Printreg Archive
Re: Daily Reporting


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From: Bob (bob@ciosys.com)
Date: Thu Apr 20 2000 - 17:24:12 CDT


CIO Systems Inc. has some very inexpensive and easy to use software for
doing VOC calculations. Check out the site at www.ciosys.com .

Mention Printech and get a 10% discout.
----- Original Message -----
From: <gjonesprinting@aol.com>
To: <printech@great-lakes.net>
Cc: <gjonesprinting@aol.com>
Sent: Thursday, April 20, 2000 8:08 AM
Subject: Re: Daily Reporting

> Doreen:
>
> There are several aspects associated with daily recordkeeping that need to
be
> addressed. First and foremost are the regulations that are being imposed
on
> the printer. Is there a requirement within the state regulations that
> requires this short term frequency? From an EPA perspective, they prefer
> short-term monitoring requirements, but for printing and other highly
> variable operations, monthly is acceptable. We have been able to have
monthly
> recordkeeping be accepted within many state rules for printers. EPA has
also
> agreed that monthly recordkeeping is acceptable for printing operations.
The
> latest reference is the MACT standard for printing and publishing at 40
CFR
> 63 and more specifically at 63.829. There are also several general EPA
> guidance documents that address this issue as well.
>
> The other important factor that needs to be considered the technical and
> economic limitations associated with daily recordkeeping. Due to the
nature
> of the type of manufacturing that occurs in the printing industry, daily
> recordkeeping is virtually impossible to perform on an accurate and
> economical basis. The arguments you want to present are included in the
> comments we submitted to EPA in opposition to their interpretation of what
> constitutes a Federally Permitted Release.
>
> Call me if you need the memos oar more information.
>
> Gary Jones
> Graphic Arts Technical Foundation
> 200 Deer Run Road
> Sewickley, PA 15143
> 412/741-6860 x608 - Phone
> 412/741-2311 - Fax
>


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