R 336.1635
R 336.1635 Emission of volatile organic compounds from existing offset lithographic and letterpress printing lines in 2015 ozone nonattainment areas.
Cite as Mich. Admin. Code R 336.1635
Rule 635. (1) As used in this rule:
(a) “Batch” means a supply of fountain solution that is prepared and used without alteration until
completely used or removed from the printing process. Batch applies to solutions prepared in
discrete batches or solutions that are continuously blended with automatic mixing units. A fountain
solution that is continuously blended with an automatic mixing unit is considered to be the same
batch until the recipe or mix ratio is changed.
(b) “Cleaning solution” means liquid solvents or solutions used to remove ink and debris from
the operating surfaces of the printing press and its parts including blanket washes, roller washes,
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 the areas around
a press. Cleaning solution does not include cleaners used on electronic components of a press, pre-
press cleaning operations, post-press cleaning operations, cleaning supplies used to clean the floor
of the area around a press, other than dried ink, or cleaning performed in parts washers or cold
cleaners.
(c) “Letterpress printing line” means all operations of letterpress printing processes characterized
by the image area being raised relative to the nonimage area and including, but not limited to, pre-
press and post-press operations that support the activity. Varnishes, glues, and other coatings that
are applied by a letterpress printing process are part of the letterpress printing operations and are
not considered as a separate process, for example, paper coating.
(d) “Non-heatset” means a lithographic printing process where the printing inks are set without
the use of heat and dry by absorption or oxidation, or both. For the purposes of this rule, use of an
infrared heater or printing conducted using ultraviolet-cured or electron beam-cured inks is
considered non-heatset.
(e) “Offset lithographic printing line” means offset printing presses characterized by a
planographic plate where the image and nonimage area are in the same geographical plane and the
related processes necessary to directly support the operation of those offset lithographic printing
processes including, but not limited to, pre-press and post-press operations. Varnishes, glues, and
other coatings that are applied by an offset lithographic printing process are part of offset
lithographic printing operations and are not considered as a separate process, for example, paper
coating.
(f) “Printing process” means any equipment, operation, or system where printing ink or a
combination of printing ink, surface coating, or adhesive is applied, dried, or cured. A printing
process may include any equipment that applies, conveys, dries, or cures inks or surface coatings
including, but not limited to, presses, digital output devices, fountain solutions, heaters, and dryers.
(2) A person shall not cause or allow the emission of any volatile organic compound from an
offset lithographic and letterpress printing line located in the 2015 ozone nonattainment area, in
excess of the applicable emission rates indicated in the following subrules, unless all of the
applicable provisions of the following subrules are met.
(3) Except as provided in subrule (6) of this rule, the provisions of this rule do not apply to the
following:
(a) All offset lithographic and letterpress printing operations, including cleaning activities,
before consideration of controls, that have volatile organic compound emissions less than or equal
to 3 tons per rolling 12-month period. If the actual rate of the emissions from an exempted cleaning
operation exceeds 3 tons per 12-month rolling period for any subsequent 12-month rolling period,
then the provisions of this rule permanently apply to the operations at that facility for as long the
applicable equipment is in operation.
(b) One hundred and ten gallons of cleaning materials per rolling 12-month period used at the
stationary source.
(c) The fountain solutions of sheet fed offset lithographic presses with a sheet size of 11 by 17
inches or smaller.
(d) The fountain solutions of any offset lithographic press with fountain solution reservoirs
totaling less than 1 gallon.
(e) A person operating an offset lithographic and letter press printing line may exclude low-use
inks or coatings that total 55 gallons or less per rolling 12-month period at a stationary source from
the provisions of this rule, except for subrule (6) of this rule.
(f) The following operations are exempt from add-on control requirements described in subrule
(4) of this rule:
(i) Any heatset web offset lithographic press or heatset web letterpress with potential volatile
organic compound emissions less than 25 tpy before control from the dryer.
(ii) Any heatset web offset lithographic press or heatset web letterpress that is limited through a
federally enforceable permit to actual volatile organic compound emissions from the dryer less
than 25 tpy from the dryer.
(iii) Any heatset presses used for book printing or heatset presses with a web width of 22 inches
or less.
(4) A person shall not cause or allow the emission of any volatile organic compound from an
existing offset lithographic or letterpress printing line, unless the following provisions are met or
unless an equivalent control method, as approved by the department under R 336.1602(2), is
implemented:
(a) Except as described in subrule (3) of this rule, a control system is required for dryer operations
of heatset web offset lithographic printing and heatset web letterpress printing operations. Each
dryer must meet 1 of the following control requirements:
(i) 90% control efficiency for dryers installed before the effective date of this rule.
