# Memorandum
Date: March 08, 2011 To: Lisa Vest DNREC Hearing Officer /, ;--" I J1(X 

### "x., V' Through: Ron Amirikian 'f) "-, 5 Planning Branch anager From: Frank Gao

# 1/e/~q Division ofAir

# QU~~REC Subject: Responses to public comments Proposed revision of Section 47.0 of 7 DE Admin Code 1124 Public hearing of February 1, 2011

Dear Hearing Officer,
Under your presiding, a public hearing was held on February 1, 2011, to address new changes being proposed to the subject revision that was previously heard in the hearing on June 2, 2010. The Division ofAir Quality (DAQ) received a comment letterfrom the GraphicArts Association (GAA) in the Febnuary 1, 2011 hearing. The document being attached hereto contains the DAQ's responses to the comments in this letter. Please be reminded, none ofthe comments in the GAA's letterwas made to the new changes subject to the February 1, 2011 hearing. However, the DAQ has determined thattwo comments in the GAA's letter provided meaningful reasons for minorchanges to the proposed revision. Please review the DAQ's explanations and the proposed changes in Sections 47.6.7.1 and 47.6.7.2. The DAQ believes that those changes are minor and will not change any regulatory nature ofthe proposed revision of Section 47.0.
Please let us know ifyou have any question regarding this document.

Attachments (1) DAQ's responses to GAA's comments; (2) Final marked-up version of Section 47.0 of7 DE Admin Code 1124.

## [DAQ's notes for this document: (I) AllDAQ's responses in this documentare in Italicjontandbracketedby [.

..]. (2) In general or unless otherwisespecified, the term "previous comment(s) " in this document means the GAA 's comment(s) in its June 2,2010 comment letter, while the term ''previous response(s)" means theDAQ's response(s) to the related "previous comment(s). ")

February 1, 2011

Mr. Jim Snead. DNREC

- Air Quality Management Section 715 Grantham Lane New Castle, DE 19720
Re: Comments on proposed amendments to 7 DE Administrative Code 1124, Section 47.0
Dear Mr. Snead:

In reviewing the proposed amendments to 7 DE Administrative Code 1124, Section 47.0 in the January 1,2011 Delaware Register of Regulations and the comment response document provided by the Division ofAir Quality (DAQ), there were several comments thatwere previously made that require additional clarification. GAA respectfully requests that DNREC consider the comments listed below as it moves forward with its rulemaking as the changes will provide for a more understandable set of requirements that are easierto implement in a context of being technically accurate as well as cost effective. The suggested changes are shown with insertions italicized and deletions with a stFikethF911gh.

Section 47.1
In the DAQ's response to the GAA's June 2, 2010 comment letter, the DAQ rejected the GAA's request to revise the current applicability threshold from 15 Ibs/day to 3 tons/year on a 12-month rolling basis. The DAQ stated that the current threshold has existed since 1994, and changing it to an annual limit would allowfor greater daily emissions. However. thecurrent 'limit" in Section 47.1 is not an emissions limit. it is an applicability threshold. It does notcontrol emissions, it merely identifies the facilities that must meet the reqUirements of Section 47.0. Asthe EPA has determined that a 3 ton/year on a 12-month rolling basis emission threshold is equivalent to a 15 

### IbJdayemission threshold, it is unclear how a change inthe emissions threshold would constitute backsliding. A change to an emissions threshold based on annual emissions does not lead to an increase in VOC emissions, however it does make the applicability threshold calculations more straightforward and less burdensome for printers. Therefore, the GAA requests that Section 47.1.3 be revised as follows:
47.1.3 Except as specified in 47.6.1 ofthis regulation, the provisions of 47.0 of this regulation do not apply to any offset lithographic and letterpress printing facility press within a facility whose total 2actual volatile organic compound (VOG) emissions from all offset lithographic and letterpress printing operations (including emissions from cleaning solutions used on lithographic printing presses) are less than 6.8 kilagrams (kg) (1

# apauRds [Ibl) 2,721 kilogram (kg) (3 tons) peryear basedon a 12 month rolling basis VOCs per day before the application of capture systems and control devices. Additionally, all references to the 151b/day applicability threshold throughout Section 47.0 should be revised to 3 tons per 12 month rolling period. 

## [DAQ's responses to Comments onSection 47.1:
The DAQdoes notagree with GAA's commentbecausemeetingan annual2, 

## 721-kg thresholddoes notguarantee meetinga daily 6.8-kg threshold. Afacility couldbe operatedunderan average 

## 2, 721-kg/year level, but its daily operation in some days may emit VOC wellabovea 6.8-kg/day threshold. In other words, itwouldpossible that afacility, now being controlledunder the daily 6.8-kg threshold, wouldbefreed from its currentcontrols 

# if the daily thresholdwere replacedbyanannual2, 

## 721-kg threshold. This wouldbe considereda "backsliding" andnotallowedunder the CleanAirAct.
The GAA shouldunderstandthatthe currentandupcomingozonestandards are daily-emission based, notannual-emission based. Controldaily VOC emission is critical forDelaware to attain the daily-basedozonestandards. Therefore, the DAQrecommends that no change be made to theproposedSection 

## 47.1.}

Section 47.3.1
In the DAQ's response to the GAA's June 2,2010 comment letter, the Department indicated that the current rule does not allow for any exemptions from the 90% destruction efficiency for control devices, and doing so would allow for greater emissions. However, the proposed rule creates a new 95% destruction efficiency that is more stringent for presses installed after the rule becomes effective, which is consistent with the CTG. In addition, the CTG recommends exemptions for heatsetweb presses that are less than 22 inches in width or used to print books, and requires control devices only for heatset presses with the potential to emit priorto control 25 tons per year of

## vac from ink oils. The proposed changes to the rule can and should allow for an exemption from the more stringent 95% destruction efficiency requirement for such presses. These presses would still 

### be subject to the 90% destruction efficiency as required by the existing rule. Therefore, Sections 47.3.1.1 and 47.3.1.2 should be revised to read as follows:
47.3.1.1 At least 90% by weight ifthe first installation date ofthe control device is prior to [insert effective date ofthis regulation] orifis used forbookprinting orhas a maximum web width of22 inches orless, orhas the potential to emit from the dryer, priorto controls, less than 25 tpy of

### VaG (petroleum inkoil).
47.3.1.2 At least 95% by weight ifthe first installation date ofthe control device is on or after [insert the effective date ofthis regulation]. Heatsetpresses usedforbookprinting or 

### 3with 

### a maximum web width of22 inches 

### or less, andanypress with the potential to emit from the dryer, priorto controls, less than 25 tpy of 

### VaG (petroleum ink oil) shall comply With 47.3.1.1. 

## [DAQ's responses to Comments onSection 47.3.1:
The DAQ believes thatsetting upa morestringent requirement for newpresses (95% destruction efficiency) does notnecessarily leadto those exemptions, even though theyare mentionedin the CTG. As indicatedpreviously, the DAQhas the authorityto implementrequirements in Delaware thatare morestringent than CTG's recommendation, andareneeded for attainmentof the ozonestandardin Delaware. Therefore, the DAQrecommends thatno change be made to theproposedSection 

## 47.3.1.]

Section 47.3.2
In the DAQ's response to the GAA's June 2,2010 comment lelter, the Department indicated that an exemption for presses with a fountain solution reservoir of less than 1 gallon orsheetfed presses with a sheet size of 11

### x17 inches or less would lead to backsliding, as the eXisting rule does not provide such exemptions. However, the existing rule also does not have the same strict VaG content standards. As the department is proposing more stringent VaG content standards forfountain solutions, an exemption forvery small presses from these requirements is consistent with the GTG and would not lead to an overall increase in VaG emissions. As such, the change would not constitute a relaxation ofthe existing rule. Therefore, Section 47.3.2 should be revised to read asfollows:
47.3.2. No owner or operator of an offset lithographic printing press with a total fountain solution capacity of1 gallon 

### ormore 

### or

### a sheetfedpress with 

### a maximum sheetsize of11 x 17inches 

### orlargerthat lJses alGeAel in the felJntain sellJtien shall operate the printing press unless the owner or operator meets one ofthe requirements listed under47.3.2.1, 47.3.2.2, or 47.3.2.3, ans47.d.2.4 ofthis regulation. 

## [DAQ's responses to Comments on Section 47.3.2: Again, setting upmorestringent requirements does notnecessarily justifYthose exemptions. The DAQstill believes that, 

