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 of Air 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 of Air Quality (DAQ) received a comment letter from the Graphic Arts 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 of the comments in the 

GAA's letter was made to the new changes subject to the February 1, 2011 hearing. 

However, the DAQ has determined that two comments in the GAA's letter provided meaningful 

reasons for minor changes 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 of the proposed revision of Section 47.0. 

Please let us know if you have any question regarding this document. 

Attachments 

(1) DAQ's responses to GAA's comments; 

(2) Final marked-up version of Section 47.0 of 7 DE Admin Code 1124. 
[DAQ's notesfor this document: 

(I) All DAQ's responses in this document are in Italic jont and bracketed by [. ..]. 

(2) In general or unless otherwise specified, 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 the DAQ'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 of Air Quality (DAQ), there were several comments that were 

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 easier to 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 allow for greater daily emissions. However. the current 'limit" in Section 

47.1 is not an emissions limit. it is an applicability threshold. It does not control emissions, it 

merely identifies the facilities that must meet the reqUirements of Section 47.0. As the EPA has 

determined that a 3 ton/year on a 12-month rolling basis emission threshold is equivalent to a 15 

IbJday emission threshold, it is unclear how a change in the 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 of this 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 

2 
actual 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) per year 

based on 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 on Section 47.1: 

The DAQ does not agree with GAA's comment because meeting an annual 2, 721-kg 

threshold does not guarantee meeting a daily 6.8-kg threshold. A facility could be 

operated under an average 2, 721-kg/year level, but its daily operation in some days 

may emit VOC well above a 6.8-kg/day threshold. In other words, it wouldpossible 

that a facility, now being controlled under the daily 6.8-kg threshold, would be freed 

from its current controls ifthe daily threshold were replaced by an annual 2, 721-kg 

threshold. This would be considered a "backsliding" and not allowed under the 

Clean Air Act. 

The GAA should understand that the current and upcoming ozone standards are 

daily-emission based, not annual-emission based. Control daily VOC emission is 

criticalfor Delaware to attain the daily-based ozone standards. 

Therefore, the DAQ recommends that no change be made to the proposed Section 

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 

heatset web 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 prior to 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 if the first installation date of the control device is prior to 

[insert effective date of this regulation] or if is used for book printing or has a maximum 

web width of 22 inches or less, or has the potential to emit from the dryer, prior to controls, 

less than 25 tpy of VaG (petroleum ink oil). 

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 of this regulation]. Heatset presses used for book printing or 

3 
with a maximum web width of 22 inches or less, and any press with the potential to emit 

from the dryer, prior to controls, less than 25 tpy of VaG (petroleum ink oil) shall comply 

With 47.3.1.1. 

[DAQ's responses to Comments on Section 47.3.1: 

The DAQ believes that setting up a more stringent requirement for new presses 

(95% destruction efficiency) does not necessarily lead to those exemptions, even 

though they are mentioned in the CTG. As indicatedpreviously, the DAQ has the 

authority to implement requirements in Delaware that are more stringent than 

CTG's recommendation, and are neededfor attainment ofthe ozone standard in 

Delaware. 

Therefore, the DAQ recommends that no change be made to the proposed Section 

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 or sheetfed 

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 

for fountain solutions, an exemption for very 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 of the existing rule. 

Therefore, Section 47.3.2 should be revised to read as follows: 

47.3.2.	 No owner or operator of an offset lithographic printing press with a total 

fountain solution capacity of 1 gallon or more or a sheetfed press with a 

maximum sheet size of 11 x 17 inches orlarger that lJses alGeAel in the 

felJntain sellJtien shall operate the printing press unless the owner or 

operator meets one of the requirements listed under 47.3.2.1, 47.3.2.2, or 

47.3.2.3, ans47.d.2.4 of this regulation. 

[DAQ's responses to Comments on Section 47.3.2: 

Again, setting up more stringent requirements does not necessarilyjustifY those 

exemptions. The DAQ still believes that, ifthe requested exemptions were adopted, 

it would lead to a backsliding result that is not allowed under the CAA. 

