-N

SIP\NONATTN PLANS\2016\C09-SIP-2.DOC

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a single coating application system and the coatings are the 

same type or perform the same function. Such averaging shall 

not exceed 24 hours.

D. Compliance determinations for control technologies not 

based on compliant coatings (i.e., coating formulation alone) 

shall be based on the applicable emission standards in 

9VAC5-40-8830 B and the procedures of 9VAC5-20-121.

9VAC5-40-8890. Compliance schedule.

The owner shall comply with the provisions of this article as 

expeditiously as possible but in no case later than [ (one year 

after the effective date of this article) February 1, 2017 ].

9VAC5-40-8900. Test methods and procedures.

The provisions of 9VAC5-40-30 (Emission Testing) apply. 

9VAC5-40-8910. Monitoring.

The provisions of 9VAC5-40-40 (Monitoring) apply. 

9VAC5-40-8920. Notification, records, and reporting.

The provisions of 9VAC5-40-50 (Notification, Records and 

Reporting) apply. 

9VAC5-40-8930. Registration.

The provisions of 9VAC5-20-160 (Registration) apply. 

9VAC5-40-8940. Facility and control equipment 

maintenance or malfunction.

The provisions of 9VAC5-20-180 (Facility and Control 

Equipment Maintenance or Malfunction) apply. 

9VAC5-40-8950. Permits.

A permit may be required prior to beginning any of the 

activities specified [ below in this section ] and the provisions 

of 9VAC5-50 (New and Modified Stationary Sources) and 

9VAC5-80 (Permits for Stationary Sources) may apply. 

Owners contemplating such action should contact the 

appropriate regional office for guidance.

1. Construction of a facility.

2. Reconstruction (replacement of more than half) of a 

facility.

3. Modification (any physical change to equipment) of a 

facility.

4. Relocation of a facility.

5. Reactivation (re-startup) of a facility.

VA.R. Doc. No. R10-2125; Filed October 29, 2015, 11:49 a.m. 

Final Regulation

Title of Regulation: 9VAC5-40. Existing Stationary 

Sources (Rev. C09) (amending 9VAC5-40-7800; adding 

9VAC5-40-8380 through 9VAC5-40-8480). 

Statutory Authority: § 10.1-1308 of the Code of Virginia; 

§§ 110, 111, 123, 129, 171, 172, and 182 of the federal Clean 

Air Act (40 CFR Parts 51 and 60).

Effective Date: February 1, 2016. 

Agency Contact: Gary Graham, Department of 

Environmental Quality, 629 East Main Street, P.O. Box 1105, 

Richmond, VA 23218, telephone (804) 698-4103, FAX (804) 

698-4510, or email gary.graham@deq.virginia.gov.

Summary:

The regulation requires owners to limit emissions from 

offset lithographic printing operations and letterpress 

printing operations to the level necessary for the protection 

of public health and welfare and the attainment and 

maintenance of the air quality standards. The regulation 

applies to sources within the Northern Virginia Volatile 

Organic Compound Emissions Control Area and 

establishes standards, control techniques, and provisions 

for determining compliance. The regulation also includes 

provisions for visible emissions, fugitive dust, odor, toxic 

pollutants, compliance, test methods and procedures, 

monitoring, notification, registration, malfunctions, and 

permits.

Changes since publication of the proposed regulation 

include revising the conditions under which performance 

testing would be conducted, adding default retention 

factors and capture efficiencies, adding a provision to 

allow an exemption of a certain amount of cleaning 

materials, and correcting definitions and standards to 

conform to the new control techniques guidelines.

Summary of Public Comments and Agency's Response: A 

summary of comments made by the public and the agency's 

response may be obtained from the promulgating agency or 

viewed at the office of the Registrar of Regulations. 

Article 53 

Emission Standards for Lithographic Printing Processes (Rule 

4-53) 

9VAC5-40-7800. Applicability and designation of affected 

facility. 

A. Except as provided in subsections C, D, and E of this 

section, the affected facility to which the provisions of this 

article apply is each lithographic printing process which that

uses a substrate other than a textile. 

B. The provisions of this article apply only to sources of 

volatile organic compounds in volatile organic compound 

emissions control areas designated in 9VAC5-20-206. 

C. Exempted from the provisions of this article are facilities

offset lithographic printing operations in the Northern 

Virginia Volatile Organic Compound Emissions Control Area 

whose potential to emit is less than 10 tons per year of 

volatile organic compounds, provided the emission rates are 

determined in a manner acceptable to the board. All volatile 

organic compound emissions from printing inks, coatings, 

cleaning solutions, and fountain solutions shall be considered 

in applying the exemption levels specified in this subsection. 

Provisions applicable to offset lithographic printing 

operations in the Northern Virginia Volatile Organic 

Compound Emissions Control Area are provided in Article 

56.1 [ of this part ] (9VAC5-40-8420 et seq.) [ of this part ].
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D. Exempted from the provisions of this article are facilities 

in all volatile organic compound emissions control areas, 

other than the Northern Virginia Volatile Organic Compound 

Emissions Control Area, whose potential to emit is less than 

100 tons per year of volatile organic compounds, provided the 

emission rates are determined in a manner acceptable to the 

board. All volatile organic compound emissions from printing 

inks, coatings, cleaning solutions, and fountain solutions shall 

be considered in applying the exemption levels specified in 

this subsection. 

E. The provisions of this article do not apply to the 

following: 

1. Printing processes used exclusively for determination of 

product quality and commercial acceptance provided: 

a. The operation is not an integral part of the production 

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 equipment 

using water-based chemistry to develop silver halide 

images. 

3. Platemaking equipment using water-based chemistry 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 cylinder 

width of 26 inches or less. 

Article 56

Emission Standards for Letterpress Printing Operations in the 

Northern Virginia Volatile Organic Compound Emissions 

Control Area, 8-hour Ozone Standard (Rule 4-56)

9VAC5-40-8380. Applicability and designation of affected 

facility.

A. The affected facility to which the provisions of this 

article apply is any letterpress printing operation at a 

stationary source where the actual emissions of volatile 

organic compounds (VOCs) from all aspects of letterpress 

printing operations, including related cleaning activities, 

before the consideration of controls, are equal to or exceed 

3.0 tons per 12-month rolling period. 

B. The provisions of this article apply only to sources of 

VOCs located in the Northern Virginia VOC Emissions 

Control Area designated in subdivision 1 a of 9VAC5-20-

206. 

9VAC5-40-8382. Definitions.

A. For the purpose of applying this article in the context of 

the regulations for the control and abatement of air pollution 

and related uses, the words or terms shall have the meanings 

given them in subsection C of this section.

B. Unless otherwise required by context, all terms not 

defined in this section shall have the meanings given them in 

9VAC5-170 (Regulation for General Administration), 

9VAC5-10 (General Definitions), or commonly ascribed to 

them by recognized authorities, in that order of priority.

C. Terms defined.

"Cleaning materials" means any washes, cleaners, solvents, 

or rejuvenators that are used to remove excess printing 

inks, oils, and residual paper from a press, press 

equipment, or press parts, or used to remove dried ink from 

areas around a press. Cleaning materials include solvents 

and cleaners used for manual cleaning, and cleaning 

solutions used by automatic cleaning systems such as roller 

wash and type wash. Cleaning materials do not include 

cleaners used for cleaning electronic components of a 

press, pre-press cleaning operations (e.g., platemaking), 

post-press cleaning operations (e.g., binding), cleaning 

supplies such as detergents used to clean the floor (other 

than to remove dried ink from areas around a press), and 

cleaning performed in parts washers and cold cleaners 

subject to Article 47 (9VAC5-40-6820 et seq.) of Part II of 

9VAC5-40 (Existing Stationary Sources).

"Composite partial vapor pressure" means the sum of the 

partial pressures of the compounds defined as volatile 

organic compounds. Composite partial vapor pressure is 

calculated as follows:

where:

Wi = Weight of the "i"th VOC compound, 

in grams.

Ww = Weight of water, in grams.

We = Weight of exempt compound, in 

grams.

MWi = Molecular weight of the "i"th VOC 

compound, in grams/gram-mole.

MWw = Molecular weight of water, in 

grams/gram-mole.

MWe = Molecular weight of exempt 

compound, in grams/gram-mole.

PPc = VOC composite partial pressure at 

20°C, in millimeters of mercury 

(mm Hg).

VPi = Vapor pressure of the "i"th VOC 

compound at 20°C, in mm Hg.

"First installation date" means the date that a control 

device is first installed for the purpose of controlling 
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emissions. The first installation date does not change if the 

control device is later moved to a new location or installed 

on a different press.

"Heatset" means a printing process in which heat from a 

dryer is used to evaporate ink oils from the substrate.

"Letterpress printing" means a printing process in which 

the image area is raised relative to the nonimage area and 

paste ink is transferred to the substrate directly from the 

image surface.

"Letterpress printing operation" means one or more

[ letterpress ] printing processes employing letterpress 

printing on [ letterpress ] printing presses and the related 

processes necessary to directly support the operation of 

those presses including, but not limited to, cleaning, prepress, and post-press operations. 

"Non-heatset" means a printing process in which the 

printing inks are set and dried by absorption or oxidation 

rather than heat. For the purposes of this article, UV-cured 

and electron beam-cured inks are considered non-heatset.

"Press" means a printing production assembly composed of 

one or more units to produce a printed substrate (sheet or 

web).

"Printing" means a photomechanical process in which a 

transfer of text, designs, and images occurs through contact 

of an image carrier with a substrate.

"Printing process" means any operation or system wherein 

printing ink or a combination of printing ink and surface 

coating is applied, dried, or cured and that is subject to the 

same emission standard. A printing process may include 

any equipment that applies, conveys, dries, or cures inks or 

surface coatings, including, but not limited to, flow coaters, 

flashoff areas, [ air presses, digital output devices, 

heaters, ] dryers, drying areas, and ovens.

"Sheet-fed" means a printing process in which individual 

sheets of substrate are fed into the press sequentially.

"Theoretical potential to emit" means for the purposes of 

this article the maximum capacity of a letterpress printing 

process to emit VOC and shall be based on emissions at 

design capacity or maximum production and maximum 

operating hours (8,760 hours/year) before add-on controls, 

unless the [ heatset web offset lithographic letterpress ] 

printing process is subject to state and federally 

enforceable permit conditions that limit production rates or 

hours of operation.

"12-month rolling period" means a period that is 

determined monthly and consists of the previous 12 

consecutive calendar months.

"Unit" means [ , for the purposes of this article, ] the 

smallest complete printing component, composed of an 

inking [ and dampening ] system, of a [ letterpress ] 

printing press.

"VOC" means volatile organic compound.

"Web" means a continuous roll of printing substrate. 

9VAC5-40-8384. Standard for volatile organic 

compounds.

A. No owner or other person shall use or permit the use of 

any letterpress printing press, letterpress printing process, or 

other letterpress printing operation that is subject to this 

article unless that press, process, or operation meets the 

requirements of this section.

B. The following provisions apply to each dryer on each 

heatset web letterpress printing process, except that these 

provisions do not apply to (i) any heatset web letterpress 

printing process with a theoretical potential to emit less than 

25 tons per year of VOC [ (petroleum ink oil) ] from the 

dryer, prior to controls; (ii) any heatset web letterpress 

printing process used exclusively for book printing; or (iii) 

any heatset web letterpress printing process with a maximum 

web width of 22 inches or less. These provisions also do not 

apply to non-heatset web letterpress printing processes or to 

sheet-fed letterpress printing processes.

1. VOC emissions from the heatset web letterpress printing 

process dryer shall be controlled as follows:

a. The dryer shall operate at a lower air pressure than the 

pressroom air pressure at all times when the printing 

process is operating;

b. Exhaust air from the dryer shall be collected and sent 

to a control device that operates at all times when the 

printing process is operating.

c. For a control device whose first installation date is 

prior to [ (insert effective date of this article) February 1, 

2016 ], the control device shall reduce VOC emissions in 

the dryer air exhaust by at least 90%.

d. For a control device whose first installation date is on 

or after [ (insert effective date of this article) February 1, 

2016 ], the control device shall reduce VOC emissions in 

the dryer air exhaust by at least 95%. 

2. Where the heatset web letterpress printing process 

control device inlet VOC concentration is too low to 

achieve the control device efficiency requirements 

specified in subdivisions 1 c and 1 d of this subsection or 

there is no identifiable measurable inlet, the control device 

shall reduce the VOC concentration of the heatset web 

letterpress printing process dryer exhaust air to 20 parts per 

million volume (ppmv) or less, as hexane on a dry basis.

3. Federally enforceable limitations on (i) the VOC

[ (petroleum ink oil) ] content of inks and coatings applied

[ prior to the dryer ], (ii) the total amounts of inks and 

coatings applied, (iii) the press application rates of inks and 

coatings, or (iv) the hours of press operation may be used 

to meet the 25 ton per year exception to this subsection.

C. Cleaning materials used at each letterpress printing 

operation shall meet one of the following limits, as applied [ , 

except that 110 gallons of cleaning materials that meet neither 

limit may be used per 12-month rolling period ]:
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1. A VOC content of 70% by weight; or

2. A composite vapor pressure of 10 mm Hg at 20°C.

[ The use of cleaning materials not meeting the limits in 

subdivision 1 or 2 of this subsection is permitted provided 

that the quantity of cleaning material used does not exceed 

110 gallons over any 12-month rolling period. ] 

D. The following work practices shall be implemented:

1. Cleaning materials, inks, and coatings containing VOCs 

shall be kept in closed containers at all times unless filling, 

draining, or performing cleaning operations.

2. Shop towels, sponges, and other manual cleaning aids (i) 

that have been used for picking up excess ink and other 

coatings containing VOCs or (ii) that have been used with 

cleaning materials containing VOCs shall be kept in closed 

containers.

3. Spills of cleaning materials, fountain solution, inks, 

varnishes, and other coatings containing VOCs shall be 

minimized and shall be cleaned up promptly. 

9VAC5-40-8386. Standard for visible emissions.

The provisions of Article 1 (9VAC5-40-60 et seq.) of Part II 

of 9VAC5-40 (Existing Stationary Sources) apply. 

9VAC5-40-8388. Standard for fugitive dust/emissions.

The provisions of Article 1 (9VAC5-40-60 et seq.) of Part II 

of 9VAC5-40 (Existing Stationary Sources) apply. 

9VAC5-40-8390. Standard for odor.

The provisions of Article 2 (9VAC5-40-130 et seq.) of Part 

II of 9VAC5-40 (Existing Stationary Sources) apply. 

9VAC5-40-8394. Standard for toxic pollutants.

The provisions of Article 4 (9VAC5-60-200 et seq.) of Part 

II of 9VAC5-60 (Hazardous Air Pollutant Sources) apply. 

9VAC5-40-8396. Compliance.

A. The provisions of 9VAC5-40-20 (Compliance) apply.

B. [ An If requested by the board, an ] emission test of the 

control device installed on a heatset web letterpress printing 

process dryer shall be performed to demonstrate compliance 

with the provisions of 9VAC5-40-8384 B [ and 9VAC5-40-

8398 ]. The negative dryer pressure shall be established 

during the initial test using an airflow direction indicator, 

such as a smoke stick or aluminum ribbons, or a differential 

pressure gauge. [ The board may accept the results of an 

emission test conducted prior to February 1, 2016, if the 

owner or operator provides information and data that 

demonstrate that the test demonstrated compliance with the 

provisions of 9VAC5-40-8384 B. ] 

C. [ Once initial compliance has been demonstrated with the 

heatset web letterpress printing process dryer control 

requirements of 9VAC5-40-8384 B through performance 

testing of an catalytic or thermal oxidation control device, 

continuing Continuing ] compliance with the heatset web 

letterpress printing process dryer control requirements in 

9VAC5-40-8384 B shall be demonstrated for the catalytic or 

thermal oxidation control device by monitoring the control 

device in accordance with 9VAC5-40-8410 B. The owner 

shall maintain the [ 3-hour three-hour ] average of the 

monitored temperature at a temperature no less than 50°F 

below the [ 3-hour three-hour ] average temperature that was 

recorded during the most recent performance test during 

which compliance was demonstrated. [ In the absence of 

performance test results acceptable to the board that provide 

dryer control device temperatures that demonstrate continuing 

compliance with the requirements in 9VAC5-40-8384 B, 

control device temperatures that demonstrate compliance with 

manufacturer recommendations may be considered by the 

board to demonstrate compliance with heatset web offset 

letterpress printing process dryer control requirements in 

9VAC5-40-8384 B.

D. A portion of the volatile organic compounds contained in 

inks and cleaning solution is retained in the printed web and 

in the shop towels used for cleaning. When applicable, the 

following retention factors may be used in determining 

volatile organic compounds emissions from letterpress 

printing operations:

1. A 20% volatile organic compound retention factor may 

be used for petroleum ink oils contained in heatset inks that 

are printed on absorptive substrates, meaning that 80% of 

the VOC (petroleum ink oil) in the ink is emitted during 

the printing process and is available for capture and control 

by an add-on pollution control device.

2. A 100% volatile organic compound retention factor may 

be used for vegetable ink oils contained in heatset inks that 

are printed on absorptive substrates, meaning that none of 

the VOC (vegetable ink oil) in the ink is emitted during the 

printing process and available for capture and control by an 

add-on pollution control device.

3. A 95% volatile organic compound retention factor may 

be used for petroleum ink oils contained in sheet-fed and 

non-heatset web inks printed on absorptive substrates, 

meaning that 5.0% of the VOC (petroleum ink oil) in the 

ink is emitted during the printing process.

4. A 100% volatile organic compound retention factor may 

be used for vegetable ink oils contained in sheet-fed and 

non-heatset web inks printed on absorptive substrates, 

meaning that none of the VOC (vegetable ink oil) in the 

ink is emitted during the printing process.

5. A 50% volatile organic compound retention factor may 

be used for cleaning solution VOC in shop towels for those 

cleaning solutions with a volatile organic compounds 

composite vapor pressure of no more than 10 millimeters 

of mercury (Hg) at 20°C (68°F) provided that the cleaning 

materials and used shop towels are kept in closed 

containers.

E. A portion of the volatile organic compounds contained in 

inks is captured for control by add-on air pollution control 

equipment. When applicable, the following capture 
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efficiencies may be used in determining volatile organic 

compounds emissions from letterpress printing operations:

1. A 100% volatile organic compound capture efficiency 

may be used for VOC (petroleum ink oils) from oil-based 

paste inks and oil-based paste varnishes (coatings) when 

the dryer is demonstrated to be operating at negative 

pressure relative to the surrounding pressroom.

2. Conventional letterpress inks and varnishes are pastetype materials. If other types of inks or coating materials 

are used on a letterpress press (e.g., fluid inks or coatings), 

capture efficiency testing shall be conducted for the VOC 

from these other materials if the printer wants to take into 

account the effect that the dryer controls have on VOC 

emissions from these other types of inks or coatings. ] 

9VAC5-40-8398. Compliance schedule.

The owner shall comply with the provisions of this article as 

expeditiously as possible but in no case later than [ (insert a 

date corresponding to the first day of the 12th month after the 

effective date of this article) February 1, 2017 ]. 

9VAC5-40-8400. Test methods and procedures.

A. The provisions of 9VAC5-40-30 (Emission testing) 

apply.

B. The following EPA test methods shall be used to 

demonstrate compliance with the heatset web letterpress 

printing process dryer control device control requirements in 

9VAC5-40-8384 B. 

1. Reference Method 1 or 1A, as appropriate, shall be used 

to select the sampling sites. 

2. Reference Method 2, 2A, 2C, or 2D, as appropriate, 

shall be used to determine the velocity and volumetric flow 

rate of the exhaust stream.

3. Reference Method 3 or 3A, as appropriate, shall be used 

to determine the concentration of O2 and CO2.

4. Reference Method 4 shall be used to determine moisture 

content.

5. Reference Methods 18, 25, or 25A shall be used to 

determine the VOC concentration of the dryer exhaust 

stream entering and exiting the control device, unless the 

alternate limit in 9VAC5-40-8384 B 2 is being met, in 

which case only the VOC concentration of the dryer 

exhaust control device outlet shall be determined.

6. Reference Method 25A shall be used to determine the 

dryer exhaust control device inlet and outlet VOC 

concentrations when the control device outlet 

concentration is less than 50 [ ppmv parts per million 

volume (ppmv) ] VOC as carbon.

7. If the control device is an oxidizer, the combustion 

chamber temperature or catalyst bed inlet temperature 

corresponding to destruction efficiencies that meet the 

requirements of 9VAC5-40-8384 B shall be recorded.

C. The VOC content of as-applied inks, coatings, and 

cleaning materials shall be determined using Reference 

Method 24.

1. The analysis of as-supplied materials may be performed 

by the manufacturer or the supplier. Formulation 

information from the manufacturer may be used in lieu of 

Reference Method 24 analysis unless the board or the 

owner has reason to believe that the formulation 

information provided by the manufacturer is inaccurate.

2. The owner may use VOC content information provided 

by the manufacturer or supplier, such as the container 

label, the product data sheet, or the [ MSDS sheet Safety 

Data Sheet (SDS) ] to document the VOC content of the 

as-supplied material.

3. If cleaning materials are diluted by the owner prior to 

use, a calculation that combines the as-supplied VOC 

content information provided by the manufacturer or 

supplier, the VOC content of the diluent, and the 

proportions in which they are mixed may be used to make 

a determination of VOC content of the as-applied cleaning 

material in lieu of Reference Method 24.

4. The owner shall conduct Reference Method 24 testing of 

any as-applied cleaning material used for letterpress 

printing operations at any time at the board's request. The 

owner shall be prepared to sample as-applied fountain 

solution or cleaning materials at all times.

D. The VOC composite partial vapor pressure of cleaning 

solutions shall be determined using the formula provided in 

9VAC5-40-8382 C or by an appropriate test method approved 

by the board.

1. The determination VOC composite partial vapor 

pressure for as-supplied cleaning solutions may be 

performed by the manufacturer or the supplier. The 

determination of as-applied composite vapor pressure 

based upon the manufacturer's instructions for dilution may 

be performed by the manufacturer or supplier.

2. The owner may use VOC composite partial vapor 

pressure information provided by the manufacturer or 

supplier, such as the container label, the product data sheet, 

or the [ Material Safety Data Sheet (MSDS) Safety Data 

Sheet (SDS) ] to document the VOC composite partial 

vapor pressure of the as-supplied or as-applied cleaning 

materials.

3. The following provisions apply to the determination of 

VOC composite partial vapor pressure for cleaning 

materials that are diluted by the owner prior to use:

a. If the dilution is made according to the manufacturer's 

instructions, the VOC composite partial vapor pressure 

for the as-applied cleaning material provided by the 

manufacturer or supplier may be used.

b. If a dilution is made and an as-applied VOC composite 

partial vapor pressure has not been provided by the 

manufacturer or supplier, or if the dilution is not made 
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1175

according to the manufacturer's instructions, then the 

owner shall determine the VOC composite partial vapor 

pressure using the calculation method provided in 

9VAC5-40-8382 C or by an appropriate test method 

approved by the board.

