| 12.21.98 In July 1998, the New Jersey Department of
Environmental Protection (NJDEP) issued the State-of-the-Art (SOTA) guidance for printing
operations. SOTA is a term representing a concept that new printing presses must adopt the
best technology available that will result in the lowest amount of air pollution
emissions. SOTA is required by legislation passed in 1995 by New Jersey.
Development of the requirements in the SOTA manual began
in January 1997, when the NJDEP released an initial draft. Since then, a series of
meetings with representatives of the Graphic Arts Association, Association of Graphic
Communications, GATF, other industry trade groups, printers, and the NJDEP led to a
significantly revised final draft reflecting virtually all the revisions requested by the
printing industry.
SOTA is triggered when two conditions are met. The first
condition requires air pollution permits for printing presses that use more than one-half
gallon of ink per hour. Once this threshold is exceeded, SOTA is required when the
potential emissions of either VOCs or hazardous air pollutant (HAP) emissions exceed five
tons per year. Potential emissions are determined as a function of the permit application,
as the applicant provides data indicating operation (e.g., hours per year), throughput
(e.g., impressions per hour), and material data (e.g., ink and coating type, VOC/HAP
content of inks, coatings, cleaning solutions, and coverage) - all of which determine
potential emissions.
After triggering both of the thresholds for a printing
press or press line, SOTA requires that one of two approaches be adopted. The first and
most preferable would be to use compliant materials that meet certain VOC content limits.
The SOTA guide contains limits for specific input materials. If process materials that do
not meet the limits in the SOTA manual are required, then the press will have to be
equipped with a capture and control system. The SOTA manual states that a capture system
must capture 100% of the emissions generated by the press and destroy them at an
efficiency of 95%. If an oxidizer is to be used as the add-on control device, then it must
meet a design destruction efficiency of 99% but only demonstrate 95% actual destruction
efficiency. In terms of overall control efficiency, these two requirements mean a press
using a control device must demonstrate an overall destruction/reduction efficiency of
95%.
If a printer is unable to meet either
approach, then a case-by-case review of the specific control technology that will be used
to reduce the emissions is permitted. It’s important to pay attention to this
state-specific guidance because other states that have not yet published such guidelines
often look to published ones as models. For a summary of the requirements in the SOTA
manual, contact Gary Jones at 412-741-6860, ext. 608, or visit the following website: www.state.nj.us/dep/aqpp/sota.html. |
