&EPA
United States
Environmental Protection
Agency
Prevention, Pesticides
and Toxic Substances
(7406)
EPA 744-R-96-001
September 1996
              Pollution Prevention Experiences
              in Three Flexographic Printing
              Facilities
              Design for the Environment
              Printing Project
       U.S. EPA
                                      Recycled/Recyclable
                                      Printed with Soy/Canola ink on paper that
                                      contains at least 50% post-consumer recycled fiber

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POLLUTION PREVENTION EXPERIENCES IN THREE
      FLEXOGRAPHIC PRINTING FACILITIES
                    Prepared for:

     The Design for the Environment (DfE) Program
     United States Environmental Protection Agency
        Office of Pollution Prevention and Toxics
                     July 1996
                        By
     The Center for Business and Environmental Studies
           California State University, Hayward
               Under Grant #X-820802

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                             For More Information
To learn more about the Flexography Project of EPA's Design for the Environment Program or
  to obtain this document or additional information on other related materials, please contact:
              EPA's Pollution Prevention Information Clearinghouse (PPIC)
                        U.S. Environmental Protection Agency
                              401 M Street, SW (3404)
                               Washington, DC 20460
                               Phone: (202)260-1023
                                Fax:(202)260-0178
                           Internet: ppic@epamail.epa.gov
      Or visit the Design for the Environment Program World Wide Web Homepage at:
                                http://es.inel.gov/dfe

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                                Disclaimer
The use of specified trade names or the identification of specific companies,
products or processes in this document are not intended to represent any
endorsement by the EPA or the U.S. Government.

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                              TABLE OF CONTENTS
ACKNOWLEDGMENTS

PURPOSE OF THE REPORT

INTRODUCTION

BACKGROUND OF FLEXOGRAPHY

REGULATIONS GOVERNING THE FLEXOGRAPfflC INDUSTRY

METHODS OF VOC COMPLIANCE IN THE FLEXOGRAPfflC INDUSTRY

CASE STUDIES

      Emerald Packaging

      1. Facility profile
      2. Issues involved in deciding to use water-base ink vs. add-on controls
      3. Issues and/or problems during implementation of the new system
      4. Results of the change to the new process
      5. Impact of external factors
      6. Future developments

      Packaging Specialties

      1. Facility profile
      2. Issues involved in deciding to use water-base ink vs. add-on controls
      3. Issues and/or problems during implementation of the new system
      4. Results of the change to the new process
      5. Impact of external factors
      6. Future developments

      FirmX

      1. Facility profile
      2. Issues involved in deciding to use water-base ink vs. add-on controls
      3. Issues and/or problems during implementation of the new system
      4. Results of the change to the new process
      5. Impact of external factors
      6. Future developments

FINDINGS

REFERENCES

APPENDIX
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                                   ACKNOWLEDGMENTS


The research team is indebted to several organizations and individuals, without whose
participation and assistance this study would not have been completed. The Center for
Business and Environmental Studies (CBES) is grateful to James Kelly and Ron Garriety
of Emerald Packaging, George Long of Packaging Specialties, and the president of the
Northeastern printing facility, for participating in this study. We especially thank them for
taking time from their busy schedules to demonstrate and discuss their companies' printing
operations. Their willingness to share their pollution prevention experiences with the
CBES research team was invaluable to this study.

A special thank you is owed to Fred Shapiro, Environment and Safety Consultant to the
Flexographic Technical Association (FTA), and president of P.P. Technical Services, Inc.
Fred was instrumental in providing us the background and technical expertise related to
flexography, as well as spending much time and patience addressing the issues involved in
this study.
Sam Doctors, J.D., D.B.A.
Principal Investigator
Director, CBES
Mark Landheer, M.B.A.
Project Manager
Senior Associate, CBES
The report is an amendment to the scope of work for Grant # X-820802, which was a
focus group study of Lithographers and Screen Printers on the "Investigation of Methods
of Informing & Motivating Change in a Portion of the Printing Industry," completed
March 1996.  These studies were commissioned by the United States Environmental
Protection Agency (EPA), Office of Pollution Prevention and Toxics (OPPT), and
conducted by the Center for Business and Environmental Studies (CBES), at California
State University, Hayward, from October, 1993 through June, 1996.

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 PURPOSE OF THE REPORT

 This report highlights the experiences with water-base ink versus solventi-base ink of three
 flexographic printing facilities.  The primary purpose of this study was to analyze the motivations .
 of the facilities in selecting their specific pollution prevention methods,  i

 INTRODUCTION

 EPA initiated the Design for the Environment (DfE) Program to promote the use of
 environmentally sound technologies and products in manufacturing.  Through the Program, EPA
 formed the Design for the Environment Printing Project in partnership with printing industry trade
 associations, such as the Flexographic Technical Association (FTA), Screen Printers Association
 International (SPAI), and the Printing Industries of America (PIA), as well as individual printers
 and suppliers.  An important first step in developing an overall strategy for pollution prevention,
 these partnerships are intended to determine the most effective ways to reach the printing industry
 audience with messages regarding the "how to" of pollution prevention.
The format of this report provides background on the flexographic industiry, including the printing
processes, pollution concerns, and regulatory requirements. Three case studies are then
presented, one of which is anonymous.  Finally, the overall findings of the report are discussed.

The case studies follow a typical case study methodology, reporting on the following information:
1.  Facility profile, providing a brief description of each flexographic printing facility.
2.  Issues involved in deciding to use water-base ink versus add-on controls, examining the
    motivations of each flexographic facility in arriving at its particular pollution prevention
    strategy.
3.  Issues and/or problems during implementation of the new systemj, describing the
    experiences of each flexographic facility during the conversion process.

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4. Results of the change to the new process, assessing the outcome of the pollution prevention
   method chosen.
5. Impact of external factors, describing the roles of trade associations, ink suppliers, and
   consultants during the various stages of conversion.
6. Future developments, describing ways that each facility expects to further improve efficiency
   and/or reduce pollution.

