1 **UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III**  **1650 Arch Street Philadelphia, Pennsylvania 19103** 

**DATE:** June 17, 2014
**SUBJECT:** Technical Support Document for Alleghen y County ’s Adoption of Control

Techniques Guidelines for Offset Lithographi c Printing and Letterpress Printing; Flexible Packag e Printing; and Industrial Solvent Cleaning Operations for Control of Volatile Organic Compound Emissions /s/ **FROM:** Irene Shandruk, Phy sical 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 reasonabl y available control measures (RACM), including reasonabl y available control technology (RACT), for sources of emissions. Section 182(b)(2)(A) provides that for certain nonattainment areas, States must revise their SI Ps to include RACT for sources of volatile organic comp ound (VOC) emissions covered b y 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 limitat ion that a particular source is capable of meeting b y the application of control technology

that is reasonably

available considering technological and economic feas i bility .” (44 FR 53761, Sept. 17, 1979). In subsequent Federal Register notices, EPA has ad dressed 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 lithograp hic printing and letterpress printing; flexible package printing; and industrial cleaning solvents. Indeveloping these CTGs, EPA, among other things, evaluated the sources of VOC emissions from th e industry and the available control approaches for addres sing 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 cle aning solvents.2

In 19 93 , 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 techni ques (ACT) document in June 1994 that provided supplemental information for States to use in developing rules based on RACT for offset lithographic p rinting. In December 1978, EPA published a CTG for graphic arts (rotogravure printing and flexographic pri nting) that included flexible package printing. In 1994, EPA developed an ACT document for industrial cleaning solvents. A fter 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 deve loped new CTGs entitled Control Techniques Guidelines for Offset Lithographic and Letterpress Printing (Publication No . EPA 453/R

- 0 6

- 00 2 ; September 200 6 ); Control Techniques Guidelines for Flexible Package Printing (Publication No. EPA 453/R

- 0 6

- 00 3 ; September 200 6 ); Control Techniques Guidelines for Industrial Cleaning Solvents (Publication No. EPA 453/R

- 0 6

- 00 1 ; Sep tember 200 6 )

. The CTG recommendations may not appl y 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 S tate 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 approva l as part of the SI P 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 O**  **ffset Lithographic Printing and L etterpress Printing**  Offset lithograph y 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 be tween the areas on the lithographic plate, the image area is rendered oil receptive, and the non

- image area is rendered water receptive. Offset lithograph y 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, includin g 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 ty pes of offset lithograph y 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

- fed3

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. Insheet

- fed and coldest web letterpress printing, 95 percent of the petro leum 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 VOC s (petroleum ink oils) from the inks; (2) evaporation of VOC s from the fountain solution; and (3) evaporation of VOC s from the cleaning materials. There are two main sources of VOC emissions from letterpress printing: (1) evaporation of VOC s (petroleum ink oils) from the inks , and (2) evaporation of VOC s from the cleaning materials. **Description of**  **Flexible Packag e**  **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, al uminum 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 fl exible 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 flexograph ic 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 packa ging materials (designated "preformed specialt y 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 . S o , 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. An y 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 p ackaging source category

. Printing of self

adhesive 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 wr aps, wall coverings, vinyl products, decorative laminates, floor coverings, tissue products, and miscellaneous specialty products are not considered flexible packaging. There are two t ypes of printing processes used b y 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 VOC s from cleaning materials.4

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 sy stems or adding control sy stems 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 o f air handled and can necessitate up

- g rades 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, pa int, 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 variet y of reasons including safety , operability , and to avoid product contamination. The cleaning solvents used in these (unit) operations are, in many cases, generall y available bulk solvents that are used for a multitude of applications not limited to cleaning. For example, petroleum distillates may be used as a cleani ng 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 th e industrial cleaning solvent product category includes a variety

of different products with differing VOC contents, and although these products are used in different way s by a wide range of industries, there are several basic approaches to achieve VOC emi ssion 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, modifyi ng 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 of fset lithographic printing and letterpress printing; flexible package printing; and industrial cleaning solvent operations in Alleghen y County. EPA develops CTGs as guidance on control requirements for source categories. States can follow the CTGs or ado pt more restrictive standards. Alleghen y 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 Alleghen y County Health Department (ACHD) Rules and5

Regulations, Arti cle XXI, Air Pollution Control s ections 2105. 8 0 , 2105.8 1 , and 2105. 8 2 . This SIP revision also includes a revision to an existing regulation fo r graphic arts sy stems in s ection 2105 .1 1

. The r evisions are summarized below.

**I. O**  **ffset Lithographic Printing and Letterpress Printing**
T his 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 l etterpress 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

. E xceptions include heatset web offset lithographic printing operations and heatset web letterpress printing operations, for which this section only

applies to those presses with po tential to emit from the dry er 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 operation s are as follows:
1. The VOC content for heatset web offset lithographic printing contains 1.6 percent alcohol or less (b y weight), on

- press (as

- applied) in the fountain or 3.0 percent alcohol or less (b y weight) on

- press (as

- applied) in the fountain solution o r 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 (b y 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 oxidi zer 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 we ight percent VOC. 6. A combination of the methods listed in Paragraphs 1 through 5.

**II. Flexible Package Printing** 
T his section applies to the owner or operator of a flexible package printing press, including rotogravure printing and flexographic printin g , where the total actual VOC emissions from all6

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 Sy stem, 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 operation s 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 s olids 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** 
T his section applies to the owner or operato r of a facility , where the total actual VOC emissions from all of the industrial solvent cleaning operations at the facilit y 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 facilit y that emplo ys 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 L imits of VOCs for Industrial Solvent Cleaning Operations VOC Content L imitation Industrial Solvent Cleaning Operation l bs 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 pharmaceut icals

(i) Tools, equipment and machinery 6.7 0.807 (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) Specialt y flexographic printing 0.83 0.099 5. Cleaning of pol yester resin application equipme nt not subject to 40 CFR Part 63 Subpart WWWW 0.42 0.050

**I V.**  **Additional Revision** In addition to adopting the CTGs discussed above, section 2105.11, Graphic Arts Sy stems, is being amended and added to the Alleghen y County portion of the Penns yl vania 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 o f section 2105.11, Graphic Arts Sy stems, 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**  Alleghen y County has a dopted 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 Penns yl vania SIP to reflect these amendments. The maximum benefit from these amendments will be provided during the ozone season when VOCs readil y combine with NO x to form ground

- level ozone. Therefore, this revision will help Pennsylvania attain and maintain the NAAQS for ozone and EPA approval of the SI P re vision is recommended.