From: GaryJGATF (email@example.com)
Date: Thu Jan 08 1998 - 11:12:25 CST
Your question is of applicability of the print MACT for a flexographic is very
timely and pertainent. In reviewing the applicability section of Subpart KK,
the purpose of the standard is to regulate HAP emissions from publication
gravure product/packaging gravure and wide-web flexographic printing
operations. While it covers those operations that both print and coat, it does
not appear to apply to stand-alone coating operations or those units which
only apply coating. If the coating unit in question is only for coating or
stand-alone coating, then it is propably exempt. EPA has not issued any
guidance on this question and you should contact Dave Salman at 919/541-0859.
In addition, you did not say if the matierals used to coat contained any HAPs
and if the facility is a major source. The standard only applies to those
operations using HAPs and are major sources.
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