ENCLOSURE 1

COMMONWEALTH OF VIRGINIA
STATE AIR POLLUTION CONTROL BOARD
REGULATIONS FOR THE CONTROL AND ABATEMENT OF AIR POLLUTION

PROVISIONS AFFECTED
REVISION C 09
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 a nd 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 I N THE NORTHERN VIRGINIA VOLATIL E 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 Compl iance 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 I N 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/emissi ons (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 (a dded)
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 \ 201 6 \ C 09

- SIP

- 1.DOCCOMMONWEALTH 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 subsectio ns 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 volatil e 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, coatin gs, 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 emission s 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 e xclusively for determination of product quality and commercial acceptance provided:

a. The operation is not an integral part of the production process;COMMONWEALTH OF VIRGINIA PAGE 2 of 26
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 water

based chemistry to develop silver halide images.

3. Platemaking equipment using water

- based chemistry to remove
unha rdened 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 i n 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 le tterpress 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 r egulations for the

c ontrol and a batement of a ir p ollution and related uses, the words or terms shall have the meanings given them in subsection C of this section.

B. Unless otherwise requ ired 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 priorit y.COMMONWEALTH OF VIRGINIA PAGE 3 of 26
STATE AIR POLLUTION CONTROL BOARD

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

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 area s 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 electroni c 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 cleanin g 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 vo latile organic compounds. Composite partial vapor pressure is calculated as follows:

where:

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

W w = Weight of water, in grams.

W e = Weight of exempt compound, in grams.

MW i = Molecular weight of the "i" th VOC compound, in grams/gram

- mole.

MW w = Molecular weight of water, in grams/gram

- mole.

MW e = Molecular weight of exempt compound, in grams/gram

- mole.

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

VP i = Vapor pressu re 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 r elative 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, 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 subst rate (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

c ombination 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.

" Theoretic al 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 a dd

- 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 completeCOMMONWEALTH OF VIRGINIA PAGE 5 of 26
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 le tterpress 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 printin g 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 d ate is prior to [ (insert effective date of this article) February 1 , 2016 ] , the control device shall red uce 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 effecti ve 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 exhaus t air to 20 parts per million volume (ppmv) orCOMMONWEALTH OF VIRGINIA PAGE 6 of 26
STATE AIR POLLUTION CONTROL BOARD

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

less, as hexane on a dry basis.

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

conte nt 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 prac tices 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, varnis hes

, 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.

9 VAC5

- 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 P art II of 9VAC 5

- 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. T he 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 letterpres s 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

- ho ur ] 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 perform ance 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 recommendati ons 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 i s 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 comp ound retention factor may be used forCOMMONWEALTH 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

- fe d 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 lett erpress 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 pr essure 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 sh all comply with the provisions of this article as expeditiously asCOMMONWEALTH OF VIRGINIA PAGE 9 of 26
STATE AIR POLLUTION CONTROL BOARD

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 metho ds 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 O
2 and CO
2

.

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

concentra tion of the dryer exhaust stream entering and exiting the control device,
unless the alternate limit in 9VAC5

- 40

- 838 4 B 2 is being met, in which case only the VOC concentration of the dryer exhaust control device outlet shall be determined.

6. Referenc e 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 ma terials 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 unle ss the board or the owner has reason to believe that the formulation information provided by the manufacturer is inaccurate.

2. The o wner may use VOC content information provided by theCOMMONWEALTH 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 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 prov ided 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

s upplied 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 o w ner 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 p artial 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 material s that are diluted by the owner prior to use:

a. If the d ilution 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 p artial 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

p rovided 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 materialsCOMMONWEALTH OF VIRGINIA PAGE 11 of 26
STATE AIR POLLUTION CONTROL BOARD

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

used for letterpress printing operations at any time at the board's request. The owner shall be pr epared 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. C atalyst bed material in a catalytic oxida tion 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 p otential 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 i s 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. Notif ication, 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 orCOMMONWEALTH OF VIRGINIA PAGE 12 of 26
STATE AIR POLLUTION CONTROL BOARD

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

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 provi sions 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 provision s 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 5 6.1 Emission Standards for Offset Lithographic Printing Operations i n the Northern Virginia Volatile Organic Compound Emissions Control Area, 8

- hour Ozone Standard (Rule 4

- 56.1 )

9VAC5

- 40

- 8420 . Applicability and desig nation 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 o ffset 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 t he 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 r egulations for the

c ontrol and a batement of a ir p ollution and r elated uses, the words or terms shall have theCOMMONWEALTH OF VIRGINIA PAGE 13 of 26
STATE AIR POLLUTION CONTROL BOARD

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

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 Adm inistration),
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

- pro panol, 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 w ithout 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 equi pment, 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
clea ner, 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.,
b inding), 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:

W i = 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)

W w = Weight of water, in grams.

