EPA-450/3-80-031a
Publication  Rotogravure Printing
       Background Information
       for Proposed  Standards
           Emission Standards and Engineering Division
            fiSQ $33S2& Ite&tfcrn Street,
                     €0604
          U.S. ENVIRONMENTAL PROTECTION AGENCY
              Office of Air, Noise, and Radiation
           Office of Air Quality Planning and Standards
          Research Triangle Park, North Carolina 27711

                  October 1980

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This report has been reviewed by the Emission Standards  and Engineering Divisk~i
of the Office of Air Quality Planning and  Standards, EPA,  and approved for publication.
Mention of trade  names or commercial  products is not intended to constitute endorsement
or recommendation for use.   Copies  of this report are  available through the Library
Services Office (MD-35), U.  S.  Environmental Protection Agency, Research Triangle
Park, N.  C. 27711, or from National Technical Information Services, 5285 Port Royal
Road, Springfield, Virginia  22161.

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                      ENVIRONMENTAL PROTECTION AGENCY

                          Background Information
                 and Draft Environmental Impact Statement
                   for Publication Rotogravure Printing

                                 Prepared by:
Don R.  Goodwin                                                     (Date)
Director, Emission Standards and Engineering Division
U. S.  Environmental  Protection Agency
Research Triangle Park, North Carolina  27711

1.   The proposed standards of performance would limit emissions of
     volatile organic compounds (VOC) from new, modified, and reconstructed
     publication rotogravure printing presses.  Section 111 of the Clean
     Air Act (42 U.S.C. 7411), as amended, directs the Administrator to
     establish standards of performance for any category of new stationary
     source of air pollution that ". . . causes or contributes significantly
     to air pollution which may reasonably be anticipated to endanger
     public health or welfare."  The Midwest and East Coast Regions of
     the United States are particularly affected.

2.   Copies of this document have been sent to the following Federal
     Departments:  Labor, Health and Human Services, Defense, Transportation,
     Agriculture, Commerce, Interior, and Energy; the National Science
     Foundation; the Council on Environmental Quality; members of the
     State and Territorial Air Pollution Program Administrators; the
     Association of Local Air Pollution Control Officials; EPA Regional
     Administrators; and other interested parties.

3.   The comment period for review of this document is 60 days.  Mr.  Gene W. Smith,
     Section Chief, may be contacted regarding the date of the comment period.

4.   For additional  information contact:

     Mr. Gene W. Smith, Section Chief
     Standards Development Branch (MD-13)
     U. S. Environmental Protection Agency
     Research Triangle Park, North Carolina  27711
     telephone:  (919) 541-5421

5.   Copies of this document may be obtained from:

     U. S. EPA Library (MD-35)
     Research Triangle Park, North Carolina  27711

     National Technical Information Service
     5285 Port Royal Road
     Springfield, Virginia  22161


                                      iii

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                         METRIC  CONVERSION  TABLE

     In keeping with U.S.  Environmental  Protection  Agency  policy,  metrir
units are used in this report.   These units may  be  converted  to  common
English units by using the following  conversion  factors:

                                                     Equivalent
        Metric Unit           Metric  Name           English Unit

                                LENGTH
             m                   meter              39.3700 in.
             m                   meter               3.2810 ft.

                                VOLUME
             1                  liters              0.2642 U.S.  gal.
             m-              cubic meters            264.2 U.S.  gal.
            Mm            mega-cubic  meters         3.53 X 10? ft.3
                               (10 m3)

                                 WEIGHT
             Kg             kilogram  (103 grams)     2.2046 Ib.
             Mg             megagram  (106 grams)     1.1023 tons
             Gg             gigagram  (109 grams)     1,102.3  tons

                                ENERGY
             GJ                gigajoule            9.48 X 105 Btu
             GJ                gigajoule              277.76  KWh
            J/g              joule per gram            0.430  Btu/lb

                            VOLUMETRIC FLOW
           T                                                        O
          myhr          cubic meters per hour       0.5886 ACF'M (ft'/min)
         Nm /hr        normal cubic meters per hour  0.5886 SCFM (ft /min)

                                 SPEED
            m/s            meters per second      196.86 ft/min

                       SOLVENT VAPOR CONCENTRATION
           g/m          grains per cubic  meter air        266 ppmv

     Temperature in degrees Celcius ( C) can be converted to temperature
in degrees Farenheit  (OF) by the following formula:

                           (°F) = 1.8 (°C) + 32
                                    i v

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                                                    I
                               TABLE  OF  CONTENTS
  Chapter/Section                                                        Page

  1.   SUMMARY	  1-1
       1.1   Regulatory Alternatives	  1-1
       1.2   Environmental  Impact	  1-2
       1.3   Regulatory Analysis	  1-5
  2.   INTRODUCTION	  2-1
       2.1   Background and Authority  for  Standards	  2-1
       2.1   Selection of  Categories of  Stationary  Sources	  2-5
       2.3   Procedure for Development of  Standards  of
              Performance	  2-7
       2.4   Consideration of  Costs	  2-9
       2.5   Consideration of  Environmental  Impacts	  2-10
       2.6   Impact on Existing Sources	  2-11
       2.7   Revision of Standards  of  Performance	  2-12
  3.   THE  PUBLICATION ROTOGRAVURE  INDUSTRY	  3-1
       3.1   General	  3-1
       3.2   Facilities and Their  Emissions	  3-5
\
       3.3   Baseline Emissions	  3-20
       3.4   References	  3-24
  4.   EMISSION  CONTROL TECHNIQUES	  4-1
       4.1   Overall Emissions Control	  4-1
       4.2   Solvent Vapor Capture  Systems	  4-9
       4.3   Fixed-Bed Carbon  Adsorption	  4-19
       4.4   Fluidized-Bed Carbon  Adsorption	  4-33
       4.5   Solvent Destruction	  4-35
       4.6   References	  4-40
  5.   MODIFICATION AND RECONSTRUCTION	  5-1
       5.1   General	  5-1
       5.2   40 CFR Part 60 Modification and  Reconstruction	  5-2
       5.3   Modification  in a Publication Rotogravure  Plant	  5-3
       5.4   Reconstruction in a Publication  Rotogravure
              Plant	  5-5

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                       TABLE OF CONTENTS (continued)

Chapter/Section                                                       Pagp
6.   MODEL PLANTS AND REGULATORY ALTERNATIVES	 6-1
     6.1  General	 6-1
     6.2  Model Plants	 6-2
     6.3  Regulatory Alternatives	 6-11
     6.4  References	 6-14
7.   ENVIRONMENTAL IMPACT	 7-1
     7.1  Air Pollution Impact	 7-2
     7.2  Water Pollution Impact	 7-11
     7.3  Solid Waste Impact	 7-14
     7.4  Energy Impact	 7-16
     7.5  Noise Pollution Impact	 7-21
     7.6  Summary	 7-21
     7.7  References	 7-22
8.   ECONOMIC  IMPACT	 8-1
     8.1  Industry Characterization	 8-1
     8.2  Cost Analysis of  Regulatory Alternatives	 8-17
     8.3  Other  Cost Considerations	 8-30
     8.4  Economic Impact of Regulatory Alternatives	 8-30
     8.5  Potential Socio-Economic and  Inflationary
             Impacts	 8-50
     8.6  References	 8-52
APPENDICES
A.   Evolution of the Background  Information  Document	 A-l
B.   Cross-Index of Environmental  Impact  Considerations	 B-l
C.   Emission  Source Test Data	 C-l
     C.I  Meredith/Burda, Inc	 C-l
     C.2  Supplemental Sampling  at Meredith/Burda,  Inc	 C-3
     C.3  Texas  Color, Inc	  C-4
     C.4  Summary of  Results	  C-7
     C.5  Non-Tested  Facilities	  C-13
D.   Emission  Measurement and  Continuous
       Monitoring	  D-l

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                              LIST OF TABLES


Table                                                                 Page

1-1  Assessment of Environmental and Economic Relative
       Impacts for Each Regulatory Alternative	 1-3

3-1  Publication Rotogravure Installations in the U.S. as
       of January 1, 1978	 3-3,4

3-2  State Air Pollution Regulations	 3-21

4-1  Data Base Summary	 4-6

4-2  Approximate Carbon Adsorption Capacity for Various Solvents	4-24

6-1  Model Plant Parameters	 6-8

7-1  Estimated VOC Emissions	 7-3

7-2  Toxic Effects of Representative Rotogravure Solvent
       Component Vapors in Air	 7-6,7

7-3  Secondary Air Pollution Impacts	 7-9

7-4  Potential Water Pollution...Model  Plants	 7-12

7-5  Potential Solid Waste Impacts	 7-15

7-6  Potential Solid Waste Impacts	 7-17

7-7  Total Annual Energy...Large Model  Plants	 7-19

7-8  Projected 1985 Total Energy Requirements	 7-20

8-1  Geographic Distribution of Gravure Publication  Printing
       Plants as of July, 1979	 8-3

8-2  Ownership of Gravure Publication  Printing  Establishments	 8-4,5

8-3  Publication Rotogravure Printing  Industry  Total  Output  At A
       Typical Utilization Capacity under Four  Alternative
          Projections	 8-10

8-4  Installed Capital  Cost of  VOC Control By Carbon Adsorption
       For Gravure Publication  Printing Plants	 8-20

8-5  Bases for Annualized Cost  Estimates	 8-23
                                      vn

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                       LIST OF TABLES (continued)

Table                                                                  Page

8-6  Itemized and Operating Costs of VOC Control By Carbon
       Adsorption for Rotogravure Publication Model Printing Plants..  8-24

8-7  Annualized Cost of VOC Control By Carbon Adsorption for
       Publication Rotogravure Model Printing Plants	  8-27

8-8  Model Plant Investment for Plant and Equipment,  Excluding
       VOC Control s	  8-37

8-9  Total and Incremental Capital  Investment For Model Plants
       At Three Overall Recovery Efficiencies	  8-39

8-10 Fraction of Capital  Investment Allocated to VOC  Control At
       Each Level of Recovery	  8-40

8-11 Total and Incremental Annualized Cost  of VOC Control*	  8-42

8-12 Model Plant and Operating Income at 75 Percent
       Sol vent Recovery	  8-46

8-13 Model Plant and Operating Income and Profit at 85  Percent
       Sol vent Recovery	  8-48

A-l  Publication Rotogravure Industry Representatives Contacted	  A-4,5,6

A-2  Federal, State, and  Local Air  Pollution Control  Agency
       Personnel Contacted	  A-7,8

A-3  Plant Visits	  A-9

A-4  Suppliers Contacted	  A-10,11

A-5  Evolution of Proposed Standards	  A-12,13,14

C-l  Summary of. ..Control  Efficiencies	  C-15

C-2  Comparison of Press  Operations	  C-l6

C-3  Comparison of SLA*  Flow Streams	  C-l8

C-4  Summary of. ..Monsanto Tests	  C-l9

C-5  Meredith/Burda...Temperature  Correction Factor	  C-20   '

C-6  Summary of Test Runs. ..Meredith/Burda	  C-21
                                      viii

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                       LIST OF TABLES (continued)
Table                                                                 Page
C-7  Comparison of Recovered Sol vent...at Meredi th/Burda	 C-22
C-8  Solvent Loss. ..Meredith/Burda	 C-23
C-9  Meredi th/Burda Carbon Adsorber Efficiency	 C-24
C-10 Monthly Plant Data. ..Meredith/Burda	 C-25
C-ll Estimated Air Purge Times. ..Meredith/Burda	 C-26
C-12 Summary of Test Runs...Texas Color	 C-27
C-13 Comparison of Recovered Sol vent...at Texas Color	 C-28
C-14 Solvent Loss...Texas Color	 C-29
C-15 Texas Color Carbon Adsorber Efficiency	 C-30
C-16 Summary of Texas Color...Radian Corporation	 C-31
C-17 Estimated Adsorber Inlet. ..Texas Color	 C-32
C-18 Estimated Adsorber Efficiency Variations	 C-33
C-19 Potential ...Solvent Recovery...Texas Color	 C-34
C-20 Plant Data...Texas Color	 C-35
C-21 Plant Data...Standard Gravure	 C-36
C-22 VOC Control...Non-Tested Facilities	 C-38
                                      ix

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                            LIST OF  ILLUSTRATIONS
3-1  Gravure Image Surface ..................... . . ..... ............ ......  3_8

3-2  Schematic of a Typical  Eight-Unit Rotogravure i:)rinting Press ____  3-10

3-3  Diagram of a Rotogravure Printing Unit ........ , ..... . ...... ......  3_n

3-4  Fugitive Solvent Vapor Emissions Around a  Gravure
       Publication Printing Unit ............ ........ . .............. ....  3. is

4-1  Solvent Flow Around Printing Press ..... ........ ................ ....  4.3

4-2  Cabin Enclosure System for Fugitive Vapor  Capture ............ ....  4-12

4-3  Flow Diagram of Typical Solvent Recovery Process
       (Adsorber 1 Regenerating) ........... ........ ................ ....  4.21

4-4  Flow Diagram of Typical Solvent Recovery Process
       (Adsorber 2 Regenerating) ................... . ............. , ....  4-22

4-5  Top View of REECO RE-THERM System ...............................  4.37

4-5  Front View of REECO RE-THERM System .......................... ____  4-38

6-1  Schematic of Small  Model . ..Printing Plant ................... _____  6-3

6-2  Schematic Ink and Solvent Material  Balance Around a... Printing
       Facil i ty .................................................. _____  6-6

8-1  Alternative Growth Projections for the Publication Rotogravure
       Printing Industry at Typical Utilization Capacity .............  8-11

8-2  Alternative Growth Estimates for the Publication Rotogravure
       Printing Industry with Constraint of 10 New Presses Per
       Year Superimposed at Utilization Capacities of 81%, 84%,
       and 100% ...................................... .................  8-13

8-3  Alternative Growth Estimates for the Publication Rotogravure
       Printing Industry with Constraint of 15 New Presses Per
       Year Superimposed at Utilization Capacities of 81%, 84%,
       and 100% ...................................... .................  8-14

8-4  Cost of VOC Control  by Carbon Adsorption3 for Rotogravure
       Publication Model  Printing Plants .............................  8-28

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                     LIST OF ILLUSTRATIONS (continued)


Figure                                                                Page

8-5  Incremental Cost of VOC Controls on Model Plants at Various
       Solvent Prices, All Other Costs Constant	 8-43

8-6  Incremental Cost of VOC Controls on Model Plants at Various
       Solvent Prices, Other Costs Adjusted for Inflation	 8-45

C-l  Frequency of Press Shutdowns	 C-17

C-2  Overall...Recovery Performance...World Color Press	 C-37
                                     XI

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                              1 .   SUMMARY

1.1   REGULATORY ALTERNATIVES
     This Background Information Document (BID) supports proposal  of the
Federal  Regulation for limiting volatile organic compounds (VOC) vapor
emissions from the publication rotogravure printing industry.  New
Source Performance Standards  (NSPS) or standards of performance for new,
modified, and reconstructed publication rotogravure printing presses are
being proposed under Section 111  of the Clean Air Act.  The source of
the VOC emissions are the solvent components in the inks, extenders, and
varnishes used at the printing presses, as well as solvent added for
printing and cleaning.
     The three regulatory alternatives considered are presented in
Chapter 6.  These alternatives call for an overall reduction of VOC
emissions at 75, 80, and 85 percent levels.   The 75 percent control
level represents capturing the dryer exhausts from older presses.   This
baseline level  corresponds to the control techniques guideline  (CTG)
recommendation for existing facilities, which the states are expected to
use in developing their State Implementation Plans (SIP). The 80 percent
control  level represents capturing the dryer exhausts from new presses.
This corresponds to a typical, well-control led facility.  The 85 percent
control  level represents capturing the dryer exhausts from new presses,
as well  as some of the fugitive VOC vapors.   This corresponds to the
best-demonstrated controlled facility in this industry.  Test data,
presented in Appendix C, shows that the typical plants in this industry
could also potentially achieve the highest level of control by directing
their existing fugitive capture vents to a control device, rather than
to the atmosphere.
     All three regulatory control levels can be achieved with the instal-
lation of add-on control equipment.  Fixed-bed carbon adsorption with
solvent recovery is the most popular method currently used to control
VOC emissions from this industry.  In addition, overall emission reductions
greater than about 80 percent require some type of fugitive vapor
                                     1-1

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capture system to be installed around the presses.   This industry is
researching the possibilities of using waterbcrne ink  systems so that
add-on controls would not be required to meet fhe proposed VOC emission
standards.  However, only solvent-borne ink system are presently used
for publication rotogravure printing.
1 .2  ENVIRONMENTAL IMPACT
     Detailed discussions of the environmental  and energy impacts
associated with the three alternatives are presented in Chapter 7,  A
summary of the relative impacts is presented in Table  1-1.  The estimated
effects shown in this chart are based on comparisons between the impacts
of the higher NSPS control  alternatives and the baseline control level.
75 percent overall control  is the comparison baseline  and, therefore,
Its relative impact values  are zero.   The relative impacts from a delay
in promulgation of Federal  NSPS are also shown to be zero.  This effect
is based on the assumption  that all new facilities, even without Federal
standards, would probably install solvent recovery systems with overall
control at about the 75 percent level .  Recovery of about 75 percent of
the solvent used is shown in Chapter 6 to be the minimum recycle amount
required for dilution of the printing inks.  Solvent recovery can help
alleviate the problems of limited solvent supplies and increasing solvent
costs.  The actual effect of delayed standards depends on how long the
delay  is and what control level is required by the individual states.
However, the 75 percent overall control level is expected to be the
minimum level adopted for all the SIP.
     The potential VOC vapor emissions from presses used in this industry,
for the year 1985, are projected to be about 236,000 Mg  (260,000 tons).
If all facilities were controlled at the 75 percent baseline level, the
resulting emissions would be about 59,000 Mg  (65,000 tons) per year.
The baseline emissions would be reduced by about an additional  7 percent,
if all new facilities were controlled at the 80 percent level, with
existing facilities controlled at the 75 percent level.  Similarly, the
emissions would be reduced  by about an additional 13 percent over baseline
control level, if all new facilities were controlled at the 85  percent
level.
                                    1-2

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            TABLE  1-1.  ASSESSMENT OF ENVIRONMENTAL AND ECONOMIC RELATIVE IMPACTS
                       FOR EACH REGULATORY ALTERNATIVE CONSIDERED
ADMINISTRATIVE
ACTION

85% overall control

80% overall control
75% overall control
(Baseline)
Delayed Standards
(SIP control)


AIR
IMPACT

+4**

+3**
0


0


WATER
IMPACT

-2**

_1 **
0


0


SOLID
WASTE
IMPACT
-2**

_1 **
0


0


ENERGY
IMPACT

+3**

+2**
0


-o


NOISE ECONOMIC
IMPACT IMPACT

0 -2**
-3*
o Jl**
o o


0 0


Key:   + Beneficial  impact
      - Adverse impact
      0 No impact
      1 Negligible  impact
2 Small impact
3 Moderate impact
4 Large impact
  * Short-term impact
 ** Long-term impact
*** irreversible impact

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     Emissions of air pollutants from secondary sources result from the
operation of carbon adsorption control  systems.  Required electrical
power is generated in various types and sizes of separate offsite facili-
ties, which are already governed by regulations,  .''n accurate assessment
of this pollution source was not attempted.  Total  emissions from fuel
combustion to generate the required steam was estimated to represent
less than 0.5 percent of the corresponding VOC emission reductions from
the publication rotogravure presses.  Hydrocarbon vapors makeup less
than one percent of the total fuel combustion emissions.  Therefore, the
resulting total air pollutants emitted from secondary sources only
slightly offset the primary impact of reducing VOC emissions.
     Dissolved solvent in the condensate from solvent recovery systems
represents a potential water pollution source.  The amount of condensate
discharged increases  in a direct proportion with the amount of solvent
recovered.  However,  the total amount of solvent discharged with the
condensate represents less than 0.1 percent of the VOC solvent recovered
from the presses.  Also, this potential water  pollution source can be
virtually eliminated  by demonstrated removal of the dissolved solvent
content and recycling the resultant solvent-free condensate as boiler
feed water.
     The spent carbon, carbon fines, and used  fiberglass air  filters  are
the  only sources  of solid waste pollution.  The spent  carbon  can be
treated and reused, or disposed of  using readily available methods.
There  should  be  no  problem  in disposing the carbon fines or used fiber-
glass  filters.
     The operation  of carbon  adsorption control systems  require  elect-
rical  energy  for running the  solvent laden  air (SLA) fans, and fuel
energy for steam generation.  The  industry's  total direct  energy con-
sumption,  in  the year 1985,  for VOC emission  controls  at the  75  percent
level  would be about  2.6 million  GJ  (2.5 X  1012 Btu).   The direct  energy
consumption would be  increased  by  about an  additional  3  to 9  percent  for
controlling new  press emissions at the  80  and  85  percent levels,  re-
spectively.
                                      1-4

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     However, the energy impact analysis presented in section 7.4 shows
that there would be a national  net energy savings, when the fuel  energy
value of the recovered solvent is considered.  National  energy con-
sumption, in the year 1985, would be actually decreased by about 5.6
                    1 2
million GJ  (5.3 X 10   Btu), with VOC emission controls and solvent
recovery at the 75 percent level, in this industry.  The nationwide
energy savings would be further increased by about an additional  2 to 3
percent for controlling new press emissions at the 80 and 85 percent
levels, respectively.
     The only significant source of noise would be from the large SLA
fans.  However, these are normally installed in an enclosed housing, and
should not affect the surrounding environment.
1.3  REGULATORY ANALYSIS
     Executive Order 12044 requires that the EPA prepare a regulatory
analysis of the economic effects of new significant regulations.   A
detailed discussion of the economic impacts of controlling VOC emissions
at all three regulatory levels is presented in Chapter 8.  A summary of
the  relative economic impacts is also presented in Table 1-1.
     The capital costs of VOC emission controls, through the year 1985,
for all new presses controlled at the 75 percent level would be about
$46.2 million.  Control at the 80 percent and 90 percent levels would
further increase the capital costs by about 6 percent and 36 percent,
respectively.  These emission control capital investments represent from
5 to 9 percent of the total costs for the new printing plants, plus
emission control systems.  However, the annual operating costs are more
than offset by the cost value of the recovered solvent, resulting in
annual savings at all three control levels.
     The maximum return on investment (ROI) for solvent recovery systems
would occur for overall control at slightly over the 80 percent level.
At the 80 percent level, the positive ROI would yield a small short-term
increase in cost savings relative to baseline control.  In addition,
these economic benefits would increase in the long-term after the capital
costs of the control system are paid off.  At the 85 percent level , the
                                     1-5

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positive ROI is lower than with control  at the baseline level.   Consequently,
85 percent control  would yield a moderate short-term adverse impact
relative to baseline control.   However,  this f^verse impact would decrease
somewhat in the long-term once the capital  investments are paid off.
     These cost savings make the installation of emission control/sol vent
recovery systems profitable at all three control  levels.   This  economic
incentive is expected to increase in the future, as the price of solvent
increases.  The resulting return on emission controls investment is not
quite as high as for investments in new  printing equipment.  However,
this industry, unlike other industries,  can still  get some return on
their emission controls investments.  In addition, the profitability
analysis presented in section 8.4 shows  that this industry's profit
margin would not decrease by more than 0.2 percentage point, even at the
85 percent control  level.  Therefore, these minimal changes in profitability
should not cause any significant price increases for publication gravure
products.
                                     1-6

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                             2.  INTRODUCTION
2.1   BACKGROUND AND AUTHORITY FOR STANDARDS
     Before standards of performance are proposed as a Federal regulation,
air pollution control methods available to the affected industry and the
associated costs of installing and maintaining the control equipment are
examined in detail.  Various levels of control based on different technolo-
gies and degrees of efficiency are expressed as regulatory alternatives.
Each of these alternatives is studied by EPA as a prospective basis for
a standard.  The alternatives are investigated in terms of their impacts
on the economics and well-being of the industry, the impacts on the
national economy, and the impacts on the environment.  This document
summarizes the information obtained through these studies so that inter-
ested persons will  be able to see the information considered by EPA in
the development of the proposed standard.
     Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411) as amended,
hereinafter referred to as the Act.  Section 111 directs the Admin-
istrator to establish standards of performance for any category of new
stationary source of air pollution which ". .  . causes, or contributes
significantly to air pollution which may reasonably be anticipated to
endanger public health or welfare."
     The Act requires that standards of performance for stationary
sources reflect ".  . . the degree of emission  reduction achievable which
(taking into consideration the cost of achieving such emission reduction,
and any nonair quality health and environmental  impact and energy
requirements) the Administrator determines has been adequately demon-
strated for that category of sources."  The standards apply only to
stationary sources, the construction or modification of which commences
after regulations are proposed by publication  in the Federal  Register.
                                    2-1

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     The 1977 amendments to the Act altered or added numerous provisions
that apply to the process of establishing standards of performance.
     1.  EPA is required to list the categories of major stationary sources
that have not already been listed and regulated under standards of perform-
ance.  Regulations must be promulgated for these new categories on the
following schedule:
     a.  25 percent of the listed categories by August 7, 1980.
     b.  75 percent of the listed categories by August 7, 1981.
     c.  100 percent of the listed categories by August 7, 1982.
A governor of a State may apply to the Administrator to add a category not
on the list or may apply to the Administrator to have a standard of perform-
ance revised.
     2.  EPA is required to review the standards of performance every 4
years and, if appropriate, revise them.
     3.  EPA is authorized to promulgate a standard based on design, equip-
ment, work practice, or operational procedures when a standard based on
emission levels is not feasible.
     4.  The term  "standards of performance" is redefined, and a new term
"technological system of continuous emission reduction" is defined. The  new
definitions clarify that the control system must be continuous and may
include a low- or  non-polluting process or operation.
     5.  The time  between the proposal and promulgation of a standard under
Section 111 of the Act may be extended to 6 months..
     Standards of  performance, by themselves, do not: guarantee protection
of health or welfare because they are not designed to achieve any  specific
air  quality levels.  Rather, they are designed to  reflect the degree of
emission limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction, taking
into consideration the cost of achieving such emission reduction,  any
non-air-quality health and environmental impacts,  and energy requirements.
     Congress  had  several reasons for including these requirements. First,
standards with a degree of uniformity are needed to avoid situations
where  some states  may attract industries by relaxing standards relative  to
other  states.  Second, stringent standards enhance the potential for
long-term growth.  Third, stringent standards may  help achieve long-term
                                      2-2

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cost savings by avoiding the need for more expensive retrofitting when
pollution ceilings may be reduced in the future. Fourth, certain types
of standards for coal-burning sources can adversely affect the coal
market by driving up the price of low-sulfur coal or effectively excluding
certain coals from the reserve base because their untreated pollution
potentials are high.  Congress does not intend that new source performance
standards contribute to these problems.  Fifth, the standard-setting
process should create incentives for improved technology.
     Promulgation of standards of performance does not prevent State or
local agencies from adopting more stringent emission limitations for the
same sources.  States are free under Section 116 of the Act to establish
even more stringent emission limits than those established under Section
111 or those necessary to attain or maintain the National Ambient Air
Quality Standards (NAAQS) under Section 110.  Thus, new sources may in
some cases be subject to limitations more stringent than standards of
performance under Section 111, and prospective owners and operators of
new sources should be aware of this possibility in planning for such
facilities.
     A similar situation may arise when a major emitting facility is to
be constructed in a geographic area that falls under the prevention of
significant deterioration of air quality provisions of Part C of the
Act.  These provisions require, among other things, that major emitting
facilities to be constructed in such areas are to be subject to best
available control technology.  The term Best Available Control Technology
(BACT), as defined in the Act, means
          ". . . an emission limitation based on the maximum degree of
          reduction of each pollutant subject to regulation under this
          Act emitted from, or which results from, any major emitting
          facility, which the permitting authority, on a case-by-case
          basis, taking into account energy, environmental, and economic
          impacts and other costs, determines is achievable for such
          facility through application of production processes and
          available methods, systems, and techniques, including fuel
          cleaning or treatment or innovative fuel combustion techniques
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          for control  of each  such  pollutant.   In  no event shall  applica-
          tion of "best available  control  technology" result in emissions
          of any pollutants which  will  exceed  the  emissions allowed by
          any applicable standard  established  pursuant to Sections 111
          or 112 of this Act.  (Section  169(3))."
     Although standards of performance  are normally structured in terms
of numerical emission limits where feasible,  alternative approaches are
sometimes necessary.  In some cases physical  measurement of emissions
from a new source may be impractical  or exorbitantly expensive.  Section lll(h)
provides that the Administrator may promulgate a design or equipment
standard in those cases where it is not feasible to prescribe or enforce
a standard of performance.  For example, emissions of hydrocarbons from
storage vessels for petroleum liquids are greatest during tank filling.
The nature of the emissions, high  concentrations for short periods
during filling and low concentrations for longer periods during storage,
and the configuration of storage tanks  make direct emission measurement
impractical.  Therefore, a more practical approach to standards of
performance for storage vessels has been equipment specification.
      In addition, Section lll(j) authorizes the Administrator to grant
waivers of compliance to permit a source to use innovative continuous
emission control technology.  In order to grant the waiver, the
Administrator must find:   (1) a substantial likelihood that the technology
will  produce greater emission reductions than the standards require or
an equivalent reduction at  lower economic energy or environmental cost;
(2) the  proposed system has not been adequately demonstrated;  (3) the
technology will not cause  or contribute to an unreasonable risk to the
public  health, welfare, or  safety; (4) the governor of the State where
the source  is located consents; and  (5) the waiver will  not prevent the
attainment  or maintenance  of any ambient standard.  A waiver may have
conditions  attached  to  assure the  source will not prevent  attainment  of
any NAAQS.   Any  such condition will  have the  force of a  performance
standard.   Finally, waivers have definite end dates  and  may be terminated
earlier if  the  conditions  are not  met  or  if the system fails  to  perform
as  expected.   In such  a case, the  source may  be given up to three years  to
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to meet the standards with a mandatory progress schedule.
2.2  SELECTION OF CATEGORIES OF STATIONARY SOURCES
     Section 111  of the Act directs the Adminstrator to list categories
of stationary sources.  The Administrator "... shall  include a category
of sources in such list if in his judgement it causes,  or contributes
significantly to, air pollution which may reasonably be anticipated to
endanger public health or welfare."  Proposal  and promulgation of
standards of performance are to follow.
     Since passage of the Clean Air Amendments of 1970, considerable
attention has been given to the development of a system for assigning
priorities to various source categories.   The approach  specifies areas
of interest by considering the broad strategy of the Agency for imple-
menting the Clean Air Act.  Often, these "areas" are actually pollutants
emitted by stationary sources.  Source categories that  emit these
pollutants are evaluated and ranked by a process involving such factors
as:  (1) the level  of emission control  (if any) already required by
State regulations,  (2) estimated levels of control  that might be required
from standards of performance for the source category,  (3) projections
of growth and replacement of existing facilities for the source category,
and (4) the estimated incremental  amount of air pollution that could be
prevented in a preselected future year by standards  of  performance  for
the source category.   Sources for which new source  performance standards
were promulgated  or under development during 1977,  or earlier,  were
selected on these criteria.
     The Act amendments of August 1977 establish specific criteria  to be
used in determining  priorities for all  major source  categories  not  yet
listed by EPA.  These are:   (1)  the quantity of air pollutant emissions
that each such category will  emit, or will  be  designed  to emit; (2) the
extent to which  each  such  pollutant may reasonably  be anticipated to
endanger public  health or welfare; and  (3)  the mobility and  competitive
nature of each such  category  of  sources and  the consequent  need for
nationally applicable new  source  standards  of  performance.
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     The Administrator is to promulgate standards for these categories
according to the schedule referred to earlier.
     In some cases it may not be feasible immediately to develop a
standard for a source category with a high priority.  This might happen
when a program of research is needed to deveiup control  techniques or
because techniques for sampling and measuring emissions may require
refinement.  In the developing of standards, differences in the time
required to complete the necessary investigation for different source
categories must also be considered.  For example, substantially more
time may be necessary if numerous pollutants must be investigated from a
single source category.  Further, even late in the development process
the schedule for completion of a standard may change.  For example,
inablility to obtain emission data from well-control led sources in time
to pursue the development process in a systematic fashion may force a
change in scheduling.  Nevertheless, priority ranking is, and will
continue to be, used to establish the order in which projects are
initiated and resources assigned.
     After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be
determined.  A source category may have several  facilities that cause
air pollution, and emissions from some of these facilities may vary from
insignificant to very expensive to control.  Economic studies of the
source category and of applicable control  technology may show that air
pollution control  is better served by applying standards to the more
severe pollution sources.  For this reason, and because there is no
adequately demonstrated system for controlling emissions from certain
facilities, standards often do not apply to all  facilities at a source.
For the same reasons, the standards may not apply to all air pollutants
emitted.  Thus, although a source category may be selected to be covered
by a standard of performance, not all  pollutants or faculties within
that source category may be covered by the standards.
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2.3  PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
     Standards of performance must  (1) realistically reflect best demon-
strated control  practice;  (2) adequately consider the cost, the non-air-
quality health and environmental impacts, and the energy requirements of
such control ; (3) be applicable to existing sources that are modified or
reconstructed as well  as new installations; and  (4) meet these conditions
for all variations of operating conditions being considered anywhere in
the country.
     The objective of a program for developing standards is to identify
the best technological  system of continuous emission reduction that has
been adequately demonstrated.  The standard-setting process involves
three principal  phases  of activity:   (1) information gathering,
(2) analysis  of the information, and  (3) development of the standard of
performance.
     During the information-gathering phase, industries are queried
through a telephone survey, letters of inquiry, and plant visits by EPA
representatives.  Information is also gathered from many other sources,
and a literature search is conducted.  From the knowledge acquired about
the industry,  EPA selects certain plants at which emission tests are
conducted to  provide reliable data that characterize the pollutant
emissions from well-con trolled existing facilities.
     In the second phase of a project, the information about the industry
and the pollutants emitted is used in analytical  studies.  Hypothetical
"model  plants" are defined to provide a common basis for analysis.  The
model plant definitions, national  pollutant emission data, and existing
State regulations governing emissions from the source category are then
used in establishing "regulatory alternatives."  These regulatory
alternatives  are essentially different levels of emission control.
     EPA conducts studies to determine the impact of each regulatory
alternative on the economics of the industry and on the national  economy,
on the environment,  and on energy consumption.  From several  possibly
applicable alternatives, EPA selects the single most plausible regulatory
alternative as the basis for a standard of performance for the source
category under study.
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     In the third phase of a project, the selected  regulatory  alternative
is translated into a standard of performance, which, in  turn,  is written
in the form of a Federal regulation.  The Federal regulation,  when
applied to newly constructed plants, will limit emissions to the leve"^
indicated in the selected regulatory alternative.
     As early as is practical in each standard-setting project, EPA
representatives discuss the possibilities of a standard  and the form it
might take with members of the National  Air Pollution Control   Techniques
Advisory Committee.  Industry representatives and other  interested
parties also participate in these meetings.
     The information acquired in the project is summarized in  the Back-
ground Information Document  (BID).   The BID, the standard, and a preamble
explaining the standard are widely circulated to the industry  being
considered for control, environmental  groups, other government agencies,
and offices within EPA.  Through this extensive review process, the
points of view of expert reviewers  are taken into consideration as
changes are made to the documentation.
     A "proposal  package" is assembled and sent through  the offices of
EPA Assistant Administrators for concurrence before the  proposed standard
is officially endorsed by the EPA Administrator.   After  being approved
by the EPA Administrator, the preamble and the proposed  regulation are
published in the Federal Register.
     As a part of the Federal Register announcement of the proposed
regulation, the public is invited to participate  in the  standard-setting
process.   EPA invites written comments on the proposal  and also holds a
public hearing to discuss the proposed standard with interested parties.
All public comments are summarized  and incorporated into a second volume
of the BID.  All  information reviewed and generated in studies  in support
of the standard of performance is available  to the public in a  "docket"
on file in Washington, D.  C.
     Comments from the public are evaluated,  and  the standard of performance
may be altered in response to the comments.
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     The significant comments and EPA's position on the issues raised
are included in the "preamble" of a "promulgation package," which also
contains the draft of the final  regulation.  The regulation is then
subjected to another round of review and refinement until  it is approved
by the EPA Administrator.  After the Administrator signs the regulation,
it is published as a "final  rule" in the Federal Register.
2.4  CONSIDERATION OF COSTS
     Section 317 of the Act requires an economic impact assessment with
respect to any standard of performance established under Section 111
of the Act.  The assessment is required to contain an analysis of
(1) the costs of compliance with the regulation, including the extent to
which the cost of compliance varies depending on the effective date of
the regulation and the development of less expensive or mo re. efficient
methods of compliance, (2) the potential inflationary or recessionary
effects of the regulation,  (3) the effects the  regulation might have on
small business with respect to competition,  (4) the effects of the
regulation on consumer costs, and  (5) the effects of the regulation on
energy use. Section 317 also requires that the  economic impact assessment
be as extensive as practicable.
     The economic impact of a proposed standard upon an industry is
usually addressed both in absolute terms and in terms of the control
costs that would be incurred as a result of compliance with typical,
existing State control regulations.  An incremental  approach is
necessary because both new and existing plants would be required to
comply with State regulations in the absence of a Federal  standard of
performance.  This approach requires a detailed analysis of the economic
impact from the cost differential that would exist between a proposed
standard of performance and the typical State standard.
     Air pollutant emissions may cause water pollution problems, and
captured potential air pollutants may pose a solid waste disposal  problem.
The total environmental impact of an emission source must, therefore, be
analyzed and the costs determined whenever possible.
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     A thorough study of the profitability and price-setting mechanisms
of  the industry is essential to the analysis so that an accurate estimate
of  potential adverse economic impacts can be made for proposed standards.
It  is also essential  to know the capital requirements for pollution
control systems already placed on plants so that. tHe additional capital
requirements necessitated by these Federal  standards can be placed in
proper perspective.  Finally, it is necessary to assess the availability
of  capital to provide the additional  control  equipment needed to meet
the standards of performance.
2.5  CONSIDERATION OF ENVIRONMENTAL IMPACTS
     Section 102(2}(C) of the National  Environmental Policy Act (NEPA)
of  1969 requires Federal  agencies to prepare detailed: environmental
impact statements on proposals for legislation and other major Federal
actions significantly affecting  the quality of the human environment.
The objective of NEPA is  to build into the decision-making process of
Federal agencies a careful  consideration of all  environmental  aspects of
proposed actions.
     In a number of legal  challenges  to standards of performance for
various industries, the United States  Court of Appeals for the District
of Columbia Circuit has held that environmental  impact statements need
not be prepared by the Agency for proposed  actions under Section 111  of
the Clean Air Act.   Essentially,  the  Court  of Appeals has determined
that the best system of emission  reduction  requires  the Administrator to
take into account counter-productive  environmental  effects of a proposed
standard, as well  as  economic costs to the  industry.  On this  basis,
therefore, the Court established  a narrow exemption  from NEPA  for EPA
determination under Section 111.
     In addition to these judicial  determinations,  the Energy  Supply and
Environmental  Coordination  Act (ESECA)  of 1974 (PL-93-319) specifically
exempted proposed actions under  the Clean Air Act from NEPA  requirements.
According to section  7(c)(l), "No action taken under the Clean Air Act
shall  be deemed a major Federal  action  significantly affecting the
quality of the human  environment  within the meaning  of the National
Environmental  Policy  Act  of 1969." (15  U.S.C.  793(c)(l))
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     Nevertheless, the Agency has concluded that the preparation of
environmental  impact statements could have beneficial  effects on certain
regulatory actions.  Consequently, although not legally required to do
so by section 102(2)(C) of NEPA, EPA has adopted a policy requiring that
environmental  impact statements be prepared for various regulatory
actions, including standards of performance developed under section 111
of the Act.  This voluntary preparation of environmental  impact state-
ments, however, in no way legally subjects the Agency to NEPA requirements.
     To implement this policy, a separate section in this document is
devoted solely to an analysis of the potential  environmental  impacts
associated with the proposed standards.   Both adverse and beneficial
impacts in such areas as air and water pollution, increased solid waste
disposal ,  and increased energy consumption are discussed.
2.6  IMPACT ON EXISTING SOURCES
     Section 111  of the Act defines a new source as ".  .  .  any stationary
source, the construction or modification of which is commenced ..."
after the  proposed standards are published.   An existing  source is
redefined  as a new source if "modified"  or "reconstructed"  as defined in
amendments to the general  provisions of Subpart A of 40 CFR Part 60,
which were promulgated in the Federal  Register on December  16, 1975 (40
FR 58416).
     Promulgation of a standard of performance requires States to
establish  standards of performance for existing sources in  the same
industry under Section 111  (d) of the Act if the standard for new sources
limits emissions  of a designated pollutant (i.e., a pollutant for which
air quality criteria have not been issued under Section 108 or which  has
not been listed as a hazardous pollutant under Section  112).   If a State
does not act,  EPA must establish such standards.   General provisions
outlining  procedures for control  of existing  sources under  Section
111 (d) were promulgated on  November 17,  1975,  as  Subpart B  of 40 CFR
Part 60 (40 FR 53340).
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2.7  REVISION OF STANDARDS OF PERFORMANCE
     Congress was aware that the level of air pollution control achievable
by any industry may improve with techno! ogica1 advances.  Accordingly,
Section 111 of the Act provides that the Admv.istrator ". . . shall, at
least every four  years, review and, if appropriate,, revise ..." the
standards.  Revisions  are made to assure that the standards continue to
reflect the best systems that become available in the future.   Such
revisions will  not be  retroactive,  but will  apply to stationary sources
constructed or modified after the proposal  of the revised standards.
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             3.  THE PUBLICATION ROTOGRAVURE PRINTING  INDUSTRY
                     PROCESSES AND  POLLUTANT EMISSIONS

3.1  GENERAL
     The publication rotogravure printing  industry  is a highly specialized
segment of the graphic arts industry.  The graphic  arts industry, which
includes all printing, publishing,  and allied industries,  is characterized
under "Standard Industrial Classification" (SIC) 27 by the U.S. Department
of Commerce.   Commercial printing  is subclassified under  SIC 275;
additional subclassification separates gravure printing under SIC 2754.
Gravure printed products are further divided into four SIC subcategories.
The two industry sectors of packaging and  specialties gravure are repre-
sented under SIC 27542 and 27544, respectively.  Publication and adverti-
sing gravure products are listed under separate SIC Numbers 27541 and
27543, respectively.  The gravure industry, however, groups these two
product areas into a common third sector.  The dollar value of advertising
is really too small realative to the other sectors to be listed separately.
In addition, advertising products are handled by the same  gravure presses
as publication products.
     Gravure facilities printing products  in the combined  third sector
are the subject of this study.  Publication rotogravure printing involves
the high-volume printing of high-quality,  smooth paper items such as
magazines.  Also high volume, but somewhat lower quality items such as
newspaper and advertising supplements, and all  types of catalogs are
printed on the same rotogravure presses.   Most of these items are in
full color.  The combination of these gravure products accounted for
                                 O
over $2 billion in sales in 1976.   During that year weekly averages of
73.5 million regularly scheduled rotogravure newspaper supplements and
109.6 million preprinted inserts were distributed.  In addition, a
monthly average of 187 million magazines were printed wholly or in part
by rotogravure.  Facilities printing the packaging and specialty gravure
products are not considered in this study.  A more detailed economic
profile of the industry is presented in Chapter 8.
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     A list of the publication rotogravure printing establishments
operating as of January 1978 is presented in Table 3-1.   This list shows
27 printing establishments throughout 15 states.   A large portion of
these are located in the midwest and northeast sections  of the United
States.  One of these establishments ceased operation in mid-1978.  One
new establishment is expected to begin operation during  1979.
     Gravure printing is the fastest growing segment within the entire
printing industry.  Furthermore, publication rotogravure printing is
the fastest growing sector of the gravure market.  A reliable estimate
of the anticipated growth rate of the publication rotogravure industry
was not available.  However, growth projections were available for total
gravure printing and the entire printing industry.  U.S. Department of
Commerce figures estimate a 5 percent annual real growth rate for the
                                                  3
entire printing industry over the next five years.   In addition, total
gravure's percentage of the overall graphic arts market is expected to
increase from the 14 percent in 1977, to about 16 percent in 1980,, and
25 percent  in 1990.   Therefore, the output of the total gravure  industry
would  be expected to almost double by 1983.  However, several constraints
 (discussed  in Chapter 8) such as paper shortages and limited press
manufacturing capacity, are expected to decrease this potential growth
rate.  The  result of a more detailed analysis of the growth  potential
for the  publication  rotogravure printing  industry, as presented in
Chapter  8,  shows  an  estimated 7 percent annual real growth rate through
the year 1985.
      There  are  several  reasons why the  rotogravure printing  process  is
experiencing  such  rapid growth  in  the publication  industry.  The  primary
 reason is  the  result of technological advances in  the presses and in  the
printing cylinder preparation.  These advances have greatly  improved
 rotogravure's  competiveness with other  printing  methods  for  handling
shorter  run products.   In addition,  the  advantages of rotogravure over
other forms of  printing are the high quality  of  the  product, the  durability
of the image  surface,  and the  high  volume  capability.   Gravure  is the
only  printing  process  in which  the amount  of  ink applied  to  the  paper at
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     Table  3-1.   PUBLICATION ROTOGRAVURE  INSTALLATIONS  IN THE U.S.
                 AS OF JANUARY 1,  1978
•  Alco-Gravure,  Inc.
  2436 West 15th Street
  Chicago, Illinois   60608
  312/421-2929

•  Alco-Gravure,  Inc.
  828 East Holmes  Road, Whitehaven
  Memphis, Tennessee   28116
  901/397-7517

•  Alco-Gravure,  Inc.
  701  Baltimore  &  Annapolis  Blvd,
    N.W.
  Glenburnie,  Maryland  21061
  Alco-Gravure,  Inc.
  11041  Vanowen  Street
  North  Hollywood,  California
  213/760-0900
91605
  Arcata Graphics
  696 Trimble Road
  San Jose,  California  95150
  408/263-1700

  Arcata Graphics
  Buffalo Division
  TC Industrial  Park
  Depew, New York  14043
  716/684-5000

  Art Gravure Corporation  of Ohio
  1845 Superior  Avenue
  Cleveland, Ohio  44114
  216/861-1750

  Chicago Rotoprint Company*
  4601 Belmont Avenue
  Chicago, Illinois -60641
  312/794-4600
  *W. F. Hall is the parent company.
Hall of Mississippi Printing
  Company*
511 Jackson Street
P.O. Box 1555
Corinth, Mississippi  38834
601/287-3744
*W. F. Hall is the parent company.

Dayton Press, Inc.
2219 McCall Street
P.O. Box 700
Dayton, Ohio  45401
513/268-6551

The Denver Post, Inc.
Box 1709
Denver, Colorado  80201
303/297-1010

Gravure West*
4900 East 50th Street
Los Angeles, California   90058
213/583-4101
*The Denver Post is the  parent
  company.

Diversified Printing Corporation*
Box D
Atglen, Pennsylvania  19310
215/593-5173
*Parade Publications,  Inc.  is the
  parent company.

R. R.  Donnelley &  Sons Company
2223 South  Martin  Luther King
  Drive
Chicago, Illinois   60616
312/326-8000
                                      (Continued)
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                        Table 3-1.   Continued
R.  R.  Donnelley & Sons Company
Route 30 West
P.O.  Box 837
Warsaw, Indiana  46580
219/267-7101

R.  R.  Donnelley & Sons Company
Mattoon Manufacturing Division
Route 45 North, P.O. Box 189
Mattoon, Illinois  61938
217/235-0561

R.  R. Donnelley & Sons Company
801 Steam Plant Road
P.O. Box 129
Gallatin, Tennessee  37066
615/452-5170

Kable Printing Company
404 North Wesley Avenue
Mt. Morris,  Illinois  61054
815/734-4121

Meredith Corporation
1716 Locust  Street
Des Moines,  Iowa 50336
515/284-9011

Meredith/Burda,  Inc.
4201 Murray  Place
P.O. Box 842
Lynchburg,  Virginia   24505
804/846-7371

New York News,  Inc.
Newspoint Gravure  Plant
54th Avenue  and  2nd  Street
Long Island  City,  New York   11111
212/949-3300
Providence Gravure, Inc.
99 West River Street
Providence, Rhode Island
401/331-1771
02904
Texas Color Printers*
4800 Spring Valley Road
Dallas, Texas  75240
214/233-3400
*Providence Gravure is the parent
  company.

Springfield Gravure Corp.
1940 Commerce Road
Springfield, Ohio  45501

Standard Gravure Corp.
643 South Sixth Street
Louisville, Kentucky  40202
502/582-4401

Triangle Publications, Inc.*
440 North Broad Street
Philadelphia, Pennsylvania  19101
215/665-1350
*Triangle ceased operations in July
 1978.