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BACKGROUND OF FLEXOGRAPHY

The printing industry is comprised of several types of printing employing one or more processes,
such as lithography, letterpress, flexography, gravure, screen printing, and various plateless
technologies. Flexographic printing employs plates with raised images, and only the raised images
come in contact with the substrate (the film) during printing. Typically, the plates are made of
plastic, rubber or some other flexible material, which is attached to a roller or cylinder for ink
application. Ink is applied from an engraved metering roller to the raised image on the plate,
which transfers the image to the substrate.1
                  Plate Cylinder
       Anilox^Roll
  Fountain Roll
                                                        In the typical flexographic printing
                                                        sequence, the substrate is fed into
                                            Impression   the press from a roll. The image is
                                            Cylinder
                                                        printed as the substrate travels
                                                           through a series of stations, with
                                                           each station printing a single color.
                                                           Each station is made up of four
                                                           rollers. The first roller (also known
                                                           as a fountain roll) transfers the ink
                                                           from an ink fountain (tray) to the
                                                           second roller, the meter roller. The
                                                     meter roller (also known as an anilox
                                                     roll) meters the ink to a uniform
thickness onto the third roller, the plate cylinder.  The substrate moves between the plate  cylinder
and the fourth or impression roller, which supports the substrate.2
The printed web (substrate) proceeds through color printing stations and between color drying
chambers to dry the ink before the next station. Upon completion of the printing and drying of the
last color in an overhead drying tunnel, the finished product is rewound onto a second roll, hence
                                       Substrate
Figure 1: Typical print station. A. Ink fountain with fluid
ink. B. Rubber ink-fountain roll. C. Reverse angle doctor
blade (if used in the system). D. Ink-metering (anilox) roll
E. Printing plate cylinder. F. Substrate traveling through
press.  G. Impression cylinder.
Source: Introduction to Flexography

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 the term "roll-to-roll."  Many operations can be performed in-line after the substrate has been
 printed and dried, while still unwound. Some types of flexo presses are equipped with a sheeter
 that delivers sheets instead of rolls, or places them in line with bag and box making equipment to
 deliver finished products.
       Infeed & Tension Control     Printing & Drying
Outfeed & Rewind
                      Exhibit 1: Webfed Rotary Flexographic Press
Source: EPA 1994
The system can also run with a doctor blade, which improves ink distribution by wiping excessive
ink off the anilox roller. Modern presses are now equipped with enclosed doctor blade systems

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 which eliminate the fountain roller and ink fountain, thereby reducing evaporation loss.3 Using
 ultra-violet (UV) inks eliminates the volatile solvent in the ink, while water-base ink produces
 relatively low emissions of Volatile Organic Compounds (VOCs) as compared to solvent-base
 ink.
 The width of flexography presses ranges from 4.5 inches up to 115 inches. The ink tray (fountain)
 used on larger (wide-web) presses is very long, allowing for significant evaporation of ink if an
 enclosed doctor blade box is not used. Flexographic printers  use a wide variety of substrates,
 ranging from paper to exotic plastic films.  Printers have more success with water-base inks on
 papers and other absorbent substrates. Wide web printers encounter physical problems when
 printing on films due to the surface tension differences between the materials and the inks. Narrow
 web printers use a more limited range of materials and work with narrow width and smaller
 circumference rollers, making it more cost effective to use both water-base and UV curable inks.

 The inks used in flexography are fast-drying and of low-viscosity.  These inks lie on the surface of
 non-absorbent substrates and solidify when solvents are removed, making flexography ideal for
 printing on impervious materials such as polyethylene, cellophane and other plastics and
 metallized surfaces. Also, the soft plates, which are relief plates of varying durometers (rubber
 hardness), allow quality printing on compressible surfaces such as cardboard packaging. 4

 With low cost plates and a relatively simple press, flexography is one of the least expensive and
 fastest growing printing processes. According to the Flexographic Technical Association,
 flexography accounts for 85 percent of printed packaging, such as plastic wrappers, corrugated
boxes, milk cartons, labels, and foil and paper bags.5  In 1991, flexographic printing accounted for
 17 percent of the total value of US printing industry output (excluding instant and in-plant
printing), which was estimated at $161 billion.6 Between 1991 and 2025, however, flexography's
 share of the printing market is expected to increase to 21 percent or more.  In addition, the total
printing industry's dollar volume is expected to grow by 3.8 to 5.3 percent during that same time

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period. Growth areas for flexography are expected to be pre-printed labels for corrugated boxes,
pressure sensitive labels, newspaper inserts, comic books, directories, and catalogs.7

Of a total of 59,636 plants in the United States with printing presses, only 1,587, or 2.7 percent,
have flexographic presses. Flexographic printers, however, tend to be larger than printers using
other processes. Almost 55 percent of plants with flexographic presses have 20 or more
employees, compared to less than 16 percent for the printing industry as a whole.8

Flexographic printing operations use materials that-adversely affect air, water, and land. Certain
chemicals involved in printing, such as solvents, volatilize, which contributes to air emissions from
the printing facility and to smog formation. Chemicals may be discharged to drains and effect
freshwater or marine ecosystems. Solid  wastes, such as film and paper waste, contribute to
existing local and regional disposal problems.
 The major concern regarding the flexographic industry is the release of oxidants into the
atmosphere. These oxidants result from chemical reactions by organic compounds and other non-
methane VOCs.  The flexographic industry releases approximately 99 percent of its pollution to
the air, and it is these emissions that the study will focus on.9

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 REGULATIONS GOVERNING THE FLEXOGRAPHIC INDUSTRY

 The Clean Air Act of 1970 set up the first national system to regulate and enforce air pollution
 standards. The Act has been amended several times and now provides a comprehensive program,
 administered primarily by the states, to reduce hazardous emissions. It is designed to "protect and
 enhance the nation's air resources so as to promote the public health and welfare and the
 productive capacity of the population."10

 In particular, regulatory agencies work to reduce oxidants in the atmosphere, as set forth in State
 Implementation Plans (SEPs). The oxidant plan portions of SIPs must reflect the application of
 reasonably available control technology (RACT) to pollution sources in non-attainment areas.
 Non-attainment areas do not comply with local air quality standards and usually experience
 greater scrutiny. RACTs aim for the lowest possible emission level that any source can reasonably
 attain. This level is derived from EPA studies published in control techniques guidelines (CTG), a
 technical document providing plant owners, state regulatory agencies and the EPA guidelines for
 defining RACTs. The CTG document for flexography (Volume "vTH, Graphic Arts-Rotogravure
 and Flexography) specifies low-solvent inks to reduce VOC emissions. For processes and
 applications that can use these complying inks, emissions can be reduced to acceptable levels
without further technology. Using these inks is not feasible for some applications. In these cases,
the CTG document states that incineration or solvent recovery are the most reasonably available
control technology. n

