SUBJECT: Technical Support Document for the Incorporation of EPA’s Control Techniques

Guidelines for Offset Lithographic Printing and Letterpress Printing into the Codeof Maryland

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A. Background

Section 1 72(c)( 1) ofthe Clean Air Act (CAA) requires that state implementation plans (SIPs)

contain reasonably available control measures (RACM) which includes reasonably availablecontrol technology (RACT). Section 1 82(b)(2)(A) provides that for certain nonattainment areas,

States must revise their SIPs to include RACT for sources of volatile organic compound (VOC)

emissions covered by a control techniques guidelines (CTG) document issued after November

15, 1990 and prior to the area’s date of attainment. RACT is defined as “the lowest emission

limitation that a particular source is capable ofmeeting by the application of control technology

that is reasonably available considering technological and economic feasibility.” (44 FR 53761,

Sept. 17, 1979). Under the CAA, the Environmental Protection Agency (EPA) is required to

provide control technique guidelines (CTG); these guidelines provide states and agencies

involved in air quality control information on air pollution control techniques. Section 183(e) of

the CAA directs EPA to list for regulation categories of products that account for at least 80percent of volatile organic compound (VOC) emissions (on a reactivity-adjusted basis) from

consumer and commercial products in areas that violate the national ambient air quality standard(NAAQS) for ozone. Offset lithographic printing and letterpress printing are included on thecurrent section 183(e) list. Although offset lithographic printing and letterpress printing are two

distinct product categories on the section 183(e) list they have many similarities and areaddressed in one CTG.

In September 2006, EPA published a CTG for Offset Lithographic Printing and LetterpressPrinting titled Control Technique Guidelinesfor Offset Lithographic Printing and Letterpress

Printing (Publication No. EPA-453/R-06-004). This CTG is similar to the draft CTG for offset

lithographic printing and letterpress printing published on November 8, 1993. In June 1994,
Offset Lithography is a planographic method of printing. Planographic means that areas meant

for printing and areas not meant for printing are located on the same plane of a thin lithographic

metal plate. Since printing occurs on the same plane, the image area is rendered oil receptive

and the non-image area is rendered water receptive. Lithographic printing is an indirect printing

method, the ink is not directly transferred to the substrate; instead, the ink is transferred from thelithographic plate to a rubber-covered, intermediate “blanket” cylinder. The ink is then

transferred from the cylinder to the substrate. Offset lithographic printing is utilized in the

production of books, magazines, periodicals, labels and wrappers, catalogs and directories,

financial and legal documents, business forms, advertising brochures, newspapers, newspaperinserts, charts and maps, calendars, tickets and coupons, greeting cards and stamps. There are

two types of lithographic printing presses characterized by how the substrate is fed to the press.

In sheet-fed printing, individual sheets ofsubstrate or paper are fed to the press while during web

printing, continuous rolls ofsubstrate are fed into the press and are resized afterwards.

Letterpress printing operates similarly to lithographic printing. VOC emissions from either of

the two methods of printing can occur from the evaporation ofinks, fountain solutions, cleaningmaterials and other materials such as varnishes, glues and coatings.

C. EPA’s Recommended Control Options for Lithographic Printing and Letterpress

Printing

EPA issued a CTG for offset lithographic and letterpress printing in 2006. As stated above,

VOC emissions can occur from the evaporation of inks, fountain solutions, cleaning materialsand other materials such as varnishes, glues and coatings. Mainly, there are three mechanisms to

reduce VOC emissions from offset lithographic and letterpress printing; the three mechanisms

are add-on controls, process modifications or work practices and material reformulation and

substitution.

For the control of VOC emissions from heatset inks, fountain solutions, and cleaning materials

used in offset lithographic printing operations and letterpress printing operations, EPA’s

recommendations are as follows:

1. Heatset web offset lithographic and heatset letterpress inks and dryers

The recommended level of control for VOC emissions from heatset dryers is tied to the

first installation date ofthe control device. The first installation date for the control

device does not change if it is later moved to a new location. The first installation date

for a control device does not change ifit is later used to control a new press.

