r
S, EPA
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA^53/R-96-005b
May 1996
Air
NATIONAL EMISSION STANDARDS
FOR HAZARDOUS AIR
POLLUTANTS (NESHAP) FOR THE
PRINTING AND PUBLISHING
INDUSTRY - BACKGROUND
INFORMATION FOR
PROMULGATED STANDARDS
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EPA-453/R-96-005b
National Emission Standards For Hazardous Air Pollutants
(NESHAP) for the Printing and Publishing Industry -
Background Information for Promulgated Standards
Emission Standards Division
R A^^ncnlal Premier, ^^
7?i;^;;;;^^^-ion ~-n^
c'"lc*&, ^'&04-' 12[ '• Floor
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
May 1996
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This report has been reviewed by the Emission Standards Division
of the Office of Air Quality Planning and Standards, 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. Copies of this
report are available through the Library Services Offices
(MD-35), U.S. Environmental Protection Agency, Research Triangle
Park, N.C. 27711, or from National Technical Information
Services, 5285 Port Royal Road, Springfield, Virginia 22161.
11
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U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA)
Background Information
and Final
Environmental Impact Statement
for Hazardous Air Pollutant Emissions
From the Printing and Publishing Industry
Prepared by:
~>?i'L->~i .
"^^•'uce C. Jordan (Date)
Director, Emission Standards Division
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
1. The promulgated standards of performance would reduce
hazardous air pollutants (HAP) emissions from existing and
new rotogravure and wide-web flexographic printing
facilities that are major sources of HAP emissions. Under
Section 112 of the Clean Air Act (CAA), as amended in 1990,
the EPA is authorized to require the maximum degree of
reduction in emissions of hazardous air pollutants that is
achievable, taking into consideration the cost of achieving
such emission reductions, and any nonair quality health and
environmental impacts and energy requirements.
2. Copies of this document have been sent to the following
Federal Departments: Labor, Health and Human Services,
Defense, Transportation, Agriculture, Commerce, Interior,
and Energy; the National Science Foundation; the Council on
Environmental Quality; members of the State and Territorial
Air Pollution Program Administrators; the Association of
Local Air Pollution Control Offices; EPA Regional
Administrators; and other interested parties.
3. For additional information contact:
Mr. David Salman
Coatings and Consumer Products Group (MD-13)
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Telephone: (919) 541-0859
4. Paper copies of this document may be obtained from:
National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
Telephone: (703) 487-4650
U.S. EPA Library Services Office (MD-35)
U.S. Environmental Protection Agency
Research Triangle Park, N.C. 277111
Telephone: (919) 541-2777
iii
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5. Electronic copies of this document may be obtained from the
EPA Technology Transfer Network (TTN). The TTN is an
electronic bulletin board system which is free, except for
the normal long distance charges. To access the printing
and publishing BID:
Set software to data bits: 8, N; stop bits: 1
Use access number (919) 541-5742 for 1200, 2400, or
9600 bps modems [access problems should be directed to
the system operator at (919) 541-5384].
Specify TTN Bulletin Board: Clean Air Act Amendments
Select menu item: Recently Signed Rules
IV
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TABLE OF CONTENTS
1. SUMMARY 1-1
1.1 SUMMARY OF CHANGES MADE SINCE PROPOSAL 1-1
1.1.1 Incidental Printing and Ancillary Printing Equipment 1-1
1.1.2 Research and Laboratory Equipment 1-2
1.1.3 Addition of Presses to Existing Affected Sources . . 1-2
1.1.4 Affected Source for Product and Packaging Rotogravure
and Wide-web Flexographic Printing Facilities . . . 1-3
1.1.5 Organic HAP Analysis Methods 1-3
1.1.6 Volatile Matter Analysis Methods 1-3
1.1.7 Compliance Monitoring for Catalytic Oxidizers . . . 1-4
1.1.8 Additional Compliance Options for Product and
Packaging Rotogravure and Wide-web Flexographic
Printing Affected Sources 1-4
1.1.9 Capture Efficiency Protocols and Test Methods . . . 1-4
1.1.10 Transition from Area Source to Major Source Status . 1-5
1.1.11 Definition of "Month" 1-5
1.1.12 Alternatives to Vent Stream Flow Rate Monitoring . . 1-5
1.1.13 Extension of Deadline for Initial Notification . . . 1-5
1.1.14 Provisions for Optional Inclusion of Stand-alone
Coating Equipment 1-6
2. SUMMARY OF PUBLIC COMMENTS 2-1
2.1 SYNTHETIC AREA SOURCE MECHANISM 2-9
2.2 DEFINITION OF MAJOR SOURCE 2-12
2.3 TRANSITION FROM AREA SOURCE TO MAJOR SOURCE .... 2-13
2.4 ONCE IN/ALWAYS IN 2-14
2.5 RESEARCH AND LABORATORY OPERATIONS 2-15
2.6 NEW SOURCE MACT 2-16
2.7 AFFECTED SOURCE AT PUBLICATION FACILITIES 2-17
2.8 AFFECTED SOURCE AT PRODUCT AND PACKAGING ROTOGRAVURE
AND WIDE-WEB FLEXOGRAPHIC PRINTING 2-17
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2,9 DEFINITIONS 2-21
2.10 REPORTING 2-24
2.11 LEVEL OF CONTROL FOR PRODUCT AND PACKAGING
ROTOGRAVURE AND WIDE-WEB FLEXOGRAPHIC PRINTING
AFFECTED SOURCES 2-28
2.12 LEVEL OF CONTROL FOR PUBLICATION ROTOGRAVURE AFFECTED
SOURCES 2-31
2.13 STANDARDS FOR PRODUCT AND PACKAGING ROTOGRAVURE AND WIDE-
WEB FLEXOGRAPHIC PRINTING AFFECTED SOURCES 2-32
2.14 COMPLIANCE FOR PUBLICATION ROTOGRAVURE AFFECTED
SOURCES 2-33
2.15 MONITORING 2-34
2.16 COMPLIANCE DATES FOR NEW SOURCES 2-40
2.17 COMPLIANCE DATES-GENERAL ISSUES 2-42
2.18 HAP CONTENT DETERMINATION 2-43
2.19 METHOD 24/24A ._ 2-46
2.20 OXIDIZER TERMINOLOGY 2-47
2.21 COMPLIANCE DEMONSTRATION-GENERAL ISSUES 2-47
2.22 COMPLIANCE DEMONSTRATION FOR CATALYTIC OXIDIZERS . . 2-50
2.23 CAPTURE EFFICIENCY DETERMINATION 2-51
2.24 STARTUP/SHUTDOWN ISSUES 2-53
2.25 RECORDKEEPING 2-54
2.26 PRINTING/COATING ISSUES 2-57
2.27 STANDARD FOR LITHO AND HEATSET PRINTING - 2-59
2.28 UNITS 2-59
2.29 GLYCOL ETHERS 2-60
2.30 SUMMARY TABLE IN REGULATION 2-61
2.31 GENERAL PROVISIONS CROSS REFERENCE TABLE 2-61
2.32 VALIDITY OF COST ANALYSIS 2-62
2.33 INTERCHANGEABILITY OF INK SYSTEMS 2-63
2.34 STATE AIR TOXICS PROGRAMS 2-63
VI
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2.35 ALTERNATE TEST METHODS 2-63
2.36 WORK PRACTICE STANDARDS 2-64
2.37 INNOVATIVE TECHNOLOGIES 2-64
2.38 DUE PROCESS 2-64
2.39 EXEMPTION FOR NEWLY LISTED HAP 2-65
2.40 FEASIBILITY OF MATERIALS SUBSTITUTION 2-65
VII
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1. SUMMARY
On March 14, 1995, the EPA proposed national emission
standards for hazardous air pollutants (NESHAP) for rotogravure
and wide-web flexographic printing (60 FR 13664) under authority
of Section 112 of the amended CAA. Public comments were
requested on the proposal in the Federal Register. One hundred
seventeen commenters, composed of State and local air pollution
control agencies; trade associations for printers; ink
manufacturers and control equipment manufacturers; printers; ink
manufacturers; and citizens responded to the request.
The comments that were submitted and the responses to those
comments are summarized in this document. The summary of
comments and responses serves as the basis for the revisions made
to the standards between proposal and promulgation.
1.1 SUMMARY OF CHANGES MADE SINCE PROPOSAL
Several changes have been made since the proposal of these
standards. A discussion of these changes is provided in the
preamble to the final rule. A summary of the major changes is
presented below.
1.1.1 Incidental Printing and Ancillary Printing Equipment
The final standard includes simplified requirements and does
not mandate emission controls for incidental printers.
Incidental printers are a subgroup of product and packaging
rotogravure or wide-web flexographic printing affected sources at
facilities that are major sources of HAP. Affected sources
within this subgroup are those which meet a monthly threshold in
either materials applied or organic HAP applied on product and
packaging rotogravure and wide-web flexographic printing presses.
Such affected sources would be subject only to initial
notification requirements and recordkeeping requirements to show
that one of the thresholds is met every month. If, in any month,
such an affected source meets neither of the thresholds, then the
affected source would become subject to all relevant requirements
of the final standard and would no longer qualify for inclusion
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in the subgroup even if, in subsequent months, the affected
source did meet either of the thresholds.
The final standard also permits the owner or operator of a
product and packaging rotogravure or wide-web flexographic
printing affected source to choose to exclude ancillary printing
equipment from the affected source. This equipment is used
primarily for coating, laminating, or other operations besides
product and packaging rotogravure and wide-web flexographic
printing. Presses on which five weight-percent or less of the
total material applied each month is applied by rotogravure or
wide-web flexographic print stations would be subject only to a
simplified recordkeeping requirement. The EPA believes it is
appropriate to provide the owner or operator with the option not
to subject these presses to the HAP emission limitations for
product and packaging and wide-web flexographic printing in
§63.825 because the work being done on the rotogravure and wide-
web flexographic print stations on these presses is ancillary to
the work being done on other work stations (i.e., coating
stations) on these presses. The EPA is separately establishing
maximum achievable control technology (MACT) for other source
categories, such as the paper and other web coating source
category and the metal coil coating source category, which may be
more appropriate for this type of equipment. Ancillary printing
equipment, if excluded from this standard, will be subject to the
appropriate source category standard when such a standard is
issued.
1.1.2 Research and Laboratory Equipment
All research and laboratory equipment has been excluded from
the final standard whether or not it is collocated with
production facilities.
1.1.3 Addition of Presses to Existing Affected Sources
Addition of presses to existing affected sources will
subject the affected source to the compliance deadline for new
sources if the additional press or presses constitutes a
reconstruction of the source. Additions, replacements, and
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modifications to existing sources which do not meet the
i
definition of reconstruction do not alter the compliance
deadline.
1.1.4 Affected Source for Product and Packaging Rotogravure and
Wide-web Flexographic Printing Facilities
The final standard considers all product and packaging
rotogravure and wide-web flexographic printing equipment at a
given facility as a single affected source. Compliance with
reporting and recordkeeping requirements for a single affected
source will be less burdensome than compliance on a press-by-
press basis. In addition, sources may achieve the required
emissions reductions through affected source-wide limitation of
emissions, including controlled and uncontrolled presses. This
will allow sources to comply in the most cost-effective way and
will not require expensive control equipment for small presses
which emit relatively small amounts of .organic HAP if equivalent
emissions reductions can be achieved elsewhere within the
affected source.
1.1.5 Organic HAP Analysis Methods
The final standard adopts Method 311, as revised and
promulgated with the wood furniture NESHAP, for organic HAP
analysis. Printers and ink manufacturers have the option of
relying on formulation data if the data meet specified criteria.
In the event of any discrepancy between formulation data and the
results of Method 311, the results of Method 311 shall be
presumed to govern for all compliance purposes.
In addition, the printer may determine the volatile matter
content of the material and use this value for the organic HAP
content for all compliance purposes. This option may be useful
if organic HAP makes up all or substantially all of the volatile
matter in an ink or other material.
1.1.6 Volatile Matter Analysis Methods
The final standard allows printers and ink manufacturers the
option of relying on formulation data for volatile matter and
solids contents, in lieu of EPA Methods 24 and 24A. In the event
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of any discrepancy between formulation data and the results of
the EPA test methods, the test methods shall be presumed to
govern for all compliance purposes.
1.1-7 Compliance Monitoring for Catalytic Oxidizers
The final standard requires owners or operators using a
catalytic oxidizer and monitoring an operating parameter to
ensure compliance with the standard to monitor the temperature
immediately upstream of the catalyst bed. The requirement to
monitor the temperature downstream of the catalyst bed has been
eliminated. Since the operating parameters are established
during a test under normal operating conditions, a downstream
temperature monitoring parameter might be impossible to meet
during periods when organic loading to the oxidizer was lower
than normal. This might have led to exceedances which were not
indicative of improper operating conditions or excessive
emissions.
1.1.8 Additional Compliance Options for Product and Packaging
Rotogravure and Wide-web Flexographic Printing Affected Sources
In order to make the compliance options for low organic HAP
materials based on organic HAP content and solids applied
consistent with the definition of affected source, additional
means of demonstrating compliance have been added to the final
rule. Affected sources may demonstrate that each material
applied meets either of the organic HAP thresholds, or that all
materials on average meet either of the organic HAP thresholds,
or that the organic HAP emitted is less than the organic HAP
allowed taking these thresholds into account. In addition,
emissions from controlled and uncontrolled presses are aggregated
to determine compliance with an organic HAP emission standard
applicable to the entire affected source.
1.1.9 Capture Efficiency Protocols and Test Methods
The final rule allows the use of alternate capture
efficiency protocols and test methods which satisfy the criteria
of either the Data Quality Objective or Lower Confidence Limit
approaches. An appendix describing these approaches has been
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added to the final rule. Additional information on alternate
capture efficiency protocols and test methods is available in
Guidelines for Determining Capture Efficiency. January 1995.
This document is attached to Item No. II-B-3 in the project
docket.
1.1.10 Transition from Area Source to Major Source Status
A provision has been added to the final rule by which
owners or operators that have used the provisions of
§63.820(a) (2) to establish the facility as an area source may
reestablish the facility as a major source. Such a source must
comply with its HAP usage commitments until it meets all
requirements for major sources.
1.1.11 Definition of "Month"
The definition of "month" in the final rule has been changed
to include prespecified periods of 28 to 35 days.
1.1.12 Alternatives to Vent Stream FlowrRate Monitoring
The final regulation includes alternatives to the vent
stream flow rate measurement requirement.
Owners or operators of product and packaging rotogravure or
wide-web flexographic presses with intermittently-controllable
work stations may, as alternatives to measuring vent stream flow
rate, install flow indicators on the bypass lines, secure bypass
line valves with locking mechanisms or car seals, continuously
monitor bypass valve position or equip the press with an
interlock preventing operation when the control device is
bypassed. Sampling lines for gas analyzers and relief valves
needed for safety purposes are not considered bypass lines for
the purposes of these provisions. Presses that do not have any
intermittently-controllable work stations are not subject to
these provisions.
1.1.13 Extension of Deadline for Initial Notification
The final rule overrides the General Provisions and requires
initial notification for existing sources no later than one year
before the compliance date. This will allow existing sources two
years from the date of promulgation of this standard. The EPA
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believes that this will provide adequate notice to ensure
compliance.
1.1.14 Provisions for Optional Inclusion of Stand-alone Coating
Equipment
The final rule provides a mechanism by which product and
packaging rotogravure and wide-web flexographic printers may
include stand-alone coating equipment in their affected source.
