oEPA
United States !
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EFA-45O/3-8O-031 b
October 1982
Air
Publication Final
Rotogravure EIS
Printing -
Background
Information for
Promulgated Standards
-------
-------
EPA~450/3-80-031b
Publication Rotogravure Printing -
Background Information
for Promulgated Standards
Emission Standards and Engineering Division
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
October 1982
-------
This report has been reviewed by the Emission Standards and
Engineering Division of the Office of Air Quality Planning
and Standards, EPAS and approved for publication. Mention
of trade names or commercial products is not intended to
constitute endorsement or recommendation for use. Copies
of this report are available through the Library Services
Office (MD-35), U. S. Environmental Protection Agency,
Research Triangle Park, N. C. 27711, or from National
Technical Information Services, 5285 Port Royal Road,
Springfield, Virginia 22161.
PUBLICATION NO. EPA-450/3-80-031b
-------
ENVIRONMENTAL PROTECTION AGENCY
Background Information
Final Environmental Impact Statement
for Publication Rotogravure Printing
Prepared by:
l<9
Don R. Goodwin
Director, Emission Standards and Engineering Division
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
1.
i(Date)
2.
The promulgated standards of performance will limit emissions of
volatile organic compounds (VOC) from new, modified, and reconstructed
publication rotogravure printing presses. Section 111 of the Clean
Air Act (42 U.S.C. 7411), as amended, directs the Administrator to
establish standards of performance for any category of new stationary
source of air pollution that "... causes or contributes signifi-
cantly to air pollution which may reasonably be anticipated to endanqer
public health or welfare." The Midwest and East Coast Regions of
the United States are particularly affected.
Copies of this document have been sent to the following Federal
Departments: Office of Management and Budget; Labor, Health and
Human Services, Defense, Transportation, Agriculture, Commerce,
Interior, and Energy; the National Science Foundation; the Council
on Environmental Quality; members of the State and Territorial Air
Pollution Program Administrators; the Association of Local Air
Pollution Control Officials; EPA Regional Administrators; and other
interested parties. .:
3. For additional information contact:
Mr. Fred Porter, Section Chief
Standards Development Branch (MD-13)
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
telephone: (919) 541-5624
4. Copies of this document may be obtained from:
U. S. EPA Library (MD-35) ;
Research Triangle Park, North Carolina 27711
National Technical Information Service
5285 Port Royal Road
Springfield, Virginia 22161 :
m
-------
-------
TABLE OF CONTENTS
Chapter
Page
1 SUMMARY ; \. 1-1
1.1 Summary of Changes Since Proposal l-i
1.2 Summary of Impacts of Promulgated Action . ,. 1-6
2 SUMMARY OF PUBLIC COMMENTS 2-1
2.1 General ....'; 2-1
2.2 Emission Control Technology . 2-6
2.3 Modification and Reconstruction 2-7
2.4 Economic Impact 2-11
2.5 Environmental Impact 2-12
2.6 Emission Monitoring ..... 2-12
2.7 Test Methods ..''.... 2-26
2.8 Reporting and Recordkeeping 2-27
2.9 Miscellaneous ; 2-30
IV
-------
-------
1. SUMMARY
On October 28, 1980, the Environmental Protection Agency (EPA)
proposed standards of performance for the Graphic Arts Industry; Publication
Rotogravure Printing (45 FR 71538) under authority of Section 111 of the
Clean Air Act. Also, a draft Environmental Impact Statement (EIS) was
published in a background document (BID) entitled, Publication Rotogravure
Printing - Background Informatton for Proposed Standards (EPA 450/3-80-
031a). Public comments were requested on the proposal in the Federal
Register. There were six commuters representing the printing industry.
Comments were also received from the State of Wisconsin and the National
Instutute for Occupational Safety and Health. In addition to written
comments, a public hearing was held on November 25, 1980.
This BID supports promulgation of the Federal standard for limiting
volatile organic compound (VOC) vapor emissions from the printing presses.
This document provides a final EIS and a discussion of changes made
after proposal resulting from public comments. Chapter 1 presents a
summary of the changes made to the regulation between proposal and
promulgation, with resulting impacts, and any corrections or clarifications
to the draft EIS. Chapter 2 contains a summary of all comments and EPA
responses to the comments.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
! '.
The proposed regulation was extensively revised for promulgation.
The significant changes involved the format of the standard, determination
of compliance, monitoring of operations, recordkeeping, and reporting.
Wording revisions were also made in several miscellaneous items.
1.1.1 Format of Standard
The emission limit for the^revised VOC standard was changed from a
volume to a mass basis. Pub!icicomments pointed out that most ink
suppliers base their raw ink formulation and VOC content on weight
measurements. Also, raw ink is usually sold by weight rather than
volume. Several plants presently prefer ink tank truck weighings and
ink storage tank weighings to volume meters for monitoring raw ink
1-1
-------
usage. In addition, the mass-based emission limit eliminates the necessity
for calculation of the solvent base temperature that was required with
the proposed volume-based emission limit (see Section 1.1.2).
The proposed separate VOC emission limits for waterborne and solvent-
borne ink usage have been combined into one standard in the final regulation.
The proposed VOC-to-solids volume ratio and solvent dilution limits for
waterborne ink systems were deleted. The emission limit for the revised
standard is based on the total amount of VOC solvent and water used at
the press.
The revision allows the industry greater flexibility for the use of
waterborne ink systems for several reasons. First, there are no restrictions
on the VOC-to-solids ratio. Second, the revised standard creates an
incentive for development of very low VOC waterborne inks. Where solvent-
borne and very low VOC waterborne inks are used at separate printing
units on the same press, compliance could be accomplished with less
stringent control of VOC vapors from the solvent-borne inks. On the
other hand, the revised standard allows use of higher VOC waterborne
inks provided that the VOC control level on solvent-borne inks would be
correspondingly increased to comply with the emission limit for the
entire press. Finally, the revised standard allows the addition of VOC
to the raw inks used at the press.
1.1.2 Determination of Compliance
The final regulation requires only an initial performance test with
other tests as requested by the Administrator instead of continual
monthly performance tests as required in the proposed regulation. The
proposed performance test procedures and compliance provisions sections
were combined in the final regulation. The proposed direct solvent
volume balance equations for calculating emission percentages were
revised to mass balance equations. Mass balance equations for determination
of compliance with waterborne ink systems have been added. The proposed
separate performance test procedures and compliance provisions for
waterborne ink usage were deleted. Performance tests will require
volume or mass measurements, as well as temperature measurements for
1-2
-------
density detenni nation of the ink, solvent, and water used and solvent
recovered from the presses. However, the measurement recording requirements
have been reduced from daily to at least weekly. With the mass balance
format, calculation of a solvent base temperature is not needed. Thus,
all proposed temperature symbols (BC, Bd, B , and B ) and the proposed
base temperature calculation equation were deleted. However, the mass
balance equations required addition of new symbols for the following
terms in the final regulation:
The mass of VOC solvent and water quantities measured by
direct weighing (Mc>';Md, Mg, MH, ry MQ, Mr, V^,- Mv,and MW),
The volume of water used measured by liquid meters (L.)5
The weight fraction of VOC in the raw ink and related coatings
used (WQ), I
The volume and weight fraction of water in the raw inks and
related coatings used (V and Ww),
The densities of measured liquid volumes used and recovered
(Dc, Dd,
D_, Du, D , ;D , and D ), and
Hi i w W
The VOC solvent density at a base temperature (Db).
Two optional compliance provisions were added in the final regulation.
The first option allows for compliance determination by a density-
corrected solvent volume balance instead of a mass balance if only
solvent-borne inks are used. This option might be desireable if only
liquid volume flow meters are used for monitoring ink, solvent, and
water handled (see monitoring in Section 1.1.3). The second option
allows the owner or operator to choose to demonstrate compliance by
showing that the total VOC discharged from all affected and existing
facilities in the plant is equal to or less than 16 percent of the total
mass of VOC solvent and water used at those facilities during the performance
test. This option gives industry the flexibility requested in the
comments by removing the requirement that the owner or operator measure
raw ink usage at each affected'[facility. By choosing this option, the
owner or operator would not need to segregate ink usage at each affected
facility from ink usage at existing and other affected facilities. Also,
1-3
-------
no separate emission tests on existing facilities would be necessary
with this option.
