EPA 453/R-06-003 Septem ber 2006



# Control Techniques Guidelines for Flexible Package PrintingThis page intentionally left blank.

iiEPA 453/R-06-003 Septem ber 2006



# Control Techniques Guidelines for Flexible Package Printing

Sector Policies and Programs Division Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency Research Triangle Park, North Carolina

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ivTABLE OF CONTENTS

I. Introduction.................................................................................. Page 1

II. Background and Overview

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III. Applicability

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IV. Process Description and Sour ces of VOC Emissions

.................. Page 5 A. Def i nitio n of Flexible Packaging B. Printing Processes and Em ission s Rotogravure Printing Flexographic Printing C. Definition of Press D. Definition of Cleaning fo r Flexib le Packaging P r inting

V. Available Control Options

........................................................... Page 8 A. Inks, Coatings and Adhesives Add-On Controls – Capture Systems Add-On Controls – Control Devices Low- and No-VOC Inks, Coatings, and Adhesives B. Cleaning M a terials C. Summ ary of State and L o cal Regulations

VI. Recommended Control Options

.................................................. Page 13 A. Coatings, Inks, and Adhesives B. Cleaning M a terials

VII. Cost Effectiveness of Recommended Control Options

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VIII. References

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Appendix A 1978 CTG for Graphic Arts

......................................................... Page 17 2005 TSD for Title V Perm itting of Printing F a cilities

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Appendix B Estim ated Costs Associated with th e Recommendations Contained in the Control Techniques Guideline for Flexible Package Printing

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viI. Introduction

Clean Air Act (CAA) section 172(c)(1) pr ovides that state implementation plans (SIPs) for nonattainment areas must include “reasonably available control measures” (RACM), including “reasonably available c ontrol technology ” (RAC T), for sources of emissions. Section 182(b)(2)(A) provides that for certain nonattainment areas, States must revise their SIPs to include RACT for s ources of VOC emissions covered by a control techniques guidelines (CTG) document issu ed after November 15, 1990 and prior to the area’s date of attainment.

The United States Environmental Protecti on Agency (EPA) defines RACT as “the lowest emission limitation that a particular source is capable of meeting by the application of control technology that is r easonably available considerin g technological and economic feasibility.” 44 FR 53761 (Sept. 17, 1979). In subsequent Federal Register notices, EPA has addressed how states can meet the RACT requirements of the Act.

CAA section 183(e) directs EPA to list fo r regulation those categories of products that account for at least 80 percent of the VOC emissions, on a reactivity-adjusted basis, from consumer and commercial products in ar eas that violate the NAAQS for ozone (i.e., ozone nonattainment areas). EPA issued the list on March 23, 1995, and has revised the list periodically. See 60 FR 15264 (March 23, 1995); see also 71 FR 28320 (May 16, 2006), 70 FR 69759 (Nov. 17, 2005); 64 FR 13422 (Mar. 18, 1999). Flexible package printing materials is included on the cu rrent section 183(e) list.

The CTG is intended to provide state a nd local air pollution control authorities information that should assist them in dete rmining RACT for volatile organic compounds (VOC) from flexible package printing facilities. In developing this CTG, EPA, among other things, evaluated the sources of VOC emissions from this indu stry and the available control approaches for addressing these emissions, incl uding the costs of such approaches. Based on available information and data, EPA provide s recommendations for RACT for VOC from flexible package printing facilities.

States can use the recommendations in th is CTG for VOC from this source category to inform their own determination as to what constitutes RACT in their particular nonattainment areas. The information contai ned in this document is provided only as guidance. This guidance does not change, or substitute for, applicable sections of the CAA or EPA’s regulations; nor is it a regulati on itself. This document does not impose any legally binding requirements on any entity. It provides only recommendations for state and local air pollution control agencies to cons ider in determining RACT. State and local pollution control agencies are free to implem ent other technically-sound approaches that are consistent with the CAA and EPA’s implementing regulations.The recommendations contained in this CTG are based on data and information

curren tly av ailab l e to EP A. These general recom m e ndations m a y not apply to a particular situation based upon the circum stances of a partic ular source. Regardless of whether a State chooses to implem e nt the recomm endations contained herein thr ough State rules, or to issue State rules that adopt differe nt approaches for im plem enta tion of RACT for VOCs from f l exible pa c k age prin tin g, States m u st subm it the i r RACT rules to EPA f o r review and approval as part of the S I P process. EPA will evaluate the ru les and determ ine, through notice and comm ent rulem a king in the SIP proces s, whether they m eet the RACT requirem e nts of the Act and EPA’s regulations. To the exten t a State ado p ts any of th e

recomm endations in th is guidance in to its S t at e RACT rules, inte rest ed p a rties can raise questions and objections about th e substance of this guidance and the appropriateness of the application of this guidance to a particular situation during the developm ent of the State rules and EP A’s SIP approval process.

CAA section 182(b)(2) provides that a CTG issued after Novem b er 15, 1990 and before the date of attainm e nt m u st include the date by which States m u st subm it SIP revisions in response to the CTG. St ates su bject to section 182(b) should subm it their SIP revisions within one year of the date of i ssuance of the final CTG for flexible packag e printing. States subject to CAA section 172( c)(1) m a y take action in response to this guidance, as necessary to attain.

II. Background and Overview

In Decem be r 1978, EPA published a CTG for graphic arts (rotogravure p r inting and flexographic printing) that included flexib le package printing. 1 The 1978 CTG discusses the flexible package printing industry, the natu re of VOC e m issions from that industry, available co ntrol techno logies for addressing such em issions, th e cos t s of available co ntrol options, and other item s . The 1978 CTG is incl uded as an Appendix to this CTG. The proposed recommended approaches for RACT in this docum ent build upon those identified in the 1978 CTG for graphic arts.

EPA also published a national em ission standard for hazardou s air po llu tants (NESHAP) for the printing and publishing indus try (40 CFR Part 60, Subpart KK) in May 1996, which is applicable to flexible package printing. 2 The background inform ation docum ent used to support the 1996 N E SHAP incl uded an analysis of the industry based on

surveys com p leted by f l e x ible pa ckag e prin ters. 3

EPA developed the recommended approach es contained in this docum ent after conducting a com p rehensive review of curre nt existing state and local VOC e m ission reduction approaches for flexible package printing, reviewing the 1978 CTG and the 1996 NESHAP ba ckground infor m ation docum ent, a nd considering inform ation obtained since

prom ulgation of the NESHAP. Si m ilar to the 1978 CTG, this docum ent contains

recomm endations for reducing VOC em issions based on the use of add on controls. T h e

recomm endations in th is CTG reflect, however , the technological im provem e nts that have

2occurred with regard to such controls sin ce 1978. This CTG also contains recomm endat i ons for establishing work practice standards for cleaning.

The rem a inder of this docum e nt is divided in to six (6) sec tion s

. Section III describes the scope of sources to which this CTG app lies. S ection IV provides a summary of the

processes as sociated with the flexib le pack age p r inting and id entif ie s the sources of VOC

em issions from those processes. Section V de scribes the availab l e c ontrol approaches for addressing VOC e m issions from this sour ce category and su mmarizes state and local regulatory approaches f o r addressing such em issions. Section VI provides our proposed

recomm endations for R A CT for VOC e m issions from flexible package printing. Section VII discus ses the cos t -ef f

ectivenes s of the r ecomm ended control approaches. References

are prov ided in Section VIII.

III. Applicability

This CTG provides control recomm e ndati ons for reducing V O C e m issions from inks, coatings, adhesives and cl eaning m a terials used in flexib le packaging printing. This section discusses our recommenda tions for applicability of th ese control recomm endat i ons. State and lo cal agen cies have the d i s c retion to co nsider o t her applic ability criter ia f o r their regulations.

