TECHNICAL SUPPORT DOCUMENT
FOR
CONTROLLING VOM
EMISSIONS
FROM
LITHOGRAPHIC PRINTING, LETTERPRESS
PRINTING, FLEXIBLE
PACKAGE
PRINTING, FLAT
WOOD
PANELING
COATING, AND
INDUSTRIAL CLEANING OPERATIONS
DIVISION OF AIR
POLLUTION CONTROL
BUREAU OF AIR
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY
SPRINGFIELD, IL 62702
APRIL 2009
1.0
INTRODUCTION
Section 172
of the Clean Air
Act (CAA)
requires that state
implementation plans
(SIPs)
for nonattainment
areas,
such as the
Chicago and Metro-East
St. Louis
nonattainment
areas
(NAAs) in
Illinois,
must
include requirements
for
“reasonably
available
control
technology”
(RACT)
as it applies to
emissions
sources.
1
The Chicago
NAA currently
includes the entire
counties
of Cook,
DuPage, Kane,
Lake, McHenry,
and Will,
as
well
as
Aux Sable and Goose
Lake
Townships
in
Gnmdy County,
and
Oswego
Township in Kendall
county.
Madison,
Monroe,
St. Clair, and Jersey
counties
are part of the ozone
NAA in the
St. Louis/Metro-East
geographic
location.
In March
2008,
the
United States
Environmental
Protection Agency
(USEPA)
strengthened the
eight-hour
ozone
standard.
It
is likely
that the same areas
in
Illinois
that are
currently designated
as nonattainment
for the
present standards
will soon
be designated
as nonattainment
for this revised
standard. Reducing
VOM emissions
in these areas
will likely help
Illinois achieve
the newly revised
NAAQS
as well as
satisfy
CAA
obligations.
USEPA
is expected
to finalize
the
nonattainment
designations
in 2010,
initiating
a
new
cycle
of planning
and regulatory
development.
Obviously,
such planning has
not occurred
yet, so it is
not
possible
to identify specific
emission reduction
measures
needed to attain
these standards. However,
VOM
emission reductions
will
improve ozone
air quality,
which will
help
to meet the new standards
and
should
help
to address
any future requirements
to implement
RACT for the
new
standards.
Section 182(b)(2)(A)
of
the CAA further
requires that SIPs
be revised to include
RACT for volatile
organic material
(VOM) emissions
sources that
are covered
by
a control
techniques
guideline (CTG) document
issued
by USEPA after
November
15,
1990, and
before
the area’s date of
attainment.
The USEPA
defines RACT as
“the lowest emission
limitation that
a particular
source
is capable
of
meeting
by
the
application of control
technology
that is
reasonably available
considering
technological
and economic
feasibility.” (44
FR
53761,
September
17, 1979.) fri developing
the CTGs
for
the categories
covered
by this Technical
Support
Document
(TSD), USEPA evaluated
the
sources
of
VOM emissions
from the applicable
industries,
the available control
possibilities
to address
the
associated
emissions,
and the cost of such
control
measures.
Emissions
of VOM
result from various
points in
the processes covered
by this
TSD.
These
VOM emissions
react
with
other pollutants in
the atmosphere,
such
as oxides of nitrogen
(NOx) and
carbon monoxide
(CO),
to form
ozone. Ozone
formation
is most
active during the
summer months because
the chemical
reactions involved
rely on direct
sunlight and
high ambient temperatures.
Ozone
1
is a
powerful
oxidant,
and
as such
reacts
readily
with
a
wide range
of substances.
In
humans,
ozone irritates
the
respiratory
system
and reduces
lung
function.
Laboratory
studies
suggest that
it may
damage lung
and
other
tissue.
There
is
concern
that
this damage
can
impair breathing
and
reduce
immunity
to disease
for
people in
good
health,
and
the effect
may
be
more
severe
for
people
with pre
existing
respiratory
diseases.
Ozone
oxidation
can
also
impair
plant
tissue
and
reduce
the
yield
of some
crops, as
well as
damage materials
such
as rubber
products.
This TSD
presents the
rationale,
documentation,
and
methodology
relied upon
to
technically
justify
the
Illinois EPA’
s proposed
regulatory
changes
to control
VOM
emissions
from
the categories
known
collectively
as
the Consumer
and
Commercial
Products,
Group
II,
which
includes
lithographic
printing,
letterpress
printing,
flexible
packaging
printing,
flat
wood
paneling
coating,
and industrial
cleaning
solvents.
To
assist
in evaluating
the
potential
for implementing
new emission
standards
for
Illinois
sources,
the Illinois
Environmental
Protection
Agency
(Illinois
EPA)
reviewed
and evaluated
the
USEPA
CTGs, as well
as
other
available
information,
including
regulations
in other
states and
those
already
existing
within
Illinois. In
addition,
Illinois
EPA
staff
held conversations
with
staff
from
USEPA and
other
states,
as
well as
with representatives
from various
industry groups.
Based
on this
information,
the
Illinois EPA
determined
the
applicability
thresholds
for
application
of controls
and
is recommending
appropriate
control
measures.
This
TSD is
based on
the aforementioned
documents
and
addresses
the technological
feasibility
and economic
reasonableness
of implementing
new
standards
for
lithographic
printing,
letterpress
printing,
flexible
package
printing, flat
wood
paneling
coating,
and industrial
cleaning
processes.
2.0
PROCESS
DESCRIPTION
AND SOURCES
OF EMISSIONS
2.1
Lithographic
Printing
Offset
lithographic
printing
has
a
broad
range
of applications,
including
books,
magazines,
periodicals,
labels and
wrappers,
catalogs
and
directories,
financial
and
legal
documents,
business
forms,
advertising
materials,
newspapers,
newspaper
inserts,
charts
and
maps,
calendars,
tickets
and
coupons,
greeting
cards,
and stamps.
None
of
the
above
applications
are exclusive
to offset printing;
other
modes
of
printing
in
the
graphic
arts industry
can
produce items
such
as those mentioned
above.
However,
the newspaper
industry
uses
offset lithography
predominantly,
with
over
70 percent
of all newspapers
in the United
States
printed
by this
method.
2
Lithography
is
a
planographic
method
of
printing;
that is,
the
printing
and
nonprinting
areas are
essentially
in
the
same
plane
on
the surface
of
a thin
metal
“lithographic”
plate.
The
distinction
between
the
areas
is
maintained
chemically;
when
the
lithographic
plate is
made,
the image
area
is rendered
water
repellent,
and
the nonimage
area
is
rendered
water
receptive.
In
offset
lithographic
printing,
ink
is
transferred
from
the
lithographic
plate
to
a
rubber-covered
“intermediate,”
or
“blanket,”
cylinder
and
then
to the
substrate.
Transfer
of
the
ink from
the
lithographic
plate
to the
blanket
cylinder,
rather
than
directly
to
the substrate,
is the offset
characteristic
of
this type
of printing.
A
printing
press
is made
up of
a
number
of
printing
units.
Printing
units
are
available
that
print
both sides
of the
substrate
at the
same
time
(a process
known
as perfecting),
as well
as only
one
side
(known
as
nonperfecting).
Offset
lithographic
printing
is also
characterized
by the
form in
which
the
material
to
be printed
on
— the substrate
— is
fed to
the
press.
In
sheet-fed
printing,
individual
sheets
of
paper
or other
substrate
are fed
to the
press.
In
web
printing,
continuous
rolls
of
paper
are
fed
to the press
and
the paper
is
cut to size
after
it is
printed.