Because this second option permits a showing of plantwide compliance,
an owner or operator choosing this option would be required to show that
the average control among all plant facilities affected and existing
is equal to or better than the NSPS level of control. In the Agency's
judgment, under the circumstances presented here this assures that the
affected facilities within the plants will achieve the degree of control
reflecting application of the best demonstrated system of continuous
emission reduction. As a result, the plantwide compliance option will
provide rotogravure plant owners the benefit of measurement flexibility
without any resulting loss in emission reduction.
After careful consideration of the public comments, the Administrator
concluded that the compliance provisions could be made more flexible
without sacrificing environmental benefits of the standard. The regulation
was changed to allow alternatives to ink and solvent metering because
the high cost of ink and solvent creates sufficient economic incentive
for this industry to keep very accurate ink and solvent usage records.
Also, the economic incentive to recover solvent and the possibility of
the Administrator requiring a performance test are sufficient to ensure
that the industry will operate the best demonstrated control system
effectively.
1.1.3 Monitoring and Recordkeepinq
The final regulation gives the industry much greater monitoring
flexibility than allowed in the proposed regulation. The proposed
stipulations requiring ink and solvent volume meters, automatic temperature
compensators on recovered solvent meters, and temperature indicators
have been deleted. The proposed meter recalibration requirements were
also deleted. All of these items are still allowed, however, if an
owner or operator chooses to use them. Alternative liquid measuring
techniques to press meters are allowed, but are not specified in the
final regulation. In addition, the equation for calculation of solvent
base temperature has been deleted since emission percentage is determined
1-4
-------
by a mass balance in the final regulation. The proposed separate monitoring
requirements for waterborne ink systems were deleted since the proposed
separate waterborne and solvent-borne ink standards were combined into
one standard in the final regulation.
i
After performance tests are completed, the final regulation requires
simplified recordkeeping for monitoring proper operation and maintenance.
Records of monthly solvent and [water use, solvent recovery and the
estimated monthly emission percentages must be maintained. Temperature
readings of the measured inks and solvents are not required. The estimated
emission percentages will be useful to plant personnel in troubleshooting
decreases in solvent recovery efficiencies. The Administrator will also
use this information to determine whether additional performance tests
would be required because of improper operation or maintenance.
t
1.1.4 Reporting
The proposed requirement for non-compliance reports has been deleted
in the final regulation. Reporits of excess emission and all periodic
reports were deleted because the Administrator has the authority to
inspect plant records at any time and request additional performance
tests. Deleting such reporting requirements reduces the burden on industry
to prepare and submit reports. I Also, EPA is relieved of having to
review and file the periodic reports.
1.1.5 Miscellaneous Revisions ;
The proposed definition of affected facility has been reworded in
the final regulation. The definition of "Publication rotogravure printing
press" has been revised in accordance with the clarification notice
published in the Federal Register (46 FR 8587) on January 27, 1981.
Reference to Standard Industrial Classification (SIC) codes have been
i
deleted. A list of the publication printing products was added to the
definition. Also, the term "prjoof press" was added to the list of
definitions and the proof press: exemption has been clarified in a separate
paragraph. !
1-5
-------
In addition several other definitions and notations were revised in
the final standard. The following terms were clarified by wording
changes: "Automatic temperature compensator", "Base temperature",
"Density", "Gravure Cylinder", "Performance averaging period", "Publication
rotogravure printing press", "Rotogravure printing unit", "Solvent-borne
ink systems", "Solvent recovery system", "VOC", and "Waterborne ink
systems." The proposed term, "Total amount of VOC solvent used" was
deleted.
Several wording changes were made in the test methods and procedures
section of the regulation. In addition, the title for the reference
test method proposed with the regulation has been changed from 29 to
24A. Several typographical errors were also corrected in the text of
the test method.
1.2 SUMMARY OF IMPACTS OF PROMULGATED ACTION
1.2.1 Alternatives to Promulgated Action
The regulatory alternatives are discussed in Chapter 6 of the
proposal BID. These regulatory alternatives reflect the different
levels of emission control from which one is selected that represents
the best demonstrated technology, considering costs, nonair quality
health, and environmental and economic impacts for publication rotogravure
printing. These alternatives remain the same.
1.2.2 Environmental Impacts of Promulgated Action
The changes in the regulation described above will have no effect
on the environmental impacts ascribed to the standard as originally
proposed. These impacts are described in Chapter 7 of the proposal BID.
That analysis of environmental impacts now becomes the final Environmental
Impact Statement (EIS) for the promulgated standards.
1.2.3 Energy and Economic Impacts of Promulgated Action
Section 7.4 of the proposal BID describes the energy impacts of the
standards. The changes made in the standards have no effect on these
impacts.
Chapter 8 of the proposal BID describes the economic impacts of the
proposed standards. The replacement of specific metering requirements
1-6
-------
with options for use of other ink and solvent measurement methods may
slightly reduce some ope rat ing'costs. This is primarily because of the
elimination of meter recalibration requirements. The elimination of
noncompliance reporting may also slightly reduce operating costs.
However, the economic impacts of the promulgated standards are expected
to remain essentially as presented in the proposal BID.
1.2.4 Other Considerations ;
1. 2.4.1 Irreversible andiIrretrievable Commitment of Resources.
Chapter 7 of the proposal BID concludes that other than fuels required
for steam and electricity generation and the materials required for
construction of the system, there is no apparent irreversible or irretrievable
commitment of resources associated with the construction or operation of
the control systems. This remains unchanged since proposal.
!2.4.2 Environmental and Energy Impacts of Delayed Standards.
Table 1-1 in the proposal BID summarizes the environmental and energy
impacts associated with delaying promulgation of the standard. Delayed
promulgation would mean affected facilities would be controlled to the
State Implementation Plan (SIP) level. This is the control level used
as the baseline alternative in (the model plant analyses. These impacts
remain unchanged since proposal'. f
1.2.4.3 Urban and Community Impacts. Chapter 8 of the proposal
BID discusses potential socioeconomic impacts. There have been no
changes in the urban or community impacts since proposal of the standards.
1.2.4.4 Corrections and
discussions stating that modifications and reconstructions would not
occur in this industry (p. 8-15 and 8-49). However, after proposal of
the standard, several industry
right side of Figure 4-2, "Cabi
(p. 4-12) in the proposal BID.
1 arifications. The proposal BID presented
representatives expected retrofitting of
existing presses to become more common. See discussion in Chapter 2.
The term "Fugitive Solvent Vapors" was mistakenly left off of the
n enclosure
printing press"
1-7
-------
-------
2. SUMMARY OF PUBLIC COMMENTS
The list of commenters, th!eir affiliation, and the EPA docket
number of each of the comments iare shown in Table 2-1. In addition to
comments made at the public hearing, seven letters commenting on the
proposed standard were received. The comments have been combined into
the following nine categories:
2.1 General I
2.2 Emission Control Technology
2.3 Modification and Reconstruction
2.4 Economic Impact I
2.5 Environmental Impact |
2.6 Emission Monitoring
2.7 Test Methods
2.8 Reporting and Recordkeeping
2.9 Miscellaneous
L
The comments and responses; are discussed in the following sections
of this chapter. A summary of changes made in the regulation is included
in Chapter 1. \
The docket reference is indicated in parentheses in each comment.
Unless otherwise noted, all docket references are part of Docket Number A-79-50,
Category IV. For comments made,at the public hearing, the page number
from the transcript (F-l) is shown.
2.1 GENERAL ;
2.1.1 Comment: General comments were made on several different
topics. One commenter (D-l; F-l, p. 7) pointed out, both at the public
hearing and in his subsequent letter, that the new source performance
standards (NSPS) are not really:necessary to obtain the projected 13 percent
emission reduction because the gravure industry has already taken steps
to control emissions. He cited as an example the fact that all the
2-1
-------
TABLE 2-1
List of Commenters on the Proposed Standards of Performance for
Publication Rotogravure Printing Presses.