We recommend applying the control r ecomm endations for flexible packaging printing cleaning m a terials to flexible packag ing printing operations that em it at least 6.8 kg/day (15 lb/day) actual em issi ons of VOC before considera tion of controls. State and local agencies have dis c retion to con s ider th e 15 lb VOC per day applicability level, an equivalent applicability level expressed on a m o nthly basis (e.g., 450 lb/month), an equivalent applicability level expressed on a 12-month rolling basis (e.g., 3 tons per 12- month rolling period), or ot her app lic ability levels for their regulations.

The recommendations for controlling VOC e m iss i ons from flexible packaging printing cleaning m a terials are work practice recomm endations. Since work practices are carried out o n a facility-wide basis, we belie ve it is par ticu l ar ly appropr ia te f o r the applic ability of work practic es to be determ in ed on a facility-wide basis. For purposes of determ ining whether th e 15 lb/day a c t ual em issio n s applicability threshold or an equivalent threshold is m e t at a given facility, we reco mmend that a flexible packaging printer should consider emissions from all flex ible packagi ng printing and related cleaning activities at the facility prior to controls.

The 15 lb VOC per day level is consistent with the applicab ility threshold contained in m a ny previous CTGs. It is also consis tent with the purpose of the section 183(e)

program . In section 183(e), Congress direct ed E P A to assist St ates in achieving VOC

em ission reductions from consum er and commerc ial products. These products individually

m a y result in relatively sm all a m ounts of VOC em issions, but, in the aggregate, they contribute significantly to ozone form ation in nonattainm e nt areas. Give n the nature of the products and sources at issue here, we believe that the 15 lb VOC per day applicability threshold or equivalent is appropr iate f o r f l exible packaging p r inti ng cleaning m a terials.

3We recommend applying the control r ecomm endations for inks, coatings and adhesives only to those presses wi th potential to em it f r om the dr yer, prior to controls, of at least 25 tpy of VOC (petroleum ink oil) from inks, coatings and adhesives com b ined. We

recomm end providing p r inters with the opti on of using an enforceab le limitation on potential em issions to keep an individual press below this 25 tpy potential to em it threshold. Guidance on lim iting potentia l to em it f r om printi ng operations is provid ed in the Tech nical Support Docum e nt (TSD) for Title V Perm itting o f Printing Facilities (s ee Appendix A). 4 We recommend this higher threshold for the con t rol recommendation s co ncerning ink s , coating s , an d adhesives because no t all flex ib le p ackaging p r esses can u s e low VOC content inks, coatings, and adhesives. W e believe that control of a press th at is above the 25 tpy threshold will generally be cost effective. Add- on controls for presses with potential to emit below 25 tp y will gene r a lly be too c o stly f o r th e em ission red u ction that would be ac hieved

.

For those facilities where actual em issi ons from flexible packaging printing operations are greater than 15 lb/day before c onsideration of controls and where pote n tia l to

em it is less than 25 tpy of VOC on a per pr ess basis before controls, we recommend applying only the recomm ended work practices f o r cleaning.

The Flexible Packaging Association ( FPA) estim ated that in 2005, there were 1,071 f l exible pa c k aging f acilities. 5 FPA did not identify which of these facilities conduct flexible package printing operations (to which this CTG is applicable), but EPA concluded that the

num b er of fl exible package printing faciliti es is less than 1,071. To estim ate the total

num b er of fl exible package printing faciliti es and subsequently estim ate the num ber of facilities in current nonattainm e nt areas that would m eet the a pplicability threshold in this CTG, EPA reviewed data obtained during deve lopm ent of the 1996 NESHAP and data from the 2002 NEI. 6

The 1996 NESHAP bac kground inform ation docum ent reported that the Gravure Association of Am erica estim ated that in 1994 there were an es tim ated 400 locations within the U.S. that conducted rotogravure printing operations, but m a de no distinction betw een rotogravu r e package/p r o duct pr intin g (to which this CTG is applicable) and rotogravure publication printing locations (to which this CT G is not applicable). As part of the NESHAP project, EPA identified 108 locat ions thought to oper ate package/product rotogravure printing equipm ent. The 108 pack age/product rotogravure facilities include both area and m a jor sources of HAP. EPA also identified 520 fac ilities conducting wide web flexographic printing operations (to which this CTG is applicab le) as part of the NESHAP project. The 520 wide-web flexograp hic facilities include both area and m a jor sources of HAP. Of these 520 facilities c onducting wide-web flexography, EPA estim a t es that approxim a tely 221 facilities are potenti al flexible packaging printers. Thus, the NESHAP da ta indicate that there are approxim a tely 329 potential flexible package printers.

An addition a l search of the 2002 NEI (April 11, 2006 versio n) datab a se for SIC codes 2671, 2673, 2674, and 3497, identified 146 uni que facilities (i.e., not already identified as part of the NESHAP project). This num b er m a y be ar tificially high because

m a ny of the f acilities co uld not be d e f i nitiv ely c onf irm e d as f l exible pa c k age prin ter s ;

4however, th ese facilities were not o m itted from the facility list. A search of the 2002 NEI (April 11, 2006 version) database for NAICS codes 322221, 326112, 322223, 326111, 322224, 322225, and 332999 was conducted to identify additional flexible package printing f

acilities. T h e num ber of unique f acilities (i.e., n o t already id entif ied a s p a rt of the NESHAP project or as part of the 2002 NEI SI C search discussed above) identified that 107 facilities co uld be flexib le packag e p r inters. This num b er m a y be artificially high because

m a ny of the f acilities co uld not be d e f i nitiv ely c onf irm e d as f l exible pa c k age prin ter s ; however, th ese f acilities were not o m itted f r om the f acility list. In to ta l, the NEI sear ch resulted in 253 potential fl exible packaging printers.

The NESHAP and the NEI search com b ined identified a total of 582 facilities that could be flexible package prin ters. Of the 582 facilities id entified as pote ntial flexible package printers, a total of 219 facilities are located in ozon e nonattainment areas (b ased on April 2004 designations). Based on VOC e m i ssions data, we estim ate that there are approxim a tely 100 facilities in ozone nonattainm e nt areas that have em issions of greater than 15 pounds per day (lb/day).

IV. Process Des cription and Sources of VOC Emissions

A. Def i nition o f Flexible Pa ckaging

Flexible packaging refers to any package or part of a package the shape of which can be readily changed. Flexible packaging includes, but is not lim ited to, bags, pouches, liners, and wraps utilizing paper, plastic, film, alum inum foil, m e talized or coated paper or film , or any com b ination of thes e m a terials. 7 Flexible package m a nufacturers are som e ti m e s referred to as "converters." The word "converted " in this use is an industry-specific term that refers to the fact th at flexible packaging m a teria l s start ou t as ro lls of paper or foil, or beads of plastic resin, and are "conv erted" into a package or roll of packaging m a terial.

Printing on flexible packaging is almost entirely conducted by rotogravure and wideweb flexographic printing. The ratio of rot ogravure printing to fl exographic printing am ong converters is approxim a tely 1:4. Flexible packaging printers ar e likely to be included under SIC codes 2671, 2673, 2674, and 3497. Typical NAICS codes for this industry include 322221, 326112, 322223, 326111, 322224, 322225, and 332999. Flexible package printers could also be classified under other SIC and NAICS code s as well depending on other processes conducted at the facility.

