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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE:

SUBJECT: Technical Support Document for Pennsylvania’s Adoption of Control Technique

Guidelines from: Offset Lithographic Printing and Letterpress Printing, Flexible 

Package Printing, and Adhesives, Sealants, Primers, and Solvents

FROM: Ellen Schmitt, Environmental Scientist /s/ 3/12/15

Office of Air Program Planning 

TO: File

THRU: Marilyn Powers, Acting Associate Director /s/ 3/12/15

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 certain 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 

technique guideline (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 adhesives, sealants, 

primers, and 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 provided recommendations for RACT for VOCs from offset lithographic printing,

letterpress printing, flexible package printing, and adhesives, sealants, primers, and solvents. 

States can follow the CTGs or adopt more restrictive standards.
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In 1993, EPA published a draft CTG for offset lithographic printing. See 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. 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 three 

new CTGs entitled Control Techniques Guidelines for Offset Lithographic and Letterpress 

Printing (EPA 453/R-06-002; September 2006), Control Techniques Guidelines for Flexible 

Package Printing (EPA 453/R-06-003; September 2006), and Control Techniques Guidelines for 

Industrial Cleaning Solvents (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 

letterpress presses use coldset inks. Most web letterpress equipment use coldset inks. These 
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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 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 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 VOCs 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.

B. STATE SUBMITTAL

On January 12, 2011, Pennsylvania submitted a SIP revision to meet the RACT requirements for 

the adhesives, sealants, primers, and solvents source category; this SIP revision was approved by 

EPA on September 26, 2012. See 77 FR 59090. Specifically, Pennsylvania submitted 25 Pa 

Code 129.51 (Sources of VOCs), 129.77 (Control of emissions from the use or application of 

adhesives, sealants, primers and solvents), and 130.701 – 708 (under Subchapter D, Adhesives, 

sealants, primers and solvents). 

On August 27, 2014, Pennsylvania Department of Environmental Protection (PADEP) submitted 

to EPA SIP revisions which adopt EPA’s CTG recommendations for offset lithographic printing 

and letterpress printing, flexible package printing, and adhesives, sealants, primers, and solvents

with a number of changes. The SIP revisions include the revised 25 Pa Code 129.67 and new 

sections 25 Pa Code 129.67a and 129.67b. The SIP revisions also include revisions to 25 Pa 

Code 121.1 to include related definitions and conforming revisions to 25 Pa Code 129.51, 

129.77, and 130.703. The revisions are summarized below. The August 2014 revisions do not 

affect the prior approval of the January 2011 SIP revision as meeting the RACT requirements for 

the adhesives, sealants, primers, and solvents source category as approved on September 26, 

2012. 

I. Flexible Package Printing – 25 Pa Code 129.67a

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

as exemptions. Exemptions to particular provisions of 25 Pa Code 129.67a are described with 

those particular provisions, whereas exemptions to the entire 129.67a section are described 

separately.

a) Applicability

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

rotogravure printing and flexographic printing, where one or more of the following apply:

1. An individual flexible packaging printing press has potential emissions from the 

dryer, before consideration of add-on controls, of at least 25 tons per year (tpy) of 

VOCs from inks, coatings and adhesives combined;
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2. The total actual VOC emissions from all inks, coatings and adhesives combined from 

all flexible packaging printing presses and all VOC emissions from related cleaning 

activities at the facility are equal to or greater than 450 pounds (204.1 kilograms) per 

month or 2.7 tons (2,455 kilograms) per 12-month rolling period, before 

consideration of add-on controls; or 

3. The total actual VOC emissions from all inks, coatings and adhesives combined from 

all flexible packaging printing presses and all VOC emissions from related cleaning 

activities at the facility are less than 450 pounds (204.1 kilograms) per month or 2.7 

tons (2,455 kilograms) per 12-month rolling period, before consideration of add-on 

controls.

This section does not apply in the case where VOCs from adhesives are not used or applied 

on or with a flexible packaging printing press; these may be regulated under 25 Pa Code

129.52b, 129.77, or 130, Subchapter D. This section supersedes the requirements of a RACT 

permit issued to the owner or operator of a source subject to this section prior to January 1, 

2015, under 25 Pa Code 129.91 – 129.95 to control, reduce, or minimize VOCs from a 

flexible packaging printing press, except to the extent the RACT permit contains more 

stringent requirements. 

b) Emission Limits

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

well as exemptions. Emissions of VOCs from flexible package printing operations may not 

be permitted unless one or more of the following are met:

1. For individual inks, coatings, or adhesives the VOC content, as applied, on a single 

press, must be equal to or less than either 0.16 pounds (lbs) VOC per pound of 

material or 0.8 lbs VOC per pound material solid, or both, as applied.