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heatset web offset lithographic printing presses with potential to emit from the dryer,

prior to controls, at least 25 tons per year (tpy) of VOC (petroleum ink oil). It is alsorecommended to apply the above recommended levels of control to individual heatsetweb letterpress printing presses with potential to emit from the dyer, prior to controls, at

least 25 tpy of VOC (petroleum ink oil). It is recommended to provide printers with theoption of using an enforceable limitation on potential emissions to keep an individual

heatset press below this 25 tpy potential to emit threshold. This equates to using inks and

coating which contain less than 31.25 tpy VOC (petroleum ink oil) because ofthe 20

percent ink oil retention. It is also recommended that heatset presses used for bookprinting and heatset presses with maximum web width of 22 inches or less be excluded

from the add-on control recommendations.

It is not recommended that VOC emissions from sheet-fed or coldest web inks, sheet-fed

or coldest web varnishes, waterborne coatings or radiation (ultra-violet light or electron

beam) cured materials used on offset lithographic presses or letterpress presses be

controlled. The VOC emissions from these materials are already low and they are notamenable to add-on control.

2. Fountain Solution

a. Heatset Web Offset Lithographic Printing

The recommended level of control for VOC emissions from on-press (as-applied)fountain solution for heatset web offset lithographic printing is 1.6 percent alcohol

(by weight) in the fountain or its equivalent. There are three approaches to

achieving this recommended level of control. First, the on-press (as-applied)alcohol content is reduced to 1.6 percent alcohol or less (by weight). Secondly, 3

percent alcohol or less by weight on-press (as-applied) in the fountain solution ifthe fountain solution is refrigerated to below 60 °F (15.5°C). Thirdly, 5 percent

alcohol substitute or less (by weight) on-press (as-applied) and no alcohol in thefountain solution can be used.

b. Sheet-fed Offset Lithographic Printing

The recommended level of control for VOC emissions from on-press (as-applied)fountain solution for sheet-fed printing is equivalent to 5 percent alcohol (by

weight) in the fountain or equivalent. There are at least three different approachesfor achieving this recommended level of control. The first approach involves

reducing the on-press (as-applied) alcohol center to 5.0 percent alcohol or less (byweight). The second approach involves using 8.5 percent alcohol or less (byweight) on-press (as-applied) provided the fountain solution is refrigerated to

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coldest web is 5 percent alcohol substitute or less (by weight) on-press (asapplied) and no alcohol in the fountain solution.

It is recommended applying control recommendations for offset lithographic printing fountain

solution to any offset lithographic printing operations where the emissions associated with all

aspects ofthat operation equal or exceed 6.8 kilograms per day (kg/day) or 15 pounds per day(lb/day) actual emissions of VOC, or an equivalent level, before consideration of controls. It is

also recommended that these control recommendations for fountain solution not be applied tosheet-fed presses with maximum sheet size 1 lxi 7 inches or smaller, or to any presses with

maximum sheet size lix17 inches or smaller, or to any press with total fountain solutionreservoir ofless than 1 gallon. For these presses, the recommended VOC (alcohol or alcohol

substitute) content levels would yield a small emission reduction relative to the cost of achieving

that reduction (e.g., changing and maintaining rollers).

3. Cleaning Materials

The following recommendations apply to blanket washing, roller washing, plate cleaners,

metering roller cleaners, impression cylinder cleaners, rubber rejuvenators, and other

cleaners used for cleaning a press, press parts, or to remove dried ink from areas around a

press. EPA recommends that when States develop RACT rules in response to the

Industrial Cleaning Solvents CTG, see EPA 453/R-06-00l (Sept. 2006), they consider

excluding from those rules the activities noted in the prior sentence, which are covered by

this CTG. See 71 FR 44540. In addition, the recommendations for cleaning materialsprovided below do not apply to cleaners used on electronic components of a press, prepress cleaning operations (e.g., platemaking), post-press cleaning operations (e.g.,binding), cleaning supplies (e.g., detergents) used to clean the floor (other than dried ink)

in the area around a press, or cleaning performed in parts washers or cold cleaners.

