United States
            Environmental Protection
            Agency
 Office of Air Quality
 Planning and Standards
 Research Triangle Park NC 27711
EPA-450/3-91-008
February 1991
            Air
&EPA     Best Demonstrated Control

            Technology for Graphic Arts
            control
technology center

-------
                                                    EPA-450/3-91-008
BEST DEMONSTRATED CONTROL TECHNOLOGY FOR GRAPHIC ARTS
               CONTROL TECHNOLOGY CENTER

                       SPONSORED BY:

                   Emission Standards Division
            Office of Air Quality Planning and Standards
               U.S. Environmental Protection Agency
                Research Triangle Park, NC  27711
          Air and Energy Engineering Research Laboratory
               Office of Research and Development
               U.S. Environmental Protection Agency
                Research Triangle Park.NC 27711


           Center for Environmental Research Information
               Office of Research and Development
               U.S. Environmental Protection Agency
                     Cincinnati, OH 45268


                        February 1991

-------
                                                      EPA-450/3-91-003
                                                      February 1991
BEST DEMONSTRATED CONTROL TECHNOLOGY FOR GRAPHIC ARTS
                          Prepared by:
                         Beth Friedman
                          Chuck Vaught

                    Midwest Research Institute
                    Gary, North Carolina 27513
                   EPA Contract No. 68-02-4379
                      ESD Project No. 89/08
                      MRI Project No. 8952-31
                           Prepared for:
                         Karen P. Catlett
                   Chemicals and Petroleum Branch
             Office of Air Quality Planning and Standards

                    Control Technology Center
               U.S. Environmental Protection Agency
                Research Triangle Park, NC 27711
                                                                •lil Floof
                                           Chicago,          -

-------
                                  PREFACE
     The CTC was established by EPA's Office of Research and Development
(ORD) and Office of Air Quality Planning and Standards (OAQPS) to provide
technical assistance to State and local air pollution control agencies.
Three levels of assistance can be accessed through the CTC.  First, a CTC
HOTLINE has been established to provide telephone assistance on matters
relating to air pollution control technology.  Second, more in-depth
engineering assistance can be provided when appropriate.  Third, the CTC
can provide technical guidance through publication of technical guidance
documents, development of personal computer software, and presentation of
workshops on control technology matters.
     The technical guidance projects, such as this one, focus on topics of
national or regional interest that are identified through contact with
State and local agencies.
     In this case, the CTC had received numerous .-requests for assistance
in determining BACT/LAER for the graphics arts industry.  They had also
received reports that several graphics arts facilities were achieving VOC
control efficiencies of 90 percent or greater.  This study was undertaken
to document the reported overall control efficiency for VOC's at a number
of rotogravure and flexographic printing facilities.

-------
                              NOTICE

This report was prepared by Midwest Research Institute, Gary NC.
It has been reviewed for technical accuracy by the Emission
Standards Division of the Office of Air Quality Planning and
Standards and the Air and Energy Engineering Research Laboratory
of the Office of Research and Development, U.S. Environmental
Protection Agency, and approved for publication.  Mention of
trade names or commercial products is not intended to constitute
endorsement or recommendation for use.
                         ACKNOHLEOGEMEMT

This report was prepared for the Control Technology Center by
Beth Friedman, Chuck Vaught, Charles Hester, and Rebecca
Nicholson of Midwest Research Institute.  The EPA project officer
was Karen Catlett.  Also serving on the EPA project review team
were James Berry and Bob Blaszczak of the Office of Air Quality
Planning and Standards, and Chuck Darvin of the Office of
Research and development.
                               ii

-------
                             TABLE OF CONTENTS

                                                                       Page

1.0  INTRODUCTION	       1

2.0  CONCLUSIONS	       2

3.0  DESCRIPTION OF PROCESSES USED BY THE GRAPHIC ARTS
       INDUSTRY	       5

     3.1  FLEX06RAPHIC PRINTING	       5
     3.2  ROTOGRAVURE PRINTING	.	       7

4.0  CRITERIA FOR DETERMINING OVERALL CONTROL EFFICIENCY	       9

     4.1  PERMANENT TOTAL ENCLOSURE CRITERIA	       9
     4.2  DESTRUCTION OR REMOVAL EFFICIENCY CRITERIA	     10

5.0  RESULTS	     11

     5.1  PACKAGE PRODUCTS	     11
     5.2  TARKETT, INC	     16
     5.3  MAXWELL GRAPHICS	     19
     5.4  ADVANCED PRINTING TECHNOLOGY	"....     23
     5.5  MORRILL PRESS	     26
     5.6  AMKO PLASTICS	     30
     5.7  CMS GILBRETH PACKAGING SYSTEMS	     32

6.0  DISCUSSION	     37

     6.1 . OVERALL CONTROL SUMMARY	     37
     6.2  WATER-BASED INKS	     40
     6.3  OTHER TOTAL ENCLOSURE CONSIDERATIONS	     41

7.0  REFERENCES	     42

-------
                              LIST OF FIGURES

                                                                      Page

Figure 1.  Flexographic printing process	      6

Figure 2.  Rotogravure printing process....	      8
                              LIST OF TABLES

TABLE 1.   CHARACTERISTICS OF PLANTS VISITED TO ESTABLISH
           CURRENT BEST DEMONSTRATED TECHNOLOGY	  .    3

TABLE 2.  SUMMARY OF PTE CRITERIA AT PACKAGE
           PRODUCTS IN CHARLOTTE, NORTH CAROLINA	     15

TABLE 3.  SUMMARY OF PTE CRITERIA AT TARKETT
           IN WHITEHALL, PENNSYLVANIA	     18

TABLE 4.  SUMMARY OF PTE CRITERIA AT MAXWELL
           GRAPHICS IN RICHMOND, VIRGINIA	     22

TABLE 5.  SUMMARY OF PTE CRITERIA AT ADVANCED PRINTING
           TECHNOLOGY IN MORGANTOWN, PENNSYLVANIA	     24

TABLE 6.  SUMMARY OF PTE CRITERIA AT
           MORRILL PRESS IN FULTON, NEW YORK	     29

TABLE 7.  SUMMARY OF RESULTS OF EXAMINATION FOR PTE
           CRITERIA AT ALL PLANTS VISITED	,.     38

TABLES.  SUMMARY OF OVERALL CONTROL EFFICIENCIES	     39
                                  1v

-------
 1.0  INTRODUCTION
     The Control Technology Center  (CTC) and others within  the  U. S.
 Environmental Protection Agency (EPA) have received reports that several
 graphic arts facilities are achieving VOC control efficiencies  of
 90 percent or greater and that several facilities are using permanent
 total enclosures.  The CTC also received requests for assistance in
 determining best available control  technology and lowest  achievable
 emissions rate (BACT/LAER) for this industry.  This study documents the
 reported overall control efficiency for volatile organic  compounds (VOC's)
 at a number of rotogravure and flexographic printing facilities.
 Facilities were contacted for background information to (1)  identify
 facilities with 90 percent control  efficiency or greater  and  (2) document
 these efficiencies.  The overall objective of the effort  is to  provide
 assistance to State and local agencies requesting information on BACT and
 LAER.  Documenting that several facilities achieve very high capture and
 control efficiencies is a necessary approach to this effort.
     The information obtained from  site visits was used to  document the
 overall control efficiency achieved at each operation.  As  with any air
 pollution control problem, overall control efficiency is  based  on the
 product of two component efficiencies:  capture efficiency  and  control
 device efficiency.  Previous regulatory efforts have typically  focused on
 the control device component; therefore, existing documentation and test
 methodologies tend to be more readily available for this  efficiency
 determination.  Therefore, the focus of this project was  the collection of
 information related to the efficiency of the capture system.  In some
 cases, limited capture efficiency test data were available;  in  other-
 cases, information on enclosure system design criteria and  operating
 conditions was collected to determine capture system efficiency.  An
 overall control efficiency was then estimated for each facility.  Because
 one of the facilities had converted to water-based inks,  thereby
dramatically reducing maximum potential  VOC emissions, local regulations
did not require a capture system and a control device.
     Midwest Research Institute contacted (by telephone)  State  and local
agencies,  Regional  EPA offices, and graphic arts facilities to  obtain
 information on flexographic and rotogravure graphic arts  facilities that

                                     1

-------
reportedly achieved VOC control efficiencies of 90 percent or greater.
Nineteen graphic arts facilities and one vinyl flooring manufacturer were
contacted.  Of the 20 facilities contacted, only seven stcited that their
overal 1 VOC control efficiency was 90 percent or greater.  Of these seven
facilities, six were visited by the project team.  Two additional
facilities that were thought to have adopted particularly innovative
capture technologies were later identified by EPA.  These facilities were
visited as well.
     Table 1 is a list of facilities that were visited and a summary of
the key characteristics of the facilities.  Seven of the facilities are
typical graphic arts facilities.  Of these seven, six are packaging
facilities and one is a publishing facility.  The eighth facility, which
is a vinyl flooring manufacturer, was visited because the VOC capture and
control system (total enclosure plus incinerator) used at this facility
promised to be applicable to graphic arts facilities also.  In addition,
the eighth facility uses a rotogravure printer for its vinyl printing
operation, the basic printing process is similar to that used at more
typical graphic arts facilities, and the facility is regulated as a
graphic arts facility.
2.0  CONCLUSIONS
     The following list of conclusions is based on the information
collected during the study:
      1.  The use of capture and control systems and the use of
water-based ink systems have been demonstrated to be effective and
reliable in achieving a greater than 90 percent overall reduction in VOC
emissions from graphic arts facilities using rotogravure and flexographic
printing presses.  In addition, more recent information reported to EPA
indicates that the following graphic arts facilities using solvent-based
inks have adopted (or are in the process of adopting) capture and control
systems that achieve greater than 90 percent VOC emission reductions:
    •  Colonial Heights Packaging, Virginia
    •  Central States Diversified, Minnesota
    •  Maxwell Communications Corporation, Tennessee
    •  Princeton Packaging, Incorporated, Pennsylvania

-------
      TABLE  1.   CHARACTERISTICS OF PLANTS VISITED TO ESTABLISH CURRENT BEST DEMONSTRATED TECHNOLOGY
Company, location
Type of primary
printing system
End product
Special characteristics/
add-on control
Plants with total enclosures
Package Products,
  Charlotte, NC

Tarkett, Inc.,
  Whitehall, PA

Maxwell Graphics,
  Richmond, VA

Advanced Printing Technology,

  Morgantown, PA

Morrlll Press,
  Fulton, NY

CMS Gllbreth—Bristol Plant,
  Croydon, PA
CMS Gllbreth—Bensalem Plant,
  Bensalem, PA
Plant which uses only
waterborne coatings
Amko Plastics,
  Cincinnati, OH
Flexographlc


