From: Vrajesh Patel (PATELV@state.mi.us)
Date: Wed Mar 17 1999 - 10:29:59 CST
Thank you for your response. My question was related to record keeping procedure. Also, I believe beside the HAP (10 HAP and 25 HAPs) issue the length of web width makes flexographic printing process subject to MACT (> 18").
>>> <email@example.com> 03/17 8:52 AM >>>
It is not clear from your question what information your are seek. However, to
provide a response to what I think your question is, the following summary of
the MACT rule should help answer your question. If you have a more specific
information need, please let me know.
In order for the MACT rule to be applicable to a flexographic printing
operation, the facility has to first be considered a major source for
hazardous air pollutants (HAPs). This means that their actual or potential
emissions exceed either the 10 TPY threshold for a single HAP or 25 TPY for
all HAPs combined.
The Printing and Publishing rule has four compliance options. The first
involves taking agreeing to limit emissions to qualify as an area source,
which means single HAP emissions of less than 10 TPY and 25 TPY for all HAPs
combined. The next two options involve having the entire flexographic line to
either qualify as an incidental or ancillary printing unit. The threshold for
incidental printing is tied to the consumption of inks, coatings, adhesives or
other materials. If the entire press/bindery line uses less than a total of
500 kilograms/month (227 LB/MO) of inks, coatings, adhesives or other
materials, then it would be considered an incidental operation.
The ancillary threshold is tied to the amount of HAP emissions from all of the
input materials. The emission threshold is 400 kilograms/month (182 lbs/mo).
If the emissions are less than 400 kilograms/month, then the operation
qualifies as ancillary operation. There are specific recordkeeping
requirements for the first three options.
The last option, full compliance, has three separate approaches. The first is
to achieve a 95% overall reduction in HAP emissions through the use of capture
and control systems. The 95% overall requirement will mostly likely entail the
use of a total enclosure with all of the air in it ducted to an afterburner.
Another option is to use materials with a HAP content of 0.2 kilogram/kilogram
(0.2 lb/lb) of solids or 0.04 kilogram/kilogram (0.04 lb/lb) of materials
applied. The final full compliance option would be use a combination of low
HAP containing materials in conjunction with a capture and control system.
Under this option the HAP emissions cannot exceed 0.2 kilogram/kilogram (0.2
lb/lb) of solids applied.
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