Docket Number A-79-50, IV
Public Hearing
Commenter Docket Reference
Mr. Harvey George F-l
GRI/6TA
Gravure Industry Emission Control Committee
22 Manhasset Avenue, Manorhaven
Port Washington, New York 11050
Mr. Gerald Bender F-l
R. R. Donnelley and Sons Company
2223 S. Martin Luther King Drive
Chicago, Illinois 60616
Mr. W. B. Cashion F-l
R. J. R. Archer, Inc.
Wins ton-Sal em, North Carolina
Mr. Michael Lefkow F-l
R. R. Donnelley and Sons Company
2223 S. Martin Luther King Drive
Chicago, Illinois 60616
Mr. R. D. Fremgen F-l
Dayton Press, Inc.
Post Office Box 700
Dayton, Ohio 45407
Mr. Bob Oppenheimer F-l
Gravure Research Institute, Inc.
22 Hanhasset Avenue, Manorhaven
Port Washington, New York 11050
Mr. Warren Weaver F-l
Diversified Printing
Post Office Box D
Atglen, Pennsylvania 19310
2-2
-------
Letters
Commenter
Mr. Harvey George
6RI/GTA
22 Manhasset Avenue, Manorhaveri
Port Washington, New York 11050
Mr. Warren Weaver
Diversified Printing '
Post Office Box D :
Atglen, Pennsylvania 19310 '
Mr. Thomas J. Dunn, Jr.
Flexible Packaging Association
12025 Shaker Boulevard
Cleveland, Ohio 44120
Mr. W. D. Major
Westvaco
299 Park Avenue
New York, New York
10017
Mr. J. F. McAvoy
State of Ohio Environmental Protection Agency
361 E. Broad Street
Columbus, Ohio 43216
Mr. Donald F. Theiler
Wisconsin Department of Natural
Box 7921
Madison, Wisconsin 53707
Mr. Bail us Walker
U. S. Department of Labor
Occupational Safety and Health Administration
Washington, D.C. 20210
Mr. L. R. Harris
National Institute for Occupational
Safety and Health
5600 Fishers Lane
Rockville, Maryland 20857
Resources
Docket Reference
D-l
D-la
D-7 (no comments)
D-2
D-3
D-4
D-5 (no comments)
D-6
H-l (no comments)
H-2
2-3
-------
plants tested or surveyed during the development of this regulation had
installed solvent recovery systems without regulation. He said that
future installations would do the same because of current State regulations
and because it is now and will continue to be economically beneficial to
do so.
Response: There are several reasons for EPA's establishing an NSPS
for publication rotogravure printing. First, as stated in the preamble
to the proposed regulation (45 FR 71540), publication rotogravure
printing is part of the graphic arts industry which is sixth on the
"Priority List and Additions to the List of Categories of Stationary
Sources" promulgated at 44 FR 49222 on August 21, 1979. This list for
new source performance standards ranks emission sources in terms of
quantities of air pollutant emissions, mobility and competitive nature
of each source category, and the extent to which each pollutant endangers
public health and welfare. The Agency's listing of publication rotogravure
printing is the result of the Administrator's finding that the publication
rotogravure printing industry is a significant contributor to air pollution
and the Agency is aware of no reasons to alter this finding. Section
lll(b)(l)(B) of the Clean Air Act requires the Administrator to promulgate
NSPS for all categories on the priority list.
Second, economic incentives may not be strong enough to ensure that
rotogravure publication plants will use the best demonstrated technology.
Section lll(a)(l)(B) of the Clean Air Act as amended August 1977, states
that a standard of performance shall reflect the degree of emission
limitation achievable through application of the best (emphasis added)
technological system of continuous emission reduction. Although all
plants tested or visited had solvent recovery systems, the best demonstrated
technology was not being used at all plants tested. Furthermore, only
19 out of the 27 publication rotogravure plants existing when the standards
were proposed had solvent recovery systems.
2-4
-------
2.1.2 Comment: A question was raised by two participants at the
public hearing (F-l, p. 13-15, ;17) concerning the definition of VOC.
The commenters asked if the EPA proposed to publish a method whereby one
could determine whether or not an organic compound participates in
atmospheric photochemical reactions. They stressed that the EPA needed
to clarify the VOC definition.
i
This question was in regard to the proposed definition of VOC
distributed at the public hearing as an attachment to the agenda. That
definition states, "'Volatile Organic Compound1 means any organic compound
which participates in atmospheric photochemical reactions, or which is
measured by a reference method, an equivalent method, an alternative
method, or which is determined by procedures specified under any subpart."
Response: This definition>as since been promulgated at 45 FR 85415
on December 24, 1980 and was amended to 40 CFR 60.2 in July 1981.
EPA published its initial policy on photochemical oxidants entitled
"Recommended Policy on Control of Volatile Organic Compounds," on July 8,
1977 (42 FR 35314). The policy,was later clarified on June 4, 1979
(44 FR 32042), on May 16, 1980 (45 FR 32424), and again on July 22, 1980
(45 FR 48941). The policy excludes 11 organic compounds from the family
of organics that react to form Oxidants. Additional work is underway
and it is possible that other organics may be added to the list of
compounds that do not react. A imethod for determining if a compound is
photochemically reactive is not |part of the definition of VOC. However,
EPA does determine photochemical reactivity of organic compounds and
lists those considered to be of'negligible reactivity.
2.1.3 Comment: At the public hearing and in a letter (D-l; F-l,
p. 8), a representative of the Gravure Research Institute and the Gravure
Technical Association said that ithe gravure industry considered the
84 percent standard for emission control to be a realistic figure. The
industry felt it would be hard to meet on an annual basis, but they were
optimistic that the industry would be able to comply.
2-5
-------
Response: As discussed in the section entitled "Selection of
Numerical Emission Limits" in the preamble to the proposed regulation
(45 FR 71546), the emission limit of 16 percent, or 84 percent overall
reduction, was chosen to allow for variations in control efficiency over
an entire year of operation. The data base showed that a 15 percent
emission limit could be achieved for most of the monthly compliance
periods during the year. However, there were a few months in which the
emission limit was slightly exceeded. The standard was, therefore,
relaxed to 16 percent. The Administrator believes this emission limit
to represent the maximum control level achievable on a continual basis
by the best demonstrated system of emission reduction.
2.1.4 Comment: The Flexible Packaging Association (D-3) objects
to the implied applicability of the proposed standards to packaging
rotogravure printing.
Response; The proposed standards do not apply to packaging rotogravure
printing. The definition of affected facility was clarified in 46 FR 8587
on January 27S 1981. This clarification notice listed products covered
by the standard.
2.2 EMISSION CONTROL TECHNOLOGY
2.2.1 Comment: One commenter (D-4) suggested that capture efficiency,
especially with retrofit presses, may not be as high as contemplated by
the proposed regulations. He noted that a recent publication (Gravure
Environmental Newsletter, No. 11, page 23, Gravure Research Institute,
Inc.) presents the results of capture efficiency tests made on a retrofit
multi-color gravure press. Six determinations were made, using three
different techniques. The average reported capture efficiency was
42 percent, with a range of 25-65 percent.
Response: EPA obtained a copy of the referenced publication (D-7)
through a telephone call (E-12) to the Gravure Research Institute.
2-6
-------
The referenced publication described capture efficiency tests conducted
at rotogravure presses printing on paperboard to be used for the manufacture
of folding cartons. Although these presses would not be subject to the
standard for publication rotogravure presses, the printing equipment and
capture systems are similar. The article concluded that the analytical
methodology which had been used! to determine capture efficiency was
inaccurate. It acknowledged that if capture efficiencies were indeed as
low as the test had measured, high solvent losses into the pressroom
would have led to disastrous consequences because of the explosion
hazard that would have been crelated.
During the development of this standard however, other more accurate
and rigorous test methods were used to measure the overall recovery
efficiency (capture and control, device efficiencies combined) and the
efficiency of the control device. Based on these measurements, EPA
concluded and still maintains that the capture efficiency of a well
designed press is in excess of 88 percent. The results of the tests
conducted by EPA are summarized in Appendix C of the proposal BID
(Volume I). :
F
Furthermore, EPA finds no reason, and the commenter identified no
reasons, for a retrofitted press to have a lower capture efficiency than
a new press. The fugitive capture system required for a new press or a
retrofit press could consist of;similarly designed add-on devices having
the same capture efficiencies. -
. I
2.3 MODIFICATION AND RECONSTRUCTION
2.3.1 Comment: One commepter (D-4) pointed out that the statement
in the preamble to the proposed"regulation (45 FR 71543 and 71550) that
says, "neither modification nor reconstruction is expected in this
industry," was not adequately supported. Subsequently, in a meeting on
February 19, 1981, with the Gra^ure Technical Association, industry
representatives stated that while they did not consider it a major
issue, they believe reconstruction and modification are likely to occur
in this industry.