World Color Press
Salem Gravure
Route #4, P. 0. Box 558
Salem, Illinois  62881
618/548-4010
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any one point can be varied.  The gravure method excells for reproducing
photographs, fine drawn lines for ads, and separated tones.  Modern
press speeds, up to about 11 meters per second  (2200 feet per minute),
greatly facilitate the handling of large production runs.
3.2  FACILITIES AND THEIR EMISSIONS
     This study pertains to the volatile organic compounds  (VOC) emissions
from publication rotogravure printing presses, which are referred to as
the "facilities".  VOC emissions from ink and solvent storage and transfer
facilities, as well as emissions from other printing operations within
the same printing plant are not discussed in this document.  Additional
presses that print other gravure products and different types of printing
processes are sometimes housed within the same plant.  An attempt to
characterize entire printing plants would have dramatically increased
the complexity of this study.  Therefore, this study involves only those
facilities printing publication and advertising products.  Air pollutant
emissions from the other gravure sectors and from other printing processes
may be characterized under future studies.
     A typical  publication rotogravure printing establishment will
consist of two to six production presses and a proof press.  Some larger
installations have a dozen or more production presses with additional
proof presses.   Each production press usually consists of eight to
twelve individual  printing units; proof presses consist of only four
printing units.  The production presses operate at speeds up to about 11
meters per second  (2200 feet per minute); proof presses are usually
operated at much slower speeds pf about 0.8 to 2.0 meters per second
(150 to 400 feet per minute).5'6  A 1977 estimate indicated that there
were about 150 publication rotogravure presses  (production and proof),
with a total  of about 1500 printing units in the United States.7  Of
these, about 125 presses were full-size production facilities.
     Proof presses serve as an intermediate testing step between prepara-
tion of the printing cylinder and production runs.   The proof press is
used only to check the quality of the image formation of newly engraved
or etched printing cylinders.  Therefore, to handle the printing cylinders
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the proof press must be the same width as the production presses.   Proof
presses are operated slowly and intermittantly compared to the high
speed production presses.  The ink and solvents used at proof presses
are usually handled out of drums.  The total  solvent usage by proof
presses varies from plant to plant within a range of less than one
                                                                8 9
percent to about two percent of the usage by production presses. '
     The source of the VOC emissions are the solvent components in the
inks, extenders, and varnishes used at the printing presses, as well  as
solvent added for printing and cleaning.  The gravure printing method
usually involves handling of inks of only the four primary colors of
yellow, red, blue, and black.  Only one color of ink is handled at each
individual printing unit.  Any color other than the primary color is
produced by printing one primary color ink on top of another to yield
the desired mixture.  A typical gravure ink consists of pigment, binder,
and a solvent.  The ink's color is provided by numerous pigment materials
such as clay, titanium dioxide, cadi urn yellows, metallics and flourescents.
Various types of resins are employed as binders to lock the pigment to
the substrate or web, as well as to protect the pigment from heat,
moisture, and abrasion.  The extenders or varnishes are sometimes mixed
in with the ink to provide a certain texture or glossy effect for the
final printed product.
     There are two basic types of solvents presently used in this industry.
In a few cases only toluene  is used.  Toluene  is usually a  better solvent
for dissolving the ink resins and for producing a higher quality printed
product.  On the other hand, toluene  is a more expensive solvent and its
supply  is limited because of the demand from the chemical and fuel -
additives industries.  The second and most common solvent is a mixture
of toluene-xylene-1 actol spirits  (naphtha).  Xylene slows the evaporation
rate of the solvent: 1 actol  spirits hasten this evaporation.  In areas
where highly  photochemically  reactive solvents are  regulated more strin-
gently  than are lesser photochemical ly  reactive solvents, and 81-85
volume  percent  aliphatic, 15-19  volume  percent aromatic mixture  is
commonly  used.  The aliphatic  components  frequently function more as
reducing  agents rather than  true solvents.
                                    3-6

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     This industry is researching the possibilities of using low-VOC,
waterborne ink systems to reduce their VOC emissions.  At present,
waterborne inks have not been developed for publication rotogravure
printing.  One technical problem for waterborne inks is the need for
pigments that are more water-soluble than those used now in solvent-
borne inks.  In addition, waterborne inks tend to form beads on the web
surface, rather than sink into the surface as organics do.  Also, water-
borne inks are more difficult to dry than solvent-borne inks.  Drying of
the ink  is very critical in rotogravure printing because the high speed
operation of the presses requires fast and thorough drying of the paperweb
between  the printing units.  Waterborne ink systems are not expected to
be developed for this industry for 5 to 10 more years.  '
3.2.1  The Printing Process
     Gravure is distinguished from other printing methods by the nature
of the image surface.  The method is often referred to as the "intaglio"
process.  An enlargement of the image surface is shown in Figure 3-1.
The surface of the gravure printing cyclinder is etched or engraved with
many tiny recesses  (cells).  The depth of each cell determines the
amount of ink that will be applied to the paper at that point.  The cell
depth typically ranges to a maximum of about 35 micrometers [microns]
 (.0014 inches).
     The gravure printing method can be used with two types of printing
processes.  Rotogravure is the most widely used process.  It involves a
continuous web of paper that is fed from a continuous roll and passed
over the image surface of a revolving printing cylinder.  This is known
as web-fed or roll-fed gravure.  The second gravure printing process,
known as sheet-fed gravure, involves the insertion of separate sheets of
substrate or paper into a gravure press.  Publication and advertising
products are printed on web-fed presses only; sheet-fed gravure is not
considered in this document.
                                    3-7

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              PAPER
CO
I
00
                                                                                               PAPER
 IMAGE
SURFACE
                                         Figure 3-1.  Gravure image surface,

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     The most common web-fed  rotogravure  printing press  consists  of
eight printing units.  A schematic of a typical  rotogravure  printing
press is presented  in Figure  3-2.  All units of  a press  must  be the same
size and width.   In addition, all the units must simultaneously operate
at the same press speed.  However, each unit handles  an  individual color
of ink and prints on only one side of the paper  web.  Typical press
operation consists  of printing the four color  inks on one  side of the
web as it passes  through the  first four units.   The web  is then guided
through four additional units for printing on  the reverse  side.  After
leaving the final printing unit, the web  is directed  to  a  cutting and
folding machine.
     The rotogravure press is designed as a continuous printing facility.
However, typical  operation is probably better  described  as being semi-
continuous.  Normal  press operation is characterized  by  numerous shutdowns
caused by web breaks or mechanical problems.   The frequency and downtime
for the press shutdowns varies depending upon  the product  being printed
and the specific  cause of the shutdown.  Press operating data from
                                         12 13
several  tests is  presented in Appendix C.  '     The data shows that
normal  printing operations involve about 6 to  14 press shutdowns per 24
hour period.   This yields actual  printing times  of only  about 60 to 85
percent of the scheduled time.  Additional downtime occurs at the end of
each product run.  After completion of the job run, the  printing cylinders
are removed from each unit.   Newly prepared printing cylinders are then
installed in each unit for the next job run.
     An expanded  diagram showing an end view of  an individual printing
unit is presented in Figure 3-3.   The paper web  is woven through a
series of rollers which precisely adjust its path through the press.
The rollers also help regulate the paper tension and maintain constant
speed.   The web is guided between the revolving gravure  printing cylinder
and a rubber roller.  The paper is pressed against the image surface of
the gravure cylinder by the rubber roller, which serves as a backing.
Pressure is applied  to the rubber roller by a pressure cylinder.   The
                                     3-9

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GJ
I
                                                           Guide Rollers  (Typical)
                                                                                 Paper Web
          To
      Cutting  &
      Product
      Folder
             / / / / /  * / / / ///////S/////
                                    Press  Unit  (Typical)
                                                                 o.
            Ink Colors:
            Y-Yellow     BL-Blue
            R-Red        BK-Black
Paper Feed  Roll
                                      Figure 3-2.  Schematic of a Typical  Eight-Unit Rotogravure
                                                            Printing  Press

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                                                                                           TO NEXT UNIT
CO
i
                       ADJUSTABLE
                       COMPENSATING
                       ROLLER
                                                                    DRYER EXIT'
                                                                    AIR FLOW
                                                                                                    RECIRCULATION
                                                                                                    FAN
                                                                                                                 TO
                                                                                                                 DRYER
                                                                                                                 EXHAUST
                                                                                                                 HEADER
                                                                                                       MJ—*- EXTENDER/VARNISH
                                                                                                   M |	4— INK

                                                                                                         «	 SOLVENT
                                                                  CIRCULATION
                                                                     PUMP
                                                                                                   -LIQUID VOLUME METERS
                                        Figure  3-3.   Diagram of a  rotogravure  printing  unit.

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point of contact between the web and the gravure cylinder is called the
"nip" area.
     After the impression has been made, the paper web travels  up through
an enclosed dryer where jets of heated air evaporate the volatile solvent.
The web exits the top of the dryer and is guided along rollers  to the
next printing unit.   In modern printing unit designs,  the dryer inlet
air is drawn in through the bottom and top openings of the dryer.  This
air is then pulled out of the dryer with the heated air and solvent
vapors by the recirculation fan.  The dryer air is then directed through
a steam heating coil.  Most dryer desi|ngjs contact the  heated air on only
one side of the paper web: however, some designs dry from both  sides.  A
portion of the fan discharge air is continuously drawn off as the dryer
exhaust.  In a typically controlled facility, the exhaust from  all  the
dryers are gathered  in a header, and directed to a carbon adsorption
system.  This dryer exhaust is vented to the atmosphere in an uncontrolled
plant.
     Each printing unit has its own ink handling system.  The raw ink is
purchased as a concentrated liquid-solid mixture which must be  diluted
before being used for printing.  The ink is mixed with solvent, and
sometimes extenders  or varnishes, in a mixing tank.  The resultant
mixture is then continuously circulated through the ink fountain and
back to the mix tank.  This circulation prevents the ink pigments from
settling out of the  mixture.  The make-up ink and extenders or varnish
streams are continuously fed in a controlled ratio to  the mix tank by
automatic level control.  The make-up solvent is usually fed to the mix
tank by automatic viscosity control.  The amount of solvent addition
depends upon the desired ink color density.
     The gravure cylinder, on which the image surface  has been  etched,
is about one-fourth  submerged in a trough of ink called the ink fountain.
Before a portion of the gravure cylinder contacts the  paper, it picks up
ink from the ink fountain and is then scraped by a flexible "doctor
blade".  This blade  removes the ink from the smooth non-image surface
but leaves the ink in the cells.
                                    3-12

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     At the end of each job run, the old image surface is removed from
the gravure printing cylinder.  A new image is then etched or engraved
into the cylinder surface for the next product run.  The gravure cylinder
is usually made of steel  with copper plating.   There are several methods
presently used to form the image surface.  The most common methods are
acid etching and electronic engraving.  After the image surface has been
tested-out and approved on a proof press, the gravure cylinder's surface
is then plated with a very thin layer of chrome.  This protective chrome
plating is much harder than copper and greatly adds to the durability of
the image surface.
     The ink used for rotogravure printing must instantly fill the cells
in the image surface, and therefore must have a relatively low viscosity.
This ink mixture, transferred from the cells to paper, must spread on
the paper to form printed solid images.  The ink solvent to solids ratio
as applied to the gravure cylinder varies with the ink type, color, and
substrate used.  The raw, purchased ink is normally about 50 volume
percent solvent.  At the press, this ink is diluted with additional
solvent at a volume ratio of about 1:1 to achieve a desired viscosity.
The resulting mixture is about 25 percent ink resins and solids, and 75
percent solvent.  An additional amount of solvent  (averaging about 5
percent) is periodically added to the ink fountain to replace evaporated
fugitive losses.  Therefore, the total equivalent ink mixture used is
about 80 volume percent solvent and 20 volume percent ink and varnish
solids.  A schematic of a general  solvent material balance is presented
in Chapter 6 for the development of model plant characteristics.
     The source of VOC emissions from the publication rotogravure printing
presses results from the evaporated solvent used for printing and cleaning.
Almost all of the solvent used at the facility eventually vaporizes.
Unless this evaporated solvent is captured and controlled, the resultant
vapors become air pollutants.  A small amount of solvent used at the
facility is disposed of as liquid waste ink mixture.  This waste ink is
usually pumped into drums and is sent out of the plant.   In addition,
some cleaned-up, used dirty solvent is also disposed of with the waste
                                   3-13

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 inks.  Some of the solvent used at the press is retained by the printed
 product.  However, this retained solvent eventually evaporates after the
 printed product leaves the press.
 3.2.2  Process Conditions
     There are many process conditions to deal  with in the publication
 rotogravure printing industry.  Several of these conditions are-
    • Cylinder width,
    • Cylinder circumference,
    • Web width,
    • Line speed,
    • Dryer temperature,
    • Dryer air flow,
    • Dryer exhaust VOC concentration,
    • Sol vent blend,
    • Ink type,
    • Ink color,
    • Ink coverage, and
    • Type of paper.
     A gravure press is a custom-made machine.   When a new press  is
ordered, the number of units and the cylinder width are specified.   The
cylinder circumference and the line speed of the press are variable, but
the maximum speed is frequently governed by either the mechanical  capabi-
lities of the press itself, or the folder.   The typical  press has eight
printing units, although ten and twleve unit presses are common.   Cylinder
widths range from 1 to 2.7 m  (3 to 9 ft.),  but  a 1.8 m (6 ft) cylinder
is quite common.  Cylinder circumferences range from about 0.6 to 1.2 m
 (2 to 4 ft), but average at about 1  m  (3.3  ft).  Typical  press speeds
range from 5 to 6 m/s  (1000 to 1200 ft/m) for older presses; 9 to 11 m/s
 (1800 to 2200 ft/m) for newer presses.
     The press manufacturer usually supplies the dryer.   The design of
the dryer depends upon the required drying  temperatures,  the press
speed, and the exhaust air flow.   A high boiling solvent requires a
higher drying temperature  and/or a higher air flow rate.   A longer
                                   3-14

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drying path  is also sometimes  specified.   The drying  temperature must  be
carefully controlled to avoid  any shrinkage of the web.  Web shrinkage
is undesirable because it causes web breaks and poor  color registration,
which results in an off-grade  printed product.  Drying problems during
production runs are usually solved by slight changes  in the solvent
composition  and/or dryer temperatures. The drying temperatures range
from ambient to about 120°C (250°F).  The  black printing units use the
highest temperatures.  Most of the existing dryer exhaust fan systems
are operated at a fixed flow rate and are  not adjustable.  The air flow
rate capacity is usually conservatively designed to allow printing with
the maximum  expected ink coverage.  The dryer exhaust flow rate for each
unit ranges  from 3400 to 6800  m3/hr (2000 to 4000 ft3/min) and depends
greatly on the cylinder width  and press speed.
     Changes in the web width, press speed, and ink coverage influence
the dryer exhaust solvent vapor concentration.  The dryers are designed
with an air  recirculation fan  to concentrate the solvent vapors in the
dryer exhaust.  Recirculation  fans on most of the existing printing unit
dryers are designed only for one constant air flow capacity, in a similiar
fashion to the exhaust fan.  With fixed air handling capacity systems,
a wide press printing on a narrow web could cause excessive dryer exhaust
dilution.  However, some existing dryers are designed to facilitate
throttling and recirculation air flow and provide adequate fresh air
makeup, without excessive dryer exhaust dilution.  Some of the air
throttling controls are manual, while others are automatic.  Excessive
dryer exhaust dilution requires a larger, more expensive solvent laden
air (SLA) capture and control   system.   The SLA capture and control
systems are discussed in detail in Chapter 4.
     A very  important parameter for dryer operation concerns the lower
explosive limit (LEL) of the solvent vapors.   The LEL is the lowest
vapor concentration in air, expressed  as volume percent, at which the
mixture could support a  flame  or explosion at temperatures below 121°c
(250°F).   Above this temperature, the  LEL should be decreased  by a
factor of 0.7 since explosibility increases with higher temperatures.
                                    3-15

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Solvent vapor concentrations in the dryer exhaust from most printing
units range from about 5 to 20 percent of the LEL.   A factor which
limits the maximum permissible LEL is frequently the insurance safety
regulation.  Most facilities are conservatively operated so that the
vapor concentrations are maintained well  below the 25 percent of LEL
maximum recommended safety guideline.  Alternatively, solvent vapor
concentrations up to 50 percent of the LEL may be allowed if approved
continuous vapor-concentration indicator/controllers are used.
     Vapor analyzers can be installed in the dryer exhausts for maximiz-
                                     14 15
ing the solvent vapor concentrations.  ' '   These analyzers control  the
organic vapor concentration to a certain set point by automatically
regulating the amount of exhaust air drawn from the dryers.  An alarm
can be installed to sound if the vapors in the collected exhausts reach
a certain maximum desired level, or the vapors in any of the individual
dryer exhausts reach about 40 percent of the LEL.  Additional safety
features can include automatic press shutdown if the vapor concentration
should reach about 50 percent of the LEL.
     The percent ink coverage for a specific ink color is defined as the
percentage of maximum positive density for that specific ink.  The
maximum possible ink coverage for a four-color product  (total coverage
for each of four colors) is 400 percent.  Typical total ink coverages
range from less than 100 percent to 300 percent for a spot on a four-
color product. If the ink coverage increases, the dryer exhaust may
become more concentrated with VOC.   If, however, the ink coverage decreases,
the dryer exhaust may become less concentrated.
     The color and type of  ink can affect the VOC concentration in  the
SLA from the various printing units.  Each unit uses a different  color
of ink for one side of the  printed product.  Each color and  type  of
purchased  ink has a different solvent content.  The  solvent  content
ranges from about 30 to 70  volume percent, but averages 50 volume percent.
The dilution solvent used for the inks is all the same, but  the amount
required varies depending on the varnish and  resin  content.   The  typical
solvent content of  the mixed  ink  ranges  from 70 to  85  volume  percent,
                                  3-16

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 but  averages  75 percent.   Consequently,  the solvent content of the mixed
 ink  (as  printed) varies  from unit to unit.  This variation can affect the
 SLA  concentration from each  unit's dryer.
      The type and quality of paper used  can affect the maximum practical
 press speed.   Excessive  press speeds with  poor grades  of paper can cause
 frequent web  breaks.   Web breaks  can create a  significant amount  of
 unscheduled down time, and are therefore undesirable.   The coated paper
 stock (used in high  quality  magazines and  advertisements) is  more difficult
 to dry,  and therefore  sometimes  requires greater dryer air flow rates.
      Test data presented  in  Appendix C shows that publication rotogravure
 presses  have  unscheduled  shutdown frequencies  ranging  from 0.2 to 0.7
 shutdowns per press  hour.  Typical  run times range from one to three
 hours, with maximum  run  times exceeding  four hours.  The individual
 presses  at one tested  plant  were  running about  64 to 86 percent of the
 total  test time.   Presses at another plant were operating about  72  and
 78 percent of the time.
 3.2.3  Fugitive  Emissions
      Figure 3-4  presents  a side or end view of  a typical  printing  unit,
 showing  the locations  where  fugitive  vapors can  escape.   The  main  sources
 of fugitive vapors result  from solvent evaporation in  the ink  fountain,
 the  exposed part  of  the gravure cylinder, the paper path  from  the  printing
 nip  to the dryer inlet, and  from  the  paper  after exiting  the  dryer.  In
 some  installations the nip area and  ink  fountain  are exposed,  and  the
 dryer  inlet and  exit openings  are  large.  The proximity  of the  dryer
 inlet  to  the  nip  area  also varies  with each press.  On  newer  presses,
 these  fugitive vapors  are minimized  by enclosing  the ink  fountain,
 extending  the  bottom of the  dryer  down closer to  nip area,  and  providing
 only  small slit openings  for the web  entrance and  exists.
     A small   amount of solvent is  retained  in the  finished  product.  The
 amount of  this retained solvent may vary from about 1  to  7  percent of
 the total  solvent used at the  press,  depending  on  the type  of paper  and
                 1R IQ ?n ?i
type of ink used.I0>I3'^u'^1  An industry study  has estimated that an
average of 2.5 percent of the solvent used  remains in the  printed product.22
                                    3-17

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Paper —-
 Web
 Doctor
 Blade
                        D%
             Dryer Exit
              Air Flow
            V
     2
                                                        Dryer
                                                       Exhaust
                                             Steam
                                            Heating
                                             Coil
                                             Warm Air
                                              Nozzle
                                                 Dryer
Dryer Inlet Air Flow

Fugitive Solvent Vapor
     Figure 3-4.  Fugitive solvent vapor emissions around a
                 gravure publication printing unit.
                              3-18

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                                         23
One firm estimates a 3 percent retention.    At present there is no
known reliable method for determining the exact amount of retained
solvent.2   In general, a product printed with a glossy ink and varnish
retains more solvent than does a product printed with a non-gloss ink.
This solvent is eventually emitted to the atmosphere.  Careful operation
of the dryers should minimize the retained solvent.  However, it is not
possible to completely eliminate all retained solvent.
     The quantity of fugitive emissions and dryer exhaust emissions is
directly related to the amount of ink used.  The amount of ink used
depends on the percent of ink coverage on the product, the press speed,
and the operating time.  The percent of ink coverage and the amount of
running time may vary widely.  A typical press operation consists of
periodic shutdowns due to web breaks, mechanical problems, and cylinder
cleaning.
     An efficient SLA capture system must be able to adapt to varied
conditions of shutdown and startup and printing operation.  The vaporiza-
tion rate of solvent from a printing unit is greatly  reduced when the
press  is shut down.  The shutdown mode further complicates efficient SLA
capture because the SLA stream approaches room temperature during shut
down mode.  The cooler solvent fumes during shut down mode tend to
settle near the lower part of the pressroom.  These cool fumes can be
effectively  removed with floor sweep ventilators.  However, during
normal operation, the warm solvent fumes rise.  These warm fumes are
most efficiently collected in the mid to upper part of the pressroom,  in
the press area.  Floor sweeps are not very effective  in removing the
warm solvent fumes, which are generated during normal operation.
     Fugitive emissions can be minimized by —
    •Enclosing the ink fountain,
    • Reducing the distance between the dryer inlet and the nip area,
    • Improve vapor capture at the entrance and exit of the dryer,
    •Thorough drying of the web  in each dryer, and
    • Increased solvent vapor capture in the upper and lower areas of the
     press.
                                    3-19

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3.3  BASELINE EMISSIONS
     The baseline emission level  is the level  of emission control  that
is achieved by the affected industry in the absence of additional  EPA
standards. A recent guidelines document, issued by EPA recommends  that
states with oxidant non-attainment areas revise their implementation
plans to provide an emission reduction of 75 percent from existing
                               oc
publication rotogravure plants.    New plants in these areas will  be
subject to at least this level of control.  In most attainment areas,
new plants will be subject to emission limitations to prevent significant
deterioration.  In the few areas where state restrictions will not
apply,  it seems logical that this industry should want to recover some
of the  solvent used.  Solvent supplies are closely related to gasoline
and other fuel supplies, which will become less available and more
expensive in the future.  A general material balance  presented in Chapter
6 shows that this  industry would probably want to control at  least  75
percent of their potential VOC emissions, and  recycle the recovered
solvent.  For  these reasons a baseline control level  of  75 percent  was
chosen  as the  level to which  new publication rotogravure plants would be
controlled in  the  absence  of  new source  performance standards.
      Table 3-2 summarizes  state emission  regulations  which apply  to the
present rotogravure printing  industry.  Many state  regulations for
stationary sources  of  organic  solvent  are  similar to  Los Angeles  Rule
66,  which allows an emission  of 40  Ib/day  of  "photochemically" reactive
solvent and  3000 Ib/day  of "non-photochemically"  reactive solvent.
However,  most  states  exempt  "non-photochemically" reactive  solvents from
control  regulations.26  A "non-photochemically"  reactive solvent  is
usually defined  as one in which  highly photochemically  reactive content
 is less than 20  precent  and  that  of aromatic  organic  solvents with  more
than 8 carbons is  less than  8 percent.   Several  states  have  no volatile
                            ?7 ?R
organic emission standards.   '     Photochemical  reactivity  is discussed
 further in  Chapter 7.
                                     3-20

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                               TABLE  3-2.   STATE  AIR  POLLUTION  REGULATIONS FOR ORGANIC SOLVENT  EMISSIONS
                                       WHICH APPLY  TO THE  PUBLICATION ROTOGRAVURE PRINTING INDUSTRY
                                           Non-exempt
                                                                    Exempt'
                                                                             Exceptions
co
i
ro
California        18 kg/day, 3.6 kg/hr  (40 Ib/day, 8 Ib/hr)
  (Los Angeles)
                                                                            3000 Ib/day, 450 Ib/hr     Unless controlled 85 percent
Colorado

Illinois


Indiana


Iowa


Kentucky



Maryland

Mississippi


New York

Ohio


Pennsylvania


Rhode Island


Tennessee

Texas

Virginia
                               18 kg/day, 3.6 kg/hr (40  Ib/day, 8 Ib/hr)

                               3.6 kg/hr           (8 Ib/hr)


                               6.8 kg/day. 1.4 kg/hr(15  Ib/day, 3 Ib/hr)
                                            3000 Ib/day, 450 Ib/hr

                                            8 Ib/hr if odorous
18 kg/day, 3.6  kg/hr (40  Ib/day, 8 Ib/hr)



18 kg/day, 3.6  kg/hr (40  Ib/day, 8 Ib/hr)




                (Regulations specific to pollutant, site, volume, etc.)

18 kg/day, 3.6  kg/hr (40  Ib/day, 8 Ib/hr)
18 kg/day, 45 kg/day/site
  (40 Ib day, 100  Ib/day/site)

                (Regulations  specify "Reasonable &  Proper Technology")

45 k^hr            (100 Ib/hr)

18 kg/day           (40 Ib/day)
Unless  controlled 85  percent

Unless  controlled 85  percent,
  no controls for exempt

Unless  controlled 85  percent,
  no controls for exempt

No volatile  organic  compound
standards

Unless  controlled 85  percent
  by weight, no controls  for
  exempt

No controls  for exempt

No specific  volatile  organic
compound controls
                                                                                                     Unless controlled 85 percent,
                                                                                                       no  controls for exempt

                                                                                                     No volatile organic compound
                                                                                                       controls

                                                                                                     No controls for exempt
                                                                                                     No controls for exempt

                                                                                                     Unless  controlled 85  percent,
                                                                                                       no controls for exempt
             a     Photochemically reactive solvent
             b     Low- or non-photochemically reactive  solvent

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     According to an industry survey, 82,000 Mg (90,000 tons) of ink
                                                          on
were used by the publication rotogravure industry  in 1976.     Considering
the growth rate of the industry, an ink usage of 91 ,000 Mg   (100,000
tons) for 1977 was estimated.  The purchased ink typically  averages
about 50 volume percent solvent, and is mixed on a 1:1  volume basis with
additional  solvent.  Thus, approximately 136,000 Mg  (150,000 tons) of
solvent was estimated to have passed through publication rotogravure
presses in 1977.  An accumulation of information obtained from numerous
sources indicated that the total solvent usage was about 137,300 Mg
(151,190 tons).    A small amount of additional  solvent was used for
cleaning.
     This entire 137,300 Mg  (151,190 tons) of solvent  would have been
emitted to the atmosphere if no control  devices were used by the industry
in 1977.  However, information from numerous sources indicated that only
                                           31
about 56,800 Mg (62,570 tons) were emitted.     Approximately 80 percent
of these emissions were from uncontrolled sources.  Thus, almost 60
percent of the solvent used was recovered.  In most  cases,  the recovered
solvent was recycled by the printing plants; some  solvent was sold back
to ink manufacturers.
     In an uncontrolled plant, none of the volatile  solvents are recovered,
The dryer exhaust is vented directly to the atmosphere.  Most of the
fugitive solvent vapors are removed from the press areas through room
vents by roof and peripheral  vents fans.  The fans ventilate the working
areas by maintaining a negative pressure in the press  room.  The resulting
solvent concentration in the pressroom air  is maintained below the OSHA
standards, which is 200 PPM for toluene.32
     Nineteen of the 27 installations that were operating in 1977 were
using carbon adsorption systems to recover the solvent vapors from at
least one press.  In a typical solvent recovery installation only the
dryer exhausts are treated by the carbon adsorption  system.  Appendix C
shows data from two plants which recover 75 to 85 percent of the solvent
used, by just capturing the dryer exhausts.   At some facilities, fugitive
vapor pickups are installed as local capture points  to prevent the
                                    3-22

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formation of pockets of solvent laden air around the presses.  However,
roof and peripheral  vent fans may still be required to keep the solvent
concentration in the pressroom air below the OSHA regulations.
     An apparent overall recovery efficiency of greater than 90 percent
                                      33
has been demonstrated at one facility.    At this facility careful
attention was given to the design details of the solvent vapor capture
system, as well as to the control device, to achieve the high overall
recovery efficiency.  All vents are routed to the solvent recovery
system.  The web path through the units is essentially contained.  The
major solvent losses here are fugitive emissions associated with solvent
retention in the printed product.  Additional emissions result from the
adsorber exhaust.  Typical average treated exhaust concentrations range
from 10 ppm to 100 ppm, with occasional breakthrough concentrations
reaching several hundred ppm.  Chapter 4 provides a more detailed discussion
on the VOC emission control techniques, which apply to this industry.
                                    3-23

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3.4  REFERENCES

1.   U.S. Department of Commerce.   Standard  Industrial Classification
     Manual,  1972.   U.S.G.P.O.   P.  102.

2.   Daum, W.R. and R.P.  Long.   Profile  of the American Gravure Industry,
     1976-'77.  Gravure Technical Association, Graphic Arts Marketing
     Information Service of the  Printing  Industries  of America.  New
     York. 1978.  p. 17-19.

3.   Telecon.  George,  H.  -Gravure  Research  Institute, with Collins,
     Radian Corporation.   September 21,  1978.

4.   Reference 2, p. 13.

5.   Letter from Fremgen,  R.D. - Dayton  Press, Inc.,  to Goodwin, D.R. -
     U.S. EPA.  December 3,  1979.   p.  3  Comments  to  NAPCTAC on draft
     NSPS.

6.   Tel con.   Burt, R.C.  - Radian Corporation, with  MacAskill, P. -
     Texas Color Printers.   March 6,  1980.

7.   Reference 2, P. 55-56.

8.   Telecon  and Attachment.   Woolfolk,  J. - Texas Color  Printers, with
     Burt, R.C. - Radian Corporation.  March 10,  1980.

9.   Trip Report.  Plant visit to Standard Gravure Corporation, Louisville,
     KY.   Burt, R.C. -  Radian  Corporation.   June  6,  1980.

10.  Letter from George,  H.F.-GRI/GTA  Gravure Industry, to Vincent,
     E.J.- EPA.  September 5,  1979.   p.  5.   NSPS  for Gravure Industry.

11.  Letter from Swinford,  G.-Croda  Inks  Inc., to Burklin C.E.-Radian
     Corporation.  April  12, 1979.   Review of BID Chapters 3-6.

12.  Feairheller, W.R.   Graphic  Arts  Emission Test Report, Meredith/Burda,
     Lynchburg, VA.  Monsanto  Research Corporation.   Dayton, Ohio.  EPA
     Contract 68-02-2818-16, EMB 79-GRA-l.   April 4,  1979.  p. 5.

13.  Feairheller, W.R.   Graphic  Arts  Emission Test Report, Texas Color
     Printers, Dallas,  Texas.  Monsanto  Research  Corporation.  Dayton,
     Ohio.  EPA Contract 68-02-2818-20,  EMB  79-GRA-3.  October 1979.  p. 5.

14.  Trip Report.  Plant Visit to Meridith/Burda, Inc., Lynchburg, VA.
     Reich,  R.A., Radian Corporation.  October 26, 1978.

15.  Reference 12,  p.  17-20.
                                    3-24

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16.  Reference 12, p.5.

17.  Reference 13, p.  5.

18.  Trip Report.  Plant Visit to Standard Gravure Corporation,  Louisville,
     KY.  Reich,  R.A., Radian Corporation.  September 25,  1978.

19.  Reference 10, p.  4.

20.  Reference 14.

21.  Letter from George, H.F.-GRI/GTA Gravure Industry,  to Reich,  R.A.-
     Radian Corp.  June 4, 1979.   Comments on BID Chapters 3-6.

22.  Letter from Fremgen, R.D. (Representing the  GRI/GTA Gravure Industry
     Emission Control  Subcommittee) to Reich, R.A. -  Radian Corporation,
     April  6, 1979.

23.  Letter from Gugler, H.-Meredith/Burda, Inc., to  Vincent,  E.J.-EPA.
     July 6, 1979.  Solvent Recovery.

24.  Letter from George, H.F.-GRI/GTA Gravure Industry,  to Vincent,
     E.J.- EPA.   November 22, 1978.  CTG/NSPS Test Plans.

25.  Control of Volatile Organic  Emissions from Existing Stationary
     Sources - Volume  VIII:  Graphic Arts - Rotogravure  and Flexography.
     EPA-450/2-78-033, OAQPS No.  1.2-109, U.S.  Environmental Protection
     Agency.   Research  Triangle  Park, NC   27711. December 1978.

26.  Bureau of National  Affairs.   State Air Quality Control  Laws.
     1972-1977.

27.  Telecon.  Karachiwala, B.-Iowa State Air Pollution  Control, with
     Collins, C.-Radian Corporation.  September 1, 1978.

28.  Telecon.  Hambright, J.-Pennsylvania State Air Pollution  Control,
     with Collins, C.-Radian Corporation.  September  1,  1978.

29.  Reference 2, p.  60.

30.  Itemized information not available for public disclosure.   Solvent
     usage data  for individual facilities is kept in  confidential  files
     at the request of the data sources.

31.  Reference 30.

32.  Verschveren, K.   Handbook of Environmental Data  on  Organic  Chemicals.
     New York, Van Nostrand Reinhold Company,  p.  593.

33.  Reference 12.
                                   3-25

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                    4.  EMISSION CONTROL TECHNIQUES
     This chapter discusses techniques used for controlling volatile
organic compound (VOC) emissions from publication rotogravure printing
presses.  The chapter begins with a general discussion on existing and
alternative emission control systems.  EPA emission test results and
industry plant data for several existing control systems are then presented.
Finally, discussions on solvent vapor capture systems, solvent recovery
systems, and solvent destruction systems are presented.
4.1  OVERALL EMISSION CONTROL
4.1.1  General
     The complete air pollution control system for a modern publication
rotogravure printing facility consists of two discrete sections:  the
capture system and the emission control device system.  The capture
system is designed to gather the volatile organic compounds (VOC) vapors
emitted from the presses.  The captured vapors are then directed to an
add-on control device.  The overall reduction efficiency for VOC emission
control systems is equal to the capture efficiency times the control
device efficiency.
     Carbon adsorption is the only method currently being used to control
solvent vapor emissions from the presses.  Multiple fixed-beds, operating
in parallel  configurations, regenerated by steaming, represent the
typical case.  A new adsorption technique using a fluidized-bed of
carbon may be used in the future.  Solvent recovery is usually an integral
part of both types of carbon adsorption systems.  Solvent destruction
(i.e. oxidation) systems are also available for control of VOC vapor
emissions.  However, these systems destroy the valuable solvent vapors.
The actual printing operation is not ordinarily affected by the emission
control system.
                                    4-1

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     As an alternative emission control technique, this industry is
researching the possibilities of using low-VOC, waterborne ink systems
to reduce their VOC emissions.  However, only solvent-borne ink systems
are presently used, as explained in Chapter 3.
     A flow diagram showing where the VOC solvent enters and leaves a
controlled printing facility using solvent recovery is presented in
Figure 4-1.  Liquid solvent enters the facility as part of the inks,
varnishes and extenders used, as well as solvent added for printing and
cleaning.  Some of the solvent leaves the press as uncaptured fugitive
vapor emissions.  The printed product retains about three percent of the
total solvent used at the press, as mentioned in Chapter 3.  Recovered
waste solvent from cleaning operations and any waste inks are sent out
of the plant to be reclaimed.  The adsorber outlet vapor losses depend
on the capture-air flow rate and the adsorber efficiency, which is
discussed in a later section.  A waste water stream containing dissolved
solvent results from the condensation of steam which is used to regenerate
the carbon beds.  Test data presented in Appendix C show that dissolved
solvent discharged with the condensate represents less than 0.1 percent
of the total solvent used at the press.  The recovered liquid solvent
from the captured vapors is metered and recycled for use as solvent
addition.  Any excess recovered solvent can be sold as a by-product.
     Most new rotogravure printing plants install liquid volume meters
to measure the amounts of inks, extenders/varnishes, and solvent input
to each printing unit of the press.  A meter also measures the volume
amount of recovered solvent.  These meters are installed for process
control  and customer billing purposes.  Moreover, they provide a basis
for measurement of the overall solvent loss.  The liquid meters currently
installed in this industry operate by several variations of the positive
displacement type principle.  Manufacturer's data on some of the liquid
meters used for the inks, extenders and varnishes provide accuracies
                                          1 ?
ranging from ±1.0 percent to ±1.5 percent. '   The data on meters used
for solvent addition at the press and recovered solvent show accuracies
ranging from ±0.2 percent to ±1.0 percent.0' ''   The manufacturers
recommended that the meters be recalibrated at least every six months.
                                     4-2

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                               Liquid Solvent in
                              Inks, Varnishes
                                 & Extenders
 i
Co
                                Liquid Solvent
                                  Added For
                               Printing/Cleaning
                                                                   Recovered
                                                                    Solvent
                                                                     Sales
                                                                                                         Reclaimed
                                                                                                         Reclaimed
                                                                                                         Outlet
                                                                                                        Vapor Losses
Condensate
Solvent Losses
                                                                                                  Liquid meters
                         FIGURE 4-1.   Solvent  flow  around a publication  rotogravure printing  press
                                             with carbon adsorption/solvent recovery.

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4.1.2  Performance Data
     The performance of existing VOC emission control  systems in this
industry was demonstrated during short-term tests at facilities in two
plant sites:  Meredith/Burda, Inc. (Phase III facilities) and Texas
Color Printers, Inc.  The performance data were obtained during only a
few days of testing at each facility.  Three separate methods were
employed to determine the operating performance of the emission control
systems at both tested facilities.  Two of the methods involved vapor
phase analyses combined with air flow measurements.  These two methods
                                                    8 9
are discussed in the test reports and in Appendix C. '   The third
method involved an overall liquid solvent volume material balance utilizing
the liquid meters, combined with the ink manufacturer's data on the VOC
volume content of the  inks and extenders/varnishes used.  A comparison
of the results of the  three test methods is presented in Appendix C.
The results showed that the liquid solvent volume balance is the most
accurate, reliable, and convenient method for determination of overall
VOC emission reduction.  Thus, the solvent volume balance method was
used to report and compare the performance results of the two formal
tests.
     Long-term plant data were obtained  in addition to  the short-term
test data.  Discussions  in Chapter  3 concerning  the variability of  the
rotogravure printing process and  the wide range  of  products  handled
suggest that short-term  test data may  not be  adequate to  project  long-
term emission  control  performance  in this  industry.   Consequently,
several months  (and  four-week periods)  of  plant  data  showing  the  long-
term performance  of  VOC  emission  control  systems were obtained  from both
tested  facilities,  as  well as several  non-tested facilities.   The long-
term data  were obtained  by plant  personnel  using an  overall  liquid
solvent balance method on  a  volume  basis,  except at Standard Gravure,
 Inc. where a weight-based  solvent balance  is employed.
     The  typically controlled facilities,  which  capture only the  dryer
exhausts,  achieve overall  VOC control  efficiencies ranging  from 75 to
about  84  percent.  VOC emissions  from  existing,  older presses are controlled
                                      4-4

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at only the efficiency levels in the lower end of this range to recover
enough solvent for re-use at the presses.  However, newer presses controlled
by modern adsorber systems can achieve the higher control levels at the
upper end of the range.  Overall emission reductions of 80 to 84 percent
were determined from short-term tests conducted at the Texas Color
Printers plant.  '    In addition, five months of plant data obtained
from Texas Color showed an average overall control efficiency of about
           12
81 percent.    Also, over four months of plant data from World Color
Press showed 4-week average overall control efficiencies ranging from 78
to 84 percent.    A summary of these data is presented in Appendix C.
     The best controlled facilities capture some of the fugitive solvent
vapors, as well as the dryer exhausts.  Reported long-term plant data
from a few non-tested facilities show overall VOC reduction efficiencies
ranging from 82 to about 90 percent.  Triangle Publications reported
plant data ranging from 82 to 87 percent overall control.    Several
other plants reported VOC emission control in the 87 to 90 percent
range.  '  '    However, the most reliable performance data for the best
demonstrated VOC emission control systems were obtained for facilities
at the Meredith/Burda (Phase III), Standard Gravure, and Texas Color
plants.  Table 4-1 presents a performance data summary for these three
controlled facilities showing overall reduction efficiencies ranging
from 84 to 93 percent.
     The first data source presented in Table 4-1 is the Meredith/Burda
plant.  Toluene is the solvent used at these facilities.  Apparent
overall control efficiencies of greater than 90 percent were demonstrated
                                                           1 Q
in short-term tests at the newest facilities in this plant.    In addition,
data were obtained from this plant for ten separate months, indicating
                                                                    1 n pQ pi
apparent overall control efficiencies greater than about 89 percent.  ''
     Several representatives of this industry have asserted that 90 percent
overall control is not achievable.  Their comments pointed out several
"unique features" and possible problems with the newest Meredith/Burda
           O O O O O A
facilities.  '  '    Supplemental sampling was conducted at that plant
                                                           pr
to acquire more data regarding some of industry's comments.    The
                                     4-5

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TABLE 4-1.  DATA BASE SUMMARY OF BEST DEMONSTRATED OVERALL VOC EMISSION
            CONTROL SYSTEM PERFORMANCE IN THE PUBLICATION ROTOGRAVURE
            PRINTING INDUSTRY.
Data Source (year)
Meredith/Burda (Phase III):
- Short-term EPA tests
(1978)
- Long-term plant data
(1979-1980)
Standard Gravure:
- Long-term plant data
(1979-1980)
- 1975 Technical paper
(1973-1974)
Texas Color:
- Calculated potential
from short-term EPA
tests (1979)
- Calculated potential
with combined long-term
plant data (1979)
Performance
Averaging
Periods
26-51*5 hours
10 individual
months
15 four-week
periods
1 04 week
periods
13%-82 hours
one 5 month
period
Overall Solvent Recovery
Efficiency, %
Apparent
Average
94-97
89-96
85-90
90
90-93
88-90
Adjusted
Average
89-92
84-91
35 percent total  efficiency  adjustment  for  Meredith/Burda  data:   2  percent
 temperature correction  factor for  recovered  solvent;  3  percent  factor for
 infiltration of  solvent vapors.  No  adjustment  required for  data from
 other sources.

Reference 29.
                                    4-6

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results of the supplemental measurements are summarized in Appendix C.
Consideration of industry comments and a thorough evaluation of the
Meredith/Burda test results and supplemental measurement results show
that the apparent overall control  efficiencies should be adjusted downward
by about five percent to compensate for two characteristics.
    • A two percent factor is required for the density variation caused
     by the differences in temperature between the recovered toluene
     solvent and the raw inks and toluene used at the presses.  To
     obtain a true overall solvent material balance, the direct volumetric
     reading of the recovered solvent meter must be corrected to compensate
     for the density difference  (see Appendix C).26'27'28'29'30'31.32,33,34
    •A three percent factor is required for infiltration of solvent
                                               or
     vapors from other pressrooms in the plant.
     In addition, industry representatives mentioned that some other
plants in this industry could not consistently achieve even the adjusted
overall control levels demonstrated at Meredith/Burda.  The following
three reasons were cited for the expected lower overall control performance.
    • The highly effective solvent vapor capture system design employed
     at Meredith/Burda may not be usable by some facilities because of
     potential OSHA worker exposure violations (See section 4.2.1).
    •Some printed products retain more solvent than others — the more
     solvent retained, the less vapor that can be captured and recovered.
    • Meredith/Burda handles special long run products, while most other
     plants print shorter run products—the shorter run products cause
     more frequent web breaks and press shutdowns during printing, as
     well as more press down-time between job runs—the capture efficiency
     may be lower with the resulting more dilute solvent laden air
     decreasing the adsorber efficiency when handling the shorter run
     products.
     The second data source is the Standard Gravure plant.  Naphtha-
based mixed solvents are used at these facilities.  This plant is regarded
as having the most thorough capture system; however, the system requires
handling and treatment of much larger amounts of solvent laden air (SLA)
                                     4-7

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than the capture system at Meredith/Burda.  Tests were not conducted at
this plant site because the capture system did not appear to be as
economical as the one at Meredith/Burda.  Long-term, four-week average
overall control efficiencies reported by Standard Gravure range from 85
              oc 07
to 90 percent.  '    In addition, a longer-term study conducted at these
facilities after the initial installation showed a 90 percent average
                                        38
overall control level on a weekly basis.    No adjustment to these
reported plant data are necessary.
     The third data source is the Texas Color plant.  Naphtha-based
mixed solvents are also used at these facilities.  As previously mentioned,
only dryer exhausts are captured at these tested facilities.  During the
short-term tests, gas phase monitoring results showed that the pressroom
ventilation SLA discharged to the atmosphere accounted for about eight percent
of the total  solvent volume used at the presses.  Calculations show that
overall solvent recovery efficiencies exceeding 90 percent could potentially
be achieved if the pressroom ventilation air were directed to the control
device rather than to the atmosphere.  However, combination of the
short-term test data with five months of plant data indicated potential
overall solvent recovery efficiencies of only about 88 to 90 percent.
The lowest calculated potential efficiency, in each case, was based on a
one percent decrease in adsorber efficiency which would result from the
30 percent increase in the captured SLA flowrate.  The highest calculated
potential efficiencies would correspond to increased adsorber efficiencies
from modification and better instrument controls comparable with those
at Meredith/Burda.  These potential cases are tabulated in Appendix C.
     In conclusion, the performance of the best demonstrated emission
control systems in the publication rotogravure printing industry are
influenced by many factors which cause a wide range of overall efficiency
results.  It appears that 90 percent overall control is achievable under
some conditions, but not on a long-term basis.  The highest achievable
long-term average overall VOC control efficiency is about 85 percent;
although, the  performance may drop to about the 84 percent level during
one or two months throughout a year of operation.  These lowest achievable
                                     4-8

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efficiencies account for periods of low solvent usage, solvent retention
in the product, and printing of products that cause frequent production
delays.  These three factors are discussed in more detail in the following
sections.
4.2  SOLVENT VAPOR CAPTURE SYSTEMS
4.2.1  System Descriptions
     Existing solvent vapor capture system designs vary considerably.
Most plants capture only the dryer exhausts.  In addition, a few facilities
have floor sweeps or pressroom vents near each press to capture some of
the fugitive solvent vapors.  However, the most effective system designs
attempt to capture all of the solvent laden air (SLA) that leaves the
pressroom.
     The capture efficiency of the dryers is limited by their temperature
and the operating speed of the newer presses.  Dryer temperatures range
from ambient to about 120°C (250°F), as discussed in Chapter 3.  The
higher temperatures in this range can only be used on the units printing
with black ink.  Higher temperatures impair product quality and increase
the frequency of web breaks.  The increasing operating press speeds of
modern presses of over 10 m/s (2,000 fpm) limit the web's residence time
in the dryers.  Thus, significant amounts of fugitive solvent vapors are
emitted from the presses because of the limited dryer capture efficiency.
     The dryer exhaust SLA vapor concentration level greatly influences
the required size of the adsorber system.  Modern high velocity dryers
are usually equipped with integral  drying air recirculation fans to
concentrate the dryer exhaust and minimize the amount of SLA.  Vapor
analyzer control  systems can be installed on the printing unit dryers to
safely increase the exhaust solvent vapor concentrations.  The lower
explosive limit (LEL) for rotogravure solvent vapors range from about
9,000 to 12,700 ppmv.  Thus, the dryer exhaust vapor concentration level
would have to be lower with some solvents than others.  Insurance require-
ments limit the normal maximum allowable vapor concentration to about 50
percent of the LEL.  Thus, the maximum operating vapor concentration
could probably be as high as 30-40 percent of the LEL, or 2,700 to 4,800
                                    4-9

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ppm (V/V).  From short-term test data,  the Meredith/Burda dryer exhaust
levels were calculated to be about 2,300 ppmv toluene vapors.   This
represents a level  of almost 19 percent of the toluene LEL;  equivalent
concentrations with vapors from naptha  based  solvents would  represent
about 26 percent of the LEL.
     Facilities that capture only the dryer exhausts must install  some
type of pressroom ventilation fans that discharge to the atmosphere.
These fans are necessary to remove the  fugitive solvent vapors from the
press-room.  The solvent vapor concentration  in the pressroom air must
be kept below the level of OSHA regulations.   The present OSHA time-
weighted average (TWA), 8-hour exposure limit for toluene vapors is 200
ppmv. The allowable vapor concentration limits for the components of the
naphtha based mixed solvents range from 100 ppmv up to 500 ppmv as shown
in Chapter 7.  OSHA has a proration formula for determining  compliance
with vapor component mixtures.
     A highly efficient capture system is necessary to achieve high
overall emission reduction efficiencies.  Fugitive solvent vapors, as
well as the concentrated dryer exhausts must be captured.  Some of the
fugitive solvent vapors result from evaporated solvent in the ink fountains,
from the exposed part of the gravure printing cylinder, and exposed
portions of the paper web before entering the dryers.  Enclosed ink
fountains and extended enclosed dryer designs of newer presses help to-
minimize the escape of fugitive vapors from these locations during press
operation.  However, these areas must be uncovered to obtain access to
the  press during shutdowns for web breaks, cylinder changes, or maintenance
items.  The major source of fugitive vapors from newer presses during
operation is the paper web after exiting the dryers.  Fugitive vapors
are  emitted from this  source even during press shutdowns.   In addition,
as discussed in Chapter 3, the final printed product  retains about one
to seven  percent of the solvent used at the press, and continues  to be a
source of fugitive vapors  from the cutting and folding areas after
leaving the  press.
                                     4-10

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      Three  types  of capture  systems were  evaluated.   The  first  type,
 demonstrated  at the facilities  of  Texas Color  Printers, Inc., captures
 only  dryer  exhaust vapors, while pressroom  ventilation air  is discharged
 to  the atmosphere.  Naphtha-based  mixed solvents are  used at these
 tested facilities.  Test data for  this capture  system show  that about
 900 to 1,000  SCFM of ventilation air are  required for each  printing
 unit; while the dryer exhaust for  each printing unit  accounts for about
                           oq
 2,300 to 2,400 SCFM of air.     The amount of ventilation  air thus required
 to  remove fugitive vapors represents about  30 percent of  the total
 amount of air removed from the  pressroom.
      A second type capture system  was demonstrated at the newest facilities
 of  Meredith/Burda, Inc.40'41  Toluene is  the solvent  used at these
 tested facilities.  Fugitive vapor cabin  enclosures are installed over
 the top portion of the printing presses.  A schematic of  such an enclosure,
 installed over the top portion  of  an eight-unit printing  press, is
 presented in  Figure 4-2.  Fume  pickup nozzles located on  the bottom of
 the cabin draw in enough air to keep the  pressroom at a slightly negative
 pressure.  Since  the air surrounding the  press has a  higher solvent
 vapor content that the average  pressroom air, minimal air makeup is
 required to satisfy OSHA regulations.   This is because the solvent
 vapors surrounding the press units are drawn into the cabin before they
 can propagate throughout the pressroom.   In addition, fugitive vapors
 from evaporated solvent leaving the paper web between printing units are
 also captured.  The captured fugitive  solvent vapors are then pulled out
 of the cabin  through  multiple vents,  directed along with the dryer
 exhausts from each printing unit,  and  sent to a carbon adsorption system.
 One or more large SLA fans provide the motive force for pulling the air
 through the cabin enclosures and printing unit dryers.  Pressroom ventilation
 fans are not  installed  at these facilities.   Wall  or ceiling vents could
 be added to increase  the capture efficiency of fugitive vapors,  if more
stringent OSHA regulations become  necessary.  Test  data from the Meredith/Burda
facilities  show that  approximately 900 SCFM of air  per printing  unit are
pulled through the cabin enclosures.42  This fugitive VOC  capture air
                                   4-11

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                                                                                SLA* to  Adsorber
                                                                                   System
       SLA*  Capture
       Vents  (typical)
Dryer Exhaust
  (typical)
                                             Fugitive Solvent
                                                  Vapors
Paper Web
                    Press Unit (typical)
                                                                          *SLA - Solvent Laden Air
                                            I

           Figure 4-2.  Cabin enclosure system for fugitive solvent vapor capture around a typical
                        eight-unit publication rotogravure printing press.