Printing, coating, and lam i nating m a y all be perform e d on or in-line with a flexible package printing press and these activities ar e included in the source category. One portion of the flexible packaging industry provides fully printed packaging m a terials (designated "preform ed specialty bags") to contract packagers. Another portion provides com b ination or lam i nated materials (designated converted wrap ) for printing and/or fi nal packing by captive packaging operations. Applyi ng coatings is a m a jor capabi lity of flexible packaging converters, so the sam e facilities m a y be us ed to m a nufacture non-packaging m a terials such as gift wraps and hot stamp foils. The i ndustry m a kes a distinction betw een labels and

wrappers, w h ich are package com p onents, from a product that becom e s the entire package

5and should be called a flexible package. Any printing of shrink-wrap labels or wrappers conducted on or in-line with a flexible packag e printing press is also considered to be included under the flexible packaging source ca tegory. Printing of self-adhesive labels would not be considered flexible packaging.

Rigid packaging printing operations are often tim es co-located with flexible packag e printing operations. Folding cartons, som e labels and wrappers, gift wraps, wall coverings, vinyl products, decorative la m i nates, floor coverings, tissu e products, and m i scellaneous specialty products are not considered flexible packaging.

B. Printing P r ocesses and E m issions

There are tw o types of printing processes used by f l exible pa c k age prin tin g f a cilities : (1) rotogravure printing; a nd (2) flexographic printing.

Rotogravure Printing

Rotogravure printing is a prin ting process in which an im age (type and art) is etched

or engrav ed below the su rface of a plate or cylind e r. On a ro togravure cylinder, the printing im age consists of m illions of m i nute cells. Roto gravure requ ires ve ry f l uid inks which will f l ow f r om the cells to the subs trate at high press speeds. In addition to inks, coatings and adhesives m a y be applied with rotogravure cy linders. These m a terials dry by evaporation as the substrate passes through hot air dryers. Solv ent-borne or waterborne ink system s can be used but these ink system s are not interchange able. Both the printing cylinders and the drying system s are specific to the solvent system in use. The evaporated com ponents of the ink and othe r m a terials c ontain VOC to vary ing e x tents. Add ition a l VOC m a y be pres ent in solvents used to clean presses and press com ponents. Rotogravure can be divided into the publication, product, and packaging segm ents. For this source category, we are interested in the flexible packaging, which is a part of th e packaging segm ent. Beca use of the expense and com p lexity of rotogravure cylinder engrav ing, it is particularly suited to long run printing jobs.

Rotogravure package printing us es a wide variety of differe nt ink system s, including VOC based ink system s and waterborne ink syst em s. Num e r ous specially m i xed colors are applied at various tim e s in this industry segm en t. In addition, a wide range of m a terials are applied with rotogravure cylinders in this segm en t of the industry. A variety of coatings and adhesives are applied on or in-line w ith ro t ograv ure pres ses. Because of the variety of

m a terials ap plied, the ap proach to V O C control in packaging rotogravu r e facilities v a ries. Packaging gravure facilities use a variety of therm a l and catalytic oxidizers and activated carbon based solvent recovery syst em s. Use of waterborne inks for rotogravure printing is increasing. 8

Printing is only one stage (often m i nor) in the manufacturing and is, in m a ny cases, a rela tive l y s m all part of the to tal pa c k aging pr oduction process. In m a ny cases, operations such as lam i nating, cutting, and folding m a ke up a greater proportion of the value of the package than the printing operation.

6Due to the wide variety of ink types and colo rs that are used in this segment of the printing industry, ink is typica lly rec e ived in d r u m s (or sm aller containe r sizes ) and to te bins. Only rarely is bulk ink received and stored in tanks.

Flexographic Printing

In flexographic printing, the im age is raised above the pr inting plate, and the im age carrier is m a de of rubber or other elastom e ric m a terials. The m a jor applications of flexographic printing are flexib le and rigid packaging; tags and labels; newspapers,

m a gazines, and directories; and paper towels, tiss u es, etc. Because of the ease of plate

m a king and press set up, flexogra phic printing is more suited to short production runs than rotogravu r e.

Flexographic inks m u st be very fluid to print properly. Flexographic inks include both waterborne and solvent based system s. So lvents used must be compatib le with the rubber or polym e ric plates; thus, arom atic solven ts are not used. Som e of the com ponents of solvent based flexographic ink in clude ethyl, n-propyl and iso-pr opyl alcohols; glycol ethers, aliphatic hy drocarbons, acetates and esters. A va riety of coatings and adh e sives are ap plied on or in-line with flexographic presses incl uding solvent-borne, waterborne, wax coatings, wax lam i nations, extrusion coatings, extrusi on lam i nations, 100 percent solid adhesives, ultra-vio l et cured coatin gs, el ectron beam cured coatings, hot m e lt coatin gs, and cold seal coating s

.
Flexographic printing can be divided be tween publication, packaging, and product printing. For this source category, only the flex ible packaging segm ent is considered. W i de web flexographic presses (defined to include pr esses of 18 inches or greater in width) are used to print flexible and rigid packaging.

Flexographic presses can be divided into three m a in types depending on the relative rela tionsh i p of the print s t ati ons. Stack presses have indivi dual print stations oriented vertically with the unwind and rewind sections on the sam e side of the print stations. Stack presses are easily acces sible for rap i d changeovers between press runs.

Stack pres ses are a v i ntage design th at is no t eas ily enclo s ed for VOC em i ssions capture. Common i m pr ession presses (also called central impression p r e sses) have the print stations around the circumference of a singl e large im pression cylinder. T h e web is constantly supported between print stations , which is an advantage for printing on

stre tchab l e m a terials. More re cent models of central im pression presses include capture system s within the press design. In-line presse s have the print stati ons in a horizontal row (the geom etry is sim ilar to rotogravure pre sses). These presses have an advantage when used with ad dition a l con v erting (such as cutting, gluing, and lam i nating) equipm ent.

7C. Definition of Press

Rotogravure press m eans an unwind or feed section, which may include more than one unwind or feed station (such as on a lam i nato r), a series of indivi dual work stations, one

or m o re of which is a rotogravure print station, any dryers associated wi th the work stations, and a rewind, stack, or collection section. I nboard and outboard work stations, including those em ploying any other technology, such as flexography, are included if they are capable of printing or coating on the sam e substrate.

Flexographic press m eans an unwind or feed section, which m a y include m o re than one unwind or feed station (such as on a lam i nato r), a series of indivi dual work stations, one

or m o re of which is a flexographic print stati on, any dryers (including interstage dryers and overhead tunnel dryers) associated w ith the work stations, an d a rewind, stack, or collection section. The work stations m a y be orie nted vertically, horizontally, or around the circum ference of a single large im pression cylin der. Inboard and outboard work stations, including those em ploying any other technology, su ch as rotogravure, are included if they

are cap able of printing o r co ating on the sam e substrate.

D. Definition of Cleaning for Flexib le Packaging P r inting

Cleaning for flexible package prin tin g can be characterized as clean ing of a press, press parts, or rem oving dried ink from areas around a press. In general, it would not include cleaning electronic com ponents of a press, cleaning in pre-press (e.g., platemaking) or post-press (e.g., binding) opera tions, or use of janitorial su pplies (e.g., detergents or floor cleaners) to clean areas around a press. Cleaning would also not include parts washers or cold cleaners.

V. Available Controls and State and Local Regulatory Approaches

There are tw o m a in sources of VOC em issions from flexible package printing for both rotogravure and flexographic: (1) ev aporation of VOC from inks, coatings, and adhesives, and (2) evaporation of VOC from cleaning m a terials.

There are tw o approaches to reducing VOC e m is sions from i nks, coatings, and adhesives used in the flexible package pr inting industry: (1) adding/im pr oving add-on controls, and (2) m a terial reform ulation or substitution. The first approach includes im proving capture and/or control system s or a dding control system s where none are in use. Capture and control can be a ddressed separately, although in m a ny cases, im proved capture is ach ieved through an in crease in th e am ount of a i r hand led and can necessitate upgrades to existing control devices. The second appr oach, f o cusing on pollution prevention, is to substitute lo w VOC or VOC-f ree mater i als f o r m a terials (inks, coatings, and adhesives) presently in use.