For calculating the VOC content when expressed in units of weight of VOC per 

weight of material solids the following formula should be used:

VOCB =

Wo

Wn

Where:

VOCB = VOC content in lb VOC/lb of solids as applied or kg VOC/kg of solids as 

applied

Wo = Weight percent of VOC (Wv -Ww -Wex)

Wv = Weight percent of total volatiles (100%-weight percent solids)

Ww = Weight percent of water

Wex = Weight percent of exempt solvents

Wn = Weight percent of solids of the as applied ink, coating or adhesive
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2. The daily weighted-average VOC content meets the 0.16 lbs VOC per lb material or 

0.8 lbs VOC per lb material solids limits above, in which case the use of averaging to 

meet the VOC content limits is available for use on a single flexible packaging 

printing press using the following formula:

∑CiVi

n

i=t

VOCw = ___________

Vt

Where:

VOCw = The daily weighted average VOC content, as applied, of all inks, coatings 

and adhesives combined used on a single flexible packaging printing press, in lb 

VOC/gal of coating solids

n = The number of different inks, coatings and adhesives used each day on the 

single flexible packaging printing press

Vi = The volume of solids for each ink, coating and adhesive, as applied, used each 

day on the single flexible packaging printing press, in gallons

Ci = The VOC content of each ink, coating and adhesive, as applied, used each day 

on the single flexible packaging printing press, in lb VOC/gal coating solids

Vt = The total volume of solids for all inks, coatings and adhesives combined, as 

applied, used each day on the single flexible packaging printing press, in gallons

3. The overall weight of VOCs emitted to the atmosphere is reduced through the use of 

vapor recovery or oxidation or another method that is acceptable under chapter 

129.51(a) (relating to general). The overall control efficiency of a control system 

may not be less than that listed in Table 1.

Table 1 – Overall Control Efficiency Requirement of a Control System on a Single Flexible 

Packaging Printing Press with Potential Emissions ≥ 25 tpy of VOC Before Control

Control System

Overall Control

Efficiency Requirement

Printing Press

First Installation Date1

Air Pollution Control Device

First Installation Date1

Prior to On or after Prior to On or after 

March 14, 

1995*

March 14, 

1995*

January 1, 

2015

January 1, 

2015

≥ 65% X X

≥ 70% X X

≥ 75% X X

≥ 80% X X

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 First installation date is the first date of operation for a source or a control device. This date does not 

change if the source or control device is moved to a new location or if the control device is later used to 

control a new source.

* March 14, 1995, is the date of the proposed 1996 NESHAP for the printing and publishing industry.
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4. The Department has issued a plan approval, operating permit or Title V permit to the 

owner or operator prior to January 1, 2015, establishing a Federally-enforceable 

limitation to limit the potential emissions of VOC from the flexible packaging 

printing press below 25 tpy before consideration of add-on controls.

c) Compliance and Monitoring Requirements

For add on air pollution control devices for a flexible packaging printing press the following 

requirements must be followed:

1. The control device shall be equipped with the applicable monitoring equipment and 

shall be installed, calibrated, operated and maintained according to manufacturer’s 

specifications at all times the add-on air pollution control device is in use.

a. For non-catalytic thermal oxidizers the minimum combustion or operating 

temperature must be continuously monitored and the temperature reading must be 

recorded at least once every 15 minutes while operating.

b. For catalytic thermal oxidizers the inlet gas temperature must be continuously 

monitored and the temperature reading must be recorded every 15 minutes while 

operating. Additionally, a catalyst activity test should be performed a minimum 

of once per rolling 2-year period.

c. For a control device other than a non-catalytic or catalytic thermal oxidizer, the 

parameters specific to the control device must be continuously monitored and the 

parameters must be recorded every 15 minutes while operating. It must also be: 

(1) Approved by the DEP, (2) operated continuously while the source is 

operating, and (3) operate with a 3-hour average temperature not lower than 50°F 

below the average temperature demonstrated during the most recent compliant 

source test approved by the DEP.

d) Recordkeeping and Reporting Requirements

The owner or operator of a printing press subject to this section must maintain sufficient 

records to demonstrate compliance with this section and may include purchase, use, 

production, and other records. These records must be maintained onsite for two years unless 

a longer period is required by a plan approval or operating permit.

1. For add-on air pollution control devices, the owner or operator must maintain records 

of: (1) Temperature reading of the control device, (2) maintenance performed on the 

device and monitoring equipment, including date and type of maintenance performed, 

and (3) catalyst activity test, if applicable

2. For owners and operators not using an add-on air pollution control device, the owner 

or operator must maintain records of the as applied VOC content of inks, coatings, 

and adhesives sufficient to demonstrate compliance with the emission limits 

described above in section II(b)(1 and 2).
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3. For owners and operators that claim an exemption, the owner or operator must 

maintain records that demonstrate that the press or facility is exempt.

e) Work practice requirements for cleaning activities

Owners and operators of an offset lithographic printing press or a letterpress printing press

must comply with the following work practices for cleaning activities at the facility:

1. Store all VOC-containing cleaning solutions, waste cleaning solutions and used shop 

towels in closed containers.

2. Ensure that mixing vessels and storage containers used for VOC-containing cleaning 

solutions, waste cleaning solutions and used shop towels are kept closed at all times, 

except when depositing or removing these solutions or shop towels.

3. Minimize spills of VOC-containing cleaning solutions and waste cleaning solutions 

and clean up spills immediately.

4. Convey VOC-containing cleaning solutions, waste cleaning solutions and used shop 

towels from one location to another in closed containers or pipes.

These requirements apply to the following activities: (1) Cleaning of ink, coating, or 

adhesive from a press; (2) cleaning of ink, coating, or adhesive from press parts, including 

press parts that have been removed from the press for cleaning; and (3) cleaning of ink, 

coating, or adhesive from areas around a press. The requirements do not apply to the 

following activities: (1) Cleaning electronic components of a press, (2) cleaning in pre-press 

operations (i.e. platemaking), (3) cleaning in post-press operations (i.e. binding), (4) using 

janitorial supplies for general cleaning, and (5) the use of parts washers or cold cleaners at a 

flexible packaging printing facility.