-------
flow represented about 30 percent of the total  air handled by the control
device system.
     On a theoretical  basis, a fugitive vapor cabin enclosure design
should not pose any risk of excessive worker exposure to solvent vapors
which would constitute an OSHA violation.  Solvent (toluene) vapor
concentrations were measured inside the Meredith/Burda cabin enclosures
during the short-term tests and again during supplemental  sampling
tests.  During printing operations, the measured toluene vapor concentrations
ranged from about 300 ppm to over 1,000 ppmv.  '    However, the cabin
enclosure is not a normal work area during printing operations.  Operators
enter the cabins only during press shutdowns.  When a press shutdown
occurs (e.g., for a web break) the generation rate of solvent vapors
greatly decreases, but pressroom air is still pulled through the cabin
enclosures.  Therefore, if enough purge time is allowed, the cabin
enclosure environment should reach equilibrium with the pressroom ambient
solvent vapor concentration.  Adequate purge time is determined by the
volumetric air purge rate and the ambient solvent vapor concentration in
the pressroom air.  Theoretical calculations, presented in Appendix C,
using measured volumetric air purge rates show that an initial  1,000 ppmv
cabin enclosure toluene vapor concentration should be decreased to below
the OSHA 8-hour TWA limit in about one to one and one-half minutes after
press shutdown, assuming respective ambient pressroom vapor concentrations
of 50 to 150 ppmv.  It should be noted that the measured air purge rates
during the Meredith/Burda tests were only at about 70 percent of the
17,000 Nm3/hr (10,000 SCFM) design air flow rate.  The required purge
time to meet the OSHA 8-hour TWA toluene limit would be reduced by about
30 percent at the design air purge rate.  Therefore, for well designed
cabin enclosures and normal ambient pressroom solvent vapor concentrations,
about one minute of purging should be required before operators could
safely enter the enclosure.
     Direct application of the demonstrated Meredith/Burda cabin enclosure
design may, however, present difficulties in meeting some  OSHA regulations.
Toluene vapor concentrations inside the enclosures were measured to be
                                   4-13

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as high as 200 to over 300 ppmv, during press shutdowns.   '     These
vapor concentration levels are within the ceiling limits  of OSHA regulations;
however, repeated exposure to these high concentrations,  combined with
pressroom ambient vapor concentration levels may cause some press operators
to be exposed in excess of the 8-hour TWA limit.  One major reason for
the high shutdown vapor concentrations is that the newest pressroom
ambient vapor concentrations were measured at about 100 to over 200 ppmv.
In comparison, ambient toluene vapor concentrations were  measured to be
only 20-60 ppmv in other pressrooms and plant areas with  ventilation
                                   40
fans discharging to the atmosphere.    A second major reason for the
high shutdown vapor concentrations is the maldistribution of air flow
through the cabins.  In addition, Meredith/Burda handles  larger volume
print orders than some other printers in this industry.  Some of the
shorter-run products not handled by Meredith/Burda may cause more frequent
web breaks and press shutdowns.  The printing of these more troublesome
products could require the press operators to enter a cabin enclosure
more often than required at Meredith/Burda, thereby increasing their
potential  for exposure to solvent vapors.  Press operating data supporting
this reasoning, as discussed in Chapter 3, were obtained  during the two
plant tests and general information provided by industry  on typical
operations.  Therefore, a cabin enclosure design may not  be a suitable
fugitive vapor capture system for some facilites.
     Analysis of the Meredith/Burda capture system and pressroom design
shows that some design improvements could be incorporated to facilitate
compliance with OSHA regulations.  First of all, the pressroom ambient
solvent vapor concentration level could be substantially  decreased
                                                          49
through modification of the pressroom air handling system.    The SLA
exhaust from the air handling system for the product cutting/folding
areas could be redirected to the carbon adsorption system instead of
being circulated through the pressroom.  Infiltration of  solvent vapors
to the newest pressroom from other areas of the printing  plant could be
minimized by keeping the pressroom doors closed when possible and by
decreasing the ambient solvent vapor concentration in the adjacent
                                     4-14

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hallways and rooms through better ventilation.  Secondly, at the time of
a press shutdown, the solvent vapor concentration inside the cabin
enclosure could be decreased faster and more uniformly through modification
of several of the cabin design features.    An individual cabin provides
an enclosure for the printing press units in common with the product
cutting/folding area.  Propagation of fugitive solvent vapors from the
printing press units to the cutting/folding air handling system could be
eliminated through installation of a separating wall inside the cabin
enclosure.  The solvent vapor concentration profile and stagnant vapor
zones inside the enclosure could be minimized or eliminated by correcting
the maldistribution of air flow through the cabin.  The ends and room
side of the cabin are totally closed, while the wall side is essentially
open on each enclosure.  Completion of the enclosure on the wall side
and installation of more floor inlet nozzles would redirect entering air
through the cabin floor and should help to correct the maldistribution
problem.  Finally, an increase in the air flow rate through the cabin,
from the measured 11,900 nm3/hr (7,000 SCFM) to the design 17,000 nm3/hr
(10,000 SCFM), would help minimize the time required to decrease the
cabin solvent vapor concentration level to below the OSHA standard
limit, at the time of a press shutdown.  Theoretical calculations presented
in Appendix C show that the increased air flow rate would cause a decrease
of less than 0.5 percent in the carbon adsorber efficiency.
     A third type system which captures all the pressroom air was demon-
strated at the Standard Gravure plant.  This system is similar to what
the potential  Texas Color capture system would be with the fugitive
ventilation air directed to the control device.  In addition, ventila-
tion air from the cutting, folding, and product storage areas are captured
at this plant and sent to a carbon adsorption system.   Tests were not
conducted at this plant because the amount of capture  air required with
this design was much greater than for the Meredith/Burda or the Texas
Color potential  capture system designs.
     The Triangle Publications plant also attempted to capture all the
              51  52
pressroom air.  '    However, this plant ceased operations in July 1978;
detailed data on the capture system was not obtained.
                                   4-15

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4.2.2  Capture Efficiencies
     The actual  capture efficiency is difficult to measure.  There are
several  routes through which solvent can leave the presses, as previously
described.  The adsorber efficiencies can be determined by analyzing the
vapor concentrations of both the inlet and outlet SLA streams of the
adsorber bed during the adsorption cycle.  The overall emission reduction
efficiency is equal to the capture efficiency times the adsorber efficiency.
Therefore, the average operating capture efficiency can be calculated by
dividing the overall control efficiency by the measured average adsorber
efficr'e'rcy.
     DoTionstrated capture efficiencies were calculated using test data
from two plants.  The results of these calculations are presented in
Appendix C.  The newest Meredith/Burda facilities with the fugitive
vapor cabin enclosure system captures 94 to 97 percent of the total
solvent volume used at the presses.  Solvent retained in the printed
product and uncaptured fugitive vapors account for the remaining 3 to 6
percent.  The Texas Color Printers facilities achieved capture efficiencies
of about 85 to 89  percent by capturing only the dryer exhausts.
     Additional calculations presented in Appendix C show that the Texas
Color capture efficiency could be potentially increased by directing
their fugitive ventilation vents to the adsorption system rather than to
the atmosphere.  Solvent vapor analyses of the fugitive emissions discharged
from the Texas Color pressroom showed that the ventilation system captured
about eight percent of the total solvent volume used at the  presses.
Calculations adding these fugitive vapors to the dryer exhausts show
potential capture  efficiencies of 93 to 97 percent.  The remaining three
to seven  percent represents solvent retained in the printed  product.
4.2.3  Best Capture Systems
     There  is some  uncertainty as to what is the best demonstrated
capture system.  The Meredith/Burda cabin enclosures probably  represent
the most  effective  vapor capture system, requiring the least amount  of
SLA handling to capture essentially all fugitive vapors from the  presses.
However,  this type  enclosure may require some modifications  to  improve
                                    4-16

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the air flow patterns within the enclosure and reduce vapor concentrations
below OSHA limitations.  The inks and solvent used at Meredith/Burda
contain a single toluene component.  Other plants, including Texas Color
and Standard Gravure, use the naphtha-based mixed solvent.  The mixed
solvent contains components which are more volatile than toluene.  There
could be a tendency for larger amounts of fugitive vapors with the mixed
solvent.  However, a well designed capture system should be just as
efficient with either solvent.  This was demonstrated when the capture
efficiencies at Texas Color were calculated to be potentially just as
high as at Meredith/ Burda.  In addition, the use of naptha-based mixed
solvents would pose fewer problems in complying with OSHA regulations
since the standards for some of the solvent components allow higher
vapor concentrations in the air (see Chapter 7).  Therefore, the highest
capture efficiencies should be achievable by employing partial enclosure
systems with the use of either type solvent.  On the other hand, printing
of some products handled by this industry might cause more press down
time than other products, and thus a cabin enclosure design may not be a
suitable capture system for some facilities.
     Other capture designs may gather a high percentage of the fugitive
vapors, but larger amounts of SLA would be handled, lowering the cost
and energy effectiveness.  All of the pressroom air could be captured
along with the dryer exhausts and SLA from the cutting, folding, and
product storage areas,  such as practiced at the Standard Gravure plant.
     The amount of air required to capture the fugitive vapors depends
upon the design and installed placement of the capture system.  Less
amounts of air may be required to be captured with designs installed
close enough to the press areas to pick up the highest concentrations of
solvent laden air.  An  enclosed pressroom with multiple fugitive vapor
pickup vents, located as close as practical  and perhaps with "swing
away" features for maintenance, combined with regulated floor sweep
vents may be a very efficient capture system alternative.  However, the
ultimate efficiency of any capture system is limited by the amount of
solvent retained in tho printed product.
                                    4-17

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     The variations in press widths,  press operating speeds,  and number
of printing units per press can significantly affect the amount of air
handled by the capture system.   Operating conditions such as  a narrow
web being printed on a wide press, decreased ink coverage, and technological
advancements allowing press speeds of over 10.2 m/s (2,000 fpm) could
cause decreased capture efficiency and excessive dryer exhaust SLA
dilution.  These effects were shown during the two plant tests while
printing both narrow and full width webs with several different products
and ink coverages.
     Excess air dilution could be minimized by designing flexibility
into the solvent vapor capture system.  A VCC vapor monitor could be
installed  in the dryer exhausts streams to control the amount of  internal
air recirculation; this would maximize the VOC vapor concentration in
the SLA stream treated by  the control device.  Adjustable width openings
for the dryer  inlets  and outlets  could be designed to help minimize  the
amount  of  dilution air drawn into  the dryer.  These  adjustments could  be
made when  the  printing cylinders  are changed  between job  runs.  More
thorough dryer designs will  need  to  be utilized to handle the  higher
press  speeds.   In  addition,  fugitive vapor  capture-air  systems  incorporating
valve-diverting  or turndown  mechanisms could  be installed for  periods  of
low  production and press shutdowns.
      In  summary,  the  facilities  at both  tested  plant sites demonstrated
that  at least  a  90 percent average capture  efficiency can be  expected
when  fugitive  solvent vapors are  captured along with the dryer exhausts
from  new  presses.   This  conservative average  efficiency allows  for
printing  of products  that  retain  larger  amounts of solvent or that cause
more fluctuations in  the printing operations  than were  experienced
during the two short-term  plant tests.   If  only dryer  exhausts are
directed  to the  control  device,  then the average  capture efficiency can
 be expected to be only about 85 percent, as demonstrated during tests at
 Texas Color.  Older facilities handling  only the  dryer exhausts can be
 expected to achieve an average capture efficiency of about  84 percent.
 This lowest capture efficiency reflects  an  estimate of slightly more
                                     4-18

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 fugitive  solvent vapor losses  from  the more exposed areas of older press
 designs.
 4.3   FIXED-BED  CARBON ADSORPTION/SOLVENT  RECOVERY
 4.3.1  General  Description
      Fixed-bed  carbon adsorption  is currently the most widely used
 method for the  control of solvent vapor emissions in this industry.
 These systems involve the use  of at least two adsorption vessels.  At
 any one time, adsorption is occurring in one bed while desorption or
 regeneration is occurring in another.
      The  adsorption process is a physical phenomenon that involves the
 removal of solvent vapor from  an air stream.  The solvent vapor is
 concentrated on the surface area of the pores of activated carbon.  The
 adsorbent used  in this instance is a bed of small carbon pellets.
 Activated carbon is a highly porous solid employing Van der Waals'
 forces to adhere the solvent molecules to the pore surface.
      When a solvent vapor mixture is being adsorbed, the solvent vapor
 molecules of lower molecular weights are gradually displaced by the
 heavier, less volatile molecules.  As the adsorption process continues,
 the carbon becomes saturated with the lower molecular weight components,
 and starts desorbing them.  In time, the carbon will become saturated
 with  all the solvent components, and the adsorber outlet vapor concentra-
 tions will be the same as the  inlet.
      Initially, the adsorption process is rapid and complete.  During
 the course of the adsorption cycle, the outlet solvent vapor concentra-
 tion  remains relatively constant until breakthrough occurs.   Once this
 significant saturation has occurred, the outlet solvent vapor concentra-
 tion  rapidly increases.   The percentage of the inlet solvent concentration
measured at the outlet is defined as the percent breakthrough.   Before
an unacceptable level  of breakthrough is reached, the air flow is trans-
ferred to a freshly regenerated bed, and the saturated  bed  is regenerated.
     Regeneration is usually accomplished by backflushing the carbon  bed
with low-pressure steam.   This operation is  generally called the stripping
cycle.  The steam heats  the bed and provides the heat of desorption of
                                    4-19

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the solvent.  The steam also functions as a diluent,  lowering the partial
pressure of the solvent.  The solvent is then recovered by condensing
the solvent-laden steam, and separating the liquid  mixture by decanting.
Figures 4-3 and 4-4 illustrate a typical carbon adsorption solvent
recovery process in the adsorption and desorption modes.
4.3.2  Equipment Design
     The captured solvent laden air (SLA) is drawn  from the printing
presses and through a filter by several fans.  A cooler is also installed
in some designs.  The purpose of the cooler is discussed  later.  There
is usually one operating filter with at least one spare.   The filters
usually consist of a single, thin fiberglass curtain  extended the full
width from the ceiling to the floor inside a large housing.  The housing
is sized to greatly reduce the air velocity and allow the heavier entrained
dirt and paper dust particles to settle out.  The smaller particles are
caught by the filter curtain.  The pressure drop across the filter must
be monitored.  The SLA is switched to the spare filter at a preset
value, or when the pressure drop begins to affect the operating capacity
of the fans. The large fans are normally of centrifugal design with at
least one spare. The design of the fans and their operating costs are
directly influenced by the pressure drop across the filters and the
carbon adsorption beds.  The resulting  pre-conditioned air is then
directed to the adsorption vessels.
     The operating differential pressure of typical centrifugal fans is
"limited to about a maximum 500 mm  (20 inches) of water pressure.  Other
SLA moving devices, such as blowers and compressors,  could be used to
achieve higher pressures, but the  capital costs of these more complex
air-movers are much higher compared to  centrifugal fans.  The discharge
pressure of most fans  in existing  carbon adsorption systems ranges from
about 150 to 250 mm (6-10 inches)  of water  pressure.
     A fixed-bed carbon adsorption system requires at  least two adsorption
vessels.  Most small plants have at least three, while some larger
plants have ten or more vessels.   In  some cases, the fixed carbon beds
are cone or dome shaped to allow more  surface area for gas contact at
                                    4-20

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               SOLVENT LADEN
-fa
 I
PO
                    COOLER
                    FILTER
                                                                                                TREATED AIR TO ATMOSPHERE
                                   '       ACTIVATED
                                          CARBON \
                                                                                               & COOLER   DECANTER
                             FAN
                                                         (X] °Pen
                                                                              closed
                               Figure  4-3.  Flow diagram of  typical  solvent  recovery process
                                             (Adsorber  1  regenerating).

-------
             SOLVENT LADEN
I
ro
ro
             AIR IN
               STEAM
              "IN"
                 COOLER-
                 FILTER
                           FAN
                                                                                                TREATED AIR TO  ATMOSPHERE
                                     NON-CONDENSABLE
                                                                       GAS RECYCLE
rtXP
I
J
                                          ADSORBER

                                            1
                                                          !X|  open
                                                                             ACTIVATED
                                                                              CARBON
ADSORBER

   2
            closed
                                                                                                                   WASTE

                                                                                                                   WATER
                           CONDENSER
                           &  COOLER   DECANTER
                                   Figure  4-4.  Flow diagram  of typical  solvent recovery  process
                                                  (Adsorber 2 regenerating).

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higher gas flow rates.   The conventional  carbon adsorption vessel  is
limited to a gas flow rate of about 65,000 m3/hr (38,000 CFM).   This
accounts for the large  number of adsorption vessels required in some of
the larger printing plants.  A vertical  multi-bed adsorption vessel
employing the same principles as the once-through flat bed design,
previously described, makes more efficient use of limited space.   In
this design, the carbon beds are situated above one another and the  air
flow is directed through an annular header so that adsorption takes
place simultaneously among all the beds  in the vessel.  '    This  design
permits at least twice  the solvent laden air (SLA) capacity per vessel
than conventional  vessels allow, without sacrificing any efficiency.
     The total  operating cycle for carbon adsorption systems is comprised
of several steps.   The  adsorption step time typically ranges from  1  to  8
hours.  The duration of the adsorption step is sometimes regulated only
by a timer.  However, optimum performance can be obtained by installing
a gas analyzer to  monitor the adsorber outlet, with a timer as  backup.
The gas analyzer initiates regeneration  when the outlet solvent vapor
concentration reaches a preset value.  Such instrumentation control  then
allows the actual  pressroom activity to  determine the time span of the
adsorption cycle.   The  regeneration steps begin with desorption, or
steam stripping.  This  step is usually controlled by a timer.  Times
range from 0.5 to  2 hours, depending on  boiler capacity and maximum
design steam velocities through the carbon bed.  Finally, 15 to 20
minute long drying or cooling step is usually included to minimize
premature breakthrough  once the bed is returned to the adsorption  step.
     The adsorption system efficiency depends upon the correct, appropriate
sizing of the carbon bed.  The following information is needed  to  properly
size a system:
    • Solvent laden air  (SLA) flow rate,
    •Maximum inlet vapor concentration,
    •Maximum desired outlet vapor concentration, or desired efficiency,
    • Allowable pressure drop,
                                    4-23

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    • Operating conditions,  such  as  temperature,  pressure,  and  humidity,
    • Chemical  nature and physical  properties  of  all  vapor  components,
    •Steam to  solvent ratio,
    • Space limitations,
    • Available utilities, and
    • Desired instrumentation  controls.
     The type  and size of the carbon packing  affects the overall  bed
size. Activated carbon is a product of organic matter (e.g.  peat, wood,
brown coal, coconut shells),  which  is produced in numerous special
grades.  The typical granular carbon particles range in size from 1  to
5 mm, or 4 to  10 mesh equivalent.   The bulk packing  density  ranges in
size from 380  to 480 Kg/m3 (24-30 lb/ft3).55'56   The selected  carbon
grade must have suitable affinity for the solvent vapor components.   A
summary of approximate adsorption capacities  for selected  rotogravure
solvent components is shown in Table 4-2.
        TABLE 4-2.  APPROXIMATE CARBON ADSORPTION CAPACITY FOR   ,-7
    VARIOUS SOLVENTS, KG SOLVENT/KG CARBON (LB SOLVENT/LB CARBON)0'
          Heptane                            0.06
          Hexane                             0.06
          Toluene                            0.07
          VM&P Naphtha                       0.07
          Xylene                             0.10
     The capacity of the carbon to adsorb solvent vapors is also a
function of the pressure and temperature.  The adsorption capacity of
carbon increases significantly as temperature decreases.  Gas coolers
are frequently used to keep the solvent laden air at or below 41°C
(105°F) to insure good adsorption efficiency.  The operating pressure
                                    4-24

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has only a small influence on the efficiency, providing that the pressure
is near atmospheric.
     The capacity of the selected carbon and the design cycle time serve
as the basis for sizing the bed.  The total  amount of carbon needed is
then determined by the SLA flow rate, inlet vapor concentration, and
desired efficiency.  An efficient and economical adsorption system
requires a stable gas velocity with a uniform solvent vapor concentration.
The gas velocity determines the residence time of the solvent vapor in
the bed. Typical design superficial velocities range from 21-30 m/min
(70-100 ft/min).  The SLA inlet hydrocarbon vapor concentrations from
                                                      o
publication rotogravure presses range from 1 to 10 g/m  (300-2600 ppm
V/V).  '  '    Many existing adsorption systems were originally designed
for only 90 to 95 percent "bed efficiency".  However, newer systems can
be designed for 97 to almost 99 percent efficiency.
     The highest adsorber efficiencies can be designed with the highest
inlet SLA vapor concentrations.  The press unit dryer exhausts can be
recycled to increase the solvent vapor concentrations.  When dryer
exhaust recycling is used, however, the vapor concentration must be
regulated to insure operation sufficiently below the lower explosive
limit (LEL).  Gas analyzers can be installed for maximizing the dryer
exhaust vapor concentration to the allowable safe level (see section
3.2).
     The design thickness of the carbon bed  is a function of the allowable
pressure drop, as well as the inlet vapor concentration.  The pressure
drop across the adsorber is directly proportional to the SLA flow rate
and the thickness of the carbon bed.  The packing density also affects
pressure drop.  A gross oversizing of the carbon bed thickness would
create an excessively high pressure drop.  The resulting pressure drop
directly affects the power consumption and the electrical  costs for
operating the SLA fans. A design compromise  is usually reached between
thick beds for higher efficiency, and thin beds for lower electrical
operating costs.  Frequently, the bed thickness is determined by considering
the maximum inlet vapor concentration excursion expected.   Operating
                                   4-25

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costs will be higher for a more efficient adsorber,  which is designed to
handle the cases where peak vapor concentrations are considerably
higher than average values.  Most of the adsorption  vessels presently
installed in this industry contain beds of activated carbon from 0.5 to
1.2 meters (20-50 inches) thick.61'62  A combination of this bed thickness
range with the 500 mm (20 inches) of water maximum pressure available
with centrifugal fans shows that the pressure drop across the carbon bed
must be less than 400 to 1,000 mm of water per meter (5-12 inches of
H 0/ft) of bed depth.  The appropriate carbon particle size must be
selected  based on the design superficial air velocity through the bed to
limit the pressure drop  to below the allowable level.  A wide range  of
granular  activated carbons is commercially available to  satisfy these
                         *  63
pressure  drop  requirements.
      Regeneration expenses, which are  essentially the steam costs, are
also  affected  by the  solvent vapor  content of the exhaust  gas.  When a
carbon  bed  is  regenerated, approximately one-third  of the  total steam
consumption  is used  to  heat  the  bed  up to  regeneration temperature.
This  initial  steam  flow does only a  small  fraction  of the  total  stripping.
A system which requires frequent regeneration usually has  poor  steam
 utilization  efficiency.  Consequently, carbon beds  are designed  to  be
 just thick enough  to handle  the  solvent concentration without too  frequent
 regeneration, yet  thin  enough  to limit energy consumption  from  the  fans.
      Another parameter  which affects the design efficiency and  operating
 cost of  the fixed  bed system is  the breakthrough point.   A very low
 breakthrough point will yield a  high adsorption removal  efficiency
 although the adsorption capacity (per cycle) will decrease.  The steam
 consumption per unit of recovered solvent will  increase accordingly.
 This increased  steam requirement will raise fuel costs.   A higher breakthrough
 point will, on  the other hand, reduce fuel consumption by decreasing the
 frequency of  steam regeneration.  Some  adsorption  systems have been
 designed with gas analyzers to monitor  and control  the adsorber outlet
 hydrocarbon vapor concentrations.   Adsorption  systems at  three publication
 rotogravure  printing facilities are regenerated at breakthrough points
 as  low  as 15  and  to  30 ppm  (V/V).64'65'66'67
                                     4-26

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     The regeneration step of the adsorber cycle is designed to desorb
most of the retained solvent, and recondition the carbon bed.  Low
pressure saturated steam has been the only stripping method used to
regenerate the carbon beds in this industry.  First, the SLA flow through
                                                    2
the bed is stopped.  Then, steam at 1.8 to 3.5 Kg/cm  (25-50 psig) is
admitted through the bed, usually in a counter-current direction to the
SLA flow.  The steam flow rates depend on the adsorber size and boiler
capacity. Typical design flow rates range from 3600 to 6800 Kg/hr (8,000-
15,000 Ibs/hr). The design steam to recovered solvent ratio for older,
existing systems range from about 4.0 to over 6.0 on a weight per weight
basis.  '  '    However, newer designs promise lower ratios of from less
than 4.0 down to 1.8.71>72>73>74
     The steam and solvent vapor mixture is directed out of the bed and
condensed.  The condenser and an associated cooler are sized according
to the steam flow rate.  Tempered water at about 24°C (75°F), which is
usually a mixture of chilled water and cooling tower water, is used as
the coolant.
     The subcooled, condensed two phase solvent/water mixture then flows
down to a decanter.  The decanter is simply a liquid-liquid gravity
separator.  Fortunately for this industry, the solvents used are almost
immiscible with water and can be readily separated from the steam condensate.
The less dense solvent flows upwards while the water settles to the
bottom of the decanter.  The decanter capacity, usually several hundred
gallons or more, is sized according to the condensate flow rate.  The
decanter is sometimes a vertical vessel; however, horizontal designs are
employed where more residence time is required for the solvent/water
separation.  The decanted solvent does not normally require any additional
treatment.  This recovered solvent can be recycled to the printing
presses for solvent addition or sold as a by-product.
     Dissolved solvent in the condensate from the decanter is a source
of solvent loss from carbon adsorption systems.  The solvent content
depends on the specific solubility of the individual solvent components.
In addition, the solubility of most organic liquids in water increases
                                    4-27

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with temperature. Analyses of condensate samples at two plants showed
solvent concentrations ranging from 130 to 2,000 ppm.   '     This small
amount of solvent loss typically represents less than  one percent of the
total solvent used at the printing presses.  However,  this potential
source of water pollution and solvent loss can be virtually eliminated
by stripping the condensate.
     Hot-air stripping of the condensate is one demonstrated method for
                               77 78
removal of the solvent content.  '    Ambient air is drawn up through a
steam heated packed column by the SLA fans.  The solvent laden condensate
is directed down through the packing, counter-current to the air flow.
The SLA from this stripper is then directed into the adsorber inlet
header for recovery. This process reduces the condensate solvent concentration
to less than 3 ppm.    The stripped steam condensate can then be recycled
as hot boiler-feed water or reused as essentially solvent-free cooling
tower water makeup.  Other methods for handling of this waste water are
discussed in Chapter 7.
     Vacuum regeneration is an alternative method for stripping the
           on
carbon bed.    The total adsorber cycle is similar to that for steam
regeneration, except that steam  is not mixed with the re-evaporated
solvent during the desorption  step.   In this case, the carbon bed vessels
are  usually constructed with an  external jacket.  During the  regeneration
cycle, steam is  admitted through the  vessel jackets to heat the carbon
bed  indirectly.  The carbon is heated to approximately 175° to 225°F, or
at  least  50° to  60°F above  the adsoprtion  temperature.  A vacuum is  then
applied to the hot carbon bed  to remove the solvent.  The solvent
vapors are then  condensed and  cooled  without any further required treatment
steps  for water  separation.  With  the condenser  on the suction  side  of
the  vacuum pump,  the  system constitutes a  vacuum distillation facility.
This condensing  design  is relatively  expensive,  requiring a large refrigerated
or  chilled water condenser.  A less expensive  design alternative is  to
condense  on  the  discharge  (pressure)  side  of  the vacuum  pump.   The
capital cost of  vacuum  desorption  systems  are  comparable to steam regeneration
systems;  however,  the  operating  costs tend to  be higher  with  the vacuum
                                     4-28

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system.    In general, vacuum desertion designs would only be used if
there are handling or treatment problems for disposal or recycling of
the condensate waste water from steam regeneration systems.
     There are several other carbon adsorption system design features
which must be considered.  The materials of construction and valve
designs can greatly affect the long term performance of adsorption
systems.  Design decisions must be made between lower cost valves and
carbon steel construction, versus better valve design and corrosion
resistant alloys.  Most new adsorbers are constructed of carbon steel
shells with titanium bed supports.  The condenser and some condensate
systems are made of stainless steel.  The vents from the condenser and
decanter are usually directed back into the adsorber inlet header.  In
addition, a decision must be made on the method to dry and/or cool the
carbon bed at the end of the regeneration cycle.  Some designs use the
inlet solvent laden air while the adsorber outlet air can also be used
if the pressure drop is not excessive.
4.3.3  Performance
     The performance of a carbon adsorption system can be expressed in
terms of emission reduction and relative economy.  When new and operating
within design conditions, many of these fixed bed systems will reduce
the inlet SLA vapor concentration by 99 percent or more.  Discrepancies
between the design and actual operating bed efficiencies can be the
result of changing inlet SLA vapor concentrations, carbon attrition,
deactivation, bed blockages, corrosion and valve leakages.  However,
several carbon adsorption systems installed in this industry, provide
evidence that the carbon bed still maintains the design "activity" for
                     82 83 84
more than five years.  '  '    The relative economy is a function of
electrical power usage for the SLA fans, and steam usage for bed regeneration,
     Some of the larger carbon particles are reduced to fine particles
(fines) because of mechanical abrasion.  Thermal degradation weakens the
carbon binder and accelerates the formation of carbon fines.  These
fines increase the pressure drop across the carbon bed and reduce the
potential air flow rate.  Periodic maintenance can minimize these adverse
                                   4-29

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effects. The carbon fines can be withdrawn from the bed by filtering.
New makeup carbon can be added, as needed, to replace the carbon fines.
     High molecular weight by-products entrained dirt, and residues can
decrease the carbon's adsorption/desorptiori ability.  A good SLA filtering
system should minimize these problems.  In some services, the carbon can
gradually become less effective after several years; replacement of the
carbon bed is generally required after about five years.  The solvent
molecules with the lower molecular weights are more loosely adsorbed,
and therefore, are the first to be desorbed.  A small portion of even
the easiest to remove solvents are not desorbed from the carbon.  The
energy and time required to remove the last, traces of solvent does not
justify the additional capacity regained.  For this reason the relevent
adsorption capacity of a carbon bed is actually the working capacity
rather than the total capacity.  The working capacity of a carbon bed is
essentially the amount of solvent adsorbed at the specified breakthrough
percent.  The small amount of retained solvent, which is the difference
between the total and working capacities, is called the heel.  With some
solvent mixtures, this heel can be an accumulation of high molecular
weight compounds present in trace quantities.  If the compounds present
in this heel are reactive, then partial blockage of the carbon pores
could take place over a period of time from the formation of high molecular
weight reaction products.  However, these "bed blockages" have not
occurred with existing adsorption systems and solvent blends used in the
publication rotogravure printing industry.
     Other operational problems associated with the fixed bed carbon
adsorption systems can be corrosion and valve leakage.  Major corrosion
problems are generally eliminated when stainless steel condensers and
piping are used.  Titanium alloys have been successfully used as internal
bed supports in many cases.  Carbon steel is generally used for the
remainder of the equipment.  Valve leakage, which can also account for a
gradual loss of emission reduction efficiency, occurs when corrosion and
wear act on the valve seats.   Easily  replaceable valve seals and seats
minimize this problem.   In addition,  this problem can be virtually
                                    4-30

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eliminated with modern "tight-shutoff" valve designs, and corrosion
                       oc
resistant construction.
     The typical instrumentation for a fixed-bed carbon system usually
includes outlet hydrocarbon analyzers, which are used to initiate regene-
ration after breakthrough is detected.  A timer override is usually
coupled with hydrocarbon analyzers.  The steaming cycles are usually
controlled by either separate timers or steam totalizers for each bed.
In some cases the adsorption-desorption cycle is totally controlled by
timers.  The best compromise for sustained high efficiency operation,
and minimum steam consumption is obtained by using hydrocarbon analyzers.
Hydrocarbon breakthrough analyzers initiate regeneration only when it is
needed.
     Another technique which enhances overall emission reduction is a
cooling/drying cycle.  High temperatures and wet conditions impair the
adsorption ability of a carbon system.  The carbon beds can be cooled
and further stripped of hydrocarbons at the end of each regeneration
cycle.  Filtered ambient air or treated exhaust air is forced into the
freshly regenerated bed to disengage any trapped steam and solvent
condensate.  This effluent is discharged into the condenser or is routed
back into the inlet manifold to the adsorbers.  The non-condensable
gases from the condenser and decanter are also routed back into the
inlet manifold of the adsorbers.
     Actual adsorber operating efficiencies were measured at the Meredith/
Burda plant (M/B) and the Texas Color Printers plant (T/C).86'87  The
summarized data presented in Appendix C shows that the M/B adsorber
efficiency ranged from 97 to 98 percent; while the T/C adsorber efficiency
ranged from 88 to 97 percent.  The vapor concentration levels of the
inlet solvent laden air (SLA), as well as the outlet, appear to be the
main reasons for the less efficient T/C adsorbers.  Appendix C shows
that the maximum vapor concentrations at T/C were about 40 percent lower
than at M/B.  The M/B press unit dryers have gas analyzers for maximizing
the allowable exhaust vapor concentrations; the T/C dryers do not have
such analyzers.  The allowable vapor concentration at T/C must be lower
                                    4-31

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because the lower explosive limit (LEL)  of the solvent-blend  vapors  is
8,000 -10,000 PPM, versus 12,700 PPM for toluene.   However, an  increase
in the T/C vapor concentration to the 1,900 PPM maximum  detected  M/B
inlet level would result at only 21  - 24 percent of the  LEL.   The M/B
dryer exhaust's level  was calculated to  be about 2,300 PPM, as  shown in
Appendix C. This represents a level  of almost 19 percent of the toluene
LEL and about 26 percent of the naphtha  solvent LEL,   Both these  levels
should be well below insurance requirements.   In addition, information
from the Alco-Gravure and Standard Gravure plants  show that adsorbers
can be designed to control  the outlet concentration to less than  15
    QO on on
PPM.  '  '    Thus, the installation of  dryer exhaust analyzers and
adsorber outlet analyzers with better adsorber design could  increase the
T/C adsorber efficiency to the level of  M/B.
     The instantaneous adsorber efficiency fluctuates with changes in
the inlet SLA vapor concentrations.   The adsorbers are designed to
handle the maximum expected vapor concentrations (1600 to 2,000 ppm) at
the matched capacity of the SLA fans.  The amount of solvent  vapors  is
greatly reduced during press shutdowns.   The adsorber outlet  concentration
will remain unchanged; however, the adsorber efficiency will  decrease
during press shutdowns because of the dilute inlet SLA concentrations.
Therefore, some sort, of time averaged adsorber efficiency should  be
used.
     The duration of the combined press  operating modes  with  the  resulting
adsorber inlet vapor concentrations are presented in Appendix C.   Operating
mode times at both plants were practically identical.  Both  presses  were
printing about 60 percent of the time, while only one was down about 33
percent of the time.  Both presses were down about 7 percent  of the
time.  This data can serve as a basis for determining adsorber efficiency
variation.
     A time weighted average adsorber efficiency of 97.9 percent was
calculated, as shown in Appendix C.  This calculation is based on the
combined shutdown/running operations for two presses.  The calculations
show that  the instantaneous efficiency can vary from the design maximum
                                   4-32

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of 98.8 percent, down to 93.3 percent.  Therefore, these results show
that a realistic average 97 percent adsorber efficiency can be assumed
for modern, well instrumented fixed-bed adsorption systems in this
industry.
     High inlet SLA concentrations decrease the adsorption cycle time
but improve steam efficiency.  The steam efficiency is expressed as the
ratio of steam used to solvent recovered.  Calculations presented in
Appendix C show that operating ratios at M/B range from 3.0 to 3.7
pounds of steam per pound of recovered solvent.  Instrumentation was not
available to determine the operating ratio at T/C.  However, T/C plant
personnel mentioned that a typical ratio of about 4.5 is expected.91  If
the SLA inlet concentration becomes very dilute, a small increase in
adsorption cycle time will occur but at the expense of very poor steam
efficiency.  The best overall performance is obtained when the SLA inlet
concentration remains high.  Both steam and emission reduction efficiency
will be best at high SLA inlet concentrations.  Therefore, a well designed
and properly operated solvent vapor capture system is essential  to
maintaining high control  efficiencies.
     In summary, the long-term average performance of fixed-bed carbon
adsorption/solvent recovery control  systems is expected to be slightly
different from the performance results of the two short-term plant
tests.  Modern carbon adsorbers can be expected to achieve a long-term
average solvent vapor reduction efficiency of about 95 percent.   Short-
term efficiencies of the best demonstrated adsorbers may be higher at
times, but this average efficiency accounts for wide fluctuations of the
SLA vapor concentrations  at the inlet to the adsorber.  In comparison,
older adsorber systems were designed to perform at about only a  90 percent
average efficiency.  The  long-term average steam to recovered solvent
ratio is expected to be about four to one, on a weight basis.  However,
newer design specifications by some equipment manufacturers indicate
that this may be a conservatively high ratio.
4.4  FLUIDIZED BED CARBON ADSORPTION/SOLVENT RECOVERY
     Fluidized-bed carbon adsorption systems are used to recover solvents
in several  publication rotogravure plants  in Japan.   This  control  system,
                                    4-33

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which is presently marketed in the U.S. by Union Carbide Corporation, is
being installed on a domestic plant.  The system is called the PURASIV
           92
HR process.    There is no domestic operating data available as yet, but
the system looks very promising.
     Fluidized-bed carbon adsorption is a continuous process.  Adsorption
and desorption occur simultaneously in a single vertical vessel, which
resembles a sieve tray distillation column.  The adsorbant used is
beaded activated carbon spheres which flow countercurrent to the exhaust
gas. As the solvent-laden exhaust gas flows upward, it contacts the
activated carbon in the adsorption section and the solvent is removed.
The clean gas exits through the top of the vessel  while the carbon
beads, now containing the solvent, continue down to the desorption zone.
In the desorption zone, the carbon is indirectly preheated with steam.
The solvent is then stripped from the carbon through direct contact with
steam.  The regenerated carbon is then carried back to the top of the
vessel by a carrier gas and is ready to repeat the process.  The steam-
solvent vapor exits through the desorption section and is condensed.
The solvent can be removed by decanting or distillation.
     One advantage of this system is that it is not limited to steam as
a stripping medium.  Because the stripping medium can be recycled, pure
nitrogen can be used economically in its place.  The advantage this
replacement offers is a large reduction in condenser size.  It also
eliminates the condensate clean-up problems present in the steam system.
The use of steam can be eliminated completely by substituting an indirect
hot fluid heating system to preheat the sol vent-laden carbon.  With this
system, a preheat temperature of about 200-260°C (400-500°F) can be
achieved as opposed to about 100°C (212°F) with steam.  This increase in
temperature decreases the amount of nitrogen required to strip the
solvent, thus reducing stripping gas costs.  A decrease in the amount of
stripping gas further reduces the size of the condenser required for
solvent recovery.  The volume of carbon is also decreased.  For these
reasons, the substitution of an indirect hot; fluid preheating system
with nitrogen gas stripping is an economical way to eliminate steam from
a system where no extra steam capacity is available.
                                     4-34

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     The fluidized-bed process offers a lower energy consumption (for a
given flow rate of SLA) than a fixed-bed system.  This advantage is
partially offset by the fact that the system air flow rate must remain
constant; and therefore, significant turndown does not reduce operating
costs.  The fluidized-bed system is a new process in the United States
and previous operating experience is minimal.  The capital investment is
also higher than any other control  method investigated.
4.5  SOLVENT DESTRUCTION
     Solvent destruction (i.e. oxidation) is a widely used method of air
pollution control for VOC and other organic vapor emissions.  This
control technique destroys the organic vapors by thermal or catalytic
oxidation to carbon dioxide (C0?) and water (H«0), along with carbon
monoxide (CO) and nitrogen oxides (NO ) and other reaction products
                                     /\
formed from non-organic components (e.g. halogenated organics).  At
present, there are no solvent destruction control devices being used on
publication rotogravure facilities in this country.
     Most thermal oxidation systems rely on large amounts of supplemental
fuel to sustain combustion temperatures.  Typical oxidation temperatures
range from about 450°C to 980°C (850°-1800°F).  Consequently, if a large
quantity of thermal energy is not needed at a plant site, the system
becomes very costly to operate.  Although primary heat recovery will
reduce the fuel requirements by preheating the SLA feed gas, the fuel
requirements can be still quite substantial.  Additional energy savings
would result if secondary heat exchangers were used to preheat the dryer
inlet air on the printing press units.  Existing publication rotogravure
printing press dryers are not designed to accommodate this feature.
Although it is probably possible to make use of this secondary heat, it
has not been demonstrated.  The printing press dryers are designed to
use steam as an energy source.  The steam enters a heat exchanger which
heats the dryer circulation air.  If hot exhaust gas from a thermal
oxidation device were used in place of steam, the dryer design would
require modification to increase the size and change the design of this
secondary heat exchanger.
                                     4-35

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     Catalytic oxidation offers reduced fuel  requirements, but still
requires large amounts of fuel  to heat-up the SLA feed gas unless elaborate
primary heat recovery is employed.  The use of a catalyst permits lower
oxidation reaction temperatures, and therefore, requires about 50 percent
less fuel than for thermal  oxidation.  The catalyst ignition temperatures
for most of the VOC components  of the SLA from rotogravure printing
facilities range from about 300°C to 315°C (575° - 600°F).93  The exhaust
gas temperature must be controlled between 480°C and about 650°C (900° -
1,200°F) to ensure adequate VOC destruction without deactivating the
                        94
catalyst by overheating.    Secondary heat recovery could also be used
with catalytic oxidation devices, although it would be less effective
since the exhaust gas temperature is much lower than for thermal oxidation
devices.
     Another approach, introduced by REECO Inc., is called the RE-THERM
       95
system.    This system thermally oxidizes dilute hydrocarbon vapor
streams by passing the stream through regenerative combustion beds.
Thermal recovery efficiencies of 85-90 percent can be achieved.
     The RE-THERM system utilizes a vertical, cylindrical combustion
chamber surrounded by a series  of packed, stoneware beds.  Top and front
views of a five-bed system are  illustrated in Figures 4-5 and 4-6,
respectively. The pressroom exhaust enters a feed header, gets preheated
through a hot bed, and passes through the high temperature 760°C (1400°F)
combustion chamber.  The hot combustion gases pass through a different
stoneware bed transferring the heat of combustion to that bed.  Inlet
and exhaust valves on each bed  control the gas flow as the bed is depleted
or saturated with heat.  Each bed goes through this depletion/saturation
cycle every few minutes.
     An energy savings and fuel cost savings can result providing that
the printing plant can use all  of the waste heat generated.    The RE-
THERM system is self-sustaining, requiring little or no fuel, if the
inlet waste gas has a hydrocarbon content of at least 4 to 5 percent of
the lower explosive limit  (LEL).  The hydrocarbon vapor content of
typical SLA streams from rotogravure presses usually corresponds to at
                                    4-36

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                                                                   Inlet Manifold
                                  Fumes  from
                                   Process
•£>
I
co
                           Exhaust
                             Fan
                                                                                   Upper and Lower
                                                                                       Headers
Fan Inlet
 Damper
                                                                                Stoneware
                                                                                   Bed
           Exhaust
          Manifold
                                   Figure  4-5.  Top view of REECO RE-THERM system.

-------
co
00
                                                Fumes  from
                                                Process
                          Inlet
                         Manifold
                                       Inlet Valve
                                          (Open)
                                        Vertical
                                          Flue
Stoneware
   Bed
                                     Exhaust Valve
                                       (Closed)
                           Clean Exhaust
                               Air
                                                Exhaust
                                               Manifold
                                         Incineration
                                           Chamber
                                  Figure 4-6.   Front view of REECO RE-THERM system.

