UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103
DATE: August 5, 2010 SUBJECT: Technical Support Document for Maryland’s Adoption of Control

Techniques Guidelines for Flexible Packaging Printi ng /s/ FROM: Irene Shandruk, Phy sical Scientist

Office of Air Program Planning TO: File

/s/ THRU: Maria A. Pino, Acting Associate Director

Office of Air Program Planning
A. BACKGROUND What is the flexible package printing CTG? S ection 172(c)(1) of the Clean Air Act (CAA) provides that state implementation plans (SIPs) for nonattainment areas must include reasonably available control measures (RACM), including reasonably available control technology (RACT), for sources of emissions. Sec tion 182(b)(2)(A) provides that for certain nonattainment areas, States must revise their SIPs to include RACT for sources of volatile organic compound ( VOC ) emissions covered b y a control techniques guidelines (CTG) document issued after November 15, 1990 and prior to the area’s date of attainment. The United States Environmental Protection Agency (EPA) defines RACT as “the lowest emission limitation that a particular source is capable of meeting b y the application of control technology

that is reasonabl y available considering technological and economic feasibility .” (44 FR 53761, Sept. 17, 1979 )

. Insubsequent Federal Register notices, EPA has addressed how states can mee t the RACT requirements of the CAA

. The CTG for flexible package printing is inte nded to provide state and local air pollution control authorities information that should assist them in determining RACT for VOC s from flexible package printing facilities. In developing this CTG, EPA, among other things, evaluated the sources of VOC emis sions from this industry and the available control approaches for addressing these emissions, includin g the costs of such approaches. Based on available information and data, EPA provides recommendations for RACT for VOC s from flexible package printing fa cilities.In December 1978, EPA published a CTG for graphic arts (rotogravure printing and

flexographic printing) that included flexible package printing. 1 The 1978 CTG discusses the flexible package printing industry , the nature of VOC emissions from that industry , available control technologies for addressing such emissions, the costs of available control options, and other items. EPA also published a national emission standard for hazardous air pollutants (NESHAP) for the printing and publishing indu stry (40 CFR Part 60, Subpart KK) in May 1996, which is applicable to flexible package printing

. In September 2006, after conducting a review of currentl y existing state and local VOC emission reduction approaches for flexible package printing, reviewin g the 1978 CTG and the 1996 NESHAP for the printing and publishing industry (40 CFR Part 60, Subpart KK), and taking into account the information that has become available since then, EPA developed a new CTG for flexible package printing entitled Control T echniques Guidelines for Flexible Package Printing (Publication No. EPA 453/R

- 06
- 003). What is flexible p ackaging? Flexible packaging refers to any package or part of a package , the shape of which can be readil y changed. Flexible packaging includes, b ut is not limited to, bags, pouches, liners, and wraps utilizing paper, plastic, film, aluminum foil, metalized or coated paper or film, or an y combination of these materials. Flexible package manufacturers are sometimes referred to as "converters." 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. Printing on flexible packaging is almost entirel y conducted b y rotogravure and wide

- web flexographic printing

. Printing, coating, and laminating may all be performed on or in

- line with a flexible package printing press ; and these activities are included in the source category . One portion of the flexible packaging industry provides fully

printed packaging materials (designated "preformed specialt y bags") to contract packagers. Another portion provides combination or laminated materials (designated converted wrap) for printing and/or final packing b y captive packaging operations. Applying coatings is a major capability of flexible packaging converters . S o , the same facilities may be used to manufacture non

packaging materials such as gift wraps and hot stamp foils. The industry makes a distinction between labels and wrappers, which are package components, and a product that becomes the entire package and should be called a flexible package. Any printing of shrink

- wrap labels or wrappers conducted on or in

- line with a flexible package printing press is also considered to be included under the flexible packaging source category

. Printing of self

- adhesive labels would not be considered flexible packaging.