This inclusion is optional and subject to certain eligibility
criteria. Coating equipment may be covered by standards for
other source categories (e.g., Paper and Other Web Coating) which
will be promulgated in the future. In order to avoid the
additional effort required to comply with two (or more) separate
MACT standards, owners or operators of printing affected sources
may choose to subject this equipment to regulation under the
printing and publishing standard.
Stand-alone coating equipment is eligible for inclusion if
(1) it coats the same substrate as a rotogravure or wide-web
flexographic press included in the affected source, or (2) it
applies a solids-containing material in common with a rotogravure
or wide-web flexographic press included in the affected source,
or, (3) it shares a control device with a rotogravure or wide-web
flexographic press included in the affected source. In order to
take advantage of this provision, all eligible stand-alone
coating equipment within the facility must be included and no
product or packaging rotogravure or wide-web flexographic presses
may be excluded from the affected source using the mechanism in
§63.821(a) (2) (ii) .
1.2 SUMMARY OF IMPACTS OF PROMULGATED ACTION
The final rule will reduce nationwide emissions of HAP by
approximately 6700 megagrams per year (mg/yr) (7400 tons per year
(tpy)). This will result from a reduction of approximately
4,750 mg/yr (5,220 tpy) from publication rotogravure facilities
and an additional 1,940 mg/yr (2,140 tpy) from product and
package rotogravure and wide-web flexographic printers.
Substantial reductions in emissions of volatile organic compounds
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(VOC) are also expected as a result of this rule. The VOC
reductions may be slightly greater than the HAP reductions if
affected sources convert from HAP containing solvent-based
materials to waterborne or radiation cured materials.
Alternately, the VOC reductions may be slightly less than the HAP
reductions if affected sources convert from HAP containing
solvent-based materials to reduced HAP solvent-based materials in
lieu of upgrading capture and control systems.
The nationwide annual costs (including capital recovery) of
the final rule are estimated at $40 million per year. These costs
include $21 million per year for publication rotogravure printers
and $19 million per year for package and product rotogravure and
wide-web flexographic printers. Cost estimates for publication
rotogravure printers remain unchanged from the proposed rule.
Estimated costs for package and product rotogravure and wide-web
flexographic printers are slightly less, than those for the
proposed rule due to reductions in cost as a result of facility-
wide definition of affected source. The proposed rule was
determined not to have a significant economic impact. No firms
or facilities were found to be at risk of closure as a result of
the standards and there was not a significant economic impact on
a substantial number of small entities. Because compliance costs
and reporting and recordkeeping burdens have been reduced in the
final rule, the economic impact has not increased and remains
insignificant.
No significant secondary environmental impacts are expected
to occur as a result of this rule. The rule encourages
conversion of HAP based ink systems to ink systems based on non-
HAP substitutes. To the extent that printers adopt waterborne
ink systems, some reduction in the production of Resource
Conservation and Recovery Act regulated hazardous waste, and some
increase in discharges of wastewater to publicly owned treatment
plants may occur.
A net increase in consumption of electricity is expected to
occur as a result of increased fan horsepower requirements in
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systems which are retrofit to improve capture efficiency.
Individual facilities that choose to comply through partial or
complete elimination of solvent borne ink systems in favor of
waterborne or radiation cure ink systems will use less
electricity. Because it is impossible to predict the extent to
which various compliance strategies (i.e., improved capture and
control, conversion to non-HAP solvent-borne materials, or
conversion to waterborne or radiation cure materials), the net
impact of the rule on electricity consumption has not been
estimated.
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2. SUMMARY OF PUBLIC COMMENTS
A total of 117 letters commenting on the proposed standard
were received. A list of commenters, their affiliations, and the
EPA docket item number assigned to their correspondence are given
in Table 2-1. The comments have been categorized under the
following topics:
1. Synthetic Area Source Mechanism
2. Definition of Major Source
3. Transition from Area Source to Major Source
4. Once in/Always in
5. Research and Laboratory Operations
6. New Source MACT
7. Affected Source "at Publication Facilities
8. Affected Source at Product and Packaging Rotogravure and
Wide-Web Flexographic Printing Facilities
9. Definitions
10. Reporting
11. Level of Control for Product and Packaging Rotogravure
and Wide-Web Flexographic Printing Affected Sources
12. Level of Control for Publication Affected Sources
13. Standards for Product and Packaging Rotogravure and
Wide-Web Flexographic Printing Affected Sources
14. Compliance for Publication Rotogravure Affected Sources
15. Monitoring
16. Compliance Dates for New sources
17. Compliance Dates-General Issues
18. HAP Content determination
19. Method 24/24A
20. Oxidizer Terminology
21. Compliance Demonstration-General Issues
22. Compliance Demonstration for Catalytic Oxidizers
23. Compliance Demonstration for Capture Efficiency
24. Startup/shutdown Issues
25. Recordkeeping
26. Printing/Coating Issues
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27. Standard for Litho and Heatset Printing
28. Units
29. Glycol ethers
30. Summary Table in Regulation
31. General Provisions Cross Reference Table
32. Validity of Cost Analysis
33. Interchangeability
34. State Air Toxics Programs
35. Alternate Test Methods
36. Work Practice Standards
37. Innovative Technologies
38. Due Process
39. Exemption for Newly Listed HAP
40. Feasibility of Materials Substitution
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TABLE 2-1. LIST OF COMMENTERS ON NATIONAL EMISSION STANDARDS
FOR THE PRINTING AND PUBLISHING INDUSTRY
Item Number in
Docket A-92-42 Commenter and Affiliation
IV-D-1 T. A. Loredo, Reynolds Metals Company, Flexible
Packaging Division
IV-D-2 E. W. Siemering, Federal Paper Board Company
IV-D-3 C. Whisenant, Shamrock Corporation
IV-D-4 F. Shapiro, PF Technical Services
IV-D-5 V. W. Ducker, Ecusta
IV-D-6 D. P. Sankot, Color Converting Industries
IV-D-7 D. L. McKinnon, Manufacturers of Emissions
Controls Association
IV-D-8 A. M. Friedman, Starlight Flexible Packaging
IV-D-9 Unsigned
IV-D-10 M. L. Ashenbrenner, Little Rapids Corporation
IV-D-11 M. A. Schilling, TUFCO Industries, Incorporated
IV-D-12 D. Sullivan, Fox Converting, Incorporated
IV-D-13 M. Prabhu, Solar Press, Incorporated
IV-D-14 D. R. Pendleton, Texas Natural Resource
Conservation Commission
IV-D-15 R. Dennison, Gravure Association of America
IV-D-16 K. S. Barnett, Aluminum Corporation of America
IV-D-17 T. A. Loredo, Reynolds Metals Company, Flexible
Packaging Division
IV-D-18 D. A. Jurewicz, Stone Container Corporation
IV-D-19 P. R. Addison, Print Flex, Incorporated
IV-D-20 Illegible signature
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TABLE 2-1. LIST OF COMMENTERS ON THE PROPOSED NESHAP FOR
THE PRINTING AND PUBLISHING INDUSTRY (CONTINUED)
Item Number in
Docket A-92-42 Commenter and Affiliation
IV-D-21 J. H. Sutphin, National Association of Printing
Ink Manufacturers, Incorporated
IV-D-22 Illegible signature, M & D Industries
International, Incorporated
IV-D-23 F. G. Christeson, DE'COR Gravure Corporation
IV-D-24 J. McGill, Interflex Group
IV-D-25 T. VJarlick, Graphic Packaging Corporation
IV-D-26 K. Lee, Shorewood Packaging
IV-D-27 R. Bronstein, U. S. Converting, Incorporated
IV-D-28 K. Flackam, INX International, Incorporated
IV-D-29 R. E. Heskett, Bemis Company, Incorporated
IV-D-30 Illegible signature, Squareshooter Candy Company
IV-D-31 S. Shaw, Betna Film Systems, Incorporated
IV-D-32 R. Kline, Graphic Packaging Corporation
IV-D-33 R. H. Miller, James River Corporation
IV-D-34 G. A. Morris, Sandusky Vinyl Products Corporation
IV-D-35 G. J. Sullivan, Little Falls Color-Print
IV-D-36 M. G. Wygonik, Flexible Packaging Association
IV-D-37 N. Zlotkin, Air Pollution Control District, County
of San Diego
IV-D-38 R. H. Colby and D. F. Theiler, STAPPA/ALAPCO,
State and Territorial Air Pollution Program
Administrators and the Association of Local Air
Pollution Control Officials
IV-D-39 R- D. Fletcher, State of California, California
Environmental Protection Agency
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TABLE 2-1. LIST OF COMMENTERS ON THE PROPOSED NESHAP FOR
THE PRINTING AND PUBLISHING INDUSTRY (CONTINUED)
Item Number in
Docket A-92-42 Commenter and Affiliation
IV-D-40 W. E. Bachman, GenCorp
IV-D-41 C. Martin, Plas-Techs, Incorporated
IV-D-42 C. Yedinak, Northstar Print Group
IV-D-43 F. Jelalian, Accutech International
IV-D-44 D. Redding, Duralam, Incorporated
IV-D-45 Illegible signature, Waterlox Coatings Corporation
IV-D-46 Illegible signature
IV-D-47 Illegible signature, Formal Industries,
Incorporated
IV-D-48 G. T. McCarter, Fres-co System USA, Incorporated
IV-D-49 C. Twaroski, Minnesota Pollution Control Agency
IV-D-50 R. D. Robinson, Borden, Incorporated
IV-D-51 J. E. Walther and S. H. Maurer, James River
Corporation
IV-D-52 K. Orsborne, Flint Ink Corporation
IV-D-53 D. G. Ellison, American National Can Company
IV-D-54 L. J. Liszewski, Eastman Kodak Company
IV-D-55 Illegible signature, Prestige-Pak, Incorporated
IV-D-56 M. J. Wax, Institute of Clean Air Companies
IV-D-57 J. R. Schrader, Printworld, Division of
Technographics, Incorporated
IV-D-58 Illegible signature, Zorn Packaging, Incorporated
IV-D-59 D. Roeing, Croda Inks Corporation
IV-D-60 J. L. Murphy, Westvaco
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TABLE 2-1. LIST OF COMMENTERS ON THE PROPOSED NESHAP FOR
THE PRINTING AND PUBLISHING INDUSTRY (CONTINUED)
Item Number in
Docket A-92-42 Commenter and Affiliation
IV-D-61 D. Wefring, 3M Environmental Engineering and
Pollution Control
IV-D-62 L. A. Spurlock, Chemical Manufacturers Association
IV-D-63 D. W. Marshall, Union Camp Corporation
IV-D-64 J. Kraemer
IV-D-65 L. Gallins, Halsted Corporation
IV-D-66 T. A. Elliott, Zeneca, Incorporated
IV-D-67 H. E. Coffey, Westvaco
IV-D-68 Two illegible signatures-, Walden Paper Services,
Incorporated
IV-D-69 L. H. Goldstein, Colonial Transparent Products
Company, Incorporated
IV-D-70 W. A. Riessen, B & D Plastics, Incorporated
IV-D-70A L. G. Gwin, Julian B. Slevin Company
IV-D-71 R. Creighton, Package-Craft, Incorporated
IV-D-72 Illegible signature, Northern Expediting
Corporation
IV-D-73 T. H. Jones, Precision Packaging, Incorporated
IV-D-74 Illegible signature, Graphic Creation Stationery &
School Supply, Incorporated
IV-D-75 Illegible signature, Ohio Valley Converting,
Limited
IV-D-76 S. G. Mushall, Mannington
IV-D-77 H. Michail, Magruder Color Company
IV-D-78 Illegible signature, Lally-Pak, Incorporated
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TABLE 2-1. LIST OF COMMENTERS ON THE PROPOSED NESHAP FOR
THE PRINTING AND PUBLISHING INDUSTRY (CONTINUED)
Item Number in
Docket A-92-42 Commenter and Affiliation
IV-D-79 M. Feldstein, Bay Area Air Quality Management
District
IV-D-80 J. L. Shumaker, International Paper
IV-D-81 J. A. Dege, DuPont SHE Excellence Center
IV-D-82 K. Z. Klaber, Environmental Resources Management,
Incorporated
IV-D-83 D. M. Gorewitz, Longview Fibre Company
IV-D-84 M. E. Ward, R. J. Reynolds Tobacco Company
IV-D-85 R. C. Barnard, Fonda Group, Incorporated
IV-D-86 D. Chaffee, Sancoa International
IV-D-87 J. M. Daley
IV-D-88 J. P. Leyden, South Coast Air Quality Management
District
IV-D-89 Illegible signature, Package Printing Company,
Incorporated
IV-D-90 R. C. Rhodes, Universal Packaging Corporation
IV-D-91 G. Kaufman, Manhattan Poly Bag Corporation
IV-D-92 J. D. Eichenlaub, Trinity Packaging Corporation
IV-D-93 B. V. Trave, Bemis Company, Incorporated
IV-D-94 R. Bennett, Ultra-Creative Corporation
IV-D-95 R. A. Knowles, Huntsman Packaging Corporation
IV-D-96 G. T. Richards, Vitex Packaging, Incorporated
IV-D-97 D. Larson, Bemis Company, Incorporated
IV-D-98 D. C. Cook, Printpak, Incorporated
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TABLE 2-1. LIST OF COMMENTERS ON THE PROPOSED NESHAP FOR
THE PRINTING AND PUBLISHING INDUSTRY (CONTINUED)
Item Number in
Docket A-92-42 Commenter and Affiliation
IV-D-99 T. Sattis, Graphic Packaging Corporation
IV-D-100 T. Salo, Apple Converting
IV-D-101 L. Cowert, Dixie Packaging, Incorporated
IV-D-102 L. Pietroski, Berwick Industries, Incorporated
IV-D-103 Illegible signature, Metropolitan Packaging
Manufacturing Corporation
IV-D-104 J. P. Duhig, Fortune Plastics, Incorporated
IV-D-105 E. Jones, International Converter, Incorporated
IV-D-106 T. Tellez, Poly-Pak Industries, Incorporated
IV-D-107 Illegible signature
IV-D-108 S. A. Moyer
IV-D-109 L. McClure, Bemis Company, Incorporated
IV-D-110 H. Rothchild, Poly Plastic Packaging Company,
Incorporated
IV-D-111 A. Kuehl, Olympic Packaging, Incorporated
IV-D-112 T. A. Augurt, Propper Manufacturing Company,
Incorporated
IV-D-113 B. L. Olsen, RollPrint Packaging Products,
Incorporated
IV-D-114 Illegible signature, Fabricon Products
IV-D-115 Illegible signature, Union Industries
IV-D-116 S. Castellan, Graphic Packaging Corporation
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2.1 SYNTHETIC AREA SOURCE MECHANISM
Comment: A number of comments were received suggesting
simplified mechanisms for establishing synthetic area source
status. Three commenters recommended strategies involving state
operating permits. Commenter IV-D-36 suggested accepting
emissions limitations under "Federally Exempt State Permits."
Commenter IV-D-63 suggested grandfathering facilities which
presently have state operating permits which incorporate HAP
emission limits. Commenters IV-D-49 and IV-D-63 suggested
allowing case-by-case operating restrictions within State
permits.
Seven commenters suggested specific mechanisms to establish
area source status. Commenter IV-D-14 suggested -that sources
determine emissions using initial capture and control device test
data in conjunction with actual ink usage rates and HAP contents.
