United States      Office of Air Quality      EPA-450/2-78-033
           Environmental Protection  Planning and Standards     OAQPS No. 1.2-109
           Agency        Research Triangle Park NC 27711  December 1978
           _—
?,EPA      OAQPS Guideline
           Series

           Control of Volatile
           Organic Emissions
           from Existing
           Stationary Sources

           Volume VIII: Graphic
           Arts - Rotogravure
           and Flexography

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                               EPA-450/2-78-033
                               OAQPS No. 1.2-109
       Control of Volatile
       Organic Emissions
                from
Existing Stationary Sources -
 Volume VIII: Graphic Arts -
Rotogravure  and Flexography
                Second Printing
            (First printing errata corrected)
       Emission Standards and Engineering Division
           Chemical and Petroleum Branch
       U.S. ENVIRONMENTAL PROTECTION AGENCY
          Office of Air and Waste Management
        Office of Air Quality Planning and Standards
       Research Triangle Park, North Carolina 27711

                           U.S. Environmental Protection Agency
                December 1978   ?^J" ^J^ (PL-12J)
                           // West Jackson Boulevard, 12th Fkw
                           Chicago. It 60604-3590

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                                      OAQPS GUIDELINE SERIES


The guideline series of reports is being issued by the Office of Air Quality Planning and Standards (OAQPS) to
provide  information to state and local air pollution control agencies; for example, to provide guidance on the
acquisition and processing of air quality data and on the planning and analysis requisite for the maintenance of air
quality.  Reports published in this series will be available - as supplies permit - from the Library Services Office
(MD-35), U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711, or, for a nominal
fee, from the National Technical Information Service, 5285 Port Royal Road, Springfield, Virginia 22161.
                                  Publication No. EPA-450/2-78-033
                                        (OAQPS No. 1.2-109)

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                    CONVERSION FACTORS FOR METRIC UNITS
                                                           Equivalent

Metric Unit                     Metric Name               English Unit



Kg                           kilogram (103grams)            2.2046 lb


liter                        liter                          0.0353 ft3


m                            meter                          3.28 ft

 _                                                                 3
m                            cubic meter                   35.31 ft


Mg                           megagram (10 grams)           2,204.6 lb


metric ton                   metric ton (10 grams)         2,204.6 lb
     In keeping with U.S. Environmental Protection Agency policy, metric


units are used in this report.  These units may be converted to common


English units by using the above conversion factors.


     Temperature in degrees Celsius (C°) can be converted to temperature


in degrees Farenheit (°F) by the following formula:



     t°f = 1.8 (t°c) + 32





     t°f = temperature in degrees Farenheit





     t°  = temperature in degrees Celsius or degrees Centigrade
                                       m

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                            TABLE OF CONTENTS


CONVERSION FACTORS FOR METRIC UNITS	  iii

1.0  INTRODUCTION AND SUMMARY 	  1-1

     1.1  General Discussion 	  1-1

     1.2  Achievable Control Levels 	  l-i

     1.2.1  Available Add-On Control Devices 	  1-2

     1.2.2  Water Borne and High-Solids Inks 	  1-3

     1.2.3  Alternative Control  Methods 	  1-3

     1.2.A  Differentiation of Coating and Printing 	  I-/1

     1.3  Cost Effectiveness 	  1-5

2.0  SOURCES AND TYPES OF EMISSIONS	  2-1

     2.1  General Discussion 	  2-1

     2.2  Printing Processes 	  2-1

     2.2.1  Flexography 	  2-2

     2.2.2  Gravure 	  2-2

     2.2.2.1  Uses for Flexographic and Rotogravure Printing
                 and Coating 	  2-A

     2.2.2.2  Nature of the Flexographic and Gravure Printing
                 Industries 	  2-5

     2.3  Stock Feeding Methods  	  2-5

     2.4  Printing Inks 	  2-5

     2.5  Emmission Points  	  2-5

     2.5.1  Dryer Types	  2-7

     2.6  National Emmissions 	  2-7

     2.7  References  	  2-Q


                                    iv

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3.0  APPLICABLE SYSTEMS OF EMMISSION REDUCTION	  3-1

     3.1  Introduction 	  3-1

     3.2  Add-On Equipment 	  3-1

     3.2.1  Carbon Adsorption 	  3-1

     3.2.2  Incineration 	  3-3

     3.2.2.1  Heat Recovery 	  3-A

     3.3  Use of Low Solvent Inks for Packaging Gravure
             and Flexographic Printing 	  3-6

     3.3.1  Water-Borne Inks 	  3-9

     3.4  Summary of Applicability of Control Methods 	  3-°

     3.A.I  Rotogravure 	  3-9

     3.4.2  Flexography 	  3-10

     3.5  References 	  3-11

4.n  COST ANALYSIS	  4-1

     4.1  Introduction 	  4-1

     4.1.1  Purpose 	  4-1

     4.1.2  Scope 	  4-1

     4.1.3  Use of Model Plants 	  4-1

     4.1.^  Bases for Capital Costs 	  4-"

     4.1.5  Bases for Annualized Costs 	  4-^

     4.2  VOC Control  in the Printing Industry 	  4-6

     A.2.1  Model Plant Parometers 	  4-fi

     4.2.2  Control  Costs 	  4-6

     4.2.3  Cost-effectiveness 	  4-21

     4.2.4  References 	  4-2fi

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5.0  ADVERSE AND BENEFICIAL EFFECTS OF APPLYING CONTROL
        METHODS	  5_1

     5.1  Incineration 	  5_1

     5.2  Carbon Adsorption 	  5_T

6.0  MONITORING TECHNIQUES AND ENFORCEMENT ASPECTS	  6-1

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                   1.0   INTRODUCTION  AND  SUMMARY

1.1   GENERAL DISCUSSION
     This report is one of a continuing series designed to assist State
and local jurisdictions in the development of air pollution control
regulations for volatile organic compounds. (VOC) which contribute to the
formation of photochemical oxidants.   The report deals with VOC
emissions from the graphic arts operations which utilize inks containing
volatile organic solvents.
     The graphic arts  industry encompasses printing operations which fall
into four principal categories, namely:  letterpress, offset lithography,
rotogravure  and flexography.  This guideline  is  applicable to both the
flexographic and rotogravure  processes as  applied to both  publication
and  packaging  printing.   It does not  apply to offset lithography or
letterpress  printing.
 1.2  ACHIEVABLE CONTROL LEVELS
      Rotogravure and flexography utilizes inks which contain large
 fractions  (50 to 80 percent or higher) of volatile organic solvents.
 Certain applications  are as high as 96 percent  solvent.
      Below  are provided emission limitations  that represent the  presumptive
 norm that  can be  achieved through the application of reasonably  available
 control technology (RACT).  Reasonably  available control  technology is
 defined as  the lowest emission limit  that a  particular source is
                                       1-1

