EPA-453/R-95-002a

National Emission Standards for
Hazardous Air Pollutants:

Printing and Publishing Industry
Background Information for
Proposed Standards

Emission Standards Division

U. S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and

Standards

Research Triangle Park, North Carolina

27711
February 1995

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TABLE OF CONTENTS

1.0 INTRODUCTION	1-1

1.1	OVERVIEW	1-1

1.2	PROJECT HISTORY	1-1

1.2.1	Background	1-1

1.2.2	Data Gathering	1-3

1.2.3	Emissions and Control Data	1-4

1.3	REFERENCES	1-4
2.0 THE PRINTING AND PUBLISHING INDUSTRY	2-1

2.1	INTRODUCTION	2-1

2.2	GRAVURE PRINTING	2-2

2.2.1 Publication Rotogravure	2-3

2.2.1.1	Process Description	2-3

2.2.1.2	Profile of the Publication Rotogravure
Segment	2-4

2.2.1.3	HAP Use and Emissions	2-4

2.2.1.4	Baseline Emissions	2-6

2.2.2	Packaging and Product Gravure	2-6

2.2.2.1	Process Description	2-10

2.2.2.2	Profile of the Package/Product

Rotogravure Segment	2-11

2.2.2.3	Hap Use and Emissions	2-11

2.2.2.4	Baseline Emissions	2-20

2.2.3	Intaglio Plate Gravure	2-20

2.3	FLEXOGRAPHY	2-22
2.3.1. Wide Web (and Sheetfed) Flexographic Printing 2-22

2.3.1.1	Process Description	2-23

2.3.1.2	Profile of Wide Web Flexographic Segment 2-23

2.3.1.3	HAP Use and Emissions	2-24

2.3.1.4	Baseline Emissions from Wide Web
Flexographic Segment	2-4 0

2.3.2 Narrow Web Flexographic Printing	2-40

2.4	LITHOGRAPHY	2-41

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2.4.1	Sheet-fed Lithography	2-42

2.4.2	Non-Heatset Web Lithographic Printing	2-42

2.4.3	Heatset Web Lithographic Printing	2-43

2.5	LETTERPRESS	2-44

2.5.1	Non-heatset Letterpress	2-44

2.5.2	Heatset Letterpress	2-45

2.6	SCREEN PRINTING	2-45

2.7	OTHER PRINTING PROCESSES	2-46
2.7 REFERENCES	2-4 6

3.0	CONTROL TECHNOLOGY AND PERFORMANCE OF CONTROLS	3-1

3.1	INTRODUCTION	3-1

3.2	CAPTURE SYSTEMS	3-1

3.2.1	Publication Rotogravure	3-2

3.2.2	Product and Package Gravure	3-2

3.2.3	Wide-web Flexographic Printing	3-3

3.3	CONTROL DEVICES	3-3

3.3.1	Carbon Adsorption	3-3

3.3.2	Thermal Incineration	3-4

3.3.3	Catalytic Incineration	3-4

3.4	PERFORMANCE OF CONTROLS	3-5

3.4.1	Publication Gravure	3-5

3.4.2	Product and Packaging Gravure	3-7

3.4.3	Wide-web Flexographic Printing	3-10

3.5	LOW HAP AND HAP-FREE INKS (AND OTHER MATERIALS)	3-15

3.5.1	Publication Rotogravure	3-16

3.5.2	Product and Packaging Rotogravure	3-16

3.5.3	Wide-web Flexographic Printing	3-17

3.6	REFERENCES	3-19

4.0	MODEL PLANTS, CONTROL OPTIONS, AND ENHANCED MONITORING 4-1

4.1	INTRODUCTION	4-1

4.2	MODEL PLANTS	4-1

4.2.1	Publication Rotogravure Model Plants	4-1

4.2.2	Product and Packaging Gravure Model Plants	4-3

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4.2.3 Wide-web and Sheet Fed Flexocrraphv Model Plants 4-4
4.3 CONTROL OPTIONS	4-31

4.3.1 Control Options for Publication Rotogravure	4-31

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4.3.2	Control Options for Product and Packaging
Rotogravure	4-33

4.3.3	Control Options for Wide-web and Sheet Fed
Flexographv	4-37

4.4 ENHANCED MONITORING	4-3 8

4.4.1	Enhanced Monitoring for Publication Gravure	4-38

4.4.2	Enhanced Monitoring for Product and Packaging
Rotogravure	4-4 0

4.4.3	Enhanced Monitoring for Wide-web and Sheet Fed
Flexographv	4-41

5.0	ENVIRONMENTAL AND ENERGY IMPACTS OF CONTROL OPTIONS	5-1

5.1	ENERGY IMPACT	5-1

5.1.1	Publication Rotogravure	5-1

5.1.2	Product and Packaging Rotogravure	5-2

5.1.3	Wide-web and Sheet Fed Flexographv	5-3

5.2	AIR IMPACTS	5-5

5.2.1	Publication Rotogravure	5-5

5.2.2	Product and Packaging Gravure	5-5

5.2.3	Wide-web and Sheet Fed Flexographv	5-6

5.3	WATER IMPACTS	5-8

5.3.1	Publication Rotogravure	5-8

5.3.2	Product and Packaging Rotogravure and Wide-web

and Sheet Fed Flexographv	5-8

5.4. SOLID WASTE IMPACT	5-8

5.4.1 Publication Rotogravure	5-8
5.4.2 Product and Packaging Rotogravure and

Wide-web and Sheet Fed Flexographv	5-8

6.0	MODEL PLANT CONTROL OPTION COST	6-1

6.1	INTRODUCTION	6-1

6.2	PUBLICATION ROTOGRAVURE	6-1

6.3	PRODUCT AND PACKAGING ROTOGRAVURE	6-16

6.4	WIDE-WEB AND SHEET FED FLEXOGRAPHY	6-2 6

6.5	REFERENCES	6-35

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viii

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LIST OF TABLES

Table 2-1. Publication Gravure Plants 	 2-5

Table 2-2. Packaging/Product Gravure Responses 	 2-12

Table 2-3. Rotogravure Facilities Printing on Paper and

Cardboard	2-14

Table 2-4. Rotogravure Facilities Printing Exclusively on

Foil and Film	2-15

Table 2-5. Rotogravure Facilities Printing Vinyl Products. 2-16

Table 2-6. Rotogravure Facilities Printing on Paper or

Cardboard and Foil or Film	2-17

Table 2-7. Rotogravure Facilities Printing Miscellaneous

Products	2-18

Table 2-8. Baseline Emissions from Product and Packaging

Rotogravure Responses	2-21

Table 2-9. Baseline Emissions from Major Sources in the

Product and Packaging Rotogravure Industries	2-21

Table 2-10. Wide-Web Flexographic Printing Responses. . . 2-25

Table 2-11. Baseline Emissions from Flexographic Printing. 2-41

Table 3-1. Overall Control Efficiencies Reported for

Publication Gravure Plants	3-7

Table 3-2. Overall Efficiencies Reported for Product and

Packaging Gravure Facilities with Control Systems. . . 3-10

Table 3-3. Control Device Efficiencies Reported for

Packaging and Product Gravure Facilities with Control
Systems	3-11

Table 3-4. Overall Efficiencies by Industry Segment for

Packaging and Product Gravure Facilities with Control
Systems	3-11

Table 3-5. Control Devices in Use by Flexographic Printers.

	3-13

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Table 3-6. Overall Efficiencies Reported for Flexographic

Facilities with Control Systems	3-15

Table 4-1. Publication Rotogravure Model Plants	4-2

Table 4-2. HAP Use by Rotogravure Facilities Printing on

Paper and Cardboard	4-5

Table 4-3. HAP Use by Rotogravure Facilities Printing

Exclusively on Foil and Film	4-8

Table 4-4. HAP Use by Rotogravure Facilities Printing Vinyl

Products	4-9

Table 4-5. Model Plant Specifications for Product/Packaging

Rotogravure	4-10

Table 4-6. HAP Use on Flexographic Presses	4-12

Table 4-7. Model Plant Specifications for Flexography. . . 4-30

Table 4-8. Control Options for Publication Rotogravure

Plants	4-34

Table 4-9. Control Options for Packaging and Product

Rotogravure Plants	4-37

Table 4-10. Control Options for Flexographic Printing

Plants	4-40

Table 5-1. Energy Impact of Control Options for Publication

Rotogravure Plants	5-2

Table 5-2. Energy Impact of Control Options for Product and

Packaging Gravure Plants	5-3

Table 5-3. Energy Impact of Control Options for Wide-web

and Sheet Fed Flexography	5-5

Table 5-4. Air Impact of Control Options for Publication

Rotogravure Plants	5-6

Table 5-5. Air Impact of Control Options for Product and

Packaging Rotogravure Plants	5-7

Table 6-1. Publication Rotogravure Model Plant

Specifications Used for Control Option Costing	6-2

Table 6-2. Publication Rotogravure Control Device

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Specifications used for Control Option Costing	6-4

Table 6-3. Capital Costs of Concentrator/Solvent Recovery
Systems for Control Option A at Model Publication
Rotogravure Plants	6-5

Table 6-4. Capital Costs of Concentrator/Solvent Recovery
Systems for Control Option B at Model Publication
Rotogravure Plants	6-6

Table 6-5. Capital Costs of Concentrator/Solvent Recovery
Systems for Control Option C at Model Publication
Rotogravure Plants	6-7

Table 6-6. Capital Costs of Required Solvent Recovery
System Upgrades for Control Option A at Model
Publication Rotogravure Plants	6-8

Table 6-7. Capital Costs of Required Solvent Recovery
Upgrades for Control Options B and C at Model
Publication Rotogravure Plants	6-9

Table 6-8. Capital Costs of Permanent Total Enclosure for
Control Option C at Model Publication Rotogravure
Plants	6-10

Table 6-9. Total Annual Costs for Control Option A at Model

Publication Rotogravure Plants	6-11

Table 6-10. Total Annual Costs for Control Option B at

Model Publication Rotogravure Plants	6-12

Table 6-11. Total Annual Costs for Control Option C at

Model Publication Rotogravure Plants	6-13

Table 6-12. Notes to Control Cost Calculations for Model

Publication Rotogravure Plants	6-14

Table 6-13. Cost Effectiveness of Concentrator Systems for
Incremental Control of Publication Rotogravure Model
Plants	6-15

Table 6-14. Model Plant Specifications for Product and

Packaging Rotogravure	6-17

Table 6-15. Incinerator Specifications for Product and

Packaging Rotogravure Control Options	6-18

Table 6-16. Capital Costs for Thermal Incinerators at Model

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Product and Packaging Rotogravure Plants - Control

Option A	6-20

Table 6-17. Capital Costs for Thermal Incinerators at Model
Product and Packaging Rotogravure Plants - Control
Option B	6-21

Table 6-18. Total Enclosure Construction Costs for Product

and Packaging Rotogravure - Control Option B	6-22

Table 6-19. Total Annual Costs for Thermal Incinerators at
Model Product and Packaging Rotogravure Plants -
Control Option A	 6-23

Table 6-20. Total Annual Costs for Thermal Incinerators at
Model Product and Packaging Rotogravure Plants -
Control Option B	 6-24

Table 6-21. Cost Effectiveness of Control Options A and B
for Incremental Control at Model Product and Packaging
Rotogravure Plants	6-25

Table 6-22. Model Plant Specifications for Flexography. . 6-27

Table 6-23. Incinerator Specifications for Flexography

Control Options	6-28

Table 6-24. Capital Costs for Thermal Incinerators at Model

Flexographic plants - Control Option A	6-29

Table 6-25. Capital Costs for Thermal Incinerators at Model

Flexographic plants - Control Option B	6-30

Table 6-26. Total Enclosure Construction Costs for

Flexographic Plants - Control Option B	6-32

Table 6-27. Total Annual Costs for Thermal Incinerators at

Model Flexographic Plants - Control Option A	6-33

Table 6-28. Total Annual Costs for Thermal Incinerators at

Model Flexographic Plants - Control Option B	6-34

Table 6-29. Cost Effectiveness of Control Options A and B

for Control of Model Flexographic Printing Plants. . . 6-35

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1.0 INTRODUCTION

1.1	OVERVIEW

Section 112 of the Clean Air Act (Act) requires that the
U. S. Environmental Protection Agency (EPA) establish emission
standards for all categories of sources of hazardous air
pollutants (HAP). These national emission standards for
hazardous air pollutants (NESHAP) must represent the maximum
achievable control technology (MACT) for all major sources. The
Act defines a major source as:

...any stationary source or group of stationary sources
located within a contiguous area and under common control
that emits or has the potential to emit, in the aggregate,
10 tons per year or more of any hazardous air pollutant or
25 tons per year or more of any combination of hazardous air
pollutants.

In July 1992, the Documentation for Developing the Initial
Source Category List1 was published. "Printing/Publishing
(Surface Coating)" was included as a source category. The
Printing and Publishing Industry NESHAP project will establish
standards for major sources in this source category.

The purpose of this document is to summarize the background
information gathered during the development of the printing and
publishing industry NESHAP.

1.2	PROJECT HISTORY
1.2.1 Background

The printing industry can be divided by technology,
substrate or type of product. Further divisions and industry
segments can be identified in each of the major industry

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divisions. Many manufacturing processes include printing
operations as one step in the production process. It is
estimated that more than 60,000 establishments in the U. S.
operate printing presses2. This estimate excludes plateless
printing establishments.

The printing industry can be divided by technology into six
different segments: gravure, flexographic, lithographic,
letterpress, screen, and plateless (xerographic, electrostatic,
magnetic, thermal, ink-jet, etc). The technology (i. e. the type
of press equipment) dictates the types of inks and coatings which
can be used. This defines to a large extent the type of HAP
involved, the emissions and the control techniques which are
applicable.

The printing industry can also be divided by the type of
substrate that is printed. Among the flexible substrates, paper,
foil and films are printed. Paper can be further classified in
many ways, including coated vs. uncoated. Films include
polyethylene and a number of other polymers. Rigid substrates
include cardboard and vinyl. A given substrate may be printed
using different technologies depending on factors such as the end
use, quality requirements, quantity, cost and environmental
considerations. Textiles are specifically excluded from the
printing source category.

The printing industry can be additionally divided by the
type of product. In general, the end use falls into the broad
categories of publication, packaging or product. Publication
printing includes newspapers, magazines, books and advertising.
Packaging includes paper, plastic and foil bags and wrappers, and
cardboard cartons. Products include wall and floor covering,
greeting cards and paper towels. Various technologies can be
used to print specific items within the broad categories.

In 1978, a control technique guidelines (CTG) document was
established for the control of VOC from rotogravure and

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flexographic printing operations3. New source performance
standards (NSPS) for VOC emissions from publication rotogravure4
were proposed October 28, 1980 (45 FR 71538) and promulgated
November 8, 1982 (47 FR 50644). NSPS for VOC emissions from
rotogravure printing and coating of flexible vinyl5 were proposed
January 18, 1983 (48 FR 2276) and promulgated June 29, 1984 (49
FR 26885). In 1993, a draft CTG document was published for the
control of VOC emissions from offset lithographic printing6.

None of these efforts were specifically directed towards HAP,
however, many HAP of concern in the printing and publishing
industry are VOC and the same control devices used to limit VOC
emissions are also applicable to control of HAP.

HAP are present in some of the inks, coatings, primers and
adhesives applied on printing presses, and are also present in
some of the materials used for cleaning press parts. Aromatic
(e. g. toluene), aliphatic and oxygenated hydrocarbons make up
the majority of the HAP used in the printing industry. HAP use
associated with various printing technologies and industry
segments is discussed in Chapter 2.

1.2.2 Data Gathering

In 1993, a questionnaire was developed by EPA and the
Gravure Association of America (GAA), to determine HAP use and
control in the publication rotogravure segment. Responses to
this questionnaire were voluntarily provided to EPA by all
publication rotogravure facilities operating in the U. S.

Two additional questionnaires were developed by EPA, GAA,
and the Flexible Packaging Association (FPA), to determine HAP
use and control by product and packaging rotogravure facilities
and flexographic printing facilities. These questionnaires were
included with information collection requests (ICR) sent out
under the authority of section 114 of the Act. Most of the
recipients opted to complete the questionnaires in lieu of the
ICR. Questionnaires were sent to approximately 90 companies

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thought to operate product or packaging rotogravure presses, and
approximately 37 0 companies thought to operate wide-web
flexographic presses.

In addition to information obtained from these
questionnaires, several site visits were made to printing
facilities. Also, the EPA has met with multiple trade
organizations and industry representatives over the past several
years.

1.2.3 Emissions and Control Data

The available emissions and control information for the
printing and publishing industry has been summarized in Chapter
3. Most of the information collected is based on calendar year
1992, and is representative of current practices. In some
segments of the industry, there has been a shift away from HAP to
non-HAP VOC and waterborne materials. Control efficiency data
are relevant to current conditions for the purpose of MACT
determination.

1.3 REFERENCES

1.	U. S. Environmental Protection Agency. Documentation for
Developing the Initial Source Category List: Final Report.
Publication No. EPA-450/3-91-030. Research Triangle Park,
NC July 1992.

2.	U. S. Environmental Protection Agency. Use Cluster Analysis
of the Printing Industry--Draft Final report. Washington,
DC. May 26, 1992. 182 pp.

3.	U. S. Environmental Protection Agency. Control of Volatile
Organic Compound Emissions from Existing Stationary Sources-
Volume VIII: Graphic Arts-Rotogravure and Flexography.
Publication No. EPA-450/2-7 8-033. Research Triangle Park,
NC. December, 1978. 52 pp.

4.	U. S. Environmental Protection Agency. Publication
Rotogravure Printing-Background Information for Proposed
Standards. Publication No. EPA-450/3-80-031a. Research
Triangle Park, NC. October, 1980.

5.	U. S. Environmental Protection Agency. Standards of
Performance for New Stationary Sources; Flexible Vinyl

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Coating and Printing Operations. 48 FR 12. January 18,
1983. p.2276 et. seq.

6. U. S. Environmental Protection Agency. Draft-Control of

Volatile Organic Compound Emissions from Offset Lithographic
Printing. Research Triangle Park, NC. September, 1993. 234

pp.

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2.0 THE PRINTING AND PUBLISHING INDUSTRY

2.1 INTRODUCTION

The printing industry can be divided by technology,
substrate or type of product. Further divisions and industry
segments can be identified in each of the major industry
divisions. Many manufacturing processes include printing
operations as one step in the production process. It is
estimated that more than 60,000 establishments in the U. S.
operate printing presses1. This estimate excludes plateless
printing establishments.

The printing industry can be divided by technology into
six different segments: gravure, flexographic, lithographic,
letterpress, screen, and plateless (xerographic,
electrostatic, magnetic, thermal, ink-jet, etc). The
technology (i. e. the type of press equipment) dictates the
types of inks and coatings which can be used. This defines to
a large extent the type of HAP involved, the emissions and the
control techniques which are applicable.

The printing industry can also be divided by the type of
substrate that is printed. Among the flexible substrates,
paper, foil and films are printed. Paper can be further
classified in many ways, including coated vs. uncoated. Films
include polyethylene and a number of other polymers. Rigid
substrates include cardboard and vinyl. A given substrate may
be printed using different technologies depending on factors
such as the end use, quality requirements, quantity, cost and

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environmental considerations. Textiles are specifically
excluded from the printing source category.

The printing industry can be additionally divided by the
type of product. In general, the end use falls into the broad
categories of publication, packaging or product. Publication
printing includes newspapers, magazines, books and
advertising. Packaging includes paper, plastic and foil bags
and wrappers, and cardboard cartons. Products include wall
and floor covering, greeting cards and paper towels. Various
technologies can be used to print specific items within the
broad categories.

Because inks and other HAP containing materials are
customized for particular printing technologies in terms of
viscosity (e. g. gravure and flexographic inks are relatively
fluid, lithographic, letterpress and screen inks are
relatively viscous) and chemical compatibility (e. g.
flexographic plates are incompatible with aromatic solvents)
HAP emissions will be discussed in terms of printing
technology. It should be recognized that in many cases the
same product can be produced by more than one technology
(e. g. newspapers are produced by lithography, letterpress,
and flexography).

2.2 GRAVURE PRINTING

Nearly all gravure printing is done by rotogravure.
Gravure printing is a printing process in which an image (type
and art) is etched or engraved below the surface of a plate or
cylinder. On a gravure plate or cylinder, the printing image
consists of millions of minute cells.2 Gravure requires very
fluid inks which will flow from the cells to the substrate at
high press speeds. In addition to inks, other materials
including adhesives, primers, coatings and varnishes may be
applied with gravure cylinders. These materials dry by
evaporation as the substrate passes through hot air dryers.

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Solvent borne or waterborne ink systems can be used but these
ink systems are not interchangeable. Both the printing
cylinders and the drying systems are specific to the solvent
system in use. The evaporated components of the ink and other
materials may contain HAP to varying extents. Additional HAP
may be present in solvents used to clean presses and press
components. Rotogravure can be divided into the publication
and product/packaging segments. Because of the expense and
complexity of rotogravure cylinder engraving, it is
particularly suited to long run printing jobs.
2.2.1 Publication Rotogravure

Publication rotogravure printing focuses on magazine,
catalog and advertising insert printing. In 1993, there were
27 publication rotogravure plants in the U. S. These plants
were operated by six corporations. These plants all use
toluene/xylene based ink systems, and operate solvent recovery
systems based on carbon adsorption with steam regeneration.
Recovered solvent is sold back to the ink manufacturers.

Press capture systems vary depending on the age of the press.
Press and cylinder technologies, products, inks and control
systems are discussed in the Background Information Document
for New Source Performance Standards for Publication
Rotogravure Printing3. Capture technologies and capture
efficiency testing are discussed in The Measurement Solution:
Using a Temporary Total Enclosure for Capture Efficiency
Testing4.

2.2.1.1 Process Description. On a gravure cylinder, the
printing image consists of millions of minute cells which are
engraved into the surface of the cylinder5. Different colored
inks are applied in succession as the web passes from station
to station. A separate cylinder, ink supply and dryer are
required for each station. After the ink is applied at each
station, the web is dried before being printed by the next

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station. Typically, four stations are required to print each
side of the web. Publication gravure presses in operation in
the U. S. have up to 16 stations. Gravure requires very fluid
inks which will flow from the cells to the web at high press
speeds. The ink dries by evaporation as the substrate passes
through hot air dryers.

Publication gravure presses in the United States use
solvent borne ink systems exclusively. Because of the expense
and complexity of rotogravure cylinder engraving, it is
particularly suited to long run printing jobs. It is
generally believed in the industry that publication gravure
equipment is capable of higher quality printing than competing
processes.

2.2.1.2	Profile of the Publication Rotogravure Segment.

There are 27 publication gravure plants in the United States.
These plants are owned by six companies, none of which are
small businesses. All 27 plants are major sources for
hazardous air pollutants. Some of these companies operate
additional printing processes using technologies other than
rotogravure. In some cases, these other processes are
conducted at separate locations. All of the plants
voluntarily provided responses to a list of questions
developed by the EPA and the Gravure Association of America.

The information in this section is based on these
responses. Seventeen of the responses are in the public
docket; the remaining ten responses contain some confidential
business information. A list of plant locations and owners is
given in Table 2-1.

2.2.1.3	HAP Use and Emissions. All of the U. S. publication
gravure plants use solvent based ink systems. The primary
solvent is toluene, a HAP. At some plants xylenes and ethyl
benzene, also HAP, are present in the solvent blend and are
used, emitted, recovered and handled in the same manner as

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toluene. The plants purchase ink containing solvent and add
additional solvent to obtain the desired viscosity. Ink is
applied to the web which then passes through a dryer, where
the solvent is evaporated into heated air. The web then
travels to the next press station where the process is
repeated with a different color. Most of the evaporated
solvent is recovered using activated carbon solvent recovery
systems. The recovered solvent is reused; excess solvent is
sold back to the ink manufacturers. Additional solvent (of
the same composition as the solvent in the ink) is used for
cleaning gravure cylinders and other press components.

Table 2-1. Publication Gravure Plants

Companv Name



Citv

State

Brown

Printing Company

Franklin

KY

R. R.

Donnelley Printing Company

Casa Grande

AZ

R. R.

Donnelley Printing Company

Lynchburg

VA

R. R.

Donnelley Printing Company

Newton

NC

R. R.

Donnelley Printing Company,

Des Moines

IA

R. R.

Donnelley &

Sons Company

Mattoon

IL

R. R.

Donnelley &

Sons Company

Reno

NV

R. R.

Donnelley &

Sons Company

Warsaw

IN

R. R.

Donnelley &

Sons Company

Spartanburg

SC

R. R.

Donnelley &

Sons Company

Lancaster

PA

R. R.

Donnelley &

Sons Company

Chicago

IL

R. R.

Donnelley &

Sons Company

Gallatin

TN

Quad/Graphics



Lomira

WI

Quebecor Printing

Atglen Inc.

Atglen

PA

Quebecor Printing

Buffalo Inc.

Depew

NY

Quebecor Printing

Dallas Inc.

Dallas

TX

Quebecor Printing

Dickson Inc.

Dickson

TN

Quebecor Printing

Memphis Inc.

Baltimore

MD

Quebecor Printing

Memphis Inc.

Memphis

TN

Quebecor Printing

Mt. Morris Inc.

Mt. Morris

IL

Quebecor Printing

Providence Inc.

Providence

RI

Quebecor Printing

Richmond Inc.

Richmond

VA

Quebecor Printing

San Jose Inc.

San Jose

CA

Ringier America Inc.

Corinth

MS

Ringier America, Inc.

Evans

GA

World

Color Press,

Inc.

Salem

IL

World

Color Press,

Inc.

Dyersburg

TN

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All of the U. S. publication gravure plants account for
solvent on the basis of liquid-liquid mass balances.

Emissions are calculated taking into account ink purchases,
solvent purchases and sales, and changes in inventory over a
suitable time frame. All solvent losses are counted as
emissions whether they result from pressroom capture losses,
control device losses, retention in the finished publications
or evaporation from uncontrolled equipment (including proof
presses).

HAP emissions result from incomplete recovery of captured
HAP, and from incomplete capture. Activated carbon solvent
recovery systems are suitable for control of toluene and
similar aromatic solvents. High control efficiencies can be
achieved, however some solvent is unavoidably emitted as a
result of thermodynamic limitations (the toluene-
carbon/ toluene-air equilibrium) and flow irregularities (e. g.
channelling through the carbon bed). Some HAP is not captured
in the dryer exhaust. This includes HAP which evaporates from
the ink fountains into the pressroom, HAP which is evaporated
from the web in the dryers but is then swept out of the dryer
as the web travels towards the succeeding press station, HAP
which remains in the web after the last drier which evaporates
during additional processing (slitting, folding, stitching,
etc.) and HAP which leaves the plant trapped in the magazine,
catalog or advertising insert.

Additional HAP is emitted from proof presses, which in
some plants are uncontrolled, gravure cylinder cleaning, other
parts cleaning, storage tank evaporation and breathing losses
and ink mixing operations. These sources are relatively minor
by comparison, however, they are reflected in the overall
efficiencies determined from liquid-liquid mass balances.
2.2.1.4. Baseline Emissions. There are 27 publication gravure
plants in the United States. All of the plants voluntarily

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provided responses to a list of questions developed by the EPA
and the Gravure Association of America. The information in
this section is based on these responses. Seventeen of the
responses are in the public docket; the remaining ten
responses contain confidential business information. A total
of 38,400,000 pounds (19,200 tons) of HAP was emitted in 1992.
The HAP is primarily toluene; some plants report using a
mixture containing mixed xylenes and ethyl benzene.
2.2.2 Packaging and Product Gravure

The gravure printing operation is, in many cases, a
relatively small part of the total package or product
production process. This section briefly describes the
various types of packages and products that include gravure
printing in their manufacture, and notes what production steps
are required in addition to the gravure printing step.

Folding Cartons. Folding carton packages are used for a
wide variety of products including wet and dry foods,
beverages, bakery items, and candy. They are also used for
nonfood products such as detergents, hardware, paper goods,
cosmetics, medical products, tobacco products, and sporting
goods.

The folding carton is made from one of several grades of
paperboard. It may be printed, laminated or coated, or may be
shipped unprinted to be used with another label or wrapper.
Besides printing, operations in the manufacture of folding
cartons include creasing, trimming, die-cutting, coating, and
gluing. The cartons are shipped flat, to be assembled and
filled by the customer. In addition to gravure printing,
flexography is used for folding cartons. Letterpress use has
declined. Most of the gravure presses used for folding carton
printing are web-fed. However, some folding carton presses
are sheet-fed, with only one or two print stations.6

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Flexible Packaging. Flexible packaging, by one
definition, consists of "converted materials intended to
package and display products weighing less than 25 pounds."7
The word "converted" in this use is an industry-specific term
that refers to the fact that flexible packaging materials
start out as rolls of paper or foil, or beads of plastic
resin, and are "converted" into a package or roll of packaging
material. Flexible package manufacturers are sometimes
referred to as "converters". The ratio of gravure printing to
flexographic printing among converters is approximately
20:80,® it is, however, an important component of the gravure
printing industry. Converters produce a wide range of non-
rigid packages made of paper, plastic film, foil laminates,
and combinations of these substrates.

One portion of the flexible packaging industry provides
fully printed packaging materials (designated "preformed
specialty bags") to contract packagers. Another portion
provides combination or laminated materials (designed
converted wrap) for printing and/or final packing by captive
packaging operations. Applying coatings is a major capability
of flexible packaging converters, so the same facilities may
be used to manufacture non-packaging materials such as gift
wraps and hot stamp foils.9

Labels and Wrappers. Labels and wrappers include roll
and sheet labels applied to cans, unprinted cartons, composite
cans, bottles and other containers, tags, and self-adhesive
label products. Paper is the common substrate, but laminates
and foil are also used. The industry makes a distinction
between labels and wrappers, which are package components,
from a product that becomes the entire package and should be
called a flexible package. This is because of the distinction
of SIC codes that apply (see above). However, it is suggested
that product shipment reports are probably based more on the

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substrate (i.e., paper for labels and wrappers; plastic film
for flexible packages) than on a precise definition of end
use.10

One interesting manufacturing technique used in making
labels is the use of combination gravure/flexo presses. The
manufacturer uses a gravure cylinder for "halftone" material
and for coating operations, and uses a flexographic cylinder
for typographic material that might have frequent changes.11

Gift Wraps. About 90 percent of all gift wraps are
printed. They are produced by greeting card companies and by
label and flexible packaging firms. Because gravure printing
is particularly suitable for producing the continuous patterns
used on gift wrap, it accounts for 60 to 70 percent of the
market.12 Historically a significant portion of the gift wrap
was made from laminated foil, as are many flexible packaging
materials. Although foil gift wrap is no longer a significant
product, it is the reason why flexible package manufacturers
often print gift wrap.13

Wallcoverings. The wallcovering industry is a
traditional user of gravure. The principal types of
wallcoverings are prepasted paper, prepasted paper-backed
vinyl, fabric-backed vinyl, and specialty items (e.g.,
metallics, grass cloth, rice paper). Gravure printing is
typically used to print only the vinyl wallcoverings.14

The steps in manufacturing wallcoverings include printing
the paper and laminating it to the backing sheet. A special
effect that may be added in some cases is "registered
embossing" to add texture. It is usually done in line with
the laminator.15

Vinvl Printing. These products consist of auto
upholstery, furniture upholstery, tablecloths, decorative
trim, and shower curtains. Gravure dominates this product
area because of the complex repeat patterns (e.g., woodgrain),

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and the requirement, in many cases, for overcoating that is
readily applied using a gravure cylinder. Printing is
performed on unsupported vinyl, supported vinyl (backed with
fabric or paper), and paper substrate that is then coated with
vinyl.16

The manufacturing steps typically consist of printing,
coating, embossing, and other finishing. In some cases items
that are screen printed or flexographically printed are still
coated using a gravure process.17

Decorative Laminates. These products consist of solid,
thermoset laminates used in furniture and construction, and
other laminates, principally wood grain veneers, widely used
in furniture. The dense sheets consist of many layers of
polymer-saturated paper. The top sheet is a translucent sheet
impregnated in melamine, laid over a printed or solid
pigmented pattern sheet. Heat and pressure are both used to
produce the final product.18

Floor Coverings. Gravure presses are used to decorate
and apply texture and finish to sheet vinyl floor coverings.
Rotary screen printing is sometimes used in combination with
gravure. Gravure is also used to print transfer papers used
to decorate vinyl tile, and some tile products are printed
using "offset/gravure," a hybrid press type using a gravure
cylinder offsetting to a rubber image carrier.19

Tissue Products. Some type of printing process is used
to apply color patterns to paper towels, bathroom tissue, and
napkins. The older paper mills producing tissue products were
typically equipped with gravure presses. Today, that
production accounts for less than 5 percent of the total
production.20

Miscellaneous Specialty Products. Other miscellaneous
and specialty products that require a printed patter are also
produced using gravure printing. One such product is

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cigarette tipping paper, the paper with a cork-like or other
pattern that is wrapped around cigarette filters.

