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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: June 17, 2014

SUBJECT: Technical Support Document for Allegheny County’s Adoption of Control 

Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing; 

Flexible Package Printing; and Industrial Solvent Cleaning Operations for Control 

of Volatile Organic Compound Emissions

/s/ 

FROM: Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO: File

/s

THRU: Cristina Fernandez, Associate Director 

Office of Air Program Planning

A. BACKGROUND 

Section 172(c)(1) of the Clean Air Act (CAA) provides that state implementation plans (SIPs) 

for nonattainment areas must include reasonably available control measures (RACM), including 

reasonably available control technology (RACT), for sources of emissions. Section 182(b)(2)(A) 

provides that for certain nonattainment areas, States must revise their SIPs to include RACT for 

sources of volatile organic compound (VOC) emissions covered by a control techniques 

guidelines (CTG) document issued after November 15, 1990 and prior to the area’s date of 

attainment. 

The United States Environmental Protection Agency (EPA) defines RACT as “the lowest 

emission limitation that a particular source is capable of meeting by the application of control 

technology that is reasonably available considering technological and economic feasibility.” (44 

FR 53761, Sept. 17, 1979). In subsequent Federal Register notices, EPA has addressed how 

states can meet the RACT requirements of the CAA. 

CTGs are intended to provide state and local air pollution control authorities information that 

should assist them in determining RACT for VOCs from various sources, including offset 

lithographic printing and letterpress printing; flexible package printing; and industrial cleaning 

solvents. In developing these CTGs, EPA, among other things, evaluated the sources of VOC 

emissions from the industry and the available control approaches for addressing these emissions, 

including the costs of such approaches. Based on available information and data, EPA provides 

recommendations for RACT for VOCs from offset lithographic printing and letterpress printing; 

flexible package printing; and industrial cleaning solvents.
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In 1993, EPA published a draft CTG for offset lithographic printing. (58 FR 59261). After 

reviewing comments on the draft CTG and soliciting additional information to help clarify those 

comments, EPA published an alternative control techniques (ACT) document in June 1994 that 

provided supplemental information for States to use in developing rules based on RACT for 

offset lithographic printing. In December 1978, EPA published a CTG for graphic arts (rotogravure 

printing and flexographic printing) that included flexible package printing. In 1994, EPA developed 

an ACT document for industrial cleaning solvents. After reviewing the 1978/1993/1994 CTGs 

and ACTs for these industries, conducting a review of currently existing state and local VOC 

emission reduction approaches for these industries, and taking into account any information that 

has become available since then, EPA developed new CTGs entitled Control Techniques 

Guidelines for Offset Lithographic and Letterpress Printing (Publication No. EPA 453/R-06-

002; September 2006); Control Techniques Guidelines for Flexible Package Printing 

(Publication No. EPA 453/R-06-003; September 2006); Control Techniques Guidelines for 

Industrial Cleaning Solvents (Publication No. EPA 453/R-06-001; September 2006).

The CTG recommendations may not apply to a particular situation based upon the circumstances 

of a specific source. Regardless of whether a State chooses to implement the recommendations 

contained within the CTGs through State rules, or to issue State rules that adopt different 

approaches for RACT for VOCs for offset lithographic printing and letterpress printing, flexible 

package printing, and industrial solvent cleaning operations, States must submit their RACT

rules to EPA for review and approval as part of the SIP process. EPA will evaluate the rules and 

determine, through notice and comment rulemaking in the SIP process, whether they meet the 

RACT requirements of the CAA and EPA’s regulations.

Description of Offset Lithographic Printing and Letterpress Printing

Offset lithography is a planographic method of printing. The term “planographic” denotes that 

the printing and non-printing areas are in the same plane on the surface of a thin metal 

lithographic plate. To maintain the distinction between the areas on the lithographic plate, the 

image area is rendered oil receptive, and the non-image area is rendered water receptive.