Therefore, DAQ recommends that no change be made to the proposed Section 

47.3.2.] 

Sections 47.3.2.1 through 47.3.2.4 

4 
In the DAQ's response to the GAA's June 2, 2010 comment letter, the Department indicated that 

changing the vae content limits for fountain 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 of fountain solution 

concentration that has been added to a gallon of water. However, to determine vae by volume, 

more complicated calculations are required, as the volume of VaG 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 or weight percent basis which can then be 

used to calculate vae content on a weight percent basis of the 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 of vae, a 

similar change of "by volume" to "by weight" is technically correct and does not lead to a 

relaxation of the 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 

47.3.2.1.1.2 At 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 of the 

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's previous responses, most VOCs have a density or 

specific weight smaller than water, which means changing to a by-weight % limit 

may represent a greater % limit than the existing by-volume limit. Apparently, such 

a change will be considered "backsliding" and not allowed under the CAA. 

It is true that most material safety data sheets (MSDSs) from manufacturers provide 

VOC content on a pound/gallon or weight percent basis which can then be used to 

calculate VOC content on a weight percent basis ofthe as-appliedfountain solution. 

The MSDSs, however, also provide density or specific weight data for the VOCs 

being used. In addition, Appendix C ofthis regulation provides a general VOC 

density that can be usedfor such conversion. It is a simple calculation to convert 

VOC-content by weight to VOC content by volume using the density data. 

The GAA 's comment above regarding Section 47.3.2.4 is no longer valid since this 

section has been deleted in the proposed regulation. 

Therefore, the DAQ recommends that no change be made to the proposed Sections 

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 roller washes. When the 2006 GTG was 

finalized, EPA dramatically expanded the scope of the solvents covered and set a limit of 70 

percent by weight limit for 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 limits for all possible 

cleaning activities. EPA stated in the 2006 GTG "a small number of cleaning tasks cannot be 

carried out with low VaG composite vapor pressure cleaning materials or reduced 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 or operator 

reduces VaG emissions from cleaning solutions by meeting requirements in 

47.3.3.1, or 47.3.3.2, and 47.3.3.3 and 47.3.3.4 of this regulation: 

47.3.3.1 Using llSiR§-a cleaning solution with a 30% SF less 70% or less by weight 

(as used) VaG content. 

6 
47.3.3.3.4 The use of cleaning solutions not meeting section 47.3.3.1 or 47.3.3.2 is 

permitted provided that the quantfty used does not exceed 110 gallons over any 

twelve consecutive months. 

[DAQ's responses to Comments on Section 47.3.3: 

In its previous response, the DAQ explained that adding the I 10-gallon exemption 

to the proposed regulation would lead extra vac emissionsfrom the exempted 110 

gallons at allfacilities being governed by this rule, which would be considered as 

"backsliding" and not allowed under the CAA. 

Similarly, changing the 30% limit to a 70% limit in Section 47.3.3.1 would be also 

considered as "backsliding" and not allowed under the CAA. The GAA needs also 

to understand that the DAQ cannot implement any new regulation that would have 

less stringent requirements, thus increasing emissions and worsening the air quality 

in Delaware. 

Therefore, the DAQ recommends that no change be made to the proposed Section 

47.3.3.] 

Section 47.4 

In the DAQ's response to the GAA's request in the June 2, 2010 comment letter to remove 

references to Appendix 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 of the 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 of this 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 of Appendix 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 sufficient to 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 of the 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 

7 
pressroom 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 of VOC 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, low volatile 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 EPA concluded 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 our June 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 of this regulation is demonstrated 

through the applicable coating analysis aREl 6a13lUfe sy51eFR and control 

device efficiency test methods specified in Appendix B, AppeRrlix Q, and 

Appendix E of this regulation and ;n accordance with the capture efficiency 

test method identified;n 47.6.3.3. anG in aGGereanoo with the GBptlJl'fJ 

effiGiORG}' te81 methofis 8peGifiefl ifl AppendiK D of#1is refjtJlatioR. 