-------
least 10 percent of the LEL.  The regenerative combustion system is the
only attractive solvent destruction device for this industry.  This
oxidation process may provide fuel cost savings if the hot exhaust gas
can be used for pressroom heating and to generate the process steam
required in the printing press unit dryers.  However, solvent supplies
are closely related to gasoline and other fuel  supplies, which will
become less available and more expensive in the future. Therefore, a
good solvent recovery system is probably the better choice for this
industry.
                                   4-39

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4.6  REFERENCES
1.   Letter and attached test reports from George, H.F. - Gravure Research
     Institute, Inc., to Vincent, E.J. - U.S. EPA.  February 7, 1980.
     P. 27 of attached February 28, 1979 memornadum on tests at
     Meredith/Burda (March 6, 1979 addendum).  Response on cancellation
     of meeting and response to request letter for test data.
2.   Reference 1, P. 2 of attached June 4, 1979 memorandum on tests at
     Texas Color Printers.
3.   Reference 1.
4.   Reference 2.
5.   Telecon.  Gugler, Heinz - Meredith/Burda, Inc. with Reich, Richard -
     Radian Corporation.  August 21, 1979.  Liquid meters for recovered
     solvent.
6.   Telecon.  Curtis, Dave - Tockheim Corporation with Reich,  Richard -
     Radian Corporation.  August 21, 1979.  Meter specifications.
7.   Reference 6.
8.   Feairheller, W.R.  Graphic Arts Emission Test Report, Meredith/Burda,
     Lunchburg, Virginia.  Monsanto Research Corporation.  Dayton, Ohio.
     EPA Contract 68-02-2818-16, EMB 79-GRA-l.  April  4, 1979.   P. 29-30.
9.   Feairheller, W.R.  Graphic Arts Emission Test Report, Texas Color
     Printers, Dallas, Texas.  Monsanto Research Corporation.  Dayton,
     Ohio.  EPA Contract 68-02-2818-20, EMB 79-GRA-3.   October  19, 1979.
     P. 31-34.
10.  Reference 9, 185 pages.
11.  Reference 1, Attached June 4, 1979 memorandum on  tests at  Texas Color
     Printers.  3 pages with 32 page appendix.
12.  Letter from MacAs kill. P.R. - Texas Color Printers, to Reich, R.A. -
     Radian Corporation.  July 3, 1979.  Solvent Recovery.
13.  Trip Report.  May 9, 1979 plant visit to World Color Press, Salem,
     Illinois.  Edwin Vincent - U.S. EPA.   June 14, 1979.
14.  Telecon.  Hastings, E. - Triangle Publications, with Reich, R.A. -
     Radian Corporation, August 7, 1978.  Solvent recovery system.
15.  Trip Report.  September 15, 1978 plant visit to Meredith/Burda, Inc.,
     Lynchburg, VA.  Richard A.  Reich, Radian Corporation, October 26,
     1978.  p. 3 (Older solvent recovery system).
                                   4-40

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16.  Letter from Verdooner, Marcel - Alco Gravure, to Reich, R.A. -
     Radian Corporation.  November 13, 1978.  Response to Section 114
     letter on rotogravure printing facilities.
17.  Telecon.  Yalbezian, Chris - Gravure West, with Burt, Richard -
     Radian Corporation.  February 19, 1980.  Overall emission control
     efficiency.
18.  Reference 8, 30 pages and appendices.
19.  Letter from Gugler, H. - Meredith/Burda, Inc., to Vincent, E.J. -
     U.S. EPA.  July 6, 1979.  Solvent Recovery.
20.  Letter from Gugler, H. - Meredith/Burda, Inc., to Vincent, E.J. -
     U.S. EPA.  March 10, 1980.  Response to report on tests performed
     during January 22-24, 1980.
21.  Letter and attachment from Gugler, H. - Meredith/Burda, Inc.,
     to Goodwin, D. R. - U.S. EPA.  June 19, 1980.  Phase III solvent
     recovery performance.
22.  Letter from George, H.F. - Gravure Research  Institute, Inc., to
     Vincent, E.J. - U.S. EPA.  September 5, 1979.  Comments about
     NSPS data base.
23.  Letter from Fremgen, R.D. - Dayton Press Inc., to Goodwin, D.R. -
     U.S. EPA.  December 3, 1979.  Comments to NAPCTAC on draft NSPS.
24.  Letter and attachments from George, H.F. - Gravure Research
     Institute, Inc., to Goodwin, D.R. - U.S. EPA.  December 17, 1979.
     NAPCTAC presentation and comments on draft NSPS.
25.  Kelly, Winton.  Graphic Arts Test Report, Meredith/Burda, Lynchburg,
     Virginia.  U.S. EPA, Emission Measurement Branch.  Research Triangle
     Park, North Carolina.  EMB 79-GRA-1A.  April 1980.  86 p.
26.  Reference 1, page 27.
27.  Meeting minutes.  March 8, 1979 discussions  between the Gravure Research
     Industry Emission Control Subcommittee and the U.S. EPA, Durham,
     North Carolina.  Harvey F. George - Gravure  Research Institute.
     March 26, 1979.  Preliminary Meredith/Burda  test results,  p. 2.
                                    4-41

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28.   Meeting Minutes.   August 2,  1979 discussions between the Gravure
     Research Institute and other industry representatives and the U.S. EPA,
     Durham, North Carolina.   E.  J.  Vincent - U.S.  EPA.   August 15, 1979.
     p.  2,3.
29.   Telecon.  Reich,  Richard - Radian Corporation with  Gugler, Heinz -
     Meredith/Burda,  Inc.   August 10, 1979.  Recovered solvent meter accuracy.
30.   Telecon.  Gugler,  Heinz - Meredith/Burda, Inc. with Reich, Richard -
     Radian Corporation.  August 20,  1979.  Liquid meter accuracy.
31.   Reference 22, p.  2.
32.   Trip Report.   September 27,  1979 plant visit to Meredith/Burda, Inc.,
     Lynchburg, VA.  Richard C. Burt  - Radian Corporation.  October 8, 1979.
     Recovered solvent temperature.
33.   Lange, N. A.   Lange's Handbook  of Chemistry.  New York, McGraw Hill Co.
     1979, 12th ed.  p. 7-367, 10-115, and 10-129.
34.   Weast, R. C.   CRC Handbook of Chemistry and Physics.  Cleveland, The
     Chemical Rubber Co.  May 1968,  49th ed.  p. C571.
35.   Reference 25, p.  15-16.
36.   Trip Report.   August 14, 1978 plant visit to Standard Gravure,
     Louisville, KY.   Richard A.  Reich - Radian Corporation.  September 25,
     1978.
37.   Trip Report.   May 6,  1980 plant visit to Standard Gravure, Louisville,
     KY.  Richard C.  Burt - Radian Corporation.  June 6, 1980.
38.   Harvin, R.L.   Recovery and Reuse of Organic Ink Solvents.  C&I Girdler,
     Inc. Louisville, KY.   (Presented at the Conference on Environmental
     Aspects of Chemical Use in Printing Operations.  King of Prussia.
     September 22-24, 1975).   25 p.
39.   Reference 9, 185 pages.
40.   Reference 8, P.  17-20.
41.   Reference 15, P. 4-6.
42.   Reference 8, 30 pages and appendices.
43.   Reference 8, p.  5-16.
44.   Reference 25, p. 2, 4,  5, 14.
45.   Reference 8, p. 5-16.
46.   Reference 25, p. 4, 6,  8, 14-15.
                                     4-42

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47.   Reference 25, p. 2, 3, 12.
48.   Reference 25, Press 504.  p. 4, 7, 8, 12.
49.   Reference 25, p. 12-14, 18, 20, 21.
50.   Reference 25, p. 15, 17, 20.
51.   Telecon.  Hastings, E. - Triangle Publications, with Reich, R.A. -
     Radian Corporation.  July 14, 1978.  Plant operations data.
52.   Telecon.  Reich, Richard - Radian Coroporation, with Anderson, Jim -
     Standard Gravure.  July 14, 1978.  Plant operations data.
53.   Trip report.  September 7, 1978 plant visit to Alco-Gravure, California
     Rotogravure Division, North Hollywood, CA.  Richard A. Reich, Radian
     Corporation.  October 19, 1978.  p. 3.
54.   Trip Report.  Plant Visit to R.R. Donnelley & Sons Company, Chicago,
     IL.  Richard A.  Reich, Radian Corporation.  July 24, 1978.
55.   Brochure.  "Type BPL Granular Carbon".  Calgon Corporation, Activated
     Carbon Division, Pittsburgh, PA.  2 p.
56.   Watkins, B.G. and Marnell, P.  Solvent Recovery in a Modern Rotogravure
     Printing Plant.   Wiley & Wilson, Inc., Lynchburg, VA and American
     Lurgi, Inc., Hasbrouck, NJ.  (Presented at the Conference on
     Environmental Aspects of Chemical Use in Printing Operations.  King
     of Prussia.  Sept. 22-24, 1975) 10 p.
57.   Manzonne, R.R. and D.W. Oakes.  "Profitably Recycling Solvents from
     Process Systems".  Pollution Engineering.  Volume 5, Number 10.
     p. 23-24.  October 1973.
58.   Letter from George, Harvey F. - Gravure Research Institute, Inc., to
     Anderson, Theresa, J. - Radian Corporation.  October 18, 1978.  Response
     to question 35 of request letter.
59.   Reference 8, p.  5, 11-16.
60.   Reference 36.
61.   Reference 53.
62.   Reference 58.
63.   Reference 55.
64.   Reference 8, p.  5, 11-16.
65.   Reference 36, p. 3.
66.   Reference 38, p. 24.
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67.   Reference 53, p.  4.
68.   Reference 36, p.  4.
69.   Reference 14.
70.   Reference 54.
71.   Telecon.  Dundee, Mitchell D. - Croftshaw Engineers, with Reich, R.A. -
     Radian Corporation.  March 23, 1979.
72.   Telecon.  Dundee, Mitchell D. - Croftshaw Engineers, with Reich, R.A. -
     Radian Corporation.  April 23, 1979.
73.   Telecon.  Moses, William - Sutcliffe Speakman & Company, with  Reich,
     R.A. - Radian Corporation.  April 2, 1979.
74.   Telecon.  Seguy, B. - American Ceca, with Reich, R.A. - Radian
     Corporation.  April 24, 1979.
75.   Reference 8, appendix V.
76.   Reference 9, appendix K.
77.   Reference 15, p. 4.
78.   Reference 8, p. 18, 22.
79.  Reference 8, p. 22, 26, and appendix V.
80.   Trip Report  and attachments.  August 15-16, 1978,  third meeting  of the
     GRI Solvent  Recovery Commission,  Salem,  IL.   Richard A. Reich  -
     Radian  Corporation.  October  19,  1978.   p.  7  of attachments.   Vacuum
     regenerative carbon adsorption.
81.  Telecon.  Kenson,  R. -  Oxy-Catalyst, Inc.,  with Reich,  R.A.  -
     Radian  Corporation.  September  21,  1978.   Vacuum desorption  systems.
82.  Reference 38.
83.  Reference 51.
84.  Telecon.  Dundee,  Mitchell  D. -  Croftshaw Engineers, with  Burt,
     R.C.  -  Radian  Corporation.   December 20,  1979.
85.  Reference 84.
86.  Reference 8, p.  5, 11-16.
87.  Reference 9, p.  6-8, 15.
88.  Reference 53,  p.  4.
89.  Reference 36,  p.3.
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90.  Reference 38, p. 24.
91.  Reference 9, p. 14.
92.  Letter from Thomas, R.L. - Union Carbide Corporation, Linde Division,
     to Reich, R.A. - Radian Corporation.  July 20, 1979.  Fluidized-bed
     carbon adsorption.
93.  Key, J.A., Control Device Evaluation-Catalytic Oxidation.
     Hydroscience, Inc. for U.S. Environmental Protection Agency.
     Knoxville, Tennessee.  Contract No. 68-02-2577.  March 1980.
     p. 1-1 to II-7.
94.  Reference 93, p. II-3.
95.  Letter from Pennington, R.L. - REECO, Inc. to Anderson, T.J. - Radian
     Corporation.  October 11, 1978.  Thermal Oxidation.
96.  Letter from Pennington, R.L. - REECO, Inc. to Goodwin, D.R. - U.S EPA.
     November 29, 1979.  Thermal Oxidation.
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                    5.  MODIFICATION AND RECONSTRUCTION

5.1   GENERAL
     In the publication rotogravure printing industry, each printing
plant is considered to be a stationary source, while each production
press is considered to be a separate facility.  Proof presses, whether
existing or new, will  not be subject to the standards.  An "existing
facility" is defined in 40 CFR 60.2 (aa).  With reference to stationary
source, an "existing facility" in this industry, means any rotogravure
publication press which underwent construction or modification before
the date of proposal of the new source performance standard -f or any
press which could be altered in such a way as to be of that type.  An
"existing facility" may become an "affected facility" and be subject to
standards of performance if classified as modified or reconstructed
under the provisions of 40 CFR 60.14 or 60.15, respectively.   An "affected
facility" in this industry is any rotogravure publication press which
underwent construction, reconstruction, or modification after date of
proposal for the new source performance standard.
     The Clean Air Act applies to new facilities and to those modified
or reconstructed as described in Subpart A, General Provisions, of 40
CFR Part 60.  In general , any physical  or operational  change to an
existing facility which causes an increase in the emission rate of
volatile organic compounds (VOC) might be considered a modification. A
replacement of parts of an existing facility which costs more than half
of what a comparable entirely new facility would cost might be considered
a reconstruction, even if emissions are not increased.  The specific
determination of modification and reconstruction is made on a case-by-
case basis by the appropriate enforcement authority.
                                     5-1

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5.2   40 CFR PART 60 - MODIFICATION AND RECONSTRUCTION
5.2.1  Modification

     Modification is defined under the provisions in Section 60.14 as

fol lows:

          "Except as provided under paragraphs (e) and (f)
     of this section, any physical  or operational change  to an
     existing facility which results in an increase in the emission
     rate to the atmosphere of any pollutant to which a standard
     applies shall  be considered a modification within the meaning
     of section 111 of the Act.   Upon modification, an existing
     facility shall become an affected facility for each  pollutant
     to which va standard applies and for which there is an increase
     in the emission rate to the atmosphere."

     Paragraph  (e)  lists certain physical  or operational  changes which

will  not be considered as modification, irrespective of any change in

the emission rate.   These changes include the following:

     (1)  Maintenance, repair, and replacement which the  Administrator
          determines to be routine.

     (2)  An increase in the production rate of an existing facility,
          if that increase can be accomplished without a  capital
          expenditure as defined in Section 60.2  (bb).

     (3)  An increase in the hours of operation.

     (4)  Use of an alternative  fuel or raw material, if  the existing
          facility  was designed  to accommodate that alternate fuel or
          raw material prior to  the date of the standard.

     (5)  The addition or use of any system or device whose primary
          function  is the reduction of air pollutants, except when an
          emission  control system is removed or  replaced  by a system
          which the Administrator determines to be less environmentally
          beneficial.

     (6)  The relocation or change in ownership of an existing facility
           (rotogravure publication press).

     Paragraph  (b)  clarifies what constitutes an  increase in emissions

in kilograms per hour and the procedures for determining  the increase,

including the use of emission factors, material balances, a continuous

monitoring system and manual emission tests.  Paragraph  (c) affirms that

the addition of an affected facility  (rotogravure publication press) to

a  stationary source  (printing plant) does not make any other facility
                                     5-2

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(rotogravure publication press) within that source  (printing plant)
subject to standards of performance.  Paragraph  (f) provides for super-
seding any conflicting provisions.
5.2.2  Reconstruction
     Reconstruction is defined under the provisions in Section 60.15 as
fol lows:
          "Reconstruction means the replacement of components of
          an existing facility to such as extent that-
          (1) The fixed capital cost of the new components exceeds
          50 percent of the fixed capital cost that would be re-
          quired to construct a comparable entirely new facility;
          and (2) It is technologically and economically feasible
          to meet the applicable standards set forth is this part".

     This provision ensures that an owner or operator does not perpetuate
an existing facility  (rotogravure publication press) by replacing all
the working components rather than totally replacing the press,  in order
to avoid the applicable standards of performance.  The EPA, upon request,
will determine if the proposed replacement of an existing facility's
components constitutes reconstruction.
5.3  MODIFICATION IN A PUBLICATION ROTOGRAVURE PLANT
     Most publication rotogravure presses, because of workload variations,
do not operate at full capacity all of the time.  As the market  demand
grows, the utilization of individual presses will increase.  Such an
increase in production to full capacity does not involve increased
capital costs and would not be considered a modification.  Routine
maintenance, repair, and replacements, which are standard to this
industry, do not increase emissions and do not constitute modifications,
according to the General  Provisions of 40 CFR Part 60.
     These provisions also exclude substitution of alternative raw
materials if the existing printing press was designed to accommodate the
use of that alternative.  Since most publication rotogravure presses are
capable of printing on several types of paper using a variety of ink
formulations, a change in substrate or ink formulation, within the
                                     5-3

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capacity of the equipment, would not be considered a modification.
Although a change in solvent may effect a change in emission rates, such
a change is defined as not being a modification.
     The emission rate also varies with the amount of ink coverage per
page.  This coverage varies widely and frequently, depending on customer
demands and not on changes in operation procedures or equipment.  Therefore,
changes in ink coverage would not be considered modifications.
     The addition of printing units to an existing press would be the
most obvious change to be considered a modification, in this  industry. A
basic eight-unit press can print four colors on each side of  the paper
web.  These colors, the primary colors, are yellow,  red, blue, and
black.  Some presses have  ten to twelve units.   These presses  can print
an  additional  one or two  colors on  both sides  of  the paper.   Though  such
a modification could be quite expensive,  additional  units may  be added
to  an existing press to make it more  responsive to  customer demands.
Some presses,  which have  more than  eight  units, are  used because  "last
minute" production  changes  are  possible.   This feature  is  particularly
 important  for  advertising products.   A press  having  more than eight
 units  is  considered a  single  press,  providing  that  all  the  units  are
 capable of printing simultaneously  on the same continuous  paper web.
 This  definition  allows such  a  press to operate independently, as  separate
 web-fed sections (such as an  eight  unit section and a  four unit section),
 as  long as the entire press has the capability of printing on a single
 continuous web.  Since additional  units would be added  to an existing
 press  to increase its versatility,  it is highly unlikely that other
 units of the  same press would be shut down.  Each unit is  potentially an
 equal  source  of emissions ; therefore, the addition of units would cause
 an incremental increase  in emissions. Such an increase would be considered
 a modification.   It is more likely, however, that a new press will  be
 installed to  provide the additional capacity.
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     The main air pollution control systems considered in Chapter 4 are
add-on equipment. However, this industry is researching the possibilities
for using waterborne inks and solvents.  Any of the add-on control
systems could be applied to an uncontrolled, modified press.  However,
fume pickup vents and ductwork, for maximizing the capture efficiency,
may have to be designed a little differently than for new press.  There
may also be problems associated with providing a site for the new control
devi ce.
5.4  RECONSTRUCTION IN A PUBLICATION ROTOGRAVURE PLANT
     According to the provisions of 40 CFR Part 60, as interpreted for
the publication  rotogravure industry, if the replacement of parts of an
existing press cost more than half of what a new press would cost, the
press  is considered reconstructed.  A reconstructed press may be subject
to  the same standards of performance as a new press, even if emissions
do  not increase, as a result of the reconstruction.
     A major  renovation which involves simultaneous replacement with
identical parts  of substantial portions of a press could be considered a
reconstruction.  If less than half of the fixed capital cost of a
comparable entirely new press is incurred, the renovation could be
considered routine repair providing there is no increase in emissions.
This distinction could be difficult to assess.  However, such a renovation
is  very unlikely.
     Replacement of more than half the printing units of a press might
be  considered a  reconstruction.  However, since the units are essentially
identical and receive essentially  the same use and care, it is unlikely
that only a portion of them would  be replaced at one time.  If extensive
replacement is  indicated, it is much more likely that all would be
replaced.  Replacement of all units would be the creation of a new
facility instead of the reconstruction of an existing one.
     As stated  in Section 5.3, the ease of controlling an existing press
depends on the effectiveness of any existing control system for that
press. If the press is not currently controlled, the installation of a
                                     5-5

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control system for a reconstructed press will be essentially the same as
for a new press.  However, this assumes the  VOC vapor capture efficiency
is comparable.  Extensive changes may be required to improve the VOC
capture efficiency of an older existing press. This fact must be considered
before a decision is made to modify or reconstruct an existing press.
                                     5-6

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               6.  MODEL PLANTS AND REGULATORY ALTERNATIVES

6.1  GENERAL
     The purpose of this chapter is to define the model plants and the
regulatory alternatives that can be applied to them.  Model plants are
parametric descriptions of the types of plants that, in EPA's judgement,
will consist of newly constructed, modified, or reconstructed affected
facilities, as defined in Chapter 5.  For this study, the affected
facility is designated as a single publication rotogravure printing
press.  A typical printing press consists of eight printing units, each
with individual gravure printing cylinders and dryers.  The model plants
consist of several production printing presses all of the same type and
size.  The regulatory alternatives represent various courses of action
that the EPA could take towards controlling volatile organic compound
(VOC) vapor emissions from rotogravure printing facilities.  The model
plants derived in this chapter are used in Chapters 7 and 8 to determine
projected environmental, energy, and economic impacts associated with
application of the regulatory alternatives considered.
     The model plants presented in this chapter represent control of VOC
emissions from newly constructed printing facilities with fixed-bed
carbon adsorption/solvent recovery systems.  Model plants are not developed
to represent emission control by any other solvent recovery systems,
such as fluidized-bed carbon adsorption, because sufficient operating
information for use in this industry was not available.  Also, model
plants are not developed for analysis of VOC emissions control by solvent
destruction devices (i.e. oxidation) since these devices are not presently
used and not expected to be employed in the future by this industry.
Furthermore, model plants representing the use of waterborne ink systems
with or without air pollution control  equipment, are not analyzed since
                                    6-1

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waterborne inks are not expected to be developed for this industry for
another five to ten years.  Finally, model plants representing modified
and reconstructed existing facilities are not developed.  Neither modification
nor reconstruction is expected in this industry, as explained in Chapter 5.
6.2  MODEL PLANTS
     Two model plants consisting of only new publication rotogravure
printing presses are presented.  A small model plant is assumed to
consist of two production presses; a large model plant contains four
production presses.  Each model plant also has one proof press.  These
two model plants should represent most of the expected new plant expansions;
however, some single press expansions may also occur.  By comparison,
some existing plants contain six or more  production presses with two or
more proof presses, as mentioned in Chapter 3.   Proof presses are not
considered as affected facilities, however, they are necessary  standard
equipment in all publication rotogravure  printing  plants.  The  model
plants characterize facilities which use  only solvent-borne  ink systems.
     The  production and proof  presses are considered to  be of one constant
size for  both model plants.  All production presses are  assumed to  be  of
the same  width,  operating at the same speed, and consisting  of  eight
printing  units  each.   There are  some  smaller and some  larger existing
presses;  however,  the  press size chosen  is expected to  be  the most
common  for  future  facilities.   Most modern rotogravure  presses  are
designed  to  operate at about  the speed  chosen for  study, although older
presses  operate at only about  half that  speed.   The proof  presses are
considered  to be the  same width, but  consisting of only four printing
units.   The proof presses are  operated  only  intermittantly and  at much
slower speeds compared to the  production presses.
      The control of VOC emissions  from  the model  printing  facilities  is
 based  on the use of solvent vapor  capture systems  combined with fixed-
 bed  carbon  adsorption/solvent recovery  control  systems, as described  in
 Chapter 4.   A diagram representing the  small  model printing  plant incorporating
 a fugitive  solvent vapor  capture system is  presented  in Figure 6-1.
                                     6-2

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CT1

CO
                     Solvent
                     Vapor
                     Capture
                     System
                      (TYP.
                             4-Unit
                             Proof
                             Press
                                                 SLA
                                                 Fans
                                                                                 SLA
                                                                                Cooler
                                                                             —D
                             8 Unit
                       Production Presses
                                                                                                           Treated Air
                                                                                                          to Atmosphere
                                                                                             Fixed-Bed
                                                                                          Carbon Adsorber
                                                                                              Vessels
                                                                                                                   Evaporative
                                                                                                                     Losses
1
^ * * ?
£ i
£ -. • • J
_ 1







9t*~
                                                                                                                   Cooling
                                                                                                                   Tower
  Recycle Solvent
   to Presses

       Solvent
        Sales
                                          Recovered
                                          Solvent
                                          Storage
 LEGEND

 SLA —Solvent Laden Air
   9 —Printing Unit Dryer Exhaust Uptake
   Y —Fugitive Vapor pickup vent

	SLA (gas) stream
	Steam
—/—/	Steam/Sol vent vapors
—•	Liquid stream
                                                            Condensate
                                                             Stripper
                                                                                                                              Makeup
                                                                                                                              Water
                                                                                                     Slowdown
Flue Gases
to Atomsphere


    [Natural Gas
1   /   and
    1  Fuel Oil
    ^ Supplies

Slowdown
                                                                        Makeup
                                                                     Boiler Feed Water
                        Figure 6-1.   Schematic  of small model  publication rotogravure  printing  plant
                                        with  fugitive solvent vapor capture  systems  and a  fixed-bed
                                        carbon  adsorption/solvent  recovery control system.

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Captured solvent laden air (SLA) is drawn from the production presses,
as well as from the proof press, and through a filter by the SLA fan.  A
spare filter and fan are included.  The SLA from proof presses is included
to conservatively oversize the emissions control system, even though the
solvent consumption by these presses is very small compared to production
presses.  The SLA is then directed through a cooler and distributed to
multiple fixed-bed carbon adsorbers, with one spare bed for regeneration
mode.  The recovered solvent is as.sumed to be directly recycled to the
presses, as needed, with excess recovered solvent serving as a by-
product for sale to the ink manufacturer or others.  All model plants
include a waste water stripping operation to remove most of the dissolved
solvent content and recycle the resultant stripped condensate as make-up
feed water to the plant steam boiler.  The condensate stripper is a
steam heated vertical packed column made of stainless steel.  The solvent
stripping medium is provided by ambient air pulled up through the column
by the SLA fan.
     Several utilities are required for operation of fixed-bed carbon
adsorption control systems.  Steam for regenerating the carbon beds and
heating the condensate stripper is provided by an on site boiler.  The
boiler is assumed to be fired by natural gas half the time and fuel oil
half the time.  The boiler flue gas emissions are vented directly to the
atmosphere.  Cooling water is provided by an on site cooling tower.
Make-up water for cooling tower and boiler blowdowns and other water
losses is provided by the normal plant water supply.  Electricity for
running the SLA fans, miscellaneous pumps, boiler and cooling tower
support systems, and control instrumentation is provided by power supply
generated from offsite facilities.
6.2.1  The Printing Operation
     The two main printing operation characteristics which identify the
model plants are the hourly production rate capacity and the press
operating or printing time.  The potential production capacity is described
in terms of the average hourly total solvent consumption rate.  The
                                  6-4

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plants' solvent usage capacity is directly related to the number of
production presses, the press widths, and the press speeds.  As described
in Chapter 3, the raw ink composition, the ink coverage, and the paper
weight all vary for each production run; however, the mixed ink consumption
as applied to the gravure printing cylinder must be controlled within a
narrow range for good quality gravure printing.  Consequently, total
solvent consumption is the best indicator of production capacity.  Since
the production presses are assumed to be all the same size, the large
model plant then consumes twice as much solvent as the small plant.  The
yearly average press printing time is assumed to be 65 percent of the
scheduled operating time.  This assumption is based on the plant test
data presented in Appendix C, as explained in Chapter 3, combined with
                                              1 2
industry information on historical operations. '
     The potential amount of VOC emissions are equal to the total amount
of solvent consumed in the printing process.  The total amount of solvent
includes the solvent in the raw inks, solvent in any extenders/varnishes
used, and the solvent added at the press.  A general volumetric relationship
among raw ink usage, recycled recovered solvent, total solvent consumption,
and expected emissions at three overall VOC control levels is presented
in Figure 6-2.  Raw ink, as purchased, typically averages about 50 volume
percent solvent and 50 volume percent nonvolatile components.  The raw
ink is then diluted in a one-to-one volume ratio with solvent.  For
simplicity, extender/varnish quantities are not shown as these are
usually very small compared to the raw ink usage.  A solvent make-up
allowance is included to cover evaporative losses from the ink fountain.
The resultant 80 percent solvent volume ink mixture applied at the press
is typically the composition required to control ink viscosity for high
quality gravure printing.  All of the nonvolatile ink components and
about three percent of the total solvent used leave the press with the
printed product (see Chapters 3 and 4).  These product retained solvents
are considered VOC air pollutants since they will eventually evaporate
from the product.  Finally, the material balance shows the amount of
                                  6-5

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          Purchased
              Ink
                               Printed
                               Product
                                                                              0.44  S
                1.00 N+S
                                    0.50 N
                                    0.06 S
                                                             0.34 S
                                                                                            0.24  S
                                                                    Direct Solvent
                                                                    Vapor Emissions
          Raw  Ink
          Storage

            50% N
            50% S
0.50
0.50 S'
  Ink
Fountain
 25% N
 75% S
0.50 N.
                     1.50 S
Printing
Press
  20% N
  80%S
                                           1.94 S
                                      1.00  S
                                      Dilution
T
          Solvent
          Storage

          100% S
                                             0.50 S Makeup
                     Captured &
                     Fugitive
                     Solvent
                     Vapors
                                                                                75%
                                                                80%
                                                             85%
Overall Solvent
   Recovery
  Efficiency
                                                                              1.50  S
                                                             1.60 S
                                                                                             1.70  S
                                                                    Recovered
                                                                    Solvent
                                                 1.50  S  Recycle
                                              75%
                                          80%
                                         85%
                                                                                0  S
                                                                                                      Solvent
                                                                                                      Sales
                                                                                     0.10  S
                                                                                             0.20  S
        Legend
        N - Volume  quantity  of  nonvolatile  ink  components  (resins,  pigments,  varnish)
        S - Volume  quantity  of  liquid  solvent (or equivalent  liquid volume  of solvent vapors)
        Basis:  -   Recovered solvent at  the same temperature  as  solvent  and ink  used at the  press
                -   Three  percent  of solvent retained  in printed  product
                -   Total  solvent  vapor emissions include direct  vapor  emissions  from control device  outlet
                    losses and fugitive press losses,  as well  as  solvent  retained in  product
                        Figure 6-2.   Schematic  ink  and  solvent  volume material  balance around a
                                     publication  rotogravure  model  printing  facility with  solvent
                                     recovery control at  three  regulatory alternative levels.

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surplus or by-product recovered solvent (for sales) at the three overall
control levels.  Overall control pertains to the total amount of solvent
used at the press.  The solvent volume balance is based on the assumption
that the recovered solvent is at the same density (i.e. temperature) as
the solvent used at the press.
6.2.2  Model Plant Parameters
     Three regulatory alternatives are applied to each model plant size
considered.  The regulatory alternatives considered result from variations
in both capture and carbon adsorber efficiencies.  The basis for the
regulatory alternatives that were chosen is explained in a later section.
A complete description of the resulting six model plant cases is presented
in Table 6-1.  The following assumptions were used to calculate the
material balances for each case:
       •  Only dryer exhaust solvent vapors are captured for the 75 and
          80 percent overall control efficiency cases.  The SLA flow
          rate for each unit represents typical modern design practice
          to maintain the organic vapor concentration at about 20 percent
          of the lower explosive limit (LEL) level.3'4'5'6
       •  Fugitive solvent vapors are captured with the dryer exhausts
          for the 85 percent overall control efficiency cases.  The
          fugitives capture-air flow is based on the design air flow
          rate through the Meredith/Burda cabin enclosure.
       •  Typical total solvent volume consumption capacity rate for
          each production press is 454 liters/hr (120 gallons/hr).  '
          The actual  average usage rate is about only 65 percent of the
          capacity because of frequent press shutdowns, as explained in
          Chapter 3.
       •  Typical raw ink volume usage is based on the two-to-one volume
          ratio of total solvent consumption to raw ink usage shown in
          the general  material balance schematic presented in Figure 6-2»
       •  The solvent used is a typical naphtha-based (lactol spirits)
          mixture consisting of the components described in Chapter 7, with
          an average  liquid density of 0.742 kg/liter (6.2 Ibs/gallon).10'11'12
                                    6-7

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                                                         TABLE  6-1.    MODEL  PLANT PARAMETERS
Plant Size
Production Presses/units
Press data
Speed, m/5 (ft/mln)
Web width, m (In)
Average overall control efficiency
Average control device efficiency
Average Capture Efficiency
Approximate operating time (65% of
scheduled)
Typical design SLA* dryer/fugUlva
flow rate (per unit, production press)
Flow, tlm'/hr
(SCFM)
Estimated SLA flow rate (proof press)
Flow, Nm'/hr
(SCFM)
Estimated design SLA bulk conditions
(to control system)
Flow, m'/hr (ACFH)
Concentration", q/m' (ppmv)
Temperature, 'C I'f)
Typical raw Ink consumption,
1/hr (gal/hr)
Typical mixed ink consumption,
1/hr (gal/hr)
Typical total solvent consumption
1/hr (gal/hr)
Potential^emissions @65% on-line factor,
Mg/yr (tons/yr)
Expected emissions0 with controls,
Mg/yr (tons/yr)
Small
2/8 units each

10.16 (2000)
1.83 (72)
751
90%
84%
4740 hrs/yr
4250/0
(2500/0)
16.990
(10,000)
90,560 53,300)
7.45 1980)
41 105)
456 (120)
1136 (300)
908 (240)
3198 (3525)
798 (880)
Small
2/8 units each

10.16 (2000)
1.83 (72)
SOX
951
SSI
4740 hrs/yr
4670/0
(2750/0)
16.990
(10.000)
97.800 57,560)1
7.20 1920)
4V 105)
456 (120)
1136 (300)
908 (240)
3198 (3525)
640 (705)
Small
2/8 units each

10.16 2000)
1.83 72)
851
951
90t
4740 hrs/yr
4250/2125
(2500/1250)
16,990
(10.000)
126,790 (74,620)
5.60 (1480)
41 (105)
456 (120)
1136 (300)
908 (240)
3198 (3525)
473 (530)
Large
4/8 units each

10.16 (2000)
1.83 (72)
75%
901
84%
4740 hrs/yr
4250/0
(2500/0)
16,990
(10,000)
163,020 (95,940)
7.45 1980)
41 (105)
912 (240)
2272 (600)
1816 (*80)
6396 (7050)
1596 (1760)
Large
4/8 units each

10.16 (2000)
1.83 (72)
80%
951
851
4740 hrs/yr
4670/0
(2750/0)
16,990
(10,000)
177,510 104,470)
7.20 1920)
41 (105)
912 (240)
2272 (600)
1816 (480)
6396 (7050)
1280 (1410)
Large
4/8 units each

10.16 (2000)
1.83 (72)
851
95%
901
4740 hrs/yr
4250/2125
(2500/1250)
16,990
(10.000)
235,490 (138,590)
5.60 (14flO)
41 (105)
912 (240)
2272 (600)
1816 (480)
6396 (7050)
946 (1060)
00
              ?SLA - solvent laden air
              ^he actual  operating concentration varies greatly with operating conditions (estimated to  be 85% of design).
              GThese figures assume that any  solvent Initially retained in the printed product  is an air  pollutant.

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       •  Solvent vapor concentration in the SLA to the control system
          is determined from the cumulative SLA flow rate from the
          production presses combined with the assumed captured amount
          of evaporated solvent.
       •  Ink and solvent usage by proof presses is negligible and not
          included,
       •  Typical scheduled press operation time is about 7,296 hrs/yr,
          based on 24 hrs/day, six operating days/week, with eight holidays/hr.
6.2.3  Solvent Vapor Capture System
     The purpose of the solvent vapor capture system is to gather the
VOC vapors emitted from the presses and direct these vapors to the
control device.  The ultimate efficiency of any capture system is limited
by the amount of solvent retained in the printed product and by the
numerous fluctuations in the rotogravure printing process, as explained
in Chapters 3 and 4.  The capture efficiency used for each model  plant
case presented in Table 6-1 is the average long-term efficiency that is
expected for printing the full range of products handled in this industry.
     Three capture efficiencies are used for the development of the
six model  plant cases.  The lowest capture efficiency is assumed to be
about 84 percent.  This represents capturing just the dryer exhausts
from the least expensive, older-type design printing presses.  These
press designs allow fugitive emissions to occur by solvent vapor losses
from open areas of the press, exposing parts of the ink fountain, the
gravure printing cylinder, and the paper web.  A typical capture-air
flow rate of 4250 Nm3/hr (2500 SCFM) is assumed for each printing unit
dryer.  As explained in Chapters 3 and 4, the pressroom is ventilated
with roof or peripheral fans discharing fugitive vapors directly to the
atmosphere with these type press capture designs.
     The second capture efficiency is assumed to be slightly higher at
about 85 percent.  This represents capturing just the dryer exhausts
from more expensive, modern-design presses.  These newer designs help to
minimize fugitive vapor losses by enclosing the ink fountain and extending
the lower end of the enclosed dryers down closer to the printing cylinder
along with about a ten percent increase in the dryer air flow rate.
Pressroom ventilation is required for this type capture design also.
                                    6-9

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     The highest capture efficiency is assumed to be at least 90 percent.
This represents capturing the dryer exhausts from modern-design presses
along with most of the fugitive vapors emitted from the presses.  The
total capture-air flow rate for each printing unit is increased by
50 percent over that for the older-type press designs.   For these model
plant cases, pressroom ventilation is not required.  The fugitive vapors
are assumed to be captured by —
        • A partial  enclosure fugitive vapor capture system that is
          vented to  the control device; or
        • A system of multiple fugitive vapor capture vents that are
          located around the press and collectively ducted to the control
          device; or
        • Total pressroom ventilation air that is directed to the control
          device.
     An ideal  solvent vapor capture system, which is not considered in
the model  plants, would be designed to further concentrate the solvent
vapors in the dryer  exhausts.  As explained in Chapters 3 and 4, technology
and instrumentation  are available to control and safely concentrate the
organic vapors in the dryer exhaust SLA to about 50 percent of the lower
explosive limit (LEL) level.  This practice could minimize the SLA
volumetric flow rate that must be handled.  In comparision, the dryer
exhaust SLA vapor concentrations shown in Table 6-1 are at the 19 to
20 percent of LEL level.  Therefore, the model plant emissions control
systems are conservatively oversized.  This capture design feature is
not included in the  model plants because solvent vapor analyzer/controllers
are generally not presently utilized in this industry.   The plant personnel
feel that they would rather handle an excess amount of air to be safe
instead of minimizing the air flow rate for decreasing the required size
of the emission control equipment and increasing the control device
efficiency.
6.2.4  Solvent Laden Air Treatment
     Fixed-bed carbon adsorption/solvent recovery systems are used as
the emission control devices for all model plants.  The average efficiency
                                   6-10

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of these control devices is limited by the design solvent vapor concentration
in the SLA treated, as well as wide variations in the vapor concentrations
caused by fluctuations in the printing process.  The control device
efficiency used for each model plant case presented in Table 6-1 is the
average long-term efficiency that is expected over normal printing
periods, as well as during the numerous routine press shutdowns.
     Two control device efficiencies are used for the development of the
six model plant cases.  The lowest efficiency is assumed to be about
90 percent; the highest efficiency is assumed to be at least 95 percent.
The lower efficiency represents the performance of the least expensive,
older-type design carbon adsorber systems.  The higher efficiency represents
the performance of the more expensive, modern-design adsorbers.  These
control device efficiencies are thoroughly discussed in Chapter 4.
     As shown in Figure 6-1, the model plants include an extra carbon
bed vessel.  This extra vessel is required for all fixed-bed adsorber
systems to allow for the regeneration mode, while the other vessels
handle the full SLA flow rate.
6.3  REGULATORY ALTERNATIVES
     Three regulatory alternatives were considered.  These alternatives
call for an overall reduction of VOC emissions at 75, 80, and 85 percent
levels.  These three alternatives were selected to represent the various
emission control levels which are achievable, based on the discussion of
the emission control techniques in Chapter 4.  The three alternatives
were applied to the two plant sizes considered to develop the six model
plant cases shown in Table 6-1.  The overall VOC control efficiency is
equal to the capture efficiency times the emission control device efficiency.
As previously mentioned, regulatory alternatives were not developed
specifically to represent VOC emissions reduction by low-VOC, waterborne
ink system usage.
     The 75 percent overall control level represents capturing and
treating the dryer exhausts from the least expensive, older-type design
presses with the lowest cost, older-type design carbon adsorber systems.
                                  6-11

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This is considered to be the baseline control  level.  This corresponds
to the control  techniques guidelines (CTG) recommendation for existing
rotogravure printing facilities, which the states are expected to use in
revising their State Implementation Plants (SIP).    This control level
is achievable by capturing about 84 percent of the potential solvent
vapors from the press with a 90 percent adsorber efficiency.
     The 80 percent overall control level represents capturing the dryer
exhausts from new, well-designed presses.  In this case 85 percent
capture would be required with a 95 percent efficient adsorber.  This
corresponds to a typical, well controlled modern facility.  Overall VOC
emission reductions of 80 to 84 percent were determined from short term
test data and five months of plant data at Texas Color Printers  plant.  '  '
In addition, over four months of plant data from World Color Press
showed four-week average overall VOC control efficiencies ranging from
78 to 84 percent.
     The 85 percent regulatory alternative represents capturing  the
dryer exhausts from modern-designed presses, as well as some of  the
fugitive solvent vapors.  This  is  intended to correspond  to about 90  percent
capture of the solvent vapors emitted from the facilities with a 95 percent
efficient adsorber.  The results of operating data  obtained from the
Meredith/Burda, Texas  Color  Printers, and Standard  Gravure  plants are
discussed  in Chapter 4.  The  analysis presented  in  Chapter  4 shows  the
following:
       •  The  Meredith/Burda  overall  VOC  emission control efficiencies,
          after adjustment  for  density  (temperature) correction  and
           infiltration of  solvent  vapors, are —
           —   89  to 91  percent  by  short-terrn  tests; and
           —   84  to 91  percent  by  monthly plant  data.
       •   The  Texas Color  facilities  could  potentially achieve about
           88 percent overall  VOC control  by  directing  their ventilation-
           floor  sweep  vents into the  carbon  adsorber system,  rather than
           to the  atmosphere.
                                    6-12

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       •  The four-week average overall VOC control efficiencies reported
          by the Standard Gravure plant range from 85 to 90 percent.  '
     The data base shows that application of the best demonstrated
technology will achieve about 90 percent overall VOC control at times,
with certain type products.  However, only about 85 percent overall
control is achievable in the typical plants in this industry when printing
some other products.  The 85 percent control level is the maximum that
can be expected to be continually achieved.  This regulatory alternative
allows for expected efficiency variations in both the capture and adsorber
systems, combined with larger amounts of solvent retained by some printed
products.
     The resultant expected annual emissions from application of each
regulatory alternative is shown in Table 6-1.  The reduction in solvent
emissions or amount of recovered solvent is equal to the difference in
potential and expected emissions.  The potential emissions are the
annual amounts of total solvent consumption, assuming actual press
operation at 65 percent of scheduled time.
     The environmental and energy impact analyses of the VOC emission
control systems for the six model plant cases is presented in Chapter 7.
The economic impact analyses are presented in Chapter 8.
                                   6-13

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6.4  REFERENCES
1.   Letter and attachment from Fremgen, R.D. - Dayton Press, Inc., to
     Reich, R.A., Radian Corporation.  April 6, 1979.  Comments on
     preliminary draft of Model Plant Parameters.
2.   Telecon.  Gugler, H., Meredith/Burda, Inc., with Burt, R.C., Radian
     Corporation.  January 11, 1980.  Press operating time.
3.   Feairheller, W.R.  Graphic Arts Emission Test Report, Meredith/
     Burda, Lynchburg, Virginia.  Monsanto Research Corporation.  Dayton,
     Ohio.  EPA Contract 68-02-2818-16, EMB 79-GRA-l.  April 4, 1979.
     p. 17.
4.   Trip Report.  September 15, 1978 plant visit to Meredith/Burda, Inc.,
     Lynchburg, VA.   Reich, R. A.  - Radian Corporation.  October 26, 1978.
     p. 6.
5.   Trip Reprot.  September 7, 1978 plant visit to Alco-Gravure, Inc.,
     North Hollywood, CA.  Reich,  R. A. - Radian Corporation.  October 19,
     1978.  p. 3.
6.   Trip Reprot.  July 24, 1978 plant visit to R. R. Donnelley & Sons
     company, Chicago, IL.  Reich, R. A. - Radian Corporation.  August 24, 1978.
     p. 4.
7.   Reference 3, p.  18.
8.   Reference 1.
9.   Reference 3, p.  5, 17.
10.  Feairheller, W.R.  Graphic Arts Emission Test Report, Texas Color
     Printers, Dallas, Texas.  Monsanto Research Corporation.  Dayton,
     Ohio.  EPA Contract 68-02-2818-20, EMB 79-GRA-3.  October 19, 1979.
     p. 14.
11.  Reference 1.
12.  Letter and attachment from Verdooner, Marcel - Alco-Gravure, Inc., to
     Reich, R. A. -  Radian Corporation.  November 13, 1978.  Response to
     Section 114 request letter.
13.  Control of Volatile Organic Emissions from Existing Stationary
     Sources - Volume VIII:  Graphic Arts - Rotogravure and Flexography.
     EPA-450/2-78-033, OAQPS No. 1.2-109, U.S. Environmental Protection
     Agency.  Research Triangle Park, NC  27711.  December 1978.
                                    6-14

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14.  Reference 10, 185 pages.
15.  Letter from MacAskill, P.R.-Texas Color Printers, to Reich, R.A.-
     Radian Corporation.  July 3, 1979.  Solvent Recovery.
16.  Letter and attached test reports from George, H.F. - Gravure
     Institute, Inc., to Vincent, E.J. - U.S. EPA.  February 7, 1980.
     Attached June 4, 1979 memorandum on tests at Texas Color Printers,
     32 pages.  Response on cancellation of meeting and response to
     request letter for test data.
17.  Trip Report.  May 9, 1979 plant visit to World Color Press, Salem,
     Illinois.  Edwin Vincent - U.S. EPA.  June 14, 1979.
18.  Trip Report.  May 6, 1980 plant visit to Standard Gravure,
     Louisville, KY.  Richard C. Burt - Radian Corporation. June 6,
     1980.
19.  Marvin, R.L.  Recovery and Reuse of Organic Ink Solvents.  (C&I/
     Girdler, Inc. Louisville, KY.  (Presented at the Conference on
     Environmental Aspects of Chemical Use in Printing Operations.
     King of Prussia.  Sept. 22-24, 1975).  25 p.
                                    6-15

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                 7.  ENVIRONMENTAL AND  ENERGY  IMPACTS

     As discussed in Chapter 3, the volatile organic compounds  (VOC)
emissions from a rotogravure publication  printing  plant  result  from the
evaporation of the printing solvent.  This  solvent  originates from the
purchased ink, extenders, and varnishes,  and the solvent which  is added
to the ink at the press.  A small amount  of additional solvent  is used
for cleanup purposes.   In an uncontrolled plant the entire  amount of
solvent is vented to the atmosphere.
     Emission control techniques were identified in Chapter 4 as possible
candidates for the emission control system.  Carbon adsorption  using  fixed
adsorption beds represents the most popular method.  In  the past, some
states did not require the use of an emission control system if a "non-
photochemical ly" reactive solvent was used.  Presently,  the states are
governed by new State Implementation Plans  (SIP's).  These  SIP's are  based
on a Control Techniques Guideline (CTG) document  for this  industry.
The CTG recommends at least a 75 percent  overall reduction  from existing
sources in oxidant non-attainment areas.
     Fixed-bed carbon adsorption systems  are commonly used  in the industry.
Typical existing systems, however, have a lower overall  control efficiency
than that of a system which might be considered the best-demonstrated
control system.
     Incineration has not been used by the publication rotogravure industry
because it is more economical  to recover  the solvent.  The  first fluidized
carbon bed system to be used by the publication rotogravure  industry  in
this country began operation in 1979.  No operating data on  this system
is available.
     In this chapter, the air, water, solid waste, and noise pollution
impacts,  as well  as energy impacts are examined for the three regulatory
alternatives described in Chapter 6.   These impacts are examined for
individual  model  plants and for the nationwide effect.
                                     7-1

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7.1   AIR POLLUTION IMPACT
7.1.1   Emissions Fron Rotogravure Publication Printing Plants
     Emission estimates discussed in Chapter 3 indicate that about
56,800 Mg (62,600 tons) of solvent were emitted to the atmosphere by the
publication rotogravure printing industry in 1977.  Of this total, about
44,400 Mg (49,000 tons) were emitted from uncontrolled sites.  The total
potential emissions during this period were about 137,200 Mg (151,200
tons).  Considering recent trends in the industry, it is assumed that if
no Mew Source Performance Standards (NSPS) are promulgated by the EPA,
state regulations and economic considerations will require CTG provisions
for at least a 75 percent overall reduction of VOC emissions.  If a
75 percent control were applied to the uncontrolled sources, the 1977
total emissions would have been reduced to about 23,500 Fig (25,900 tons).
     The seven percent growth projections discussed in Chapters 3 and 8
indicate that the output of the publication rotogravure printing industry
will almost double between 1976 and 1986.  Table 7-1  illustrates the
air pollution impact, resulting from the implementation of NSPS at the three
different levels  of control.  The NSPS proposal date  is set  for mid-lQBO.
Estimated emissions during the five-year period from  1981 to 1985 are
illustrated in this table.  The estimates assume that all presses installed
before 1980 would  be controlled at only the 75 percent level.  Only the
new "affected" presses would  be controlled at  the two higher levels.
7.1.2  Primary Air Pollution  Impacts
      7.1.2.1  Chemical Composition.   In some  instances, toluene  is  used
alone as the  solvent in  a publication  rotogravure facility,  but  the
solvent  most  used  by the  industry  is  a petroleum  fraction which  distills
in  the 93-127°C  (200-260°F) range.  This  solvent  fraction  is commonly
                                                                    234
called VM&P naphtha, lactol spirits,  or one  of several trade names.  '  '
It  consists mainly of  Cf  to C-,  paraffins  and  cycloparrafins, and  Cj to
C0  aromatics, namely toluene, xylene,  and  ethyl benzene.   Benzene  and
  o
olefin content  are very  low and  are carefully limited.
      The solvent compositions used  by the  printers  varies  according to  the
ink used and  other printing conditions.   Where state  regulations  specify  a
"nonphotochemically  reactive" or  low  photochemical  reactive  solvent,  the
                                     7-2

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                 TABLE 7-1.  ESTIMATED VOC EMISSIONS FROM PUBLICATION ROTOGRAVURE PRINTING INDUSTRY
                                 AT THREE ALTERNATIVE NSPS LEVELS, Mg/yr (tons/yr)
Year
1977
1979
1980
1981
1985
Potential
Uncontrol led
Emissions9
137,000 (151,000)
157,000 (173,000)
168,000 (185,000)
180,000 (198,000)
236,000 (260,000)
NSPS Overall Control Level sb
75%
34,300 (37, 800) C
39,300 (43,300)
42,000 (46,300)
45,000 (49,600)
59,000 (65,000)
80%
—
—
41,500 (45,700)
43,900 (48,300)
55,000 (60,600)
85%
—
—
41,000 (45
42,800 (47
51,100 (56


,100)
,000)
,300)
CO
         Seven percent annual real growth rate assumed.

         All presses installed before 1980 controlled at only the 75% level.   New Source Performance
         Standards (NSPS) affect only new presses installed during or after 1980.

        cActual 1977 VOC emissions were about 56,800 Mq  (62,600 tons), representing an Industrywide overall
         control  average of about only 60 percent.