The oxidants released during printing result from chemical reactions by organic compounds and
other non-methane VOCs. Some 40% of these compounds come from cars and other vehicles.
The second largest source, about 27%, is from operations that use solvents, and the EPA
identifies the flexographic printing industry as part of this group.12   These solvents are organic
compounds in liquid form, and are found in purchased ink and in solvents added to reduce inks
                                                                                     7

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while printing to maintain the appropriate level of viscosity. The vapors released into the air
during the drying process interact with sunlight to form ozone (a bluish gaseous reactive form of
oxygen): one of the EPA's main concerns, because of its effects on human health.13

The Occupational Safety and Health Administration (OSHA), which is charged with protecting
health and safety in the workplace also oversees the flexographic industry. OSHA is concerned
with overexposure of employees to solvents used in printing which can have harmful health
effects. Threshold limit values for each solvent are listed in OSHA's "Table Z" in the Hazard
Communication Standard of November 25,1983.14 As flexographic companies comply with the
CTG document, they also reduce employee exposure to the solvents.
This study attempts to document the actual experiences of three flexographic printers who have
made the choice between the use of low-solvent inks and incineration as a means of complying
with both pollution prevention and employee safety regulations.

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 METHODS OF VOC COMPLIANCE IN THE FLEXOGRAPHIC
 INDUSTRY

 The two methods of compliance in reducing volatile organic compounds emissions for
 flexographic printers, set forth in the CTG document, are the following:1S

 Method 1: Use of Low-Solvent Inks:
 •   Water-base inks, which contain no more than 25% by volume of organic solvent in the volatile
    portion.                                                           '
 •   Compliant high-solid inks, which contain 60% overall solids by volume, make drying difficult
    because of the relatively high latent heat of water. Also, these inks do not apply successfully
    to substrates that are commonly used in flexography. In addition, they are not currently
    available. Our focus is therefore on water-base ink, which has been successfully used for some
    flexographic applications.
Method 2: Add-On Controls:
•  Solvent recovery removes organic solvents in vapor form from the air, turns them back into a
   liquid and recycles them into the existing ink supply. After this process, the airstream should
   contain minimal amounts of VOCs and be well within allowable limits.  The most common
   solvent recovery technique is carbon absorption. This process uses activated charcoal or
   carbon to separate solvents from an airstream. When the vapor-laden air from the dryers
   passes through a bed of this carbon, the carbon simply catches and retains the solvents. When
   the solvent can be separated readily from the water and reused as a raw material, then cost
   savings make the use of solvent recovery systems a good choice. Unfortunately, most
   solvents used in flexographic printing are blends of alcohols and acetates, many of which are
   water soluble, rendering carbon absorption technically unusable for flexo printers.

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    Incineration, or destroying solvents by oxidation, is a process that uses heat and oxygen to
    convert organic solvents to carbon dioxide and water vapor. The equation is:
    VOC + oxygen + heat = carbon dioxide + water.
    Two incineration techniques are appropriate for compliance:
    1.  Thermal incineration, where VOCs are exposed to 1,400°F to 1,500°F with a dwell time
       of 0.3 second to 1.0 second. This is the time interval during which elements must remain
       in contact or in a static position.16
    2.  Catalytic incineration, in which a catalyst is used to start a chemical reaction that can
       proceed under different conditions and at a lower temperature than otherwise possible.
       The catalyst induces oxidation at 500°F to 700°F and requires a dwell time of about 0.7
       second.
To compare the difference in capital outlay between the incineration system and water-base ink
method, several attachments are included in Appendix A. (These charts were provided by Fred
Shapiro of P.P. Technical Services, Inc., and were prepared for a client to illustrate the variable
capital expenditures required to convert his three presses to water-base ink compared to
converting to an incineration system).

In addition to using low-solvent inks or add-on controls, there are a number of other pollution
prevention opportunities for flexographic printers to reduce VOC emissions during the printing
process on a smaller scale. These opportunities include:n
•  Improving housekeeping and operating practices, such as covering reservoirs and containers,
   scheduling jobs according to increasing darkness of ink color, and using wipes until fully
   saturated. These procedures can minimize solvent losses from inks and cleaning solutions.
•  Reducing ink vaporization by using diaphragm pumps which do not heat ink as much as
   mechanical vane pumps.
•  Recycling waste solvents on-site or off-site. Segregating of solvents may allow a second use
   (e.g., for equipment cleaning or ink thinning).
                                                                                       10

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 •   Recycling of certain waste inks where possible.
 •   Recycling of product rejects where possible.
 •   Using alternative ink and cleaning products with reduced VOC emissions. Lowering the VOC
    emissions from printing and press clean-up may be accomplished using water-base or UV
    curable inks (rather than solvent-base inks) where possible and using safer (less toxic)
    solvents, and low-VOC or VOC-free cleaning solutions.
 •   Installing automatic ink levelers to keep ink conditions optimal.
 •   Using automatic cleaning equipment, which can often be retrofitted to existing presses and
    operations. Typically, lower volumes of cleaning formulations are applied with such cleaning
    equipment. Air contact and thus volatility are then reduced.
 •   Minimizing finished product rejects by automating monitoring technologies which detect tears
    in web and press performance.

 The final steps in making a printed product may involve folding, trimming, binding, laminating and
 embossing. Typical waste streams include: scrap substrate from trimming, rejects from finishing
 operations, and VOCs released from adhesives. Pollution prevention opportunities at this stage of
the process include:18                                    '            '          ->
•   Collecting and  reclaiming recyclable materials.
•   Replacing VOC-base adhesives with water-soluble adhesives (binding adhesives that are not
    water-soluble may interfere with later recycling), hot-melt adhesives, or mechanical methods
    in laminating and converting operations.
                                                                                       11

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CASE STUDIES

This section presents the findings of on-site visits by the study team at three flexographic printing
facilities: Emerald Packaging, Packaging Specialties, and Firm X. These facilities were selected, in
consultation with flexographic industry associations, by the DfE Flexography project of the EPA.
The three companies voluntarily agreed to participate in the study. The site visits took place
during March and April of 1996.

The on-site visits were to enable the research team to document the actual experience of those
involved in the decision making and implementation process of the selected pollution prevention
method. All participants were cooperative and sources of valuable information, however, there
were two areas of information that each of these companies declined to reveal publicly:
•   financial information, such as cost/benefit analysis data related to the conversion; and
•   composition of the ink, as these companies had spent much energy and capital in creating just
    the right ink for the substrates being used by them, and were unwilling to pass this  information
    on to competitors.