II. Offset Lithographic Printing and Letterpress Printing – 25 Pa Code 129.67b

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

as exemptions. Exemptions to particular provisions of 25 Pa Code 129.67b are described with 

those particular provisions, whereas exemptions to the entire 129.67b section are described 

separately.

a) Applicability

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

letterpress printing operation, if the press is: 

1. A single heatset web offset lithographic printing press or heatset web letterpress 

printing press that has potential emissions from the dryer, before consideration of 

add-on controls, of at least 25 tpy of VOCs from all heatset inks (including 

varnishes), coatings and adhesives combined.
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2. One or more letterpress printing presses if the total actual VOC emissions from all 

inks (including varnishes), coatings and adhesives combined from all letterpress 

printing presses and all VOC emissions from related cleaning activities at the facility 

are equal to or greater than 450 pounds (204.1 kilograms) per month or 2.7 tons 

(2,455 kilograms) per 12-month rolling period, before consideration of add-on 

controls.

3. One or more offset lithographic printing presses if the total actual VOC emissions 

from all inks (including varnishes), coatings, adhesives and fountain solutions 

combined from all offset lithographic printing presses and all VOC emissions from 

related cleaning activities at the facility are equal to or greater than 450 pounds (204.1 

kilograms) per month or 2.7 tons (2,455 kilograms) per 12-month rolling period, 

before consideration of add-on controls.

4. One or more offset lithographic printing presses and one or more letterpress printing 

presses if the total actual VOC emissions from all inks (including varnishes), 

coatings, adhesives and fountain solutions combined and all VOC emissions from 

related cleaning activities at the facility are equal to or greater than 450 pounds (204.1 

kilograms) per month or 2.7 tons (2,455 kilograms) per 12-month rolling period, 

before consideration of add-on controls.

5. The total actual VOC emissions from all inks (including varnishes), coatings, 

adhesives and fountain solutions combined from all offset lithographic printing 

presses, all letterpress printing presses and all VOC emissions from related cleaning 

activities at the facility are less than 450 pounds (204.1 kilograms) per month and 2.7 

tons (2,455 kilograms) per 12-month rolling period, before consideration of add-on 

controls.

This section does not apply in the situation where VOCs from adhesives are not used or 

applied on or with an offset lithographic printing press or a letterpress printing press. In 

these situations VOCs from adhesives may be regulated under either chapter 129.77 or 

chapter 130. This section also supersedes the requirements of a RACT permit issued to the 

owner or operator of a source prior to January 1, 2015, under 25 Pa Code 129.91 – 129.95 

(relating to stationary sources of NOx and VOCs) to control, reduce or minimize VOCs from 

an offset lithographic printing press or a letterpress printing press, or both, except to the 

extent the RACT permit contains more stringent requirements.

b) Emission limits

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

operations are as follows:

1. The VOC content for cleaning solutions must have a VOC composite partial vapor 

pressure less than 10 millimeters of mercury at 68°F (20°C) and/or must have a VOC 

content less than 70% by weight. Where one or more cleaning solutions does not 
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meet either limit, the cleaning solution is limited to 110 gallons per year, combined, 

of all cleaning solutions that exceed those limits.

2. The VOC content for fountain solutions must:

a. For each heatset web offset lithographic printing press, the as applied solution 

must have a VOC content of 1.6% or less by weight, 3% or less by weight if the 

solution is refrigerated below 60°F (15.5°C), 5% or less by weight and contains 

no alcohol, or another method that achieves a level of control equal to or better 

than the previous methods. 

b. For each sheet-fed offset lithographic printing press, the as applied solution must 

have a VOC content of 5% or less by weight, 8.5% or less by weight if the 

solution is refrigerated below 60°F (15.5°C), 5% or less by weight and contains 

no alcohol, or another method that achieves a level of control equal to or better 

than the previous methods.

c. For each non-heatset web offset lithographic printing press, the as applied 

solution must have a VOC content of 5% or less by weight and contains no 

alcohol.

3. The VOC content for heatset web offset lithographic printing presses and heatset web 

letterpress printing presses must not be emitted to the atmosphere from the heatset 

dryer unless the overall weight of VOCs is reduced through the use of vapor recovery 

or oxidation or another authorized method. The control efficiency of an add-on 

control device must meet either:

a. At least 90% if installed before January 1, 2015, or

b. At least 95% if installed after January 1, 2015.

The installation date is the first date of operation for a source or a control device and 

does not change if the source or control device is moved to a new location or if the 

control device is later used to control a new source. Alternatives may be used if 

approved by the Department of Environmental Protection and only if, (1) the inlet 

VOC concentration to the control device is so low that compliance with the 90% or 

95% efficiency is not achievable or the press is using a combination dryer and 

oxidizer or other control equipment configuration that does not have an inlet that 

meets the requirement for testing as specified, and (2) the minimum outlet VOC 

concentration that the unit can achieve, does not exceed 20 parts per million (ppm) as 

hexane (40 ppm as propane) on a dry basis.