Rotogravure


Rotogravure


Rotogravure



Rotogravure


Rotogravure
Rotogravure and
.  flexograhlc
Flexographlc
Packaging
Catalytic incinerator
Vinyl flooring   Regenerative Incinerator
Publishing
Packaging


Packaging



Packaging
Packaging
Carbon adsorber
Wood grained     Thermal incinerator
  laminates
Catalytic incinerator
Capture systems use
  recirculation,
Regenerative incinerator

Capture systems use
  recirculation,
Regenerative incinerator
Water-based coatings

-------
     Although EPA has not verified these reports, they are an indication
of the growing use of high efficiency capture and control systems in the
graphics arts industry.
      2.  The facilities visited demonstrated overall control efficiencies
of 94 to over 99 percent;
      3.  States should be cognizant of the demonstrated control
efficiencies obtained in these and other graphic arts facilities and apply
this information in future RACT, BACT, and LAER determinations.  The
previously accepted VOC reductions of 65 percent, often considered to be
RACT for this industry, may no longer be considered the maximum reduction
capability for graphic arts operations;
      4.  Only one of the facilities visited was a totally new facility.
The other facilities, including the facility using water-based inks, had
all been retrofitted with the technology used to reduce VOC emissions;
      5.  The majority of facilities reporting >90 percent overall control
used total enclosures and add-on devices to achieve that level;
      6.  Permanent total enclosures (PTE's) meeting EPA criteria have
been successfully installed and operated at graphic arts facilities using
rotogravure and flexographic presses;
      7.  At some plants, differential pressure controllers in the
enclosure were used to maintain a specified pressure drop between the
inside of the enclosure and ambient pressure.  Maintaining a static
pressure drop of about 1.0 pascal (Pa) (0.004 inch [in.] water) across the
natural draft opening (NDO) results in internal face velocities of at
least 3,600 meters per hour (m/hr) (200 feet per minute [ft/min]), thus
meeting EPA Criteria 4, one of the criteria established by EPA for
defining a PTE;
      8.  For facilities utilizing capture and control, well-designed
localized air collection and overall air management systems not only
enhance the effectiveness of the control system but are also reported to
improve the quality of the air in the press room and, as a result, working
conditions;

-------
      9.  There was  no degradation  in worker  safety or  health  conditions
 in facilities utilizing permanent total enclosures.  Based on  comments  by
 management and workers, working conditions were  improved  in  some
 facilities;
      10.  The PTE's  present no more of a  fire hazard than other press
 rooms.  All are designed  so that workers  can  exit  quickly in case there is
 a fire or explosion; and
      11.  The plant  that  used water-based inks reported other
 environmental, health, and safety benefits in addition  to reduced VOC
 emissions.  These benefits included reduced amounts of  hazardous wastes
 (and  reduced disposal costs), elimination of  the need for special storage
 areas (water-based inks are noncombustible),  and significantly improved
 working conditions.
 3.0   DESCRIPTION OF  PROCESSES USED  BY THE GRAPHIC  ARTS  INDUSTRY
 3.1   FLEXOGRAPHIC PRINTING1
      Flexography, shown in Figure 1, uses a flexible plate, which may be
.made  of rubber or a  photo sensitive polymer known  as a  photopolymer, and
 fluid inks.  Flexography  is well suited for printing on almost all
 flexible packaging materials since  the flexographic inks  dry rapidly.
 Because the plastic  substrates on which the ink  is placed, such as
 polyolefins, polystyrene, and polyesters, have nonporous  surfaces (i.e.,
 the ink will not penetrate the substrate), it is essential that the inks
 dry quickly to avoid smearing.  Flexographic  inks  also  print well on paper
 stocks, aluminum foil, paperboard,  and paper  used  for folded cartons, cups
 and containers.
      Flexographic presses are rotary machines with up to  eight color
 stations.  Ink is pumped  or poured  from a storage  container to a press
 "fountain."  The ink distribution system  usually consists of a fountain
 roller and an anilox form roller that delivers the ink  to the  printing
 plate, although some newer distribution systems  eliminate the  rubber
 fountain roller and  immerse the anilox form roller in the ink  fountain.
 A doctor blade removes excess ink from the form  roller.   The ink is
 transferred from the form roller to the printing plate  and from the
 printing plate to the substrate.  A drying oven  then dries the printed
 web.

-------
                     FLEXDGRAPHIC  PRINTING
       PLATE
       CYLINDER

   ANILDX FORM
   ROLLER
FOUNTAIN
  ROLLER
                                                 PAPER
                                        IMPRESSION
                                        CYLINDER
           INK FOUNTAIN
                                                         PAPER
                                                         STOCK
                    Figure 1.  Flexographic printing process.

-------
     Flexographic inks consist of one or more resins dissolved in a
solvent blend.  A combination of solvents may be required, particularly
when more than one resin is used.  The solvent blend consists primarily of
the lower molecular weight alcohols, such as ethyl, n-propyl, and
isopropyl.  These may be mixed with small amounts of glycol ethers,
aliphatic hydrocarbons, acetates, or esters to obtain optimum resin
solubility, proper drying speed, and viscosity.
     Flexographic inks can also be water-based.  Although they are used
primarily on porous substrates such as paper and paperboard, they can be
used successfully on any substrate if the printer is willing to invest
enough effort in devising a workable system.  Water-based inks have
several advantages, including good press stability and printability,
compliance with air pollution regulations, absence of fire hazards, and
reduced insurance costs.  They are also economical and convenient because
water can be used for dilution and for cleaning up.  The printing industry
has reported some problems with water-based inks.  On nonabsorbent
substrates such as plastic films, water-based inks do not have the gloss
of solvent-based inks and they dry more slowly.  Newer types pf water-
based inks that are more suitable for printing on plastic films are being
developed and used.
3.2  ROTOGRAVURE PRINTING1
     For the gravure printing process shown in Figure 2, the design to be
printed is etched or engraved into (below the surface of) the printing
cylinder.  The printing image consists of thousands of recessed "cells" or
indentations per square inch.  The depth and width of the cells controls
the amount of ink that is metered.  The gravure process is used for
publication printing and printing folding cartons, flexible packaging, and
specialty items such as gift wraps, vinyl plastic film, and vinyl-coated
fabrics.
     The gravure press consists of the gravure cylinder on which the
design to be reproduced is etched, an ink pan in which the cylinder is
immersed, a doctor blade that removes excess ink from the surface of the
cylinder, and the impression roller that brings the web of material to be
printed into contact with the gravure cylinder.  A drying oven then dries
the printed web.

-------
                          GRAVURE  PRINTING
oo
                      DDCTDR
                      BLADE
IMPRESSIDN
CYLINDER
 ETCHED
 CYLINDER
                                                       PAPER
                                                       STOCK
                         Figure 2. Rotogravure printing process.

-------
     Gravure inks are composed of three  ingredients:  pigment, binder, and
 solvent.  Pigment selection is based on  the color desired and any
 additional properties, such as light fastness, that may be required for
 the  job.  The binder ensures that the pigment is evenly dispersed  in the
 liquid  ink, prevents bleeding, and  helps the pigment adhere to the printed
 substrate.  Binders are selected based on their ability to develop maximum
 adhesion to the surface to be printed and on the level of gloss and
 flexibility required in the printed product.  The solvent dissolves the
 binder  to form a fluid ink and then evaporates to leave a dried ink
 film.   Organic solvents used in rotogravure inks may be esters, alcohols,
 ketones, acetates, aromatic hydrocarbons, or aliphatic hydrocarbons.  The
 solvent is selected based on a number of criteria, including complete
 solubilization or dispersion of the resins, speed of drying, cost
 efficiency, and compliance with OSHA and EPA standards.
     Water-based inks are also being used in gravure printing for  some
 applications, primarily for paper and paperboard, and, to a lesser extent,
 for  film and foil.  Research on developing ink resins that are appropriate
 for  water-based systems has resulted in  a greater variety of resin being
 available.  These new water-based systems are suitable for use on more
 substrates, have a wide range of end use properties, and dry more quickly.
 4.0  CRITERIA FOR DETERMINING OVERALL CONTROL EFFICIENCY
     As previously discussed, the purpose of this study is to verify and
 document reports that some currently existing rotogravure and flexographic
 printing plants routinely achieve 90 percent or greater overall control
 efficiencies for VOC's.  For plants using solvent-based inks, control of
 VOC's is a two-part endeavor involving first the capture of the VOC's and
 second  the destruction or removal of the VOC's from an exhausted air
 stream.  Multiplying the efficiencies of these two endeavors results in
 the overall VOC control efficiency.
 4.1  PERMANENT TOTAL ENCLOSURE CRITERIA
     Six of the eight facilities visited were using, or plan to install,
 PTE's as part of their strategy to capture and control at least 90 percent
of press operation emissions.  A permanent total enclosure is a structure
constructed around a source of emissions so that all VOC emissions are
collected and exhausted through a stack or duct to a control device.  With

-------
a PTE, there are no fugitive emissions.  All VOC must exit through a
ductwork so that any necessary concentration measurements can be made.
The PTE's may be built around a specific press or number of presses, or an
entire room may be sealed off and modified to function as a PTE.  In
either case, EPA has developed a set of design and operational criteria
which, when incorporated into the design of an enclosure, should cause its
actual capture efficiency to be essentially total.  The criteria are as
follows:
     1.  All VOC emissions must be captured and contained for discharge
through a control device;
     2.  The total area of all NDO's shall not exceed 5 percent of the
surface area of the enclosure's four walls, floor, and ceiling;
     3.  All access doors and windows whose areas are not included in
Criteria 2 and are not included in the calculation in Criteria 4 shall be
closed during routine operation of the process;
     4.  The average facial velocity (FV) of air through all NDO's shall
be at least 3,600 m/hr (200 ft/min), which equates to a pressure drop of
0.004 inches of water.  The direction of air through all NDO's shall be
into the enclosure; and
     5.  Any NDO shall be at least 4 equivalent opening diameters from any
VOC emitting" source.
     The PTE criteria were published in the new source performance
standard (NSPS) for the magnetic tape industry and the NSPS for the
coating of polymeric substrates.  Additionally, a policy statement
published April 16, 1990, "Guidelines for Developing a State Protocol for
the Measurement of Capture Efficiency" contains these criteria.  According
to these guidelines, if the criteria are met, EPA will presume that the
capture efficiency is 100 percent.  The facilities discussed in this
report that were utilizing, or are in the process of installing, PTE's had
all based the design of the PTE's on these criteria.
4.2  DESTRUCTION OR REMOVAL EFFICIENCY CRITERIA
     The determination of the destruction or removal efficiency of VOC's
exiting the enclosure is generally based on information supplied by the
plant on tests conducted to document the performance of the control
device.  The EPA Reference Method 25 is one method for determining the VOC