4. The owner shall conduct testing of any as-applied 

cleaning materials used for letterpress printing operations 

at any time at the board's request. The owner shall be 

prepared to sample as-applied cleaning materials at all 

times. 

9VAC5-40-8410. Monitoring.

A. The provisions of 9VAC5-40-40 (Monitoring) apply.

B. Periodic monitoring of letterpress printing operations 

shall be conducted as follows:

1. The temperature of a catalytic or thermal oxidation 

control device shall be monitored at least once every 15 

minutes while the printing process is operating, and that 

temperature shall be recorded by an analog or digital 

recording device.

a. For a catalytic oxidizer, the dryer exhaust temperature 

upstream of the catalyst bed shall be monitored and 

recorded.

b. For a thermal oxidizer, the combustion chamber 

temperature of the oxidizer shall be monitored and 

recorded.

2. Catalyst bed material in a catalytic oxidation control 

device shall be inspected annually for general catalyst 

condition and any signs of potential catalyst depletion. 

Sampling and evaluation of the catalyst bed material shall 

be conducted whenever the results of the inspection 

indicate signs of potential catalyst depletion or poor 

catalyst condition based on manufacturer's 

recommendations, but not less than once per year.

3. If a heatset web letterpress printing process is 

interlocked to ensure that the control device is operating 

and airflow is present when the printing process is 

operating, then periodic monitoring of dryer air flow is not 

required. If no interlock is present, then the printing 

process dryer air flow shall be verified and recorded once 

per operating day. 

9VAC5-40-8412. Notification, records, and reporting.

The provisions of 9VAC5-40-50 (Notification, records and 

reporting) apply. 

9VAC5-40-8414. Registration.

The provisions of 9VAC5-20-160 (Registration) apply.

9VAC5-40-8416. Facility and control equipment 

maintenance or malfunction.

The provisions of 9VAC5-20-180 (Facility and control 

equipment maintenance or malfunction) apply.

9VAC5-40-8418. Permits.

A permit may be required prior to beginning any of the 

activities specified [ below in this section ] if the provisions 

of 9VAC5-50 (New and Modified Stationary Sources) and 

9VAC5-80 (Permits for Stationary Sources) apply. Owners 

contemplating such action should review those provisions and 

contact the appropriate regional office for guidance on 

whether those provisions apply.

1. Construction of a facility.

2. Reconstruction (replacement of more than half) of a 

facility.

3. Modification (any physical change to equipment) of a 

facility.

4. Relocation of a facility.

5. Reactivation (re-startup) of a facility.

6. Operation of a facility. 

Article 56.1

Emission Standards for Offset Lithographic Printing 

Operations in the Northern Virginia Volatile Organic 

Compound Emissions Control Area, 8-hour Ozone Standard 

(Rule 4-56.1)

9VAC5-40-8420. Applicability and designation of affected 

facility.

A. The affected facility to which the provisions of this 

article apply is any offset lithographic printing operation at a 

stationary source where the actual emissions of volatile 

organic compounds (VOCs) from all aspects of offset 

lithographic printing operations, including related cleaning 

activities, before the consideration of controls are equal to or 

exceed 3.0 tons per 12-month rolling period.

B. The provisions of this article apply only to sources of 

VOCs located in the Northern Virginia VOC Emissions 

Control Area designated in subdivision 1 a of 9VAC5-20-

206.

9VAC5-40-8422. Definitions.

A. For the purpose of applying this article in the context of 

the regulations for the control and abatement of air pollution 

and related uses, the words or terms shall have the meanings 

given them in subsection C of this section.

B. Unless otherwise required by context, all terms not 

defined in this section shall have the meanings given them in 

9VAC5-170 (Regulation for General Administration), 

9VAC5-10 (General Definitions), or commonly ascribed to 

them by recognized authorities, in that order of priority.

C. Terms defined.

"Alcohol" means any of the following compounds when 

used as a fountain solution additive: ethanol, n-propanol, 

and isopropanol.

"Alcohol substitute" means any nonalcohol additive that 

contains volatile organic compounds and is used in the 

fountain solution.
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"Batch" means a supply of fountain solution [ or cleaning 

solution ] that is prepared and used without alteration until 

completely used or removed from the printing process.

"Cleaning materials" means any washes, cleaners, solvents, 

or rejuvenators that are used to remove (i) excess printing 

inks, oils, and residual paper from a press, press 

equipment, or press parts or (ii) dried ink from areas 

around a press. Cleaning materials include solvents and 

cleaners used for manual cleaning and cleaning solutions 

used by automatic cleaning systems such as blanket wash, 

plate cleaner, metering roller cleaner, impression cylinder 

washes, rubber rejuvenators, and roller wash. Cleaning 

materials do not include cleaners used for cleaning 

electronic components of a press, pre-press cleaning 

operations (e.g., platemaking), post-press cleaning 

operations (e.g., binding), cleaning supplies such as 

detergents used to clean the floor (other than to remove 

dried ink from areas around a press), and cleaning 

performed in parts washers and cold cleaners subject to 

Article 47 (9VAC5-40-6820 et seq.) of Part II of 9VAC5-

40 (Existing Stationary Sources). 

"Composite partial vapor pressure" means the sum of the 

partial pressures of the compounds defined as volatile 

organic compounds. Composite partial vapor pressure is 

calculated as follows:

where:

Wi = Weight of the "i"th VOC compound, 

in grams.

Ww = Weight of water, in grams.

We = Weight of exempt compound, in 

grams.

MWi = Molecular weight of the "i"th VOC 

compound, in grams/gram-mole.

MWw = Molecular weight of water, in 

grams/gram-mole.

MWe = Molecular weight of exempt 

compound, in grams/gram-mole.

PPc = VOC composite partial pressure at 

20°C, in millimeters of mercury 

(mm Hg).

VPi = Vapor pressure of the "i"th VOC 

compound at 20°C, in mm Hg.

"First installation date" means the date that a control 

device is first installed for the purpose of controlling 

emissions. The first installation date does not change if the 

control device is later moved to a new location or installed 

on a different press. 

"Fountain solution" means any mixture of water, volatile 

and nonvolatile chemicals, and additives applied to a 

lithographic plate to repel ink from the nonimage area on 

the plate.

"Heatset" means a printing process in which heat from a 

dryer is used to evaporate ink oils from the substrate.

"Heatset web offset lithographic printing dryer" means the 

dryer or dryers installed as part of a heatset web offset 

lithographic printing process that dries [ or cures ] inks or 

surface coatings.

"Lithographic printing" means a planographic printing 

process in which the image and nonimage areas are 

chemically differentiated with the image area being oil 

receptive and the nonimage area being water receptive. 

This process differs from other printing processes, where 

the image is a raised or recessed surface.

"Non-heatset" means a printing process in which the 

printing inks are set and dried by absorption or oxidation 

rather than heat. For the purposes of this article, UV-cured 

and electron beam-cured inks are considered non-heatset.

"Offset lithographic printing" means a printing process that 

transfers the ink film from the lithographic plate to an 

intermediary surface (blanket), which, in turn, transfers the 

ink film to the substrate.

"Offset lithographic printing operation" means one or more 

printing processes employing offset lithographic printing 

on [ offset lithographic ] printing presses and includes the 

related processes necessary to directly support the 

operation of those offset lithographic printing processes 

including, but not limited to, pre-press and post-press 

operations. Varnishes, glues, and other coatings that are 

applied by an offset lithographic printing process are part 

of offset lithographic printing operations and are not 

considered as a separate process (e.g., paper coating). 

"Press" means a printing production assembly composed of 

one or more units to produce a printed substrate (sheet or 

web).

"Printing" means a photomechanical process in which a 

transfer of text, designs, and images occurs through contact 

of an image carrier with a substrate.

"Printing process" means any operation or system wherein 

printing ink or a combination of printing ink and surface 

coating is applied, dried, or cured and that is subject to the 

same emission standard. A printing process may include 

any equipment that applies, conveys, dries, or cures inks or 

surface coatings, including, but not limited to, flow coaters, 

flashoff areas, [ air presses, digital output devices, fountain 

solutions, heaters, ] dryers, drying areas, and ovens.

"Sheet-fed" means a printing process in which individual 

sheets of substrate are fed into the press sequentially.
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"Theoretical potential to emit" means for the purposes of 

this article the maximum capacity of a heatset web offset 

lithographic printing process to emit VOC and shall be 

based on emissions at design capacity or maximum 

production and maximum operating hours (8,760 

hours/year) before add-on controls, unless the heatset web 

offset lithographic printing process is subject to state and 

federally enforceable permit conditions that limit 

production rates or hours of operation.

"12-month rolling period" means a period that is 

determined monthly and consists of the previous 12 

consecutive calendar months.

"Unit" means the smallest complete printing component, 

composed of an inking [ and dampening ] system, of a 

printing press.

"VOC" means volatile organic compound.

"Web" means a continuous roll of printing substrate. 

9VAC5-40-8424. Standard for volatile organic 

compounds.

A. No owner or other person shall use or permit the use of 

any offset lithographic printing press, offset lithographic 

printing process, or other offset lithographic printing 

operation that is subject to this article unless that press, 

process, or operation meets the requirements of this section.

B. Except as provided in subdivision 3 of this subsection, 

the following provisions apply to each heatset offset 

lithographic printing process at a facility whose potential to 

emit is greater than or equal to 10 tons per year of VOC, 

provided that the emission rates are determined in a manner 

acceptable to the board. All VOC emissions from printing 

inks, coatings, cleaning solutions, and fountain solutions shall 

be considered in determining the potential to emit for this 

subsection.

1. VOC emissions from the heatset web offset lithographic 

printing process dryer shall be controlled as follows:

a. The dryer shall operate at a lower air pressure than the 

pressroom air pressure at all times when the printing 

process is operating.

b. Exhaust air from the dryer shall be collected and sent 

to a control device that operates at all times when the 

printing process is operating.

c. The control device shall reduce VOC emissions in the 

dryer air exhaust by at least 90%.

2. Where the heatset web offset lithographic printing 

process control device inlet VOC concentration is too low 

to achieve the control device efficiency requirements 

specified in [ subdivisions subdivision ] 1 c of this 

subsection or there is no identifiable measurable inlet, the 

control device shall reduce the VOC concentration of the 

heatset web offset lithographic printing process dryer 

exhaust air to 50 parts per million volume (ppmv) or less, 

as carbon (minus methane and ethane).

3. The provisions in subdivisions 1 and 2 of this subsection 

do not apply to the following:

a. Any heatset web offset lithographic printing process 

with a theoretical potential to emit of 25 tons per year of 

VOC [ (petroleum ink oil) ] or more from the heatset web 

offset lithographic printing dryer. VOC standards for 

heatset web offset lithographic printing process with a 

theoretical potential to emit of 25 tons per year of VOC

[ (petroleum ink oil) ] or more are provided in subsection 

C of this section. 

b. Printing processes used exclusively for determination 

of product quality and commercial acceptance provided:

(1) The operation is not an integral part of the production 

process;

(2) The emissions from all product quality printing 

processes do not exceed 400 pounds in any 30-day 

period; and

(3) The exemption is approved by the board.

c. Photoprocessing, typesetting, or imagesetting 

equipment using water-based chemistry to develop silver 

halide images.

d. Platemaking equipment using water-based chemistry 

to remove unhardened image-producing material from an 

exposed plate.

e. Equipment used to make blueprints.

f. Any sheet-fed offset lithographic press with a cylinder 

width of 26 inches or less.

C. Except as provided in subdivisions [ 3, ] 4 [ , ] and 5 of 

this subsection, the following provisions apply to each heatset 

web offset lithographic printing process with a theoretical 

potential to emit of 25 tons per year of VOC [ (petroleum ink 

oil) ] or more from the dryer. These provisions do not apply 

to non-heatset web offset lithographic printing processes or to 

sheet-fed offset lithographic printing processes.

1. VOC emissions from the heatset web offset lithographic 

printing process dryer shall be controlled as follows:

a. The dryer shall operate at a lower air pressure than the 

pressroom air pressure at all times when the printing 

process is operating.

b. Exhaust air from the dryer shall be collected and sent 

to a control device that operates at all times when the 

printing process is operating.

c. For a control device whose first installation date is 

prior to [ (insert effective date of this article) February 1, 

2016 ], the control device shall reduce VOC emissions in 

the dryer air exhaust by at least 90%.

d. For a control device whose first installation date is on 

or after [ (insert effective date of this article) February 1, 

2016 ], the control device shall reduce VOC emissions in 

the dryer air exhaust by at least 95%.
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2. Where the heatset web offset lithographic printing 

process control device inlet VOC concentration is too low 

to achieve the control device efficiency requirements 

specified in subdivisions 1 c and 1 d of this subsection or 

there is no identifiable measurable inlet, the control device 

shall reduce the VOC concentration of the heatset web 

offset lithographic printing process dryer exhaust air to 20 

parts per million volume (ppmv) or less, as hexane on a dry 

basis.

3. Federally enforceable limitations on (i) the VOC

[ (petroleum ink oil) ] content of inks, varnishes, and other 

coatings applied [ prior to the dryer ]; (ii) the total amounts 

of inks, varnishes, and other coatings applied; (iii) the 

press application rates of inks, varnishes, and other 

coatings; or (iv) the hours of press operation may be used 

to meet the 25 ton per year exception to this subsection.

4. The provisions of subdivisions 1 and 2 of this subsection 

do not apply to (i) any heatset web offset lithographic 

printing process constructed on or after [ (insert effective 

date of this article) February 1, 2016, ] and used 

exclusively for book printing or (ii) any heatset web offset 

lithographic printing process constructed on or after

[ (insert effective date of this article) February 1, 2016, ]

with a maximum web width of 22 inches or less. 

5. The heatset web offset lithographic printing process 

dryer control device provisions of subdivision 1 d of this 

subsection do not apply to (i) any heatset web offset 

lithographic printing process used exclusively for book 

printing; or (ii) any heatset web offset lithographic printing 

process with a maximum web width of 22 inches or less.

D. The following provisions shall apply to fountain solution 

applied to each offset lithographic printing press, except that 

these provisions shall not apply to (i) sheet-fed offset 

lithographic printing processes with a sheet size of 11 inches 

by 17 inches or smaller or (ii) sheet-fed offset lithographic 

printing processes with a total fountain solution reservoir of 

less than one gallon.

1. For each heatset web press:

a. When the fountain solution contains alcohol:

(1) The fountain solution, as applied, shall contain no 

more than 1.6% volatile organic compounds by weight; 

or

(2) The temperature of the fountain solution shall be 

maintained at or below 60°F and the fountain solution, as 

applied, shall contain no more than 3.0% VOCs by 

weight; or

b. When the fountain solution contains no alcohol, the 

fountain solution, as applied, shall contain no more than 

5.0% VOCs by weight.

2. For each non-heatset web press, the fountain solution, as 

applied, shall contain no alcohol and shall contain no more 

than 5.0% VOCs by weight.

3. For each sheet-fed press:

a. The fountain solution, as applied, shall contain no 

more than 5.0% VOCs by weight; or

b. The temperature of the fountain solution shall be 

maintained at or below 60°F and the fountain solution, as 

applied, shall contain no more than 8.5% VOCs by 

weight.

E. Cleaning materials used at each offset lithographic 

printing operation shall meet one of the following limits, as 

applied:

1. A VOC content of 30% by weight; or

2. A composite vapor pressure of 10 mm Hg at 20°C 

(68°F).

[ The use of cleaning materials not meeting the limits in 

subdivision 1 or 2 of this subsection is permitted provided 

that the quantity of cleaning material used does not exceed 

110 gallons over any 12-month rolling period. ] 

F. The following work practices shall be implemented.

1. Cleaning materials, fountain solution, inks, varnishes, 

and coatings containing VOCs shall be kept in closed 

containers at all times unless filling, draining, or 

performing cleaning operations.

2. Shop towels, sponges, and other manual cleaning aids 

that (i) have been used for picking up excess ink, fountain 

solution, varnishes, and other coatings containing VOCs or 

(ii) have been used with cleaning materials containing 

VOCs shall be kept in closed containers.

3. Spills of cleaning materials, fountain solution, inks, 

varnishes, and other coatings containing VOCs shall be 

minimized and shall be cleaned up promptly.

9VAC5-40-8426. Standard for visible emissions.

The provisions of Article 1 (9VAC5-40-60 et seq.) of Part II 

of 9VAC5-40 (Existing Stationary Sources) apply. 

9VAC5-40-8428. Standard for fugitive dust/emissions.

The provisions of Article 1 (9VAC5-40-60 et seq.) of Part II 

of 9VAC5-40 (Existing Stationary Sources) apply. 

9VAC5-40-8430. Standard for odor.

The provisions of Article 2 (9VAC5-40-130 et seq.) of Part 

II of 9VAC5-40 (Existing Stationary Sources) apply. 

9VAC5-40-8432. Standard for toxic pollutants.

The provisions of Article 4 (9VAC5-60-200 et seq.) of Part 

II of 9VAC5-60 (Hazardous Air Pollutant Sources) apply. 

9VAC5-40-8434. Compliance.

A. The provisions of 9VAC5-40-20 (Compliance) apply.

B. [ An If requested by the board, an ] emission test of the 

control device installed on a heatset web offset lithographic 

printing process dryer shall be performed to demonstrate 

compliance with the provisions of 9VAC5-40-8424 B and C

[ and 9VAC5-40-8436 ]. The negative dryer pressure shall be 

established during the initial test using an airflow direction 

indicator, such as a smoke stick or aluminum ribbons, or a 
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differential pressure gauge. [ The board may accept the 

results of an emission test conducted prior to the compliance 

date specified in 9VAC5-40-8436 if the owner or operator 

provides information and data that demonstrate that the test 

demonstrated compliance with the provisions of 9VAC5-40-

8424 B and C. ] 

C. [ Once initial compliance has been demonstrated with the 

heatset web offset lithographic printing process dryer control 

requirements of 9VAC5-40-8424 B and C through 

performance testing of an catalytic or thermal oxidation 

control device, continuing Continuing ] compliance with the 

heatset web offset lithographic printing process dryer control 

requirements in 9VAC5-40-8424 B and C shall be 

demonstrated for the catalytic or thermal oxidation control 

device by monitoring the control device in accordance with 

9VAC5-40-8440 B 3, B 4, and B 5. The owner shall maintain 

the [ 3-hour three-hour ] average of the monitored 

temperature at a temperature no less than 50°F below the [ 3-

hour three-hour ] average temperature that was recorded 

during the most recent performance test during which 

compliance was demonstrated. [ In the absence of 

performance test results acceptable to the board that provide 

dryer control device temperatures that demonstrate continuing 

compliance with the requirements in 9VAC5-40-8424 B and 

C, control device temperatures that demonstrate compliance 

with manufacturer recommendations may be considered by 

the board to demonstrate compliance with heatset web offset 

lithographic printing process dryer control requirements in 

9VAC5-40-8424 B and C.

D. A portion of the volatile organic compounds contained in 

inks and cleaning solution is retained in the printed web and 

in the shop towels used for cleaning. When applicable, the 

following retention factors may be used in determining 

volatile organic compounds emissions from offset 

lithographic printing operations:

1. A 20% volatile organic compound retention factor may 

be used for petroleum ink oils contained in heatset inks that 

are printed on absorptive substrates, meaning that 80% of 

the VOC (petroleum ink oil) in the ink is emitted during 

the printing process and is available for capture and control 

by an add-on pollution control device.

2. A 100% volatile organic compound retention factor may 

be used for vegetable ink oils contained in heatset inks that 

are printed on absorptive substrates, meaning that none of 

the VOC (vegetable ink oil) in the ink is emitted during the 

printing process and available for capture and control by an 

add-on pollution control device.

3. A 95% volatile organic compound retention factor may 

be used for petroleum ink oils contained in sheet-fed and 

non-heatset web inks printed on absorptive substrates, 

meaning that 5.0% of the VOC (petroleum ink oil) in the 

ink is emitted during the printing process.

4. A 100% volatile organic compound retention factor may 

be used for vegetable ink oils contained in sheet-fed and 

non-heatset web inks printed on absorptive substrates, 

meaning that none of the VOC (vegetable ink oil) in the 

ink is emitted during the printing process.

5. A 50% volatile organic compound retention factor may 

be used for cleaning solution VOC in shop towels for those 

cleaning solutions with a volatile organic compounds 

composite vapor pressure of no more than 10 millimeters 

of mercury (Hg) at 20°C (68°F) provided that the cleaning 

materials and used shop towels are kept in closed 

containers. 

E. A portion of the volatile organic compounds contained in 

inks, fountain solutions, and automatic blanket washes is 

captured for control by add-on air pollution control 

equipment. When applicable, the following capture 

efficiencies may be used in determining volatile organic 

compounds emissions from offset lithographic printing 

operations:

1. A 40% volatile organic compound capture efficiency 

may be used for automatic blanket washing when the VOC 

composite vapor pressure of the cleaning material is less 

than 10 millimeters of mercury (Hg).

2. A 70% volatile organic compound capture efficiency 

may be used for alcohol substitutes in fountain solutions.

3. A 100% volatile organic compound capture efficiency 

may be used for VOC (petroleum ink oils) from oil-based 

paste inks and oil-based paste varnishes (coatings) when 

the dryer is demonstrated to be operating at negative 

pressure relative to the surrounding pressroom.

4. Conventional heatset lithographic inks and varnishes are 

paste-type materials. If other types of inks or coating 

materials are used on a heatset lithographic press (e.g., 

fluid inks or coatings), capture efficiency testing shall be 

conducted for the VOC from these other materials if the 

printer wants to take into account the effect that the dryer 

controls have on VOC emissions from these other types of 

inks or coatings. ] 

9VAC5-40-8436. Compliance schedule.

The owner shall comply with the provisions of this article as 

expeditiously as possible but in no case later than [ (insert a 

date corresponding to the first day of the 12th month after the 

effective date of this article) February 1, 2017 ].

9VAC5-40-8438. Test methods and procedures.

A. The provisions of 9VAC5-40-30 (Emission testing) 

apply.

B. The following EPA test methods shall be used to 

demonstrate compliance with the heatset web offset 

lithographic printing process dryer control device control 

requirements in 9VAC5-40-8424 B and C.

1. Reference Method 1 or 1A, as appropriate, shall be used 

to select the sampling sites. 
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2. Reference Method 2, 2A, 2C, or 2D, as appropriate, 

shall be used to determine the velocity and volumetric flow 

rate of the exhaust stream.

3. Reference Method 3 or 3A, as appropriate, shall be used 

to determine the concentration of O2 and CO2.

4. Reference Method 4 shall be used to determine moisture 

content.

5. Reference Methods 18, 25, or 25A shall be used to 

determine the VOC concentration of the dryer exhaust 

stream entering and exiting the control device, unless the 

alternate limit in 9VAC5-40-8424 B 2 or C 2 is being met, 

in which case only the VOC concentration of the dryer 

exhaust control device outlet shall be determined.

6. Reference Method 25A shall be used to determine the 

dryer exhaust control device inlet and outlet VOC 

concentrations when the control device outlet 

concentration is less than 50 [ ppmv parts per million 

volume (ppmv) ] VOC as carbon.