W e = Weight of exempt compound, in grams.

MW i = Molecular weight of the "i"th VOC compound, in grams/gram

- mole.

MW w = Molecular weight of water, in grams/gram

- mole.

MW e = Molecular weight of exempt compound, in grams/gram

- mole.

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

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

"First installation date" means the date that a control device i s 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 a nd 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 off set 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

- he atset" 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.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

processe s 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" mea ns 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 equip ment
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 VO C 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 perm it
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 s hall use or permit the use of any offset lithographicCOMMONWEALTH 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 t his 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, provide d 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. Ex haust 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 heats et 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 inle t, 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 subdivision s 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 pri nting 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 ex clusively 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 remo ve 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 sh all 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 c ontrol 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 concentrat ion of the heatsetCOMMONWEALTH 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 h eatset 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
offse t 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 t he 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 pr ess, 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 tem perature 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 shal l 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 c oatings 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 sha ll 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 provisio ns 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 9VAC 5

- 40 (Existing Stationary Sources) apply.

9VAC5

- 4 0

- 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 re quested 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 negat ive 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 li thographic 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 demonstrat ed

. [ 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 temperature s that demonstrate com pliance 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 compo unds 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 substr ates

, 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 pet roleum 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 ma y 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 ret ention 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 an d 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 com posite 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 e fficiency 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 lith ographic 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 expeditio usly 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, shal l 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 deter mine
the concentration of O
2 and CO
2

.

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 correspondin g 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 usin g 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 re ason to believe that the formulation information provided by the manufacturer is inaccurate.

2. The o wner 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 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.

4. The ow ner 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

as

- applied fountain solution o r 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

- 84 24 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 v apor 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 o wner 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
docu ment 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 material s 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

- app lied 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 o ffset 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 stand ard 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. C atalyst bed material in a catalytic oxidat ion control device shall beCOMMONWEALTH 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 po tential 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 ai rflow 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 mainten ance or malfunction.

The provisions of 9VAC5

- 20

- 180 (Facility and control equipment maintenance or malfunction) apply.

9VAC5

- 40

- 8 480 . Permits.

A permit may be required prior to beginning any of the activities specified [ below in
thi s section ] if the provisions of 9VAC 5

- 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 .DOC1 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), t he 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 Nationa l 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 requ ired 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, 20 15

. 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 Regi ons. 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 Stat e 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 t he 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 pro visions 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 \ 201 6 \ C 09

- SIP

- 2.DOC

## Regulations

Volume 32, Issue 7 Virginia Register of Regulations November 30, 2015

1170 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 s chedule.
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 Stati onary 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

faci lity.
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. Ex isting 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 p ublic 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 pro visions 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 si nce 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 cleani ng 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 promul gating 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 print ing 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. Al l 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 operatio ns 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 ]

.

## Regulations

Volume 32, Issue 7 Virginia Register of Regulations November 30, 2015

1171 D. Exempted from the provisions of this article are facilities in all volatile organic comp ound 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 ac ceptable 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 pr inting 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 equipme nt 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 Standard s 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 prov isions 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 s ection. 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 autho rities, 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 a round 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 c ompounds defined as volatile organic compounds. Composite partial vapor pressure is

calculated as follows:

where:

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

in grams.

W

w = Weight of water, in grams.

W

e = Weight of exempt compound, in

grams.

MW i = Molecular weight of the "i"th VOC

compound, in grams/gram

- mole.

MW

w = Molecular weight of water, in

grams/gram

- mole.

MW

e = Molecular weight of exempt

compound, in grams/gram

- mole.

PP

c = VOC composite partial pressure at

20°C, in millimeters of mercury (mm Hg).

VP i = 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

## Regulations

Volume 32, Issue 7 Virginia Register of Regulations November 30, 2015

1172 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, pre

press, and post

- press operations.

"Non

- heatset" means a printing process in which the printi ng 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 produc e 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.