                                    10

-------
content into and out of a control device.  The EPA has extensive
experience with the most commonly used control devices, incinerators and
carbon adsorbers, and has information to support that these control
devices should achieve efficiencies of at least 95 percent if they are
properly designed, operated, and maintained units.
5.0  RESULTS
     This section contains a brief summary of each of the eight plants
visited and an assessment of their respective VOC capture and control
efficiencies.
5.1  PACKAGE PRODUCTS2
     Package Products Company operates eight flexographic printing presses
at its facility in Charlotte, North Carolina.  The facility prints a
variety of flexible packaging films including plastic candy wrappers and
soft drink shrink-wrap.  The presses are multicolor units with each color
applied sequentially at a different ink station.  Each color of ink is
dried before the next color is applied.  Drying is accomplished with a
natural-gas-fired, hot air dryer called the between-the-colors (BC)
dryer.  The BC dryer blows hot air on the film after each color
application.  Exhaust slots then collect the evaporated ink solvent.
After the final color is applied and dried, the printed film goes into a
natural-gas-fired overhead dryer where additional hot air is blown on the
film to remove any residual ink solvent.  All the presses are located in
one large room that has been modified to serve as a PTE capable of
capturing fugitive VOC emissions from the presses.  The VOC emissions from
the room are controlled by seven catalytic incinerators.
5.1.1  Capture Efficiency
     Permit conditions established by the Mecklenberg County Department of
Environmental Health (MCDEH) at the Package Products facility specify
90 percent VOC removal and, for three of the presses and one laminator, a
120 tons/year combined total emissions limit.  Actual combined emissions
for the three presses and one laminator were 25 tons/year.  One additional
press is limited to 40 tons/year of emissions; the plant estimates that
actual emissions are less than 2 tons/year.  Overall, the facility was
credited with achieving LAER for flexographic printing in a nonattainment
area for ozone.3
                                    11

-------
       The Package Products'  PTE  is  a room  of  approximately  6,372 cubic
  meters (m3)  (225,000  cubic  foot [ft3]).   All  entrances  to  the  room are
- closed with  the  exception of  a  2.7 square meter  (m2)  (96 square foot
  [ft ]) doorway between  the  press room  and laminating  room,,  which is
  covered with overlapping vinyl  strips.  Clean air is  blown  toward the
  vinyl  strips from within the  enclosed  press  room in order  to impede the
  movement of  dust and  dirt drawn into the  press room.
       Forced  makeup  air  is supplied to  the PTE at approximately
  850 cubic meters per  minute (m3/min) (30,000  standard cubic feet per
  minute [scfm]) from the windup  end of  the presses.  Press room air is
  exhausted through ducts located at the opposite  end of  the  presses at
  approximately 935 m3/min (33,000 scfm).   There are eight exhaust ducts,
  one behind each  press.  Thus, as the air  travels across the room from the
  supply ducts to  the exhaust ducts,  it  picks up fugitive VOC emissions from
  the presses.
       Package Products tested  the capture  efficiency of  the  PTE system
  using  three  different techniques:
       1.   Room air balance on  portion of air captured  and incinerated;
       2.   Mass balance based on  VOC charged to press;  and
       3.   Chemical smoke releases.
  At  the time  of the  test program, only four of the eight fugitive pickup
  ducts  were connected to an  incinerator because the other incinerators had
  not yet  been installed.
      The first technique, the room air balance,  showed  that 670 m3/min
  (23,666  ft3/min)  of fresh air entered the room and 630 m3/min
  (22,254  ft3/min)  was captured in the fugitive pickup  duct.  (Note:  Not
  all  of the fugitive pickup-  ducts and incinerators were  installed at this
  time.)   Approximately 42.5  m3/min  (1,500  ft3/min) of  air is collected by
.  the dryers.   Results of their air  balance analysis led  Package Products to
  conclude  that 97.6  percent  of the  VOC's are captured.
      A second technique, a  VOC  mass  balance  (liquid-gas), was  performed by
  quantifying  the  amount  of each  color ink  charged to the presses.   Using
  Ink  solvent  composition data, the  quantities  of  solvents charged to the
  presses were  calculated.  The VOC  input was compared  to the VOC loading
  measured  at  the  incinerator inlet  and a capture  efficiency  value was
  calculated.
                                      12

-------
     The capture efficiency values varied from between 42 and 130 percent.
This type of variation, although extreme, is not completely unexpected
because mass balances on presses are subject to many errors, especially
for short-term runs.  First, liquid-gas material balances have been
historically difficult to close.  Second, the physical layout at Package
Products has all of the presses in one large room.  This configuration can
result in a mixing of fugitive emissions from the presses, such that the
amount of solvent charged to an individual press may not equal the amount
of captured solvent delivered to the control device.
     As a third technique to determine qualitatively the effectiveness of
the capture system, chemical smoke tubes were used to visually demonstrate
airflow patterns in the press room.  The assumption was that demonstration
of the uninterrupted movement of smoke from the press to the air"pickup
registers is an indication of optimal capture system performance and
minimal press room VOC concentrations.  Package Products reports'that the
experiments showed that the airflow patterns were consistent from the air
supply registers, across the press room, to the air pickup registers.
     Since these three tests were conducted, the remaining incinerators
have been installed, and four more fugitive pickup ducts were connected to
the catalytic incinerators.
     During the visit, face velocity measurements were taken by the site
visit team, using a hot wire anemometer, at the vinyl-strip-covered
interior doorway and at a door leading outside that was partially
opened.  Face velocities recorded at the 2.4 m x 3.7 m (8 ft X 12 ft)
doorway with vinyl strip curtains were erratic and generally less than
30.8 m/min (100 ft/min).  At times, the airflow appeared to be directed
out of the enclosure as the result of a fan that continuously blew air at
the doorway from inside the enclosure.  Face velocity measurements were
also taken at an outside door that was partially opened by plant personnel
for the purpose of demonstrating that even if a worker enters or exits the
enclosure, a significant inward face velocity is maintained.  The
measurements showed a consistent face velocity into the enclosure of
approximately 169 m/min (550 ft/min).
                                     13

-------
     Table 2 is a summary of the PTE criteria that are satisfied at
Package Products.  Criteria 1 and 3 are clearly satisfied.
     Because of the vinyl strips in place at the 2.4 m x 3.7 m
(8 ft x 12 ft) doorway, it was not possible to accurately determine the
effective open area of the doorway.  The enclosure exhaust system draws
85 m /min (3,000 scfm) more than the makeup air system supplies.
Theoretically for this exhaust flow rate, a well sealed enclosure with
face velocities of 61 m/min (200 ft/min) across the NDO's would have an
NDO area of 1.4 m2 (15 ft2).  The total area of the doorway is 8.9 m2
(96 ft ).  In order for the criteria to be satisfied, the vinyl strips
covering the doorway must cover at least 7.5 m2 (81 ft2), or 84 percent of
the area of the doorway.  Observations made during the visit suggest that
over 95 percent of the doorway was effectively covered, by the vinyl
strips.  This analysis indicates that the theoretical face velocity is
greater than 61 m/min (200 ft/min), thus satisfying Criteria 4, and that
because the area of the NDO must be less than 5 percent of the total
surface area of the enclosure, that Criteria 2 is satisfied.
     A complicating factor .in evaluating Criteria 4 is the erratic face
velocity measurements at the 2.4 m x 3.7 m (8 ft x 12 ft) doorway leading
from the. laminating room.  The vinyl strips did not hang uniformly to seal
the doorway for at least two reasons.  The most obvious reason is the
85 m /min (3,000 scfm) that can enter only through the door-way.  In
addition, however, the ventilation system discharged against the internal
side of the door with outside air creates turbulence at the doorway.  For
this reason this facility deviates somewhat from the ideal total enclosure
and it is not possible to make absolute judgments about the probability
that fugitive emissions are not somehow aspirated through the strips.  It
does however seem unlikely.
    .The worst-case scenario for meeting the fifth criterion is that, in
the absence of the vinyl strips, the equivalent diameter of the natural
draft opening would be 2.9 m (9.6 ft).  The distance between the opening
and the nearest emission source is approximately 12.2 m (40 ft).
Therefore, Criteria 5 would be met.  In reality, the effective area of tbe
natural draft opening is much smaller because of the vinyl strips, which
greatly decrease the equivalent diameter of the opening.  The fifth
criterion is thus certainly met.
                                    14

-------
                   TABLE 2.  SUMMARY OF PTE CRITERIA AT
              PACKAGE PRODUCTS IN CHARLOTTE, NORTH CAROLINA
Criteria No.
                                                                 Plant met
                                                                 criteria
1.  All VOC emissions must be captured and contained for
      discharge through a control device

2.  Total area of NDO's is not to exceed 5 percent of total
      surface area

3.  Access doors and windows should be closed during normal
      operation

4.  The average inward face velocity across all NDO's must
      be at least 3,600 m/hr (200 ft/min)
                                                                 Yes
                                                                 Yes
                                                                 Yes
                                                                 Yes(
                                                                 Yes
5.  All sources of emissions within the enclosure should be
      at least 4 equivalent diameters away from each NDO

aFace velocity measurements were erratic at the 2.4 m x 3.7 m
 (8 ft x 12 ft) doorway leading from the laminating room.  The vinyl
 strips did not hang uniformly to seal the doorway for at least two
 reasons.  The most obvious reason is the 85 m /min (3,000 scfm) that can
 enter only through the doorway.  In addition, however, the ventilation
 system discharged against the internal side of the door with outside air
 creates turbulence at the doorway.  For this reason this facility
 deviates somewhat from the ideal total enclosure and it is not possible
 to make absolute judgments about the probability that fugitive emissions
 are not somehow aspirated through the strips.  It does however seem very
 unlikely.
                                    .15