47.4.2 The control device is equipped with the applicable monitoring 

equipment specified in 47.6.3 2J) ofAppeRdix Q 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. 

[DAQ's responses to Comments on Section 47.4: 

In its previous responses, the DAQ explained in detail why Appendix D could not be 

removedfrom the proposed Section 47. O. Those responses are still validfor 

addressing the current GAA 's comments. 

In addition, the DAQ does not agree that the requirements ofAppendix D in 47.4. I 

and 47.4.2 are "directly contradictory to Section 47.6.3.3 ofthe existing 

regulation. " Specifically, Section 47.4 sets up operational requirements for control 

devices, while Section 47.6 sets up recordkeeping and reporting requirements. 

8 
Therefore, DAQ recommends that no change be made to the proposed Section 47.4.] 

Section 47.5.1 

In light of the 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 1124 would read as follows: 

47.5.1 The VOC content of each ink, the alcohol content of each fountain 

solution, and the efficiency of each G8pwre S}'SIem ami control 

device shall be determined by the applicable test methods and procedures 

specified in Appendix A B and through Appendix 0 C, and Appendix E 

of this regulation to establish the records required under 47.6 of this 

regulation. 

[DAQ's responses to Comments on Section 47.5.1: 

Please see DAQ 's responses to Comments on 47.4 above. 

Therefore, DAQ recommends that no change be made to the proposed Section 

47.5.1.] 

Section 47.5.2 

In the DAQ's response to the GAA's June 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 that jobs 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 artificial jobs, 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) for Title V Permitting of Printing Operations on 

page 68, Section 5.7, and described typical operating conditions for printing facilities as follows: 

"Such operating conditions should strive to minimize downtime while running as 

many presses as practicable, when multiple presses are being served by a 

common control device. The proposed operating scenario should also be 

reflective of a typical normal production schedule. As necessary, proposed 

testing conditions should rely on historical production records for establishing 

average coverage rates, press speeds, or ink and other input material 

consumption rates, run times, and average time ofintermittent events such 

as press cleaning, web breaks or similar shutdown situations. " 

9 
The 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 of 47.0 of this 

regulation, the facility affected by 47.0 of this 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 the DAQ pointed out in its previous responses to the same comment, the 

maximum operating condition ofa press is not artificial and unachievable. A 

facility can determine this condition with its operation records or product orders in 

a reasonable time period, with consultation andprior agreementfrom DAQ's 

Engineering and Compliance Branch for necessary help and guidance. In addition, 

this maximum operating condition can be specified in a facility's permit. 

In addition, the DAQ believes that, due to the daily nature ofthe ozone air quality 

problem in Delaware, it is critical that all VOC sources in Delaware, including 

those in offset lithographic and letterpress printingfacilities, need to be controlled 

at maximum operating conditions. Clearly, a requirement ofcontrol at typical 

operating condition cannot guarantee that afacility will not operate at a level 

higher than its typical condition. Therefore, changing requirementfrom a 

"maximum operating condition" to a "typical operating condition" is considered a 

backsliding action and not allowed under the Clean Air Act. More importantly, 

such a change will hinder Delaware's overall efforts to attain the ozone standard. 

Therefore, DAQ recommends that no change be made to the proposed Section 

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 per Appendix 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 for fountain solutions containing alcohol as it is for fountain 

solutions containing alcohol substitutes, the currently proposed Section 47.5.4.4 should be 

revised to include fountain solutions containing alcohol. 

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

47.5.4 To determine compliance with 47.3.2 of this 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 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 of the fountain solution in accordance with 47.3.2.1 through 

47.3.2.4 of this regUlation, before the fountain solution is used.47.8.4.2 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 of this regulation. 

47.8.4.d 47.5.4.2 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 aRE! 47.8.4.2 

of this regulation. The unit shall be considered in compliance with 47.3.2.1 

through 47.3.2.4 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%. 