# if the requestedexemptions were adopted, itwouldleadto a backslidingresult that is 

## notallowedunder the CAA. Therefore, DAQrecommends thatno change be made to theproposedSection 

## 47.3.2.]

Sections 47.3.2.1 through 47.3.2.4



### 4In the DAQ's response to the GAA's June 2, 2010 comment letter, the Department indicated that changing the vae content limits forfountain solutions from a "by volume" to a "by weight" limit would constitute backsliding. However, the existing rule sets limits on an "by volume" basis specifically for alcohol, not the more generic vac. Since alcohol is 100 percent vae, calculations of alcohol addition to fountain solution by volume are relatively easy, as fountain solutions using alcohol are mixed by adding a specific volume of alcohol to a specific volume offountain solution concentration that has been added to a gallon ofwater. However, to determine vae by volume, more complicated calculations are required, as the volume ofVaG in each fountain solution concentrate and additive must be determined through calculation since concentrates and nonalcohol additives are not composed of 100 percent vae. Most material data sheets from manufacturers provide vac content on a pound/gallon orweight percent basis which can then be used to calculate vae content on a weight percent basis ofthe as-applied fountain solution.
In addition, while the existing rule sets limits based on alcohol by volume in 47.3.2.1 and 47.3.2.3, those limits are based on the use of alcohol in fountain solutions. In existing 47.3.2.4, the limit is based on vae content for the use of alcohol substitutes, instead of alcohol content. The vae content limit in existing 47.3.2.4 is based on vae content by weight. These provisions in the existing rule acknowledge the distinction between monitoring vae content and alcohol content. As the currently proposed rule sets all limits on a vae content basis, the rule should provide for a simple method of calculating vac content in the as applied fountain solution.
The most straightforward method of calculating vae content is on a "by weight" basis. The 2006 eTG recognized this fact, and recommended that vae content limits be set on a "by weight" basis. As the new rule is changing the limits from the content of alcohol to the content ofvae, a similar change of "byvolume" to "by weight" is technically correct and does not lead to a relaxation ofthe existing rule. As a result, all references to vae content "by volume" should be changed to "by weight". Therefore, Sections 47.3.2.1 through 47.3.2.4 should be revised to read as follows:
47.3.2.1.1 When the fountain solution contains alcohol, the fountain solution on-press, (as applied) vae content shall be maintained
47.3.2.1.1.1 At 1.6% or less (ey \,ell,jffie) (by weight), or 47.3.2.1.1.2At 3.0% or less (ey '/ell,jffie) (by weight) and the temperature of the fountain solution shall be maintained at or below 15.5 degrees Celsius (C) (60 degrees Fahrenheit [Fl.
47.3.2.1.2 When the fountain solution contains no alcohol, the fountain solution on-press (as-applied) vac content shall be maintained at 3.0% or less (ey \,ell,jffie) (by weight).
47.3.2.2 For any non-heatset web offset lithographic printing press: 47.2.2.1 There shall be no alcohol in the fountain solution, and 47.2.2.2 The fountain solution on-press (as-applied) vae content shall be maintained at 3.0% or less (ey '/ell,jffie) (by weight).
47.3.2.3 For any sheet-fed offset lithographic printing press the fountain solution on-press (as-applied) vae content shall be maintained.
47.3.2.3.1 At 5% or less (ey \,ell,jffie) (by weight), or 47.3.2.3.2 At 8.5% or less (ey \'ell,jffie) (by weight) and the temperature ofthe fountain solution shall be maintained at or below 15.65 °e (60°F).

.........

## _-- 

# ----- --_

.....

# __..

# _ .....-

# ... ---. 

### 5

## [DAQ's responses to Comments on Sections 47.3.2.1 

## through 47.3.2.4:
As mentioned in the DAQ'sprevious responses, most VOCs have a densityor specificweightsmaller than water, which means changingto a by-weight % 

## limit mayrepresent a greater % 

## limit than the existingby-volume limit. Apparently, such a changewill be considered "backsliding"andnotallowedunder the CAA.
It is 

## true thatmostmaterialsafetydata sheets (MSDSs)from manufacturersprovide VOC contentonapound/gallon orweightpercentbasis which can then be usedto calculate VOC contentona weightpercentbasis of the as-applied fountain solution. The MSDSs, however, alsoprovide densityorspecific weightdatafor the VOCs being used. In addition, Appendix C 

## of this regulationprovides a general VOC density thatcan be used for such conversion. It is 

## a simple calculation to convert VOC-content by weightto VOC contentby volume usingthe densitydata.
The GAA 's 

## commentabove regardingSection 47.3.2.4 is 

## no longer validsince this section has beendeleted in theproposedregulation. Therefore, theDAQrecommends that no change be made to theproposedSections 47.3.2.1 through 47.3.2.4.]

Section 47.3.3
As stated in the June 2, 2010 comment letter, the 30 percent by weight limits in the eXisting rule were based on a draft GTG issued by EPA in 1993. The 30 percent by weight limit was based on "cleaning solutions" defined to including only blanket and rollerwashes. When the 2006 GTG was finalized, EPA dramatically expanded the scope ofthe solvents covered and set a limit of70 percent by weight limitfor all cleaning solutions used to clean ink, dried ink, and debris from in and around a printing press. As such, a 70percent by weight limit on cleaning solutions result in additional VaG emissions reductions, since many more cleaning solutions would now be covered by the emission limits. Additionally, the Department should include an exemption from the limits for 110 gallons of cleaning solution used over a 12-month rolling period. As mentioned in the June 2, 2010 GAA comment letter, the EPA recognized the limitations of imposing these limitsfor all possible cleaning activities. EPA stated in the 2006 GTG "a smallnumberofcleaning tasks cannot be carriedout with low 

### VaG composite vaporpressure cleaning materials orreduced 

### VaG content cleaning materials. " Therefore, Section 47.3.3 should be revised to read as follows:
47.3.3 No owner or operator of an offset lithographic printing press or a letterpress printing press shall operate the printing press unless the owner oroperator reduces VaG emissions from cleaning solutions by meeting requirements in 47.3.3.1, or 47.3.3.2, and 47.3.3.3 and47.3.3.4 ofthis regulation:
47.3.3.1 Using llSiR§-a cleaning solution with a 30% SF less 70% orless by weight (as used) VaG content. 

### 6

### 47.3.3.3.4 The use ofcleaning solutions notmeetingsection 47.3.3.1 

### or47.3.3.2 

### is permittedprovided that the quantftyused does not exceed 110 gallons overany twelve consecutive months. 

## [DAQ's responses to Comments onSection 47.3.3:
In itsprevious response, theDAQexplainedthat adding the I10-gallon exemption to theproposedregulation wouldleadextra 

# vacemissionsfrom the exempted 110 gallons at allfacilities beinggovernedby this rule, which wouldbe consideredas

"backsliding" andnotallowed under the CAA. Similarly, changingthe 30% limit to a 70% limit in Section 

## 47.3.3.1 wouldbealso consideredas "backsliding" andnotallowedunder the CAA. The GAA needs also to understandthat theDAQcannot implementanynew regulation that wouldhave less stringentrequirements, thus increasing emissions andworsening the air quality in

## Delaware. Therefore, theDAQrecommends that no change bemade to theproposedSection 

## 47.3.3.]

Section 47.4
In the DAQ's response to the GAA's request in the June 2, 2010 comment letterto remove references toAppendix D in 47.4.1 and 47.4.2, the Department indicated that TIE and BE as required in Appendix D are necessary to demonstrate control device capture efficiency. While the DAQ may not agree with the recommendations contained in the EPA's CTG, the requirement for TrE and BE is directly contradictory to Section 47.6.3.3 ofthe existing regulation. In section 47.6.3.3, the Department states "A 100% emissions capture efficiency for the dryer shall be demonstrated using an air flow direction measuring device."
It is important to understand that a press dryer is a capture device which directly ducts exhaust to a control device, which can either be integrated into the dryer or a separate stand alone unit. a dryer is a capture device and 47.3.1 ofthis regulation requires control devices only for heatset presses, which means they have a press dryer, and capture testing for dryers is the only required capture testing. Since 47.6.3.3 outlines the requirements for capture testing of dryers, the inclusion ofAppendix D is not necessary. While the DAQ has indicated removing references to Appendix D will constitute backsliding, Appendix D is not necessary as Section 47.6.3.3 clearly states what is sufficientto demonstrate capture efficiency on press dryers and is an equivalent method for testing capture efficiency. The removal of references to TIE and BE testing in Appendix D will not constitute backsliding. Additionally, the DAQ has indicated that in its experience, TIE and BE are cost effective means to demonstrate capture efficiency. The GAA respectfully disagrees. The experience by the lithographic printing segment has shown that such tests cost at least $20,000. Such testing is very expensive. especially as it provides no additional necessary information. Past testing has confirmed that 100 percent capture ofthe

## vac in the ink. which is known as ink oil occurs in the press dryer. In addition. since the press dryers run at a very high negative pressure relative to



### 7pressroom combined with using low volatile alcohol substitutes and automatic blanket wash solvents, EPA allows for a carry over efficiency of

### 70 and 

### 40 percent, respectively. Lithographic printing is a process in which an emulsion of ink and fountain solution is applied to the substrate. The ink oils contained in heatset ink are of such low volatility that they are only emitted as they are evaporated in the drier, so virtually 

### 100 percent ofVOC emissions from heatset ink are captured in the dryer as long as airflow in to the dryer is negative. As alcohol substitutes have a low volatility, 

### 70 percent of emissions from alcohol substitutes are captured in the dryer when the ink/fountain solution is dried. In addition, since press dryer airflow is so negative relative to the pressroom air, lowvolatile blanket washes defined as those with less than 

### 10 mm Hg at 

### 68°F ensures that 

### 40 percent of automatic blanket wash is carried over and subsequently captured by the dryer.
It is for these reasons that EPAconcluded that total enclosure capture testing is not necessary for heatset web offset lithographic printing press dryers that are required to be controlled. EPA's position on this is contained in the 

### 2006 CTG and the Technical Support Document for Tille V Permitting of Printing Operations. The specific statements were contained in ourJune 

### 2, 2010 comment letter.
In addition, the GAA apologizes for any confusion arising from a typographical error contained in the June 

### 2, 2010 comment letter. GAA suggested replacing the monitoring requirements in Appendix D with Section 

### 47.6.5.1, while the correct reference is 

### 47.6.3. Therefore, Sections 

### 47.4.1 and 

### 47.4.1.2 should be revised to read as follows:


### 47.4.1 The capture system and control device are operated at all times 

### tRat when the printing press is in operation, and the aWRer or ol3eratar E1eFRaRstrates compliance with 

### 47.0 ofthis regulation is demonstrated through the applicable coating analysis aREl 6a13lUfe sy51eFR and control device efficiency test methods specified in 

### Appendix B, AppeRrlixQ, and 

### Appendix E ofthis regulation and ;n accordance with the capture efficiency test methodidentified;n 

### 47.6.3.3. anG 

### in aGGereanoo with the GBptlJl'fJ 

### effiGiORG}'

### te81 methofis 8peGifiefl

### ifl AppendiKDof#1is 

### refjtJlatioR.


### 47.4.2 The control device is equipped with the applicable monitoring equipment specified in 

### 47.6.3 

### 2J) ofAppeRdix Q ofthis regulation, and the monitoring eqUipment is installed, calibrated, operated, and maintained according to the vendor's specifications at all times the control device is in use. 