-------
     Based on the Package Product capture efficiency test program, it
appears that the press room enclosure is capable of achieving a high level
of capture efficiency.  Because the enclosure satisfies the PTE total
criteria, the capture efficiency can be assumed to be 100 percent.
5.1.2  Control Device Efficiency
     Package Products conducted stack tests on each of the seven
incinerators in either August 1987 or February 1986.  The purpose of these
tests was to determine compliance with the plant's permit conditions.
Destruction efficiencies ranged from 98.7 to 99.6 percent.
5.2  TARKETT, INC."
     Tarkett, Inc., operates one rotogravure printing press at its
facility in Whitehall, Pennsylvania.  The facility manufactures vinyl
floor covering.  The press is a six station unit.  The inks are thinned
with solvents, primarily methyl ethyl ketone and methyl isobutyl ketone,
to achieve the proper viscosity for printing.  Each color or ink is dried
in a dryer before the next color is applied.  The dryer draws air over the
web after each color application.  The dryers do not require heat because
the line speed is low.  The plant has been retrofitted with capture and
control devices for control of VOC emissions from the press, which is
located in a large room that is sealed off to serve as a total
enclosure.  Emissions are controlled by a regenerative thermal
incinerator.  Use of the PTE allows the plant to minimize the amount of
airflow to be treated by the incinerator.5
5.2.1  Capture Efficiency
     A 2,095 m3/min (74,000 acfm) exhaust fan removes air from the total
enclosure and induces it through the control device.  Doors leading into
the enclosure remain closed and are equipped with automatic closing
devices.  Also, two slots in the enclosure walls allow passage of the web
into and out of the press room.  These slots serve as the only natural
draft openings to the enclosure.
     Capture efficiency tests have been conducted by Tarkett in accordance
with Pennsylvania regulations.  These regulations require Tarkett to
design"and operate a capture and control system that is consistent with
good engineering practices and that provides for an overall reduction in
VOC emissions of at least 65 percent.  Velocity profiles were measured at

                                     16

-------
 the  slots  where the web  enters  and exits the press room.  Also,
 differential  static pressures were measured across the slots using  low-
 range manometers and anemometers.  Based on a liquid-gas material balance,
 the  test contractor reported that capture efficiencies ranged between 97
 and  100 percent with the printing room doors open (the test report  lacks
 sufficient detail to independently verify these efficiencies).  Although
 Tarkett intended to measure capture efficiency with the printing room
 doors closed, this portion of the test was aborted when the incinerator
 went down.  However, it  is expected that capture efficiencies will  be
 enhanced with the doors  closed.
     During our visit, face velocities were measured at the natural draft
 openings using a hot wire anemometer.  Face velocities through the  natural
 draft opening into the enclosure ranged between 45.7 and 91.4 m/min (150
 and  300 ft/min) depending upon  the position of the probe.  The differing
 face velocities are attributed  to the web and web-conveying equipment that
 are  positioned in the natural draft opening, which possibly cause
 variability in local face velocities.  In reality, the effective area of
 the  natural draft opening is a  fraction of the area of the slots because
 of the area occupied by  the web-conveying equipment that passes through
 them.
     Table  3 indicates which PTE criteria have been satisfied by Tarkett1s
 enclosure of their rotogravure  press.  Criteria 1 and 3 are clearly
 satisfied at Tarkett.  The total area of the natural draft openings is
     2       2
 2.4  m  (26  ft ).  From our observations it appears that the enclosure has
 approximately 818 m2 (8,800 ft2) of surface area.  Therefore, the natural
 draft opening is much less than 5 percent of the total surface area of the
 enclosure,  and so Criteria 2 is satisfied.
     Theoretical face velocities through the natural draft openings into
 the  enclosure can be calculated by dividing the airflow exhausted from the
 room (1,020 m3/min [36,000 ft3/nrin])  by the total area of the natural
 draft openings (there is no forced makeup air).   The theoretical face
 velocity through the natural draft openings is 422 m/min (1,384 ft/min),
which satisfies Criteria 4.  The equivalent diameter of the slots is
 approximately 0.6 m (2 ft).  There are no emission sources (ink decks)
within 2.4 m (8 ft)  of the natural draft openings, so the fifth criterion
 is met.
                                    17

-------
                   TABLE 3.  SUMMARY OF PTE CRITERIA AT
                    TARKETT IN  WHITEHALL,  PENNSYLVANIA
                                                                 Plant  met
Criteria No.                                                     criteria


1.  All VOC emissions must be captured and contained for         Yes
      discharge through a control device

2.  Total area of NDO's is not to exceed 5 percent of total      Yes
      surface area

3.  Access doors and windows should be closed during normal      Yes
      operation

4.  The average inward face velocity across all NDO's must       Yes
      be at least 3,600 m/hr (200 ft/min)

5.  All sources of emissions within the enclosure should be      Yes
      at least 4 equivalent diameters away from each NDO
                                    18

-------
     Although the Tarkett capture data cannot be verified, they do
indicate a high level of capture efficiency.  Because the enclosure
satisfies the PTE criteria, 100 percent capture can be assumed.
     The enclosure was recently reviewed by Occupational Health and Safety
Administration (OSHA) personnel, and worker exposure was determined to be
only 40 percent of the time weighted average exposure limit.  Noise levels
were well below the 55 decibel limit, and excessive temperature or
humidity conditions have not resulted from use of the enclosure.  Worker
safety is not an issue either, because the presence of fire doors in the
enclosure actually contributes to fire protection.
5.2.2  Control Device Efficiency
     Tests on the destruction efficiency of the RE-THERM system were done
in July 1987.  The incinerator destruction efficiency averaged 98 percent
for total hydrocarbon as measured by EPA Method 25A.
5.3  MAXWELL GRAPHICS6
     Maxwell Graphics operates five rotogravure printing presses and one
proof press at its facility in Richmond, Virginia.  The plant prints the
National Enquirer and various advertising inserts on newsprint.  The
presses are multicolor units with each color being applied sequentially at
a different ink station.  Each color of ink is dried in a dryer before the
next color is applied.  The dryers draw warm ajr over the web after each
color application.  One new press is located in a large room that is
separate from the other presses.  This press is equipped with a partial
enclosure and was designed to meet lowest achievable emission reduction
requirements (Richmond is nonattainment for ozone).   Three of the other
presses have been modified to enhance local ventilation in response to
permit requirements.  Captured emissions are controlled by two carbon
adsorbers.
5.3.1  Capture Efficiency
     While the plant has not installed total enclosures, it has taken
steps to enhance capture of fugitive emissions from the press rooms.  One
press, an Albert-Frankenthal gravure press, is located in a large room
separate from the other four older presses.  Three doors lead into the
room and are equipped with automatic closing devices.  Two bay doors
accommodate the loading and unloading of trucks.  The larger bay door

                                    19

-------
leading outdoors was open during the site  visit.   The Albert-Frankenthal
press is equipped with a partial enclosure above  the applicators, and the
lower part of the press (near the applicators)  has hoods that close to
contain vapors from the application section.  The partial  enclosure above
the press draws VOC-laden air through the  hoods on the application section
of the press and" directs it to a carbon  adsorber.  The room enclosure has
no exhaust system of its own.  Air in the  room  enclosure is induced out
through the partial enclosure mounted above the press at a rate of
1,500 m3/min (53,000 ft3/min).  Approximately 1,132 m3/min
(40,000 ft3/min) of makeup air is fed into the  large room.  We were not
able to detect with a hot wire anemometer  any significant airflow (face
velocity) into the large room containing the Albert-Frankenthal press.  We
suspect this was due in part to the large  bay door's being open.
     Three of the remaining presses (all Goss presses) have been modified
to enhance the flow of air through the air spaces of the presses.  These
modifications include the installation of  rubber  curtains that drop down
to cover the gap between the paint deck  and the dryer.  The curtains
reduce the total area of the opening and increase the velocity of air
induced through the remaining spaces. Also,  these presses have air
exhaust systems designed to remove air from beneath the presses.  These
presses are installed above a concrete basin.  An induction fan at the
rewind end of the press induces airflow  through the basin beneath the
presses, thus contributing to the capture  of fugitive VOC's from the
presses.  The captured emissions are sent  to the  carbon adsorption system.
     To date, no tests have been done to determine independently the
capture efficiency of the enclosure.  However,  Maxwell Graphics performs a
metered and computerized daily mass balance of  all the inks and solvents
used during production.  This information  is used to trace the use of the
solvents and to document the amount of solvent  that is not recovered.
This is done by totaling the amount of solvent  used and subtracting the
amount of solvent recovered in the carbon  adsorbers.  Daily variations
between 83 and 115 percent solvent recovery are common.  According to the
plant,, the annual VOC recovery is approximately 94 to 95 percent of all
solvents used in the printing process. 'The relatively high overall
efficiency estimate indicates that capture efficiency is above 90 percent.
                                    20

-------
      Table  4  Indicates which PTE criteria have been satisfied  by Maxwell
 Graphics  efforts  to  enclose their Albert-Frankenthal rotogravure press.
 Criteria  1  and  3  are met  if the bay door, which was open on the day of the
 visit,  is considered a natural draft opening.  The bay door area accounts
 for approximately 2  percent of the total surface area of the room, which
 satisfies Criteria 2.  Dividing the difference between the exhaust air and
 makeup  air  rate (368 m3/min [13,000 ft3/min] by the surface area of the
 natural draft opening (13.0 m2 [140 ft  ]) indicates that the theoretical
 face velocity is  approximately 28.3 m/min (93 ft/min).  Therefore,
 Criteria  4  is not met.  Four times the  equivalent diameter of  the bay door
 is  14.2 m (46.7 ft).  The Albert-Frankenthal press is approximately 23 m
 (75 ft) away from the opened bay door;  therefore, the fifth criterion is
 met.
      The  air quality in the press room  improved significantly  with the
 addition  of the enclosure systems.  The "close capture" of solvent-laden
 air prevents the  solvent fumes from escaping into the room.  The OSHA
 recently  dropped  the personal exposure  limit for toluene to less than
 100 parts per million (ppm).  The plant said that this change  may result
 in  the need for some workers to wear masks.  However, without  the current
 enclosure system,  the standard would be even more difficult to meet.7
      The  company  has always had a training program regarding routes of
 egress and procedures in the event of a fire or explosion.  The addition
 of  the enclosures  did not result in any modifications to the safety
 program,  i.e.,  the enclosures do not present an inherent safety problem.7
 5.3.2  Control  Device Efficiency
     There are  two separate carbon adsorber systems at the plant.  Solvent
 recovery unit No.   1  has four carbon beds, each with a capacity of
 1,416 m3/min (50,000  ft3/min).  This unit is used to recover  solvent from
 two of the Goss presses and the Motter press.  These presses have a
 combined exhaust rate of 2,974 m3/min (105,000 ft3/min).  Solvent recovery
 unit No. 2 has three carbon beds each with a capacity of 1,529 m3/min
 (54,000 ft /min).   This unit recovers solvent from one Goss press, the
proof press, and the Albert-Frankenthal press.   These three presses have a
combined exhaust rate of 2,832 m3/min (100,000 ft3/min).  Solvents (mostly
toluene and  xylene) are recovered by steam injection of the beds and are
                                    21