7. If the control device is an oxidizer, the combustion 

chamber temperature or catalyst bed inlet temperature 

corresponding to destruction efficiencies that meet the 

requirements of 9VAC5-40-8424 B or C, as appropriate, 

shall be recorded.

C. The VOC content of as-applied inks, varnishes and other 

coatings, fountain solutions, and cleaning materials shall be 

determined using Reference Method 24.

1. The analysis of as-supplied materials may be performed 

by the manufacturer or the supplier. Formulation 

information from the manufacturer may be used in lieu of 

Reference Method 24 analysis unless the board or the 

owner has reason to believe that the formulation 

information provided by the manufacturer is inaccurate.

2. The owner may use VOC content information provided 

by the manufacturer or supplier, such as the container 

label, the product data sheet, or the [ MSDS sheet Safety 

Data Sheet (SDS) ] to document the VOC content of the 

as-supplied material.

3. If fountain solution or cleaning materials are diluted by 

the owner prior to use, a calculation that combines the assupplied VOC content information provided by the 

manufacturer or supplier, the VOC content of the diluent, 

and the proportions in which they are mixed may be used 

to make a determination of VOC content of the as-applied 

fountain solution or cleaning material in lieu of Reference 

Method 24.

4. The owner shall conduct Reference Method 24 testing of 

any as-applied fountain solution or cleaning material used 

for offset lithographic printing operations at any time at the 

board's request. The owner shall be prepared to sample asapplied fountain solution or cleaning materials at all times.

D. A thermometer or other temperature detection device 

capable of reading the temperature of the fountain solution to 

within 0.5°F shall be used to determine compliance with 

fountain solution temperature requirements in 9VAC5-40-

8424 D.

E. The VOC composite partial vapor pressure of cleaning 

solutions shall be determined using the formula provided in 

9VAC5-40-8422 C or by an appropriate test method approved 

by the board.

1. The determination VOC composite partial vapor 

pressure for as-supplied cleaning solutions may be 

performed by the manufacturer or the supplier. The 

determination of as-applied composite vapor pressure 

based upon the manufacturer's instructions for dilution may 

be performed by the manufacturer or supplier.

2. The owner may use VOC composite partial vapor 

pressure information provided by the manufacturer or 

supplier, such as the container label, the product data sheet, 

or the [ Material Safety Data Sheet (MSDS) Safety Data 

Sheet (SDS) ], to document the VOC composite partial 

vapor pressure of the as-supplied or as-applied cleaning 

materials.

3. The following provisions apply to the determination of 

VOC composite partial vapor pressure for cleaning 

materials that are diluted by the owner prior to use:

a. If the dilution is made according to the manufacturer's 

instructions, the VOC composite partial vapor pressure 

for the as-applied cleaning material provided by the 

manufacturer or supplier may be used.

b. If a dilution is made and an as-applied VOC composite 

partial vapor pressure has not been provided by the 

manufacturer or supplier, or if the dilution is not made 

according to the manufacturer's instructions, then the 

owner shall determine the VOC composite partial vapor 

pressure using the calculation method provided in 

9VAC5-40-8422 C.

4. The owner shall conduct testing of any as-applied 

cleaning materials used for offset lithographic printing 

operations at any time at the board's request. The owner 

shall be prepared to sample as-applied cleaning materials at 

all times.

9VAC5-40-8440. Monitoring.

A. The provisions of 9VAC5-40-40 (Monitoring) apply.

B. Periodic monitoring of offset lithographic printing 

operations shall be conducted as follows:

1. The alcohol concentration of offset lithographic printing 

process fountain solution shall be monitored with a 

hydrometer, equipped with temperature correction or with 

readings adjusted for temperature, and recorded at least 

once per shift or once per batch, whichever is longer. A 

standard solution shall be used to calibrate the hydrometer 

for the type of alcohol used in the fountain.

2. The temperature of refrigerated fountain solution shall 

be measured at the recirculating tank at least once per 

operating day.
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3. The temperature of a catalytic or thermal oxidation 

control device shall be monitored at least once every 15 

minutes while the printing process is operating, and that 

temperature shall be recorded by an analog or digital 

recording device.

a. For a catalytic oxidizer, the dryer exhaust temperature

upstream of the catalyst bed shall be monitored and 

recorded.

b. For a thermal oxidizer, the combustion chamber 

temperature of the oxidizer shall be monitored and 

recorded.

4. Catalyst bed material in a catalytic oxidation control device 

shall be inspected annually for general catalyst condition and 

any signs of potential catalyst depletion. Sampling and 

evaluation of the catalyst bed material shall be conducted 

whenever the results of the inspection indicate signs of 

potential catalyst depletion or poor catalyst condition based on 

manufacturer's recommendations, but not less than once per 

year.

5. If a heatset web offset lithographic printing process is 

interlocked to ensure that the control device is operating 

and airflow is present when the printing process is 

operating, then periodic monitoring of dryer air flow is not 

required. If no interlock is present, then the printing 

process dryer air flow shall be verified and recorded once 

per operating day.

9VAC5-40-8450. Notification, records, and reporting.

The provisions of 9VAC5-40-50 (Notification, records, and 

reporting) apply.

9VAC5-40-8460. Registration.

The provisions of 9VAC5-20-160 (Registration) apply.

9VAC5-40-8470. Facility and control equipment 

maintenance or malfunction.

The provisions of 9VAC5-20-180 (Facility and control 

equipment maintenance or malfunction) apply.

9VAC5-40-8480. Permits.

A permit may be required prior to beginning any of the 

activities specified [ below in this section ] if the provisions of 

9VAC5-50 (New and Modified Stationary Sources) and 9VAC5-

80 (Permits for Stationary Sources) apply. Owners contemplating 

such action should review those provisions and contact the 

appropriate regional office for guidance on whether those 

provisions apply.

1. Construction of a facility.

2. Reconstruction (replacement of more than half) of a 

facility.

3. Modification (any physical change to equipment) of a 

facility.

4. Relocation of a facility.

5. Reactivation (re-startup) of a facility.

6. Operation of a facility. 

VA.R. Doc. No. R10-2126; Filed October 29, 2015, 11:50 a.m. 

Final Regulation

Title of Regulation: 9VAC5-40. Existing Stationary 

Sources (Rev. D09) (adding 9VAC5-40-8510 through 

9VAC5-40-8800). 

Statutory Authority: § 10.1-1308 of the Code of Virginia; 

§§ 110, 111, 123, 129, 171, 172, and 182 of the federal Clean 

Air Act (40 CFR Parts 51 and 60).

Effective Date: February 1, 2016. 

Agency Contact: Karen G. Sabasteanski, Department of 

Environmental Quality, 629 East Main Street, P.O. Box 1105, 

Richmond, VA 23218, telephone (804) 698-4426, FAX (804) 

698-4510, or email karen.sabasteanski@deq.virginia.gov.

Summary:

The regulation requires owners to limit emissions of air 

pollution from industrial solvent cleaning operations and 

miscellaneous industrial adhesive application processes to 

the level necessary for the protection of public health and 

welfare and the attainment and maintenance of the air 

quality standards. The regulation applies to sources within 

the Northern Virginia Volatile Organic Compound 

Emissions Control Area and establishes standards, control 

techniques, and provisions for determining compliance. 

The regulation includes provisions for visible emissions, 

fugitive dust, odor, toxic pollutants, compliance, test 

methods and procedures, monitoring, notification, 

registration, malfunctions, and permits. The final 

amendments add an alternative work practices procedure 

and an alternative standard for coatings, inks, adhesives, 

and resin manufacturing operations.

Summary of Public Comments and Agency's Response: A 

summary of comments made by the public and the agency's 

response may be obtained from the promulgating agency or 

viewed at the office of the Registrar of Regulations. 

Article 57

Emission Standards for Industrial Solvent Cleaning 

Operations in the Northern Virginia Volatile Organic 

Compound Emissions Control Area, 8-hour Ozone Standard 

(Rule 4-57)

9VAC5-40-8510. Applicability and designation of affected 

facility.

A. Except as provided in subsections C and D of this 

section, the affected facility to which the provisions of this 

article apply is each facility that uses organic solvent for 

cleaning unit operations such as mixing vessels (tanks), spray 

booths, and parts cleaners and that emits, before consideration 

of controls, at least 6.8 kilograms per day (15 pounds per day) 

of volatile organic compounds (VOCs). Such operations 

include, but are not limited to, spray gun cleaning, spray 

booth cleaning, large manufactured components cleaning, 

parts cleaning, equipment cleaning, line cleaning, floor 

cleaning, tank cleaning, and small manufactured components 

cleaning.
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b. An adult high school diploma shall be awarded to an 

adult student who completes the course credit 

requirements in effect for any Board of Education 

diploma, with the exception of health and physical 

education course requirements, at the time he first 

entered the ninth grade. The requirement for specific 

assessments may be waived if the assessments are no 

longer administered to students in Virginia public 

schools. 

c. An adult high school diploma shall be awarded to an 

adult student who demonstrates through applied 

performance assessment full mastery of the National 

External Diploma Program Generalized Competencies 

Correlated with CASAS Competencies, 1996, version 

5.0, January 2013, a CASAS program, as promulgated by 

the American Council on Education and validated and 

endorsed by the United States U.S. Department of 

Education. 

d. A General Achievement Diploma, as provided in 

8VAC20-680, shall be awarded to an adult student who 

completes all requirements of the diploma. A general 

achievement adult high school diploma shall be awarded 

to a student who is not subject to the compulsory 

attendance requirements of § 22.1-254 of the Code of 

Virginia and who:

(1) Successfully completes the general educational 

development (GED) program that meets the requirements 

of the Board of Education's Regulations Governing 

General Educational Development Certificates 

(8VAC20-360) and earns a GED certificate;

(2) Earns a Board of Education-approved career and 

technical education credential, such as the successful 

completion of an industry certification, a state licensure 

examination, a national occupational competency 

assessment, or the Virginia Workplace Readiness Skills 

Assessment; and

(3) Successfully completes the following courses that 

incorporate or exceed the applicable Standards of 

Learning:

Discipline Area Standard Units of 

Credit Required

English 4

Mathematics 3

Science 2

History and Social 

Sciences 2

Electives 9

TOTAL 20

Courses completed to satisfy the requirements in 

mathematics and science shall include content in courses 

that incorporate or exceed the content of courses 

approved by the Board of Education to satisfy any other 

board-recognized diploma. 

Courses completed to satisfy the history and social 

sciences requirements shall include one unit of credit in 

Virginia and U.S. history and one unit of credit in 

Virginia and U.S. government in courses that incorporate 

or exceed the content of courses approved by the Board

of Education to satisfy any other board-recognized 

diploma. 

Courses completed to satisfy the electives requirement 

shall include at least two sequential electives in an area 

of concentration or specialization, which may include 

career and technical education and training.

DOCUMENTS INCORPORATED BY REFERENCE 

(8VAC20-30) 

National External Diploma Program Generalized 

Competencies Correlated with CASAS Competencies, 

Comprehensive Adult Student Assessment System 

EDP/CASAS, 1996.

National External Diploma Program Competencies, version 

5.0, January 2013, a CASAS program, as promulgated by the 

American Council on Education and validated and endorsed 

by the U.S. Department of Education

VA.R. Doc. No. R13-3303; Filed December 15, 2014, 10:50 a.m. 

 –––––––––––––––––– 

TITLE 9. ENVIRONMENT

STATE AIR POLLUTION CONTROL BOARD

Proposed Regulation

Title of Regulation: 9VAC5-40. Existing Stationary 

Sources (Rev. C09) (amending 9VAC5-40-7800; adding 

9VAC5-40-8380 through 9VAC5-40-8480). 

Statutory Authority: § 10.1-1308 of the Code of Virginia; 

federal Clean Air Act (§§ 110, 111, 123, 129, 171, 172, and 

182); 40 CFR Parts 51 and 60.

Public Hearing Information:

February 26, 2015 - 11 a.m. - Department of 

Environmental Quality, Northern Regional Office, 13901 

Crown Court, Woodbridge, VA 22193

Public Comment Deadline: March 13, 2015.

Agency Contact: Gary Graham, Department of 

Environmental Quality, 629 East Main Street, P.O. Box 1105, 

Richmond, VA 23218, telephone (804) 698-4103, FAX (804) 

698-4510, or email gary.graham@deq.virginia.gov.

Basis: Section 10.1-1308 of the Virginia Air Pollution 

Control Law (Chapter 13 (§ 10.1-1300 et seq.) of Title 10.1 

of the Code of Virginia) authorizes the State Air Pollution 

Control Board to promulgate regulations abating, controlling, 
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and prohibiting air pollution to protect public health and 

welfare. Written assurance from the Office of the Attorney 

General that the State Air Pollution Control Board possesses 

the statutory authority to promulgate the proposed regulation 

amendments is available upon request.

Specific Federal Requirements.

Ground-level ozone is an air pollutant that forms when 

volatile organic compounds (VOCs) and nitrogen oxides 

(NOX) interact with sunlight. The national standard for ozone 

measured over an 8-hour period was promulgated by the U.S. 

Environmental Protection Agency (EPA) on July 18, 1997 

(62 FR 38856) at a level of 0.08 parts per million (ppm).

Once EPA establishes a national standard for ozone, it must 

then designate areas that do not attain the standard 

(nonattainment areas). In turn, states must develop plans 

(state implementation plans or SIPs), including regulations, 

which will enable nonattainment areas to attain and maintain 

the standard.

40 CFR Part 81 specifies the designations of areas made 

under § 107(d) of the federal Clean Air Act and the associated 

nonattainment classification under § 181 of the Act or 

40 CFR 51.903(a). Virginia's designations are in 40 CFR 

81.347. On April 30, 2004 (69 FR 23858), EPA published 

designations for 0.08 ppm 8-hour ozone nonattainment areas 

and associated classifications.

On April 30, 2004 (69 FR 23951), EPA promulgated phase 1 

of a final rule adding Subpart X to 40 CFR Part 51. Subpart X 

contains the provisions for the implementation of the 8-hour 

ozone NAAQS, along with associated planning requirements. 

Specifically, 40 CFR 51.903(a) sets forth the classification 

criteria and nonattainment dates for 8-hour ozone 

nonattainment areas once they are designated as such under 

40 CFR Part 81. The remainder of the planning requirements 

(phase 2) were published on November 29, 2005 (70 FR 

71612).

In order to implement the control measures needed to attain 

and maintain ozone air quality standard, Virginia has 

established VOC and NOX emissions control areas. These 

areas were created to provide a legal mechanism for defining 

geographic areas in which to implement certain control 

measures in the nonattainment areas. The emissions control 

areas may or may not coincide with the nonattainment areas, 

depending on regional planning requirements.

Section 172(c)(1) of the Act provides that SIPs for 

nonattainment areas must include "reasonably available 

control measures" (RACM), including "reasonably available 

control techniques" (RACT), for sources of emissions. 

Section 182(b)(2) provides that for certain nonattainment 

areas, states must revise their SIPs to include RACT for 

sources of VOC emissions covered by a control techniques 

guidelines document (CTG) issued after November 15, 1990, 

and prior to the areas date of attainment. 

Section 183(e) directs EPA to list for regulation those 

categories of products that account for at least 80% of the 

VOC emissions from commercial products in ozone 

nonattainment areas. EPA issued such a list on March 23, 

1995, and has revised the list periodically. RACT controls for 

listed source categories controlled by a CTG are known as 

CTG RACTs. A CTG RACT has been issued for offset 

lithographic and letterpress printing operations (October 5, 

2006, 71 FR 58745). Therefore, states with moderate ozone 

nonattainment areas must implement these CTG RACTs as 

part of their attainment SIPs.

General Federal Requirements.

Sections 109 (a) and (b) of the federal Clean Air Act require 

EPA to prescribe primary and secondary air quality standards 

to protect public health and welfare. These standards are 

known as the National Ambient Air Quality Standards 

(NAAQS). Section 109 (c) requires EPA to prescribe such 

standards simultaneously with the issuance of new air quality 

criteria for any additional air pollutant. The primary and 

secondary air quality criteria are authorized for promulgation 

under § 108.

Once the NAAQS are promulgated pursuant to § 109, 

§ 107(d) sets out a process for designating those areas that are 

in compliance with the standards (attainment or 

unclassifiable) and those that are not (nonattainment). 

Governors make the initial recommendations but EPA makes 

the final decision. Section 107(d) also sets forth the process 

for redesignations once the nonattainment areas are in 

compliance with the applicable NAAQS.

Section 110(a) of the Act mandates that each state adopt and 

submit to EPA a plan that provides for the implementation, 

maintenance, and enforcement of each primary and secondary 

air quality standard within each air quality control region in 

the state. The state implementation plan (SIP) must include 

provisions to accomplish, among other tasks, the following:

1. Establish enforceable emission limitations and other 

control measures as necessary to comply with the Act;

2. Establish schedules for compliance;

3. Prohibit emissions that would contribute to 

nonattainment of the standards or interference with 

maintenance of the standards by any state; and

4. Require sources of air pollution to install, maintain, 

and replace monitoring equipment as necessary and to 

report periodically on emissions-related data.

40 CFR Part 50 specifies the NAAQS for sulfur dioxide, 

particulate matter, carbon monoxide, ozone, nitrogen dioxide, 

and lead.

40 CFR Part 51 sets out requirements for the preparation, 

adoption, and submittal of SIPs. These requirements mandate 

that any such plan must include certain provisions, including 

those summarized below.

Subpart G (Control Strategy) specifies the description of 

control measures and schedules for implementation, the 
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description of emissions reductions estimates sufficient to 

attain and maintain the standards, time periods for 

demonstrations of the control strategy's adequacy, an 

emissions inventory, an air quality data summary, data 

availability, special requirements for lead emissions, stack 

height provisions, and intermittent control systems.

Subpart K (Source Surveillance) specifies procedures for 

emissions reports and recordkeeping, procedures for testing, 

inspection, enforcement, and complaints, transportation 

control measures, and procedures for continuous emissions 

monitoring.

Subpart L (Legal Authority) specifies the requirements for 

legal authority to implement plans. Section 51.230 under 

Subpart L specifies that each SIP must show that the state has 

the legal authority to carry out the plan, including the 

authority to perform the following actions:

1. Adopt emission standards and limitations and any 

other measures necessary for the attainment and 

maintenance of the national ambient air quality 

standards;

2. Enforce applicable laws, regulations, and standards, 

and seek injunctive relief;

3. Abate pollutant emissions on an emergency basis to 

prevent substantial endangerment to the health of 

persons;

4. Prevent construction, modification, or operation of a 

facility, building, structure, or installation, or 

combination thereof, which directly or indirectly results 

or may result in emissions of any air pollutant at any 

location which will prevent the attainment or 

maintenance of a national standard;

5. Obtain information necessary to determine whether air 

pollution sources comply with applicable laws, 

regulations, and standards, including authority to require 

recordkeeping and to make inspections and conduct tests 

of air pollution sources;

6. Require owners or operators of stationary sources to 

install, maintain, and use emission monitoring devices 

and to make periodic reports to the state on the nature 

and amounts of emissions from such stationary sources; 

and

7. Make emissions data available to the public as 

reported and as correlated with any applicable emission 

standards or limitations.

Section 51.231 under Subpart L requires the identification of 

legal authority: (i) the provisions of law or regulation which 

the state determines provide the authorities required under 

this section must be specifically identified, and copies of such 

laws or regulations must be submitted with the plan; and (ii) 

the plan must show that the legal authorities specified in this 

subpart are available to the state at the time of submission of 

the plan.

Subpart N (Compliance Schedules) specifies legally 

enforceable compliance schedules, final compliance schedule 

dates, and conditions for extensions beyond one year.

Part D describes how nonattainment areas are established, 

classified, and required to meet attainment. Subpart 1 

provides the overall framework of what nonattainment plans 

are to contain, while Subpart 2 provides more detail on what 

is required of areas designated nonattainment for ozone.

Section 171 defines "reasonable further progress," 

"nonattainment area," "lowest achievable emission rate," and 

"modification."

Section 172(a) authorizes EPA to classify nonattainment 

areas for the purpose of assigning attainment dates. Section 

172(b) authorizes EPA to establish schedules for the 

submission of plans designed to achieve attainment by the 

specified dates. Section 172(c) specifies the provisions to be 

included in each attainment plan, as follows:

1. Implementation of all reasonably available control 

measures as expeditiously as practicable and provide for 

the attainment of the national ambient air quality 

standards;

2. Reasonable further progress;

3. A comprehensive, accurate, current inventory of actual 

emissions from all sources of the relevant pollutants in 

the nonattainment area;

4. Identification and quantification of allowable 

emissions from the construction and modification of new 

and modified major stationary sources in the 

nonattainment area;

5. A requirement for permits for the construction and 

operations of new and modified major stationary sources 

in the nonattainment area;

6. Inclusion of enforceable emission limitations and such 

other control measures (including economic incentives 

such as fees, marketable permits, and auctions of 

emission rights) as well as schedules for compliance;

7. If applicable, the proposal of equivalent modeling, 

emission inventory, or planning procedures; and

8. Inclusion of specific contingency measures to be 

undertaken if the nonattainment area fails to make 

reasonable further progress or to attain the national 

ambient air quality standards by the attainment date.

Section 172(d) requires that attainment plans be revised if 

EPA finds inadequacies. Section 172(e) authorizes the 

issuance of requirements for nonattainment areas in the event 

of a relaxation of any national ambient air quality standard. 

Such requirements must provide for controls which are not 

less stringent than the controls applicable to these same areas 

before such relaxation.

Section 107(d)(3)(D) provides that a state may petition EPA 

to redesignate a nonattainment area as attainment and EPA 

may approve the redesignation subject to certain criteria 
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being met. Section 107(d)(3)(E) stipulates one of these 

criteria, that EPA must fully approve a maintenance plan that 

meets the requirements of § 175A. According to § 175A(a), 

the maintenance plan must be part of a SIP submission, and 

must provide for maintenance of the NAAQS for at least 10 

years after the redesignation. The plan must contain any 

additional measures needed to ensure maintenance. Section 

175A(b) further requires that 8 years after redesignation, a 

maintenance plan for the next 10 years must then be 

submitted. As stated in § 175A(c), nonattainment 

requirements continue to apply until the SIP submittal is 

approved. Finally, § 175A(d) requires that the maintenance 

plan contain contingency provisions which will be 

implemented should the area fail to maintain the NAAQS as 

provided for in the original plan.

Under Part D, Subpart 2, § 181 sets forth the classifications 

and nonattainment dates for 1-hour ozone nonattainment 

areas once they are designated as such under § 107(d).

Section 182(a)(2)(A) requires that the existing regulatory 

program requiring reasonably available control technology 

(RACT) for stationary sources of VOCs in marginal 

nonattainment areas be corrected by May 15, 1991, to meet 

the minimum requirements in existence prior to the enactment 

of the 1990 amendments. EPA has published control 

techniques guidelines (CTGs) for various types of sources, 

thereby defining the minimum acceptable control measure or 

RACT for a particular source type.