Lithographic
inks are
composed
of
pigments,
vehicles,
binders,
and
other
additives.
The
pigments
provide
the
desired
color
and
are
composed
of
organic
and
inorganic
materials.
Lithographic
inks may
be
heatset,
where
heat is
required
to set the
ink,
or
non-heatset,
where
the
inks are
set by
absorption
into
the
substrate
by oxidation
or
other
methods
not
requiring
added
heat.
Heatset
inks
may
contain
up to 45
percent
VOMs.
Non-heatset
inks
have
higher
boiling
points
than
heatset
inks
and
are
less
pasty.
They
usually
contain
less
than 35
percent
VOMs.
Most
non-heatset
inks
used in
sheet-fed
printing
are
below
25
percent
VOM.
A
fountain
solution
is applied
to the
lithographic
plate
to
render
the nonimage
areas
unreceptive
to ink.
Since
printing
inks
are oil-based
and oil
is repelled
by
water,
the
fountain
solution
is water-based.
The
fountain
solution
contains
small
quantities
of gum
arabic
or synthetic
resins,
acids,
and buffer
salts
to maintain
the
pH
of
the solution,
and
a wetting
agent
or
“dampening
aid”
to enhance
the
spreadability
of
the fountain
solution
across
the
print
plate.
The
role of
the
dampening
aid
is to
reduce
the
surface
tension
of
water
as
well
as
increase
viscosity.
Isopropyl
alcohol
(IPA),
a
VOM,
had been
used
as the
primary
dampening
aid
since
the
195
Os. Ethanol
and
normal
propyl
alcohol
have
also
been
used
in
this
capacity.
Before
the
1
980s,
concentration
of
alcohol
in
the
fountain
solution
could
range
from
0
to
35 percent
or
higher,
with
most
presses
using between
15
and
20
percent.
However,
in more
recent
years,
printers
have
significantly reduced
3
fountain
solution
alcohol
contents
and
often
replaced
alcohol
completely
with
other
dampening
aids.
Indeed,
current
Illinois
rules
for
heatset
web
presses
in
the
NAAs
require
that
subj
ect
sources
use
no
more
than
1.6 percent
alcohol,
or 3
percent
if the
fountain
solution
is
refrigerated;
fountain
solutions
using
only
alcohol
substitutes
may
use
up
to 5
percent
VOM.
Non-heatset
web
presses
cannot
use
any
alcohol
and
are
subject
to the
same
5
percent
VOM
limit.
Sheet-fed
presses
are
limited
to 5
percent
VOM
content
or
8.5 percent
if the
fountain
solution
is
refrigerated.
Cleaning
solutions
are
used
to remove
excess
printing
inks,
oils,
and
paper
components
from
press
equipment.
The
solutions
are
petroleum-based
solvents,
often
mixed
with
detergent
and/or
water.
The
cleaning
compound
may
be a
single
solvent,
such
as
kerosene,
or
a
combination
of
solvents.
Cleaning
solutions
are
used
to
wash
the
blankets, the
rollers,
the
outside
of the
presses,
and
to
remove
excess
ink
residue
between
color
changes.
Some
cleaning
is
done
automatically,
while
other
cleaning
is
done
manually.
2.2
Letterpress
Printing
Letterpress
printing
involves
the
use
of
a reverse-imaged
raised
surface
that
is
inked
and
then
pressed
against
a
substrate
to transfer
the
image.
Letterpress
operations
make
up a
very
small
percentage
of
the
printing
industry
compared
to
other
types
of
printing
(lithographic,
flexographic,
rotogravure).
Indeed,
according
to
information from
the Illinois
EPA’s
source
inventory,
no
letterpress
printing
facility
could
be
found
in
the Metro-East
NAA,
with
very
few
of these
facilities
found
even
in the
Chicago
NAA.
Letterpress
inks
and
lithographic
inks
are
very
similar,
and
letterpress
operations
also
may be
accomplished
through
sheet-fed
and
web
presses.
Thus,
ink
emission
sources
are
similar
to those
described
above
for lithographic
printing.
Letterpress
operations
do
not
use fountain
solutions,
but
the
cleaning
solutions
are
once
again
similar
to
those
used
in lithographic
printing
operations.
2.3
Flexible Package
Printing
The
existing regulations
found
in
Sections
218/219.401-404
currently
cover
all
rotogravure
and
flexographic
printing.
The
modifications
being
proposed
in
this
rulemaking cover
both
types
of
printing,
but
only
as
they
apply
to
flexible
packaging.
Flexible
packaging
means
any
package
or
part
of a
package,
the shape
of
which
can be
readily
changed.
Flexible
packaging
includes,
but
is
not limited
to,
bags,
pouches,
liners,
and
wraps
utilizing
paper,
plastic,
film,
aluminum
foil,
metalized
or
coated
paper
or
film,
or any
combination
of
these
materials.
Shrink
wrap
labels
or
wrappers
(but
not
self-adhesive
labels)
printed
on
or in-line
with
a
flexible
packaging
printing
press
are
also considered
to be
flexible
packaging.
4
Flexible
packaging does
not include folding
cartons,
gift wraps, hot stamp
foils,
wall
coverings,
vinyl products,
decorative
laminates, floor coverings,
or
tissue
products.
Rotogravure
printing
uses an image
etched
or engraved
into a plate or
cylinder.
Inks,
coatings, and adhesives
may be
applied to a substrate
through the
rotogravure
process.
Flexographic printing
has an image
raised above the
level
of the printing
plate,
with
the image carrier
made
of rubber or
other
flexible
material. Flexographic
printing
is better suited to short
production
runs, in contrast to
rotogravure
printing, which
is more useful for long
runs.
VOM emissions
for both types
of printing
originate
from the drying
of inks as
well
as solvents used
to clean presses and
other components.
According to
the CTG for Flexible
Package
Printing,
the use of waterbased
inks is
increasing.
However, USEPA
also noted,
“Many
facilities
use
hundreds
of
different inks
to
print various
custom colors
required by their
packaging
customers.
Low
[VOM] inks, coatings,
and adhesives
may not be
available to
meet all of the performance
requirements.”
3
As such, most
VOM control
for flexible package
printing is achieved
through the
use
of add-on control devices.
In these
processes, most of
the solvent is captured
through evaporation
in a
dryer, along with hoods
and other collection
devices for
solvent that evaporates
elsewhere
in the printing process.
Older presses frequently
do
not
allow for the same level
of capture
as newer installations
do, but the
CTG
notes, “There
have been
significant
improvements
in capture efficiency
of
flexographic
presses
and
rotogravure
presses” since the last
time USEPA
reviewed
those types of operations.
It continues, “Since
1990, many
vendors have
guaranteed capture
efficiency of 85 to
90
percent without
use of a permanent
total
enclosure.”
Control
devices,
which
destroy or recover
the captured
solvents,
“can
achieve at least
95 percent control,”
according
to USEPA.
3
USEPA’s
recommended
approach
to reducing VOM
emissions
from
flexible
package
printing cleaning
materials focuses
on work practices,
“such as keeping
solvent containers
closed
except
when filling, draining
or conducting
cleaning
operations,
keeping
used shop towels
in closed containers,
and
conveying cleaning
materials
from
one location
to another in closed
containers
or
pipes.”