The focus of this study is on the experiences of the three flexographic printing facilities as they
implemented either low-solvent ink or add-on controls. Each of the three facilities had  its own
motivation to select the pollution prevention method currently in place, as described in the
following case studies. The facilities being studied do not deal with pre-press operations, such as
image making and plate making, therefore the pollution prevention focus of this study is on press
and post-press operations.
                                                                                       12

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 EMERALD PACKAGING


 Emerald Packaging, located in Union City, California, decided in the late 1980's to transfer from

 solvent-base ink to water-base ink. The company received strong support from Zeneca Specialty

 Inks, Emerald's main ink supplier, who first introduced the company to water-base ink, and

 worked closely with Emerald to improve the ink's quality and reliability. Although the decision

 was mostly compliance driven, management believed that there would be an eventual cost benefit

 to the water-base ink. Management used a gradual process of converting to water-base ink, in

 part due to the trial and error nature and initial poor results of these inks. In 1988, 3200 pounds

 of water-base ink were used by Emerald Packaging, and by 1991 this had increased to 100,000

 pounds. For the last five years this facility has used  entirely water-base ink for its operations.

 Although others in the industry had perceived a decline in the quality of their products as a result

 of converting to water-base ink, during and after the time of implementation at Emerald

Packaging, it did not experience a single return of any of its finished products.
1.  Facility Profile

   Number Of Employees:
   Annual Sales:
   Sales Area:
   Main Product:
   Plant Size:
   Office Size:
   Other Features:

   Operating Schedule:
   Printing Presses:

   Primary Ink:
   Primary Substrate:
   Plate Making:
   VOC Emissions Permit:
   Current Emissions:
   Ink Cost:
   Ink Waste:
   Ink Waste Cost:
97 (includes 9 in front office)
$10 to 20 million (1995)
Western United States (broker network)
Produce packaging manufacturing (85% of sales)
46,000 square feet
5,000 square feet
2-3 week turnaround of orders; average of 10-20 days backlog
of client orders
3 shifts/7 days a week
4 flexographic presses with enclosed doctor blade boxes, 2 six
rollers and 2 four rollers
Water-base
Polyethylene
Out-sourced
Maximum of 31.5 tons/yr.
14-15 tons/yr.
4-5% of total sales
Thirty-six  55 gallon drums/yr.
$7,920/yr. ($220/55 gallon drum)
                                                                                     13

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2, Issues Involved In Deciding To Use Water-Base Ink Vs. Add-On Controls

   Compliance drove Emerald Packaging management to migrate to water-base ink. However,

   the decision was made well before experiencing any external regulatory pressure. The process

   began in 1988, and the transfer to sole use of water-base ink on all presses was completed by

   1992. Management used a pro-active approach in addressing pollution prevention, as it

   believed that eventually regulatory agencies such as the Bay Area Quality Management

   District would force them to implement pollution prevention measures.
    Emerald Packaging reviewed two alternatives in preventing pollution: water-base inks versus

   an incinerator. Cost estimates for an incinerator were given in 1989 by two major

   manufacturers, Reeco and JWP:

                                    JWP                            Reeco

   Equipment                 $1,508,000                       $1,920,000

   Soft Costs© 12%             181,000                          230,000

   Sales Tax @ 8.25%            139.000       	177.000

   Total                      $1,828,000                 '      $2,327,000
   Amortized (10% interest)  $  290,000/yr.
   (formula was not available)
   Fuel (Natural gas)
$  359,000/yr.
($55.83/hr)
   Electricity ($31.03/hr)     $  199,000/yr.

   Maintenance ($15.00/hr)   $   90.000/vr.

   Total Annual Cost        $ 938,000
 $ 369,000/yr.


 $ 213,000/yr.
($33.00/hr)

 $ 199,000/yr.

 $   90.000/vr.
                                  $  871,000
                                                                                     14

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 The following is an estimated cost outlay of the necessary investments to water-base ink




 provided by the production manager at Emerald Packaging:
                       Per item:




 Corona treater:        $ 30,000




 Anilox roller:          $   5,000




 Drying equipment:     $   3,000




 Enclosed doctor blades: $ 10,000




 Miscellaneous:         $  4,000




       Total investment per press:
Total for a
4-roller press
$ 30,000
$ 20,000
$ 12,000
$ 40,000
$ 16.000
$118,000
Total for a
6-roller press
$ 30,000
$ 30,000
$ 18,000
$ 60,000
$ 24.000
$162,000
 The total investment for Emerald Packaging to convert to water-base ink was about




 $400,000, which was based on two 4-roller presses and one 6-roller press.









 Although some of the costs of converting to water-base ink (such as operating costs) were not




 fully disclosed, management believed that water-base inks had several advantages over an



 incinerator:




 •   Due to expected market growth, Emerald would need to move its operations in the next




    few years,  and with it the incinerator, at an additional expense.




•   Reverting to water-base ink was the environmentally right thing to do, as it reduced or




    eliminated  VOCs, the solvent odor in the plant, and the energy costs of an incinerator.




•   The investment of converting to a water-base ink system appears to be considerably less
                                                                                   15

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       than the investment of acquiring an incinerator (see above).




       Should the trial and error stage of implementing water-base ink be unsuccessful, Emerald




       still had the choice of reverting to an incinerator, while still being in compliance during the




       implementation period.




       If successful, being one of the first flexo printers in its market to convert to water-base ink




       could give Emerald Packaging a competitive edge.
3.  Issues And/Or Problems During Implementation Of The New System




   One of the first issues was the poor results in quality and reliability of the water-base ink.




   Because the ink would not dry and because of problems with the ink density and poor




   pigment, the ink bled and/or applied poorly to the substrate. By experimenting with free




   samples of water-base inks from Zeneca, Emerald's main ink supplier, technicians were able to




   give continuous feedback to Zeneca and eventually help create a satisfactory water-base ink




   for their substrates. First, a thicker layer of ink was tried, which improved the color and




   transfer of the ink onto the substrate; however, it still took too long to dry. Ultimately, a




   combination of factors made water-base ink application successful:




   •   The substrate (polyethylene) was treated to a higher dyne level on the printing side to




       increase the surface tension, improving the transfer, adhesion, and drying time of the ink.




   •   Enclosed doctor blades were attached to the anilox rollers which greatly improved the




       distribution of the ink onto the roller and eliminated evaporation, thereby increasing the




       consistency of the ink lay down.




   •   The drying process was improved by increasing the airflow, rather than using  heat.




   •   The ink supplier created a lower viscosity, higher solids ink which dried more easily, and







                                                                                       16

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       at the same time improved the density to maintain color.