This section also establishes emission limit exemptions including:

1. For fountain solutions:

a. For sheet-fed offset lithographic printing presses with maximum sheet size of 

11x17 inches or smaller

b. For an offset lithographic printing press with total fountain solution reservoir of 

less than 1 gallon

2. For heatset web offset lithographic printing presses and heatset web letterpress 

printing presses:
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a. If the press is used for book printing,

b. If the press has a maximum web width of 22 inches or less, or

c. If the press is operated with one or more of the following inks:

i. Waterborne coatings,

ii. Ultra-violet light or electron beam radiation cured materials,

iii. Sheet-fed or non-heatset web inks, or

iv. Sheet-fed or non-heatset web varnishes.

c) Compliance and Monitoring Requirements

1. For add on air pollution control devices for heatset web offset lithographic printing 

press or heatset web letterpress printing press must comply with the following:

a. The control device shall be equipped with the applicable monitoring equipment 

and shall be installed, calibrated, operated and maintained according to 

manufacturer’s specifications at all times the add-on air pollution control device is 

in use.

i. For non-catalytic thermal oxidizers the minimum combustion or operating 

temperature must be continuously monitored and the temperature reading 

must be recorded at least once every 15 minutes while operating.

ii. For catalytic thermal oxidizers the inlet gas temperature must be continuously 

monitored and the temperature reading must be recorded every 15 minutes 

while operating. Additionally, a catalyst activity test should be performed a 

minimum of once per rolling 2-year period.

iii. For a control device other than a non-catalytic or catalytic thermal oxidizer, 

the parameters specific to the control device must be continuously monitored

and the parameters must be recorded every 15 minutes while operating. It 

must also be: (1) Approved by the DEP, (2) operated continuously while the 

source is operating, (3) operate with a 3-hour average temperature not lower 

than 50°F below the average temperature demonstrated during the most recent 

compliant source test approved by the DEP, and (4) negative dryer pressure 

should be established during the initial test using an air flow direction 

indicator.

2. For fountain solutions, compliance shall be demonstrated with one or more of the 

following:

a. Analysis of a sample of the as applied fountain solution for VOC content using 

EPA Reference Method 24, as revised.

b. Maintain Material Data Safety Sheets (MSDS), Certified Product Data Sheets 

(CPDS), or other data provided by the manufacturer of the fountain solution that 

indicates the VOC content.

c. Calculation of the VOC content of the as applied solution that combines the 

analytical VOC content data from Reference Method 24 for each of the 

concentrated components used to prepare the solution

i. The VOC content data for each of the concentrated components must be 

combined in the proportions in which they are mixed to make the as applied 

solution
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ii. The VOC content should be calculated once for each recipe. The recipe 

name, VOC content of each concentrated component, and mix ratio shall be 

recorded in a logbook.

iii. Reference Method 24 analysis may be performed by the supplier of the 

components, the results of which can be provided to the owner of the affected 

press.

d. Measurement of the recirculating reservoir temperature of a refrigerated as 

applied solution with a thermometer (or other temperature detection device)

capable of reading to 0.5°F (0.28°C). The temperature of the refrigerated fountain 

solution containing alcohol should be maintained below 60°F (15.5°C) at all 

times. The temperature shall be continuously monitored and recorded at least 

once per operating day.

e. Monitoring of the as applied solution for alcohol concentration or VOC content 

with one or more of the following instruments:

i. A refractometer or a hydrometer to monitor the fountain solution alcohol 

concentration. The instrument must be (1) corrected for temperature once 

every 8-hour shift, (2) have a visual, analog, or digital readout with an 

accuracy of 0.5%, and (3) be calibrated with a standard solution for the type of 

alcohol used.

ii. A conductivity meter to determine the VOC content of the solution referenced 

to the conductivity of the incoming water.

f. Other methods to determine compliance with the VOC content limits, if the owner 

or operator requests approval of the alternative method, demonstrates the 

alternative method provides results that accurately determines the VOC content, 

and the DEP provides approval.

3. For cleaning solutions, compliance with the VOC content limit or VOC composite 

partial vapor pressure limit shall be met with one or more of the following methods:

a. Analysis of a sample of as applied solution for VOC content using Method 24

b. Use of the equation for composite partial vapor pressure

c. Use of the methods in section 129.67b(k) for VOC composite partial vapor 

pressure for a single component of a solution

d. Maintenance of MSDS, CPDS, or other data provided by the manufacturer of the 

as applied solution

e. Calculation of the VOC content, VOC composite partial vapor pressure, or both, 

of the as applied solution that combines the Method 24 VOC content data or 

analytical VOC composite partial vapor pressure data for each of the components 

used in the solution.

i. The VOC content data for each of the concentrated components must be 

combined in the proportions in which they are mixed to make the as applied 

solution

ii. The VOC content should be calculated once for each recipe. The recipe 

name, VOC content of each concentrated component, and mix ratio shall be 

recorded in a logbook.
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iii. Reference Method 24 analysis may be performed by the supplier of the 

components, the results of which can be provided to the owner of the affected 

press.

f. Another method to determine compliance with the VOC content limits if the 

owner or operator requests approval of the alternative method, demonstrates the 

alternative method provides results that accurately determines the VOC content, 

and the DEP provides approval.

d) Reporting and Recordkeeping requirements

The owner or operator of a printing press subject to this section must maintain sufficient 

records to demonstrate compliance with this section and may include purchase, use, 

production, and other records. These records must be maintained onsite for two years unless 

a longer period is required by a plan approval or operating permit.