3
2.4
Industrial
Cleaning
Solvents
The
industrial cleaning
solvents category
encompasses
many
products
and
cleaning
styles
that are used to
clean dirt, soil,
oil, and grease as well
as remove
adhesives,
paints,
and inks. Studies done
by USEPA
on six focus industries
5
(automotive,
electrical
equipment,
magnetic
tape,
furniture,
packaging,
and
photographic
supplies) identified
nine
main
areas
where
emissions
of VOM
occurred
during
cleaning
processes.
These
nine
cleaning
categories
are
spray
gun
cleaning,
spray
booth
cleaning,
large
manufactured
components
cleaning,
parts
cleaning,
equipment
cleaning,
line
cleaning,
floor
cleaning,
tank
cleaning,
and
small
manufactured
components
cleaning.
The
majority
of
VOM
emissions
were
released
during
the
first
four
types
of
operations,
especially
the
spray
gun
cleaning,
which
made
up
50
percent
of emissions
by itself.
However,
it
should
be
noted
that
while
the
CTG
focused
on these
specific
areas,
it recommends
coverage
of a
wide
range
of
cleaning
activities
and
the
proposed
industrial
cleaning
regulation
follows
that recommendation.
VOM
emissions
occur
during
the
cleaning
process
while
wiping,
flushing,
brushing,
and
from
the
storage
and
disposal
of used
solvents
and
rags.
General
cleaning
of
offices,
bathrooms,
and
other
janitorial
type
services
are
not
covered
by
this
proposed
regulation.
2.5
Flat
Wood
Paneling
Coating
According
to the
CTG
for Flat
Wood
Paneling
Coatings,
“Flat
wood
paneling
products
are
used
in
construction
and
can
be
classified
as three
main
product
types:
decorative interior
panels,
exterior
siding,
and
tileboard.”
5
Decorative
interior
panels
are
often
embossed
and
usually
grooved,
having
more
decorative
coating
requirements
than
many
other
products.
Substrates
include
hardwood,
plywood,
medium
density
fiberboard,
and
particle
board.
Exterior
siding
may
be coated
at the
production
facility
or on-site
(the
latter
is
not
subject
to
this
proposed
regulation).
Exterior
trim
is
also
generally
manufactured
at
the
same
production
facility
and
coated
with
the
same
coatings.
Substrates
include
solid
wood,
hardboard,
and waferboard.
Tileboard
is used
in
high-moisture
areas
such
as
kitchens
and
bathrooms,
and
is
considered a premium
interior
wall
paneling.
Tileboard
meets
the
specifications
for
Class
I
hardboard
according
to
the American
National
Standards
Institute.
Flat
wood
paneling
products
are coated
to
provide
protection
from
the
environment, modify
the
surface,
and
present
a desired
appearance.
According
to the
CTG
for Flat
Wood
Paneling
Coatings,
“A typical
flat
wood
coating
facility
applies
stains
and varnishes
to
natural
plywood
panels
used
for
wall
coverings.
Other
plants
print
wood
grain
patterns
on
particle
board
panels
that
were
first
undercoated
with
an
opaque
coating
to
mask
the original
surface.
Coatings applied
to
flat wood
paneling
include
fillers,
sealers, ‘groove’
coats,
primers,
stains,
basecoats,
inks
and
topcoats.
Most
coatings
are
applied
by
direct
6
roll
coating.
Filler
is usually
applied
by
reverse
roll
coating.
The
offset
rotogravure
process
is
used
where
the coating
and
printing
operation
requires
precision
printing
techniques.
Other
coating
methods
include
spray
techniques,
brush coating
and curtain
coating.
A
typical
flat
wood
paneling
coating
line
includes
a
succession
of coating
operations.
Each
individual
operation
consists
of
the
application
of
one or
more
coatings
followed
by
a heated
oven
to cure
the
coatings.
A
typical
production
line
begins
with
mechanical
alterations
of
the
substrate
(filling
of
holes, cutting
of
grooves,
sanding,
etc.),
followed
by
the
coating
operations,
and
packaging/stacking
for
shipment.”
5
VOM
emissions
occur
primarily
during
the coating
process
as
the coatings
dry
and
cure,
but
also as
coatings
are applied,
and
during
mixing
before
application.
3.0
TECHNICAL
FEASIBILITY
OF CONTROLS
CTGs
for each
of
these categories
were
published
by
the
USEPA
in
September
2006.
Each
of
the CTGs
contain
information
about
add-on
controls,
process
modifications,
work
practices,
and material
reformulation
and
substitution
that
can
be
used
to accomplish
the
necessary
emission
reductions.
The
Illinois
EPA
depended
on the
CTGs,
as well
as
discussions
with
other
states
and industry,
in
developing
and implementing
the
proposed
regulations.
3.1
Lithographic
Printing
Add-On
Controls
Add-on
control
devices
are
applicable
only
to heatset
web
offset
lithographic
printing,
not non-heatset
or sheet-fed
lithographic
printing,
and can
be
grouped
into
two broad
categories:
combustion
control
devices
(destructive)
and
recovery
devices
(nondestructive).
Combustion control
devices
are
designed
to
destroy
VOMs
in the
vent
stream
prior
to
atmospheric
discharge;
recovery
devices
limit
VOM
emissions
by
recovering
material
for
reuse.
The
heatset
web
offset
lithographic
printing
industry
employs
three
basic
add-on
control
devices:
(1) thermal
afterburners,
(2)
catalytic
afterburners,
and
(3)
condenser
filter systems.
The experience
of the
Illinois
EPA
indicates
that
the
field
is
dominated
by
thermal
and catalytic
afterburners,
which
can
often
achieve
98
percent
or
greater
VOM
removal.
The
condenser
filter systems
currently
in use
have been
designed
specifically
for
the
heatset
web offset
printing
industry.
Condenser
filter
systems
can
achieve
as
high
as
97 percent
VOM
removal
efficiency,
with
90
percent
being
easily
achievable
for older
systems.
7
Fountain
Solution
Reformulation
and Process
Mod,fications
A
significant
portion
of
VOM
emissions
from lithographic
printing
can
be
ascribed
to evaporation
from
fountain
solutions.
Alcohol
substitutes
have
been
in
use
for over
20
years to
replace
or minimize
the
amount
of alcohol
used
in
a
fountain
solution.
These
substitutes
have
lower
volatility
than
alcohol
and
thus
reduce
emissions.
Process
modifications
are changes
in
operational
methods
or
equipment
resulting
in
improved
VOM
control.
Such
modifications
may
involve
retrofitting
existing
equipment
or replacing
older
equipment
with
new technology
to
accommodate
the
process
change.
However,
the illinois
EPA
does
not
expect
retrofitting
or
replacement
to
be an issue
with
this rulemaking.
Cooling
a fountain
solution
is one
process
modification
that reduces
VOM
emissions
from
the
fountain
solution
by minimizing
evaporation.
Refrigerated
circulators
can cool
the fountain
solution
to a
temperature
that
usually
ranges
between
55
and
60°F.
Refrigeration
has
been
shown
to reduce
consumption
of
alcohol
in
the
solution
by as
much
as 44
percent.
Material
Reformulation
or
Substitution
for
Cleaning
Solutions
As
with
fountain
solutions,
cleaning
solutions
can
also
be a
significant
source
of
VOM
emissions
from
the
overall
lithographic
printing
process.
To reduce
these
emissions,
cleaning
solutions
may
be
reformulated
in
one
of two ways.
Solutions
containing
a
smaller
amount
of VOM
may
be
used.
The
current
illinois
rule
limits
such
solutions
to no
more
than
30 percent
VOM.