Section 182(b) requires stationary sources in moderate 

nonattainment areas to comply with the requirements for 

sources in marginal nonattainment areas. The additional, 

more comprehensive control measures in § 182(b)(2)(A) 

require that each category of VOC sources employ RACT if 

the source is covered by a CTG document issued between 

enactment of the 1990 amendments and the attainment date 

for the nonattainment area. Section 182(b)(2)(B) requires that 

existing stationary sources emitting VOCs for which a CTG 

existed prior to adoption of the 1990 amendments also 

employ RACT.

40 CFR Part 81 specifies the designations of areas made 

under § 107(d) of the Act and the associated nonattainment 

classification (if any) under § 181 of the Act or 40 CFR 

51.903(a), as applicable. Subpart X to 40 CFR Part 51 

contains the provisions for the implementation of the 8-hour 

ozone NAAQS, along with associated planning requirements. 

Specifically, 40 CFR 51.903(a) sets forth the classification 

criteria and nonattainment dates for 8-hour ozone 

nonattainment areas once they are designated.

State Requirements.

These specific amendments are not required by state mandate. 

Rather, Virginia's Air Pollution Control Law gives the State 

Air Pollution Control Board the discretionary authority to 

promulgate regulations "abating, controlling and prohibiting 

air pollution throughout or in any part of the Commonwealth" 

(§ 10.1-1308 A of the Code of Virginia). The law defines 

such air pollution as "the presence in the outdoor atmosphere 

of one or more substances which are or may be harmful or 

injurious to human health, welfare or safety, to animal or 

plant life, or to property, or which unreasonably interfere with 

the enjoyment by the people or life or property" (§ 10.1-1300 

of the Code of Virginia).

Purpose: The purpose of the proposed action is to adopt new 

standards for the control of volatile organic compound (VOC) 

emissions from (i) offset lithographic printing operations and 

(ii) letterpress printing operations within the Northern 

Virginia VOC Emissions Control Area. This action is being 

taken to allow Virginia to meet its obligation to implement 

control measures in areas designated as nonattainment under 

the 0.08 parts per million (ppm) 8-hour ozone standard. It will 

contribute to the reduction of ozone air pollution, and thereby 

improve public health and welfare.

Substance: For existing Article 53 pertaining to earlier 

standards for lithographic operations in all VOC emissions 

control areas, applicability provisions for facilities located in 

the Northern Virginia VOC emissions control area are 

deleted. Provisions of Article 53 applicable to sources in the 

Northern Virginia VOC emissions control area are preserved 

in Article 56.1, most notably (i) offset lithographic printing 

process dryer control provisions for sources with a facility 

potential to emit between 10 tons of VOC per year and 

having individual presses with a theoretical potential to emit 

25 tons of VOC per year, and (ii) limits on the VOC content 

of cleaning materials (30% instead of 70%). 

For each new article (Articles 56 and 56.1):

1. An applicability section is established which specifies 

that facilities in the Northern Virginia VOC emissions 

control area are affected.

2. Definitions of terms used in the rule are provided.

3. A standard for VOC emissions is established, along 

with provisions for achieving the standard.

4. Compliance provisions are provided detailing how 

compliance is determined with the standards.

5. Test methods are provided by which compliance may 

be determined.

6. Monitoring provisions are provided to ensure that the 

owner is able to stay in compliance with the standards.

7. Standard provisions are provided for visible emissions; 

fugitive dust/emissions; odor; toxic pollutants; a 

compliance schedule; notification, records and reporting; 

registration; facility and control equipment maintenance 

or malfunction; and permits.

Issues: The primary advantage to the general public is the 

reduction of VOC air pollution, which has a negative effect 

on public health and welfare. Regulated sources may realize 

cost savings through more effective application procedures 

and practices. There are no disadvantages to the public.
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The primary advantages to the department are that the 

adoption of these regulations will allow Virginia to attain and 

maintain air quality standards and improve public health of 

Virginians. The primary disadvantage to the department is the 

potential for an increased compliance cost to administer the 

new regulations.

Department of Planning and Budget's Economic Impact 

Analysis: 

Summary of the Proposed Amendments to Regulation. The 

State Air Pollution Control Board (Board) proposes to amend 

its existing air pollution regulations to add new standards for 

the control of volatile organic compound (VOC) emissions 

from letterpress printing, and change the standards for 

lithographic printing, within the Northern Virginia VOC 

Emissions Control Area.

Result of Analysis. Because the Department of 

Environmental Quality (DEQ) does not know with any degree 

of certainty how many entities these regulatory changes will 

affect, there is likely insufficient information to decide if 

benefits outweigh costs.

Estimated Economic Impact. Currently, any lithographic 

printing operations that have the potential to emit 10 or more 

tons of VOC are subject to the rules in 9 VAC 5-40. The 

Board proposes to amend this language so that any operations 

that actually emit 3 tons or more of VOC will have to abide 

by the restrictions in these regulations. DEQ reports that these

two standards are roughly equivalent and, so, they do not 

anticipate that many businesses in the Northern Virginia VOC 

Emissions Control Area will be affected by this change. For 

any businesses that would newly be subject to these 

regulations on account of this change, DEQ anticipates that 

costs added would be approximately $855 per ton of VOC 

produced. 

The Board also proposes to require several new standards for 

cleaning materials used in lithographic printing operations. 

Specifically, the Board proposes to require these businesses 

to 1) store cleaning materials, used shop towels, sponges and 

other manual cleaning aids in closed containers which are 

required to remain closed except when cleaners or manual 

cleaning aids are added or removed and 2) minimize spills of 

VOC containing cleaners. DEQ reports that these new rules 

may add additional costs of up to $855 per ton of VOC 

removed for affected businesses. These costs may be partially 

or completely offset by savings that businesses will see on 

account of decreased evaporation of their cleaning products. 

Currently, the Boards air pollution control regulations do not 

include rules for the control of volatile organic compound 

(VOC) emissions from letterpress printing. The Board 

proposes to add rules that largely mimic those for 

lithographic printing. The rules for letterbox printing will be 

slightly more permissive in that they allow for cleaning 

materials that have a VOC content of 70% by weight rather 

than the 30% by weight required for lithographic printing. 

DEQ estimates that most letterbox printing operations in 

Northern Virginia very likely already meet the standards that 

will be set in the proposed regulations. Those that would not 

already be in compliance may incur costs of $855 per ton of 

VOC removed.

DEQ will incur costs associated with promulgating these new 

rules that include the cost of identifying and registering 

affected businesses. DEQ estimates that these costs will total 

between $12,144 and $48,576. Affected businesses may incur 

costs for potentially more expensive low VOC products and, 

on rarer occasions, for control equipment. DEQ estimates that 

these costs would add to approximately $855 per ton of VOC 

removed. The Environmental Protection Agency (EPA) is 

requiring Virginia to promulgate these regulations under 

threat of loss of highway funding so one of the benefits of this 

regulatory action will be the preservation of that highway 

funding.

Businesses and Entities Affected. DEQ reports that it is 

impossible to know how many businesses will be affected by 

these regulations. Given that the products that will be 

regulated have many applications, there are likely numerous 

businesses that will be affected. For the portions of these 

rules that are new, many affected businesses will not have had 

to register with, or get a permit from, the Board before.

Localities Particularly Affected. Localities in the Northern 

Virginia non-attainment area (the counties of Arlington, 

Fairfax, Loudon, Prince William and Stafford as well as the 

cities of Alexandria, Fairfax, Falls Church, Manassas and 

Manassas Park) will be particularly affected by this proposed 

regulatory action.

Projected Impact on Employment. This regulatory action will 

likely have little impact on employment in the 

Commonwealth.

Effects on the Use and Value of Private Property. This 

regulatory action will likely have little effect on the use or 

value of private property in the Commonwealth.

Small Businesses: Costs and Other Effects. Affected small 

businesses may incur costs from having to change the 

cleaning products they use or, in rare instances, from having 

to purchase control equipment. DEQ believes that these costs 

will be partially offset by savings that businesses will realize 

from losing less cleaning product to evaporation.

Small Businesses: Alternative Method that Minimizes 

Adverse Impact. There do not appear to be any alternate 

methods that would both further minimize costs and achieve 

the aims of the Board.

Real Estate Development Costs. This regulatory action will 

likely have no effect on real estate development costs in the 

Commonwealth.

Legal Mandate. The Department of Planning and Budget 

(DPB) has analyzed the economic impact of this proposed 

regulation in accordance with § 2.2-4007.04 of the 

Administrative Process Act and Executive Order Number 14 

(10). Section 2.2-4007.04 requires that such economic impact 
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analyses include, but need not be limited to, the projected 

number of businesses or other entities to whom the regulation 

would apply, the identity of any localities and types of 

businesses or other entities particularly affected, the projected 

number of persons and employment positions to be affected, 

the projected costs to affected businesses or entities to 

implement or comply with the regulation, and the impact on 

the use and value of private property. Further, if the proposed 

regulation has adverse effect on small businesses, § 2.2-

4007.04 requires that such economic impact analyses include 

(i) an identification and estimate of the number of small 

businesses subject to the regulation; (ii) the projected 

reporting, recordkeeping, and other administrative costs 

required for small businesses to comply with the regulation, 

including the type of professional skills necessary for 

preparing required reports and other documents; (iii) a 

statement of the probable effect of the regulation on affected 

small businesses; and (iv) a description of any less intrusive 

or less costly alternative methods of achieving the purpose of 

the regulation. The analysis presented above represents DPB's 

best estimate of these economic impacts.

Agency's Response to Economic Impact Analysis: The 

department has reviewed the economic impact analysis 

prepared by the Department of Planning and Budget and has 

no comment.

Summary:

The proposed regulation requires owners to limit 

emissions from offset lithographic printing operations and 

letterpress printing operations to the level necessary for 

the protection of public health and welfare and the 

attainment and maintenance of the air quality standards. 

The regulation applies to sources within the Northern 

Virginia VOC Emissions Control Area, and establishes 

standards, control techniques, and provisions for 

determining compliance. The regulation also includes 

provisions for visible emissions, fugitive dust, odor, toxic 

pollutants, compliance, test methods and procedures, 

monitoring, notification, registration, malfunctions, and 

permits.

Article 53 

Emission Standards for Lithographic Printing Processes (Rule 

4- 53) 

9VAC5-40-7800. Applicability and designation of affected 

facility. 

A. Except as provided in subsections C, D, and E of this 

section, the affected facility to which the provisions of this 

article apply is each lithographic printing process which that

uses a substrate other than a textile. 

B. The provisions of this article apply only to sources of 

volatile organic compounds in volatile organic compound 

emissions control areas designated in 9VAC5-20-206. 

C. Exempted from the provisions of this article are facilities

offset lithographic printing operations in the Northern 

Virginia Volatile Organic Compound Emissions Control Area 

whose potential to emit is less than 10 tons per year of 

volatile organic compounds, provided the emission rates are 

determined in a manner acceptable to the board. All volatile 

organic compound emissions from printing inks, coatings, 

cleaning solutions, and fountain solutions shall be considered 

in applying the exemption levels specified in this subsection. 

Provisions applicable to offset lithographic printing 

operations in the Northern Virginia Volatile Organic 

Compound Emissions Control Area are provided in Article 

56.1 of this part (9VAC5-40-8420 et seq.).

D. Exempted from the provisions of this article are facilities 

in all volatile organic compound emissions control areas, 

other than the Northern Virginia Volatile Organic Compound 

Emissions Control Area, whose potential to emit is less than 

100 tons per year of volatile organic compounds, provided the 

emission rates are determined in a manner acceptable to the 

board. All volatile organic compound emissions from printing 

inks, coatings, cleaning solutions, and fountain solutions shall 

be considered in applying the exemption levels specified in 

this subsection. 

E. The provisions of this article do not apply to the 

following: 

1. Printing processes used exclusively for determination of 

product quality and commercial acceptance provided: 

a. The operation is not an integral part of the production 

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 equipment 

using water-based chemistry to develop silver halide 

images. 

3. Platemaking equipment using water-based chemistry 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 cylinder 

width of 26 inches or less. 

Article 56

Emission Standards for Letterpress Printing Operations in the 

Northern Virginia Volatile Organic Compound Emissions 

Control Area, 8-hour Ozone Standard (Rule 4-56)

9VAC5-40-8380. Applicability and designation of affected 

facility.

A. The affected facility to which the provisions of this 

article apply is any letterpress printing operation at a 

stationary source where the actual emissions of volatile 

organic compounds (VOCs) from all aspects of letterpress 

printing operations, including related cleaning activities, 
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before the consideration of controls, are equal to or exceed 

3.0 tons per 12-month rolling period. 

B. The provisions of this article apply only to sources of 

VOCs located in the Northern Virginia VOC Emissions 

Control Area designated in subdivision 1 a of 9VAC5-20-

206. 

9VAC5-40-8382. Definitions.

A. For the purpose of applying this article in the context of 

the regulations for the control and abatement of air pollution 

and related uses, the words or terms shall have the meanings 

given them in subsection C of this section.

B. Unless otherwise required by context, all terms not 

defined in this section shall have the meanings given them in 

9VAC5-170 (Regulation for General Administration), 

9VAC5-10 (General Definitions), or commonly ascribed to 

them by recognized authorities, in that order of priority.

C. Terms defined.

"Cleaning materials" means any washes, cleaners, solvents, 

or rejuvenators that are used to remove excess printing 

inks, oils, and residual paper from a press, press 

equipment, or press parts, or used to remove dried ink from 

areas around a press. Cleaning materials include solvents 

and cleaners used for manual cleaning, and cleaning 

solutions used by automatic cleaning systems such as roller 

wash and type wash. Cleaning materials do not include 

cleaners used for cleaning electronic components of a 

press, pre-press cleaning operations (e.g., platemaking), 

post-press cleaning operations (e.g., binding), cleaning 

supplies such as detergents used to clean the floor (other 

than to remove dried ink from areas around a press), and 

cleaning performed in parts washers and cold cleaners 

subject to Article 47 (9VAC5-40-6820 et seq.) of Part II of 

9VAC5-40 (Existing Stationary Sources).

"Composite partial vapor pressure" means the sum of the 

partial pressures of the compounds defined as volatile 

organic compounds. Composite partial vapor pressure is 

calculated as follows:

where:

Wi = Weight of the "i"th VOC compound, 

in grams.

Ww = Weight of water, in grams.

We = Weight of exempt compound, in 

grams.

MWi = Molecular weight of the "i"th VOC 

compound, in grams/gram-mole.

MWw = Molecular weight of water, in 

grams/gram-mole.

MWe = Molecular weight of exempt 

compound, in grams/gram-mole.

PPc = VOC composite partial pressure at 

20°C, in millimeters of mercury (mm 

Hg).

VPi = Vapor pressure of the "i"th VOC 

compound at 20°C, in mm Hg.

"First installation date" means the date that a control 

device is first installed for the purpose of controlling 

emissions. The first installation date does not change if the 

control device is later moved to a new location or installed 

on a different press.

"Heatset" means a printing process in which heat from a 

dryer is used to evaporate ink oils from the substrate.

"Letterpress printing" means a printing process in which 

the image area is raised relative to the nonimage area and 

paste ink is transferred to the substrate directly from the 

image surface.

"Letterpress printing operation" means one or more 

letterpress printing processes employing letterpress 

printing on letterpress printing presses and the related 

processes necessary to directly support the operation of 

those presses including, but not limited to, cleaning, prepress, and post-press operations. 

"Non-heatset" means a printing process in which the 

printing inks are set and dried by absorption or oxidation 

rather than heat. For the purposes of this article, UV-cured 

and electron beam-cured inks are considered non-heatset.

"Press" means a printing production assembly composed of 

one or more units to produce a printed substrate (sheet or 

web).

"Printing" means a photomechanical process in which a 

transfer of text, designs, and images occurs through contact 

of an image carrier with a substrate.

"Printing process" means any operation or system wherein 

printing ink or a combination of printing ink and surface 

coating is applied, dried, or cured and that is subject to the 

same emission standard. A printing process may include 

any equipment that applies, conveys, dries, or cures inks or 

surface coatings, including, but not limited to, flow coaters, 

flashoff areas, air dryers, drying areas, and ovens.

"Sheet-fed" means a printing process in which individual 

sheets of substrate are fed into the press sequentially.

"Theoretical potential to emit" means for the purposes of 

this article the maximum capacity of a letterpress printing 

process to emit VOC and shall be based on emissions at 

design capacity or maximum production and maximum 

operating hours (8,760 hours/year) before add-on controls, 

unless the heatset web offset lithographic printing process 
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is subject to state and federally enforceable permit 

conditions that limit production rates or hours of operation.

"12-month rolling period" means a period that is 

determined monthly and consists of the previous 12 

consecutive calendar months.

"Unit" means the smallest complete printing component, 

composed of an inking and dampening system, of a 

printing press.

"VOC" means volatile organic compound.

"Web" means a continuous roll of printing substrate. 

9VAC5-40-8384. Standard for volatile organic 

compounds.

A. No owner or other person shall use or permit the use of 

any letterpress printing press, letterpress printing process, or 

other letterpress printing operation that is subject to this 

article unless that press, process, or operation meets the 

requirements of this section.

B. The following provisions apply to each dryer on each 

heatset web letterpress printing process, except that these 

provisions do not apply to (i) any heatset web letterpress 

printing process with a theoretical potential to emit less than 

25 tons per year of VOC from the dryer, prior to controls; (ii) 

any heatset web letterpress printing process used exclusively 

for book printing; or (iii) any heatset web letterpress printing 

process with a maximum web width of 22 inches or less. 

These provisions also do not apply to non-heatset web 

letterpress printing processes or to sheet-fed letterpress 

printing processes.

1. VOC emissions from the heatset web letterpress printing 

process dryer shall be controlled as follows:

a. The dryer shall operate at a lower air pressure than the 

pressroom air pressure at all times when the printing 

process is operating;

b. Exhaust air from the dryer shall be collected and sent 

to a control device that operates at all times when the 

printing process is operating.

c. For a control device whose first installation date is 

prior to (insert effective date of this article), the control 

device shall reduce VOC emissions in the dryer air 

exhaust by at least 90%.

d. For a control device whose first installation date is on 

or after (insert effective date of this article), the control 

device shall reduce VOC emissions in the dryer air 

exhaust by at least 95%. 

2. Where the heatset web letterpress printing process 

control device inlet VOC concentration is too low to 

achieve the control device efficiency requirements 

specified in subdivisions 1 c and 1 d of this subsection or 

there is no identifiable measurable inlet, the control device 

shall reduce the VOC concentration of the heatset web 

letterpress printing process dryer exhaust air to 20 parts per 

million volume (ppmv) or less, as hexane on a dry basis.

3. Federally enforceable limitations on (i) the VOC content 

of inks and coatings applied, (ii) the total amounts of inks 

and coatings applied, (iii) the press application rates of inks 

and coatings, or (iv) the hours of press operation may be 

used to meet the 25 ton per year exception to this 

subsection.

C. Cleaning materials used at each letterpress printing 

operation shall meet one of the following limits, as applied, 

except that 110 gallons of cleaning materials that meet neither 

limit may be used per 12-month rolling period:

1. A VOC content of 70% by weight; or

2. A composite vapor pressure of 10 mm Hg at 20°C.

D. The following work practices shall be implemented:

1. Cleaning materials, inks, and coatings containing VOCs 

shall be kept in closed containers at all times unless filling, 

draining, or performing cleaning operations.

2. Shop towels, sponges, and other manual cleaning aids (i) 

that have been used for picking up excess ink and other 

coatings containing VOCs or (ii) that have been used with 

cleaning materials containing VOCs shall be kept in closed 

containers.

3. Spills of cleaning materials, fountain solution, inks, 

varnishes, and other coatings containing VOCs shall be 

minimized and shall be cleaned up promptly. 

9VAC5-40-8386. Standard for visible emissions.

The provisions of Article 1 (9VAC5-40-60 et seq.) of Part II 

of 9VAC5-40 (Existing Stationary Sources) apply. 

9VAC5-40-8388. Standard for fugitive dust/emissions.

The provisions of Article 1 (9VAC5-40-60 et seq.) of Part II 

of 9VAC5-40 (Existing Stationary Sources) apply. 

9VAC5-40-8390. Standard for odor.

The provisions of Article 2 (9VAC5-40-130 et seq.) of Part 

II of 9VAC5-40 (Existing Stationary Sources) apply. 

9VAC5-40-8394. Standard for toxic pollutants.

The provisions of Article 4 (9VAC5-60-200 et seq.) of Part 

II of 9VAC5-60 (Hazardous Air Pollutant Sources) apply. 

9VAC5-40-8396. Compliance.

A. The provisions of 9VAC5-40-20 (Compliance) apply.

B. An emission test of the control device installed on a 

heatset web letterpress printing process dryer shall be 

performed to demonstrate compliance with the provisions of 

9VAC5-40-8384 B and 9VAC5-40-8398. The negative dryer 

pressure shall be established during the initial test using an 

airflow direction indicator, such as a smoke stick or 

aluminum ribbons, or a differential pressure gauge.

C. Once initial compliance has been demonstrated with the 

heatset web letterpress printing process dryer control 

requirements of 9VAC5-40-8384 B through performance 

testing of an catalytic or thermal oxidation control device, 

continuing compliance with the heatset web letterpress 

printing process dryer control requirements in 9VAC5-40-
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8384 B shall be demonstrated for the catalytic or thermal 

oxidation control device by monitoring the control device in 

accordance with 9VAC5-40-8410 B. The owner shall 

maintain the 3-hour average of the monitored temperature at a 

temperature no less than 50°F below the 3-hour average 

temperature that was recorded during the most recent 

performance test during which compliance was demonstrated.

9VAC5-40-8398. Compliance schedule.

The owner shall comply with the provisions of this article as 

expeditiously as possible but in no case later than (insert a 

date corresponding to the first day of the 12th month after the 

effective date of this article). 

9VAC5-40-8400. Test methods and procedures.

A. The provisions of 9VAC5-40-30 (Emission testing) 

apply.

B. The following EPA test methods shall be used to 

demonstrate compliance with the heatset web letterpress 

printing process dryer control device control requirements in 

9VAC5-40-8384 B. 

1. Reference Method 1 or 1A, as appropriate, shall be used 

to select the sampling sites. 

2. Reference Method 2, 2A, 2C, or 2D, as appropriate, 

shall be used to determine the velocity and volumetric flow 

rate of the exhaust stream.

3. Reference Method 3 or 3A, as appropriate, shall be used 

to determine the concentration of O2 and CO2.

4. Reference Method 4 shall be used to determine moisture 

content.

5. Reference Methods 18, 25, or 25A shall be used to 

determine the VOC concentration of the dryer exhaust 

stream entering and exiting the control device, unless the 

alternate limit in 9VAC5-40-8384 B 2 is being met, in 

which case only the VOC concentration of the dryer 

exhaust control device outlet shall be determined.

6. Reference Method 25A shall be used to determine the 

dryer exhaust control device inlet and outlet VOC 

concentrations when the control device outlet 

concentration is less than 50 ppmv VOC as carbon.