"Theore tical 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) befor e 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, letterpre ss 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 pr inting 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 th e 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 ef

fective 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) Februar y 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 dev ice
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) ] co ntent 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 t o 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 ] :

## Regulations

Volume 32, Issue 7 Virginia Register of Regulations November 30, 2015

1173 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

- 6 0 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. Stand ard 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, o r 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 o f 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,

contin uing 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 9VA C5

- 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
wh ich 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 temperature s 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 organ ic 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

th e 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 in k 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 t owels 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

## Regulations

Volume 32, Issue 7 Virginia Register of Regulations November 30, 2015

1174 efficiencies may be used in determining volatil e 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 demonst rated 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 coat ings), 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. Com pliance 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 con trol 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 O 2 and CO 2

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

content.
5. Reference Methods 18, 25, or 25A shall be used to

determine the V OC 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 devi ce 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 unles s 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 t he 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 Refer ence 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 compos ite 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 so lutions 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 compos ite 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 t he 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

## Regulations

Volume 32, Issue 7 Virginia Register of Regulations November 30, 2015

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 a n 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 c atalyst 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 conditi on 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 Stationa ry 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. R econstruction (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 Stand ards 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 w hich 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 cl eaning 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 s ubdivision 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 t o 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 additiv e that contains volatile organic compounds and is used in the

fountain solution.

## Regulations

Volume 32, Issue 7 Virginia Register of Regulations November 30, 2015

1176 "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 materia ls 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

mat erials 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 t o 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 o f the partial pressures of the compounds defined as volatile organic compounds. Composite partial vapor pressure is

calculated as follows:

where:

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

in grams.

W

w = Weight of water, in grams.

W

e = Weight of exempt compound, in

grams.

MW i = Molecular weight of the "i"th VOC

compound, in grams/gram

- mole.

MW

w = Molecular weight of water, in

grams/gram

- mole.

MW

e = Molecular weight of exempt

compound, in grams/gram

- mole.

PP

c = VOC composite partial pressure at

20°C, in millimeters of mercury (mm Hg).

VP i = 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 d oes 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 th e 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

rece ptive 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 oxi dation 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

re lated 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

we b).
"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.

## Regulations

Volume 32, Issue 7 Virginia Register of Regulations November 30, 2015

1177 "Theoretical potentia l 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

determi ned 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 contin uous 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 lithographi c 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 solu tions, 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 specif ied 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 ton s 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 o il) ] 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

ha lide 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 le ss. 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 shal l 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 a t 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%.

## Regulations

Volume 32, Issue 7 Virginia Register of Regulations November 30, 2015

1178 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 i nk 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 p ress 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 eff ective 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 exc lusively 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 t han 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 shal l 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 w eight; 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 shal l 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 sh all 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 manu al 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 ma terials, 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 (Ex isting 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 Artic le 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

c ompliance 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

## Regulations

Volume 32, Issue 7 Virginia Register of Regulations November 30, 2015

1179 differential pressu re 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 provis ions 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 oxidat ion 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 t he 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 re corded 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

w ith 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 i n 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 operati ons: 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 proce ss 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 non e 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 c leaning 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 ma y 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 cleanin g 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 i nk 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 mater ials 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 expedit iously 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 (Emiss ion 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 appr opriate, shall be used to select the sampling sites.

## Regulations

Volume 32, Issue 7 Virginia Register of Regulations November 30, 2015

1180 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

t o determine the concentration of O 2 and CO 2

. 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 contro l 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 con trol 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 materi als 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 b oard 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 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 2 4.
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 as

applied fountai n 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 requi rements 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 parti al 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 docu ment 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 calculat ion 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 m aterials 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.

## Regulations

Volume 32, Issue 7 Virginia Register of Regulations November 30, 2015

1181 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 inspecte d 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 c atalyst 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 proc ess 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.

T he 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

- 2 0

- 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 Stationar y 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. Re construction (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; Fil ed 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, 6 29 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 Nor thern 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, compl iance, 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 opera tions.
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 co nsideration 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 clean ing, equipment cleaning, line cleaning, floor cleaning, tank cleaning, and small manufactured components cleaning.

## Regulations

Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

768 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 exc eption 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 a dult 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, Janu ary 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 educa tion 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 Virgini a; 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

Pu blic 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: Se ction 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,

## Regulations

Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

769 and prohibiting air pollutio n 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.
Speci fic Federal Requirements.