    •  During the transition, Emerald used a white solvent-base ink as the ground layer for




       water-base ink in order to enhance the gloss.




    •  Press operators were supportive in implementing this new technology and provided




       feedback on the outcome of numerous trials, which aided the improvement of the water-




       base ink for Emerald's operations.




    •  Running the presses non-stop reduced start-up and shut-down costs, which prevented




       additional problems with the ink quality.









    Initially, Emerald Packaging used water-base ink on just one of its four flexographic printing




    presses, in order to minimize any loss of productivity.









4.  Results OfThe Change To The New Process




    Although it took Emerald (and Zeneca) several years to perfect the water-base ink needed, as




    well as improve the printing surface of the substrate, there remain many advantages and only a




    few disadvantages compared to solvent-base ink.
   The disadvantages are:




   •   Higher price (20%) for water-base ink (no dollar amounts were provided).




   •   Slower runs (10-15%) with water-base ink versus solvent-base ink (actual numbers were



       not provided).                              -




   •  Decrease in gloss of water-base ink.




   •  Higher labor costs for better trained personnel to handle water-base ink (no dollar
                                                                                     17

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       amounts were provided).




   •   Major investment needed in new equipment to operate water-base ink, i.e.: enclosed




       doctor blade boxes, corona discharge treaters, drying system, etc.









The advantages are:




   •   Water-base ink has much better mileage (20-30% more) than solvent-base. Mileage is the




       usage factor of an ink, and refers to the amount of ink used to cover a certain area of




       printed surface (actual numbers were not provided).




   •   Cost of water-base ink per impression is actually less than solvent-base ink (no dollar




       amounts were provided).




   •   Recovered water-base ink is recycled without filtering.




   •   Color quality is more consistent with water-base ink.




   •   Slower runs (with water-base ink) cause lower VOC emissions (actual numbers were not




       provided).




   •   Emerald's annual VOC emissions is between 14 to 15  tons using water-base ink, while it




       has a permit that allows annual VOC emissions of up to 31.5 tons. While using solvent-




       base ink and only two presses, Emerald emitted well over 50 tons of VOC annually.




   •   Safer environment for employees.




   •   Rubber plates are less hazardous to clean (solvent-less).




   •   Less waste ink as the ink is easier to recycle.




   •   Avoidance of major investment for an incinerator plus high operating costs.




   •   Peace of mind in compliance situation.
                                                                                      18

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 5.  Impact Of External Factors




    While the decision was mainly instigated by management to pursue a pro-active pollution




    prevention program, Emerald's ink supplier, Zeneca, played a pivotal role in creating the right




    ink and in working closely with those involved at the plant.  Management also made use of its




    trade association, the California Film and Extruders Conversion Association (CFECA), to




    obtain information and feedback from other members, which assisted in Emerald Packaging's




    decision making and implementation process.








6.   Future Developments




    Management at Emerald Packaging hopes to eventually use photopolymer plates in the




    production process. Photopolymers are light-sensitive materials, which, when used in




   flexographic printing plates, are similar to rubber in that they are flexible, resilient and have




   the printing image in relief. These plates are easier to clean, reducing the amount of solvent




   necessary in the cleaning process. Moreover, photopolymer plates provide a better defined ink




   image, which should reduce both initial ink consumption and the quantity of defective final



   product.









   A recent trend that seems likely to continue is an increase in local companies leaving the Bay




   Area, in search of less strict environmental regulations and a more stable work force




   elsewhere.  Management is concerned that this is leading to an unfair competitive situation.
                                                                                     19

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PACKAGING SPECIALTIES








Packaging Specialties, located in Fayetteville, Arkansas, was forced into compliance in 1989 by




the Arkansas Department of Pollution Control and Ecology, which issued it two Consent




Administrative Orders (CAO) in 1990 and 1991, resulting in fines totaling $64,500.









The General Manager of Packaging Specialties initially decided to convert all flexographic




printing presses from using solvent-base ink to using water-base ink at that time, in order to




comply with VOC emission regulations. This decision was made primarily for three reasons:




1.     It was possible to reduce VOC emissions immediately using water-base ink, whereas




       installing an incinerator required a major capital investment and resultant delays.




2.     Water-base ink was believed to be more environmentally friendly than the incineration




       method, in light of the increased energy consumption required to operate it.




3.     Converting to water-base ink was to be a permanent solution, while an incinerator was




       considered a short-term, quick-fix solution, and eventually would need to be replaced as




       the company kept growing.









Packaging Specialties uses three different substrates: polyethylene, poly vinyl chloride (PVC) and




Cryovac. Because each requires different printing techniques, composition of the ink is a complex




issue.  PVC allows for stretching after printing, while Cryovac allows for shrinkage after printing,




and both require high-performance inks. Management had experimented with water-base ink




during the late 1980's and felt confident that conversion to water-base ink would be successful.
                                                                                      20

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 During a 14 month period in 1991 and 1992, only water-base ink was used on all presses. Due to

 poor print quality, regulatory pressure to comply with VOC emissions, and increased returns from

 clients, including its largest customer who threatened to take its business elsewhere if quality

 didn't improve, management felt compelled to install an incinerator system and revert to using

 solvent-base ink.  As print quality has become more important, and an incinerator with ventilation

 system is in place, management considers it extremely unlikely that the facility will return to solely

 water-base ink in the short-term, unless regulatory agencies strongly curtail the VOC emission

 permit allowance. However in the long-term, management expects to implement water-base

 and/or UV-base inks to remain in compliance. Now that Packaging Specialties has invested in an

 incinerator system, it has little economic motivation to change soon. This case study will describe

the implementation of the incinerator with ventilation system and its results and future

expectations.

   1.  Facility Profile

   Number Of Employees:     85 (including 20 in front office)
   Annual Sales:
   Sales Area:
   Main Product:
   Plant Size:
   Other Features:

   Operating Schedule:
   Printing Presses:

   Primary Ink:
   Primary Substrate:
   Plate Making:
                          $15 to 20 million (1995)
                          South Central US. and West Coast (sales force)
                          Poultry packaging manufacturing (70% of sales)
                          50,000 square feet
                          2-3 week turnaround of orders; average of 4-5 days backlog of
                          client orders
                          3 shifts/5 days a week
                          9 flexographic presses, 3 with doctor blades, all presses with 5 to
                          8 rollers
                          Solvent-base
                          PVC, polyethylene, and Cryovac
                          Out-sourced
   VOC Emissions Permit:    Maximum of 93.3 tons/yr.
   Current Emissions:        35-40 tons/yr.
                            6% of total sales (includes in-house ink technician)
                            Sixty 55 gallon drums/yr.
                            $4,500/yr. ($75/55 gallon drum)
Ink Cost:
Ink Waste:
Ink Waste Cost:
                                                                                     21

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2. Issues Involved In Deciding To Use Water-Base Ink Vs. Add-On Controls




   Packaging Specialties experienced two periods of decision making. The first occurred in 1991,




   when, forced to comply with environmental regulations, the General Manager decided to




   transfer to using water-base ink. The second occurred 14 months later, when management




   reverted to solvent-base ink and installed an incinerator and ventilation system.