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aromatic content is limited to less than 20 percent..  In many instances the
aromatic content is limited to less than 20 percent due to high toluene and
xylene levels.  The blending of naphtha, toluene, and xylene affect the
drying rate of the solvent.  Xylene retards the drying, while naphtha
hastens it.
     7.1.2.2  Photochemical Characteristics.  It is a well-known fact that
the major cause of smog is photochemical reaction which starts with the
organics in the air and ends up with a cloud of irritating chemicals.  The
VOC emitted from this industry, in the presence of NO  (nitric oxide or
                                                     A
nitrogen dioxide) and ultraviolet irradiation (sunlight), can react to
form various toxic compounds, such as aldehydes, ketones, PAN, ozone, and
other oxidants.  Thus, the toxicity of the solvent component vapors is
regarded as of lesser importance than the toxicity of their reaction products
This effect is very pertinent to the study of this industry since most of
the printing plants are located within or very close to urban areas.
Therefore, reduction in VOC emissions would result in less formation of
snog and irritating chemicals.
     In the early "I970's many SIP's similar to Los Angeles' Rule 66 were
promulgated.  These SIP's allowed the substitution of "nonphotochenically
reactive" solvent for "photoreactive" solvent as an acceptable control
method.  Many of these SIP's allow unlimited emission of  "nonphotochemically
reactive" material.  According to their definitions, only the aromatics
used by the rotogravure industry are considered "photochemically reactive".
     However, recent reactivity studies indicate that though they are
not as  reactive as the aronatics, the C.  paraffins arid cycloparaffins
                                                             r- /;
react in the atmosphere to form significant amounts of ozone.  ' '  Their
reactivities have been estimated to be about one-third to one-half that
of toluene at a hydrocarbon-to-NO  ratio of 2, considered typical for an
                                 A
urban environment.  These  reactivities appear to increase as the HC/NO
                7
ratio  increases.
     On the basis of these studies, the EPA has acknowledged that if
Rule 66 were revised to be consistent with  current  knowledge of reactivity,
the solvent substitution  option would be eliminated for most sources  which
                                    7-4

-------
           o
now use it.   For these reasons, the solvent composition is not expected
to play any significant role in the development, promulgation, or enforcement
of NSPS for this industry.
     7.1.2.3  Toxicities.  The toxic properties of the components in the
typical mixed solvents are important considerations for the workers and
operators in the pressroom of the printing plants, as well as for the
surrounding environment outside the plants.  Adequate ventilation is
required to maintain the solvent vapor concentrations in the pressroom air
below the OSHA regulation levels.  In addition, Threshold Limit Values (TLV),
which are equal  to or below OSHA levels, have been recommended as health
hazard guidelines by the American Conference of Governmental Industrial
Hygienists (ACGIH), a private organization.  Measurements during tests at
the Texas Color plant showed that the ventilation air discharged directly
to the atmosphere from pressrooms can contain solvent vapor concentrations
ranging from about 200 to 400 ppm (V/V).  The dryer exhausts solvent laden
air (SLA) vapor concentrations can range from a low of about 1500 ppn to a
maximum, allowed by insurance guidelines of up to about 5,000 ppm, depending
on the solvent blend.  In an uncontrolled plant, both the dryer exhausts and
ventilation air are discharged directly to the atmosphere.  These vents
are usually located on the plant roof to help disperse and dilute the solvent
vapors.  However, the solvent vapors, being heavier than air, will have
a tendency to settle back to the ground.  The locations at which the solvent
vapors may settle or concentrate in the surrounding environment depend upon
the atmospheric conditions.
     The toxic effects of several representative mixed solvent airborne
component vapors are presented in Table 7-2.  Toluene is considered a more
powerful narcotic and more acutely toxic than is benzene.  However, benzene
has been shown to pose a greater long term health hazard and has, therefore,
been essentially eliminated from rotogravure solvents.  The acute toxicities
of xylene and ethyl benzene are considered comparable to each other and
greater than that of toluene.  No studies have been made on the chronic
toxicities of xylene and ethyl benzene in man.  Normal paraffins in the
C  and C  range are classified as central nervous system depressants.
                                    7-5

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                          TABLE  7-2.
                         TOXIC  EFFECTS  OF  REPRESENTATIVE  ROTOGRAVURE  SOLVENT
                           mMDnWFMT VAPORS  TW  ATRy»  IU»  ''»   ' *-
                                             COMPONENT VAPORS  IN  AIR
                ,  v«P°r.«       Toluene
                Concentration
                           Commercial xylene     Ethyl benzene
                       N-HepUne
                                                                                                        N-Hexine
                                                                                                      Cyclohexane     Methylcyclohexane
                  100
                         i TLV
                          • OSHA TWA
                          • TLV
• OSHA TWA
• TLY
                                                                                                       • TLV
                  174
                  200
                         • OSHA TWA
                          • Affects central
                            nervous system
                            1n mice.
                         • Fatigue, confusion,
                           parentheslas of skin
                           In mn after 8 hrs.
                                             t Acute eye Irrita-
                                              tion In man.
                                              Intensity of 1
                                              or 2.
en
300     • OSHA Celling

       • Above symptoms more
        pronounced.
                                                                                                                     •  OSHA TWA

                                                                                                                     •  TLV
                  400
                  500
         Mental confusion 1ft
         nan after 8 hrs.
                   • TIV


                   • OSHA TWA
                                                                                                   t  OSHA TWA
                                                                                                                                           • TLV


                                                                                                                                           • OSHA TWA
                  600
                   786
       • Extreme confusion,
         exhilaration,
         nausea, dizziness In
         man after 3 hours,
         symptoms more
         pronounced after
         8 hrs.

       • Dilated pupils,
         Incoordlnation.
         Insomnia after 8
         hrs.
                                                                                                   • Liver and kidney
                                                                                                     changes  1n rabbits
                                                                                                     after 6  hrs/day,
                                                                                                     50 days.
                   TLV « Threshold limit value, TVA recommended by ACSIH
                   TWA • 1-hour tine weighted average exposure.
                                                                                                                                         (continued)

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                                                                         TABLE  7-2  (continued).
                       Vapor
                   Concentration
       Toluene
                     Coimerclal xylene     Ethyl  fcenzene
                     N-Heptane
                       N-Hexane
                                                                                                     Qyclohexane
                                                                           Methylcyclohexane
                        1000
                        1150
                        2000
 I
•-J
                                       • Acute eye Irri-
                                         tation in man.
                                         Intensity of 3.
                    • Decreased leuko-
                      cytes and red
                      blood cells.
                      Increased
                      platelets 1n
                      rabbit after
                      8 hr/day, 6
                      days/week for
                      55 days.
                        2700


                        3300
• Acute prostration
  1n mice.
                • Slight vertigo tn
                  man after 6
                  minutes.
                                        • Acute  severe
                                          eye Irritation,
                                          lacrlmatlon,
                                          Irritation  of
                                          nasal  menfcranes
                                          1n man.
                                        • Dizziness In  man
                                          after 6 minutes.
                 •  Slight  vertigo
                   1n man  after 6
                   minutes.
                  • No symptoms In man
                    after 10 minutes.
                                                                                                                       • Minor kidney and
                                                                                                                         liver Injury In
                                                                                                                         rabbits after
                                                                                                                         S hrs/day,  70  days.
                         3500


                         4000



                         4700


                         5000
  Death In animals
  after a few 4-hour
  exposures.
 •  501  fatalities In
   nice after 8 hr».
                                        • Acute prostration
                                          In mice.
                      t Acute prostration
                        in mice.
Intolerable
acute irrita-
tion of eyes
and nasal  mem-
branes In man.
• Harked vertigo,
  hilarity.
  Incoordfnatlon
  In man after 4
  minute* (no Irri-
  tation of mucous
  mctnbranes).
t Uncontrolled
  hilarity or stupor
  1n nan after IS
  minutes.
Dizziness  1n man
after 10 minutes.

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Toxicities of branched paraffins in the Cg to C-, range are generally
unknown, but these substances are suspected to have narcotic or anesthetic
                                                                     13
properties.  Cycloparaffins have a narcotic effect on the human body.
Methyl cyclohexane is considered three times as toxic as hexane.  Little
is known of the chronic toxicities of the eyeloparaffins.    The toxicities
of other components are assumed to be similar.  No data on the toxicity
of the entire solvent mixture has been found in the literature.  This
table shows that although toluene, xylene, and ethylbenzene are obviously
toxic, other components of the publication rotogravure solvent may also
be health hazards.
7.1.3  Secondary Air Pollution
     Emissions of air pollutants from two secondary sources result from
the generation of energy required for operation of fixed-bed carbon
adsorption control systems.  The main source of secondary air pollution
results from the fuel combustion to produce steam.  The steam is used to
regenerate the carbon beds and recover the solvent, at an assumed constant
ratio of 4 Kg steam per Kg recovered solvent.  The steam boilers are
located on the plant, site.  Secondary air pollutants also result from
electrical power generation.  The electrical power is required to drive
the large SLA fans, cooling tower pumps and fans, boiler pumps and air
fans, and all emission controls instrumentation.  The electrical power
plants are separata off-site facilities.
     The relationship between secondary air pollutant emissions from
steam production arcl the reduction in primary VOC emissions, or recovered
solvent, is presented in Table 7-3 for the three overall control levels
considered.  Estimates are presented for  large model plants only, with
projections for nationwide impacts in the year 1985.  Total secondary
emissions consist of particulate matter,  carbon monoxide, unburned
hydrocarbon, sulfur oxide  (SOV) and nitrogen oxide (NO  ) components  in
                             X                        X
the flue gases from the boiler combustion chambers.  The resulting fuel
combustion emissions are estimated from published factors for uncontrolled
industrial boilers.  '     The boilers are assumed to be  fired by distillate
grade fuel oil with a one  weight percent  sulfur content  half of the
                                      7-8

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TABLE  7-3.   SECONDARY  AIR  POLLUTION  IMPACTS  OF  STEAM  PRODUCTION  AND  ELECTRICAL  POWER  GENERATION  FOR
               CONTROL OF VOC EMISSIONS  BY  FIXED-BED  CARBON  ADSORPTION/SOLVENT RECOVERY  IN THE
               PUBLICATION ROTOGRAVURE  INDUSTRY, Mg/yr (tons/yr)a
Items
Secondary "HC* emissions for
large model plant :b
Total secondary emissions
for large model p1ant:c
Separate:
Combined:
Estimated recovered solvent
from large model plant:
Projected national total
secondary emissions for 1985:
Separate:
Combined:
Projected national recovered
solvent for 1985:
Overall Solvent Recovery Efficiency
75X
Steam Electrical
Power
0.13
(0.14)

18.72 5.41
(20.58) (5.96)
24.08
(26.54)
4800
(5290)

691 200
(760) (220)
890
(980)
177,110
(194,820)
BOX
Steam Electrical
Power
0.14
(0.16)

19.98 5.97
[21.96) (6.58)
25.90
(28.54)
5120
(5640)

706 211
(776) (233)
915
(1.009)
181.050
(199,160)
85S
Steam Electrical
Power
0.15
(0.17)

21.23 8.12
(23.35) (8.95)
29.30
(32.30)
5450
(5990)

720 276
(792^ (304)
995
(1.096)
184.990
(203.490)
Incremental VOC Control
75X-85X
Steam Electrical
Power
0.02
(0.03)

2.51 2.71
(2.77) (2.99)
5.22
(5.76)
650
(700)

29 76
(32) (84)
105
(116)
7.880
(8,670)
    "steam production by uncontrolled on-slte steam boilers fired by distillate grade fuel oil  50t of the tine and by natural gas SOX of the
     time - Reference 15,16; electrical power from controlled off-site coal-fired utilities (worst case) - Reference 17,18.
     Unburned hydrocarbons  In flue gases
    cTotal flue gas pollutants:  partlculate matter, SO . HC. and N0u
    A                                         XX
     See Table 6-1, difference between potential and expected emissions
    eScale
-------
time, and by natural gas half the time.  An 80 percent  thermal  efficiency
is assumed for each fuel usage.  Sulfur oxides (SO  ) are  the major
                                                  /\
pollutants in the flue gases from fuel oil combustion;  however,  nitrogen
oxides  (N0x) are the major pollutants of concern when burning  natural
gas.  In the future, however, flue gas emissions from new  industrial
boilers should be much lower than estimated in order to comply  with
federal emission standards now being developed.  In Table  7-3,  the total
secondary air pollutant emissions increase in a direct  proportion with
increased overall reduction in primary VOC emissions.   This is  because
of the  constant factors for steam usage to recovered solvent and flue
gas emissions per unit of fuel combustion.
     The relationship between secondary air pollutant emissions  from
electrical power generation and the reduction in primary VOC emissions
is also presented in Table 7-3.  An estimate of the quantity and type of
air pollutant emissions from electrical utilities is more  complex,
however, because of the wide range of processes and fuel resources used
(e.g., coal, fuel oil, natural gas, nuclear power, waterpower).  As a
worst case estimate, the electrical power is assumed to be generated by
coal-fired utilities,.   The coal is assumed to be Illinois  No. 6 bituminous
grade with 3.5 weight percent sulfur and 12.3 weight percent ash content.
The direct flue gases from the coal combustion were first  determined
from published factors for uncontrolled electric utility steam  boilers
which use the wet bottom pulverized process.     However, fuel combustion
emissions from these utilities are regulated under federal air  pollution
          18
standards.    Therefore, the resulting fuel  combustion emissions are
estimated for controlled utilities in compliance with the  federal emission
standards.  Sulfur oxides (SO ) and nitrogen oxides (NO )  are the major
                             x                         x
pollutants in the flue gases from the controlled utilities.
7.1.4  Air Pollution Impact Summary
     A very favorable air pollution impact is associated with the implemen-
tation of carbon adsorption equipment in this industry.   The potential
VOC vapor emissions from this industry, for the year 1985, are projected
to be about 236,000 Mg (260,000 tons).   If all  facilities were controlled
at the 75 percent baseline-level, the resulting emissions would be about

                                     7-10

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59,000 Mg (65,000 tons) per year.  The emissions would be reduced by
about an additional eight percent, if all new facilities were controlled
at the 80 percent level, with existing facilities controlled at the
75 percent level.  Similarly, the emissions would be reduced by about an
additional 13 percent over baseline control level, if all new facilities
were controlled at the 85 percent level.
     Emissions of air pollutants from two secondary sources result from
the operation of carbon adsorption control systems.  However, as shown
in Table 7-3, the total secondary air pollutants are estimated to represent
only about 0.5 percent of the corresponding VOC emission reduction from
the publication rotogravure presses.  Moreover, hydrocarbon vapors
makeup less than one percent of these total secondary emissions.  The
only combustion emissions of any significance are oxides of sulfur and
nitrogen.  Even these emissions are very low.  In conclusion, the
resulting total air pollutants emitted from secondary sources are expected
to represent only a very slight offsetting effect for control of VOC
emissions from publication rotogravure presses.
7.2  WATER POLLUTION IMPACT
     There are three potential sources of water pollution associated
with the model plants developed in Chapter 6.  The largest source is the
dissolved solvent in the condensate discharged from the decanter section
of the carbon adsorption system.  This condensate typically contains
from 130 to 200 ppm solvent, but can be as high as 1,900 ppm solvent,
                                                  19 20
depending on the solvent used and the temperature.  '    Potential
impact estimates representing condensate discharged untreated from the
model plants and projections for the year 1985 are presented in Table 7-4
for each regulatory alternative considered.  The estimates are based on
the assumption that only new "affected" presses would be controlled at
the higher regulatory levels, as explained in Section 7.1.1.  Comparison
of the results of Tables 7-3 and 7-4 show that the discharged organic
solvent content corresponds to less than 0.1 percent of the respective
VOC emission reductions, recovered solvent, from the presses.  Also,
this potential water pollution source could be virtually eliminated by
air-stripping the condensate and recycling the resultant solvent-free
                                    7-11

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                     TABLE 7-4.  POTENTIAL WATER POLLUTION IMPACTS FOR VOC EMISSION CONTROL
                                 ON MODEL PLANTS BY FIXED-BED CARBON ADSORPTION/SOLVENT
                                 RECOVERY SYSTEMS*
Items
Small plants
Total discharge flow, 10
(10° gallons/yr)
Organic solvent content,
(tons/yr)
Large plants
Total discharge flow, 10
(10° gallons/yr)
Organic solvent content,
(tons/yr)
Projected national dischar
year 1985
Total discharge flow, 10
(10b gallons/yr)
Organic solvent content,
(tons/yr)
liters/yr
Mg/yr
liters/yr
Mg/yr
ge for the
liters/yr
Mg/yr
Overall Solvent Recovery^ Efficiency
75%
9.60
(7-5?)
1.84
(2.00)
19.20
(5.08)
3.64
(4.00)
708.
(187.)
135.
(148.)
80%
10.24
(2.72)
1.96
(2.16)
20.48
(5.40)
3.88
(4.28)
724.
(191.)
138.
(152.)
85%
10.92
(2.88)
2.08
(2.28)
21.80
(5.76)
4.16
(4.56)
740.
(196.)
141.
(155.)
Incremental
75% -
1.
(0.
0.
(0.
2.
(0.
0.
(o.
32.
(9.
6.
(7.
VOC Control
85%
32
36)
24
28)
60
68)
52
56)
)
)
ro
      *Basis:
           1.
     Potential water discharge flow equal to steam usage at 4 Kg steam per Kg recovered solvent;
     water density at 1.0 Kg/liter (8.34 Ib/gal)
2.   Estimates of recovered solvent from Table 6-1 and Table 7-3
3.   Discharged water contains an average 190 ppm organic solvent

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water (less than about 5 ppm) as makeup feed water to the plant steam
boiler, as described in Chapter 4 and used in development of model
plants in Chapter 6.
     Alternatively, the solvent laden condensate could be discharged to
a conventional biological waste treatment system (e.g., activated sludge,
trickle filter).  At present, there are no Federal effluent regulations
specifically for the printing industry.  However, most State effluent
regulations are at least as stringent as the Federal regulations for
                                             2i
secondary treatment of municipal wastewaters.    These Federal regulations
would require a minimum 85 percent removal of the organic solvent content
in the discharged condensate and would allow only a maximum of 30 mg/L
of five-day biochemical oxygen demand (BODg), as averaged over 30 days.
BOD- is defined as the amount of oxygen required by the bacteria over a
five day period to reduce most of the organic matter to water and carbon
dioxide and provide new cell growth.
     The BODj- of a waste water stream is normally measured as the difference
in the dissolved oxygen content, determined from analyses of a sample of
the wastewater both initially and after five days.  However, the BODj. of
a typical condensate stream containing 200 mg/L (200 ppm) of toluene
solvent can be estimated by considering the following simplified general
biological reaction:
                                    Microorganisms
                    1 C?H8 + 9 02   	*- 7 C02 + 4 H20
                   Toluene  Oxygen               Carbon    Water
                                                 Dioxide
In addition, the BOD,, is usually about 70 percent of the ultimate required
                                                   ??
oxygen to totally remove all of the organic matter.    Therefore, on a
weight basis, the BODg for the typical condensate effluent would be
about 2.2 times the solvent concentration, or about 438 mg/L.  The
overall water pollution impacts from discharge of solvent containing
condensate would be small.  Under the 85 percent control  option a large plant
would discharge approximately 70 Ib BOD5/day which is an amount equivalent
to a population of 350 people.  The total  nationwide incremental  impact
                                   7-13

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would be about 30,000 gallons/day with a BOD5 concentration of 108
Ib/day (540 people equivalent).  The required removal  efficiency is
calculated to be about 93 percent to meet the 30 mg/L BODr level.  A
secondary impact resulting from biological  treatment of the waste water
is the production of sludge.  Sludge handling is discussed in the next
section on solid waste impacts.
     A second alternative would be treatment of the wastewater by carbon
           23
adsorption.    The use of activated carbon has been demonstrated to be
one of the most efficient organic removal processes.  The organic content
in the effluent can be reduced to below one mg/L BODr by activated
carbon treatment.
     Two other sources of water pollution resulting from carbon adsorption
control systems are the plant cooling tower and steam boiler blowdowns.
Dissolved organics and solids in these discharge streams represent only
minor sources of pollution compared to the condensate stream.  The
cooling tower water and steam usages increases in direct proportion to
the amount of recovered solvent.  The respective blowdown rates would
thus increase correspondingly.  These two sources are controlled under
State and local regulations.  No attempt is made to quantify the estimated
impacts of these two sources.
7.3  SOLID WASTE IMPACT
     There are two potential direct sources of solid waste material
resulting  from VOC emission control by carbon adsorption/solvent recovery
systems.  The first direct source is the activated carbon used in the
adsorber vessels.  Estimates of the potential amount of waste activated
carbon resulting from the model plants and industrywide projections
through the year 1985 are presented in Table 7-5.  As mentioned  in
Chapter 4, the activated carbon should not need to be replaced for at
least  five years for service in this industry.  Thus, the actual solid
waste  impact would more than likely be much lower than estimated.
Handling of the waste carbon should not  pose any significant problems.
The carbon can be sent back to the manufacturer for high temperature
                                     7-14

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                       TABLE 7-5.   POTENTIAL  SOLID  WASTE  IMPACTS FOR VOC  EMISSION CONTROL
                                   ON  MODEL  PLANTS  BY  FIXED-BED CARBON ADSORPTION/SOLVENT
                                   RECOVERY  SYSTEMS THROUGH  THE YEAR 1985,  MG (tons)*
Plants/facilities
Small plants
Large plants
Total 75 new presses
Overall Solvent Recovery Efficiency
75%
16.9
(18.6)
33.7
(37.2)
632.8
(697.5)
80%
18.0
(19.8)
36.0
(39.6)
675.0
(744.0)
85%
19.1
(21.1)
38.2
(42.2)
717.2
(790.5)
Incremental VOC Control
75% - 85%
2.2
(2.5)
4.5
(5.0)
84.4
(93.0)
en
      *Basis:
           1.
     Total  activated carbon usage is estimated from —
     a.  120 gallons/hr/press total  solvent usage — See Table 6-1;
     b.  2 hour adsorption time per cycle;
     c.  0.06 Kg solvent/Kg carbon adsorption capacity — See Table 4-1; and
     d.  0.742 Kg/liter (6.2 Ibs/gallon)  solvent density

2.    Activated carbon replacement required  only once every five years
       Projected  total  new presses  through  the year  1985  --  See  Chapter 8.

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regeneration.  In addition, the carbon could be incinerated, supplying
an excellent source of fuel energy.  Also, disposal  by landfill ing is
possible without any serious environmental problems.
     The second direct source of solid waste is the SLA filters.  These
filters are usually made of fiberglass materials.  Usage of the filters
increases proportionately to the SLA flow rate.  The amount of waste
filters for control at the 80 to 85 percent levels would, thus, increase
by about nine and 40 percent over that for baseline control, respectively.
Some of the filters can be cleaned and reused.  An estimate of the bulk
quantities of waste filters is not attempted.  The waste filters contain
no harmful materials and can be disposed of commercially.
     A potential secondary source of solid waste would result  from the
biological treatment of the waste water.  Waste biological sludge is
produced when excess microorganisms are removed from the treatment
process to control the microorganism population.  For the typical wastewater
stream containing 200 mg/L  (200 ppm) toluene solvent, the 93 percent
BOD. removal would result  in the production of about 0.35 Kg sludge per
                           24
Kg of BODr in the effluent.    The sludge handling  requirements for
model plants and industrywide projections for the year 1985 are presented
in Table 7-6 for each regulatory alternative considered.  The  estimated
solid waste  impacts are calculated from the wastewater discharges
presented  in Table 7-4.
7.4  ENERGY  IMPACT
     The operation of carbon adsorption solvent  recovery control  systems
require electrical energy  and steam usage.  The  steam is used  to  regenerate
the  carbon beds and recover the solvent,  at an assumed constant  ratio  of
4 Kg steam per  Kg  recovered solvent.  The in-plant  steam boilers  are
assumed to generate steam  by fuel  oil combustion half of the time and  by
                                                                  3
natural gas  combustion half the time.   Heating values of 39.0  GJ/m
 (140,000 Btu/gal)  arid 37.2 MJ/Nm3  (1,000  Btu/SCF) were assumed for  fuel
oil  and natural gas, respectively.  An  80 percent thermal efficiency was
assumed for  each fuel usage.  The  electrical energy is mostly  required
                                      7-16

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         TABLE 7-6.  POTENTIAL SECONDARY SOLID WASTE IMPACTS FOR BIOLOGICAL TREATMENT OF
                   WASTEWATER DISCHARGED FROM CONTROL OF VOC EMISSIONS IN THE
                PUBLICATION ROTOGRAVURE PRINTING INDUSTRY USING FIXED-BED CARBON
                          ADSORPTION/SOLVENT RECOVERY, Mg/Yr (Tons/Yr)*
Items
                         Overall  Solvent Recovery Efficiency
 75%
 80%
 85%
Incremental  VOC Control

       75% - 85%
Small Model plants
1.6
(1.8)
1.8
(2.0)
2.0
(2.2)
0.4
(0.4)
Large Model plants
 3.3
(3.6)
 3.6
(4.0)
 4.0
(4.4)
          0.7
         (0.8)
Projected industry-
wide total for the 130 133 136
year 1985 (143) (147) (150)
*Basis:
1. Estimates of wastewater discharges from Table 7-4.
2. Waste sludge production equal to 0.35 Kg sludge per Kg of BOD(. in the
3. Sludge handling factor of 1.25 applied for inert allowance.
4. Effluent BODg loading is about 2.2 times the organic solvent content,
6
(7)
effluent.
on a weight basis.

-------
for operating the large SLA fans.  Additional  smaller amounts of electricity
are required for the cooling tower pumps and fans, boiler support systems,
and all emissions controls instrumentation.  Total electrical consumption
is estimated for 5,470 hours per year, which represents about 75 percent
of scheduled press operating time.  Total  annual  electrical  usage is
about 64.9 GJ per 1,000 m3/hr (30,630 KWh per 1,000 CFM) of SLA, based
on a rate of 5.6 KW/ 1,000 CFM of SLA.
     The annual  energy requirements for VOC control in a large model
plant are presented in Table 7-7.  Control  of emissions at the 85 percent
level would require about 18 percent more direct energy than at the 75
percent level.  Steam usage accounts for about 86 percent of the total
direct energy consumption at the 75 percent control level ; whereas,
steam represents about 83 percent of the total  energy usage at the 85
percent control  level, where more electrical energy is required for
capture of fugitive vapors.  However, there would be net energy savings
associated with control at all three regulatory levels, when the fuel
energy value  (heat of conbustion) of the recovered solvent is considered.
Control at the 85 percent level  would thus provide about an 11 percent
energy savings over control at the 75 percent level.
     The projected energy usage for new source VOC control in the year
1985 is presented in Table 7-8.   The estimate is scaled-up from the
large model plant analysis, on an energy consumption per unit of recovered
solvent basis.  The industry's total direct energy consumption in the
year 1985 for VOC emission controls at the 75 percent level  would be
                              12
about 2.6 million GJ  (2.5 X 10   Btu).  The energy consumption would be
increased by about an additional 3 to 9 percent for controlling new
press emissions at the 80 and 85 percent levels, respectively.
     However, there is a net national energy savings when the fuel
energy value of the recovered solvent is considered.  Nationwide energy
consumption in the year 1985 would be actually decreased by about 5.6
                    1 o
million GJ (5.3 X 10   Btu), with VOC emission controls and solvent
recovery at the 75 percent level in this industry.  These energy savings
                                    7-18

-------
         TABLE 7-7.   TOTAL  ANNUAL  ENERGY REQUIREMENTS OF VOC CONTROL BY  CARBON
                ADSORPTION  FOR  LARGE MODEL  PUBLICATION ROTOGRAVURE PLANTS
Energy Sources
Direct Consumption
No. 2 fuel oil, m3 (105 Gals.)
Natural Gas, Nn3 (107 Ft3)
Total Fuel Value3, GO (1010 Btu)
Electric Powerb, GO (106 KWH)
Total Energy, GJ (1010 Btu)
Recovered Solvent0, Mq (Ton)
Total Energy Valued, GJ (1010 Btu)
Net Energy Savings, GJ (1010 Btu)
Overall NSPS VOC Control Efficiency
75*
768 (2.03)
0.804 (2.84)
60.018 (5.69)
9,396 (2.61)
69,414 (6.58)
4,800 (5,290)
223,056 (21.2)
153,642 (14.6)
80*
821 (2.17)
0.858 (3.03)
63,953 (6.06)
10,344 (2.87)
74,297 (7.04)
5,120 (5,640)
237,625 (22.6)
163,328 (15.6)
85*
870 (2.30)
0.912 (3.22)
67,921 (6.44)
14,123 (3.92)
82,044 (7.78)
5,450 (5,990)
252,941 (24.0)
170,897 (16.2)
Incremental
7S*-85*
102 (0.27)
0.108 (0.38)
7,903 (0.75)
4,727 (1.31)
12,630 (1.20)
650 (700)
29,885 (2.8)
17,255 (1.6)
  For steam generation requirements of 4 Kg steam per Kg recovered solvent.

 Operation of large SLA fans, cooling tower pumps and fans,  boiler^pumps and fans,
 and all emission controls  instrumentation—64.9 GJ/yr per 1,000 m /hr  of SLA
 (30,630 KWH per 1,000 ACFM of SLA).

CSee Table 7-3.

 Heating value of toluene,  xylene, paraffins mixed solvent at 46,470 J/g (20,000 Btu/lb).

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                             TABLE 7-8.  PROJECTED 1985 TOTAL ENERGY REQUIREMENTS
                                    OF VOC CONTROL BY CARBON ADSORPTION FOR
                                     THE PUBLICATION ROTOGRAVURE INDUSTRY
Energy Sources
Direct Consumption9, 1
Recovered Solvent , Mg
c 6
Recovered Energy , 10
Net Energy Savings, 10
O6 GJ (1012 Btu)
(tons)
GJ (1012 Btu)
6 GJ (1012 Btu)
Overall NSPS VOC Control Efficiency
75%
2.56 (2.42)
177,110 (194,820)
8.23 (7.81)
5.67 (5.39)
80%
2.63 (2.49)
181,050 (199,160)
8.40 (7.98)
5.77 (5.49)
85%
2.78 (2.64)
184,990 (230,490)
8.59 (8.15)
5.81 (5.51 )
--_.._
Incremental
75%-85%
0.22 (0.22)
7,880 (8,670)
0.36 (0.34)
0.14 (0,1 2)
aScaled-up from large model plant ratio of total  direct energy consumption per unit
 of recovered solvent—See Table 7-7.
bSee Table 7-3.
cSee Table 7-7 for solvent heating value.

-------
would be further increased by about an additional  2 to 3 percent for
controlling new press emissions at the 80 and 85 percent levels, respectively.
Solvent supplies are closely related to gasoline and other fuel supplies,
which will  become less available and more expensive in the future.
Toluene, and other solvent components, are used in automobile fuels.
The available energy value of the solvents used in rotogravure printing
must be considered.  Therefore, the highest level  of control  of VOC
emissions provides a very favorable national  energy impact, as well as
air pollution impact.
7.5  NOISE POLLUTION IMPACT
     The only significant source of noise would be from the large SLA
fans. However, these are normally installed in an enclosed housing and
should not affect the surrounding environment.  The operators may need
to wear conventional ear protection for work very close to the fans for
extended periods.  No other significant, detrimental  noise impact is
expected from the control of VOC emissions from the publication rotogravure
industry.
7.6  SUMMARY
     Other than the fuels required for steam and electricity generation,
and the materials required for the construction of the system, there is
no apparent irreversible or irretrievable commitment of resources associated
with the construction or operation of the control  systems.  Many of the
construction materials and the land itself could be reclaimed.  The
installation of VOC air pollution control systems in this industry do
not produce any significant air, water, or land pollution side effect
problems.  In addition, recovery of the solvent is energy efficient.
The economic impact analysis presented in Chapter 8 shows that solvent
recovery provides positive economic impacts,  as well.
                                     7-21

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 7.7 REFERENCES
1.   Control  of Volatile Organic Emissions from Existing Stationary Source. -
     Volume VIII:   Graphic Arts - Rotogravure and Flexography.   EPA-450/
     2-78-033,  OAQPS No. 1.2-109, U.S. Environmental  Protection Agency.
     Research Triangle Park, NC   27711.   December 1978.
2.   Telecon.  Brown, G.-Independent Petroleum Co., with Collins, C.S.-
     Radian Corp.  September 28, 1978.
3.   Telecon.  Yourens, A.-Charter Oil Company, with Collins, C.S.-Radian
     Corp. September 29, 1978.
4.   Telecon.  Youens, A.-Charter Oil  Company, with Collins, C.S.-Radian
     Corp. September 27, 1978.
5.   Dimitriades,  B., editor,  In:  International Conference of Photo-
     chemical Oxidant Pollution and Its Control, Volume II.  EPA-500/
     3-77-0016.  Raleigh, N.C.   Sept.  12-17, 1976.
6.   Farley, F.F.  Photochemical Reactivity Classification of Hydrocarbons
     and other Organic Compounds.  In:  Proceedings of the International
     Conference on Photochemical Oxidant Pollution and Its Control,
     Volume 11.  EPA-600/3-77-0016.  Raleigh, N.C. September 12-17,
     1976.  p.  715.
7.   Reference 6,  p. 723.
8.   Federal Register. Volume 42, number 131.  Pages 35314-35316.
     July 8, 1977.
9    Sax, N.I., et al.  Dangerous Properties of Industrial Materials.
     New York, Van Nostrand Reinhold Company, Fourth ED. P. 590-1246.
10.  Patty, F.A.,  editor.   Industrial  Hygiene and Toxicology.  Second
     Revised Edition.  New York, Interscience Publishers, division of
     John Wiley and Sons, Inc.  p. 1174-1234.
11.  U.S. Department of Labor,  Occupational Safety and Health Standards.
     Subpart Z - Toxic and Hazardous Substances, 1910.1000 Air
     Contaminants.  Washington, D.C. U.S. G.P.O. Attachment to
     February 19,  1980 letter.
12.  American Conference of Governmental  Industrial Hygienists.  Recommended
     Threshold Limit Values for toxic vapors.  1979 edition.
                                      7-22

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13.   Reference 9, p.  593.
14.   Reference 9, p.  917.
15.   Environmental  Protection Agency.  Compilation of Air Pollutant
     Emission Factors.   OAQPS, Research Triangle Park, N.C.  Publication
     AP-42.  Second Edition with Supplements 1-7.  Supplement No. 6,
     April 1977, p. 1.3-2.
16.   Reference 15,  Supplement No. 3, May 1974, p. 1.4-2.
17.   Reference 15 April 1973, p. 1.1-1 to 1.1-2, April 1976, p. 1.1-3.
18.   U.S. Environmental Protection Agency.  New Stationary Sources Performance
     Standards; Electric Utility Steam Generating Units.  Federal Register 44,
     No. 133.  June 11, 1979.
19.   Feairheller, W.R.   Graphic Arts Emission Test Report, Texas Color
     Printers, Dallas,  Texas.  Monsanto Research Corporation.  Dayton,
     Ohio.  EPA Contract 68-02-2818-20, EMB 79-GRA-3.  October 1979.
20.   Feairheller, W.R.   Graphic Arts Emission Test Report, Meredith/
     Burda, Lynchburg,  VA.  Monsanto Research Corporation.  Dayton,
     Ohio.  EPA Contract 68-02-2818-16, EMB 79-GRA-l.  April 4, 1979.
21.   U. S. Environmental Protection Agency.  Secondary Treatment Information.
     Federal Register 38. No. 159.  August 17, 1973.
22.   Clark, J. W., W. Viessman, and M. J. Hammer.  Water Supply and Pollution
     Control.  New York,  lEP-Dunn/Donnelley.  1977.   p. 288-291.
23.   U. S. Environmental Protection Agency.  Process  Design Manual for Carbon
     Adsorption.  Cincinnati, U.S.G.P.O. October 1973.
24.   Thomson, S. J.  How to Design Activated Sludge Units.  Hydrocarbon
     Processing.  August 1975.  p. 99-102.
                                     7-23

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                            8.  ECONOMIC IMPACT

8.1  INDUSTRY CHARACTERIZATION
8.1.1  General Profile
     The graphic arts industry, which includes all printing, publishing,
and allied industries is characterized by the U.S. Department of Commerce
as a division of "Standard Industrial Classification" (SIC) 27.  The
total product value from this group has increased from about $43 billion
in 1976 to about $53 billion in 1978.1  Commercial printing, SIC 2751-2-4
is a subclassification of this group.  Printing receipts have increased
from over $13 billion in 1976 to over $16 billion in 1978.  Gravure
printing is a subclassification of commercial printing and is listed as
SIC 2754, commercial printing-gravure.  Gravure publication printing is
listed as subclassification of commercial printing, and is denoted as
SIC 27541.  However, for the purposes of this study, gravure publication
printing is defined as including SIC 27541  and SIC 27543 (gravure advertising
printing).
     The publication rotogravure printing industry represents the largest
of the three sectors involved in gravure printing.  Packaging and specialties
printing are the two other gravure sectors, but these are not considered
in this study.  There are many differences  in the solvent, substrate,
ink, and equipment used  in these three gravure sectors.
                       2
     An industry survey   rated the value of gravure publication shipments
at over $2.1  billion, and over 37 percent of the total gravure shipment
value in 1976.  The major publication gravure product areas fall in the
following categories (dollar value percentage):
     •   newspaper supplements and preprinted inserts - 58 percent
     •   catalogs (all types)                          - 19 percent
     •   magazines                                    - 18 percent
     •   advertising printing                          -  5 percent
                                   8-1

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The distribution of these gravure  publications  is extensive.   In  1976,
over 183 million newspaper supplements  and  preprinted  inserts  were dis-
tributed weekly.  In addition,  over  180 million magazines every month
were printed either entirely or partly  by gravure.   Despite  this  large
circulation, this volume of printed  material  is produced  in  fewer than
30 plants nationwide.
     There were 27 gravure publication  printing plants in oocration  as  of
July, 1979.  These plants are distributed among 15  states.   Illinois has
the greatest concentration, with six plants (three  in  Chicago  alone),
which contain approximately one-third of the total  number of production
presses in the industry.  Ohio and California each  have three  publication
gravure operations, and Tennessee, Kentucky, and  New York each have  two.
The remaining nine plants are scattered among as  many  states,  all but two
of which are east of the Mississippi.  An additional plant  is  currently
under construction in North Carolina.  Table 8-1  is a  geographic  distribu-
tion of the Gravure publication plants in this country.
     Very little activity occurs in  the import/export  market for  printed
products.  In the printing and publishing industry  (SIC 27), combined
imports and exports have recently been somewhat in  excess of $1  billion
annually (about 2 percent of the 1978 market value).  Books  and periodicals
account for roughly three-fourths of exports and  two-thirds  of imports.
Exports typically exceed imports in a ratio of two  to  one.   This  ratio,
and the same general volume of international trading are expected to
continue into the early 1980's.  Canada, the United Kingdom, Australia
and Japan are the major export markets.  The ratio of exports plus  imports
to total value of shipments is similar in the commercial printing portion
of the  industry  (SIC 2751-2-4) and is expected to remain so  in the next
few years.3  Exports and imports are thus not a particularly significant
component of the markets for publication gravure  products.
     The 27 gravure  publication plants  (soon to be 28) are  operated by 17
companies.  As Table 8-2 shows, a number of these operating companies are
privately owned, and others are subsidiaries of larger corporations.
Three of the owners, Charter,  City Investing,  and Mobil Oil, are highly
                                   8-2

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 TABLE  8-1.  GEOGRAPHIC DISTRIBUTION OF GRAVURE PUBLICATION
             PRINTING PLANTS AS  OF JULY,  1979a
             Illinois                       6

             California                     3

             Ohio                           3

             Kentucky                       2

             New York                       2

             Tennessee                      2

             Colorado                       1

             Indiana                        1

             Iowa                           1

             Maryland                       1

             Mississippi                    1

             Pennsylvania                   1

             Rhode Island                   1

             Texas                          1

             Virginia                      _J_

             TOTAL                         27


aTakes into account the 1978 closing of Triangle Publications
 in Philadelphia and the planned 1979 opening of the Brown
 Printing Company plant in Bowling Green,  Kentucky.
                          8-3

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  TABLE 8-2.  OWNERSHIP OF GRAVURE PUBLICATION PRINTING ESTABLISHMENTS
         Owner
Operating companyc
    Establishment
Arcata Corporation
Art Gravure Corp.

Bemisb
The Charter Company

City Investing Company

The Denver Post, Inc.
Brown Printing Co.,
Inc.

Dayton Press, Inc.

World Color Press
The George Banta Company

Macmillan, Inc.            Alco-Gravure, Inc.
Meredith Corporation

Meredith Corp. and
  Burda GmbH

Mobil Oil Corp.
New York News, Inc.

Parade Publications,
  Inc.

Providence Journal Co.
Meredith/Burda, Inc.
W. F. Hall
Arcata Graphics
San Jose Graphics

Art Gravure Corp.

Brown Printing,
Bowling Green

Dayton Press

Salem Gravure

The Denver Post
Gravure West

Springfield Gravure

Alco Gravure, Chicago
Alco Gravure, Glen
  Burnie
Alco Gravure, Memphis
Alco Gravure, Los
  Angeles

Meredith

Meredith/Burda
Chicago Rotoprint Co.
Hall of Miss. Printing
Company

Newsprint Gravure Plant

Diversified Printing
  Corp.

Providence Gravure,  Inc.
Texas Color Printers
                                                            Continued
                                  8-4

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                           TABLE 8-2.  Continued
         Owner
Operating company0
Establishment
R. R. Donnelley and Sons
Standard Gravure Corp.

Western Publishing Company
                       R. R. Donnelley, Chicago
                       R. R. Donnelley, Warsaw
                       R. R. Donnelley,
                         Mattoon
                       R. R. Donnelley,
                         Gallatin

                       Standard Gravure Corp.

                       Kable Printing Company
 Where different from owner

^Privately held company
                                  8-5

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diversified concerns.   Most of the other owners  are involved  in  one or
more aspects of printing or publishing in addition to gravure publications.
8.1.2  Trends
     8.1.2.1  Product  Demand.   The printing and  publishing industry serves
a wide rarge of educational, cultural, business, and informational  needs.
Strong economic growth, a better-educated population, and higher personal
incomes are significant factors affecting the demand for printed products.
Equitable postal rates, and an expanding economy have been major factors
in a continuing strong growth  pattern for the printing industry.  Consid-
siderable competition  in the advertising market  is generated  by  the broad-
casting industry, and  a reduction in advertising expenditures is more likely
to affect the printing industry, than it would the broadcasting  industry.
     Gravure publication printing has experienced increased growth in the
printing and publishing industry.  The GTA-GAMIS survey^ reported that
gravure's contribution to the  total  printing and publishing industry will
increase from 14 percent in 1977, to an estimated 16 percent  in  1980, and
then to 25 percent by  1990.  These trends are largely the result of tech-
nological advances in  the presses and in cylinder preparation.   Cylinder
preparation is a costly and time-consuming process, preventing  gravure from
competing with the other processes on short runs.  However, automation and
other charges in this  pre-press phase of gravure printing have  lowered the
minimum r_n length at  which gravure can compete  with lithography from 1
million to 500,000 or  even 250,OOO6 copies in some cases.  This  signifi-
cant improvement represents the gradual elimination of gravure's major
competitive disadvantage with  other printing processes.
     The process has a number  of distinct advantages.  It is  better able  to
handle long runs.  It  is the only process that can vary the thickness of
the ink layer on the page and  can thereby reproduce art work.  It can better
handle lesser grades and lighter weights of paper, including  uncoated stock,
and can operate with less waste, all very meaningful in the face of paper
shortages and rising postal rates and paper costs.''1  Publication gravure
printing "s in an especially good position to take advantage  of rapidly
rising der.and from publishers  of newspaper inserts and magazines.  The
                                    8-6

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market for publication gravure printing can be expected to grow rather
rapidly in the foreseeable future due to growth in demand for printed
products, and gravure's improving competitive advantage with respect to
letterpress and offset lithography.
     8.1.2.2  Factors Affecting Supply.  There are a number of constraints
on the ability of the publication gravure industry to take full advantage
of the increasing demand.  Limited availability of new equipment, age of
existing equipment, present high equipment utilization rates, and projected
shortages of materials all contribute to supply constraints.
     There are three principal manufacturers of publication gravure presses:
Albert-Frankenthal AG (Germany), Motter Printing Press Company (York,
Pennsylvania) and Officine Meccaniche Giovanni Cerutti S.p.A.  (Italy).
Motter is able to build six presses per year and has a two-year backlog.
Albert-Frankenthal and Cerutti each have the capacity for about ten presses
annually, but at least half of their production is committed to filling
European orders at present.  Cerutti is considering opening an American
assembly plant, but it would at first produce only packaging gravure
presses.8  Consequently,  it appears that between 10 and 15 presses per
year is the most that could be expected for the U.S. market over the next
five years.  Some of these new presses will be replacements for existing
equipment.  Few presses can still do top quality work after 15 years, and
the 1976-1977 GTA-GAMIS Survey showed that approximately one-fourth of
those  in operation exceed that age, while about one-half are between five
and 15 years old.9  Some  of these older presses will be overhauled, but
others will require replacement.
     Commerce Department  statistics show that commercial printing utiliza-
tion rates have been 80 to 81 percent of practical capacity between 1975
and 1977.10  The practical capacity is defined as the greatest level of
output a plant can achieve, considering a realistic work pattern, normal
product mix, operable machinery, and reasonable time for maintenance.
Trade  association sources confirm  that the present capacity  in publication
gravure printing is utilized on the average at 80 to 85 percent of practi-
cal capacity.  However, seasonal work catalogs and holiday advertising
                                   8-7

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results in virtually no excess capacity for 70 percent of the time.
This observation seems consistent with another Commerce Department
finding that commercial printers operated at 96 and 95 percent of prefer'ed
capacity in 1976 and 1977,  respectively.^  The preferred capacity is
defined as the production level  in which the manufacturer would prefer not
to exceed due to cost and other considerations.  It is not likely that any-
thing more than a 10 percent increase in output could be obtained from
existing capacity; five percent would be a more reasonable expectation.
     There is currently a paper shortage, and it is likely that this
shortage will persist into the early 1980's.  Estimates of the shortfall
vary, but in 1979, new production capacity for printing grades of paper
is estimated to be up 2.5 percent, while the lowest estimate of real growth
                                     1 2
for commercial printing is 3 percent.    Estimates indicate a demand for
gravure grades of paper will increase 4 percent annually, while the paper
production will only increase at 2.5 percent..    The costs of whatever
gravure paper is available are expected to increase by 10 percent in 1979
      1 ?
alone.    However, a shortage of paper, particularly of the higher or
heavier grades, may improve gravure's competitive advantages over other
printing processes.  Gravure presses waste less and can operate with poorer
and lighter grades of paper.  A serious shortage would of course affect all
printing methods adversely, even if gravure were comparatively less severe-
ly restricted in output.
     Many of the ink components are petroleum derivatives, and consequently
ink costs are increasing sharply and will likely continue to do so.  More-
over, many of the solvent constituents, especially toluene, are also used
as gasoline additives.  Their prices are therefore established in a market
in which printers are a small customer with virtually no ability to affect
prices.  A typical gravure  publication solvent mix which sold for 65 cents
per gallon in January of 1979 was priced at 80 cents on July 1, 1979,
and  is expected  to rise to  a  least 90 cents by the end of 1979.  * 5
      In summary, any publication gravure expansion will be limited by a
number of short-term constraints, some of which are very strong.  The new
sources which come into being in this rapidly growing industry are likely
to be  influenced by these supply factors.
                                   8-8

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      8.1.2.3   Industry Growth Projections.  Historically, the real growth
 of  the  commercial  printing  industry has closely followed real growth  in
 gross national  product (GNP).  Considering an annual average of 3 percent
 real  increase  in GNP  for  the next five years, a 3 percent annual increase
 in  the  total value of output from commercial printers  (in constant dollars)
 is  expected.   To this can be applied the publication gravure market share
 with  some  rate  of  annual  increase, to arrive at a set  of growth projections.
 Since estimates of the rate of increase of the market  share vary, four
 alternative projections were determined and are presented in Table 8-3.
 The initial (1976) market share of 16 percent was calculated using industry
 survey  statistics  for publication gravure and U.S. Department of Commerce
                                2 3
 records for commercial printing.  '   The 1976 dollar value for commercial
 printing was $13,355,000,000 while the publication rotogravure printing
 value was  $2,129,200,000.  The base year chosen for projections is 1976,
 the year for which the most complete data were available.  The four alter-
 native  projections (I, II, III, and IV) were determined by assuming the
 following  information:
     Projection I   - Constant 16 percent market share (3 percent annual
                      real growth)
     Projection II  - GTA estimate of 5 to 6 percent real growth annually
                      to 1985 (5.5 percent annual  real  growth)
     Projection III - Market share increasing 1  percent per year,  from 16
                      to 25 percent (plus 3 percent annual  real  growth)
     Projection IV  - Market share increasing 1.5  percent per year,  from
                      16 to 29.5 percent (plus  3 percent annual  real  growth)
     These four projections are graphically illustrated in Figure  8-1.
 Projection I,  an annual  real growth rate of 3 percent is clearly conserva-
 tive for this  expanding  industry.   Any of the other three projections
 appear possible, considering only  the  increased  demand for gravure publica-
 tion products.   However,  the restrictions on supply,  in particular those
 imposed  by the  capacities of gravure press  manufacturers, must be  intro-
duced  into the  growth projection process to determine which  of curves II,
 III, and IV are reasonably attainable.
                                   8-9

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    TABLE 8-3.  PUBLICATION ROTOGRAVURE  PRINTING INDUSTRY TOTAL  OUTPUT9  AT TYPICAL 81% UTILIZATION
                CAPACITY UNDER FOUR ALTERNATIVE  PROJECTIONS





00
o
Projection
I
II
III
IV
a
1976
2,129
2,129
2,129
2,129

1977
2,193
2,246
2,339
2,407

1978
2,259
2,370
2,550
2,692

1979
2,327
2,500
2,773
2,992

1980
2,396
2,638
3,006
3,307

1981
2,468
2,783
3,251
3,638

1982
2,542
2,936
3,508
3,987

1983
2,619
3,097
3,778
4,352

1984
2,697
3,268
4,060
4,737

1985
2,778
3,447
4,356
5,140

 Output is in millions of 1976 dollars.
I   -  3% Real  Growth
II  -  5.5% Real  Growth
III  -  3% Real  Growth plus ]"/* annual  increases  in Market share,
IV  -  3% Real  Growth plus 1.5% annual  increase in Market  share.

-------
00
               l/l
               10

               &
                   5500
                   5000
                   4500
                   4000
               -   3500
               in
               c
               o
               a:   3000
                   2500
                   2000
                            Basis:  see Table 8-3
                      1976      1977       1978       1979       1980       1981       1982       1983       1984       1985

                                                             Year
                 Figure 8-1.   Alternative  growth projections  for the publication  rotogravure  printing
                               industry at  typical 81  percent  utilization  capacity.