2.2.2.1	Process Description. The rotogravure printing process
is described in section 2.2.1.1. Product and packaging
rotogravure differs from publication gravure with respect to
the materials used, the applicable control devices, and the
decreased importance of the actual printing process in an
overall manufacturing process.

Packaging and product rotogravure printing uses a wide
variety of different ink systems, including the aromatic HAP
based ink systems common to publication gravure, solvent based
non-HAP ink systems, and waterborne ink systems. Numerous
specially mixed colors are applied at various times in this
industry segment, in contrast to the publication segment which
primarily applies four basic colors. In addition a wider
range of materials are applied with gravure cylinders in this
segment of the industry. A variety of coatings, adhesives and
primers are applied at print stations on rotogravure presses.

Because of the variety of materials applied, the approach
to HAP and VOC control in packaging and product gravure
facilities varies. In addition to the activated carbon based
solvent recovery systems used by the publication segment,
packaging and product gravure facilities also use a variety of
thermal and catalytic oxidizers. Many facilities operate
without significant HAP use and do not have control devices.

Printing is only one stage (often minor) in
manufacturing. In many cases, operations such as laminating,
cutting, folding and calendering make up a greater proportion
of the value of the product or package than the printing
operation.

2.2.2.2	Profile of the Package/Product Rotogravure Segment

As of 1994, the Gravure Association of America (GAA)

estimated that rotogravure printing operations were conducted

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at 400 locations within the U. S.21 The EPA sent an
information collection request (ICR) to approximately 80
parent companies thought to operate rotogravure printing
equipment. Responses pertaining to rotogravure operations at
more than 100 locations were received. In lieu of completing
the ICR, nearly all of the companies chose to respond to a
simplified question list developed by EPA with the assistance
of GAA and the Flexible Packaging Association (FPA). A list
of companies from which usable information was received is
given in Table 2-2. These responses are included in the
project docket. Specific descriptions of printed products and
packaging are given for five substrate categories in Tables 2-
3 through 2-7.

2.2.2.3 Hap Use and Emissions. In product and packaging
gravure facilities, HAP is contained in both the printing inks
and in other materials (adhesives, coatings) that are applied
as part of a continuous manufacturing process. One survey
showed that the weight of coatings and lacquers applied in
gravure packaging plants was almost as much as the weight of
the ink.22 The predominant type of ink is based on
nitrocellulose resin, with some polyamide inks. Solvent

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Table 2-2. Packaging/Product Gravure Responses (See Codes

Following Table).

Company Name	Location	Code

AMGRAPH Packaging, Inc.



Versailles

CT

M

Alcan Foil Products



Louisville

KY

F

Alford Packaging



Baltimore

MD

P

Allied Stamp Corporation



Sand Springs

OK

P

Alusuisse Flexible Packaging,

Inc.

Shelbyville

KY

M

American Fuji Seal, Inc.



Anaheim

CA

F

American Fuji Seal, Inc.



Fairfield

NJ

F

American Greetings



Corbin

KY

P

Avery Dennison



Clinton

SC

M

Avery Dennison



Framingham

MA

P

Avery Dennison



Schereville

IN

V

Avery Dennison Corporation



Pasadena

CA

W

Butler Printing & Laminating,

Inc.

Butler

NJ

V

CPS Corporation



Franklin

TN

M

Cello-Foil Products, Inc.



Battle Creek

MI

M

Chiyoda America Inc.



Morgantown

PA

P

Cleo, Inc.



Memphis

TN

P

Columbus Coated Fabrics



Columbus

OH

V

Congoleum Corporation



Marcus Hook

PA

V

Congoleum Corporation



Mercerville

NJ

V

Constant Services, Inc.



Fairfield

NJ

V

DRG Medical Packaging



Madison

WI

M

Decor Gravure Corporation



Bensenville

IL

V

Decorating Resources



Clifton

NJ

F

Decorative Specialties International,

Inc.Johnston

RI

P

Decorative Specialties International,

Inc.Reading

PA

M

Decorative Specialties International,

Inc.West Springfield

MA V



Dinagraphics	Norwood	OH W

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Dittler Brothers	Atlanta	GA	W

Dittler Brothers	Oakwood	GA	W

Dopaco, Inc.	Downingtown	PA	P

Dopaco, Inc.	Saint Claries	IL	P

Dopaco, Inc.	Stockton	CA	P

Eskimo Pie Corporation	Bloomfield	NJ	M

Federal Paper Board Co., Inc.	Durham	NC	P

Federal Paper Board Co., Inc.	Wilmington	NC	P

Fleming Packaging Corporation	Peoria	IL	M

Fres-Co System USA, Inc.	Telford	PA	F

GenCorp Inc.	Jeannette	PA	F

GenCorp Inc.	Salem	NH	V

GenCorp Polymer Products	Columbus	MS	V

Graphic Packaging Corporation	Franklin	OH	M

Graphic Packaging Corporation	Lawrenceburg	TN	P

Graphic Packaging Corporation	Paoli	PA	P

Gravure Carton & Label	Surgoinsville	TN	P

Gravure Packaging, Inc.	Richmond	VA	P

Hallmark Cards	Kansas City	MO	P

Hallmark Cards	Leavenworth	KS	P

Hargro Flexible Packaging	Edinburgh	IN	M

Hargro Packaging	Flemington	NJ	M

International Label Company	Clarksville	TN	P

International Playing Card & Label CompanyRogersville	TN	P

J. W. Fergusson and Sons, Inc.	Richmond	VA	M

JSC/CCA	Carol Stream	IL	P

JSC/CCA	Lockland	OH	P

JSC/CCA	North Wales	PA	P

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Table 2-2. Packaging/Product Gravure Responses (concluded).

JSC/CCA	Santa Clara	CA	P

JSC/CCA	Stone Mountain	GA	P

James River Corporation	Hazelwood	MO	M

James River Paper Company	Darlington	SC	P

James River Paper Company	Fort Smith	AR	P

James River Paper Company	Lexington	KY	P

James River Paper Company	Portland	OR	M

James River Paper Corporation	Kalamazoo	MI	P

Jefferson Smurfit Corporation	Chicago	IL	P

Jefferson Smurfit Corporation	Jacksonville	FL	W

Johio, Inc.	Dayton	OH	M

Koch Label Company, Inc.	Evansville	IN	M

Lamotite, Inc.	Cleveland	OH	W

Lux Packaging Ltd.	Waco	TX	P

Mannington Mills, Inc.	Salem	NJ	V

Mundet-Hermetite Inc.	Buena Vista	VA	P

Newco Inc.	Newton	NJ	V

Orchard Decorative Products	Blythewood	SC	M

Orchard Decorative Products	St. Louis	MO	M

Package Service Company	Northmoor	MO	M

Paramount Packaging Corporation	Chalfont	PA	F

Paramount Packaging Corporation	Longview	TX	F

Paramount Packaging Corporation	Murfreesboro	TN	F

Quick Roll Leaf Manufacturing Company	Middletown	NY	F

Reynods Metals Company	Richmond	VA	F

Reynolds Metals Company	Downingtown	PA	M

Reynolds Metals Company	Richmond	VA	M

Riverwood International USA, Inc.	Bakersfield	CA	P

Riverwood International USA, Inc.	Cincinnati	OH	P

Riverwood International USA, Inc.	West Monroe	LA	P

Roslyn Converters Inc.	Colonial Heights	VA	P

Scientific Games, Inc.	Alpharetta	GA	W

Scientific Games, Inc.	Gilroy	CA	W

Screen Art	Fulton	NY	M

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Screen Art

Moorestown

NJ

F

Shamrock Corporation

Greensboro

NC

M

Shamrock Corporation

Greensboro

NC

P

Smurfit Flexible Packaging

Schaumburg

IL

M

Smurfit Laminations

Elk Grove Village

IL

M

Somerville Packaging

Newport News

VA

P

Stone Container Corporation

Louisville

KY

P

Technographics Printworld

North Monroe

NC

W

The C. W. Zumbiel Company

Cincinnati

OH

P

Union Camp Corporation

Asheville

NC

M

Union Camp Corporation

Englewood

NJ

P

Union Camp Corporation

Spartanburg

SC

P

Vernon Plastics Company

Haverhill

MA

V

Vitex Packaging, Inc.

Suffolk

VA

M

Waldorf Corporation

Chicago

IL

P

Waldorf Corporation

Saint Paul

MN

P

Wrico Packaging

Chicago

IL

M

P=Paper/Cardboard only
F=Film/Foil only
V=Vinyl product

M=Paper/cardboard AND Foil/film
W=miscellaneous, NEC

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Table 2-3. Rotogravure Facilities Printing on Paper and Cardboard.

Company Name	State

Alford Packaging	MD

Allied Stamp Corporation	OK

American Greetings	KY

Avery Dennison	MA

Chiyoda America Inc.	PA

Cleo, Inc.	TN

Decorative Specialties Int'l, Inc.	RI

Dopaco, Inc.	PA

Dopaco, Inc.	IL

Dopaco, Inc.	CA

Federal Paper Board Co., Inc.	NC

Federal Paper Board Co., Inc.	NC

Graphic Packaging Corporation	TN

Graphic Packaging Corporation	PA

Gravure Carton & Label	TN

Gravure Packaging, Inc.	VA

Hallmark Cards	MO

Hallmark Cards	KS

International Label Company	TN

Product
Paperboard

Soft drink labels, trading stamps

Gift wrap

Paper packaging

Paper packaging

Gift wrapping paper

Paper coating / printing for book covering/fancy
packaging

Paperboard packing (cartons and cups)

Paperboard packaging (cartons and cups)
Paperboard packaging (cartons and cups)

Paper packaging
Consumer packaging/cartons
Paperboard packaging, folding cartons
Paper packaging
Paper

Paperboard packaging

Paper products (98%); Vinyl products (2%)

Paper products
Paper packaging

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Int'l Playing Card & Label Co.	TN

JSC/CCA	IL

JSC/CCA	OH

JSC/CCA	PA

JSC/CCA	CA

JSC/CCA	GA

James River Paper Company	SC

James River Paper Company	AR

James River Paper Company	KY

James River Paper Corporation	MI

Jefferson Smurfit Corporation	IL

Lux Packaging Ltd.	TX

Mundet-Hermetite Inc.	VA

Riverwood International USA, Inc.	CA

Riverwood International USA, Inc.	OH

Riverwood International USA, Inc.	LA

Roslyn Converters Inc.	VA

Shamrock Corporation	NC

Paper packaging
Paper board packaging
Paperboard packaging
Paper packaging

Paperboard packaging (folding cartons)

Paper packaging

Sanitary paper food containers, paper plates, bowls,cups
Paper

Side paper for 3 oz. paper cups.

Paperboard packaging
Folding cartons
Paper packaging
Tipping paper for cigarettes
Paperboard packaging
Paperboard packaging
Paperboard packaging
Tipping paper for cigarettes
Cigarette tipping paper

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Table 2-3. Rotogravure Facilities Printing

Company Name	State

Somerville Packaging	VA

Stone Container Corporation	KY

The C. W. Zumbiel Company	OH

Union Camp Corporation	NJ

Union Camp Corporation	SC

Waldorf Corporation	IL

Waldorf Corporation	MN

on Paper and Cardboard (concluded).

Product

Paperboard box

Paper packaging products - small bags
Paper folding cartons

Paperboard packaging (sheet fed gravure—not webs)
multiwall paper bags
Paperboard packaging
Paperboard packaging

Table 2-4. Rotogravure Facilities Printing Exclusively on Foil and Film.

Company Name



State

Product

Alcan Foil Products



KY

Foil packaging

American Fuji Seal,

Inc.

CA

Heat shrinkable film

American Fuji Seal,

Inc.

NJ

Heat shrinkable film

Decorating Resources



NJ

Film - heat transfer labels

Fres-Co System USA,

Inc.

PA

Film packaging

GenCorp Inc.



PA

Graphic arts/decorative films
metal, wood)

Paramount Packaging

Corporation

PA

Film packaging

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Paramount Packaging Corporation	TX

Paramount Packaging Corporation	TN

Quick Roll Leaf Manufacturing Co.	NY

Reynolds Metals Company	VA

Screen Art	NJ

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Table 2-5. Rotogravure Facilities Printing Vinyl Products.

Company Name	State

Avery Dennison	IN

Butler Printing & Laminating, Inc.	NJ

Columbus Coated Fabrics	OH

Congoleum Corporation	PA

Congoleum Corporation	NJ

Constant Services, Inc.	NJ

Decor Gravure Corporation	IL

Product

Polyester and vinyl films

Vinyl wallcovering and pool liner

Vinyl/paper wallcovering, Industrial
films

Vinyl floor covering
Vinyl floor covering
vinyl

Vinyl wall covering

Decorative Specialties Int'l, Inc.

MA

Vinyl coated saturated or unsaturated





paper

GenCorp Inc.

NH

Vinyl wallcovering, upholstery, vinyl





wood/metal laminates

GenCorp Polymer Products

MS

Vinyl wallcovering, commercial vinyls

Mannington Mills, Inc.

NJ

Vinyl flooring

Newco Inc.

NJ

Vinyl wallcovering

Vernon Plastics Company

MA

Decorated vinyl film products

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Table 2-6. Rotogravure Facilities Printing on Paper or Cardboard and Foil or Film.

Company Name

Altigraph Packaging, Inc.

Alusuisse Flexible Packaging, Inc

Avery Dennison

CPS Corporation

Cello-Foil Products, Inc.

DRG Medical Packaging

Decorative Specialties Int'l, Inc

Eskimo Pie Corporation

Fleming Packaging Corporation

Graphic Packaging Corporation

Hargro Flexible Packaging

Hargro Packaging
J. W. Fergusson and Sons, Inc.
James River Corporation
James River Paper Company
Johio, Inc.

Koch Label Company, Inc.

Orchard Decorative Products
Orchard Decorative Products

State Product

CT	Flexible packaging

KY	Paper, film and foil packaging

SC	Paper postage stamps, paper and film label products

TN	Paper and foil giftwrap

MI	Flexible packaging

WI	Paper & Film Packaging

PA	Paper and paper/foil laminated paper

NJ	Paper/foil laminations

IL	Paper & foil packaging items (labels, lids, bands)

OH	Paper, film and foil packaging

IN	Paper/polyethylene packaging; paper/foil packaging; film
packaging

NJ	Paper packaging, film packaging

VA	Paper, film, foil, packaging

MO	Paper packaging, film packaging

OR	Paper, film packaging

OH	Paper packaging, film packaging, foil packaging

IN	Paper, foil, metallized paper, film labels

SC	Decorative papers and paper foils

MO	Paper for wall paneling, furniture, RTA furniture, HP
laminates, film

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Package Service Company	MO

Reynolds Metals Company	PA

Reynolds Metals Company	VA

Screen Art	NY

Shamrock Corporation	NC

Smurfit Flexible Packaging	IL

Smurfit Laminations	IL

Union Camp Corporation
Vitex Packaging, Inc.
Wrico Packaging

NC
VA
IL

Foil, paper labels

Flexible packaging with foil, film, paper, and laminates
Film, paper, board, aluminum foil

Paper packaging, film packaging, foil packaging, paper
gift wrap

Paper and foil packaging (giftwrap)

Foil, paper, poly, PVC, PET, packaging

Laminated films and foils, unlamninated paper and board
stocks

Paper and foil packaging

Paper packaging, Film packaging

Paper, film and boxboard packaging

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Table 2-7. Rotogravure Facilities Printing Miscellaneous Products.

Company Name

Avery Dennison Corporation

Dinagraphics

Dittler Brothers

Dittler Brothers

Jefferson Smurfit Corporation

Lamotite, Inc.

Scientific Games, Inc.
Scientific Games, Inc.
Technographics Printworld

State	Product

CA	Self adhesive postage stamps

OH	Heat transfer labels on wax-coated paper

GA	Product Gravure - Commercial Games

GA	Product Gravure - Lottery tickets

FL	Heat transfer labels on wax-coated paper,

paper packaging

OH	Reinforced laminations

GA	Scratch-off lottery tickets

CA	Scratch-off lottery tickets

NC	Decorative papers for heat transfer to cloth

and for laminated surfaces

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systems include aromatic, aliphatic and oxygenated hydrocarbon
solvent inks, and water-based inks.

Due to the wide variety of ink types and colors that are
used in this segment of the printing industry, ink is
typically received in drum (or smaller container sizes) and
tote bins. Only rarely is bulk ink received and stored in
tank farms.

About 60 percent of the coatings used are petroleum-based
waxes and hot melts. About 35 percent of the coatings are
extrusion coatings, typically low density polyethylene (LDPE).
The remaining 5 percent are solution coatings, typically
applied to flexible packaging. The 25 percent of theextrusion
coatings that are not LDPE consist of polyvinyl chloride
(PVC), polyvinyl acetate (PVA), ethylene vinyl acetate (EVA)
copolymers, high density polyethylene, and polypropylene.23

Folding Cartons. About half of the ink used for folding
cartons is nitrocellulose based. The remainder is alcohol
solvent and water based. On a weight basis, coatings and
lacquers are about equal to ink use.24

Flexible Packaging. Solvent-based, nitrocellulose resin
ink is the predominant type. Coatings and lacquers are only a
third of the ink use, by weight.25 Some flexible packaging
printers have switched from the traditional toluene solvent to
non-HAP solvents such as iso- and normal-propyl acetate.26 The
use of water-based inks in this industry segment is growing.
At one company, all HAP except for glycol ethers have been
eliminated.27

Labels and Wrappers. Nitrocellulose resin inks account
for about half the inks used in this industry segment, with a
wide variety of ink types accounting for the rest. Coatings
and lacquers amounted to about 1.5 times the weight of ink
used.28

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Vinvl Products. In response to the ICR, vinyl product
manufacturers reported use of methyl ethyl ketone, and methyl
isobutyl ketone as the major HAP present in materials applied
with rotogravure presses. Significant quantities of toluene
and xylene were also used.

2.2.2.4 Baseline Emissions

HAP emissions data are available for most of the
facilities submitting data in response to the ICR. In some
cases, responses were received, however, the HAP emissions
data were not usable. This resulted from missing or ambiguous
answers to questions relating to HAP usage and control
efficiency. Specific data on control efficiency for HAP are
not available. Data have been analyzed on the assumption that
overall HAP control efficiency is equivalent to reported
overall efficiency. These data are most often based on tests
or vendor guarantees relating to VOC. In many cases, HAP
makes up only a minor proportion of the VOC used on-press.

Baseline emissions calculated from the responses to the
ICR are given in Table 2-8. Analogous information given
in Table 2-9 pertains to major sources as determined on the
basis of actual HAP emissions. When potential-to-emit is
considered there are more major sources. An upper bound on
baseline emissions can be estimated by assuming that there are
400 product and packaging gravure facilities and that the
facilities providing usable data in response to the ICR are
representative of the total population. In this case,
baseline emissions from product and packaging gravure would be
approximately 32,000,000 lb/yr. It is more likely that
responses were obtained from larger facilities within the
industry, and that baseline emissions are much lower.
2.2.3 Intaglio Plate Gravure

Intaglio plate gravure or engraving, uses a flat copper
plate on a sheetfed press. This process is used for currency,

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postage stamps, securities and stationery29. It makes up a
small proportion of the gravure printing segment.

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Table 2-8. Baseline Emissions from Product and Packaging

Rotogravure Responses.

Industry Segment

Number of Usable
Responses

HAP Emissions
(lb/yr)

Paper/Cardboard Only

40

2,004,000

Foil/Film Only

10

597,900

Paper/Cardboard/Foil/Film

27

2,598,000

Vinyl Product

10

896,500

Miscellaneous

9

1,465,000

Total

96

7,561,000

Table 2-9. Baseline Emissions from Major Sources in the
Product and Packaging Rotogravure Industries.

Industry Segment

Number of Usable
Responses

HAP Emissions
(lb/yr)

Paper/Cardboard Only

16

1,811,000

Foil/Film Only

4

581,100

Paper/Cardboard/Foil/Film

9

1,257,000

Vinyl Product

3

822,500

Miscellaneous

4

1,418,000

Total

36

5,890,000

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2.3 FLEXOGRAPHY

Flexographic printing is considered to be the application
of words, designs and pictures to a substrate by means of a
printing technique in which the pattern to be applied is
raised above the printing plate and the image carrier is made
of rubber or other elastomeric materials.30 It has been
estimated that there are 1,587 plants in the U. S. with
flexographic presses.31 The major applications of flexographic
printing are flexible and rigid packaging; tags and labels;
newspapers, magazines, and directories; and paper towels,
tissues etc. Because of the ease of plate making and press
set up, flexographic printing is more suited to
shortproduction runs than gravure. It is estimated that 85
percent of package printing is done by flexography.32

Flexographic inks must be very fluid to print properly.
Flexographic inks include both waterborne and solvent based
systems. Solvents used must be compatible with the rubber or
polymeric plates; thus, aromatic solvents are not used. Some
of the components of solvent based flexographic ink include
ethyl, n-propyl and i-propyl alcohols; glycol ethers,
aliphatic hydrocarbons, acetates and esters.33

Flexographic printing can be divided between publication
and packaging/product printing. An alternate approach, and
the one chosen for this project, is to divide between wide web
and narrow web equipment with an 18 inch web width being an
arbitrary cutoff between the two categories. Additional
distinctions can be made on the basis of web vs. sheetfed
press equipment.

2.3.1. Wide Web (and Sheetfed) Flexographic Printing

Wide web flexographic presses are used to print flexible
and rigid packaging; newspapers, magazines, and directories;
and paper towels, tissues etc; and printed vinyl shower
curtains and wallpaper. Corrugated cartons are one of the few

2-29

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substrates printed by sheetfed flexography.34 Substrates
include polyolefins, polystyrene, polyesters, glassine,
tissue, sulfite, kraft and other paper stocks, aluminum foil,
paperboard, corrugated, folding cartons, gift wraps, paper
cups and containers.35

2.3.1.1	Process Description. Flexographic presses can be
divided into three main types depending on the relative
relationship of the print stations. Stack presses have
individual print stations oriented vertically with the unwind
and rewind sections on the same side of the print stations.
Stack presses are easily accessible for rapid changeovers
between pressruns. Common impression presses have the print
stations around the circumference of a single large impression
cylinder. The web is constantly supported between print
stations, which is an advantage for printing on stretchable
materials. In-line presses have the print stations in a
horizontal row (the geometry is similar to rotogravure
presses). These presses have an advantage when used with
additional converting (such as cutting, gluing and laminating)
equipment.36

2.3.1.2	Profile of Wide Web Flexographic Segment. Most wide
web flexographic printing facilities produce various types of
packaging. Flexible packaging producers often operate both
flexographic and rotogravure presses at the same facilities;
the selection of equipment for a particular job depends on
length of run, quality requirements and substrate. The
printing component makes up a relatively minor part of the
value of some types of packaging. Facilities that produce
corrugated cartons and paper bags may not consider themselves
to be printers. Large paper companies often operate many
small facilities at locations around the country to serve
local markets.

2-30

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Newspaper production makes up a small proportion of
flexographic printing facilities. There are 35
flexographically printed newspapers in the U. S.37 This number
is expected to grow as newspapers replace aging letterpress
equipment. Several large newspaper chains use flexographic
presses at multiple locations.

The EPA sent an information collection request (ICR) to
approximately 380 parent companies thought to operate
flexographic printing equipment. Approximately 100 of these
facilities were found to operate only narrow web presses; no
information was collected from narrow web printers other than
their names, addresses and numbers of employees. Responses
pertaining to wide web flexographic printing operations at
approximately 500 facilities were received. In lieu of
completing the ICR, nearly all companies chose to respond to a
simplified question list developed by EPA with the assistance
of the Flexible Packaging Association (FPA). A list of the
names and locations of facilities submitting information is
given in Table 2-10. These responses, with the exception of
confidential business information, are included in the project
docket.

2.3.1.3 HAP Use and Emissions. HAP emissions result from
components of ink (and other materials applied with
flexographic plates, including varnishes, primers, and
adhesives) and solvents used to clean presses and equipment.
In the past, flexographic platemaking systems commonly used
HAP; these systems are becoming rare as improved HAP free
platemaking technologies have become available. Within the
converting industry, printed substrates are formed or
purchased then printed and converted to packaging such as bags
or boxes. In many cases, the printing operation is a
relatively small part of the processing which may include film
blowing, laminating, coating, adhesive application, and

2-31

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cutting. Some or all of these processing operations are done
at flexographic press stations or in-line with the presses.
Converting operations done in conjunction with flexographic
printing may result in additional HAP emissions.

Most flexographic printing (including all flexographic
newspaper and corrugated carton printing) is done with

2-32

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Table 2-10. Wide-Web Flexographic Printing Responses

Name	Address

Abbott Box Co. Inc.

Action Packaging

Acorn Corrugated Box Co.

Advance Packaging Corporation

Advance Packaging Corp.

Akron Beacon Journal
All-Pak, Inc.

Alusuisse Flexible Packaging, Inc.

Alusuisse Flexible Packaging, Inc.

Alusuisse Flexible Packaging, Inc.

American Greetings Corp

American Greetings Corp.

American National Can/Food Plastics

American National Can/Food Plastics

American National Can/Food Plastics
American National Can/Food Plastics

American National Can/Food Plastics

American National Can/Food Plastics
American National Can/Food Plastics

58 Teed Drive, Randolph, MA 02368

667 Atkins Avenue, Brooklyn, NY
11208

5133 W. 65th Street, Bedford Park,
IL 60 638

4450 36th Street, SE, P.O. Box
888311, Grand Rapids, MI
49588-8311

2400 E. High St., P.O. Box 730,
Jackson, MI 49203

44 East Exchange St., Akron, OH
44309

5383 Truman Drive, Decatur, GA
30035

1403 Fourth Ave.,New Hyde Park, NY
11040

5303 St. Charles Road, Bellwood, IL
60104

6700 Midland Industrial Drive,
Shelbyville, KY 40065

P.O. Box 1570, Corbin, KY
40702-5851

Hwy. 11 E ByPass, Afton, TN 37616

1300 S. River St., Batavia, IL
60510

1500 E. Aurora Ave., Des Moines, IA
50313

271 River St., Menasha, WI 54952

150 26th Ave. SE, Minneapolis, MN
55414

201 W. Madison St., Mount Vernon,
OH 43050

1815 Marathon Ave.,Neenah,WI 54956

6590 Central Ave., Newark, NJ
94560

2-33

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American National Can/Food Plastics

American Packaging Corp.

American Packaging Corp.

American Packaging Corp.

American Packaging Corp.

Amko Plastics, Inc.

Anagram International, Inc.

Areata Graphics\Kingsport

Arcon Coating Mills, Inc.

Arkansas Poly, Inc.

Atlanta Film Converting Co, Inc.

3600 Alabama Ave.,St. Louis Park,
MN 55416

2900 Grant Ave., Philadelphia, PA
19114

125 W. Broad St., Story City, IA
50248

200 Continental Dr., Columbus, WI
53925

111 Driving Park Ave., Rochester,
NY 14613

12025 Trilon Road, Cincinnati, OH
45246

7700 Anagram Drive, Eden Prairie,
MN 55344

P.O. Box 711, Press and Roller
Streets, Kingsport, TN 37662

3067 New Street, Oceanside, NY
11572

1248 So. 28th Street, Van Buren, AR
72956

1132 Pryor Rd., P.O. Box 6756,
Atlanta, GA 30315

2-34

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Table 2-10. Wide-Web Flexographic Printing Responses

(continued).

Automated Packaging Systems, Inc.
Automated Label Systems Co.
Avery-Dennison, K & M Division
Avery-Dennison

Bagcraft Corporation of America

Bancroft Bag, Inc

Banner Packaging, Inc.

Bell Packaging Corp

Bingo Paper Inc.

Bomarko, Inc

Bonar Packaging, Inc.

Bryce Corporation

BRC, A Division of Bryce Corporation
Bryce Corporation
Johnson Bryce Corp.

Bryce Dixico

Tennessee Packaging

Koch Container

All-Size Corrugated Prods.

13555 McCracken Road, Garfield
Heights, OH 44125

8400 Darrow Road, twinsburg, OH
44087

4100 Hwy 45 North, Meridian, MS
39305

4350 Avery Drive, P.O. Box 547,
Flowery Branch, GA 30542

3900 West 43rd St., Chicago, IL
60632

425 Bancroft Blvd, West Monroe, LA
71291

3550 Moser Street, Oshkosh, WI
54901

3102 S. Boots St., Marion, IN
46953

801 River Drive So., Great Falls,
MT 59405

1955 North Oak Road, P. 0. Box K,
Plymouth, IN 46563

2410 N. Lyndon, Tyler, TX 75702

450 S. Benton St., Searcy, AR
72143

75 Isabelle Street, Buffalo, NY
14207-0007

4505 Old Lamar and 3861 Delp
Street, Memphis, Tennessee 38118

4224 Premier Street, Memphis, TN
38118

1300 South Polk St., Dallas,

TX

75224

Hwy 11 Longmeadow Rd, Sweetwater,
TN 37874

777 Old Dutch Road 14564

P.O. Box 4544, Lancaster, PA
17604

2-35

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Buckeye Container
Buckeye Packaging
Burrows Paper Corporation
Burrows Paper Corporation
Cadillac Products, Inc.

Cadillac Products, Inc.

Cadillac Products, Inc.

Cello-Wrap Printing Company, Inc.
Central States Diversified, Inc.
Champion International Corp.
Champion International Corp.

P.O. Box 16, 326 N. Hillcrest
Drive, Woostor, OH 44691

12223 Marlboro Avenue, Alliance, OH
44601

101 Commerce Drive, Mt. Vernon, OH
43050

1722 53rd Street, Fort Madison, IA
52627

840 Woodrow St., S.W., Atlanta, GA
30310-3431

2005 S. Main St., Paris, IL
61944-2950

7000 East 15 Mile Rd, Sterling
Heights, MI 48311-8012

110 N. Main, P.O. Box 32,
Farmersville, TX 75442

5221 Natural Bridge, St. Louis, MO
63115

155 East Hanover Ave, Morristown,
NJ 07960

1500 South 14th Street, Clinton, IA
52732

2-36

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Table 2-10. Wide-Web F1

(cor

Champion International Corp.

Champion International Corp.

Champion International Corp.

Charleston Packaging Company, Inc.

Clark Container, Inc.

Cleo, Inc.

Compak, Inc.

Webcor Packaging Corp.

Crystal Tissue

Castle Rock Container Company

C. P. C. Packaging, Inc.

Cryovac Division

Cryovac Division

Cryovac Division

Bemis Company, Inc.

Bemis Company, Inc.

Bemis Company, Inc.

Bemis Company, Inc.

Bemis Company, Inc.

Bemis Company, Inc.

cographic Printing Responses
inued).

7920 Mapleway Drive, Olmsted Falls,
OH 44138

1901 Windsor Place, Fort Worth, TX
76110

600 Dairy Pak Road, Athens, GA
30607

4229 Domino Ave, North Charleston,
SC 29405-7486

P.O. Box 160, Bates Crossing
Industrial Park, Lyles, TN 37098

3963 Vernal Pike, Bloomington, IN
47402

8789 E. Lansing Road, Durand, MI
48429

1220 N. Center Road, Burton, MI
48509

1118 Progress Way, Maysville, KY
41056

P.O. Box 530 - Grove Street, Adams,
WI 53910

214 Brace Ave., Eluria, OH 44035

1301 West Magnolia Avenue, Iowa
Park, TX 76367

1125 Wilson Avenue, S.W., Cedar
Rapids, IA 52406

P.O. Box 338 (803 N. Maple St.),
Simpsonville, SC 29681

1401 West 3rd Avenue, Crossett, AR
71635

1975 Latham St., Memphis, TN 38106

2705 University Ave., Minneapolis,
MN 55418

3514 South 25th St., Omaha, NE
68105

Sloan St., Peoria, IL 61603
Chapel Place, Pepperell, MA 01463

2-37

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Bemis Company, Inc.