## [DAQ's responses to Comments on Section 47.4:
In itsprevious responses, theDAQexplained in detailwhyAppendixD couldnotbe removed from theproposedSection 47.

## O. Those responses are still valid for addressingthe current GAA 's comments.
In addition, theDAQdoes notagree that the requirements of AppendixD in 47.4.

## I and47.4.2are "directly contradictory to Section 47.6.3.3 of the existing regulation. " Specifically, Section 47.4 sets up operational requirements for control devices, whileSection 47.6

## sets up recordkeepingandreporting requirements.

8

## Therefore, DAQ recommends that no change be made to theproposedSection 47.4.]

Section 

### 47.5.1
In light ofthe comments on Section 

### 47.4, proposed Section 

### 47.5.1 should also be modified by deleting the reference to Appendix D. Therefore, Section 

### 47.5.1 of

### 7 DE Administrative Code 

### 1124would read as follows:


### 47.5.1 The VOC content ofeach ink, the alcohol content of each fountain solution, and the efficiency of each 

### G8pwre S}'SIem amicontrol

device shall be determined by the applicable test methods and procedures specified in Appendix A 

### B and through Appendix 0 C, 

### andAppendix E ofthis regulation to establish the records required under

### 47.6 ofthis regulation. 

## [DAQ's responses to Comments on Section 47.5.1:


## Please see DAQ 's 

## responses to Comments on 47.4 

## above. Therefore, DAQrecommends that no change be made to theproposedSection 47.5.1.]

Section 

### 47.5.2
In the DAQ's response to the GAA'sJune 

### 2, 2010 comment letter, the Department indicated that specifying "typical" instead of "maximum" operating conditions and flow rates would constitute backsliding, and that maximum operating conditions are achievable and can be determined using operation and production records. The GAA agrees that testing should be completed at conditions that are realistic within the realm of recent production, however it is not always possible to run equipment at levels that match previous maximums using actual printing jobs.
Print schedUling requires thatjobs are run within a short timeframe, and production schedules cannot be anticipated weeks in advance. In many instances, production schedules will change on a daily and sometimes an hourly basis. If maximum operating conditions are reqUired and there are no jobs that correspond to the Department's definition of maximum production, regulated facilities will be forced to create artificialjobs, wasting significant time, materials, and money. As mentioned in the June 

### 2, 2010 comment letter, the EPA has recognized this dilemma in USEPA's Technical Support Document (TSD) forTitle V Permitting of Printing Operations on page 

### 68, Section 

### 5.7, and described typical operating conditions for printing facilities as follows:


### "Such operating conditions shouldstrive to minimize downtime while running as manypresses aspracticable, when multiple presses are being servedby

### a common 

### controldevice. The proposed operating scenario shouldalso be reflective of

### a typicalnormalproduction schedule. As necessary, proposed testing conditions shouldrely on historicalproduction records forestablishing average coverage rates, press speeds, orinkandotherinputmaterial consumption rates, run times, andaverage time of

### intermittent events such aspress cleaning, web breaks orsimilarshutdown situations. " 

### 9The GAA requests that the DAQ revise section 47.5.2 to state that testing must by completed at typical operating conditions. To specify what constitutes typical operating conditions, the DAQ may wish to define "Typical operating conditions" as referenced in the TSD above. Therefore, Section 47.5.2 should be revised to read as follows:
47.5.2 To demonstrate compliance with the emission control requirements of47.0 ofthis regulation, the facility affected by 47.0 ofthis regulation shall be run at ffia*iFfHlffi 

### typical operating conditions and flow rates during any emission testing. 

## [DAQ's responses to Comments on Section 47.5.2:
As theDAQpointedout in itsprevious responses to the same comment, the maximum operatingcondition of apress is 

## notartificialandunachievable. A facility can determine this condition with its operation records orproductorders in a reasonable timeperiod, with consultation andprioragreement from DAQ 's EngineeringandCompliance Branch for necessaryhelp andguidance. In addition, this maximum operatingcondition can be specifiedin afacility'spermit.
In addition, theDAQbelieves that, due to the dailynature of the ozoneair quality problem in Delaware, it is 

## critical thatall VOC sources in Delaware, including those in offset lithographic andletterpressprinting facilities, needto be controlled atmaximum operatingconditions. Clearly, a requirementof controlattypical operatingcondition cannotguarantee thatafacilitywillnot operate ata level higher than its typical condition. Therefore, changingrequirement from a "maximum operatingcondition" to a "typicaloperatingcondition" is considereda backslidingaction andnotallowedunder the CleanAirAct. More importantly, such a changewillhinderDelaware's overallefforts to attain the ozone standard. Therefore, DAQ recommends that no change bemade to theproposedSection 47.5.2.]

Section 47.5.4
In the DAQ's response to the GAA's June 2,2010 comment letter, the Department indicated that under Section 47.5.4, only 47.5.4.3 is optional. However, this is not accurate. One example is fountain solutions containing alcohol substitutes Only Section 47.5.4.4 is required to be met. For facilities that choose to test with a hydrometer, only Section 47.5.4.3 is required. For facilities that choose to test perAppendix L, Sections 47.5.4.1 and 47.5.4.2 are required. Since facilities are not required to complete all four options under Section 47.5.4.1, and the only two sections that must be completed together are Sections 47.5.4.1 and 47.5.4.2, the DAQ should combine Sections 47.5.4.1 and 47.5.4.2 and revise Section 47.5.4. Additionally, as

## voe content calculation is equally effective forfountain solutions containing alcohol as it is forfountain solutions containing alcohol substitutes, the currently proposed Section 47.5.4.4 should be revised to include fountain solutions containing alcohol. 

### 10Therefore Section 47.5.4 should be revised to read as follows:

47.5.4 To determine compliance with 47.3.2 ofthis regulation, the owner or operator of an offset lithographic printing facility shall perform one of the following procedures:
47.5.4.1 A sample shall be taken ofthe fountain solution (as used) from the fountain tray or reservoir that contains a fresh batch offountain solution (after mixing), for each unit or centralized reservoir, to determine the alcohol content ofthe fountain solution in accordance with 47.3.2.1 through 47.3.2.4 ofthis regUlation, before the fountain solution is used.47.8.4.2 A direct measurement ofthe alcohol content ofthe fountain solution sample or samples shall be performed in accordance with the method specified in Appendix L ofthis regulation.
47.8.4.d 47.5.4.2Alternatively, a sample ofthe fountain solution (as used) may be taken from the fountain tray or reservoir offountain solution during use and measured with a hydrometer or refractometer that has been standardized with tests performed in accordancewith 47.5.4.1 aRE! 47.8.4.2 ofthis regulation. The unit shall be considered in compliance with 47.3.2.1 through 47.3.2.4 ofthis regUlation ifthe refractometer or hydrometer measurement is less than or equal to the measurement obtained by the method specified in Appendix L ofthis regUlation plus 10%.
47.8.4.447.5.4.3 The vae content of a fountain solution containing alcohol, alcohol SUbstitutes, or non-alcohol additives shall be established with proper recordkeeping and the manufacturer's technical information of the vae content ofthe concentrated alcohol substitute and included in facility records. Records shall include the amount of concentrated substitute added per quantity offountain water; the date and time of preparation ifthe fountain solution is mixed as a batch; and the calculated vae ofthe final solution to fulfill the requirements listed in 47.3.2 of this regulation. Additionally, the DAQ acknowledged that the method used in Appendix L leads to incorrect results, as carbon from non-volatile organics will also be included in test results. The DAQ indicated that to correct this error, manufacturer data on non-Vae organics can be used to subtractthe corresponding non-Vae portion. As the DAQ acknowledges thatthis method of determining vae content is flawed, and recommends using manufacturer information to correct it, the use ofAppendix L should be discontinued in favor of utilizing manufacturer information to determine vae content. Additionally, it is unclear in Section 47.5.4 how often the testing per Appendix L as outlined in Section 47.5.4.2 is required. As Section 47.6.7 indicates that daily records pertaining to 47.5.4 are required, it appears that such testing may 

### be required on a daily basis. This is not necessary to ensure that facilities are in compliance with the vae content requirements of Section 47.3.2 primarily because once a printing operation is able to obtain the proper mix ratio for concentrate and additives, it is not altered. Altering the mix ratio will and introduce significant changes to the processjeopardizing print quality to the point that images will not be transferred to the substrate. Furthermore, it is unclear as to why such testing is reqUired. Section 47.5.6.2 allows forthe manufacturer information to determine vae content and vae partial pressure, with AppendiX L as an alternative option. Since calculating vae content perAppendix L relies on manufacturer 

### 11information to correct results, and

## vae content of cleaning solutions can be calculated from manufacturer's data, there is no need for inclusion of Appendix L, especially as the only method for determining VaG content in Section 47.5.4.2. Appendix L should either be presented as an option, as recommended in the comment above and as allowed in Section 47.5.6.2, or completely removed from Sections 47.5.4.2,47.5.4.3, and 47.5.6.2. 

## [DAQ's responses to Comments on Section 47.5.4:
The DAQwouldagree that combiningSections 47.5.4.1 

## and47.5.4.2

## might leadto a betterpresentation of the options. However, such a combination seems not necessary, inparticular

# if considering itwouldtake excessive time andefforts in rule-makingprocess. Regardingthe testingmethodin AppendixL, theDAQhas explainedin itsprevious responses thatthe currentmethodmayleadto elevatedresults, andsuch results can be easily corrected. When the EPA makes an appropriate testingmethodbecome available in the future, theDAQwill consider revisingSection 47.5.4 

## orAppendixL accordingly. The GAA willbe iriformedandwelcome topresentcomments atthat time. Regardingthe GAA 's 

## requestof adding "alcohol" in Section 47.5.4.4, 

## theDAQ believes thatthe request is 

## notappropriate sinceSection 47.5.4.4 is

## specifically for fountain solutions that do NOTcontain alcohol.

Therefore, DAQrecommends thatno change be made to theproposedSection 47.5.4.]