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 capable  of meeting  by  the  application of  control  technology  that  is
 reasonably available considering  technological  and economic  feasibility.
 It may require technology  that has been applied to similar,  but not
 necessarily  identical  source categories.   It must be cautioned that the
 limits reported  in  this section are based  on capabilities and problems
 which are general to the industry, but may not be applicable to every
 plant.
 1.2.1  Available Add-On Control Devices
     The vast majority of  rotogravure and  flexographic printing units use
 organic solvent-borne  inks.  Emission reduction can be achieved by use
 of carbon adsorption or incineration sytems.  A reduction efficiency of
 90 percent of the VOC delivered to these devices can and should be achieve.;.
 In addition, it  is  implicit the RACT requires installation of the best
 practicable  capture system to assure that  the VOC is directed to the control
 device.  A number of carbon adsorption systems at publication and roto-
 gravure plants have been reported to achieve overall recovery efficiencies
 of 75 percent or more, based on material balances.  Assuming adsorber
 efficiencies of 90  to 95 percent,  capture efficiencies of 75 to 85 percent
 were being realized.  There is no available method of measuring capture
 efficiency directly.
     Large packaging rotogravure presses could be expected to have capture
efficiencies  somewhat less  than publication plants because of shorter
runs  and other factors.   A capture efficiency of 75 percent would appear
to be reasonable, with  an  overall  VOC recovery/control efficiency of about
 65 percent for either adsorption on incineration systems.
                                     1-2

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     The capture problem for flexographic presses is more difficult than
for  rotogravure presses because of the manner of construction of
flexographic presses.  The printing units and dryers are mounted on a
vertical circular  axis such that effective hooding and ducting are
difficult  to construct.  A capture efficiency of 70 percent  appears
to  be  reasonable for  these presses for an overall VOC control efficiency
of  60  percent.
 1.2.2   Water-Borne and High Solids Inks
     Water-borne  inks are  available which will  meet  some  printing
 requirements  of both  rotogravure  and  flexography.   Ink manufacturers
 are working to develop water-borne  inks  which will  meet  additional
 requirements.   EPA desires to encourage  such developments because  of
 the material  and energy  saving potentials.   It  is  recommended that
 printing systems in which  all printing units utilize a water-borne
 ink whose volatile portion consists  of 75 volume percent water and 25
 volume percent organic solvent (or a lower VOC content)  be considered
 equivalent to the exhaust treatment systems described in Section 1.2.1.
       Some printing systems may be able to utilize water-borne inks for
 heaviest coverage, but still require some solvent-borne  inks for light
 coverage.* For such  systems, if a 70 volume percent overall reduction
 of  solvent usage  is  achieved  (compared to all  solvent-borne ink usage),
 the complete  operation can be considered equivalent to the  exhaust treat-
 ment  systems  described in Section 1.2.1.
     There  are  no  high solids  inks now in  use in rotogravure  or
flexographic printing  operations.   However,  ink  manufacturers have  stated
that they will  continue development work  in  this area.   It is recommended
that inks which contain 60  percent or more non-volatile material  be exempt
from emission limitations in order to encourage development of high
solids  inks.
*Heavy coverage means large areas of  a given color.  A thin  strip of  a
  given color  is an example of light coverage.
                                 1-3

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 1.2.3  Alternative  Control  Methods
      Publication  rotogravure  uses  inks  with  solvent  mixtures  of  water-
 immiscible  solvents.   The  vapor  can  be  recovered with  carbon  adsorption
 systems and reused  by  ink  manufacturers and  printers.   Some systems
 yield a net profit  after amortization and  operating  expenses.
      Printing of  "packaging materials by rotogravure  and flexography
 requires inks with  more complex  solvent mixtures.  Many of the solvents
 are water-soluble.  Conventional carbon adsorption systems using steam
 for regeneration  may not be a viable control method  because the
 recovered solvents  cannot  be  reused.  Reformulation  of the inks  may,  in
 some cases,  make  carbon adsorption a viable  control  technique.   A new
 fluidized bed carbon adsorption  system  uses  nitrogen for desorption and
 may provide  a viable method for  recovering solvents  from packaging inks;
 as  well  as  publication  inks.   Incineration systems with heat recovery
 may be a more practical  solution  for  some packaging operations.
 Incineration  has  been shown to provide  90 percent and  greater removal
 of  VOC  in many similar applications.
 ]-2-4   Differentiation of Coating and Printing Operations
     The production of packaging materials involves two principal
 operations which  emit volatile organic compounds:  1)  coating and
 laminating of paper, film,  and foil; 2)  printing of words,  designs, and
 pictures upon webs of paper, film,  and foil.   For  the purposes of this
 document, coating  is defined as the application of a  uniform layer of
material across the entire  width of a web.   Printing  is the formation
of words, designs  and  pictures, usually  by a  series of application rolls
each with only partial  coverage.
                             1-4

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     The recommended emission limits for coating and laminating operations
in the production of packaging materials are given in Volume II of this
series.*  The emission limits in this document apply to printing
operations in the production of packaging materials and to publication
rotogravure printing operations.  However, all units in a machine which
 has both coating and printing units will be considered as performing
 a printing operation.   A typical  operation is as follows:  The first unit
 applies a uniform background color; subsequent units print addtiional
 colors; the final unit applies a  varnish overcoat.  Such a machine would
 be subject to the guideline for graphic arts.

 1.3  COST EFFECTIVENESS
      The cost effectiveness of carbon adsorption is influenced strongly
 by VOC concentration and tonnage  and by the value of recovered solvent.
 Where VOC concentration is 1200 ppm, cost effectiveness range from
 $51  to $38/Mg ($46 to  $34/ton)  of VOC recovered over the range of
 2000 Mg (2200 tons) to 4000 Mg (4400 tons) of VOC input per year. At a
 VOC concentration of 2400 ppm and 2000 Mg/yr input the recovery system
 pays for itself, and at 4000 Mg/yr input yields a $15/Mg profit.
 These values  are  typical  of  a large  operation  where the  solvent can  be
reused  in  the process  or  sold to  an  ink  manufacturer.  No data are"
available  for smaller  carbon systems.
     The  cost effectiveness  of  incineration  systems are  strongly  influenced
by annual  tonnage of the  VOC controlled  and  by the VOC concentration  and
degree  of  heat recovery.   For a VOC  input  rate of  about  90  Mg/yr
(100 tons/yr) the cost of effectiveness  ranges from $600/Mg  ($600/ton)
of VOC  controlled at a concentration of  1500  ppm  and 85  percent heat
*Control of Volatile Organic Emissions from Existing Stationary Sources -
 Volume II: Surface Coating of Cans,  Coils, Paper,  Fabrics,  Automobiles,
 and Light-Duty Trucks.   EPA-450/2-77-008,  May 1977.
                                    1-5

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recovery to $2000/Mg ($1800/ton)  at a VOC concentration of 500 ppm and
no heat recovery.  For a VOC input rate of about 1500 Mg/yr (1650 ton/yr)
the cost effectiveness ranges from $120 per ton of VOC at concentrations
of 1500 ppm and 85 percent heat recovery to $1500/Mg ($1650/ton) for
concentrations of 500 ppm and no heat recovery.
     The greatest VOC control costs are associated with small  flexo-
graphic printing operations having relatively low VOC levels and often
operated intermittedly.  In many cases, it may be possible to  improve
capture systems resulting in higher VOC levels and lower ventilation rates,
Even with improved capture systems, it may not be reasonable to require
exhaust gas treatment at many small printing installations.
                                 1-6

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                    2.0  SOURCES AND TYPES OF EMISSIONS

2.1  GENERAL DISCUSSION
     Originally the term graphic arts meant only such fine arts as painting
and drawing.  In time the meaning expanded and shifted to various picture
reproduction methods, such as engraving, etching, and lithographing.
Finally, the graphic arts industry has become simply a different name for
the printing industry.
     This diverse industry is characterized by a large number of small
plants and a small number of large plants.  Approximately 80 percent of
                                                               2
commercial printing establishments employ fewer than 20 people.   The
largest publication gravure plants employ hundreds of people and have
a  daily potential VOC  emission  rate of 20 Mg  (22 tons).
     Printing establishments are scattered throughout the country but the
vast bulk of the printing has historically been done in the large
metropolitan areas.  Most periodicals are published  in New York, Chicago,
Philadelphia and Los Angeles.2   However,  in  the  last few years several
new  large plants have  been built in non-urban areas.  This appears  to be a
new  trend.