47.8.4.447.5.4.3 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 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 of the 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 

subtract the corresponding non-Vae portion. As the DAQ acknowledges that this method of 

determining vae content is flawed, and recommends using manufacturer information to correct 

it, the use of Appendix 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 process jeopardizing 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 for the 

manufacturer information to determine vae content and vae partial pressure, with AppendiX L 

as an alternative option. Since calculating vae content per Appendix L relies on manufacturer 

11 
information 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 DAQ would agree that combining Sections 47.5.4.1 and 47.5.4.2 might lead to a 

better presentation ofthe options. However, such a combination seems not 

necessary, in particular ifconsidering it would take excessive time and efforts in 

rule-making process. 

Regarding the testing method in Appendix L, the DAQ has explained in its previous 

responses that the current method may lead to elevated results, and such results can 

be easily corrected. When the EPA makes an appropriate testing method become 

available in the future, the DAQ will consider revising Section 47.5.4 or Appendix L 

accordingly. The GAA will be iriformed and welcome to present comments at that 

time. 

Regarding the GAA 's request ofadding "alcohol" in Section 47.5.4.4, the DAQ 

believes that the request is not appropriate since Section 47.5.4.4 is specificallyfor 

fountain solutions that do NOT contain alcohol. 

Therefore, DAQ recommends that no change be made to the proposed Section 

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 that their 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, GAA disagrees 

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 

12 
year 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 it since there is no corresponding requirement in the 

proposed regulation regarding the weight of VaG per volume of coating solids". Section 

47.6.2.2.2 which reqUires the same records for facilities exceeding the threshold, should also be 

deleted. 

Material Use Thresholds for Applicability Determination 

Calculation of vac 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 of the 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% of the corresponding major source threshold. The 

purpose of the gUidance was to set material use thresholds at 50% of the 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. For the 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 of the 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 of fountain 

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 (5 tons) vac, or 50% of the major source threshold 

for vac 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 of the PTE guidance further explain these calculations and demonstrate that actual emissions 

for material use in the chart are half of the emissions cap. 

13 
From 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 limits would 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 for which 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 of those materials, prohibitory rules may establish a 50 percent 

emissions cap. The technical support document includes equations to use in establishing 

that sources would remain below the 50 percent limitation. Note that emission calculations 

under this approach would use the actual density of each material used, rather than the 

"default" densities assumed in the technical support document. This more detailed 

approach must be used where any of the screening levels are exceeded, or there is a 

combination of printing technologies (e.g., lithographic and f1exographic or water-based 

and solvent-based flexographic) present in the same facility. 

To provide an extra level of conservation, GM requests that a threshold of 768 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 per year 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 if the requirements of 47.0 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 of this 

revision of 47.0] or upon initial startup of a new printing press, the 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 of the 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 of 47.0 of this 

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 at the facility are and will be less 

than €Ul k!} (15 Ie) Iler say 2, 721 kg (3 tons) per 12-month rolling period before the 

application of capture systems and control devices. Such records may include the 

following: 

47.6.1.1.4.1	 Material use records that show the facility meets the following 

material use thresholds: 

Type of Offset Lithographic Printing 12-Month Rolling Material Use i 

14 
aDeration Threshold 

Sheet-fed 768 gallons of cleaning solvent and 

fountain solution additives 

Non-heatset Web 768 gallons of cleaning solvent and 

fountain solution additives 

Heatset Web 5400 pounds of ink, cleaning 

solvent, and fountain solution 

additives 

47.6.1.1.4.2	 The following monthly records and calculations demonstrating actual 

VaG emissions did not equal or exceed three tons of volatile organic 

compounds per rolling twelve-month period: 

(i)	 The total amount, in pounds or gallons, of each ink, fountain solution, and 

cleaning solvent used; 

(ii)	 The volatile organic compounds content of each ink, fountain solution, and 

cleaning used: 

Volatile organic compounds calculations shall be based on the following 

formula using applicable retention factors identffied in section 47.6.7 ofthis 

rule. 

