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 of Volatile Organic 

Compound Emissions from Offset Lithographic 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 

printing (7 DE Admin Code 1124, 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 Lithographic Printing and Letterpress Printing, EPA453/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 Lithographic 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 lithographic printing industry. (See docket 

EPA-HQ-OAR-2006-0536). In September 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 2010 to reflect the new requirements in EPA’s 2006 CTG. 

DNREC’s revision to Section 47.0 expanded the control of VOC emissions to include letterpress 

printing presses.
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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 types of inks and cleaning materials used, the sources 

of VOC emissions, and the controls available to address those emissions.

The title of Section 47.0 was amended to add “and Letterpress Printing.” This SIP revision 

applies to any offset lithographic or letterpress printing press. The owner or operator of any 

offset lithographic or letterpress printing press shall comply with the provisions of Section 47.0 

on and after April 11, 2011 (effective date of this SIP revision). Except for existing permitted 

sources, a one-year transition period for facilities to comply with the new requirements is 

specified.

Definition of “letterpress printing” was added and “dampening system” was deleted. The 

following definitions were amended: (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 printing 

operations, including VOC emissions from cleaning materials and activities.” 

Section 47.0 sets 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 provision, this SIP 

revision sets up a new and more stringent 95 percent reduction standard for those control systems 

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 technical 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 unspecified 

temperature monitoring devices for control systems; that is, at the outlet of the control device or 

at a location approved by PADEP and EPA.

C. EPA EVALUATION

This regulation 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.
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D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION

Amendments to the control of VOC emissions from offset lithographic printing and letterpress 

printing (7 DE Admin Code 1124, Section 47.0) adopted by the State of Delaware will result in 

the reduction of VOC emissions from the affected sources. Section 47.0 meets the applicable 

requirements of the CAA and the applicable EPA regulations, guidance and policy and can be 

approved. This SIP revision will help Delaware in attaining compliance with the 8-hour ozone 

NAAQS.

EPA’s approval of the SIP revisions is recommended.