2.2  PRINTING  PROCESSES
     Printing  operations  of  any sizeable  volume  utilize  presses  in  which
the  image carrier  is  curved  and mounted on  a cylinder  which rotates,
(rotary presses)  or  the image  is engraved  or  etched  directly on  a cylinder.
                                     2-1

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In direct printing the image is transferred directly from the image to
the print surface.  In indirect printing the image is transferred to an
intermediate roll (called a blanket) and thence to the print surface.
2.2.1  Flexography
     In flexographic printing, the image areas are raised above the non-
image surface.  The distinguishing feature is that the image carrier is
made of rubber and other elastomeric materials.  A feed cylinder rotates
in a trough of ink (called an ink fountain), and delivers ink to the
plate (image), cylinder, through a distribution roll, as shown in Figure 2.1.
Flexographic presses are usually of rotary web design, i.e., roll-fed.
Presses printing upon corrugated paperboard are a major exception.
     Flexography uses very fluid inks, (low viscosity) typically about
75 volume percent organic solvent.  The inks dry by solvent absorption into
the web and evaporation, usually in high velocity air dryers at temperatures
below 120 C.  Solvents compatible with rubber or other plate materials
must be used.  Typical solvents are alcohols, glycols, esters, hydrocarbons
and ethers.
2.2.2  Gravure
     In the gravure method printing, image areas are recessed relative to
non-image area.  The image carrier is a copper-plated steel cylinder
usually also chrome plated to enhance wear resistance.  The image is in
the form of cells or cups mechanically or chemically etched in the surface.
Typically, a gravure cell is 35 y (.0014 inches) deep by 125 y (.005 inches)
square, with 22,500 cells to the square inch.   The gravure cylinder rotates

                                     2-2

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in an ink trough or fountain.   Excess ink is removed by a steel  doctor
blade.  The ink in the cells is then transferred to the web when it is
pressed against the cylinder by a rubber-covered impression roll, as
shown in Figure 2-2.  Rotary gravure presses are called rotogravure presses.
     Rotogravure also requires very fluid inks.   Solvent content ranges
from 50 to 85 percent or higher.   Typical  solvents, include alcohols,
aliphatic napthas, aromatic hydrocarbons, esters, glycol ethers, ketones,
nitroparaffins and water.   Solvent is evaporated in low temperature driers,
38° to 93°C (100° to 200°F).  The hot air infringement dryers usually are
indirectly heated by steam or hot air.  Steam drum dryers are also used.
2.2.2.1  Uses for Flexographic and Rotogravure Printing and Coating
     Flexographic and gravure printing and coating applications  fall into
three major cateogries:  publication, packaging and specialties.  In the
publications field, magazines, mail order catalogues,  brochures, newspaper
supplements, comics and other commercial printing are printed by the
gravure process.  Packaging products predominantly printed by gravure,
include cigarette cartons and labels, can labels, detergent cartons, and
many other folding cartons.  Flexography is typically used for bread bags,
multi-wall bags, milk cartons, corrugated paper board, paper cups and plates,
labels, tags, tapes and envelopes.  Both printing processes are used for
flexible film and foil to be used for overwraps or laminates, composite
cans, carrier cartons, frozen food wraps, and gift wraps.
      In the specialty field, both flexography and gravure are used for wall
covering and decorating household paper products such as towels and tissue.
Gravure is used for floor covering, cigarette filter tips, vinyl upholstery,
                                      2-4

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woodgrains,  and a variety of other products.  Gravure is also used for
applying accurately metered quantities of coatings to paper and other
kinds of webs in various manufacturing operations where its fast-drying
inks and the ability to print well on a wide variety of surfaces are
advantageous.   Recommended emissions limitations from the coating uses
of gravure are covered in other volumes of this guideline series, such
as Volume II:  Surface Coating of Cans, Coils, Paper, Fabric, Automobiles,
and Light-Duty Trucks, and Volume VII: Factory Surface Coating of Flat Wood
Paneling.  The recommended emission limitations given in this volume do not
apply to these operations.
2.2.2.2  Nature of the Flexographic and Gravure Printing Industries -
Publication printing is done in large printing plants, numbering less than
            3
50 in total.   Package and specialty printing by flexography and gravure is
done by a considerably larger number of companies, ranging from large
integrated packaging companies with many press units of small captive
operations with only one or two press units.   It is estimated that there
                                                  /i
are from 13 to 14 thousand gravure printing units'* and 30,000 flexographic
printing units.

2.3  STOCK FEEDING METHODS
     Presses are divided into two classes by feeding methods:
sheet-fed and roll-fed.  Stock fed from a roll  is referred to as a web.
High volume roll  presses are significant sources of VOC.

2.4  PRINTING INKS
     Printing inks are composed of the same type of ingredients  as surface
coatings:  pigments,  vehicles  and solvents.   Of  course,  they are  tailored
to have different properties  than coatings.   In  addition  to regulatory

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limitations required by EPA, OSHA, FDA, and USDA,  the specifications
for an ink are governed by a number of considerations such as:  (1)
printing processes and methods; (2) kind of press; (3) paper or other
substrate; (4) drying process; (5) desired finish, matte, gloss, etc.,
(6) end use of the printed product; (7) color; (8) fabrication  method to
which the printed stock will be subjected; (9) sequence of ink  application,
in multicolor printing.
     The solvent content of inks varies widely.  Flexograph and gravure ink
contain 50 to 85 percent solvent and dry by solvent evaporation.  Water-
borne inks are used for special applications; they contain 5 to 30 percent
VOC solvent.
     The following solvents are representative of those used in printing
inks, usually in combinations:
                     Toluene             Ethanol
                     Xylene              Butanol
                     Heptane             Glycols
                     Isooctane           Glycol ether esters
                     Mineral Spirits     Glycol esters
                     Naphtha             Acetone
                     Hexane              Methyl ethyl ketone
                     Propanol            Isopropyl acetate
                     Isopropanol         Normal propyl acetate
                     Methanol            Ethyl acetate
2.5  EMISSION POINTS
     Roll-fed printing presses require dryers to evaporate solvent in
order to produce a product with immediate handleability.  Solvent vapors
are emitted from printing units and dryers.  Some printing operations
which utilize air pollution control equipment have the printing units
hooded and vented to the control device.
                                     2-6

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2.5.1  Dryer Types
     A variety of dryer types are used including steam-heated and other
indirectly heated designs.  Direct-fired dryers are mainly high velocity/
hot air dryers.  Steam-heated dryers are the principal type of indirectly
heated dryers.
     Steam-heated dryers are of two types: drum and forced circulation
dryers.  Drum dryers are cylinders to which steam is applied.  The printed
web is brought around the drum with the printed surface on the outside.
The web is heated by conduction.  In forced circulation dryers, air is
heated by passing over steam coils or tubes and is circulated through the
drying chamber by a fan(s).