1 Control of Volatile Organic Emissions from Existing Stationary Sources

— Volume VIII: Graphic Arts

— Rotogravure and Flexography . EPA Publication No. EPA

- 450/2

- 78
- 033. U.S. Environmental Protection Agency. Research Triangle Park, NC. December 1978

.Rigid packaging printing operations are often co - located with flexible package printing

operations. Folding cartons, some labels and wrappers, gift wraps, wall coverings, vinyl products, decorative laminates, floor coverings, tissue products, and miscellaneous specialty products are not considered flexible packaging

. There are two t ypes of printing processes used b y flexible package printing facilities: (1) rotogravure printing; and (2) flexographic printing. And there are two main sources of VOC emissions from flexible package printing for both rotogravure and fle xographic: (1) evaporation of VOC from inks, coatings, and adhesives, and (2) evaporation of VOC s from cleaning materials. There are two approaches to reducing VOC emissions from inks, coatings, and adhesives used in the flexible package printing industry : (1) adding/improving add

- on controls, and (2) material reformulation or substitution. The first approach includes improving capture and/or control s ys tems or adding control sy stems 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 and can necessitate up

- grades to existing control devices. The second approach, focusing on pollution prevention, is to substitute low VOC or VOC

- free m aterials for materials (inks, coatings, and adhesives) presentl y in use. EPA’s Recommended Control Options for Flexible Package Printing EPA issued a CTG for Flexible Packaging Printing on September 2006 (EPA 453/R

- 06
- 003). Recommendations for controlli ng VOC emissions from inks, coatings, adhesives and cleaning materials used in flexible package printing operations are outlined in the CTG and are as follows: A. Coatings, inks and adhesives used on flexible package printing presses : The recommended level of control for VOC emissions from coatings, inks and adhesives used on flexible package printing presses is tied to the first installation date of the equipment. The first installation date for a piece of equipment does not change if the equipment is late r moved to a new location. For example, a brand new press first installed in 1992 is moved to a new location in 1998

– the first installation date for this press is still 1992. Or, if a brand new control device first installed in 2004 is moved to a new l ocation in 2009

– the first installation date for thi s control device is still 2004. The first installation date for a control device does not change if it is later used to control a new press. For example, if a brand new press is installed in 2009 and e missions from this press are controlled by a control device that was first installed in 2002 , then the first installation date for this press is 2009 and the first installation date for this control device is still 2002. The recommended control lev els in EPA’s final CTG include the following: • 65 percent overall control for a press that was first installed prior to March 14, 1995 and that is controlled by an add

- on air pollution control device( APCD ) whose first installation date was prior to the effective date of the State RACT rule. • 70 percent overall control for a press that was first installed prior to March 14, 1995 and that is controlled by an add

- on APCD whose first installation date was on or after the effective date of the State RACT ru le. • 75 percent overall control for a press that was first installed on or after March 14, 1995 and that is controlled by an add

- on APCD whose first installation date was prior to the effective date of the State RACT rule. • 80 percent overall control f or a press that was first installed on or after March 14, 1995 and that is controlled by an add

- on APCD whose first installation date was on or after the effective date of the State RACT rule. As an alternative to emission reduction percentages specified above, EPA also recommend s providing the following two equivalent VOC content limits which can be met by use of low VOC content materials or combinations of materials and controls as follows: (1) 0.8 kg VOC/kg solids applied, or (2) 0.16 kg VOC/kg materia ls applied. These VOC content limits are consistent with an 80 percent overall emissions reduction level and reflect similar control levels as the capture and control option. The VOC content limits can be met by averaging the VOC content of materials use d on a single press, i.e., within a line. B. Cleaning Materials Work Practices at Flexible Package Printing Presses : Recommended work practices for cleaning materials are to keep cleaning materials and used shop towels in closed containers, and convey cle aning materials from one location to another in closed containers or pipes.
B. STATE SUBMITTAL On April 23, 2010, Maryland Department of the Environment (MDE) submitted to EPA a SIP revision concerning the adoption of the EPA CTG for flexible packaging printing. EPA develops CTGs as guidance on control requirements for source categories. States can follow the CTGs or adopt more restrictive standards. MDE is adopting EPA’s CTG standards for flexible packaging printing and work practices (see EPA 453/R