8A. Inks, coatings, and adhesives

Add-On Controls - Capture Systems

Capture sys t em s are designed to collect so lv ent laden air and direct it to a control device. In rotogravure and fl exographic printing processes, mo st of the solvent is rem oved from the printed substrate by evaporation in a dryer. The exhaust from the dryer can be ducted to a control d e vice. Addition a l syst em s such as floor sweeps and hoods are often used to co llect solv ents that evapo r ate from ot her parts of the printing press, in addition to those co llec t ed f r om the dryer. Pre s s r oom ventila tion a i r can also be exh a usted to a co ntrol device. Som e presses are contained and ope ra te d within pe r m anent total enclosur es. Solvent laden air from several presses m a y be combined and ducted to a comm on control device.

Differences in captu re ef ficiency of th e exhaust contribute much m o re to the variation in overall efficiencies than the choice o f control dev i ce . Test procedures have been estab lished f o r dete rm ining captur e e f f i ciency and for confirm i ng the presence of perm anent total enclo s u r es (PTE). Capture efficiency can b e determ ined accord ing to the EPA protocols for testing with tem porary total encl osures that are specifi ed in Methods 204 and 204A through F of 40 CFR Part 51 Appendix M. In order to assum e a capture efficiency of 100 percent, you m u st confirm th at your capture system is a PTE by de monstrating that it

m eets the requirem e nts of Section 6 of Met hod 204 of 40 CFR Part 51 Appendix M and that all exh a ust g a ses from the enclosu r e are deliver ed to a control device. More inform ation on determ ining capture efficiency for rotogravur e and flexographic printi ng presses, including alternative capture efficiency tes t pro cedures that do not use tem porary total enclosure, is presented in the Printing and Publishing NESHAP (40 CFR Part 63 Subpart KK).

Capture system s can be improved through co llection of additiona l solvent laden air from the press area and through cons truction of addition a l ho oding and press enclo s ures. In theory, capture can be improved to (nearly) 100 percent for any press or pressroom by retrofitting walls and increasing ven tilation to meet th e requ irem ents of perm anent total enclosures. Many new presses ha ve been ins t alle d within pe r m anent total enclosures. Som e existing facilities have modified their pressroom s to serve as p e rm anent total enclosures. There m a y be space con s traints, su ch as clos e p r o x im ity to other m achines, that lim it the ability of so m e presses to be enclos ed. En closin g som e presses m a y lim i t access to the unit and m a y cause increased tem p eratures within the enclosure, which could be an exposure concern for workers.

The RACT r ecomm endat i ons in the 1978 CTG considered capture and control of VOC e m issions from fle xographic and rotogravur e presses. Packaging rotogravure presses were estim a ted to have a capture efficiency of 75 percent. A lower capture efficiency of 70 percent was estim ated for flexographic presse s due to the m a nner of construction of the stacked p r es ses and cen tral im pression presses in use at that tim e.

There have been significant im provem e nt s in capture efficiency of flexographic presses and rotogravure presses since 1978. These im provem e nts can be attributed to

9replacem ent of aging presses w ith newer presses, enclosed do ctor blades, and im provem e nts in dryer technology. In addition, m o re recent m odels of central im pression presses used for flexographic printing and in-line presses used for flexographic prin ting or rotogravure printing now incorporate capture system s w ithin the press design. Since around 1990, m a ny vendors have guaranteed capture efficiency of 85 to 90 percent without use of a permanent

tota l enclo s u r e.

Many package rotogravure printing and wide -web flexographic printing f acilities use low VOC and low HAP i nks and coatings. Dryer exhausts from these facilities, presses, or individual w o rk stations m a y be vented to the atmosphere without the use of a control device.

Add-On Controls - Control Devices

The control devices in use in flexible packaging rotogravure and flexographic printing processes include carbon adsorbers, ther m a l oxidizers, and catalytic oxidizers. In contrast to oxidation techniques, carbon adso rption does not destroy th e VOC in the treated air but recovers it for reuse. The selection of a control device is influenced by the type of inks, coatings, and adhesives applied on the pr ess, the volum e of solv ent laden air to be treated, and the operating schedul e of the facility. The RA CT recomm endations in the 1978 CTG considered carbon adsorbers and oxidizers with 90 percent c ontrol device efficiency. Today, these control devices can achieve at l east 95 percent control device efficiency.

Low- and No-VOC Inks, Coatings, and Adhesives

Pollution prevention has been achieve d by m a ny facilities in the packaging rotogravure and flexographic prin ting industries. Ma ny facilities use waterborne inks, and these inks typically contain a sm all proportion of alcohols or glycol et hers which function to reduce su rface tens ion and im prove flow character is tics. Their use m a y require red e sign of the system (changes in ink for m ulation, cy linder engraving, press operation, and dryer design) for rotogravure flexible pack age prin ting. W h ile use of waterborne inks reduces or elim inates V O C em issions, their hig h er surface te nsion and s l ower dryin g rate contin ue to be obstacles to their expanded use. Flexible packaging printers us e a wide variety of coatings and adhesives includi ng solvent-borne, waterborne, wa x coatings, wax lam i nations, extrusion coatings, extrusion lam i nations, 100 pe rcent solid adhesives, ultra-violet cured coatings, electron beam cured coatings, hot m e lt coatings, and cold seal coatings.

Packaging rotogravure facilities and fle xographic facilities produce a wide variety of products, and flexible packaging producers, in particular, print on m a ny different substrates within th e sam e facility. Many facilities use hund reds of diffe rent inks to print v a riou s custom colors requ ired b y their pack agi ng custom ers. Low VOC inks, coatings, and adhesives m a y not be available to m eet all of the perform a nc e requirem e nts. Low VOC inks

m a y not be available for all of the substrates and in all of the co lors required by som e f

acilities.

10B. Cleaning M a terials

The recommended approach to reduce VOC e m is sions from c l eaning m a terials used in flexible package printing includes use of work practices. Work practices such as keeping solvent containers clos ed except wh en f illing, d r aining o r co nducting cleaning operations, keeping used shop towels in closed containe rs, and conveying cleaning m a terials from one location to another in closed contai ners or pipes reduce VOC em issions. The work practice

recomm endations f o r c l eaning app l y to f l exible packaging p r inting f acilities em itting 15 lb/day or m o re before consideration of contro ls from all covered flexible packaging printing and clean ing activ ities at the facility. . EP A recommends that when States develop R A CT rules in response to the I ndustrial Cleaning Solvents CTG, see EPA 453/R-06-001 (S ept. 2006), they consider excluding fr om those rules the cleaning ac tivities covered by this CTG (See 71 FR 44540).

C. Summ ary of State and L o cal Regulations

Many States and local ag encies h a ve a dopted reg u lations for contro lling em issions from flexible package printing. At least 34 St ates and several more local agencies have regulations that control VOC e m issions from rotogravure and flexographic printing f o r flexible packaging. The m a jority of these agen cies have adopted control levels consistent with the 1978 RACT levels of 65 percent ove rall control for rotogravure and 60 percent overall control for flexography, or use of waterb orne or other low VOC inks with less than or equal to 25 percent by volum e VOC in th eir vo latile f r ac tio n, m o re than 60 percent volum e solids less water and less exempt com pounds , or less than 0.5 kg VOC per kg solids. The 65 percent overall control efficiency for rotogravure was based on a 90 percent control device efficiency and approxim a tely 72 percen t capture efficiency; th e 60 percent overall control efficiency for flexography was based on a 90 percent control device efficiency and approxim a tely 66 percent capture efficiency.