Offset lithography is an indirect printing method; that is, ink is not transferred directly to a 

substrate. Rather, ink is transferred from the lithographic plate to a rubber-covered, intermediate 

“blanket” cylinder and then transferred from the blanket cylinder to the substrate. The offset 

lithographic process is used for a broad range of printing applications, including books, 

magazines, periodicals, labels and wrappers, catalogs and directories, financial and legal

documents, business forms, advertising brochures, newspapers, newspaper inserts, charts and 

maps, calendars, tickets and coupons, greeting cards, and stamps. There are two types of offset 

lithography characterized by the method in which the substrate is fed to the press. In sheet-fed 

printing, individual sheets of paper or other substrate are fed to the press. In web printing, 

continuous rolls of substrate material are fed to the press and rewound or cut to size after 

printing. VOC emissions from offset lithographic printing result from the evaporation of

components of the inks, fountain solutions, cleaning materials and other miscellaneous materials 

such as varnishes, coatings and glues.

Letterpress inks are similar to offset lithographic inks. They are paste inks containing petroleum 

oils or vegetable oils. Both sheet-fed and web presses are used for letterpress printing. Sheet-fed 
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letterpress presses use coldset inks. Most web letterpress equipment use coldset inks. These 

letterpress inks are similar in composition and behavior to sheet-fed and coldset web lithographic 

inks. In sheet-fed and coldest web letterpress printing, 95 percent of the petroleum ink oils and 

essentially all of the vegetable oils are retained in the substrate and dry ink film. The remaining 

5 percent of petroleum ink oils is volatilized and emitted. Because of the high level of ink oil 

retention, emissions from sheet-fed and coldset web letterpress inks are inherently very low. 

There are three main sources of VOC emissions from offset lithographic printing: 

(1) evaporation of VOCs (petroleum ink oils) from the inks; (2) evaporation of VOCs from

the fountain solution; and (3) evaporation of VOCs from the cleaning materials. There

are two main sources of VOC emissions from letterpress printing: (1) evaporation of

VOCs (petroleum ink oils) from the inks, and (2) evaporation of VOCs from the cleaning

materials.

Description of Flexible Package Printing

Flexible packaging refers to any package or part of a package, the shape of which can be readily

changed. Flexible packaging includes, but is not limited to, bags, pouches, liners, and wraps 

utilizing paper, plastic, film, aluminum foil, metalized or coated paper or film, or any 

combination of these materials. Flexible package manufacturers are sometimes referred to as 

"converters." The word "converted" in this use is an industry-specific term that refers to the fact 

that flexible packaging materials start out as rolls of paper or foil, or beads of plastic resin, and 

are "converted" into a package or roll of packaging material. Printing on flexible packaging is 

almost entirely conducted by rotogravure and wide-web flexographic printing.

Printing, coating, and laminating may all be performed on or in-line with a flexible package 

printing press; and these activities are included in the source category. One portion of the flexible 

packaging industry provides fully printed packaging materials (designated "preformed specialty 

bags") to contract packagers. Another portion provides combination or laminated materials 

(designated converted wrap) for printing and/or final packing by captive packaging operations. 

Applying coatings is a major capability of flexible packaging converters. So, the same facilities 

may be used to manufacture non-packaging materials such as gift wraps and hot stamp foils. The 

industry makes a distinction between labels and wrappers, which are package components, and a 

product that becomes the entire package and should be called a flexible package. Any printing 

of shrink-wrap labels or wrappers conducted on or in-line with a flexible package printing press 

is also considered to be included under the flexible packaging source category. Printing of selfadhesive labels would not be considered flexible packaging. Rigid packaging printing operations 

are often co-located with flexible package printing operations. Folding cartons, some labels and 

wrappers, gift wraps, wall coverings, vinyl products, decorative laminates, floor coverings, tissue 

products, and miscellaneous specialty products are not considered flexible packaging.