2.6  NATIONAL EMISSIONS
     Data for a direct determination of the total national emissions from
                                                                       2
the printing industry are not available.  However, a report by Gadomski
contained data on the ink and solvent usage for 1968 from plants estimated
to have 32 percent of the national total.  Total ink usage for these
plants was 141 million pounds.  Additional solvent for ink dilution
and clean-up totaled 21 million gallons.  Total solvent usage was 95,000
tons (87,000 Mg).  From this the study suggested a 1968 national total
usage of 300,000 tons (270,000 Mg).  Assuming a three percent annual growth
rate, the 1976 solvent usage rate would be 380,000 tons (340,000 Mg).  The
average degree of control is estimated to be 30 percent leaving uncontrolled
emissions of 270,000 tons per year (240,000 Mg/yr).
     The above report separated the ink consumption into a percentage for
each printing process by the survey results and by a survey conducted by
the National Association of Printing Ink Manufacturers.  The additional
                                      2-7

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solvent figures were also separated by printing process type.   The three

sets of figures were averaged to give the following breakdown:

                                 Percent of              Emissions
        Process                  Emissions                 Mg/yr

        Gravure                      41                  100,000
        Lithography                  28                   67,000
        Letterpress                  18                   43,000
        Flexography                  13                   30,000
                                                         240,000
                                       2-8

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2.7  REFERENCES

1.  Strauss, Victor, The Printing  Industry.   Printing  Industries  of
    America, Inc., Washington,  D.C.  1967.

2.  Gadomski, R.  R., et. al.  Evaluations  of  Emissions  and  Control
    Technologies  in the Graphic Arts Industries,  Phase I,  Graphic Arts
    Technical Institute.  August 1970.

3.  George, H.  F., Gravure Industry's  Environmental  Program.   In
    conference  on  Environmental Aspects  of Chemical  Use in Printing
    Operations.  EPA-5601/1-005.  Office  of  Toxic Substances,
    Environmental  Protection  Agency, January 1976.  pp  204-216

4.  Long, R. P.,  and W. R. Daum, "Gravure  Survey,"   Package Printing
    Diecutting, January 1975, pp 12-14.   Cited  in Reference 3.

5.  Comment letter from the Flexographic  Technical  Association,
    November 27,  1978.                :
                                      2-9

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                 3.0  APPLICABLE SYSTEMS OF EMISSION REDUCTION

3.1  INTRODUCTION
      Emissions of volatile organic compounds (VOC)  can be reduced by
add-on control  devices and by the use of water-borne and low solvent
inks.  In this  chapter the applicability of these methods to the
various printing processes will be reviewed.
3.2  ADD-ON EQUIPMENT
      Fume incinerators and carbon adsorbers are the only devices which
have proven to have a high efficiency in controlling vapors from rotogravure
and flexographic printing operations.
3.2.1  Carbon Adsorption
      Recovery of solvents by use of carbon adsorption systems has been
successful at a number of large publication rotogravure plants.  The presses
in question used a single, water immiscible solvent (toluene) or a mixture
which is recovered in approximately the proportions used in the ink.  Three
such plants were reported to have systems which recover 6,000 to 7,000
gallons (20 to 23 Mg) per day of solvent each.1'2'3  These recovery systems
were installed for economic and regulatory reasons.   Solvent is evaporated
from the web in indirect steam heated dryers which precludes any solvent
decomposition.   Regeneration is accomplished by use of steam, followed by
condensation and a simple decantation.  Because the solvents are water-
immiscible a relatively simple system for separating condensed water and
solvent is possible.
                                      3-1

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      Some rotogravure operations, such as  printing and coating  of packaging
materials, utilize inks and coatings  containing complex solvent  mixtures.
Many of the solvents are water soluble.  The solvents  required for a folding
carton operation, for example, consists of  toluene, heptane,  ethyl  acetate,
methyl ethyl  ketone, and isopropyl alcohol.   The last  three are  soluble
in water.  If a carbon recovery system with  steam regeneration were used,  a
distillation  system would be required to recover and separate the water-
soluble solvents.  Since azeotropes (constant boiling  mixtures)  are formed,
adequate separation would be very difficult.  In addition,  frequent product
changes result in varying solvent combinations, making solvent recovery
for reuse difficult and costly.
      However, reformulation of inks  offers  a possible method of avoiding
the above difficulties.  Many of the  present solvent mixtures were developed
to comply with Rule 66 of Los Angeles County and similar legislation. Because
of EPA's 1977 policy statement on reactivity, it is now possible to revert
to the simpler solvent mixtures used  in the  past.  Many printers will be
able to revert to a mixture of immiscible hydrocarbons and  a single ester
or MEK, which could be reused as a mixture  after dewatering.   It will be
practical for many packaging type printers  to solve a  large percentage of
their emission control requirements by the  use of carbon adsorption and
                                        4
relatively simple dewatering techniques.
      A new type of carbon adsorption system offers another method of
avoiding trouble with water soluble solvents.  A fluidized  bed carbon
system, developed in Japan, is being  marketed in the United States.  The
carbon is in  the form of highly abrasion resistant carbon beads.  In the
                                    3-2

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adsorbing section the beads cascade in the fluidized state down a tray
tower.  Solvent laden air enters the bottom of the tower and leaves at the
top.  The beads then flow through the desorbing section in a dense bed where
they are heated indirectly in the presence of nitrogen which acts as a
desorbing gas.  The nitrogen is then cooled in indirect heat exchangers to
condense the solvent.  The nitrogen is then recycled to the desorber.
      The following advantages are claimed for the fluidized bed system,
relative to fix bed systems:
      .  Better thermal efficiency
         Lower blower power consumption
      .  No mixing with water at desorption
      .  No valves or cycling equipment
      .  less space required
      .  Less susceptible  to blinding
         Can  be regenerated at higher temperatures to  remove high  boiling
         materials
      A  disadvantage of this system  is that  relatively constant  air  volume
must  be  maintained.  Also  the capital cost may be higher.
      Additional  information on  theory, design and practices concerning
carbon  adsorption systems  is given  in Volume  I (EPA-450/2-76-028)  of this
                  5
guideline series.
3.2.2  Incineration
       Incineration  destroys organic  emissions  by  oxidizing  them  to carbon
dioxide  and water vapor.   Incineration is  a  technically feasible method  of
                                     3-3