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     The annual  dollar value product output of a  gravure press  cannot be
accurately determined due to the mix of products  typically produced and
the variety of sizes and weights of paper used.   An annual dollar-value
product output per press factor of approximately  $15.8 million  was esti-
mated using the 1976 total  output value, $2,129,200,000, and the fact that
                                                                   216
there were about 135 production presses in operation at that time.  '
Since 81 percent of practical capacity was being  utilized by commercial
printers in 1976, a single gravure publication press would then theoreti-
cally produce about $19.5 million worth of product at full practical capa-
city.  Production at preferred capacity* (84 percent of practical capacity)
would be about $16.4 million.
     The press manufacturers, even in 1979, can only produce 10 to 15
presses for the United States market each year.   Therefore the  gravure
publication capacity (based on 1976 dollars) can  be expanded at an annual
rate of $158 to $237 million at typical capacity  (81 percent),  $164 to
$246 million at preferred capacity (84 percent),  and $195 to $293 million
at full practical capacity (100 percent).  Figure 8-2 illustrates the growth
constraints associated with the production of 10  new presses per year.
These constraints are superimposed on the project growth curves  (from Figure
8-1) for capacity utilizations of 81, 84, and 100 percent of full practical
capacity.  These constraints include the new press capacity as  well as the
additional output available through increased utilization of existing capa-
city.  Figure 8-3 illustrates the same relationship as Figure 8-2, except
that the production of 15 new presses per year is used rather than 10 per
year.
     The rates of possible capacity expansion may be somewhat understated,
because new presses are faster and more efficient than o']d ones.   It
appears, nevertheless, that growth curve IV, an annual real growth rate
of about 10.5 percent, is no more realistic than is the probability of
continued  operation at 100 percent of full practical capacity.    Therefore
the  remainder of this analysis  is based on the expectation that  real

Operation during 1976 was 96 percent of preferred capacity,'  which was
 also equivalent to 81 percent of practical capacity.  Therefore  the
 preferred capacity was 84 percent of the practical capacity.
                                   8-12

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co
i
             s
             c
             o
                5500
                5000
                4500
                4000
                3500
                3000
                2500
                2000
                          Basis:
                                  See Table 8-3
                          	   10 new presses per year
                                                                                                         100%
                   1976
   1977
1978
1979
1980
                                                       Year
1981
1982
1983
1984
1985
           Figure 8-2.
Alternative  growth estimates for the publication  rotogravure printing industry

with constraint  of 10 new presses per year superimposed at utilization capacities
of 81%, 84%,  and 100%.

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           5500
           5000
           4500
           4000
       £  3500
                 Basis:
                                                                                                     100%
                      see Table 8-3
                  	 15 new presses per year
00
        c
        o
           3000
           2500
           2000
                                                     _L
              1976
1977
1978
1979
                                                    1980

                                                    Year
                                      1981
                                      1982
                                                         1983
                                                         1984
                                                         1985
       Figure 8-3.  Alternative growth estimates  for the publication rotogravure printing industry
                    with constraint  of 15 new presses per year  superimposed  at utilization caparities
                    of  81  percent, 84 percent, and  100 percent.

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expansion will occur within the envelope bounded by curves  II and  III, at
a nominal rate of about 7 percent per year.
     8.1.2.4  Affected Facilities.  Modifications and reconstruction of
existing rotogravure printing presses are described in Chapter  5.   A
number of reasons account for the low probability that any  "affected
facilities" will be created through modification or reconstruction.
While older presses may operate properly for many years under proper
maintenance,  recent and continuing improvements in peripheral equipment
and automation make new equipment more desirable.    Older  presses  are
often retained for back-up or peak demand capacity, when  new equipment
is purchased.  Consequently, reconstruction and modification is not
considered a  significant generator of "affected facilities".
     The ages of existing equipment and the projected growth in demand
are such that the maximum output of the publication gravure press manufacturers
will  probably be utilized between 1979 and 1985.   To meet the projected
seven percent annual  real  growth rate, the industry appears to  be demanding more
new press capacity than immediately needed.  This industry seems to be
favoring the installation of an excess of new presses utilized  at a lower
rate, rather than operating with fewer presses at increased utilization rates.
Thus, assuming a maximum 15 presses per year can be manufactured, approximately
75 individual  new presses over the five-year period of analysis (1981-1985) are
expected.  Most of these new presses  will  be devoted to expansion of existing
operations;  however,  some existing presses will be replaced.  About 25 percent
of the new presses are expected to go into new grass roots plants.  The number of
production presses will, therefore, total  about 250 by the year 1985.
     To achieve the same seven percent growth rate with new, model plant type
presses, only about 45 new presses, utilized at the 81  percent  rate, would be
required.  This is because modern presses are faster and more efficient than
older presses.  The model  plant presses have the capacity to operate at speeds
of about 2000 ft/min  (see Table 6-1)  compared to only 1200 to 1500 ft/min for
older, existing presses (see Chapter  3).   However, the printing of some type
products may require  lower press speeds  and may result in lower press  utilization
rates.  The  result of these operating conditions  would increase the required
number of model  plant type presses.
                                     8-15

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     If 75 new model  plant type presses were used at an 81 percent utilization
rate with all existing presses, the industry's potential  annual  real growth
rate from 1981 through 1985 could be as high as eight to nine percent.  However,
the higher speed new presses will allow a lower utilization rate than older
presses to meet customer demands.  This will decrease the required number of  ours
that operators will  have to be paid to print an equivalent amount of product.  The
projected seven percent growth rate is, therefore, conservative, but reasonable
when decreased press utilization and possible requirements for lower press
speeds combined with replacement of some old presses by new presses is considered.
     Since approximately 75 percent of expected expansions will occur at
existing operations, most new  plants  in this  industry will be located in
the 15 states where publication  gravure plants are presently concentrated.
All but four of them are east  of the Mississippi, and little West Coast
    *u •       * J  11
growth is expected.
     The often-mentioned tendency for new manufacturing  industries  to
locate in the southern states  to take advantage of less-expensive labor
is not particularly significant  for publication gravure  and is becoming
less so for  two reasons.  First, the  industry's primary  concern in  the
labor market  is to obtain the  highly  skilled  employees it needs, and they
are in short  supply.  As equipment becomes  still more sophisticated, the
need for well-trained personnel  will  become even more significant.  Second,
the cost of  shipping paper continues  to rise, and most of it comes  from
       Q
Canada.   Consequently, although two  of the newest plants will be in
Kentucky and South Carolina, this does not necessarily signal a shift of
the center of gravure printing to the south.  It is likely that most new
plants will  be located in the  northeastern quadrant of the United States
since the raw material supplies  such as paper and ink are already well
established  in this area.
     There is no clear trend which can be used to predict the sizes of
new publication gravure plants in terms of the two-press or four-press
model plants postulated for this analysis.  The most recent, new grass
roots plant opened is a one-press operation in Bowling Green, Kentucky.
However, another company has a four-press plant under construction  in
Spartanburg, South Carolina, scheduled for a  1980 opening.  Another company
                                     8-16

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has ordered four presses for expansion, while still another has ordered six
for use in a single plant.8  Consequently, the analyses presented in sections
8.4 and 8.5 considers the impacts associated with a mixture of model plant
sizes.  This mixture is an estimation of the expected future structure of
this industry.

8.2  COST ANALYSIS OF REGULATORY ALTERNATIVES
     Three regulatory alternatives are presented in Chapter 6.  These
alternatives call for an overall volatile organic compound (VOC) reduction
of 75, 80, or  85 percent.  The baseline,  75  percent,  level of  control
corresponds to  the anticipated State  Implementation Plan  (SIP) regulations.
This  is based on the  Control  Techniques  Guideline    (CTG) document  for
this  industry.   A  75  percent  VOC reduction is readily attainable on older
gravure publication printing  presses  using conventional emission control
technology.   In fact,  about 70 percent of the gravure publication plants
currently have  emission control  systems which meet or exceed this CTG
recommendation.
      An intermediate  80 percent level of control  is attainable using
conventional  emission control  techniques  on  new  presses.   The  new"presses
provide for better containment of  the solvent vapors.   This helps
reduce fugitive vapor losses  without  any  additional  emission control
equipmc  -..
      The  highest control  level  considered at 85  percent,  requires a significant
effort to contain  and treat fugitive  vapors. One  possible technique
utilizing a proven method  for capturing  fugitive vapors is presented
in Chapters 4 and  6.   This technique  is based on an existing plant  which
was  tested by the  EPA.
      Each regulatory  alternative is applied  in conjunction with two  plant
sizes.  A total of six  model  plants are used to  describe  the various con-
figurations for new plants.   Specific information  about each model  plant
is presented  in Chapter 6  (Table 6-1).  A cost analysis is presented in
                                   8-17

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this chapter for each emission control  system used in the six model plants.
The installed capital cost, operating cost, annualized cost, and cost
effectiveness for each emission control  system is analyzed for each model
plant.  A discussion concerning modified or reconstructed facilities is
also presented.
8.2.1  New Facilities
     The model plant analysis applies to six new plants.  Two plant sizes
are used to describe predicted new future plant configurations.  Each
plant contains one proof press and either two or four production presses.
Only one control technology, fixed-bed carbon adsorption, is examined in
this study.  The costs presented in this section are order-of-magnitude
type estimates based on plant experience and vendor quotations.  The margin
of error in the absolute costs is ±30 percent.  The results presented here-
in are intended to be used as a comparative basis to examine the relative
economics which may face a printer if a regulation goes into effect.
     8.2.1.1  Capital Costs.  The capital costs associated with the imple-
mentation of a fixed-bed carbon adsorption system are based on combined
                                      19  20  21  22,23,24,25,26
information from the printing industry   »>>»>_»>    and  also  from
                   97  0^ 9Q  Q*n  *3T
equipment vendors.   ' °'   '   '    The industry  cost data obtained  tended to
be slightly higher than that supplied by equipment vendors.  Detailed indus-
try data is likely to be a better estimate of the actual costs incurred
since this information also includes outside battery limits costs.  Conse-
quently, the cost analysis is based more heavily on past, detailed, indus-
trial experience, rather than vendor quotations.
      A carbon  adsorption, solvent recovery system  is usually purchased
as  a  series of  prefabricated equipment components.  The purchased  equip-
ment  price depends greatly on  the SLA capacity, the instrumentation, and
the materials  of construction.  The carbon adsorption systems  analyzed
in  this  study  are  all equipped with the same  instrumentation options which
are considered  necessary for sustained high efficiency operation.   The
                                   8-18

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expected operating adsorber efficiency for these systems is 95 percent.
This high efficiency is achieved by using moderately thick (0.75-1.0 meters)
adsorption beds, and hydrocarbon vapor breakthrough analyzers.  The
analyzers are equipped with a backup timer override system which limits
prolonged high outlet vapor concentrations if analyzer problems occur.
     The purchased and installed capital costs of the carbon adsorption,
solvent recovery systems used in the model plants are presented in Table
8-4.  These costs do not include any facilities for the printing presses,
or the presses themselves.  These other costs are discussed in Sections
8.4 and 8.5.  When necessary, the solvent recovery/emission control system
costs were scaled to match the model plant sizes by employing the 0.6
power-law estimating equation.  The equipment design sizes chosen for the
model plant cases allow for the additional SLA flow from the proof presses.
The "Chemical Engineering Plant Cost Index" was used to escalate all costs
to first quarter (March) 1979 dollars.
     Field assembly includes steam piping, electrical  connections for
recorders, gauges and instruments,  and all insulation.  The costs of
mounting equipment and vessels on supports and/or foundations is also
included.   The cost of painting, as needed to prevent  corrosion from the
weather, is included as well.   Field assembly expenses are estimated to
be 25 percent of the purchased cost of equipment based on industry data.
     Process buildings for the boiler, solvent recovery equipment,  and
the instrumentation are required to provide weather protection.   No special
or unusual  circumstances are foreseen.   The cost is estimated to be 20 per-
cent of the purchased equipment  cost.
     The boiler cost, as presented, accounts for an entire steam generation
plant.   Sufficient excess steam  capacity is provided.   A steam to  solvent
ratio of 4.0 to 1  is assumed in  the sizing of the boilers.   The small  model
                                    3-19

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                 TABLE 8-4.  INSTALLED CAPITAL COST OF VOC CONTROL BY  CARBON ADSORPTION3  FOR GRAVURE
                             PUBLICATION PRINTING PLANTS
Plant size
Overall V.O.C. control efficiency, *
Carbon adsorption system capacity
(solvent laden air flow rate)
Total production press flow rate; m'/hr
(ACFH)
Proof press flow rate; m'/hr
(ACFH)
Total solvent laden air flow rate; m'/hr
(ACFM)
Purchased cost of solvent recovery equipment
Field assembly and utility tie-In
(25X of purchased cost)
Process building (Including foundations) for
boiler, solvent recovery plant, and Instruments
(20% of purchased cost)
Support facilities: Boiler (Installed)
Cooling tower (Installed)
Ductwork: Fugitive capture hoods and ducts
Dryer exhaust ducts
Direct Costs
Start up (2.5J of direct costs)
Subtotal
Contingency costs (10% of subtotal)
Installed capital cost
Small
75

72,450
(42,640)
18,110
(10,660)
90,560
(53,300)
$ 655,000
164,000
131,000
135,000
27,000
50,000
$1,162,000
29,000
$1,191,000
119,000
$1,310,000
Small
80

79,690
(46,900)
18,110
(10,660)
97,800
(57,560)
$ 695,000
174,000
139,000
135,000
27,000
52,000
$1,222,000
31,000
$1,253,000
125,000
$1,378,000
Small
85

108,680
(63,960)
18,110
(10,660)
126,790
(74,620)
$ 860,000
215,000
172,000
135,000
27,000
126,000
55,000
$1,590,000
40,000
$1,630,000
163,000
$1,793,000
Large
75

144,910
(85.280)
18,110
(10,660)
163,020
(95,940)
$1,050,000
263,000
210,000
145,000
42.000
92,000
$1,802,000
45,000
$1,847,000
185,000
$2,032,000
Large
80

159,400
(93,810)
18,110
(10,660)
177,510
(104,470)
$1,150,000
288,000
230,000
145,000
42,000
98,000
$1,953,000
49,000
$2,002,000
200,000
$2,202,000
Large
85

217,380
(127,930)
18,110
(10,660)
235,490
(138,590)
$1,265,000
316,000
253,000
145,000
42,000
252.000
103.000
$2,376,000
59,000
$2.435,000
244.000
$2.679,000
CD
no
O
           First quarter 1979 dollars

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plants require one 24.7 Gj/nr (700 hp) boiler, while a 28.3 Gj/hr (800 hp)
boiler will supply the large model plants.  Boiler costs are determined
from data given by various printers.  They include the installed cost of
the boiler, piping and general support facilities (e.g. water treatment).
     Cooling tower costs are determined from one vendor quote of the
                                                          o o
purchased cost, supplemented by information from printers/The costs,
as presented, include the purchase price of a prefabricated, roof-mounted
system.  The cooling tower capacity is sized on the basis that an average
of about 3 gallons of cooling tower water with a 23  C°  (40  F°) temperature
rise  are  required to  cool and condense each  pound of steam used  in  the
                         27
carbon adsorption system.  The cooling towers for the small model plants
are one-cell units whereas the large model plants use two-cell units.  In
both cases the cooling towers are sized to provide adequate excess capacity
under all weather conditions.
     Fugitive  vapors  must be captured and  treated to achieve  an  85  percent
 overall  VOC reduction.   The  cost  estimates for  the  85  percent control levels
 in  Table  8-4 are  based  on construction of  a  hood enclosure over  each
                                  ??
 press to  capture  fugitive vapors.     The  hoods  are  connected  to  a common
duct running over the entire press.  However, an extensive array of fume
collection nozzles and ducts could be substituted with similar results.
In either case, floor sweeps will  also be required as usual  to prevent
hazardous fume concentrations during extended shutdown periods.   The cost
of the floor sweeps is not included in these estimates, since they repre-
sent a standard pressroom safety system.   Fugitive vapor  capture
systems are only required on the 85 percent VOC reduction cases.
     All of the model  plant cases  require ductwork to carry the  SLA from
the presses to the carbon adsorption units.  Each production press will
require about 45 meters (150 feet) of header, 0.9 meters  (3 feet) in
diameter.  Each proof press  requires 45  meters (150  feet) of header, 0.8
meters (2.5 feet)  in diameter.  The headers tie into a  main duct  which
                                  8-21

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is about 90 meters (300 feet) long.  The diameter of the main duct depends
on the size of the printing facility.  The cost estimate information for
ductwork was obtained from contractors.33,34,35
     Start up expenses are estimated at 2.5 percent of the direct costs.
Initial performance testing is included in this figure.  Contingency costs
are estimated at 10 percent of the sum of the direct costs plus the start
up expenses.  This item is to allow for inclement weather during construc-
tion, labor disputes, small design changes, and other unexpected expenses.
     Land requirements vary with the size of the individual carbon adsorp-
tion units.  Estimates for land costs have not been included due to the
uncertain nature of this expense.  The land can also be reclaimed at a
later date.  The actual  land requirement ranges from about 400-1000 m^
(0.1-0.25 acres).
     8.2.1.2  Annualized Costs and Cost Effectiveness.   The annualized
costs are composed of the sum of the annual operating costs and the annual
capital charges minus the solvent recovery credit.   The bases used in com-
puting the annualized costs are presented in Table  8-5.  Many of these
items are dependent on location.   Nevertheless, an  effort has been made
to use the figures which are representative of the  entire gravure publica-
tion printing industry.   A detailed breakdown of the annual operating costs
for the six model plants is presented in Table 8-6.   These costs; reflect
operating expenses for the carbon adsorption, solvent recovery systems.
     An average of four  kilograms of steam are required to recover a  kilo-
gram of solvent.   For the purposes of this study,  it is estimated that
steam is produced 50  percent of the time by natural  gas,  and 50 percent
of the time by No.  2  fuel  oil.   Natural  gas costs  are estimated at about
$106/1000 m3 ($3/1000 ft3).  No.  2 fuel  oil  costs  are estimated at about
$0.132/1 Her ($0.50/gallon).   For a 50/50 fuel  mix,  the average cost  per
1000 kilograms of produced steam is $9.02/Mg ($4.10/1000  Ib steam).   The
total  steam cost is therefore $0.036/kg recovered solvent (S0.0164/1b
recovered solvent).
     Electricity in a carbon  adsorption plant is primarily required to
operate fans for moving  the SLA.   The national  average  cost of electricity
(in early 1979) was $0.0277/kWhr.35  However,  the gravure industry-wide
                                   8-22

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            TABLE 8-5.   BASES FOR ANNUALIZED COST ESTIMATES
    Description
 Unit cost
      Basis for costs
     and other comments
Annualized costs for
new installation
Average press operating
  time
Average solvent recovery
  plant operating time
Utilities
    Electricity

    Steam
    Water


Operating labor
Maintenance

    Labor

    Carbon replacement
      cost

    Misc. maintenance,
      parts and material
Capital recovery factor

Taxes and insurance

Administration and
   permits
Solvent adjustment
   credit
One year

4740 hr/yr

5470 hr/yr
$8.89/GJ
($0.032/kWh)

$9.02/Mg

($4.10/103 Ib)


$0.198/m3
($0.75/1000 gal)

12.00/hr


13.20/hr


2% of capital
  cost

1% of capital
  cost
16.275% of
  capital cost
2% of capital
  cost
2% of capital
  cost
$0.172/1 Her
($0.65/gal) a

   231/Mg
($210/ton)
Commencing early (March)
1979
65% of scheduled operating
  time
75% of scheduled operating
  time
50% operation with No.  2
  fuel oil at $0.50/gal
50% operation with natural
  gas at $3.00/1000 ft3
Includes fringes
Hourly rate at 10% premium
  over operating labor

Carbon life at 5 years, and
  10% of the capital cost
10% interest rate and 10
  years equipment life
Recovered solvent for sale
  or reuse

Typical  nixed solvent density
at 0.742 Kg/liter (6.2 Ibs/gal)
 Ref. 15.
                               8-23

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          TABLE 8-6.  ITEMIZED  ANNUAL OPERATING COSTS OF  VOC CONTROL BY CARBON  ADSORPTION FOR  ROTOGRAVURE
                                       PUBLICATION MODEL  PRINTING PLANTS3
PLANT SIZE
OVERALL VOC CONTROL EFFICIENCY, %
Carbon adsorption system capacity
(solvent laden air flow rate); rnVhr
(ACFM)
Fuel for steam generation
($0.0164/pound recovered solvent)
Electricity
($577/1000 mVhr total process exhaust, per year)
Water and water treatment
Labor - Operating (1460 hrs/yr G>$12.00/hr)
- Maintenance (320 hrs/yr @$13.20/hr)
- Engineering supervision
Maintenance parts and materials
(1% of installed capital cost)
Carbon replacement and valve seal replacement,
including labor (2% of installed capital cost)
Taxes and insurance
(2% of installed capital cost)
Administration and permits
(2% of installed capital cost)
Total annual operating costs
Small
75
90,560
(53,300)
$ 86,800
42,400
3,400
17,500
4,200
5,000
13,100
26,200
26,200
26,200
$251 ,000
Small
80
97,800
(57,560)
$ 92,500
46,600
3,600
17,500
4,200
5,000
13,800
27,600
27,600
27,600
$266,000
Small
85
126,790
(74,620)
$ 98,200
62,800
3,900
17,500
4,200
10,000
17,900
35,900
35,900
35,900
$322,200
Large
75
163,020
(95,940)
$173,500
84,200
6,800
1 7 , 500
4,200
5,000
20,300
40,600
40,600
40,600
$433,300
Large
80
177,510
(104,470)
$185,000
92,600
7,300
17,500
4,200
5,000
22,000
44,000
44,000
44,000
$465,600
Large
85
235,490
(138,590)
$196,500
125,500
7,700
17,500
4,200
10,000
26,800
53,600
53,600
53,600
Se.49,000
CO

ro
        First quarter 1979 dollars

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                                                        19 23  24  27
figures indicated the average was closer to $0.032/kWhr.   '   '   '     This
figure is more representative of the volume of consumption and geographical
cost differences experienced within the industry.   Electrical  utilities
consumption is estimated at 5470 hours per year (75 percent of scheduled
                                                                       3
operation).  The annual  rate of consumption is about 64.9 Gj per  1000 m /hr
of SLA (30,630 kWh per 1000 CFM of SLA) from the production presses.   Hence,
the annual electrical cost is $577 per 1000 m3/hr ($980 per 1000  CFM) of
production press exhaust.  These figures are based on a total  electrical
power requirement of 5.6 kW/1000 CFM of SLA from the production presses.
This power consumption accounts only for the emission control  system.  Also,
the expected water consumption is based only on the emission control  system
needs.
     The calculations of water usage are based on expected make-up for
cooling tower losses and boiler losses on an individual plant  basis.   The
cost of water is estimated at $0.198/m3 ($0.75/1000 gal.).
     The operating labor cost is estimated at $17,500/yr and the  mainte-
nance labor cost is estimated at $4,200/yr for all the model plants.   The
operating labor rate is  estimated at $12.00/hr, which includes  fringe bene-
fits.  Industry sources  indicate the operating labor required  for a  carbon
                                                              19  23  24 27
adsorption unit is about 20 percent of a man's time per shift.   '  '   '
                                                            19 23 24 27
The maintenance labor required is about 40 man-days per year-  '  '  '   at
a rate of $13.20/hr.  Periodic engineering supervision is required to
insure that the adsorption units are operating efficiently.   This  cost is
                             1Q ?"3 9A. 91
estimated at $5,000 per year.  '"'  ' '  The 85 percent efficient systems
have to be maintained at their peak efficiency which requires  engineering
supervision on a more regular basis.  Hence, the cost for these cases is
estimated at $10,000 per year.
     The activated carbon in the adsorption units should have a useful life  of
more than  5 years, as described in Chapter 4.  However, to be conservative,
costs were included to completely replace the carbon bed.  Since  the carbon
adsorption unit must be partially dismantled to replace the activated
carbon, it is also a good time to replace any worn valve seals in the
system.  The total estimated cost of the carbon, valve seals,  and the
labor required for this work is estimated at 10 percent of the installed
                                   8-25

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capital cost;  distributed out over 5 years, the annual cost is 2 percent.
     The annual capital charges are based on a capital recovery factor of
16.275 percent (10 percent interest, 10 year equipment life).  The annup"!
capital charges are determined by multiplying the  installed capital cost
(from Table 8-4) by the capital recovery factor.  These charges are calcu-
lated for each model plant.
     The solvent recovery credit is the dollar-value of the recovered
solvent, for a period of one year.  The amount of recovered solvent is
determined by subtracting the expected emissions from the potential
emissions, using Table 6-1 in Chapter 6.  This is determined for each
model plant.  The solvent, as recovered, is suitable for immediate reuse
in the presses or may be resold to an ink manufacturer.  For this reason,
the credit is figured at the full  market value of the solvent.   The market
value of the solvent in early 1979 as established through discussions with
several printers and a producer was $0.172/liter ($0.65/gal).15  Therefore,
the annual solvent credit is $231/Mg ($21C/ton) of recovered solvent,
assuming 0.742 Kg/liter (6.2 Ibs/gal) for typical mixed solvents.
     The total annualized costs associated with the operation of carbon
adsorption systems in  the model printing plants are presented in Table 8-7.
The cost effectiveness figures are also presented in Table 8-7.  In all
cases studied, the annualized costs represent a savings (credit).  That is
to say, in none of these cases is  there a financial loss associated with
reclaiming the solvent.  These numerical values are intended to illustrate
the relative aspects of the total  annualized cost and cost effectiveness
with respect to the model plant size and overall  level of control.   A
graphical  representation of the purchased costs,  installed capital  costs,
and annualized costs is presented  in Figure 8-4.   The actual  model  plant
cases are illustrated  on these curves.
     8.2.1.3  Emission Monitoring  and Compliance Testing Costs.  Emission
monitoring is assumed  to involve a simple material  balance procedure which can
be used for compliance testing purposes.  This  test could  involve a month-
long period of normal  operation in which a detailed solvent  material
balance is conducted.   The official  recording of the solvent  meter readings
(both solvent supply and recovered solvent)  and the ink meter readings can
                                   8-26

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                        TABLE  8-7.   ANNUALIZED  COST  OF  VOC  CONTROL  BY  CARBON  ADSORPTION  FOR  PUBLICATION
                                                     ROTOGRAVURE MODEL  PRINTING  PLANTS3
co
 i
IX)
                   cSee Table 8-6.

                    Equal  to installed capital cost times the capital recovery factor (Table 8-5).

                    Equal  to Solvent adjustment credit (Table 8-5) times recovered solvent, which equals  potential
                    emissions minus expected emissions shown in Table 6-1.

                  fR 0 t  _ Total annualized savings  y ,«.,
                          Installed capital cost   X 10°-
PLANT SIZE
UVtRAI 1 Vin CONTROL EFFICIENCY, X
Carbon adsorption system capacity
(solvent laden air flow rato); m'/hr
(ACFM)
Instdlled capita] costb
Annual opera tinn, costc
Annual capital charges
Solvent recovery credit6
Total annual lied cost
Cost effectiveness; $/Mg recovered solvent
($/ton recovered solvent)
RETURN ON INVESTMENT (R.O.I.). %
aFirst quarter 19/9 dollars.
bSee Table 8-4.
Sea 11
75
90.560
(53,500)
$1,310,010
$ 251,000
213.200
-554.600
$ - 90,400
-37.67
(-34.18)
6.9

Sn.ill
ao
97,800
(57.560;
$1,378,000
S 266.000
224,300
-591.300
$ -101.100
-39.48
(-35.82)
7.3

Snail
85
126,790
(74.620)
$1,793, 000
$ 32?, 200
291 .800
-627,800
$ - 13.800
-5.07
(-4.60)
0.8

Large
75
163.020
(95.940)
$2,032,000
$ 433.300
330,700
-1,109,200
$ -345,200
-71.92
(-65.26)
17.0

Large
80
177,510
(104,470)
$2,202,000
$ 465,600
358,400
-1,182,600
S -358,600
-70.09
(-63.58)
16.3

Large
R5
235,490
(138.590)
S2, 679. 000
$ 549.000
436,000
i ,?sf),rjon
$ -271,500
-49.82
(-45.33)
10.1


-------
CO
 <
rv>
Co
                                                                                                    751 Control Efficiency
                                                                                                  ° 801 Control Efficiency
                                                                                                  D 85S Control Efficiency
                                    80   90  100  110  120  130  140   150  160  170  180 190  200  210  220 230  240  250

                                    (47) (53) (59)  (65)  (71) (77) (62) (88)  (94) (100) (1C5) (112}(I18)(124) (129)( 135)041) (147}
                          First quarter 1979 dollars
                                                   Solvent Laden Air Flow.Rate. 10' m'/hr (10' ACFM)
                     Figure  8-4.   Cost  of VOC control by carbon adsorption3  for  rotogravure  publication
                                     model  printing plants.

-------
be performed by the operating staff at the plant.   An annual  allowance of
$5,000 to $10,000 has been included in the operating costs presented in
Table 8-6.  This allowance covers the reporting requirements and additional
technical support as required.  No additional expenses are anticipated.
     Appendix D gives more information on emission measurement and contin-
uous monitoring of controlled rotogravure publication printing facilities.
     8.2.1.4  Costs Associated with Increased Hater Pollution and Solid
Waste Disposal.  Carbon adsorption systems have the potential for producing
both a solid waste and wastewater.  The solid waste results from used fiber-
glass air filters and spent carbon.  The spent carbon is frequently sent
back to processors for regeneration and subsequent reuse.  Unuseable carbon
and used fiberglass air filters can be disposed of commercially for subse-
quent incineration or landfill.  This cost is not a significant expense.
     Potential wastewater streams  result from (1) contaminated cooling
tower blowdown or  (2) solvent  laden steam condensate.   Since the model
plants are  assumed to reuse the  steam condensate as boiler feed water,
cooling  tower water  contamination  is eliminated.  Boiler and cooling  tower
water blowdowns  are  expected  to  be very small flows, with very low solvent
levels.   These streams can be  disposed of in a municipal sewer system.
Consequently, wastewater  problems  are not considered to be serious, and
the  costs are not  significant.
8.2.2  Modified/Reconstructed  Facilities
     A complete  discussion of  the  possible changes which result in being
classified  as a  modified  or reconstructed facility are  presented in Chapter
5.   Modifications  and reconstructions are not considered a major item of
significance  in  this industry.   The cost analysis presented  in Section
8.2.1 can be  applied to a modified or reconstructed facility, with the
following qualifications:
      1)   An increase in the SLA  flow may create a need  for more
          adsorber  capacity, which  may present a space  (land)
          problem.
      2)   SLA  collection equipment  costs may  be slightly higher on
          an older  press.  This problem results from the generally
          poor fume containment within older  presses.
                                     8-29

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     3)  Installation costs for ductwork may be more expensive
         than for a new plant.  This is because the old ductwork
         may be too small, thus requiring its removal and subse-
         quent replacement with larger ductwork.
8.3  OTHER COST CONSIDERATIONS
     The publication rotogravure printing industry is governed by regula-
tions concerning the environment within the plant (i.e. the pressroom, etc.)
as well as the outside environment.  This study is only concerned with the
control of airborne VOC emissions outside the plant (in the outside atmo-
sphere).  The responsibility of the working areas within the plant belongs
to NIOSH (National  Institute for Occupational Safety and Health) and OSHA
(Occupational Safety and Health Administration).  A discussion of the work-
ing area environment is presented in Chapter 7 (7.1.2.2).  The costs
incurred by the plants, to meet these worker area regulations, are not
expected to limit the financial ability of these plants to comply with the
proposed New Source Performance Standards (NSPS).
     The EPA has issued a guideline document V for existing gravure
publication facilities, which the states are using to develop SIP regula-
tions.  These regulations, which call for a 75 percent YOC reduction,
are not expected to financially burden the industry.  In fact, the SIP
recommendations of 75 percent VOC control will lead to substantial savings
of money, solvent, and energy.  Consequently, the promulgation of NSPS
will not result in any significant economic problems.

8.4  ECONOMIC IMPACT OF REGULATORY ALTERNATIVES
     The purpose of this section is to present the potential  economic
effects of NSPS volatile organic compound recovery requirements on new
publication and advertising rotogravure printing facilities.   The emphasis
of the analysis is to identify possible adverse impacts on industry growth.
Other impacts to be examined are those on energy consumption,  employment,
inflation, foreign trade and balance of payments.   The section begins with
some relevant supplementary information on the industry,  followed by a
brief discussion of economic impact analytical  methodology.   The analysis
itself, presented next, is based primarily on the  model  plants described  in
                                   8-30

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Chapter 6.  The section concludes with an examination of  industry-wide and
national  impacts.
8.4.1  Supplementary Industry Profile Data and Economic Impact Assessment
       Methodology
     8.4.1.1  Concentration.  In 1972, the four largest firms in the
publication gravure industry accounted for 60 percent of  the total value
                                                                   07
of shipments.  The eight largest together accounted for 83 percent.    A
few new firms have entered the industry since 1972, but it remains rather
highly concentrated.
     8.4.1.2  Integration and Diversification.  A completely vertically
integrated publication gravure printing concern would be  involved  in  ink
and paper production, cylinder preparation, and product sales and  distribu-
tion.  Horizontal integration, strictly speaking, would imply involvement
in other  printing processes.  None of the gravure firms are 100 percent
vertically integrated, but a substantial amount of vertical integration is
commonplace.  Many firms also display significant horizontal integration.
In addition, a number of the firms are highly diversified.  While  little
information is available on firms which are privately owned, several
examples  of publicly-owned corporations are described below.
     Macmillan, Inc., owner of Alco-Gravure, considers itself a diversified
firm in the "transfer of knowledge" industries.   In 1977, printing accoun-
ted for 14.2 percent of its total revenues.  The remainder was divided
among publishing, instruction (Macmillan owns Berlitz and Katharine Gibbs),
musical instruments, and "distribution", including book clubs,  films,
department stores and other retailing.  Alco-Gravure specializes in adver-
                                            38
tising, catalogs, and newspaper supplements.
     R. R. Donnelley and Sons Company, on the other hand, is engaged solely
in printing, but it is the largest commercial printer in the United States.
Donnelley uses all three processes - gravure, offset,  and letterpress - and
does its own typesetting,  platemaking, cylinder preparation, and binding.
The company prints books,  magazines,  catalogs, newspaper inserts,  telephone
directories, and financial  forms and documents.
     The Charter Company,  a highly diversified firm,   owns Dayton  Press,
Inc.   Charter publishes Ladies Home Journal,  Red Book,  and Sport,  and
Dayton prints these as well as McCall's.  Vogue,  House  and Garden,  Readers
                                   8-31

-------
Digest, Newsweek, and Esquire.  The Charter Company is also engaged in
broadcasting, subscription service, direct marketing,  insurance, and oil
refining.  Printing accounted for less than ten percent of Charter's 1977
gross revenue, and approximately one-third of the printing sales were to
                                  40
other segments of the corporation.
     Most of the publicly-owned corporations in the industry fall somewhere
within the range characterized by one of the foregoing examples.  Some are
fairly large, and integrated and diversified primarily within the "communi-
cations" field.  Others are engaged primarily in printing and publishing
with significant vertical and horizontal integration.   A few are highly
diversified firms in which gravure printing may be a relatively small
component.  It is difficult to learn much about the private firms, but
their names suggest that they are less diversified.
     8.4.1.3  Process Economics and Profitability for Model Plants.  The
publication gravure printing industry carefully guards information on
process economics and profitability.   Neither the trade associations nor
the several individual firms contacted were willing to release any data
which could be used in this report.  Fortunately, the lack of such material
is not critical, for, as presented in Section 8.2,'the net cash flow impact
of solvent recovery system installation is positive.   A rigorous analysis
of the absolute effects on profitability was thus neither necessary nor
justified, and process economics data were not needed for the examination
of comparative impacts on different model plants.  Some industry-wide
information on profitability is given in the next subsection.
     8.4.1.4  Financial Profile of the Industry.  Financial information on
the publication gravure industry is scarce and difficult to obtain.  Sta-
tistics are given in government reports for commercial printing (SIC 2751-
2-4) and, on a more limited scale, for commercial printing gravure (SIC
2754), but little is presented for gravure publication or advertising
printing, (SIC 27541 and 27543).  The 1972 Census of Manufacturers reported
the following for SIC 27541:41
                                   8-32

-------
          Value added by manufacture         $199,000,000
          Cost of materials                  $143,600,000
          Value of receipts                  $343,900,000
          Capital expenditures, new          $ 12,000,000
          Total employees                          10,800
          Total payroll                      $126,000,000
          Total production workers                  9,700
          Total wages                        $109,400,000
     The survey conducted in 1976 and 1977 by Gravure Technical Associa-
tion (GTA) and Graphic Arts Marketing Information Service (GAMIS) contains
more extensive statistics for value of gravure-printed publication and
advertising products.
                     1962                   $  561,296,260
                     1965                   $  785,137,000
                     1968                   $  972,766,600
                     1971                   $1,210,831,020
                     1976                   $2,129,200,000
     GTA/GAMIS used Department of Commerce statistics but also data from
printers, equipment manufacturers, publishers groups, trade journals and
                               2
specialized trade associations.   Use of supplementary sources, coupled
with revisions to the SIC system which occurred  in 1972, probably account
for the discrepancy  between the Department of Commerce value of receipts
and the GTA/GAMIS 1971 product value.
     The  annual  reports  of  individual publication gravure printing compa-
nies which are publicly  owned  are of little value in further detailing
the industry  financial profile, because results  of publication gravure
printing  are  invariably  combined with other printing, with printing and
publishing, or with  other  less closely related operations.  Some  informa-
tion could be  extracted  from them on annual operating profit as a percen-
tage of total  sales.   For the  six firms which reported results in suffi-
cient disaggregation to  be  useful for this analysis, the average  profit
                                                          42
for the period from  1973 to  1978 was 8.1 percent of  sales.
     8.4.1.5   Capital  Budgetary Decision Process.  In view of the high cost
of gravure presses,  the  long lead times required by  press manufacturers,
and the present  inability of gravure to compete  with offset printing on
                                   3-33

-------
the shorter runs, it is not surprising that expansions of capacity are
generally not undertaken on speculation or merely on the basis of projected
growth in demand.  A review of trade journal announcements of planned
expansions gives the impression that a gravure printer often has customers
for much of the production of a new press before ordering it.  Conversa-
tions with trade association staff confirm that expansion to meet existing
long-term contracts is commonplace.    Discussions with a representative
of R. R. Donnelley and Sons Company suggest that it is in fact the usual
practice, and that only large firms would undertake speculative expansion.
Most gravure plants have a nucleus of one or more long-term customers who
utilize a major fraction of press capacity and on whose needs expansion
plans are based.  Donnelley's Chicago plant, for example, has Sears as its
               43 44
major customer.  ' •   National Enquirer recently signed 10-year contracts
with Texas Color Printers and Arcata Graphics (Buffalo) to print its nearly
10 million copy weekly circulation.  This triggered an $11 million expan-
sion at Arcata - two new presses with supporting and cylinder engraving
          45
equipment.    Ten year contracts which specify the initial publishing date
and count, and the desired rate of increase in volume are not uncommon.
Contracts may be negotiated 12 to 18 months prior to the first printing
A 4  44
date.
     These practices allow firms to plan orderly expansion and give the
customer the opportunity to have specifications met exactly.  There are
even cases where customers have purchased presses for installation in the
plants of their printers.  Moreover, the contracts are flexible enough
to prevent adverse effects on profits from external factors; prices are
permitted to increase with higher materials costs, and there are usually
                              44
provisions for renegotiation.
     8.4.1.6  Supply, Demand, and Price Elasticity.  The determinants of
supply and demand in the publication gravure industry have been fully
discussed in Section 8.1 as a necessary forerunner of the industry growth
projections presented there.
     There are no published studies of price elasticity for SIC 27541
or 27543, nor were there sufficient price and volume of sales data to
permit an elasticity analysis to be conducted in the context of this
economic analysis.  However, a number of observations suggest that demand
                                    8-34

-------
is relatively inelastic.  First, the industry is successfully convincing
growing numbers of customers that its process is the process of choice for
high quality work on press runs of k!50,000 to 50U,UOO copies and longer.
Many printers agree that offset does not compete well on these long press
runs.  Second, letterpress printing, with which gravure competes, is a
diminishing industry, while gravure continues to grow.  Finally, output
of gravure-printed publications has climbed steadily, and so have paper,
ink, solvent, energy, labor, and therefore production costs and product
prices.
     8.4.1.7  Economic Impact Assessment Methodology.  In this situation,
where model plant control cost projections show that solvent recovery has
a net positive influence on cash flows, and where no other environmental
quality control costs could be identified (Section 8.3), in-depth exami-
nation of impacts on profitability using techniques such as discounted cash
flow analysis was not warranted.  Insofar as profitability was studied, the
emphasis, instead, was on the differential impacts which might be felt by
plants of different sizes and at different levels of control.  Incremental
costs or revenues incurred in moving from baseline control to either of
the higher levels under consideration were compared.  Credit for recovered
solvent, a key variable in the control cost equation, was subjected to
sensitivity analysis, using present and likely future values for solvent.
     In considering whether industry growth might be affected by a proposed
NSPS, the capital investment in model plant control equipment was added
to that for plant and process equipment with baseline controls.  The per-
centage increase in required capital was examined with respect to capital
availability.  This portion of the assessment was necessarily quite general,
since little data on capital investment for model plants could be obtained.
     In order to comply with the requirements of Executive Order 12044,
total annualized control costs were calculated and examined to ascertain
whether they would exceed $100 million in any calendar year between 1979
and 1985.  Total additional costs of production, defined here as total
annualized control costs, were compared with projected value of industry
output, in the absence of specific data for specific products,  to determine
whether price increases greater than 5 percent could be expected.  Energy
                                                            1 ?
consumption by control equipment was compared to the 50 x 10   BTU per
                                   8-35

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year criterion.  Investigation of supply and demand effects on the  speci-
fied critical materials was not relevant for the publication gravure
industry.
8.4.2  Impact on New Facilities
     The analysis of potential NSPS impacts on industry growth includes
examination of effects on capital availability; cash flow, prices,  and
profitability; product substitution; foreign trade and import competition;
and domestic employment.  It  is based primarily on the model plants des-
cribed in Chapter 6.
     8.4.2.1  Capital Availability.  Information on investment in plant and
equipment is not as closely guarded as that on profitability but  is still
difficult to obtain from firms in this industry.   Equipment manufacturers
and specialized engineering consultants were better sources for capital
costs.  Prices for a single, eight-unit, 72-inch publication gravure press
ordered from Motter Printing Press Company could vary from $3.1 to  $5.4
million,  depending on options ordered.    Discounts of ten percent  are
given for additional presses ordered at the same time as the first.  An
average installed price for a typical  press and associated process  equiment
would be approximately $4.5 million.
     Experience in design and construction of publication gravure facili-
ties has  shown that a typical installation requires approximately 70,000
square feet of building space for a single press and its supporting equip-
ment, including ink and paper storage and solvent recovery systems, bindery,
and similar items.   The cost of constructing and equipping such a building,
including utilities, solvent recovery and other supporting equipment but
excluding the press itself and its associated process machinery,  commonly
ranges from $70 to $80 per square foot.  '    Land acquisition is not included
in these estimates, nor has it been considered in this analysis.   It is
usually a small value in relation to the cost of plant and equipment,  and
it is highly variable depending on geographic location, topography, and
many other characteristics.   Moreover, it is not possible to predict the
number of cases in which it will  be a factor;  many plant expansions can
take place on land already owned  by the company involved.
     Table 8-8 has been prepared  on the basis of the foregoing average
costs.  They show the estimated investment in plant and installed equipment
                                   8-36

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     Table 8-8.   MODEL PLANT INVESTMENT FOR PLANT AND EQUIPMENT,
                       EXCLUDING VOC CONTROLS
         Item
2-Press Model Plant
4-Press Model Plant
8-unit, 72-inch presses
t
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required for the two-press  and four-press model plants.    Costs  associated
with solvent recovery have  been deliberately excluded  by reducing  the
median per-square foot building cost  from $75 to $65.  The reduction was
derived from the two-press  installed  capital cost  for  controls with  75
percent recovery efficiency  (see Table 8-4) in the  following manner:
          $1,310,000   CCrC nnr, -     .   ,
          — ! — r2 - = $655,000 for single press recovery  system

           $655,000    t0 ic       f
          7n nnn f4.2 = $9-36 cost of  recovery per  square foot of plant
          /0,000 ft          ared) rouncjed off to  $10
     In Table 8-9, capital costs for each model plant  at 75, 80,  and  85
percent overall solvent recovery are presented.  The incremental  investment
required to increase recovery efficiency from the baseline of 75  percent  to
80 or 85 percent  is shown along with total capital cost.  Table 8-10  shows
the fraction of total capital investment allocated to VOC control  systems
at each level of  solvent recovery, as well as the incremental capital
investment for higher levels of control expressed as a percentage  of  total
capital investment for a baseline (75% recovery efficiency) plant.
     Table 8-10 shows that although VOC control equipment represents  a
significant fraction of total capital investment at any level of  control,
the incremental capital  cost required for either model plant to attain  an
80 percent overall solvent recovery efficiency is very small in comparison
to the total investment for a new plant with a 75 percent recovery effi-
ciency system.  The additional cost of a 85 percent efficient system, in
the vicinity of 2 percent in both cases, is more significant but  not  so
large that it would lead to reduced capital availability which could, in
turn, restrict growth in the industry.
     Second, at the baseline control level, a firm purchasing a new small
model plant would be spending a slightly higher fraction, 1.4 percent, on
solvent recovery equipment than would the buyer of a new large model  plant.
At the 80 percent recovery level, this difference is virtually identical.
The gap widens to 2.1 percent for 85  percent recovery.   The differences are
small enough that a real differential impact on a smaller firm's  ability to
expand its capacity because of capital  limitations is unlikely.
     8.4.2.2  Cash Flows.   Because the overall  effect of solvent recovery
is a net cash inflow at  the levels being evaluated for NSPS,  discounted
                                  8-38

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Table 8-9.  TOTAL AND INCREMENTAL CAPITAL INVESTMENT FOR
   MODEL PLANTS AT THREE OVERALL RECOVERY EFFICIENCIES

Small Model Plant:
For 75% recovery
For 80% recovery
For 85% recovery
Incremental cost,
75 to 80%
Incremental cost
75 to 85%
Large Model Plant:
For 75% recovery
For 80% recovery
For 85% recovery
Incremental cost
75 to 80%
Incremental cost
75 to 85%
Plant/Equipment + VOC Control = Total

$17,650,000
17,650,000
17,650,000





$34,850,000
34,850,000
34,850,000





$1,310,000
1,378,000
1,793,000





$2,032,000
2,202,000
2,679,000





$18,960,000
19,028,000
19,443,000

68,000

483,000

$36,882,000
37,052,000
37,529,000

170,000

647,000
                          8-39

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    Table 8-10.  FRACTION OF CAPITAL INVESTMENT ALLOCATED TO VOC
                  CONTROL AT EACH LEVEL OF RECOVERY
                     Total Control Cost As
                      Percentage of Total
                         Capital Costs
                     Incremental Cost As
                Percentage of Total Baseline
               	Plant Capital Cos t s
Small Model Plant

 75% recovery
 80% recovery
 85% recovery

Large Model Plant

 75% recovery
 80% recovery
 85% recovery
6.9%
7.2%
9.2%
2.5%
5.5%
5.9%
7.1%
1.8%
                                  8-40

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cash flow modeling was not  considered  necessary  for  the  economic  impact
analysis.  Total annualized control  costs were scrutinized,  however,  to
identify differences  in  incremental  impact  on the  two model  plant  sizes.
In addition, the solvent recovery credit term in the control  cost  equation
was subjected to sensitivity  analysis  because it has a substantial  effect
on the projected costs.
     In Table 8-11, total annualized control costs given  in  Table  8-7
are summarized and the incremental costs associated  with  80  percent and
85 percent recovery are  shown.  Negative total costs represent  net  cash
inflows.  Negative incremental costs represent decreases  in  net control
cost or increases in  net cash  inflows.
     The table shows  that net  cash inflows  are projected  from any  of  the
three control levels  at  either size  plant due to reuse, return, or  sale
of recovered solvent.  It also shows that a profit-maximizing operation
of either size would  logically practice 80  percent recovery,  or a  slightly
higher level, since increased  profits  should result.  In  moving to  the 85
percent control level, however, the  annual  operating and  capital charges
begin to exceed the savings and revenue realized from additional recovered
solvent (see Table 8-7), and the incremental values  in this  table  become
positive, reflecting  a decrease in net cash inflow.