There are two types of printing processes used by flexible package printing facilities: (1) 

rotogravure printing; and (2) flexographic printing. And there are two main sources of VOC 

emissions from flexible package printing for both rotogravure and flexographic: (1) evaporation 

of VOC from inks, coatings, and adhesives, and (2) evaporation of VOCs from cleaning 

materials.
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There are two approaches to reducing VOC emissions from inks, coatings, and adhesives used in 

the flexible package printing industry: (1) adding/improving add-on controls, and (2) material 

reformulation or substitution. The first approach includes improving capture and/or control 

systems or adding control systems where none are in use. Capture and control can be addressed 

separately, although in many cases, improved capture is achieved through an increase in the 

amount of air handled and can necessitate up-grades to existing control devices. The second 

approach, focusing on pollution prevention, is to substitute low VOC or VOC-free materials for 

materials (inks, coatings, and adhesives) presently in use.

Description of Industrial Cleaning Solvent Operations

This category of consumer and commercial products includes the industrial cleaning solvents 

used by many industries. It includes a variety of products that are used to remove contaminants 

such as adhesives, inks, paint, dirt, soil, oil, and grease. Contaminants are removed from parts, 

products, tools, machinery, equipment, vessels, floors, walls, and other work production related 

work areas for a variety of reasons including safety, operability, and to avoid product 

contamination. The cleaning solvents used in these (unit) operations are, in many cases, 

generally available bulk solvents that are used for a multitude of applications not limited to 

cleaning. For example, petroleum distillates may be used as a cleaning solvent, as a paint 

thinner, or as an ingredient used in the manufacture of a coating, such as paint. Because a portion 

of all solvents evaporate during use, such solvent-based cleaning materials result in large 

amounts of emissions of VOC.

Although the industrial cleaning solvent product category includes a variety of different products 

with differing VOC contents, and although these products are used in different ways by a wide 

range of industries, there are several basic approaches to achieve VOC emission reductions. 

First, the users of the products can control emissions through work practices targeted at the 

activities and sources of emissions specific to the user’s industry (e.g., keeping solvent 

containers covered, properly storing and disposing of used shop towels and solvent, etc.). 

Second, users can also reduce overall VOC emissions through solvent substitution (e.g., use of 

low - VOC, no -VOC, or low -vapor pressure solvents). They can also reduce VOC emissions 

by using add-on controls, modifying equipment, or upgrading to using a lower emitting cleaning 

technology.

B. STATE SUBMITTAL

On November 15, 2013, Pennsylvania Department of Environmental Protection (PADEP) 

submitted to EPA a SIP revision concerning the adoption of the EPA CTGs for offset 

lithographic printing and letterpress printing; flexible package printing; and industrial cleaning 

solvent operations in Allegheny County. EPA develops CTGs as guidance on control 

requirements for source categories. States can follow the CTGs or adopt more restrictive 

standards. Allegheny County is adopting EPA’s CTG standards for offset lithographic printing 

and letterpress printing; flexible package printing; and industrial cleaning solvent operations. 

These regulations are contained in the Allegheny County Health Department (ACHD) Rules and 
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Regulations, Article XXI, Air Pollution Control sections 2105.80, 2105.81, and 2105.82. This 

SIP revision also includes a revision to an existing regulation for graphic arts systems in section 

2105.11. The revisions are summarized below.

I. Offset Lithographic Printing and Letterpress Printing

This section applies to the owner or operator of an offset lithographic printing and/or letterpress 

printing operation, where the total actual VOC emissions from all offset lithographic printing and 

letterpress printing operations are equal to or greater than 15 pounds (6.8 kilograms) per day or 

2.7 (2,455 kilograms) per twelve month rolling period. Exceptions include heatset web offset 

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

section only applies to those presses with potential to emit from the dryer at least 25 tons (22,680 

kilograms) of VOC per twelve month rolling period.

This section establishes emission limits, recordkeeping and housekeeping requirements, as well 

as exemptions. Emission limits of VOCs from offset lithographic printing and/or letterpress 

printing operations are as follows:

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

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

alcohol or less (by weight) on-press (as-applied) in the fountain solution or 5.0 

percent alcohol or less on-press and no alcohol in the fountain solution.

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

alcohol or less (by weight), in the fountain or 8.5 percent alcohol or less on-press in 

the fountain solution or 5.0 percent alcohol substitute or less on-press and no alcohol 

in the fountain solution.