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controlling emissions from all  printing operations.   Both direct flame
(thermal) and catalytic incinerators are potential  methods of controlling
emissions from flexography and  packaging gravure printing.
3.2.2.1  Heat Recovery
      The cost of operating an  incineration system  can be substantially
reduced by the use of heat recovery equipment.   Primary heat recovery uses
the hot incinerator exhaust gases to preheat the dryer exhaust gases prior
to incineration.   A secondary heat exchanger can sometimes supply the heated
air required to operate the dryer.  Cost data is given in Chapter 4 for
incineration systems with and without heat recovery.   Incineration and
heat recovery systems are described in Volume I  (EPA-450/2-76-028) of this
series.
       In addition to direct-flame and catalytic incinerators, a third
type is available.  Pebble bed  incinerators combine the functions of a
heat exchanger and a combustion device.  A diagram  of such a system
is shown in Figure 3-3.  The solvent laden exhaust  from the dryers and
floor sweeps enter one of the pebble beds which  has  been heated by the
combustion chamber exhaust in the previous cycle. Oxidation of the
vapors starts in  the preheat bed and is completed in  the combustion
chamber.  The exhaust gases exit through a second pebble bed transferring
heat to the pebbles.  The dampers are reversed  periodically, thereby
alternating the functions of the two pebble beds.
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      An incinerator having three or more pebble beds will  allow one
pebble bed to be removed from the process while the other two pebble beds
are acting as both the energy recovery after incineration and as  air
preheat prior to incineration.   The use of the third pebble bed  will further
allow the residual fumes in that chamber to be flushed to the combustion
zone prior to flow reversal, thus providing the highest level of combustion
efficiencies.  Such flushing is not possible if there are only two pebble
beds.  A diagram of a five bed  system is shown in Figure 3-4.
      Pebble bed systems have been designed to achieve a heat recovery
efficiency of 85 percent.  When the vapor concentration is  about 10 percent
of the LEL, the burner throttles to a pilot light condition, the VOC fumes
furnishing virtually all of the fuel requirement during periods  of continuous
operation.
      Recovery of heat from incineration exhaust gases can  also  be
accomplished by the use of liquid media heat exchangers.  A system using
hot oil to transfer heat from the incinerator exhaust to the dryers has
been installed on a number of rotogravure presses at paperboard  and bag
printing plants.  This system utilizes an organic vapor sensing  device to
control dampers in dryer exhaust so as to maintain a preset percentage of
the Lower Explosive Limit (L.E.L.).  Thus the exhaust rate  is minimized, and
the VOC furnishes the greater part of the heat to operate the incinerator.
Also the incinerator furnishes  the heat to operate the dryers.   A sketch of
such a system is shown in Figure 3-5.
3.3  USE OF LOW SOLVENT INKS FOR PACKAGING GRAVURE AND FLEXOGRAPHIC PRINTING
      Low solvent inks are of three types: water-borne, high-solids and
radiation curable inks.   Only water-borne inks are widely used at the present
time and are discussed in the following section.
                                      3-6

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 3.3.1   Water-Borne  Inks
       These  inks  are  not  completely  solvent-free,  as  the  volatile  portion
 contains  up  to  35 percent water soluble  organic  compounds.  Water-borne  inks
 are  used  extensively  in printing of  corrugated paperboard for  containers,
 or multi-wall bags  and other packaging materials made  of  paper and paper
 products.  There  is a limit  upon the amount  of water-borne  ink that can  be
 printed upon thin stock before  paper will  be seriously weakened.   Thus,
 the  expanded use of water-borne  inks  faces  this severe  limitation.
 3.4   SUMMARY OF APPLICABILITY OF CONTROL METHODS
       The available control  methods  for  each of  the  printing methods are
 summarized in the following  sections.
 3.4.1   Rotogravure
       Publication rotogravure operations  can be  controlled  by  carbon
 adsorption systems with a capture efficiency of  75-85  percent  of the VOC
 emitted from the  printing units  and  the  dryers.  The  carbon recovery system
 can  be  operated with  a recovery  efficiency of 90 percent  of the VOC entering
 the  carbon beds.  An  overall  emission reduction efficiency of  75 percent
 can  thus  be  achieved.
      Packaging rotogravure  printing  operations can be controlled  by
 incineration systems with an expected capture efficiency  of 70-80  percent
 and  a combustion efficiency  of 90 percent.  An overall emission reduction
 efficiency of 65 percent  can thus be achieved.
      Some rotogravure packaging printing operations  with less  demanding
quality requirements can  use water-borne  inks.  Most  water-borne inks
contain some  VOC as  a  co-solvent.  Emission limits  comparable  to carbon
adsorption and  incineration can  be achieved if the  solvent portion  of the
ink consists  of  75 volume  percent water and 25 volume percent organic solvent.
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3.4.2  Flexography
      Flexographic printing operations can be controlled by incineration
systems with an expected capture efficiency of 65-70 percent and a combustion
efficiency of 90 percent.   Thus an overall emission reduction efficiency of
60 percent can be achieved.
      Some flexographic packaging printing operations can utilize water-
borne inks.  Emission limits comparable to incineration can be achieved
when the solvent portion of the ink consists of 75 volume percent water
and 25 volume percent organic solvent.
                                     3-10

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3.5  REFERENCES

1.  George H. F., Gravure Industry's Environmental Program.  In con-
    ference on Environmental Aspects of Chemical Use in Printing Operations
    EPA-5601/I-75-005.  Office of Toxic Substances, Environmental
    Protection Agency, January 1976. pp 204-216

2.  Watkins, B.G., and P. Marnell, Solvent Recovery in a Modern
    Rotogravure Printing Plant.  In conference on Environmental Aspects
    of Chemical Use in printing Operations, EPA 5601/1-75-005.  Office
    of Toxic Substances, Environmental Protection Agency.  January 1976.
    pp. 344-355.

3.  Marvin, R. L., Recovery and Reuse of Organic Ink Solvents.  In
    conference on Environmental Aspects of Chemical Use in Printing
    Operations.  EPA 5601/1-75-005 Office of Toxic Substances,
    Environmental Protection Agency,  pp 367-387.  January 1976.

4.  Comment letter from Michael J. Worral, American Ceca Corporation.
    November 30, 1978.

5.  Control of Volatile Organic Emissions from Existing Stationary
    Sources - Volume I: Control Methods for Surface Coating Operations.
    U.S. Environmental Protection Agency.  Research Triangle Park, N.C.
    27711.  November 1976.