   In 1991, Packaging Specialties was instructed by the local regulatory agencies to comply with




   environmental regulations by installing an incinerator. The company's General Manager,




   however,  was convinced at the time that transferring to water-base ink would bring the facility




   into compliance in the shortest possible time and at the lowest capital investment (figures were




   not available for the study).  Since the local regulatory agencies were not familiar with the




   time frame necessary for implementation to water-base ink in 1990, management spent




   considerable time and effort justifying its approach to the local regulatory agencies.




   Eventually, all presses were operated using water-base ink. This meant that the composition of




   the ink had to be changed, the substrates treated, the plant employees trained, and a slight




   decline in product quality was to be expected. The actual cost of this conversion was




   estimated at $915,696,  considerably higher than anticipated.









   Although great effort was undertaken to perfect all aspects of the water-base ink conversion,




   several factors worked against it:




   •   The ink supplier, GPI, was not able to provide a consistently successful water-base ink, in




       particular for the P VC and Cryovac substrates, and management could not find any other
                                                                                       22

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        ink manufacturers with success in this regard.  There is very little use of PVC and Cryovac




        in the flexographic industry, creating little incentive for ink suppliers to develop a water-




        base ink specifically for these substrates.




    •   Due to compliance pressure, Packaging Specialties was not able to undergo a trial and




        error phase, like others in the industry.




    •   Customer complaints and an increase in product returns (up to 5% of all finished




        products) forced Packaging Specialties to print using solvent-base ink to appease certain




        clients, and eventually led to more production based on solvent-base ink, increasing the



        need for an incinerator.




    •    The up-front cost of water-base ink was about 50% more than solvent-base ink for




        Packaging Specialties, while there were no perceived savings in using less water-base ink.




    •    Whereas enclosed doctor blade boxes are highly recommended on all rollers when using




        water-base ink, none of the nine flexographic presses at that time had either reversed angle




        doctor blades or enclosed doctor blade boxes on its rollers. Doctor blades greatly reduce




       the amount of ink applied, which partly explains the lack of perceived savings on the




       mileage of water-base ink. It should be noted that this aspect was not emphasized by GPI




       or other industry sources during the conversion to water-base ink in  1991.
3  Issues And/Or Problems During Implementation Of The New System




   Since Packaging Specialties had previously been using solvent-base ink, it was a relatively




   easy transition to reacquaint all the printing presses and employees to solvent-base ink. The




   incinerator and ventilation system required an investment of about $750,000. The only




   significant problem during this process concerned the functioning of the incinerator, as it
                                                                                       23

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   needed to be monitored to ensure that it disposed of the required VOC emissions. Initially, the




   incinerator experienced several operating problems, which implied periods where the VOC




   emissions were not being disposed of, potentially violating environmental regulations. One of




   the reasons for the occasional malfunctioning was a buildup of silicon in the incinerator, which




   deactivates the catalyst. Although the source of the silicon is unknown to the company, the




   problem has been resolved by cleaning the catalyst more frequently.









4. Results Of The Change To The New Process




   The results of the first change from solvent-base to water-base ink have been documented




   previously in section 2. The change from water-base back to solvent-base ink with an




   incinerator was due to the poor but improving results of the water-base ink, and due to time




   constraints from the Arkansas Department of Pollution Control and Ecology, who in 1992




   threatened huge fines on the company. Especially on substrates such as PVC and Cryovac,




   water-base ink did not meet the desired quality, and since the ink supplier(s) were not able to




   solve the problem, Packaging Specialties felt forced to use  an incinerator. The quality, using




   solvent-base ink, is perceived to be more than satisfactory for all substrates, which is also




   reflected in the fact that there have been virtually no product returns or customer complaints




   based on the print quality. In 1989, Packaging Specialties emitted 702 tons of VOC's,




   without the incineration method. Currently, VOC emissions run at 35-40 tons per year,




   constituting a 95% decrease in VOC emissions.
                                                                                      24

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 5.  Impact of External Factors




    Packaging Specialties' ink supplier, GPI, was unable to create a water-base ink that would




    apply properly to the PVC and Gryovac substrates. GPI provides Packaging Specialties with




    an in-house ink technician who strongly favors solvent-base ink, as do the plant employees,




    who find it easier to work with solvent-base ink. However, their opinions did not play a




    substantive role in the company's decision making process.  Management consulted




    Environmental Services Company, Inc., a Little Rock environmental consulting company,




    whose advice and recommendations played an important role in management's decision to




    purchase the current incinerator system.









6.   Future Developments




    Packaging  Specialties hopes to implement both UV-base ink, which has reduced volatility




    content, and other environmentally-friendly inks in the future, to offset possible regulatory




    reduction in their VOC emission allowance. The use of PVC as a substrate is declining due to




    declining client demand, and is expected to disappear in the next ten years, contributing to the




   lack of commitment from ink vendors to develop a water-base ink for it.  Furthermore, due to




   market growth, Packaging Specialties is expanding its operations at its current site, and




   believes the current incinerator can handle added VOC emissions.
                                                                                     25

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FERMX



Firm X, located in Nassau County, New York, was compliance-driven in 1990 to reduce its VOC

emissions. At the time the local regulatory agencies (the Nassau County Department of Health

and the New York State Department of Environmental Conservation) were not aware that the

firm was violating its VOC emissions permit. Management took the first step on its own in

determining how best to comply without regulatory prodding. The first attempt in 1990 to

change from using solvent-base ink to water-base ink was unsuccessful, as at this stage the

results were disappointing and management was not fully committed. The second attempt,

completed in 1992 after nine months, was successful and will be further analyzed in this case

study. The transfer to water-base ink is believed to be very successful as it has lowered 1995

VOC emissions to 8% of the 1990 VOC emissions.
 1.  Facility Profile

    Number Of Employees:
    Annual Sales:
    Sales Area:
    Main Product:
    Plant Size:
    Operating Schedule:
    Printing Presses:

    Primary Ink:
    Primary Substrate:
    Plate Making:
    VOC Emissions Permit:
    Current Emissions:
    Ink Cost:
    Ink Waste:
    Ink Waste Cost:
Approximately 50
$20 to 30 million (1995)
Entire United States
Pattern coated polyolefin films
31,000 square feet
2 shifts/5 days a week
2 presses using chamber doctor blade systems with flexographic
or gravure stations
Water-base
Film and paper
Out-sourced
Maximum of 25/yr.
Approximately 11 tons/yr.
Not available
Four 55 gallon drums/yr.
$2,200/yr. ($550/55 gallon drum)
                                                                                    26

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 2.  Issues Involved In Deciding To Use Water-Base Ink Vs. Add-On Controls




     Management at Firm X attempted twice to convert to water-base ink in the early 1990's.