7. If the control device is an oxidizer, the combustion 

chamber temperature or catalyst bed inlet temperature 

corresponding to destruction efficiencies that meet the 

requirements of 9VAC5-40-8384 B shall be recorded.

C. The VOC content of as-applied inks, coatings, and 

cleaning materials shall be determined using Reference 

Method 24.

1. The analysis of as-supplied materials may be performed 

by the manufacturer or the supplier. Formulation 

information from the manufacturer may be used in lieu of 

Reference Method 24 analysis unless the board or the 

owner has reason to believe that the formulation 

information provided by the manufacturer is inaccurate.

2. The owner may use VOC content information provided 

by the manufacturer or supplier, such as the container 

label, the product data sheet, or the MSDS sheet to 

document the VOC content of the as-supplied material.

3. If cleaning materials are diluted by the owner prior to 

use, a calculation that combines the as-supplied VOC 

content information provided by the manufacturer or 

supplier, the VOC content of the diluent, and the 

proportions in which they are mixed may be used to make 

a determination of VOC content of the as-applied cleaning 

material in lieu of Reference Method 24.

4. The owner shall conduct Reference Method 24 testing of 

any as-applied cleaning material used for letterpress 

printing operations at any time at the board's request. The 

owner shall be prepared to sample as-applied fountain 

solution or cleaning materials at all times.

D. The VOC composite partial vapor pressure of cleaning 

solutions shall be determined using the formula provided in 

9VAC5-40-8382 C or by an appropriate test method approved 

by the board.

1. The determination VOC composite partial vapor 

pressure for as-supplied cleaning solutions may be 

performed by the manufacturer or the supplier. The

determination of as-applied composite vapor pressure 

based upon the manufacturer's instructions for dilution may 

be performed by the manufacturer or supplier.

2. The owner may use VOC composite partial vapor 

pressure information provided by the manufacturer or 

supplier, such as the container label, the product data sheet, 

or the Material Safety Data Sheet (MSDS) to document the 

VOC composite partial vapor pressure of the as-supplied or 

as-applied cleaning materials.

3. The following provisions apply to the determination of 

VOC composite partial vapor pressure for cleaning 

materials that are diluted by the owner prior to use:

a. If the dilution is made according to the manufacturer's 

instructions, the VOC composite partial vapor pressure 

for the as-applied cleaning material provided by the 

manufacturer or supplier may be used.

b. If a dilution is made and an as-applied VOC composite 

partial vapor pressure has not been provided by the 

manufacturer or supplier, or if the dilution is not made 

according to the manufacturer's instructions, then the 

owner shall determine the VOC composite partial vapor 

pressure using the calculation method provided in 

9VAC5-40-8382 C or by an appropriate test method 

approved by the board.

4. The owner shall conduct testing of any as-applied 

cleaning materials used for letterpress printing operations 

at any time at the board's request. The owner shall be 

prepared to sample as-applied cleaning materials at all 

times. 
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9VAC5-40-8410. Monitoring.

A. The provisions of 9VAC5-40-40 (Monitoring) apply.

B. Periodic monitoring of letterpress printing operations 

shall be conducted as follows:

1. The temperature of a catalytic or thermal oxidation 

control device shall be monitored at least once every 15 

minutes while the printing process is operating, and that 

temperature shall be recorded by an analog or digital 

recording device.

a. For a catalytic oxidizer, the dryer exhaust temperature 

upstream of the catalyst bed shall be monitored and 

recorded.

b. For a thermal oxidizer, the combustion chamber 

temperature of the oxidizer shall be monitored and 

recorded.

2. Catalyst bed material in a catalytic oxidation control 

device shall be inspected annually for general catalyst 

condition and any signs of potential catalyst depletion. 

Sampling and evaluation of the catalyst bed material shall 

be conducted whenever the results of the inspection 

indicate signs of potential catalyst depletion or poor 

catalyst condition based on manufacturer's 

recommendations, but not less than once per year.

3. If a heatset web letterpress printing process is 

interlocked to ensure that the control device is operating 

and airflow is present when the printing process is 

operating, then periodic monitoring of dryer air flow is not 

required. If no interlock is present, then the printing 

process dryer air flow shall be verified and recorded once 

per operating day. 

9VAC5-40-8412. Notification, records, and reporting.

The provisions of 9VAC5-40-50 (Notification, records and 

reporting) apply. 

9VAC5-40-8414. Registration.

The provisions of 9VAC5-20-160 (Registration) apply.

9VAC5-40-8416. Facility and control equipment 

maintenance or malfunction.

The provisions of 9VAC5-20-180 (Facility and control 

equipment maintenance or malfunction) apply.

9VAC5-40-8418. Permits.

A permit may be required prior to beginning any of the 

activities specified below if the provisions of 9VAC5-50 

(New and Modified Stationary Sources) and 9VAC5-80 

(Permits for Stationary Sources) apply. Owners 

contemplating such action should review those provisions and 

contact the appropriate regional office for guidance on 

whether those provisions apply.

1. Construction of a facility.

2. Reconstruction (replacement of more than half) of a 

facility.

3. Modification (any physical change to equipment) of a 

facility.

4. Relocation of a facility.

5. Reactivation (re-startup) of a facility.

6. Operation of a facility. 

Article 56.1

Emission Standards for Offset Lithographic Printing 

Operations in the Northern Virginia Volatile Organic 

Compound Emissions Control Area, 8-hour Ozone Standard 

(Rule 4-56.1)

9VAC5-40-8420. Applicability and designation of affected 

facility.

A. The affected facility to which the provisions of this 

article apply is any offset lithographic printing operation at a 

stationary source where the actual emissions of volatile 

organic compounds (VOCs) from all aspects of offset 

lithographic printing operations, including related cleaning 

activities, before the consideration of controls are equal to or 

exceed 3.0 tons per 12-month rolling period.

B. The provisions of this article apply only to sources of 

VOCs located in the Northern Virginia VOC Emissions 

Control Area designated in subdivision 1 a of 9VAC5-20-

206.

9VAC5-40-8422. Definitions.

A. For the purpose of applying this article in the context of 

the regulations for the control and abatement of air pollution 

and related uses, the words or terms shall have the meanings 

given them in subsection C of this section.

B. Unless otherwise required by context, all terms not 

defined in this section shall have the meanings given them in 

9VAC5-170 (Regulation for General Administration), 

9VAC5-10 (General Definitions), or commonly ascribed to 

them by recognized authorities, in that order of priority.

C. Terms defined.

"Alcohol" means any of the following compounds when

used as a fountain solution additive: ethanol, n-propanol, 

and isopropanol.

"Alcohol substitute" means any nonalcohol additive that 

contains volatile organic compounds and is used in the 

fountain solution.

"Batch" means a supply of fountain solution that is 

prepared and used without alteration until completely used 

or removed from the printing process.

"Cleaning materials" means any washes, cleaners, solvents, 

or rejuvenators that are used to remove (i) excess printing 

inks, oils, and residual paper from a press, press 

equipment, or press parts or (ii) dried ink from areas 

around a press. Cleaning materials include solvents and 

cleaners used for manual cleaning and cleaning solutions 

used by automatic cleaning systems such as blanket wash, 

plate cleaner, metering roller cleaner, impression cylinder 

washes, rubber rejuvenators, and roller wash. Cleaning 
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materials do not include cleaners used for cleaning 

electronic components of a press, pre-press cleaning 

operations (e.g., platemaking), post-press cleaning 

operations (e.g., binding), cleaning supplies such as 

detergents used to clean the floor (other than to remove 

dried ink from areas around a press), and cleaning 

performed in parts washers and cold cleaners subject to 

Article 47 (9VAC5-40-6820 et seq.) of Part II of 9VAC5-

40 (Existing Stationary Sources). 

"Composite partial vapor pressure" means the sum of the 

partial pressures of the compounds defined as volatile 

organic compounds. Composite partial vapor pressure is 

calculated as follows:

where:

Wi = Weight of the "i"th VOC compound, 

in grams.

Ww = Weight of water, in grams.

We = Weight of exempt compound, in 

grams.

MWi = Molecular weight of the "i"th VOC 

compound, in grams/gram-mole.

MWw = Molecular weight of water, in 

grams/gram-mole.

MWe = Molecular weight of exempt 

compound, in grams/gram-mole.

PPc = VOC composite partial pressure at 

20°C, in millimeters of mercury (mm 

Hg).

VPi = Vapor pressure of the "i"th VOC 

compound at 20°C, in mm Hg.

"First installation date" means the date that a control 

device is first installed for the purpose of controlling 

emissions. The first installation date does not change if the 

control device is later moved to a new location or installed 

on a different press. 

"Fountain solution" means any mixture of water, volatile 

and nonvolatile chemicals, and additives applied to a 

lithographic plate to repel ink from the nonimage area on 

the plate.

"Heatset" means a printing process in which heat from a 

dryer is used to evaporate ink oils from the substrate.

"Heatset web offset lithographic printing dryer" means the 

dryer or dryers installed as part of a heatset web offset 

lithographic printing process that dries or cures inks or 

surface coatings.

"Lithographic printing" means a planographic printing 

process in which the image and nonimage areas are 

chemically differentiated with the image area being oil 

receptive and the nonimage area being water receptive. 

This process differs from other printing processes, where 

the image is a raised or recessed surface.

"Non-heatset" means a printing process in which the 

printing inks are set and dried by absorption or oxidation 

rather than heat. For the purposes of this article, UV-cured 

and electron beam-cured inks are considered non-heatset.

"Offset lithographic printing" means a printing process that 

transfers the ink film from the lithographic plate to an 

intermediary surface (blanket), which, in turn, transfers the 

ink film to the substrate.

"Offset lithographic printing operation" means one or more 

printing processes employing offset lithographic printing 

on offset lithographic printing presses and includes the 

related processes necessary to directly support the 

operation of those offset lithographic printing processes 

including, but not limited to, pre-press and post-press 

operations. Varnishes, glues, and other coatings that are 

applied by an offset lithographic printing process are part 

of offset lithographic printing operations and are not 

considered as a separate process (e.g., paper coating). 

"Press" means a printing production assembly composed of 

one or more units to produce a printed substrate (sheet or 

web).

"Printing" means a photomechanical process in which a 

transfer of text, designs, and images occurs through contact

of an image carrier with a substrate.

"Printing process" means any operation or system wherein 

printing ink or a combination of printing ink and surface 

coating is applied, dried, or cured and that is subject to the 

same emission standard. A printing process may include 

any equipment that applies, conveys, dries, or cures inks or 

surface coatings, including, but not limited to, flow coaters, 

flashoff areas, air dryers, drying areas, and ovens.

"Sheet-fed" means a printing process in which individual 

sheets of substrate are fed into the press sequentially.

"Theoretical potential to emit" means for the purposes of 

this article the maximum capacity of a heatset web offset 

lithographic printing process to emit VOC and shall be 

based on emissions at design capacity or maximum 

production and maximum operating hours (8,760 

hours/year) before add-on controls, unless the heatset web 

offset lithographic printing process is subject to state and 

federally enforceable permit conditions that limit 

production rates or hours of operation.

"12-month rolling period" means a period that is 

determined monthly and consists of the previous 12 

consecutive calendar months.
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"Unit" means the smallest complete printing component, 

composed of an inking and dampening system, of a 

printing press.

"VOC" means volatile organic compound.

"Web" means a continuous roll of printing substrate. 

9VAC5-40-8424. Standard for volatile organic 

compounds.

A. No owner or other person shall use or permit the use of 

any offset lithographic printing press, offset lithographic 

printing process, or other offset lithographic printing 

operation that is subject to this article unless that press, 

process, or operation meets the requirements of this section.

B. Except as provided in subdivision 3 of this subsection, 

the following provisions apply to each heatset offset 

lithographic printing process at a facility whose potential to 

emit is greater than or equal to 10 tons per year of VOC, 

provided that the emission rates are determined in a manner 

acceptable to the board. All VOC emissions from printing 

inks, coatings, cleaning solutions, and fountain solutions shall 

be considered in determining the potential to emit for this 

subsection.

1. VOC emissions from the heatset web offset lithographic 

printing process dryer shall be controlled as follows:

a. The dryer shall operate at a lower air pressure than the 

pressroom air pressure at all times when the printing 

process is operating.

b. Exhaust air from the dryer shall be collected and sent 

to a control device that operates at all times when the 

printing process is operating.

c. The control device shall reduce VOC emissions in the 

dryer air exhaust by at least 90%.

2. Where the heatset web offset lithographic printing 

process control device inlet VOC concentration is too low 

to achieve the control device efficiency requirements 

specified in subdivisions 1 c of this subsection or there is 

no identifiable measurable inlet, the control device shall 

reduce the VOC concentration of the heatset web offset 

lithographic printing process dryer exhaust air to 50 parts 

per million volume (ppmv) or less, as carbon (minus 

methane and ethane).

3. The provisions in subdivisions 1 and 2 of this subsection 

do not apply to the following:

a. Any heatset web offset lithographic printing process 

with a theoretical potential to emit of 25 tons per year of 

VOC or more from the heatset web offset lithographic 

printing dryer. VOC standards for heatset web offset 

lithographic printing process with a theoretical potential 

to emit of 25 tons per year of VOC or more are provided 

in subsection C of this section. 

b. Printing processes used exclusively for determination 

of product quality and commercial acceptance provided:

(1) The operation is not an integral part of the production 

process;

(2) The emissions from all product quality printing 

processes do not exceed 400 pounds in any 30-day 

period; and

(3) The exemption is approved by the board.

c. Photoprocessing, typesetting, or imagesetting 

equipment using water-based chemistry to develop silver 

halide images.

d. Platemaking equipment using water-based chemistry 

to remove unhardened image-producing material from an 

exposed plate.

e. Equipment used to make blueprints.

f. Any sheet-fed offset lithographic press with a cylinder 

width of 26 inches or less.

C. Except as provided in subdivisions 4 and 5 of this 

subsection, the following provisions apply to each heatset 

web offset lithographic printing process with a theoretical 

potential to emit of 25 tons per year of VOC or more from the 

dryer. These provisions do not apply to non-heatset web 

offset lithographic printing processes or to sheet-fed offset 

lithographic printing processes.

1. VOC emissions from the heatset web offset lithographic 

printing process dryer shall be controlled as follows:

a. The dryer shall operate at a lower air pressure than the 

pressroom air pressure at all times when the printing 

process is operating.

b. Exhaust air from the dryer shall be collected and sent 

to a control device that operates at all times when the 

printing process is operating.

c. For a control device whose first installation date is 

prior to (insert effective date of this article), the control 

device shall reduce VOC emissions in the dryer air 

exhaust by at least 90%.

d. For a control device whose first installation date is on 

or after (insert effective date of this article), the control 

device shall reduce VOC emissions in the dryer air 

exhaust by at least 95%.

2. Where the heatset web offset lithographic printing 

process control device inlet VOC concentration is too low 

to achieve the control device efficiency requirements 

specified in subdivisions 1 c and 1 d of this subsection or 

there is no identifiable measurable inlet, the control device 

shall reduce the VOC concentration of the heatset web 

offset lithographic printing process dryer exhaust air to 20 

parts per million volume (ppmv) or less, as hexane on a dry 

basis.

3. Federally enforceable limitations on (i) the VOC content 

of inks, varnishes, and other coatings applied; (ii) the total 

amounts of inks, varnishes, and other coatings applied; (iii) 

the press application rates of inks, varnishes, and other 
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coatings; or (iv) the hours of press operation may be used 

to meet the 25 ton per year exception to this subsection.

4. The provisions of subdivisions 1 and 2 of this subsection 

do not apply to (i) any heatset web offset lithographic 

printing process constructed on or after (insert effective 

date of this article) and used exclusively for book printing 

or (ii) any heatset web offset lithographic printing process 

constructed on or after (insert effective date of this article) 

with a maximum web width of 22 inches or less. 

5. The heatset web offset lithographic printing process 

dryer control device provisions of subdivision 1 d of this 

subsection do not apply to (i) any heatset web offset 

lithographic printing process used exclusively for book 

printing; or (ii) any heatset web offset lithographic printing 

process with a maximum web width of 22 inches or less.

D. The following provisions shall apply to fountain solution 

applied to each offset lithographic printing press, except that 

these provisions shall not apply to (i) sheet-fed offset 

lithographic printing processes with a sheet size of 11 inches 

by 17 inches or smaller or (ii) sheet-fed offset lithographic 

printing processes with a total fountain solution reservoir of 

less than one gallon.

1. For each heatset web press:

a. When the fountain solution contains alcohol:

(1) The fountain solution, as applied, shall contain no 

more than 1.6% volatile organic compounds by weight; 

or

(2) The temperature of the fountain solution shall be 

maintained at or below 60°F and the fountain solution, as 

applied, shall contain no more than 3.0% VOCs by 

weight; or

b. When the fountain solution contains no alcohol, the 

fountain solution, as applied, shall contain no more than 

5.0% VOCs by weight.

2. For each non-heatset web press, the fountain solution, as 

applied, shall contain no alcohol and shall contain no more 

than 5.0% VOCs by weight.

3. For each sheet-fed press:

a. The fountain solution, as applied, shall contain no 

more than 5.0% VOCs by weight; or

b. The temperature of the fountain solution shall be 

maintained at or below 60°F and the fountain solution, as 

applied, shall contain no more than 8.5% VOCs by 

weight.

E. Cleaning materials used at each offset lithographic 

printing operation shall meet one of the following limits, as 

applied:

1. A VOC content of 30% by weight; or

2. A composite vapor pressure of 10 mm Hg at 20°C 

(68°F).

F. The following work practices shall be implemented.

1. Cleaning materials, fountain solution, inks, varnishes, 

and coatings containing VOCs shall be kept in closed 

containers at all times unless filling, draining, or 

performing cleaning operations.

2. Shop towels, sponges, and other manual cleaning aids 

that (i) have been used for picking up excess ink, fountain 

solution, varnishes, and other coatings containing VOCs or 

(ii) have been used with cleaning materials containing 

VOCs shall be kept in closed containers.

3. Spills of cleaning materials, fountain solution, inks, 

varnishes, and other coatings containing VOCs shall be 

minimized and shall be cleaned up promptly.

9VAC5-40-8426. Standard for visible emissions.

The provisions of Article 1 (9VAC5-40-60 et seq.) of Part II 

of 9VAC5-40 (Existing Stationary Sources) apply. 

9VAC5-40-8428. Standard for fugitive dust/emissions.

The provisions of Article 1 (9VAC5-40-60 et seq.) of Part II 

of 9VAC5-40 (Existing Stationary Sources) apply. 

9VAC5-40-8430. Standard for odor.

The provisions of Article 2 (9VAC5-40-130 et seq.) of Part 

II of 9VAC5-40 (Existing Stationary Sources) apply. 

9VAC5-40-8432. Standard for toxic pollutants.

The provisions of Article 4 (9VAC5-60-200 et seq.) of Part 

II of 9VAC5-60 (Hazardous Air Pollutant Sources) apply. 

9VAC5-40-8434. Compliance.

A. The provisions of 9VAC5-40-20 (Compliance) apply.

B. An emission test of the control device installed on a 

heatset web offset lithographic printing process dryer shall be 

performed to demonstrate compliance with the provisions of 

9VAC5-40-8424 B and C and 9VAC5-40-8436. The negative 

dryer pressure shall be established during the initial test using 

an airflow direction indicator, such as a smoke stick or 

aluminum ribbons, or a differential pressure gauge.

C. Once initial compliance has been demonstrated with the 

heatset web offset lithographic printing process dryer control 

requirements of 9VAC5-40-8424 B and C through 

performance testing of an catalytic or thermal oxidation 

control device, continuing compliance with the heatset web 

offset lithographic printing process dryer control 

requirements in 9VAC5-40-8424 B and C shall be 

demonstrated for the catalytic or thermal oxidation control 

device by monitoring the control device in accordance with 

9VAC5-40-8440 B 3, B 4, and B 5. The owner shall maintain 

the 3-hour average of the monitored temperature at a 

temperature no less than 50°F below the 3-hour average 

temperature that was recorded during the most recent 

performance test during which compliance was demonstrated. 

9VAC5-40-8436. Compliance schedule.

The owner shall comply with the provisions of this article as 

expeditiously as possible but in no case later than (insert a 
Regulations

Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

781

date corresponding to the first day of the 12th month after the 

effective date of this article).

Statutory Authority

9VAC5-40-8438. Test methods and procedures.

A. The provisions of 9VAC5-40-30 (Emission testing) 

apply.

B. The following EPA test methods shall be used to 

demonstrate compliance with the heatset web offset 

lithographic printing process dryer control device control

requirements in 9VAC5-40-8424 B and C.

1. Reference Method 1 or 1A, as appropriate, shall be used 

to select the sampling sites. 

2. Reference Method 2, 2A, 2C, or 2D, as appropriate, 

shall be used to determine the velocity and volumetric flow 

rate of the exhaust stream.

3. Reference Method 3 or 3A, as appropriate, shall be used 

to determine the concentration of O2 and CO2.

4. Reference Method 4 shall be used to determine moisture 

content.

5. Reference Methods 18, 25, or 25A shall be used to 

determine the VOC concentration of the dryer exhaust 

stream entering and exiting the control device, unless the 

alternate limit in 9VAC5-40-8424 B 2 or C 2 is being met, 

in which case only the VOC concentration of the dryer 

exhaust control device outlet shall be determined.

6. Reference Method 25A shall be used to determine the 

dryer exhaust control device inlet and outlet VOC 

concentrations when the control device outlet 

concentration is less than 50 ppmv VOC as carbon.

7 If the control device is an oxidizer, the combustion 

chamber temperature or catalyst bed inlet temperature 

corresponding to destruction efficiencies that meet the 

requirements of 9VAC5-40-8424 B or C, as appropriate, 

shall be recorded.

C. The VOC content of as-applied inks, varnishes and other 

coatings, fountain solutions, and cleaning materials shall be 

determined using Reference Method 24.

1. The analysis of as-supplied materials may be performed 

by the manufacturer or the supplier. Formulation 

information from the manufacturer may be used in lieu of 

Reference Method 24 analysis unless the board or the 

owner has reason to believe that the formulation 

information provided by the manufacturer is inaccurate.

2. The owner may use VOC content information provided 

by the manufacturer or supplier, such as the container 

label, the product data sheet, or the MSDS sheet to 

document the VOC content of the as-supplied material.

3. If fountain solution or cleaning materials are diluted by 

the owner prior to use, a calculation that combines the assupplied VOC content information provided by the 

manufacturer or supplier, the VOC content of the diluent, 

and the proportions in which they are mixed may be used 

to make a determination of VOC content of the as-applied 

fountain solution or cleaning material in lieu of Reference 

Method 24.

4. The owner shall conduct Reference Method 24 testing of 

any as-applied fountain solution or cleaning material used 

for offset lithographic printing operations at any time at the 

board's request. The owner shall be prepared to sample asapplied fountain solution or cleaning materials at all times.