Section 47.6.1 and 47.6.2 Section 47.6.1 is redundant and unclear. The DAQ has set requirements for facilities that remain below the applicability threshold for this rule that include both certification and recordkeeping. However, the connection between the records kept and the information submitted in the certification is not clear. Sections 47.6.1.1 through 47.6.1.1.4 are clear in that they require a facility to submit certification to the Department thattheir emissions are below the threshold identified in Section 47.1. Section 47.6.1.2.2 requires annual

## vae emissions calculation records to be kept for five years. However, the information required in both Sections 47.6.1.1.5 and 47.6.1.2.1 serves no clear purpose. The GAA agrees with the DAQ's response to GAA's comment regarding Section 47.6.1.1.5 in that ink volumes are important to determining a facility's 

## vae emissions. However, GAAdisagrees with requirements of Section 47.6.1.1.5 as currently written. There is no instrument available to "measure or calculate the volume of ink applied and the amount that can potentially 

### be applied" and it is unclear as to why the Department requires this specific information, as Section 47.6.1.1.4 requires calculations of

## vae emissions, which would include ink usage to be SUbmitted. Therefore, Section 47.6.1.1.5 provides the DAQ with no additional relevant information that is necessary to reduce the state's

## vae emissions. Similarly, the information required in Section 47.6.1.2.1, including the name and identification number of each ink applied on each press each 

### 12year serves no clear additional purpose in determining emissions, as vac calculations are already required. Lastly, there is no corresponding regulatory requirement that this recordkeeping provision needs to be performed to demonstrate compliance. It is unnecessary and a significant administrative burden as some printing operations can use hundreds of inks on a single press per year. The GAA requests that Sections 47.6.1.1.5 and 47.6.1.2.1 be removed from the regulation. In addition, as the DAQ stated in response to the GAA's June 2, 2010 comment letter regarding Section 47.6.1.2.2 "we agree to delete itsince there is no corresponding requirement in the proposed regulation regarding the weight of 

### VaG pervolume ofcoating solids". Section 47.6.2.2.2 which reqUires the same records forfacilities exceeding the threshold, should also be deleted.
Material Use Thresholds for Applicability Determination Calculation ofvac emissions is a time consuming and complicated task and many small printing operations do not have the personnel time or expertise to complete such calcUlations. Requiring calculations imposes an unacceptable administrative and recordkeeping burden that is not necessary or appropriate considering the size and nature ofthe businesses that are involved in printing. As an alternative, facilities should have the option to determine applicability based on material use thresholds. The material use factors being proposed for inclusion have been approved by USEPA (EPA Potential to Emit (PTE) Guidance for Specific Sources) (http://www.epa.gov/ttncaaa1/t3/memoranda/lowmarch.pdf) and the accompanying Technical Support Document for Potential to Emit Guidance Memo. Documentation of Emission Calculations. (http://www.epa.gov/ttncaaa1tt3/memoranda/tekmarch.pdf) and are very conservative.
The material use data contained in EPA's Potential to Emit (PTE) Guidance for Specific Sources can be deceiving as it is based on 50% ofthe corresponding major source threshold. The purpose ofthe gUidance was to set material use thresholds at 50% ofthe major source threshold so states that choose to use the material use approach would have confidence that any source below these thresholds would never be major. Forthe purposes of RACT applicability, there is no need to have the same level of confidence as the actual material use amounts themselves are also very conservative as the ones used for printing assume 7 pounds per gallon vac content and that all ofthe material is emitted. For example, fountain solution is sold as a concentrate and it can have up to 40-50% vac. The material use thresholds assume that the gallon offountain solution is 100%vac and has a vac content of 7 pounds per gallon. Thus, the USEPA's 1,425 gallon threshold for sheet-fed offset lithographic press solvents and fountain solutions actually represents 5 tpy vac, not 10 tpy vac. Therefore 2,850 gallons actually equates to 10 tpy vac emissions, and based on 5 tpy equaling the use of 1,425 gallons, 855 gallons is actually equal to 3 tpyVac.
Additional information on the assumptions that were used to derive the material use data in EPA's Potential to Emit (PTE) Guidance for Specific Sources can be found in the Technical Support Document, which is a separate document from the guidance memo. The PTE Technical Support Document on page 36 contains the statement: "Example calculation based upon footnotes 1, 2 and 3: 1425 gallons of "cleaning solvent and fountain solution additive" times the assumed 7.0 Ibs/gallon density equates to 10,000 pounds (5tons) vac, or 50% ofthe major source threshold forvac in extreme ozone nonattainment areas. Similarly, 1425 gallons of "solvent based inks, cleaning solvent and adhesives' for screening printing X 7 Ib/gallon equates to 10,000 pounds."
Footnotes 1 and 2 to Table 3: Guidance for Printing, Publishing and Packing aperations on page 18 ofthe PTE guidance further explain these calculations and demonstrate that actual emissions for material use in the chart are half ofthe emissions cap. 

### 13From the PTE Guidance document, page 18: NOTES ON TABLE 

### 3: 1. These gUidelines represent a simplified screening approach. This means that these cutoffs represent conservative calculations that would ensure that printers accepting these screening cutoffs as limitswould be considered minor sources if records are kept of material usage. 2. A more sophisticated system of prohibitory rule or general permit limit is possible for sources exceeding these levels, but forwhich emissions remain well below the major source threshold. For such sources, who are willing to keep records of not only material usage but also the content ofthose materials, prohibitory rules mayestablish a 50 percent emissions cap. The technical support document includes equationsto use in establishing that sources would remain below the 50 percent limitation. Note that emission calculations underthis approach would use the actual density of each material used, ratherthan the "default" densities assumed in the technical support document. This more detailed approach must be used where any ofthe screening levels are exceeded, or there is a combination ofprinting technologies (e.g., lithographic and f1exographic orwater-based and solvent-based flexographic) present in the same facility.
To provide an extra level ofconservation, GM requests that a threshold of768 gallons of fountain and cleaning solution requested in the material use exemption 

### be used as this is based on a VaG content of 8.5 pounds per gallon, which is a common density for alcohol substitutes. The 768 gallons is more stringent than the 3 ton peryear threshold. The same logic applies to the 5,400 pounds of ink, cleaning solvent and fountain solution additives for heatset web presses. These material use thresholds should be included to allow an alternative option for facilities seeking to determine ifthe requirements of47.0 are applicable to their operations. Therefore, Section 47.6.1.1 should 

### be revised to read as follows:
47.6.1.1 Initial Certification. Within six months after [insert the effective date ofthis revision of47.0] or upon initial startup of a new printing press, the owner or operator shall certify to the Departmentthat the facility emits less than the threshold limit according to 47.1 ofthis regulation. Such certification shall include the following information:

47.6.1.1.1 The name and location ofthe facility.
47.6.1.1.2 The address and telephone number ofthe person responsible for the facility.
47.6.1.1.3 A declaration that the facility is not subject to the requirements of47.0 ofthis regulation because of the criteria listed in 47.1 of this regulation.
47.6.1.1.4 The**GalG~lali9Rs** records demonstrating that total actual 

## vac emissions from all offset lithographic and letterpress printing presses atthe facility are and will be less than 

### €Ul k!} (15 

### Ie) Iler say 2, 721 kg (3 tons) per 12-month rollingperiodbefore the application of capture systems and control devices. Such records mayinclude the following:
47.6.1.1.4.1 Material use records thatshow the facilitymeets the following material use thresholds: Type of Offset Lithographic Printing 12-Month Rolling Material Use 

## i
14

### aDeration Threshold Sheet-fed 768 gallons ofcleaning solvent and fountain solution additives Non-heatset Web 768 gallons ofcleaning solvent and fountain solution additives Heatset Web 5400pounds ofink, cleaning solvent, and fountain solution additives
47.6.1.1.4.2 The following monthlyrecords andcalculations demonstrating actual VaG emissions did not equal orexceed three tons ofvolatile organic compoundsperrolling twelve-month period: (i) The total amount, in pounds orgallons, ofeach ink, fountain solution, and cleaning solvent used; (ii) The volatile organic compounds content ofeach ink, fountain solution, and cleaning used:
Volatile organic compounds calculations shallbe basedon the following formula using applicable retention factors identffiedin section 47.6.7 

### ofthis rule.
Volatile organic compounds emissions 

### = amount ofink (pounds) x volatile organic compounds content (weightpercent) x 

### [1 -(retention factor/100)] 

### + amountoffountain solution (gallons) x volatile organic compounds content (poundspergallon) 

### + amount ofcleaning solvent (gallons) x volatile organic compounds content (pounds pergallon) x

### [1 -(retention factor/100)]. 

### 47.6.1.1.5 /\ sessRpli9R 9f IAe iRslFllmeRI 9r melA9s ey wAisA IAe 9WRer sr speral9r assllralely measllres sr salslliales IAe v9111me 9f iRk applies aRS tAe am911RIIAat saR p9leRtiaily ee aJ'jJ'jlies easA year SR easA J')FiRliR§ J'jress.

For the reasons described above regarding Section 47.6.1.1.5 and 47.6.1.2.1, Sections 47.6.2.1.4 and 47.6.2.2.1 should also be deleted. 