Bemis Company, Inc.

Bemis Company, Inc.

Bemis Company Inc.

Bemis Company, Inc.

Bemis Company, Inc.

Bemis Specialty Films

Bemis Curwood

Bemis Curwood
Bemis Milprint
Bemis Milprint

Cello-Foil Products, Inc

55 South Atlantic St., Seattle, WA
98124

1401 West 4th Plain Blvd,
Vancouver, WA 98660

1000 East 13th St., Wichita, KS
67214

1350 North Fruitridge Ave., Terre
Haute, IN 47808

Rt. 12 West, P.O. Box 475,
Flemington, NJ 08822

Jaycee Drive, Hazleton, PA 18201

2450 Badger Avenue, Oshkosh, WI
54904

19th and Wall Sts., Murphysboro,
IL 62966

718 High St., New London, WI 54961

590 Woodrow St., Denmark, WI 54902

1309 HWY 61 North, Lancaster, WI
53813

155 Brook Street, Battle Creek, MI
49017

2-38

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Table 2-10. Wide-Web Flexographic Printing Responses

(continued).

Custom Poly Bag, Inc.

Dart Container Corporation

Deco Paper Products, Inc.

Design Containers, Inc.

Dixico, Inc.

Dynamic Packaging, Inc.

Eisenhart Wallcoverings Co.

Eskimo Pie Corporation

Equitable Bag Co., Inc

Excelsior Transparent Bag MFG Corp.

Fabricon Products

Fabricon Products

Spec-Fab

Fleetwood Container & Display

fp Webkote, Inc.

Spiralkote, Inc.

Flex-Pak, Inc.

Flexo Transparent, Inc.

Focus Packaging, Inc.

9465 Edison Street, NE, Alliance,
OH 44601

60 E. Main Street, Leola, PA
17540

1028 South Eighth Street,
Louisville, KY 40203

2913 West Side Blvd., Jacksonville,
FL 32209

276 S. Parkway West, Memphis, TN
38109

7875 School Road, Cincinnati, OH
45249

400 Pine Street, P.O. Box 464,
Hanover, PA 17 331

118 J.F. Kennedy Dr. North,
Bloomfield, NJ 07003

7 600 Empire Drive, Florence, KY
41042

159 Alexander Street, Yonkers, NY
10701

1721 W. Pleasant, River Rouge, MI
48218

4101 North American Street,
Philadelphia, PA 19140

1818 Rowland Street, Riverton, NJ
08077

2721 E. 45th Street, Vernon, CA
90058

1016 S. W. Adams St., Peoria, IL
61602-1694

1200 Central Florida Parkway,
Orlando, FL 32809

555 Branch Drive, Alpharetta, GA
30201

28 Wasson St, Buffalo, NY 14210

5207 Richland Ave., Kansas City, KS
66106

2-39

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Fort Wayne Newspapers

Frank C. Meyer Company, Inc.

Gateway Packaging

Gentry Poly Specialties, Inc.

Georgia-Pacific Corp.

Georgia-Pacific Corp.

Georgia-Pacific
Georgia-Pacific Corp

Georgia-Pacific Corp

Georgia-Pacific

600 W. Main St., Fort Wayne, IN
46801

585 S. Union Street, Lawrence, MA
01843

P.O. Box 29, Granite City, IL
62040

P.O. Box 688, Route 2, Gentry, AR
72734

1500 Orchard Hill Drive, LaGrange,
GA 30240

327 Margaret Street, Plattsburgh,
NY 12901

P.O. Box 3333, Crossett, AR 71635

17 Forester Ave, Warwick, NY
10990

P.O. Box 919, Palatka, FL
32178-0919

RR6 Box 8, Riverside Lane,
Brattleboro, VT

2-40

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Table 2-10. Wide-Web Flexographic Printing Responses

(continued).

Georgia-Pacific

G-P Albany Plant

G-P Asheboro Plant

G-P Augusta Plant

G-P Bradford Plant

G-P Buena Park Plant

G-P Canton Plant

G-P Chicago Plant

G-P Cincinnati Plant

G-P Circleville Plant

G-P Cleveland Plant

G-P Cleveland Plant

G-P Doraville Plant

G-P Dubuque Plant

G-P Franklin Plant

G-P Huntsville Plant

G-P Kansas City Plant

G-P Lake Placid Plant

G-P Madera Container Plant

300 W. Laurel Street, Bellingham,
WA 98225

405 Maxwell Drive, Albany, GA
31701

200 McDowell Road, Asheboro, NC
27203

Perkins & New Savannah Rd, Augusta,
GA 30913

One Owen's Way, Bradford, PA
16701

6300 Regio Avenue, Buena Park, CA
90620

2820 Winfield Way, Canton, OH
44705

440 East 138th Street, Chicago, IL
60627

220 West North Bend Road,
Cincinnati, OH 45216

2850 Owens Road, Circleville, OH
43113

4660 Brook Park Road, Cleveland, OH
44142

4200 Old Tasso Road, Cleveland, TN
37311

4600 NE Expressway, Doraville, GA
30340

2150 Kerper Boulevard, Dubuque, IA
52004

210 Grove Street, Franklin, MA
02038

3420 Stanwood Boulevard,

Huntsville, AL 35811

8600 Northeast 38th Street, Kansas
City, MO 64161

400 S.R. 70 West, Lake Placid, FL
33852

24600 Avenue 13, Madera, CA 93637

2-41

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G-P Martinsville Plant
G-P Memphis Plant
G-P Milan Plant
G-P Modesto Plant
G-P Monticello Plant
G-P Mt. Olive Plant
G-P Mt. Wolf Plant
G-P Olympia Plant
G-P Ooltewah Plant
G-P Oshkosh Plant

US 200 and Route 970, Martinsville,
VA 24112

611 Winchester Road, Memphis, TN
38116

951 County Street, Milan, MI
48160

2400 Lapham Drive, Modesto, CA
95354

823 North Cedar Street, Monticello,
IA 52310

Old Rt. 66 and 8th Street, Mt.
Olive, IL 62029

25 Walnut Street, Mt. Wolf, PA
17347

1203 Fones Road, Olympia, WA
98501

5201 Ooltewah-Ringwold Road,
Ooltewah, TN 37363

413 East Murdock Avenue, Oshkosh,
WI 54902

2-42

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Table 2-10. Wide-Web Flexographic Printing Responses

(continued).

G-P Owosso Plant

G-P Schenectady Plant

G-P Sheboygan Plant

G-P So. San Francisco Plant

G-P Spartanburg Plant

G-P Valdosta Plant

G-P Warren County Plant
G-P West Monroe Plant

G-P Waxahachie Plant

Gilman Converted Products

Glenroy, Inc.

Graphic Packaging Corporation
Graphic Packaging Corp.

Greif Bros. Corp

Gulf Coast Plastics Div. Dairy-Mix, Inc

Gulf States Paper Corp.

H. S. Crocker Co., Inc.

Hallmark Cards
Hallmark Cards

465 S. Delaney Road, Owosso, MI
48867

Building 801 Corporations Park,
Schenectady, NY 12302

1927 Erie Avenue, Sheboygan, WI
53082

249 East Grand Avenue, So. San
Francisco, CA 94080

3100 Southport Road, Spartanburg,
SC 29304

Highway 31 South, Clyattville, GA
31601

U.S. Highway 1, Manson, NC 27553

400 Central Street, West Monroe, LA
71292

5800 Hwy 35 East, Waxahachie, TX
75165

3201 McRae Highway, Eastman, GA
21023

W158 N9332 Nor-X-Way Ave., P.O. Box
534, Menomonee Falls, WI
53052-0534

708 South Avenue, Franklin, OH
45005

Mathews and Cedar Hollow Road, P.O.
Box 500, Paoli, PA 19301

2750 - 145th Street West,

Rosemount, MN 55068-4998

9314 Princess Palm Ave., Tampa, FL
33619

244 Warner Road, Maplesville, AL
36750

12100 Smith Drive, Huntley, IL
60142

Select Drive, Leavenworth, Kansas

Eisenhower Road, Leavenworth,
Kansas

2-43

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Hargo Flexible Packaging Corp

Hargo Flexible Packaging Corp

Hargro Flexible Packaging

Hargro Health Care Packaging

Home Plastics, Inc.

Huntsman Packaging Products, Corp

Carolina Printing & Converting Interfl

International Paper

International

Paper

International

Paper

International

Paper

International

Paper

International

Paper

County Line Road, Boyertown, PA
19512

1501 North Seventh Street,
Harrisburg, PA 17102

U.S. 31 North, P.O. Box 188,
Edinburgh, IN 46124

3500 N. Kimball Avenue, Chicago, IL
60618-5508

5250 NE 17th St, DesMoines, IA
50313

8039 S. 192nd Street, Kent,
Washington 98032-2162

Rt. 4 Box 4 Highway
268 West,

Wilkesboro, NC 28697

310 Airport Drive, Presque Isle, ME
04769

Auburndale

Carson

Chicago

Cincinnati

Dallas

2-44

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Table 2-10. Wide-Web Flexographic Printing Responses

(continued).

International

Paper



Detroit

International

Paper



Edinburg

International

Paper



El Paso

International

Paper



Fond du Lac

International

Paper



Geneva

International

Paper



Georgetown

International

Paper



Minneapolis

International

Paper



Mobile

International

Paper



Modesto

International

Paper



Mt. Carmel

International

Paper



Nashville

International

Paper



Putnam

International

Paper



Russellvile

International

Paper



San Jose

International

Paper



Shreveport

International

Paper



Spring Hill

International

Paper



Statesville

International

Paper



Stockton

International

Paper



Tallman

International

Paper



Wooster

International

Paper-Bag

Pack

Camden

International

Paper-Bag

Pack

Jackson

International

Paper-Bag

Pack

Mobile

International

Paper-Bag

Pack

Pittsburg

International

Paper-Bag

Pack

Wilmington

International

Paper-folding Cartons

Hopkinsville

International

Paper--Label Div

Peoria

International

Paper-Specialty Div.

Menasha

International

Paper-Specialty Div.

Lancaster

2-45

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International Paper-Specialty Div.
International Paper-Specialty Div.
Interstate Packaging Corp.

James River Paper Company

Kaukauna
Knoxville

P.O. Box 271, Coldenham Road,
Walden, NY 12586

Camas Mill; 4th and Adams; Camas,
WA 98607

James River Paper Co

James River Paper Co., Inc

James River Paper Co

P.O. Box 500, 126 A Avenue,
Darlington, SC 29532

James River Corporation, 605
Kuebler Rd., Easton, PA 18042

4411 Midland Blvd., Fort Smith, AR
72904

James River Paper Co., Inc.

1505 West Main Street, Greensburg,
IN 47240

James River Corp. Location 571

310 McDonnell Blvd., Hazelwood, MO
63042

James River Paper Co

451 Harbison Rd., Lexington, KY
40511

James River Corporation, Creative

James River Corp

James River Corp

James River Corp

Expressions

3500 North Arlington Ave.,
Indianapolis, IN 46218

Canal Plant, 258 River Street,
Menasha, WI 54952

River Road and Grantham Lane, New
Castle, DE 19720

400 Island Avenue, Parchment, MI
49004

James River Paper Co., Inc.

North Portland Plant, 3400 N.
Marine Drive, Portland, OR 97217

2-46

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Table 2-10. Wide-Web Flexographic Printing Responses

(continued).

James River	2424 SE Holgate, Portland, OR

97202

James River - Specialty Tabletop	18554 S. Susana Road, Rancho

Dominguez, CA

James River Corp.	2101 Williams Street, San Leandro,

CA 94577

James River Paper Co.	210 Kansas City Ave., Shreveport,

LA 71107

James River Corp - Wausau Plant	200 West Bridge Street, P.O. Box

1047, Wausau, WI 54402-1047

Smurfit Flexible Packaging	1228 E Tower Road, Schaumburg, IL

60173-4386

Jefferson Smurfit Corp	170 Lisle Road, Lexington, KY

40511

Jefferson Smurfit/Container Corp. of America

601 Monster Road, SW, Renton,
WA 98055

Smurfit Flexible Packaging	7074 W. Parkland Ct, Milwaukee, WI

53188

Jefferson Smurfit Corp	301 S Butterfield Road, Muncie, IN

47303

Jefferson Smurfit Corp	12005 N. Burgard Road, Portland, OR

97203

JSC/CCA	99 Harris Street, Fulton, NY

13069

JSC/CCA	8440 Tewantin, Houston, TX 77061

Jefferson Smurfit Corp./Container Corp. of America

Shawnee & Ridge Road,

Muskogee, OK 74401

Jefferson Smurfit Corp	Sixth and Zschokke, Highland, IL

62249

Jefferson Smurfit Corp	122 Quentin Ave., New Brunswick, NJ

08901

Jefferson Smurfit Corp./Container Corp. of America

57 7 Goddard Ave.,

Chesterfield, MO 63005

Jefferson Smurfit/Container Corporation of America

2 65 W Trigg Avenue,

2-47

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Jefferson Smurfit Corporation
Jefferson Smurfit Corporation
Jefferson Smurfit Corp.
Jefferson Smurfit Corp.
Jefferson Smurfit Corp.
Jefferson Smurfit
Jefferson Smurfit Corp
JSC/CCA

Jefferson Smurfit

Jefferson Smurfit Corporation

Jefferson Smurfic	Corp
Jefferson Smurfit Corporation

Memphis, TN 3810 6

3505 Tree Court Industrial Blvd.,
St. Louis, MO 63122

201 S. Hillview Drive - Milpitas,
CA 95035

4600 Newlon Rd., Ft. Smith, AR
72914

6701 South Freeway, Fort Worth, TX
76134

3 N. Sherman Street, Anderson, IN
46016

111 Folmar Parkway, Montgomery, AL
36105

75 Cascade Blvd, Milford, CT
06460

100 McDonald Boulevard, Aston, PA
19014

41 Campion Road, New Hartford, NY
13413

12200 Westport Rd., Louisville, KY
40245

8209 CR 131, Wildwood, FL 34785

365 Audubon Road, Wakefield, MA
01880

2-48

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Table 2-10. Wide-Web Flexographic Printing Responses

(continued).

Jefferson Smurfit Corp
Jefferson Smurfit Corp

4512 Anderson Road, Knoxville, TN
37918

2200 Industrial Dr., P.O. Box 2277,
Jonesboro, AR72402

Jefferson Smurfit/Container Corp. of America

2 601 S. Malt Ave., Los Angeles,
CA 90040

Container Corporation of America

6541 Eastern Avenue, Baltimore, MD
21224

Jefferson Smurfit/Container Corporation of America

185 N. Smith Street,

Jefferson Smurfit Corp
Jefferson Smurfit Corp.

JSC/CCA

Container Corporation of America
JSC/CCA

Jefferson Smurfit Corporation

Jefferson Smurfit
Jefferson Smurfit Corportion

Jefferson Smurfit Corp

Jefferson Smurfit Corp

Jefferson Smurfit Corporation

Jefferson Smurfit Corporation

Jefferson Smurfit Corp

Jefferson Smurfit Corp

Corona, CA 91720

301 E 144th Street, Dolton, IL
60419

2743 South Pierce Street, Dallas,
TX 60419

2525 S. Sunland Avenue, Fresno, CA
93725

9960 Alliance Road, Cincinnati, OH
45242

975 North Freedom, Ravenna, OH

1201 East Lincolnway, LaPorte, IN
46350

N Pt. Blvd., Winston Salem, NC

172 0 Ninth Avenue, Humboldt, TN
38343

1601 Tri View Avenue, Sioux City,
IA 51103

Pearl and Central, Lancaster, NY
14086

775 South Linwood Road, P.O. Box
1268, Galesburg, IL 61402-1268

JSC Preprint, 9960 Alliance Road,
Cincinnati, OH 45242

1125 Haley Road, Murfreesboro, TN
37133-0638

460 N Belcrest, Springfield, MO
65808

2-49

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Jefferson Smurfit Corp./CCA
Packaging Unlimited, Inc.

Jefferson Smurfit Corporation

John H. Harland Company
Kookaburra USA LTD

Kleartone, Inc.

Lin Pac, Inc.

Lin Pac

Longhorn Packaging, Inc.

Macon Telegraph
Mafcote Industries

662 Washburn Switch Rd., Shelby, NC
28150

P.O. Box 5102, Pta de Tierra
Station, San Juan, Puerto Rico
00906

2101 Rossville Ave, Chattanooga, TN
37408

293 Miller Rd, Decatur, GA 30035

1 Commerce Drive S, Harriman, NY
10926

695 Summer Avenue, Westbury, NY
11590

4200 Cambridge Road, Fort Worth, TX
76155

5725 Commerce, Morristown, TN
37814

110 Pierce Ave., San Antonio, TX
78208

120 Broadway, Macon. GA 31213

4525 N. Euclid Ave., St. Louis, MO
63115

2-50

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Table 2-10. Wide-Web Flexographic Printing Responses

(continued).

Mafcote/SWACO
Mail-Well Envelope

Maine Poly, Inc.
Malnove, Inc.

Marglo Packaging Corp.

Massillon Container

101 Ascher Street., Quitman, MS
38355

4500 Tiedeman Road, Cleveland, OH
44144

P.O. Box 8, Route 202, Greene, ME
4115 University Blvd. Court West,
Jacksonville, FL 32217

1522 Old Country Road, Plainview,
NY 11803

49 Ohio Street, Navarre, OH 44662

McClatchy Newspapers, Inc., dba The Modesto Bee

1325 "H" Street, Modesto, CA
95354

McClatchy Newspapers, Inc. dba The Fresno Bee

1626 E Street, Fresno, CA
93786

Mead Packaging
Menasha Corporation

Miami Herald Publishing Co.
Mid-West Poly Pak, Inc.

Milwaukee Container

1105 Herndon Street, NW, Atlanta,
GA 30318

Menasha Packaging - Neenah Plant,
1645 Bergstrom Rd., Neenah, WI
54957

One Herald Plaza, Miami, FL 33032

P.O. Box 35, 89 Marion Street,
Doylestown, OH 44230

2800 W. Custer Avenue, Milwaukee,
WI 53209

M.T.P. Industries, Inc. (Mason Transparent Pkg)

1180 Commerce Avenue, Bronx,
NY 10462

Neenah Printing - Wide Web Flexo Plant 1257 Gillingham Road, Neenah, WI

54957-0425

Midwest Film Corp

Mohawk Northern Plastics, Inc.

Moore, Business Forms and Systems

4848 South Hoyne Avenue, Chicago,
IL 60 60 9

701 "A" Street NW / Box 583,
Auburn, WA 98 002

2275 Commerce Drive, Fremont, OH
43420

2-51

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NCR Corp.

NCR - B.F.D.

Nichols Paper Products Co., Inc.
Owens-Illinois, Inc.

Package Printing Co., Inc.

Package Products Flexible Corporation

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

2901 45W Bypass, Humboldt, TN
38343

1201 North Main Street, Viroqua, WI
54665

38 Depot Street, Nichols, WI
54152

Operator-1051 Bloomfield Rd.,
Bardstown, KY 40004

33 Myron Street, West Springfield,
MA 01089

2203 Hawkins St., Charlotte NC
28203

Akron, OH

Arlington, TX

Ashland, OH

Atlanta, GA

Buffalo, NY

Burlington, WI

Colby, WI

Denver, CO

Garland, TX

Gas City, IN

Goldsboro, NC

Grafton, WV

2-52

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Table 2-10. Wide

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Packaging

Corp

of

America

Web Flexographic Printing Responses
(continued).

Grandville, MI
Hanover, PA
Harrisonburg, VA
High Point, NC
Honea Path, SC
Jackson, TN
Jacksonville,

Knoxville, TN
Lancaster, PA
Los Angeles, CA
Marshalltown, IA
Miami, FL
Middletown, OH
Milwaukee, WI
Minneapolis, MN
Morganton, NC
Newark, OH
Newberry, SC
Northhampton, MA
Omaha, NE
Opelika, AL
Phoenix, AZ
Pittsburgh, PA
Piano, TX
Plymouth, MI
Richmond, VA
Salisbury, NC
Syracuse, NY
Trexlertown, PA

2-53

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Packaging Corp of America
Packaging Corp of America
Packaging Industries, Inc.

Vincennes, IN
Winter Haven, FL

2450 Alvarado Street, San Leandro,
CA 94577

Packaging Materials Incorporated

62805 Bennett Avenue, Cambridge, OH
43725

Packaging Products Corp.

1807 Parrish Drive, Rome, GA
30161

Packaging Products Corporation

999 Lee Street, Elk Grove Village,
IL 60007

Packaging Products Corp.

6800 W. 61st St., Mission, KS
66202

Packaging Specialties, Inc.

Pacquet Oneida, Inc.

P.O. Box 360, 1663 Armstrong Ave.,
Fayetteville, AR 72702-0360

10 Clifton Blvd., Clifton, NJ
07015

Paramount Packaging Corp.

800 Jordan Vally Rosad, Longview,
TX 76508

Paramount Packaging Corp.
Paramount Packaging Corp.

202 Oak Ave. Chalfont, PA 18914

720 Eagle Blvd. Shelbyville, TN
37160

Paramount Packaging Corp.

106 Samsonite Blvd, Murfreesboro,
TN 37130

Percy Kent Bag Co., Inc.

5910 Winner Road, Kansas City, MO
64125

Phoenix Packaging

10949 91st Ave, N, Maple Grove, MN
55369

Phoenix Products Co., Inc.

6161 N. 64th Street, Milwaukee, WI
53218

2-54

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Table 2-10. Wide-Web F1

(cor

Pioneer Balloon Company
Viskase Corp.

Plastic Packaging Corp
Plastic Packaging, Inc.

Plicon Corp.

Poly Plastic Packaging, Inc.

Poly Plastic Packaging, Inc.

Polyflex Film & Converting, Inc.

Press Telegram

Procter and Gamble Co.

Procter and Gamble Co.

Procter and Gamble Co.

Procter and Gamble Co.

Providence Journal Company

Rand -Whitney/Northeast Container
Rand -Whitney/Southeast Container Corp.

Rand -Whitney Container Corp.
Rex-Rosenlew International, Inc.

The Robinette Company

Rock-Tenn Company

cographic Printing Responses
inued).

2400 Pioneer Drive, El Dorado, KS
67042

24th and O'Neal Streets, P.O. Box
250, Centerville, IA 52544

750 South 65th Street, Kansas City,
KS 64111

12 4 6 Main Ave., S.E., P.O. Box
2029, Hickory, NC 28603

6001 River Road, Suite 300,
Columbus, GA 31904

510 Industrial Avenue, P.O. Box
219, Boynton Beach, FL 33425

36-36 36th Street, Long Island
City, NY 11101

1301 Hwy 51 N, Summit, MS 39666

604 Pine Avenue, Long Beach,
California 90844

512 Liberty Expressway, Albany, GA
31703

Mehoopany, PA 18 62 9

501 Eastman Ave., Green Bay, WI
54302

800 North Rice Ave., Oxnard, CA
93010

210 Kinsley Avenue, Providence, RI
02903

45 Industrial Way, Dover, NH 03820

455 Narragansett Park
Dr.,Pawtucket, RI 02861

Agrand St., Worcester, MA 01607

1308 Blair Street, Thomasville, NC
27360

250 Blackley Road, Bristol, TN
37625

329 Industrial Park Road, Harrison,
AR 72601

2-55

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Rock-Tenn Company

525 West 19th Street, Chattanooga,
TN 37408

Rock-Tenn Company

4 691 Lewis Road, Stone Mountain, GA
30086

Rock-Tenn Company

Rock-Tenn Company

Rock-Tenn Company

302 Hartman Drive, P.O. Box 997,
Lebanon, TN 37087

Forest Hills School Road,
Marshville, NC 28103

105 Tote - M Avenue, Eutaw, AL
35462

Rock-Tenn
Rock-Tenn Company

198 Commerce, Conway, AR 72032

6702 Hwy. 66W, Greenville, TX
75402

Rock-Tenn Company

R. R. Donnelley & Sons Company

302 Hartman Drive, P.O. Box 997,
Lebanon, TN 37087

Lancaster West Plant, 1375
Harrisburg Pike, Lancaster, PA
17601

Sealright Packaging Company

814 South First Street, Fulton, NY
13069

Sealright Packaging Co.

2925 Fairfax Road, Kansas City, KS
66115

2-56

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Table 2-10. Wide-Web Flexographic Printing Responses

(continued).

Sealright Packaging Co.

Venture Packaging

Jaite Packaging

Packaging Industries, Inc.

Selig Sealing Products, Inc.

Solar Press

Solo Cup Company

Solo Cup Company

Southern Colortype Co., Inc.

Specialty Container Corporation

Standard Packaging & Printing Corp.
The Standard Register Company

Sunrise Packaging, Inc.

Superpac, Inc.

Susan Crane, Inc.

Teepak, Inc.

Tennessee Press, Inc.

Toph

Toph

4209 E. Noakes Street, Los Angeles,
CA 90023

1600 Westinghouse Blvd., Charlotte,
NC 28273

1972 Akron-Peninsula Road, Akron,
OH 44313

2450 Alvarado Street, San Leandro,
CA 94577

342 E. Wabash, Forrest, IL 61741

1500	Shore Road, Naperville, IL
60563-1799

1951 Highway 304, Belen, New Mexico
87002

1501	E. 96th Street, Chicago, IL
60628

2927 Sidco Drive, Nashville, TN
37204

1608 Plantation Rd., Dallas, TX
75235

NC Hwy 73W, Mt. Gilead, NC 27306

Industrial Avenue, Rocky Mount, VA
24151

2025 W. South Branch Blvd., Oak
Creek, WI 53154

1220 Industrial Boulevard,
Southampton, PA 18966

8107 Chancellor Row, Dallas TX
75247

915 N. Michigan Avenue, Danville,
IL 61832

1400 Sixth Avenue, Knoxville, TN
37917

1120 Heritage Drive, Osage, IA
50461-0119

1001 Rialto Rd., Covington, TX
38019

2-57

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Uniflex, Inc.

474 Grand Blvd., Westbury, NY
11590

Union Camp Corp. - Container Division

1975 Lakeside Parkway SW 314,
Tucker, GA 30084

Union Camp Corp

W. Lathrop Ave., Savannah, GA
31402

Union Camp Corp

345 Cedar Springs Rd., P.O. Box
5497, Spartanburg, SC 29302

Union Camp Corp.

Hazleton Plant, Maplewood Drive,
Hazleton, PA 18201

Union Camp Corporation

501 Williams Street, Tomah, WI
54660

Union Camp Corp.

901 Commerce Circle, Shelbyville,
KY 40065

Union Camp Corp

10801 Iona Ave., Hanford, CA
93230

Union Camp Corp

3100 Jim Christal Rd., Denton, TX
76207

Union Camp Corp

2200 D. Avenue East, Freeman Field,
Seymour, IN 4 7274

2-58

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Table 2-10

Union Camp Corp
Union Camp Corp.
Union Camp, Inc.

Wide-Web Flexographic Printing Responses
(continued).

3055 Sweeten Creek Rd., Asheville,
NC 28813

Cloverdale Rd., P.O. Box 278,
Sibley, IA 51249

Union Camp Corp

Union Camp Corp., Richmond Retail Pkg.

Union Camp Corp

Viskase Corp.

Vitex Packaging, Inc.

Waldan Paper Services, Inc.

Ward/Kraft, Inc.

Western Publishing Co., Inc.

Beach Products

Wabash Pioneer Container Corp.

Westvaco Envelope Division

Westvaco Envelope Division
Westvaco Envelope Division
Westvaco Envelope Division
Westvaco Envelope Division
Westvaco Envelope Division
Westvaco Envelope Division

1829 Hwy. 35S, Monticello, AR
71655

Rt. 2, Box 433K, Tifton, GA 31794

2801 Cofer Road, Richmond, VA
23224

1304 Arthur K. Bolton Parkway,
Griffin, GA 30223

24th & O'Neal Streets, P.O. Box
250, Centerville, IA 52544

1137 Progress Road, Suffolk, VA
23434

167 W. 28th Avenue, Oshkosh, WI
54901

2401 Cooper Street, P.O. Box 938,

Fort Scott, Kansas	66701

1220 Mound Avenue, Racine, WI
53404

2001 Fulford, Kalamazoo, MI 49001

N143 W6049 Pioneer Road, Cedarburg,
WI 53012

Springfield Plant, 315 Industry
Avenue, Springfield, MA
01104-3246

Williamsburg Plant, Route 866, P.O.
Box C, Williamsburg, PA 16693

Atlanta Plant, 5625 New Peachtree
Road, Chamblee, GA 30341

North Chicago Plant, 1001 South
Sheridan, North Chicago, IL 60064

Indianapolis Plant, 6302 Churchman
Bypass, Indianapolis, IN 46203

Dallas Plant, 10700 Harry Hines
Blvd., Dallas, TX 75220

Los Angeles Plant,2828 East 12th
Street, Los Angeles, CA 90023

2-59

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Westvaco Envelope Division

Westvaco - Flexible Packaging

San Francisco Plant, 5650 Hollis
Street, Emeryville, CA 94608

311 Industry Avenue, Springfield,
MA 01101

Westvaco Container Division

3400 East Biddle Street, Baltimore,
MD 21213

Westvaco Container Division

85 Dorothy Street, Buffalo, NY
14206

Westvaco Container Division

4400 West 45th Street, Chicago, IL
60632

Westvaco Container Division

2110 West 110th Street, Cleveland,
OH 44102

Westvaco

Blue Springs Road, Cleveland, TN
37311

Westvaco Container Division

4847 Cargo Drive, Columbus, GA
31907

Westvaco Container Division
Westvaco Container Division

RR 2, Hwy 35, Eaton, OH 45320

601 North Modena Street, Gastonia,
NC 28053

Westvaco Container Division

Empire Avenue, Meriden, CT 06453

2-60

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Table 2-10. Wide-Web Flexographic Printing Responses

(concluded).

Westvaco Container Division

Westvaco Container Division

Westvaco, Liquid Packaging Division

Weyerhaeuser Paper Company

Weyerhaeuser Paper Company

Weyerhaeuser Paper Company

Weyerhaeuser Paper Company

Weyerhaeuser Company/IMPAK

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

Willamette Industries,	Inc.

2300 Jefferson Davis Hwy, Richmond,
VA 23234

Flexpak Plant 2910, Cofer Road,
Richmond, VA 23224

2828 Cofer Road, Richmond, VA
23224

100 Hawkes Street, Westbrook, ME
04092

950 Shaver Road NE, Cedar Rapids,
IA 52402

6706 N. 23rd Street, Tampa, FL
33610

261 Broadway, P.O. Box 509,
Franklin, KY 42134

5099 North Royal Atlanta Drive,
Tucker, GA 30084

Beaverton, OR;P. 0. Box G

Buena Park, CA

Dallas, TX

Kansas City, MO

Tacoma, WA

Aurora, IL

Beaverton, OR; P. 0. Box 666

Bellvue, Wa

Bellmawr, NJ

Bowling Green, KY

Cerritos, CA

Compton, CA

Dallas, TX

Delaware, OH

Elk Grove, IL

Fort Smith, AR

Golden, CO

2-61

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Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.

Willamette	Industries,	Inc.
Zim's Bagging Co., Inc.

Griffin, GA
Indianapolis, IN
Kansas City, KS
Lincoln, IL
Louisville, KY
Lumberton, NC
Matthews, NC
Memphis, TN
Moses Lake, WA
Newton, NC
Sacramento, CA
San Leandro, CA
Sanger, CA
Sealy, TX
St. Paul, MN
West Memphis, AR
Tigard, OR

4200 Big Sandy Rd., Prichard, WV
25555

2-62

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waterborne inks. Waterborne inks are available for some
applications which contain no HAP. Some waterborne inks
contain relatively low proportions of HAP, principally
ethylene glycol and glycol ethers. Most solvent based
flexographic inks contain little or no HAP. Capture and
control devices used with solvent based inks are usually
designed, permitted and operated for VOC control.
2.3.1.4 Baseline Emissions from Wide Web Flexographic Segment.
HAP emissions data are available for most of the facilities
submitting data in response to the ICR. In some cases,
responses were received, however the HAP emissions data were
not usable. This resulted from missing or ambiguous answers
to questions relating to HAP usage and control efficiency.
Nospecific control efficiency relative to HAP was requested.
Data have been analyzed on the assumption that overall HAP
control efficiency is equivalent to reported overall
efficiency. These data are most often based on tests or
vendor guarantees relating to VOC. In many cases, HAP makes
up only a minor proportion of the VOC used on press.