(ii) 95% control efficiency for dryers installed after the effective date of this rule.
(iii) Maintain a maximum outlet concentration of volatile organic compounds of 20 ppmv as
hexane on a dry basis.
(b) The fountain solution used in a heatset web offset lithographic printing line has a volatile
organic compound content that meets 1 of the following requirements:
(i) The fountain solution, as applied, must be at or below 1.6% alcohol by weight.
(ii) If refrigerated to below 60 degrees Fahrenheit, the fountain solution, as applied, must be at
or below 3% alcohol by weight.
(iii) The fountain solution, as applied, must contain 5% or less of alcohol substitute and no
alcohol.
(c) The fountain solution used in a sheet-fed offset lithographic printing line must have a volatile
organic compound content that meets 1 of the following requirements:
(i) The fountain solution, as applied, must be at or below 5% alcohol by weight.
(ii) If refrigerated to below 60 degrees Fahrenheit, the fountain solution, as applied, must be at
or below 8.5% alcohol by weight.
(d) Nonheatset web offset lithographic printing press must be less than 5% alcohol substitute by
weight on press and no alcohol in the fountain solution.
(e) The cleaning solutions used with printing lines subject to this rule must meet 1 of the
following requirements:
(i) The cleaning solutions must have a volatile composite vapor pressure of less than 10 mm Hg
at 20 degrees Celsius or be less than 70% volatile organic compound by weight.
(ii) All cleaning materials and used shop towels must be kept in closed containers.
(5) Compliance with the emission limits specified in this rule must be based upon all of the
following provisions, as applicable:
(a) Compliance with required control efficiency limits must be determined by performing
emission tests in accordance with a stack testing protocol approved by the department.
(b) Compliance with the emission limits specified in subrule (4) of this rule must be based upon
all volatile organic containing compounds used during each calendar month by using
manufacturers’ formulation data, United States Environmental Protection Agency method 24
analysis, safety data sheets, an alternate method, or combination of the methods stated within this
subdivision, as approvable by the department and in sufficient detail to demonstrate compliance
with the limitations described in subrule (4) of this rule.
(c) If more than 1 control option or emission limit listed in subrule (4) of this rule is used on a
printing line, then compliance must be determined separately for each option used and be based
upon all materials used for each option during each period.
(6) For the purpose of this rule, recordkeeping for all requirements and applicability
demonstrations must be maintained in sufficient detail to demonstrate compliance with all
applicable standards of the rule. Records must include, but are not limited to, the following:
(a) The volume and volatile organic compound content of each alcohol and alcohol substitute
added to make the batch of fountain solution, based upon the approvable method described in
subrule (5)(b) of this rule.
(b) The calculated volatile organic compound content of the final, mixed batch of solution, as
applied.
(c) All cleaning solutions employed in all the offset lithographic and letterpress printing
operations and quantities and volatile organic compound contents as necessary to demonstrate
compliance with subrule (4) of this rule.
(d) Monthly volatile organic compound emissions and materials usage as needed to demonstrate
the emissions are below thresholds described in subrule (3) of this rule.
(e) Approvable retention factors must be utilized for volatile organic compound content in
absorptive printed substrates and shop towels used in cleaning and used in emission calculations
and control efficiencies. For the purposes of determining VOC emissions from these operations,
the following retention factors may be used if not otherwise established by the department:
(i) Twenty percent VOC retention for heatset inks printed on absorptive substrates.
(ii) Ninety-five percent VOC retention for sheet fed and non heatset web inks printed on
absorptive substrates.
(iii) Fifty percent VOC retention for cleaning solution in shop towels for cleaning solutions with
a VOC composite vapor pressure of no more than 10 mmHg at 20 degrees Celsius (68 degrees
Fahrenheit) if the contaminated shop towels are kept in closed containers.
(7) Any offset lithographic or letter printing press line that utilizes control requirements to meet
standards in subrule (4) of this rule must have an approvable operation and preventative
maintenance plan. The plan must include, at a minimum, the following, as applicable:
(a) A continuous temperature monitoring and recording system.
(b) A maintenance schedule for all control equipment with spare part list.
(c) A malfunction abatement plan to be implemented in the event of abnormal situations
involving the control equipment.