## [DAQ's responses to Comments on Sections 47.6.1 

## and47.6.2:
The DAQdoes notagree thatSection 47.6.1 

## is redundantandunclear. Specifically, theDAQbelieves thatSections 47.6.1.1.5 

## and47.6.1.2.1 

## willprovidenecessary information/orthe agency to understandandevaluate a/acility's operation. As the GAApointedout that "someprintingoperations can use hundreds

# 0/ inks on a singlepressperyear." No matterwhether this statement is 

## true (which means a press uses a different ink on a differentday throughouttheyear), theDAQ needs to know the daily usage

# 0/ each inkvia requirements o/Sections 47.6.1.1.5 

## and 47.6.1.2.1.


## The DAQ agree thatcalculation o/VOCemissions is 

## time consumingandsometimes complicated. It is 

## also true that manysmallprintingoperations do nothave the
15

## appropriatepersonnelor expertise to complete such calculations. However, the DAQ believes that most, 

## if notall, smallprintingoperations will fall into Section 47.6.1 below thresholdlimit. An initial certification andthen-after annual recordkeeping for those small facilities are necessary, andhave beenproved, in the past 16

## years since Section 47.0was started in 1994, 

## appropriateandnota significantadministrative burden for the small facilities Regardingthe GAA 's 

## comments on "Material Use ThresholdsforApplicability Determination, " theDAQhasprovideddetaileddiscussion in itsprevious responses to the GAA'sJune 

## 2, 2010 commentletter, as wellas in its responses to Comments onSection 47.1 

## above in this document. Therefore, DAQrecommends thatno change bemade to theproposedSections 47.6.1 and47.6.2.]

Section 47.6.4
As the DAQ referenced in their response to the June 2,2010 comments from GAA, Sections 47.6.4.1 and 47.6.4.2 specify that alcohol concentration must be monitored at least once per 8­ hourshift of once per batch, whichever is longer. Therefore, the word "frequently" is not required in Section 47.6.4 and could create confusion. GAA requests that it be removed. Therefore, Section 47.6.4 should be revised to read as follows:
47.6.4 Requirements for Monitoring Fountain Solution VOC Concentration. On and after [insertthe effective date ofthis revision of47.0], the alcohol concentration in the fountain solution shaH be monitored to provide data that can be correlated to the amount of material used when the fountain solution complies with the limits listed in 47.3.2.1 through 47.3.2.4 ofthis regulation. One ofthe following methods shall be used to freElloleRlly measure the concentration ofalcohol in the fountain solution: 

## [DAQ's responses to Comments on Section 47.6.4:
TheDAQ believes that the word "frequently" in Section 47.6.4

## willnotalter the requirementnature of Section 47.6.4. 

## Therefore, DAQrecommends that no change be made to theproposedSection 47.6.4.]

Section 47.6.6
In response to the GAA's June 2,2010 comment letter, the DAQ indicated thatflow meters for water and cleaning solvent are reqUired to determine emissionsfrom automaticwashing systems. However, this statement is incorrect, as emissions are not based on the mix ratio orflow ofwater and cleaning solvent, and are instead a factor ofthe amount of cleaning solvent used and the


### 16

### vaG content ofthat solvent. Section 47.6.6 is not designed to determine VaG emissions, it is instead designed to determine compliance with vae content limits indicated in Section 47.3.3. Specifically, Section 47.6.6 is designed to assurance that automatic mixing units are meeting the VaG content limits in Section 47.3.3, as vapor pressure of 10 mmHg is an absolute limit, and is not dependant on mixing.
In orderto determine the vae content ofthe continuous cleaning solution, the correct application would be to determine that the calibration ofthe automatic mixing unit is correct. Automatic mixing units are based on volume ofwater and concentrate added, not flow. Automatic mixing units do not have meters to measure the flow ofthese two ingredients, as they are not monitored. The mix ratio is set for the unit that is based on discrete volumes of solvent and water, and the unit applies those components at a fixed flow rate. The requirement to install and monitor flow rates of cleaning solvent and water is not necessary, as a simple check of the accuracy ofthe calibration ofthe automatic mixing unit will ensure that the proper mix ratio is being utilized. As this change is merely a correction to a requirement that is currently inaccurate, it does not constitute backsliding by increasing VaG emissions. Instead, it continues to allow Section 47.6.6 to ensure proper mix ratios as required in Section 47.3.3. Therefore, Section 47.6.6 should be revised to read as follows:
47.6.6 Requirements for Monitoring Gleaning Solution. an and atter [insert the effective date of this revision of47.0], for any offset lithographic printing press orany letterpress printing press with continuous cleaning equipment, flew meleFS shall Be uses Ie meRiter lhe

.....aler aRs sleaRiR!j selulieR flew rales. The flew melers shall be 

### calibrated so that the vae content ofthe mixed solution is accurately measured to fulfill the requirements of47.3.3 ofthis regulation. 

## [DAQ's responses to Comments on Section 47.6.6:
The intent of theproposedSection 47.6.6 is 

## to covera general case where the continuous cleaningprocess obtains cleaningsolution thatis 

## continuouslymixed from continuous inputs of waterandcleaningsolvent, andthe flow rates of such continuous inputs mustbe monitored.
The GAA 's 

## above comment is 

## validonlywhen the cleaningprocess obtains cleaning solution from a large reservoir in whichpre-determinedvolumes of waterand cleaningsolventaremixedthoroughly before the cleaningprocessstarts. When the pre-mixedcleaningsolution in the reservoir is 

## usedup, the cleaningprocess has to be stoppeduntilanother batch of cleaningsolution in the reservoir is 

## ready. The DAQ believes that this specialcase can be handledin the facility'spermitto comply with Section 47.3.3. Therefore, DAQrecommends thatno change be made to theproposedSection 47.6.6.]

Section 47.6.7



### 17Section 47.6.7 contains requirements for monitoring other key parameters. While the DAQ responded that these daily records are crucial to control daily

## vae emissions, the GAA respectfully disagrees. These recordkeeping requirements are currently confusing and contradictory.
For example, what benefit is gained from a daily record ofthe type ofcontrol device operating as specified in Section 47.6.7.1? Such information would not change on a daily basis. Additionally, Section 47.6.7.1 requires recording the operating parameters specified in Section 47.5.3 on a daily basis. This is not possible, as there are no operating parameters specified in Section 47.5.3. Section 47.5.3 requires emissions testing to demonstrate compliance. Similarly, 47.6.7.2 requires recording the "equipment standard" selected to comply with the fountain solution and cleaning solution

## vae content limits. It is unclearwhat is meant by "equipment standard". If Section 47.6.7.2 is referencing the content limit that a facility has chosen to meet, recording this information is similarly unnecessary on a daily basis. Such drastic changes in fountain solution mix ratios or recipes do not occur on a daily basis, as changes to fountain solutions result in serious changes in print quality. Section 47.6.7.4 requires daily records offountain solution temperature, while Section 47.6.5.2 requires continuous recording. Section 47.6.7.6 requires recordkeeping of a parameterthat is not available for monitoring, as outlined in the comments on Section 47.6.6. GAA recommends that the DAQ review this section again, as it is unclear as to its purpose. Ideally, this entire section should be deleted, as it does not strengthen the regulation and conflicts with the requirements in the other sections ofthe regulations which specify the appropriate monitoring requirements. At a minimum, the section should be revised to state proper recordkeeping timeframes that are relevant to the specific requirements. Information in Sections 47.6.7.1,47.6.7.2,47.6.7.3, and 47.6.7.5 should only be required to be recorded initially and when any change is made, such as installing a new control device, or changing a fountain solution recipe. Section 47.6.7.4 is not necessary nor is Section 47.6.7.6. 

### [DAQ's responses to Comments on Section 47.6.7: (1)ForSection 

## 47.6.7.1, the citation of 

## 47.5.3was unintentionallyoverlooked andleft unchangedwhen itsprevious numerical requirements were movedto Section 

## 47.3.1. Therefore, theDAQproposedto revise Section 

## 47.6.7.1 as follows:

47.6.7.1 The type of control device operating on tile any heatset offset lithographic printing press or any heatset letterpress printing press and the operating parameters specified in 4hS.3 [47.3.1] ofthis regulation. 

## (2)ForSection 

## 47.6.7.2, the DAQagrees thatthe term "equipmentstandard" seems to be confusing, andthereforeproposes to revise itas follows:

47.6.7.2 The equipment [operating] standard selected to comply with the requirements listed in 47.3.2.1 through 47.a.2.4 47.3.2.3 and 47.3.3 ofthis regulation. 

## (3)ForSection 

## 47.6.7.4, theDAQdoes agree thatSection 

## 47.6.7.4andSection 47.6.5.2 are contradictory. 

## .if afacility meets the requirementof Section 47.6.5.2, itautomaticallymeets the requirementof Section 

## 47.6.7.4. 18

## (4)ForSection 

## 47.6.7.6,pleasesee theDAQ's responses to Comments on Section 47.6.6 

## in this document. (5)

## Regardingthe GAA's comments on the daily requirements in Section 47.6.7, 

## theDAQ believes thatsuch daily recording is 

## necessary for closely monitoringthefacility's operation to catch upanysignificantemission variation on a daily basis. Such variation is 

## essential forDelaware's overall effortsfor attaining the daily ozonestandard. Due to this essentiality, changing the daily requirements to a lessfrequent schedule will be considered "back-sliding"and prohibitedunder the CleanAirAct. To simply the recordingprocess, thefacility could use terms such as "same" or "unchanged" in daily recording 

# if the operatingstandardor conditions are notchanged.

Proposed Section
In the DAQ's response to the GAA's June 2,2010 comment letter, the DAQ stated "it would be reasonable andpractical to use otherretention factors, carry-overrate, and capture efficiencies, as mentionedin this comment, and in Comment

### 4.8 and Comment

### 4.26, when a facility calculates its emission inventory, control device efficiency, andemission fee, etc. The DAQ is confident that using those factors/rate/efficiencies would notaffecta facility's thresholddetermination. n The DAQ, however, felt that these emission and retention factors could be addressed in facility's air permit. However, the GAA requests that these retention and emission factors 

### be included in 47.0. Inclusion in the rule creates a common basis forthe use of retention and emission factors, ensuring that they are included in permits. Withoutthe inclusion ofthese factors in this rule, their use is left to the discretion ofthe permit writer, who mayor may not be familiar with the retention factors and the DAQ's approval oftheir use, as indicated in the DAQ's response. Additionally, the GAA disagrees with the DAQ that no studies have shown that vacs from ink are retained in substrates. There are in fact several studies that demonstrate vac retention in substrates. The studies were submitted to EPA during the development ofthe CTG and they were reviewed and approved by EPA. Ifthe DAQ would like to review the ink oil retention studies, they can be provided.
Forthe reasons explained above, the GAA requests the inclusion ofthe following Section 47.6.7 (so numbered upon deletion of existing Section 47.6.7, otherwise numbered 47.6.8):
47.6.7Retention Factors and Capture Efficiencies