D. A thermometer or other temperature detection device 

capable of reading the temperature of the fountain solution to 

within 0.5°F shall be used to determine compliance with 

fountain solution temperature requirements in 9VAC5-40-

8424 D.

E. The VOC composite partial vapor pressure of cleaning 

solutions shall be determined using the formula provided in 

9VAC5-40-8422 C or by an appropriate test method approved 

by the board.

1. The determination VOC composite partial vapor 

pressure for as-supplied cleaning solutions may be 

performed by the manufacturer or the supplier. The 

determination of as-applied composite vapor pressure 

based upon the manufacturer's instructions for dilution may 

be performed by the manufacturer or supplier.

2. The owner may use VOC composite partial vapor 

pressure information provided by the manufacturer or 

supplier, such as the container label, the product data sheet, 

or the Material Safety Data Sheet (MSDS), to document 

the VOC composite partial vapor pressure of the assupplied or as-applied cleaning materials.

3. The following provisions apply to the determination of 

VOC composite partial vapor pressure for cleaning 

materials that are diluted by the owner prior to use:

a. If the dilution is made according to the manufacturer's 

instructions, the VOC composite partial vapor pressure 

for the as-applied cleaning material provided by the 

manufacturer or supplier may be used.

b. If a dilution is made and an as-applied VOC composite 

partial vapor pressure has not been provided by the 

manufacturer or supplier, or if the dilution is not made 

according to the manufacturer's instructions, then the 

owner shall determine the VOC composite partial vapor 

pressure using the calculation method provided in 

9VAC5-40-8422 C.

4. The owner shall conduct testing of any as-applied 

cleaning materials used for offset lithographic printing 

operations at any time at the board's request. The owner 

shall be prepared to sample as-applied cleaning materials at 

all times.

9VAC5-40-8440. Monitoring.

A. The provisions of 9VAC5-40-40 (Monitoring) apply.

B. Periodic monitoring of offset lithographic printing 

operations shall be conducted as follows:
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Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

782

1. The alcohol concentration of offset lithographic printing 

process fountain solution shall be monitored with a 

hydrometer, equipped with temperature correction or with 

readings adjusted for temperature, and recorded at least 

once per shift or once per batch, whichever is longer. A 

standard solution shall be used to calibrate the hydrometer 

for the type of alcohol used in the fountain.

2. The temperature of refrigerated fountain solution shall 

be measured at the recirculating tank at least once per 

operating day.

3. The temperature of a catalytic or thermal oxidation 

control device shall be monitored at least once every 15 

minutes while the printing process is operating, and that 

temperature shall be recorded by an analog or digital 

recording device.

a. For a catalytic oxidizer, the dryer exhaust temperature 

upstream of the catalyst bed shall be monitored and 

recorded.

b. For a thermal oxidizer, the combustion chamber 

temperature of the oxidizer shall be monitored and 

recorded.

4. Catalyst bed material in a catalytic oxidation control 

device shall be inspected annually for general catalyst 

condition and any signs of potential catalyst depletion. 

Sampling and evaluation of the catalyst bed material shall 

be conducted whenever the results of the inspection 

indicate signs of potential catalyst depletion or poor 

catalyst condition based on manufacturer's 

recommendations, but not less than once per year.

5. If a heatset web offset lithographic printing process is 

interlocked to ensure that the control device is operating 

and airflow is present when the printing process is 

operating, then periodic monitoring of dryer air flow is not 

required. If no interlock is present, then the printing 

process dryer air flow shall be verified and recorded once 

per operating day.

9VAC5-40-8450. Notification, records, and reporting.

The provisions of 9VAC5-40-50 (Notification, records, and 

reporting) apply.

9VAC5-40-8460. Registration.

The provisions of 9VAC5-20-160 (Registration) apply.

9VAC5-40-8470. Facility and control equipment 

maintenance or malfunction.

The provisions of 9VAC5-20-180 (Facility and control 

equipment maintenance or malfunction) apply.

9VAC5-40-8480. Permits.

A permit may be required prior to beginning any of the 

activities specified below if the provisions of 9VAC5-50 

(New and Modified Stationary Sources) and 9VAC5-80 

(Permits for Stationary Sources) apply. Owners 

contemplating such action should review those provisions and 

contact the appropriate regional office for guidance on 

whether those provisions apply.

1. Construction of a facility.

2. Reconstruction (replacement of more than half) of a 

facility.

3. Modification (any physical change to equipment) of a 

facility.

4. Relocation of a facility.

5. Reactivation (re-startup) of a facility.

6. Operation of a facility. 

VA.R. Doc. No. R10-2126; Filed December 18, 2014, 8:00 a.m. 

Proposed Regulation

Title of Regulation: 9VAC5-40. Existing Stationary 

Sources (Rev. D09) (adding 9VAC5-40-8510 through 

9VAC5-40-8800). 

Statutory Authority: § 10.1-1308 of the Code of Virginia; 

federal Clean Air Act (§§ 110, 111, 123, 129, 171, 172, and 

182); 40 CFR Parts 51 and 60.

Public Hearing Information:

February 26, 2015 - 11 a.m. - Department of 

Environmental Quality, Northern Regional Office, 13901 

Crown Court, Woodbridge, VA 22193

Public Comment Deadline: March 13, 2015.

Agency Contact: Karen G. Sabasteanski, Department of 

Environmental Quality, 629 East Main Street, P.O. Box 1105, 

Richmond, VA 23218, telephone (804) 698-4426, FAX (804) 

698-4510, or email karen.sabasteanski@deq.virginia.gov.

Basis:

State Requirements.

Section 10.1-1308 of the Virginia Air Pollution Control Law 

(Chapter 13 of Title 10.1 of the Code of Virginia) gives the 

State Air Pollution Control Board the discretionary authority 

to promulgate regulations abating, controlling, and 

prohibiting air pollution throughout or in any part of the 

Commonwealth. Section 10.1-1300 of the Code of Virginia 

defines air pollution as "the presence in the outdoor 

atmosphere of one or more substances which are or may be 

harmful or injurious to human health, welfare or safety, to 

animal or plant life, or to property, or which unreasonably 

interfere with the enjoyment by the people of life or 

property." 

These specific amendments are not required by state mandate. 

Specific Federal Requirements.

Ground-level ozone is an air pollutant that forms when 

volatile organic compounds (VOCs) and nitrogen oxides 

(NOX) interact with sunlight. The national standard for ozone 

measured over an 8-hour period was promulgated by the U.S. 

Environmental Protection Agency (EPA) on July 18, 1997 

(62 FR 38856), at a level of 0.08 parts per million (ppm).
1

ENCLOSURE 3

RECORD OF HEARING AND SUMMARY OF COMMENT

As required by 40 CFR 51.102(e), the complete record of the hearing, along with a list 

of commenters and the text of the written presentations or summary of the oral 

presentations, is located at the Air Division of the Department of Environmental Quality. 

The Department contact to access this information is the Director, Air Division.

As required by Section 2.1(h) of Appendix V of 40 CFR Part 51, a copy of the 

comments received and responses thereto is attached. Included is a brief statement of 

the subject, the identification of the commenter, the summary of the comment and the 

response (analysis and action taken). Each issue is discussed in light of all of the 

comments received that affect that issue. All comments have been reviewed and 

responses developed based on an evaluation of the issues raised in consideration of 

the overall goals and objectives of the air quality program and the intended purpose of 

the document under review.

TEMPLATES\SIP-REG\REG03-ph

SIP\NONATTN PLANS\2016\C09-SIP-3.DOC
COMMONWEALTH OF VIRGINIA

STATE AIR POLLUTION CONTROL BOARD

SUMMARY AND ANALYSIS OF PUBLIC COMMENT FOR

REGULATION REVISION C09

CONCERNING

LETTERPRESS AND OFFSET LITHOGRAPHIC PRINTING IN THE NORTHERN 

VIRGINIA VOC EMISSION CONTROL AREA

(9VAC5 CHAPTER 40)

INTRODUCTION

At the September, 2010 meeting, the Board authorized the Department to promulgate 

for public comment a proposed regulation revision concerning emission standards for

volatile organic compound emissions from letterpress and offset lithograph printing 

operations in the Northern Virginia VOC Emissions Control Area.

The public comment period began on January 12, 2015, with publication in the Virginia 

Register of Regulations. A public hearing was advertised accordingly and held in 

Woodbridge, Virginia on February 26, 2015 and the public comment period closed on 

March 13, 2015. The proposed regulation amendments subject to the hearing are 

summarized below followed by a summary of the public participation process and an 

analysis of the public comment, along with the basis for the decision of the Board.

SUMMARY OF PROPOSED AMENDMENTS

The proposed regulation amendments concerned provisions covering emission 

standards for volatile organic compound emissions from letterpress and offset 

lithograph printing operations in the Northern Virginia VOC Emissions Control Area. A 

summary of the amendments follows:

For existing Article 53 pertaining to earlier standards for lithographic operations in all 

VOC emissions control areas, applicability provisions for facilities located in the 

Northern Virginia VOC emissions control area are deleted. Provisions of Article 53 

applicable to sources in the Northern Virginia VOC emissions control area are 

preserved in Article 56, most notably (i) offset lithographic printing process dryer control 

provisions for sources with a facility potential to emit between 10 tons of VOC per year 

and having individual presses with a theoretical potential to emit 25 tons of VOC per 

year, and (ii) limits on the VOC content of cleaning materials (30% instead of 70%). 

For each new article (Articles 56 and 56.1):

1. An applicability section is established which specifies that facilities in the Northern 
Virginia VOC emissions control area are affected.

2. Definitions of terms used in the rule are provided.

3. A standard for VOC emissions is established, along with provisions for achieving the 

standard.

4. Compliance provisions are provided detailing how compliance is determined with the 

standards.

5. Test methods are provided by which compliance may be determined.

6. Monitoring provisions are provided to ensure that the owner is able to stay in 

compliance with the standards.

7. Standard provisions are provided for visible emissions; fugitive dust/emissions; odor; 

toxic pollutants; a compliance schedule; notification, records and reporting; registration; 

facility and control equipment maintenance or malfunction; and permits.

SUMMARY OF PUBLIC PARTICIPATION PROCESS

A public hearing was held in Woodbridge, Virginia on February 26, 2015. One person 

attended the hearing but did not comment on this revision. Two sets of written 

comments were received during the public comment period. As required by law, notice 

of this hearing was given to the public on January 12, 2015 in the Virginia Register and 

in the Washington Times, a major newspaper in the affected Air Quality Control Region. 

In addition, personal notice of this hearing and the opportunity to comment was given 

by mail to those persons on the Department's list to receive notices of proposed 

regulation revisions. A list of hearing attendees is included in the hearing report which 

is on file at the Department.

ANALYSIS OF COMMENT

Below is a summary of each person's comments and the accompanying analysis. 

Included is a brief statement of the subject, the identification of the commenter, the text 

of the comment and the Board's response (analysis and action taken). Each issue is 

discussed in light of all of the comments received that affect that issue. The Board has 

reviewed the comments and developed a specific response based on its evaluation of 

the issue raised. The Board's action is based on consideration of the overall goals and 

objectives of the air quality program and the intended purpose of the regulation.

1. SUBJECT: Malfunctions.
COMMENTER: U.S. Environmental Protection Agency (EPA)

TEXT: These regulations contain the provision "Facility and control equipment 

maintenance or malfunction," which incorporates by reference the provisions of 

9VAC5-20-180. This regulation contains Virginia’s affirmative defense for 

malfunction (subsection G). EPA cannot approve any State Implementation Plan 

(SIP) revisions containing 9VAC5-20-180 G as presently written. 

By notice published on February 22, 2013 (78 FR 12459), EPA proposed to take 

action on a petition for rulemaking that the Sierra Club filed with the EPA 

Administrator on June 30, 2011. In that proposal notice, we described and 

proposed the EPA’s response to the petition concerning the treatment of excess 

emissions from sources during periods of startup/shutdown/malfunction (SSM) in 

SIPs. EPA proposed to find these provisions are substantially inadequate 

because they are not consistent with fundamental legal requirements of the 

Clean Air Act, and EPA proposed to issue a SIP call to each affected state for 

these specific provisions. In the February 2013 proposal notice, EPA included 

Virginia’s 9VAC5-20-180 G. 

Subsequent to EPA’s issuance of the February 2013 proposal, a federal court 

ruled that §§ 113 and 304 of the Act preclude EPA authority to create affirmative 

defense provisions in EPA’s own regulations imposing emission limits on 

sources, because such provisions purport to alter the jurisdiction of federal 

courts to assess liability and impose penalties for violations of those limits in 

private civil enforcement cases. See NRDC v. EPA, 749 F.3d 1055 (D.C. 

Cir.2014). 

EPA believes that the reasoning of the United States Court of Appeals for the 

District of Columbia Circuit in NRDC v. EPA indicates that the states, like EPA, 

have no authority in SIP provisions to alter the jurisdiction of federal courts to 

assess penalties for violations of Act requirements through affirmative defense 

provisions. If states lack authority under the Act to alter the jurisdiction of the 

federal courts through affirmative defense provisions in SIPs, then the EPA lacks 

authority to approve any such provision in a SIP. 

Therefore, in a supplemental proposed rulemaking (SNPR) on states' affirmative 

defense provisions for malfunctions in SIPs, we supplemented and revised what 

we had earlier proposed as our response to the Petitioner’s requests in our 

February 2013 rulemaking, but only to the extent the requests narrowly concern 

affirmative defense provisions in SIPs. See 79 FR 55920 (September 17, 2014).

This SNPR also identified Virginia’s 9VAC5-20-180 G among other states’ 

regulations. In the SNPR, EPA proposed to find that these provisions for 

affirmative defenses are substantially inadequate because they are not 

consistent with fundamental legal requirements of the Act, and EPA proposed to 

issue a SIP call to each affected state, including Virginia, for these specific 

provisions. EPA is addressing state regulations which contain provisions related 
to exemptions or affirmative defenses in this separate rulemaking. See 78 FR 

12460 and 79 FR 55920. In the meantime, EPA encourages any state having 

deficient SSM provisions to take steps to correct them as soon as possible. 

RESPONSE: In EPA's September 17, 2014 (79 FR 55920) supplemental 

proposal, EPA reiterated that 9VAC5-20-180 G is substantially inadequate to 

meet Act requirements and is thus proposing to issue a SIP call with respect to 

this provision. It is anticipated that this proposal will become final in May 2015; 

states will have 18 months after that date to submit a corrected SIP.

Virginia's current series of CTG rules for the control of VOC (Revisions C09, D09 

and E09) were approved by the Governor to be issued for public comment on 

December 10, 2014. This started a mandatory Administrative Process Act (APA) 

clock for the remainder of the regulatory process. In order to meet the APA 

schedule (as well as fulfill the state's federal obligation to promulgate these 

regulations), the regulations will be adopted as final by the State Air Pollution 

Control Board at the June 2015 meeting.

Because the final SIP call malfunction rule was signed on May 22, 2015, the 

department will not have time to modify the malfunction rules in time such that 

reference to them in the CTG rules is not an issue. Therefore, the affected 

malfunction provisions of the CTG rules will simply not be submitted as part of 

the initial SIP revision for those rules. This will enable EPA to approve the 

remainder of the CTG rules into the SIP in a timely and administratively rational 

manner. When the final malfunction rule is published and the department is able 

to amend the malfunction regulations accordingly, the outstanding CTG 

provisions will be submitted as part of the SIP at the same time.

No change has been made to the proposal as a result of this comment.

2. SUBJECT: State-only provisions.

COMMENTER: U.S. EPA

TEXT: These regulations contain the provisions entitled "Standard for odor" and 

"Standard for toxic pollutants," which incorporate by reference the provisions in

9VAC5-40-130 (Emission Standards for Odor) and 9VAC5-60-200 (Emission 

Standards for Toxic Pollutants from Existing Sources). Section 107(a) of the 

Clean Air Act provides that State Implementation Plans are for the attainment 

and maintenance of national ambient air quality standards (NAAQS). The 

provisions in 9VAC5-40-130 and 9VAC5-60-200 are not applicable to the 

NAAQS. Therefore, EPA is concerned with SIP-approving provisions not in 

accordance with § 107(a), unless Virginia can explain how these are related to 

attainment and maintenance of the NAAQS. 
RESPONSE: As has been done in the past with other stationary source 

regulations for the control of VOC, the state-only odor and toxics provisions will 

not be submitted as part of the final SIP submittal. The public notice states, "It is 

planned to submit all provisions of the proposals as revisions to the 

Commonwealth of Virginia SIP with the exception of provisions related to state 

programs for odor and toxics." No change has been made to the proposal as a

result of this comment.

3. SUBJECT: The definition of "non-heatset" needs to be revised.

COMMENTER: Jay K. Goldscher, Printing and Graphics Association MidAtlantic 

(PGAMA).

TEXT: The definition for “Non-heatset” in 9VAC5-40-8382 and 9VAC5-40-8422 

needs to have “and/” inserted between “absorption” and “or” so that it reads as 

follows:

"Non-heatset" means a printing process in which the printing inks are set 

and dried by absorption and/or oxidation rather than heat. For the 

purposes of this article, UV-cured and electron beam-cured inks are 

considered non-heatset.

RESPONSE: The use of informal terms such as "and/or" is not consistent with 

the standards for style in regulatory technical writing. In this case, the word “or” is 

proper to convey the thought of “one, or the other, or any of them.” No change 

has been made to the proposal as a result of this comment.

4. SUBJECT: The definitions of "letterpress printing operation" and "offset

lithographic printing operation" need to be revised.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: The definitions for “Letterpress printing operation” in 9VAC5-40-8382 and 

"Offset lithographic printing operation" in 9VAC5-40-8422 are very confusing and 

need to be revised so that it reflects the intent of the applicability. 

"Letterpress printing operation" means one or more letterpress printing 

processes employing letterpress printing on letterpress printing presses 

and the related processes necessary to directly support the operation of 

those presses including, but not limited to, cleaning, prepress, and postpress operations.

"Offset lithographic printing operation" means one or more printing 

processes employing offset lithographic printing on offset lithographic 
printing presses and includes the related processes necessary to directly 

support the operation of those offset lithographic printing processes 

including, but not limited to, pre-press and post-press operations. 

Varnishes, glues, and other coatings that are applied by an offset 

lithographic printing process are part of offset lithographic printing 

operations and are not considered as a separate process (e.g., paper 

coating)

RESPONSE: As proposed, the definitions describe the facility (letterpress 

printing operation or offset lithographic printing operation) in terms of specific 

equipment (letterpress printing presses or offset lithographic printing presses) 

using a specific technique (letterpress printing or offset lithographic printing), the 

printing system that uses the defined equipment and technique (letterpress 

printing process or offset lithographic printing process), and the ancillary 

processes necessary to keep the system operating. Omitting the term "printing 

process" from the definition might be interpreted as excluding surface coating 

operations and this interpretation would not be correct. However, the point that 

the definitions are wordy and repetitive and therefore confusing is well taken. 

Appropriate changes reflecting the intent of the comment have been made to the 

proposal.

5. SUBJECT: The definition for “Printing Process” needs to be revised. 

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: The definition for “Printing Process” in 9VAC5-40-8382 and 9VAC5-40-

8422 needs to be slightly revised as it includes terms that are not applicable to 

printing presses or other printing equipment. Therefore, the definition should be 

revised as follows:

"Printing process" means any operation or system wherein printing ink or 

a combination of printing ink and surface coating is applied, dried, or 

cured and that is subject to the same emission standard. A printing 

process may include any equipment that applies, conveys, dries, or cures 

inks or surface coatings including, but not limited to, presses, digital 

output devices, fountain solutions, heaters, and dryers. flow coaters, 

flashoff areas, air dryers, drying areas, and ovens.

RESPONSE: The term "printing process" is more inclusive than applying only to 

printing techniques. It also refers to surface coatings that may be applied as part 

of the same process. It is therefore appropriate to describe equipment and 

terms that may be used in surface coating operations as well as those used on 

printing presses. Additionally, the listed equipment are examples of equipment 

that may be found on such a process. The list is not intended to be a list of 

required equipment or to implying that the presence of other equipment would 
exclude a certain printing line from the definition. That said, this definition can be 

revised to be particular to the printing process that is regulated in that article 

(Article 56 for letterpress printing operations and Article 56.1 for offset 

lithographic printing operations), so it is appropriate to include specific equipment 

that is proposed by stakeholders as being more appropriate to that printing 

process. Appropriate changes reflecting the intent of the comment have been 

made to the proposal.

6. SUBJECT: The definition of "Theoretical Potential to Emit" needs revision.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: The definition for “Theoretical potential to emit” in 9VAC5-40-8382 

includes a reference to heatset web offset lithographic, which limits its 

applicability to only those types of printing operations and the reference should 

be deleted. In addition the term “emissions” needs to be inserted between “limit” 

and “production” as USEPA allows certain types of sources, including printing 

operations to limit their potential to emit by taking limits on emissions. USEPA’s 

position can be found in Section 6.3 of the June 2007 Technical Support 

Document (TSD) for Title V Permitting of Printing Facilities 

(http://www.epa.gov/airquality/permits/memoranda/tsd.pdf). Section 6.3 was 

specifically included in the document to provide printing operations with an 

enforceable mechanism that allows them the ability to maintain compliance with 

a limit while simultaneously providing needed operational flexibility. Section 6.3 is 

attached as Appendix A. 

Therefore, the definition should be revised as follows:

"Theoretical potential to emit" means for the purposes of this article the 

maximum capacity of a letterpress printing process to emit VOC and shall 

be based on emissions at design capacity or maximum production and 

maximum operating hours (8,760 hours/year) before add-on controls, 

unless the heatset web offset lithographic printing process is subject to 

state and federally enforceable permit conditions that limit emissions,

production rates, or hours of operation.

RESPONSE: The definition contains an erroneous reference to a lithographic 

printing press instead of the intended letterpress printing press. This comment is 

appropriate and changes reflecting the intent of this portion of the comment have 

been made to the proposal.

The definition of "theoretical potential to emit" serves the only use of the term in 

9VAC5-40-8284 (standard for volatile organic compounds) subsection B. The 

term is used as the method for determining the 25 ton per year dryer emissions 

exception to the dryer control requirements of subsection B of that section. 
Subdivision 3 of that subsection is clear that enforceable limits on the VOC 

content and application rates of inks and coatings (among other limits) may be 

used to meet that exception. No change has been made to the proposal as a 

result of this portion of the comment. 

7. SUBJECT: A definition for “Batch” needs to be added.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: A definition for “batch” should be added to 9VAC5-40-8382 and it should 

read as follows:

"Batch" means a supply of fountain solution that is prepared in a discrete 

amount or continuously blended with an automatic mixing unit, or a 

cleaning solution that is prepared in a discrete amount or blended and 

delivered with an automatic blanket or roller wash system and used 

without alteration until completely used or removed from the printing 

process.

RESPONSE: Because fountain solution is not applied on letterpress printing 

presses and because the term "batch" is not used in Article 56, there is no 

reason to define such a term in 9VAC5-40-8382. No change has been made to 

the proposal as a result of this comment.

8. SUBJECT: The definition for “Unit” needs to be revised.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: The definition for “Unit” in 9VAC5-40-8382 needs to be revised because 

it describes a lithographic printing press unit and not a letterpress printing unit. It 

should read as follows:

"Unit" means the smallest, complete printing component, composed of an 

inking and dampening system of a printing press.