The requirem e nts for se veral S t ate and local agencies that have adopted regulations more stringent than the current RACT requi rem e nts are summ arized below in Table 1. Local agencies in California with regulations m o re stringent than RACT have requirem ents ranging from 66 to 85 percent overall con t rol efficien cy.

A few local air pollution control agenci es have also adopted requirem e nts for clean ing m a terials. A cleaning m a terials summ ary is provided in Table 2. There is a wide range of VOC lim its for cleaning m a terials, from 0.42 lb VOC/gal m a terial to 6.8 lb VOC/gal including water.

11Table 1. Summary of St ate and Local Agency Rules with Requ irements Mo re Stringent than the Reco m m endations fo r RACT Pro v ided in the 1978 CTG
State or L o c a l Agenc y Summ a r y of State or L o c a l requirements New Jersey 75 pe rce n t capt u re efficiency for r o t o gra v ure, 7 0 perce n t ca pture e fficiency for fl ex og rap h y , a n d 9 5 pe rcent c ont rol de vice e fficiency for t h erm a l oxi di zer s. North Carolina 95 pe rce n t control device e ffi ciency C a l i f or ni a: An telop e Valley 6 7 p e rcen t ov erall con t ro l efficien cy Bay Area 85 pe rce n t ove r all control efficiency El D o ra do C o u n t y 95 pe rce n t co n t rol devi ce e ffi ciency and 70 perc e n t ca pture efficiency
Ker n C o u n t y 95 pe rce n t co n t rol devi ce e ffi ciency and 90 perce n t ca pture efficiency; or 75

p e rcen t o v e rall con t ro l on a daily b a sis Placer County 95 pe rce n t control device e ffi ciency and 70 perce n t ca pture efficiency Sant a B a r b a r a 67 pe rce n t ove r all control efficiency So ut h C o ast 75 pe rce n t o v e r all control efficiency San J o a q ui n V a l l e y 67 pe rce n t o v e r al l co nt rol ef fi ci ency San Di eg o C o u n t y 85 pe rce n t ove r all control efficiency Sacram ent o M e t r o 95 pe rce n t co n t rol devi ce e ffi ciency and 70 capture efficiency
Vent ura C o unt y 75 pe rce n t o v e r al l co nt rol ef fi ci ency Yol o -S ol a n o C o u n t y 75 pe rce n t ove r all control efficiency

Table 2. Su mmary of State and Local Agency Limits for Clea ning Solvents Used for Fle x ible Package Printing
State or L o c a l Agenc y Cleaning Requirement C a l i f or ni a: Bay Area Ro tog r av ure Prin tin g : 6

. 7 l b VOC/gal in clud ing water o r p a rtial pressu re of 2 5 mm Hg at 2 0 C Flexographic Printing : 6

. 8 lb VOC/gal in clud ing water and pa rt i a l press u r e o f 21 mm H g at 20 C San t a Barb ara Ink App lication Equ i p m en t Clean in g, Prin ti n g : 3.75 l b VO C/g a l an d 33 mm H g at 20C San J o a q ui n V a l l e y In k Ap pl i cat i o n E q ui pm ent
, Fl exo g r ap hi c P r i n t i n g : 0

. 4 2 lb VOC/gal m a t e rial Ink App lication Equ i p m en t, Ro tog r av ure Prin tin g , Pack ag in g : 0.42 l b VO C/g a l

mater i al San Diego C oun ty Clean in g So lv en t : 1.66 l b VOC/g a l m a terial o r to tal v a po r pressure of 4 5 mm Hg at 20C Sacram ento Metro p o litan App licatio n Equ i p m en t, Flexog raph ic Pri n ting : 0

. 8 3 lb VOC/g al in clud ing water and exem pt

co m poun ds So ut h C o ast In k Ap pl i cat i o n E q ui pm ent
, Fl exo g r ap hi c P r i n t i n g : 0

. 2 1 lb VOC/gal Ink App lication Equ i p m en t, Ro tog r av ure Prin tin g , Pack ag in g : 0.21 l b VO C/g a l
Vent ura C o unt y In k Ap pl i cat i o n E q ui pm ent
, Fl exo g r ap hi c P r i n t i n g, Ot he r Fl exo g r ap hi c : 0. 83 l b VOC/gal and 3 mm H g at 2 0 C Ink App lication Equ i p m en t, Ro tog r av ure Prin tin g , Pack ag in g : 0.83 l b VO C/g a l an d 3 m m Hg at 20C

12VI. Recommen d ed Control Options
Recommendations for controlling V O C e m i ssions from inks, coatings, adhesives and clean ing m a terials u s ed in flexible package printing operation s are as follo w s:

A. Coatings, inks and adhesives used on flexible package printing presses

The recommended level of control for VOC e m is sions from c o atings, inks and adhesives used on flexible package printi ng p r esses is tied to the f i r s t installation date of the equipm ent. The first in sta llation date for a piece of equipm ent does not change if the equipm ent is later m oved to a new location. For exam ple, a brand new press first installed in 1992 is m oved to a new location in 1998 – the first installation date for this press is stil l 1992. Or, if a brand new cont rol device first installed in 2004 is m o ved to a new location in 2009 – the first installation date for this control device is still 2004. The first in stallation date for a contro l device does not change if it is la ter us e d to control a new press. Fo r exam ple, a brand new press is installed in 2009 and em issions from this press are contro lled by a control device that was first installed in 2002 - the firs t installation date for this press is 2009 and the first installation date for this control device is still 2002.

The recommended control levels in the final CTG include the following:



### • 65 percen t o v erall contro l for a press th at was f i rs t installed pr ior to M a rch 14, 1995 and that is controlled by an add-on APCD whose fi rst installation date was pr ior to th e ef f

ectiv e date o f the State R A CT rule.



### • 70 percen t o v erall contro l for a press th at was f i rs t installed pr ior to M a rch 14, 1995 and that is controlled by an add-on APCD whose fi rst installation date was on or after the effectiv e date of the State RACT rule.



### • 75 percen t o v erall contro l for a press that was first installed on or after March 14, 1995 and that is controlled by an add-on APCD whose fi rst installation date was pr ior to th e ef f

ectiv e date o f the State R A CT rule.



### • 80 percen t o v erall contro l for a press that was first installed on or after March 14, 1995 and that is controlled by an add-on APCD whose fi rst installation date was on or after the effectiv e date of the State RACT rule.

March 14, 1995 was the proposal date for the 1996 NESHAP for the printing and publishing industry. To provide inform ation on the derivation or basis of the overall control levels, the 6 5 percen t ov erall control effici ency is based on a capture efficiency of 75 percent and a control device e fficien cy of 90 percent. The 7 0 percen t ov erall control efficiency is based on a capture efficiency of 75 percent and a contro l device efficien cy of 95 percent. The 75 percent overa ll control efficiency is bas e d on capture efficiency of 85 percent and control device e fficiency of 95 percent. The 80 percent overall control efficiency is based on a capture efficiency of 85 percent and a contro l device efficien cy of 95 percent. It is not suggested that f acilities m eet the indivi d u al cap ture efficiency or the individu al control efficiencies ; the recomm e ndat i on is for achieving the overall control efficiency. As an alternative to em ission reduction percentages specified above, we also

13recomm end providing the following two equivale nt VOC content lim its which can be m e t by use of low VOC content m a terials or com b ina tions of m a terials and controls as follows: (1) 0.8 kg VOC/kg solids applied, or (2) 0.16 kg VOC/kg m a terials a pplied. These VOC content lim its are consistent with an 80 percen t overall em issions reduction level and reflect sim ilar control levels as the capture and control option. The VOC content lim its can be m e t by averag in g the VOC content of m a terials u s ed on a single press, i.e., within a line. T h e use of averaging to m eet the VOC content lim its is not recom m e nded for cross-line, i.e.,

across m u ltiple lines.