6.  Study of Systems for Heat Recovery from Afterburners.  Prepared
    for U.S. Environmental Protection Agency by Industrial Gas Cleaning
    Institute, Inc.  Stamford, Connecticut.  April 1978.
                                   3-11

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                             4.0  COST ANALYSIS
4.1  INTRODUCTION
4.1.1  Purpose
     This section presents estimated installed capital and annualized costs
for control of volatile organic compounds (VOC) from that portion of the
graphic arts industry involved in flexographic and rotogravure packaging
printing and rotogravure publication printing.  The section also includes
an analysis of the cost-effectiveness of the control methods.
4.1.2  Scope
     The analysis includes all the printing operations involved, i.e., the
application and drying or curing of inks.  Cost estimates have been developed
on the basis of retrofitting VOC controls on existing plants.  Two groups of
printing processes are analyzed.  The first uses flexographic and rotogravure
processes on packaging.  The second uses the rotogravure processes to print
publications.  Light hydrocarbon emissions are generated by both groups.
Various typical plant sizes (based on annual ink use) are analyzed for both
packaging and publication printing.  Tables 4-1 and 4-2 present the process
parameters of the model sizes selected for the packaging and publications
groups, respectively.  These parameters include exhaust gas volumetric
flow rates and temperatures, control devices, and control efficiencies
for each model plant.  (Flow diagrams showing the plant configurations
are presented in Chapter 2.)
4.1.3  Use of Model Plants
     Cost estimates developed for this analysis are based solely on model
plant configurations.  Yearly ink usage of the model plant sizes selected for
packaging printing are 7 Mg (7.7 tons), 40 Mg (44 tons), 150 Mg (165 tons),
                                      4-1

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400 Mg (440 tons), and 2500 Mg (2750 tons).   For publication printing,
the yearly ink usages are 3500 Mg (3860 tons) and 7000 Mg (7720
tons).  Because factors such as width and operating speed of the  printing
machinery influence control costs at actual  facilities, actual  costs for
specific plant sizes will vary.  Nevertheless, cost estimates based on  model
plants are useful  for comparing control alternatives.
4.1.4  Bases for Capital  Costs
     Installed capital costs represent the total investment required for
installing retrofit emission control systems on existing presses;  they
include the cost of equipment, material, labor for equipment erection,  and
other associated costs.  These estimated costs reflect mid-1978 dollars and
are based on equipment costs obtained from equipment vendors.   '        The
control equipment is assumed to be mounted on structural steel  above grade
or roof; the ducting requirement is based on equipment that is  installed
within 100 meters (350 ft) of the press.   The installation costs  have
been estimated on installed material requirements.  No attempt has
been made to include either production losses during installation  and
startup, or research and development costs.   Table 4-3 presents the
bases and assumptions used in estimating capital costs.
4.1.5  Bases for Annualized Costs
     Annualized costs represent the cost of operating and maintaining control
systems and the cost of recovering the capital investment required for  these
systems.  They include direct costs such as utilities, materials,  labor, and
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              TABLE 4-3.   BASES FOR CAPITAL COST ESTIMATES
All costs are expressed in mid-1978 dollars.
The afterburners have a 0.5-second residence  time and a 746°C (1375°F)
incineration temperature.
Afterburners and carbon adsorption systems have a VOC emission
reduction efficiency of 90 percent.
The initial  carbon for bedding is included in capital costs.
Capital investment includes:
     Basic control equipment
     Auxiliary equipment (e.g., hoods,  ducts)
     Fuel oil storage for 10 days operation
     Installation of basic and auxiliary equipment
     Removal of existing equipment, as  required
     Contingencies
     Contractor's fee, taxes, and other indirect costs
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maintenance; indirect costs such as taxes, insurance, depreciation, interest
rate, administration, and permits; and adjustments such as credits for re-
covered solvents.  Table 4-4 presents bases and assumptions used to estimate
annualized costs.
4.2  VOC CONTROL IN THE PRINTING INDUSTRY
4.2.1  Model Plant Parameters
     Costs were developed for thermal incinerators with and without 40
percent primary heat recovery on flexographic and rotogravure packaging,
and for carbon adsorption control on rotogravure publication printing
processes.  In addition, the costs for thermal incinerators with heat
recovery were compared to costs for identically sized pebble bed incinera-
tors.
4.2.2  Control Costs
     The capital and annualized costs and cost-effectiveness ratios of
thermal  incinerators for VOC control on flexographic and rotogravure
packaging model plants are presented in Tables 4-5 through 4-9; costs of carbon
adsorption systems on rotogravure publication model  plants are presented in
Table 4-10.  The respective cost data are plotted against model plant ink usage
in Figures 4-1, 4-2, and 4-3.   Finally, Table 4-11 displays these data for
pebble bed incinerators.
     In  packaging printing,  the incinerator with a primary heat recovery
system requires a larger capital investment than one without primary heat
recovery.   Because primary heat recovery reduces fuel  costs, the savings
therefrom increase proportionately with volumetric flow rate and VOC concentration,
     In  packaging printing,  incineration for each model  plant size has been eval-
uated at two gas flow rates, the smaller rate being  one third of the larger.
These lower rates are considered attainable with minor modifications to press
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            TABLE  4-4.   BASES FOR ANNUALIZED COST  ESTIMATES
Description
   Unit  cost
Basis for costs and other comments
Annualized costs

Installation type

Press operating time
Utilities
  No. 2 fuel  oil3
  Electricity


  Steam



Operating labor

Maintenance
  Labor


  Material
  Misc.  maint.,  parts
  and material
Capital  recovery
  factor
Taxes and insurance
Administration and
  permits
Adjustment
  creditc
  0.105/liter
 ($0.396/gal)
  0.0266/kWh
   $9.02/Mg
($4.10/103 lb)
    $8.66/h


    $9.53/h


    $9.53
  16.275% of
 capital cost

 2%  of capital
 cost
 2%  of capital
 cost

 $0.105/liter
 ($0.396/gal)
One year period commencing mid-1978

Retrofit

1000 h/yr or 250 days/yr at 4  h/day;
2000 h/yr or 250 days/yr at 8  h/day;
3000 h/yr or 250 days/yr at 12 h/day;
4000 h/yr or 250 days/yr at 16 h/day


$0.105/liter ($0.396/gal); based  upon
transport lots of 27,250 liters (7200
gal) delivered from Midwest terminal

EPA-230/3-77-015b report cost  for
iron and steel industry

Based on 80% efficiency;  includes 16C
for facilities, maintenance, depreciation,
and others b

Includes 20% for fringes
Hourly rate at 10"  premium over  operating
labor $9.53/h

Average (over life  of equipment) material
costs equal to labor costs
                     Carbon beds:  annual  allowance  for  5-year
                     life, 10% of the equipment capital  cost
10% interest rate and  10 years  equip-
ment life
Reclaimed solvent for  use  of diesel or
fuel  oil
a Assumed to be the  only  fuel used by all systems.

b In other words:   1000 lb steam  x 1000  Btu/lb x $0.396/gal * (140,000 Btu/gal  x  0.8 eff.)
  = $354/103 lb steam plus 16%  =  $4.10/103 lb steam.