     Sensitivity analysis showed that the incremental control costs were
highly responsive to small  changes in the price of recovered  solvent.  The
price used as the basis of the recovered solvent credit in Table 6-7 was $.17
per liter ($.65/gal),  the prevailing  market price in early 1979.  By July 1,
1979,  the price had  risen to $.21/1  ($.80/gal)  and was expected to reach
$.24/1  ($.90/gal)  easily by the year's end.     Since many solvent  components
are used in much  larger quantities  in gasoline production, it is unlikely
that  any decreases  in  price will  occur in the next  five years.
     In Figure 8-5,  the effects of  anticipated  increases   in solvent price
in 1979 on incremental annualized  control  costs  are shown with all  other
                                   8-41

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      Table 8-11.  TOTAL AND INCREMENTAL ANNUALIZED COST OF VOC CONTROL3
 Small model
  plant
 Large model
  plant	
               75% Recovery
                  Total
$ -  90,400
$ - 345,200
                  80% Recovery
                         Incremental
                Total      From 75%
$ - 101,100  $ - 10,700
$ - 358,600  $ - 13,400
                             85%  Recovery
                                     Incremental
                            Total      From 75%
$ -  13,800  $ + 76,600
$ - 271,500  $ + 73,700
a,-.
 First quarter 1979 dollars based on a recovered solvent price of $.17/1 Her
 ($.65/gallon)—See Table 8-7.
                                   8-42

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       Figure 8-5.    INCREMENTAL COST OF VOC CONTROLS ON  MODEL
          PLANTS  AT  VARIOUS SOLVENT PRICES, ALL  OTHER
                          COSTS  CONSTANT  a
    80
    70
    60
    50
    40
    30
    10
              POSITIVE COST » DECREASED NET CASH INFLOW
                                                                     Small - 85%
                                                                      A
                                                                      Large -  85%
2  -10
   -20
   -30
   -40 —
   -50
              NEGATIVE COST * INCREASED NET CASH INFLOW

                   I	I	I	I	I
                                                                      Small  - 80%
         0.17      0.18     0.19
0.20
0.21     0.22
                                                            0.23     0.24
           0.65
          0.80
                                                                   0.90
5/Liter

$/Gallon
                             SOLVENT PRICE
       aFirst quarter 1979  dollars  -- Table 8-7 solvent recovery credit adjusted
        for increases in solvent cost value.
                                   8-43

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elements of the control costs in Table 8-7 held constant.   Figure  8-6
displays similar information with capital and operating control  costs
increasing by an assumed 5 percent up to the middle of 1979 and  about
10 percent to the end of 1979 to compensate for inflation.
     Eighty percent recovery has already been shown to be beneficial,  from
a cash flow standpoint, to either size model plant.  The two figures show
that with increasing solvent prices, both will enjoy further net increases
in cash inflow.  At 85 percent, however, both model plants would experience
net decreases in cash inflows even with the anticipated near-term  solvent
cost value increases.  The large plant's position improves more  rapidly with
increasing solvent costs than does the small plant's, so that a  gap
develops between the two and becomes wider with each increase.
     8.4.2.3  Profitability.  One conclusion that can be drawn from the
cash flow analysis is that profitability will not be adversely affected by
imposition of 80 percent recovery requirements on either the two-press or
four-press model plant.  Consequently, these cases will not be considered
further in this subsection, and the profitability analysis will focus
instead on the differences in impacts of 85 percent recovery requirements
on the two plant sizes.
     In the absence of specific information on process economics for a
publication rotogravure facility, two assumptions were made for the profit-
ability analysis.   The first, based on 1976 industry output and installed
capacity, is that the annual gross income produced by a single, eight-unit,
72-inch press at a typical utilization rate of 80 percent of practical
capacity is $15.8 million in 1976 dollars.   (See Subsection 8.1.2.3 for
the basis for this estimate.).   This estimate must be inflated to $18.0
million 1979 dollars, on the basis of printing and publishing industry cost
and price experience, to permit direct comparison with control costs.
The second assumption is that the pre-tax operating income from each press,
with baseline (75 percent) solvent recovery, is 8 percent of gross income.
(See Subsection 8.4.1.4.)  The simplified pro-forma statements in Table
8-12 can then be produced.
                                   8-44

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Figure 8-6.   INCREMENTAL  COST OF  VOC  CONTROLS  ON  MODEL  PLANTS  AT
    VARIOUS SOLVENT PRICES, OTHER  COSTS ADJUSTED FOR ASSUMED
               INFLATION DURING  1979 a
           80
           70
           60
           50
           40
           30
       o
       §   20
           10
                JANUARY
                  JULY
                                                           DECEMBER
       =  -10
          -20
          -30
          -40   _
          -50
                                                                  Small - 851
                                                                Large - 855!
POSITIVE COST = DECREASED NET CASH INFLOW
                                                                Small - 801
                                                                Large - 801
                        NEGATIVE COST =• INCREASED NET CASH INFLOW
                 0.17   0.18   0.19

                    I	
             0.20  0.21

            	I
0.22   0.23  0.24
             J
                   0.65
                    0.80

            SOLVENT PRICE
            0.90
$/Liter


$/Gallon
               Table 8-7 Total Annualized costs adjusted for increases  in solvent
               cost value with 5 percent and 10 percent increases in capital  and
               operating costs through mid to end of  1979, respectively.
                                        8-45

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           Table  8-12.   MODEL  PLANT  ANNUAL  OPERATING  INCOME
                   AT  75 PERCENT  SOLVENT  RECOVERY

	Sma 11	Large  	

 Gross  Income3               $36,000,000                 $72,000,000
 Less  Operating  Expenses       33,120,000                  66,240,000
 Net  Operating  Income         $  2,880,000                 $  5,760,000
  Before  Taxes"	_____	

  $18.0 million  (1979)  income per  press
  Assumed to  be  8.0  percent  of  gross  income
                                   8-46

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     Table 8-13 shows the changes which would occur in those statements
at 85 percent recovery, using various solvent prices.   This is the "worst
case" condition; it assumes that the large plant does not change its
product prices and that to remain competitive, the small plant does not
increase its prices either, although it experiences slightly higher oper-
ating cost because of the increment added for additional solvent recovery.
The table shows changes in profit caused by adding the control cost incre-
ment to the operating costs and subtracting the total  cost from gross
income.
     This analysis shows that the large plant's rate of operating profit
would be consistently higher than the small plant's at 85 recovery.
However, the differences are very small, between 0.1 and 0.2 percentage
points.  Moreover, in neither model does the profit vary by more than
0.2 percentage points from the assumed starting rate of 8.0 percent.
     The reason for these small magnitudes of change in profitability  is
that the absolute values of the incremental control costs are in every case
much less than one percent of the total operating expenses.  Consequently,
while the incremental costs themselves show the small model to be at a slight
competitive disadvantage under a standard requiring 85 percent solvent
recovery (subsection 8.4.2.2), the effect would be translated into a
scarcely noticeable impact on profitability.
     8.4.2.4  Prices.  The minimal changes in profitability described  in
the preceding subsection should not result in any significant price changes
for gravure products.  Prices are likely to rise during the 1980 to 1985
period, but as a result of the continuing paper shortages and increasing
energy and ink constituent costs described in Subsection 8.1.2.2.
     8.4.2.5  Product Substitution.  Because there are no significant NSPS-
related projected price increases, implementation of NSPS will not result
in product substitution.  The present trend of increasing market share in
the publication gravure industry would not be affected by implementation of
either NSPS under consideration.
     8.4.2.6  Small Business Aspects.  Officially, a gravure firm qualifies
as a small business for loan purposes if it has 500 or fewer employees, in-
cluding those of the parent corporation. Practically,  even the smaller ones
of the existing publication gravure firms are not "small" businesses if one
                                   8-47

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    Table 8-13.  MODEL PLANT ANNUAL OPERATING INCOME AND PRE-TAX PROFIT
                   AT 85 PERCENT SOLVENT RECOVERY
                          Operating
                          Expenses
                Net Operating
                   T     b
                   Income
                  Percentage
                    Profit0
Solvent price $.17/1  ($.65/gal):
 Small plant
 Large plant
$33,196,600
 66,313,700
$2,803,400
 5,686,300
7.8
7.9
Solvent price $.21/1  ($.80/gal):
 Small plant
 Large plant
 33,179,400
 66,279,100
 2,820,600
 5,720,900
7.8
7.9
Solvent price $.21/1  ($.80/gal); all other control costs increased 5%:
 Small plant
 Large plant
 33,186,900
 66,290,200
 2,813,100
 5,709,800
7.8
7.9
Solvent price $.24/1 ($.90/gal):
 Small plant
 Large plant
 33,166,500
 66,253,000
 2,833,500
 5,747,000
7.9
8.0
Solvent price $.24/1 ($.90/gal); all other control costs increased 10%:
 Small plant
 Large plant
 33,181,500
 66,275,100
 2,818,500
 5,724,900
7.8
8.0
 aTotal  expenses for 75 percent VOC control shown in Table 8-12 plus
  incremental costs for 85 percent VOC control oresented in Figures
  8-5 or 8-6.
  Equal  to Gross Income shown in Table 8-12 minus Operating Expenses,
  'Profit % = Net Income
             Gross Income
   X 100
                                  8-48

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considers the size of the necessary capital investment and the extent of in-
tegration and diversification.  In either case, the analyses in subsections
8.4.2.1 through 8.4.2.3 indicate that within the range of likely new source
sizes there would be no major differential impacts related to firm size.
     8.4.2.7  Competition From Imports.  Foreign trade, relatively minor in
this industry at present, would not be affected by the proposed NSPS.
     8.4.2.8  Domestic Employment.  As industry growth would not be altered
by the NSPS under consideration (see Subsection 8.4.2.1), employment would
not be adversely affected.  New sources will be more heavily automated than
existing equipment, however, and this will increasingly limit the number of
new jobs made available by each increment of expansion in the industry.
     8.4.2.9  Summary of Conclusions for New Facilities.   Neither 80 per-
cent nor 85 percent solvent recovery requirements would pose problems of
capital availability and thus adverse impacts on industry growth.  From
a cash flow point of view, it appears to be in the industry's own best
interests to recover somewhat more than 80 percent of solvent used volun-
tarily.  Compliance with 85 percent recovery appears less profitable for
both size plants at current and projected solvent costs.  The differences
in impact on the larger and smaller plants at 85 percent would be very small
and should not affect competition in the industry.  No measurable price
impacts are anticipated.  Small business would not be adversely affected,
nor would foreign trade or domestic employment suffer.
8.4.3  Modified or Reconstructed Facilities
     Chapter 5 describes actions which would lead to designation of an
existing rotogravure press as a modified or reconstructed facility subject
to NSPS.  It also presents the reasons for concluding that modification or
reconstruction is a highly unlikely event in this industry.   These points
are discussed more fully in Suosection 8.1.2.4.  Because any facilities
affected by the proposed NSPS are almost certain to be newly constructed,
a separate economic impact assessment has not oeen conducted for modification
or reconstruction.
                                    3-49

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8.5  POTENTIAL SOCIOECONOMIC AND INFLATIONARY IMPACTS
     Socio-Economic Impact Assessment.  The purpose of Section 8.5 is to
address the tests of macro-economic impact presented in Executive Order
12044 and, more generally, to assess any other significant macro-economic
and social impacts that may result from the NSPS.
     The economic impact assessment is only concerned with the costs or
negative impacts of the NSPS.   The NSPS will also result in benefits or
positive impacts such as cleaner air and improved health for the popula-
tion, potential increases in worker productivity, and increased business
for the pollution control manufacturing industry.  However, these NSPS
benefits will not be discussed here.
     Executive Order 12044.   Executive Order 12044 provides several cri-
teria for a determination of major economic impact.  Those criteria are:
     1.   Additional annual  costs of compliance, including capital
          charges (interest  and depreciation), total $100 million  (i)
          within any one of  the first five years of implementation (normally
          in the fifth year  for NSPS), or (ii) if applicable, within any
          calendar year up to the date by which the law requires attainment
          of the relevant pollution standard.
     2.   Total additional cost of production of any major industry product
          or service exceeds 5 percent of the selling price of the product.
     3.   The administrator  requests  such an analysis (for example, when
          there appear to be major impacts on geographical regions or local
          governments).
8.5.1  Additional Costs of Compliance
     As described in Subsection 8.1.2.4, a maximum of 75 new sources are
projected to be constructed  during the five years this  analysis addresses.
It is unlikely that more than one four-press expansion  or new plant will
be opened in any given year; the remainder will  be assumed to be two-press
facilities, although single  press expansions will undoubtedly occur.  On an
industry basis, then, 75 new gravure  presses will be subject to NSPS--five
large model  plants and 27-1/2 small  ones.   The incremental  annualized costs
of VOC control at the 85 percent level versus  the 75 percent level was
presented in Table 8-11.  Thus, the total  additional costs of compliance
                                  8-50

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in the fifth year, in early 1979 dollars, for control at the 85 percent
level  nay be projected as follows:

     27-1/2 small plants x $76,600          =    $2,106,500
     5 large plants x $73.700               =   +   368.500
     Fifth year additional annualized cost  =    $2,475,000
This is the "worst case " - all other combinations of solvent price and
recovery efficiency will yield lower total costs - and it clearly does not
nearly reach the $100 million threshold of major economic impact.
8.5.2  Excessive Additional Production Costs
     As shown in subsection 8.4.2.3, total additional costs of production
will vary by much less than 1 percent.  The resulting rates of net profit
from operations will be reduced by no more than 0.2 percentage points.
Total  additional annualized costs will be increased by approximately
0.1 percent of total industry revenues in the worst case.  Mo major
economic impact is indicated.
                                   8-5]

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8.6  REFERENCES
1.   U.S. Department of Commerce,  Industry and  Trade Administration.
     1979 U.S.  Industrial  Outlook.   U.S.6.P.O.   January  1979.   p.  90.
2.   Daum, Warren R. and Robert P.  Long.   Profile  of the American  Gravure
     Industry,  1976-77.  New York,  Gravure Technical  Association,  Graphic
     Arts Marketing Information Service of the  Printing  Industries of
     America, 1978.  p. 17-19.
3.   Ref. 1,  p. 103.
4.   Ref. 1,  p. 89.
5.   Ref. 2,  p. 13.
6.   Daum, Warren R.  Gravure Surges Forward.   Graphic Arts  Monthly.
     April 1979.  pp.  39-44.
7.   Chemical Market Reporter.   October 9, 1978.
8.   Telecon.  DeWitt, George,  Sales Manager, Motter Printing  Press
     Company, with Walton, Thomas  E., Jaca Corporation.   May 18,  1979.
9.   Ref. 2,  p. 56.
10.  U.S. Department of Commerce,  Bureau of the Census.   Current  Industrial
     Reports:  Survey of Plant Capacity.   U.S.G.P.O.   1977.  p.  5, A-l.
11.  Telecon.  Daum, Warren, R., Executive Director,  Gravure Technical
     Association, with Walton,  Thomas E., Jaca  Corporation.  May  8, 1979.
12.  Ref. 1,  p. 101.
13.  Mcllhenny, J. H.   The Gravure Publication  Industry  - Some proposals
     for coping with the future.  Gravure Bulletin XXIX:2.   1976.
     p. 47-49.
14.  Telecon.  Pasquale, Vincent,  Inmont Corporation, with Walton, Thomas  E.,
     Jaca Corporation.  July 3, 1979.
15.  Telecon.  Emmerton, Mr., Charter Oil Co.,  with Reich,  Richard, Radian
     Corporation.  June 5, 1979.
16.  Ref. 2,  p. 55-56, 63.  Supplemented by personal  communication with
     industry  representatives.
17.  U.S. Department of Commerce,  Bureau of the Census.   Current  Industrial
     Reports:  Survey of Plant Capacity.  U.S.G.P.O.   1976.  p.  19.
                                   8-52

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 18.  Control  of Volatile Organic Emissions from Existing Stationary
     Sources  - Volume VIII:  Graphic Arts - Rotogravure and Flexography.
     EPA-450/2-78-033, OAQPS No. 1.2-109, U.S. Environmental Protection
     Agency.  Research Triangle Park, NC  27711.  December 1978.
 19.  Watkins, B. Gordon Jr. and Paul Marnell.  Solvent Recovery in a
     Modern Rotogravure Printing Plant.   (Presented at EPA Conference on
     "Environmental Aspects of Chemical Use in Printing Operations:, King
     of Prussia, PA.  September 22-24, 1975.)
 20.  Trip Report.  Plant Visit to R. R. Donnelley & Sons Company,
     Chicago, Illinois.  Richard A. Reich, Radian Corporation.
     August  24, 1978.
 21.  Trip Report.  Plant Visit to Standard Gravure, Louisville, KY.
     Richard A. Reich, Radian Corporation.  September 25,  1978.
 22.  Trip Report.  Plant Visit to Meredith/Burda, Inc., Lynchburg,
     Virginia.  Richard A. Reich, Radian Corporation.   October 26,
     1978.
 23.  Letter from Verdooner, Marcel, Alco-Gravure, Inc. to  Reich,
     Richard A., Radian Corporation.  November 13, 1978.
 24.  Letter from Bender, Gerald J., R. R.  Donnelley &  Sons Company to
     Vincent, Edwin J., EPA.  November 21, 1978.
 25.  Trip Report.  Pre-test Plant Visit to the Texas Color Printers
     Plant, Dallas, Texas.  Richard A. Reich,  Radian Corporation.
     March 1, 1979.
 26.  Letter from MacAskill, Philip, Texas  Color Printers,  Inc.  to
     Reich, Richard A.,  Radian Corporation.   October 19, 1978.
 27.  Letter from Worrall,  Michael  J.,  American Ceca  Corporation to
     Andersen, Theresa J., Radian Corporation.  October 19,  1978.
 28.  Telecon.   Dundee, Mitchell  D., Croftshaw  Engineers, with Reich,
     Richard A.  Radian Corporation.  March 23, 1979.
29.  Telecon.   Cannon, Tom, Vic  Manufacturing  Company, with  Reich,
     Richard A.,  Radian  Corporation.   March 26,  1979.
30.  Telecon.   Moses,  William, Sutcliffe Speakman  &  Company,with
     Reich,  Richard A.,  Radian Corporation.  April 2,  1979.
                                  8-53

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31.   Telecon.   Seguy,  Bernard, American Ceca Corporation, with Reich,
     Richard A.,  Radian Corporation.  April 24, 1979.
32.   Telecon.   Rodriques,  Gene,  Homer & Company, with Reich, Richard A.,
     Radian Corporation.   April  3,  1979.
33.   Telecon.   Duff,  Paul, Yeargin  Co., with Reich,  Richard, Radian
     Corporation.   April  2, 1979.
34.   Telecon.   Moses,  William, Sutcliffe Speakman &  Co., with Reich,
     Richard A.,  Radian Corporation.  April 2,  1979.
35.   Telecon.   McGee,  Larry, Comfort  Engineering, with Reich, Richard A.,
     Radian Corporation.   May 22,  1979.
36.   U. S. Department of Energy, Form CLC-92,  April,  1979.
37.   U.S. Department of Commerce,  Bureau of the Census,  Census of
     Manufacturers, 1972,  U.S.G.P.O.   1976, p.  SR2-90, VOL.  I.
38.   Macmillan, Inc.,  Annual Report,  1977.
39.   R.R. Donnelley and Sons Co.,  Annual Report,  1978.
40.   The Charter Company,  Annual Report, 1977.
41.   U.S. Department of Commerce,  Bureau of the Census,  1972 Census  of
     Manufacturers, U.S.G.P.O.,  1972, p.  27B-16,  VOL. II.
42.   Firms are Macmillan, Charter,  Meredith and Meredith/Burda,  George
     Banta, and City Investing Company.
43.  Telecon.   Daum, Warren R.,  Executive  Director,  Gravure Technical
     Association, with Walton, Thomas E.,  Jaca Corporation,  July 30,1979.
44.  Telecon.   Bender, Gerry, Corporate Engineer,  R.R.  Donnelley and
     Sons Co., with Walton, Thomas E.,  Jaca Corporation.  August 1,  1979.
45.  Ynostroza, Roger, "Like it or Not,  Gravure is  Hot", Graphic Arts
     Monthly,  October  1978, p. 37.
46.  Telecon.  Loeback, Michael, Motter Printing  Press Company,  with
     Reich, R.A.-Radian Corp.  March 29, 1979.
47.  Telecon.  DeWitt, George, Motter Printing Press Company,  with
     Reich, Richard A., Radian Corporation.  August 25,  1978.
48.  Telecon.  Miller, James W., Wiley and Wilson,  Inc., with  Walton,
     Thomas E., Jaca Corporation.  August 15, 1979.
                                   8-54

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49.   Telecon.   Connelly,  G.-Wiley & Wilson,  Inc., with Walton, T.E.-Jaca Corp.
     July 18,  1979.
50.   Telecon.   Eldridge,  D.-U.S. Department  of  Commerce, Bureau of Economic
     Analysis, with  Walton,  T.E.-Jaca  Corp.   August  21, 1979.  Price
     deflators for gross  product originating in SIC  27 unpublished data.
     1972 = 100.0, 1976 = 133.0, 1977 = 142.5,  1978  = 151.5.
                                   8-55

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       Appendix A - Evolution of the Background Information Document

     The purpose of this study was to develop a basis for supporting
proposed new source performance standards (NSPS) for the publication
rotogravure printing industry.  Primarily the study involved gathering
and analyzing relevant data in such detail  that a reasonable performance
                                               »
standard could be developed, proposed, and  defended.  To accomplish the
objectives of this program technical data was acquired on the following
aspects of the publication rotogravure printing industry:  (1)  printing
operations and processes; (2) the release and controllability of organic
emissions into the atmosphere by this source; and (3) the types and
costs of demonstrated emission control technologies.  The bulk  of this
information was retrieved from the following sources:
      -  open technical literature
      -  meetings with specific companies, trade associations,  and
         regulatory authorities
      -  plant visits
      -  emissions source testing.
      Radian Corporation started work on this study in June 1978, following
the completion of the  EPA screening study.  This work was under the direction
of the Office of Air Quality  Planning and Standards (OAQPS), Emission
Standards and Engineering Division  (ESED) with Mr. Edwin J. Vincent of the
Chemicals and Petroleum Branch  (CPB) as the lead engineer.  The study was
performed under EPA Contract  Number 68-02-3058.
     In June, 1978, a literature search began with the automated biblio-
graphic  and directly type data bases available through Lockhead Retrieval
Service's DIALOG and Systems  Development Corporation's ORBIT,    The data
bases search included APTIC,  Chemical Abstracts, Engineering Index, NTIS,
ENVIROLINE, EIS Plants, Comprehensive Dissertations International, and
PAPERCHEM.  Most data  bases covered the literature from  1970 to the present.
The key  word "Rotogravure" was used.  The information found in the literature
was, for the most part, out-of-date or more applicable to specialty and
packaging gravure than to publication rotogravure.
                                    A-l

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      The  results of the GTA/GAMIS survey were the most valuable outcome of
 the  literature search.  This survey was conducted in 1976 by the Gravure
 Technical  Association  (GTA) and the Graphic Arts Marketing Information
 Service  (GAMIS) of the Printing Industries of America.   From this survey
 Radian   learned enough about the industry to conduct a telephone survey
 of the industry and its suppliers.
      A  list of sixteen companies and their subsidiaries (27 plant sites)
was obtained from the Gravure Research Institute (GRI)  in June, 1978.
 Key personnel at each of these sites were contacted by phone.  It was
 therefore  concluded that the initial list of 27 sites was complete.   One
of these sites was deactivated in mid-1978, but it was  included in the
1977 totals.  Table A-l lists the industry personnel  contacted and their
titles.   These contacts continued from June 1978 to September 1979.
      A  list of the federal, state and local  Air Pollution Control  personnel
contacted  is included as Table A-2.   Emissions data was generally available
from the state agencies, but there was often confusion  about the validity
or the interpretation of the figures.   Two common problems were bed  effici-
ency given as overall  efficiency and data from recent permits given  without
note of the fact that there might be older presses with less efficient
controls, or with no controls,  at the same site.   Radian sometimes was
also given out-of-date information.
      A number of industry personnel  were willing to  discuss their problems
and their satisfaction with their emission control  systems.   Several  also
gave Radian published brochures detailing the operation and  the economics
of their systems.   Information  on specific systems was  also  gathered  during
the plant visits  listed as Table A-3.   Radian relied  on vendors and  plant
visits for details of the most  efficient adaptions of fixed  bed carbon
adsorption, and other available control  techniques.   The vendors  contacted
for this  study are listed as Table A-4.
      The chronological history of the development and  evolution  of  the
proposed  standards is listed as Table A-5.
                                    A-2

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      In addition to Radian, two other companies also had input to this
study.  They were JACA Corporation and Monsanto Research Corporation.
JACA, under the EPA direction of Mr.  Neil  Efird of the Economic Analysis
Branch (EAB), prepared the economic impact analysis.   Monsanto, under  the
EPA direction of Mr. Frank Clay of the Emission Measurement Branch (EMB),
performed all of the emission source  testing.   Also during Phase II,
Mr. William MacDowell  of the Standards Development Branch (SDB) helped
direct the preparation of the BID and preamble package for presentation
at the Working Group,  NAPTAC, and Steering Committee meetings.
                                    A-3

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  TABLE A-l.   PUBLICATION ROTOGRAVURE INDUSTRY REPRESENTATIVES CONTACTED
ALCO GRAVURE, INC.
    Comptroller - North Hollywood, CA.
    Bob Gellatly, Eng. Dept. - North Hollywood, CA.
    Doug Johnson, Press Room Superintendent - Memphis, TN»
    W.A. Milanese, Sr. Vice President of Manufacturing and
      Technical  Services - New York, NY
    Marcel Verdooner, Plant Manager - North Hollywood, CA.
ARCATA GRAPHICS
    John Dona - Depew, NY
    Jerry Uhrland, Manager of Eng. Services - San Jose, CA.
ARCATA PUBLICATIONS GROUP
    Frank Beacham, Vice President of Technical
      services - Stamford, CN.
ART GRAVURE
    David Ring, Plant Manager - Cleveland, OH
DAYTON PRESS
    Bob Fremgen, Manager of Environmental and Chemical Engineering -
      Dayton, OH
DENVER POST
    Don Ciefer, Head of Rotogravure - Denver, CO,
    Robert Zeis, Business Manager - Denver, CO.
DIVERSIFIED PRINTING
    Barry Neal, Technical Director - Atglen, PA.
GRAPHIC ARTS TECHNICAL FOUNDATION
    Dr. William D. Schaeffer, Research Director - Pittsburgh, PA.
GRAVURE RESEARCH INSTITUTE
    Harvey George, Executive Vice President and
      Research Director - Port Washington, NY
GRAVURE TECHNICAL ASSOCIATION
    Warren Daum, Director - New York, NY
                                    A-4

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                          Table A-l.   (Continued)
GRAVURE WEST
    J. Stegeman, Plant Manager - Los Angeles,  CA.

KABLE PRINTING CO.
    Richard Watson, Manager of Printing - MT.  Morris, IL.

MEREDITH CORP.
    Bob Cottrell,  Vice President & Head of Eng.  -  Des Moines,  IA.
    John Downey, Plant Manager - Des Moines, IA.
    Gary Johnson,  Vice President of Eng. - Des Moines, IA.
    George Ruby, Vice President - Des Moines,  IA.

MEREDITH/BURDA, INC.
    Heinz Gugler,  Director of Eng. - Lynchburg,  VA.

NEWSPOINT GRAVURE PLANT-NEW YORK NEWS,  INC.
    Richard Taglieri, Building Maintenance Manager - Long Island City, NY
    Gregory Tyszka, Manager of Gravure  Presses - Long Island City, NY

PROVIDENCE GRAVURE, INC.
    Jim Stefanik, Eng. Maintenance - Providence, RI.
    James Trier, Chief Engineer - Providence,  RI.

R.R.  DONNELLEY AND SONS CO.
    Gerald J. Bender, Manager of Process Eng. & Development Dept. -
      Chicago, IL.
    Stephen Blecharczyk, Project Eng. - Chicago, IL.

SPRINGFIELD GRAVURE CORP.
    Tony Ringler, Division of Eng. - Springfield, OH.

STANDARD GRAVURE CORP.
    Jim Anderson, Vice President & Technical Director - Louisville, KY
    B. Bockman, Vice President & General Manager - Louisville, KY
    Jack Uhl,  Engineer - Louisville, KY
                                    A-5

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                         Table A-l.   (Continued)
TEXAS COLOR PRINTERS
    Peter Gristansky, Salesman & Personnel  Director - Dallas, TX
    Oscar Wargnier, Boiler Room Superintendent - Dallas, TX.
    Everitt Williams, Eng. Manager - Dallas, TX.

TRIANGLE PUBLICATIONS, INC.
    Fred Duffy, Manager of Manufacturing - Philadelphia, PA.
    Edward Hastings, Engineer - Philadelphia, PA.


W.F. HALL PRINTING CO.  (CHICAGO ROTQPRINT & HALL OF MISS.)
    A.J. Aligretti, Vice President of Engineering - Chicago,  IL.

WORLD COLOR PRESS
    Fred Nasser - Effingham, IL.
    John Newsome, Vice President & Director of Research & Eng.  -
      Effingham, IL.
                                    A-6

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      Table A-2.   FEDERAL, STATE & LOCAL AIR POLLUTION CONTROL AGENCY
                  PERSONNEL CONTACTED DURING THE SURVEY OF THE
                  PUBLICATION ROTOGRAVURE INDUSTRY
CALIFORNIA

  Johnson Lam, State EPA
  Teresa Lee, Bay Area EPA
  George Rhett, South Coast EPA

COLORADO

  Dan Rogers, State EPA

CONNECTICUT

  Dave Nash, State EPA

ILLINOIS
  Lai it Banker, Regional EPA
  Si Levine, Regional EPA
  Gary Melvin, State EPA
  Dick Pressler, State EPA
  Gary Stonewall, Regional EPA

INDIANA
  Robert Ondrusek, State EPA

IOWA

  Bob Karachiwala, State EPA
  Bob Moss, Polk County EPA

KENTUCKY
  Richard Eberhard, Jefferson County EPA

MARYLAND

  Donald Palmer, State EPA
  Russell Summers, State EPA

MINNESOTA

  Tom Townsend, State EPA

MISSISSIPPI

  Tom Adams, State EPA
                                    A-7

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                              Table A-2. (Continued)
NEU YORK
  Sidney Marlow, State EPA

NORTH CAROLINA
  Charlotte Chamber of Commerce
  James McColman, State EPA

OHIO

  Charles Kirk, State EPA
  Robert Miles, Columbus EPA
  Jim Orleman, State EPA
  John Paul, Dayton EPA

PENNSYLVANIA
  John Hambright, State EPA
  Bill Reilly, Philadelphia EPA

RHODE ISLAND

  Douglas McVay, State EPA

TENNESSEE
  Tom Dale,  Shelby County EPA
  James Haynes, State EPA

TEXAS
  William Chafin, Fortworth TACB
  Robert James, Austin TACB
  Jessie Macias, Region 8 EPA
  Lawrence Pewitt, State EPA
  Charles Shevlin, Austin TACB

U.S. EPA
  Harold Barkhaw, OAQPS, MDAD, NADB, RTOP, NC

VIRGINIA
  C. B. Holloway, Jr., VACB
  A. K. Jain, VACB
  W.W. Parks, Region 3 EPA
                                     A-8

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                 TABLE A-3.   PLANT VISITS
         Date


July 24, 1978


August 14, 1978


August 15, 1978


September 7, 1978



September 15, 1978


December 11-16, 1978



January 3, 1979


February 20, 1979



February 22, 1979



April 9-13, 1979



September 27, 1979



January 22-24, 1980


May 6, 1980
       Location


R.R. Donnelly & Sons,  Co.
Chicago, IL

Standard Gravure Corp.
Louisville, KY

World Color Press
Salem, IL

Alco Gravure Corp.
California Rotogravure  Div.
North Hollywood, CA

Meredith/Burda, Inc.
Lynchburg, VA

Meredith/Burda, Inc.
  (Emission Test)
Lynchburg, VA

Texas Color Printers
Dallas, TX

World Color Press
  (Pre-Test Survey)
Salem, IL

Texas Color Printers
  (Pre-Test Survey)
Dallas, TX

Texas Color Printers
  (Emission Test)
Dallas, TX

Meredith/Burda, Inc.
Lynchburg, VA

Meredith/Burda, Inc.
Lynchburg, VA

Standard Gravure Corp.
Louisville, KY
                          A-9

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            Table A-4.  SUPPLIERS TO THE ROTOGRAVURE PRINTING
                           INDUSTRY CONTACTED
 AMERICAN CECA
   Michael  Worrall ,  Manager of Solvent Recovery Division - Oak Brook, IL
   Bernard  Seguy
 CALGON CORP.
   Frank Bossie,  Sales Representative - Pittsburgh,  PA
 CHARTER OIL
   Mr.  Emrnerton,  Marketing Manager -  Houston,  TX
   Al  Youens
 COMFORT ENGINEERING
   Larry McGee -  Austin,  TX
 CRODA  INKS CORP.
   Severino Tarinas  -  Niles,  IL
CROFTSHAW ENGINEERS (changed to SIMON-CHROFTSHAW, INC. in 1980)
  Mitchell  Dundee,  President - Larchmont, NY (Before  1980)
  Robert Wuyts, Executive Vice President - Red Bank,  NJ (After 1980)
DuPQNT CO.
  John Straub - Wilmington, DE
GOTHAM INK
  Sam Kantor - New  York, NY
HORNER & CO.
  Gene Rodriques -  San Antonio, TX
INDEPENDENT PETROLEUM
  Greg Browne - St. Louis, MO
INMONT CORP.
  Frank  lannuzzi -  Louisville, KY
  Chuck Wright
JOHN ZINK CO.
  Cliff Cantrell -  Tulsa, OK
MOTTER PRINTING PRESS CO.
  George DeWitt, Sales Manager - York, PA
  Michael Loeback
                                   A-10

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                         Table A-4.  (Continued)
REGENERATIVE ENVIRONMENTAL EQUIPMENT CO.
  James Mueller, President - Morris Plains, NO
  Rodney Pennington, Project Manager - Morris Plains, NJ
SPECIALTY SOLVENTS CHEMICALS CO.
  Denver, CO
SUN CHEMICAL CORPORATION
  Jeffrey Boehlert - Carlstadt, NJ
SUTCLIFFE SPEAKMAN & CO.
  William Moses, Sales Manager - Bronxville, NY
TOCKHEIM CORP.
  Dave Curtis - Fort Wayne, IN
UNION CARBIDE CORP.
  Joseph Spiro - Sales Representative - San Diego, CA
  Larry Thomas, Purasiv HR Representative - Tarrytown, NY
VARA INTERNATIONAL
  Tom Vara, President - Vero Beach, FL
VIC MANUFACTURING CO.
  Tom Cannon, Asst. Sales Manager - Minneapolis, MN
YEARGIN CO.
  Paul  Duff - Charlotte, NC
                                   A-ll

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         Table  A-5.   EVOLUTION OF  PROPOSED  STANDARDS
 Date
 6/78
 6/27/78
 7/13/78
 7/24/78

 7/31/78
 8/14/78
 8/15/78
 8/15,16/78

 9/7/78

 9/15/78
 9/26/78
 11/78

 12/11-16/78
 1/79

 1/3/79
 2/79
 2/20/79
 2/22/79
 3/79

 4/4/79

4/6/79

4/9-13/79
4/4/79
                  EvejTt_
Literature & Telephone surveys begun
APCA Meeting in Houston, Texas
Meeting in NYC with the GRI and GTA
Plant visit to R.R. Donnelly & Sons
  Company
Section 114 letters submitted
Plant visit to Standard Gravure Corp.
Plant tour of the World Color Press
Third Solvent Recovery Commission Meeting
  of the GRI in Salem, IL
Plant visit to Alco-Gravure, California
  Rotogravure Division
Plant visit to Keredith/Burda, Inc.
Issued draft of the Test Plan
Issued draft of the sections of the
  SSEIS (BID)
Emission test at Meredith/Burda,  Inc.
Preliminary model  plant and preliminary
  Section 8.1  data submitted to EAB
Plant visit to Texas Color Printers
Final  test requests  submitted to  EMB
Pre-test survey at World  Color Press
Pre-test survey at Texas  Color Printers
Final  irodel plant  parameters defined;
  Preliminary BID  Chapters 3 through 6
  distributed for  outside comments
Final  report issued  for December 1978
  Emission Test at Meredith/Purda, Inc.
Response from GRI  on model  plant
  parameters
Emission test  at Texas Color Printers
Prelininary control  cost  data submitted
                            A-12

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                    Table A-5.  (Continued)
 Date
                Event
 5/17/79


 6/25/79




 7/19/79


 7/31/79


 8/79


 9/28/79

10/19/79


11/02/79

11/15/79

12/13/79

 1/3/80


 1/22-24/80


 2/14/80
 3/21/80


 3/80


 4/10/80
Regulatory Alternative Recommendation
  memo issued

Recommendation memo on the form and
  level of the standard submitted; con-
  currence memo draft on model plants
  and regulatory alternatives submitted

Meeting with project team; Basis for
  Standards defined

Revised Concurrence memo on regulatory
  alternatives submitted

Cost and Economic Analysis completed;
  Chapter 9 and Regulation submitted

Complete Working Group Package submitted

Final  report issued for April 1979  Emission
  Test at Texas Color Printers
Complete NAPCTAC Package  submitted

Working Group Meeting

NAPCTAC Meeting

Meeting with project team; NAPCTAC  issues
  and  industry's comments evaluation

Supplemental vapor sampling/neasurenents
  at Meredith/Burda, Inc.
Meeting with project team; Re-evaluation
  of data base and rationale  for  level of
  recommended standard to complete
  preparation of Steering Committee
  Package
Final draft of new Reference Method 29
  issued by EMB

Final report issued for January 1980
  vapor measurements at Meredith/Burda

Meeting of all  industrial  surface coating
  NSPS projects on regulation requirements
  for continual  compliance; new regulation
  guidelines issued.
                            A-13

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                      Table A-5. (Continued)
 Date

 4/24/80


 5/6/80

 6/3/80




 6/6/80

 7/8/80
 7/30/80

10/1/80


10/80
                    Event

Complete Steering Committee Package
  submitted

Plant visit to Standard Gravure Corp.

Meeting in Durham, N.C. with GRI, GTA,
  and other industry representatives
  about comments on the Steering
  Committee Package

Reports Impact Analysis submitted

Meeting with project team: Evaluation
  of long-term overall  efficiency
  control  data from Meredith/Burda and
  Standard Gravure; Rationale for level
  of recommended standard to complete
  preparation of AA concurrence package

Complete AA concurrence package submitted

Revised  proposal  package submitted to
  Assistant Administrators for concurrence

NSPS proposed  in Federal  Register
                                A-14

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                            APPENDIX B
               INDEX TO ENVIRONMENTAL CONSIDERATIONS

     This appendix consists of a reference system which is cross
indexed with the October 21, 1974, Federal Register (39 FR 37419)
containing EPA guidelines for the preparation of Environmental
Impact Statements.  This index can be used to identify sections  of
the document which contain data and information germane to any
portion of the Federal  Register guidelines.
                               B-l

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                                 APPENDIX B


             CROSS-INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
 Agency Guidelines  for Preparing
 Regulatory Action  Environmental
 Impact Statements  (39 FR 37419)
 1.   Background  and  Summary of
      Regulatory Alternatives
      Statutory  Basis  for  the
        Standard
      Facility Affected
     Process Affected
     Availability of Control
       Technology
     Existing Regulations
       at State or Local Level
2.  Environmental, Energy, and
     Economic Impacts of Regulatory
     Alternatives

     Health and Welfare Impact
   Location Within the Background
     Information Document (RID)
 The regulatory alternatives from which
 standards  will be chosen for proposal
 are summarized in Chapter 1,
 section  1.1.

 The statutory basis  for proposing
 standards  is  summarized in Chapter 3,
 section  2.1.

 A  description of  the facility to
 be affected  is given in Chapter 3,
 section  3.1.

 A  description of  the process  to be
 affected is given  in Chapter 3,
 section  3.2.

 Information on the availability
 of control technology  is  given
 in  Chapter 4.

 A  discussion  of existino  regulations
 for the  industry to  be  affected by
 the standards  are  included  in
 Chapter 3, section 3.3.
The impact of emission control
systems on health and welfare
is considered in Chapter 7,
section 7.1.
                                     B-2

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    CROSS-INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS  (Concluded)
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
  Location Within the Background
    Information Document  (BID)
     Air Pollution
     Water Pollution
     Sol id Waste Disposal
     Energy
     Costs
     Economics
The air pollution impact of the
regulatory alternatives are considered
in Chapter 7, section 7.1.

The impacts of the regulatory
alternatives on water pollution are
considered in Chapter 7, section 7.2.

The impact of the regulatory
alternatives on solid waste disposal
are considered in Chapter 7,
section 7.3.

The impacts of the regulatory
alternatives on energy use are
considered in Chapter 7, section 7.4.

The cost impact of the emission
control systems is considered in
Chapter 8, section 8.2.

Economic impacts of the regulatory
alternatives are considered in
Chapter 8, section 8.4.
                                     B-3

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                               APPENDIX C
                        EMISSION SOURCE TEST DATA

     Sampling programs to obtain volatile organic compound (VOC) emission
data were carried out at two well-controlled plants to provide background
data for new source performance standards (NSPS).  In addition, long-
term plant data were obtained from both tested plants and several non-
tested plants.
C.I  MEREDITH/BURDA INC. PLANT
     The Meredith/Burda Inc. Plant, located at 4201 Murray Place, Lynchburg,
Virginia, was tested during the week of December 11-16, 1978.  The
Meredith/Burda plant operates a total  of six rotogravure publication
presses (Phases I, II, and III).  The two newest presses, press 505 and
506, were the only presses monitored during the course of this test.
These two presses, located in a separate pressroom, are controlled by a
separate fixed-bed carbon adsorption/solvent recovery system (Phase
III).  This plant uses pure toluene as the printing solvent.  A unique
system is utilized in this pressroom to capture fugitive VOC vapor
emissions.  A cabin-like structure encloses the top one-third of each
printing press.  Air is drawn from the pressroom and up through each
cabin enclosure.  Fugitive solvent vapors from around the printing units
and from the paper web are captured by this contained air flow.  The
resultant solvent laden air (SLA) is directed along with the dryer
exhausts to the carbon adsorption system.
     The emissions from presses 505 and 506 are controlled by a Lurgi
"Supersorbon" carbon adsorption system.  The system consists of three
adsorption vessels containing activated carbon.  Two vessels adsorb
simultaneously while the third vessel  is stripped using countercurrent
live-steam injection.  The recovered solvent/steam mixture is condensed,
cooled, and separated.  The dewatered solvent is sent to the recycle
                                    C-l

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solvent  storage tank.   The water layer  (the condensed steam) is sent to
a  condensate  stripper,  where  it is contacted countercurrently with warm
air.   This water  is  reused as boiler feed water.  The toluene laden
airstream  is  then  recycled back into the adsorber induction system.
      Hydrocarbon measurements were made on a sernicontinuous basis at
both  the inlet and outlet of  the carbon adsorbers.  Grab samples were
collected  at  the  inlet  and outlet adsorber sites at the ventilation
ducts  from vapor  control enclosures around both press units (505 and
506).  The grab samples were  analyzed on-site by gas chromatography to
identify and  determine  concentrations of the components in the gas
streams.   Mixed (diluted) ink samples were obtained from each of the
eight  feed tanks on  each press for determination of the toluene content.
The solvent content  of  the bulk (undiluted) inks was obtained from the
ink manufacturer.  Samples of both boiler feed water and the water
(steam condensate) H:>OITI the toluene/water decanter (separator) were also
collected  for toluene content analysis.
      The test program consisted of three sampling periods.  Each test
period was defined as the time required for all  of the three carbon
adsorbers to  complete a single adsorption-desorption cycle.  The test
periods  ranged from  about 8% to 9 hours.  Each adsorber remained in the
adsorption cycle for 160-180 minutes, followed by a 50 minute steam
desorption, conditioning, and cooling cycle.   Breakthrough of the solvent
vapors occurring on  a particular adsorber started the desorption cycle
for that adsorber.   This was accomplished by an internal hydrocarbon
analyzer.  An override timer was used to automatically initiate desorption
in the event that the hydrocarbon analyzer did not breakthrough.
      During the test program, velocity data and liquid samples were
collected by Mr. Robert Oppenheimer and Mr. James Totura of the Gravure
Research Institute (GRI), located in Port Washington, N.Y., 10050.  A
test  engineer from Lurgi was on-site during the test program in order to
monitor  the operation of the adsorber system.   The sampling and on-site
analysis were conducted by a Monsanto Research Corporation team consisting
                                    C-2

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of Messrs. W.R. Feairheller (team leader), W. McCurley, W. Meyer, L.
Cox, and C. Clark, and was observed by Mr. Frank Clay of the Emission
Measurement Branch of the EPA.  Mr. Richard Reich of Radian Corporation
was on-site to obtain process design and operating information.
C.2.  SUPPLEMENTAL SAMPLING AT MEREDITH/BURDA INC.
     The Meredith/Burda Inc. plant was revisited for special sampling
and measurements of solvent vapors during January 22-24, 1980.  The
general purpose of the visit was to acquire more data for evaluation of
industry's comments, presented at the December 1979 NAPCTAC meeting.
Industry representatives mentioned two possible problems with using the
December 1978 Meredith/Burda test results as a basis for establishing
proposed standards.  First, the fugitive-capture cabin enclosure design
may create potential OSHA violations by exposing press operators to
excessively high concentration levels of solvent vapors.  Secondly, the
overall solvent recovery results may have been inflated by solvent
vapors drawn into the tested pressroom facilities (Phase III) from other
non-tested pressrooms.
     The results of measurements inside the cabin enclosures showed
toluene vapor concentrations as high as 200 to over 300 ppmv during
press shutdowns.  These vapor concentration levels agree with the Monsanto
report for the December 1978 tests.  In comparison, the vapor concentration
levels above the upper catwalk around the older presses, without cabin
enclosures, were measured at 5090 ppmv during press shutdowns.  The
higher solvent vapor concentrations above the newest presses, with the
cabin enclosure, appears to have two causes: (1) higher ambient pressroom
vapor concentrations, and (2) maldistribution of air flow through the
enclosures which allows stagnant zones of concentrated solvent vapors in
the cabin air.  In addition, the results of pressroom measurements
showed some infiltration of solvent vapors into the newest (Phase III)
pressroom.
     The ambient air in both an older, and newest pressrooms were measured
for toluene vapor concentration levels.  The vapor concentrations in the
older pressroom ranged from 40 to 50 ppmv; concentrations in the newest
                                    C-3

-------
 pressroom ranged from about 65 to 200 ppmv.   The initial  thought was
 that the air flow through the cabin enclosures was too low, thus allowing
 fugitive vapors  to propagate throughout the  newest pressroom.
      Supplemental  measurements revealed two  other possible sources which
 could contribute solvent vapors to the newest Meredith/Burda pressroom.
 Fresh outside air and recycle air from the cutting areas  are drawn
 through  the  heating and  air conditioning system,  which discharges to the
 newest pressroom.   Measurements indicated that recycling  the air from
 the  cutting  areas  is  probably the dominant factor causing elevated
 solvent  vapor concentrations in the pressroom air.   [n addition,  it was
 determined that  solvent  laden air infiltrates the newest  pressroom from
 other areas  of the plant.   Measurements  showed that some  air containing
 60 to 70 ppmv toluene vapors is drawn  into the newest  pressroom  from
 other pressrooms  and  plant  areas.   This  infiltration of toluene  vapors
 could have inflated  the  overall  solvent  recovery  results  by about three
 percent.  This estimate  is  based  on  the  assumption  that the infiltrated
 toluene  vapors were  generated from  other printing facilities.
      The sampling  and  vapor measurements  were conducted by  the Emission
 Measurement  Branch,  ESED, of the  EPA.  The sampling team  consisted  of
 Messrs.   Winton  Kelly  (team  leader), Frank Clay,  and John Brown.   Mr.
 Edwin  Vincent  of the  Chemical  Petroleum  Branch, ESED,  of  the EPA  was
 also  present  to thelp  direct  the  sampling  procedure.
 C.3   TEXAS COLOR  INC.  PLANT
      The  Texas Color  Press  Inc. Plant  is  located  at 4800  Spring Valley
 Road,  Dallas, Texas.   It was  sampled during the week of April 9-13,
 1979.  The Texas Color Printers plant  operates two  rotogravure publication
 presses.  These two presses  (press 741 and 742) were monitored during
 the emissions test.  The dryer  exhaust from press 741 and 742 is  combined
with  the dryer exhaust from the gravure proof press.  This  SLA exhaust
stream is controlled by a carbon adsorption,   solvent recovery system.
Texas Color Printers uses a mixed petroleum fraction for their gravure
solvent.   Typical toluene and xylene contents are about 30 percent and 4
                                     C-4

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percent, respectively.  The balance of the solvent  (66 percent) is
lactol spirits.  Two grades of gravure ink (Group 1 and Group 5) are
used at this plant.
     Fugitive emissions are collected by using floor sweeps in the lower
areas of the pressroom.  The presses have a floor sweep for each unit,
located on the side of the press near the ink tank.  The floor sweeps
are tied into a separate header for each press.  The exhaust from these
floor sweeps is not treated by the carbon adsorption system.  A separate
roof fan for each header discharges the floor sweep exhaust into the
atmosphere.
     The emission control system used at this plant is a Croftshaw
design.  The system consists of three horizontal adsorption vessels
containing activated carbon.  Two vessels adsorb simultaneously for a
total SLA capacity of 75,000 CFM.  The SLA stream collected from the
dryer exhausts is drawn through a header system on the pressroom roof.
Two 150 HP fans draw the SLA through roll-fed filters and force the air
through the adsorption vessels.  The treated air stream is ducted into
an exit header and discharged to the atmosphere.
     The adsorption cycle, which is regulated by a timer, lasts 3 hours
per vessel.  The cycles are staggered, thus permitting enough time for
regeneration of one bed while the other two are adsorbing.  Regeneration
is accomplished by countercurrent live steam stripping of the adsorption
vessel.  The 45 minute regeneration cycle is controlled by a timer.  A
15 minute cooling period immediately follows regeneration.  The cooling
cycle consists of placing the hot, wet, newly regenerated bed on line,
to operate along with the other two beds.  The inlet SLA, which enters
at about 100°F, cools and removes excess moisture from the bed.   After
the cooling cycle, the newly regenerated bed is taken off line until  it
is needed.   During the regeneration cycle, the stripping steam passes
through an adsorber and into the condensers.   The two phase condensate
is cooled and sent to the decanter.  The dewatered solvent flows from
the decanter into the underground solvent storage tanks.   The steam
                                    C-5