HAP emissions were calculated from wide-web flexographic
press operations at 475 facilities. Most facilities reported
data for calendar year 1992; in some cases data for more
recent twelve month periods were reported. A total of 10
facilities were determined to be major sources on the basis of
emissions of 25 tons of HAP per year, or 10 tons of any
individual HAP per year. If major source status is determined
by potential-to-emit, there will be a greater number of major
sources. Baseline emissions are given in Table 2-11.
2.3.2 Narrow Web Flexographic Printing

Narrow web flexographic presses are used principally for
printing and adhesive application on tags and labels. The
presses can be used to print on paper, foil, film or other
substrates. Ink systems for narrow web flexographic printing

2-63

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can be similar to those
cure inks are used with

for wide web; in addition, ultraviolet
some narrow web presses.

2-64

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Table 2-11. Baseline Emissions from Flexographic Printing.



All Responses

Major Sources

Number of Facilities

485

10

Material Applied
(lb/yr)

176,000,000

10,200,000

HAP Used (lb/yr)

2,350,000

827,000

HAP Emitted

1,680,000

706,000

Narrow web presses have the potential to emit relatively
small quantities of HAP. These presses are sometimes operated
with no capture or control systems.

2.4 LITHOGRAPHY

Lithography is a planographic method of printing (in
contrast to gravure, in which the image is etched into the
plate or flexography, in which the image is raised above the
surface of the plate). The plate surface is divided between
water repellent (ink receptive) and water receptive (ink
repellent). In offset lithographic printing, ink is
transferred from the plate to a rubber blanket cylinder. The
blanket cylinder is used to print the substrate38. An
extensive discussion of the processes, equipment, inks, and
other substances with the potential to result in HAP emissions
is given in the Control Techniques Guideline for Offset
Lithographic Printing39. There are over 54,000 lithographic
printing plants in the US, which supply about 50 percent of
the market for printing. About 91 percent of printing
facilities have lithographic presses40.

The lithographic printing industry is divided on the
basis of press equipment between sheet-fed, non-heatset web
and heatset web printing. The CTG41 makes a further
distinction between newspaper non-heatset web and non-
newspaper non-heatset web printing.

2-65

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2.4.1	Sheet-fed Lithography

About 92 percent of the facilities with lithographic
presses have sheetfed lithographic presses. Sheetfed presses
are used to print on metal, paper, cardboard, foil and film.
Commercial printing (e. g. advertising, brochures, annual
reports, business forms, etc.) is usually done by sheetfed
lithography42.

Organic emissions can arise from inks, fountain solutions
and cleaning chemicals, although potential HAP emissions come
primarily from fountain solutions. Sheet-fed lithographic
inks contain phenolic, maleic-modified or rosin-ester resins
dissolved in vegetable drying oils (e. g. linseed and soya)
and diluted with hydrocarbon solvents43. Most inks used in
sheetfed printing contain less than 25 percent VOC44, and no
HAP.

Fountain solutions are used to dampen the printing plates
to make the non-image areas repellent to ink. Traditionally,
these solutions were primarily isopropanol and water with some
added resins and buffering salts. These solutions contain no
HAP. In an attempt to reduce VOC emissions, alcohol
substitutes which often contain glycols and glycol ethers,
which are HAP, are now in use. Generally, no attempt has been
made to capture glycol ethers emitted from sheetfed
lithographic printing. Refrigeration of the fountain
solutions is a practical means to control emissions of VOC
from this source, but lower VOC, HAP containing alternatives
have been adopted in some cases as an alternative to
refrigeration of higher VOC, no HAP solutions.

Solvents used for press clean-up are usually kerosene
type high boiling point hydrocarbons, sometimes mixed with
detergents45. These materials can contain up to 100 percent
VOC but are generally free of HAP.

2.4.2	Non-Heatset Web Lithographic Printing

2-66

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Non-heatset web lithography is used to print newspapers,
journals, directories and forms. It is estimated that there
are 4950 plants with non-heatset web lithographic presses46.
The ink used is similar to that used in sheetfed lithography
and generally contains less than 35 percent VOC47. Fountain
solutions and clean-up solvents are similar to those used in
sheet-fed lithography. The main source of HAP from this
process is low VOC fountain solutions which contain glycols
and glycol ethers. Typically no controls for HAP are used.
Refrigeration of the fountain solutions is a practical means
to control emissions of VOC from this source, but lower VOC
HAP-containing alternatives have been adopted in some cases as
an alternative to refrigeration of higher VOC, no HAP
solutions.

2.4.3 Heatset Web Lithographic Printing

Heatset web lithography is used to print magazines,
periodicals and catalogs. It is estimated that there are 1376
plants with heatset web lithographic presses48. The inks are
about 40 percent VOC and contain high boiling petroleum
distillates, resins and pigments. In general, there are no
HAP in the ink. Fountain solutions and clean-up solvents are
similar to those used in sheet-fed lithography. The main
source of HAP from this process is low VOC fountain solutions
which contain glycols and glycol ethers.

Capture systems for heatset lithographic presses are used
to collect drier exhaust gases, which contain about 20 percent
of the VOC in the ink. Control system options include thermal
incinerators, catalytic incinerators, condenser filters with
activated carbon and condenser filters without activated
carbon. VOC control efficiencies are estimated at 98 percent
for incinerators, 95 percent for condenser filters with
activated carbon and 90 percent for condenser filters without
activated carbon49. It should be noted that there are no

2-67

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performance test data relating to HAP control efficiencies.

Refrigeration of the fountain solution is a practical
means to control emissions of VOC from this source, but lower
VOC HAP-containing alternatives have been adopted in some
cases as an alternative to refrigeration of higher VOC, no HAP
solutions. Clean-up solvents which contain no HAP, or only
very low levels of HAP are available.

2.5 LETTERPRESS

Letterpress printing uses a relief printing plate as does
flexography and viscous inks similar to lithographic inks.
Various types of letterpress plates are available. These
plates differ from flexographic plates in that they have a
metal backing. Both sheetfed and web presses are in use. Web
letterpress equipment using heatset and non-heatset inks is in
use. Newspapers were traditionally printed by web non-heatset
letterpress, however these are gradually being replaced by
flexographic and lithographic presses. Letterpress is used to
print newspapers, magazines, books, stationery and
advertising. It is estimated that there are about 21,000
plants with letterpress equipment of which about 19,000 have
sheetfed letterpress equipment50.

2.5.1 Non-heatset Letterpress

Non-heatset web letterpress ink is similar to non-heatset
lithographic ink differing mainly in that it contains less low
viscosity mineral oils and more vegetable oils and high
viscosity mineral oils51. No fountain solutions are required.
Cleaning solvents are similar to those used in lithography.
This process can be almost entirely HAP free. Non-heatset
letterpress equipment typically has no emissions control
systems.

Non-heatset sheetfed letterpress ink varies depending
upon factors including the substrate printed, the type of
plate and press, and the press speed. In most applications,

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this process can be almost entirely HAP free and is typically
conducted with no control system. No fountain solutions are
required. Cleaning solvents are similar to those used in
lithography. "Moisture set" inks used in some packaging
applications contain triethylene glycol, which is a HAP.

"Water washable" letterpress inks are sometimes used for
printing kraft paper and corrugated boxes. These inks contain
glycol based solvents which may contain HAP.

2.5.2 Heatset Letterpress

Heatset letterpress is used for publication printing on
coated papers. Heatset letterpress ink is similar to heatset
lithographic ink. These inks contain resins dissolved in
aliphatic hydrocarbons. These inks are dried in hot air
ovens; drier exhausts can be ducted to VOC control systems.
The inks can be entirely HAP free. No fountain solutions are
required. Cleaning solvents are similar to those used in
lithography.

2.6 SCREEN PRINTING

Screen printing processes involve forcing ink through a
stencil in which the image areas are porous. The screens are
generally made of silk, nylon or metal mesh. Screen printing
is used for signs, displays, electronics, wall paper, greeting
cards, ceramics, decals, banners and textiles. It has been
estimated that there are more than 40,000 screen printing
plants in the U. S., nearly half of which print textiles52.

Ink systems used in screen printing include ultraviolet
cure, waterborne, solvent borne and plastisol with plastisol
(polyvinyl chloride) being mainly used in textile printing.
Solvent based ink systems contain aliphatic, aromatic and
oxygenated organic solvents.

Both sheetfed and web presses are used. Depending on the
substrate printed, the substrate can be dried after each
station or, for absorbent substrates, after all colors are

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printed. Solvent and waterborne inks are dried in hot air or
infrared drying ovens. Dryer gases are partially recycled and
partially vented (either to the atmosphere or to a control
system). Both thermal and catalytic oxidizers are in use on
screen printing dryer exhausts for solvent borne ink systems.
Overall control efficiencies of 70 to 80 percent are
achievable53.

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2.7 OTHER PRINTING PROCESSES

Plateless printing technologies are relatively new
processes used primarily for short runs on paper substrates.
These processes include electronic (e.g., laser printers),
electrostatic (e.g., xerographic copiers), magnetic, thermal
(e.g., facsimile machines) and ink jet printing. In 1991,
plateless printing processes accounted for 3 percent of the
total value of printing54. Electrostatic toners and ink jet
printer inks mav contain HAP, however the quantities emitted
at any location are small.

2.7 REFERENCES

1.	U. S. Environmental Protection Agency. Use Cluster Analysis
of the Printing Industry, Draft Final Report. Washington,
DC. May 26, 1992. p. 8.

2.	Documentation for Developing the Initial Source Category
List. U. S. Environmental Protection Agency, Research
Triangle Park, NC. EPA-450/3-91-030. December, 1991.

3.	Publication Rotogravure Printing - Background Information
for Proposed Standards. U. S. EPA. Research Triangle Park,
NC. EPA-450/3-80-031a. October, 1980. pp2-l to 4-40.

4.	Edgerton, Stephen, Joanne Kempen and Thomas W. Lapp. The
Measurement Solution: Using a Temporary Total Enclosure
Method for Capture Efficiency Testing. EPA-450/4-91-020.
August 1991.

5.	Reference 3, p. 3-7.

6.	Profile Survey of the U. S. Gravure Industry; A Market Study
of Industries Using Gravure and a Profile of Equipment,
Cylinders, Ink and Substrates. Gravure Association of
America. 1989. p. PRESS-18.

7.	Reference 6, p. SUM-10.

8.	Memorandum from Green, D., RTI, to D. Salman, EPA/ESD.

April 6, 1993. Summary of meeting with EPA, RTI, and
representatives of the Flexible Packaging Association,
Research Triangle Park, NC.

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9.

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

Reference 6
Reference 6
Reference 6
Reference 6
Reference 6
Reference 6
Reference 6
Reference 6
Reference 6
Reference 6
Reference 6
Reference 6

MAR-5 6.
MAR-67.
MAR-7 2 .
SUM-12.
MAR- 7 9 .
MAR-8 6.
MAR-8 7.
SUM-14.
MAR-97.
SUM-16.
SUM-18.
SUM-21.

Memorandum from Green, D., RTI, to D. Salman, EPA/ESD.
September 12, 1994. Summary of Meeting with Representatives
of the Gravure Association of America.

Reference 6, p. INK-5.

Reference 6, p. INK-11.

Reference 6, p. INK-6.

Reference 6, p. INK-8.

Memorandum from Green, D., RTI, to Salman, D., EPA/CPB.

July 30, 1993. Summary of meeting with Representatives of
the Flexible Packaging Association.

Reference 26.

Reference 6, p. INK-9.

Reference 6, p. MAR-126.

Reference 2.

Reference 1, p. 15.

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32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

Mulvihill, Donna C. Flexography Primer, Graphic Arts
Technical Foundation, Pittsburgh, PA. 1985. p. 57.

Printing Ink Handbook, Fifth edition. National Association
of Printing Ink Manufacturers, Inc. Harrison, NY. 1988. p.
38 .

Reference 32, p. 60.

Reference 32, p. 60-64.

Reference 32, p. 49-50.

Cunningham, Elizabeth. Flexo in Flux. American Ink Maker.
June 1992. pp. 52.

U. S. Environmental Protection Agency. Control of Volatile
Organic Compound Emissions from Offset Lithographic Printing
-Draft. Research Triangle Park, NC. September, 1983. p. 2-
1.

Reference 38, 235 pp.

Reference 1, p. 63.

Reference 38, p. 2-4
Reference 33, p. 34.

Kirk-Othmer Encyclopedia of Chemical Technology, Third
Edition. "Inks". New York, NY. 1982. p. 374.

Reference 38, p. 2-8.

Reference 38, p.2-4.

Reference 1, p. 63.

Reference 38, p. 3-37.

Reference 1, p. B-28.

Reference 38, p.4-1 to 4-14.
Reference 1, p. 101.

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51. Cunningham, H. W. Nonheatset Web Printing, in Bunicore, A.
and W. T. Davis. Air Pollution Engineering Manual. New
York, NY. 1992.

52.	Kinter, Marcia. Screen Printing, in Bunicore, A. and W. T.
Davis. Air Pollution Engineering Manual. New York. NY.
1992 .

53.	Reference 52.

54.	Reference 1, p. 40.

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3.0 CONTROL TECHNOLOGY AND PERFORMANCE OF CONTROLS

3.1	INTRODUCTION

There are two approaches to limitation of HAP in the
printing and publishing industry. The first approach is to
improve capture and control systems or to add control devices
where none are in use. Capture and control can be addressed
separately, although in many cases, improved capture is achieved
through an increase in the amount of air handled. This can
necessitate upgrades to existing control devices. The second
approach, focusing on pollution prevention, is to substitute low
HAP or HAP-free materials for materials (inks, coatings,
varnishes, adhesives, primers, etc.) presently in use.

3.2	CAPTURE SYSTEMS

Capture systems are designed to collect solvent laden air
and direct it to a control device. In heatset printing
processes, solvent is removed from the printed substrate by
evaporation in a dryer. The exhaust from the dryer can be ducted
to a control device. Additional systems are often used to
collect solvents which evaporate from other parts of the printing
press, as well as those which escape from the dryer. In
addition, pressroom ventilation air can be exhausted to a control
device.

Differences in capture efficiency contribute much more to
the variation in overall efficiencies than the choice of control
device. Reported capture efficiencies ranged from estimates of
less than 50 percent to the 100 percent capture which is assumed
for systems meeting the requirements of permanent total

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enclosures. Test procedures have been established for
determining capture efficiency1 and for confirming the presence
of permanent total enclosures.2 Capture systems can be improved
through collection of additional solvent laden air from the press
area and through construction of additional hooding and press
enclosures. In theory, capture can be improved to (nearly) 100
percent for any press or pressroom by retrofitting walls and
increasing ventilation to meet the requirements of permanent
total enclosures. In practice, it may be prohibitively expensive
to retrofit some existing facilities.

3.2.1	Publication Rotogravure.

Within the publication rotogravure industry, all presses
have dryer exhaust gases routed to the solvent recovery system.
Based on responses to the voluntary question list developed by
the EPA and the GAA, additional capture systems in place were
described as dryer hood systems, partial upper deck enclosures,
full upper deck enclosures, enclosed presses, permanent total
enclosures, room enclosures, rooms operated under negative
pressure and floor sweeps. It is not known whether the capture
systems described as enclosed presses and room enclosures meet
the EPA definition of permanent total enclosure3. Typically,
solvent laden air captured from several presses is combined and
treated with a common solvent recovery system. The individual
presses may have different capture devices, and different capture
efficiencies.

3.2.2	Product and Package Gravure.

In the product and package gravure industry, many facilities
use low VOC (and low-HAP) inks and coatings. Dryer exhausts from
these facilities may be captured and vented to the atmosphere
without the use of a control device. Where solvent based inks
are in use, more elaborate capture and control systems may be
required. Capture systems in use at product and packaging
gravure facilities include combinations of dryer exhausts, floor

3-2

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sweeps, collection ducting, hoods, press enclosures, total
enclosures, room enclosures, negative pressure pressrooms,
partial enclosures and ink pan covers. With the exception of
total enclosures, none of these technologies has a precise
definition with regard to capture efficiency. In many cases
terms are used interchangeably. Where control devices are in
use, solvent laden air from several presses may be combined and
ducted to a common control device.

3.2.3 Wide-web Flexocrraphic Printing.

Capture systems in use at flexographic printing facilities
include combinations of dryer exhausts, floor sweeps, hoods, and
total enclosures. Capture efficiencies of between 50 and 100
percent were reported, although many respondents did not report
capture efficiencies.Many facilities, including most sheetfed
corrugated box facilities have no capture systems and rely on
pressroom exhaust to the atmosphere to dilute the small amount of
HAP present in the ink.

3.3 CONTROL DEVICES

The control devices in use in rotogravure and flexographic
printing processes include carbon adsorption, thermal
incineration and catalytic incineration. The selection of a
control device is influenced by the type of inks (and other
materials) applied on the press, the volume of solvent laden air
to be treated and the operating schedule of facility. Design
procedures and limitations for these control devices are given in
the EPA Control Technologies Handbook4.

3.3.1 Carbon Adsorption.

Activated carbon is a material with a high surface area
which adsorbs many organics from air streams. Typically, solvent
laden air is passed through two or more fixed beds of granular
activated carbon. Organic HAP in the air is adsorbed on active
sites on the carbon, until, at some point the capacity of the
carbon is exhausted, and the organics pass through unadsorbed.

3-3

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Adsorbers are operated in parallel so that when the capacity of
one unit is exhausted, it can be removed from service and a
second adsorber can be put into service. The exhausted carbon in
the first adsorber is then regenerated5.

In contrast to incineration techniques, carbon adsorption
does not destroy the HAP in the treated air. Carbon adsorbers in
the printing industry are regenerated by passing steam through
the carbon beds. The HAP is removed from the carbon, and
transferred to the steam. The steam-HAP mixture is then
condensed, and the solvent separates from the water. The solvent
can then be decanted for sale or reuse.

Carbon adsorption systems can achieve control device
efficiencies of 95 to 99 percent for some organic HAP6. These
systems are most suitable for solvent systems which are
immiscible with water, such as toluene and xylene. They are not
recommended for ketones such as methyl ethyl ketone and methyl
isobutyl ketone.

3.3.2 Thermal Incineration

Thermal incinerators are control devices in which the
solvent laden air is preheated and the organic HAP are ignited
and combusted to carbon dioxide and water. Dilute gas streams
require auxiliary fuel (generally natural gas) to sustain
combustion. Various incinerator designs are used by different
manufactures. The combustion chamber designs must provide high
turbulence to mix the fuel and solvent laden air. The other
requirements are a high enough temperature and a long enough
residence time to insure essentially complete combustion.

Thermal incinerators can be operated to achieve a wide range of
control device efficiencies7. Efficiencies of 98 percent8 to
greater than 99 percent are possible9.

Because the incinerator must be in operation at times when
HAP emissions are very low (e. g. when presses are on standby
between jobs) supplemental fuel requirements will vary.

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Incinerators are supplied with controls to start-up and bring the
combustion chamber to the proper temperature. These controls can
provide an interlock to prevent operation of the press until the
incinerator temperature is adequate to insure destruction of HAP.
3.3.3 Catalytic Incineration

Catalytic incinerators are control devices in which the
solvent laden air is preheated and the organic HAP are ignited
and combusted to carbon dioxide and water. In the presence of a
catalyst, this reaction will take place at lower temperatures
than those required for thermal incineration. Temperatures
between 350 and 500 degrees Celsius are common. The catalysts
are metal oxides or precious metals where are supported on
ceramic or metallic substrates. Catalytic incinerators can
achieve control device efficiencies of 95 to 99 percent10.

From an operational standpoint, the lower reaction
temperature means that the requirement for supplemental fuel is
reduced or eliminated during normal operation. The lower
operating temperatures will also decease the formation of oxides
of nitrogen.

The use of a catalyst is inconsistent with certain ink
formulations. Chlorinated solvents and some silicone ink
additives can poison or deactivate catalysts. Design of
catalytic incinerators varies from manufacturer to manufacturer.
The major differences involve the geometry of the combustion
chamber, the type of catalyst and support material, and the type
of contact between the gas and the catalyst.

3.4 PERFORMANCE OF CONTROLS
3.4.1 Publication Gravure

The 27 plants currently operating in the U. S. all use
toluene based ink systems, and operate solvent recovery systems
which include fixed bed activated carbon adsorption units which
are regenerated with steam. Recovered solvent is added to the
as-purchased ink to adjust the viscosity as necessary. Excess

3-5

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recovered solvent is sold back to the ink manufacturers. Press
capture systems vary depending on the age of the press, however
the majority of the solvent is captured through the dryer
exhausts.

A total of 31 separate solvent recovery systems are in
service at the 27 publication gravure plants. In addition, some
plants have substituted non-HAP solvents for a portion of the
toluene based solvent in publication gravure ink.

Catalytic and thermal oxidation systems are technically feasible
for control of publication gravure emissions. These technologies
offer little or no potential improvement in control and have
economic disadvantages as they destroy rather than recover the
solvent.

The control devices in use at all publication gravure
facilities are similar in design and operation. Capture
efficiencies of between 85 and 100 percent were reported, however
this information was not available for the majority of the
presses. Control device efficiencies of 95 to 99.9 percent were
reported, however, these data were not reported for all control
systems. The median control efficiency reported was 98 percent.
One solvent recovery system manufacturer estimates control device
efficiencies for publication gravure systems at 97 to 99 percent.
This estimate excludes solvent retained in the web equal to
between 1 and 5 percent of that applied11. This indicates a
maximum expected overall efficiency of 98 percent (i.e. 99
percent control of the 99 percent of the HAP which is not
retained).

Excluding that portion of the HAP which is retained in the
web and emitted after it leaves the press, control device
efficiencies can theoretically be improved with thicker carbon
beds. Improvement in capture efficiency is expected to be more
cost effective in many cases, as capture efficiencies of close to
100 percent have been achieved using total enclosures.

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Overall efficiencies, based on liquid-liquid mass balances
were reported for all control systems. Overall efficiency
represents the product of capture efficiency and control device
efficiency. These involve determinations of total VOC present in
purchased ink and other VOC containing materials, inventories of
solvent recovery and use through tank level measurements, and
flow meters on ink distribution and recovered solvent purchases.
These balances are conducted frequently by all facilities, and
are typically reported as monthly averages.

Long term averages are highly accurate as noise from
measurement errors is averaged out. The nature of the testing,
i. e. material balance, eliminates much of the error associated
with sampling and analysis of stack emissions. Analyses of VOC
and HAP content of inks and other materials are, however, subject
to chemical analysis errors.

On an annual basis, overall efficiencies were reported in
the range of 83 to 109 percent. It should be noted that the
system reporting 109 percent overall efficiency is able to
achieve a solvent recovery of over 100% by drawing air from a
pressroom controlled by a separate control system, containing
presses with a lower capture efficiency. Thus, this control
system actually recovers fugitive emissions from a separate
source, in addition to the emissions from the presses that it
controls.

All facilities reported overall efficiencies achieved in
1992, and provided the range of overall efficiencies achieved
determined on a monthly basis for 1992. Since some facilities
operate more than one control system, data from 33 control
systems were reported by the 27 facilities. The range of overall
control data reported for these control systems in the voluntary
responses provided to EPA is given in Table 3-1.

3-7

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Table 3-1. Overall Control Efficiencies Reported for Publication

Gravure Plants.

Basis of Ranking

Best Month

Annual Average

Worst Month

Overall Control

a
o

a
o

a
o

Best System

115

109

96

Median System

94

91 . 8

88

Worst System

85

83

78

3.4.2 Product and Packaging Gravure

Product and packaging gravure facilities use a variety of
ink systems. Inks in use include toluene based inks which are
similar or identical to those used in publication gravure (See
section 3.4.1), high VOC solvent based inks with very low or no
HAP content, waterborne ink with low VOC and low HAP content and
waterborne ink with low VOC and no HAP content.

The type of ink used is influenced by factors including the
nature of the substrate printed, the type of product or package
printed, the age of the press and existing air pollution
regulations and permit requirements related to VOC emissions.
Product and packaging rotogravure ink can contain HAP such as
toluene, hexane, methyl ethyl ketone, methyl isobutyl ketone,
methanol and glycol ethers as well as non-HAP VOC such as ethyl
acetate propyl acetate and butyl acetate. The control
technologies employed are influenced by the type of ink used.

Existing control technologies for product and packaging
rotogravure are directed to control of VOC. In most cases, the
HAP and non-HAP portion of the VOC present in the ink are equally
difficult to control.

Based on data submitted in response to the ICR, control
devices in use at product and packaging gravure facilities
include carbon adsorption, catalytic incineration, fume
incineration, fume/vapor incineration, (unspecified)

3-8

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incineration, fumes burned in boiler, periodic recuperative
thermal oxidation, recuperative incineration, regenerative
thermal oxidation and regenerative thermal incineration. These
terms refer to devices which can be divided into three groups:
carbon adsorption, thermal incineration and catalytic
incineration.

Emissions data submitted in response to the ICR are based on
emissions tests, equipment vendors guarantees and various types
of engineering estimates. In all cases, emissions test data
refer to VOC emissions. It is assumed that recovery or
destruction of VOC is equivalent to that for HAP. Capture
efficiencies of between 30 and 100 percent were reported,
although many respondents did not report capture efficiencies.
Control device efficiencies of between 89 and 100 percent were
reported by respondents reporting non-zero control device
efficiencies. Control device efficiencies were not reported by
all facilities which operate control devices.

Data on overall efficiency were reported for 87 control
systems. Some facilities responding to the ICR did not operate
control systems. The 87 systems for which usable data were
available claimed overall efficiencies of between 45 and 100
percent. The basis for the estimates vary. Where solvent
recovery systems are in place the overall efficiencies are
typically determined by liquid-liquid mass balances (as described
in Section 3.4.2). If total enclosures are in place capture
efficiency is assumed to be 100 percent; control device
efficiency is calculated.

For catalytic and thermal incineration control devices test
data is available for overall efficiency in some cases and for
control device efficiency in others. Where test data is
available for destruction across the control device, capture
efficiencies are often estimated using engineering judgment.
Overall efficiencies incorporate these judgments. In many cases,

3-9

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either the control device efficiency or the capture efficiency
was based on vender guarantees and the overall efficiency was
estimated. In general, when operated as designed, control
devices will out-perform vender guarantees on an average basis.

It should be noted that the accuracy of the reported overall
efficiencies varies. In addition to the (presumably biased low)
data based on vendor guarantees, estimates made by operating
personnel of capture efficiency may not be realistic. There is,
however, less likelihood of a consistent bias (high or low) in
these estimates.

Overall efficiency data were reported for 87 control
systems. Other facilities had no control devices in place.

These data are of variable reliability, as described above. In
addition it should be recalled that reported efficiency data
pertain to VOC control and that the applicability of these data
to the HAP portion of the VOC has not been determined. The range
of overall efficiencies for carbon adsorption, catalytic

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incineration and all other types of incineration are given in
Table 3-2 .

Table 3-2. Overall Efficiencies Reported for Product and
Packaging Gravure Facilities with Control Systems.

Control
Device

Number of
Systems

Minimum
Efficiency

Average
Efficiency

Maximum
Efficiency

Carbon
Adsorption

22

45

79.8

100

Catalytic
Incineration

24

65

85.4

99.2

Thermal
Incineration

41

47 . 5

83 . 6

99.2

The range of control device efficiencies for the systems
where these data are reported is given in Table 3-3. Overall
efficiencies reported for three specific industry segments are
given in Table 3-4. These data are also given for the major
sources (as determined by actual HAP emissions) in the industry
segments.

3.4.3 Wide-web Flexocrraphic Printing

Flexographic printing facilities use a variety of ink
systems. Solvent based inks are primarily formulated with non-
HAP solvents which may contain small proportions of ethylene
glycol, glycol ethers and methanol which are HAP. Solvent based
inks are available for some applications which are completely HAP
free. Capture and control systems used with these systems are
designed and operated for control of VOC. In the absence of
compound specific performance data it is assumed that individual
HAP are controlled to the same extent as VOC.

The type of ink used is influenced by factors including the
nature of the substrate printed, the type of product or package

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Table 3-3. Control Device Efficiencies Reported for Packaging and
Product Gravure Facilities with Control Systems.

Control Device

Minimum Efficiency (%)

Maximum Efficiency(%)

Carbon
Adsorption

89

100

Catalytic
Incineration

CO

CO
CO

99.7

Thermal
Incineration

CO

CO
CO

99.3

Table 3-4. Overall Efficiencies by Industry Segment for
Packaging and Product Gravure Facilities with Control Systems
(Data for Major sources in Parentheses).

Industry Segment

Overall Efficiency (%)

Paper/Cardboard Only

45-98.6 (65-95.3)

Foil/Film Only

65-95 (65-95)

Vinyl Product

80-97.7 (80-93)

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printed, the age of the press and existing air pollution
regulations and permit requirements related to VOC emissions.
Packaging ink is subject to additional requirements depending on
the intended contents of the package.

Many wide web flexographic printing facilities use
waterborne inks with either no HAP or low HAP content. The
majority of these facilities have no control devices, and may
have converted from solvent based to waterborne materials to
avoid the need to install control devices to comply with VOC
regulations. Existing control devices for flexography are
directed to control of VOC. In most cases, the HAP and non-HAP
portion of the VOC present in the ink are equally difficult to
control.

Where control devices are in use, solvent laden air from
several presses may be combined and ducted to a common control
device. In addition, HAP from flexographic printing may be
ducted to control devices designed and operated for control of
HAP from other processes (such as rotogravure) operated at the
same plant.

Based on data submitted in response to the ICR, control
devices in use at flexographic facilities include carbon
adsorption, catalytic incinerators, and thermal incinerators
(including, but not limited to regenerative and recuperative).

Usable ICR data are reported by industry segment and control
device in Table 3-5.

Emissions data submitted in response to the ICR is based on
emissions tests, equipment vendors guarantees and various types
of engineering estimates. In all cases, emissions test data
refer to VOC emissions. It is assumed that recovery or
destruction of VOC is equivalent to that for HAP. Control device
efficiencies of between 90 and 99 percent were reported by
respondents reporting non-zero control device efficiencies.

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A total of 53 facilities operated control devices. Those
facilities which do not operate control devices were assumed to
emit 100% of the HAP used. Not all of the facilities which

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Table 3-5. Control Devices in Use by Flexographic Printers.



Control Device



None

Catalytic
Incinerator

Thermal Incinerator

Solvent
Recovery

Total

Segment

Recuperative

Regenerative

Other

















Corrugated box

238

0

0

0

0

0

238

















Flexible Packaging















Film/foil

55

26

4

0

1

1

87

Paper/cardboard

40

1

0

0

0

0

41

Mixed/unknown

43

15

1

2

1

1

63

Total

138

42

5

2

2

2

191

















Product

















Paper/plastic

9

0

0

0

0

0

9

Paper only

40

0

0

0

0

0

40

Total

49

0

0

0

0

0

49

















Books/directories

3

0

0

0

0

0

3

















Newspapers



8

0

0

0

0

0

8

















Total



436

42

5

2

2

2

489

-------
reported overall efficiencies provided separate data on capture
and control efficiencies. The basis for the estimates vary.
Solvent recovery systems are in place at two facilities; overall
efficiency data for these control systems are typically
determined by liquid-liquid mass balances (as described in
Section 3.4.1) .

For catalytic and thermal incineration control devices test
data is available for overall efficiency in some cases and for
control device efficiency in others. Where test data is
available for destruction across the control device, capture
efficiencies are often estimated using engineering judgment.
Overall efficiencies incorporate these judgments. In many cases,
either the control device efficiency or the capture efficiency
was based on vender guarantees and the overall efficiency was
estimated.

It should be noted that the accuracy of the reported overall
efficiencies varies. In addition to the (presumably biased low)
data based on vendor guarantees, estimates made by operating
personnel of capture efficiency may not be realistic. There is,
however, less likelihood of a consistent bias (high or low) in
these estimates.

Based on approximately 500 usable responses to the ICR, 125
facilities reported using no HAP whatsoever for flexographic
printing. Overall efficiency data was reported for 53 control
systems. It should be noted that none of the facilities
operating control devices had HAP emissions in excess of 25 tons
per year of HAP of 10 tons per year of any specific HAP.