c Where applicable.
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enclosures.  Significant modifications to enclosures  or the addition  of high-
velocity air jets could reduce ventilation rates to one-sixth  that  of the
unimproved, and could increase VOC concentration proportionately.   This reduction
in flow rates significantly reduces the control  system capital  cost for all
plants.  The capital cost reductions for the model  plant sizes of 7 Mg/yr
(7.7 tons/yr), 40 Mg/yr (44 tons/yr), 150 Mg/yr  (165  tons/yr), 400  Mg/yr (440
tons/yr), and 2500 Mg/yr (2750 tons/yr) are, respectively:   10%, 10%, 41%,  36%,  and
67% for incinerators without heat recovery; and  6%, 13%, 23%,  31%,  and 67%  for
incinerators with 40% primary heat recovery.
     For all model plants, these lower capital costs  effect proportional
reductions in annualized capital charges.  This  66% reduction  in the
volumetric flow rate (with an accompanying trebling of VOC  concentration)
causes reductions in the direct annual operating costs (fuel,  electricity,
etc.) for the respective model plant sizes of:   50%,  65%, 70%, 72%, and
74% for incinerators without heat recovery; and  37%,  60%, 78%, 75%, and
78% for incinerators with 40% primary heat recovery.  In other  words,
for a given model plant size, smaller incinerators  are less expensive
than larger ones to buy and operate.
     The addition of primary heat recovery equipment  to incinerators increases
the capital cost, but reduces annual fuel consumption proportionately with
the operating hours.  Neither the 7 Mg/yr (7.7 tons/yr) plant  nor  the 40 Mg/yr
(44 tons/yr) plant operates enough hours per year to  realize an annual ized  cost
savings from heat recovery, relative to the corresponding  thermal  incinerator
without heat recovery.  For the larger plants operating more hours  per year,
however, the incinerators with heat recovery have lower annual ized
costs than those without heat recovery.
                                     4-16

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     The effect of heat recovery on total annualized cost is also illustrated
by Figures 4-1 and 4-2.  As these figures show, the annualized costs are
less than 25% of the capital costs of incinerators with or without heat
recovery for the smallest model plant.  As the plant size increases to
the largest model plant size, however, the annualized costs exceed
capital costs for those without heat recovery, but the addition of heat
recovery reduces the annualized costs to less than the corresponding
capital costs.
     Table 4-10 lists capital and annualized costs for carbon adsorption
systems. Although the capital cost increases with plant size, smaller
volumetric flow rates may effect reductions in both capital and operating
costs for a given model plant size.  For example, a 50 percent reduction in
volumetric flow rate for the 3500 Mg/yr (3860 tons/yr) plant reduces the
capital cost from $701,000 to $435,000, and reduces the annualized
capital charges from $142,100 to $88,200. The solvent recovery credits
are $170,100 for both volumetric flow rates, since the VOC emissions
from the presses are based on the same hourly emission rate and the same
annual operating hours.  The direct operating costs are reduced from
$100,800 and $82,900 solely because less electric power is required for
the lower volumetric flow rate.  It is important to note that neither
the steam requirements for desorbing nor the cooling water required for
condensing the steam and desorbed VOC is reduced, because both are
related to the VOC collected and not the volumetric flow rate.  In all,
the total  annualized cost is reduced from $72,800 to $1000 for a 3500 Mg/yr (3860
                                  4-17

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be emphasized that the pebble bed incinerator vendor claims a very high
primary heat recovery (85 to 90%), versus 40% for the thermal incinerator.
Thus, the pebble bed's fuel cost constitutes an even lower percentage of
its total annualized cost.  Indeed, in some cases, the fuel requirements--
and costs—are negligible.
     Shown in Table 4-11, the annualized cost ranges from $26,600 to $478,000
per year for the smallest and largest plant sizes.  These costs are signifi-
cantly lower than those for the thermal incinerator with primary heat
recovery.  The incinerator costs range from $33,700 to $1,117,000 per year.
Now, the costs in Table 4-11 correspond to an 85% heat recovery, a fairly
typical value.  If the recovery were boosted to 90%, the annualized costs
would decrease modestly in most cases.  However, in some instances the
annualized costs would increase, because the higher heat recovery units would
require larger pebble beds which would, in turn, drive up their installed
costs.
4.2.3  Cost-effectiveness
     The cost-effectiveness ratio  (in this report) is defined as the total
annualized cost per annual unit of pollutant controlled.  The annual amount
of pollutant controlled depends on control device efficiency and total
operating hours.  By definition, the lower the ratio, the better the cost-
effectiveness.
     The cost-effectiveness ratios and efficiencies of the control systems
and the quantities of pollutant controlled are shown in Tables 4-5 through
4-10 for thermal incinerators and  carbon adsorbers, and in Table 4-11 for
pebble bed incinerators.   Figures  4-4, 4-5, and 4-6 present cost-effectiveness
curves for thermal incinerators on packaging printing processes and carbon
adsorbers on publication  printing  processes.
                                    4-21

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     Data show that the cost-effectiveness of control  systems improves with
plant size.  Because thermal incinerator costs are based on the same
efficiency for all plant sizes, their cost-effectiveness is enhanced by
increased plant operation and control utilization.  As shown in Figure
4-5 and discussed in Section 4.2.2, the incinerator with heat recovery
is less cost-effective than a system without heat recovery for the two
smaller packaging printing plants analyzed, and is more cost-effective
for the three larger plants.  The cost-effectiveness ratio for thermal
incinerators with heat recovery decreases from $12,500/Mg ($ll,370/ton)
at the smallest plant to $280/Mg ($250/ton) at the largest plant, based
on the 90% control device efficiency.
     The cost-effectiveness of controlling the publication printing process
also improves as the plant size increases.  Specifically, the cost-
effectiveness ratio decreases from $51/Mg ($46/ton) at the smallest plant
to a negative $15/Mg ($13/ton) at the largest plant, based on this same
90% control device efficiency.
     Lastly, because its annualized costs are consistently lower than
those for identically-sized thermal incinerators with  heat recovery, the
cost-effectiveness of pebble bed incinerators is also  better.  Its cost-
effectiveness ratio decreases from $9,260/Mg ($8,400/ton) to $130/Mg
($120/ton) as the plant size goes from smallest to largest.
                                  4-25

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                        REFERENCES  FOR  CHAPTER 4

1.    Industrial  Gas Cleaning Institute,  Stamford,  Connecticut.  Study of
     Systems for Heat Recovery from Afterburners.   Prepared for Chemical and
     Petroleum Branch, U.S.  Environmental  Protection Agency, Research Triangle
     Park, North Carolina,  under Contract  No. 68-02-1473, Task No. 23.
     October 1977.

2.    C-E Air Preheater, Combustion  Engineering, Wellsville, New York.   Report
     of Fuel Requirements,  Capital  Cost, and  Operating  Expense for Catalytic
     and Thermal Afterburners.  Prepared for  Environmental Protection Agency
     under Contract No. 68-02-1473, Task No.  13.   December 1973.

3.    Personal communication from Derek  Oaks,  Hoyt  Manufacturing Corporation,
     Westport, Massachusetts, to Art Knox, PEDCo Environmental,
     Inc., Cincinnati, Ohio.  August 1978.

4.    Personal communication from K. Allen  Napier,  Oxy-Catalyst,  Inc., Research-
     Cottrell, Inc., West Chester,  Pennsylvania, to Art Knox,  PEDCo  Environmental,
     Inc., Cincinnati, Ohio.  February  23, 1978.

5.    Personal communication from Dennis Snyder  of  Smith Environmental,  South
     Elmonte, California, to Art Knox,  PEDCo  Environmental,  Inc.,
     Cincinnati, Ohio.  August 23,  1978.

6.    Personal communication from Carol  Paulette of C-E  Preheater  Division,
     Wellsville, New York,  to Art Knox, PEDCo Environmental,  Inc., Cincinnati,
     Ohio.  August 30, 1978.

