From: Robert Gifford (email@example.com)
Date: Wed Apr 19 2000 - 11:34:11 CDT
Forwarded From "Bruce Goodman" <firstname.lastname@example.org>
Does Rule 624 apply. If so, it requires daily averaging.
One could argue that if all the inks can be shown to be below the
applicable limit, and that therefore the average will be below the
applicable limit, that monthly averaging is "good enough". If Rule 632
applies, however, this variance would need to go to US EPA as a SIP
Revision under Rule 602.
> >>> email@example.com 04/19/00 10:24AM >>>
>A flexo printer is moving equipment into an existing facility in Michigan
>and is being required to calculate VOC emissions on a daily basis by the
>state officials. The plant uses very low VOC inks (also arguing the
>requirement to do Test Method 24/24A as not accurate on low VOC inks). They
>need some citations as to the irrationality of doing daily VOC calcuations
>and acceptance of doing montly calculations.
>Any citations off the top of your collective heads?
>Thanks in advance,
>Doreen M. Monteleone
>Director of Environmental Affairs
>Flexographic Technical Association
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