Reported efficiency data pertain to VOC control and the
applicability of these data to the HAP portion of the VOC has not
been determined. The range of overall efficiencies for carbon
adsorption, catalytic incineration and all other types of
incineration are given in Table 3-6.

3-16

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Most of the variation in overall efficiencies is due to
variation in capture efficiencies. All of the reported control
device efficiencies were greater than 91 percent, although not

3-17

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Table 3-6. Overall Efficiencies Reported for Flexographic
Facilities with Control Systems.

Control
Device

Number of
Systems

Minimum
Efficiency

Average
Efficiency

Maximum
Efficiency

Carbon
Adsorption

2

91

93

95

Catalytic
Incineration

42

48

77

98

Thermal
Incineration

9

48

76

95

all facilities reporting overall efficiencies provided data on
control device efficiencies.

Control device capabilities applicable to flexographic
printing are comparable to those for packaging and product
rotogravure (see Section 3.4.2). Capture systems for in-line
presses are comparable to those for gravure presses. Capture
systems for dryer exhausts from common impression and stack
presses may be less efficient than those for in-line presses.
The technology and capabilities of total enclosures and press
room ventilation described in Section 3.2 are applicable to
flexographic printing.

3.5 LOW HAP AND HAP-FREE INKS (AND OTHER MATERIALS)

Most facilities have adopted air pollution control
strategies directed towards elimination or control of VOC. Many
low HAP inks contain high proportions of VOC. VOC control
devices also control organic HAP. Some existing regulations have
resulted in lower VOC emissions as sources converted from solvent
based to waterborne inks. In some cases, conversion to
waterborne inks, which could result in significant reduction in
VOC use, will be inhibited if HAP standards are formulated in
terms of percentage reduction.

3-18

-------
The types of control devices used by facilities using
solvent based inks, are not likely to adequately function as HAP
control devices when waterborne inks are used, because the dryer
exhaust streams will contain relatively large amounts of water
and relatively low heat content. In cases where low HAP (as
opposed to no HAP) inks are necessary for particular products or
packaging, the feasibilty of conversion to waterborne inks may
form the basis for segmentation of the industry for HAP
regulation. Conversion from solvent based inks to waterborne
inks may in some cases increase the amount of HAP in the press
exhaust.

3.5.1	Publication Rotogravure

At present all publication gravure facilities use solvent
systems based on HAP. The solvent in use is principally toluene;
other aromatic HAP (xylenes and ethylbenzene) are sometimes
present in the solvent blend. Eleven of the 33 control systems
use solvents which are 100 percent HAP. Some facilities have
been able to print with acceptable speed and quality using a
solvent which contains a lower proportion of HAP. While the
solvent in use is still 100 percent VOC, the substitution of non-
HAP solvent represents a HAP pollution prevention opportunity of
demonstrated feasibility.

As of yet, water-borne publication gravure inks have not
been developed which offer the production speed and print quality
of solvent based inks12. The development of acceptable
waterborne inks may represent a future pollution prevention
opportunity.

3.5.2	Product and Packaging Rotogravure

Pollution prevention, in terms of HAP elimination has been
achieved by many facilities in the packaging and product
rotogravure industry. Inks with zero HAP content are available
and in use at some facilities in all industry segments. In
addition, many facilities, particularly those printing on paper

3-19

-------
and cardboard packaging, use waterborne inks which contain only a
very low percentage of HAP. These inks typically contain a small
proportion of glycol ethers which function to reduce surface
tension and improve flow characteristics. The adoption of these
inks by additional existing sources is a likely consequence of
increased regulation of HAP emissions. It should also be noted
that some solvent based inks are completely HAP free.

Packaging and product rotogravure facilities produce a wide
variety of products. Flexible packaging producers, in
particular, print on many different substrates within the same
facility. Low HAP inks may not be available to meet all of the
performance requirements of these facilities. In addition, many
facilities use hundreds of different inks to print various custom
colors required by their packaging customers. Low HAP inks may
not be available for all substrates in all of the colors required
by some facilities. Existing facilities with well performing
control systems may have little incentive to make additional
investments to adapt to inks with no HAP.

Some sources currently use carbon adsorption steam
regeneration solvent recovery systems. These systems have
important pollution prevention benefits, in that they recover
solvent for reuse as opposed to thermal or catalytic destruction.
At present, solvent recovery systems work best with HAP solvents,
particularly toluene. Conversion to no HAP or low HAP acetate
based solvent systems would complicate or eliminate the utility
of these systems and increase VOC use. In cases where existing
solvent recovery systems are performing well, they may represent
an overall pollution prevention benefit. One possibility would
be to regulate product and packaging rotogravure facilities with
solvent recovery systems under the same standards which are
applied to publication rotogravure facilities.

3.5.3 Wide-web Flexocrraphic Printing

3-20

-------
Pollution prevention, in terms of HAP elimination has been
achieved by many facilities in the flexographic printing
industry. Inks with zero HAP content are available and in use at
some facilities in all industry segments. In addition, many
facilities use inks which contain only a very low percentage of
HAP. These inks typically contain a small proportion of glycol
ethers which function to reduce surface tension and improve flow
characteristics. The adoption of these inks by additional
existing sources is a likely consequence of increased regulation
of HAP emissions.

Flexographic printing facilities produce a wide variety of
products. Flexible packaging producers, in particular, print on
many different substrates within the same facility. Low HAP inks
may not be available to meet all of the performance requirements
of these facilities. In addition, many facilities use hundreds
of different inks to print various custom colors required by
their packaging customers. Low HAP inks may not be available for
all substrates in all of the colors required by some facilities.
Replacement of existing inks with inks containing less HAP (for
those applications for which satisfactory replacements are
available) is likely to occur.

Two specific examples where pollution prevention strategies
are promising are corrugated box and newspaper production. In
both cases facilities using zero HAP inks can produce nearly
identical products to those using low HAP inks. Increased
awareness of the options available will cause some flexographic
printers to eliminate HAP.

Based on approximately 500 usable responses to the ICR, 125
facilities reported using no HAP whatsoever for flexographic
printing. These facilities included 49 corrugated box
manufacturers, 22 paper product manufacturers, 2 product
manufacturers that made at least some plastic products, one book
manufacturer, and 51 flexible packaging manufacturers. Of the

3-21

-------
flexible packaging manufacturers, 15 printed on paper substrates,
19 printed on foil or film substrates. The remaining 17 flexible
packaging manufacturers either indicated that they printed on
both paper and film or did not provide specific information about
substrate. It should be noted that 9 of these facilities
operated catalytic incinerators for VOC control. Some unknown
fraction of the facilities which reported no HAP use on press may
have been unaware of the HAP content. It is clear, however, that
HAP free formulations are available for printing on both porous
and non-porous substrates. Many other facilities applied
materials on their flexographic presses which contained very low
proportions of HAP on an average annual basis.

The types of control devices used by facilities applying
solvent based materials are not likely to adequately function as
HAP control devices when waterborne inks are used, because the
dryer exhaust streams will contain relatively large amounts of
water and relatively low heat content. In cases where low HAP
(as opposed to no HAP) inks are necessary for particular products
or packaging, the feasibility of conversion to waterborne inks
may be a basis for segmentation of the industry for HAP
regulation. Conversion from solvent based inks to waterborne
inks may in some cases increase the amount of HAP in the dryer
exhaust.

3.6 REFERENCES

1.	Edgerton, Stephen, Joanne Kempen and Thomas W. Lapp. The
Measurement Solution: Using a temporary Total Enclosure
Method for Capture Efficiency Testing. EPA-450/4-91-020.
August 1991. p.39-42.

2.	Reference 1, p. B-l through B-4.

3.	Standards of Performance for Magnetic Tape Coating
Facilities. 40 CFR 60, Subpart SS, July 1990. pp.438-444.

4.	U. S. Environmental Protection Agency. Handbook: Control
Technologies for Hazardous Air Pollutants. Publication No.
EPA/625/6-91/014. Cincinnati, OH. June 1991. 168 pp.

3-22

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5.	U. S. Environmental Protection Agency. Internal Instruction
Manual for ESD Regulation Development: Combustion Controls
for Organic Emissions from Process Vents, Second Printing.
Research Triangle Park, North Carolina. August 31, 1994.

p. 3-39 through 3-43.

6.	Reference 4, p.3-4.

7.	Reference 6, p. 3-16 through 3-21.

8.	Reference 6, p. 3-16.

9.	Handbook: Control Technologies for Hazardous Air Pollutants.
(Ref. 2) p.4-2.

10.	Reference 4, p. 4-10.

11.	Worrall, M. J. VOC Capture for High Speed Publication
Rotogravure Printing. Paper 93-TA-33.02, presented at AWMA
Meeting. June 1993.

12.	Reference 11.

3-23

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4.0 MODEL PLANTS, CONTROL OPTIONS, AND ENHANCED MONITORING

4.1	INTRODUCTION

This chapter describes model plants, control options and
enhanced monitoring options for specific segments of the printing
and publishing industry. Model plants were developed to evaluate
the effects of various control options on the source category.
Control options were selected based on the application of
presently available control devices and varying levels of capture
consistent with different levels of overall control. Enhanced
monitoring options are specified to insure the consistent
performance of control devices.

4.2	MODEL PLANTS

Model plants have been specified for three segments of the
printing industry. Model plants have been selected to represent
the range of capacity and overall control efficiency existing in
these industry segments as determined by responses to the
information collection requests.

4.2.1 Publication Rotogravure Model Plants

Model plants have been selected to represent a total
industry population of 33 separate control systems at 27
publication rotogravure plants. Specifications for these plants
are given in Table 4-1. Information on HAP usage and overall
control efficiencies are available for the entire population.

Four model plants are based on size (based on ink usage) and
control efficiencies reported in voluntary responses to EPA
question lists. The large plants (Model Plants 1 and 2) were
specified based on the 80th percentile of ink usage. The small

4-1

-------
plants (Model Plants 3 and 4) were specified based on the 20th
percentile of ink usage.

4-2

-------
Table 4-1. Publication Rotogravure Model Plants.

Model Plant

1

2

3

4

5

Presses/Stations

8/10

8/10

4/8

4/8

5/8

Pressroom Length (ft)

240

240

120

120

150

Pressroom Width (ft)

150

150

120

120

120

Pressroom Height (ft)

30

30

30

30

30

HAP usage(lb/yr)

22,500,000

22,500,000

6, 400,000

6, 400,000

14,000,000

HAP usage (g/min)

19,435

19,435

5, 528

5, 528

12,093

Capture Efficiency (%)

CO
I—1

90 . 7

CO
I—1

90 . 7

¦xT

O
CO

Control Efficiency (%)

97 . 0

97 . 0

97 . 0

97 . 0

97 . 0

Overall Control (%)

95.2

o

CO
CO

95.2

o

CO
CO

78 . 0

HAP controlled (lb/yr)

21,420,000

19,800,000

6,092,800

5,632,000

10,920,000

HAP emitted (lb/yr)

1,080,000

2,700,000

307,200

768,000

3,080,000

HAP retained (lb/yr)

337,500

337,500

96,000

96,000

210,000

HAP to Pressroom(lb/yr)

90,000

1,755,000

25,600

499,200

2,534,000

Pressroom Volume (CF)

1,080,000

1,080,000

432,000

432,000

540,000



Assumed 1.5% of HAP used is retained in the web, and ultimately emitted outside the pressroom.

-------
Plants with a high level of control (Model Plants 1 and 3)
were selected based on the 80th percentile of overall control
efficiencies. Plants with a low level of control (Model Plants 2
and 4) were specified based on the 20th percentile of overall
control efficiency. One additional model plant (Model Plant 5)
was selected based on the lowest reported monthly overall control
efficiency. The size of this plant was specified based on the
approximate size of the actual plant reporting this efficiency.

Presses under control at each model plant were specified
based on the approximate equipment in use at plants with this
level of ink usage. Pressroom dimensions were assumed based on
equipment size. Actual facilities may have multiple pressrooms
under control by common systems, or more widely spaced presses
separated by other equipment. All plants in this segment of the
industry have similar solvent recovery systems; most of the
difference in overall control is due to variations in capture.
All or nearly all of the HAP in use at the plants is accounted
for by overall liquid-liquid mass balances. Unrecovered HAP may
be due to fugitive emissions, stack emissions or residual solvent
shipped out in the product (this is assumed to be emitted at some
stage in the life cycle of the product).

4.2.2 Product and Packaging Gravure Model Plants

Data provided by packaging and product rotogravure
facilities in response to the ICR were used to subcategorize this
part of the printing industry on the basis of substrate and end
use. The list of facilities for which usable information was
received and the subcategories into which these facilities were
placed is described in Chapter 2.

HAP usage varied widely among the facilities. In addition,
HAP usage as a proportion of total material applied on
rotogravure presses varied widely. At least twelve facilities
reported zero HAP usage, including one facility which applied
over 7 million pounds per year of inks and coatings. The

4-4

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availability of suitable low HAP or no HAP ink may be dependent
upon the substrate and specific end product. In addition,
existing control devices, which in most cases are designed and
operated for VOC control, may not be compatible with low HAP
formulations. Substitution of inks with lower HAP content may be
an important pollution prevention option at some facilities.

Other facilities, which are operating efficient VOC control
systems may have little incentive to reduce the HAP content of
their inks.

Facilities printing on paper and cardboard packaging only,
film and foil packaging only and vinyl products have been listed
in Tables 4-2 through 4-4. Based on data submitted in response
to the ICR, total ink (including coatings, adhesives, varnishes
and primers) use, HAP use associated with this ink use, estimated
overall control and probable major source status have been listed
in these tables. In some cases, data were incomplete or
ambiguous. These tables exclude facilities which print on both
paper or cardboard and foil or film, and other miscellaneous
products. Lists of these facilities are given in Chapter 2.

Model plants were selected from the mid-range of the
identifiable maior sources within each subcategory. It should be
noted that while this is representative of the sources which will
be regulated, it is not necessarily representative of the
subcategory as a whole. Because of the varying approaches to
emissions control used by the major sources in the packaging
subcategories (relatively high HAP use with extensive control
versus relatively low-HAP use with no control), two model plants
have been selected for paper/cardboard and foil/film packaging.

Model plant specifications are given in Table 4-5. Ink, HAP
and VOC use, overall efficiency and numbers of presses and
stations were based on actual responses from representative
facilities in each sub-category.

4.2.3 Wide-web and Sheet Fed Flexocrraphv Model Plants

4-5

-------
Data were provided by approximately 500 flexographic
printing facilities in response to the ICR. The list of
facilities for which usable information was received is included
in Chapter 2. Responses were obtained from printers of flexible

4-6

-------
Table 4-2. HAP Use by Rot

.ogravure Faciliti

es Printing

)n Paper and

Cardboard.



Company Name

Ink Usage

HAP usage

Overall

Maj ora

Emissions



(lb/yr)

(lb/yr)

Control(%)



(lb/yr)













Alford Packaging

1,484,884

78,125

90

NO

7812

Allied Stamp Corporation

699,562

111,908

98

NO

2238

American Greetings

1,650,000

20,040

0

NO

20040

Avery Dennison

879,000

867,000

89

YES

95370

Cleo, Inc.

7,400,000

0

NA

NO

0

Decorative Specialties
International, Inc.

374,000

19,185

0

NO

19185

Dopaco, Inc., Downington

2,288,742

939,235

80 . 6

YES

182211

Dopaco, Inc., Saint Charles

901,135

191

0

NO

191

Dopaco, Inc.

1,146,807

2,423

0

NO

2423

Federal Paper Board Co., Inc.,
Wilmington

4,144,000

440,084

70

YES

132025

Federal Paper Board Co., Inc.,
Durham

1,240,840

1,858

NA

NO

NA

Graphic Packaging Corporation,
Lawrenceburg

8,978,632

796,552

95 . 3

YES

37437

Graphic Packaging Corporation, Paoli

534,468

4,823

71.78

NO

1361

Gravure Carton & Label

71,360

14,190

0

NO

14190

Gravure Packaging, Inc.

1,795,000

205,100

78 . 7

YES

43686

Hallmark Cards, Kansas City

58,000

6, 777

30

NO

4743

Hallmark Cards, Leavenworth

2,629,406

21,880

45

NO

12034

International Label Company

1,089,824

316,891

86.83

YES

41734

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Table 4-2. HAP Use by Rot

.ogravure Faciliti

es Printing

)n Paper and

Cardboard.



Company Name

Ink Usage

HAP usage

Overall

Maj ora

Emissions



(lb/yr)

(lb/yr)

Control(%)



(lb/yr)

International Playing Card & Label
Company

2,856,071

568,680

85

YES

85302

James River Paper Company,
Darlington

1,915,572

575,988

0

YES

575988

James River Paper Company, Fort
Smith

1,233,549

147,951

0

YES

147951

James River Paper Company, Lexington

131,794

0

0

NO

0

James River Paper Corporation,
Kalamazoo

4,343,000

115,372

93

NO

8076

Jefferson Smurfit Corporation,
Chicago

262,923

91,122

80

NO

18224

JSC/CCA, Carol Stream

1,060,412

93,178

75

YES

23294

JSC/CCA, Lockland

1,218,069

66,868

78 . 7

NO

14242

JSC/CCA, North Wales

819,965

307,574

90

YES

30757

JSC/CCA, Santa Clara

1,673,193

25,139

0

NO

25139

JSC/CCA, Stone Mountain

1,219,797

238,190

95 . 5

NO

10718

Lux Packaging Ltd.

845,985

46,442

88 . 9

NO

5155

Mundet-Hermetite Inc.,

1,149,193

101,856

NA

NA

NA

Riverwood International USA, Inc.,
Bakersfield

828,788

1,833

65

NO

641

Riverwood International USA, Inc.,
Cincinnati

789,562

275,294

71

YES

79835

Riverwood International USA, Inc.,
West Monroe

3,832,837

534,045

65

YES

186915

4-8

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Table 4-2. HAP Use by Rotogravure Facilities Printing on Paper and Cardboard.

Company Name

Ink Usage

HAP usage

Overall

Maj ora

Emissions



(lb/yr)

(lb/yr)

Control(%)



(lb/yr)

Roslyn Converters Inc.

3,005,492

2,079

CO

NO

29

Shamrock Corporation

773,564

0

0

NO

0

Somerville Packaging

NA

NA

84 . 7

NA

NA

Stone Container Corporation

648,444

44,564

62 . 4

NO

16756

The C. W. Zumbiel Company(Cleneay)

422,603

0

0

NO

0

The C. W. Zumbiel Company(Harris)

1,078,595

179,970

95

NO

8998

Union Camp Corporation, Englewood

265,650

160,200

84 . 7

YES

24510

Union Camp Corporation, Spartanburg

2,065,555

188,456

76

YES

45229

Waldorf Corporation, Chicago

600,551

378,408

79

YES

79465

Waldorf Corporation, Saint Paul

964,900

839,594

NA

YES

NA

NA=Not available, a=based on estimated emissions.

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Table 4-3. HAP Use by Rotogravure Facilities Printing Exclusively on Foil and Film.

Company Name

Ink used

HAP used

Overall

Maj ora

Emissions



(lb/yr)

(lb/yr)

Control(%)



(lb/yr)













Alcan Foil Products

NA

NA

95

YES

NA

American Fuji Seal, Inc., Anaheim

104,700

3, 152

95

NO

157

American Fuji Seal, Inc., Fairfield

384,706

77,845

89

NO

8562

Decorating Resources

81,473

65,212

97

NO

1956

Paramount Packaging Corporation, Chalfont

296,351

2, 692

74 . 4

NO

689

Paramount Packaging Corporation, Longview

847,883

109,400

95

NO

5470

Screen Art

87,980

0

92

NO

0

Fres-Co System USA, Inc.

1,665,400

1,077,618

90

YES

107761

Paramount Packaging Corporation,
Murfreesboro

289,395

67,083

0

YES

67083

Quick Roll Leaf Manufacturing Company

3,500,000

840,000

93

YES

58800

Reynolds Metals Company

5,315,422

992,744

65

YES

347460

NA=Not available, a=based on estimated emissions.

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Table 4-4. HAP Use by Rotogravure Facilities Printing Vinyl Products.

Company Name

Ink

HAP usage

Efficiency

Maj ora

Emissions



lbs/yr

lbs/yr

O.
o





Avery Dennison

2,037,375

885,684

93

Yes

61,998

Butler Printing & Laminating

915,500

803,400

85

YES

120,510

Columbus Coated Fabrics

2,355,116

1,346,742

NA

NA

NA

Congoleum Corporation, Marcus Hook

1,830,000

0

0

NO

0

Congoleum Corporation, Mercerville

210,000

173,000

93

NO

12,110

Constant Services, Inc.

222,622

206,898

87

NA

26,897

Decor Gravure Corporation

400,000

400,000

97 . 7

NO

9,200

Decorative Specialties Int'l

101,100

156,644

97

NO

4, 699

GenCorp Inc., Salem

1,500

5,228

0

NO

5,228

GenCorp Polymer Products, Columbus

3,938,395

3,200,000

80

YES

640,000

GenCorp, Inc., Jeanette

182,000

166,000

NA

NA

NA

Mannington Mills, Inc.

1,242,127

190,674

91. 7

NO

15,826

Newco Inc.

290,874

270,014

NA

NA

NA

Vernon Plastics Company

NA

549,455

NA

NA

NA



NA=Not available. a=based on estimated emissions.

-------
Table 4-5. Model Plant Specifications for Product/Packaging Rotogravure.

Model
Plant



1

2

3

4

5



Substrate

Vinyl Products

Paper/Cardboard Packaging

Foil/Film Packaging

Ink Use, lb/year

1,000,000

1,800,000

2,000,000

3,000,000

300,000

VOC Use, lb/year

900,000

1,000,000

800,000

2,500,000

150,000

HAP Use, lb/year

900,000

200,000

600,000

1,000,000

65,000

Capture Efficiency, %

89

81

N/A

95

N/A

Control Device
Efficiency, %

95

97

0

95

0

Overall Efficiency, %

85

79

0

90

0

Presses/Stations

8/4

4/8

1/6

2/8

4/6

Pressroom Dimensions,
ft x ft x ft

240 x 100 x30

150 x 120 x 30

100 x 30 x30

60 x 150 x 30

120 xl20 x30

-------
packaging, products, corrugated cartons and newspapers. Flexible
packaging and products involved both porous and non-porous
substrates.

HAP usage varied widely among the facilities. In addition,
HAP usage as a proportion of total material applied on
flexographic presses varied widely. Over 100 facilities reported
zero HAP usage; many more reported HAP usage well below one
percent of the total material applied. The availability of
suitable low HAP or no HAP ink is dependent upon the substrate
and specific end product. In addition, existing control devices,
which in most cases are designed and operated for VOC control,
may not be compatible with low HAP formulations. Substitution of
inks with lower HAP content may be an important pollution
prevention option at some facilities. Other facilities, which
are operating efficient VOC control systems may have little
incentive to reduce the HAP content of their inks.

A list of facilities for which usable data are available is
given in Table 4-6. Based on data submitted in response to the
ICR, total ink (including coatings, adhesives, varnishes and
primers) use, HAP use associated with this ink use, estimated
emissions and type of substrate have been listed in this table.
In some cases, data were incomplete or ambiguous.

Model plants have been selected to represent those sources
which are likely to be regulated under the standard. It should
be noted that while this is representative of the sources which
will be regulated, it is not necessarily representative of the
sub-category as a whole. Three model plants are specified in
Table 4-7. Plants 1 and 2 and based on actual responses from
uncontrolled major sources due to flexographic printing. Model
plant 1 is a large plant using waterborne inks with a low HAP
concentration and no control device. Model plant 2 is a medium
sized plant using solvent based inks containing a significant
amount of HAP and no control device.

4-13

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A number of facilities operate flexographic printing
operations as well as other more HAP intensive operations such as

4-14

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

Abbott Box Co. Inc.

15,000

10

10

b

Acorn Corrugated Box Co.

161,000

0

0

b

Advance Packaging Corporation

122,100

1,591

1,591

b

Advance Packaging-Jackson

13,400

745

745

b

Tennessee Packaging

19,454

72

72

b

Koch Container

2,154

0

0

b

All-Size Corrugated Prods.

11,178

0

0

b

Compak, Inc.

10,295

193

193

b

Webcor Packaging Corp.

122,060

2, 512

2, 512

b

Castle Rock Container Company

231,768

10

10

b

Fleetwood Container & Display

78,660

Not major



b

Focus Packaging, Inc.

36,000

0

0

b

Frank C. Meyer Company, Inc.

333,045

0

0

b

GP-Albany Plant

361,893

3, 619

3, 619

b

GP-Asheboro Plant

165,206

1, 652

1, 652

b

GP-Augusta Plant

225,000

4,500

4,500

b

GP-Bradford Plant

212,664

2, 127

2, 127

b

GP-Buena Park Plant

1,235,300

12,353

12,353

b

GP-Canton Plant

70,627

706

706

b

GP-Chicago Plant

135,335

2,707

2,707

b

GP-Cincinnati

114,342

1,143

1,143

b

GP-Circleville Plant

224,653

2,247

2,247

b

GP-Cleveland Plant

134,926

1,349

1,349

b

GP-Cleveland Plant

131,708

13,171

13,171

b

GP-Doraville Plant

114,791

1,148

1,148

b

GP-Dubuque Plant

216,303

649

649

b

GP-Franklin Plant

180,000

12,600

12,600

b

GP-Huntsville Plant

187,152

0

0

b

GP-Kansas City Plant

219,516

0

0

b

GP-Lake Placid Plant

721,374

0

0

b

4-15

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

GP-Madera Container Plant

213,754

641

641

b

GP-'Martinsville Plant

250,000

0

0

b

GP-Memphis Plant

69,786

209

209

b

GP-Milan Plant

190,693

572

572

b

Modesto Plant

175,052

525

525

b

GP-Monticello Plant

26,779

7,498

7,498

b

GP-Mt. Olive Plant

212,188

664

664

b

GP-Mt. Wolf Plant

70,586

212

212

b

GP-Olympia Plant

133,080

1,198

1,198

b

GP-Ooltewah Plant

1,000

40

40

b

GP-Oshkosh Plant

27,077

542

542

b

GP-Owosso Plant

94,057

1,882

1,882

b

GP-Schenectady Plant

57,763

1, 329

1, 329

b

GP-Sheboygan Plant

122,629

2,453

2,453

b

GP-So. San Francisco Plant

932,691

2,798

2,798

b

GP-Spartanburg Plant

141,211

0

0

b

GP-Valdosta Plant

540,000

0

0

b

GP-Warren County Plant

120,173

361

361

b

GP-West Monroe Plant

140,969

5, 639

5, 639

b

GP-Waxahachie Plant

228,934

9,157

9,157

b

GP-Gulf States Paper Corp.

424,405

0

0

b

International Paper-Presque
Isle

101,725

844

844

b

International Paper-Auburndale

223,525

1,182

1,182

b

International Paper-Carson

375,752

822

822

b

International Paper-Chicago

226,287

770

770

b

International Paper-Cincinnati

129,055

523

523

b

International Paper-Dallas

166,287

390

390

b

International Paper-Detroit

146,360

1, 020

1, 020

b

International PaperEdinburg

240,391

856

856

b

International Paper-El Paso

197,102

1, 900

1, 900

b

4-16

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

International Paper-Fond du Lac

230,990

683

683

b

International Paper-Geneva

98,250

136

136

b

International Paper-Georgetown

59,711

2,846

2,846

b

International Paper-Minneapolis

95,542

720

720

b

International Paper-Mobile

230,224

3,039

3,039

b

International Paper-Modesto

347,046

1,341

1,341

b

International Paper-Mt. Carmel

337,500

4, 940

4, 940

b

International Paper-Nashville

245,662

8, 685

8, 685

b

International Paper-Putnam

228,407

890

890

b

International
Paper-Russellville

247,201

1,198

1,198

b

International Paper-San Jose

328,783

775

775

b

International Paper-Shreveport

417,513

0

0

b

International Paper-Spring Hill

254,985

3, 957

3, 957

b

International Paper-Statesville

158,250

5,315

5,315

b

International PaperStockton

2, 626

36

36

b

International Paper-Tallman

447,392

2,139

2,139

b

International Paper-Wooster

200,425

859

859

b

International
Paper-Hopkinsville

308,312

2, 312

2, 312

b

James River-Portland

124,655

0

0

b

Jefferson Smurfit
Corp-Lexington

6, 000

113

113

b

Jefferson Smurfit-Renton

103,004

483

483

b

Jefferson Smurfit Corp-Muncie

13,100

0

0

b

Jefferson Smurfit Corp-Portland

111,952

0

0

b

JSC/CCA-Fulton

42,672

0

0

b

JSC/CCA-Houston

150,200

2,148

2,148

b

Jefferson Smurfit
Corp.-Muskogee

94,733

344

344

b

Jefferson Smurfit Corp-Highland

101,000

0

0

b

4-17

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

Jefferson Smurfit Corp-New
Brunswick

156,597

815

815

b

Jefferson Smurfit
Corp-Chesterfield

68,000

0

0

b

Jefferson Smurfit-Memphis

193,043

3,455

3,455

b

Jefferson Smurfit -St.Louis

39,000

0

0

b

Jefferson Smurfit Milpitas

210,000

0

0

b

Jefferson Smurfit-Ft. Smith

6, 500

49

49

b

Jefferson Smurfit-Ft. Worth

186,000

0

0

b

Jefferson Smurfit -Anderson

102,625

1,840

1,840

b

Jefferson Smurfit-Montgomery

252,000

0

0

b

Jefferson Smurfit -Milford

63,990

422

422

b

JSC/CCA-Aston

312,136

1,853

1,853

b

Jefferson Smurfit-New hartford

121,488

728

728

b

Jefferson Smurfit-Louisville

98,300

1, 760

1, 760

b

Jefferson Smurfit-Wildwood

183,798

1, 060

1, 060

b

Jefferson Smurfit -Wakefield

100,300

496

496

b

Jefferson Smurfit-Knoxville

na

1, 320

1, 320

b

Jefferson Smurfit-Jonesboro

na

14

14

b

Jefferson Smurfit-Los Angeles

179,367

0

0

b

JSC/CCA-Baltimore

140,170

894

894

b

Jefferson Smurfit-Corona

129,419

0

0

b

Jefferson Smurfit-Dolton

151,682

550

550

b

Jefferson Smurfit-Dallas

40,300

22

22

b

JSC/CCA-Fresno

135,093

0

0

b

JSC/CCA-Cincinnati

178,484

3,195

3,195

b

JSC/CCA-Ravenna

75,753

1,356

1,356

b

Jefferson Smurfit -LaPorte

174,297

316

316

b

Jefferson Smurfit-Winston-Salem

240,000

0

0

b

Jefferson Smurfit -Humboldt

11,887

270

270

b

Jefferson Smurfit-Sioux City

160,536

92

92

b

4-18

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

Jefferson Smurfit -Lancaster

79,000

620

620

b

Jefferson Smurfit-Galesburg

46,149

0

0

b

JSC Preprint-Cincinnati

251,500

0

0

b

Jefferson Smurfit
-Murfreeesboro

115,466

0

0

b

Jefferson Smurfit-Springfield

15,589

0

0

b

Jefferson Smurfit -Shelby

83,773

586

586

b

Packaging Unlimited, Inc.

121,382

6, 386

6, 386

b

Jefferson Smurfit -Chattanooga

120,000

0

0

b

Lin Pac, Inc.

52,289

3

3

b

Mafcote Industries

138,189

9,130

9,130

b

Mafcote/SWACO

96,674

0

0

b

Malnove, Inc.

27,606

0

0

b

Massillon Container

13,000

0

0

b

Menasha Corporation

197,095

282

282

b

Milwaukee Container

139,571

2,791

2,791

b

PCA/Akron

21,860

219

219

b

PCA/Arlington

198,800

1, 998

1, 998

b

PCA/Ashland

234,000

2,340

2,340

b

PCA/Atlanta

120,000

1,200

1,200

b

PCA/Buffalo

62,300

623

623

b

PCA/Burlington

305,000

3,050

3,050

b

PCA/Colby

116,000

1, 160

1, 160

b

PCA/Denver

119,900

1,199

1,199

b

PCA/Garland

145,800

1,458

1,458

b

PCA/Gas City

97,300

973

973

b

PCA/Goldsboro

11,400

114

114

b

PCA/Grafton

43,000

430

430

b

PCA/Grandville

110,600

1,106

1,106

b

PCA/Hanover

28,000

280

280

b

PCA/Harrisonburg

160,000

1,200

1,200

b

4-19

-------
Table 4-6. HAP Use on Flexoc

graphic Presses (See Notes Following Table).