7.    R.S. Means Company.  Building  Construction Cost  Data  -  1978;  and Mechanical
     and Electrical Cost Data - 1978.  Duxburn,  Massachusetts.

8.    Personal communication from R.L. Pennington,  REECo, Inc., Morris Plains,
     New Jersey, to E.J. Vincent, U.S.  Environmental  Protection  Agency,
     Office of Air Quality Planning and Standards, Research  Triangle Park,
     N.C., October 27, 1978.

9.    Personal communication from W.M. Vatavuk,  U.S. Environmental  Protection
     Agency, Office of Air Quality Planning and Standards,  Research  Triangle
     Park, N.C., to R.L. Pennington, REECo, Inc.,  Morris Plains,  New Jersey.
     November 13, 1978.

10.  Ibid.  November 20, 1978.

11.  Personal communication from W.M. Vatavuk,  U.S. Environmental  Protection
     Agency, Office of Air Quality Planning and Standards,  Research  Triangle
     Park, N.C., to Art Knox, PEDCo Environmental, Inc., Cincinnati, Ohio.
     November 22, 1978.
                                      4-26

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              5.0  ADVERSE AND BENEFICIAL EFFECTS OF APPLYING
                           CONTROL TECHNOLOGY
5.1  INCINERATION
      Incineration is applicable to packaging gravure and flexographic
printing operations which use conventional solvent-borne inks.  The principal
disadvantage is the use of scarce and increasingly expensive fuel.  Fuel
consumption can be minimized by the inclusion of heat recovery equipment in
the design.  Primary heat exchangers can reduce fuel usage to some extent.
Hypothetically, the use of pebble bed incinerators with their inherently
effective heat recovery systems can reduce fuel usage substantially.   At
current fuel prices the annualized cost of the heat recovery system will be
greater than the fuel saving and there will  be a net increase in operating
cost.
5.2  CARBON ADSORPTION
      Carbon adsorption systems can recover solvent for reuse in ink manufacture.
Thus, a valuable and increasingly scarce material can be conserved.  Steam
stripping is the usual method for removing adsorbed solvent from the carbon
beds.  If water soluble solvents are used in the inks, the condensed steam
will contain orgam'cs which will require the additional expense of pretreatment
facilities.  This disadvantage is not present in the recently developed
fluidized bed carbon adsorption system in which desorption is achieved by
indirect heat and nitrogen gas.
                                  5-1

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            6.0  MONITORING TECHNIQUES AND ENFORCEMENT ASPECTS

      In the majority of cases the suggested emission limits  will  probably
be met by incineration and carbon adsorption systems.  The basic problem of
the control official is determining that the control  device is operating
correctly.  A measurement of efficiency across the device could be required
when the unit is installed.  (One test may be adequate when several  identical
units are installed).
      A thermal incinerator which initially shows a high combustion  efficiency
will probably continue to perform well if operated at the same or greater
temperature.  All incinerators should be equipped with temperature indicators;
recorders should be required for larger installations.  The range instrument
of 1200° to 1800°F will cover thermal incinerators; catalytic units  seldom
operate at less than 600° or more than 1200°F.  The sensing elements should
be shielded from direct flame radiation.  Other incinerator parameters are
fixed by the design, e.g., there is no need to monitor residence time or
mixing velocity.
      For catalytic incinerators, the temperature rise across the catalyst
bed should be measured during the initial test for combustion efficiency.
This temperature rise reflects the activity of the catalyst (but may also
vary with process variables and material input changes in the process).
Temperature sensors should be installed on both the inlet and outlet of the
catalyst bed to provide a continuous indication of catalyst activity.
                                6-1

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      To assure satisfactory operation of carbon  adsorbers,  it  is  necessary
to regenerate the carbon beds at intervals sufficient to  prevent "breakthrough"
Breakthrough is the point at which VOC starts  to  appear in  the  exit  gases
in significant concentrations.   The regeneration  cycle is controlled by
three methods:  1) a sequence timer,  2)  a vapor  detector,   3)  both  a
sequence timer and a vapor detector.
      A sequence timer is the simplest control method. The length of the
adsorption period is determined by trial at the highest VOC concentrations
likely to occur.  This method can be wasteful  of  steam, as  regeneration will
often be performed before the bed is fully loaded.   On the other hand, if
the cycle is made too long , breakthrough will often occur.
      A vapor detector sensitive to 50 to 100 ppm is sufficient for most
applications.  The  detector may  actuate  an audible or visible alarm only, with
the regeneration operations being performed manually.  Or the detector
may actuate an automatic control mechanism for performing the regeneration
operation.  This method is the more economical of steam,  as regeneration is
done only when the bed is loaded to the maximum allowable level.  However,
if the detector malfunctions extended breakthroughs could occur.
      The combination system is  always fully automatic.  The sequence timer
is set for a period of average VOC concentration.  During periods of higher
than average VOC concentration the vapor detector will initiate the
regeneration.  The  timer will act as  a back-up device in case of a mal-
function of the vapor detector.  Most system at publication rotogravure plants
are of this type.
                                   6-2

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the rei'trse before completing)
1. REPORT NO.
 EPA-450/2-78-033
  TITLE AND SUBTITLE
  Control  of  Volatile Organic Emissions from Existing
  Stationary  Sources - Volume VIII:  Graphic Arts -
  Rotogravure and Flexography
7. AUTHOR(S)
  Edwin J.
  William f
Vincent
I. Vatavuk
8. PERFORMING ORGANIZATION REPORT NO

    OAQPS  No.  1.2-109
                                                            3. RECIPIENT'S ACCESSION NO.
                                                 5. REPORT DATE
                                                     December 1978
                                                 6. PERFORMING ORGANIZATION CODE
9 PERFORMING ORGANIZATION NAME AND ADDRESS
  U. S. Environmental Protection Agency
  Office of Air,  Noise and Radiation
  Office of Air Quality Planning and  Standards
  Research  Triangle Park, North Carolina  27711
                                                            10. PROGRAM ELEMENT NO.
                                                 11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
                                                            13. TYPE OF REPORT AND PERIOD COVERED
                                                            14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
       This  document provides guidance for development of  regulations to limit
  emissions  of volatile organic  compounds from rotogravure and flexographic printing
  operations.   This guidance includes  recommended control  requirements for carbon
  adsorption and incineration systems  which represent Reasonably Available Control
  Technology for these operations.   Provisions for the potential compliance by  use
  of water-borne and high-solids  inks  are recommended.  The industry is described,
  methods  for  reducing organic emissions are reviewed, and monitoring and enforcement
  aspects  are  discussed.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
  Air Pollution
  Publication  Rotogravure Printing
  Packaging  Printing Industry
  Volatile Organic Compound Emissions
    Limits
  Regulatory Guidance
                                              b.IDENTIFIERS/OPEN ENDED TERMS
                                   Air Pollution Control
                                   Stationary Sources
                                   Organic Vapors
                                                              c.  COSATl Field/Group
18. DISTRIBUTION STATEMENT
                                              19. SECURITY CLASS (This Report)
                                                Unclassified
  Unlimited
                                                              21. NO. OF PAGES
                                                                   52
                                   20 SECURITY CLASS (This page}
                                    Unclassified
                                                                         22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSCH ETE

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