1. For add-on air pollution control devices, the owner or operator must maintain records 

of: (1) Temperature reading of the control device, (2) maintenance performed on the 

device and monitoring equipment, including date and type of maintenance performed, 

and (3) catalyst activity test, if applicable

2. For all printing presses, 

a. The following parameters for each press ready blanket, roller or other cleaning 

solution: (1) Name and identification number for the blanket, roller, or other 

cleaning solution, (2) the VOC content (weight %) or VOC composite partial 

vapor pressure of each cleaning solution as applied, (3) the volume of each 

cleaning solution used, if the owner or operator is using cleaning solutions which 

exceed a composite partial vapor pressure of 10 millimeters of mercury at 68°F or 

has a VOC content greater than 70% by weight, and (4) records of cleaning 

solution monitoring

b. For fountain solutions owners and operators are required to maintain records of 

the VOC content (weight %) and other records of fountain solution monitoring as 

required.

3. For owners and operators that claim an exemption, the owner or operator must 

maintain records that demonstrate that the press or facility is exempt.

e) Work practice requirements for cleaning activities

Owners and operators of an offset lithographic printing press or a letterpress printing press

must comply with the following work practices for cleaning activities at the facility:

1. Store all VOC-containing cleaning solutions, waste cleaning solutions and used shop 

towels in closed containers.
14

2. Ensure that mixing vessels and storage containers used for VOC-containing cleaning 

solutions, waste cleaning solutions and used shop towels are kept closed at all times, 

except when depositing or removing these solutions or shop towels.

3. Minimize spills of VOC-containing cleaning solutions and waste cleaning solutions 

and clean up spills immediately.

4. Convey VOC-containing cleaning solutions, waste cleaning solutions and used shop 

towels from one location to another in closed containers or pipes.

These requirements apply to the following activities: (1) Cleaning of a press, including 

blanket washing, roller washing, plate cleaners, metering roller cleaners, impression cylinder 

cleaners and rubber rejuvenators; (2) cleaning of press parts, including press parts that have 

been removed from the press for cleaning; and (3) cleaning of ink, coating or adhesive from 

areas around a press. The requirements do not apply to the following activities: (1) Cleaning 

electronic components of a press, (2) cleaning in pre-press operations (i.e. platemaking), (3) 

cleaning in post-press operations (i.e. binding), (4) using janitorial supplies for general 

cleaning, and (5) the use of parts washers or cold cleaners at an offset lithographic printing or 

a letterpress printing facility.

f) Vapor Pressure Calculations

Composite partial vapor pressure of organic compounds in cleaning solutions shall be 

determined by either (1) quantifying the amount of each compound in the blend using gas 

chromatographic analysis, or (2) using the following equation:

∑

(Wi)(VPi)

MWi

n

i=1

PPc = ______________________________

WV

MWW

+ ∑

We

MWe

k

e=1

+ ∑

Wi

MWi

n

i=1

Where:

PPc = VOC composite partial vapor pressure at 20°C, in mm mercury

Wi = Weight of the “i”h VOC compound, in grams

Ww = Weight of water, in grams

We = Weight of the “e”th exempt compound, in grams

MWi = Molecular weight of the “i”th VOC compound, in grams per g-mole, as given in 

chemical reference literature

MWw = Molecular weight of water, in grams per g-mole (18 grams per g-mole)

MWe = Molecular weight of the “e”th exempt compound, in grams per g-mole, as given in 

chemical reference literature

VPi = Vapor pressure of the “i”th VOC compound at 20°C, in mm mercury, as determined 

by subsection (k)
15

For determining the vapor pressure of a single component in cleaning solutions, the

following methods may be used: (1) An appropriate and current American Society for 

Testing and Materials (ASTM) test method with written approval by DEP, and/or (2) the 

most recent edition of one or more of four identified reference books or an additional source 

approved by DEP.

g) VOC Retention Factors And Capture Efficiency Factors

A portion of the VOCs contained in the ink or cleaning solution, or both, is retained in the 

printed web substrate or in the shop towels used for cleaning. The following VOC emission 

retention factors can be used, as applicable:

1. A 20% VOC emission retention factor for a petroleum ink oil-based heatset ink 

printed on an absorptive substrate. This means that 80% of the petroleum ink oil 

content is emitted as VOC during the printing process and is available for capture and 

control by an add-on air pollution control device. The petroleum ink oil content of a 

heatset ink may be determined from formulation data included on a CPDS or MSDS.

2. A 95% VOC emission retention factor for a petroleum ink oil-based non-heatset web 

or non-heatset sheet-fed ink. This means that 5% of the petroleum ink oil content is 

emitted as VOC during the printing process and is available for capture and control 

by an add-on air pollution control device. The petroleum ink oil content of a nonheatset web or non-heatset sheet-fed ink may be determined from formulation data 

included on a CPDS or MSDS.

3. A 100% VOC emission retention factor for vegetable ink oil-based heatset and nonheatset inks.

4. A 50% VOC emission retention factor for low VOC composite vapor pressure 

cleaning solutions in shop towels if both of the following conditions are met: (1) The 

VOC composite vapor pressure of the cleaning solution is less than 10mm mercury at 

20°C (68°F), and (2) the cleaning solutions and used shop towels are kept in closed 

containers.

A portion of the VOCs contained in one or more of the ink, fountain solution, or automatic 

blanket wash materials is captured in the press dryer for control by the add-on air pollution 

control device. The following capture efficiency factors can be used, as applicable:

1. A 100% VOC emission capture efficiency for volatilized ink oils for oil-based heatset 

paste inks and varnishes if, (1) the press dryer is operating at negative pressure 

relative to the surrounding pressroom, and (2) the air flow is into the press dryer.