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 condensate  flows  from  the  decanter  into  a  hot  well,  where  the  condensate
 is  recycled  as  boiler  feed  water.
      Total  hydrocarbon and  specific  compound gas  chromatographic  analysis
 data  were collected  on a semi continuous  basis  at  both  the  inlet  and
 outlet  of the carbon adsorber system.  The solvent vapors  from two
 presses  and  a proof  press  are captured by  the  air handling  system.   The
 solvent  in  the  air is  removed  and recovered by the carbon  adsorbers.
 The air  in  the  room  around  the presses is  ventilated by  a  separate
 system which is emitted directly to  the  atmosphere (uncontrolled).   Grab
 samples  of  this ventilated  air were  collected  and analyzed  by  on-site
 gas chromatography for specific chemical compounds.  Samples of diluted
 ink were obtained from each of the ink feed tanks on the two presses for
 determination of  solvent content.  Raw (undiluted) ink samples were  also
 obtained and analyzed.  Samples of the water layer (steam condensate)
 from  the solvent/water decanter (separator) were  also collected and
 analyzed for solvent content.
      The test program  consisted of three sampling periods.  Each  test
 period was defined as  the time  required  for all of the three carbon
 adsorbers to complete  an adsorption-desorption cycle.  The  test periods
 lasted about % hours  during which each  adsorber  remained in the  adsorption
 cycle for about 180 minutes, followed by a 45 minute desorption (steaming)
 period and a 10 minute cooling and conditioning period.  Two of the
 three carbon beds were in the  adsorption cycle at all times.  At  the
 beginning and end of each test period, the solvent supply meter,  the
 decanter solvent meter, and the ink meters readings were recorded.
      The sampling and  on-site  analysis was conducted by a Monsanto
 Research Corporation team consisting of Messrs. W.R. Feairheller  (leader),
 K. Tackett,  W.  McDonald, and D. Sterling, and was observed  by Mr. Frank
 Clay of the Emission Measurement Branch of EPA.  Mr.  Gary Hippie  of
 Pollution Control  Science,  Inc., Miamisburg, Ohio, collected samples for
total  gas non-methane  organic  (TGNMO) analysis  during the test program.
 Pollution Control  Science was  hired as a subcontractor by Monsanto
 Research Corporation.  Mr.  Richard Reich  of Radian Corporation was on-
                                    C-6

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 site  to  obtain  process  deisgn  and  operation  information.   The test
 program  was  observed  by representatives  of the  Texas  Air  Control  Board
 (TACB) and the  Gravure  Research  Institute.   Mr.  Charles Shevlin (TACB-
 Austin)  was  present during  the entire  test period,  while  Dr.  Robert  James
 (TACB-Austin) and Mr. William  Chafin  (TACB-Fort  Worth) were  present  for
 a  portion of the test.   Mr.  Robert  Oppenheimer  and  Mr. James  Totura
 (GRI) were present during the  entire program and collected samples and
 data  during  the test  periods.
 C.4   SUMMARY OF RESULTS
      A summary  of the emission control efficiencies for the  Meredith/Burda
 and Texas Color Printers facilities is presented in Table  C-l.  The
 overall  efficiencies  are based on  solvent  volume material  balance  data
 obtained from liquid  meter  readings acquired from several  sources.   The
 Monsanto data are from  several short-term, hourly test runs  and from one
 continuous run  over several  days at each plant.   The  Radian  data  for
 Texas Color  represent one continuous run over a  slightly longer period
 than  for the Monsanto tests.   The GRI data represent  independent tests
 results  conducted in  parallel  with the Monsanto  tests but  for a slightly
 longer period.  In addition, longer-term monthly plant data were obtained
 from  both tested plants.  The  calculated apparent overall  efficiencies
 for Meredith/Burda were  corrected for temperature variations  among the
 individual  liquid meters and for infiltration of solvent vapors into the
 tested (Phase III) pressroom.  The adsorber  efficiencies are  based on
 short-term test data obtained  by vapor phase  analyses and  by  combinations
 of liquid meter readings with  vapor phase analyses results.
     A comparison of the press operations during  the Monsanto  tests  at
 both  plants  is  shown in Table  C-2.   The operation of the presses at  both
 plants were  practically identical.   The frequency of press shutdowns  at
 Texas Color was only slightly  higher than at Meredith/Burda.   A graphical
 presentation of the prress shutdown data is  shown in Figure C-l.  A
comparison of the SLA flow streams  at both plants is presented  in Table
C-3.   A summary of the longer-term  Monsanto test  results  for  both plants
is presented  in Table C-4.
                                     C-7

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     An explaination of the temperature correction factor required for
the Meredith/Burda data is presented in Table C-5.  This temperature
correction factor is not required for the Texas Color data.  At Texas
Color, the recovered solvent is at the same temperature as the inks and
solvent used at the presses.
     The short-term test run data from the Monsanto tests at Meredith/Burda
are presented in Table C-6.  The capture efficiencies and adsorber
efficiencies were determined by combinations of liquid meter readings
and vapor phase monitoring results.  The overall efficiencies were
determined from only liquid meter readings.  The overall solvent balances
are also useful for determining the amount of product retained solvent.
Approximately 3.5 percent of the solvent used was retained in the Meredith/Burda
products during the tests, with a capture efficiency of over 96 percent.
     A comparison of the amount of solvent recovered at Meredith/Burda
as determined by vapor phase measurements and by liquid meter readings
is presented in Table C-7.  The recovered solvent amounts determined by
GC/FID on-line vapor phase measurements range from about 10 to 30 percent
lower than by liquid meter readings. The variations in the calculated
adsorber efficiencies shown in Tables C-6 and C-7 reflect the differences
in the determined recovered solvent quantities.
     Adsorber efficiencies determined by the combination of liquid meter
readings of recovered solvent with outlet gas phase analyses should be
more reliable than by inlet and outlet gas phase analyses.  The accurate
accounting of solvent vapor into the adsorbers is difficult because of
the abrupt changes in solvent vapor concentrations during press shutdowns.
The vapor phase analyzers and inlet sampling system may not allow
instantaneous instrument response.  The inlet vapor concentration varies
over a wide range which the analyzer must be calibrated for.  The solvent
laden air flow through the adsorbers is not constant but fluctuates
somewhat during press operations.  On the other hand, the outlet vapor
concentration is fairly stable except upon breakthrough.  Even then, the
outlet vapor concentration change is gradual compared to the abrupt
inlet changes.
                                     C-8

-------
     Although vapor phase measurements are useful for determining adsorber
bed efficiency, vapor analyses have limited usefulness for accurately
assessing overall efficiencies.  Continuous vapor phase monitoring is
more expensive than liquid phase monitoring.  To determine the quantity
of recovered solvent by vapor measurements, both air flow and vapor
analyses must be continuous and the results of each integrated (by hand
or by on-line flow computer) for the entire test time.  The test results
show that long-term tests are more reliable than short-term tests.
Long-term averaging periods are required because of the fluctuations in
the printing process and the solvent hold-up in the carbon adsorber
beds.  Vapor measurements are very difficult to conduct over long periods.
In addition, the results of vapor measurements require conversion to
equivalent liquid quantities for comparison to the liquid solvent used
at the press.
     The potential  solvent loss from the Meredith/Burda solvent recovery
decanter represented about 0.5 percent of the solvent used as shown in
Table C-8.  However, essentially all of this solvent was recovered by
stripping the solvent laden condensate in a special tower.  Steam to
recovered solvent ratios were also determined to average 3.2 during the
tests.  The decanter solvent losses were included in a material balance
around the adsorbers to determine the adsorber efficiencies, as shown in
Table C-9.  These efficiencies agree well with those shown in Table C-6.
     In addition to the short-term test data, long-term plant data were
obtained from the Meredith/Burda plant.  Fourteen months of overall
solvent recovery performance data are presented in Table C-10.  The
facilities were reported to be operating normally and at typical  conditions
except during the four months indicated.  The performance results are
determined by liquid volume meter readings.  The apparent solvent recovery
results are adjusted for the temperature correction factor and the
factor for infiltration of solvent vapors.
     Presented in Table C-ll are theoretical calculations addressing the
OSHA violation problem with the Meredith/Burda cabin enclosure design.
Air purge times required to decrease the toluene vapor concentration to
                                    C-9

-------
 a safe level  inside the enclosure after a press shutdown are shown.  The
 purge time depends on the air flow rate through the enclosure, the
 initial  toluene vapor concentration inside the enclosure at the time of
 a press  shutdown,  the desired final  toluene vapor concentration after a
 press shutdown, and the pressroom ambient toluene vapor concentration
 level (driving  force for clearing the enclosure).  The results show that
 the enclosure  should be available for safe entry in about one minute
 after press  shutdown for the  measured air flow rate and normal  pressroom
 ambient  toluene vapor concentrations.   An increase in  the air flow to
 the design rate would decrease the required purge times by about  30
 percent  and would  decrease  the adsorber efficiency by  less  than 0.5
 percent.
      The short-term test run  data from the Monsanto tests at Texas  Color
 are presented in Table C-12.   The capture efficiencies  and  adsorber
 efficiencies were  determined  by combinations of liquid  meter readings
 and vapor phase monitoring  results.   The  overall  efficiencies  were
 determined from only liquid meter readings.  The overall  solvent  balances
 are also  useful for determining  the  amount  of  product  retained  solvent.
 Approximately 3.3  percent of  the  solvent  used  at  the press  was  retained
 in  the Texas Color products during the tests,  with  a capture efficiency
 of  about  88 percent.
      Comparisons of the  amount  of  solvent  recovered at  Texas  Color  as
 determined by vapor phase measurements  and  by  liquid meter  readings  are
 presented  in Table  C-13.  Three  separate  vapor  phase analysis methods
 were  employed:  GC/FID,  TGNMO  (EPA  Reference Method  25),  and  FID.  The
 recovered  solvent  amounts determined by GC/FID and  FID methods  range
 from  about 15 to 50 percent lower than  by  liquid meter  readings.  On
 the other  hand, the  recovered  solvent  amounts determined  by  the TGNMO
method were lower than  by liquid meter  readings for one  run  and higher
for two of the  runs, but the  cumulative run totals  for the two methods
agreed very well.   These data  show, along with the  Meredith/Burda test
data, that vapor phase measurements are inconsistent and  not  reliable
                                     C-10

-------
for determination of VOC emission control performance in this industry.
The variations in the calculated adsorber efficiencies shown in Tables C-12
and C-13 reflect the differences in the determined recovered solvent
quantities.
     The solvent loss from the Texas Color solvent recovery decanter
represented less than 0.1 percent of the solvent used, as shown in
Table C-14.  Meter readings were not available to determine steam to
solvent recovered ratios at this plant.  Adsorber efficiencies were
determined from material balances, including condensate losses, as shown
in Table C-15.
     Presented in Table C-16 are the results of a solvent volume material
balance conducted by Radian Corporation around the Texas Color facilities.
The overall solvent recovery efficiency results are determined from
liquid meter readings.  The data cover normal operations over several
continuous days compared to only two days for the Monsanto tests.
     The Texas Color facilities capture only the dryer exhausts.  Fugitive
solvent vapors are pulled out of the pressroom and discharged directly
to the atmosphere through floor sweep vents.  Presented in Table C-17 is
a comparison of the measured Texas Color adsorber inlet conditions to
the estimated adsorber  inlet conditions if the floor sweeps were vented
to the adsorber.
     An estimate of the time-weighted average adsorber efficiency that
can be expected for control of VOC emissions in this industry is presented
in Table C-18.  This estimate is based on the inlet and outlet solvent
vapor concentrations measured during the Monsanto tests at Meredith/Burda
combined with the press operating data presented in Table C-2 for the
Monsanto tests at both  tested plants.
     As estimate of the increased solvent recovery efficiency that could
potentially be achieved by the Texas Color facilities is presented in
Table C-19.   Estimates  are shown for the four data sources presented  in
Table C-l.  The estimates show that the overall solvent recovery efficiency
at these facilities could potentially be increased to the 88 to 92
percent range if floor  sweeps were vented to the adsorber system.
                                    C-ll

-------
 Analyses of the floor sweeps, presented in Table C-12, showed that an
 average of 8.2 percent of the solvent is presently vented to the atmosphere,
 Directing these floorsweeps to the adsorbers could account for increased
 solvent recovery.   Of course, additional adsorber capacity may need to
 be installed to handle the 31 percent increase in potential  air flow
 (see Table C-17).   However, elimination of the "proof press" and "end of
 header" solvent laden air streams  may offset the floor sweep air flow,
 as shown in Table  C-3.
      The Texas Color potential  increased overall  recovery efficiencies
 include reduced adsorber efficiencies for the more dilute solvent,  laden
 air flows.   The adsorber efficiencies would  decrease  about one percent
 for each case  shown  in  Table  C-19.   The calculations  assume  that the
 differences  in the  overall  recovery  efficiencies  by the  four data  sources
 were caused  by variations  in  product  retentions  with  constant  fugitive
 vapor capture  by the floor  sweeps.   If,  on the other  hand, the product
 retentions  were constant  for  all cases,  the  variations in  fugitive
 captures  would  yield the  same  potential  overall  efficiency as  shown for
 the  Monsanto test, since  all  fugitives  would  be  directed to  the  adsorber.
 The  Texas  Color overall  efficiency could  be  further increased  by utilizing
 gas  analyses for concentrating the dryer  exhausts  and  initiating bed
 regenerations.  These features with close capture  of  fugitive  vapors
would  increase  the solvent  vapor cencentrations and, therefore,  would
facilitate an  average adsorber efficiency of  at least 97 percent, as
shown  in Table  C-18.
      In  addition to  the short-term test data, long-term plant  data were
obtained from the Texas Color plant.  Five months  of overall solvent
recovery performance data are presented in Table C-20.  The facilities
were  reported to be  operating normally and at typical  conditions during
the five month period.  The performance results are determined by liquid
volume meter readings.  No adjustments to the solvent  recovery results
are required.
                                    C-12

-------
C.5  NON-TESTED FACILITIES
     Long-term plant data on overall VOC emission control performance
were obtained for several non-tested facilities.  It is important to
recognize that long-term (monthly or four-week periods) performance
averaging is more reliable than short-term (hourly, daily, or even
weekly) performance averaging for determination of the overall control
efficiency level that can be continually achievable.  Publication rotogravure
printing is characterized by many production upsets (press shutdowns),
which affect the performance of the carbon adsorber/solvent recovery
system.  For this reason, a long-term (one month or four-week period)
performance test and monitoring period may be necessary for determination
of compliance with the proposed emission standards.
     The most significant source of these long-term data is the Standard
Gravure, Inc. plant in Louisville,  Kentucky.  Six publication rotogravure
presses are used at this plant.  The most important characteristic of
this plant is the thorough fugitive solvent vapor capture system.
Fugitive solvent vapors are captured from all sections of the plant,
including the pressroom, product cutting/folding areas, product storage
areas, and the  proof press and cylinder preparation areas.  This thorough
capture system  is achieved by ventilating essentially all the air from
these plant areas, along with the press dryer exhausts, to the carbon
adsorption system.  In addition, the more typical, mixed-naphtha based
solvents are used at this plant.
     Presented  in Table  C-21 are overall solvent recovery performance
plant data for twenty, four-week averaging periods at the Standard Gravure
plant.  The facilities were reported to be operating normally and at
typical conditions, except during the five periods indicated.  The
performance results are  determined  by tank truck weighings of purchased
inks combined with liquid volume meter  readings of the solvent added  at
the  presses and the recovered solvent.  No adjustments to the solvent
recovery results are required.
                                     C-13

-------
      There  are  three  reasons  why EPA  tests  were  not  conducted  at the
 Standard  Gravure  plant.   First,  the Standard  Gravure emission  control
 system  handles  much higher  air flows  to  capture  fugitive solvent vapors
 with  the  dryer  exhausts  than  the tested  system at  Meredith/Burda or the
 potential system  at the  tested Texas  Color  plant.   Secondly, the presses
 at  Standard  Gravure were installed in the early  1970's  and  represent
 older-type  facilities.   The older-type presses cannot print  as  fast and
 are not as  well designed as the  modern presses at  Meredith/Burda and
 Texas Color.  Thirdly, the  liquid meters for  the inks used  at  the presses
 are not modern  meters and are not very accurate.   The overall  solvent
 balance using ink tank truck weighings is probably just  as  accurate as
 by modern liquid meters,  but tank weighings are  not  the  common  practice
 in this industry.
      Long-term  plant data was also obtained from the World  Color Press
 plant in Salem, Illinois.   Routine weekly overall  solvent recovery
 efficiencies reported by this plant are presented  in Figure  C-2.   Only
 dryer exhausts  are treated  at this plant; fugitive solvent  vapors  are not
 captured.   These data show  the wide fluctuations in  control performance
 by short-term averaging  periods.   The  long-term performance average at
this plant is 80 to 81 percent overall VOC control  efficiency.
     Long-term  plant data were also obtained  from  several other  non-
tested plants.  These overall  control  efficiencies  are presented  in
Table C-22.   All of these facilities  have installed some type of  fugitive
solvent  vapor capture system.   The emission control system at the  Triangle
Publication plant was identical  to the system at the Standard Gravure
plant, but Triangle's facilities  were much older.
                                    C-14

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                        TABLE C-l.   SUMMARY  OF  DEMONSTRATED  VOC  EMISSION  CONTROL  EFFICIENCIES
                             IN THE  PUBLICATION ROTOGRAVURE  PRINTING  INDUSTRY,  PERCENT
o
I
en

Me redith/Burda( Phase III) Texas Color Printers
Data Sources Overall9
Monsanto Research Corporation tests 89-92
Radian Corporation
Gravure Research Institute (GRI) tests'1 88
Meredith/Burda1 84-91
Texas Color Printers
Adsorber Overall
97_99C 84d(92e)
839(91e)
99 81
__
81j(89e)
Adsorber
93-96f
--
98
—
—

          Efficiencies are 5 percent lower  than measured  apparent  efficiencies:   2% for a temperature
          correction factor (see Table  C-5)  and 3%  for  infiltration  of solvent  vapors.
         bSee Table C-4 and C-6.
         cSee Table C-6,  C-7,  and C-9.
         dSee Table C-4 and C-12,
         Potential  efficiency - see Table  C-19.
         fSee Table C-12,  C-13,  C-15.
         9See Table C-16.
          This information appeared  in  a  letter from  Harvey  F.  George  (GRI)  to  Edwin J.  Vincent (EPA)
          dated 9/5/79 -  total  material balances  over 78  hours  at  each plant.
         Monthly plant data - see Table  C-10.
         JFive months of  plant data  - see Table C-20.

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                      TABLE C-2.   COMPARISON OF PRESS OPERATIONS DURING MONSANTO RESEARCH CORP   TESTS
                                            AT MEREDITH/BURDA AND TEXAS COLOR
o
PRESS OPERATION
Advertising Product-Press:
Press width, inches:
Web width, inches:
Shutdowns/hour (b):
Printing time, % :
Press speed ft/mi n:
Magazine Product-Press:
Press width, inches:
Web width, inches:
Shutdowns/hour(b):
Printing time, % :
Press speed ft/mi n:
Both Presses:
Shutdowns/hour(b] :
Printing time, %.
Both up, %C (PPMa): .
One up/one down, %C(PPM ):
Both down, %C(PPM ):
Total solvent usage, Gal/hr:e
Type of solvent used:
MEREDITH/BURDA
#505
79
50
0.27(6.5)
86.
900-1,100
#506
79
78 3/8
0.58(13.8)
64.
1,500-1,900

0.42(10.1)
75.
60(1,670)
33(770)
7(300)
143
toluene
TEXAS COLOR
#1
94
62%
0.60(14.2)
78.
1,700-1,800
#2
94
93
0.37(8.9)
72.
900-1,700

0.48(11.5)
75.
60(1,020)
33(500)
7(70)
219
mixed-naphtha based
              Average of three test runs—See  Figure  C-l.
             'Equivalent shutdowns  per 24 hour period.
             "Actual  press  operating time relative  to  test time.
              Adsorber inlet  solvent vapor concentrations.
             'Includes  solvent in  inks,  varnishes,  and extenders.

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#506 #1




























1 2 3
#2
   MEREDITH/BURDA
    (Dec.  1978)
                        TEST  RUNS
 TEXAS COLOR
(April 1979)
FIGURE C-l.   FREQUENCY OF PRESS SHUTDOHNS DURING TESTS
           AT MEREDITH/BURDA AND TEXAS COLOR
                            C-17

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I
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CO
                        TABLE  C-3.  COMPARISON OF SLA* FLOW STREAMS FOR MEREDITH/BURDA
                               AND TEXAS COLOR TESTS BY MONSANTO RESEARCH CORP.
ITEM SLA* STREAM MEREDITH/BURDA9
1 Total adsorber inlet, SCFM (2+3+4+5)
cumulative: 48,800
per unit: 3,050
2 Fugitives capture, SCFM: Total: 14,400
Per Unit: 900
3 End of header, SCFMd
4 Proof press, SCFM
5 Press unit dryer, exhausts, SCFM: Total: 34,400
Per Unit: 2,150
rcrt-ciiL luyiuivco Capture, 7o \^,f) £:? . 0
TEXAS COLOR
61,200b (80,330)c
(3,305)
(19,130)
(960)
4,300
10,000
46.900
2,345
(29.0)
        2 presses--16 units total; cabin enclosures around top portion of two presses.

        2 presses--20 units total; floor sweeps  presently vented to atmosphere.

        Numbers in parenthesis would represent conditions if floor sweeps were captured and directed
        to the carbon adsorption system.

       "Dilution air to control SLA  header pressure.
       *
        Solvent laden air.

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                       TABLE C-4.   SUMMARY  OF  RESULTS  FROM  MONSANTO RESEARCH  CORP.

                                         MATERIAL  BALANCE TESTS
o
I
i-O

Item
1
2
3
4
5
6
7
Meter Readings
Total bulk ink and extender input
Total solvent in bulk ink and extender
Total solvent added
Total solvent input (2+3)
Solvent recovered through decanter
Apparent average overall recovery
efficiency (5/4)
Corrected average overall recovery
efficiency
Meredith/Burda3
(Liters)
15,197
9,195
20,630
29,825
28,165
94.4%
89.4%C
Texas Color Printers
(Gallons)
3,501
2,248
3,661
5,909
5,019
84.9%
NOT APPLICABLE

        Total  material  balance  over  51.5  hours,  from  Dec.  14  through  Dec.  16,  1978.


       5Total  material  balance  over  27  hours,  from April  11 through April  12,  1978.


       'Efficiencies  are  5  percent lower  than  measured  apparent  efficiencies:  2% for a  temperature

        correction  factor (see  Table C-5) and  3% for  infiltration  of  solvent vapors.

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                             TABLE C-5.  MEREDITH/BURDA RECOVERED TOLUENE SOLVENT
                                         VOLUME TEMPERATURE CORRECTION3

Liquid Meters
Raw ink to press
Extender to press
Solvent added to press
Recovered solvent from Decanter0
Temperature
°C (°F)
21 (70)
21 (70)
21 (70)
40 (104)
Toluene Density
g/cc
0.866
0.866
0.866
0.849
0     Correction factor:  (°-8^6:°'849) X 100 = 2.0%
I                              U.oDD
       The calculated apparent efficiencies require a correction factor to compensate for
       the temperature difference between the recovered solvent and the ink-solvent "input"
       to the presses.  This allowance is necessary because of the volumetric expansion
       or density change in liquid toluene at various temperatures.

       Assumed temperatures—not measured.

      cMaximum indicated temperature at decanter inlet during regeneration—temperature
       between regeneration cycles (no flow thru meter) was 30°-32°C (87°-90°F).

      dData from Lange's Handbook of Chemistry, McCraw Hill Co., 12th ED., p. 7-367,
       10-115, and 10-129; CRC Handbook of Chemistry and Physics,  Chemical Rubber Co.,
       49th ED., P.  C-571.

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                                       TABLE C-6.  SUMMARY OF TEST RUN RESULTS DURING
                          MONSANTO RESFARCH CORP. TESTS AT MEREDITH/BURDA (PHASE III) FACILITIES3
o
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ro
I tern
1
2
3
4
5
6
7
8
9
10
Run
Test time, hours
Total solvent to presses, liters
Recovered solvent, liters
Adsorber outlet loss liters0
Condensate-solvent loss, liters
Product retained, liters6
Percent of total solvent (5/1)
Apparent overall recovery, % (2/1)
Adjusted overall recovery, %
Capture Efficiency, %9 (2+2&J
Adsorber Efficiency, % (7/8)
1
8.5
4,186.7
3,895.5
25.7
ND
265.5
6.3
93.0
90.0
93.7
99.2
2 3
9.0 8.5
5,253.1 4,605.7
4,846.1 4,610.9
79.1 90.6
ND ND
327.9
6.2
92.2 100.0
89.7 97.3
93.8
98.3
Total
26
14,045.5
13,352.5
195.4
~
497.6
3.5
95.1
92.3
96.5
98.5
              See Figure 4-1, Chapter 4.

              Meter readings reduced by 2  percent temperature correction factor—see Table C-5.
             r*
             "GC/FID on-line analyzer/recorder-sol vent vapor concentrations were graphically
              integrated with measured air flow rates  to obtain total  solvent loss  for each run.
              ND--less than 3.0 ppm in condensate from stripper--see Table C-8.
             "[l-(2+3+4)]—Assuming no fugitive vapor  losses from pressroom.
              Adjusted efficiency accounts for  the  3%  correction for the infiltration of solvent
              vapors.

              Represents the relative amount  of solvent vapors that are captured and directed
              through  carbon adsorbers.

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                             TABLE C-7.   COMPARISON OF  SOLVENT  RECOVERED  DATA  BY
                         VAPOR PHASE  MEASUREMENTS AND METER  READINGS  AT MEREDITH/BURDA
                                     DURING  MONSANTO RESEARCH CORP. TESTS
o
r-o
rsa

Run
Test time, hours
Recovered solvent by
1
8.5
3,895.5
2
9.0
4,846.1
3
8.5
4,610.9
Total
26
13,352.


5
       meter readings,  liters

       Recovered  solvent by vapor,
       phase measurements,  liters

       Adsorber efficiency, %
2,640     4,000     4,100
 97.9
98.0
97.2
                      10,740
97.7
        Readings  reduced  by 2  percent  for  temperature correction  factor—see Table  C-5.
       5GC/FID on-line  analyzer/recorders  for adsorber  inlet and  outlets.  Solvent  vapor
        concentrations  were graphically  integrated with measured  air  flow rates to  obtain
        total solvent recovered  for  each run.

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                               TABLE C-8.   SOLVENT LOSS WITH CONDENSATE  FROM
                                        DECANTER AT MEREDITH/BURDA
o
ro
U)

Run
Test time, hours
Steam/recovered solvent, #/#a
Solvent content from decanter,
PPm r
liters0
Percent of total solvent
Solvent content from stripper,
ppm
1
8.5
3.7
1,985
28.6
0.7
ND
2
9.0
3.0
720
10.4
0.2
ND
3
8.5
3.1
715
10.3
0.2
ND
TOTAL
26
3.2
49.3
0.4
—

         Weight per unit weight ratio—27,500 Ibs.  steam usage by flow meter readings  each  test
         run, and recovered solvent 00.866 grams/cc (7.2 Ibs/gallon)  meter readings  shown in Table C-7.
        [j
         Temperature not measured.   Decanter inlet  temperature varies—see Table C-5.   Literature
         solubility of toluene in water at 16°C  is  about 500 ppm.

        "Calculated assuming condensate flow equal  to measured steam  flow with  solvent density
         of 0.866 grams/c.c.

         Solvent volume loss from decanter divided  by total  solvent used  at the
         presses (see Table C-6,  #1).

        "Condensate from decanter is stripped of solvent by  counter-current contact
         with hot air—ND is less than 3 ppm.

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                              TABLE C-9.   MEREDITH/BURDA CARBON ADSORBER EFFICIENCY TESTS
                                          BY MONSANTO RESEARCH CORP.
o
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ITEM
1
2
3
4
5

RUN 1
Recovered solvent, liters3 3,895.5
Decanter solvent loss, liters 28.6
Adsorber outlet loss, liters0 25.7
Total solvent thru adsorber, 3,949.8
liters (1+2+3)
Adsorber efficiency, % 99.3
(— )
2 3 TOTAL
4,846.1 4,610.9 13,352.5
10.4 10.3 49.3
79.1 90.6 195.4
4,935.6 4,711.8 13,597.2
98.4 98.1 98.6


         Meter readings from Table C-7.
        bSee Table C-8.
        cSee Table C-6, #3.
         Total  solvent recovered by adsorber is  equal  to metered recovered solvent plus solvent
         loss from decanter.

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                                TABLE  C-10.   MONTHLY PLANT  OPERATING  DATA  ON  OVERALL  EMISSION  CONTROL  PERFORMANCE
                                                  SUPPLIED  BY  MEREDITH/BURDA3  (SOLVENT  QUANTITIES  EXPRESSED  IN GALLONS)
                                      April     May      June     July     August   September   October   November   December   January   February   March   April   May
              Item   Solvent Item       1979    1979      1979     1979      1979      1979       1979       1979       1979       1980      1980      1980    1980  1980
                1  Solvent content    21,409   17,445   22,817   26,705     42,891    45,535      48,213    41,037     44,326     36,983    26,113    34,164  30,497  35 601
                   of  bulk ink and                                                                                                                            '  '
                   extender
                2  Solvent added      46,888   50,164   54,260   58,487     88,002   100,815     107,652    89,922    108,317     76,455    61,466   80,866  60,545  78 105
                   to  ink
                3  Total solvent      68,297   67,609   77,077   85,192    130,893   146,350     155,865   130,959    152,643    113,438    87,579   115,030  91,042 113 796
                   used  (1+2)


                4  Solvent            63,546   60,510   74,404   66,494     95,862    99,949     66,082   121,340    135,652    102,058    77,534   109,955  85  115 106 916
                   recovered through                                                                                                                           *
I"5                 decanter
ro	,	„___________„	
01              5  Used  Solvent       2,200    3,850     -                  -         -".         ~.          ~        I         I       ~~      ~
                   recovered from
                   clean-up
                6  Total recovered    65,746   64,360   74,404   66,494     95,862    99,949      66,082   121,340    135,652    102,058    77,534  109 955  85 115 106 916
                  solvent (4+5)                                                                                                                               '
                7  Apparent average    96.3%    95.2%    96.5%    78.1*      73.2%     68.3%       42.4%    92.7%      88.9*      90.0%      88.5%   95.5%   93 5*  94 c?
                  overalI  recovery
                  efficiency (6/3)
                                 b
                8  Adjusted average    91.3%   90.2%    91.5%              Emission Control              87.7%      83.9%      85 0%      83 5%   90 5%   88 5?  89  0*
                  overall recovery                                       system malfunction
                  efficiency during
                  time period
             8This information was supplied  by Heinz Gugler  (M/B) in two  letters: (1)  July 6, 1979 to Edwin J. Vincent  (EPA), (2) June 19,  1980 to Don R.  Goodwin (EPA)

              Efficiencies  are 5 percent lower than measured apparent efficiencies:   ?.%  for a temperature correction factor (see Table C-5) and 3% for infiltration  of
              solvent vapors.

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                                TABLE C-ll.   ESTIMATED  AIR PURGE TIMES REQUIRED TO DECREASE
                        THE  TOLUENE VAPOR CONCENTRATION INSIDE THE MEREDITH/BURDA CABIN ENCLOSURES
                          TO BELOW OSHA STANDARDS  LEVEL AT THE TIME OF A PRESS SHUTDOWN, MINUTES3
ro
en
Pressroom concentration,
a = ppmv
50
100
150
Adsorber efficiency
Air flow rate through cabin enclosure,
Q=SCFM
7,000 (measured)
0.9
1.1
1.4
98.3
(tested average)
10,000 (design)
0.6
0.8
1.0
98.1
(calculated)

                         1.   Cabin  is  assumed  to  enclose  only  the  top portion of the eight printing units of
                             a  press.
                         2.   Cabin  dimensions  are assumed to be  51  ft.  long by 9 ft.  wide by 7 ft.  high,  for
                             a  total volume  V  = 3,200 cubic feet.
                         3.   OSHA time-weighted average allowable  toluene  vapor concentration at 200 ppmv.
                         4.   Initial toluene vapor concentration in cabin  at press  shutdown is Yo = 1,000 ppmv
                             (worst-case).
                         5.   Desired final toluene vapor  concentration  in  cabin after press shutdown is
                             Y  = 190 ppmv.
                         6.   Pressroom ambient air toluene vapor concentration ranges from about a  = 50  to
                             over 150  ppmv.
                         7.   The measured air  flow rate through  each  cabin enclosure  was  about Q =  7,000  SCFM;
                             the design rate was  Q = 10,000 SCFM.
8.   Purge time:
                                             V ,   /Yo -
                                           = Q  ln  1
             Increasing the  air  purge  to the design flow rate would decrease  the  adsorber  inlet  toluene  vapor
             concentration from  an average of  1,200 ppmv (see Table C-18)  to  about  1,080 ppmv.

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                      TABLE C-12.   SUMMARY  OF  TEST  RUN  RESULTS  DURING  MONSANTO RESEARCH CORP.  TESTS
                                           AT  TEXAS COLOR  PRINTER  FACILITIES9
o
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ro
ITEM
1
2
3
4
5
6
7
8
9
10
11
RUN
Total solvent to presses, gallons
Recovered solvent, gallons
Adsorber outlet loss, gallons
Condensate-solvent loss, gallons0
Floor sweep loss, gallons
Percent of total solvent, % (5/1)
Product retained, gallons
Percent of total solvent, % (7/1)
Overall recovery, % (2/1)
Capture efficiency, %e (2+^+4)
Adsorber efficiency, % (9/10)
1
900
859
16.7
0.7
61.5
6.8
--
--
95.4
97.4
98.0
2
978
881
70.2
0.5
84.7
8.7
--
--
90.0
97.3
92.5
3
1,078
764
23.2
0.7
95.5
8.9
194.6
18.0
70.9
73.1
97.0
TOTAL
2,956
2,504
110.1
1.9
241.7
8.2
98.3
3.3
84.7
88.5
95.7
            See  Figure  4-1,  Chapter 4.

            GC/FID analyses  on  a  semi-continuous basis-integrated with measured  air  flow rates.

           cSee  Table C-14.
            [l-(2+3+4+5)]—Assuming no unaccounted  fugitive  vapor losses  from  pressroom.
           Q
            Represents  the relative amount of solvent vapors that are captures and directed
            thru carbon adsorbers.

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              TABLE C-13.  COMPARISON OF RECOVERED SOLVENT DATA BY VAPOR PHASE MEASUREMENTS AND
                   METER READINGS FROM MONSANTO RESEARCH CORP. TESTS AT TEXAS COLOR PRINTERS
00

Run
Test time, hours
Recovered solvent by
meter readings, gallons
Recovered solvent by
vapor phase measurements
GC/FID analysis method, gallons
TGNMO analysis method, gallons
FID analysis method, gallons
Adsorber efficiencies, %a
GC/FID:
TGNMO :b
FID:
1 2 3
4Jg 4% 4^
859 881 764

450 511 675
609 953 973
536 517 582

96.4 87.9 96.7
95.5 96.3 95.4
97.1 88.5 96.4
TOTAL
13%
2504

1636
2536
1635

93.7
95.7
94.0
       Recovered solvent was  calculated as the difference in total hydrocarbon content of the
        gas flows in and out of  the adsorbers.
       bSolvent assumed to  be  86%  carbon with density of 6.6 Ibs/gallon.

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              TABLE C-14.   SOLVENT  LOSS  WITH  CONDENSATE  FROM  DECANTER  DETERMINED  BY
                         MONSANTO RESEARCH  CORP.  AT  TEXAS  COLOR  PRINTERS


Run


Test time, hours


o
ro
to
Steam/recovered
Solvent content
solvent, #/#a
from decanter,
PPMD:
gallons0:
Percent of total solvent, %d



1
4%
4.5
171
0.7
0.07


2 3
4% $h
4.5 4.5
132 187
0.5 0.7
0.05 0.06


TOTAL
13*
4.5
1.9
0.06

 Weight per unit weight ratio  according  to  plant  information—not measured.

 Total  of Naphtha,  Toluene,  and  Xylene component  analyses  by  GC/FID--temperature  not
 measured.   Toluene is  largest dissolved component—Naphtha is  smallest.

'Calculated assuming condensate  flow  equal  to  calculated  steam  flow with  solvent  density
 of 0.742 grams/cc

 Solvent volume loss from  decanter  divided  by  total  solvent used at the presses
 (See  Table C-12, #1).

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            TABLE C-15.  TEXAS COLOR CARBON ADSORBER EFFICIENCY DETERMINED  FROM TESTS
                                   BY MONSANTO RESEARCH CORP.






o
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o


ITEM
1
2
3
4


5




RUN 1 2
Recovered solvent, gallons9 859 881
Decanter solvent loss, gallons 0.7 0.5
Adsorber outlet loss, gallons0 16.7 70.2
Total solvent thru adsorber, 876.4 951.7
gallons (1+2+3)

Adsorber efficiency, % 98.1 92.6
i i o A
i iT
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o
            TABLE  C-16.   SUMMARY OF TEXAS COLOR PRINTERS TEST RESULTS  FROM MATERIAL  BALANCES*
                                          BY RADIAN CORPORATION

Item
1
2
3
4
5
6
Meter Readings
Total bulk ink and extender input
Total solvent in bulk ink and extender
Total solvent added
Total solvent input (2+3)
Solvent recovered through decanter
Average overall recovery efficiency (5/4)
Volumes
(Gallons)
11,508
5,382
13,173
18,555
15,427
83.1%

       *This material  balance was conducted  in an 82 hour  period  from 4/9/79  to  4/12/79.

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                      TABLE C-17.    ESTIMATED ADSORBER INLET SLA* VAPOR CONCENTRATIONS
                               IF  FLOOR SWEEPS VENTED TO TEXAS COLOR ADSORBER

Total Hydrocarbons, ppma
SLA* Stream
Adsorber Inlet
Both Floor Sweeps
Potential Adsorber Inlet
Presses Up
1,020
400
870
Presses Down
70
200
100
Flowrate
(SCFM)
61,200
19,130
80,330
        aAverage of three test runs by GC/FID analyses for toluene, xylene, and naphtha components.
         Solvent laden air.

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                           TABLE C-18.  ESTIMATED ADSORBER EFFICIENCY VARIATIONS FROM

                                   MONSANTO RESEARCH CORP. TEST RESULTS

Two-Press Operation
Both up:
One up/one down:
Both down:
Time-weighted average:
Printing
Time,
%
60
33
7
—
Inlet ,
cone. ,
ppmv
1,670
770
300
—
Outlet.
cone. ,
ppmv
20
20
20
—
Adsorber
Efficiency
%
98.8
97.4
93.3
97.9

o

GO

00       a
         Average of three test runs at both Meredith/Burda and Texas Color—See Table C-2.


         Measured at Meredith/Burda.

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                        TABLE  C-19.   POTENTIAL  FOR  INCREASED  SOLVENT RECOVERY  EFFICIENCY
                                  AT  TEXAS  COLOR  PRINTERS  IF  FLOOR  SWEEP  VENTS
                                        WERE  DIRECTED TO ADSORBER SYSTEM
o
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-F*


DATA SOURCES
MONSANTO (EPA) TESTS
RADIAN (EPA) DATA
GRI DATA
TEXAS COLOR DATA6
Overall
Efficiency
%
84.7
83.1
81.5
81.0
Capture
Efficiency
%
88.5
86.9
85.3
84.8
Potential5
Capture
Efficiency
%
96.7
95.1
93.5
93.0
Potential Overall
Efficiency, %
(c)
91.7
90.1
88.5
88.0
(d)
93.8
92.2
90.7
90.2

        Calculated  from material  balance  around adsorber assuming  constant  air  flow  and  therefore
        constant  adsorber  outlet  loss  as  shown in Table C-12, #3.

        3Floor  sweep solvent  content  8.2%  of total solvent used  as  shown  in  Table  C-12, #6;  differences
        in overall  recovery  efficiency assumed to be caused  by  variations in  product retentions,
        with constant  fugitive  vapor capture  by floor  sweeps.

        'Calculated  from material  balance  around adsorber for 31% increase in  air  flow and adsorber
        outlet losses—Adsorber efficiency would decrease about 1%  in each  case.

        Utilizing gas  analyzers for  concentrating exhausts and  initiating bed regeneration, with
        close  capture  of fugitive vapors  would facilitate an average adsorber efficiency of
        97%, yielding  higher overall efficiencies.

        "This reflects  long-term data - see Table C-20.

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o
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                        TABLE  C-20.   PLANT OPERATING  DATA  SUPPLIED  BY  TEXAS  COLOR PRINTERS

                                     ON  OVERALL  EMISSION CONTROL  PERFORMANCE3
                                     (SOLVENT QUANTITIES  EXPRESSED  IN  GALLONS)

Item
1
2
3
4
5
6
7
Solvent Item
Solvent content of bulk ink and extender
Solvent added (to pressroom)
Total solvent used during period (1+2)
Solvent recovered through decanter
Used solvent recovered from clean-up
Total recovered solvent (4+5)
Apparent average overall recovery efficiency
during time period (6/3)
Five month cumulative period
during 1979
173,160
344,000
517,160
419,000
-
419,000
81%
        aThis  information  appeared  in a  letter  from  Phillip  R.  Macaskill  (TCP)  to Richard A.  Reich (Radian)
         dated July  3,  1979.

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                              TABLE C-21.  FOUR-WEEK AVERAGED PLANT OPERATING DATA
                      ON OVERALL EMISSION CONTROL PERFORMANCE SUPPLIED BY STANDARD GRAVURE
o
CO
Four-Week
Period/Year
10/1978
11
12
13
1/1979
2
3
4
5
6
7
8
9
10
11
12
13
1/1980
2
3
Total Solventb
Usage
1.4
1.5
1.5
1.2
1.1
1.3
1.5
1.4
1.2
1.4
1.2
1.4
1.3
1.4
1.4
1.5
1.3
1.0
1.1
1.3
Steam Usage9
Rati o
5.5
5.0
5.2
6.3
7.1
6.0
6.0
5.7
6.2
5.8
7.1
4.7
6.5
6.3
6.2
5.8
6.2
7.4
7.8
8.0
Overall Control0
Efficiency, %
82.1 Emission
80.5 Control
81.7 System
85.4 Malfunction
81.2 4
85.1
86.0
85.8
90.4
87.1
86.4
85.0
87.2
87.4
88.0
89.3
89.0
85.9
86.0
88.5
        aPounds of steam per pound of recovery solvent.
        ^Millions of pounds of solvent per period, including solvent in purchased inks.
        cTotal pounds of recovered solvent divided by total pounds of solvent used.

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    C
    a:
      90
    o

    OJ
    •P"
    o
      80
    OJ

o   I
'    
    O
       60
      70   „
                              FIGURE C-2.   OVERALL VOC EMISSION CONTROL/SOLVENT RECOVERY SYSTEM PERFORMANCE
                                           BY WEEKLY AVERAGING PERIODS SUPPLIED BY  WORLD COLOR PRESS

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                            TABLE C-22.  VOC CONTROL DATA  FROM  A FEW  NON-TESTED
                                    PUBLICATION ROTOGRAVURE  FACILITIES
o
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00

DATA SOURCES
Alco-Gravure, Los Angeles, CA
Gravure West, Los Angeles, CA
Older Meredith/Burda (phase I and phase II),
Lynchburg, VA

FUGITIVES
CAPTURE
METHOD
Drop hoses
Floor sweeps
Floor sweeps
Without floor sweeps

OVERALL CONTROL
EFFICIENCY, % a
87-88
90
87
82
DO O7
         Monthly average efficiency estimates reported  by  plants.

        }Ceased operations  in  1978.

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                             APPENDIX D
             EMISSION MEASUREMENT AND CONTINUOUS  MONITORING
 D.I  EMISSION MEASUREMENT METHODS
      During the standard support study for the Publication Rotogravure
 Printing industry, the EPA conducted tests for volatile organic compounds
 at two printing facilities.  In order to determine solvent recovery
 efficiencies, ink and solvent samples were taken and analyzed for
 volatile organic compounds.  In addition, stack tests were performed
 as described in "Measurement of Gaseous Organic Compound Emissions  by
 Gas Chromatography," by W.  R. Feairheller, Monsanto Research Corporation
 under EPA Contract No. 68-02-2818,  and, on one test,  with  the EPA draft
 Method 25 for determination of Total Gaseous  Nonmethane Organic emissions
 (TGNMO) to evaluate the capture efficiencies  of hoods and  the control
 efficiencies of carbon adsorbers.
      Of the two facilities  tested,  both used  carbon adsorbers for emission
 control and solvent recovery.  The  inlet and  outlet of each  adsorber
-system was  tested  using direct  coupling of a  gas  chromatograph  with  a
 flame ionization detector (GC/FID).   Sampling was  over the entire cycle
 of the adsorber system.   Periodic bag samples were also  taken and analyzed
 for speciation  by  GC/FID.   Ink,  solvent,  and  water samples were  taken
 during the  adsorber cycle and analyzed  by GC/FID at the  contractor's lab
 after the field test.
      At one of  the test  sites,  part  of  the  emissions  from the printing
 process were vented  to the  atmosphere.  These locations were  analyzed by
 collecting  bag  samples and  using a GC/FID for  analysis.  On this  test,
 TGNMO samples were  taken  on the adsorber  system inlet  and outlet and the
 ducts that  vented  organic compounds  to the  atmosphere.
                                D-l

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 D.2   PERFORMANCE TESTING AND CONTINUOUS MONITORING



      During the development of the standard,  several  methods  were



 considered for demonstrating performance and  continuous monitoring  of



 control equipment.   Two of these includes the measurement  of  organic



 stack emissions or  the measurement of the inlet and outlet organic



 emission rates for  determination of control equipment efficiencies.



 Both of these approaches would have required  either the GC/FID or the TGNMO



 (Method 25) tests performed by EPA during the standard development  test



 program.  The third method considered was solvent inventory which measures



 the solvent used in the printing operation and the solvent  recovered



 by the control  device.   The first two methods would not account  for



 fugitive emissions  which are not captured and removed by the  control



 device where the solvent inventory would  measure all  solvent  loss.  Therefore,



 the recommended method  for the demonstration  of performance and  continuous



.monitoring for operation and maintenance  of control  equipment"is  the



 measurement of solvent  used and the solvent recovered during  the



 printing operation.



      To determine the solvent recovery efficiency of a carbon adsorption



 system used on  a Rotogravure printing operation, a solvent  inventory



 system can be used.  In  such a system,  it  is  necessary to know three  things:



      (1)   the amount of solvent mixed with the raw ink at the



           ink fountains



      (2)   the solvent content of the  raw  ink and varnish, as it



           comes  from.the supplier



      (3)   the solvent recovered from  the  printing operation by the



           carbon adsorption system
                                 D-2

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      The quantity of solvent used to dilute the  raw  ink  can be obtained



 from the meter at the solvent storage tank.   (This meter will read



 slightly higher than the sum of the individual solvent meters at the



 press fountains since a faucet is located  in  the line prior to each meter



 and some solvent from each faucet is used  for periodic cleaning of press



 components.)



      Quantities of raw ink and varnish  used can  be obtained from the



 respective meters located  at the fountains  and solvent recovered can



 be read  from  a  meter at the solvent  recovery decanter.



      Since the  raw ink contains  a high  percent of solvent, the solvent



 recovered by  the adsorption system can  be greater than the solvent used



 from the solvent storage tank.   It is necessary, then, to know the



 quantity of solvent contained  in the raw ink and varnish to accurately



 characterize  the system.   This can be determined from the ink manufacturer



-or using a  simple evaporative  technique.  If the same supplier furnishes



 solvent,  ink, and varnish  during the period of the solvent inventory,



 concentration should  not change.   Furthermore, these components  are



 constantly  circulated  in their bulk  storage tanks, so one analysis of



 this  nature should  suffice.



      To  determine the  efficiency  of  the carbon adsorber  system,  readings



 of the solvent used,  solvent recovered, and solvent contained  in the raw



 ink and varnish could  be collected over a period  of 2 to  4  weeks.   This



 time  interval  would provide accurate data as well as  rendering insignificant



 variations in the process that would otherwise effect the accuracy



 of similar or other measuring techniques of much  shorter  duration.
                                 D-3

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                                    TECHNICAL REPORT DATA
                            (/'lease read Instructions on the reverse before complctinR)
  H: HOR r NO.
  EPA-450/3-80-031a
   i TIE AND SUBTITLE
   I i TLE AND SUBTITLE
   Publication  Rotogravure Printing  -
  Background Information for Proposed  Standards
                                                            t> REPORT DATt
                                                                 October 1980
                                                            6. PERFORMING ORGANIZA1 ION CODt
J7 AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
,« __ _, ________
?S   R
               _ _
      pRMINGORGANJLZATJON NAME AND ADDRESS     ,    ,
      ice  of Air Quality Planning  ana  Standards
  U,  S, Environmental Protection  Agency
  Research  Triangle Park, North Carolina  27711
J12 SPONSORING AGENCY NAME AND ADDRESS
{  DAA  for  Air Quality Planning  and  Standards
I  Office of Air, Noise, and Radiation
I  U.S.  Environmental Protection Agency
  Research Triangle Park, North Carolina  27711
                                                            3. RECIPIENTS ACCESSION NO.
                                                            10 PROGRAM ELEMENT NO.
                                                            11. CONTRACT/GRANT NO.

                                                              68-02-3058
                                                            13. TYPE OF REPORT AND PERIOD COVERED
                                                                Final
                                                            14. SPONSORING AGENCY CODE

                                                                 EPA/200/04
 15 SUPPLEMENTARY NOTES
 16. ABSTRACT                                                             ~~	'	
  Standards  of Performance for  the  control of emissions  from publication rotogravure
  printing  presses are being  proposed under the authority  of Section 111 of  the  Clean
  Air  Act.   These standards would apply only to presses  printing saleable products and
  for  which  construction or modification began on or after the date of proposal  of the
  regulation.   This document  contains background information and environmental and
  economic  impact assessments of the regulatory alternatives considered in developing
  Proposed standards.
KEY WORDS AND DOCUMENT ANALYSIS
';'.' DESCRIPTORS
A.,- pollution
;, Graphic Arts Industry
, -ollution Control
' P'ib': i cation Rotogravure Printing
Rotogravure
Standards of Performance
i "n];;cile Organic Compounds (VOC)
.:-, ;-",rH" '.'TION STATEMENT
I
Unlimited
Jt
b.lDENTIFIERS/OPEN ENDED TERMS
Air Pollution Control
19 SEC RITY CLASS (This Report/'
Unclassified
20. Stf RITY CL.ASS (This page)
Unclassified
c. COSATI [ ield/Gtoup
13B
21 NO. OF PAGES
273
22. PRICE
 ".!A Fofi.i L'??0-1 (Rev. 4-77)
                       PREVIOUS EDITION is OBSOLETE

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