2-7
-------
The comment letter (D-4) suggested that neither modified nor recon-
structed presses should be subjected to emission limits as stringent as
totally new facilities. With the high cost of capital, an owner might
very well choose to improve an old press by modification rather than
install a completely new press. The latter would require either new
floor space (more capital) or demolition of the existing press and
temporary loss of its productive capacity. However, applying the new
source limits to such a press would result in control costs equal to or
greater than those for a new press due to retrofit costs. Thus, according
to this comment, the cost of compliance would be proportionally much
higher for a modified press. The commenter suggested that it would be
reasonable for a modified or reconstructed press to be required to
capture and control dryer exhaust vapors only. If the press dryers
capture 85 percent of the total VOC used and the adsorber efficiency is
95 percent, as stated in the preamble to the proposed standards (45 FR 71542),
then control of dryer exhausts only should achieve an overall control
efficiency of 81 percent. He maintains that this is a reasonable control
requirement for a modified or reconstructed press.
In two telephone calls to clarify this commenter's remarks (E-13
and 14), the respondent said that, although he has no definite information,
he was referring to a hypothetical small printer who might want to
upgrade an old press rather than purchase a new press. The commenter
was concerned about the economic impact of having to install fugitive
capture systems to comply with the proposed standards. He felt that
just the rebuilding costs to upgrade capture efficiencies of old, inefficient
dryers to 85 percent might present an excessively high economic impact
on the small printer. The commenter mentioned several small printing
operations that, to his knowledge, operated only one or two publication
rotogravure presses. His concern was that these small printers might
not be able to afford new presses and might be limited to retrofitting
their existing presses.
2-8
-------
Response: During the development of this regulation prior to
proposal, EPA believed it was ujnllkely that existing facilities would
become affected facilities under the provisions for modification and
reconstruction (40 CFR 60.14 arid 60.15). As discussed on page 8-15 of
the proposal BID (Volume I), this belief was based on information from '
a representative of the Gravure; Technical Association (II-E-19) who said
that new presses are demanded because of technological improvements.
Publication rotogravure printing is a very competitive industry. Rapidly
improving press operation technology makes new printing presses and
associated equipment significantly more desirable to maintain or improve
a printer's competitive position.
The comment summarized aboye indicated that this belief may have
been incorrect and that there may be instances in which an existing
facility would be upgraded. Such a source would become subject to the
NSPS if it were modified or reconstructed. An existing source becomes a
modified source if a physical or operational change involving a capital
expenditure results in an increase in the emission rate of a pollutant
to which the standard applies (40 CFR 60.14). An existing source is
considered on a case-by-case basis to be reconstructed if the fixed
capital cost of new components exceeds 50 percent of the fixed capital
cost that would be required to construct a comparable new facility and
if it is technologically and economically feasible to meet the standard
(40 CFR 60.15). '
In view of the possibility;that some existing presses will be
retrofitted and may be affected; by the standard, EPA sought to obtain
information to determine and evaluate possible added impacts the standard
might have on such sources. Specifically, EPA attempted to conduct cost
and economic analyses on expansion of existing carbon adsorption controls
for retrofit model plant cases.; EPA requested control cost information
on retrofitted facilities from the industry at the February 19, 1981
meeting (E-19) and made several:additional requests for data from the
industry (E-20, E-21, E-22, E-24). No information was received, however.
In addition, EPA consulted a major carbon adsorber manufacturer (E-23)
2-9
-------
for guidance and expertise in analyzing expansion costs of the control
systems. Information received indicates that control system capital
costs for retrofitted facilities are generally higher than for same size
new installations. This information does not suggest, however, that
these costs would be unreasonable. Moreover, the Agency found no specific
process characteristics that would render control of retrofitted facilities
technologically infeasible or exorbitantly costly; nor did any commenter
provide such information. It should also be noted that an older facility
would need only to improve the performance of its current control system
to prevent an increase in anissions, and thereby prevent a modification.
This improvement would often not be as costly as an improvement necessary
to meet the NSPS.
Consequently, EPA must conclude that the effect of the standard on
modified and reconstructed facilities is not significantly different
from new facilities and that possible impacts would be reasonable.
Since the provisions of 40 CFR 60.15 provide for case-by-case determinations
of technical and economic feasibility* reconstructed sources are precl uded
from unreasonable impact. In the case of an older source which modernizes
and increases emissions (i.e., a modification), without any specific
examples of the circumstances under which unreasonable impact would
result from compliance with the standard, EPA finds no basis at this
time for establishing a separate standard or an'exemption.
2.3.2 Comment: The commenter (D-4) also noted that installation
of an additional printing station, or "unit", would not necessarily
result in increased emissions, as stated on page 45 FR 71550. He stated
that it is possible that the press would be designed for a new product
having less total ink coverage and thus fewer VOC emissions. The addition
2-10
-------
of printing units should not be
increased emissions.
Response: The preamble to
considered prima facie evidence of
the proposed regulation may have been
misleading on this point. It states that each unit is potentially an
equal source of emissions and therefore, the addition of units would
(emphasis added) cause an incremental increase in emissions. This
statement would have been clearer if it had said that additional units
could increase emissions. EPA agrees that addition of printing units
would not necessarily increase emissions.
2.4 ECONOMIC IMPACT !
2.4.1 Comment: One commehter (D-4) stated that spent carbon from
the adsorber might be considered hazardous solid waste under the provisions
of the Resource Conservation and Recovery Act (RCRA). The commenter
stated that proper handling and" disposal of such waste would affect the
economic impact of the standard* This possibility is not considered in
the solid waste section on page45 FR 71544 of the preamble to the
proposed regulation.
t
i
Response: In the analysis:of carbon adsorption systems undertaken
by EPA prior to the development!of these standards of performance for
i
publication rotogravure printing, it was assumed that facilities would
use the existing, routine option of returning the waste carbon to the
activated carbon supplier and that the supplier would be equipped to
handle the waste in an acceptable fashion.
Activated carbon waste is not presently listed as a hazardous waste
(40 CFR Part 261.30) although some rotogravure printing solvents which
would be adsorbed on the carbon;particles are listed. This; list is
periodically revised and activated carbon conceivably could be included
i
at some later date. If spent carbon should be listed as a hazardous
waste in the future, the optionlof returning the carbon to the supplier
would still be a viable one and;would not be precluded under RCRA provisions.
2-11
-------
2.5 ENVIRONMENTAL IMPACT
2.5.1 Comment: One of the letters received (D-4) pointed out that
the potential emission reduction for a "typical sized new plant" (45 FR 71539)
using the proposed standards versus baseline is not 700 megagrams per
year but (6400)(0.25-0.16) = 576 megagrams per year.
Response; The calculation in this comment is correct if only 84
percent control is assumed. However, the discrepancy noted is the
result of two factors. First, as noted in the preamble (45 FR 71539),
"the projected impacts are based on the expectation that, most of the
time, only 15 percent (85 percent overall control) of the total VOC
solvent used at affected facilities would be emitted. However, emissions
are expected to increase to the 16 percent level (84 percent overall
control) during only one or two months per year." Projected impacts
were calculated assuming 15 percent control level. Therefore, the
estimate of potential reduction described in the preamble was calculated
as (6400)(0.25-0.15) = 640 megagrams per year. The figure of 640 was
rounded to "about 700" rather than 600.
Second, Table 6-1 in the BID, Volume I illustrates another calculation
of potential reduction. It lists expected emissions with controls. At
the 75 percent and 85 percent control levels, expected emissions are
1596 Mg/yr and 946 Mg/yr, respectively. Calculating potential reduction
from these figures, 1596-946 = 650 Mg/yr or about 700 Mg/yr.
2.6 EMISSION MONITORING
2.6.1 Comment; Several commenters (D-l , D-4; F-l, p. 10-11, 21-
24) mentioned that the proposed regulation was too detailed, complex,
and inflexible. One of the major points was that the industry recognizes
the need for accurate ink and solvent consumption measurements, but
suggests that acceptable alternative compliance provisions be included
with the metering devices required in the proposed regulation. Of the
plants tested for the development of this regulation, one commenter
thought only one used the ink metering system described in the standard.