2. A 70% VOC emission capture efficiency for a fountain solution that contains an 

alcohol substitute.
16

3. A 40% VOC emission capture efficiency for an automatic blanket wash if the VOC 

composite vapor pressure of the cleaning solution is less than 10mm Hg at 20°C 

(68°F).

III. Other Revisions

In addition to adding the regulations previously discussed, Pennsylvania is also revising 25 Pa 

Code 121.1 (Definitions), 25 Pa Code 129.51 (General), 25 Pa Code 129.67 (Graphic arts 

systems), 25 Pa Code 129.77 (Control of emissions from the use or application of adhesives, 

sealants, primers and solvents), and 25 Pa Code 130.703 (Exemptions and exceptions). The 

revisions to sections 121.1, 129.51, 129.67, 129.77, and 130.703 are being made to better define 

each relevant section and to ensure the correct applicability for each printing operation.

a) Revisions to 121.1 (Definitions)

The following new definitions were included in the revisions to 25 Pa Code 121.1 

(Definitions):

 Alcohol – A chemical compound consisting of the hydroxyl (OH) group attached to 

an alkyl radical and having the general formula CnH2n+1OH, such as ethanol, npropanol, and isopropyl alcohol.

 Alcohol substitute – Nonalcohol additives that contain VOCs and are used in the 

fountain solution including ethylene glycol and glycol ethers. Some additives are 

used to reduce the surface tension of water and others are added to prevent piling (ink 

build up). 

 Batch –

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

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

printing process.

(ii) The term includes:

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

amount.

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

unit.

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

of an automatic blanket or roller wash system.

 Cleaning solution – A liquid solvent or solution used to remove ink, including dried 

ink, and debris from the operating surfaces of a printing press and its parts. The term 

includes a blanket wash, impression cylinder wash, roller wash, metering roller 

cleaner, plate cleaner, rubber rejuvenator and other cleaners used for cleaning a press 

or press parts or to remove dried ink or coating from areas around the press.

 Flexible packaging –

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

which can be readily changed. Flexible packaging may be made of paper, plastic, 

film, aluminum foil, metalized or coated paper, metalized or coated film, or other 
17

material.

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

flexible packaging printing press.

(iii) The term does not include folding cartons or other rigid packaging or selfadhesive labels.

 Flexible packaging printing press – A printing press used for the production of 

printed flexible packaging materials using flexographic printing or rotogravure 

printing, or both.

 Fountain solution – A mixture of water, volatile and nonvolatile chemicals and one or 

more additives that reduce the surface tension of the water so that the mixture spreads 

easily across the printing surface of a lithographic plate. The mixture wets the 

nonimage area so that the printing ink is maintained within the image area.

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

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

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

 Heatset – An operation in which heat is required to evaporate ink oils from the 

printing inks that are applied to the substrate.

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

 Letterpress printing – A printing process in which the image area of the plate is raised 

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

from the image surface. The substrate can be fed to the press as either an individual 

sheet or a rolled web.

 Lithographic plate – The plate used in lithographic or offset lithographic printing 

which has chemically differentiated image and nonimage areas so that the printing ink 

adheres to the image areas. 

 Lithographic printing – A printing process in which the image and nonimage areas 

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

areas are chemically differentiated; the image area is oil receptive and the nonimage 

area is water receptive. The substrate can be fed to the press as either an individual 

sheet or a rolled web.

 Non-heatset – A lithographic or letterpress printing process in which the printing 

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

rather than by evaporation with heat. These non-polymerization processes are also 

known as “coldest” processes. Polymerization processes including the use of an 

infrared dryer, ultraviolet curing or electron beam curing are also considered nonheatset operations.

 Offset lithographic printing – A printing process in which the image and nonimage 

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

nonimage areas are chemically differentiated. The ink film is transferred from the 

lithographic plate to an intermediary surface, typically a rubber-covered cylinder 

called a blanket, which in turn transfers the ink film to the substrate. The substrate 

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

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

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

at least one printing work station. The following equipment, if present, is also 

considered part of the term:
18

(i) One or multiple unwind or feed sections.

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

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

coating, is considered part of the printing press if the station is capable of printing 

or coating on the same substrate and if the work station is physically connected as 

part of the printing press.

(iii) A dryer associated with a work station.

(iv) A rewind, stack or collection section.

 Sheet-fed printing – A printing process in which individual sheets of substrate are fed 

sequentially to the printing press.

 Varnish – For purposes of §129.67b, an unpigmented offset lithographic ink which is 

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

pigmented offset lithographic ink. The term includes a heatset varnish, sheet-fed 

varnish and non-heatset varnish.

 Web printing – A printing process in which continuous rolls of substrate material are 

fed to the printing press and rewound or cut to size after printing.

The following definitions were revised in 25 Pa Code 121.1 (Definitions); additions are 

identified as underlined and deletions are identified in [brackets]:

 As applied –

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

sealant primer, surface preparation solvent or cleanup solvent that is actually used 

to coat the substrate.

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

coating.

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

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

offset lithographic printing presses and letterpress printing presses), the VOC 

concentration of an ink, coating, adhesive, fountain solution or cleaning solution 

at the time it is actually used on a printing press.

 As supplied –

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

sealant primer, surface preparation solvent or cleanup solvent as sold and 

delivered to the end user.