Ground

- level ozone is an air pollutant that forms when volatile organic compounds (VOCs) and nitrogen oxides (NO X ) 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 requ irements. 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 pu blished 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 NO X emissions control areas. These areas were created to provide a legal mecha nism 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) o f 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 nonattainmen t 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 sou rce 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 crite ria 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 emi ssions

- 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 requirement s 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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770 description of emissions reductions estimates s ufficient 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, an d 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 em issions 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 standard s, 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

comb ination 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 pollutio n 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, a nd 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) spe cifies 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 o verall 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 e mission 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 nationa l 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

em issions 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 equiva lent 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

## Regulations

Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

771 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 maintenanc e 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 co ntingency 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, 1 991, 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 par ticular 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 outdoo r 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 th e 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

con tribute 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 print ing 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 ma terials (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 rul e 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 complia nce 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.

## Regulations

Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

772 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 Plannin g 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 comp ound (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 de gree 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 e mit 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 o f 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 prin ting. 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 remov ed.
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 p otentially 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 wil l 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 U se 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 Business es: 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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Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

773 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 va lue 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 regul ation; (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 owne rs 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 ap

plies 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

po llutants, 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 t his 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 com

pound 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 Vir ginia 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 th e 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 p rocesses 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 i n 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.

Articl e 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 faci lity 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,

## Regulations

Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

774 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 subdiv ision 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

th em 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 p ress 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
part ial pressures of the compounds defined as volatile organic compounds. Composite partial vapor pressure is

calculated as follows:

where:

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

in grams.

W

w = Weight of water, in grams.

W

e = Weight of exempt compound, in

grams.

MW i = Molecular weight of the "i"th VOC

compound, in grams/gram

- mole.

MW

w = Molecular weight of water, in grams/gram

- mole.

MW

e = Molecular weight of exempt

compound, in grams/gram

- mole.

PP

c = VOC composite partial pressure at

20°C, in millimeters of mercury (mm Hg).

VP i = 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 installa tion 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 limit ed 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, UV

- cured

and electron beam

- cured ink s 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 throu gh 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 pri nting 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 individ ual 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 max imum 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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Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

775 is subject to state and federally enforceable permit conditions that limit production rates or hours of opera tion.

"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 print ing 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 p rocess, 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 proces s 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 prin ting 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 ai r 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 n o 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 limit ations 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 VO C 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 Stationar y 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 s hall 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 dev ice, continuing compliance with the heatset web letterpress printing process dryer control requirements in 9VAC5

- 40

-

## Regulations

Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

776 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 cont rol 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 ex haust stream.
3. Reference Method 3 or 3A, as appropriate, shall be used

to determine the concentration of O 2 and CO 2

. 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. Re ference 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

cham ber 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 R eference

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 f or 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 determi ned 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 manufactur er 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 c leaning 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 ma nufacturer'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.

## Regulations

Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

777 9VAC5

- 40

- 8410. Monitoring.
A. The provisions of 9VAC5

- 40

- 40 (Monitor ing) 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 opera ting, 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 chambe r 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 evaluatio n 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 prin ting 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 requi red 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

contac t 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 em issions 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 provis ions 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 regu lations 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 me anings 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, me tering roller cleaner, impression cylinder washes, rubber rejuvenators, and roller wash. Cleaning

## Regulations

Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

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

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

- press cleaning

o perations (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 P art 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:

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

in grams.

W

w = Weight of water, in grams.

W

e = Weight of exempt compound, in

grams.

MW i = Molecular weight of the "i"th VOC

compound, in grams/gram

- mole.

MW

w = Molecular weight of water, in

grams/gram

- mole.

MW

e = Molecular weight of exempt

compound, in grams/gram

- mole.

PP

c = VOC composite partial pressure at

20°C, in millimeters of mercury (mm Hg).

VP i = 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 pres s. "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 im age 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 no n

- 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 operatio n" 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 pro cess 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

sheet s 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 capa city 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 hou rs of operation.

"12

- month rolling period" means a period that is determined monthly and consists of the previous 12

consecutive calendar months.

## Regulations

Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

779 "Unit" means the smallest complete printing component, composed of an inking and dampening system, of a printi ng 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 subsecti on, 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 dry er 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 op erates 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 t oo 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 printin g 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 pro cess 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 yea r 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

ha lide 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 pr ovisions 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 proc ess 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 install ation 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 lithogra phic 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, var nishes, and other coatings applied; (iii) the press application rates of inks, varnishes, and other

## Regulations

Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

780 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 proce ss 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 so lution 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 pri nting 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 compoun ds 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 sol ution, 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 founta in 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 imple mented. 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, fou ntain 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 Stati onary 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. Co mpliance.
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 dem onstrated 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 litho graphic 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 ma intain

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 sc hedule.
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

- 4 0

- 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 O 2 and CO 2

. 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 determi ned.