2-12
-------
This commenter noted that most of EPA's background data was based on
plant records of ink shipments combined with tank level meters rather
than by numerous flow meters. Commenters felt that these flow meters
are expensive to buy and calibrate, inconvenient to service, and too
numerous to read daily. A plant containing four eight-unit presses
would need as many as 96 ink arid solvent meters. Most plants rely on
other types of records. Printers have found that ink manufacturers'
delivery records of their tank truck loading meters, ink tank truck
weighings, tank truck unloading; meters, storage tank level measurements,
or storage tank weighings with a strain gauge are more accurate and more
easily serviced than meters installed at the press. Commenters noted
that local pollution agencies tend to apply only the methods specified
in Federal regulations. Therefore, any alternative compliance provisions
included in the proposed standards would minimize problems with local
pollution agencies. ;!
Response: The Agency has made four major changes that simplify and
add flexibility to the standard* First, the final standard permits the
owner or operator to show compliance on a plantwide basis. Second, the
final standard contains no specific procedures for measuring the amount
of ink and solvent used at the press. Third, facilities are no longer
subject to continual or monthly I compliance tests. Finally, there are no
longer any periodic monthly reporting requirements. The first three
changes are discussed in this response; changes in reporting requirements
are discussed in Section 2.8. ;j
In response to the commenters1 request for alternative compliance
provisions, the Agency has added to the final standard a provision
allowing the owner or operator to demonstrate compliance by showing that
the total VOC discharged from all affected and existing facilities in
the plant is equal to or less than 16 percent of the total mass of VOC
solvent and water used at thosejfacilities during the performance test.
This option gives industry the flexibility requested in the comments by
removing the requirement that the owner or operator measure raw ink
2-13
-------
usage at each affected facility. By choosing this option, the owner or
operator would not need to segregate ink usage at each affected facility
from ink usage at existing and other affected facilities.
Because this option permits a showing of plantwide compliance, an
owner or operator choosing this option would be required to show that
the average control among all plant facilities affected and existing
is equal to or better than the NSPS level of control. In the Agency's
judgment, under the circumstances presented here this assures that the
affected facilities within the plants will achieve the degree of control
reflecting application of the best demonstrated system of continuous
emission reduction. As a result, the plantwide compliance option will
provide rotogravure plant ov/ners the benefit of measurement flexibility
without any resulting loss in emission reduction.
Whether the owner selects this compliance option or instead chooses
to show compliance at each affected facility, the owner is no longer
limited to a specific procedure for measuring ink and solvent consumption
in calculating the material balance. EPA studied the alternative compliance.
provisions recommended in this comment and for several reasons concluded
that there are suitable alternatives to the ink and solvent metering
system required in the proposed regulation. First, because of high ink
costs and the large amounts of ink used, this industry and the ink
suppliers have a strong economic incentive to keep accurate records of
raw ink usage. For example, a typical four-press printing plant uses
about 4,500 tons of raw ink per year. At the 1981 price range of $0.50
to $1.00 per pound, the annual raw ink costs amount to:
4,500 tons x 2,000 ^| x ($0.50 to $1.00 per Ib) = $4.5 to $9.0 million
A ±1.5 percent error, comparable to the proposed regulation accuracy
requirements for press ink meters, would result in an accounting error
for annual operating costs of $68,000 to $135,000. Thus, even a small
error would be very costly to a plant. Second, there is doubt as to the
accuracy of press ink meters. According to printing industry representatives
2-14
-------
(E-19), press ink metars are not accurate to ±1.5 percent, the level
i
required in the proposed regulation. However, a meter manufacturer
(E-8) claims meters are accurate to the level required or the proposed
standard. EPA agrees with the printing industry that maintenance of
accuracy could be a problem. Finally, printing industry representatives
(E-19) have explained that alternative ink measurement techniques can
give accurate and timely measurement of ink used at the affected facility.
To provide more flexibility, several ink and solvent monitoring
options have been added to the final regulation. The industry is allowed
to use any monitoring devices and procedures which will provide an
accurate accounting of ink and solvent consumption. Procedures for
various monitoring alternatives have not been delineated in the regulation.
Such specification of alternative procedures would have greatly increased
the complexity of the regulation. Measurement of the mass or corrected-
volume of ink, solvent, and water used and solvent recovered is required
in the final regulation for performance tests and for monthly monitoring
purposes.
The main alternatives to press ink metering devices are ink storage
tank weighings or level measurements, ink tank truck weighings, truck
loading and unloading meters, and ink supplier shipment records. Where
individual press metering devices are not used for affected facilities,
temporary separate ink and solvent storage/handling systems must be used
i
during performance tests to segregate affected and existing facilities.
However, this requirement is not necessary if the combined facilities or
plantwide compliance options are chosen. Where ink storage tank weighings
or level measurements are used,-the tank inventory must be recorded
both immediately before and after each new ink supply addition.
If ink tank truck weights or loading or unloading meters are used,
the weight or meter readings must be recorded for each delivery and the
quantities of each color of ink:in the shipment must be recorded separately.
Reliable procedures must be followed in using any alternative to minimize
the potential ink accounting error resulting from the lag time between
ink inventory and actual use at: the press.
2-15
-------
It is important to note that the ink metering system required by
the proposed regulation was chosen for three reasons. Firsts EPA believed
that there are modern flow meters available which could be very accurate
for this service. Both plants tested during the development of this
regulation, Meredith/Burda, Inc. and Texas Color Printing, Inc., used
the ink and solvent metering system described in the proposed standards.
The accuracy requirements in the proposed regulation were based on the
meter manufacturer's specifications for the meters used at both these
plants. EPA still believes that if the press ink meters are calibrated
prior to a performance test, they are sufficiently accurate for compliance
purposes.
The second reason for EPA's choice of meters is that each individual
new press, not the entire printing plant, has been designated as the
affected facility. In addition to new publication presses, some printing
plants might contain older (existing) publication presses, gravure
presses for printing only packaging or specialty gravure products, and
other printing type presses. Thus, in multiple-press plants, the press
ink metering system provides a convenient method to account for raw inks
used directly at the affected presses.
The third reason for selecting the ink metering system in the
proposed regulation was that ink press meters provide for timely accounting
of the raw inks on an "as used at the press" basis., This procedure
minimizes any lag-time error from inventory accumulations which could
occur where using ink supplier shipment records, tank truck weighings,
or truck unloading meters. However, this would not be a problem for
storage tank monitoring, which reflects a direct response to ink usage
at the press. For these three reasons, ink meters are still considered
suitable for determining compliance.
The third major change in the final regulation deleted the proposed
continual monthly compliance test requirement. Compliance with the
2-16
-------
emission limit must be demonstrated during an initial performance test
and any other test requested by the Administrator. After completion of
the performance test, monthly mbnitoring is conducted to determine if
the control system is being properly operated and maintained. The
economic incentive to recover solvent and the possibility of the Adminis-
trator's requiring a performance test are sufficient to ensure that the
industry will operate the best demonstrated control system effectively.
, [
2.6.2 Comment: The gravure industry (D-l; F-l, p. 10) questioned
the necessity for measurement of the temperature of the inks used.
Response; In the final regulation, the material balance may be
calculated either on a mass basis or on a temperature/density corrected
volume basis. In most cases, sspme quantity required for the material
balance will be measured by volume and will require a figure for ink
density to convert to a mass basis or will require temperature measurement
to calculate volume at a constant temperature. Since density of a
liquid varies with temperature,, it is necessary to measure temperature
to determine density. For the Itoluene and naphtha solvents used in this
industry, the potential error in determination of compliance would be
about 2.0 to 3.5 percent or more (see response to comment 2.6.8).
The final regulation requires temperature measurement only during a
performance test. After ink and solvent densities are determined in the
performance test, those densities are used in monthly calculations to
estimate the corrected amounts [of ink and solvent used and recovered.
i
2.6.3 Comment: Two comme'nters (F-l, p. 10, 27, 28) felt that
daily temperature measurements jand daily ink meter readings are unnecessary
and would require a great deal :of time because of the large number of
meters in each plant. It would be at the owner's risk of non-compliance
if he chose not to monitor these parameters daily. However, to make it
mandatory is quite an administrative burden on the industry.