-------
                     TABLE  4.   SUMMARY  OF  PTE  CRITERIA
            SATISFIED AT MAXWELL GRAPHICS  IN RICHMOND, VIRGINIA

                                                                 Plant met
Criteria No.                                                     criteria


1.  All VOC emissions must be captured  and contained for         Yes
      discharge through a control device

2.  Total area of NDO's is not to exceed 5 percent of total      Yes
      surface area

3.  Access doors and windows should be  closed  during normal      Yes
      operation

4.  The average inward face velocity across all NDO's must       No
      be at least 3,600 m/hr (200 ft/min)

5.  All sources of emissions within the enclosure should be      Yes
      at least 4 equivalent diameters away from each NDO
                                    22

-------
 sold to ink formulators.   Although the efficiency of the system has never
 been tested, the design efficiency of each unit is 98 percent.
 5.4  ADVANCED PRINTING TECHNOLOGY8
      Advanced Printing Technology operates two rotogravure printing
 presses at its facility in Morgantown, Pennsylvania.
      The presses are multicolor units that print wood-grained  laminates
 used for interior decor.   Each  color or design is applied  sequentially at
 a different ink station.   Each  color or application of ink is dried before
 the next color is applied.   The inks are dried with hot gases recovered
 from the regenerative thermal incinerator.  The plant, built  in 1987,  was
 designed to incorporate state-of-the-art techniques to capture  and  control
.fugitive VOC's.  Both presses are located in one large room, which  is
 designed to serve as a PTE.  Air is  exhausted from this room and sent  to a
 Smith Environmental  Corporation thermal  incinerator.
 5.4.1  Capture Efficiency  Criteria
      All  doors leading into  the enclosure remain closed and are equipped
 with automatic closing devices.   The fork!ift door and product  conveyor
 door are equipped with overlapping vinyl  strips that seal  off the
 enclosure and allow  personnel and equipment  to move in and out  of the
 press room.
      Tests were performed  in July 1989 to determine the average inward
 face velocity at  the natural draft openings.   This determination was made
 to  demonstrate compliance of the  enclosure with EPA's  proposed  PTE
 criteria.   During the  test, anemometer readings were taken at the product
 conveyor  and  forklift  doors.  The anemometer readings  at the product
 conveyor  door ranged between 102  and  132  m/min (334 and 439 ft/min) and
 averaged  113  m/min (370 ft/min)   into  the  press  room.   Likewise,
 measurements  were taken at the forklift door that  ranged between 107 and
 130  m/min  (352 and 426 ft/min) with  an average  of  119  m/min (389 ft/min)
 into  the press  room.   During our  visit, MRI  took anemometer readings that
 registered over 183  m/min (600 ft/min) at an  opening located next to the
 fork  lift door.
      Table 5  indicates whether the PTE criteria  have been  satisfied at the
Advanced Printing facility.  Advanced  Printing  is  a  new facility that  was
designed and  built to meet or exceed these enclosure criteria.   Criteria 1
and  3 are clearly met.
                                     23

-------
                   TABLE 5.  SUMMARY OF PTE CRITERIA AT
         ADVANCED PRINTING TECHNOLOGY IN MORGANTOWN, PENNSYLVANIA

                                                                 Plant met
Criteria No.                                                     criteria
                                          *
1.  All VOC emissions must be captured and contained for         Yes
      discharge through a control  device

2.  Total area of NDO's is not to  exceed 5 percent of total      Yes
      surface area

3.  Access doors and windows should be closed during normal      Yes
      operation

4.  The average inward face velocity across all  NDO's must       Yes
      be at least 3,600 m/hr (200  ft/min)

5.  All sources of emissions within the enclosure should be      Yes
      at least 4 equivalent diameters away from  each NDO
                                    24

-------
     The facility  is  equipped with  a pressure sensor  to monitor  the
 differential pressure between the enclosure and  its surroundings.  Because
 the makeup  airflow rate  is automatically contralled based  upon input  from
 the differential pressure sensor, the airflow rate is  subject to
 variations  when disturbances such as door openings or  exhaust gas  flow
 rate changes occur.   As  a result, plant personnel are  generally  not aware
 of what the changing  makeup airflow rate is at any given time.   However,
 the differential pressure controller has an adjustable control set point
 that enables maintaining a desired  and relatively constant pressure drop
 between the enclosure and its surroundings.  The control set point of
 Advanced Printing's differential pressure controller  is 0.02 inches of
 water column.  Studies performed on industrial ventilation indicate that  a
 static pressure drop  of  0.004 inches of water column  is sufficient to
 induce face velocities of 61 m/min  (200 ft/min) through natural  draft
 openings.   The differential pressure controller used by Advanced Printing
 is set to maintain a  much greater differential pressure.   Consequently,
 face velocities through  their two natural draft openings will exceed
 61 m/min (200 ft/min), thus satisfying Criteria 4.
     The total surface area of the room is approximately 6,568 m2
 (70,700 ft2).  While  it  is not possible to exactly determine the area of
 the natural draft openings, the total area must be less than 15 m2
 (161 ft2) (total area of NDO's without vinyl strips) because the
 overlapping vinyl strips block the majority of the opening.  The area is
 certainly less than the  5 percent requirement, which would be 94 m2
 (1,010 ft2) in this case.  Therefore, Criteria 2 is met.   The natural
 draft openings are approximately 30.5 m (100 ft) away  from any emission
 source at the presses.  The forklift door and product  conveyor door have  .
 an equivalent diameter of 12 and 3.7, respectively (not considering the
 placement of the vinyl strips over the door openings).  These doors are
 not within four equivalent diameters of any VOC emission source,  so
 Criteria 5 is met.
     In addition to satisfying the EPA criteria for a  PTE, the enclosure
 also easily satisfies OSHA requirements.   Plant management indicated  that
the concentration of VOC's in the enclosure is approximately 30 percent of
that allowed by OSHA.   Also,  the large enclosure allows the workers to
                                    25

-------
have easy access to the two presses with no significant restrictions to
workers in the event it becomes necessary to quickly evacuate the
enclosure.
5.4.2  Control Device Efficiency
     Also in July 1989, Advanced Printing Technology tested the
destruction efficiency of the incinerator.  The tests showed an average
destruction efficiency of 99.3 percent for VOC's entering the incinerator
as measured by EPA Method 25A.
5.5  MORRILL PRESS9
     Merrill Press operates four rotogravure printing presses in Fulton,
New York.  The plant prints paper and plastic packaging materials for the
food processing and other industries.  Two of the four presses are new,
and the two new presses are subject to prevention of significant
deterioration (PSD) regulations.  The best available control technology at
the time of permitting was 75 percent.3  In addition to the Federal PSD
regulations, these new sources must meet the applicable New York State
regulations that require an overall control efficiency of 90 percent for
each press.
     These presses are located in a large room that serves as an enclosure
to capture and collect fugitive VOC emissions from the presses.  The VOC
emissions from the two presses are reduced individually by two catalytic
incinerators.
5.5.1  Capture Efficiency
     The plant has made extensive use of local capture devices in addition
to the enclosure as a whole.  For example, each printing station is
equipped with a hood to capture solvent evaporating from the web.
Airflows through the hoods are controlled by automatic positioning dampers
that are controlled by static pressure in the hoods.  This ensures a
constant fugitive pickup (capture) by the hoods.  In addition, both
presses have flexible duct floor sweeps located at each printing station
to capture fugitive VOC emissions from beneath the ink decks.  Because the
floor sweeps are flexible, they can be placed where they will be most
effective.  To reduce fugitive VOC losses, the inks are mixed as needed
and held in 12-gallon kits, which remain covered during printing.
                                    26

-------
      There are two makeup air duct outlets that supply fresh air to the
 enclosure.  One makeup air duct outlet is located inside, the enclosure;
 the maximum airflow rate through this duct is 283 m3/min (10,000 scfm).
 This duct is generally not turned on except in the winter months, when
 additional heat is needed for worker comfort.  The other duct is located
 outside of the enclosure outlet in the cylinder storage room, because it
 created airflow problems when it was placed in the press room.  While this
 duct is always on, it is not operated at its maximum airflow rate of
 1,416 m3/min (50,000 scfm).  Plant personnel said that the fan usually
 remains on a low speed, but they could not provide any information on the
 exact volume of air delivered.  The air from the cylinder storage room
-duct outlet is delivered through the adjacent staging room and from there
 through the only natural draft opening in the enclosure, which is a 7.4 m2
 (80 ft.) open doorway between the press room and the staging room.
 Airflow measurements taken at the inlet of each catalytic incinerator
 indicate that the exhaust rate from the two presses are approximately 402
 and 463 m3/min (14,200 and 16,350 scfm), respectively.
   Y  Compliance testing was performed simultaneously on these two presses
 on May 18, 1989,  to determine the VOC capture efficiency (liquid/gas
 balance) and incinerator VOC destruction efficiency (discussed below)  on
 each line.  Total  solvent use was measured over a 3-hour period while VOC
 measurements were made at the inlet and outlet of the two catalytic
 incinerators.   During the test,  all  outside doors and the doors leading to
 the dock and cylinder storage areas were closed.  The makeup air duct in
 the cylinder storage room was delivering approximately 1,416 m3/min
 (50,000 scfm)  (maximum rated capacity),  while the makeup air duct in the
 enclosure remained  idle.   The doorway between the staging room and  the
 enclosure was  open.   Face velocity through the natural  draft opening was
 determined by  hot wire anemometer to be  about 160 m/min (525 ft/min).
      For the one  press,  the  VOC  capture  efficiency averaged  112 percent
 and the VOC  destruction  efficiency averaged  97.0 percent.  The overall  VOC
 control  efficiency was reported  as 108.6 percent,  which is the product of
 the capture  efficiency and destruction  efficiency.   The other press had  an
 average  VOC  capture  efficiency of 99.7 percent  and  a VOC destruction
 efficiency of 99.6 percent.   The  overall  VOC  control  efficiency was