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 combus tion 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

R eference 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 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 Refere nce 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 as

app lied 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 tempe rature 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 com posite 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 com

posite 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 d ilution 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 parti al 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 provi ded 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:

## Regulations

Volume 31, Issue 10 Virginia Register of Regulations January 12, 2015

782 1. The alcohol concentration of offset lithographic printing process fou ntain 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 d evice 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 cat alyst 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 gener al 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 ba sed 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, th en 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 a nd 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 tha n 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.

Prop osed 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, Woodbrid ge, 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.sabastea nski@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 "t he 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 o r 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 (NO X ) interact with sunlight. The nation al 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 Sec tion 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 ac tion 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 \ 201 6 \ C 09

- SIP

- 3.DOCCOMM ONWEALTH 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 p rinting 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, Virg inia 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 commen t , 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 prin ting 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 printi ng 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 mat erials (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 NorthernVirginia VOC emissions control area are affected.

2. Definitions of terms used in the r ule 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 co mpliance 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 com pliance 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 Reg ister 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 p roposed 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 statemen t 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 comme nts 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 : Malfunct ions.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 conta ins 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 ta ke 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 d uring 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 thos e 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,
ha ve 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 cou rts 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 supple mented 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 req uirements 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 relatedto exemptions or affirmative defenses in this separa te 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 af ter 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 Administrativ e 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 Polluti on 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. The refore, the affected malfunction provisions of the CTG rules will simply not be submit ted 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 rat ional

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 p roposal 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 am bient 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 relat ed 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. T he 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 d efinition 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

nee ds 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 thoug ht 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 definition s of "letterpress printing operation" and "offset lithographic printing operation " need to be revised.

COMMENTER : Jay K. Goldscher, PGAMA.

TEXT : The definition s 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 applicabil ity.

"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 no t limited to, cleaning, prepress, and post

press operations.

"Offset lithographic printing operation" means one or more printing processes employing offset lithographic printing on offset lithographicprinting presses and includes the related processes ne cessary 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 a re 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 (lett erpress 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 def inition 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 print ing 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 tha t 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 " p rinting process" is more inclusive than applying only to printing techniques. It also refers to surface coating s 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, t he listed equipment are examples of equipment that may be found on such a process. The li st is not intended to be a list of required equipment or to implying that the presence of other equipment wouldexclude 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 a ppropriate to include specific equipment
that is proposed by stakeholders as being more appropriate to th at 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 “Th eoretical 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 Sup port 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 prov ide 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 def inition 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) sub section B

. The term is used as the method for determining the 25 ton per year dryer emissions exception to the dry er 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 ha s 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 f ollows:

"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 blanke t 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, the re 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 exemptionfrom 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 constitut es 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. Specifi cally, 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 le ast 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) shoul d 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

t o 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 w idth 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.CO MMENTER : 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 addit ion, “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
Prin ting 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 excep tion 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. Thi s 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 excepti on. 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 practi cally 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 mandator y.

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 c osts 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 retes t 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 emiss ions 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 print ing 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 St ack 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 d evice. 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 norm al 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
intermit tent 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 chec ked, may be a part of normal, representative operations, we recommend that sampling continue during these short

term events while the control device is being tested. All testing conditions should be thoroughly discussed and approved by you prior to the act ual
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

represe ntative 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 non

mandatory, 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

- 84 38 A. No change has been made to the proposal as a result of this portion of the comment.

12. SUBJECT : Testing re quirements 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 allo w 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 coati ngs, 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 sever al 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. N o 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 : Subdivision s 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, Subdivision s 9 VA C5

- 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 Safe ty 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 t o 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 differ ent 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 r atio 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 conten t 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 operat ions 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 r equirement 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.
Subdivis ion 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 : Subdi vision s 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, Subdivision s 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 provide d 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 materia ls.

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, PGAM A.

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 o f 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 deleti ng 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 exa mple. 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 9VA C5

- 40

- 842 2 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 “pr oduction” as USEPA allows certain types of sources, including printingoperations 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 Per mitting 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
enf orceable 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:

"Theoretica l 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 : Th e definition in 9VAC5

- 40

- 8422 specifies that it applies only to the proposed Article 56.1 and as such will only apply to o ffset lithographic printing processes

.