If oxidizers were used, continuous temperature monitoring would
be required. The sources would maintain monthly records of
calculated emission rates and provide an annual self-certified
report. If physical limitations prevented a source from emitting
at threshold levels (presumably a source so small or so slow that
it could never use threshold levels of HAP) then a onetime
certification would suffice. Commenter IV-D-53 suggested the use
of capture and control device test data and formulation data to
establish that emissions were 90 percent or less of the 10/25
threshold. Sources would be required to maintain records to
demonstrate this on a twelve month rolling average basis.
Commenter IV-D-98 suggested having the source report actual
emissions (taking into account documented capture and control
efficiencies) to the permitting authority on a quarterly basis.
Commenter IV-D-80 suggested calculating actual emissions
based on overall control efficiency testing and then requiring
monitoring, recordkeeping, and reporting only with respect to
conformity with an operating and maintenance plan for the control
equipment.
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Commenter IV-D-39 suggested that major sources that
establish the existence of control devices which limit emissions
to below threshold amounts be treated in accordance with the
John Seitz memoranda of 1/25/95 and 5/16/95; and that these
sources not be required to maintain a Title V permit.
Commenter IV-D-79 suggested a simplified cutoff based on
quantity of materials used (e.g., 250 gallons per month, as in
wood furniture); the commitment procedure could take the form of
a signed statement submitted before the final compliance date.
Very small facilities (2 tons/5 tons) could demonstrate
compliance on request of the regulatory authority without any
commitment. Commenter IV-D-18 suggested using the Superfund
Amendments and Reorganization Act (SARA) 313 annual recordkeeping
and reporting to establish emissions below the 10/25 threshold.
Two commenters (IV-D-39 and IV-D-53) suggested excluding
area sources from a requirement for a Part 70 permit.
Commenter IV-D-53 requested explicit language that §63.821(d) of
the proposed rule applies only to major sources.
Response: The synthetic area source mechanism in §63.820
has been retained. This is not intended to preclude the use of
other mechanisms based on Federally enforceable limitations on
potential-to-emit. These mechanisms are described in the
response included in section 2.2 below. As described below,
major source status is not determined by actual HAP emissions or
actual HAP use. Any limitations on potential-to-emit must be
physical (e.g., size, capacity, speed, materials compatibility)
or Federally enforceable commitments (or certain State-
enforceable commitments which are practically effective).
Additional information is provided in the EPA's "Interim Policy
of Federal Enforceability of Limitations on Potential to Emit"
(Docket Item IV-B-2).
Provisions by which sources can establish area source status
based on the use of control devices have not been added to the
rule. Major source status is determined by facility-wide
potential-to-emit. The use of control equipment to control
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emissions from affected sources under this rule might not ensure
area source status because of potential emissions from collocated
affected sources subject to other source categories. In making
and demonstrating compliance with area source commitments outside
of this rule for facilities with controlled printing presses, the
procedures in this rule for determining HAP content, capture
efficiency, control device efficiency, monitoring and
recordkeeping may be useful in limiting the potential to emit
from the controlled printing presses.
Simplified requirements have been added to the final
standard for incidental printers. These are major sources which
operate product and packaging and wide-web flexographic printing
presses that apply relatively small amounts of material or apply
relatively small quantities of HAP. Sources which apply no more
than 500 kilograms (kg) per month of materials on product and
packaging rotogravure and wide-web flexographic printing presses,
or no more than 400 kg per month of organic HAP on product and
packaging rotogravure and wide-web flexographic printing presses
are subject only to greatly simplified recordkeeping
requirements.
In addition, owners or operators of ancillary printing
equipment may exclude this equipment from the affected source.
Ancillary printing equipment is equipment which is used primarily
for coating, laminating, or printing by processes other than
product and packaging rotogravure and wide-web flexographic
printing. Presses on which five weight-percent or less of the
total material applied each month is applied by rotogravure or
wide-web flexographic print stations would be subject only to a
simplified recordkeeping requirement.
The requirement to apply for and obtain a Part 70 permit is
not exclusively based on Title III (HAP). Other pollutants, at
levels which vary by location, and requirements of State
implementation plans also affect Part 70 permit requirements.
The area source provisions within the rule do not obligate the
source to obtain a Part 70 permit, nor do they exempt the source
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from other requirements to which it is subject. Consistent with
the EPA's December 1995 proposal to amend the NESHAP for Chromium
Electroplating, nonmajor sources are not required to obtain
Title V operating permits.
2.2 DEFINITION OF MAJOR SOURCE
Comment: Seven commenters (IV-D-1, IV-D-15, IV-D-36,
IV-D-51, IV-D-53, IV-D-63, IV-D-79, and IV-D-84) suggested basing
major source status on HAP emissions as opposed to HAP use. Five
of the seven (IV-D-1, IV-D-36, IV-D-53, IV-D-63, and IV-D-84)
further suggested that major source status should be based on
organic HAP use, as inorganic HAP are not regulated under the
proposed standard. Commenter IV-D-36 specifically recommended
exclusion of organic HAP which is not emitted (such as
dibutylphthalate) from the determination of major source status.
Commenters IV-D-38 and IV-D-51 suggested exempting small
printing operations located at facilities that are major sources
as a result of other operations. Commenter IV-D-51 suggested
establishing a de minimis quantity of HAP use for these
operations, or alternately allowing the source to commit to a
5/10 threshold based on HAP use and confirm this by maintaining
material safety data sheets (MSDS) and records of materials used.
Response: Major source status is determined based on
"potential-to-emit" as defined in the General Provisions, §63.2,
as opposed to actual emissions or HAP usage for any particular
year. Potential-to-emit means the maximum capacity of a
stationary source to emit a pollutant under its physical and
operational design. Any physical or operational limitation on the
capacity of the stationary source to emit a pollutant, including
air pollution control equipment and restrictions on hours of
operation or on the type or amount of material combusted, stored
or processed, shall be treated as part of its design if the
limitation or the effect it would have on emissions is Federally
enforceable.
Federally enforceable limits on potential-to-emit can be
obtained through new source review permits, permits issued under
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State operating permit programs adopted in State implementation
p*lans and approved by the EPA (extended to HAP) , Title V
operating permits, State implementation plan limits for
individual sources, Section 112(1) State HAP programs, or State-
created protocols included in a Section 112(1) provision. Other
mechanisms may also be available.
Nonvolatile materials, including many metallic compounds,
may not be capable of being emitted as air pollutants. Use of
materials which have no potential for emission to the air do not
affect major source status. However, the definition of
"hazardous air pollutant" in §112(b) of the CAA (including all
inorganic HAP) is the basis for making major source
"determinations if the facility has the potential to emit such
pollutants (even if they are not controlled by this standard).
The CAA defines "major source" to mean "any stationary
source or group of stationary sources [emphasis added] located
within a contiguous area and under common control that emits or
has the potential to emit considering controls, in the aggregate.
[emphasis added] 10 tpy or more of any hazardous air pollutant or
25 tpy or more of any combination of hazardous air pollutants."
The EPA interprets this to allow aggregation of sources across
source categories at a facility in determining major source
status.
Simplified provisions have been added to the final rule for
incidental printers. These are small printing operations located
at facilities which are major sources principally as a result of
other operations. These sources are subject only to simplified
recordkeeping requirements.
2.3 TRANSITION FROM AREA SOURCE TO MAJOR SOURCE
Comment: Commenter IV-D-15 requested that a provision
allowing a transition period for a newly designated major source
to come into compliance be incorporated in the rule. The
proposal makes no allowance for a source to make this transition
without being in violation of the standard.
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Response: The owner or operator of an area source intending
to increase the capacity of the facility to the extent that it
would become a major source is required to apply for and obtain a
Title V permit. The owner or operator of an area source seeking
to remove a provision limiting potential-to-emit from the
source's Title V permit must apply for and obtain a permit
modification. Any new area source that becomes a major affected
source must comply with the standard upon becoming a major
source. Any existing area source that becomes a major affected
source must comply with the standard by the existing source
compliance date or upon becoming a major source, whichever is
later.
A provision has been added to the final rule in
§63.820(a)(6) which provides a mechanism for owners or operators
that have used the provisions of §63.820(a)(2) to establish the
facility as an area source to reestablish the facility as a major
source. Such a source must continue to comply with its HAP usage
commitments until it meets all requirements for major sources.
2.4 ONCE IN/ALWAYS IN
Comment: Commenters IV-D-14 and IV-D-15 stated that this
policy eliminates an incentive for companies to reduce HAP
emissions. Three commenters (IV-D-14, IV-D-49 and IV-D-84)
requested the inclusion of a provision for major sources to alter
their operations and become area sources. Commenter IV-D-14
recommend a mechanism for attaining synthetic area source status
through documentation of monthly records of emission rates and an
annual report. If physical modifications are made to eliminate
the possibility of major source level emissions, a onetime
certification is suggested. Commenters IV-D-49 and IV-D-84
request some mechanism to attain synthetic area source status
after eliminating HAP use or reducing HAP use below a de minimis
level.
Commenters IV-D-36 and IV-D-53 request a provision for
retaining area source status after a violation of the commitment.
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Commenter IV-D-84 suggested an appeal process whereby facilities
with onetime exceedances can maintain area source status.
Response: The EPA believes that the "once in, always in"
policy follows most naturally from the language and structure of
the CAA. In many cases, application of maximum achievable
control technology (MACT) will reduce a major emitter's emissions
to levels substantially below the major source thresholds.
Without a "once in, always in" policy, these facilities could
"backslide" from MACT control levels by obtaining pc tential-to-
emit limits, escaping applicability of the MACT standard, and
increasing emissions to the major source threshold (10/25 tpy).
Thus, the maximum achievable emissions reductions that Congress
mandated for major sources would not be achieved. A "once in,
always in" policy ensures that the MACT emission reductions are
permanent, and that the health and environmental protection
provided by MACT standards is not undermined.
This issue was addressed in a May 16, 1995 memo "Potential
to Emit for MACT Standards--Guidance on Timing Issues" from
John Seitz, Director of the Office of Air Quality Planning and
Standards, to the directors of Regions I through X
(Docket Item IV-B-2), and further discussed in the Background
Information Document (BID) for the promulgated NESHAP for Wood
Furniture Manufacturing Operations (EPA-453/R-95-018b).
2.5 RESEARCH AND LABORATORY OPERATIONS
Comment -. Eight comments were received requesting varying
degrees of exemption for research and laboratory equipment. 'Five
commenters (IV-D-15, IV-D-36, IV-D-61, IV-D-63, IV-D-80, and
IV-D-84) suggested exempting all research and development
activities from the standard. Commenter IV-D-80 stated that the
purpose and operation of a research press is independent of its
location. Commenter IV-D-63 suggested exempting research and
development activities which are collocated with production;
these are the only research and development activities expected
to be affected by the proposed rule. Commenter IV-D-61 suggested
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exempting all research and laboratory operations and covering
these operations with a separate standard.
Commer.ter IV-D-1 suggested exempting laboratories collocated
at production facilities if they are located in separate
buildings. The same individual recommended in a separate comment
(IV-D-17) exempting all research and laboratory facilities whose
primary purpose is research and development of new processes and
products.
Two comments were received on research work conducted on
production presses. Commenter IV-D-63 suggested exempting
research and development on production presses if it was done in
non-marketable quantities. Commenter IV-D-82 suggested that
trial runs of less than production quantity (presumably conducted
on production equipment) should be exempt and that a de minimis
in terms of press size, hours of operation, or maximum emissions
should be specified.
Response: The final rule excludes research and laboratory
equipment. As the commenter suggested, in order to regulate
research and laboratory equipment, it would be necessary to
develop a separate source category as directed by
Section 112(c)(7) of the CAA to assure equitable treatment of
such equipment. Furthermore, the EPA believes that many of the
types of emission points associated with research and laboratory
equipment (such as laboratory bench-scale equipment) may not be
feasibly controlled using the same control devices as are used
for production equipment because they may be small, intermittent,
remote from production equipment or incompatible with materials
used in the production process.
2.6 NEW SOURCE MACT
Comment: One commenter IV-D-49 suggested that the EPA
consider establishing separate new source MACT standards.
Response: The EPA believes that the standard for existing
publication rotogravure facilities, 92 percent overall control on
a facility-wide basis to be achieved each and every month, will
require an efficient capture system and a state-of-the-art
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control device. This level of control is the MACT floor for both
existing and new sources. There is no distinct identifiable
technology available to new sources that would allow them to
achieve a more stringent standard.
The EPA believes that the overall efficiency standard for
existing package and product facilities, 95 percent overall
control on a facility wide basis to be demonstrated under
performance test conditions, will require an efficient capture
system and a state-of-the-art control device. This level of
control is the MACT floor for both existing and new sources.
There is no distinct identifiable technology available to new
sources that would allow them to achieve a more stringent
-standard. Because of the wide variation in performance
requirements of printed substrates, there is no assurance that
all new facilities would be able to meet a more stringent
standard through the use of low-HAP materials.
2.7 AFFECTED SOURCE AT PUBLICATION FACILITIES
Comment: Commenter IV-D-15 suggested explicitly clarifying
that the affected source for the publication rotogravure standard
is the entire facility (not individual presses or operations) and
that the standard be restricted to gravure related operations
using organic HAP.
Response: The definition of the affected source in
§63.821(a)(1) includes all rotogravure presses and all affiliated
equipment within a facility. Plating of rotogravure cylinders is
covered by a separate NESHAP in subpart N, and is not regula'ted
under this standard.
2.8 AFFECTED SOURCE AT PRODUCT AND PACKAGING ROTOGRAVURE AND
WIDE-WEB FLEXOGRAPHIC PRINTING FACILITIES
Comment: Four commenters (IV-D-36, IV-D-51, IV-D-53, and
IV-D-88) suggested allowing compliance based on the entire
facility rather than line-by-line. Commenter IV-D-36 suggested
this only with regard to averaging materials to meet the low-HAP
threshold, and stated that it would cut recordkeeping expenses
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from $250,000 per year to $20,000. Commenter IV-D-53 also stated
that this would reduce recordkeeping expenses.
Eight commenters (IV-D-1, IV-D-15, IV-D-36, IV-D-51,
IV-D-53, IV-D-63, IV-D-82, IV-D-84) suggested allowing grouping
and averaging for all presses controlled by any common control
device rather than only solvent recovery systems.
Two commenters (IV-D-17 and IV-D-36) suggested allowing
individual stations or any groups of stations on the same press
to comply on an individual or group basis with any standard.
Various parts of the same press could comply on the basis of the
low-HAP threshold, the low solids threshold or the HAP emissions
threshold. Station by station inventories of materials used
would be maintained.
Commenter IV-D-51 suggested relaxing the qualifications for
group compliance applicable to groups of presses controlled by a
common solvent recovery system. The Commenter suggested dropping
the requirement that common solvent recovery systems be used only
for control of printing operations so as not to penalize
facilities that have tightened up their control systems by tying
in other sources of HAP.
Commenter IV-D-38 suggested including cylinder and parts
cleaners, ink and solvent mixing, and solvent recovery equipment
at product and packaging facilities to make it consistent with
the operations covered at publication rotogravure facilities.
Five commenters requested restrictions on the applicability
of the standard and one commenter requested clarifying the
applicability. Two commenters (IV-D-36 and IV-D-51) suggest
restricting applicability to sources using organic HAP.
Commenter IV-D-54 suggested adding language to §63.821 exempting
sources that do not use HAP even if they are collocated with
other non-printing operations that are major sources.
Commenter 81 suggested excluding rotogravure equipment located at
facilities with non-printing standard industrial classification
(SIC) codes, such as chemical plants, and regulating them when
the appropriate chemical process plant MACT is issued.