Volatile organic compounds emissions = amount of ink (pounds) x volatile 

organic compounds content (weight percent) x [1 -(retention factor/100)] + 

amount offountain solution (gallons) x volatile organic compounds content 

(pounds per gallon) + amount of cleaning solvent (gallons) x volatile 

organic compounds content (pounds per gallon) 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 and 47.6.2: 

The DAQ does not agree that Section 47.6.1 is redundant and unclear. Specifically, 

the DAQ believes that Sections 47.6.1.1.5 and 47.6.1.2.1 will provide necessary 

information/or the agency to understand and evaluate a/acility's operation. As the 

GAA pointed out that "some printing operations can use hundreds 0/inks on a 

single press per year." No matter whether this statement is true (which means a 

press uses a different ink on a different day throughout the year), the DAQ needs to 

know the daily usage 0/each ink via requirements o/Sections 47.6.1.1.5 and 

47.6.1.2.1. 

The DAQ agree that calculation o/VOC emissions is time consuming and sometimes 

complicated. It is also true that many small printing operations do not have the 

15 
appropriate personnel or expertise to complete such calculations. However, the 

DAQ believes that most, ifnot all, small printing operations will fall into Section 

47.6.1 below threshold limit. An initial certification and then-after annual 

recordkeepingfor those smallfacilities are necessary, and have been proved, in the 

past 16 years since Section 47.0 was started in 1994, appropriate and not a 

significant administrative burden for the small facilities 

Regarding the GAA 's comments on "Material Use Thresholds for Applicability 

Determination, " the DAQ has provided detailed discussion in its previous responses 

to the GAA's June 2, 2010 comment letter, as well as in its responses to Comments 

on Section 47.1 above in this document. 

Therefore, DAQ recommends that no change be made to the proposed Sections 

47.6.1 and 47.6.2.] 

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

hour shift 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 [insert the effective date of this revision of 47.0], 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 of this 

regulation. One of the following methods shall be used to freElloleRlly 

measure the concentration of alcohol in the fountain solution: 

[DAQ's responses to Comments on Section 47.6.4: 

The DAQ believes that the word "frequently" in Section 47.6.4 will not alter the 

requirement nature ofSection 47.6.4. 

Therefore, DAQ recommends that no change be made to the proposed Section 

47.6.4.] 

Section 47.6.6 

In response to the GAA's June 2,2010 comment letter, the DAQ indicated that flow meters for 

water and cleaning solvent are reqUired to determine emissions from automatic washing systems. 

However, this statement is incorrect, as emissions are not based on the mix ratio or flow of water 

and cleaning solvent, and are instead a factor of the amount of cleaning solvent used and the 

16 
vaG content of that 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 order to determine the vae content of the continuous cleaning solution, the correct application 

would be to determine that the calibration of the automatic mixing unit is correct. Automatic 

mixing units are based on volume of water and concentrate added, not flow. Automatic mixing 

units do not have meters to measure the flow of these 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 of the 

calibration of the 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 of 47.0], for any offset lithographic 

printing press or any 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 of the mixed solution is accurately 

measured to fulfill the requirements of 47.3.3 of this regulation. 

[DAQ's responses to Comments on Section 47.6.6: 

The intent ofthe proposed Section 47.6.6 is to cover a general case where the 

continuous cleaning process obtains cleaning solution that is continuously mixed 

from continuous inputs ofwater and cleaning solvent, and the flow rates ofsuch 

continuous inputs must be monitored. 

The GAA 's above comment is valid only when the cleaning process obtains cleaning 

solution from a large reservoir in which pre-determined volumes ofwater and 

cleaning solvent are mixed thoroughly before the cleaning process starts. When the 

pre-mixed cleaning solution in the reservoir is used up, the cleaning process has to 

be stopped until another batch ofcleaning solution in the reservoir is ready. The 

DAQ believes that this special case can be handled in the facility's permit to comply 

with Section 47.3.3. 

Therefore, DAQ recommends that no change be made to the proposed Section 

47.6.6.] 

Section 47.6.7 

17 
Section 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 of the type of control 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 unclear what 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 

of fountain solution temperature, while Section 47.6.5.2 requires continuous recording. Section 

47.6.7.6 requires recordkeeping of a parameter that 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 of the 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) For Section 47.6.7.1, the citation of47.5.3 was unintentionally overlooked 

and left unchanged when its previous numerical requirements were moved to 

Section 47.3.1. Therefore, the DAQproposed to 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] of this regulation. 

