Printreg Archive
Re: MACT for Flexographic Printing


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From: DAVE SALMAN (SALMAN.DAVE@epamail.epa.gov)
Date: Thu Mar 18 1999 - 08:20:21 CST


Vrajesh - You are right on target about the web width being
important for something to qualify as wide-web flexo printing in the
printing MACT rule. One item we are considering adding to the
rule is an option that allows the printer to choose to include narrow
web flexo presses in the affected source. Some printers might want
to do this for recordkeeeping simplicity - it is easier to include the
materials used on narrow web presses when assessing
compliance for the affected source than it is to have to subtract them
out from the total used on all presses.

Gary - I do not know if the wording is important, but I would not
describe the optional area source provision, or the ancillary printing
equipment provision, or even the incidental printing operation
provisions as compliance options. I think of them more as
applicability provisions.

Your descriptions of the ancillary and incidental provisions are a little
off.

Ancillary applies to a single "press". An ancillary piece of
equipment is one for which each month the mass of material
applied by rotogravure printing plus the mass of material applied by
wide-web flexo printing is less than or equal to 5 percent of the total
mass of material applied. See 63.821(a)(2)(ii). Note that in
63.821(a)(2)(ii)(A) it should say "product and packaging rotogravure
print stations" instead of "product and packaging rotogravure work
stations".

Incidental applies to the entire affected source (i.e., all of the
presses). An affected source is an incidental printing operation if
every month no more than 500kg of material are applied (total on all
of the presses in the affected source) or no more than 400kg of HAP
are applied (total on all of the presses in the affected source.) See
63.821(b) and (c).

With regard to area sources there are two choices. First, a facility
can establish and maintain itself as an area source by using the
optional area source provision in the rule. See 63.820(a)(2) through
(6).

Second, the facility can establish and maintain itself as an area
source through any legitimate mechanism available through the
permitting authority. See 63.820(a)(7). These mechanisms can
range from max. theoretical potential to emit, to permit by rule or
prohibitory rule, to FESOP, to conditions in a title 5 permit that the
facility needs because it is major for some pollutant other than
HAPS (e.g., for VOC). One key point about using a mechanism
available from the permitting authority is that the agreement must be
in place (i.e, issued by the permitting authority) before the
compliance date of the rule.

Dave Salman
US EPA
tel 919 541 0859
e-mail salman.dave@epa.gov

>>> Vrajesh Patel <PATELV@state.mi.us> 03/17/99 11:29am >>>
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").

>>> <gjonesprinting@aol.com> 03/17 8:52 AM >>>
Dear Patel:

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.

Gary Jones
GATF

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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