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Commenter IV-D-82 requested an exemption for (undefined) small
presses collocated with large presses as these will be expensive
to control and will yield little emission reduction.
Commenter IV-D-39 requested explicit clarification that presses
collocated at major sources are affected sources under the
standard.
Commenter IV-D-63 suggested correcting the error in
§63.825(b) of the proposed rule to include flexographic presses.
This was inadvertently omitted.
Response: The final rule defines the affected source to
include all of the packaging and product rotogravure and wide-web
flexographic printing presses rather than individual presses.
This will reduce recordkeeping, reporting, compliance
demonstration, and enforcement costs. All presses, including
uncontrolled presses and controlled presses regardless of whether
they share a common control system are included. The facility-
*
wide affected source definition is not expected to affect the
overall emissions from a facility but it will eliminate the need
to run particular printing jobs on particular presses as part of
a facility's compliance strategy. Station-by-station compliance,
grouping of stations which are part of one or more presses, and
press-by-press compliance are not permitted in the final rule
because facility-wide compliance encompasses these options and is
more easily and more reliably demonstrated. In addition to
reducing recordkeeping costs, this will reduce the labor
associated with enforcement. Facilities which apply a
combination of materials, all of which meet either the low-
HAP/solids or the low-HAP/material thresholds, can comply with
the rule without dedicating particular stations to specific types
of materials. Facility-wide definition of affected source will
remove the incentive for awkward and suboptimal scheduling of
jobs and equipment to achieve press-by-press compliance. In
addition, facilities will have an incentive to decrease HAP use
where possible (beyond the emissions threshold for a particular
job, press, or type of application) to achieve an emission
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reduction that can be used to offset emissions in areas where
emission reduction is more expensive.
The final standard includes provisions by which an owner or
operator of stand-alone coating equipment which is functionally
related to printing equipment, may choose, under some
circumstances, to include this equipment in an affected source.
To be eligible for inclusion, stand-alone coating equipment must
share a common control device with a rotogravure or wide-web
flexographic press included in the affected source, or coat a
substrate previously or subsequently printed by a rotogravure or
wide-web flexographic press included in the affected source, or
apply a solids-containing material which is also applied by a
rotogravure or wide-web flexographic press included in the
affected source. Equipment which is not functionally related to
product and packaging rotogravure printing or wide-web
flexographic printing presses is more appropriately regulated
under a different standard (e.g., Paper and Other Web Coating).
The EPA does not have sufficient data to determine MACT for
cylinder and parts washers, proof presses, and ink and solvent
mixing and storage equipment affiliated with presses at product
and packaging rotogravure and wide-web flexographic printing
facilities. The extremely diverse nature of this segment of the
printing industry (equipment type, material type, substrate type,
and product or package produced) complicates the determination of
achievable control. The database for publication rotogravure
facilities provided material balances over all printing rela'ted
equipment.
The rule applies to affected sources located at major
sources of HAP. Recordkeeping for facilities that use no organic
HAP on their product and packaging rotogravure and wide-web
flexographic printing presses requires minimal labor and is
essential to ensure that the facilities are in fact using no HAP
and that the facilities maintain information from testing or from
raw material suppliers to establish this fact. Such facilities
may use the provision in §63.821(b) of the final rule.
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The EPA does not believe that it can determine what
facilities operate printing presses using only SIC codes.
Converters and product printers generally use an SIC code
specific for the type of product or package that they produce.
MACT for controlling organic HAP emissions from product and
packaging rotogravure and wide-web flexographic presses is
independent of whether or not the press or presses are collocated
with a chemical plant or other potential source of HAP.
The final standard includes a facility-wide definition of
affected source which will allow owners or operators to achieve
facility-wide organic HAP emission reductions through
installation or upgrading of capture or control equipment or by
reducing the organic HAP content of materials used on whatever
press or presses that this can be most economically implemented.
Section 63.821(a)(2) of the final rule specifies that all
product and packaging rotogravure or wide-web flexographic
presses at a facility are subject to the standard (except for
proof presses). The final rule includes wide-web flexographic
presses along with product and packaging rotogravure presses in
all requirements of the standard. Although this applicability
was discussed in the preamble to the proposed rule, it was
inadvertently omitted from the proposed standard.
2.9 DEFINITIONS
Comment: Various comments were received suggesting
additional or revised definitions. In some cases the definitions
which were suggested were part of suggestions for alternate
regulations or clarifications.
Commenters IV-D-1 and IV-D-63 suggested separate definitions
of "HAP used for publication rotogravure" and "HAP used for
Package/Product rotogravure and flexography" with HAP used for
package/product rotogravure and flexography defined as equivalent
to "HAP applied". Commenter IV-D-53 suggested defining "HAP
used" to apply only to publication rotogravure.
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Commenter IV-D-15 suggested expanding the definition of
month to include (unspecified) "months" other than calendar
months or 28 or 35 days.
Commenter IV-D-15 suggested defining organic volatile matter
as VOC, and recommended new definitions for "overall equivalent
volatile organic HAP control efficiency" and "overall organic
volatile matter recovery" to reflect the combination
substitution/control efficiency and recovered HAP plus non-HAP
solvent. Commenter IV-D-15 also recommended adding definitions
for "facility" and "source."
Three comments were received suggesting definition of the
term "emission unit" as part of suggested changes to the
designation of affected sources. Commenters IV-D-17 and IV-D-36
recommend defining an emission unit as a station or group of
stations on a press. Commenter IV-D-63 suggested defining
emission unit as a stand alone press, a press within a group of
commonly controlled presses or an inboard or outboard station on
a press.
Commenter IV-D-17 recommended that "HAP control efficiency"
be defined and the definition include a statement that it is not
expected to be different than VOC control efficiency.
Commenters IV-D-36 and IV-D-63 suggest defining "HAP
emitted" to exclude materials in ink such as phthalates which are
not emitted.
Commenter IV-D-49 suggested changing the capture efficiency
definition to provide that HAP must reach the inlet of the
control device, not just be directed towards it.
Commenter IV-D-49 suggested including a de minimis in the
definition of research and development.
Commenter IV-D-54 recommended defining rotogravure printing
to exclude single uniform coatings over the length and width of
the substrate. Commenter IV-D-61 recommended including a
definition of "off-line rotogravure coating".
Response: The definitions of HAP applied and HAP used have
been clarified. The standards including the equations used to
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demonstrate compliance and the definitions of the variables used
in those equations are expressed in terms of "HAP used" for
publication rotogravure and "HAP applied" for product and package
rotogravure and wide-web flexographic printing.
The definition of "month" in the final rule has been changed
to include prespecified periods of 28 to 35 days.
Organic volatile matter encompasses a wider range of
materials than VOC which excludes exempt solvents and is subject
to change in the future. The standard has been written based on
organic volatile matter. The compliance procedures, and the
equations for demonstrating compliance are consistent with the
definitions of the variables used in the equations. Affected
source is defined for the purposes of this standard in §63.821.
A definition of facility has been added.
The standard for product and packaging rotogravure and wide-
web flexographic printing includes a revised description of
affected source to include all product and packaging rotogravure
and wide-web flexographic presses at the facility (with certain
exceptions). Facility-wide definition of affected source
provides flexibility in choosing how to comply with the rule.
The final standard does not provide for compliance on the basis
of emission units because this is much more difficult to enforce
and will result in minimal additional HAP control.
The procedures for compliance demonstration are written so
as not to require a separate definition of HAP control
efficiency. Equation 1 in §63.824 has been rewritten to clarify
that volatile matter recovery efficiency can be assumed to be
equivalent to organic HAP recovery efficiency. The extent to
which phthalates and other organic HAP are retained on the
printed substrate has not been established. These compounds may
be emitted under some circumstances, thus they have not been
excluded through a definition of HAP emitted.
In the final rule, the definition of capture efficiency has
been clarified. The commenter was correct that the intent of
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this definition was that captured HAP must be delivered to the
control device.
In the final rule, the definition of research or laboratory
facility is based on the definition in Section 112(c)(7) of the
CAA. The EPA does not have sufficient information that "de
minimis manner" could be defined for this source category.
Definitions of "coating operation" and "stand-alone coating
equipment" have been added to clarify the scope of the rule.
2.10 REPORTING
Comment: Two comments were received requesting
clarification that only reports applicable to the specific
control strategy employed were required. Commenter IV-D-1
suggested that the rule require only applicable reports.
Commenter IV-D-15 requested explicit exemption from initial
notification, performance test notification, and performance test
reporting for sources complying by means of liquid-liquid mass
balances.
Commenters IV-D-1 and IV-D-36 suggested synchronizing the
required semi-annual reports with required Title V reporting.
Three comments were received requesting the elimination of
redundant reporting requirements. Commenters IV-D-36 and IV-D-63
suggested eliminating HAP usage reporting requirements if this
was already a condition of the State operating permit.
Commenter IV-D-50 suggested that the requirement for an annual
statement of compliance was redundant with other General
Provisions requirements.
Five comments were received regarding the initial
notification requirements. Commenters IV-D-37 and IV-D-39
suggested extending the notification period from 120 to 180 days
because 120 days is insufficient for notification, guidance and
resubmission. Commenter IV-D-79 recommended extending the
initial notification period to 270 days. Commenter IV-D-53
requested language in the rule to indicate that the Title V
application constitutes initial notification. Commenter IV-D-49
requested that area sources be required to submit initial
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notifications so that the States will know who they are and what
they are doing.
Commenters IV-D-1 and IV-D-53 suggested requiring reporting
of "HAP emitted" rather than "HAP used". Commenter IV-D-51
requested that sources meeting the requirements of §63.821(a)(2)
of the proposed rule be allowed 60 days rather than 30 days for
reporting of annual HAP usage because of delays expected as a
result of required testing methods. Commenter IV-D-54 suggested
exempting affected sources that do not use HAP from all reporting
other than an annual statement to this effect.
Commenter IV-D-54 suggested clarifying that only an estimate
of HAP use is required for the period 12 months prior to
notification, because no records will be available based on the
required test methods.
Commenter IV-D-4 feels that reporting requirements should be
reduced for flexographers (relative to rotogravure printers) so
that the cost of reporting is in line with the expected emission
reductions. Commenter IV-D-25 feels that the reporting
requirements are excessive and may be in violation of the Federal
Paperwork Reduction Act. Commenter IV-D-81 recommended
eliminating reporting for area sources that are distinctly below
the 10/25 threshold and requiring only on-site recordkeeping.
Commenter IV-D-81 suggested eliminating all reporting
requirements except for an annual certification.
Commenter IV-D-81 suggested eliminating the requirement for
documentation of deviations from the startup, shutdown, and "
malfunction report except when the standard is not met as a
consequence of the deviation.
Commenter IV-D-88 suggested delegating the authority to
require reports to the permitting authority.
Response: Reports required under §63.830(b)(6) of the
revised rule are to be submitted as applicable. In accordance
with §63.10(e)(3)(i) of the General Provisions, reportable excess
emissions and parameter exceedances are defined in §§63.824-825
of the revised standard.
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Section 63.10(a)(5) of the General Provisions applies to
this standard. This section provides that the dates by which
periodic reports shall be submitted can be changed to be
consistent with the State's schedule (without changing the
frequency of reporting) by mutual agreement between the owner or
operator and the State. Procedures governing the implementation
of this provision are specified in §63.9(i) of the General
Provisions.
HAP as defined under different State air toxics control
programs may not coincide with HAP listed in §112(b) of the CAA,
therefore HAP usage reporting requirements may not be redundant
and have been retained. The requirement for an annual statement
of compliance has been retained; however -the standard does not
preclude submission of this statement as part of, or in
conjunction with, a periodic report.
Initial notification is essential for the enforcement of the
standard, as it alerts permitting authorities to the presence of
affected sources. Initial notification requirements for existing
sources have been extended until one year before the compliance
date. This will allow potential sources more time to determine
whether they are subject to the standard and will have no adverse
impact on HAP emissions. Conditions under which an application
for a Title V permit or a Part 70 permit may be construed as
initial notification are stated in the final rule. In addition,
an application for approval of construction or reconstruction
under §63.5(d) of the General Provisions can be used to fulfill
notification requirements. The applicability of the standard and
all reporting requirements, including initial notification, is
limited to facilities defined in §63.820(a). Sources which use
the provisions of this standard to establish area source status
are required to submit initial notifications. Sources which use
other mechanisms to establish area source status must comply with
the conditions of those mechanisms. This standard does not limit
the authority of a State to require initial notification from
area sources under State laws.
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The requirement to include, in the initial notification, the
amount of HAP used by existing sources in the 12 months preceding
the notification, has been eliminated from the final rule to make
it consistent with the General Provisions and to decrease the
reporting burden.
Facilities meeting the requirements of §63.820(a)(2) are
required to submit annual HAP usage reports no later than 30 days
after the end of the 12-month reporting period. Sources seeking
to comply by means of this provision are required to determine
HAP usage for each 12-month period (i.e., to make a determination
each month and add it to the amount for the preceding 11 months).
The EPA feels that 30 days is sufficient time to make this
determination for the last month in the 12-month reporting
period, do the summation, and submit the report. The General
Provisions §63.9(i) (2) provide a means by which an owner or
operator can request an extension.
Affected sources that do not use HAP may comply on a
facility-wide basis under §63.825(b)(1). Recordkeeping
(including records demonstrating that inks and other materials do
not contain HAP) is essential to ensure compliance. Alternately,
affected sources that do not use HAP may use the provisions of
§63.820(b) to simplify recordkeeping and avoid all routine
reporting.
The standard for wide-web flexography is equal to that for
product and packaging rotogravure. Equal reporting requirements
are necessary to ensure compliance with the standard. The
reporting requirements specified in the General Provisions as
well as the additional requirements proposed in this subpart have
been reviewed in accordance with the Paperwork Reduction Act and
an Office of Management and Budget control number has been
issued. Sources using the provisions of the rule to establish
area source status are subject to reporting requirements only in
cases where the area source commitment is not met. The EPA feels
that the reporting requirements in the final rule are the minimum
necessary to ensure compliance with the standard. These reports
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alert the permitting authority to excess HAP emissions,
malfunctioning or improperly operated capture, control and
monitoring equipment, and unapproved startup, shutdown, and
malfunction procedures.
The purpose of the startup, shutdown, and malfunction plan
is to ensure compliance with the standard. Documentation and
reporting of deviations from the startup, shutdown, and
malfunction plan is essential to allow the permitting authority
to determine when violations of the standard may have occurred.
States may use the provisions of §112(1) of the CAA to
obtain a partial or complete delegation of the Administrator's
authorities under this standard.
2.11 LEVEL OF CONTROL FOR PRODUCT AND PACKAGING ROTOGRAVURE AND
WIDE-WEB FLEXOGRAPHIC PRINTING AFFECTED SOURCES
Comment: Eight comments were received which support the
level of control specified in the rule. Commenters IV-D-1,
IV-D-36, IV-D-53, and IV-D-55 support the proposed standard.
Commenter IV-D-4 stated that catalytic oxidizers can regularly
obtain destruction rates of 99 percent and, thus, considered the
standard appropriate. Commenter IV-D-7 stated that 95 percent
overall control efficiency is achievable and that catalytic
oxidizers can reach 98 percent destruction efficiency.
Commenter IV-D-36 stated that catalytic oxidizers can obtain
98 percent and higher control device efficiency.
Commenter IV-D-25 stated that 95 percent overall control
efficiency is achievable and common.