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

PCA/High Point

19,100

191

191

b

PCA/Honea Path

45,950

460

460

b

PCA/Jackson

137,000

1,370

1,370

b

PCA/Jacksonville

126,700

1, 267

1, 267

b

PCA/Knoxville

3, 520

35

35

b

PCA/Lancaster

187,800

1,878

1,878

b

PCA/Los Angeles

294,000

1,470

1,470

b

PCA/Marshalltown

129,800

1,298

1,298

b

PCA/Miami

64,300

643

643

b

PCA/Middletown

75,022

750

750

b

PCA/Milwaukee

38,300

383

383

b

PCA/Minneapoolis

78,000

780

780

b

PCA/Morganton

60,800

1,250

1,250

b

PCA/Newark

76,300

763

763

b

PCA/Newberry

109,500

1,095

1,095

b

PCA/Northhampton

133,900

1,339

1,339

b

PCA/Omaha

90,000

900

900

b

PCA/Opelika

10,600

106

106

b

PCA/Phoenix

98,800

CO
CO

CO
CO

b

PCA/Pittsburgh

193,800

1, 938

1, 938

b

PCA/Plano

140,600

1,406

1,406

b

PCA/Plymouth

60,500

605

605

b

PCA/Richmond

49,400

494

494

b

PCA/Salisbury

97,000

970

970

b

PCA/Syracuse

141,800

1,418

1,418

b

PCA/Trexlertown

158,332

1,583

1,583

b

PCA/Vincennes

65,500

655

655

b

PCA/Winter Haven

238,800

2,388

2,388

b

Rand -Whitney/Northeast
Container

18,087

158

158

b

4-20

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

Rand -Whitney/Southeast
Container Corp.

17,426

5

5

b

Rand -Whitney Container Corp.

91,727

0

0

b

Rock-Tenn-Harrison

25,000

0

0

b

Rock-Tenn -Chattanooga

30,000

300

300

b

Rock-Tenn-Stone Mountain

117,624

1,340

1,340

b

Rock-Tenn-Lebanon

104,400

0

0

b

Rock-Tenn-Marshville

15,000

0

0

b

Rock-Tenn-Eutaw

200,000

500

500

b

Rock-Tenn-Conway

28,719

4

4

b

Rock-Tenn Greenville

125,000

0

0

b

Sealright Packaging Co.

326,000

0

0

b

Union Camp Corp. -Tucker

126,000

2,720

2,720

b

Wabash Pioneer Container Corp.

498,303

2,145

2,145

b

Westvaco-Baltimore

305,000

15,410

15,410

b

Westvaco-Buffalo

219,000

1,590

1,590

b

Westvaco Chicago

423,000

290

290

b

Westvaco-Cleveland OH

205,000

870

870

b

Westvaco-Cleveland TN

290,000

5,300

5,300

b

Westvaco-Columbus

249,000

1, 900

1, 900

b

Westvaco-Eaton

292,000

4,740

4,740

b

Westvaco-Gastonia

125,000

2, 630

2, 630

b

Westvaco-Meridian

214,400

1,400

1,400

b

Westvaco-Richmond

128,000

560

560

b

Westvaco-Flexpak-Richmond

482,000

0

0

b

Weyerhaeuser -Westbrook

145,609

790

790

b

Weyerhaeuser-Cedar Rapids

151,270

1, 971

1, 971

b

Weyerhaeuser-Tampa

464,367

421

421

b

Weyerhaeuser -Franklin

540,817

3,366

3,366

b

Weyerhaeuser-Tucker

1,674,177

151

151

b

Willamette -Beaverton

435,581

0

0

b

4-21

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

Willamette -Buena Park

394,942

0

0

b

Willamette -Dallas

383,384

0

0

b

Willamette -Kansas City

140,814

0

0

b

Willamette -Tacoma

130,604

0

0

b

Willamette -Aurora

435,235

962

962

b

Willamette -Beaverton 2

237,772

311

311

b

Willamette -Ellvue

460,521

1,895

1,895

b

Willamette -Bellmawr

265,373

355

355

b

Willamette -Bowling Green

226,528

516

516

b

Willamette -Cerritos

268,859

515

515

b

Willamette -Compton

403,363

685

685

b

Willamette -Dallas 2

299,787

684

684

b

Willamette -Delaware

679,079

3,334

3,334

b

Willamette -Elk Grove

223,379

447

447

b

Willamette -Ft. Smith

231,814

440

440

b

Willamette -Golden

58,801

90

90

b

Willamette -Griffen

380,183

1,784

1,784

b

Willamette -Indianapolis

63,083

159

159

b

Willamette -Kansas City

168,945

338

338

b

Willamette
-Lincoln

41,256

80

80

b

Willamette -Louisville

11,924

16

16

b

Willamette -Lumberton

41,488

191

191

b

Willamette -Matthews

90,770

203

203

b

Willamette -Memphis

40,958

214

214

b

Willamette -Moses Lake

302,716

549

549

b

Willamette -Newton

65,621

475

475

b

Willamette -Sacramento

297,249

537

537

b

Willamette -San Leandro

423,133

590

590

b

Willamette -Sanger

227,039

496

496

b

Willamette -Sealy

133,688

289

289

b

4-22

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

Willamette -St. Paul

81,811

118

118

b

Willamette -West Memphis

157,355

177

177

b

American Greetings Corp

230,000

7,400

7,400

d

Avery-Dennison

15,954

0

0

d

Cadillac Products, Inc.Paris

250,633

27,334

27,334

d

Cadillac Products, Inc.

25,516

3,039

3,039

d

Cleo, Inc.

20,000

400

400

d

Crystal Tissue

125,333

170

170

d

Eisenhart Wallcoverings Co.

63,076

321

321

d

Pioneer Balloon Company

113,820

1,484

1,484

d

Waldan Paper Services, Inc.

550,000

0

0

d

American Greetings Corp.Aftan

4,187,556

0

0

e

Deco Paper Products, Inc.

571,308

4,055

4,055

e

Design Containers, Inc.

11,201

21

21

e

GP-LaGrange

36,941

843

843

e

GP-Piattsburgh

1,757,500

0

0

e

GP-Crosett

652,182

8,424

8,424

e

GP-Palatka

329,000

0

0

e

GP-Brattleboro

134,810

125

125

e

GP-Bellingham

76,650

0

0

e

Gilman Converted Products

913,367

5, 460

5, 460

e

Hallmark Cards

69,900

14

14

e

James River Darlington

234,017

5,277

5,277

e

James River-Easton

93,644

0

0

e

James River-Lexington

88,592

0

0

e

James River-Indianapolis

281,088

0

0

e

John H. Harland Company

121,650

0

0

e

Kookaburra USA LTD

55,329

0

0

e

Mail-Well Envelope

103,150

426

426

e

Moore, Business Forms and
Systems

124

1,101

1,101

e

4-23

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

NCR Corp.

117,290

0

0

e

Procter and Gamble-Albany

636,886

0

0

e

Procter/Gamble-Mehoopany

949,300

0

0

e

Procter/Gamble-Green Bay

423,400

0

0

e

Procter/Gamble-Oxnard

113,450

0

0

e

Solo Cup Company-Belan

38,680

0

0

e

Solo Cup Company-Chicago

18,870

0

0

e

The Standard Register Company

209,305

1

1

e

Susan Crane, Inc.

136,840

0

0

e

Toph-Osage

60,000

0

0

e

Toph-Covington

203,963

0

0

e

Ward/Kraft, Inc.

37,783

5

5

e

Beach Products

260,000

1, 660

1, 660

e

Westvaco-Springfield

855,473

0

0

e

Westvaco-Williamsburg

929,945

7,284

7,284

e

Westvaco-Atlanta

840,289

0

0

e

Westvaco-North Chicago

546,821

7,277

7,277

e

Westvaco-Indianapolis

890,044

4, 608

4, 608

e

Westvaco-Dallas

721,007

5, 662

5, 662

e

Westvaco-Los Angeles

831,225

2, 656

2, 656

e

Westvaco-San Francisco

460,905

0

0

e

Areata Graphics\Kingsport

57,117

0

0

g

R. R. Donnelley & Sons Company

367,200

100

100

g

Western Publishing Co., Inc.

57,200

5,475

5,475

g

Interstate Packaging Corp.

217,277

8, 361

2,341

h

American Packaging-Storry City

892,160

7, 660

7, 660

h

American Packaging-Columbus

1,869,137

3,293

3,293

h

Avery-Dennison, K & M Division

28,500

19,950

19,950

h

Bagcraft Corporation of America

650,000

15,000

15,000

h

Bancroft Bag, Inc

1,522,877

350,870

350,870

h

4-24

-------
Table 4-6. HAP Use on Flexoc

graphic Presses (See Notes Following Table).

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

Bingo Paper Inc.

38,701

0

0

h

Champion-Morristown

294,738

23,832

23,832

h

Champion-Clinton

167,415

18,728

18,728

h

Champion-Olmstead Falls

304,197

19,028

19,028

h

Chamption-Ft. Worth

192,319

14,790

14,790

h

Champion-Athens

285,554

22,213

22,213

h

Bemis Company-Crosett

530,107

0

0

h

Bemis Company-Memphis

323,542

2,070

2,070

h

Bemis Company-Minneapolis

16,000

0

0

h

Bemis Company-Omaha

665,336

1,728

1,728

h

Bemis Company-Peoria

318,364

3, 021

3, 021

h

Bemis Company-Pepperell

182,063

0

0

h

Bemis Company-Seattle

105,275

2,377

2,377

h

Bemis Company-Vancouver

437,010

0

0

h

Bemis Company-Wichita

7,138

0

0

h

Graphic Packaging Corp.

195,031

0

0

h

Hallmark Cards

72,286

846

846

h

International Paper-Camden

663,359

0

0

h

International Paper-Mobile

650,000

355

355

h

International Paper-Pittsburg

195,000

0

0

h

International Paper-Wilmington

396,000

57

57

h

James River -Ft. Smith

41,959

2, 937

2, 937

h

James River - Specialty
Tabletop

12,500

0

0

h

James River Corp - Wausau Plant

425,873

291

291

h

Mead Packaging

2,267,734

564

564

h

Percy Kent Bag Co., Inc.

665,500

0

0

h

The Robinette Company

633,000

0

0

h

Sealright Packaging Co.

82,491

0

0

h

Union Camp-Savannah

320,362

4,416

4,416

h

Union Camp-Spartenburg

1,476,648

21,420

21,420

h

4-25

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

Union Camp-Hazleton

206,000

0

0

h

Union Camp-Hanford

155,864

1,045

1,045

h

Union Camp-Sibley

435,923

13,500

13,500

h

Westvaco, Liquid Packaging

135,900

8, 524

8, 524

h

Willamette Industries, Inc.

1,070,078

0

0

h

Alusuisse-Shelbyville

206,000

1,000

282

m

Equitable Bag Co., Inc

1,805,400

46,152

13,107

m

Alusuisse-New Hyde Park

2,030,000

76,000

15,124

m

Bryce Corporation

2,045,155

0

0

m

BRC, A Division of Bryce
Corporation

294,587

34

14

m

Bemis -Terre Haute

5,114,960

27,267

7,089

m

Bemis -Oshkosh

2,619,780

108,864

14,261

m

Bemis Milprint Denmark

1,268,300

2,118

593

m

Bemis Milprint Lancaster

3,644,494

1, 628

133

m

Spec-Fab

34,088

681

102

m

Spiralkote, Inc.

844,943

19,360

6, 970

m

Glenroy, Inc.

124,809

0

0

m

Smurfit Flexible Packaging

90,167

7,731

951

m

Kleartone, Inc.

118,953

2,271

227

m

Packaging Products Corp., Rome,
GA Division

338,780

12,792

1,254

m

Pacquet Oneida, Inc.

712,400

1,735

226

m

Westvaco Envelope Springfield

453,238

36,470

6, 565

m

Fabricon Products

287,616

4,172

1, 168

m

Alusuisse-Bellwood

1,540,000

8,000

2, 160

m

Union Camp-Asheville

224,842

5,193

2,700

m

Graphic Packaging Corporation

120,000

100,000

9,100

m

American Packaging Philadelphia

89,756

243

243

m

American Packaging Rochester

49,557

250

250

m

Bell Packaging Corp

27,832

453

453

m

4-26

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

Bomarko, Inc

499,260

0

0

m

Bryce Corporation

3,060,900

0

0

m

Burrows Paper Corporation - Ft.
Madison Facility

344,426

6, 180

6, 180

m

Cello-Wrap Printing Company,
Inc.

170,120

2,453

2,453

m

Charleston Packaging Company,
Inc.

415,057

350

350

m

Bemis Curwood-Murphysboro

330,112

12,329

12,329

m

Bemis Curwood-New London

2,919,293

38,367

38,367

m

Dixico, Inc.

734,273

0

0

m

Fabricon Products

104,364

1,158

1,158

m

fp Webkote, Inc.

111,606

19,800

19,800

m

Gateway Packaging

10,000

200

200

m

Greif Bros. Corp

279,494

0

0

m

H. S. Crocker Co., Inc.

91,823

0

0

m

Hargo-Harrisburg

349,576

0

0

m

Hargro-Edinburgh

200,942

7702

7, 702

m

IP-Jackson

591,966

942

942

m

IP-Peoria

325,387

33,827

33,827

m

IP-Menasha

100,254

6,490

6,490

m

IP-Lancaster

24,124

1,477

1,477

m

IP-Kaukauna

525,606

3,189

3,189

m

IP-Knoxville

127,235

55

55

m

James River -Camas

68,000

0

0

m

James River-Hazelwood

991,726

923

923

m

James River-Menasha

64,025

28

28

m

James River-San Leandro

866,000

0

0

m

Longhorn Packaging, Inc.

29,894

9



m

Neenah Printing - Wide Web
Flexo Plant

364,376

1, 924

1, 924

m

Midwest Film Corp

276,679

20

20

m

4-27

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

NCR - B.F.D.

33,342

0

0

m

Nichols Paper Products Co.,
Inc.

86,289

418

418

m

Phoenix Products Co., Inc.

61,040

16,656

16,656

m

Solar Press

131,324

0

0

m

Standard Packaging & Printing
Corp.

305,000

0

0

m

Sunrise Packaging, Inc.

632,789

4,579

4,579

m

Superpac, Inc.

560,300

7,039

7,039

m

Teepak, Inc.

816,691

0

0

m

Union Camp-Monticello

368,000

12,232

12,232

m

Union Camp-Tifton

469,967

0

0

m

Vitex Packaging, Inc.

502,402

5,819

5,819

m

Akron Beacon Journal

308,031

3,018

3,018

n

Fort Wayne Newspapers

381,022

0

0

n

Macon Telegraph

195,000

1,053

1,053

n

Modesto Bee

394,237

0

0

n

The Fresno Bee

699,367

0

0

n

Miami Herald Publishing Co.

981,662

22,743

22,743

n

Press Telegram

236,000

82

82

n

Providence Journal Company

930,300

2, 902

2, 902

n

Bonar Packaging, Inc.

334,260

13,401

3,886

P

Georgia-Pacific-Warwick

721,500

210

84

P

Paramount Packaging-Longview

169,577

109,200

5, 460

P

Paramount Packaging-Chalfont

440,317

1,154

196

P

Action Packaging

120,370

602

138

P

All-Pak, Inc.

254,199

748

187

P

Atlanta Film Converting Co,
Inc.

398,621

0

0

P

Automated Packaging Systems,
Inc.

344,101

2, 329

326

P

Automated Label Systems Co.

346,955

1, 461

136

P

4-28

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

Banner Packaging, Inc.

1,718,688

46,311

12,967

P

Cryovac-Iowa Park

70,786

350

182

P

Cryovac-Cedar Rapids

248,500

8,100

1, 944

P

Cryovac-Simpsonville

1,060,000

1,515

348

P

Bemis Company-Hazelton

7,622,511

59,472

13,381

P

Cello-Foil Products, Inc.

551,055

0

0

P

Excelsior Transparent Bag MFG
Corp.

1,358,606

5,300

1,007

P

Flex-Pak, Inc.

400,694

0

0

P

Hargo-Boyerstown

605,047

1,876

413

P

Huntsman Packaging Products,
Corp

409,000

10,205

1, 765

P

Smurfit Flexible Packaging

392,612

9 9?



P

Marglo Packaging Corp.

13,506

333

130

P

Package Printing Co., Inc.

108,896

0



P

Package Products Flexible
Corporation

2,360,000

0

0

P

Packaging Materials
Incorporated

7686

0

0

P

Packaging Products Corp.

397,000

5, 904

1,830

P

Plastic Packaging, Inc.

1,002,196

126

41

P

Plicon Corp.

216,717

11,740

3, 992

P

Poly Plastic Packaging, Inc.

55,229

506

104

P

Union Camp-Tomah

305,483

117,815

16,494

P

Union Camp -Griffen

383,193

2,180

109

P

Central States Diversified,
Inc.

200,288

1, 973

322

P

Mohawk Northern Plastics, Inc.

101,214

3, 684

280

P

Maine Poly, Inc.

312,000

4, 996

999

P

Amko Plastics, Inc.

370,630

21,354

21,354

P

Anagram International, Inc.

254,542

3,436

3,436

P

Arcon Coating Mills, Inc.

261,812

787

787

P

Arkansas Poly, Inc.

145,796

2, 134

2, 134

P

4-29

-------
Table 4-6. HAP Use on Flexoc

graphic Press

es (See Notes

Following Tab

le) .

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

Johnson Bryce Corp.

230,390

0

0

P

Bryce Dixico

505,943

52

52

P

Buckeye Container

37,775

0

0

P

Buckeye Packaging

115,737

0

0

P

Cadillac Products, Inc.

158,021

0

0

P

Clark Container, Inc.

81,660

5,216

5,216

P

C. P. C. Packaging, Inc.

9,725

1, 945

1, 945

P

Bemis -Flemington

53,139

56

56

P

Custom Poly Bag, Inc.

71,417

0

0

P

Dart Container Corporation

26,149

0

0

P

Dynamic Packaging, Inc.

189,489

1,591

1,591

P

Eskimo Pie Corporation

41,767

0

0

P

Flexo Transparent, Inc.

107,033

11,094

11,094

P

Gentry Poly Specialties, Inc.

38,192

0

0

P

Gulf Coast Plastics Div.
Dairy-Mix, Inc.

9, 702

0

0

P

Hargro Health Care Packaging

24,335

0

0

P

Home Plastics, Inc.

35,000

700

700

P

Carolina Printing & Converting
A Division of Interflex

162,739

10,694

10,694

P

James River-Greensburg

4,756,127

0

0

P

James River-New Castle

874,312

31

31

P

James River-Parchment

150,000

0

0

P

James River-Portland

407,858

292

292

P

James River-Shreveport

2,088,304

0

0

P

Lin Pac

317,468

298

298

P

Mid-West Poly Pak, Inc.

25,015

112

112

P

M.T.P. Industries, Inc. (Mason
Transparent Pkg)

125855

0

0

P

Owens-Illinois, Inc.

1,438,000

42,086

42,086

P

Packaging Industries, Inc.

836,972

12,117

12,117

P

Packaging Products Corporation

188,780

7, 693

7, 693

P

4-30

-------
Table 4-6. HAP Use on Flexoc

graphic Presses (See Notes Following Table).

Name

INK ETC.
APPLIED
(lb/yr)

HAP USED
ON PRESS
(lb/yr)

HAP
Emissions
(lb/yr)

PROD.

Packaging Specialties, Inc.

598,431

14,425

14,425

P

Paramount Packaging-Shelbyville

320,770

1,169

1,169

P

Paramount Packaging
-Murfreesboro

566,370

96,821

96,821

P

Phoenix Packaging

8,170,551

19,784

19,784

P

Viskase Corp.

103,718

5, 924

5, 924

P

Plastic Packaging Corp

65,560

0

0

P

Poly Plastic Packaging, Inc.

26,800

226

226

P

Polyflex Film & Converting,
Inc.

566,106

0

0

P

Rex-Rosenlew International,
Inc.

494,445

1

1

P

Sealright Packaging Company

429,758

12,729

12,729

P

Packaging Industries, Inc.

836,972

12,117

12,117

P

Selig Sealing Products, Inc.

16,950

26

26

P

Southern Colortype Co., Inc.

65,176

332

332

P

Specialty Container Corporation

60,819

45,790

45,790

P

Tennessee Press, Inc.

1,546,762

0

0

P

Uniflex, Inc.

208617

208,617

50,068

P

Union Camp-Shelbyville

256,216

0

0

P

Union Camp-Denton

269,994

13,499

13,499

P

Union Camp-Freeman Field

332,087

558

558

P

Union Camp Corp., Richmond

217,253

0

0

P

Viskase Corp.

103,718

5, 924

5, 924

P

Zim's Bagging Co., Inc.

1,400

25

25

P

Notes: b=corrugated box, d=paper/plastic products, e=paper products, g=books,
h=paper packaging, m=mixed packaging, n=newspapers, p=plastic packaging

4-31

-------
Table 4-7. Model Plant Specifications for Flexography.

Model Plant



1

2

3

Substrate



Multi-wall bags

Film Packaging

Paper/Film Pkg

Ink Use

lb/year

1,500,000

800,000

1,500,000

VOC Use

lb/year

25,000

550,000

1,100,000

HAP Use

lb/year

21,000

100,000

8, 000

Capture Efficiency

a
o

0

0

78

Control Device
Efficiency

a
o

0

0

94

Overall Efficiency

a
o

0

0

73

Presses/Stations



12/4

6/6

6/6

Pressroom Dimensions

ft x ft x ft

150 x 90 x 30

150 x 90 x 30

150 x 90 x 30

-------
rotogravure. Model plant 3 represents a flexographic printing
operation which is not a major source when considered alone.

Some flexographic operations of this nature will come under the
NESHAP regulations because of other HAP emitting operations at
the facility. It is possible that more flexographic facilities
will be regulated because of non-flexographic printing emissions
than because of the HAP which results from flexographic
operations by themselves.

4.3 CONTROL OPTIONS

4.3.1 Control Options for Publication Rotogravure

All publication rotogravure plants in the United States
presently use solvent recovery systems incorporating activated
carbon adsorption and steam regeneration. Control device
efficiencies of 95 percent to greater than 99 percent were
reported. The recovered solvent is blended with purchased ink to
maintain the proper viscosity for printing. Excess solvent is
resold to the ink manufacturers.

Most of the variation in overall efficiencies reported by
publication gravure facilities is due to variations in capture
systems. In all cases, dryer exhausts, containing relatively
concentrated solvent laden air, are ducted to the solvent
recovery system. Additional solvent losses during the printing
process result from evaporation from ink fountains, escape of
solvent laden air from driers (e. g. carried out with web between
stages) and residual solvent left in substrate after the final
press station. Non-production solvent losses occur from
uncontrolled proof presses, off-press cylinder cleaning, and the
storage, mixing, shipping and receiving of ink and solvent.

Control options include varying degrees of improvement in
capture and reduction in HAP content of ink. Improved capture
involves containment of additional solvent laden air. Capture
technologies, beyond collection and ducting of dryer exhausts,
presently in use include floor sweeps, partial and full upper

4-33

-------
deck hooding of the presses, and total enclosures. Total
enclosures are used in conjunction with collection and treatment
of all pressroom ventilation air. Control options involving air
handling can be specified in terms of varying degrees of air
collection, up to and including construction of (or conversion of
existing pressrooms to) permanent total enclosures. Improvements
to press capture systems, including "close-in" hooding, will
result in less HAP escaping to the pressroom. Reduced flows of
HAP to the pressroom will decrease the overall air treatment
requirements (with or without a total enclosure) if pressroom
ventilation air must be treated to improve overall efficiency.

All improved capture and control options, costed in Chapter
6, require the handling and treatment of additional volumes of
air. The incremental solvent captured will be present at lower
concentrations than the solvent laden air presently ducted to the
solvent recovery systems. In the case of total enclosure
systems, the HAP concentration in the additional air will
approximate that of the pressroom. Pressroom concentrations of
toluene, the HAP present in highest concentration in the ink (and
the pressroom air), are limited by occupational health
considerations to 100 ppmv.

It may be economically advantageous to pretreat the
additional air resulting from improvements in capture efficiency
using solvent concentrator systems. It should be noted that
systems of this type are not presently in use in the publication
gravure industry segment; they are, however, in use in related
applications including control of paint spray booth emissions.
Concentrator systems are designed to adsorb solvents from dilute
air streams. The sorbent (activated carbon or zeolite) is
regenerated with hot air. The regeneration air requirement is
only about ten percent of the volume of air treated. Thus the
dilute solvent laden air stream is converted to a concentrated
regeneration air stream which is exhausted to another control

4-34

-------
device. In this case, the exhaust from the concentrator system
may be ducted to the existing solvent recovery system. Some
increase in capacity of the existing solvent recovery systems may
be required.

The substitution of non-HAP solvents for a portion of the
HAP solvents in the ink is a control option which may be used to
decrease HAP emissions without increasing either the capture
efficiency or the control device efficiency. This control option
may not be available to all facilities. No information is
available on the cost and effects on output quality resulting
from substitution of non-HAP solvents for HAP such as toluene.
It should be noted that while substitution of non-HAP solvents
for HAP could be encouraged as a pollution prevention option, it
does not significantly affect VOC emissions.

All demonstrated control options include the use of solvent
recovery systems as the control device. The systems of
demonstrated effectiveness are composed of fixed bed activated
carbon adsorption units which are cyclically regenerated with
steam. These systems include regeneration gas condensers and
solvent/water decanters.

The distinction among the control options is the capture
system employed. The specification of ventilation, hooding and
ducting for incremental improvements to existing systems is site
specific. There are an infinite number of gradations between
existing capture systems and permanent total enclosures. Table
4-8 lists control options which represent discrete levels of
capture.

In all cases pollution prevention could be encouraged by
allowing credit for elimination of HAP emissions through
substitution of non-HAP solvent for HAP. A reduction in HAP
emissions through substitution, combined with some degree of
improvement in capture can achieve the same reduction in HAP
emissions as that of the specified control option.

4-35

-------
4.3.2 Control Options for Product and Packaging Rotogravure
Packaging and product rotogravure plants in the United
States use a variety of control technologies. Control strategies
are influenced by the composition of inks and other materials
applied on the press, and regulatory requirements. In most
cases, regulations presently in effect limit emissions of VOC.

4-36

-------
Table 4-8. Control Options for Publication Rotogravure Plants.

Option

Control Device

Capture System

A

Solvent recovery system
with carbon adsorption and
steam regeneration.

Draw 50% of required pressroom
ventilation air through concentrator to
existing solvent recovery system.

B



Draw 100% of required pressroom
ventilation air through concentrator to
existing solvent recovery system.

C



Construct permanent total enclosure and
draw 100% of required pressroom
ventilation air through concentrator to
existing solvent recovery system.

-------
Control devices presently in operation were, for the most part, specified and operated to
meet VOC emissions requirements. Where ink systems are primarily based on non-HAP
solvents, no data have been collected to demonstrate the effectiveness of existing control
devices with respect to individual HAP. Where HAP (e. g. toluene) based inks are used,
control device efficiencies are directly relevant to HAP control.

The selection of ink is influenced by the substrate printed and the performance
requirements of the packaging or product. Air pollution regulations in force at the time
of construction of the facility or specification of the control device also influence the
type of ink system.

Control technologies presently in use among major sources include activated carbon
solvent recovery systems, catalytic incinerators and oxidizers, and thermal incinerators
and oxidizers. These devices are capable of controlling greater than 95 percent of most
volatile organic compounds when properly designed and operated. Much of the variation in
overall control efficiencies achieved with any of these control devices is due to
variation in capture efficiency. Where presses are located within permanent total
enclosures capture efficiencies are assumed to be 100 percent. In other cases, capture
efficiencies depend on the type of capture devices and pressroom ventilation systems in
use.

Some plants have adopted waterborne ink technologies to reduce VOC emissions. In
many cases, low VOC ink formulations are used with no control devices. Capture systems at
these facilities serve to collect dryer exhausts and vent them to the atmosphere. Some
formulations are HAP free; many low VOC waterborne ink systems do contain small

4-38

-------
percentages of HAP (typically glycols, glycol ethers or
alcohols).

Control options for packaging and product rotogravure plants
are given in Table 4-9. In options A and B, a control device is
used with different levels of capture efficiency. The control
device can be selected based on the ink system in use, or if more

4-39

-------
Table 4-9. Control Options for Packaging and Product Rotogravure Plants.

Option

Control Device

Capture System

A

Solvent recovery system, or
catalytic incinerator or thermal
incinerator depending on ink
system in use.

Treat dryer exhaust plus 50
percent of required pressroom
air with control device.

B

Permanent Total Enclosure

C

Use of ink containing less than
1.5 percent HAP.

None

-------
than one type of device is potentially suitable, on the basis of
cost. As described above, all control devices presently in use
in this segment of the industry can achieve efficiencies of more
than 95 percent. Option C provides for the use of low HAP ink
with no control, provided that emissions do not exceed those of
plants using solvent based inks with a high HAP content using an
efficient capture and control system.

4.3.3 Control Options for Wide-web and Sheet Fed Flexocrraphv

Most flexographic printing facilities, and all flexographic
printing facilities outside of the flexible packaging industry,
operate without control devices. Control strategies are
influenced by the composition of inks and other materials applied
on the press, and regulatory requirements. Control devices
presently in operation were, for the most part, designed and
operated to meet VOC emissions requirements. Where ink systems
are primarily based on non-HAP solvents, no data have been
collected to demonstrate the effectiveness of existing control
devices with respect to individual HAP.

The selection of ink (and other materials such as adhesives,
primers and varnishes) is influenced by the substrate printed and
the performance requirements of the packaging or product. Air
pollution regulations in force at the time of construction of the
facility or specification of the control device also influence
the type of ink system.

Some plants have adopted waterborne ink technologies to
reduce VOC emissions. In many cases, low VOC ink formulations
are used with no control devices. Capture systems at these
facilities serve to collect dryer exhausts and vent them to the
atmosphere. Some formulations are HAP free; many low VOC
waterborne ink systems contain small percentages of HAP
(typically glycols, glycol ethers or alcohols). Many
flexographic printers use solvent based formulations which are
completely HAP free. In some cases, solvent based inks contain

4-41

-------
small percentages of the same HAP used in waterborne materials.
Some of these facilities operate VOC control devices. In the
absence of compound specific data on HAP control, HAP removal
efficiencies are estimated on the basis of VOC removal
efficiencies.

Control technologies presently in use include activated
carbon solvent recovery systems, catalytic incinerators and
oxidizers, and thermal incinerators and oxidizers. These devices
are capable of controlling greater than 95 percent of most
volatile organic compounds when properly designed and operated.
Much of the variation in overall control efficiencies achieved
with any of these control devices is due to variation in capture
efficiency. Where presses are located within permanent total
enclosures capture efficiencies are assumed to be 100 percent.
In other cases, capture efficiencies depend on the type of
capture devices and pressroom ventilation systems in use. None
of the flexographic facilities using control devices for
materials applied on flexographic presses are major sources on
the basis of reported HAP emissions.

Control options for flexographic printing facilities are
given in Table 4-10. In options A and B, a control device is
used with different levels of capture efficiency. The control
device can be selected based on the ink system in use, or if more
than one type of device is potentially suitable, on the basis of
cost. As described above, all control devices presently in use
in this segment of the industry can achieve efficiencies of more
than 95 percent, at high concentrations of HAP in the solvent
laden air. (It may be difficult to reach this level of control
device efficiency at lower HAP concentrations.) Option C
provides for the use of low HAP ink with no control, provided
that emissions do not exceed those of plants using solvent based
inks with a high HAP content using an efficient capture and
control system.

4-42

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4.4 ENHANCED MONITORING

4.4.1 Enhanced Monitoring for Publication Gravure

All existing publication rotogravure facilities monitor
control system performance using liquid-liquid mass balances.

4-43

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Table 4-10. Control Options for Flexographic Printing Plants.

Option

Control Device

Capture System

A

Solvent recovery system, or
catalytic incinerator or thermal
incinerator depending on ink
system in use.