While
no
problems
with
this
limit
have
been
reported
to
Agency
personnel
in
Illinois,
there
have
apparently
been
complaints
on
a
national
level.
As such,
the
CTG
now
recommends
limiting
such
solutions
to 70
percent
VOM.
2
The Illinois
EPA’s
proposed
regulation
contains
this
higher
limit
for
sources
between
15
and
100
pounds
per day
(PPD),
with
the
previous
limit
remaining
in
effect
for larger
sources.
In
addition,
an
alternative
to
low-VOM
cleaning
materials
are
solutions
with
a
low
vapor
pressure.
The
CTG
notes,
“Cleaning
materials
with
[VOM]
composite
vapor
pressure
less
than
10 millimeters
of mercury
(mm
Hg) at 20°C
have
been
used
successfully
by
many
printers
for blanket
washing
and
other cleaning
activities.”
2
It was
determined
by USEPA
prior to
Illinois’
promulgation
of the
previous
lithographic
printing
rule
that the
use
of cleaning
materials
with
a
VOM
composite
vapor
pressure
less
than
10
mm Hg
at
20°C
would
result
in a
comparable
emission
reduction
to
using cleaning
materials
that
contain
less
than
30
weight
percent
VOM.
Once
again,
the Agency
believes
that
currently-subject
sources
are
using
materials
that
meet
this
limit
without
problems.
As
such,
this
limit
is
not being
changed;
it will
just
apply
to
smaller
sources
as well.
8
3.2
Letterpress
Printing
Letterpress
emission
sources
are
similar
to those
for
lithographic
printing,
with
the
exception
that
letterpress
operations
do
not use
a
fountain
solution.
In addition,
letterpress
printing
presses
are often
operated
at the same
source
as
lithographic
printing
and
many of
the control
options
for letterpress
printing
are
the same
as
the
control
options
for
lithographic
printing
as well.
This
is
especially
true
in
terms
of cleaning
solutions,
though.
Because
letterpress
operations
have
never
been
specifically
regulated
in Illinois
before,
the Agency
is
proposing
to
use the
70 percent
VOM
content
limit
for
all
subject
letterpress
units.
It is
the
Agency’s
belief,
supported
by
conversations
with
industry
representatives,
that
Illinois
does
not currently
contain
any
heatset
web
letterpress
operations
in
either
the
Chicago
or
Metro-East
NAA,
but
the
regulation
is
necessary
and
technically
feasible
should
a new
such
operation
locate
into
one
of the
NAAs.
3.3
Flexible
Packaging
Printing
Similar
to
the
types
of printing
discussed
above,
the
two main
sources
of VOM
emissions
from
flexible
package
printing
are
the evaporation
of
inks,
coatings,
and
adhesives,
as
well as
the
use
of
cleaning
materials.
These
VOM
emissions
may be
controlled
by
material
reformulation
or,
especially
in
the case
of
ink
emissions,
through
the
use
of
add-on
controls.
Material
Reformulation
This
approach,
similar
to
that described
above,
focuses
on
the substitution
of low—
VOM
inks,
coatings,
and adhesives.
According
to
the
CTG, such
reformulation
“has
been
achieved
by
many
facilities
in
the packaging
rotogravure
and
flexographic
printing
industries.”
3
Whether
a particular
facility
is able
to
use
such
reformulated
materials
depends
upon
their
specific
activities,
including
the
substrate(s)
being
used.
Add-On
Controls
Add-on
controls,
however,
may
be
used
by all
such printers.
The most
common
control
devices
used
by
these
sources
are thermal
oxidizers,
catalytic
oxidizers,
and
carbon
adsorbers,
with
adsorbers
probably
being
the
least-used
of the
three.
As
the
CTG
notes,
“Today,
these
control
devices
can achieve
at
least
95
percent
control
device
efficiency.”
3
Capture
systems
have
evolved
over
the years.
These
systems
collect
the VOM
containing
air so
it may
be destroyed
or
reclaimed
by
the
control
device
described
above.
While
new
presses
may
be
able to
obtain
as
high
as 100
percent
capture
if
designed
properly,
older
presses
were
not necessarily
constructed
with emissions
9
capture
in mind.
As
such,
the
Agency
is proposing
a
tiered
approach
to capture
and
control
in this
rulemaking.
Work Practices
for
Cleaning
Materials
The CTG
recommends
work
practice
requirements
as the
best
means
to control
emissions
from cleaning
operations
at
flexible package
printing
sources.
In
particular,
the
document
says
these
practices
should
include
“keeping
solvent
containers
closed
except
when filling,
draining
or conducting
cleaning
operations,
keeping
used
shop
towels
in closed containers,
and
conveying
cleaning
materials
from one
location to
another
in
closed
containers
or pipes.”
3
3.4
Industrial
Cleaning
Solvents
The industrial
cleaning
solvents
proposed
regulation
covers
a
wide
range
of
products
that
remove
contaminants
from
parts, products,
tools,
machinery,
and
other work
production
areas.
The
nine
main cleaning
categories
mentioned
in
Section
2.4,
above,
use a multitude
of
different solvents
with
different
styles of
applications.
VOM emission
reductions
can be attained
by
work
practices,
solvent
substitution,
and
controls.
The
CTG
recommends
that
sources
exceeding
15 lbs/day
of VOM emissions
from
the
cleaning
category
must comply
with
the following
requirements.
4
The
proposed
regulation
follows
this suggestion.
Work Practices
Reductions
can be
obtained
through
solvent
management
practices.
General work
practices
include
keeping
solvent
containers
and
used
applicators
covered;
properly
storing and
disposing
of
spent
solvents
and used
cleaning
rags;
minimizing
air circulation
around
all cleaning
operations;
and
implementing
equipment
practices
that reduce
emissions,
e.g.,
leak detection
and
repair
practices.
VOM
Content
Limits
Solvent
substitution
to
a low-VOM
or no-VOM
solvent
can
also
reduce
emissions.
The
CTG recommends
a
content limit
of
50 grams VOM
per liter
(0.42
lb/gal)
of cleaning
material
for those
industries
that
are not already
covered,
or to be
covered,
by
a CTG,
as listed
in
Section
218.187(a)(2)(B).
4
However,
discussions
with
industry, other
states,
and
USEPA
led
to
the addition
of
a
number
of
exemptions
and
higher
VOM
content
limits
for
certain
specific
cleaning
activities.
10
Higher
limits
have
been
considered
for
categories
that
may
not be
able
to
easily
meet
this
limit, based
on
recommendations
from
industry
as
well as
from other
states.
These
higher
limits
are
outlined
within
the
rule.
Alternate
Vapor
Pressure
Limit
Low
vapor
pressure
solvents
are
also
recommended
since
the
slower
evaporation
reduces
the
amount
of VOM
released
into
the atmosphere.
The
CTG
recommends
that a limit
of
8 mm
Hg
at 20
degrees
Celsius
be allowed
in
place
of
the 50
gram
VOM
per
liter
of
cleaning
material,
and
the
proposed
regulation
follows
this
recommendation.
Alternate
Control
Emissions
can
also be
reduced
by add-on
controls,
modifying
equipment,
or
changing
the method
of
cleaning.
The
CTG recommends
an
overall
control
efficiency
of
85 percent
reduction
in
emissions
of
VOM,
which
is reflected
in
the
proposed
rule.