Eight comments were received questioning the determination
of the MACT floor. Three commenters (IV-D-15, IV-D-40, and
IV-D-50) stated that the MACT calculation was biased because
point (test) data were used rather than ranges of operating
conditions. Commenter IV-D-50 stated that the database was
adequate if the control equipment is required to pass a test at
95 percent but not consistently meet this standard.
Commenter IV-D-15 felt that the data base used was too small
relative to the size of the industry. Commenter IV-D-61 stated
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that the MACT floor is not supportable for facilities with
ancillary printing because the database used was not
representative of this type of facility. Commenters IV-D-50 and
IV-D-84 stated that it is inconsistent to regulate publication at
92 percent overall control efficiency and expect 95 percent from
packaging rotogravure because the technologies are similar.
Commenter IV-D-38 stated that actual emissions rather than
potential to emit were used to determine which sources were
included in the MACT floor determination and that this biased the
determination.
Commenter IV-D-4 stated that it is inappropriate to group
flexography with rotogravure and that flexography should be a
separate subcategory.
Commenter IV-D-82 stated that the database did not
adequately represent the decorative foil segment of the
rotogravure industry and that these facilities should be exempt
from the standard.
Response: Many of the data upon which the MACT floor
determination were based, were in fact, the most recent onetime
test data available. These data are consistent with the final
standard. Owners or operators choosing to comply through the use
of control equipment may conduct an initial performance
demonstration to establish the efficiency under test conditions.
During the initial performance test, operating parameters are
also established. The owner or operator must then maintain those
operating parameters. The standard does not require owners or
operators complying in this way to continuously demonstrate the
control efficiency. They must, however, continuously monitor the
operating parameters (typically oxidizer temperatures and a
parameter indicating that the capture system is operating in an
equivalent manner to its operation during the performance test).
Owners or operators may also comply through the use of continuous
emission monitors, and where solvent recovery systems are used,
through monthly liquid-liquid material balances.
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The database contained a substantial proportion of sources
which will be affected by the standard, and the EPA, in
cooperation with industry associations, expanded it to the
greatest extent possible. The database included lines which had
both printing stations and coating stations. The control
techniques for ancillary printing equipment and coating lines are
the same as those for product and packaging rotogravure and wide-
web flexographic presses. The final rule does provide owners or
operators with the option of excluding ancillary printing
equipment from the affected source. Such equipment, if excluded
from this standard, will be subject to the appropriate source
category standard when such a standard is issued.
The comparison between the standard for publication
rotogravure and the standard for product and packaging
rotogravure and wide-web flexography is not valid. Publication
rotogravure sources must achieve a minimum of 92 percent overall
efficiency each and every month. In order to meet this standard,
average overall efficiencies are likely to be substantially
higher. Product and packaging rotogravure and wide-web
flexography sources are required to demonstrate 95 percent
overall efficiency under test conditions, establish operating
parameters during the test, and maintain those operating
parameters. This is not, necessarily, equivalent to achieving
95 percent overall efficiency on a monthly average, each and
every month. In both cases, the form of the final standard was
consistent with the database used to develop that standard.
Actual emissions were not used to determine which sources
were included in the MACT floor determination. Rather, potential
emissions were estimated to make this determination. Wide-web
flexography was grouped with product and package rotogravure
because many "hybrid" presses are in operation which include both
rotogravure and flexographic print stations. If a separate
subcategory had been established for flexography, the MACT floor,
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and thus, the standard, for this category would be identical to
*
that established for the combination. The database contains
numerous film and foil printers including sources in the roll
leaf and decorative foil industries. Capture and control
equipment available for use in the decorative foil industry is
similar to that available to the product and package rotogravure
industry in general.
2.12 LEVEL OF CONTROL FOR PUBLICATION ROTOGRAVURE AFFECTED
SOURCES
Comment: Commenter IV-D-7 supported the proposed standard
and stated that control devices can meet the 92 percent overall
efficiency standard.
Commenter IV-D-37 requested that an explicit de minitnis HAP
content be established as a compliance alternative for operation
without a control device. Commenter IV-D-38 requested that
regulatory alternatives more stringent than the MACT floor be
considered.
Response: The de minimis organic HAP content for
publication rotogravure facilities operating without a control
device is eight percent of the volatile matter used. If the inks
used in a month contain less than 0.08 kg organic HAP per kg of
volatile matter (including water), the facility would be in
compliance without a control device. This has been clarified in
§63.824(b)(3).
The EPA believes that, based on facility material balance
data, the standard for existing publication rotogravure
facilities, 92 percent overall control on a facility-wide basis
to be achieved each and every month, will require an efficient
capture system and a state-of-the-art control device. There is
no distinct identifiable technology available to new sources
which would allow them to achieve a more stringent standard.
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2.13 STANDARDS FOR PRODUCT AND PACKAGING ROTOGRAVURE AND WIDE-
WEB FLEXOGRAPHIC PRINTING AFFECTED SOURCES
Comment: Seven commenters (IV-D-1, IV-D-15, IV-D-17,
IV-D-36, IV-D-51, IV-D-53, and IV-D-63) suggested revising the
standard to allow the use of control devices to meet the low-HAP/
materials applied standard.
Four commenters (IV-D-1, IV-D-36, IV-D-53, and IV-D-63)
noted an error in §63.825 (f) (5) of the proposed rule where the
words "material applied" should have appeared instead of "solids
applied."
Three commenters requested clarification of §63.825(b) (1)
and (2) to reflect that presses applying low HAP materials do not
need control devices. Commenters IV-D-15 and IV-D-51 suggested
addition of the word "and" between the sections.
Commenter IV-D-63 suggested language clarifying that sources need
only comply by one mechanism. Commenter IV-D-51 requested
clarification that a combination of add-on control and reduced
HAP materials will meet the standard, suggesting that the
language in the proposed rule could be interpreted to allow this
only for solvent recovery systems.
Commenter IV-D-53 requested clarification that organic HAP
contents of materials are expressed "by weight."
Commenter IV-D-82 requested a 20 parts per million (ppm)
control device exhaust limit as an alternative to 95 percent
control.
Response: The standard has been revised to allow the use of
control devices to meet the low-HAP/materials applied limitation.
The revised standard has been clarified to enumerate the
different ways in which a source can comply and make it clear
that only one means of compliance is necessary. The error in
§63.825(f)(5) of the proposed regulation has been eliminated from
the final regulation. The final regulation permits the use of
control devices (not restricted to solvent recovery systems), as
well as a combination of control devices (not restricted to
solvent recovery systems) and low-HAP materials to comply.
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The final regulation provides for compliance on an affected
source-wide basis. Control devices are not required on presses
applying low-HAP materials provided that the affected source
achieves compliance by one of the mechanisms listed in §63.825.
The variables in the equations used to determine compliance
are defined in §63.822. The units given in the definitions in
both the proposed and final rule establish that the organic HAP
contents of materials applied are expressed "by weight."
Affected sources may comply on the basis of HAP emitted/material
applied, HAP emitted/solids applied, or HAP emitted relative to a
calculated allowable mass emission level based on materials
applied and solids applied, or overall control efficiency.
Affected sources complying on the basis of overall control
efficiency may demonstrate 95 percent control under "test
conditions" and then maintain the appropriate control device
operating parameters. Affected sources operating solvent
recovery systems may demonstrate compliance through liquid-liquid
material balances. The actual control device exhaust
concentration would be of interest only for sources complying
through the use of continuous emissions monitors across the
control device. Compliance on the basis of 20 ppm exhaust gas
concentration would be inconsistent with the database used to
establish the standard, however, it is expected that such sources
would be in compliance and could demonstrate compliance based on
HAP emitted/material applied, HAP emitted/solids applied or
calculated allowable HAP emissions.
2.14 COMPLIANCE FOR PUBLICATION ROTOGRAVURE AFFECTED SOURCES
Comment: Three comments were received on provisions for
compliance by liquid-liquid mass balance. Commenters IV-D-38 and
IV-D-49 requested clarifying the procedure for accounting for
recovered mixtures of HAP and non-HAP volatile matter.
Commenter IV-D-15 requested explicit acknowledgement that
recovered solvent can be assumed to contain the same fraction of
HAP as the volatile matter present in the ink.
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Response: The final rule includes this provision in
§63.824(b). In practice, the recovery efficiencies of organic
HAP and non-HAP organic volatile matter are equivalent for the
solvent blends used in the publication rotogravure industry. The
recovered solvent is reused within the facility and the excess is
sold back to the ink manufacturer for production of more ink.
This is feasible because recovered solvent has the same
composition as the solvent used to manufacture the ink.
2.15 MONITORING
Comment: Seven comments were received regarding the
requirement to measure vent stream flow rates. Commenter IV-D-1
suggested allowing vent stream flow rate to be determined from
fan amperage. Commenter IV-D-36 suggested allowing the use of
fan indicators, fan rotation indicators, or press interlocks and
allowing the system to be operated at different rates than those
used for the performance test. Commenter IV-D-63 recommended
allowing other devices, including press interlocks instead of
flow meters. Commenter IV-D-84 suggested requiring only flow
indicators and not press-by-press flow meters.
Commenters IV-D-15 and IV-D-84 suggested allowing alternate
devices for flow measurements when the physical layout does not
permit placement of the flow meter as required in the proposed
rule.
Commenter IV-D-53 suggested eliminating the requirement for
flow rate monitoring because it has no relevance in the
converting industry. Commenter IV-D-51 stated that flow
monitoring is useless, except for sources complying by means of
continuous emissions monitoring.
Three comments were received concerning thermocouple
requirements for monitoring oxidizers. Commenter IV-D-15
suggested eliminating the requirement for routine thermocouple
calibration or replacement. Commenter IV-D-36 stated that
thermocouples are difficult and expensive to calibrate and that
the act of recalibration may increase the likelihood of system
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failure. Commenter IV-D-54 stated that the required thermocouple
accuracies are unnecessarily strict and requested limits of
two percent or _+ 1 degree Celsius. Commenter IV-D-54 also
suggested providing flexibility for the thermocouple location.
Three comments were received suggesting alternatives to
continuous monitoring. Commenter IV-D-14 suggested allowing
initial capture and control tests, weekly recording of materials
usage, and monthly reduction to emission rates, as well as
continuous temperature monitoring for oxidizers. No additional
testing should be required unless the permitting authority thinks
it is necessary. Commenter IV-D-25 suggested requiring control
equipment tests every three years plus measurements of
temperature rise (across catalytic oxidizers) and pressure
differential, and eliminating burdensome three hour period
temperature monitoring requirements. The commenter stated that
most State and local EPA officials prefer this approach.
Commenter IV-D-25 also suggested exempting sources with permanent
total enclosures from monitoring with a requirement for a
performance test every three years. Commenter IV-D-25 also
recommended exempting sources with presses interlocked to control
device operating parameters from testing and monitoring
requirements. Commenter IV-D-36 suggested exempting sources
complying by means of liquid-liquid mass balances from parameter
monitoring requirements.
Commenter IV-D-15 suggested that the rule not specify
performance criteria for solvent recovery system cumulative
recovery measurement instrumentation, and that mass balance
provisions require that water input be measured, but that only
volatile organic matter (and not water) be recovered and
measured.
Commenters IV-D-36 and IV-D-63 suggested eliminating
startup, shutdown, setup, rewebbing and changeover periods from
temperature monitoring requirements.
Commenters IV-D-36 and IV-D-63 requested guidance on the
selection of the capture system parameter. Commenter IV-D-49
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suggested requiring continuous monitors under §63.824(b) (1) (ii)
of the proposed rule to assure that the capture efficiency is the
same as the capture efficiency determined during the performance
test.
Two comments were received regarding performance tests and
the establishment of oxidizer operating parameters. Commenter
IV-D-49 suggested conducting performance tests under both high
load and low load conditions and suggested that required oxidizer
operating parameters be established based on worst-case (i.e.,
shortest retention time and lowest temperature) conditions.
Commenter IV-D-84 suggested requiring performance testing under
normal, as opposed to maximum, conditions.
Commenter IV-D-82 stated that it would- be more practical to
require averaging of operating parameters over 24 hours (instead
of three hours) because frequent short jobs and changeover
periods would make it difficult to calculate averages over the
applicable time periods.
Commenter IV-D-51 suggested that excursions in operating
parameters should not be considered violations, but only trigger
a potential request to re-test the control system from the
permitting agency. Commenters IV-D-16 and IV-D-36 recommended
more flexible monitoring requirements with exceedances triggering
a maintenance response as defined in a standard operating
procedure. Excessive malfunctions could trigger a stack test
request by the State.
Two comments were received concerning delegation of
authority. Commenter IV-D-39 suggested delegating all monitoring
approval to the permitting authority. Commenter IV-D-39
suggested delegating approval of operating parameters to the
permitting authority.
Commenter IV-D-36 suggested that monitoring equipment
accuracy not be specified in the rule but be held at
manufacturers specified level and stated that auditing of
continuous emission monitors would be difficult.
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Commenters IV-D-36 and IV-D-53 suggested removing all
i
monitoring requirements from the rule until the EPA formulates a
new monitoring rule.
Response: The final regulation includes alternatives to the
vent stream flow rate measurement requirement. Owners or
operators of product and packaging rotogravure and wide-web
flexographic presses with intermittantly-controllable work
stations may, as alternatives to measuring vent stream flow rate,
install flow indicators on the bypass lines, secure bypass line
valves with locking mechanisms or car seals, continuously monitor
bypass valve position or equip the press with an interlock
preventing operation when the control device is bypassed. These
are acceptable alternatives to vent stream flow rate monitoring
because they ensure that control devices are not bypassed.
Sampling lines for gas analyzers and relief valves needed for
safety purposes are not considered bypass lines for the purposes
of these provisions. Presses that do not have any
intermittently-controllable work stations are not subject to
these provisions.
Accurate temperature monitoring is essential to ensure that
oxidizers are routinely operated at the same efficiency as
demonstrated during the performance test. If temperature
monitoring equipment is not calibrated periodically it is
impossible to ensure continuous compliance with the standard.
The final rule has been changed to clarify that all temperature
monitoring equipment must be installed, calibrated, maintained,
and operated according to manufacturers specifications; and that
the chart recorder, data logger, or temperature indicator (rather
than the thermocouple or temperature sensor) must be calibrated
every three months. In the unlikely event that the type or
layout of the control equipment makes it impossible to reliably
calibrate the temperature monitoring equipment on a periodic
basis, sources may comply through the installation of continuous
emission monitors.
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The final rule has been changed to require thermocouple
accuracies of ± 1 degree Celsius or +. 1 percent of the
temperature being monitored in degrees Celsius. In practice this
provides for an accuracy of ± 2 to eight degrees Celsius which is
well within the accuracy attainable using thermocouples with
analog or digital chart recorders, voltmeters, or data loggers.
The EPA considers that the requirement for locating thermocouples
or temperature sensors "in the combustion chamber downstream of
the combustion zone" or "at the nearest feasible point to the
catalyst inlet," provides adequate flexibility.
Sources operating control devices must monitor an operating
parameter or parameters to ensure that the control device is
operating at the same or higher efficiency as that achieved
during the initial compliance demonstration. As an alternative,
continuous emission monitors may be installed across the control
device and monitored to ensure compliance. In addition, sources
operating control devices, except for those in permanent total
enclosures, must monitor an operating parameter to ensure that
capture efficiency is the same as, or higher than, the capture
efficiency achieved during the compliance demonstration. These
requirements do not apply to sources operating solvent recovery
systems and demonstrating compliance by means of monthly liquid-
liquid material balances. The three hour averaging period for
oxidizer temperature monitoring allows for transient temperature
fluctuations which may occur due to press operating conditions.