Treat dryer exhaust plus 50
percent of required pressroom
air with control device.

B

Permanent Total Enclosure

C

Use of ink containing less than 1
percent HAP.

None

-------
These mass balances provide average recovery data averaged over
the reporting period. Because the HAP emissions are recovered,
rather than destroyed, any intermittent system failures,
decreases in control device efficiency or increases in fugitive
emissions will be reflected in the overall mass balance. This
method provides an average of continuous overall efficiency
(rather than an average of discrete measurements of control
device efficiency).

4.4.2 Enhanced Monitoring for Product and Packaging Rotogravure

Facilities operating solvent recovery systems monitor
control system performance using liquid-liquid mass balances.
These mass balances provide recovery data averaged over the
reporting period. Because the HAP emissions are recovered,
rather than destroyed, any intermittent system failures,
decreases in control device efficiency or increases in fugitive
emissions will be reflected in the overall mass balance. Since
this method provides an average of continuous overall efficiency
(rather than an average of discrete measurements of control
device efficiency) enhanced monitoring is not recommended for
this industry segment.

Facilities operating thermal incinerators or catalytic
incinerators must monitor control device performance. Continuous
emission monitoring may not be reliable for emission streams in
which the HAP present makes up a small percentage of the VOC
present, as is the case in many emission streams from packaging
and product rotogravure printing. The output of continuous
emissions monitors may not reflect the HAP concentration of the
emissions stream due to differences in response among the HAP,
non-HAP VOC, and products of incomplete combustion.

Continuous control device measurement should be required for
facilities operating thermal incinerators or catalytic
incinerators. Variations in combustion temperature affect the

4-45

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performance of these devices. The operators of thermal and
catalytic incinerators should install, calibrate, maintain, and
operate a temperature monitoring device in accordance with the
manufacturer's specifications. The temperature should be
maintained at a temperature equal to or higher than the
temperature at which compliance was demonstrated.

4.4.3 Enhanced Monitoring for Wide-web and Sheet Fed Flexocrraphv

Based on responses to the ICR, none of the flexographic
printing facilities operating control devices had HAP emissions
in excess of 25 tons per year of HAP or 10 tons per year of any
specific HAP. Facilities affected by a MACT standard regulating
HAP emissions which operate control devices should be subject to
the same enhanced monitoring requirements as product and
packaging gravure facilities (see Section 4.4.2) .

Facilities controlling HAP emissions through the use of low
HAP ink formulations should maintain documentation confirming the
HAP content of the materials applied on flexographic presses. In
the event that specifications provided by ink suppliers are
inadequate to establish the HAP content, additional compositional
analyses should be conducted by the facility.

4-46

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5.0 ENVIRONMENTAL AND ENERGY IMPACTS OF CONTROL OPTIONS

5.1 ENERGY IMPACT

5.1.1 Publication Rotogravure

Energy requirements for implementation of the control
options for publication gravure plants include electricity to
collect and treat additional ventilation air, natural gas to heat
air for desorption of HAP recovered by the concentrators, and
additional steam required for regeneration of the incremental
activated carbon and recovery of the incremental HAP. The
control options will recover incremental amounts of toluene,
which has a heating value but is not used as a fuel. Energy use
has been estimated for each of the 27 publication rotogravure
facilities. The sum of the increased energy requirements is
given in Table 5-1. Control options B and C have equal energy
requirements.

Energy impact calculations were based on the assumption of
1.5 percent solvent retention in the substrate. Uncontrolled and
unretained HAP is assumed to be available in pressroom air at 50
ppmv. Ventilation requirements are estimated based on the volume
of air necessary to dilute the uncontrolled and unretained HAP to
this level. Fan power requirements are based on moving 50
percent (Control option A) or 100% (Control options B and C) of
the pressroom ventilation requirement through concentrator
systems plus the desorption gas. The desorption gas flow rate is
10 percent of the gas treated. The concentrator is assumed to be
93 percent efficient (this assumption is subject to change,
should test data become available); the incremental adsorption

5-1

-------
capacity devoted to the concentrated stream is assumed to be 98
percent efficient.

5-2

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Table 5-1. Energy Impact of Control Options for Publication

Rotogravure Plants.

Energy Impact

Control Option A

Control Options B & C

Fan Power (kwhr/yr)

26,100,000

52,100,000

Natural Gas
(SCF/yr)

553,000,000

1,100,000,000

The concentrator is assumed to be desorbed with 300 degree F air
heated with natural gas at 90 percent efficiency. Incremental
carbon capacity is desorbed with 2 pounds steam per pound of HAP,
based on model plant calculations. Table 5-1 gives the energy
impact of the control options, assuming natural gas fired boilers
are used to generate incremental carbon regeneration steam.
5.1.2 Product and Packaging Rotogravure

Energy requirements for implementation of the control
options A and B for package and product gravure plants include
electricity to collect and treat additional ventilation air and
natural gas for auxiliary fuel required for HAP destruction.
Energy use has been estimated for 36 package and product
rotogravure facilities with large enough emissions to be covered
under the MACT standard. The sum of the increased energy
requirements for control options A and B have been estimated in
Table 5-2. These estimates are based on improvements to capture
(with incineration of the recovered fugitive emissions) at 28
facilities, and installation of capture systems and control
devices at 6 presently uncontrolled facilities. Two facilities
which apply materials which are less than 4 percent HAP, and have
no control devices, are excluded from the estimate.

Electricity and natural gas requirements have been based on
the model plant calculations. Model plants with control devices
had average electricity and gas requirements of 16 kwhr and 9000
SCF per pound of incrementally controlled HAP. Model plants

5-3

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Table 5-2. Energy Impact of Control Options for Product and

Packaging Gravure Plants.

Energy Impact

Control Option A

Control Option B

Fan Power (kwhr/yr)

47,000,000

70,000,000

Natural Gas
(SCF/yr)

1.8 E 10

3.0 E 10

without control devices had average electricity and gas
requirements of 11 kwhr and 2000 SCF per pound of incrementally
controlled HAP. Control option B provides overall control
equivalent to 96.5 percent of HAP usage. This is consistent with
a 98 percent efficient control device, allowing for 1.5 percent
HAP retention in the printed substrate. Control option A
provides for varying overall efficiencies depending on the
capture efficiency of the existing system. HAP retention may
vary, but this will have only a small effect on energy
requirements.

Control option C could represent a decrease in energy
requirements if facilities which presently operate incinerators
converted to ink formulations with lower HAP content. Under some
circumstances, operation of existing incinerators would no longer
be required. This would result in the elimination of all
auxiliary fuel requirements. These energy savings would not be
realized by facilities presently operating control devices for
VOC control unless waterborne (low HAP, low VOC), formulations
were used. The energy impact of this control option has not been
estimated because it is impossible to predict what formulations
would be used to comply.

5.1.3 Wide-web and Sheet Fed Flexocrraphv

Energy requirements for implementation of the control
options A and B for wide web flexography plants include
electricity to collect and treat additional ventilation air and

5-4

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natural gas for auxiliary fuel required for HAP destruction. It
is estimated that 50 facilities may have emissions large enough
to be covered by the standard based on estimated "potential to
emit". This includes all facilities providing responses to the
ICR with HAP usage of at least 10,000 pounds in 1992. Some of
these facilities may have permit restrictions or other
limitations which would keep their potential to emit below 25
tons HAP per year (or ten tons of any single HAP). Of these
facilities, 15 presently operate control devices. The following
discussion assumes that the 35 flexographic printing facilities
not presently operating control devices will comply with the
standard by reducing their HAP usage and the remaining facilities
will improve capture and control.

The sum of the increased energy requirements for control
options A and B have been estimated in Table 5-3. These
estimates are based on improvements to capture (with incineration
of the recovered fugitive emissions) at 15 facilities. Energy
requirements will increase if facilities which presently have no
control devices install them to meet the standard. Energy
requirements may decrease somewhat if some of the facilities
considered on the basis of HAP usage are not major sources by
reason of limitations of their potential to emit.

Electricity and natural gas requirements have been based on
the model plant calculations. Model plants with control devices
had average electricity and gas requirements of 30 kwhr and 5400
SCF per pound of incrementally controlled HAP. Control option B
provides overall control equivalent to 93.5 percent of HAP usage.
This is consistent with a 95 percent efficient control device,
allowing for 1.5 percent HAP retention in the printed substrate.
Control option A provides for varying overall efficiencies
depending on the capture efficiency of the existing system. HAP
retention may vary, but this will have only a small effect on
energy requirements.

5-5

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Table 5-3. Energy Impact of Control Options for Wide-web and

Sheet Fed Flexography.

Energy Impact

Control Option A

Control Option B

Fan Power (kwhr/yr)

1,770,000

3,540,000

Natural Gas
(SCF/yr)

318,000,000

637,000,000

Control option C could represent a decrease in energy
requirements if facilities which presently operate incinerators
converted to ink formulations with lower HAP content. Under
somecircumstances, operation of existing incinerators would no
longer be required. This would result in the elimination of all
auxiliary fuel requirements. These energy savings would not be
realized by facilities presently operating control devices for
VOC control unless waterborne (low HAP, low VOC), formulations
were used. The energy impact of this control option has not been
estimated because it is impossible to predict what formulations
would be used to comply.

5.2 AIR IMPACTS

5.2.1	Publication Rotogravure

The major air impact of implementing the control options is
reduced emissions of HAP to the atmosphere. Minor impacts are
associated with the production and use of electricity and fuel
required for fans, desorption gas heaters, and boilers generating
steam for incremental carbon regeneration requirements. Table
5-4 lists air impacts for the control options. Impacts
associated with electric utility generation are assumed to be 3.6
grams sulfur dioxide and 560 grams carbon dioxide per kwhr.

5.2.2	Product and Packaging Gravure

The major air impact of implementing the control options is
reduced emissions of HAP to the atmosphere. Minor impacts are
associated with the production and use of electricity required

5-6

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Table 5-4. Air Impact of Control Options for Publication

Rotogravure Plants.

Air Impact

Control Option A

Control Options B & C

HAP Eliminated
(Ton/yr)

7, 000

14,000

Sulfur Dioxide
Emitted (Ton/yr)

103

206

Carbon Dioxide
Emitted (Ton/yr)

50,000

100,000

for fans and auxiliary fuel for incinerators. Table 5-5 lists
air impacts for the control options. Estimates for options A and
B are based on upgrades to 28 facilities presently
operatingcontrol devices and installation of capture and control
systems at 6 facilities. Estimates for option C are based on the
34 facilities considered for options A and B plus two additional
facilities presently applying formulations containing less than 4
percent HAP. Impacts associated with electric utility generation
are assumed to be 3.6 grams sulfur dioxide and 560 grams carbon
dioxide per kwhr.

5.2.3 Wide-web and Sheet Fed Flexocrraphv

The major air impact of implementing the control options is
reduced emissions of HAP to the atmosphere. Minor impacts are
associated with the production and use of electricity required
for fans and auxiliary fuel for incinerators. Table 5-6 lists
air impacts for the control options. Estimates for options A and
B are based on upgrades to 15 facilities presently operating
control devices. Estimates for option C are based on a total of
50 facilities (an additional 35 facilities not presently
considered for options A and B are included). Impacts associated
with electric utility generation are assumed to be 3.6 grams
sulfur dioxide and 560 grams carbon dioxide per kwhr.

5-7

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Table 5-5. Air Impact of Control Options for Product and
Packaging Rotogravure Plants.

Air Impact

Option A

Option B

Option C

HAP Eliminated
(Ton/yr)

1800

2600

2400

Sulfur Dioxide
Emitted (Ton/yr)

1900

2800

NA

Carbon Dioxide
Emitted (Ton/yr)

31000

47000

NA

NA=Not available.

Table 5-6. Air Impact of Control Options for Wide-web and Sheet

Fed Flexography.

Air Impact

Option A

Option B

Option C

HAP Eliminated
(Ton/yr)

29

59

830

Sulfur Dioxide
Emitted (Ton/yr)

7 . 0

14

NA

Carbon Dioxide
Emitted (Ton/yr)

20,000

39,000

NA

NA=Not available.

5-8

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5.3 WATER IMPACTS

5.3.1	Publication Rotogravure

Water impacts resulting from implementation of the control
options are insignificant. Small increases in boiler blowdown
may be associated with the incremental increase in steam required
for recovery of incremental HAP. This water will be of
relatively high quality.

5.3.2	Product and Packaging Rotogravure and Wide-web and Sheet-
Fed Flexocrraphv

Water impacts resulting from implementation of the control
options are insignificant. Control option C does not assume
conversion to waterborne inks. If waterborne inks are adopted,
pressroom cleaning will be done with water which may generate an
additional low volume wastewater stream.

5.4. SOLID WASTE IMPACT

5.4.1	Publication Rotogravure

The impact of the control options on solid waste will be
negligible. The incremental carbon will require replacement
every five to ten years. It is expected that most of this
material will be sold for reprocessing into other products and
will not become solid waste. The concentrators are expected to
last 15 years or longer.

5.4.2	Product and Packaging Rotogravure and Wide-web Flexographv
The impact of the control options on solid waste will be

negligible. If catalytic incinerators are used, catalyst
replacement may be necessary every ten years. Spent catalyst may
require disposal as hazardous waste.

5-9

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6.0 MODEL PLANT CONTROL OPTION COST

6.1	INTRODUCTION

Model plants, and the criteria used to choose them have been
described in Chapter 4. Control options applicable to specific
segments of the printing and publishing industry have also been
described in Chapter 4. This chapter describes the estimated
costs of applying the control options to the model plants.

6.2	PUBLICATION ROTOGRAVURE

Model plant specifications are given in Table 6-1. These
are based on several assumptions. HAP retention in the web is
assumed to be 1.5 percent of that used. This material is not
emitted in the pressroom or dryer. Pressroom ventilation rates
have been proposed based on the volume of air necessary to dilute
the fugitive emissions to acceptable levels for the health and
safety of the operators. This ventilation may be presently
supplied by doors, windows and leaks to the atmosphere.

Pressroom volumes have been assumed based on the number and size
of the presses in the model plants. Corresponding air exchange
rates are listed, however, only the assumed ventilation rate
affects the amount of air to be treated. The pressroom volume
and air exchange rates can vary to provide the assumed
ventilation rate. The pressroom and control systems are assumed
to operate 120 hours per week.

6-1

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The control options apply to incremental capture and control
of fugitive emissions. The control options involve collecting
and treating pressroom air containing fugitive HAP which escapes

6-2

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Table 6-1. Publication Rotogravure Model Plant Specifications Used for Control Option

Costing.

Model Plant

1

2

3

4

5

Presses/Stations

8/10

8/10

4/8

4/8

5/8

Pressroom Length (ft)

240

240

120

120

150

Pressroom Width (ft)

150

150

120

120

120

Pressroom Height (ft)

30

30

30

30

30

Hap usage (lb/yr)

22,500,000

22,500,000

6, 400,000

6, 400,000

14,000,000

HAP usage (g/min)

19,435

19,435

5, 528

5, 528

12,093

Capture Efficiency (%)

98 .1

90 . 7

98 .1

90 . 7

80 . 4

Control Efficiency (%)

97 . 0

97 . 0

97 . 0

97 . 0

97 . 0

Overall Control (%)

95.2

o

CO
CO

95.2

o

CO
CO

78 . 0

HAP controlled (lb/Yr)

21,420,000

19,800,000

6,092,800

5,632,000

10,920,000

HAP emitted (lb/Yr)

1,080,000

2,700,000

307,200

768,000

3,080,000

HAP retained (lb/Yr)

337,500

337,500

96,000

96,000

210,000

HAP to Pressroom (lb/Yr)

90,000

1,755,000

25,600

499,200

2,534,000

Pressroom Volume (CF)

1,080,000

1,080,000

432,000

432,000

540,000

Air Change Rate(/hr)

2

30

2

30

60

Vent. Rate (SCFM)

36,000

540,000

14,400

216,000

540,000

Pressroom Cone, (lb/acf)

6.6 6e-0 6

8.6 6e-0 6

4 . 74e-06

6.16e-0 6

1. 25e-05

Pressroom Cone, (ppm)

28 . 3

36.8

20 .1

26.2

53.2

Assumed pressroom volume based on new installation information. Assumed 1.5% of HAP used is
retained in the web, and ultimately emitted outside the pressroom. Operating time based on 1980
NSPS. Assumed plant (and concentrator) operation 5 days/wk; 24 hr/day.

-------
the existing capture system. Since the pressroom air is at
relatively low concentration, cost calculations are based on use
of a concentrator system. The assumed concentrator
specifications are given in Table 6-2. Control option A has not
been applied to model plants 1 and 3, as incremental HAP
reduction would be negligible for these cases. The concentrator
systems are assumed to be 93 percent efficient (this assumption
is subject to revision if test data become available) and exhaust
a stream of 10 percent of the volume of the treated pressroom
air. This concentrated exhaust stream is assumed to be added to
the carbon adsorption/steam regeneration solvent recovery system.
The capital costs of these systems for the three control options
are given in Tables 6-3 through 6-5. Concentrator system costs
were based on telephone quotes from three vendors. An upgrade to
the existing solvent recovery system to account for the increased
capacity required to treat the concentrator exhaust is included
in Tables 6-3 through 6-5. These costs are detailed in Tables 6-
6 and 6-7. The inclusion of solvent recovery system upgrade
costs is conservative as existing solvent recovery systems may be
adequate to treat the incremental concentrator exhaust flows. In
this case, increased regeneration frequencies could be required.
Control option C includes retrofit construction of a permanent
total enclosure. These costs are estimated in Table 6-8 and
included in Table 6-5. Total enclosure costs are based on the
construction of two new walls and the presence of two existing
walls. Depending on the existing structure, total enclosure
costs could be higher or lower than those estimated.

Total annual costs have been estimated for the three control
options in Tables 6-9 through 6-11. These estimates include
recovery of capital costs based on a 7 percent interest rate and
a 15 year equipment life. Operating costs include utilities,
labor, materials, tax, insurance and administration. Additional
notes to the cost calculation tables are given in Table 6-12.

6-4

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Cost effectiveness of the control options applied to the model
plants is given in Table 6-13. Cost effectiveness varies between

6-5

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Table 6-2. Publication Rotogravure Control Device Specifications usedfor Control Option

Costing.

Concentrator System-Control Option A



Model Plant

2

4

5



Flow to Concentrator (scfm)



300,000

100,000

300,000



Flow from Concentrator (scfm)



30,000

10,000

30,000



HAP to Concentrator (lb/yr)



975,000

231,111

1,407,778



Incremental Control (lb/yr)



879,548

208,485

1,269,956



Incremental Control Efficiency (%)



3 . 91

3.26

9 . 07



New overall Control (%)



91. 9

91. 3

87 .1





Concentrator System-Control Options B & C



Model Plant

1

2

3

4

5

Flow to Concentrator (scfm)

36,000

540,000

14,400

216,000

540,000

Flow from Concentrator (scfm)

3, 600

54,000

1,440

21,600

54,000

HAP to Concentrator (lb/yr)

90,000

1,755,000

25,600

499,200

2,534,000

Incremental Control (lb/yr)

81,189

1,583,186

23,094

450,328

2,285,921

Incremental Control Efficiency (%)

0 .36

7 . 04

0 .36

7 . 04

16.33

New overall Control (%)

95 . 6

95 . 0

95 . 6

95 . 0

94 . 3



Assumed 93% concentrator efficiency.

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Table 6-3. Capital Costs of Concentrator/Solvent Recovery
Systems for Control Option A at Model Publication Rotogravure

Plants.

Model Plant

2

4

5



Intake Rate (SCFM)

300,000

100,000

300,000

Intake rate (ACFM)

327,473

109,158

327,473

Exhaust rate (SCFM)

30,000

10,000

30,000

Installed Cost--Note 1

$3,600,000

$1,200,000

$3,600,000

Site Preparation-Note 2

360,000

120,000

360,000

Duct Length (ft)--Note 12

180

60

180

Duct Diameter (in)

60

60

60

Duct Cost @$126/ft

22,680

7,560

22,680

Solvent Recovery System
upgrade

19,040

7, 955

24,536

Cost including duct and
site Prep.

4,001,720

1,335,515

4,007,216

Engineering, supervision,
construction, field
expenses, fee, start-up,
performance test and
contingencies-Note 3

1,240,533

414,010

1,242,237



Total Capital Cost-
Concentrator System

5,242,253

1,749,524

5,249,453



Capital Recovery
factor-Note 4

0.1098

0.1098

0.1098

Annualized Capital Cost

$575,571

$192,088

$576,362



Solvent recovery system upgrade costs are detailed in Table
6-6. See notes to cost calculations in Table 6-12.

6-7

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Table 6-4. Capital Costs of Concentrator/Solvent Recovery Systems for Control Option B at

Model Publication Rotogravure Plants.

Model Plant

1

2

3

4

5



Intake Rate (SCFM)

36,000

540,000

14,400

216,000

540,000

Intake rate (ACFM)

39,297

589,451

15,719

235,780

589,451

Exhaust rate (SCFM)

3, 600

54,000

1,440

21,600

54,000

Installed Cost--Note 1

$432,000

$6,480,000

$172,800

$2,592,000

$6,480,000

Site Preparation-Note 2

$43,200

$648,000

$17,280

$259,200

$648,000

Duct Length (ft)--Note 12

30

330

30

150

330

Duct Diameter (in)

60

60

60

60

60

Duct Cost 0$126/ft

$3,780

$41,580

$3,780

$18,900

$41,580

Solvent Recovery System upgrade

$5,000

$26,725

$5,000

$14,140

$34,542

Cost including duct and site
Preparation

$483,980

$7,196,305

$198,860

$2,884,240

$7,204,122

Engineering, supervision,
construction field expenses, fee,
start-up, performance test and
contingencies-Note 3

$150,034

$2,230,855

$61,647

$894,114

$2,233,278



Total Capital Cost- Concentrator
System

$634,014

$9,427,159

$260,507

$3,778,355

$9,437,400

Capital Recovery factor-Note 4

0.1098

0.1098

0.1098

0.1098

0.1098

Annualized Capital Cost

$69,611

$1,035,051

$28,602

$414,843

$1,036,176



Solvent recovery system upgrade costs are detailed in Table 6-7.
See notes to cost calculations in Table 6-12.

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6-9

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Table 6-5. Capital Costs of Concentrator/Solvent Recovery Systems for Control Option C at

Model Publication Rotogravure Plants.

Model Plant

1

2

3

4

5

Intake Rate (SCFM)

36,000

540,000

14,400

216,000

540,000

Intake rate (ACFM)

39,297

589,451

15,719

235,780

589,451

Exhaust rate (SCFM)

3, 600

54,000

1,440

21,600

54,000

Installed Cost--Note 1

$432,000

$6,480,000

$172,800

$2,592,000

$6,480,000

Site Preparation-Note 2

$43,200

$648,000

$17,280

$259,200

$648,000

Duct Length (ft)--Note 12

30

330

30

150

330

Duct Diameter (in)

60

60

60

60

60

Duct Cost 0$126/ft

$3,780

$41,580

$3,780

$18,900

$41,580

Solvent Recovery System upgrade

$5,000

$26,725

$5,000

$14,140

$34,542

Cost including duct and site Prep.

$483,980

$7,196,305

$198,860

$2,884,240

$7,204,122

Engineering, supervision,
construction, field expenses, fee,
start-up, performance test and
contingencies-Note 3

$150,034

$2,230,855

$61,647

$894,114

$2,233,278

Total Capital Cost- Concentrator
System

$634,014

$9,427,159

$260,507

$3,778,355

$9,437,400

Permanent Total Enclosure
Construction Cost

$44,704

$44,704

$28,284

$28,284

$31,568













Total Capital Cost

$678,718

$9,471,864

$288,790

$3,806,638

$9,468,968

Capital Recovery factor-Note 4

0.1098

0.1098

0.1098

0.1098

0.1098

Annualized Capital Cost

$74,520

$1,039,960

$31,708

$417,948

$1,039,642

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Permanent total enclosure costs are detailed in Table 6-8. Solvent recovery system upgrade costs are
detailed in Table 6-7. See notes to cost calculations in Table 6-12.

6-11

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Table 6-6. Capital Costs of Required Solvent Recovery System
Upgrades for Control Option A at Model Publication Rotogravure

Plants.

Model Plant

2

4

5



Incremental Flow Rate
(SCFM)

30,000

10,000

30,000

Pressroom Concentration
(ppm)

36.8

26.2

53.2

Concentrator Exhaust Cone,
(ppm)

342

244

495

Incremental HAP Loading
(lb/hr)

140 . 6

33 . 3

203 . 0

Adsorption Time (hr)

2

2

2

Equilibrium Adsorptivity
(lb toluene/lb carbon)

0 .31

0 .30

0 . 32

Working Capacity (lb
HAP/lb carbon)

0 . 154

0 . 148

0.160

Carbon Required (lb)

1827

449

2532

Adsorber Volume Required
(CF)

109.59

26. 97

151.95

Adsorber Length (ft)

16

9

22

Adsorber Diameter (ft)

3

2

3

Adsorber Surface (sf)

164.934

62.832

221.4828

Adsorber Cost ($1989)

$14,389

$6,791

$18,099

Adsorber Cost ($1993)

$14,474

$6, 831

$18,205

Carbon Cost @$2.50/lb

$4,566

$1,124

$6, 331

Adsorber Cost including
carbon

$19,040

$7,955

$24,536



Note: Costs escalated to 1993$ using Marshall and Swift cost
index factor of (394.4/392.1) .

6-12

-------
Table 6-7. Capital Costs of Required Solvent Recovery Upgrades for Control Options B and

C at Model Publication Rotogravure Plants.

Model Plant

1

2

3

4

5



Incremental Flow Rate (SCFM)

3, 600

54,000

1,440

21,600

54,000

Pressroom Concentration (ppm)

28 . 3

36.8

20 .1

26.2

53.2

Concentrator Exhaust Cone, (ppm)

263

342

187

244

495

Incremental HAP Loading (lb/hr)

13 . 0

253 . 0

3 . 7

72 . 0

365 . 3

Adsorption Time (hr)

2

2

2

2

2

Equilibrium Adsorptivity (lb toluene/lb
carbon)

0 . 30

0 . 31

0.29

0 . 30

0 . 32

Working Capacity (lb HAP/lb carbon)

0 .15

0 .15

0 .14

0 .15

0 .16

Carbon Required (lb)

174

3288

51

971

4558

Adsorber Volume Required (CF)

10 .41

197.26

3 . 08

58 .25

273.51

Adsorber Length (ft)

NOTE 13

16

NOTE 13

19

22

Adsorber Diameter (ft)

NOTE 13

4

NOTE 13

2

4

Adsorber Surface (sf)

NOTE 13

226.1952

NOTE 13

125 . 656

301.5744

Adsorber Cost ($1989)

NOTE 13

$18,397

NOTE 13

$11,645

$23,011

Adsorber Cost ($1993)

NOTE 13

$18,505

NOTE 13

$11,713

$23,146

Carbon Cost0$2.50/lb

NOTE 13

$8,220

NOTE 13

$2,427

$11,396

Adsorber Cost including carbon

$5,000

$26,725

$5,000

$14,140

$34,542



Note: Costs escalated to 1993$ using Marshall and Swift cost index factor of (394.4/392.1).
See notes to cost calculations in Table 6-12.

-------
Table 6-8. Capital Costs of Permanent Total Enclosure for Control Option C at Model

Publication Rotogravure Plants.

Wall Dimensions (ft)

240 x 30

240 x 30

120 x 30

120 x 30

150 x 30

Wall Dimensions (ft)

150 x 30

150 x 30

120 x 30

120 x 30

120 x 30

Total Area-Two Walls (SF)

11700

11700

7200

7200

8100

Large Door Dimensions (ft)

6 x 10

6 x 10

6 x 10

6 x 10

6 x 10

Small Door Dimensions (ft)

8x4

8x4

8x4

8x4

8x4

Wall Cost

$42,694

$42,694

$26,274

$26,274

$29,558

Large Door Cost

1850

1850

1850

1850

1850

Small Door Cost

160

160

160

160

160

Total Cost

$44,704

$44,704

$28,284

$28,284

$31,568



Assumptions: Two existing walls, two walls to be constructed, one large door
and one small door to be added. 8" concrete (sand aggregate) block, 3/8"
mortar joint, tooled one side. Large door-Aluminum door and frame including
hardware and closer. Small door-16 gauge steel, 5" deep.

Costs from Waier, Phillip R. et al.,Means Building Construction Cost
51st Annual Edition, R. S. Means Company, 1992.

Data,

-------
Table 6-9. Total Annual Costs for Control Option A at Model Publication Rotogravure

Plants.

Control Option/Model Plant

A-2

A-4

LO
1

<



Annualized Capital Cost

$575,571

$192,088

$576,362

Operating Costs

Electricity-Concentrator-Note 5

146,867

48,956

146,867

Gas-Concentrator-Note 6

44,973

14,991

44,973

Steam-Recovery System Upgrade-Note 14

10,286

2,531

14,261

Operating labor-Note 7

58,662

19,554

58,656

Supervisory Labor-Note 8

8,799

2, 933

8,798

Maintenance Labor-Note 9

64,528

21,509

64,522

Materials-Note 10

64,528

21,509

64,522

Property tax, Insurance and
Administrative-Note 11.

209,690

69,981

209,978



Total Annual Costs

$1,183,905

$394,053

$1,188,939



Solvent Recovery Credit-Note 15

$131,932

$31,273

$190,493



Net Annual Costs

$1,051,972

$362,780

$998,445



See notes to cost calculations in Table 6-12.

-------
Table 6-10. Total Annual Costs for Control Option B at Model Publication Rotogravure

Plants.

Control Option/Model Plant

w

1

I—1

w

1

t\)

w

1

CO

B-4

B-5



Annualized Capital Cost

$69,611

$1,035,051

$28,602

$414,843

$1,036,176



Operating Costs

Electricity-Concentrator-Note 5

17,624

264,361

7,050

105,744

264,361

Gas-Concentrator-Note 6

26,909

403,638

10,764

161,455

403,638

Steam-Recovery System
Upgrade-Note 14

977

18,515

289

5, 467

25,671

Operating labor-Note 7

9,777

107,547

29,331

48,885

107,547

Supervisory Labor-Note 8

1, 467

16,132

4,400

7,333

16,132

Maintenance Labor-Note 9

10,755

118,302

32,264

53,774

118,302

Materials-Note 10

10,755

118,302

32,264

53,774

118,302

Property tax, Insurance and
Administrative-Note 11.

25,361

377,086

10,420

151,134

377,496



Total Annual Costs

$173,235

$2,458,934

$155,383

$1,002,409

$2,467,624



Solvent Recovery Credit-Note 15

$12,178

$237,478

$3,464

$67,549

$342,888



Net Annual Costs

$161,057

$2,221,456

$151,919

$934,859

$2,124,736



See notes to cost calculations in Table 6-12.

-------
6-17

-------
Table 6-11. Total Annual Costs for Control Option C at Model Publication Rotogravure

Plants.

Control Option/Model Plant

0

1

I—1

0

1

t\)

0

1

CO

¦xT

1

O

LO
1

o



Annualized Capital Cost

$74,520

$1,039,960

$31,708

$417,948

$1,039,642

Operating Costs

Electricity-Concentrator-Note 5

17,624

264,361

7,050

105,744

264,361

Gas-Concentrator-Note 6

26,909

403,638

10,764

161,455

403,638

Steam-Recovery System
Upgrade-Note 14

977

18,515

289

5, 467

25,671

Operating labor-Note 7

9,777

107,547

29,331

48,885

107,547

Supervisory Labor-Note 8

1, 467

16,132

4,400

7,333

16,132

Maintenance Labor-Note 9

10,755

118,302

32,264

53,774

118,302

Materials-Note 10

10,755

118,302

32,264

53,774

118,302

Property tax, Insurance and
Administrative-Note 11.

27,149

378,875

11,552

152,266

378,759



Total Annual Costs

$179,932

$2,465,631

$159,620

$1,006,645

$2,472,353



Solvent Recovery Credit-Note 15

$12,178

$237,478

$3,464

$67,549

$342,888



Net Annual Costs

$167,754

$2,228,153

$156,156

$939,096

$2,129,465



See notes to cost calculations in Table 6-12.

-------
Table 6-12. Notes to Control Cost Calculations for Model
Publication Rotogravure Plants.