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

substitute or less on-press and no alcohol in the fountain solution.

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

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

web letterpress printing if 

a. The overall control efficiency for a chiller condenser shall be no less than 90 

percent; or

b. The overall control efficiency for an oxidizer shall be no less than 95 percent; 

or

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

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

68 degrees F or cleaning materials containing less than 70 weight percent VOC. 

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

II. Flexible Package Printing

This section applies to the owner or operator of a flexible package printing press, including 

rotogravure printing and flexographic printing, where the total actual VOC emissions from all 
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flexible package printing press operations, including related cleaning activities, at the facility are 

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

twelve month rolling period. The limits from section 2105.11, Graphic Arts System, no longer 

apply to flexible package printing presses.

This section emission limits, recordkeeping and housekeeping requirements, as well as 

exemptions. Emission limits of VOCs from flexible package printing operations are as follows:

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

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

shall not be greater than 0.8 pound (lb) VOC per lb solids applied.

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

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

III. Industrial Solvent Cleaning Operations

This section applies to the owner or operator of a facility, where the total actual VOC emissions 

from all of the industrial solvent cleaning operations at the facility are equal to or greater than 15 

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

This regulation applies to any facility that employs solvent materials in industrial solvent 

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

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

materials. This section establishes emission limits (Table 1), recordkeeping and housekeeping 

requirements, as well as exemptions.

Table 1: Emission Limits of VOCs for Industrial Solvent Cleaning Operations

VOC Content Limitation 

Industrial Solvent Cleaning Operation lbs VOC per 

gallon (gal)

Kilograms (kg) 

VOC per / liter

(l)

1. Product cleaning during manufacturing process or 

surface preparation for coating, adhesive, or ink 

application

(a) General 0.42 0.050

(b) Electrical apparatus components and electronic 

components

0.83 0.099

(c) Medical devices and pharmaceuticals 6.7 0.80

2. Repair and maintenance cleaning

(a) General 0.42 0.050

(b) Electrical apparatus components and electronic 

components

0.83 0.099

(c) Medical devices and pharmaceuticals

(i) Tools, equipment and 

machinery

6.7 0.80
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(ii) General work surfaces 5.0 0.60

3. Cleaning of coating or adhesive 0.42 0.050

4. Cleaning of ink application equipment

(a) General 0.42 0.050

(b) Flexographic printing 0.42 0.050

(c) Gravure printing

(i) Publication 0.83 0.099

(ii) Packaging 0.42 0.050

(d) Screen printing 4.2 0.50

(e) Ultraviolet ink and electron beam ink application 

equipment, except screen printing

4.2 0.50

(f) Specialty flexographic printing 0.83 0.099

5. Cleaning of polyester resin application equipment 

not subject to 40 CFR Part 63 Subpart WWWW

0.42 0.050

IV. Additional Revision

In addition to adopting the CTGs discussed above, section 2105.11, Graphic Arts Systems, is 

being amended and added to the Allegheny County portion of the Pennsylvania SIP. Paragraph 

f, Exempt Other, is being added and reads as follows: The owner or operator of a flexible 

package printing press subject to section 2105.81, Control of VOC Emissions From Flexible 

Package Printing, is no longer subject to all subparagraphs of section 2105.11, Graphic Arts 

Systems, and shall be subject to all subparagraphs of section 2105.81, Control of VOC 

Emissions from Flexible Package Printing as of January 1, 2012.

C. EPA EVALUATION AND RECOMMENDED AGENCY ACTION

Allegheny County has adopted the standards and requirements of the CTGs for offset 

lithographic printing and letterpress printing, flexible package printing, and industrial solvent 

cleaning operations, and is amending the Pennsylvania SIP to reflect these amendments. The 

maximum benefit from these amendments will be provided during the ozone season when VOCs 

readily combine with NOx to form ground-level ozone. Therefore, this revision will help 

Pennsylvania attain and maintain the NAAQS for ozone and EPA approval of the SIP revision is 

recommended.