If temperatures are consistently maintained above the established
operating parameter levels, then averaging is unnecessary
because, if the temperature is always greater than the operating
parameter, the average temperature will be greater than the
operating parameter.
Monitoring temperature rise across the catalyst bed instead
of the temperature upstream of the catalyst is not expected to
provide any decrease in equipment cost or monitoring and
recordkeeping labor. A source may seek approval of any alternate
monitoring plan. The pressure differential across the catalyst
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bed may not be indicative of performance and may not ensure
continuous compliance. Issues relating to catalytic oxidizer
monitoring are discussed further in Section 2.22.
Sources with permanent total enclosures must maintain the
conditions necessary for a permanent total enclosure. Such
sources are still required to monitor parameters to ensure that
the control device efficiency is equal to or greater than the
efficiency established during the compliance demonstration test.
Presses interlocked to prevent operation when monitoring
parameters are not maintained would meet a stricter standard than
presses maintaining operating parameters on average for every
three hour period, because if the parameters are always
maintained, then clearly they are maintained on average. An
owner or operator seeking to comply by interlocking the presses
to prevent operation at any time when the parameters were not
maintained could satisfy monitoring requirements simply by
monitoring that the interlock system was in good working order
and had not been overridden. Initial compliance testing would
still be required to establish the monitoring parameter levels
which would ensure compliance. Sources complying by liquid-
liquid material balances are exempt from parameter monitoring
requirements.
The data on which liquid-liquid material balances are based
must be accurate to ensure compliance with the standard. The
performance criteria in the final rule are necessary to prevent
generation of erroneous material recovery data. The language in
the final rule has been revised to clarify the standard does not
require instrumentation to be removed from service and shipped to
the manufacturer for calibration and certification. It is
necessary to measure all volatile matter, including water, to
ensure the validity of the organic HAP recovery determination.
Solvent recovery systems are rarely, if ever, used with
waterborne ink systems. Water vapor, if present at significant
levels in the dryer exhaust, could decrease the organic HAP
recovery capacity of the sorbent. If water and water soluble
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organic matter are not measured, the composition of the recovered
volatile matter cannot be determined.
Monitoring during periods of startup and shutdown must be
addressed in the startup, shutdown, and malfunction plan for each
affected source. It is appropriate to require temperature
monitoring during periods of setup, rewebbing, and changeover
because of the potential for emissions during these periods.
Selection of the operating parameter to ensure the proper
operation of the capture system depends on the conditions,
equipment, and layout of each individual site. Under some
circumstances relative pressure measurements, exhaust flow rate
measurements, linear velocity measurement systems at pressroom
intakes, fan amperage, or some combination of these parameters
and/or other parameters might be appropriate. The selection of
this parameter is part of the permit application process.
Continuous emission monitors, along with a measurement of ink
usage could be used to ensure capture efficiency, however, the
final rule does not require the use of continuous emission
monitors because of costs associated with equipment installation,
operation, calibration, and maintenance.
Consistent with the General Provisions, performance testing
is to be conducted under such conditions as the Administrator
specifies to the owner or operator based on representative
performance {i.e., performance based on normal operating
conditions) of the affected source. Since the final rule does
not require owners or operators of catalytic oxidizers to monitor
the temperature downstream of the catalyst, performance testing
under multiple conditions will not be required for the purpose of
establishing a representative downstream operating temperature.
A three hour averaging period has been retained in the final
rule to allow for brief temperature variations which may occur
when presses are switched on or off. A 24 hour averaging period
for operating parameters may be too long to ensure continuous
compliance with the standard, however, individual sources may get
approval for alternative recordkeeping systems. The requirement
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to average parameters over a three hour period will not result in
significantly greater recordkeeping labor than a requirement to
average over 24 hours.
In order to ensure continuous compliance, operating
parameters are established during the performance demonstration
test. If continued operation were permitted during lengthy
periods when operating parameters are not maintained, lengthy
periods of excess emissions might result. Sources have the
option of using continuous emission monitors as an alternative to
monitoring operating parameters. Sources unable to conduct
reliable audits of continuous emissions monitors, as required,
may monitor operating parameters instead of operating continuous
emission monitors.
The permitting authority must approve the selection of
operating parameters. Owners or operators may request approval
of an alternative monitoring method (and corresponding
recordkeeping system) under §63.8(f) of the General Provisions.
The final rule contains specifications for the accuracy of
thermocouples used to monitor control device efficiency and
measurement equipment used to collect data for liquid-liquid
material balances. Equipment meeting these specifications is
readily available and has been in use for many years. Owners or
operators choosing to demonstrate compliance by means of
continuous emission monitors must select, install, operate, and
maintain monitors which are capable of being audited to ensure
compliance with the standard.
Monitoring is required to ensure continuous compliance with
the rule. Owners or operators using capture systems and control
devices would be unable to certify compliance with the standard
without monitoring data.
2.16 COMPLIANCE DATES FOR NEW SOURCES
Comment: Seven comments were received concerning the
triggering of new source compliance deadlines as a result of
adding new equipment. Six comments (IV-D-15, IV-D-36, IV-D-51,
IV-D-60, IV-D-63, and IV-D-84) involved the addition of new
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presses to common control systems. Commenters IV-D-15, IV-D-51,
and IV-D-63 suggested that the addition of new presses to
affected sources should not render the entire facility
(publication) or group of commonly controlled presses (package
and product) a new source. Commenters IV-D-36 and IV-D-84 stated
that this would make it impossible to comply with "shelf life
certification requirements." Commenters IV-D-36 and IV-D-60
stated that this would make it impossible to take advantage of
the three year period to convert to low HAP materials.
Three commenters (IV-D-17, IV-D-36, and IV-D-63) felt that
addition of a new station to a product and packaging press should
not render the entire press a new source and that the new station
should comply separately as a new affected source.
Commenter IV-D-53 requested clarification of whether the
addition of a new inline coating station or outboard deck makes
the line a new source.
Response: The final rule provides that reconstructed
sources must meet the compliance date established for new
sources. Addition of one or more presses to an existing facility
would not trigger the new source compliance date unless the
additions were extensive enough to constitute a reconstruction.
Addition of a new inline coating station or outboard deck to an
existing facility would not trigger the new source compliance
date unless the additions were extensive enough to constitute a
reconstruction. Since the final rule considers the affected
source for product and packaging rotogravure and wide-web
flexographic printing facilities to be all of the presses located
at the facility (subject to certain exclusions given in §63.821)
addition of a single press to an existing facility, or addition
of one or more stations to an existing press would not
necessarily constitute a reconstruction of the facility.
Furthermore, §63.826(c) excludes the costs associated with
purchase and installation of air pollution control equipment from
the determination of whether a facility has been reconstructed,
consistent with the EPA's general policy regarding the cost of
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control equipment (59 FR 12421). Costs of modifying equipment to
*
make it compatible with low HAP ink formulations that will be
used to meet the requirements of this rule are also excluded from
this determination.
2.17 COMPLIANCE DATES-GENERAL ISSUES
Comment: Commenter IV-D-39 suggested that the final
compliance date should be 30 days after final action by the EPA
on the Section 112(1) equivalency request, provided the request
is submitted within one year of promulgation. This will avoid
the requirement for sources to comply with dual State/Federal
regulations.
Commenter IV-D-82 requested a longer compliance deadline for
facilities with oxidizers presently meeting reasonably available
control technology (RACT) because costs will be very high to
obtain only marginal emission reduction.
Response: The CAA requires existing sources to comply no
later than three years after promulgation, regardless of RACT
rules. Facilities with oxidizers may still take advantage of the
compliance options in the rule, including the use of low-HAP
materials. The final rule provides flexibility for owners or
operators to comply through the use of control devices, through
the use of low-HAP materials, or through a combination of these
means.
The EPA determined that a three year compliance deadline for
existing sources was appropriate based on the length of time
required for sources complying through the use of upgraded
capture and control equipment to design, gain approval for,
contract for, retrofit, and test the additional equipment. A
compliance deadline of 30 days after approval of a Section 112(1)
request could be less than three years from promulgation and
might be inadequate. Section 63.10(a)(5) of the General
Provisions applies to this standard. This section provides that
the dates by which periodic reports shall be submitted can be
changed to be consistent with the State's schedule (without
changing the frequency of reporting) by mutual agreement between
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the owner or operator and the State. Procedures governing the
implementation of this provision are specified in §63.9(i) of the
General Provisions.
New sources are required to comply on startup or on the date
of promulgation, whichever is later. An operating permit could
not be granted to a new source that was not capable of complying
during the period between promulgation or startup and the
approval of a Section 112(1) program.
2.18 HAP CONTENT DETERMINATION
Comment: Ninety-six comments were received stating that
they would prefer to use formulation data rather than Method 311
because the formulation data are more accurate and less
burdensome. Commenter IV-D-4 requested that Method 311 be
evaluated before becoming a requirement. Commenter IV-D-79
expressed concern about Method 311 and referred to comments
submitted on the Wood Furniture standard.
Three commenters (IV-D-1, IV-D-6, and IV-D-63) recommended
that manufacturers formulation data be accepted providing that
all HAP in excess of 0.1 percent by weight are listed.
Commenter IV-D-36 states that the provision in the proposed wood
furniture standard, (i.e., formulation data with a one percent
de minimis, 0.1 percent for Occupational Safety and Health Act
carcinogens plus a demonstration that there is no release of HAP
cure products) would be acceptable. Commenter IV-D-62 presented
comparative analytical data from Method 311 analyses of furniture
coatings containing some of the HAP of concern and found very
poor interlaboratory reproducibility. They further stated that
they were unable to recommend a suitable method and that the
chemical industry had never been able to develop a suitable
method. They suggested using formulation data and a
1/0.1 percent de minimis. Commenters IV-D-52 and IV-D-53
suggested a 1/0.1 percent de minimis. Three additional
commenters (IV-D-15, IV-D-21, and IV-D-59) recommended a
one percent de minimis.
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Commenter IV-D-28 recommended establishing a de minimis
level consistent with SARA 313 requirements. Four commenters
(IV-D-25, IV-D-50, IV-D-51, and IV-D-82) suggested use of MSDS or
other available information to avoid prohibitive analytical
costs.
Three commenters (IV-D-1, IV-D-53, and IV-D-63) suggested
changing the wording and requiring HAP content to be determined
rather than identified. This would allow printers to rely on
data from ink manufacturers.
Commenter IV-D-14 stated that Method 311 is likely to be
acceptable and suggested the use of American Society for Testing
and Materials (ASTM) D3432-80 for toluene diisocyanate, if
necessary. Commenter IV-D-15 recommended using SW 846 methods
(specifically direct injection capillary gas chromatography (GC)
methods) instead of Method 311. Commenter IV-D-39 suggested the
use of ASTM E260-91. Commenter IV-D-36. recommended changing
Method 311 by modifying the quality assurance/quality control
procedures to reflect the use of capillary columns, eliminating
matrix spikes, eliminating chain of custody procedures for on-
site analyses, and allowing alternatives to dimethylformamide.
These changes were expected to save a large ink manufacturer an
estimated $70 million per year. Commenter IV-D-66 conducted
Method 311 and found an 18 percent error with a known standard of
butyl cellosolve and a 14 percent error with a known standard of
methanol.
Commenter IV-D-6 manufactures 70-80 batches of ink per day
and estimates a cost of $500 per sample leading to a minimum
annual cost of $8.4 million. Commenter IV-D-17 estimated that a
medium sized printer would spend $750,000 per year doing
Method 311 on 1000 formulas. Commenter IV-D-28 estimated annual
costs of $4.5 million annually for one plant and $216 million
annually company-wide. Commenter IV-D-21 estimated that a small
ink manufacturer would incur costs of $5 million to $10 million
per year plus a $30,000 capital expenditure in conducting ink
analyses. Commenter IV-D-33 estimated costs at $2 million to
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$3 million if they must analyze press ready inks which have been
diluted only with non-HAP materials. Commenter IV-D-51 estimated
ink analysis costs of up to $7.5 million per year for a typical
printer. Commenter IV-D-52 stated that the failure to specify a
de minimis penalizes analysts with sensitive equipment.
Analytical costs for their ink company would be $21-$77 million
for initial analysis.
Three commenters (IV-D-6, IV-D-21, and IV-D-59) stated that
the requirement to conduct Method 311 would interfere with their
typical short lead time order/delivery schedule.
Commenter IV-D-15 suggested including provision for a
facility to concede that organic volatile material is 100 percent
HAP and avoid the need for an analysis. Commenter IV-D-38
recommended that redetermination not be required when solvents
are switched, if a worst case calculation demonstrates no
increase in HAP content.
Commenter IV-D-39 recommended allowing State and local
agencies flexibility to determine the appropriate analytical
methods.
Response: The final regulation retains the use of
Method 311, as modified and promulgated with the final rule for
wood furniture coating. The Method allows the use of any
analytical system employing GC provided that the prescribed
quality control, calibration, and method performance requirements
are met. The Method has been revised to include a simplified
calibration procedure. The Method has also been revised to
permit the use of recording integrators as alternatives to strip
chart recorders, digital flow meters as an alternative to soap
film meters, and the use of solvents other than
dimethylformamide. Revisions made to Method 311 prior to the
promulgation of Method 311 are consistent with the apparatus and
methodologies suggested by the commenters.
The final regulation also permits printers to rely on
formulation data provided that it meets certain requirements.
Formulation data provided by suppliers of inks and other
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materials can be used if all organic HAP which is present at a
level of 0.1 weight-percent or greater in any raw material used
in the formulation is accounted for. In the event of any
inconsistency between the EPA Method 311 test data and a
facility's formulation data, that is, if the EPA Method 311 test
value is higher, the Method 311 test data shall govern, unless
after consultation, an owner or operator demonstrates to the
satisfaction of the enforcement authority that the formulation
data are correct.
It should be noted that, for most organic HAP, the de
minimis concentration for formulation data used for compliance
with the final rule is lower than the de minimis concentration
for MSDS. This lower"de minimis is necessary because the
compliance options for package and product rotogravure and wide-
web flexographic printing include the use of materials which
contain less than four weight-percent organic HAP. A de minimis
of one percent organic HAP might not be stringent enough to
ensure compliance under some materials averaging strategies, and
could result in less stringent requirements for overall control
device efficiency.
The final rule includes provisions by which owners or
operators may determine the volatile matter content of materials
and use this value in lieu of the organic HAP content for all
compliance purposes. Owners or operators choosing to comply in
this way would not be required to conduct Method 311
determinations.
2.19 METHOD 24/24A
Comment: Nine comments were received (IV-D-6, IV-D-15,
IV-D-21, IV-D-28, IV-D-36, IV-D-51, IV-D-52, IV-D-53, and
IV-D-63) requesting that formulation data be considered as an
alternative to Methods 24 and 24A. Commenter IV-D-28 estimated
costs of $250 per sample leading to $1.2 million for one plant
and $59 million company-wide. Commenter IV-D-36 estimated that
formulation data with random verification by 24/24A would save
$250-$300 per sample. Commenter IV-D-52 estimated costs of $3.5
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to $7 million if they cannot use formulation data instead of
Method 24/24A.
Response: The final rule provides that printers may rely on
the results of formulation data or Method 24/24A testing
conducted by suppliers of ink and other materials. The owner or
operator must adjust these data as required to account for the
addition of dilution solvents at the printing facility. In the
event of any inconsistency between the EPA Method 24 or 24A test
data and a facility's formulation data, the test data shall
govern, unless after consultation, an owner or operator
demonstrates to the satisfaction of the enforcement authority
that the formulation data are correct.