Exclusions
As
noted
above,
the CTG
suggests
excluding
certain
categories
from
the
cleaning
regulations,
as these
categories
already
have
or will
have
their
own recommended
work
practices
and limitations.
These
categories
include
coating
operations
for
aerospace,
wood furniture,
flat wood
paneling,
large appliance,
metal
furniture,
plastic
parts,
paper
film
and
foil, miscellaneous
metal
parts,
auto
and
light-duty
truck
assembly,
and
shipbuilding
and repair;
flexible
packaging
printing
materials;
lithographic
printing
materials;
letterpress
printing
materials;
fiberglass
boat
manufacturing
materials;
and
miscellaneous
industrial
adhesives.
Other
categories
with
specific
exemptions
have
also
been
suggested
by
the
CTG
as
well
as
by
discussions
with industry
groups.
These
include
electrical
and
electronic
components; precision
optics;
numismatic
dies;
stripping
of
cured
inks,
coatings,
and
adhesives;
cleaning
of
resin,
coating,
ink,
and adhesive
mixing,
molding,
and
application
equipment;
research
and
development
laboratories;
medical
device
or
pharmaceutical
manufacturing;
and
performance
or
quality
assurance
testing
of
coatings,
inks,
or
adhesives.
Further
exclusion
recommendations
include
cleaning
of
paper-based
gaskets
and
clutch
assemblies;
cleaning
of
adhesive
application
equipment
used
for
thin metal
laminating;
touch-up
cleaning
on
circuit
boards;
cleaning
of
coating
and
adhesive
application
processes
utilized
to
manufacture
transdennal
drug
delivery
product
using
less
than
three
gallons
per
day
of
ethyl
acetate;
cleaning
of
application
equipment
used to
apply
coatings
on satellites
and
radiation
effect
coatings;
cleaning
of application
equipment
used
to
apply solvent-borne
fluoropolymer
11
coatings;
cleaning
of
ultraviolet
or electron
beam
adhesive
application;
and
cleaning
of
electrical
cables.
3.5
Flat
Wood
Paneling
Coatings
Flat wood
paneling
coating,
like
other forms
of
industrial
coating,
provides
two
options
for controlling
VOM
emissions:
reformulation
or
add-on
controls.
Material
Reformulation
Reformulation
would
entail
sources
changing
from
high-VOM
coatings
to
low
VOM
materials.
According
to the
CTG, low-VOM, water-based
coatings
“are
generally
available”
and
“can
lower
[VOM]
emissions
greatly,
and
most
coatings
operations
are
capable
of
converting
to
waterborne
coatings.”
5
Another
option
for
reformulation
is the
use of
coatings
that
emit almost
zero
VOM
and
are
cured
through
the
use of
ultraviolet
light
or
an electron
beam.
The
use
of such
systems
are
more
limited
than
those
for
waterbased
coatings,
but
they
are
available.
Add-On
Controls
Add-on
controls
for
flat
wood
paneling
coating
can
be
used
when
the
source
needs,
or chooses,
to
use
high-VOM
coatings.
The
CTG
notes,
“Currently,
an
overall
control
and
capture
efficiency
of 90
percent
is a
widely-accepted
and
readily
available
technique.”
5
illinois
EPA
agrees,
based
on
its experience
with a
variety
of coating
operations.
Work
Practices
for Coatings
and Cleaning
Materials
The
CTG
recommends
specific
work
practice
requirements
for
flat
wood
paneling
coating
operations:
“storing
all
[VOM]
coatings,
thinners,
and
cleaning
materials
in close
containers,
minimizing
spills
of
[VOM]
containing
coatings,
thinners,
cleaning
up
spills
immediately,
conveying
any
coatings,
thinners,
and cleaning
materials
in
closed
containers
or
pipes,
closing
mixing
vessels
which
contain
[VOM]
coatings
and
other
materials
except
when
specifically
in
use,
and
minimizing
emissions
of [VOM]
during
cleaning
of
storage,
mixing,
and
conveying
equipment.”
5
Some
of these
requirements
are
already
in place
within
Illinois
regulations
for
wood
furniture
coaters.
Under the
Agency’s
proposal,
these
will
apply
to
flat
wood
paneling
coaters
as well,
and
other
specific
requirements
listed
above
will
apply
as well.
These
will
minimize
unnecessary
VOM
emissions
from such
operations.
12
4.0
ECONOMIC
REASONABLENESS
4.1
Lithographic
Printing
The
largest
cost
factor
for
lithographic
printing
— add-on
control
devices
— is
applicable
to
heatset
web
lithographic
operations
only.
Since
the
Agency’s
proposal
does
not
increase
the
number
of sources
for which
this
requirement
is
applicable,
there
is no foreseen
additional
cost
due to
add-on
controls
for
existing
sources.
New
sources
will need
to
achieve
a higher
control
efficiency,
but
since
new
add-on
control
devices
would
already
be expected
to
achieve
that
efficiency,
no additional
cost
is expected
for this
reason
either.
Fountain
solution
and
cleaning
solution
reformulation
costs
could
occur
for
newly-regulated
sources
between
15 and
100
PPD of
emissions
under
this
proposal.
USEPA
estimated
the cost
for cleaning
material
reformulation
at
$855
per
ton of VOM
removed
(in
2005
dollars).
2
For
fountain
solutions,
USEPA
actually
estimated
a
cost
savings
due
to a
reduction
in the use
of
alcohol.
While
they did
not provide
a
specific
value
for
the
savings,
the
TSD
for
the
Illinois
lithographic
printing
rule
in
1994 put
this
savings
at
$920
per
ton
(while
alcohol
substitutes
are
more
expensive,
the
cost
is reduced
because
they
are
used in
lower
quantities).
6
4.2
Letterpress
Printing
As
previously
noted,
letterpress
printing
shares
a
great deal
in common
with
lithographic
printing
when
it comes
to
emissions
and
the
applicable
controls.
As
the
CTG notes,
“Because
of the similarities
between
offset
lithographic
printing
and
letterpress
printing
in terms
of the
nature
of the
processes
at
issue,
the
sources
of
[VOM]
emissions
and available
control
approaches,
it
is
reasonable
to
assume
that
the cost-effectiveness
estimates
... for control
of [VOM]
from
heatset
inks
and
control
of
[VOM]
from
cleaning
materials
apply equally
to the
letterpress
printing
industry.”
2
The difference
is that
there
is not currently
a regulation
for heatset
web
letterpress
printing
operations
in Illinois.
As such,
the reasoning
behind
the
zero cost
estimate
for
heatset
web
lithographic
printing
cannot
be
used
for
letterpress
operations.
Thus,
referring
to
the CTG,
USEPA’s
cost estimate
is
$2,010
per ton
of
VOM removed
(in
2005
dollars).
However,
as noted
earlier,
the
Agency
believes
that
the Illinois
NAAs
do
not currently
contain
any
heatset
web
letterpress
operations.
13
4.3
Flexible
Packaging
Printing
According
to the CTG,
“Many facilities
located
in ozone nonattainment
areas are
already
meeting the control
levels
being
recommended
in this CTG.”3
Indeed, this
proposal
does not
expand
the number
of sources that will
be subject to the ink
or
control device
portions
of the flexible
packaging rotogravure
and flexographic
printing regulations.
It
is
expected
that those
sources
currently able
to use
compliant inks and
coatings will
similarly
be
able to make use of
inks and
coatings meeting the
new
compliance
limit,
while those using
add-on
control
devices
will continue
to do so as well.