(ii) For purposes of §§129.67a and 129.67b, the VOC concentration of an ink, 

coating, adhesive, fountain solution or cleaning solution that is purchased for use 

on a printing press.

 CPDS – Certified Product Data Sheet –

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

129.107 (relating to wood furniture manufacturing operations), documentation 

furnished by a coating supplier or an outside laboratory for a coating, strippable 

spray booth coating or solvent that provides the VOC content as pounds of VOC 

per pound of coating solids calculated from data measured using the EPA 

Reference Method 24 or an equivalent or alternative method. Batch formulation 

data may be used if it is demonstrated to the satisfaction of the Administrator of 
19

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

during the cure. The VOC content stated should represent the maximum VOC 

emission potential of the coating, strippable spray booth coating or solvent.

(ii) For purposes of printing operations under §129.67b, documentation furnished 

by an ink supplier or an outside laboratory for an ink, fountain solution, cleaning 

solution or solvent that provides the VOC content calculated from data measured 

using the EPA Reference Method 24 or an equivalent or alternative method 

approved by the Department. The VOC content stated should represent the 

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

or solvent.

 Paper, film or foil coating or paper, film or foil surface coating – Coatings 

applied in a continuous, uniform layer to paper, film or foil surfaces, and 

pressure-sensitive tapes, regardless of substrate. The coatings are applied to 

provide a covering, finish or functional or protective layer to the substrate, 

saturate a substrate for lamination or provide adhesion between two substrates for 

lamination.

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

substrates:

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

sensitive tapes and labels.

(B) Plastic and photographic films.

(C) Industrial and decorative laminates.

(D) Abrasive products, including fabric coated for use in abrasive products.

(E) Flexible packaging, including coating of nonwoven polymer substrates for 

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

flexible packaging printing press.

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

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

materials undergo physical change – that is, the size, shape, appearance, temperature, 

state or other physical property of the material is altered – or chemical change – that

is, a substance with different chemical composition or properties [are] is formed or 

created. The term includes all of the equipment, operations and facilities necessary 

for the completion of the transformation of the materials to produce a physical or 

chemical change. There may be several processes in series or parallel necessary to 

the manufacture of a product.

 Rotogravure printing – The application of words, designs and pictures to a substrate 

by means of a roll printing technique which involves an intaglio or recessed image 

area in the form of cells.

b) Revisions to 129.51 (General)

Revisions to this section include: (1) The removal of an outdated reference to 129.70, and the 

addition of references to new sections 129.67a and 129.67b; (2) the clarification that the test 

methods in chapter 139 should be followed to monitor compliance with the emission 

requirements of section 129.51 unless otherwise set forth in chapter 129; (3) the clarification 

of the records to be kept and the amount of time they should be kept; and (4) the 
20

redesignation of section 129.51(d)(3) to 129.51(e) which clarifies that owners or operators 

claiming an exemption to this section should maintain records to demonstrate such 

exemption. 

c) Revisions to 129.67 (Graphic arts systems)

Revisions to this section account for the new requirements of section 129.67a and 129.67b. 

They also clarify that an owner or operator of a flexible packaging printing press who was 

required to install a control device under 129.67 prior to June 28, 2014 is subject to both the 

requirements of 129.67 and the new requirements of 129.67a. However, owner or operators 

subject to 129.67a by virtue of meeting the threshold of 25 tpy of potential emissions of VOC 

(before the consideration of add-on controls) is not subject to 129.67 because the 

requirements of 129.67a are more stringent than those in 129.67.

d) Revisions to 129.77 (Control of emissions etc.)

Revisions to this section include revising 129.77(k)(2) to clarify that 129.77 does not apply to

the use or application of adhesives, sealants, adhesive primers, and sealant primers that are 

subject to other regulations in chapters 129 or 130.

e) Revisions to 130.703 (Exemptions and exceptions)

Revisions to this section include revising 130.703(a)(2) to clarify that 130.703 does not apply 

to the use or application of adhesives, sealants, adhesive primers, and sealant primers that are 

subject to other regulations in chapters 129 or 130.

C. EPA’S EVALUATION

I. Flexible Package Printing – 25 Pa Code 129.67a

Section 129.67a closely mirrors the CTG for flexible package printing press operations with the 

exception of a few minor details. The CTG recommends that the controls considered should 

apply to printing presses that have potential emissions of 25 tpy of VOCs before consideration of 

add-on controls. The CTG also recommends establishing various controls based on the total 

actual VOC emissions before consideration of add-on controls, and sets the threshold for actual 

emissions at 450 lbs per month or 3 tons per 12-month rolling period. PADEP has adopted these 

applicability thresholds with the exception of the 3 tons per 12-month rolling period for actual 

VOC emissions; instead, PADEP is using 2.7 tons per 12-month rolling period in order to stay 

consistent with other PADEP regulations and historical usage. Thus, PADEP is more stringent 

in this minor change from the CTG.

The flexible package printing press CTG recommends limiting the VOC content of inks, 

coatings, and adhesives to either 0.16 lbs VOC per lb material applied or 0.8 lbs VOC per lb 

material solids as applied. The CTG allows for the calculation of a daily weighted-average VOC 

content of all inks, coatings, and adhesives in order to meet the 0.16 and 0.8 lb VOC limits. For 
21

add-on controls the CTG recommends the overall control efficiency to be between 65% and 80% 

depending on the first installation date as previously described in Table 1. 