- 06
- 003, September 2006). This SIP revision includes amendments to Regulation .10 and a new regulation .10

- 1 under COMAR 26.11.19, Volatile Organic Compounds from Specific Processes. This action affects sources that use flexographic and rotogravure press es to print flexible packaging materials. COMAR 26.11.19.10

– Flexographic and Rotogravure Printing is amended as follows to include language pertaining to flexible packing printing: Section .10(B)(2) : The provisions of this regulation (ie. COMAR 26.11 .19.10) do not apply to printing on fabric, metal, plastic, or to flexible package printing subject to COMAR 26.11.19.10

- 1. Section .10(C)(1) : A person who owns or operates a printing press that uses flexographic, packaging rotogravure, or publication rot ogravure methods and is amajor stationary source shall reduce emissions by using water

- based inks that contain less than 25 percent VOC by volume of the volatile portion of the ink, or high solids inks that contain not less than 60 percent by weight nonvo latiles. COMAR 26.11.19.10 - 1

– Flexible Packaging Printing is being added: Section .10

- 1(A) : Includes definitions for flexible packaging, flexible packaging coatings, flexible packaging printing, and flexible packaging printing line. Section .10

- 1(B) : Describes the applicability of this regulation. Section .10

- 1(C) : Describes emission standards and requirements for major stationary sources that perform flexible packaging printing. Section .10

- 1(C)(1) : Emissions are either reduced by using water

- base d inks that contain less than 25 percent VOC by volume of the volatile portion of the ink, or high solids inks that contain not less than 60 percent nonvolatiles. Section .10

- 1(C)(2) : If compliance cannot be achieved through use of the water
- based inks or high solids inks described above in (C)(1), the source shall reduce the VOC content of each ink, or reduce the average VOC content of inks used at each press as follows: (a) 60 percent reduction for flexographic presses; (b) 65 percent reduction for packaging rotogravure presses; and (c) 75 percent reduction for publication rotogravure presses. Section .10

- 1(D) : Describes additional emission standards and requirements for a person who owns or operates a flexible packaging printing line with potential to emit VOCs o f 25 tons or more per ye ar. Compliance is met by : Section .10

- 1(D)(1) : L imiting the VOC content of each flexible packaging coating or limiting the average VOC content of flexible packaging coatings of the line to not more than: (a) 0.8 lb VOC/lb or kg VOC/kg solids applied; or (b) 0.16 lb VOC/lb or kg VOC/kg materials applied; or by that described in Section .10

- 1(D)(2). Section .10

- 1(D)(2) : Venting the dryer exhaust of the line through a control device that is constructed, operated, and maintained to achieve an overall control efficiency of: (a) 65 percent overall control for a press that was first installed prior to March 14, 1995 and that is controlled by an add

- on APCD whose first installation date was prior to the effective date. (b) 70 percent overall control for a press that was first installed prior to March 14, 1995 and that is controlled by an add

- on APCD whose first installation date was on or after the effective date of the rule. (c) 75 percent overall control for a press that was first installed on or after March 14, 1995 and that is controlled by an add

- on APCD whose first installation date was prior to the effective date of the rule. (d) 80 percent overall control for a press that was first installed on or after March 14, 1995 and that is controlled by an add

- on APC Dwhose first installation date was on or after the effective date of the rule.
C. EPA EVALUATION The State of Maryland has adopted the standards and requirements of the CTG for flexible packaging printing and is amending its SIP to reflect these amendments. The maximum benefit from these amendments will be provided during the ozone season when VOCs readil y combine with NO x to form ground

- level ozone. Therefore, this revision will help Maryland attain and maintain the NAAQS for ozone. D. CONCLUSIO NS AND RECOMMENDED AGENCY ACTION The adoption of the EPA CTG requirements for flexible packaging printing by the State of Maryland will result in the reduction of VOC emissions from flexible packaging printing. EPA approval of the SIP revision is recomme nded