In the initial analysis,
it seemed that litho printing operations were not subject to the Paper and Other Web
Coating or Printing and Publishing MACTs, as EPA had excluded litho operations during
development of the rules. Since a recent EPA interpretation on this subject, it appears
that under certain circumstances either or both rules can apply.
In order for the either rule to be applicable, a facility must first be considered a
major source for HAPs because its potential emissions exceed either the 10 tpy threshold
for a single HAP or 25 tpy for all HAPs combined. Once a facility is classified as a major
source, then the application of any coating or printing with a flexo, gravure, or other
application unit performing printing or coating will pull it into the rule.
At the center of the Printing and Publishing applicability issue is the presence of
either a flexographic or rotogravure printing/coating unit located either in-line with a
press or in a stand-alone bindery line. In-line flexographic coating and printing units
have become very popular with the use of water-based coatings on web and sheetfed presses,
but more so with sheetfed.
According to EPA's recent interpretation, any printing, coating, or adhesive
application that is not full coverage or flood-coated is subject to the Printing and
Publishing rule. For full substrate coverage of ink, coating, adhesive, or other material
application, the Paper and Other Web Coating rule, when developed, will apply. Since most
printers perform flood and spot coating, they will be subject to the requirements of the
Printing and Publishing rule. If a facility is subject to the rule, notification must have
been submitted to the state agency by the end of May 1998.
The Printing and Publishing rule has four compliance options. The compliance options
involve taking limits on HAP emissions of less than 10 tpy threshold for a single HAP or
25 tpy to qualify as an area source-use less than 500 kg/month (227 lb/month) of inks,
coatings, adhesives or other materials to qualify as an incidental operation, or have HAP
emissions less than 400 kg/month (182 lb/month) to qualify as an ancillary operation.
There are recordkeeping requirements for both ancillary and incidental classifications.
The last option, full compliance, has three separate approaches. The first is to
achieve a 95% overall reduction in HAP emissions by using capture and control systems. The
95% overall requirement will mostly likely entail the use of a total enclosure with all
the air in it ducted to an afterburner. Another option is to use materials with a HAP
content of 0.2 kg/kg (0.2 lb/lb) of solids or 0.04 kg/kg (0.04 lb/lb) of materials
applied. The final full-compliance option would be to use a combination of low HAP
containing materials with a capture and control system. Under this option the HAP
emissions can not exceed 0.2 kg/kg (0.2 lb/lb) of solids applied.
The Paper and Other Web Coating rule has a similar applicability requirement in that
the facility must first be a major source for HAPs. Most importantly, the rule applies
only to in-line web operations and not sheetfed presses or bindery equipment. However, it
is not limited to flexo and gravure application methods. Since the rule is not written,
there are no details on control requirements or other requirements which are similar to
the incidental and ancillary printing provisions. EPA has expressed the desire to make the
two rules compatible with each other, as they would pertain to printing operations. GATF
and PIA continue to work with EPA on this development. An attempt is being made to obtain
a full and complete exemption from both rules for lithographic presses or bindery lines
with flexo/gravure application units. For more information, contact Gary Jones at
Author: Gary Jones, PNEAC
GATF Manager, Environmental, Health, and Safety Affairs