The flexible package printing press CTG also recommends work practice standards for cleaning 

activities which include: (1) Storing all VOC-containing cleaning solutions, waste cleaning 

solutions and used shop towels in closed containers, (2) ensuring that mixing vessels and storage 

containers used for VOC-containing cleaning solutions, waste cleaning solutions and used shop 

towels are kept closed at all times, (3) minimizing spills of VOC-containing cleaning solutions 

and waste cleaning solutions and cleaning up spills immediately, and (4) conveying VOCcontaining cleaning solutions, waste cleaning solutions and used shop towels from one location 

to another in closed containers or pipes.

PADEP has adopted these emission limits and work practice standards as recommended in the 

flexible package printing CTG. In addition to these recommendations, PADEP has also adopted 

various compliance, monitoring, recordkeeping, and reporting requirements as discussed in 

section B.I of this technical support document (TSD). Therefore, EPA finds that the 

requirements of 25 Pa Code 129.67a are equivalent to the recommendations of the flexible 

package printing press CTG, and thus meet the RACT requirements of CAA section 

182(b)(2)(A).

II. Offset Lithographic Printing and Letterpress Printing – 25 Pa Code 129.67b

Section 129.67b closely mirrors the CTG for offset lithographic and letterpress printing

operations with the exception of a few minor details. The CTG recommends that the controls 

discussed should apply to: (1) A heatset web offset lithographic printing press or heatset web 

letterpress printing press that has potential emissions from the dryer of 25 tpy of VOCs before 

consideration of add-on controls; (2) all letterpress printing and offset lithographic printing if the 

total actual VOC emissions are equal to or greater than 450 lbs per month or 3 tons per rolling 

12-month period; and (3) if the total actual VOC emissions from all lithographic printing presses, 

letterpress printing presses, and related cleaning activities is less than 450 lbs per month and 3 

tons per 12-month rolling period. PADEP has adopted these applicability thresholds with the 

exception of the 3 tons per 12-month rolling period for actual VOC emissions; instead, PADEP 

is using 2.7 tons per 12-month rolling period in order to stay consistent with other PADEP 

regulations and historical usage. Thus, PADEP is more stringent in this minor change from the 

CTG.

The lithographic printing press and letterpress printing press CTG recommends emission limits

for cleaning solutions, fountain solutions used on heatset web offset and sheet-fed offset 

lithographic printing presses, heatset web offset lithographic and heatset web letterpress printing 

presses. The CTG also allows for exceptions for certain fountain solutions and certain uses, inks, 

coatings, and varnishes for heatset web offset lithographic and heatset web letterpress printing 

presses. 

The lithographic printing press and letterpress printing press CTG also recommends work 

practice standards for cleaning activities and VOC retention and efficiency factors as discussed 

in sections B.II.(e) and B.II.(g) of this TSD, respectively. 
22

PADEP has adopted these emission limits, work practice standards, and VOC retention and 

efficiency factors as recommended in the lithographic printing press and letterpress printing 

press CTG. In addition to these recommendations, PADEP has also adopted various compliance, 

monitoring, recordkeeping, and reporting requirements as discussed in section B.II of this TSD. 

Therefore, EPA finds that the requirements of 25 Pa Code 129.67b are equivalent to the 

recommendations of the lithographic printing press and letterpress printing press CTG, and thus 

meet the RACT requirements of CAA section 182(b)(2)(A).

III. Other Revisions

As previously discussed, Pennsylvania is also revising 25 Pa Code 121.1 (Definitions), 129.51 

(General), 129.67 (Graphic arts systems), 129.77 (Control of emissions from the use or 

application of adhesives, sealants, primers and solvents), and 130.703 (Exemptions and 

exceptions). The revisions to section 121.1 include relevant definitions required to carry out new 

subsections 129.67a and 129.67b. The revisions to 129.51, 129.67, 129.77, and 130.703 are 

necessary in order to better define the applicability of the relevant requirements to the various 

source categories. These particular revisions affect the regulations that were previously adopted 

to meet the CTG recommendations for adhesives, sealants, primers, and solvents source 

categories. See 77 FR 59090 (September 26, 2012). The revisions to these regulations will not 

affect EPA’s prior determination that they meet the RACT requirements for adhesives, sealant, 

primers, and solvents. Therefore, EPA finds that the revised provisions of 25 Pa Code 129.51, 

129.67, 129.77, and 130.703 continue to meet the RACT requirements of CAA section 

182(b)(2)(A) for adhesives, sealant, primers, and solvents.

D. RECOMMENDED AGENCY ACTION

Pennsylvania has adopted the standards and recommendations of the CTGs for offset 

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

cleaning operations, and is requesting that EPA amend the Pennsylvania SIP to reflect these 

revisions. The maximum benefit from these amendments will be provided during the ozone 

season when VOCs readily combine with NOx to form ground-level ozone. 

As a whole, these revisions will meet the RACT requirements for Pennsylvania for the flexible 

packaging printing materials, offset lithographic printing materials, and letterpress printing 

materials source categories. In addition, these revisions will continue to meet the RACT 

requirements of the adhesives, sealants, primers, and solvents source category as approved on 

September 26, 2012. See 77 FR 59090. Therefore, it is recommended that these revisions to the 

Pennsylvania SIP be approved by EPA as meeting the RACT requirements of CAA section 

182(b)(2)(A) for the flexible packaging printing materials, offset lithographic printing materials, 

and letterpress printing materials source categories.