(2) For Section 47.6.7.2, the DAQ agrees that the term "equipment standard" 

seems to be confusing, and therefore proposes to revise it as 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 of this regulation. 

(3) For Section 47.6.7.4, the DAQ does agree that Section 47.6.7.4 and Section 

47.6.5.2 are contradictory. .ifa facility meets the requirement ofSection 

47.6.5.2, it automatically meets the requirement ofSection 47.6.7.4. 

18 
(4) For Section 47.6.7.6, please see the DAQ's responses to Comments on
 

Section 47.6.6 in this document.
 

(5) Regarding the GAA's comments on the daily requirements in Section 47.6.7, 

the DAQ believes that such daily recording is necessaryfor closely 

monitoring the facility's operation to catch up any significant emission 

variation on a daily basis. Such variation is essentialfor Delaware's overall 

efforts for attaining the daily ozone standard. Due to this essentiality, 

changing the daily requirements to a less frequent schedule will be 

considered "back-sliding" andprohibited under the Clean Air Act. To simply 

the recording process, the facility could use terms such as "same" or 

"unchanged" in daily recording ifthe operating standard or conditions are 

not changed. 

Proposed Section 

In the DAQ's response to the GAA's June 2,2010 comment letter, the DAQ stated "it would be 

reasonable and practical to use other retention factors, carry-over rate, and capture efficiencies, 

as mentioned in this comment, and in Comment 4.8 and Comment 4.26, when a facility calculates 

its emission inventory, control device efficiency, and emission fee, etc. The DAQ is confident that 

using those factors/rate/efficiencies would not affect a facility's threshold determination. 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 for the use of retention and emission factors, 

ensuring that they are included in permits. Without the inclusion of these factors in this rule, their 

use is left to the discretion of the permit writer, who mayor may not be familiar with the retention 

factors and the DAQ's approval of their 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 of the CTG and they 

were reviewed and approved by EPA. If the DAQ would like to review the ink oil retention studies, 

they can be provided. 

For the reasons explained above, the GAA requests the inclusion of the following Section 47.6.7 

(so numbered upon deletion of existing Section 47.6.7, otherwise numbered 47.6.8): 

47.6.7 Retention Factors and Capture Efficiencies - For purposes of determining volatile 

organic compounds emissions from offset lithographic printing operations, the 

following retention factors and capture efficiencies shall be used: 

47.6.7.1 A portion of the volatile organic compounds contained in inks and cleaning 

solution is retained in the printed web or in the shop towels used for cleaning. The 

following retention factors shall be used: 

19 
47.5.7.1.1 A 20% volatile organic compounds retention factor shall be used for 

heatset inks printed on absorptive substrates, meaning 80% ofthe volatile 

organic compounds in the ink is emitted during the printing process and is 

available for capture and control by an add-on pollution control device. 

47.6.7.1.2	 A 95% volatile organic compounds retention factor shall be used for 

sheet-fed and non-heatset web inks printed on absorptive substrates, meaning 

5% of the volatile organic compounds in the ink is emitted dUring the printing 

process. 

47.6.7.1.3 A 50% volatile organic compounds retention factor shall be used for 

cleaning solution vac in shop towels for cleaning solutions with a volatile 

organic compounds composite vapor pressure of no more than 10 mm of 

mercury (Hg) at 20"C (68"F) if the contaminated shop towels are kept in closed 

containers, meaning 50% ofthe vac used on the shop towels is emitted 

during the cleaning process. 

47.6.7.2 A par/ion of the volatile organic compounds contained in inks, fountain 

solutions, and automatic blanket washes on heatset presses is captured in Ihe 

press dryer for control by add-on pollulion control devices. Capture efficiency 

testing for heatset dryers is not reqUired if it demonstrated that pressure in the 

dryer is negative relative to the surrounding press room and the airflow is into the 

dryer. Continuous dryer air flow monitoring is not required. The following capture 

efficiencies are to be used: 

47.6.7.2.1 A 100% volatile organic compounds carry over efficiency shall be used 

for inks. All the volatile organic compounds in the ink that is not retained is 

assumed to be volatilized in the press dryer. 