As such, the Illinois
EPA expects that
there
will not
be any additional add-on
control
costs
for
subject facilities.
In
the case of any sources
not already
meeting
the
proposed
standards
and needing
to put on
an add-on control
device, the
CTG says, “The costs
... will vary
depending
on the
flow rate, hourly
solvent
use
rate, and operating
hours.” USEPA
made
reasonable
estimates
to determine
the cost effectiveness,
and determined
that “a
press exhausting approximately
5,800 cubic feet per minute,
operating
2000 hours per
year, and
achieving
70
percent
capture
efficiency”
would have a
cost
of between
$1,300
and
$2,800 per ton of VOM
removed.3A source
with a
larger
press, higher solvent
use
rate,
more operating hours,
or better capture
efficiency
would have
an even lower cost
per ton of VOM
removed.
Costs associated with
additional
sources
becoming subject
to the cleaning
provisions
of this proposed
regulation
are
expected to
be
minimal.
Indeed,
some
sources may
see an
overall
cost
savings
as less cleaning solution
is necessary.
4.4
Industrial
Cleaning
Solvents
USEPA estimated
that there
would
be
130 sources in
Illinois
NAAs that would
be
impacted
by this regulation,
with
a total
of 2293 Mg/yr (2528
tons/yr)
of
baseline
VOM emissions
per year
by
using
the
2002 Nation
Emissions Inventory
database.
USEPA
then determined
the
cost
effectiveness
of meeting
the 50 grams
of VOM
per liter of
cleaning material
limit for a parts
cleaner
at
$1664/ton
based
on a
study provided
by
the California
Bay Area Air Quality
Management
District.
Costs
associated
with switching
from
high-VOM
content
solvents
to low-VOM
content
or
aqueous
solvents
may show
an actual
cost
savings
of $1460/Mg
($1325/ton)
when taking
in consideration
the reduction of
disposal costs,
according
to the CTG.
4.5
Flat Wood
Paneling
Coatings
USEPA
based their
cost estimate on
information
obtained from the South
Coast
Air
Quality
Management
District
in
California,
arriving
at
a
cost of between
$1,900
and
$2,600 per ton of VOM
reduced
(in 2005
dollars).
According
to the
14
CTG,
for
any
sources subject
to this
rule
in Illinois,
costs “could
be
incurred
to
make
changes to
their
coatings
in order
to meet”
the new
regulation.
5
Thus, the
only
significant
cost
is
expected
to
be reformulation
of coatings.
5.0
EXISTING
AND
PROPOSED
STANDARDS
5.1
Lithographic
Printing
Currently,
Illinois
has
regulations
covering
all types
of
lithographic
printing
in the
NAAs,
with
an applicability
level
of 100
PPD (calculated
monthly).
In addition,
there is
a secondary
applicability
level
of 100
tons per year
of
maximum
theoretical
emissions
for heatset
web lithographic
printing,
which
was carried
over
from
the previous
rule.
The
Agency
is proposing
removing
the
100-ton
limit,
as
it
is no
longer
necessary
and
USEPA
has
agreed that
removing
it will not
cause
a
backsliding
concern.
This new proposal
does
not
reduce the
applicability
threshold
for add-on
control
devices
used by
heatset
presses.
Thus, no new
lithographic
printing
units will
need
to add
controls.
However,
new control
devices
on
heatset web
lithographic
presses
will
need
to
meet a
95 percent
control efficiency
instead of
the
current
90 percent
limit.
The Agency
believes
that
control
devices
in existence
today
can meet
the
95
percent
limit, but
at
the
request of
printing industry
representatives,
the Agency
has agreed
to not ask
existing
sources to
meet the
higher control
efficiency.
The
proposal
does
provide
a new applicability
threshold
of 15
PPD for
fountain
solution
and
cleaning
solution
requirements
for all lithographic
printing
operations.
The
requirements
are the
same as
are already
present in
the Illinois
regulations,
other
than a correction
to the
fountain
solution limits
that changes
their
measurement
from
“by volume”
to “by
weight.”
USEPA has
informed
Illinois
EPA
that the
limit
should be
weight-based,
and the
change will
slightly
loosen
the standard
for
sources,
if
anything.
The Illinois
EPA
has
not encountered
any
sources
with
problems complying
with the
fountain
solution,
cleaning
solution,
recordkeeping,
reporting,
or material
handling
portions
of the
existing
rule,
and
no
such
issues are
expected
when lowering
the
applicability
threshold.
Sources
between
15 and
100 PPD
will
be able
to take advantage
of
several
new
exclusions
pertaining
to fountain
and cleaning
solutions.
Sheet-fed
presses
that
print
substrates
no larger
than 11
inches
by
17 inches
and
any
lithographic
press
with
a
fountain
solution reservoir
of
no larger than
one gallon
are not
required
to
comply
with
the fountain
solution
requirements.
As
described
above,
all sources
in
this
group will
also need
to meet
only a 70
percent
VOM
content
limit
in
cleaning
solutions
rather than
the
30 percent
limit
that is applicable
to
sources
over 100
PPD.
All
such
sources
will also be
able
to use
up
to
110
gallons
of
cleaning
solution per
year
that
do
not meet
either
the VOM
content or
vapor
15
pressure
requirements.
These
exclusions
will
ease any
potential
burden
on
the
smallest
sources
affected
by
this
rule.
Sources
which
fall
below
one of
the
applicability
limits,
and
are
thus exempt
from
one or
more control
requirements,
must
certify
this
exemption
to
Illinois
EPA
through
calculations
showing
that
their
emissions
will
not
exceed
the applicable
VOM
threshold.
These
calculations
must
include
all
VOM
emissions,
including
inks,
fountain
solution,
and cleaning
solvents,
and
are
determined
on
a monthly
basis.
It
should
be noted
that
the current
regulation
recognizes
that
the substrate
retains
some
of the
VOM
present
in the
ink,
and
thus a
retention
factor
of
0.95 is
used
when
calculating
emissions
from
non-heatset
inks,
and
a
factor
of 0.20
is used
when
calculating
emissions
from heatset
inks.
In addition,
it contains
a factor
recognizing
that
VOM remains
on
solvent-laden
rags
that are
stored
and disposed
of
properly.
These factors
continue
to
be allowed
for determination
of
applicability.
In
addition,
this
proposal
adds
emission
adjustment
factors
to
be
used
in other
situations
when
not determining
applicability
(such
as
Annual
Emissions
Reports
and
permit
limits).
These
factors
take
into account
carryover
of
VOM
from automatic
blanket
wash
and
fountain
solutions
into the
dryer
and
control
device.
All of
these
factors
may
be
found
in
the CTG.
2
Because
of the
new
exclusions
that apply
only
between
15
and 100
PPD,
even
subject
sources
in this
group
must
continue
to
calculate
emissions
to ensure
they
do
not
exceed
the
100
PPD threshold
and
lose
the
exclusions.
Sources
may
opt
out
of
the
exclusions
if
they do
not wish
to make
use
of them,
and
thus would
not
need
to
calculate
emissions
in
this
fashion.
5.2
Letterpress
Printing
There
are currently
no
specific
Illinois
regulations
covering
letterpress
printing
operations;
any
such
operations
would therefore
be
covered
by Subpart
TT,
Section
2
18/219.301,
or
paper
coating
regulations.
The
new proposal
addresses
both
heatset
and non-heatset
letterpress
operations.
This
proposal
would
require
that
heatset
letterpress
printers
use
an
add-on
control
device
if they
meet
the applicability
requirement
of 25
TPY
PTE
plantwide.