B. Cleaning M a terials W o r k Practices at Flexib le Package Prin ting Presses

We recommend that the following work practices be em ployed for cleaning

m a terials: keeping cleaning m a terials and us ed shop towels in closed containers, and conveying cleaning m a terials from one location to another in closed cont ainers or pipes.

VII. Cost Effectiveness of R ecommended Control Options

Em issions data are available for m o s t of th e facilities iden tified. The em i ssions da ta include VOC data for those facilities identi fied in the 2002 NEI database. The VOC data available from the 2002 NEI were supplem ented with additional HAP data available f r om the 1996 NESHAP where appropriate. For facili ties identified as part of the 1996 NESHAP only, the H A P data from the NESHAP were used. In the ins t ance that on ly HAP data are available for a specific facility, th e as sum p ti on was m a de that VOC e m iss i ons are equal to HAP em issions, with th e recogn itio n that m o st f acilities use and em it som e VOC that are no t HAP. (HAP em issions data from the 1996 NESH AP reflect pre-im plem entation levels of that rule and do not acco unt for redu ctions m a de to com p ly with th e NESHAP.) In addition, the VOC data obtain e d from the NEI are th e total em issions from the source and m a y include VOC e m issions data from other source categories at the facility in addition to

em issions from flexible package printing.

Baseline V O C e m issions are estim ated at 28,000 tons per year (ton/yr) for 390 of the 582 facilities identified with available em issions data. The average VOC em issions per facility were 71 ton/yr. An upper bound on th e nationwide baseline VOC e m issions for flexible package printing can be estim a te d by assum i ng that there m a y be up to 1,071 facilities and that the f acilities with em issions data are re presentative of the total population. In this case, nationwide baseline VOC e m issi ons from flexible package printing would be approxim a tely 76,000 ton/yr. As a lower bound on the nationwide baseline VOC e m i ssions, it was estim ated that there are approxim ately 582 f acilities. In this case, nationwide baseline VOC e m issions from fle x ible package prin ting w ould be approxim a tely 42,000 ton/yr. Therefore the nationwide baseline em issi ons range from approxim a tely 42,000 to 76,000 ton/yr. Nonattainm e nt area VOC e m issions from f

l exible pa c k age prin tin g f acilities ( b ased on April 2004 designations) are estimated to range from 8,636 to 16,364 Mg/yr (9,500 to 18,000 tpy).

Many facilities located in ozone nonattainm e nt areas are already m eeting the control levels being recomm ended in this CTG. Thes e facilities m a y be using capture and control

14system s or low VOC content inks, coatings, and adhesives. The costs f o r f acilities n o t using low VOC content inks, coatings, and adhesives that are not alr eady using control equipm ent, will vary depending on the flow rate, hourly so lv ent use rate, and operatin g hours. Although we do not have detailed inform ation for the i ndustry as a whole, we have infor m ation for

som e sources from which we can estim a te th e likely em issions reductions and costs for a typical source subject to control for the first tim e (see Appendix B). For a press exhausting approxim a tely 5,800 cubic feet per minute, operating 2000 hours per year, and achieving 70

percen t capture efficiency, we estim ate the VOC em ission red u ction to ran g e from 30 to 60

m e gagra m s (Mg) (33 to 66 tons) per year a nd the cost effectiveness to range from $1,400/Mg to $3,100/Mg ($1,300/ton to $2,800/t on) depending on the average hourly solvent us e r a te. 9 At lower solven t us e rates, the c o st per ton of e m ission controlled would likely be higher. Increasing the hourly solven t use rate, annual operati ng hours, or capture efficiency of this s i ze p r ess would increas e the annual VOC em ission reduction and improve the cost effectiveness. L a rger presses with proportionately larger hourly solvent use rates would also have larger annual VOC em ission re ductions and better cost effectiveness than

sm aller presses.

15VIII. References

1. Control of V o latile Orga nic Emissio n s from Exis ting Sta tion a ry Sources – Volume VIII: Graphic Arts – Rotogravure and Flexography . EPA Publication No. EPA-450/2-78- 033. U.S. Environm ental Protection Agency. Research T r iangle Park, N C . Dece m b er 1978.

2. 40 CFR part 63, subpart KK. National Em issions Standards fo r Hazardous Air Pollutants: Printing and Publishing Industry.

3. National Emission Standards for Hazardous Air Pollutants: Printing and Publishing Industry Background Informa tion for Proposed Standards. EPA Publication No. E P A453/R-95/-002a. U.S. Environm ental Protection Agency. Research T r iangle Park, N C

. February 1995.

4. Technical Support Document (TSD) for Titl e V P e rmitting of Pr inting Facilities. Offi ce of

Air Quality Planning and Standar d s, U.S. Environm ental Protec tion A g ency. Research Triangle Park, NC 27711. January 2005.

5. 2005 State of the Flexible Packaging Industry Report . Flex ib le Packag in g Associatio n (FPA). Linthicum

, Maryland.

6. 2002 National Em issions Inventory. U.S. Environm ental Protection Agency. Dated April 11, 2006.

7. 40 CFR part 63, subpart JJJJ. Nation a l Em issions Standards f o r Hazardou s Air Pollutants: Paper and Other W e b Coating.

8. Printing Industry and Use Cluster Profile . U.S. Environm ental Protection Agency. EPA Publication No. 744-R-94-003. June 1994.

9. Flexographic Ink Options: A Cleaner Technologies Substitutes Assessment . EPA Publication No. EPA 744-R-02-001-A. U. S. Environm ental Protection A g ency.

16

## Appendix A

Guideline Series: Control of Volatile Organic Emissions from Existing Stationary Sources—V olume VIII: Graphic Arts – Rotogravure and Flexography . EPA Publication No. EPA-450/2-78-033. U.S. Environm ental Prot ection Agency. Research Triangle Park, NC. Dece mber 1978.

Available as a separate item in docket EPA-HQ-OAR-2006-0537 at www.regulations.gov

.

Technical Support Document (TSD) for Ti tle V P e rmitting of Printing Facilities . Office of Air Quality Planning and Standards, U.S. E nvironm ental Protection Agency. Research Triangle Park, NC 27711. January 2005.

Available as a separate item in doc ket EPA-HQ-OAR-2006-0537 at www.regulations.gov and as a sep a rate item on the in ternet at http://w ww.epa.gov/ttn/o arpg/t5/m emoranda/tsd.pdf

.

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18

## Appendix B

Estimated Costs Associated with the Recom m e ndations Contained in the C ont rol Techniques Guideline for Flexible Package Printing

I. Introductio n

This m e m o r a ndum presents the estimated costs associated with im ple m enting the

recomm endations in the CTG for controlling volatile organic com pounds (VOCs) e m issions from flexible package printing facilities in ozone nonattainm e nt areas. As explained in the CTG, the CTG is guidance for State and lo cal p o llution control agen cies to use in determ ining “reasonably available control t echnology” (RACT) for VOCs from flexible package printing. State and local pollution control agencies are free to adopt the

recomm endations contained in the C T G, or im pl em ent other technically-sound approaches for RACT, provided those approaches are cons istent with the CAA and EPA’s im plem enting regulations. Accordingly, ther e is necessarily som e uncertain ty in any prediction of costs and em ission im pacts associated with the re comm endations contained in the CTG. For purposes of this an alys is , we assum e that a ll s t ate s will adop t the re commendation s in the CTG.

Costs were estim ated for add-on air polluti on control devices (APCD) likely to be used to control em issions to the reasonabl y available control t echnology (RACT). A discussion of RACT for flexible package pr in tin g f acilities is pr ovided in section VI, Recommended Control Options, of the CTG.

