Printreg Archive
Re: Daily Reporting

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Date: Thu Apr 20 2000 - 13:08:00 CDT


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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