However,
as
noted
earlier,
the
Agency
believes
there
are no
such
operations
in
Illinois
NAAs.
All
letterpress
printing
operations
of 15
PPD
or
more
will
be
also
required
to
abide
by
cleaning
material
limitations
equivalent
to
those
described
above
for
lithographic
sources
between
15
and
100 PPD.
That
is,
cleaning
solutions
will
be
required
to
contain
no
more
than
70
percent
VOM
or
have
a
maximum
composite
partial
vapor
pressure
of
less than
10
mm Hg.
16
5.3
Flexible
Packaging
Printing
Currently,
Illinois
rules cover
all
flexographic,
packaging
rotogravure,
and
publication
rotogravure
printing.
All
ink
limits
for these
different
types
of
printing
are
identical,
with
the
only difference
found
in
the
add-on
control
requirements
—
flexographic
printers
are
required
to
get
60
percent
overall
VOM
reduction,
packaging
rotogravure
are
required
to
get 65
percent
overall
reduction,
and
publication
rotogravure
must
achieve
75
percent
overall
reduction.
The
new proposal
separates
out
flexible
package
printing
from
the
existing
flexographic
and
rotogravure
regulations.
Thus,
any flexographic
or
rotogravure
operation
that
is not printing
on flexible
packaging
will not
see a
change
to
the
applicable
regulations.
Sources
that
print
on flexible
packaging
will
need
to
meet
either a
tightened
ink
VOM
content
or add-on
control
requirement.
The
required
control
efficiency
will
depend
on
both
the date
of construction,
at
the source,
of
the press
and the
control
device.
This
recognizes
that
presses
and
control
devices
already
installed
at
the
source
might
not
have
been
designed
to
obtain
capture
and
control
efficiencies
as
high
as
are currently
obtainable.
5.4
Industrial
Cleaning
Solvents
Illinois
has
current
regulations
for cold
cleaning
degreasing,
open
top
vapor
degreasing,
and conveyorized
degreasing operations
as
well as
some limitations
and
work
practices
on
cleaning
solvent
uses
in existing
rules,
e.g.,
regulations
regarding
autobody
refinishing,
wood
furniture
coating,
and lithographic
printing.
This
new
rule
sets limitations
based
on
an
applicability
of
15 lbs/day
of
actual
VOM
emissions
from cleaning
operations.
Once
applicable,
the source
will
need
to
follow
the
work practice
standards
discussed
in Section
3.4,
above,
and
either
comply
with
a VOM
content
limitation
of
the
cleaning
solutions,
use a
low
vapor
pressure
cleaning
solution,
or
utilize
an
emissions
control
system
that
provides
85
percent
overall
control
of VOM
emissions
from
cleaning
activities.
5.5
Flat
Wood
Paneling
Coatings
There
are currently
no
specific
Illinois
regulations
covering
flat
wood paneling
coating
operations;
any
such
operations
would
therefore
be
covered
by
Subpart
TT,
Section
218/219.301,
or
potentially
wood
furniture
coating,
depending
on
whether
the
operations
fell
into the
definition
related
to
that
process.
The
new
proposal
will
add coating
VOM
requirements
and
work
practice
requirements
for
both
coatings
and associated
cleaning
operations.
As
with
other
coating
categories,
there is
also an
option
available
to use
add-on
control
instead
17
of
compliant coatings;
however,
the
flat wood
paneling
coating
category
will
require
an
overall
control
of 90
percent
rather
than
the
81
percent
overall
control
required
for
existing
coating
categories.
The work
practice
requirements
include
several
that
are
already
required
for
wood
furniture
coaters,
which
have
been
accomplished
without
any
problems
known
to
the
Agency.
In
addition,
other
common
sense
requirements
are being
added,
including minimizing
spills
of
VOM-containing
materials,
minimizing
VOM
emissions
during
cleaning,
and
closing
mixing
vessels
except
when
they
are
in
use.
6.0
AFFECTED
SOURCES
AND
EMISSION
REDUCTIONS
6.1
Lithographic Printing
The
Agency
does
not
expect
any
additional
reductions
from
increasing
the
required
control
efficiency for
heatset
web
lithographic
printers
from
90
to 95
percent,
because
that
change
will
not
affect
existing
control
devices.
However,
there
will
be
some
small
VOM
reductions
related
to
the
addition
of
fountain
and
cleaning
solution
requirements
for sources
with
15 PPD
or more
of
emissions.
It
is
difficult
to
estimate
such
reductions
because
the
Illinois
source
inventory
does
not track
information
such
as the
number
of
gallons
of
cleaning
solution
used,
the
size
of sheet-fed
presses,
or the
fountain
solution
reservoir
volume
—
as such,
sources
that
may
be
excluded
from
requirements
are
not
identifiable.
The
Agency
found
a total
of 98
lithographic
printing
sources
in
the
Chicago
NAA
and
three
in the
Metro-East
NAA
that
have
lithographic
printing
emissions
over
15
PPD,
according
to the
Bureau
of Air’s
2005
source
inventory
(modified
for
sources
that
have
shut
down
since
that
time).
In
the Chicago
NAA,
66
of
the
sources
are
below
100
PPD,
and
thus
are
potentially
impacted
by this
rulemaking
(two
more
are
over
99
PPD
and
are
assumed
to
be already
complying
with
the
existing
lithographic
printing
regulations). In
the
Metro-East
NAA,
all
three
sources
are
below
100
PPD.
The
Agency
is
conservatively
judging
that
all
of
the
sources
listed
may
be
impacted,
but
it
is likely
that
some
of
them
are
already
considered
subject,
as the
daily
emission
rate
in
the inventory
is
an
average
estimate,
while
sources
may
have
exceeded 100 PPD
at
some
previous
point.
The
Agency
has
tried
to
account
for
sources
that
are already
controlled,
as the
100
PPD
applicability
limit
applies
to
uncontrolled emissions.
(See
Appendix
B
for
the
list of
these
potentially
affected
sources.)
18
For the
sources that apparently
would
be
affected
by
this
proposed
regulation,
the
Illinois EPA
reviewed its
inventory
in an attempt
to estimate potential
emission
reductions
from fountain solution
reformulation.
The recent
lithographic
printing
CTG does not contain
enough
specific information
to usefully
estimate
such
reductions,
but refers
back
to the
1993
draft
CTG
on
this
source
category.
7
Using
the information
and
model plants
therein, Illinois
EPA determined
that fountain
solution
emission reductions
would be estimated
at between
25%
and 90% for
smaller sources.
As
this
draft
CTG is 16
years
old and
the new CTG indicates
that
steps
have
been
taken to reduce
VOM content
in fountain solutions,
the Illinois
EPA
used the 25% figure
in calculating
reductions.
Cleaning
solutions
can
be calculated
as
a straight
30%
reduction,
since the
regulation
requires
reformulation such
that they cannot
contain more
than 70%
VOM.
As noted
above, the Illinois
EPA inventory
does not necessarily
specify,
for each
source, which emissions
result
from cleaning
and which
are
from fountain
solutions.
However,
using the
model
plants from the
1993 draft CTG
as a guide, it
appears that
cleaning solution
emissions
at smaller
plants
make up a lower
percentage
of
emissions compared
to fountain
solutions, ranging
up to
approximately
50% at
certain
facilities.