RESPONSE: This comment is appropriate and changes reflecting the intent of 

the comment have been made to the proposal.

9. SUBJECT: The 25 ton exemption for letterpress inks is applied inappropriately.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivision 9 VAC5-40-8384 (B) of the proposed rule is an exemption 
from requirements of 9 VAC5-40-8384 (B) for any heatset web letterpress 

printing process with the potential to emit of 25 tons per year of VOC or more 

from the heatset web letterpress printing dryer. 

This exemption level is not consistent with the CTG as this exemption threshold 

applies only to the emissions of ink oil and not total VOC from the press dryer. 

EPA purposely focused on ink oil or ink VOC as ink oil constitutes almost all of 

the VOC that is released in the dryer. It is important to note that letterpress inks 

are identical to offset lithographic inks. This means that the provisions identified 

by the USEPA and the CTG for offset lithographic inks would apply to letterpress 

inks.

On page 5 of the CTG, EPA states the following:

“We recommend a different applicability threshold for 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 presses with potential to emit from the dryer, prior 

to controls, of at least 25 tpy of VOC (petroleum ink oil) from heatset inks. 

 

In addition, the provision needs to be revised so that it clearly states it applies to 

a single heatset web offset lithographic printing process.

Therefore, Subdivision 9 VAC5-40-8384 (B) should be revised to read as follows:

B. The following provisions apply to each dryer on each heatset web 

letterpress printing process, except that these provisions do not apply to 

(i) any heatset web letterpress printing process with a theoretical potential 

to emit less than 25 tons per year of VOC (petroleum ink oil) from the 

dryer, prior to controls; (ii) any heatset web letterpress printing process 

used exclusively for book printing; or (iii) any heatset web letterpress 

printing process with a maximum web width of 22 inches or less. These 

provisions also do not apply to non-heatset web letterpress printing 

processes or to sheet-fed letterpress printing processes.

RESPONSE: The CTG clearly intended that the 25 tpy exception to apply only 

to ink oils and not to dryer combustion emissions or VOC emissions from other 

coatings. This comment is appropriate and changes reflecting the intent of the 

comment have been made to the proposal.

10. SUBJECT: The reference to "other coatings applied" needs to be deleted.
COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivision 9 VAC5-40-8384 (B)(3) needs to be revised to reflect that the 

25 ton limit is for petroleum ink oil and “other coatings applied” needs to be 

deleted as only inks and varnishes contain ink oil. In addition, “VOC emissions” 

needs to be added as option (v) as limiting emissions from printing operations 

and presses can be used as a federally enforceable approach per Section 6.3 of 

the June 2007 Technical Support Document (TSD) for Title V Permitting of 

Printing Facilities. 

Therefore, Subdivision 9 VAC5-40-8384 (B)(3) should be revised to read as 

follows:

3. Federally enforceable limitations on (i) the VOC (petroleum ink oil)

content of inks and varnishes, and other coatings applied; (ii) the total 

amounts of inks and varnishes, and other coatings applied; (iii) the press 

application rates of inks and varnishes, and other coatings; or (iv) the 

hours of press operation; or (v) emissions of VOC (petroleum ink oil) may 

be used to meet the 25 ton per year exception to this subsection.

RESPONSE: The CTG clearly intended that the 25 tpy exception to apply only 

to petroleum ink oils and not to dryer combustion emissions or non-petroleum ink 

oil VOC emissions from other coatings. See the response to comment 9. This 

comment is appropriate and changes reflecting the intent of this portion of the 

comment have been made to the proposal.

The phrase "other coatings applied" as used in the proposed subdivision 3 of 

that subsection will include varnishes that contain ink oil and also any other 

coatings that contain petroleum ink oil that may be used in the future. Limiting 

the description of the coatings to varnishes would unnecessarily limit the 

applicability of future contributors to the 25 tpy petroleum ink oil exception. 

However, since only petroleum ink oil contributors are applied prior to the dryer, 

a change has been made to the proposal as a result of this portion of the 

comment. 

Settling the issue of whether federally enforceable emissions limitations are 

practically enforceable based upon equations in a Title V TSD is beyond the 

scope of this revision. No change has been made to the proposal as a result of 

this portion of the comment.

11. SUBJECT: Testing requirements needs to be revised so that it is not mandatory.

COMMENTER: Jay K. Goldscher, PGAMA.
TEXT: Subdivision 9VAC5-40-8396 (B) needs to be revised by adding the 

phrase “If requested” between “performed” and “to” as there is not mandatory 

testing requirement contained in the CTG. Due to the significant costs involved 

with testing of an oxidizer, it should only be required if requested by the VADEQ. 

In addition, testing is usually mandated when a facility obtains an operating 

permit and including a provision of this nature could require a facility to retest an 

oxidizer that would have been recently tested.

To prevent mandatory retesting at a frequency not mandated by an operating 

permit, an additional sentence needs to be added to this provision allowing for 

previous testing to be acceptable. The sentence should be, “Board may accept 

the results of an emission test conducted prior to the effective date of this rule, if 

the owner or operator provides information and data which demonstrate that an 

approved USEPA emission test method was employed and the test report was 

accepted.”

The provision needs to be revised to reflect the testing requirements necessary 

for a successful destruction efficiency determination for an oxidizer used to 

control emissions from a heatset letterpress press. The nature of the emissions 

from heatset letterpress press is such that simply following EPA protocols will 

result in failure forcing either re-testing or enforcement action. As such, USEPA 

recommended compliance testing should be conducted at operating conditions 

representative of a typical production schedule.

On page 67 of the Technical Support Document for Title V Permitting of Printing 

Operations, USEPA states:

“5.7 WHAT ARE THE APPROPRIATE PERFORMANCE TEST 

CONDITIONS?

Compliance testing for VOC and HAP emissions at printing facilities 

should be conducted under normal or representative operating conditions, 

in accordance with 40 CFR 60 subpart QQ, §60.433(a)(8); 40 CFR 63 

subpart KK, §63.827(d)(1)(vii); the draft CTG for Offset Lithography (EPA, 

1993b); and our National Stack Testing Guidance (EPA, 2004). These 

sections require compliance testing to be conducted under normal or 

representative operating conditions. We also recognize that a pre-test 

meeting between the printing facility owner or operator and you may 

provide a convenient opportunity to define normal, representative 

operation. During such a meeting, the owner or operator may propose an 

operating scenario for testing that is representative of actual operating 

conditions and the VOC/HAP input rate to the control device. Such 

operating conditions should strive to minimize downtime while running as 

many presses as practicable, when multiple presses are being served by 

a common control device. The proposed operating scenario should also 

be reflective of a typical normal production schedule. As necessary, 
proposed testing conditions should rely on historical production records 

for establishing average coverage rates, press speeds, or ink and other 

input material consumption rates, run times, and average time of 

intermittent events such as press cleaning, web breaks or similar 

shutdown situations. 

Because activities such as cycling of automatic blanket washing systems, 

press speed variations, web breaks or other short-term events in which 

the print quality is being checked, may be a part of normal, representative 

operations, we recommend that sampling continue during these shortterm events while the control device is being tested. All testing conditions 

should be thoroughly discussed and approved by you prior to the actual 

test date.”

Therefore, Subdivision 9 VAC5-40-8396 (B) should be revised so that it reads as 

follows:

B. An emission test of the control device installed on a heatset web 

letterpress press printing process dryer shall be performed under normal 

representative conditions, if requested, to demonstrate compliance with 

the provisions of 9VAC5-40-8384 B and C and 9VAC5-40-8398. The 

negative dryer pressure shall be established during the initial test using an 

airflow direction indicator, such as a smoke stick, aluminum ribbons, or a 

differential pressure gauge. The board may accept the results of an 

emission test conducted prior to the effective date of this rule if the owner 

or operator provides information and data that demonstrate an approved 

USEPA emission test method was employed and the test report was 

accepted. 

RESPONSE: Concerning the request to make testing and retesting nonmandatory, this portion of the comment is appropriate and changes reflecting the 

intent of the comment have been made to the proposal.

Testing during normal representative conditions is required by 9VAC5-40-30 C, 

which is incorporated into this Article by 9VAC5-40-8438 A. No change has 

been made to the proposal as a result of this portion of the comment.

12. SUBJECT: Testing requirements need to be revised to preserve flexibility.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivision 9VAC5-40-8400 (C) needs the phrase “or one of the 

following methods” inserted after “Reference Method 24” as the current phrasing 

does not allow subdivisions 9VAC5-40-8400 (C) (1), (C) (2), (C)(3), or (C) (4) to 

be used to meet the condition. 
Therefore, Subdivision 9 VAC5-40-8400 (C) should be revised so that it reads as 

follows:

C. The VOC content of as-applied inks, varnishes and other coatings, 

fountain solutions, and cleaning materials shall be determined using 

Reference Method 24 or one of the following methods: 

RESPONSE: The requirement is that the VOC content be determined by 

Reference Method 24. It does not specify who must do that determination. The 

subdivisions are not alternatives to the requirement for testing with Reference 

Method 24. Subdivisions under subsection C clarify how the owner may 

demonstrate compliance with that Reference Method 24 requirement. . 

Subdivision 1 says that the required Reference Method 24 testing may be done 

by other persons in the supply chain instead of by the owner of the printing 

facility. Subdivision 2 says that the owner can rely upon the Reference Method 

24 testing information supplied by several documents provided by the 

manufacturer or supplier. Subdivision 3 allows a dilution calculation using 

supplied Reference Method 24 information. Subdivision 4 requires the owner to 

test using the reference method at any time if requested by the board. No 

change has been made to the proposal as a result of this comment.

13. SUBJECT: Testing requirements need to be updated for OSHA form changes.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivisions 9VAC5-40-8400 (C) (2) and 9VAC5-40-8438 (C) (2) should 

have the words “MSDS sheet” deleted and replaced with Safety Data Sheet 

(SDS) as the changes OSHA made to the Hazard Communication Standard has 

eliminated Material Safety Data Sheets and replaced them with Safety Data 

Sheets. 

Therefore, Subdivisions 9 VAC5-40-8400 (C) (2) and 9VAC5-40-8438 (C) (2) 

should be revised so that they read as follows:

2. The owner may use VOC content information provided by the 

manufacturer or supplier, such as the container label, the product data 

sheet, or the MSDS sheet Safety Data Sheet (SDS) to document the VOC 

content of the as-supplied material.

RESPONSE: This comment is appropriate and changes reflecting the intent of 

the comment have been made to the proposal.
14. SUBJECT: Testing requirements need revision to reflect batch calculations. 

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivision 9VAC5-40-8400 (C) (3) needs to add the words “fountain 

solution or” between “If” and “cleaning materials.” Also an additional sentence 

needs to be added that should be revised to indicate that the calculation only 

needs to be performed once for each batch of fountain solution or cleaning 

material being used, not for each use of a batch of a solution. Since more than 

one fountain solution or cleaning material can be used on different presses in 

one operation, the calculation needs to be performed for each fountain solution 

and cleaning material. This is important as once the printing operation 

determines the proper mix ratio for its fountain solution or cleaning material, the 

mix ratio is not altered. 

Therefore, Subdivision 9 VAC5-40-8400 (C) (3) should be revised so that it reads 

as follows:

3. If fountain solution or cleaning materials are diluted by the owner prior 

to use, a calculation that combines the as-supplied VOC content 

information provided by the manufacturer or supplier, the VOC content of 

the diluent, and the proportions in which they are mixed, may be used to 

make a determination of the VOC content of the as-applied fountain 

solution or cleaning material in lieu of Reference Method 24. The VOC 

content shall be calculated only once representing for each batch of 

press-ready, as applied, fountain solution’s or cleaning material’s mix ratio 

and recorded in the form of a batch log.

RESPONSE: Letterpress printing operations do not use fountain solution. 

Nothing in subdivision C 3 precludes a calculation "per batch" or requires a 

calculation "per use", so it is entirely appropriate to calculate the VOC content 

per batch instead of per use according to subdivision C 3. No change has been 

made to the proposal as a result of this comment.

15. SUBJECT: Testing requirements need revision to preserve flexibility.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivision 9VAC5-40-8400 (D) needs the phrase “or one of the 

following methods” inserted after “Reference Method 24” as the current phrasing 

does not allow subdivisions 9VAC5-40-8400 (D) (1), (D) (2), (D)(3), or (D) (4) to 

be used to meet the condition. 

Therefore, Subdivision 9 VAC5-40-8400 (D) should be revised so that it reads as 

follows:
D. The VOC composite partial vapor pressure of cleaning solutions shall 

be determined using the formula provided in 9VAC5-40-8382 C or by an 

appropriate test method approved by the board or one of the following 

methods:

RESPONSE: The requirement is that the VOC composite partial vapor pressure

be determined by the referenced formula (or equivalent method). It does not 

specify who must do that determination. The subdivisions are not alternatives to 

the requirement for determining the VOC composite partial vapor pressure. 

Subdivisions under subsection C clarify how the owner may demonstrate 

compliance with that calculation requirement. Subdivision 1 says that the 

determination may be done by other persons in the supply chain instead of by 

the owner of the printing facility. Subdivision 2 says that the owner can rely upon 

the determinations supplied by several documents provided by the manufacturer 

or supplier. Subdivision 3 allows a dilution calculation using supplied information. 

Subdivision 4 requires the owner to test if requested by the board. No change 

has been made to the proposal as a result of this comment.

16. SUBJECT: Testing requirements need to be updated for OSHA form changes.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivisions 9VAC5-40-8400 (D) (2) and 9VAC5-40-8438 (E) (2) should 

have the words “Material Safety Data Sheet (MSDS)” deleted and replaced with 

Safety Data Sheet (SDS) as the changes OSHA made to the Hazard 

Communication Standard has eliminated Material Safety Data Sheets and 

replaced them with Safety Data Sheets. 

Therefore, Subdivisions 9 VAC5-40-8400 (D) (2) and 9VAC5-40-8438 (E) (2) 

should be revised so that it reads as follows:

2. The owner may use VOC composite partial vapor pressure information 

provided by the manufacturer or supplier, such as the container label, the 

product data sheet, or the Material Safety Data Sheet (MSDS) Safety 

Data Sheet (SDS), to document the VOC composite partial vapor 

pressure of the as supplied or as-applied cleaning materials.

RESPONSE: This comment is appropriate and changes reflecting the intent of 

the comment have been made to the proposal.

17.SUBJECT: Definition of "heatset web offset lithographic printing dryer" needs to 

be revised.
COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: The definition for “Heatset web offset lithographic printing dryer” in 

9VAC5-40-8422 needs to be revised because heatset lithographic inks do not 

cure, but dry by evaporation. Therefore, the definition should be revised as 

follows:

"Heatset web offset lithographic printing dryer" means the dryer or dryers 

installed as part of a heatset web offset lithographic printing process that 

dries or cures inks or surface coatings.

RESPONSE: This comment is appropriate and changes reflecting the intent of 

the comment have been made to the proposal.

18. SUBJECT: The definition of "lithographic printing" needs to be revised.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: The definition for “Lithographic printing” in 9VAC5-40-8422 needs to be 

revised by deleting the last sentence which describes letterpress printing. 

Therefore, the definition should be revised as follows:

"Lithographic printing" means a planographic printing process in which the 

image and nonimage areas are chemically differentiated with the image 

area being oil receptive and the nonimage area being water receptive. 

This process differs from other printing processes, where the image is a 

raised or recessed surface.

RESPONSE: The sentence in question differentiates lithographic printing from 

many other types of printing, not just letterpress printing. Flexographic printing 

and rotogravure printing are two other examples of printing processes that are so 

differentiated. This sentence is not an exclusion so much as it is a clarification 

by example. No change has been made to the proposal as a result of this 

comment.

19. SUBJECT: The definition of "Theoretical Potential to Emit" needs revision.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: The definition for “Theoretical potential to emit” in 9VAC5-40-8422

includes a reference to heatset web offset lithographic, which limits its 

applicability to only those types of printing operations and the reference should 

be deleted. In addition the term “emissions” needs to be inserted between “limit” 

and “production” as USEPA allows certain types of sources, including printing 
operations to limit their potential to emit by taking limits on emissions. USEPA’s 

position can be found in Section 6.3 of the June 2007 Technical Support 

Document (TSD) for Title V Permitting of Printing Facilities 

(http://www.epa.gov/airquality/permits/memoranda/tsd.pdf). Section 6.3 was 

specifically included in the document to provide printing operations with an 

enforceable mechanism that allows them the ability to maintain compliance with 

a limit while simultaneously providing needed operational flexibility. Section 6.3 is 

attached as Appendix A. 

Therefore, the definition should be revised as follows:

"Theoretical potential to emit" means, for the purposes of this article, the 

maximum capacity of a letterpress printing process to emit VOC and shall 

be based on emissions at design capacity or maximum production and 

maximum operating hours (8,760 hours/year) before add-on controls, 

unless the heatset web offset lithographic printing process is subject to 

state and federally enforceable permit conditions that limit emissions,

production rates or hours of operation.

RESPONSE: The definition in 9VAC5-40-8422 specifies that it applies only to 

the proposed Article 56.1 and as such will only apply to offset lithographic 

printing processes. 

The definition of "theoretical potential to emit" in this section serves the uses of 

the term in 9VAC5-40-8424 (standard for volatile organic compounds) 

subsection B subdivision 3 a and subsection C, both of which apply only to 

heatset web offset lithographic printing processes. The term is used as the 

method for determining the 25 ton per year dryer emissions exception to the 

dryer control requirements of subsection B and C of that section. Subdivision 3 

of subsection C is clear that enforceable limits on the VOC content and 

application rates of inks and coatings (among other limits) may be used to meet 

that exception in subsection C. No change has been made to the proposal as a 

result of this portion of the comment.

20. SUBJECT: The 25 tpy VOC exception is not consistent with the CTG.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivision 9 VAC5-40-8424 (B)(3)(a) of the proposed rule is an 

exemption from requirements of 9 VAC5-40-8424 (B) for any heatset web offset 

lithographic printing process with the potential to emit of 25 tons per year of VOC 

or more from the heatset web offset lithographic printing dryer. 

This exemption level is not consistent with the CTG as the requirements for add 

on controls only apply to presses with potential VOC (petroleum ink oil) 
emissions that are greater than 25 tons per year. EPA chose this threshold due 

to the cost associated with installing and operating a control device and deemed 

controlling emissions that are less than this threshold to be excessive and not 

reasonable.

This exemption threshold needs to be revised as it only applies to the emissions 

of ink oil and not total VOC from the press dryer. EPA purposely focused on ink 

oil or ink VOC as ink oil constitutes almost all of the VOC that is released in the 

dryer. 

On page 5 of the CTG, EPA states the following:

“We recommend a different applicability threshold for 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 presses with potential to emit from the dryer, prior 

to controls, of at least 25 tpy of VOC (petroleum ink oil) from heatset inks. 

We recommend providing printers with the option of using an enforceable 

limitation on potential emissions to keep an individual press below 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 Permitting of Printing Facilities (see Appendix A). We believe 

add-on control for heatset presses with potential to emit below 25 tpy is 

too costly for the emission reduction that would be achieved. 

In addition, the provision needs to be revised so that it clearly states it applies to

a single heatset web offset lithographic printing process.

Therefore, Subdivision 9 VAC5-40-8424 (B)(3)(a) should be revised to read as 

follows:

a. Any single heatset web offset lithographic printing process with a 

theoretical potential to emit of 25 tons per year of VOC (petroleum ink oil)

or more (less) from the heatset web offset lithographic printing dryer. VOC 

standards for heatset web offset lithographic printing process with a 

theoretical potential to emit of 25 tons per year of VOC (petroleum ink oil)

or more are provided in subsection C of this section.

RESPONSE: Subdivision 9 VAC5-40-8424 B 3 a is an exception to the dryer 

standards for facilities that were subject to Article 53 (covered in subsection B of 

this section). By the current wording of subsection B 3, it applies to each dryer. It 

directs the reader to the section C for standards for applicable dryers with a 

theoretical potential to emit (TPTE) of 25 tons per year of VOC or more. So this 

exception is correct as "25 tons per year of VOC (petroleum ink oil) or more." No 
change has been made to the proposal as a result of this portion of the 

comment.

This portion of the comment concerning the addition of "(petroleum ink oil)" after 

"VOC" is appropriate and changes reflecting the intent of this portion of the 

comment have been made to the proposal.

21. SUBJECT: Dryer outlet concentration is not consistent with the CTG. 

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivision 9 VAC5-40-8424 (B)(2) needs to be revised by deleting “50 

parts per million volume (ppmv) or less, as carbon (minus methane and ethane)” 

and replacing it with “20 parts per million volume (ppmv) or less, as hexane on a 

dry basis.” This would provide consistency with the CTG and 9VAC5-40-8424 

(C)(2). 

Therefore, subdivision 9 VAC5-40-8424 (B)(2) should be revised to read as 

follows:

2. Where the heatset web offset lithographic printing process control 

device inlet VOC concentration is too low to achieve the control device 

efficiency requirements specified in subdivisions (1) (C) of this subsection 

or there is no identifiable measurable inlet, the control device shall reduce 

the VOC concentration of the heatset web offset lithographic printing 

process dryer exhaust air to 50 parts per million volume (ppmv) or less, as 

carbon (minus methane and ethane). 20 parts per million volume (ppmv) 

or less, as hexane on a dry basis.

RESPONSE: The proposed Article 56.1 is to be applicable in certain areas

(specifically the Northern Virginia VOC Emissions Control Area) where the CTGspecified RACT must be applied to the specified source category. However, 

there are standards already applicable to offset lithographic printing operations in 

Virginia in 9VAC5 Chapter 40 Article 53. Even though the new RACT for the 

Northern Virginia VOC Emissions Control Area is more restrictive in some ways 

for press dryers with a theoretical potential to emit (TPTE) greater than 25 tons 

per year of VOC, the existing rule applies some dryer standards to facilities down 

to a potential to emit of 10 tons of VOC per year. For those facilities, the 

standards of Article 53 must be carried forward into the new Article 56.1. 

Subsection 9VAC5-40-8424 B does that, so the appropriate standard for heatset 

web offset lithographic printing process dryers (carried from Article 53, 9VAC5-

40-7820 B 2 with a TPTE less that 25 TPY) is 50 parts per million volume (ppmv) 

or less, as carbon (minus methane and ethane). No change has been made to 

the proposal as a result of this comment.
22. SUBJECT: The reference to "other coatings applied" needs to be deleted.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivision 9 VAC5-40-8424 (C)(3) needs to be revised to reflect that the 

25 ton limit is for petroleum ink oil and “other coatings deleted” as only inks and 

varnishes contain ink oil. In addition, “VOC emissions” needs to be added as 

option (v) as limiting emissions from printing operations and presses can be used 

as a federally enforceable approach per Section 6.3 of the June 2007 Technical 

Support Document (TSD) for Title V Permitting of Printing Facilities. 