It is recommended to use cleaning materials with a VOC composite vapor pressure less

than 10 millimeters of mercury (mmHg) at 20 °C or cleaning materials containing lessthan 70 weight percent VOC. It is believed that this combination ofmaterialrecommendations will reduce VOC emissions and allow for use of a mix ofmaterials

capable of achieving all ofthe covered cleaning tasks. Cleaning materials with low VOCcomposite vapor pressure have been used successfully by many printers for blanket

washing and other cleaning activities. Many ofthe cleaning tasks that cannot be carriedout with low VOC composite vapor pressure cleaning materials can be carried out with

reduced VOC content cleaning materials. It is also recommended to exclude 110 gallonsper year of cleaning materials which meet neither the low VOC composite vapor pressurerecommendation not the lower VOC content recommendation because a small number of

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percent of VOC.

It is recommended that the above control recommendations for offset lithographic

printing cleaning materials be applied to any offset lithographic printing operation where

emissions associated with all aspects ofthat operation equal or exceed 6.8 kg/day (15lb/day) actual emissions of VOC, or an equivalent level, before consideration of controls.

Similarly, it is recommended to apply the above control recommendations for letterpress

printing cleaning materials to any letterpress printing operation where the emissions

associated with all aspects ofthat operation equal or exceed 6.8 kg/day (15 lb/day) actual

emissions of VOC, or an equivalent level, before consideration of controls.

B. STATE SUBMITTAL

On December 16, 2011, EPA received a SIP revision from the Maryland Department ofthe

Environment (MDE) regarding the adoption ofEPA’s CTG for offset lithographic and letterpress

printing. EPA develops CTGs as guidance for control requirements for source categories. States

can follow the CTG or adopt more restrictive standards. COMAR 26.11.19.11 was revised toincorporate EPA’s CTG for offset lithographic and letterpress printing. Maryland has had

requirements for lithographic printers since 1991. The regulations pertaining to theserequirements have been adopted into Maryland’s SIP. Section 172(e) ofthe CAA states thatregulations adopted into SIPs cannot be made less stringent. Hence some parts of Maryland’srequirements in COMAR 26.11.19.11 are more stringent than the 2006 CTG for offset

lithographic and letterpress printing. The revision to COMAR 26.11.19.11 regarding the

aforementioned submittal is neither more restrictive nor more stringent than the 2006 CTG foroffset lithographic and letterpress printing.

Several revisions have been made to COMAR 26.11.19.11; these revisions include revisions to

the title and Sections A-E, as well as the addition of Sections F-H. The title of COMAR

26.11.19.11 previously read “Lithographic Printing,” the phrase “and Letterpress” was added so

the title currently reads “Lithographic and Letterpress Printing.” The definitions of fountain and

sheet-fed coating have been removed from Section COMAR 26.11.19.11(A) and the definitions

of the following terms have been added: alcohol, alcohol substitute, cleaning solution, fountain

solution, heatset, sheet-fed printing and web printing.

The title of Section COMAR 26.11.19.11(B) has been changed from “Applicability” to“Exemptions.” Also, the section has been changed to exempt heatset presses used for book

printing and heatset presses with a maximum web width of 22 inches from Section E ofthis

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The title of Section COMAR 26.11.19.11(C) has been changed from “Requirements for SheetFed Letter or Lithographic Printing. A Person May Not Operate a Sheet-Fed Letter or

Lithographic Printing Press with a Cylinder With of 18 inches or Greater Unless” to“Requirements for Sheet-Fed Lithographic Printing Press. A Person May Not Operate a SheetFed Lithographic Printing Press With a Cylinder Width of 18 inches or Greater of with a Sheet

Size of Greater than 11 Inches by 17 Inches Where the Fountain Solution Contains Alcohol

Unless.” The provision requiring that the fountain solution be maintained at 55 °F ifthe solution

is that of isopropyl alcohol was removed. There were also some administrative changes made

such as changing the word “installed” to “used” and adding the word “fountain” before solution

as well removing the phrase “ifthe solution is refrigerated” and the word “isopropyl” from in

front ofthe word alcohol.