47.6.7.2.2 A 70% volatile organic compounds carry over efficiency shall be used 

for fountain solutions containing alcohol substitutes. 

47.6.7.2.3 A 40% volatile organic compounds carry over efficiency shall to be used 

for automatic blanket wash solutions with a vac composite vapor pressure of 

no more than 10 mm of mercury (Hg) at 20"C (68"F). 

[DAQ's responses to Comments on Proposed Section: 

The DAQ wants to make it clear that in its previous responses, it did not state that 

"no studies have shown that VOCs from ink are retained in substrates." The exact 

statement is that there is "no convincing studies showing that the retained VOC on 

substrates would not emit after printing processes. .. This was why the DAQ did not 

agree to add the same section proposed by the GAA in its comment letter ofJune 2, 

2010. The DAQ stands on the same ground at this point. 

When convincing evidence becomes available, the DAQ will consider revising 

Section 47. aaccordingly. The GAA will be informed at that time, and welcome to 

provide the same and addition comments. 

20 
The DAQ did not indicate at any point in its previous responses that the use of 

retention and emission factors would be "left to the discretion ofthe permit writer, 

who mayor may not befamiliar with the retention factors and the DAQ's approval 

oftheir use." The DAQ 's permitting staffwill work closely with the regulation 

development staffto take consistent actions on relevant issues, including use of 

retention and emission factors for its emission inventory, control device efficiency, 

and emission fee, etc. 

Therefore, DAQ recommends that the GAA 's proposed section be not added to the 

proposed Section 47.0.] 

21 
7 DE Admin Code 1124 "Control of Volatile 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--AeAReatset 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 of 47.0 of this regUlation]. 

47.1.2	 Transition 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 of 47.0 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 of 47.0 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 seeA as 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.§i Any facility that becomes or is currently subject to the prOVisions of 47.0 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 subject to these provisions, even if its throughput or emissions have fallen or later 

fall below the applicability threshold. 

1 
47.2	 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 of this regulation. 

"Alcohol" means a chemical compound consisting of the 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 of water or to prevent piling (ink build-up). 

"Batch" means a supply of fountain 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 of the 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 of the 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 or web. 

"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 of 2g 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 of this 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 

3 
47.3.2.1.2	 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 el alseRel ~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 el VOCs 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 of an 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 Ww W. WI --+--+L.,-­ MW. MW. ,_. MW, 

(47-1) 

Where: 

W; = Weight of the 1tIl-[': vae compound, in grams (g);
 

Ww = Weight of water, in g;
 

We = Weight of exempt compound, in g;
 

MW; = Molecular weight of the 1tIl-[': vae compound, in grams per gram-mole
 

4 
MWw = Molecular weight of water, in 

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

PPc = vac composite partial pressure at 20'C, in mmHg 

VP; = Vapor pressure of the 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 of this 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 of this 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 of this 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 of this regulation, the owner or operator 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 of the fountain 

5 
solution 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 of this 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 

6 
threshold 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 of 47.0 of this 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 of the 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 of 47.0 of this 

regulation because of the 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 of the 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 

of five 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 of VOGs 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 

7
 
the 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 of the 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 of capture 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 of the 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 

of five 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 of voes per volume of coating solids and the volume of solids 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 of this 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 of the incoming water. 

47.6.4.4	 If, through recordkeeping for a period of 6 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 of time upon prior approval by the Department. 

47.6.5	 Requirements for monitoring fountain solution temperature. On and after [insert the 

effective date of this revision of 47.0 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 of the 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. 

9 
47.6.6	 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 of 47.3.3 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 of this regulation, if applicable. 

47.6.7,5	 For manual cleaning methods, the amount of cleaning solution and the amount of 

water added per batch of cleaning 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 of 47.4 or 47,5 of this regulation, occur, 

10