     After failing in 1990, management obtained assistance from a consultant versed in printing




     technology and environment compliance. The consultants' knowledge and expertise were




     instrumental in implementing water-base ink successfully to both presses at the facility during




     a nine month period. The major issue in this process was creating a water-base ink suitable




     for plastic, the primary substrate used.  Management contacted fourteen ink manufacturers in




     1991 and 1992, but none was able to supply a satisfactory water-base ink for the firm's




     substrate.  Eventually, faced with losing Firm X's business, worth between $0.5 - $1.0 million




     annually, the company's main ink supplier (name was not made available), agreed to develop




    an ink to meet the firm's requirements.  Although an incinerator system was reviewed, there




    were two major reasons in favor of using water-base ink:




    1.  the capital investment outlay of an incinerator was quoted by suppliers as being between




       $1 and $1.5 million, versus an estimated $300 to $400 thousand for converting to water-



       base ink.




    2.  the current site would be limited for planned growth and this would force the firm to move




       locations within a few years. This made installing an incinerator system on-site



       economically unworkable.
3.  Issues And/Or Problems During Implementation Of The New System




   As stated above in section 2, obtaining a satisfactory ink during the implementation ph
.ase was
                                                                                     27

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   a most difficult task.  The problems were similar to those experienced by many others in the




   industry: the ink would not dry quickly enough and the density was unsatisfactory, which




   caused delays and/or poor quality products.








   The substrate being printed needs a matte finish,' whereas many other flexographic printers are




   concerned with obtaining the best possible gloss on their substrates. This facilitated the ink




   development process for the firm. Despite some problems with the ink, there were minimal




   returns from clients during this phase.








   The conversion to water-base ink required a greater capital investment and higher operating




   costs than anticipated, due to:




   •   Increased equipment costs, such as new rollers, different plates, improved drying systems,




       doctor blades, etc. (dollar amounts were not available).




   •   Higher labor costs, as the water-base ink demands more sophisticated plant employees.




   •   Consulting fees (dollar amounts were not available).




   •   Opportunity loss, caused by lower productivity during the transfer phase (actual numbers




       were not available).









4. Results Of The Change To The New Process




   All parties involved at Firm X are satisfied with the current operation of the flexographic




   presses,  despite some negative impacts concerning the printing efficiency and cost.
                                                                                       28

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 The negative impacts include:




 •   Slower printing runs, approximately 25% less per day, due to water-base ink, resulting in




     lower productivity than with solvent-base ink (actual numbers were not available).




 •   Increased labor costs, as water-base ink requires more sophisticated personnel to monitor




     the process (dollar amounts were not available).




 •   Higher ink costs, estimated at 15% more than solvent-base ink (dollar amounts were not



     available).
 The positive impacts include:




 •   Cost savings, as the firm would have invested considerably more for an incinerator system,




    and would have encountered high operating expenses for the Natural Gas to fuel the




    system (dollar amounts were not available).




 •   Higher cost of water-base ink is somewhat mitigated by the better mileage using water-




    base ink than using solvent-base ink (dollar amounts were not available).




 •   Recovered water-base ink is recycled without filtering, which simultaneously improves the



    color quality.




 •   Firm's annual VOC emissions is less than hah0the permitted 25 tons of VOC with water-



    base ink.




 •   Safe and friendly environment for employees.




 •   Cleaning of rubber plates and equipment is less hazardous (much of it can be accomplished



    simply using water).




•   Only one 55 gallon drum of ink waste is produced each quarter at a disposal cost of




    approximately $550 each. Information from previous years was not made available.
                                                                                  29

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5.  Impact of External Factors




   As documented earlier, the consultant played a pivotal role in helping Firm X to convert to




   water-base ink, as well as operate in compliance with environmental regulations. As members




   of the Flexographic Technical Association, the company was able to follow progress in




   technology through the publications and meetings of the FT A. The role of the main ink




   supplier was also crucial, as it eventually did find the right balance of composition of the




   water-base ink. But most significant of all was the commitment of the current president and




   his management team to installing a pollution prevention program at the facility.









6. Future Developments




   The firm is seeking to work with other substrates in order to move the company into other




   markets and increase its performance. There has been increased pressure from some clients to




   have Firm X conform to the ISO 9000 guidelines. ISO 9000 is a series of standards which




   were developed by a technical committee of the International Standardization Organization




   (ISO) to harmonize manufacturing  quality requirements internationally. These standards




   contain requirements for the elements of an effective quality management system, including




   compliance with environmental guidelines.  Companies that  wish to comply must require their




   suppliers to do so as well, hence, the pressure from Firm X's customers.  The issue of




   compliance with ISO 9000 seems inevitable, and management has undertaken efforts in this




   direction, but prefers not to specify those efforts in this study.
                                                                                      30

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FINDINGS









This study has made the following findings regarding the emission reduction experiences of the



three flexographic printing facilities:
1.
 Several key factors consistently arose as the companies in the study evaluated their




 emission reduction experiences.  Some make the solvent-base ink and incinerator method




 of VOC compliance more attractive to printers. These include:




 •   Gloss, which adds considerably to the quality of the printed image, and is considered




    easier to achieve using solvent-base ink than water-base ink;




 •   Price, as solvent base-ink generally costs 10-20% less than water-base ink;




 •   Speed of the presses, as solvent-base ink generally allows 10-20% faster runs than




    water-base ink;




•   Ease of operation, using solvent-base ink is considered the simpler solution for press




    operators, but requires the installation of an incinerator system.
   On the other hand, several important factors weigh in favor of the water-base ink approach.