Costs were developed f o r a fixed bed catalytic oxidizer achieving 95 percent destruction efficiency.

II. Description of Cost Analysis

The cost analysis discussions include specif i c inf o rm ation that details th e

assum p tions and m e thodology used in costing A P CDs. The Air Com p liance Advisor (ACA) was used to estim ate cos t s based on February 20 03 dolla rs. I n estim ating the to tal c a p ita l investm e nt (TCI) for the add-on APCDs, the equipm ent costs were based on February 2003 dollars and were scaled to represen t costs for 2005 dollars. Purchased equipm ent costs (PEC) generally include the control device and au xiliary equ i p m ent costs, instrum e ntation costs, sales tax, and freig h t costs. Co sts fo r instrum e ntation (10 pe rcen t), s a les tax (3 percent), and freight (5 percen t) were estim a ted to be 18 percent of control device and auxiliary equipm ent costs.

19Several components of the annual costs in clude direct annual co sts such as labor wages and m a intenance costs, utilities, and ra w m a terials. C o mm on costs for indirect annual costs in clud e overhead and adm i nistrative charge s. Direct co sts are listed in Table 1.

Table 1. Common Assumptions for Annual Cost Calculations

Par a meter/F a ctor Direct Annual Costs Ope r at o r Wage R a t e (exc ept s t eam st ri pper ) $1 2. 9 5 / h r M a i n t e nance L a bo r Wa ge R a t e $1 4. 9 5 / h r Sup e rv isor Labo r Co st 1 5 p e r c en t of O p er ator labor co st M a i n t e nance m a t e ri al s cost 10 0 pe rcent of M a i n t e nance L a bo r c o st Utilities Natural Gas C o st Electricity Cost $3 .3 0 pe r 1, 00 0 sc f $ 0 .059 p e r kW- h r Indirect Annual Cos t s Ove r head 60 pe rce n t o f a l l l a bor an d m a i n t e nanc e material costs Adm i n, P r o p er t y Taxes, a n d I n su ra nce 4 perce n t of T C I

Typical or average facility and individua l press operating conditions for flexographic printing were presen ted in a recen t E P A Design for Environm ent (DfE) docum ent. 1 In the DfE report, catalytic oxidizer a dd-on APCDs were costed for a facility with four new 48- inch wide, 8-color presses. The total dryer ai r flow rate for each press was 5,800 cubic feet

per m i nute (cfm ) and the air exhaust rate for each press was 2,900 cfm (50 percent recirculation). The dryer exhaust temperatur e was 150 degrees Fahre nheit (oF). Capture efficiency was assum e d to be 70 percent. A 5,800 cfm catalytic ox idizer controlled the exhaust fro m two presses. See referenced docu m ent for addition a l discu ssion.

For this an alysis ca taly tic oxidizer add-on APCDs were firs t costed for sim ilar sing le presses with no recirculation – i. e., the air exhaust rate for each press is 5,800 standard cubic feet per m i nute (scfm ) and a 5,800 scfm cataly tic oxidizer controlled the exhaust from a single p r ess. Capture efficien cy was assum e d to be 70 percent. The param e ters for these presses were input to AC A to calculate TCI and TAC. The costs were estim a ted based on one catalytic oxidizer serving one printing press with no recirc ulation; the costs for other types of incinerators and oxidizers were also l ook ed at howev er the m o st cost effectiv e type was chosen as facilities are m o st lik ely to s e lect cost effectiv e contro ls. The TCI for the fixed bed catalytic oxidizer is estim a ted at $306,000 in February 2003 dollars. Using Marshall & Swift indi ces of 1116.4 for first quarter 2003 and 1244.5 for 2005, the TCI was scaled to $341,000 in 2005 dollars. 2, 3

The TAC was then es tim a ted for three VOC loading scenarios:

(1) for a press with 17.5 tons per year (ton/yr) solvent loading and a press operating 2000 hours per year (hr/y r), the solvent loading in the captured stream is 17.5 pounds per hour (lb/hr) VOC, the VOC is

assum e d to be toluene, and the VOC concentration is 210 parts per

m illion by volum e (ppmv),

20(2) for a press with 35 tons per year (to n /yr) so lven t loading and a press operating 2000 hours per year (hr/y r), the solvent loading in the captured stream is 35 pounds per hour (lb/hr) V O C, the VOC is

assum e d to be toluene, and the VOC concentration is 420 parts per

m illion by volum e (ppmv), and (3) for a press with 70 ton/yr solven t loading and a press operating 2000 hr/yr, the so lvent load ing is 70 lb /hr VOC, the VOC is assumed to be toluene, and the VOC concentration is 840 ppm v.

These scenarios are sho w n in Table 2. (W ith 70 percen t capture efficiency, the solv en t use rate for a press is 25 lb/hr or 25 ton/yr for th e f i r s t scena r io, 50 lb/hr or 50 ton/yr for the second scenario and 100 lb/hr or 100 ton/yr fo r the third scenario.) The T A C for the first scenario is $85,000 per year, for the second scenario is $83,000 and for the third scenario is $79,000 per year in February 2003 costs. These costs were scaled to 2005 dollars and are $95,000 per year, $93,000 per year and $88,000 per year, respectively.

The catalytic oxidizer achieves 16.6 ton/ yr of VOC control (95 percent of 17.5 ton/yr) in scenario one, 33.3 t on/yr of VOC control (95 percen t of 35 ton/yr) in scenario 2, and 66.5 ton/yr of VOC contro l (95 percent of 70 ton/yr) in scenario 3. The cost effectiveness is $5,700 per ton ($/ton) for scenario 1, $2,800/ton for scenario 2, and $1,300/ton for scenario 3.

Table 2. VOC Loading Scenarios for Flex ible package printing Press e s

Par a meter Scenari o 1 Scenari o 2 Scenari o 3

So lv en t u s ag e, to n / yr 25 5 0 1 0 0
Capture efficiency, % 70 % 70 % 7 0 %

Control device efficiency, % 95 % 9 5 % 95 %

Ope r at i n g ho ur s, h r / y r 2 000 hr /yr 2 000 hr /yr 2 000 hr /yr

Exhaust rate/oxidizer capacit y 5 800 scf m 5 800 scf m 5 800 scf m TCI, $ $ 341 ,0 00 $ 341 ,0 00 $ 341 ,0 00

So lv en t lo ad i n g , l b /hr 1 7 .5 lb /hr 3 5 lb /hr 7 0 lb /hr

Ass u m e d VOC com pou n d to lu en e to lu en e t o lu en e
VOC c o nce n t r at i on, p p m v 21 0 ppm v 42 0 ppm v 84 0 ppm v
TAC

, $ $9 5, 0 00 $9 3, 0 00 $8 8, 0 00

Sol v e n t l o a d i n g, t on/ y r 17 .5 t o n/ y r 35 t o n/ y r 70 t o n/ y r
VOC em i ssi on re duct i o n, 9 5 % ef fi ci ency 16 .6 33 .3 66 .5

C o st ef fect i v e n ess, $/ t on 5, 70 0 2, 80 0 1, 30 0

Next, the effect of recirculation or lower dryer air exhaust rate was exam ined for the lowest solvent loading scenar io. Three cases were exam ined: case 1.A with 2,900 cfm, case 1.B with 2,000 cfm

, and case 1.C with 1,500 cfm

. Thes e cases are shown in Table 3.

21For case 1.A , the TCI for the fixed bed catal ytic oxidizer is estim a ted at $208,000 in February 2003 dollars which scales to $232,000 in 2005 dollars. For case 1.B, the TCI for the fixed bed catalytic oxid izer is estim a ted at $170,000 in February 2003 dollars which scales to $190,000 in 2005 dollars. For case 1.C , th e TCI for the fixed bed catalytic oxidizer is estim a ted at $127,000 in February 2003 dollars which scales to $142,000 in 2005 dollars.