2-17
-------
Response: The regulation has been revised to relax the daily
monitoring requirements to an at least weekly basis during performance
tests. After completion of performance tests, only monthly accounting
of ink, solvent, and water usage will be required. Monthly temperature
measurements will not be required.
2.6.4 Comment: At the public hearing, an industry representative
(F-l, p. 10-12) explained that a typical ink distribution system involves
a circulating loop of ink that feeds to the various press units. A
measurement of the ink temperature at any point in this loop would be
the same, making it redundant to have a temperature indication at each
ink meter.
Response: Temperature indicators of ink at the press are not
required in the final regulation. However, EPA agrees that only one
temperature indicator would be necessary in an ink circulation loop
where ink flows through several press unit meters.
2.6.5 Comment; An industry representative (F-l, p. 10) pointed
out at the public hearing that the calibration of ink and solvent meters
every six months would impose a tremendous burden on the printer. Based
on industry experience, he said that it takes a minimum of several weeks
to have a meter recalibrated.
At the February 19, 1981 meeting (E-19), industry representatives
made two important points about meter calibration. First, they pointed
out that frequent calibration does not necessarily insure accuracy.
They also explained that in-line methods of calibration require extra
precautions and expense to avoid OSHA violations.
Response: The final regulation does not require that ink and
solvent be measured by meters. Thus, the proposed meter recalibration
requirements were deleted. However, as pointed out in the response to
Comment 2.6.1, EPA consideres the ink metering system required in the
proposed standard to be very reliable and useful.
2-18
-------
As a result of this comment, more information was obtained from a
meter manufacturer (E-8). The meter manufacturer felt that annual
calibration was adequate and pointed out some alternatives to sending
meters away from the plant for recalibration. EPA and the meter manufacturer
(E-8) agree that this process could take several weeks. First, he
stated that meter manufacturers,typically provide recalibration service
in the plant at a reasonable cost. Second, in-line methods of calibration
using drain connections and graduated containers or master meters are
relatively simple and could often be performed by plant personnel. Good
design practice would provide for installation of testing connections
for in-line calibration. Finally, meters could be removed from the
service lines and calibrated injthe plant maintenance shop on permanently
set-up special test facilities or on portable test facilities provided
by the meter company's service representative. Each calibration test
run should take only a few minutes for either method used. The total
calibration time including meter removal, testing and calibration, and
reinstallation should take less ;than two hours. The Reports Impact
Analysis (A-]0), summarized in the preamble, conservatively assumed
three man-hours per meter calibration.
EPA agrees that inks are a[difficult metering service and that
maintenance of accuracy may be a problem in some cases. Industry represent-
atives pointed out that in-line"calibration may violate OSHA requirements.
EPA recognizes that precautions are necessary to prevent violations of
OSHA regulations both during in-line calibration procedures and when
meters are removed from the line; for calibration.
i
2.6.6 Comment: One letter (D-l) stated that the standard calls
for the metering of all cleaning solvents, but in many instances cleaning
solvents are purchased in small quantities rather than large bulk
quantities. The letter remarked; that these small quantities should not
have to be metered because accurate records of consumption can be kept
by other means like counting the; number of cans or drums used.
2-19
-------
Response; As mentioned above, the proposed regulation has been
changed to eliminate specific requirements for metering of ink and
solvent used at the press. The owner or operator will be allowed to
measure ink and solvent, including cleaning solvent, by some alternative
procedure he selects.
EPA acknowledges that metering cleaning solvents purchased in small
quantities is difficult and unnecessary. Recording the number and net
weight or volume of drums or cans of cleaning solvent used would be
acceptable. The amount of cleaning solvent used is very small compared
to the total solvent used. The regulation requires cleaning solvent to
be considered in the material balance, but the small amount used does
not justify greater accuracy than obtainable by weighing or measuring
volume.
2.6.7 Comment; Concerning metering requirements, the industry
(D-la; F-l, p. 10) agrees with the necessity for automatic temperature
compensation of the recovered solvent volume meters. However, one
representative pointed out that the base temperature setting on presently
available automatic temperature compensated metering devices are preset
to a fixed value by the manufacturer and have sealed mechanisms which
cannot be readily adjusted to a new base temperature setting while in
service. These commenters said that the regulation should include an
alternative to the proposed required periodic base temperature setting
adjustments. A calculated adjustment in metered quantities equivalent
to the base temperature setting adjustment should be allowed.
Also, at the February 19, 1981 meeting (E-19), one industry representa-
tive presented a temperature compensation discussion paper from a meter
manufacturer. The manufacturer stated that for commercial sale of
liquids, the base temperature setting has been standardized at a reference
temperature of 60°F and recommended that the setting not be changed.
2-20
-------
Response: The final regulation requires measurement of recovered
solvent, but does not specify a procedure that must be used. The
regulation requires measurement; of recovered solvent temperature only
during a performance test and does not require an automatic temperature
compensator (ATC). However, EPA feels that a volume meter with an ATC
is the best method for monitoring recovered solvent. Information obtained
by EPA on these devices did not: reveal any significant problems in
periodic field adjustment of the base temperatures setting. The Agency,
however, considers that application of a calculated temperature correction
factor to the fixed-base temperature compensated meter readings would be
a suitable alternative to the proposed adjustment requirement.
EPA recognizes that 60° F 75 the standard base temperature setting
for commercial sale of liquids.! However, the recovered solvent meter is
normally not used as a sales meter. A separate meter is used for loading
tank trucks for sales shipment of recovered solvent. Therefore, the ATC
base setting for the recovered solvent meter could be at any temperature
within the adjustable range of the compensator.
i
2.6.8 Comment: One participant (F-l, p. 26-27) at the public
hearing stated that the equation presented in the proposed regulation
for calculation of the base temperature appears to be totally unmanageable,
would be subject to many errors, and is unnecessary.
i
Response: The equation for calculation of base temperature has
been deleted in the final regulation. The basis for calculation of the
emission limit was changed from a volume balance to a mass balance.
Therefore, the base temperature!calculation is not required.
The solvent base temperature equation presented in the proposed
regulation might look complicated, but actually, on a monthly basis, it
would be fairly easy to apply. jThe ink and solvent temperatures will
probably fluctuate with seasonal changes throughout a year's operation;
however, the liquid temperatures are not expected to vary significantly
during any given month. Thus, constant ink and solvent monthly temperatures
2-21
-------
would probably result in a great simplification in the calculation. EPA
acknowledges that this base temperature determination might still be
subject to errors in computation. However, determination of compliance
by any material balance procedure would be subject to human errors
because of the many ink and solvent quantities needed to be monitored
for rotogravure printing presses.
The proposed calculation of the monthly solvent base temperature
was to determine if and when the recovered solvent meter ATC base setting
needed to be adjusted. A correct base temperature setting is required
to ensure that the solvent material balance derived from the direct
volume meter readings sufficiently approximates a comparable actual mass
balance. Expected normal temperature and density differences between
measured volumes of recovered solvent and solvent used at the press
could result in calculation of incorrect emission percentages. Without
calculation of the solvent base temperature, the base temperature setting
for the recovered solvent meter ATC would need to be high enough to
prevent artificial determination of non-compliance by direct volume
meter readings. However, a higher base temperature setting would allow
too great a potential for artificially inflated apparent solvent recovery
efficiencies. Therefore, to avoid potential errors of 2.0 to 3.5 percent
or more in determination of compliance and to eliminate the calculation
of solvent base temperature, the emission percentage in the final regulation
is based on a mass balance. The mass balance procedure also accommodates
those facilities where the raw ink usage is chosen to be measured by
weight rather than by volume quantities (see Comment 2.6.1).
2.6.9 Comment; Two letters (D-l, D-2) addressed concerns about
waterborne inks, stating that the waterborne ink requirements in the
proposed standard are too restrictive. There were two provisions cited
as being excessively restrictive. The first was the provision that
prohibits the addition of VOC to waterborne inks at the press. The
commenters felt that the regulation should permit VOC addition to purchased
2-22
-------
raw waterborne inks and related coatings. Depending on press-side
problems with ink composition or production conditions, they said that
it is generally necessary to add small quantities of anti-foam agents,
alcohol speed-drying agents and special cleaning agents.