The title of Section COMAR 26.11.19.11(D) has been changed from “Requirements forLithographic Web Printing. A Person Who Owns or Operates a Lithographic Web Printing Press

Subject to this Regulation” to “Requirements for Lithographic Web Printing.” The regulation

was also revised to require the use of a fountain solution that does not contain more than 5

percent VOC content by weight and does not contain alcohol for any owner or operator of a nonheatset lithographic web printing press. The revision also calls for all lithographic web printing

presses with VOC emissions of less than 100 pounds per day use a fountain solution that

contains no more than 5 percent VOC by weight and no alcohol. Under the revision, any owneror operator of a heatset lithographic web printing press with VOC emissions of 100 pounds per

day or more shall use a fountain solution that meets the requirements for lithographic web

printing presses with VOC emissions of less than 100 pounds per day. The revision also requiresthat heatset lithographic web printing presses only operate ifthe dryer exhaust is ducted to an air

pollution control device (APCD) that can be operated at a control efficiency of 90 percent or

greater.

The title of Section COMAR 26.11.19.11(E) has been changed from “Requirements for CleaningPrinting Equipment. A Person Who Uses Materials Containing VOC to Clean PrintingEquipment Shall” to “A Person Who Owns or Operates a Heatset Lithographic Press or Heatset

Letterpress with a Potential to Emit VOC of 25 Tons or More Per year Prior to Controls Shall

Operate the Press Only ifthe Dryer Associated with the Press Is.” The revision requires that the

dryer be constructed, operated and maintained at a negative pressure with respect to the press

room. Also, the ducted APCD is required to have an outlet VOC concentration of 20 parts permillion by volume (expressed via hexane on a dry basis) or less or have a VOC control

efficiency of 90 percent or greater ifthe APCD was installed prior to July 1, 2011 or have a VOC

control efficiency of 95 percent or greater ifthe APCD was installed after July 1, 2011.

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Section COMAR 26.11.19.11(G) was added to COMAR 26.11.19.11, this section is titled

“Control Device Testing.” This revision requires that a control device be tested in accordance

with the requirements set by COMAR 26.11.19.02. It is also required that negative dryer

pressure and 100 percent emission capture efficiency be demonstrated by utilizing air flow

direction indicators, such indicators can be smoke sticks, aluminum ribbons or differential

pressure gauges.

Section COMAR 26.11.19.11(H) was added to COMAR 26.11.19.11, this section is titled

“Record Keeping. A Person Subject to this Regulation Shall Maintain Records on Site Including

the Following Information.” This section requires that the following records be maintained on

site and include the following information: the formulations ofthe fountain solutions utilized, the

VOC content ofthe fountain solutions in percent weight of VOC, the temperature ofthe pressfountain solutions for lithographic printing presses utilizing fountain solutions containing alcoholas well as the quantity of cleaning solutions utilized and their vapor pressure or VOC content by

weight.E. EPA EVALUATIONThe State of Maryland has adopted the EPA CTG standards for offset lithographic and letterpress

printing and is amending the Maryland SIP to reflect this adoption. The maximum benefit fromthe adoption ofthe aforementioned CTG will be provided during the ozone season when VOCsreadily combine with nitrogen oxides (NO) to form ground-level ozone. It is estimated thatVOC emissions in the State of Maryland would be reduced by 0.08 tons/day. Therefore, thisrevision will help Maryland attain and maintain the National Ambient Air Quality Standards

(NAAQS) for ozone.

F. CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The adoption ofthe EPA CTG standards for offset lithographic and letterpress printing by the

State of Maryland will result in the reduction of VOC emissions from lithographic and letterpress

printers. It is recommended that EPA approve the adoption ofthe EPA CTG standards for offset

lithographic and letterpress printing by the State of Maryland.

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