2.20 OXIDIZER TERMINOLOGY
Comment: Four commenters (IV-D-1, IV-D-36, IV-D-53, and
IV-D-63) suggested using the term oxidizer instead of incinerator
to distinguish vapor control devices from solid waste combustors.
Response: The final rule has adopted the term oxidizer for
these control devices.
2.21 COMPLIANCE DEMONSTRATION-GENERAL ISSUES
Comment: Commenter IV-D-51 requested that §68.827(c) (2) (ii)
of the proposed rule be rewritten to include flexographic presses
which were inadvertently omitted.
Four commenters (IV-D-1, IV-D-36, IV-D-53, and IV-D-63)
recommended allowing the use of existing test data in lieu of an
initial compliance demonstration as compliance tests are very
expensive and duplication of effort should be avoided.
Commenter IV-D-36 requested explicit language that VOC control
efficiency can be used in lieu of HAP control efficiency and that
existing VOC test data can be used for initial compliance
demonstration. This provision could save $20,000-$25,000 per
test. Commenter IV-D-25 suggested applying VOC destruction test
data to the HAP/VOC ratio from MSDS to determine HAP emissions.
Commenter IV-D-84 also requested explicit language that
overall HAP control efficiency is equal to overall VOC control
efficiency. Commenter IV-D-50 endorsed the assumption of HAP
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control efficiency equivalent to VOC control efficiency as
determined by continuous emission monitoring for thermal oxidizer
compliance.
Three commenters (IV-D-15, IV-D-40 and IV-D-53) requested
clarifying §63.825(d) of the proposed rule to make it clear that
a source need demonstrate compliance in only one of the three
possible ways.
Commenter IV-D-54 requested clarification that only the
calculations, recordkeeping, and reports applicable to the chosen
compliance strategy are required.
Commenter IV-D-4 stated that three hour periods for
averaging of operating parameter data may make compliance
difficult. Commenter IV-D-81 recommended that not all
exceedances be considered violations and that some number of
exceedances per reporting period be allowed. Commenter IV-D-50
requests an allowance for monthly variance (comparable to the UST
program) in calculation of HAP/solids ratio for compliance.
Commenter IV-D-15 recommended requiring compliance testing
under conditions reasonably expected rather than maximum
conditions.
Commenter IV-D-36 suggested eliminating non-volatile, non-
emitted HAP such as MDI, TDI, and phthalates from the emission
rate calculation.
Commenter IV-D-36 suggested allowing material-by-material
compliance to achieve either low-HAP or low-solids status at
different times on the same station.
Commenter IV-D-38 requested additional compliance provisions
for sources that do not operate control devices and suggested
that all references to total volatile matter should be changed to
total organic volatile matter or volatile matter less water to
make the standards more stringent.
Response: The final rule has been rewritten to include
wide-web flexographic presses along with product and packaging
rotogravure presses. Wide-web flexographic presses were
inadvertently excluded from this section of the proposed rule.
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The proposal preamble made clear that wide-web flexographic
printing is regulated identically to product and package
rotogravure printing. Provisions by which an owner or operator
may request a waiver of a required performance test are given in
§63.7(h) of the General Provisions. It should be understood that
the initial performance test is used both to establish that the
capture system/control device is capable of meeting the standard
and to establish the values of operating parameters which must be
monitored to ensure continuous compliance with the standard.
Existing performance test data which does not clearly establish
operating parameters for the capture system and the control
device may not be suitable to establish compliance under the
standard. ~
The performance test procedure in §63.827(d) provides for
determination of organic volatile matter control efficiency.
These data can be assumed to be equivalent to organic HAP control
efficiency under most circumstances. Language has been added to
the final rule to clarify this.
The final rule has been revised to clarify that compliance
need be demonstrated under only one compliance option.
Calculations, recordkeeping and reporting applicable to the
compliance option chosen are required. As an example,
calculations, recordkeeping and reporting to ensure control
devices are operating properly are not required of owners or
operators complying without the use of control devices.
Similarly, owners or operators complying by means of solvent
recovery systems are not required to keep records and submit
reports applicable to oxidizers. Owners or operators controlling
emissions through the use of solvent recovery systems and
complying by means of liquid-liquid material balances are not
required to conduct capture tests or monitor capture parameters.
The rule requires continuous compliance. The EPA considers
a three-hour averaging period sufficient to provide for transient
conditions which might occur during changes in press operations.
Longer averaging periods may allow operation with malfunctioning
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or improperly operated capture systems or control devices for
extended periods of time. Periods longer than three hours might
not ensure continuous compliance. Allowing one or more
exceedances per reporting period, or allowing a monthly variance
may not ensure continuous compliance with the standard. Owners
or operators concerned that three-hour parameter averaging
periods are insufficient to avoid false indications of non-
compliance may choose to install and operate continuous emission
monitors. Compliance with the low-HAP/solids or low-
HAP/materials standards must be demonstrated each and every
month. Allowance of a variance would not ensure compliance each
and every month.
The General Provisions require performance test conditions
to be based on "representative performance," that is, performance
based on normal operating conditions. The final rule is
consistent with the General Provisions. Owners or operators
wishing to establish that part of the organic volatile material
is not emitted may request approval of an alternate test method
by the Administrator.
The final rule includes compliance options for product and
packaging rotogravure and wide-web flexographic printing
facilities that allow the use of either low-solids or low-HAP
materials, or a combination of materials, each of which is either
a low-solids or low-HAP material. In addition, an option has
been included in which allowable HAP emissions are calculated
based on the amounts of both types of materials.
Total volatile matter includes water. This definition
encourages the substitution of water for organic HAP and also
encourages the substitution of non-HAP organics for organic HAP.
Eliminating water from the definition of total volatile matter
would discourage conversion to waterborne materials.
2.22 COMPLIANCE DEMONSTRATION FOR CATALYTIC OXIDIZERS
Comment: Nine commenters stated that outlet temperature is
an inappropriate monitoring parameter for catalytic oxidizers.
Comments IV-D-1 and IV-D-17 (same individual) stated that testing
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at maximum loading which would lead to a high downstream
temperature which would be impossible to comply with under
ordinary conditions. Commenter IV-D-16 stated that monitoring
inlet and outlet temperatures does not indicate the activity of
the catalyst and merely wastes natural gas. Commenter IV-D-16
recommended monitoring one temperature and requiring a quarterly
performance test by testing upstream and downstream VOC
concentrations as an alternative to upstream and downstream
temperature measurements. Commenters IV-D-25, IV-D-36, IV-D-53,
and IV-D-63 stated that temperature rise is not indicative of
performance for catalytic oxidizers. Commenter IV-D-49 suggested
monitoring inlet and outlet temperature but only maintaining the
inlet temperature. The outlet temperature would be used to
establish catalyst activity. Commenter IV-D-51 suggested
monitoring only the exit temperature with a requirement for an
annual catalyst test.
Commenter IV-D-81 suggested a 20 ppm exit concentration as
an alternative to the 95 percent overall control requirement.
Response: The final rule requires the establishment of
temperature upstream of the catalyst as an operating parameter to
ensure compliance with the standard. The requirement for
monitoring of downstream temperature was eliminated from the
final rule because failure to maintain this parameter during
times of low volatile organic matter flow rate might lead to
exceedances which incorrectly indicate a failure of the control
device.
2.23 CAPTURE EFFICIENCY DETERMINATION
Comment: Four commenters (IV-D-1, IV-D-53, IV-D-54, and
IV-D-84) recommended allowing a test protocol approved by the EPA
in lieu of the procedure specified in §52.741.
Commenter IV-D-84 suggested allowing demonstration of
capture efficiency by GC analysis every six minutes at the
control device inlet and comparing integrated HAP capture to HAP
use averaging over every one-month period in lieu of a onetime
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test. Analytical and flow rate data were provided as determined
at six-minute intervals for a period of one month.
Response: The EPA has clarified the acceptable capture test
procedures. Section 63.828(e) of the final rule specifies that
the criteria for permanent total enclosures are to be confirmed
in accordance with Procedure T in Appendix B to §52.741. In all
other situations capture efficiency may be determined in
accordance with §52.741(a) (4) (iii) (B) .
The final rule also allows the use of alternate capture
efficiency protocols and test methods which satisfy the criteria
of either the Data Quality Objective or the Lower Confidence
Limit approaches as described in Appendix A of the final rule.
The Procedures T, L, G.I, G.2, F.I and F.2 in §52.741 of
Part 52 were proposed in the Federal Register on August 2, 1995
(60 FR 39297) for addition to 40 CFR 51, Appendix M, as
Method 204 through Method 204E. (See Docket Item IV-I-3.)
Methods 204 through 204E correspond to Procedures T, L, G.I, G.2,
F.I, and F.2 respectively. There are some differences between
the test methods proposed on August 2, 1995 and the procedures in
§52.741 of Part 52. A new method, Method 204F, was also included
in the August 2, 1995 proposal. The changes and the new method
are summarized below.
First, Section 1.4, Sampling requirements, of procedures L,
G.I, G.2, F.I, and F.2 contains a requirement that the sampling
time for each temporary total enclosure (TTE) and building
enclosure (BE) test run should be at least eight hours, unless
otherwise approved. This provision has been revised in the
proposed Methods 204A through 204E to specify that each TTE or BE
run shall cover at least one complete production cycle and must
be at least three hours long. The sampling time for each run
need not exceed eight hours, even if the production cycle has not
been completed. The maximum allowable time for a test run is
24 hours. Alternative sampling times would be subject to EPA
approval.
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Second, a new section on audit sample procedures has been
added to the proposed Method 204A, VOC Input.
Third, the directions for analysis audits have been expanded
(newly added for Method 204A) to include information on audit
sample availability and reporting directions for audit results.
Next, Method 204, Criteria for and Verification of a
Permanent or Temporary Total Enclosure, and Method 204E, VOC
Emissions in Fugitive Stream from Building Enclosures, clarify
the acceptability criteria of a BE and clarify which openings in
a building constitute an exhaust point or a natural draft
opening.
Finally, a new method. Method 204F (called the distillation
approach), has been added for measuring liquid VOC input, as an
alternative to Method 204A.
Although the Procedures L, G.I, G.2, F.I, and F.2 in §52.741
of Part 52; and the Methods 204A through 204F proposed for
addition to 40 CFR 51, Appendix M were developed for TTE and BE
testing, the same procedures and methods can also be used in an
alternative capture efficiency protocol. For example, a
traditional liquid/gas mass balance capture efficiency protocol
could employ Procedure L, proposed Method 204A or proposed Method
204F to measure liquid VOC input and Procedure G.I, or proposed
Method 204B to measure captured VOC.
Additional guidance on capture efficiency testing procedures
is available in the document "Guidelines for Determining Capture
Efficiency" (Docket Item II-B-3). The proposed Methods 204 and
204A through 204F are discussed in this document.
In addition, other test methods may be used subject to
approval in accordance with the General Provisions, §63.7 (f) .
2.24 STARTUP/SHUTDOWN ISSUES
Comment: Commenter IV-D-1 recommended that data collected
during startup and shutdown be disregarded in determining
continuous compliance. Commenter IV-D-36 stated that there are
no emissions expected during startup or shutdown, therefore, only
malfunctions should be addressed and that recordkeeping should
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only be required of planned shutdowns of control devices and
fnalfunctions of control devices.
Response: The required startup, shutdown and malfunction
plan must address procedures to be followed during startup,
shutdown, and periods of malfunctioning capture or control
systems. In cases where the procedures followed are consistent
with those given in the startup, shutdown, and malfunction plan,
no reporting is necessary. The EPA does not agree that there are
no emissions associated with periods of startup and shutdown. As
an example, there is a risk of residual organic HAP in ink
fountains and ductwork escaping directly to the atmosphere or
through the control device during the periods when the control
device is being shut down.
Startup, shutdown, or malfunction of a press or presses need
not be considered as a startup, shutdown, or malfunction of the
affected source if the capture system and control device
continues to function properly. The requirements pertaining to
startup, shutdown, and malfunction plans and reports do not apply
to affected sources which do not use control devices.
2.25 RECORDKEEPING
Comment: Commenter IV-D-4 suggested that recordkeeping
requirements should be reduced for flexographers so that the cost
of recordkeeping is not out of line with the actual benefits.
Commenter IV-D-25 recommended annual accounting rather than
12-month rolling averages as this will afford greater flexibility
for seasonal variations. Commenter IV-D-25 expects that local
EPA officials will require all of the recordkeeping applicable to
major sources, even it the facility does not exceed the major
source threshold.
Commenter IV-D-36 suggested clarifying that specific
recordkeeping requirements are applicable to the control strategy
employed and all facilities are not required to do all
recordkeeping. Commenter IV-D-36 also requested inclusion of a
provision for recordkeeping under a State-approved operating
permit which would eliminate the required materials inventory.
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Commenter IV-D-88 suggested delegating recordkeeping requirement
approval to the permitting authority.
Two comments were received concerning record retention.
Commenter IV-D-39 recommended that records should be retained for
two years or until the next inspection, whichever is longer.
Commenter IV-D-79 recommended requiring records to be maintained
for five years or until six months after a compliance audit or
inspection.
Commenter IV-D-79 suggested that HAP usage recordkeeping
should not be required until two years after promulgation.
Commenter IV-D-81 suggested eliminating recordkeeping
requirements for startup, shutdown, and malfunction events except
when*the plan was not followed and excess emissions occurred as a
result. Commenter IV-D-81 recommended that if a source was
within the defined operating range for a 24 hour period, than no
records other than a notation of "no excursions" should be
required. Commenter IV-D-81 also suggested allowing manual
recordkeeping and permitting readings to be made every four hours
for devices which normally operate at steady state.
Response: Recordkeeping requirements for wide-web
flexographic printing sources are equivalent to those for product
and packaging rotogravure sources or sources that operate both
types of equipment. While flexographic printing, in general,
uses less organic HAP than rotogravure printing, the organic HAP
emitted from flexography are no less hazardous and no more
difficult to account for than an equivalent amount of organic HAP
emissions from rotogravure.
Sources taking advantage of the simplified requirements in
§63.820(a)(2) or §63.821(b) must keep monthly records to
establish eligibility for these provisions. Recordkeeping on an
annual basis might permit violations to exist for as long as
eleven months.
The States have the authority to require additional
recordkeeping if they believe it is necessary. The final
regulation prescribes the minimum recordkeeping requirements that
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the EPA believes are necessary to ensure that sources are
complying with the rule. If recordkeeping requirements to
satisfy State permits include all recordkeeping needed to comply
with the final rule, these records will be adequate. The final
rule makes it clear that a source is responsible for only those
recordkeeping requirements applicable to the compliance option
selected by the source. Additional notes have been added to
Table 1, clarifying the applicable General Provisions.
Section 63.20(b) of the General Provisions requires
facilities to maintain all records, including all reports and
notifications, for at least five years. The requirement that
records be retained for five years is based on the statute of
limitations imposed on the EPA in the GAA and is consistent with
the requirement in other rules, such as the Operating Permits
Rule--Part 70 of Title 40 of the Code of Federal Regulations.
The final rule has been revised to eliminate the requirement
for existing sources to provide HAP usage data for the 12 months
prior to the Initial Notification. This is not required by the
General Provisions. By initial notification, sources will alert
the permitting authority that they are major sources, or that
they are using the provisions of the rule to establish area
source status. The information required by the General
Provisions is sufficient.