- Forpurposes ofdetermining volatile organic compounds emissions from offsetlithographicprinting operations, the following retention factors and capture efficiencies shallbe used:


### 47.6.7.1 Aportion ofthe volatile organic compounds contained in inks andcleaning solution is retained in the printed web orin the shop towels usedforcleaning. The following retention factors shallbe used:



### 19

### 47.5.7.1.1 A20% volatile organic compounds retention factorshallbe used for heatset inks printed on absorptive substrates, meaning 80% ofthe volatile organic compounds in the ink

### is emitted during the printingprocess and is available forcapture and control byan add-on pollution control device. 

### 47.6.7.1.2 A95% volatile organic compounds retention factorshallbe used for sheet-fed andnon-heatset web inksprintedon absorptive substrates, meaning 5% ofthe volatile organic compounds in the ink

### is emitteddUring the printing process. 

### 47.6.7.1.3 A 50% volatile organic compounds retention factorshallbe used for cleaning solution 

# vac in shop towels forcleaning solutions with 

### a volatile organic compounds composite vaporpressure ofno more than 10

### mm of mercury (Hg) at20"C (68"F) 

### if the contaminatedshop towels are kept in closed containers, meaning 50% ofthe 

# vac used on the shop towels 

### is emitted during the cleaningprocess. 

### 47.6.7.2 Apar/ion ofthe volatile organic compounds containedin inks, fountain solutions, andautomatic blanket washes on heatsetpresses is capturedin Ihe press dryerforcontrol byadd-onpollulion controldevices. Capture efficiency testing forheatsetdryers 

### is notreqUiredifit demonstratedthatpressure in the dryer

### is negative relative to the surroundingpress room and the airflow

### is into the dryer. Continuous dryerairflowmonitoring

### is notrequired. The following capture efficiencies are to be used: 

### 47.6.7.2.1 A 100% volatile organic compounds carryoverefficiencyshallbe used forinks. All the volatile organic compounds in the ink that

### is not retained

### is assumedto be volatilized in the press dryer. 

### 47.6.7.2.2 A 70% volatile organic compounds carryoverefficiencyshall be used forfountain solutions containing alcohol substitutes. 

### 47.6.7.2.3A 40% volatile organic compounds carryoverefficiencyshall to be used forautomatic blanket wash solutions with 

### a 

# vac composite vaporpressure of no more than 10

### mm ofmercury (Hg) at20"C (68"F). 

## [DAQ's responses to Comments onProposedSection:
The DAQwants to 

## make itclear that in itsprevious responses, itdidnotstate that "no studies haveshown that VOCsfrom inkareretained in substrates." The exact statementis 

## that there is 

## "no convincingstudies showing that the retained VOC on substrates wouldnotemitafterprintingprocesses... This was why the DAQdidnot agree to addthe samesectionproposedbythe GAA in its comment letterof June 2, 2010. The DAQstands on the samegroundatthispoint.
When convincingevidence becomes available, the DAQwill consider revising Section 

## 47.

# aaccordingly. The GAA will be informedatthattime, andwelcome to provide the same andaddition comments.

20

## The DAQdidnot indicateatanypoint in itsprevious responses that the use of retention andemission factors wouldbe "left to the discretion of thepermitwriter, who mayormaynotbefamiliarwith the retentionfactors andtheDAQ's approval of their use." The DAQ's

## permittingstaff willworkcloselywith the regulation developmentstaff to take consistentactions on relevant issues, including use of retention andemission factorsfor its emission inventory, controldevice efficiency, andemissionfee, etc. Therefore, DAQrecommends that the GAA 's

## proposedsection benotaddedto the proposedSection 47.0.]

21

### 7 DE Admin 

### Code 1124 

### "Control ofVolatile Organic Compound Emissions"
47.0 Offset Lithographic Printing and Letterpress Printing (March 2011 Final Revision)
1112011004mm/dd12011
47.1 Applicability
47.1.1 The provisions of 47.0 of this regulation apply to any offset lithographic or letterpress printing press. fasilily, iAsllleiAg Reatset wee, ReR Reatset "'lee (AeA Ae

...**~paperh--AeA** Reatset sReet tee, aAe Aewspaper (AeA Reatset

.....ee) !asilities. Except as provided in 47.1.2 of this regulation, every owner or operator of any offset lithographic or letterpress printing press shall comply with the provisions of 47.0 of this regulation on and after [insert effective date of this revision of47.0 of this regUlation].
47.1.2Transition period for existing permitted sources. Every owner or operator of any offset lithographic printing press that is subject to a permit issued pursuant to 7 DE Admin Code 1102 or 1130 containing all applicable conditions of47.0 of this regulation, as that regulation existed on November 29, 1994, shall comply with those permit conditions for up to one year after the effective date of this revision of 47.0 of this regulation. Every owner or operator of any letterpress printing press that is subject to a permit issued pursuant to 7 DE Admin Code 1102 or 1130 shall comply with the permit's conditions for letterpress printing for up to one year after the effective date of this regulation. On and after the date one year after the effective date of this revision of 47.0 of this regulation, every such owner or operator of any offset lithographic or letterpress printing press shall comply with the provisions of47.0 of this regulation.**47.1.~2** Except as specified in 47.6.1 of this regulation, the +Ile prOVIsions of 47.0 of this regulation do not apply to any offset lithographic and letterpress printing fa6ilily press within a facilitv whose total actual volatile organic compound (VOC) emissions from all offset lithographic and letterpress printing operations (including emissions from cleaning solutions used on lithographic printing presses) are less than 6.8 kilograms (kg) (15 pounds [Ib]) VOCs per day before lIle-application of capture systems and control devices.
47.1.3 TAe pra'/isieAs af 47.0 af tRis re§lllatieA ea Aet apply te a OtRer types af priRliA§ aperatiaAs, SileR as**~elEe§rapRY,** aRe rota§raVllre, ar letterpress.
47.1.4 ElEistiA§ sellrses affestee ey 47.0 ef tRis Fe§lllatieA sRall semply witR tRe previsieAs ef 47.0 ef tRis re§lllatieR as seeAas prastisaele, ellt Aa later tRaR ,A,pril1, 1006 Deeemeer 31, 2010.**~lew,** meeiliee, ar resaAstrllstee sallrses affestee ey 47.0 af tRis re§lllatieR sRall semply WitR tRe pre'/isieRs ef 47.0 ef tRis re§lllatieA IlpeR startllp, 47.1.§iAny facility that becomes or is currently subject to the prOVisions of47.0 of this regUlation by exceeding the applicability threshold in 47.1.2,3, of this regulation shali remain subject to tRese pre'/isieAs 47.0 of this regulation even if its emissions later fall below the applicability threshold.
47,**1.e~** Any facility that is currently sUbject to a state or federal rule promulgated pursuant to the Clean Air Act Amendments of 1977 by exceeding an applicability threshold is and shall remain subjectto these provisions, even if its throughput or emissions have fallen or later fall below the applicability threshold.

147.2 Definitions. As used in 47.0 of this regulation, all terms not defined herein shall have the meanings given them in the November 15, 1990 Clean Air Act Amendments (CAAA) , or in 2.0 ofthis regulation.
"Alcohol" means a chemical compound consisting ofthe hydroxyl (OH) group attached to an alkyl radical and having the general formula CnH2n+10H, such as ethanol, n-propanol, and iso-propanol.
"Alcohol substitute" means a non-alcohol additive that contains VOCs and is used in the fountain solution to reduce the surface tension ofwater or to prevent piling (ink build-up).
"Batch" means a supply offountain solution that is prepared continuously or as a batch and that is used without alteration until completely used or removed from the printing process. "Cleaning solution" means a liquid that is used to remove ink, including dried ink, and debris from the operating surfaces ofthe printing press and its parts. "Dampening system" means**e"l~ipmenl** IRal is**~seEl** Ie Eleli"er IRe**fo~nlain sel~lien**  Ie IRe lilRe!jrapRiG plale.
"Fountain solution" means a mixture of water and non-volatile printing chemicals, and additives which reduce the surface tension ofthe water. The fountain solution wets the nonimage areas so that the ink is maintained within the image areas.
"Heatset" means any operation in which heat is required to evaporate ink oil from the printing ink. "Letterpress printing" means a printing process in which the image is raised relative to the non-image area and the paste ink is transferred to the substrate directly from the image surface. "Lithography" or "lithographic printing" means a printing process in which the image and non-image areas are chemically differentiated; the image area is oil-receptive and the nonimage area is water-receptive. This method differs from other printing methods, in which the image is a raised or recessed surface.
"Non-heatset" or "coldset" means any operation in which printing inks are set without the use of heat. For the purposes of 47.0 of this regulation, ultraviolet-cured and electron beamcured inks are considered non-heatset operations.
"Offset lithographic printing" means a printing process in ""RiGR that transfers the ink film is lransferreEl from the lithographic plate to an intermediary surface (blanket), which, in turn, transfers the ink film to the substrate.
"Press" means a printing production assembly that is composed of one or many units to produce a printed sheet orweb.
"Sheet-fed" means a printing operation in which individual sheets of substrate are fed to the press sequentially.