One letter went on to discuss concerns about a second provision,
saying that the formula used in the proposed regulation for calculating
VOC content of waterborne inks :is too restrictive with regard to the VOC
content of the ink formulation.,j The proposed standard permits a bulk
ink formulation where the ratio of volume VOC to volume solids no greater
than 0.64. This is based on the assumption that typical solvent-borne
inks currently consist of 20 percent solids, as applied. Therefore, an
ink formulation with a low solids content would severely restrict the
allowable VOC content of the ink. He noted that because of different
printing parameters needed to print different products, solids content
requirements and VOC content requirements may be grossly different for
different printers. He said that typical hydrocarbon based ink formulations
range from 12 to 35 percent solids as applied at the press. One printer
may have an unfair competitive edge over another were these regulations
finalized in this form. -
The commenter then suggested that instead of a VOC to solids ratio,
the waterfaorne ink requirement be modified to say that when using a
waterborne ink system, not more|than 16 percent VOC compared to total
volatile compounds shall be emitted, calculated on an annual basis. The
percent VOC emitted may be calculated by the following equation:
V
VVVV5
100
i
where V] is the volume percent of VOC actually emitted,
V2 is the volume of VOC in jthe bulk ink,
V3 is the volume of VOC added at the press-side,
V4 is the volume of water ijn the bulk ink, and
V5 is the volume of water added at the press-side.
2-23
-------
Response: It was not the intent of the regulation to restrict the
use of waterborne coatings. EPA's early information did not indicate
the need for additions of VOC to waterborne inks at the press. Latecoming
data have shown this necessity.
EPA agrees with the suggested format, but the calculation should be
on a mass not volume basis. The final regulation requires that the VOC
weight content be no more than 16 percent of the total volatile portion
of mixed waterborne inks, as applied. Use of this approach requires
measurement of water and VOC added at the press. This follows the
approach suggested in this comment with the exception of using a volume
basis.
The VOC to solids ratio was dropped from the final regulation
because the solids content of waterborne inks can vary substantially.
This point was confirmed in a telephone conversation with an ink manufacturer
(E-18) and at the February 19, 1981 meeting with industry (E-19).
The comment suggested calculating the percent" VOC emitted on an
annual basis. The preamble to the proposed regulation (45 FR 71548)
explains that the Administrator believes a one-month or four-week performance
averaging period is best to ensure that excess emissions do not go
undetected and that new sources are controlled to the best level achievable.
A four-week or one-month period was chosen as sufficiently long to
accomodate operational fluctuations which could affect the level of
emission control.
2.6.10 Comment: One commenter's letter (D-4) discussed the combined
use of water-based inks and solvent adsorption/recovery. This commenter
was called and asked for a clarification of his statements (E-13). He
pointed out that the proposed rules do not address the approach of using
a combination of water-based inks and solvent-borne inks on different
units at the same press. He said that specific provisions for this case
should be included in the regulation. Dryer exhaust from water-based
units should be vented to the atmosphere instead of to the carbon adsorption
system because the water vapor would affect the carbon's activity and
2-24
-------
because the water miscible orgarrics would be lost through the decanter.
This commenter suggested that if the VOC content of the water-based
coating is less than 16 volume;percent, then the difference should be
applied as a credit to allow Ibwer control of the VOC in the solvent
based ink units on the press, iIn other words, the VOC content of the
waterborne inks should be included in the emission percentage equation
presented in Section 60.433(c)(4) of the proposed regulation.
Response: Prior to this comment, EPA was unaware that the combined
use of waterborne and solvent-borne inks on the same press would be
practical or even desirable. It should be noted that the commenter is
not a publication printer, but .is a paper supplier to the publication
printing industry. The affected industry had not mentionesd any such
combined use for waterborne inks until the February 19, 1981 meeting
(E-19). At this meeting, one publication printer said his company had
been using a waterborne yellow ifor about one year.
EPA has included compliance provisions in the final regulation to
allow the combined use of wateriborne and solvent-borne inks. EPA agrees
that the compliance provisions should allow for lower capture and control
of solvent-borne ink VOC when the waterborne ink VOC, as applied, contains
less than 16 weight percent VOQ in the volatile portion. The intent is
to provide an incentive for development of very low VOC waterborne inks.
Also, the provisions allow use of higher VOC waterborne inks, provided
that the capture and control of; solvent-borne VOC would be correspondingly
increased to comply with the 16; percent emission limit for the entire
press. EPA agrees that dryer exhaust and fugitive emissions from waterborne
units should not be vented through carbon adsorbers and may be vented to
the atmosphere provided that the entire press complies with the 16
percent emission limit. :
Compliance is determined using a mass material balance. To be in
compliance, the average VOC emission percentage must be no more than 16
percent of the total mass of VOC solvent and water used. The material
balance is calculated as: total mass of VOC used minus total mass of
2-25
-------
VOC recovered divided by total mass of VOC used plus total mass of water
used. The water used includes dilution water and water in waterborne
i nks.
2.7 TEST METHODS
2.7.1 Comment: One industry representative (D-la) wrote that the
preamble to the proposed regulation (45 FR 71550) states, "the VOC
content data supplied by the ink manufacturer for the purchased raw inks
and related coatings should be based on the best method available to the
manufacturer." He stated that the gravure industry recognizes Reference
Method 29 to be a valid test method, but feels that the owner or operator
of the affected facility should also have the opportunity to use the
best equivalent method available that is accepted by the Administrator
to determine VOC content.
In a telephone call (E-12) made to clarify the commenter's intent,
he said that printers should have the option of using alternative analytical
methods such as gas chromatography (GC) and mass spectrometry (MS).
Response: EPA has renumbered the Reference Methods since this
regulation was proposed. What was Reference Method 29 is now Reference
Method 24A. The method itself has not been changed.
The proposed and final versions of the regulation recognize two
ways to determine VOC content in raw ink. One method is to record the
amount of each component part when an ink is manufactured. Obviously,
only the manufacturer can supply this data. The other method is by a
chemical analysis of the ink. The regulation allows the use of data
from the manufacturer to relieve the industry of this chore. After the
ink has been made up by the manufacturer, the only possible way to
determine its content is by sampling and analysis. The proposed and
final versions of the regulation specify Reference Method 24A (formerly
29) as the only acceptable analytical method.
At the present time, EPA has no reference method or specific
procedures for GC or MS total VOC content analysis of printing inks.
2-26
-------
One industry representative (E--.19) noted that GC results were consistent
with the ink manufacturer's datja, but noted procedural problems. The
results of GC analysis of raw rnk conducted at Texas Color Printers,
Inc. during the development of the proposed standard, did not agree with
the ink manufacturer's data. E:PA has no further test data on GC or MS
analysis of total VOC content of printing inks. GC and MS methods are
more expensive and much more complicated than Reference Method 24A, yet
Method 24A is more reliable for: determination of the total VOC content.
One problem with analysis bf naptha-based solvents is that the
amount of naptha present in the; sample is hard to calculate because it
is made up of several component?. These components do not give sharp
peaks on the GC so that total area of the naptha curve is hard to measure.
For these reasons, the firi^l regulation includes Reference Method 24A
as the only acceptable analytical method for determining VOC content in
raw inks. However, the General! Provisions for Standards of Performance
for New Stationary Sources (40 CFR 60.8 (b)) allow owners or operators
of affected facilities to petition the Administrator for permission to
use an alternative procedure for determining VOC content.
11
2.8 REPORTING AND RECORD KEEP INI3
2.8.1 Comment: In comments made both at the public hearing and in
letters (D-1; D-4; F-l, p. 9) it was stressed that the gravure industry
thinks ten days is too short a time limit for reporting when an affected
facility is out of compliance. ; One public hearing participant pointed
out that ten days does not allow enough time to determine whether an
apparent violation might be due to meter errors and a great number of
meters may have to be checked. ; He said that a plant may receive more
than 100 shipments of ink and extender per month and information on the
solvent content of each shipment has to be obtained. There are additional
complications involved with multi-plant operations in remote locations.
According to these comments, a twenty- or thirty-day reporting period
should be allowed. ;'
2-27
-------
Response; In the final regulation, EPA has deleted all periodic
reporting requirements. Notification and performance test reports:
required under the General Provisions (40 CFR 60.7 and 60.8) are still
required. Deleting periodic reporting requirements saves resources of
both the EPA and industry. Plants will be required to maintain monthly
records of estimated emission percentages for two years showing proper
operation and maintenance of control equipment. The required recordkeeping
serves as a useful troubleshooting tool for the company and allows
enforcement personnel to check for proper operation and maintenance if
necessary. Data on the total amount of solvent and water used at the
press and the amount of solvent recovered will need to be gathered and
recorded each month along with the estimation of the emission percentage.