                                     27

-------
 reported  as  99.3  percent.  The test  team  said that  the fact  that  the  VOC
 capture efficiency  on each press approached or exceeded  100  percent was
 apparently due  to the collection of  fugitive VOC emissions from the other
 two presses  not located within the enclosure.  Fugitive  emissions from
 these presses could be entering the  enclosure via the NDO or other leaks.
      Table 6 is a summary of the PTE criteria that  are satisfied  at
 Morrill Press.  Criteria 1 is clearly met.  Even if one  assumed that  all
 seven doors  leading into the enclosure remained open during  operation,
 they would comprise approximately 1  percent of the  total surface  area of
 the enclosure.  Therefore, Criteria  2 is met.  Because the presses were
 not operating at  the time of our visit, we were not able to-  observe the
 normal  operation  of the capture and  control system.  Plant personnel  did
 indicate  that all doorways remained  closed in the press  room except one
 doorway leading into the staging room, which would  satisfy Criteria 3 (the
 staging room door is considered a natural draft opening).  Recent test
 data have documented that inward face velocities have approached  160  m/min
.(525 ft/min) at the natural draft opening.  Also, the difference  between
 the amount of air exhausted to the two incinerators and the  maximum amount
 of  air  returning  through the makeup  air duct 1n the enclosure is
 708 m3/min (25,000  scfm).  Dividing  708 m3/min (25,000 scfm)  by the area
 of  the  natural  draft opening (7.4 m2 [80 ft2]) yields an inward face
 velocity  of  95  m/min (312 ft/min), thus satisfying  Criteria  4. .The
 doorway that serves as a natural draft opening is approximately 24.4  m
 (80 feet) away  from the nearest ink  station along the presses.  The
 natural draft opening is 7.4 m2 (80 ft2), with an equivalent diameter of
 2.7 m (8.9 ft).   Therefore, Criteria 5 is satisfied.
      Although the test program data probably represent an overestimation
 of  capture efficiency, a high level of capture efficiency is indicated.
 Because the  enclosure satisfies the PTE criteria, 100 percent capture
 efficiency can  be assumed.  In addition to satisfying EPA criteria plant
 personnel indicated  that VOC exposure levels are less than 50 percent of
 the level that  would trigger worker protection requirements  by OSHA.
                                     28

-------
                   TABLE 6.  SUMMARY OF PTE CRITERIA AT
                    MORRILL PRESS IN FULTON, NEW YORK
                                                                 Plant met
Criteria No.                                                     criteria


1.  All VOC emissions must be captured and contained for         Yes
      discharge through a control device

2.  Total area of NDO's is not to exceed 5 percent of total      Yes
      surface area

3.  Access doors and windows, should be closed during normal      Yes
      operation

4.  The average inward face velocity across all NDO's must       Yesa
      be at least 3,600 m/hr (200 ft/min)

5.  All sources of emissions within the enclosure should be      Yes
      at least 4 equivalent diameters away from each NDO

aNo measurements were made during our visit because the plant was not
 operating.  An emissions test dated May 18, 1989, contains measurements
 taken at an open doorway in the northwest corner of the storage area.
 The face velocity through this openings was determined using a hot wire
 anemometer to be approximately 160 m/min (525 ft/min).  Theoretical
 calculations suggest that the minimum face velocity through the NDO to be
 95 m/min (312 ft/min).
                                    29

-------
 5.5.2  Control  Device Efficiency
      The two TEC System HXC catalytic  incinerators  were installed in
 1988.  The incinerators are 3-chamber  catalytic  units  designed to treat
 142 to 566 m3/ntin (5,000 to 20,000  scfm)  of  air  each.   Typically these
 systems will  destroy  95 percent  of  the inlet VOC and are guaranteed to
 achieve 90 percent  destruction.   The system  is sized to handle the maximum
 exhaust gas from each press with all stations in service,  or  566 m3/min
 (20,000 scfm).   If  the exhaust rate from  the press  drops below 142 m3/min
 (5,000 scfm), incinerator exhaust is recirculated to the inlet to maintain
 the required minimum  airflow and bed temperatures.  The TEC Systems HXC
 unit is equipped with a variety  of  automatic controls  permitting a self-
 sustaining catalytic  oxidation (no  auxiliary fuel)  if  sufficient VOC is
 present in the  inlet  gas.
      As stated  above,  control device efficiency  on  the two incinerators
 was determined  to. be  97.0  percent and  99.6 percent, respectively.
'5.6  AMKO  PLASTICS10
      Amko  Plastics  extrudes  polyethylene  film, prints  it,  and  converts the
 printed film into finished  bags  and wraps.   The  facility employs
 11  flexographic  presses.   Until  1984,  Amko Plastics printed using  solvent-
 based (alcohol-based)  inks.   In  1984 the  facility applied  for  permits  to
 install  three new printing presses.  The  State EPA Office  informed Amko it
 would have  to comply with  BACT guidelines.   Amko  then  decided  to convert
 to  water-based  inks.   The  early  days of this  conversion  resulted in some
 equipment-related problems.  Amko made several modifications to  their
 presses  and added new  systems that have eliminated most  of the early
 problems.   They  redesigned air blowers, plenums,  and dryer hoods on all  of
 their presses to enhance the drying characteristics of  the water-based
.inks.   Changes also had to be made to the anilox  and fountain  rollers  and
 to  the printing  plate  (refer to Appendix A and to the Amko trip  report for
 details).  Amko's newest press,  installed in  December  1987, was
 specifically designed  to run water-based  inks exclusively  at press speeds
 of  up  to 297 m/min  (975 ft/min).
                                    30

-------
      The  use  of water-based  inks  has  eliminated  the  need  for  total
 enclosures  around  the  presses  and emission  control equipment  to  destroy  or
 collect the fugitive VOC's emitted from  solvent-based  inks.   The most
 notable contrast between Amko's water-based printing operation and  other
 solvent-based printing operations is  the lack of any noticeable  solvent
 odors in  the  press room.  Even when standing in  the  direct vicinity of an
 operating press, no solvent  odors were noticeable.
      Although MRI  was  not able to determine the  exact  emission reduction
 achieved  by Amko's conversion  to  water-based inks, estimates  indicate that
 the reduction is significant.  In 1983,  before the conversion occurred,
 VOC emissions were estimated to exceed 81.7 Mg/yr (90  tons/yr).   In 1989,
 with  more production volume, emissions were estimated  at  approximately
 27.2  Mg/yr  (30 tons/yr).
      A paper  presented at an Air  Pollution  Control Association (APCA)
 meeting by  Mr. Makrauer, President/CEO of Amko,  Inc. (Appendix A),
 describes in  detail the efforts,  difficulties, and successes  of  Amko
 Plastics, Inc., in converting  their flexographic printing operations from
 solvent-based inks  to  water-based  inks for  printing  on low density
 polyethylene  film.  In Mr. Makrauer1s presentation to APCA, and  during the
 site  visit, he discussed the following benefits  that are associated with
 the use of water-based inks:
      1.  Water-based inks are  not classified as  a combustible material,  so
 containers of water-based inks are  not required  to be stored  in  expensive,
 explosion-protected storage rooms.  As a result, water-based  inks may be
 stored conveniently close to the printing presses themselves.
     2.  The Resource  Conservation  and Recovery Act requires  special
 conditions to be maintained for outdoor  solvent  storage tanks, installed
 either above ground or underground.  Special liability coverage  is
 required to protect against environmental contamination damage resulting
from tank leakage.   Insurance premiums for one underground solvent storage
tank were $15,000 per year.   Since Amko purchases only small  amounts of
solvent, it has  chosen to do so in 55 gallon drums.   By emptying and
sealing their underground tank, Amko saves $15,000 each year on this
insurance premium.
                                    31

-------
     3.  Water evaporates more slowly than solvent; therefore, viscosity
changes due to evaporation take place more slowly in water-based inks than
1n solvent-based inks.  With smaller viscosity fluctuations, it is easier
to hold consistent color throughout a press run of water-based ink.
     4.  Water-based inks have greater coverage yield than solvent-based
inks.  Although the cost per pound of some water-based inks is higher than
solvent-based inks, the cost margin is generally less than the increased
yield and a net ink cost advantage exists; and
     5.  A most notable benefit Amko experienced was the improvement of
working conditions in the press room.  The drastic reduction in the
solvent content of inks has significantly reduced solvent vapors,
resulting in a noticeable improvement in the quality of ambient press room
air.
     Even though Amko has succeeded in converting to water-based inks,
some difficulties still exist.  Some customers refuse to accept bags
printed with water-based inks because they may not have the same gloss
level as bags printed with solvent-based inks.  Amko can generally achieve
the same levels of gloss with water-based inks, but some colors
occasionally have lower gloss when using standard pigments.  In those
circumstances, to improve the gloss, Amko uses chip dispersion pigment
systems.  These pigments cost more than standard pigments.
     The plant's biggest waste problem is associated with the wastewater
and sludge generated during the cleanup of the presses.  Amko spends
approximately $60,000 per year to dispose of this material.  However, Amko
has ordered a dewatering device costing about $40,000 that will dewater
the sludge and treat the effluent water to standards acceptable for
discharge into the city sewer system.  The payback on this equipment is
estimated to be 1.5 years.
5.7  CMS GILBRETH PACKAGING SYSTEMS11
     CMS Gilbreth Packaging Systems operates two plants, one in Croydon,
Pennsylvania, and one in Bensalem, Pennsylvania.  The plants are known as
the Bristol and Bensalem plants, respectively.  Both plants print flexible
packaging on heat-shrinkable polyvinylchlorfde (PVC) film, e.g., battery
covers and candy wrappers.  The Bristol plant operates one eight-station
rotogravure press.  The Bensalem plant operates 4 rotogravure presses and
one flexographic press.
                                    32

-------
      The  Bristol  plant  is  currently  operating  at its  permitted  VOC
 emission  limit.   The  plant's  owners  are  not  allowed to  increase press
 speed,  add  shifts,  or install  additional  presses without  first  reducing
 the  VOC emission  rate.   On the advice  of  a consultant,  Richmond Tech-Air
 Corp.,  the  plant  instituted a program  to  install the  necessary  capture and
 control system to reduce VOC  emissions.   A similar system was aVso
 designed  for the  Bensalem  plant, which is also subject  to LAER
 requirements.12   Neither system was  fully operational at  the time of the
 site visit.
 5.7.1  Capture Efficiency—Bristol Plant
      The  capture  system  at the Bristol plant was designed to meet EPA's
 PTE  criteria.  Because the capture system was  not operational at the time
 of the  visit, it  is not  possible to  document whether  the  enclosure meets
 the  PTE criteria.  Therefore,  the discussion in this  report will focus on
 efforts taken by  the  plant to  incorporate air  management  techniques to
 minimize  the size of  airflow  to be controlled.   Limiting  airflow reduces
 the  requisite size of the  control device  and its operating costs.
 However,  the desire to limit  airflow must be balanced against the need to
 maintain  reasonable working conditions within  the enclosure.  Humidity
 levels, temperature,  solvent  fumes,  and the  effects of machinery on
 airflow patterns must all  be  considered.12
      One  technique to reduce the size  of  airflows is  to maintain a
 quiescent environment in the press room particularly  around the  printing
 stations.  This condition  allows the heavier than air solvent vapors to be
 readily picked up by  the ink tray exhausts and  floor  sweeps without being
 scattered by air currents  in the room.  The  ink  tray pickup device, which
 is a  rectangular box  mounted slightly  below  the  ink fountain, was designed
with  this condition in mind.  Air is drawn through two slots in  the pickup
device in an attempt  to ensure that airflow  velocities across the length
of the exhaust are uniform.  However, measurements made by plant personnel
show that the air velocity across the face of the device differs by
approximately 366 m/min (1,200 ft/min) from one  end to the other.  Plant
personnel  are currently considering ways to equalize the air velocity
across the pickup devices.
                                    33