2"Total actual VOC emissions" means the quantity of vacs emitted from all lithographic and letterpress printing operations, including vac emissions from cleaning materials and activities, during a particular time period,
"Unit" means the smallest complete printing component of a printing press,
"Web" means a continuous roll of paper used as the printing substrate,
47,3 Standards
47,3,1 No owner or operator of a heatset offset lithographic printing press or a heatset letterpress printing press shall operate the printing press unless the owner or operator installs a control device to reduce vac emissions from the press dryer exhaust vent by complying with 47,3,1,1, or 47.3.1,2, or 47,3,1,3 of this regulation at all times the press ooerates: "4.!...7,,,,3,,-,1.!...,-,1_--",A

... t ",Ie",a""st 90%, (weighl) by weight if the first installation date of the control device is prior to [insert the effective date of this regulation), of Ihe**~nGOnlFOllee** lolal oFganiGs**(min~s** melhane ane elhane), OF maintains a**mal(im~m** eF)'eF**el(ha~sl o~t1el**  GonGenlFalion of2g J3arts J3eF million By >/olHme (J3J3m'l) as melhane (as C1) whiGheveF is less slFingenl when IRe J3FeSS is in 0J3eFalion 47,3,1,2 At least 95%, by weight if the first installation date of the control device is on or after [insert the effective date ofthis regulation],
47,3,1,3 Maintaining a maximum press dryer exhaust outlet vac concentration of 20 parts oer million by volume (ppmv) as carbon (C1) on a dry basis,
47,3,2 No owner or operator of an offset lithographic printing press Ihal**~ses** alGohol in Ihe**fo~ntain** solHlion shall operate the printing press unless the owner or operator meets ORe of the requirements listed under 47,3.2,1,47.3,2,2, or 47.3.2.3, ane 47.3,2.4 of this regulation,

473.21 For**~heatset** web offset lithographic printing presses,: 47,3,2.1,1 When, the fountain solution contains alcohol. the fountain solution on-press (as applied) vac content shall be maintained;Jhe**fo~nlain sol~lion**  alGohol Gonlenl shall Be mainlainee al 1.€'% OF less (By**vol~me),** AlteFRalively, a slaneaFe of 3% OF less (By**vol~FRe)** aloohol may Be**~see** if Ihe**fo~ntain sol~tion**  oontaining alGohol is FefrigeFalee Ie less Ihan 15.a eegFees**Celsi~s** (0G) (ag eegFees**~ahFenReit [O~D,**  47,3.2,1.1,1 At 1,6% or less (by volume), or 47.3,2.1,1,2 At 3,0% or less (by volume) and the temperature of the fountain solution shall be maintained at or below 15,5--degrees Celsius (OC) (60 degrees Fahrenheit 

### LEJ1

347.3.2.1.2 When the fountain solution contains no alcohol the fountain solution on-press (as-applied) vae content shall be maintained at 3.0% or less (by volume).
47.3.2.2 For 1illV...non-heatset web offset lithographic printing presses,: IRe aleeRei eeAleAI iA IRe**le~AlaiA sei~lieA**  sRall se elimiAalea. NeA aleeRel aaaili",es er alseRel**s~ssliMes** may se**~sea** Ie assem",lisR IRe latal elimiAalieA elalseRel**~se.** 47.3.2.2.1 There shall be no alcohol in the fountain solution and
47.3.2.2.2 The fountain solution on-press (as-applied) vae content shall be maintained at 3.0% or less (by volume).
47.3.2.3 For any sheet-fed offset lithographic printing presses, the fountain solution onpress (as-applied) vae content shall be maintained: IRe alseAel seAleAI iA IAe**la~AtaiA sel~lieA**  sRall se maiAtaiAea al 5% ar less (sy**vel~me).** AlleFAalj'lely, a slaAaara el 8.5% er less (sy**'Ial~me)** alseRal may se**~sea** il IRe**Ie~AlaiA sel~lieA**  is relri!jeralea Ie sele'll15.6'C (60'1').
47.3.2.3.1 At 5.0% or less (by volume). ore
47.3.2.3.2 At 8.5% or less (by volume) and the temperature of the fountain solution shall be maintained at or is relriaeralea Ie below 15.65'e (60'Fj
47.3.2.4 AAy ty",e al affsel**liIAe!jra~Ais** ",riAliA!j**~ress** sAall se GaAsiaerea iA**sam~liaAse** wilA IAis**re!j~laliaA** il IAe aAly VOCs iA IAe**Ie~AtaiA sal~ljaA**  are iA AaA alsaAal aaailives ar alsaRal**s~ssliMes,** sa tRallRe saAGeAlralieA elVOCs iA IRe**Ie~AtaiA sal~liaA**  is 3.0% ar less (sy wei!jAIl (TAe**Ie~AlaiA sal~ljaA**  sRall Aal saAlaiA aAy alsaAaL)
47.3.3 No owner or operator ofan offset lithographic printing press or a letterpress printing press shall operate the printing press unless the owner or operator reduces vae emissions from cleaning solutions by meeting reguirements in 47.3.3.10r 47.3.3.2. and 47.3.3.3. of this regulation:**:!.47,"",.",3"-,.3,,-,.-,-1_-,U~si",n,,,g** 

### usiR!l a cleaning solution with a 30% or less (as used) vae content.
47.3.3.2 Using AlleFAali'/ely, IRe**~se** ef cleaning solutions with a vae composite partial vapor pressure less than 10 millimeters (mm) mercury (Hg) (OA inches [in] Hg) at 20'e (68'F) may se**~sea.** The vae composite partial vapor pressure is calculated as follows: (W,)(VP,)

### PPc~:t MW,
1.1 W w W. WI --+--+L.,-­ MW. MW. ,_. MW, (47-1) Where: W; =Weight ofthe 

### 1tIl-[': vae compound, in grams (g); Ww =Weight ofwater, in g; We = Weight ofexemptcompound, in g; MW; = Molecular weight ofthe 

### 1tIl-[': vae compound, in grams per gram-mole
4MWw = Molecular weight ofwater, in

MW. = Molecular weight of exempt compound, in [9

# -~ole

# J

PPc =

## vac composite partial pressure at 20'C, in mmHg VP; = Vapor pressure ofthe

## 1tI1--f'vac compound at 20'C, in mmHg
47.3.3.3 Keeping all cleaning solutions and used shop towels or cloths in closed containers.

47.4 Control devices. An owner or operator of an offset lithographic printing press or a letterpress printing press equipped with a control system shall ensure that:

47.4.1 The capture system and control device are operated at all times lIlat-when the printing press is in operation, and the OWAer or sf'leFater aeFflsAslrales compliance with 47.0 of this regulation is demonstrated through the applicable coating analysis and capture system and control device efficiency test methods specified in Appendix S, Appendix 0, and Appendix E of this regulation and in accordance with the capture efficiency test methods specified in Appendix 0 ofthis regulation.

47.4.2 The control device is equipped with the applicable monitoring equipment specified in 2.0 of Appendix 0 of this regUlation, and the monitoring equipment is installed, calibrated, operated, and maintained according to the vendor's specifications at all times the control device is in use.
47.5 Test methods and procedures.

47.5.1 The 

## vac content of each ink, the alcohol content of each fountain solution, and the efficiency of each capture system and control device shall be determined by the applicable test methods and procedures specified in Appendix A through Appendix 0 of this regulation to establish the records required under 47.6 ofthis regulation.

47.5.2 To demonstrate compliance with the emission control requirements of 47.0 of this regulation, the attestea facility affected by 47.0 ofthis regUlation shall be run at maximum operating conditions and flow rates during any emission testing.

47.5.3 Emission tests for facilities using an add-on dryer exhaust control device shall include an initial test when the control device is installed and in operation, Sf'leraliAg that demonstrates compliance with 47.3.1 of this regulation. eilAer IAe 90% (tly weigl'll) FeauslioA or IAe 2l:l**f'lf'lFfl~'** eFflissisA IiFflil.

47.5.4 To determine compliance with 47.3.2 ofthis regulation, the owner oroperator of an offset lithographic printing facility shall perform the following procedures:

47.5.4.1 A sample shall be taken of the fountain solution (as used) from the fountain tray or reservoir that contains a fresh batch of fountain solution (after mixing), for each unit or centralized reservoir, to determine the alcohol content ofthe fountain



### 5solution in accordance with 47.3.2.1 through 47.3.2.3 of this regulation, before the fountain solution is used.
47.5.4.2 A direct measurement of the alcohol content of the fountain solution sample or samples shall be performed in accordance with the method specified in Appendix L ofthis regulation.
47.5.4.3 Alternatively, a sample of the fountain solution (as used) may be taken from the fountain tray or reservoir of fountain solution dUring use and measured with a hydrometer or refractometer that has been standardized with tests performed in accordance with 47.5.4.1 and 47.5.4.2 of this regulation. The unit shall be considered in compliance with 47.3.2.1 through 47.3.2.3 of this regulation if the refractometer or hydrometer measurement is less than or equal to the measurement obtained by the method specified in Appendix L of this regulation plus 10%.
47.5.4.4 The vae content of a fountain solution containing alcohol substitutes or nonalcohol additives shall be established with proper recordkeeping and the**manufacture~s** laoerateF'j aAalysis technical information of the vae content of the concentrated alcohol substitute and included in facility records. Records shall include the amount of concentrated substitute added per quantity of fountain water; the date and time of preparation if the fountain solution is mixed as a batch; and the calculated vae content of the final solution to fulfill the requirements listed in H.3.2.4 47.3.2 of this regulation.
47.5.5 To determine corT!pJiance with 47.3.2.1 47.3.2.1.1.2 and 47.3.2.3 47.3.2.3.2 of this regulation, an owner or operator of an offset lithographic printing facility shall use a thermometer or other temperature detection device capable of reading to 0.28'e (0.5'F) accuracy to ensure that a refrigerated fountain solution containing alcohol is below 15.5'e (60'F) at all times.
46.5.6 To determine compliance with 47.3.3 of this regulation, an owner or operator of an offset lithographic printing press or a letterpress printing press shall:
47.56.1 Take a sample of the cleaning solution (as used) to demonstrate compliance with the cleaning solution vae content limitations listed in 47.3.3 of this regulation. If the cleaning solution is used as received from the supplier without dilution or alteration, the manufacturer's technical information may be used to demonstrate compliance.
47.5.6.2 Use the method specified in Appendix L of this regulation to determine the vae content of the cleaning solution (as used). Alternatively, the vae content and vae partial pressure of the cleaning solution may be established using the manufacturer's technical data. If the cleaning solution is prepared through the dilution of concentrated materials, the blending ratio and vae content of the concentrate may be used to determine the "as used" vae content of the cleaning solution.
47.6 Recordkeeping and reporting.
47.6.1 Requirements for sources below threshold emission limit. Any owner or operator of any offset lithography printing Jlfe55-facility, any letterpress printing facilitv, or any facility with both offset lithographic and letterpress printing operations, that emits less than the

