**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III**  **1650 Arch Street Philadelphia, Pennsylvania 19103**  **DATE:** August 18, 2011 **SUBJECT:** Technical Support Document

– State of Delaware

– Control o f Volatile Organic

Compound Emissions from Offset L ith ographic Printing and Letterpress Printing

/s/ **FROM:** Rose Quinto, Environmental Engineer

Office of Air Program Planning **TO:** File /s/ **THRU:** Cristina Fernandez , Associate Director

Office of Air Program Planning **A. BACKGROUND** On May 25, 2011 , the Delaware Department of Natural Resources and Environmental Control (DNREC ) submitted a State Implementation Plan (SIP) revision pertaining to the control of volatile organic compound (VOC) emissions from offset lithographic printing and letterpress p rinting (7 DE Admin Code 1 124, Section 47.0). The purpose of this SIP revision is to conform to the new Control Techniques Guidelines (CTG) issued by Environmental Protection Agency (EPA) in September 2006 (CTG for Offset L ithographic Printing and L etterp ress Printing, EPA 453/R - 06 - 002) . This CTG provides control options to reduce VOC emissions stemming from the use of fountain solutions, cleaning materials and inks in offset lithographic printing, and cleaning materials and inks in letterpress printing. Section 182(b)(2) of the Clean Air Act (CAA) requires all ozone nonattainment areas, including Delaware, to update relevant regulations for reasonably available control technology (RACT) controls for emission sources covered by EPA’s CTG and to submit the regulations to EPA as SIP revisions. Section 47.0 (Offset L ithographic Printing) under 7 DE Admin Code 1124 (Control of VOC Emissions) was originally developed in 1994 after EPA issued a CTG in 1993 for the control of VOC emissions from the offset litho graphic printing industry . (See docket EPA - HQ - OAR - 2006 - 0536). InSeptember 2006, EPA updated its CTG for the offset lithographic printing industry by adding control requirements for letterpress printing operations. DNREC revised Section 47.0 in early 20 10 to reflect the new r equirements in EPA’s 2006 CTG. DNREC ’s revision to Section 47.0 expanded the control of VOC emissions to include letterpress printing presses .2

**B. STATE SUBMITTAL Summary of the SIP Revision**  Delaware’s amendments to Section 47.0 (Offset Lithographic Printing) , add letterpress printing provisions to conform to the new CTG issued by EPA in September 2006 (EPA - 453/R - 06 - 002). This CTG addresses both the offset lithographic printing industry and the letterpress printing industry since they

have similarities in the ty pes of inks and cleaning materials used, the sources of VOC emissions, and the controls available to address those emissions. The t itle of Section 47.0 was amended to add “and L etterpress Printing.” This SI P revision appli es to any

offset lithographic or letterpress printing press . The owner or operator of any offset lithographic or letter press printing press shall comply with the provisions of Section 47.0 on and after April 11, 2011 (effec tive date of this SIP revision). E xcept for existing permitted sources, a one - ye ar transition period for facilities to comply with the new requirements is specified . Definition of “letterpress printing” was added and “dampening sy stem” was deleted. The following definitions were amend ed: (1) cleaning solution

– added “including dried ink, ” (2) lithography

– added “or lithographic printing, ” (3) non - heatset

– added “or coldest, ” (4) offset

– added “lithographic printing,” and (5) total actual VOC emissions added “and letterpress printi ng operations, including VOC emissions from cleaning materials and activities.” Section 47.0 set s up a level of control for VOC emissions from heatset dryers of 90 percent control efficiency

for a control device (1993 CTG). In addition to this provisio n, this SI P revision sets up a new and more stringent 95 percent reduction standard for those control sy stems installed after April 11, 2011. The VOC content of a fountain solution containing alcohol substitutes or non - alcohol additives is established with proper recordkeeping and the manufacturer’s techni cal information of the VOC content of the concentrated alcohol substitute and included in facility

records. Another amendment to Section 47.0 is providing flexibility for facilities to locate unspecifie d temperature monitoring devices for control sy stems; that is, at the outlet of the control device or at a location approved by PADEP and EPA. **C . EPA EVALUATION**  This regu lation will reduce VOC emissions from offset lithographic printing and letterpress printing operations . 7 DE Admin Code 1124, Section 47.0 meets the requirement of a RACT rule for the offset lithographing printing and letterpress printing CTG category .3

**D . CONCLUSION**  **S AND RECOMMENDED AGENCY ACTION** Amendments to the control of VOC e missions from offset lithographic printing and letterpress printing (7 DE Admin Code 1124, Section 47.0) a dopted by the State of Delaware will result in the reduction of VOC emission s from the affected sources. Section 47.0 meets the app licable requirements of the CAA and the applicable EPA regulations, guidance and policy and can be approved. This SI P revision will help Delaware in attaining compliance with the 8 - hour ozone NAAQS. EPA’s approval of the SIP revisions is recommended.