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printreg, January, 2001
Re: Information on the difference between printing processes


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From:Gary Jones(gjonesprinting@aol.com)
Date:Friday, January 12, 2001 8:37 AM


Pat: After coming across an EPA database, I found a letter from EPA that addresses your question regarding applicability of the Subpart KK standard to lithographic operations. The data base is at http://es.epa.gov/oeca/eptdd/adi.html. The Applicability Determination Index (ADI) is a database that contains memoranda issued by EPA on applicability and compliance issues associated with the New Source Performance Standards (NSPS), National Emissions Standards for Hazardous Air Pollutants (with categories for both NESHAP, Part 61, and MACT, Part 63), and chlorofluorocarbons (CFC). There are also separate categories for asbestos (Part 61, Subpart M) and woodstoves (Part 60, Subpart AAA). Recently issued determinations are added to the database on a quarterly basis. After doing a search under printing and MACT Applicability, this letter was found. Here it is: Determination Detail Control Number: M980048 Category: MACT EPA Office: Region 1 Date: 10/14/1998 Title: Lithographic Presses Recipient: St. Jean, James Author: Kenyon, Michael Comments: Subparts: Part 63, KK Printing and Publishing Industry Abstract: Q. If a facility operates only three lithographic printing presses and does not apply any material using flexographic plates (i.e., plates made out of rubber or other elastomeric material on which the image is raised above the printing plate) and does not apply any material using rotogravure cylinders (i.e., cylinders on which the image is engraved below the surface of the cylinder), is it subject to Subpart KK? A. No. Subpart KK only applies to facilities at which publication rotogravure, product and packaging rotogravure, or wide-web flexographic printing presses as defined in Subpart KK are operated. Letter: October 14, 1998 Mr. James St. Jean Chase Graphics, Inc. 124 School Street Putnam, Connecticut 06260 Re: Applicability to 40 CFR Part 63, Subpart KK, National Emission Standards for the Printing and Publishing Industry Dear Mr. St. Jean: The U.S. Environmental Protection Agency (EPA) has reviewed the letter from Chase Graphics, Inc. (Chase Graphics) received on July 7, 1998 regarding applicability of the National Emission Standard for Printing and Publishing Industry under 40 CFR Part 63, Subpart KK. This letter provides Chase Graphics with a written applicability determination. The July 7, 1998 letter describes the operations at the Chase Graphics facility located in Putnam, Connecticut. In phone conversations with Susan Lancey of my staff on August 10, 1998 and September 14, 1998, you further described the operations at your facility. According to the letter and phone conversations, Chase Graphics operates only three lithographic printing presses. Chase Graphics applies material on these presses using only the lithographic process with pre- finished aluminum lithographic plates (i.e., plates on which the image and non-image areas are on the same plane). Cha! se Graphics does not apply any material using flexographic plates (i.e., plates made out of rubber or other elastomeric material on which the image is raised above the printing plate). Chase Graphics does not apply any material using rotogravure cylinders (i.e., cylinders on which the image is engraved below the surface of the cylinder). Based on the information provided, the presses operated by Chase Graphics are not flexographic or rotogravure presses as defined in Subpart KK because they do not apply any material using either flexographic plates or rotogravure cylinders. Subpart KK applies only to facilities at which publication rotogravure, product and packaging rotogravure, or wide-web flexographic printing presses as defined in Subpart KK are operated. Therefore, EPA has determined that Chase Graphics is not subject to Subpart KK. This applicability determination does not relieve Chase Graphics of responsibility for com! plying fully with any and all applicable federal, state and local laws, regulations and permits. Please note that any changes in the operations at the facility may subject this facility to the standards for Printing and Publishing. If you have any questions about this determination or need further assistance, please contact Susan Lancey of my staff at (617) 565-3587. Sincerely yours, Michael P. Kenyon Associate Director for Air Policy cc: Liz McAuliffe, Connecticut DEP



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