Therefore, Subdivision 9 VAC5-40-8424 (C)(3) should be revised to read as 

follows:

3. Federally enforceable limitations on (i) the VOC (petroleum ink oil)

content of inks and varnishes, and other coatings applied; (ii) the total 

amounts of inks and varnishes, and other coatings applied; (iii) the press 

application rates of inks and varnishes, and other coatings; or (iv) the 

hours of press operation; or (v) emissions of VOC (petroleum ink oil) may 

be used to meet the 25 ton per year exception to this subsection.

RESPONSE: The CTG clearly intended that the 25 tpy exception to apply only 

to petroleum ink oils and not to dryer combustion emissions or non-petroleum ink 

oil VOC emissions from other coatings. See the response to comment 9. This 

comment is appropriate and changes reflecting the intent of this portion of the 

comment have been made to the proposal.

The phrase "other coatings applied" as used in the proposed subdivision 3 of 

that subsection will include varnishes that contain ink oil and also any other 

coatings that contain petroleum ink oil that may be used in the future. Limiting 

the description of the coatings to varnishes would unnecessarily limit the 

applicability of future contributors to the 25 tpy petroleum ink oil exception. 

However, since only petroleum ink oil contributors are applied prior to the dryer, 

a change has been made to the proposal as a result of this portion of the 

comment.

Settling the issue of whether federally enforceable emissions limitations are 

practically enforceable based upon equations in a Title V TSD is beyond the 

scope of this revision. No change has been made to the proposal as a result of 

this portion of the comment.

23. SUBJECT: A 110 gallon cleaning material exclusion is needed.

COMMENTER: Jay K. Goldscher, PGAMA.
TEXT: Subdivision 9 VAC5-40-8424 (E) needs to have an exclusion provided for 

up to 110 gallons per year of any cleaning material that does meet either limit in 

9 VAC5-40-8424 (E)(1) or (E) (2). 

Due the nature of the materials and equipment being cleaned, an exclusion for 

110 gallons per year for cleaning materials not meeting the limits will provide a 

covered printing operation the flexibility to clean difficult areas on the press. The 

use of those types of cleaning solutions on a limited basis was recognized by 

USEPA and was included in its CTG, with an exclusion of 110 gallons per year 

as a reasonable amount. 

This request is supported by the information on page 3 of the CTG where 

USEPA states:

“...the cleaning control approaches recommended in this CTG include 

limitations on the VOC composite vapor pressure of cleaning materials 

and limits on the VOC content of cleaning materials, with an exclusion of 

110 gallons per year of cleaning materials which meet neither the low 

VOC composite vapor pressure recommendation nor the lower VOC 

content recommendation, and work practices. “

In addition, 9 VAC5-40-8424 (E)(1) needs to be revised by deleting “30%” and 

replacing it with “70%” per the CTG requirements for cleaning solutions. 

Although this limit was originally included in the 1993 draft CTG for Offset 

Lithography, it was subsequently superseded by the 70% by weight limit with the 

issuance of the 2006 CTG for Offset Lithographic Printing and Letterpress 

printing. 

During the development of the 2006 final CTG, the printing industry 

demonstrated to EPA that the 30% by weight VOC content limit in the 1993 CTG 

did not constitute an achievable technology and therefore EPA revised the limit 

to 70% by weight. 

On page 12 of the CTG, EPA states the following:

“Water miscible cleaning materials with less than 30 weight percent VOC 

were developed and tested for offset lithographic printing in the early 

1990’s. These materials were recommended as RACT in the 1993 draft 

CTG. These materials did not provide adequate performance and 

therefore they are not being used by the offset lithographic printing 

industry today. 

There are some water-miscible or exempt solvent containing cleaning 

materials that contain 70 weight percent VOC or less in use today. These 

lower VOC content materials are capable of performing many of the tasks, 
such as 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 cleaning materials or reduced VOC content cleaning materials.”

Therefore, Subdivision 9 VAC5-40-8424 (E) should be revised so that it reads as 

follows:

E. Cleaning materials used at each offset lithographic printing operation 

shall meet one of the following limits, as applied:

1. A VOC content of 30 70% by weight; or

2. A composite vapor pressure of 10 mm Hg at 20°C (68°F).

The use of cleaning materials not meeting the limits in subdivision 9 

VAC5-40-8424 (E) (1) or (E)(2) is permitted provided that the quantity 

used does not exceed 110 gallons over any twelve consecutive months

RESPONSE: The portion of the comment concerning the 110 gallon exclusion is 

appropriate and changes reflecting the intent of the comment have been made to

this portion of the proposal.

Regardless of what the 2006 CTG says the VOC content limit should be (i. e. 

70%), the fact that a regulation already exists that applies to these sources that 

imposes the more restrictive standard (30%) means that we must retain the more 

restrictive standard. To do otherwise would be backsliding. No change has been 

made to the proposal as a result of this portion of the comment.

24. SUBJECT: Testing requirements needs to be revised so that it is not mandatory.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivision 9VAC5-40-8434 (B) needs to be revised by adding the 

phrase “If requested” between “performed” and “to” as there is not a mandatory 

testing requirement contained in the CTG. Due to the significant costs involved 

with testing of an oxidizer, it should only be required if requested by the VADEQ. 

In addition, testing is usually mandated when a facility obtains an operating 

permit and including a provision of this nature could require a facility to retest an 

oxidizer that would have been recently tested.

To prevent mandatory retesting at a frequency not mandated by an operating 

permit, an additional sentence needs to be added to this provision allowing for 

previous testing to be acceptable. The sentence should be, “board may accept 

the results of an emission test conducted prior to the effective date of this rule, if 

the owner or operator provides information and data which demonstrate that an 
approved USEPA emission test method was employed and the test report was 

accepted.”

The provision needs to be revised to reflect the testing requirements necessary 

for a successful destruction efficiency determination for an oxidizer used to 

control emissions from a heatset web offset lithographic press. The nature of the 

emissions from heatset web offset press is such that simply following EPA 

protocols will result in failure forcing either re-testing or enforcement action. As 

such, USEPA has recommended compliance testing should be conducted at 

operating conditions representative of a typical production schedule. 

On page 67 of the Technical Support Document for Title V Permitting of Printing 

Operations, USEPA states:

“5.7 WHAT ARE THE APPROPRIATE PERFORMANCE TEST 

CONDITIONS?

Compliance testing for VOC and HAP emissions at printing facilities 

should be conducted under normal or representative operating conditions, 

in accordance with 40 CFR 60 subpart QQ, §60.433(a)(8); 40 CFR 63 

subpart KK, §63.827(d)(1)(vii); the draft CTG for Offset Lithography (EPA, 

1993b); and our National Stack Testing Guidance (EPA, 2004). These 

sections require compliance testing to be conducted under normal or 

representative operating conditions. We also recognize that a pre-test 

meeting between the printing facility owner or operator and you may 

provide a convenient opportunity to define normal, representative 

operation. During such a meeting, the owner or operator may propose an 

operating scenario for testing that is representative of actual operating 

conditions and the VOC/HAP input rate to the control device. Such 

operating conditions should strive to minimize downtime while running as 

many presses as practicable, when multiple presses are being served by 

a common control device. The proposed operating scenario should also

be reflective of a typical normal production schedule. As necessary, 

proposed testing conditions should rely on historical production records 

for establishing average coverage rates, press speeds, or ink and other 

input material consumption rates, run times, and average time of 

intermittent events such as press cleaning, web breaks or similar 

shutdown situations. 

Because activities such as cycling of automatic blanket washing systems, 

press speed variations, web breaks or other short-term events in which

the print quality is being checked, may be a part of normal, representative 

operations, we recommend that sampling continue during these shortterm events while the control device is being tested. All testing conditions 

should be thoroughly discussed and approved by you prior to the actual 

test date.”
Therefore, Subdivision 9 VAC5-40-8434 (B) should be revised so that it reads as 

follows:

B. An emission test of the control device installed on a heatset web offset 

lithographic printing process dryer shall be performed under normal 

representative conditions, if requested, to demonstrate compliance with 

the provisions of 9VAC5-40-8424 B and C and 9VAC5-40-8436. The 

negative dryer pressure shall be established during the initial test using an 

airflow direction indicator, such as a smoke stick, aluminum ribbons, or a 

differential pressure gauge. The board may accept the results of an 

emission test conducted prior to the effective date of this rule, if the owner 

or operator provides information and data which demonstrate that an 

approved USEPA emission test method was employed and the test report 

was accepted.

RESPONSE: Concerning the request to make testing and retesting nonmandatory, this portion of the comment is appropriate and changes reflecting the 

intent of the comment have been made to the proposal.

Testing during normal representative conditions is required by 9VAC5-40-30 C, 

which is incorporated into this Article by 9VAC5-40-8438 A. No change has 

been made to the proposal as a result of this portion of the comment.

25. SUBJECT: Testing requirements need to be revised to preserve flexibility.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivision 9VAC5-40-8438 (C) needs to the phrase “or one of the 

following methods” inserted after “Reference Method 24” as the current phrasing 

does not allow subdivisions 9VAC5-40-8438 (C) (1), (C) (2), (C)(3), or (C) (4) to 

be used to meet the condition. 

Therefore, Subdivision 9 VAC5-40-8438 (C) should be revised so that it reads as 

follows:

C. The VOC content of as-applied inks, varnishes and other coatings, 

fountain solutions, and cleaning materials shall be determined using 

Reference Method 24 or one of the following methods:

RESPONSE: The requirement is that the VOC content be determined by 

Reference Method 24. It does not specify who must do that determination. The 

subdivisions are not alternatives to the requirement for testing with Reference 

Method 24. Subdivisions under subsection C clarify how the owner may 

demonstrate compliance with that Reference Method 24 requirement. . 
Subdivision 1 says that the required Reference Method 24 testing may be done 

by other persons in the supply chain instead of by the owner of the printing 

facility. Subdivision 2 says that the owner can rely upon the Reference Method 

24 testing information supplied by several documents provided by the 

manufacturer or supplier. Subdivision 3 allows a dilution calculation using 

supplied Reference Method 24 information. Subdivision 4 requires the owner to 

test using Reference Method 24 at any time if requested by the board. No 

change has been made to the proposal as a result of this comment.

26. SUBJECT: Testing requirements need revision to reflect batch calculations.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivision 9VAC5-40-8438 (C) (3) needs to have an additional 

sentence added that should be revised to indicate that the calculation only needs 

to be performed once for each batch of fountain solution or cleaning material 

being used, not for each use of a batch of a solution. Since more than one 

fountain solution or cleaning material can be used on different presses in one 

operation, the calculation needs to be performed for each fountain solution and 

cleaning material. This is important as once the printing operation determines the 

proper mix ratio for its fountain solution or cleaning material, the mix ratio is not 

altered. 

Therefore, Subdivision 9 VAC5-40-8438 (C) (3) should be revised so that it reads 

as follows:

3. If fountain solution or cleaning materials are diluted by the owner prior 

to use, a calculation that combines the as supplied VOC content 

information provided by the manufacturer or supplier, the VOC content of 

the diluent, and the proportions in which they are mixed may be used to 

make a determination of VOC content of the as-applied fountain solution 

or cleaning material in lieu of Reference Method 24. The VOC content 

shall be calculated only once representing for each batch of press-ready, 

as applied, fountain solution’s or cleaning material’s mix ratio and 

recorded in the form of a batch log.

RESPONSE: Nothing in subdivision C 3 precludes a calculation "per batch" or 

requires a calculation "per use," so it is entirely appropriate to calculate the VOC 

content per batch instead of per use according to subdivision C 3. The definition 

of "batch" in 9VAC5-40-8422 C specifies that the supply of fountain solution is 

used unaltered after mixing. No change has been made to the proposal as a 

result of this portion of the comment.

However, because the definition of "batch" in 9VAC5-40-8422 C is only 

applicable to fountain solution, a change to that definition of "batch" to add "or 
cleaning solution" would be necessary to provide for batch determinations of 

VOC content of cleaning solutions. Appropriate changes reflecting the intent of

this portion of the comment have been made to the proposal.

27. SUBJECT: Testing requirements need revision to preserve flexibility.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: Subdivision 9VAC5-40-8438 (E) needs to include the phrase “or one of 

the following methods” inserted after “Reference Method 24” as the current 

phrasing does not allow subdivisions 9VAC5-40-8438 (E) (1), (E) (2), (E)(3), or 

(E) (4) to be used to meet the condition. 

Therefore, Subdivision 9 VAC5-40-8438 (E) should be revised so that it reads as 

follows:

E. The VOC composite partial vapor pressure of cleaning solutions shall 

be determined using the formula provided in 9VAC5-40-8422 C or by an 

appropriate test method approved by the board or one of the following 

methods:

RESPONSE: The requirement is that the VOC composite pressure be 

determined by a specified formula or an approved test method. It does not 

specify who must do that determination. The subdivisions are not alternatives to 

the requirement for testing using those methods. Subdivisions under subsection 

C clarify how the owner may demonstrate compliance with that testing 

requirement. Subdivision 1 says that the required testing may be done by other 

persons in the supply chain instead of by the owner of the printing facility. 

Subdivision 2 says that the owner can rely upon the testing information supplied 

by several documents provided by the manufacturer or supplier. Subdivision 3 

allows a dilution calculation using supplied testing information. Subdivision 4 

requires the owner to test using at any time if requested by the board. No 

change has been made to the proposal as a result of this comment.

28. SUBJECT: Key emission factors and retention factors need to be added.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: The proposed rule does not address key emission and retention factors 

that are specific to the lithographic printing industry and are necessary to perform 

accurate emission determinations. In order to ensure that the proper emission 

and retention factors are applied for purposes of determining applicability and 

compliance, the appropriate factors need to be included in the revisions to the 

rule. The recommended section will clarify the methodology for estimating actual 
emissions in the lithographic printing industry, saving administrative time and 

costs for both the VADEQ and the printing industry.

The inclusion of the emission and retention factors are supported by USEPA as 

the CTG states on Pages 18-20:

“This section provides a summary of some of the recommendations EPA has 

previously made to States concerning factors that may 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 

thresholds 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 discussed in the 1993 draft CTG, the 1994 

ACT and the 2005 Printing TSD.”

Therefore, a new subdivision needs to be added and should read as follows:

 Retention Factors and Capture Efficiencies - For purposes of determining 

volatile organic compounds emissions from offset lithographic printing 

operations, the following retention factors and capture efficiencies shall be 

used:

(1) A portion of the volatile organic compounds contained in inks and cleaning 

solution is retained in the printed web or in the shop towels used for 

cleaning. The following retention factors shall be used: 

(i) A 20% volatile organic compound retention factor shall be used for 

heatset inks printed on absorptive substrates, meaning 80% of the 

volatile organic compounds in the ink is emitted during the printing 

process and is available for capture and control by an add-on pollution 

control device.

(ii) A 95% volatile organic compounds retention factor shall be used for 

sheet-fed and non-heatset web inks printed on absorptive substrates, 

meaning 5% of the volatile organic compounds in the ink are emitted 

during the printing process.

(iii) A 50% volatile organic compounds retention factor shall be used for 

cleaning solution VOC in shop towels for cleaning solutions with a 

volatile organic compounds composite vapor pressure of no more than 

10 mm of mercury (Hg) at 20°C (68°F) if the contaminated shop towels 

are kept in closed containers. This means 50% of the VOC used on 

the shop towels is emitted during the cleaning process.

(2) A portion of the volatile organic compounds contained in inks, fountain 
solutions, and automatic blanket washes on heatset presses is captured 

in the press dryer for control by add-on pollution control devices. Capture 

efficiency testing for heatset dryers is not required if it demonstrated that 

pressure in the dryer is negative relative to the surrounding press room 

and the airflow is into the dryer. Continuous dryer air flow monitoring is not 

required. The following capture efficiencies are to be used:

(i) A 100% volatile organic compounds carry over efficiency shall be used 

for inks. All the volatile organic compounds in the ink that is not 

retained are assumed to be volatilized in the press dryer.

(ii) A 70% volatile organic compounds carry over efficiency shall be used 

for fountain solutions containing alcohol substitutes.

(iii) A 40% volatile organic compounds carry over efficiency shall to be 

used for automatic blanket wash solutions with a VOC composite 

vapor pressure of no more than 10 mm of mercury (Hg) at 20°C 

(68°F).

RESPONSE: Retention factors and emission factors are important pieces of 

information that need to be used in determining how much VOC (petroleum ink 

oil) that is applied to the substrate is likely to be emitted. However, both 

retention factors and emission factors are technical information "that may be 

considered" according to the CTG. In certain situations, they may be different for 

a specific situation at a specific facility, and should not be mandatory. If there are 

questions about how VOC applied translates to VOC emitted for the purposes of 

determining "theoretical potential to emit" and applicability, the source is 

encouraged to consult with the printing expert at the appropriate DEQ regional 

office. Appropriate changes reflecting the intent of this comment have been 

made to the proposal.

29. SUBJECT: The proposed rule lacks a material use alternative.

COMMENTER: Jay K. Goldscher, PGAMA.

TEXT: The proposed rule does not provide a material use alternative for 

facilities to determine applicability. The material use approach makes it much 

easier for facilities to determine their applicability and was approved by EPA in 

its Potential to Emit (PTE) Guidance for Specific Source Categories released on 

April 14, 1998. 

Therefore, a new paragraph, subdivision, needs to be added and should read as 

follows:

Facilities may determine if they are subject to the requirements of this rule 
using the following methods. 

(1) A facility shall use one of the following methods to determine if it meets 

the applicability limits of subdivision 9VAC5-40-8380 and 9VAC5-40-8420: 

(i) Material use records that show the facility consumes less than the 

following material use thresholds shall be equivalent to demonstrating 

actual volatile organic compound emissions did not equal or exceed 

three (3) tons of volatile organic compounds per 12-month rolling 

period:

Type of Offset Lithographic Printing 

Operation

12-Month Rolling Material Use 

Threshold

Sheet-fed 855 gallons of cleaning solvent 

and fountain solution additives

Non-heatset Web 855 gallons of cleaning solvent 

and fountain solution additives

Heatset Web 6,000 pounds of ink, cleaning 

solvent, and fountain solution 

additives

(ii) The following monthly records and calculations demonstrating actual 

VOC emissions:

(A) The total amount of each or each class of ink, fountain solution, 

and cleaning solvent used in pounds or gallons 

(B) The volatile organic compound content of each or each class of 

ink, fountain solution, and cleaning used:

(C) Volatile organic compounds calculations shall be based on the 

following formula using applicable retention factors identified subsection 

(l). 

Where:

VOCTOT = Total VOC emissions, expressed as tons

WINK = Weight of each ink or conventional varnish used or total of 

all inks 

 and/or conventional varnishes, expressed as pounds 

VOCINK = Weight fraction of VOC in each ink or the ink with the 
 highest VOC content, expressed as weight percent

RFINK = Retention factor of the ink, expressed as a percent

 m = Number of inks 

WCT = Weight of coating used or total of all coatings, expressed as 

 gallons or pounds 

VOCCT = Weight fraction of VOC in each coating or the coating with 

the 

 highest VOC content, expressed as pounds per gallon or 

 weight percent

 p = Number of coatings 

VOLFS = Volume of fountain solution concentrate and/or additive 

 used for each fountain solution or total of all fountain 

 solutions, expressed as gallons

VOCFS = VOC content of each fountain solution concentrate 

 and/or additive or the fountain solution concentrate 

 and/or additive with the highest VOC content, expressed 

 as pounds per gallon

 n = Number of fountain solutions

VOLCS = Volume of each cleaning solution used or a total of all 

 cleaning solutions used, expressed as gallons

VOCCS = VOC content of each cleaning solution or the cleaning 

 solution with the highest VOC content, expressed as 

 pounds per gallon

RFCS = Retention factor of the cleaning solution, expressed as a 

Percent

 r = Number of cleaning solutions 

(2) A facility with a heatset web offset printing press shall use one of the 

following methods to determine if it meets the applicability limits of 

subdivisions 9VAC5-40-8424 (B): 

(i) Material use records that show the facility consumes less than the 

following material use threshold shall be equivalent to demonstrating 
actual volatile organic compounds emissions did not equal or exceed 

ten (10) tons of volatile organic compounds per rolling twelve-month 

period:

Type of Offset Lithographic 

Printing Operation

Annual Material Use Threshold

Heatset Web 25,000 pounds of ink and 

varnish

(ii) The following monthly records and calculations demonstrating actual 

volatile organic compounds emissions did not equal or exceed ten (10) 

tons of volatile organic compounds per rolling twelve-month period:

(A) The amount of each heatset ink used or total amount of all heatset 

inks used.

(B) The volatile organic compounds content of each heatset ink or the 

ink used with the highest VOC content. 

(C) Volatile organic compounds calculations shall be based on the 

following formula using applicable retention factors identified 

subsection (l) of this rule:

Where:

VOCTOT = Total VOC emissions, expressed as tons

WINK = Weight of ink used, expressed as pounds

VOCINK = Weight fraction of VOC in the ink

RFINK = Retention factor of the ink, expressed as a percent

n = Number of inks

(3) A facility with a heatset web offset printing press shall use one of the 

following methods to determine if it meets the applicability limits of 

subdivisions 9VAC5-40-8424 (B)(3)(a) and 9VAC5-40-8424 (C): 

(i) Material use records that show the facility consumes less than the 

following material use threshold shall be equivalent to demonstrating 

actual volatile organic compounds emissions did not equal or exceed 
twenty five (25) tons of volatile organic compounds per rolling twelvemonth period:

Type of Offset Lithographic 

Printing Operation

Annual Material Use Threshold

Heatset Web 62,500 pounds of ink and 

varnish

(ii) The following monthly records and calculations demonstrating actual 

volatile organic compounds emissions did not equal or exceed twenty 

five (25) tons of volatile organic compounds per rolling twelve-month 

period:

(A) The amount of each heatset ink used or total amount of all heatset 

inks used.

(B) The volatile organic compounds content of each heatset ink or the 

ink used with the highest VOC content. 

(C) Volatile organic compounds calculations shall be based on the 

following formula using applicable retention factors identified 

subsection (l) of this rule:

Where:

VOCTOT = Total VOC emissions, expressed as tons

WINK = Weight of ink used, expressed as pounds

VOCINK = Weight fraction of VOC in the ink

RFINK = Retention factor of the ink, expressed as a percent

n = Number of inks

RESPONSE: The use of a material use alternative is not supported by EPA's

2006 Control Techniques Guidelines for Offset Lithographic Printing and 

Letterpress Printing (CTG) upon which the proposed regulation is based. There 

are differences between the recommendations in the CTG and the 1998 EPA 

document "Potential to Emit (PTE) Guidance for Specific Source Categories" 

referenced in the PGAMA comment. The referenced 1998 document defers to 

the CTGs and it is significant that the method endorsed by the 1998 PTE 
document is omitted from EPA's much later comprehensive 2006 update to the 

CTG for this source category. Also, as of this date EPA has issued no correction 

to the CTG to incorporate or allow the proposed material use alternative for 

applicability purposes. No change has been made to the proposal as a result of 

this comment.

TEMPLATES\FINAL\FR04

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