Note 1.

From telephone quotes; $12/SCFM installed
price--modular: no economies of scale

Note 2.

Arbitrarily assumed 10% of installed cost.

Note 3.

31% of installed cost, per EPA Handbook
(EPA/625/6-91/014)

Note 4.

15 years at 7%

Note 5.

Volume is 110% of intake rate, pressure drop =6 in.
water, fan efficiency is 65%, electricity at
0.0 6/kwhr

Note 6.

Desorption air at 300 degrees F. Desorption gas
flow rate =10% intake flow rate. Gas at $5/MM Btu.

Note 7.

0.5 hr/shift per concentrator, $25/hr including
overhead.

Note 8.

15% of operating labor

Note 9.

110% of operating labor

Note 10.

Assumed equal to maintenance labor.

Note 11.

4% of total capital cost

Note 12.

30 ft length of 5 ft diameter duct in parallel.

Note 13.

The existing adsorbers can be operated to handle the
small additional loading. A nominal upgrade cost is
given as a upper bound estimate.

Note 14.

0.3 lb steam/lb carbon. Steam at $6/1000 lb.

Note 15.

Recovered toluene valued at $0.15/lb.

6-19

-------
Table 6-13. Cost Effectiveness of Concentrator Systems for Incremental Control of

Publication Rotogravure Model Plants.

Control Option A

Model Plant



2



4

5



HAP Reduction (lb/yr)



879,548



208,485

1,269,956

Annual Cost



$1,051,972



$362,780

$998,445

Cost Effectiveness ($/Ton)



2, 392



3,480

1,572













Control Option B

Model Plant

1

2

3

4

5



HAP Reduction (lb/yr)

81,189

1,583,186

23,094

450,328

2,285,921

Annual Cost

$161,057

$2,221,456

$151,919

$934,859

$2,124,736

Cost Effectiveness ($/Ton)

3, 967

2,806

13,157

4, 152

1,859



Control Option C



Model Plant

1

2

3

4

5



HAP Reduction (lb/yr)

81,189

1,583,186

23,094

450,328

2,285,921

Annual Cost

$167,754

$2,228,153

$156,156

$939,096

$2,129,465

Cost Effectiveness ($/Ton)

4, 132

2,815

13,524

4,171

1, 863

-------
$1500 and $14,000 per ton of HAP reduction. The cost per
incremental ton of HAP reduction is highest at the model plants
with high levels of baseline HAP control, as these plants have
less fugitive emissions available for capture and treatment. The
annual costs for these plants are lower than the annual costs for
the model plants with low levels of baseline control as less
additional air must be handled at the well controlled plants.
6.3 PRODUCT AND PACKAGING ROTOGRAVURE

Model plant specifications are given in Table 6-14. These
are based on several assumptions. HAP retention in the web is
assumed to be 1.5 percent of that used. This material is not
emitted in the pressroom or dryer. Pressroom ventilation rates
have been proposed based on the volume of air necessary to dilute
the fugitive emissions to 50 ppmv VOC. The concentration of HAP
in the pressroom varies depending on the composition of the
materials applied. Ventilation air to dilute fugitive emissions
may be presently supplied by doors, windows, and leaks to the
atmosphere. Pressroom volumes have been assumed based on the
number and size of the presses in the model plants. The
pressroom and control systems are assumed to operate 80 hours per
week.

Control options A and B, as described in chapter 4, apply
to incremental capture and control of fugitive emissions from
existing capture systems at the model plants. Control options A
and B involve collecting and treating pressroom air containing
fugitive HAP which escapes the existing capture system. Costs
have been estimated on the basis of thermal incineration of this
pressroom air stream. Specifications for thermal incinerators
applicable to the model plants are given in Table 6-15. In many
cases, catalytic incineration would be appropriate for the
solvents in use. Catalytic incineration systems would have lower
operating costs and might have total annualized costs than the
estimates for thermal incineration systems. In some cases,

6-21

-------
concentrator systems (see Section 6.2) might be used to reduce
the size and capital and operating costs of the incinerator.

6-22

-------
Table 6-14. Model Plant Specifications for Product and Packaging Rotogravure.

Model Plant

1

2

3

4

5

Substrate

Vinyl
Products

Paper/Cardboard
Packaging

Foil/Film Packaging

Presses/Stations



8/4

4/8

1/6

2/8

4/6

Pressroom Dimensions

ft x ft x ft

240 x 100
x30

150 x 120 x
30

100 x 30
x30

60 x 150 x
30

120 x
120 x30

Ink Use

lb/year

1,000,000

1,800,000

2,000,000

3,000,000

300,000

VOC Use

lb/year

900,000

1,000,000

800,000

2,500,000

150,000

HAP Use

lb/year

900,000

200,000

600,000

1,000,000

65,000

Capture Efficiency

O.
O

89

81

N/A

95

N/A

Control Device Efficiency

o.
o

95

97

0

95

0

Overall Efficiency

o.
o

85

79

0

90

0

HAP Controlled

lb/year

765,000

158,000

0

900,000

0

HAP Retained

lb/year

13,500

3,000

9,000

15,000

975

HAP to Pressroom

lb/year

121,500

39,000

591,000

85,000

64,025

VOC Controlled

lb/year

765,000

790,000

0

2,250,000

0

VOC Retained

lb/year

13,500

15,000

12,000

37,500

2,250

VOC to Pressroom

lb/year

121,500

195,000

788,000

212,500

147,750

Pressroom VOC Cone.

ppm

50

50

50

50

50

Pressroom HAP Cone.

ppm

50 . 0

10 . 0

37 . 5

20 . 0

21. 7

N/A=Not applicable.

-------
Table 6-15. Incinerator Specifications for Product and Packaging Rotogravure Control

Options.

Thermal Incinerator--Control Option A

Model Plant

1

2

3

4

5

VOC Molecular Weight



92 .1

88 . 9

91.1

89.7

89.8

Ventilation Rate

SCFM

37,845

62,925

248,140

67,960

47,182

Incinerator Intake

SCFM

18,922

31,462

124,070

33,980

23,591

VOC to Incinerator

lb/yr

60,750

97,500

394,000

106,250

73,875

HAP to Incinerator

lb/yr

60,750

19,500

295,500

42,500

32,013

Incremental HAP Control

lb/yr

57,713

18,525

280,725

40,375

30,412

Incremental Control Effic.

O.
O

6.4

9 . 3

46.8

4 . 0

46.8

New Overall Control

o.
o

91

88

47

94

47



Thermal Incinerator--Control Option B

Model Plant

1

2

3

4

5

VOC Molecular Weight



92 .1

88 . 9

91.1

89.7

89.8

Ventilation Rate

SCFM

37,845

62,925

248,140

67,960

47,182

Incinerator Intake

SCFM

37,845

62,925

248,140

67,960

47,182

VOC to Incinerator

lb/yr

121,500

195,000

788,000

212,500

147,750

HAP to Incinerator

lb/yr

121,500

39,000

591,000

85,000

64,025

Incremental HAP Control

lb/yr

115,425

37,050

561,450

80,750

60,824

Incremental Control Effic.

O.
O

12 . 8

18 . 5

93 . 6

8 .1

93 . 6

New Overall Control

o.
o

98

98

94

98

94

Assume: HAP is toluene (MW=92.1), Non-HAP VOC is ethyl acetate (MW=88.1)
Pressroom ventilation incinerator efficiency=95%.

-------
The capital costs of these systems for control options A and
B are given in Tables 6-16 and 6-17. These costs are based on
the OAQPS Control Cost Manual1. The capital cost for control
option B includes retrofit construction of a permanent total
enclosure. The basis of this cost estimate is given in Table
6-18, and included in Table 6-17. Total enclosure costs are
based on the construction of two new walls and the presence of
two existing walls. Depending on the existing structure, total
enclosure costs could be higher or lower than those estimated.

Total annual costs have been estimated for control options A
and B in Tables 6-19 and 6-20. These estimates include recovery
of capital costs based on a 7 percent interest rate and a 15 year
equipment life. Operating costs include utilities, labor,
materials, tax, insurance and administration.

Cost effectiveness of the control options applied to the
model plants is given in Table 6-21. Cost effectiveness varies
between $10,000 and $48,000 per ton of HAP reduction. The cost
per incremental ton of HAP reduction is highest at the model
plants with high levels of baseline HAP control, as these plants
have less fugitive emissions available for capture and treatment.
The annual costs for these plants are lower than the annual costs
for the model plants with low levels of baseline control as less
additional air must be handled at the well controlled plants.

Control option C involves the use of low HAP ink. The
adoption of this control option could, in some cases, represent a
net savings over baseline levels of control. The applicability
of this option depends to a large extent on the type of printing
and the performance requirements of the product or package. Some
facilities, printing on both porous and non-porous substrates
report either zero or very low HAP use as a proportion of total
materials applied on rotogravure presses. Where feasible,
conversion to low HAP inks could result in substantial reductions

6-25

-------
in operating costs. Cost reductions from conversion to low HAP
inks have not been calculated, because low HAP inks may still

6-26

-------
Table 6-16. Capital Costs for Thermal Incinerators at Model Product and Packaging

Rotogravure Plants - Control Option A.

Model Plant



1

2

3

4

5



Incinerator Intake

SCFM

18,922

31,462

124,070

33,980

23,591

VOC to Incinerator

lb/yr

60,750

97,500

394,000

106,250

73,875

HAP to Incinerator

lb/yr

60,750

19,500

295,500

42,500

32,013

Control Efficiency

O.
O

95

95

95

95

95

Heat Recovery

o.
o

70

70

70

70

70

Costs (1988$)

Incinerator, auxiliary equipment
instrumentation, sales tax, and freight

302,738

343,780

484,445

350,460

319,903

Direct Installation Cost

90,822

103,134

145,334

105,138

95,971

Indirect Installation Cost

93,849

106,572

150,178

108,643

99,170

Site Preparation

30,274

34,378

48,445

35,046

31,990

Total Costs (1988$)

517,683

587,864

828,402

599,287

547,034

Total Costs (1993$)

587,497

667,143

940,119

680,106

620,806



Capital Recovery Factor

0.1098

0.1098

0.1098

0.1098

0.1098

Annualized capital cost

$64,507

$73,252

$103,225

$74,676

$68,164



Direct Installation includes foundation, supports, handling, erection, electrical, piping, insulation for
ductwork, and painting. Indirect installation cost includes engineering, construction and field expenses,
contractor fees, start-up, performance test, and contingencies. Costs based on OAQPS Control Cost Manual
(EPA 450/3-90-006, January 1990). Costs escalated to 1993$ using Marshall and Swift Cost Index
(Factor=966.9/852.0) .

-------
Table 6-17. Capital Costs for Thermal Incinerators at Model Product and Packaging

Rotogravure Plants - Control Option B.

Model Plant

1

2

3

4

5

Incinerator Intake

SCFM

37,845

62,925

248,140

67,960

47,182

VOC to Incinerator

lb/yr

121,500

195,000

788,000

212,500

147,750

HAP to Incinerator

lb/yr

121,500

39,000

591,000

85,000

64,025

Control Efficiency

O.
O

95

95

95

95

95

Heat Recovery

o.
o

70

70

70

70

70

Costs (1988$)

Incinerator, auxiliary equipment
instrumentation, sales tax and freight

360,020

408,828

576,107

416,769

380,431

Direct Installation Cost

108,006

122,648

172,832

125,031

114,129

Indirect Installation Cost

111,606

126,737

178,593

129,198

117,934

Site Preparation

36,002

40,883

57,611

41,677

38,043

Total Equipment Costs (1988$)

615,634

699,096

985,143

712,675

650,537

Total Equipment Costs (1993$)

698,659

793,374

1,117,998

808,786

738,268

Permanent Total Enclosure (1993$)

39,231

31,568

16,241

24,999

28,284

Cost including PTE (1993$)

737,890

824,942

1,134,239

833,785

766,552





Capital Recovery Factor

0.1098

0.1098

0.1098

0.1098

0.1098

Annualized capital cost

$81,020

$90,579

$124,539

$91,550

$84,167

Direct Installation includes foundation, supports, handling, erection, electrical, piping, insulation for
ductwork, and painting. Indirect installation cost includes engineering, construction and field expenses,
contractor fees, start-up, performance test, and contingencies. Permanent total enclosure costs based on
assumptions in following table. Costs based on OAQPS Control Cost Manual (EPA 450/3-90-006, January
1990).Costs escalated to 1993$ using Marshall and Swift Cost Index (Factor=966.9/852.0).

-------
Table 6-18. Total Enclosure Construction Costs for Product and Packaging Rotogravure -

Control Option B.

Model Plant

1

2

3

4

5



Wall Dimensions (ft )

240 x 30

150 x 30

100 x 30

150 x 30

120 x 30

Wall Dimensions (ft )

100 x 30

120 x 30

30 x 30

60 x 30

120 x 30

Total Area- Two Walls (SF)

10200

8100

3900

6300

7200

Large Door Dimensions (ft x ft)

6 x 10

6 x 10

6 x 10

6 x 10

6 x 10

Small Door Dimensions (ft x ft)

8x4

8x4

8x4

8x4

8x4

Wall Cost

$37,221

$29,558

$14,231

$22,989

$26,274

Large Door Cost

1850

1850

1850

1850

1850

Small Door Cost

160

160

160

160

160

Total Cost

$39,231

$31,568

$16,241

$24,999

$28,284



Assumptions: Two existing walls, two walls to be constructed, one large door and one
small door to be added. 8" concrete (sand aggregate) block, 3/8" mortar joint, tooled
one side. Large door-Aluminum door and frame including hardware and closer. Small
door-16 gauge steel, 5" deep.



Costs from Waier, Phillip R. et al., Means Building Construction Cost Data, 51st Annual
Edition, R. S. Means Company, 1992.

-------
Table 6-19. Total Annual Costs for Thermal Incinerators at Model Product and Packaging

Rotogravure Plants - Control Option A.

Model Plant

1

2

3

4

5



Electricity Required

kW

77 . 37

128.66

507.34

138.95

96.47

Natural Gas Required

SCFM

231

386

1516

417

289

Electricity Cost-Note 1

$/yr

19,365

32,202

126,980

34,778

24,145

Gas Cost-Note 2.

$/yr

173,217

290,146

1,138,602

312,811

217,107

Operating Labor-Note 3.

$/yr

3,886

3,886

3,886

3,886

3,886

Maintenance Labor-Note 4

$/yr

3,718

3,718

3,718

3,718

3,718

Maintenance Mat'l-Note 5

$/yr

3,718

3,718

3,718

3,718

3,718

Overhead-Note 6

$/yr

6,793

6,793

6,793

6,793

6,793

Other costs-Note 7

$/yr

23,500

26,686

37,604

27,204

24,832



Capital Recovery

$/yr

64,507

73,252

103,225

74,676

68,164



Total Annual Cost



298,704

440,401

1,424,526

467,584

352,363



Note 1. Fan power based on 4 inch pressure drop through incinerator and 15 inch pressure drop through
70% efficient heat exchanger. Fan/motor efficiency = 60%. Operation 4171 hours per year. Electricity
cost = 0.06/kWhr.

Note 2. Operation at 1400 degrees F, 4171 hours per year. Gas at $0.003/SCF.

Note 3. Operator labor 0.5 hr/shift at $12.96/hr. Supervisory labor = 15% of operating labor.

Note 4. Maintenance labor 0.5 hr/shift at $14.26/hr.

Note 5. Maintenance material assumed equal to maintenance labor.

Note 6. Overhead assumed 60% of labor plus maintenance materials.

Note 7. Administrative charges, property taxes and insurance assumed to be 4% of total capital cost.

-------
Table 6-20. Total Annual Costs for Thermal Incinerators at Model Product and Packaging

Rotogravure Plants - Control Option B.

Model Plant

1

2

3

4

5



Electricity Required

kW

154 .74

257.32

1014.68

277 . 9

192.94

Natural Gas Required

SCFM

462

772

3032

834

578

Electricity Cost-Note 1

$/yr

38,730

64,404

253,960

69,556

48,290

Gas Cost - Note 2.

$/yr

346,434

580,292

2,277,204

625,622

434,214

Operating Labor -Note 3.

$/yr

3,886

3,886

3,886

3,886

3,886

Maintenance Labor-Note 4

$/yr

3,718

3,718

3,718

3,718

3,718

Maintenance Mat'l-Note 5

$/yr

3,718

3,718

3,718

3,718

3,718

Overhead-Note 6

$/yr

6,793

6,793

6,793

6,793

6,793

Other costs- Note 7

$/yr

27,946

31,735

44,720

32,352

29,530



Capital Recovery

$/yr

81,020

90,579

124,539

91,550

84,167



Total Annual Cost



512,245

785,125

2,718,538

837,195

614,316



Note 1. Fan power based on 4 inch pressure drop through incinerator and 15 inch pressure drop
through 70% efficient heat exchanger. Fan/motor efficiency = 60%. Operation 4171 hours per
year. Electricity cost = 0.06/kWhr.

Note 2. Operation at 1400 degrees F, 4171 hours per year. Gas at $0.003/SCF.

Note 3. Operator labor 0.5 hr/shift at $12.96/hr. Supervisory labor = 15% of operating labor.

Note 4. Maintenance labor 0.5 hr/shift at $14.26/hr.

Note 5. Maintenance material assumed equal to maintenance labor.

Note 6. Overhead assumed 60% of labor plus maintenance materials.

Note 7. Administrative charges, property taxes and insurance assumed to be 4% of total capital
cost.

-------
Table 6-21. Cost Effectiveness of Control Options A and B for Incremental Control at

Model Product and Packaging Rotogravure Plants.

Model Plant

1

2

3

4

5



Control Option A



HAP Reduction (lb/yr)

57,713

18,525

280,725

40,375

30,412

Annual Cost

$298,704

$440,401

$1,424,526

$467,584

$352,363

Cost Effectiveness ($/Ton)

10,351

47,547

10,149

23,162

23,173



Control Option B



HAP Reduction (lb/yr)

115,426

37,050

561,450

80,750

60,824

Annual Cost

$512,245

$785,125

$2,718,538

$837,195

$614,316

Cost Effectiveness ($/Ton)

8,876

42,382

9, 684

20,735

20,200

-------
require operation of a control device to meet VOC emissions
standards established by other regulations.

6.4 WIDE-WEB AND SHEET FED FLEXOGRAPHY

Model plant specifications are given in Table 6-22. These
are based on several assumptions. HAP retention in the web is
assumed to be 1.5 percent of that used. This material is not
emitted in the pressroom or dryer. Pressroom ventilation rates
have been proposed based on the volume of air necessary to dilut
the fugitive emissions to 50 ppmv VOC. The concentration of HAP
in the pressroom varies depending on the composition of the
materials applied. Ventilation air to dilute fugitive emissions
may be presently supplied by doors, windows, and leaks to the
atmosphere and by exhaust fans discharging directly to the
atmosphere. Pressroom volumes have been assumed based on the
number and size of the presses in the model plants. The
pressroom and control systems are assumed to operate 80 hours pe
week.

Control options A and B apply to incremental capture and
control of uncontrolled emissions and fugitive emissions at the
model plants. Control options A and B involve collecting and
treating pressroom air containing uncontrolled HAP (model plants
1 and 2) or fugitive HAP which escapes the existing capture
system (model plant 3). Costs have been estimated on the basis
of thermal incineration of this pressroom air stream.
Specifications for thermal incinerators applicable to the model
plants are given in Table 6-23. In many cases, catalytic
incineration would be appropriate for the solvents in use.
Catalytic incineration systems would have lower operating costs
and might have lower total annualized costs than the estimates
for thermal incineration systems. In some cases, concentrator
systems (see Section 6.2) might be used to reduce the size and
capital and operating costs of the incinerator.

6-33

-------
The capital costs of these systems for control options A and
B are given in Tables 6-24 and 6-25. These costs are based on

6-34

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Table 6-22. Model Plant Specifications for Flexography.

Model Plant

1

2

3



Substrate

Multiwall Bags

Film Packaging

Paper/Film Pkg

Presses/Stations



12/4

6/6

6/6

Pressroom Dimensions

ft x ft x ft

150 x 90 x30

150 x 90 x30

150 x 90 x 30

Ink Use

lb/year

1,500,000

800,000

1,500,000

VOC Use

lb/year

25,000

550,000

1,100,000

HAP Use

lb/year

21,000

100,000

8,000

Capture Efficiency

O.
O

0

0

78

Control Device Efficiency

o.
o

0

0

94

Overall Efficiency

o.
o

0

0

73

HAP Controlled

lb/year

0

0

5840

HAP Retained

lb/year

315

1,500

120

HAP to Pressroom

lb/year

20,685

98,500

2,040

VOC Controlled

lb/year

0

0

803,000

VOC Retained

lb/year

375

8,250

16,500

VOC to Pressroom

lb/year

24,625

541,750

280,500

Pressroom VOC Concentration

ppm

50

50

50

Pressroom HAP Concentration

ppm

46.9

19

1



Assumed HAP is methanol (MW=32), Non-HAP VOC is ethyl acetate (MW=88.1). Assumed 1.5% of HAP and
VOC used is retained in the substrate and ultimately emitted outside the pressroom.

Assumed plant (and control system) operates 16 hr/day, 5 day/week.

-------
Table 6-23. Incinerator Specifications for Flexography Control

Options.

Thermal Incinerator--Control Option A



Model Plant

l

2

3



VOC Molecular Weight



35.5

66.8

87

Ventilation Rate

SCFM

19,899

232,654

92,492

Incinerator Intake

SCFM

9, 950

116,327

46,246

VOC to Incinerator

lb/yr

12,313

270,875

140,250

HAP to Incinerator

lb/yr

10,343

49,250

1, 020

Incremental HAP
Control

lb/yr

9, 825

46, 788

9 69

Incremental Control
Efficiency

a
o

46.8

46.8

12 . 1

New Overall Control

a
o

46.8

46.8

85.1



Thermal Incinerator--Control Option B



Model Plant

1

2

3



VOC Molecular Weight



35.5

66.8

87

Ventilation Rate

SCFM

19,899

232,654

92,492

Incinerator Intake

SCFM

19,899

232,654

92,492

VOC to Incinerator

lb/yr

24,625

541,750

280,500

HAP to Incinerator

lb/yr

20,685

98,500

2, 040

Incremental HAP
Control

lb/yr

19,651

93,575

1, 938

Incremental Control
Efficiency

a
o

93 . 6

93 . 6

24.2

New Overall Control

a
o

93 . 6

93 . 6

97 .2



Assume: HAP is methanol (MW=32), Non-HAP VOC is ethyl acetate
(MW=88.1) Pressroom ventilation incinerator efficiency = 95%.

6-36

-------
Table 6-24. Capital Costs for Thermal Incinerators at Model
Flexographic plants - Control Option A.

Model Plant

1

2

3



Incinerator Intake

SCFM

9, 950

116,327

46,246

VOC to Incinerator

lb/yr

12,313

270,875

140,250

HAP to Incinerator

lb/yr

10,343

49,250

1, 020

Control Efficiency

a
o

95

95

95

Heat Recovery

a
o

70

70

70

Costs (1988$)

Incinerator, auxiliary

equipment







instrumentation, sales

tax, and

257,811

476,716

378,535

freight









Direct Installation Cost

77,343

143,015

113,560

Indirect Installation Cost

79,921

147,782

117,346

Site Preparation

25,781

47,672

37,853

Total Costs (1988$)

440,856

815,185

647,294

Total Costs (1993$)

500,311

925,120

734,588



Capital Recovery Factor

0.1098

0.1098

0.1098

Annualized capital cost

$54,934

$101,578

$80,658



Direct Installation includes foundation, supports, handling,

erection, electrical, piping, insulation for ductwork,

and

painting. Indirect installation cost includes engineering,

construction and field

expenses, contractor

fees, start-up,

performance test, and contingencies. Costs

based on OAQPS

Control Cost Manual (EPA 450/3-90

-006, January 1990) .

Costs

escalated to 1993$ using Marshall

and Swift

Cost Index

(Factor=966.9/852.0).









6-37

-------
Table 6-25. Capital Costs for Thermal Incinerators at Model
Flexographic plants - Control Option B.

Model Plant

l

2

3



Incinerator Intake

SCFM

19,899

232,654

92,492

VOC to Incinerator

lb/yr

24,625

541,750

280,500

HAP to Incinerator

lb/yr

20,685

98,500

2, 040

Control Efficiency

a
o

95

95

95

Heat Recovery

a
o

70

70

70

Costs (1988$)

Incinerator, auxiliary
equipment, instrumentation,
sales tax and freight

306,588

566,916

450,156

Direct Installation Cost

91,976

170,075

135,047

Indirect Installation Cost

95,042

175,744

139,548

Site Preparation

30,659

56,692

45,016

Total Equipment Costs (1988$)

524,265

969,427

769,767

Total Equipment Costs (1993$)

594,967

1,100,162

873,577

Permanent Total Enclosure
(1993$)

28,284

28,284

28,284

Cost including PTE (1993$)

623,251

1,128,446

901,861



Capital Recovery Factor

0.1098

0.1098

0.1098

Annualized capital cost

$68,433

$123,903

$99,024



Direct Installation includes foundation, supports, handling,
erection, electrical, piping, insulation for ductwork, and
painting. Indirect installation cost includes engineering,
construction and field expenses, contractor fees, start-up,
performance test, and contingencies. Permanent total
enclosure costs based on assumptions in following table.
Costs based on OAQPS Control Cost Manual (EPA 450/3-90-006,
January 1990). Costs escalated to 1993$ using Marshall and
Swift Cost Index (Factor=966.9/852.0).

6-38

-------
the OAQPS Control Cost Manual2. The capital cost for control
option B includes retrofit construction of a permanent total
enclosure. The basis of this cost estimate is given in Table
6-26, and included in Table 6-25. Total enclosure costs are
based on the construction of two new walls and the presence of
two existing walls. Depending on the existing structure, total
enclosure costs could be higher or lower than those estimated.
Total annual costs have been estimated for control options A and
B in Tables 6-27 and 6-28. These estimates include recovery of
capital costs based on a 7 percent interest rate and a 15 year
equipment life. Operating costs include utilities, labor,
materials, tax, insurance and administration.

Cost effectiveness of the control options applied to the
model plants is given in Table 6-29. Cost effectiveness varies
between $30,000 and $60,000 per ton of HAP reduction for model
plants 1 and 2. For model plant 2, a large part of the cost may
be justified on the basis of non-HAP VOC control. Costs per ton
of HAP reduction at model plant 3 are extremely high because of
the dilute nature of the fugitive HAP. This type of plant would
be expected to meet the standard by reducing the HAP content of
its ink, or limiting its potential to emit in some other way.

Control option C involves the use of low HAP ink. The
adoption of this control option could, in some cases, represent a
net savings over baseline levels of control. The applicability
of this option depends to a large extent on the type of printing
and the performance requirements of the product or package. Some
facilities, printing on both porous and non-porous substrates
report either zero or very low HAP use as a proportion of total
materials applied on flexographic presses. Where feasible,
conversion to low HAP inks could result in substantial reductions
in operating costs. Cost reductions from conversion to low HAP
inks have not been calculated, because low HAP inks may still

6-39

-------
require operation of a control device to meet VOC emissions
standards established by other regulations.

6-40

-------
Table 6-26. Total Enclosure Construction Costs for Flexographic

Plants - Control Option B.

Wall Dimensions (ft)

150 x 30

Wall Dimensions (ft)

90 x 30

Total Area- Two Walls (SF)

7200

Large Door Dimensions (ft x ft)

6 x 10

Small Door Dimensions (ft x ft)

8x4

Wall Cost

26274

Large Door Cost

1850

Small Door Cost

160

Total Cost

$28,284



Assumptions: Two existing walls, two walls to be
constructed, one large door and one small door to be
added. 8" concrete (sand aggregate) block, 3/8" mortar
joint, tooled one side. Large door-Aluminum door and
frame including hardware and closer. Small door-16
gauge steel, 5" deep.

Costs from Waier, Phillip R. et al., Means Building
Construction Cost Data, 51st Annual Edition, R. S. Means
Company, 1992.

6-41

-------
Table 6-27. Total Annual Costs for Thermal Incinerators at Model
Flexographic Plants - Control Option A.

Model Plant

1

2

3



Electricity Required

kW

40 . 7

475.7

189.1

Natural Gas Required

SCFM

123

1436

569

Electricity Cost-Note 1

$/yr

10,185

119,069

47,334

Gas Cost - Note 2

$/yr

92,660

1,078,176

427,316

Operating Labor-Note 3.

$/yr

3, 886

3, 886

3, 886

Maintenance Labor-Note 4

$/yr

3,718

3,718

3,718

Maintenance Mat'l-Note 5

$/yr

3,718

3,718

3,718

Overhead-Note 6

$/yr

6, 793

6, 793

6, 793

Other costs-Note 7

$/yr

20,012

37,005

29,384



Capital Recovery

$/yr

54,934

101,578

80,658



Total Annual Cost

195,906

1,353,943

602,807



Note 1. Fan power based on 4 inch pressure drop through
incinerator and 15 inch pressure drop through 70%
efficient heat exchanger. Fan/motor efficiency = 60%.
Operation 4171 hours per year. Electricity cost =
0 . 0 6/kWhr.

Note 2. Operation at 1400
Gas at $0.003/SCF.

degrees F, 4171 hours per year.

Note 3. Operator labor 0.5
Supervisory labor = 15% of

hr/shift at $12.96/hr.
operating labor.



Note 4. Maintenance labor

0.5 hr/shift at $14.26/hr



Note 5. Maintenance material assumed equal to maintenance
labor.

Note 6. Overhead assumed 60% of
materials.

labor plus maintenance

Note 7. Administrative charges, property taxes and
insurance assumed to be 4% of total capital cost.



6-42

-------
6-43

-------
Table 6-28. Total Annual Costs for Thermal Incinerators at Model
Flexographic Plants - Control Option B.

Model Plant

1

2

3



Electricity Required

kW

81. 4

951 . 5

378 .2

Natural Gas Required

SCFM

247

2872

1138

Electricity Cost-Note 1

$/yr

20,369

238,138

94,669

Gas Cost-Note 2.

$/yr

185,311

2,156,352

854,631

Operating Labor-Note 3.

$/yr

3, 886

3, 886

3, 886

Maintenance Labor-Note 4

$/yr

3,718

3,718

3,718

Maintenance Mat'l-Note 5

$/yr

3,718

3,718

3,718

Overhead-Note 6

$/yr

6, 793

6, 793

6, 793

Other costs-Note 7

$/yr

24,930

45,138

36,074



Capital Recovery

$/yr

68,433

123,903

99,024



Total Annual Cost

317,158

2,581,646

1,102,513

Note 1. Fan power based on 4 inch pressure drop through
incinerator and 15 inch pressure drop through 70% efficient
heat exchanger. Fan/motor efficiency = 60%. Operation 4171
hours per year. Electricity cost = 0.06/kWhr.

Note 2. Operation at 1400 degrees F, 4171 hours per year.
Gas at $0.003/SCF.

Note 3. Operator labor 0.5 hr/shift at $12.96/hr.

Supervisory labor = 15% of operating labor.

Note 4. Maintenance labor 0.5 hr/shift at $14.26/hr.

Note 5. Maintenance material assumed equal to maintenance
labor.

Note 6. Overhead assumed 60% of labor plus maintenance
materials.

Note 7. Administrative charges, property taxes and insurance
assumed to be 4% of total capital cost.	

6-44

-------
Table 6-29. Cost Effectiveness of Control Options A and B for
Control of Model Flexographic Printing Plants.

Model Plant

1

2

3



Control Option A



HAP Reduction (lb/yr)

9, 825

46, 788

9 69

Annual Cost

$195,906

$1,353,943

$602,807

Cost Effectiveness ($/Ton)

39,879

57,876

1,244,184



Control Option B



HAP Reduction (lb/yr)

19,651

93,575

1, 938

Annual Cost

$317,158

$2,581,646

$1,102,513

Cost Effectiveness ($/Ton)

32,279

55,178

1,137,784

6.5 REFERENCES

1.	U. S. Environmental Protection Agency. OAQPS Control Cost
Manual, Fourth Edition. EPA-450/3-90-006, January, 1990.
p. 3-42 to 3-58.

2.	U. S. Environmental Protection Agency. OAQPS Control Cost
Manual, Fourth Edition. EPA-450/3-90-006, January, 1990.
p. 3-42 to 3-58.

6-45

-------