The General Provisions, §63.10(b)(v) requires that all
information necessary to demonstrate compliance with the startup,
shutdown, and malfunction plan be maintained. This information
may be recorded using a checklist, or some other effective form
of recordkeeping, in order to minimize the recordkeeping burden
for conforming events.
Records of operating parameter values (e.g., charts or
printouts) must be maintained to demonstrate compliance. The EPA
has determined that three hours is an appropriate averaging
period for operating parameter averaging which will allow for
brief transients when equipment is started up or shutdown.
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Devices that normally operate at steady state may not operate at
steady state during periods of malfunction.
2.26 PRINTING/COATING ISSUES
Comment: Two comments were received with regard to small
amounts of printing conducted on coating lines.
Commenter IV-D-16 requested exemptions for sources regulated as
coil coaters and paper and other web coaters that do small
amounts of printing. They recommend exempting printing
operations that do not exceed major source thresholds and present
a health risk of less than 1 X 1CT6. These operations would be
covered under the appropriate NESHAP when it is developed.
Commenter IV-D-61 requested exemption of facilities with small
amounts of printing conducted on coating lines because the
database on which the standard was developed did not include this
type of facility. Commenter IV-D-61 recommended following
California South Coast Air Quality Management Division (SCAQMD)
Rules 1128 and 1130.
Commenter IV-D-80 recommended a specific exemption for paper
machines and off-line and stand-alone coaters. Commenter IV-D-80
also requested an exemption for hybrid lines that sometimes print
and sometimes coat, or alternately, an exemption for coating
operations conducted on hybrid lines.
Commenter IV-D-53 requested clarification of whether
printing conducted on coating lines is covered by the standard.
Commenters IV-D-36 and IV-D-53 requested clarification of whether
flexo printing on a coating line is included.
Commenter IV-D-51 suggested that off-line coaters using a
common solvent recovery system should be covered at the
discretion of the facility and that in-line coaters that use
dissimilar solvents should not be covered unless connected to a
common control system with printing stations.
Commenter IV-D-4 stated that it is inappropriate to regulate
in-line coating under the printing standard.
Response: The final standard permits the owner or operator
of a product and packaging rotogravure or wide-web
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flexographic printing affected source to choose to exclude
ancillary printing equipment from the affected source. This
equipment is used primarily for coating, laminating, or other
operations besides product and packaging rotogravure and wide-web
flexographic printing. Presses on which five weight-percent or
less of the total material applied each month is applied by
rotogravure or wide-web flexographic print stations would be
subject only to a simplified recordkeeping requirement. The EPA
believes it is appropriate to provide the owner or operator with
the option not to subject these presses to the HAP emission
limitations for product and packaging and wide-web flexographic
printing in §63.825 because the work being done on the
rotogravure and wide-web flexographic print stations on these
presses is ancillary to the work being done on other work
stations (i.e., coating stations) on these presses. The EPA is
separately establishing MACT for other source categories, such as
the paper and other web coating source category and the metal
coil coating source category, which may be more appropriate for
this type of equipment. Ancillary printing equipment, if
excluded from this standard, will be subject to the appropriate
source category standard when such a standard is issued. Coil
coaters, paper and other web coaters, and paper machines may use
this option and comply with the appropriate NESHAP for their
source category when promulgated.
The EPA considers that exclusions based on health risk are
inappropriate for a technology based standard.
California SCAQMD Rules 1128 and 1130 provide that coating
is exempted from other rules (e.g., printing rules). Inclusion
of a provision of this type in the final rule is not appropriate
because a MACT standard for coating has not yet been promulgated.
Provisions have been added to the final rule to exempt incidental
printing operations on coating equipment from all requirements
except simplified recordkeeping provisions.
The standard applies equally to product and packaging
rotogravure and wide-web flexographic printing. Printing
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conducted on coating lines is covered by the standard, although
many of these lines may be eligible for the exclusions described
above. Off-line and stand-alone coaters, on which rotogravure or
wide-web flexographic printing operations are not conducted, are
not covered by the standard (except in some circumstances when
this equipment is eligible for inclusion at the owner or
operator's option). Coating operations conducted in-line with
rotogravure and wide-web flexographic printing operations are
covered by the standard because of the difficulty, in
distinguishing capture and control efficiencies applicable to
printing operations from those pertaining to coating operations.
These operations are covered to prevent situations where the same
equipment is subject to more than one standard.
2.27 STANDARD FOR LITHO AND HEATSET PRINTING
Comment: Commenter IV-D-14 has experience that petroleum
distillate oil used in litho and heatset inks may contain up to
20 percent HAP and requests that these processes be regulated.
Response: Lithographic and letterpress inks are formulated
with petroleum and vegetable oils which have a minimum boiling
point substantially higher than that of any of the organic HAP
present in petroleum oils (such as benzene, toluene, xylene,
ethylbenzene, or hexane), and thus contain little or no HAP. The
commenter's experience is not typical.
2.28 UNITS
Comment: Four commenters requested changes to the way the
materials are accounted for with regard to the low-HAP threshold.
Commenter IV-D-14 stated that pounds HAP per gallon of material
is preferable to kg HAP per kg solids because that is the way
that the printing industry buys and measures ink. Also, weight
units (Ib) are preferable to mass (kg) because correction for
gravitational constants are eliminated. Commenter IV-D-37
requested a standard in "grams per liter of material less water
and exempt compounds" to make this consistent with State
standards and avoid the difficulty of complying with two sets of
standards. Commenter IV-D-39 requested a standard in pounds per
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gallon of material, grams per liter of material and percent by
Volume, in addition to kg HAP per kg solids and kg HAP per kg
material as proposed. Commenter IV-D-79 requested mass/volume
units instead of mass/mass units in expressing the low-solids
standard.
Commenter IV-D-15 suggested eliminating units from the mass
ratios and replacing the constant coefficient in Equation 13 of
the proposed rule (for performance testing) with a generic
coefficient to adjust for different combinations of units which
may be used.
Commenter IV-D-4 requested the use of English units as
printers are familiar with them.
Response: The inclusion of standards based on mass per
volume (pounds per gallon, grams per liter, etc.) units would
have the effect of discouraging the use of high solids ink
formulations, and encouraging the use of additional dilution
solvents. The use of additional dilution solvents might increase
organic HAP usage and is likely to increase energy requirements.
This standard limits emissions of HAP. Existing State
standards defining "compliant materials" in terms of mass per
volume or mass per volume less water control emissions of VOC
which is a much broader category than organic HAP.
Material compositions specified in kg per kg are equivalent
to those specified in pound per pound. Sources may use either
set of units for material compositions. The equation given for
control device efficiency testing is consistent with the
variables as defined in §63.822. Sources conducting performance
tests may use the appropriate conversion factors to calculate the
coefficient which is consistent with their test data.
2.29 GLYCOL ETHERS
Comment: Commenters IV-D-36 and IV-D-63 requested explicit
definition of glycol ether HAP by CAS number rather than the
structural definition in the CAA.
Response,: The definition in the CAA provides explicit
guidance as to whether or not a particular compound is a HAP. In
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theory, many chemical compounds could fit within this definition.
Only a limited number of these compounds are presently in use in
the printing industry, however, a relaxation of the standard
resulting from explicit designation of these compounds might
encourage a shift to other compounds which are HAP as defined in
the CAA. Propylene glycol ethers, butylene glycol ethers, and
pentylene glycol ethers are not HAP, because they do not fit the
description in §112(b) of the CAA.
2.30 SUMMARY TABLE IN REGULATION
Comment: Commenter IV-D-15 recommended eliminating the
Summary Table (Table 1} or adding a disclaimer that it is not
intended as a substitute for the rule, to avoid misinterpretation
of the abbreviated provisions.
Response: Table 1 of the proposed rule has been eliminated
from the final rule.
2.31 GENERAL PROVISIONS CROSS REFERENCE TABLE
Comment: Three commenters requested additional
clarifications to the General Provisions cross reference table.
Commenter IV-D-15 recommended noting that not all provisions are
applicable to every affected source and including notes exempting
sources with Part 70 permits from requirements in §63.5 for
Federal approval.
Commenters IV-D-36 and IV-D-53 requested clarifying notes in
additional table entries indicating that COMS are not required.
Commenter IV-D-53 requested eliminating startup and shutdown from
the startup, shutdown, malfunction plan and just requiring a"'
malfunction plan because emissions are zero or negligible during
startup and shutdown.
Response: The applicability of the General Provisions is
summarized in Table 1 of the final regulation. Additional
clarifying notes have been added to clarify that continuous
opacity monitoring systems are not required. Explicit
requirements for monitoring, performance testing, reporting and
recordkeeping which are applicable to particular compliance
strategies are given in the regulation.
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Sources with Part 70 permits must comply with §63.5 by
obtaining the approval from the permitting authority. A startup,
shutdown, and malfunction plan is required of all sources
operating control devices. The EPA believes that there is a
potential for HAP emissions during the startup and shutdown of
capture systems and control devices.
2.32 VALIDITY OF COST ANALYSIS
Comment: Five comments were received regarding the accuracy
of the cost analysis. Commenter IV-D-16 stated that the cost
analysis is invalid because it did not include coil coaters that
do incidental printing. Commenter IV-D-36 stated that the costs
presented are underestimated because facilities with potential to
emit will have to conduct costly Method 311 analyses.to
demonstrate area source status. Commenter IV-D-51 stated that
costs have been underestimated due to failure to consider the
costs of enhanced monitoring and the costs of accounting to
confirm area source status. Commenter IV-D-53 stated that the
costs and the number of affected facilities have been
underestimated. Commenter IV-D-40 stated that costs have been
underestimated by at least an order of magnitude.
Response: Costs presented in the proposal preamble and BID
were estimates based on the best information available to the
EPA. The accuracy is limited by uncertainty regarding the number
of facilities which will establish area source status in
accordance with the mechanism provided in the final rule or other
available mechanisms, as well as uncertainty regarding the "
particular compliance strategy which will be adopted by affected
sources.
The final rule includes a provision in §63.821(a)(2)(ii) by
which coil coaters that conduct incidental printing operations
can be excluded from the affected source. Owners or operators of
such equipment are subject only to simplified recordkeeping
requirements to establish that they meet the criteria for
exclusion.
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The final rule includes alternatives to Method 311 analyses.
Facilities may establish area source status on the basis of
accurate formulation data obtained from their materials
suppliers.
2.33 INTERCHANGEABILITY OF INK SYSTEMS
Comment: Two comments were received regarding the
interchangeability of solvent and waterborne inks.
Commenter IV-D-36 stated that solvent and waterborne inks may be
interchangeable on some press stations. Commenter IV-D-50 stated
that much of the existing equipment in many facilities is
incompatible with waterborne materials.
Response: The extent of interchangeability of ink systems
varies depending on printing technology, equipment, and
substrate. In general, rotogravure cylinders for solvent based
and waterborne applications are not interchangeable. Some
presses lack adequate drying capacity to operate with waterborne
materials.
2.34 STATE AIR TOXICS PROGRAMS
Comment: Two comments were received on the relationship
between State and Federal Air Toxics Programs. Commenter IV-D-36
requested either elimination of, or a moratorium on, State Air
Toxics Programs to eliminate redundancy. Commenter IV-D-63
prefers State risk-based air toxics programs and recommended the
EPA work with States to develop combined non-duplicative
regulations.
Response: Section 112(d)(7) of the CAA provides that MACT
standards shall not be interpreted to replace standards issued
under State authority.
2.35 ALTERNATE TEST METHODS
Comment: Commenters IV-D-39 and IV-D-54 requested that
approval for alternate test methods be delegated to the States.
Response: The specification of test procedure is an
integral component of the emission standard. Allowing States to
approve different test methods might have the effect of
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implementing standards which are less stringent than the MACT
floor.
2.36 WORK PRACTICE STANDARDS
Comment: Commenters IV-D-39 and IV-D-79 request inclusion
of work practice standards such as keeping ink and clean-up
material container lids closed when not in use.
Response: The EPA does not have sufficient information to
include this requirement. Individual permitting authorities may
require work practice standards as a condition in operating
permits where appropriate.
2.37 INNOVATIVE TECHNOLOGIES
Comment: Commenter IV-D-40 requested provisions for using
innovative technologies such as biological treatment and allowing
for delayed compliance if the innovative technologies do not
succeed.
Response: The standard allows three years for existing
sources to comply. Provisions for requesting an extension of
compliance are given in the General Provisions, §63.7(i).
2.38 DUE PROCESS
Comment: Commenter IV-D-61 stated that sources conducting
incidental printing operations will not have the opportunity to
comment on the proposal because they will not know that they are
covered, particularly since the regulatory text is not published.
Commenter IV-D-81 stated that the EPA must print the proposed
regulation and cites difficulty with conversion of bulletin board
versions of the regulation to Microsoft WORD or WordPerfect "6.1.
Response: The preamble stated that "The proposed rule
addresses facilities which apply ink and other materials to any
substrate, except fabric, using rotogravure or wide-web
flexographic methods." This definition encompasses all
facilities affected by the regulation.
The proposed regulatory text was available for public
inspection and copying in the Air and Radiation Docket at the
time of proposal. In addition, printed copies were available by
written or telephone request to the Air and Radiation Docket.
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The EPA considers that the 75-day period allowed for public
comments included sufficient time for commenters who were unable
to make use of the electronic version of the regulatory text to
obtain a printed copy.
2.39 EXEMPTION FOR NEWLY LISTED HAP
Comment: Commenter IV-D-80 stated that the rule should not
apply to new solvents added to the HAP list after proposal of the
standard.
Response: The EPA believes that the standards in
§§63.824-825 apply to those organic HAP listed pursuant to
§112(b) of the CAA as of the date of proposal (and not
subsequently deleted). The suitability of the available capture
and control technologies considered in determining MACT would be
evaluated before extending the standard to newly listed HAP.
2.40 FEASIBILITY OF MATERIALS SUBSTITUTION
Comment: Commenter IV-D-4 stated that glycols on the HAP
list can be easily replaced with non-HAP materials.
Response: The ease of replacement of glycols and glycol
ethers on the HAP list is expected to vary depending on the
printing technology, substrate, and performance requirements of
the printed material. The final regulation provides a
significant incentive to encourage pollution prevention through
replacement of HAP with non-HAP materials.
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TECHNICAL REPORT DATA
(Please read instructions on the reverse before completing)
1. REPORT NO.
* EPA-453/R-96-005b
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
National Emission Standards for Hazardous Air Pollutants (NESHAP)
for the Printing and Publishing Industry - Background Information
for Promulgated Standards
5. REPORT DATE
May 1996
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Emission Standards Division (MD-13)
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 2771 1
10. PROGRAM ELEMENT NO.
1 1. CONTRACT/GRANT NO.
68-D1-01 18
12. SPONSORING AGENCY NAME AND ADDRESS
Director, Office of Air Quality Planning and Standards
Office of Air and Radiation
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 2771 1
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16, ABSTRACT
A rule regulating hazardous air pollutant emissions from the printing and publishing industry has been promulgated
under the authority of sections 101, 112, 114, 116, 1 83(f), and 301 of the Clean Air Act , as amended in 1990.
The types of printing covered in this rule are publication rotogravure, product and packaging rotogravure and wide-
web flexography. This document presents background information for the promulgated rule including changes made
to the rule since proposal, a summary of public comments received and EPA's response to those comments and a
summary of the national impacts of the rule
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air Pollution
Hazardous Air Pollutants
Printing and Publishing
National Emission Standards
Rotogravure
Flexography
Air Pollution Control
18 DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (THIS REPORT)
Unclassified
21. NO. OF PAGES
84
21. SECURITY CLASS (THIS PAGE)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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