For case 1.A , the TAC is estim ated at $56,000 in February 2003 dollars which scales to $62,000 in 2005 dollars. For case 1.B, the TA C is estim ated at $46,000 in February 2003 dollars which scales to $ 51,000 in 2005 dollars. For case 1.C , the TAC is estim ated at $36,000 in February 2003 dollars which scales to $46,000 in 2005 dollars.

The catalytic oxidizer achieves 16.6 ton/ yr of VOC control (95 percent of 17.5 ton/yr) in cases 1.A, 1.B and 1.C. The co st effectiveness is $3,700/ton for case 1.A, $3,100/ton for case 1.B and $2,400/ton for case 1.C.

Table 3. Effect of recirculation or low er dryer air exhaust rate on Scenario 1

Par a meter Case 1

. A Case 1

. B Case 1

. C

So lv en t u s ag e, to n / yr 2 5 2 5 2 5
Capture efficiency, % 70 % 7 0 % 70 %

Control device efficiency, % 95 % 95 % 95 %

Ope r at i n g ho ur s, h r / y r 2 000 hr /yr 2 000 hr /yr 2 000 hr /yr

Exhaust rate/oxidizer capacit y 2 900 scf m 2 000 scf m 1 500 scf m TCI, $ $ 232 ,0 00 $ 190 ,0 00 $ 142 ,0 00

So lv en t lo ad i n g , l b /hr 1 7 .5 lb /hr 1 7 .5 lb /hr 1 7 .5 lb /hr

Ass u m e d VOC com pou n d to lu en e t o lu en e to lu en e

VOC c o nce n t r at i on, p p m v 42 0 ppm v 61 0 ppm v 81 0 ppm v
TAC

, $ $6 2, 0 00 $5 1, 0 00 $4 6, 0 00

Sol v e n t l o a d i n g, t on/ y r 17 .5 t o n/ y r 17 .5 t o n/ y r 17 .5 t o n/ y r
VOC em i ssi on re duct i o n, 9 5 % ef fi ci ency 16 .6 16 .6 16 .6

C o st ef fect i v e n ess, $/ t on 3, 70 0 3, 10 0 2, 40 0

22III. Nationw i de Costs

The nationw ide cos t s for the recommended control approach es in th e CTG are presented in Table 4. As noted above, for the purposes of this analysis, we assum e d that States would adopt the control appr oaches recommended in the CTG.

We estim ate that 219 facilitie s are located in ozone nonatt ainm ent areas; of these 219 facilities, there are approxim a tely 100 facilities with VOC e m issions greater than 15 pounds per day (lb/day).

The nationw ide TCI and TAC for the 100 fac ilities identified above represent the

m a xi m u m nationwide costs. Because it is not kn own how many of thes e 100 facilities have presses which use 25 tons per year or m o re of VOC com b ined from inks, coatings and adhesives, or how m a ny of these presses are curr e n tly im plementing con t r o l techn i que s to reduce VOC em issions which satisfy the recomm endations in the CTG, we provide nationwide cost estim ates based on the assum p ti ons that 100 percent, 75 percent, 50 percent and 25 percent of the 100 facilities w ould need to insta ll con t r o l equipm ent to sa tisf y the

recomm endations in the CTG.

The high en d estim ates for each percentage assu m e 4 presses per facility. The TCI and TAC for the high end estim ates are based on scenario 1 above. The low end estim a tes for each percentage assu m e 1 press per faci lity. The TCI and TAC for the low end estim ates are based on s cenario 3 ab ove.

The assum p tion that 100 percen t of the f acilities will n eed to in stall control equipm ent is not likely and overstates the nationw ide costs. This is be cause not all of the 100 facilities will hav e a press us ing 25 tons per year or m o re of VOC combined from inks, coatings, and adhesives, and m a ny facilities are curren tly implem en ting control techniques to reduce VOC e m issions which satisfy the re commendations in the CT G. Our best estim ate is that 25 percent or less of the facilities will need to install co ntrol equip m ent to satis f y the CTG recomm endations..

23Table 4. Nationw i de Cost Estimates

. If 1 0 0 % , 1 0 0 fa cilities, in sta l l co ntro l equi pment:

1 0 0 F a c i l i t i e s $ 341 ,0 00 TCI p e r facility (1 p r ess) $ 3 4

, 10 0,000 Natio nwid e TCI, low end
$ 1 ,364 ,0 00 TCI p e r facility (4 presses) $ 136 ,4 00 ,00 0 Natio nwid e TCI, h i gh en d

$ 380 ,0 00 TAC p e r facility, h i gh end (4

press e s @ $9 5, 00 0 ) $3 8, 0 0 0

, 0 0 0 Nat i o n w i d e T A C

, hi g h e n d
$ 8 8

, 00 0 TAC p e r facility, lo w end $ 8 ,800 ,0 00 Natio nwid e TAC, l o w end

If 7 5 % , 7 5 fa cilities, in sta ll co ntro l equipment:

7 5 f a c i l i t i e s $ 341 ,0 00 TCI p e r facility (1 press) $ 2 5

, 57 5,000 Natio nwid e TCI, low end
$ 1 ,364 ,0 00 TCI p e r facility (4 presses) $ 102 ,3 00 ,00 0 Natio nwid e TCI, h i gh en d

$ 380 ,0 00 TAC p e r facility, h i gh end (4

press e s @ $9 5, 00 0 ) $2 8, 5 0 0

, 0 0 0 Nat i o n w i d e T A C

, hi g h e n d
$ 8 8

, 00 0 TAC p e r facility, lo w end $ 6 ,600 ,0 00 Natio nwid e TAC, l o w end

If 5 0 % , 5 0 fa cilities, in sta ll co ntro l equipment:

5 0 F a c i l i t i e s $ 341 ,0 00 TCI p e r facility (1 press) $ 1 7

, 05 0,000 Natio nwid e TCI, low end
$ 1 ,364 ,0 00 TCI p e r facility (4 presses) $ 6 8

, 20 0,000 Natio nwid e TCI, h i gh en d

$ 380 ,0 00 TAC p e r facility, h i gh end (4

press e s @ $9 5, 00 0 ) $ 1 9

, 00 0,000 N a tio nw id e TA C, h i gh end
$ 8 8

, 00 0 TAC p e r facility, lo w end $ 4 ,400 ,0 00 Natio nwid e TAC, l o w end

If 2 5 % , 2 5 fa cilities, in sta ll co ntro l equipment:

2 5 F a c i l i t i e s $ 341 ,0 00 TCI p e r facility (1 press) $ 8 ,525 ,0 00 Natio nwid e TCI, low end
$ 1 ,364 ,0 00 TCI p e r facility (4 presses) $ 3 4

, 10 0,000 Natio nwid e TCI, h i gh en d

$ 380 ,0 00 TAC p e r facility, h i gh end (4

press e s @ $9 5, 00 0 ) $ 9 ,500 ,0 00 N a tio nw id e TA C, h i gh end
$ 8 8

, 00 0 TAC p e r facility, lo w end $ 2 ,200 ,0 00 Natio nwid e TAC, l o w end

24IV. References

1. Flexographic Ink Options: A Cleaner Technologies Substitutes Assessment . EPA Publication No. EPA 744-R-02-001-A. U.S. Environm ental Protection A g ency. 2002.

2. Chemical Engineering . Nove m b er 2003. p. 124.

3. Chemical Engineering . March 2006. p. 84.

2526 This page intentionally left blankUnited StatesEnvironmental ProtectionAgencyOffice of Air Quality Planning and StandardsSector Policies and ProgramsDivisionResearch Triangle Park, NCPublication No. EPA 453/R-06-003September 2006