EPA has the authority to inspect these records at any time and to require
additional performance tests.
2.8.2 Comment; One industry spokesman (D-l) stated that the
standards of performance would impose unnecessary burdens of recordkeeping
and compliance monitoring on both the States and the gravure industry.
Response; As mentioned in responses to other comments, several
changes have been made in the final regulation that will reduce record-
keeping. Continual monthly performance tests requirements have been
deleted. Meters are no longer required for ink and solvent measurement
and temperature monitoring is required only during a performance test.
The only two required reports are a notification when a facility becomes
subject to the regulation and a report of the results of a performance
test. However, plants are required to keep monthly records described in
the response to comment 2.8.1 that show proper operation and maintenance
of control equipment.
2.8.3 Comment: The same commenter (D-l; F-l, p. 10) referred to
the estimate in the preamble of one-third of a person's time per company
for recordkeeping and reporting. He said that the estimate was unrealistic
2-28
-------
because there are a large number of meters and delivery records to be
checked. ;
Response; The estimate of one-third person-year for recordkeeping
and reporting was based on itemized calculations presented in the Reports
Impact Analysis (II-A-10). The calculation estimating the maintenance
of meter reading and ink VOC content data was based on 80 man-hours per
combined facility (i.e. two associated presses and four associated
presses). (
As mentioned in responses fco other comments, recordkeeping requirements
have been reduced and reporting; is required only for notifications and
performance tests. The Reports* Impact Analysis has been revised to
reflect these changes. The revised estimate for recordkeeping and
reporting by the entire industry is about 22,000 person-hours required
over the first five years of applicability of the standard. The Administrator
believes this is a reasonable manpower requirement.
2.8.4 Comment: One letter (D-4) addressed the labor requirements
for reporting. The author was telephoned (E-13) for clarification of
his comment. He pointed out that the preamble to the proposed standards
mentions that five additional persons throughout the industry would be
required for reporting. He felt this was misleading and that no additional
people would be hired, but that!some portion of existing employees' time
would have to be shifted to monitoring. He stated that actual industry-
wide labor requirements are likely to be higher when the projected
75 new presses could be distributed at as many as 37 locations. He said
this was true because the time efficiency of monitoring one press is
much lower than that for monitoring several presses at one location.
Response: The preamble was confusing on this point. The intent
was to convey that reporting requirements would generate a total of five
additional person-years of work Annually for all anticipated new facilities.
The five person-years are a measure of the total labor requirement, not
2-29
-------
the number of people required. This estimate was based on itemized
calculations of the time necessary to complete each required report at
the estimated 75 new publication rotogravure presses that will have to
comply with this standard over the next five years. Those calculations
showed that in the five-year period, 43,180 person-hours or 22.3 person-
years would be required. This is equivalent to 4.5 person-years annually.
As mentioned above, however, reporting requirements have been
reduced in the final regulation. The Reports Impact Analysis has been
revised to reflect the requirements of the final regulation.
2.9 MISCELLANEOUS
2.9.1 Comment: It was pointed out (D-l; F-l, p. 8, 9, 17, 18) at
the public hearing and in a letter that the regulation clearly exempts
proof presses. However, in the preamble (45 FR 71538) to the proposed
regulation, there is a reference to smaller four-unit proof presses.
Commenters noted that proof presses may have a different number of units
than four and that this term should be eliminated to avoid confusion by
other agencies. The commenter asked that the preamble be revised to
omit the concept of four-unit proof presses.
Response: The regulation exempts proof presses regardless of the
number of units. The term "proof press" was added to the list of definitions
in the final regulation. The statement to which this comment refers
appears in the preamble and states, "The smaller four-unit proof presses
... would not be affected by the proposed standard." This statement was
not meant to be a definition. The proposed regulation does not use
"four-unit" in regard to proof presses, but defines an affected facility
as one that prints saleable products. The concept of saleable products
exempts proof presses. The preamble to the promulgated regulation does
not use the term "four-unit" to describe proof presses.
2.9.2 Comment: Two participants (F-l, p. 19-21) at the public
hearing discussed the fact that page 71547 of the preamble to the proposed
2-30
-------
regulation states, "A VOC vapor monitor could be installed in the dryer
exhausts streams to control the amount of internal air recirculation;
this would maximize the VOC vapor concentration in the SLA stream treated
by the solvent control device." They pointed out that this is a misunder-
standing. Controlling the dryer exhaust air flow, not the recirculation
flow, is required in order to control the dryer exhaust solvent concentration.
Response; EPA agrees with this comment and concurs that the preamble
is confusing on this point. Regulating the dryer exhaust air flow with
on-line vapor monitors to control the VOC concentration is; thoroughly
discussed in the BID, Vol. 1, p. 3-16, 6-10.
i
2.9.3 Comment: The director of the Bureau of Air Management for
the State of Wisconsin Department of Natural Resources (D-6) noted that
a monthly averaging period would be used to determine compliance with
the NSPS. However, guidance from EPA's recommended reasonably available
control technology emission limitations (RACT), which Wisconsin is now
in the process of adopting, calls for instantaneous or daily average
compliance. The Director feels that it is inappropriate for U. S. EPA
to instruct Wisconsin to adopt ;more stringent compliance requirements
for existing sources than it proposes to impose on new facilities. He
requests that EPA modify the current RACT guidance. The Director stressed
that although this issue deals 'with RACT guidance, it is clearly intertwined
with the NSPS and cannot be separated.
Response; EPA is studying whether revision of the RACT recommendations
is appropriate.
2.9.4 Comment: The National Institute for Occupational Safety and
Health (NIOSH) noted (H-2) that worker exposure to toluene and xylene,
the principal components used in rotogravure printing solvents, is an
obvious health hazard that should be addressed in an EIS. Detailed
discussions of the economic, environmental., and energy impacts associated
2-31
-------
with the three alternative levels of control were presented in the
preamble, but there was no evaluation of any health aspect. NIOSH has
developed criteria documents which evaluate effects of exposure to
toluene and xylene on health.
Response: EPA agrees that there is a health hazard involved with
the exposure to toluene and xylene. This standard would not increase
worker exposure to these substances. Generally speaking, the Clean Air
Act gives EPA the authority to regulate pollutants affecting ambient air
quality. Ambient air is considered to be air outside the plant. Worker
exposure to hazardous substances inside the plant is controlled under
the Occupational Safety and Health Act and standards for worker exposure
to toluene and xylene have been promulgated under this Act.
The two documents mentioned in this comment provide useful information
on exposure to toluene and xylene. Toluene exposure is discussed in
Occupational Exposure jto Toluene: Criteria for a^ Recommended Standard,
prepared by the U.S. National Institute for Occupational Safety and
Health, NIOSH/HSM-73-11023, Washington, D. C., 1973 (98 pp.). Exposure
to xylene is discussed in Occupational Exposure to Xylene: Criteria for
a Recommended Standard, proposed by the same institute, NIOSH/.75-168s
Washington, D.C., 1975 (101 pp.).
2-32
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-80-031b
3. RECIPIE-NT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Publication Rotogravure Printing - Background
Information for Promulgated Standards
5. REPORT DATE
October 1982
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS!1
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68r02-3058
12. SPONSORING AGENCY NAME AND ADDRESS '
DAA for Air Quality Planning and Standards
Office of Air, Noise, and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Standards of Performance for the control of VOC emissions from publication
rotogravure printing presses are being promulgated under the authority of Section 111
of the Clean Air Act. These standards would apply only to presses printing
saleable products and for which construction or modification began on or after the
date of proposal of the regulation- This document contains a summary of public
comments, EPA responses, and a discussion of differences between the proposed
and promulgated standards of performance.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air Pollution
Graphic Arts Industry
Pollution Control
Publication Rotogravure Printing
Rotogravure
Standards of Performance
Volatile Organic Compounds (VOC)
Air Pollution Control
13B
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (Tilt'sReport)
Unclassified
21. NO. OF PAGES
43
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
-------
------- |