-------
     The press room also contains electrical boxes that are pressurized
with purge air that is drawn from inside the press room.  EJecause the
electrical boxes are not airtight, leaking air can be swept up under the
press and create air currents across the print stations.  These air
currents then sweep solvent vapors from around the print stations and
contribute to an increase in ambient press room VOC levels and a decrease
in the VOC capture efficiency of the system.  To solve this problem, the
plant has installed a lightweight panel wall between the print stations
and the pressurized electrical boxes to shield the print stations from the
purge air.
     The plant also plans to recirculate 425 m3/min (15,000 ft3/min) of
dryer exhaust in the press room rather than sending the full 623 m3/min
(22,000 ft3/min) directly to the control device.  However, when the
recirculation system was placed in service for testing, the result was a
significant increase in the VOC concentration of the press room air.  This
increase proved to be due to the many leaks that existed in the ductwork
that carried the recirculating exhaust under positive pressure.  Since
then, the "cracks" have been caulked to prevent VOC's from leaking into
the press room from the ductwork.  Unfortunately, at the time of the site
visit, the recirculation system was not being operated.
     The capture system design also incorporates the idea of close capture
in the placement of fugitive pickups.  The system consists of an ink tray
pickup device that is suspended slightly below the ink tray and a floor
sweep positioned at each of the eight print stations for close capture of
fugitive VOC's emitted from the press.  At each print station, 2.8 m3/min
(100 ft3/min) of air is drawn through the ink tray pickup device and
26 m3/min (900 ft3/min) of air is drawn through the floor sweep.  The
total fugitive exhaust pickup is therefore 227 m3/min (8,000 ft3/min) of
air.
     The makeup air system is controlled by a.differential pressure
controller that is set to deliver 57 m3/min (2,000 ft3/min) less air to
the enclosure than what is taken out through the exhaust.  The controller
is designed to be used in the differential pressure range of 0.01 to
0.2 inches of water column.  Because EPA accepts a differential pressure
of 0.004 inches of water column as sufficient to induce a 61 m/min
                                    34

-------
 (200  ft/min)  velocity across  a natural  draft  opening,  the  CMS  Gilbreth
 system should satisfy EPA's PTE Criteria 4.
      The  fugitive  VOC capture system has had  a  major effect  on ambient  VOC
 levels in the press  room.  Before  the system  was  installed,  ambient  VOC
 levels in the press  room averaged  around 300  ppm  as  hexane.  After
 installation  of  the  capture system,  ambient VOC levels dropped to about
 30  ppm.   Subsequent  installation of  the dryer exhaust  recirculation  system
 has probably  resulted in a further decrease in  press room  ambient VOC
 concentrations.  In  a recent  conversation, Mr.  Nash  said that  the facility
 can now operate  the  enclosure with the  doors  closed, run the air
 conditioner or heating system (as  required),  and  still  meet  the OSHA
 standard.1
 5.7.2 Control Device Efficiency—Bristol Plant
      At the time of  the site  visit,  the plant was  completing construction
 on  the regenerative  thermal oxidizer that will  control  solvent vapors sent
 from  the  capture system.  The thermal oxidizer  has three beds  packed with
 ceramic beryl  saddles.   Combustion is a cyclical operation that uses
 valves to alter  the  airflow to regenerate the heat stored  in the beryl
 saddles.  Once online,  the thermal oxidizer,  which is  rated  for 482  m3/min
 (17,000 ft /min), will  receive exhaust  gases  from  both  the press room and
 the ink room.
 5.7.3  Capture Efficiency—Bensalem  Plant
      The  five presses  at the  Bensalem plant are contained  in two rooms,
 which  are connected  by  a 2.4  m by  3.7 m (8 ft x 12 ft)  overhead door that
 remains open.  The flow of exhaust air  and forced  makeup air was designed
 so that the two  print rooms connected by the  door  serve as a single
 enclosure.  The  enclosure is  designed to remove approximately  567 m3/min
 (20,000 ft3/min)  of  room air  and to  return 510 m3/min  (18,000  ft3/min)  of
makeup air.  A differential pressure controller identical to the one used
 at the Bristol plant  is used  to control the makeup air  rate.   This
differential  pressure controller also has a range  of 0.01 to 0.2 inches of
water column.
                                    35

-------
     One of the presses, the TECMO press, employs the same fugitive VOC
control equipment as that used at the Bristol plant.  However,  during the
site visit, the ink tray exhaust hoods were disconnected from the ink
trays and were lying on the floor.  Apparently, Bensalem plant personnel
believe that the wet printed substrate is the source of evaporative losses
rather than the ink trays.  Mr. Nash, the plant engineer, said that
another problem is that the press operators have become so insensitive to
the solvent odor that even major changes in the VOC concentration in the
room are not detectable by them during the normal work week.   Mr. Nash
said that unless and until the workplace is essentially odor  free for a
matter of weeks, the employees may not develop the incentive  to improve
operating practices.  In contrast, at the Bristol facility, where the
capture system (particularly the ink tray pickup devices) is  utilized, the
press operators quickly notice increases in solvent concentrations because
they have become accustomed to the lower odor levels.
     The plant is working to resolve air management problems  related to
their relatively complicated exhaust system, and the system is not
considered fully operational.  Therefore, it was not possible to evaluate
whether the system can be judged to meet the total enclosure  criteria.
Certainly, there was a very strong solvent odor in the room.   Recent
liquid-gas mass balance capture tests performed by the State  concluded
that only 48 percent of the solvent'vapors were being captured by the
enclosure.  Plant personnel indicated a lack of confidence in the test
methodology, and the system is to be retested.
     When it is operational, the enclosure should be capable  of meeting
EPA's PTE criteria.  If the enclosure operates as designed, with all doors
closed, there should be no natural draft openings except for unsealed
cracks around doorways.  Although the set point of the differential
pressure controller is not known, the range in which it operates (0.01 to
0.2 inches of water column) exceeds the differential pressure of
0.004 inches of water necessary to maintain inward face velocities of
61 m/min (200 ft/min).
                                    36

-------
 5.7.4  Control Device Efficiency—Bensalem Plant
      Approximately 553 m3/nrin (19,500 ft3/nrin)  Of air is sent to the
 thermal oxidizer, which has a capacity to handle 623 m3/niin
 (22,000 ft /min).  The thermal oxidizer has three beds packed with ceramic
 beryl saddles and is operated using regenerative heat recovery.   When
 operational,  all  air exhausted from the enclosure and from the ink room is
 to be sent to the thermal  oxidizer.  No control  efficiency test  data are
 available.
 6.0  DISCUSSION
 6.1  OVERALL  CONTROL SUMMARY
      A summary of MRI's evaluation of the PTE criteria for the eight
 plants visited is presented in Table.7.  One of  the plants elected to
 reduce VOC emissions by converting to water-based coatings.   Therefore,
 the PTE criteria  are not applicable.
      Four  of  the  plants have enclosures that clearly satisfy each of the
 five criteria and may be deemed as "PTE's."  One plant failed to meet
 Criteria 4 (i.e., maintaining at least a 3,600 m/hr [200 ft/min] face
 velocity across all  NDO's)  and, therefore,  cannot be considered  a PTE.
 Two of the plants have not  completed  installation of their enclosure
 systems, and  their status as PTE's cannot be determined.   However,  based
 on the design and operating data presented  during the site visit,  it
 appears that  once the enclosures are  fully  operational  that  they will meet
 the PTE criteria.
      Table 8  presents a summary of EPA's  evaluation of capture efficiency
 at each of the  plants visited.   The four  plants  that have  PTE's  have been
 assumed by EPA  to have  a capture efficiency of 100  percent.   Although one
 plant  met  four  of five  PTE  criteria,  it is  not possible  to predict  the
 capture efficiency of this  enclosure  in the absence of capture efficiency
 test data.  As  can be seen  in  Table 8,  capture efficiencies  are
 unavailable at  this  time for  the  remaining  plants as  well.
     To control the  exhaust gases  coming  from the enclosures,  four  of the
 plants  use  (or plan  to use) thermal oxidizers, two  of the  plants use
catalytic  incinerators, and one  plant uses  a carbon  adsorber  (see
Table  1).  The control efficiencies of  each of these  devices  as  they are
operated in the plants visited can  be found in Table 8.  The  EPA has

                                    37

-------
              TABLE  7.   SUMMARY OF  RESULTS OF  EXAMINATION  FOR
                    PTE  CRITERIA AT ALL  PLANTS VISITED
Plant
                                          Satisfied enclosure criteria
Package Products
  Charlotte, NC

Tarkett
  Whitehall, PA

Maxwell Graphics
  Richmond, VA

Advanced Printing Technology
  Morgantown, PA

Morrill Press
  Fulton, NY

CMS Gilbreth-Bristol,
  Croydon, PAr

CMS Gilbreth-Bensalem,
  Bensalem, PAf
Amko Plastics
  Cincinnati,
Yes     Yes     Yes     Yes     Yes
Yes     Yes     Yes     Yes     Yes
Yes     Yes     Yes
No
Yes     Yes     Yes     Yes
Yes
        Yes
Yes     Yes     Yes     Yes     Yes
aAll VOC emissions must be captured and contained for discharge through a
.control device.
DTotal area of NDO's is not to exceed 5 percent of total surface area.
^Access doors and windows should be closed during normal operation.
dThe average inward face velocity across all  NDO's must be at least
 3,600 m/hr (200 ft/min).
eAll sources of emissions within the enclosure should be at least
 4 equivalent diameters away from each NDO.
'These plants' exhaust systems were designed  around the PTE concept, but
 one was not yet complete and the other shut  down before the
 examination could be completed during our visits.
     Amko plant uses waterborne inks so these criteria are not applicable.
                                    38

-------
             TABLE  8.   SUMMARY  OF  OVERALL  CONTROL EFFICIENCIES


Plant
Package Products
Charlotte, NC
Tarkett
Whitehall, PA
Maxwell Graphics
Richmond, VA
Advanced Printing Technology
Morgantown, PA
Merrill Press
Fulton, NY
Amko Plastics