The definition of "theoretical potential to emit" in this section serves the uses of
the term in 9VAC5

- 40

- 8 42 4 (standard for volatil e 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 c ontrol 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 ru le 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 lev el 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 an d 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 pres s 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
recommendatio ns 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 letterpr ess 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 to ns 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 V OC (petroleum ink oil) or more

. " Nochange 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 th is portion of th e 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, subdi vision 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 subdivisi ons (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

c arbon (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 CTG

specifie d 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 V OC 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 ton s 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 c oatings 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 cont ain 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 respo nse 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 varnis hes 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 petr oleum 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 li mitations 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 ne eded

.

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 cl eaning 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 cleani ng 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 neit her 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 clean ing 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
CT G. 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

- 4 0

- 8424 (E) (1) or (E)(2) is permitted provided that the quantity used does not exceed 110 gallons over any twelve consecutive months

RESPONSE : Th e 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 sta ndard (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 i s 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 t he 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 f acility 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 acceptabl e. 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 anapproved USEPA emission test method was employ ed 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 pr ess. 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

oper ating 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 fo r 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 o r 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 tim es, 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 short

term 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 directio n 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 de monstrate that an approved USEPA emission test method was employed and the test report was accepted.

RESPONSE : Concerning the request to make testing and retesting non

mandatory, this portion of the comment is appropriate and changes reflecting the
inten t 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

- 84 38 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 2 4. 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 Metho d 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 M ethod 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. Sinc e 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 th e 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 th e 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 conte nt 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

recor ded 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 "orcleaning solution" would be necessary to provide for batch determinations of VOC content of cleaning solutions. Appropriate changes reflecting t he 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

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- 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 r evised 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 pr inting 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.

TE XT : 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 fact ors 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 actualemissions in the lithographic pri nting 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 th e 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 disc ussed 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 emi ssions 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 s hop 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 i s 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 subst rates

, 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, fountainsolutions, 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 effic iency 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 mer cury (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 questio ns 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 r eflecting 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.

Therefor e, 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 ruleusing 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 c ompound 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 fount ain 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:

VOC TOT = Total VOC emissions, expressed as tons

W INK = Weight of each ink or conventional varnis h used or total of
all inks and/or conventional varnishes, expressed as pounds

VOC INK = Weight fraction of VOC in each ink or the ink with thehighest VOC content, expressed as weight percent

RF INK = Retention factor of the ink, express ed as a percent

m = Number of inks

W CT = Weight of coating used or total of all coatings, expressed as

gallons or pounds

VOC CT = 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

VOL FS = Volume of fountain solution concentrate and/or additive
used for each fountain solution or total of all fountain solutions, expressed as gallons

VOC FS = VOC co ntent 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

VOL CS = Volume of each cl eaning solution used or a total of all cleaning solutions used, expressed as gallons

VOC CS = VOC content of each cleaning solution or the cleaning solution with the highest VOC content, expressed as pounds per gallon

RF CS = Retention facto r 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 9 VAC5

- 40

- 8424 (B):

(i) Material use records that show the facility consumes less than the following material use threshold shall be equivalent to demonstratingactual 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
volat ile 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 co ntent 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:

VOC TOT = T otal VOC emissions, expressed as tons

W INK = Weight of ink used, expressed as pounds

VOC INK = Weight fraction of VOC in the ink

RF INK = Retention factor of the ink, expressed as a percent

n = Number of inks

(3) A facility with a heatset web offset pri nting 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 exceedtwenty five (25) tons of volatile organic compounds per rolling twelve

month period:

Type of Offset Lithographic Printing Operation Ann ual 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 comp ounds 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 organi c compounds calculations shall be based on the following formula using applicable retention factors identified subsection (l) of this rule:

Where:

VOC TOT = Total VOC emissions, expressed as tons

W INK = Weight of ink used, expressed as pounds

VOC INK = Weight fraction of VOC in the ink

RF INK = 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 Prin ting 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 PGAM A comment . The referenced 1998 document defers to
the CTGs and i t is significant that the method endorsed by the 1998 PTEdocument is o mitted from EPA's much later comprehensive 2006 update to the
CTG for this source category . A lso, a s of this date EPA ha s 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
REG \ DEV\ C09

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