6threshold limit according to 47.1 of this regulation shall comply with the following requirements:
47.6.1.1 Initial certification. Within six months after [insert the effective date of this revision of47.0 ofthis regulation!. or upon initial startup of a new printing press +lhe owner or operator shall certify to the Department that the facility emits less than the threshold limit according to 47.1 of this regulation. Such certification shall include the following information:
47.6.1.1.1 The name and location ofthe facility.
47.6.1.1.2 The address and telephone number of the person responsible for the facility.
47.6.1.1.3 A declaration that the facility is not subject to the requirements of47.0 ofthis regulation because ofthe criteria listed in 47.1 of this regulation.
47.6.1.1.4 The calculations demonstrating that total actual VaG emissions from all offset lithographic and letterpress printing presses at the facility are and will be less than 6.8 kg (15 Ib) per day before the application of capture systems and control devices.
47.6.1.1.5 A description of the instrument or method by which the owner or operator accurately measured or calculated the volume of ink applied and the amount that can potentially be applied each year on each printing press.
47.6.1.2 Recordkeeping. On and after [insert the effective date of this revision of 47.0 of this regulation!. +lhe owner or operator shall collect and record all ofthe following information each year for each offset lithographic printing press and each letterpress printing press and maintain the information at the facility for a period offive years:
47.6.1.2.1 The name and identification number of each ink, as applied, each year on each printing press.
47.8.1.2.2 TAe wei§RI af VaG Iler**vol~FI1e** of soaliA§ soliss aAs IRe**vol~FI1e** of soliss af easR iAk, as alllllies, easR year OA easR IlriAliA§llress.**47.6.1.2.6~** The total actual VaG emissions as calculated in 47.6.1.1.4 of this regulation using the VaG content for that year.
47.6.1.3 Reporting. On and after [insert the effective date of this revision of 47.0 of this regulation] UllOA**IlroFl1~I§alioA** of 47.1) af IRis**re§~lalioA,** any record showing that total actual emissions ofVOGs from all offset lithographic printing presses and all letterpress printing presses exceed 6.8 kg (15 Ib) per day before the application of capture systems and control devices shall be reported by sending a copy of the record to the Department within 45 calendar days after the exceedance occurs. This requirement is in addition to any other State of Delaware exceedance reporting requirements.
47.6.2 Requirements for sources above threshold emission limit. Any owner or operator of any offset lithography printing 

### press facility, or anv letterpress printing facilitv, or any facilitv with both offset lithographic and letterpress printing operations. that emits greater than
7the threshold limit according to 47.1 of this regulation shall comply with the following requirements:
47.6.2.1 Initial certification. Within six months after finsert the effective date of this revision of 47.0 of this regulation), or upon initial startup of a new printing press +!he owner or operator shall certify to the Department that the facility emits greater than the threshold limit according to 47.1 of this regulation. Such certification shall include the following information:
47.6.2.1.1 The name and location of the facility.
47.6.2.1.2 The address and telephone number ofthe person responsible for the facility.
47.6.2.1.3 The calculations demonstrating that total actual voe emissions from all aspects of offset**lilhe§Faj:l~iG** j:lFiRliA§ j:lresses printing operations at the facility are and shall be greater than 15 Ib (6.8 kg) per day before the application ofcapture systems and control devices.
47.6.2.1.4 A description of the instrument or method by which the owner or operator accurately measured or calculated the volume of Ink applied and the amount that can potentially be applied each year on each printing press. 47.6.2,2 Recordkeeping. On and after finsert the effective date of this revision of 47.0 of this regulation), +!he owner or operator shall collect and record all ofthe following information each year for each offset lithographic printing press and each letterpress printing press and maintain the information at the facility for a period offive years:
47.6.2.2.1 The name and identification number of each ink, as applied, each year on each printing press. 47.6.2.2,2 The weight ofvoes per volume of coating solids and the volume ofsolids of each ink, as applied, each year on each printing press.
47.6.2.2.3 The total actual voe emissions as calculated in 47.e.1.1.4 47.6.2.1.3 of this regulation using the vae content for that year. 47,6.3 Requirements for sources using an add-on dryer exhaust control device.
47.6.3.1 Within six months after [insert the effective date of this revision of 47.0 of this regulation], or upon initial startup of a new printing press, +!he owner or operator of a heatset offset lithographic printing press, or a heatset letterpress printing press, shall install, calibrate, maintain, and operate a temperature monitoring device, according to the manufacturer's instructions, at the oullet of the control device or at a location approved by the Department [and the EPAJ. The monitoring temperature shall be set during the testing required to certify compliance with the requirements of 47.4 of this regulation. Monitoring shall be performed only when the unit is operational.
47.6.3.2 The temperature monitoring device shall be equipped with a continuous recorder and shall have an accuracy of 0.28"e (OSF).

8

### 47.6.3.3 The dryer pressure shall be maintained lower than the press room area pressure such that air flows into the dryer at all times when the press is operating. A 100% emissions capture efficiency for the dryer shall be demonstrated using an air flow direction measuring device.
47.6.4 Requirements for monitoring fountain solution VaG concentration. On and after [insert the effective date of this revision of 47.0 of this regulationJ. +the alcohol concentration in the fountain solution shall be monitored to provide data that can be correlated to the amount of material used when the fountain solution complies with the limits listed in 47.3.2.1 through 47.3.2.4 47.3.2.3 of this regulation. One of the following methods shall be used to frequently measure the concentration of alcohol in the fountain solution:
47.6.4.1 The owner or operator of any offset lithographic printing press shall monitor the alcohol concentration of the fountain solution with a refractometer that is corrected for temperature at least once per 8-hour shift or once per batch, whichever is longer. The refractometer shall have a visual, analog, or digital readout with an accuracy of 0.5%. A standard solution shall be used to calibrate the refractometer for the type of alcohol used in the fountain. Alternatively, the refractometer shall be standardized with measurements performed to determine compliance, according to the procedures described in 47.5.4.1 and 47.5.4.2 of this regulation.
47.6.4.2 Alternatively, the owner or operator of any offset lithographic printing press shall monitor the alcohol concentration of the fountain solution with a hydrometer equipped with a temperature correction at least once per eight-hour shift or once per batch, whichever is longer. The hydrometer shall have a visual, analog, or digital readout with an accuracy of 0.5%. A standard solution shall be used to calibrate the hydrometer for the type of alcohol used in the fountain. Alternatively, the hydrometer shall be standardized with measurements performed to determine compliance, according to the procedures described in 47.5.4.1 and 47.5.4.2 ofthis regulation.
47.6.4.3 The VaG content of the fountain solution may be monitored with a conductivity meter if it is determined that a refractometer or hydrometer cannot be used for the type of VOGs in the fountain solution. The conductivity meter reading for the fountain solution shall be referenced to the conductivity ofthe incoming water.
47.6.4.4 If, through recordkeeping for a period of6 months or more, the printing process is shown to consistently meet the requirements in 47.3.24 and 47.5.4 of this regulation, the monitoring requirement may be waived or extended to a longer period oftime upon prior approval by the Department.
47.6.5 Requirements for monitoring fountain solution temperature. On and after [insert the effective date ofthis revision of47.0 of this regUlation]:
47.6.5.1 The owner or operator of any offset lithographic printing press using refrigeration equipment on the fountain solution shall install, maintain, and continuously operate a temperature monitor ofthe fountain solution reservoir.
47.6.5.2 The temperature monitor shall be attached to a continuous recording device such as a strip chart, recorder, or computer.

947.6.6 Requirements for Monitoring Cleaning Solution. On and after [insert the effective date of this revision of 47.0 of this regulation!.**~for** any offset lithographic printing press or any letterpress printing press with continuous cleaning equipment, flow meters shall be used to monitor the water and cleaning solution flow rates. The flow meters shall be calibrated so that the VOC content of the mixed solution is accurately measured to fulfill the requirements of47.3.3 of this regulation.
47.6.7 Requirements for Monitoring Other Key Parameters. On and after [insert the effective date of this revision of 47.0 of this regulation], +!he owner or operator of any offset iithographic printing press or any letterpress printing press shall record daily, and make available to the Department within 45 calendar days upon the Department's verbal or written request, the following key parameters: 47,6,7,1 The type of control device operating on tile any heatset offset lithographic printing press or any heatset letterpress printing press and the operating parameters specified in 41.5.3 [47.3.1] of this regulation, 47,6,7,2 The equipment [operating] standard selected to comply with the requirements iisted in 47,3.2,1 through 47,J,2,4 47.3,2,3 and 47,3,3 of this regulation.
47.6.7.3 The VOC content of the fountain solutions and cleaning solutions, to comply with the requirements iisted in 47,5.4,47,6.4, and 47,6,6 of this regulation,
47,6,7.4 The temperature of the fountain solution, to comply with the requirements iisted in 47,6.5 ofthis regulation, if applicable.
47.6.7,5 For manual cleaning methods, the amount of cleaning solution and the amount of water added per batch ofcleaning solution mixed,
47,6,7,6 For automatic cleaning methods, the flow rates of water and cleaning solution concentrate, as specified in 47,6.6 of this regulation,
47,6,7.7 Corrective actions taken when exceedances of any parameters. monitored according to the requirements of47.4 or 47,5 of this regulation, occur,

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