   These include:




      *  Initial capital investment, as the water-base ink method is more economical than the




         incinerator method;




      •  Ink mileage, with water-base ink exceeding solvent-base ink by 15-30%;




      •  Color consistency which is better maintained with water-base ink; and




      *  Working environment for employees, which is safer.
                                                                                      31

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2.  The two facilities studied which successfully converted to water-base ink concluded that




    doctor blade boxes (preferably enclosed) are essential on all flexographic presses. Doctor




    blades improve ink distribution by wiping excess ink off the anilox roller, while enclosing the




    doctor blades eliminates evaporation loss.  At Packaging Specialties, during the time of using




    solely water-base ink, none of the presses operated using doctor blades, which partially




    explains the failure of the conversion to water-base ink and the resulting decision to revert to




    solvent-base ink and install an incinerator system.









3.  In each case, the ability and willingness of the ink supplier to work with the printer in




    developing an effective water-base ink was key to success or failure of the conversion.




    Flexographic printers rely on the ink suppliers to develop an ink that will meet the company's




    requirements regarding speed, gloss, consistency, price, and mileage. This applies, in




    particular, to the development of water-base ink for  less used substrates, as those seem to be




    neglected for economic reasons.
                                                                                         32

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                                           References





 EPA, Profile of the Printing Industry. August 1995. EPA 310-R-95-014.




 EPA, Profile of the Printing Industry. August 1995. EPA 310-R-95-014.




 EPA, Profile of the Printing Industry. August 1995. EPA 310-R-95-014.




 EPA, Profile of the Printing Industry. August 1995. EPA 310-R-95-014.




 EPA, Profile of the Printing Industry. August 1995. EPA 310-R-95-014.




 EPA, Use Cluster Analysis  of the Printing Industry. May 1992.




 EPA, Use Cluster Analysis of the Printing Industry. May 1992.




 EPA, Use Cluster Analysis of the Printing Industry. May 1992.




 Foundation of FlexograpHc  Technical Association. Flexography, Principles and Practices. Fourth Edition.




 EPA, Profile of the Printing Industry. August 1995. EPA 310-R-95-014.




 Foundation of Flexographic Technical Association. Flexography, Principles and Practices. Fourth Edition.




 Foundation of Flexographic Technical Association. Flexography, Principles and Practices. Fourth Edition.




 Foundation of Flexographic Technical Association. Flexography, Principles and Practices. Fourth Edition.




 Foundation of Flexographic Technical Association. Flexography, Principles and Practices. Fourth Edition.




 Foundation of Flexographic Technical Association. Flexography, Principles and Practices. Fourth Edition.




 Foundation of Flexographic Technical Association. Flexography, Principles and Practices. Fourth Edition.




EPA, Profile of the Printing Industry. August 1995. EPA 310-R-95-014.




EPA, Profile of the Printing Industry. August 1995. EPA 310-R-95-014.

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Appendix A

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 7,500 CFMCATALYTICINCINERATOR -THREE PRESSES
 Based on Possible Reduction of Air Flow from 18,500 CFM Theoretical
Annual Operating Costs
1. Cost of Unit
Installation (estimated)
Total Costs of System
2. Less Down Payment
3. Financed Amount
4. Interest Amounts*
5. Operating Costs
Total Costs
included
included
$350,000
35,000
315,000
184,530
Percent





10.0%

A. Electricity
B. Natural Gas
C. Catalyst
D. Maintenance
E. Indirect Costs
Total Operating Costs
6. Total Cost of Controls
7. Deduct Tax Savings (35%)
8. VOC REDUCTIONS
A. Tons emitted Per Projection based on 1993-94
Purchases
B. Percent Reduction
Required
C. Tons Reduced
TOTAL COST OF CONTROLS PER TON REDUCED
Annual Costs




$31,500
18,453

15,100
14,060
8,000
10,000
0
47,160
97,113
63,123

18.30
60%
10.98
$5,749
*  Interest accrued over ten year period

Notes:
1.  Equipment Life - ten years
2.  Electrical based on vendors' data - $7.55/hour; may be high for Baltimore.
3.  Natural gas based on vendors' data - $7.03/hour; may be high for Baltimore.
4.  Catalyst replacement based on attrition over seven years.
5.  Maintenance; labor and parts estimated at $10,000 minimum.

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              REQUEST FOR VARIANCE—AIR GUIDE 20
Annual Operating Costs
1. Cost of Unit
Installation (estimated)
Total Costs of System
2. Less Down Payment
3. Financed Amount
4. Interest Amounts*
5. Operating Costs
A. Electricity
Total Costs
97,600
20,000
117,600 est.
11,760
105,840
91,361
Percent





14.0%


B. Natural Gas
C. Catalyst
D. Maintenance


E. Indirect Costs
Total Operating Costs
6. Total Cost of Controls
7. Deduct Tax Savings (35 %)
8. VOC REDUCTIONS




A. Tons emitted Per Projection based on 1993-94
Purchases
B. Percent Reduction
Required
C. Tons Reduced


TOTAL COST OF CONTROLS PER TON REDUCED
Annual Costs




$10,584
9,136

960
3,840
1,428
2,500
[0
8,728
28,448
18,491

4.70
60%
2.82
$6,557
*  Interest accrued over ten year period.
Note:
1.  Equipment life - ten years

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                                    5,000 CFM
Annual Operating Costs
1. Cost of Unit
Installation (estimated)
Total Costs of System
2. Less Down Payment
3. Financed Amount
4. Interest Amounts*
5. Operating Costs
Total Costs
201,576
0
201,576
20,158
181,418
82,714
Percent





8.0%

A. Electricity
B. Natural Gas
C. Catalyst
D. Maintenance
E. Indirect Costs
Total Operating Costs
6. Total Cost of Controls
7. Deduct Tax Savings (35 % )
8. VOC REDUCTIONS
A. Tons emitted Per Projection based on 1993-94
Purchases
B. Percent Reduction
Required
C. Tons Reduced
TOTAL COST OF CONTROLS PER TON REDUCED
Annual Costs




18,142
8,271

7,960
9,600
1,755
5,000
0
24,315
50,728
32,973

49.03
60%
29.42
$1 121
*  Interest accrued over ten year period.

Notes:
1.  Equipment Life - ten years
2.  Electrical based on $1.99/hour; DEC-E-TEC at 402,300 BTU.
3.  Natural gas based on $2.40/hour; DEC-E-TEC at 402,300 BTU.
4.  Catalyst replacement based on attrition over seven years.
5.  Maintenance; labor and parts estimated at $5,000 minimum.

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