From: Jeff Adrian (firstname.lastname@example.org)
Date: Tue Apr 27 1999 - 08:15:28 CDT
Re: EPA Method 24A 4/27/99
I would make every attempt you can to have this "requirement" removed from your draft (and final) permit. Simply put, the mechanics of trying to comply with this would tie your company in knots (in terms of production) and would be impossibly costly as w
You need to "re-direct" your permit writer's effort to acertain compliance, perhaps by offering to keep MSDS that provide this VOC content information for the products you use (inks, solvents, wetting agents) readily available on-site. But to require tes
ting of each batch is simply impractical, and for that matter, really does nothing to improve the environment.
Also, when it comes to inks, it should be sufficient to utilize a general MSDS for the type of ink used, and not get drawn into the trap of having an MSDS for each and every color! Lithographic inks, as a group, can be said to generally contain approxima
tely 26% ink oil content (from which you get the VOCs). What's more, given the EPA's allowed substrate rentention factor of 95% of ink oils (VOCs), the remaining 5% times 26% original VOC content leaves just 1.3% VOCs for non-heat-set inks. Not a big dea
When it comes to screen printing, I suggest that you contact Marci Kinter at SGIA for good advice. She can be reached at 703-359-1313.
EPA Method 24 is the current standard for measuring VOC content, although it does have some flaws. Gary Jones of GATF can provide you more information regarding Method 24, or you can review the previous discussions on this method on the PNEAC web site.
Best of luck.
The John Roberts Company
Lovensheimer, Betsy wrote:
>We are Pennsylvania printer using both lithography and screen printing methods.
>We are in the process of getting our Title V permit. The PA DEP has placed a
>condition in our draft permit to "Test each new batch of ink, adhesive and
>solvent for density and VOC content by using EPA Method 24A". I am wondering
>the following of other printers:
>Does anyone else have this condition in their permit (either in PA or other
>If so, who performs the test (supplier or you)?
>What type of costs have you or do you expect to incur due to this requirement?
>What is the difference between Method 24 and Method 24A?
>Can EPA method 24A be performed successfully on Litho Inks and solvents?
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