Capture
efficiency
PTE (100)
PTE (100)
-
PTE (100)
PTE (100)



Destruction/
removal
efficiency
99.5
98.0
-
99.3
97.0

Overall
control
efficiency
for compli-
ance purposes
99.5
98.0
94a
99.3
97.0
66. 7b
  Cincinnati, OH

CMS Gilbreth-Bristol
  Croydon, PAC

CMS Gilbreth-Bensalem
  Bensalem, PAC
aOverall control efficiency obtained from material balances performed from
 records kept on solvent used and solvent recovered in carbon adsorption
.system.
 Based on emission reductions reported by Amko from 1983 to 1989.  The
 calculated reduction does not include a correction for the increased
 production that occurred over the 6-year period.  If this could be done,
 Amko's emission reduction would be larger than presented on the table.
 These plants'  exhaust systems were designed around the PTE concept, but
 one was not yet complete and the other shut down before the examination
 could be completed during our visits.
                                    39

-------
extensive data that confirm that these control devices are capable of
achieving very high efficiencies.  These control devices are capable of
routinely achieving efficiencies of 95 percent or greater.  In fact, the -
control efficiencies documented from our visits ranged from 97 to
99.5 percent.  Overall control efficiencies ranged from 94 to 99.5 percent
for those facilities using add-on controls.
     The information gathered in the course of this study leads to the
conclusion that capture and control systems have been demonstrated to be
effective and reliable in controlling greater than 90 percent of the VOC
emissions from graphic arts facilities.  This level of control is not
limited to new facilities.  Only one of the facilities visited during this
study was a totally new facility.  The other facilities, including the
facility using water-based inks had all been retrofitted with the
technology to reduce VOC emissions.  In addition, recent information
reported to EPA indicates that other facilities have adopted capture and
control systems that achieve greater than 90 percent VOC emission
reductions.
     The information contained in this report serves to demonstrate that
VOC control efficiencies of 90 percent and greater are obtainable and
previously accepted VOC emission reductions of 65 percent may no longer
serve as a practical upper bound for control of these sources.  States
should.be cognizant of the demonstrated control efficiencies obtained in
these and other graphic arts facilities and apply this information in
future BACT/LAER and RACT determinations.
6.2  WATER-BASED INKS
     The use of water-based inks as an alternative to reducing VOC
emissions in flexible packaging printing operations has been demonstrated
by Amko Plastics in Cincinnati, Ohio.  Some of the advantages to water-
based inks include:
     1.  Water-based inks are noncombustible and are not subject to
special storage requirements;
     2.  Water evaporates more slowly than solvent, resulting in less
fluctuation of the ink viscosity during printing that affects product
quality; and
                                    40

-------
     3.  Ambient press room  air  is  virtually free of solvent vapors.
The conversion from  solvent-based inks to water-based inks requires that
presses be  altered and dryers redesigned to accommodate the greater drying
capacity needed to dry water-based  inks.  Appropriate pigment systems have
to be developed, which requires  close coordination between pigment and
coating manufacturers as well as buyer awareness programs.  In addition,
the polyethylene film must be custom blended for use with water-based
inks.  The  EPA should consider whether further VOC reductions are possible
if consumers'can be  educated about  the environmental and worker health and
safety benefits of conversion to water-based coatings.
6.3  OTHER  TOTAL ENCLOSURE CONSIDERATIONS
6.3.1  Differential  Pressure Controllers
     Some plants are equipped with  differential pressure sensors/
controllers that activate a  variable speed forced makeup air fan to adjust
the amount  of forced makeup  air that is being sent to the enclosure.
Usually, the differential pressure  controllers are set to maintain a
specified pressure drop between the inside of the enclosure and the
ambient air outside  of it.   Door openings and disturbances within the
enclosure affect the pressure in the enclosure, which may result in a
change in the forced makeup  air rate.  Since the design of the
automatically controlled system means that knowledge of actual average
airflow rates is unnecessary and is difficult to determine, plant
personnel are generally not able to provide information on the average
airflow rate of the  makeup air fan.  The alternative, using maximum design
values for the makeup air fan, can  overestimate actual face velocities
through NDO's.  Consequently, it is difficult to calculate whether the
enclosure satisfies  the average face velocity requirement of Criteria 4.
     An alternate means of complying with Criteria 4 is to establish a
minimum static pressure drop across the NDO of about 1.0 Pa (0.004 in.
water).  This pressure drop results in inward face velocities of least
3,600 m/hr  (200 ft/min).  Therefore, maintaining a minimum acceptable
differential pressure across the NDO's will ensure reasonable compliance
with the 3,600 m/hr  (200 ft/min) face velocity requirements regardless of
the changing NDO areas caused by the opening of doors and other
disturbances.
                                    41

-------
     The EPA personnel involved in inspecting or permitting facilities
that use differential pressure controllers should confirm two pieces of
Information, however.  First, if the controller controls supply air only,
it is possible that a low exhaust flow rate could result in the controller
switching off the supply fan.  In this case, there is no assurance that an
adequate pressure drop will be maintained.  It should also be noted that
the differential pressure readings must be taken across the NDO's and not
necessarily with respect to atmospheric pressure (unless the NDO leads
directly to the outside).  Enclosures with exhaust fans may effectively
reduce the pressure of an entire facility relative to atmospheric
pressure, making it necessary to measure static pressure differences
across NDO's that open to other areas of a plant.
6.3.2  Worker Exposure and Safety Considerations
     Attaining a high level of capture efficiency is only one of the
design criteria that facilities consider when they design or retrofit
total enclosures.  Issues of worker exposure to concentrated solvent
vapors and the ability of workers to .quickly exit from the enclosure in
the event of a sudden hazard must be addressed, just as they were in the
design of the initial plant.  Personnel at several facilities which have
total enclosures confirmed that worker exposure is'not a problem at their
facilities; they report that solvent levels in their enclosures are
approximately 30 to 50 percent of those allowed by OSHA and at least one
plant is reported to have altogether eliminated the characteristic solvent
odor so ubiquitous to printing facilities.  Worker exit requirements were
also specifically addressed in our discussion with plant personnel.  None
of the facilities believed that the enclosures had increased safety
problems in any respect.
7.0  REFERENCES
 1. The Printing Ink Handbook, National Association of Printing Ink
     Manufacturers, Inc., Harrison 1988.  pp. 39-47.
 2. Memorandum.  Vaught, C., MRI, to Catlett, K., EPA:CPB.  Trip Report:
     Package Products Company in Charlotte, North Carolina, on November 30,
   - 1989.
                                    42

-------
 3. Telecon.  Shine, B., MRI, with Warlick, T., Engraph.  June 26, 1989.
     Discussion about control levels and technologies at Engraph
     facilities.

 4. Memorandum.  Vaught, C., MRI, to Catlett, K., EPArCPB.  Trip Report:
     Tarkett, Inc. in Whitehall, Pennsylvania, on December 6, 1989.

 5. Telecon.  Friedman, B., MRI, with Switzer, W., Tarkett, Inc.
     December 18, 1990.  Discussion about total enclosure.

 6. Memorandum.  Vaught, C., MRI, to Catlett, K., EPA:CPB.  Trip Report:
     Maxwell Graphics in Richmond, Virginia, on January 16, 1990.

 7. Telecon.  Friedman, B., MRI, with Kontny, D., Maxwell Graphics.
     December 17, 1990.  Discussion about enclosures.

 8. Memorandum.  Vaught, C., MRI, to Catlett, K., EPA:CPB.  Trip Report:
     Advanced Printing Technology in Morgantown, Pennsylvania, on
     December 5, 1989.

 9. Memorandum.  Vaught, C., MRI, to Catlett, K., EPA:CPB.  Trip Report:
     Merrill Press in Fulton, New York, on April 6, 1990.

10. Memorandum.  Vaught, C., MRI, to Catlett, K., EPA:CPB.  Trip Report:
    Amko Plastics, Inc., in Cincinnati, Ohio, on January 18, 1990.

11. Memorandum.  Vaught, C., MRI, to Catlett, K., EPA:CPB.  Trip Report:
    CMS Gilbreth Packaging Systems in Croydon and Bensalem, Pennsylvania,
    on July 19, 1990.

12. Telecon.  Friedman, B., MRI, with Nash, J., CMS Gilbreth Packaging
    Systems.  December 17, 1990.  Discussion about enclosures.


b3101-l/ESD
                                    43

-------

-------
TECHNICAL REPORT DATA
(Please read instructions on the reverse before completing)
1. REPORT NO.
EPA, 450/3-91-008
*•
4. TITLE AND SUBTITLE
Best Demonstrated Control
Technology for Graphic Arts
7. AUTHOR(S)
Friedman, Vaught

9. PERFORMING ORGANIZATION NAME AND ADDRESS
Midwest Research Institute
401 Harrison Oaks Boulevard, Suite 350
Gary, North Carolina 27513
12. SPONSORING AGENCY NAME AND ADO
U.S. Environmental Protecti
Emission Standards Division
Office -of Air Quality Planr
Research Triangle Park, NC
RESS
.on Agency (MD-13)
L
ling and Standards
27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
Fehrnarv 1991
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-4379
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES 	 ~ 	
ESD Work Assignment Manager: Karen Catlett (MD-13) (919) 541-0835
     The Graphic Arts Industry is a source of volatile organic  compound  (VOC)
emissions.  This study was conducted to document the reported overall  control
efficiency for VOC at a number of rotogravure and flexographic  printing  facilities.

     The primary conclusions form this study are:   (1) the use  of capture and control
systems and the use of water-based ink systems have been demonstrated  to be effective
and reliable in achieving greater than 90 percent overall VOC reduction rotogravure
and flexogrpahic printing facilities; (2) facilities can be retrofitted to achieve
 90 percent VOC reductions; and (3) permanent total enclosures meeting EPA criteria
have been successfully installed and operated at rotogravure and flexographic
printing facilities.           '  . -
17- KEY WORDS AND DOCUMENT ANALYSIS
»• DESCRIPTORS
Graphic Arts
Rotogravure Priniting
Flexographic Printing
Volatile Organic Compounds Emissions
VOCs ...
Permanent Total Enclousres
18. DISTRIBUTION STATEMENT
Release Unlimited
b.lDENTIFIERS/OPEN ENDED TERMS

19. SECURITY CLASS (This Report 1
20. SECURITY CLASS (This page)
c. COSATI Field/Group

21. NO. OF PAGES
22. PRICE
                   PREVIOUS EDITION IS OBSOLETE

-------