Assuming
that almost
50% of non-ink
emissions
come from
cleaning
solutions, which
have
30%
reduction,
it
is safe to
use a
25%
overall
emission reduction
to cover
all VOM originating
from the
source.
The
total
VOM
emissions
from
the 66 Chicago NAA
sources
are 1.455 tons per
day. Thus,
a
25% overall
reduction
equates to 0.36 tons
per day of VOM.
The
total VOM emissions
from the
three
Metro-East
NAA sources
is 0.0295 tons per
day. A
25% overall
reduction would
provide 0.007 tons
per
day.
6.2
Letterpress
Printing
As noted
earlier, the
Agency
does
not believe there are
currently any
heatset
web
letterpress
printing
operations
in
the
NAAs.
As such,
no emissions reductions
are
expected
from add-on
controls
for this category.
According to a
search of the Bureau
of Air’s
2005 source inventory,
there are two
sources
in the
Chicago
NAA, and
none in the Metro-East
NAA, making
use of
letterpress printing
(see Appendix
B). Only
one of these
sources appears to
emit
more
than 15
PPD from such
operations, with less
than
0.02 TPD
of VOM,
including
emissions
from
the
letterpress
as well as other
printing operations.
Even
if all of
the emissions
originated
from letterpress
cleaning
solutions,
which are
to
be reduced
by
30 percent,
the resulting
reduction
would
be 0.005
TPD. As such,
the Illinois EPA
expects
negligible
emission
reductions overall
from
the
implementation
of this
regulation.
19
6.3
Flexible
Packaging
Printing
It
is difficult to
estimate
emission
reductions
for
the
flexible packaging
printing
category,
as
the
Illinois
source
database
does
not
generally
specify
the
type
of
substrate
being
used
by
a
flexographic
or
rotogravure
printing
operation,
nor
does
it
specify
the
date
of
original
installation
of the
printing
press
or
the
associated
control
device.
As
such,
all
existing
flexographic
and
rotogravure
printing
facilities
identified
as
such
in
the
Illinois
inventory
and
exceeding
the
proposed
applicability
threshold
are
listed
in
Appendix
B
as
potentially
affected
sources.
However, the
Illinois
inventory
indicates
that
all
sources
but
one
using
flexographic
or
rotogravure
printing
of any
type
are
already
achieving
greater
control
efficiency
than
required
by
the
proposed
regulation.
The
remaining
source
(identified
with
an
asterisk
in Appendix
B)
is required
by
its
permit
to achieve
60
percent
control
efficiency,
but
will
now
need
to
achieve
65
percent.
This
change
would
equate
to
a 0.03
TPD
reduction
according
to
its
permitted
emissions,
but
a
0.01
TPD
reduction according
to emissions
information
in
the
inventory.
While
the
inventory
does
not
provide
information
regarding
the
use of
compliant
inks,
it
has been
the
Agency’s
experience
that
sources
printing
on
flexible
packaging
have
had
difficulty
with
the
use
of compliant
VOM
inks
on
such
substrates.
Sources
either
relied
on
add-on
controls
or switched to
waterbased
inks
that
should
meet
the
newly
proposed
requirements
as
well
as
the
existing
ones.
As
such,
negligible
emission
reductions
are
expected
from
the
new
ink
limits.
The
cleaning
materials
work
practice
standards
being
proposed
do
not
lend
themselves
to
a calculation
of
emission
reductions.
The
Agency
believes
that
the
environment
will
see
actual
VOM
emission
reductions
due
to
the
storing
of
cleaning
materials
and
used
shop
towels
in
closed
containers,
as
well
as
conveying
cleaning
materials
in closed
containers
or pipes,
but
calculation
of such
emission
reductions
cannot
be
accomplished
without
detailed
information
from
every
affected
source
—
both
before
and
after
such
changes
are
made.
6.4
Industrial
Cleaning Solvents
USEPA
estimated
that
there
are
130
sources
in
the
impacted
areas
that
have
emissions
over
15 PPD
in
Illinois.
These
sources
are
estimated
to
have
baseline
emissions
of
2293
Mg/yr
(2528
TPY)
of VOM
as mentioned
previously
and
include
degreasing
operations
that
are
already
impacted
by
existing
state
regulations that
will
not
gain
any
further
reductions.
It
is not
reasonably
practicable
to
estimate
emission
reductions
for
the
other
impacted sources
under
the
industrial
clean-up
solvent
rule,
as
any
source
in
either
20
NAAs that
uses cleaning
solvents is
potentially affected,
depending upon
the
source’s usage
level. Further,
many different
types of sources
throughout the
NAAs
may
use different
types
of cleaning
solutions
and
may
already be using
compliant solutions.
For these
reasons,
Appendix
B does
not list specific
sources
that are
potentially
impacted by this
rulemaking.
As discussed
above, the Agency
believes
that the
environment
will see actual
VOM emission
reductions
due to these
proposed regulations,
but calculation of
such
emission reductions
cannot
be
accomplished
without
detailed
information
from
every
affected source.
6.5
Flat Wood
Paneling
Coatings
A search of the
Bureau
of Air’s
2005 source
inventory indicated
four sources that
will
likely
be subject to
the proposed
flat wood
paneling
coating regulation
in the
Chicago NAA,
and none
in the Metro-East
NAA. One of
these four sources would
appear to fall below
the proposed
applicability
threshold. The other
three total
0.09 TPD
of VOM emissions.
According
to the CTG,
VOM emissions were
reduced an average
of 60 percent
for
interior
paneling
and tileboard
manufacturing.
This description
seems to fit the
Illinois
NAA
sources best. As
such,
Illinois EPA estimates
a
VOM
reduction of
0.05 TPD in the Chicago
NAA
and no
reductions
in the
Metro-East NAA.
7.0
OTHER STATES’
STANDARDS
7.1
Lithographic
Printing
Appendix B of the
CTG for Lithographic
and
Letterpress Printing
contains a list
of state
standards
for
lithographic printing
across the
country. Rather than
reproduce the
entire list
here,
the
reader is referred
to that list.
2
A key point to note
is
that all states with ozone
NAAs will
need to implement
the same Group
II
CTGs as
Illinois is implementing
with
this rulemaking.
7.2
Letterpress
Printing
Appendix
C of
the
CTG
for Lithographic and
Letterpress
Printing contains a
list
of
state standards
for letterpress
printing across
the country. Rather
than
reproduce
the
entire
list here,
the reader is referred
to
that list.
2
A key point to note
is
that
all
states
with ozone
NAAs
will
need to
implement
the same Group
II CTGs
as
Illinois is implementing
with
this
rulemaking.
7.3
Flexible
Packaging
Printing
Section
V of the
CTG for Flexible
Package
Printing contains
a list of state
standards
for flexible
package printing
across the country.
Rather than
reproduce
21
the entire list
here,
the reader
is
referred to
that list.
3
A key point
to
note is that
all
states with
ozone
NAAs
will
need
to implement
the
same Group
II CTGs
as
Illinois
is
implementing
with this
rulemaking.
7.4
Industrial
Cleaning
Solvents
The
CTG
for
Industrial
Cleaning
Solvents
contains
some
information
on other
state standards
throughout
the
document.
4
Besides
those rules,
of particular
note
are
regulations
in
California
—
South Coast,
Bay Area,
and
San
Joaquin
Valley —
as
well as Wisconsin
and
a
proposed
regulation
in Ohio,
from
which Illinois
obtained
most of
its
proposed
limits for
activities
that have
a
limit
different
from
the basic
one
suggested
in the
CTG.
Appendix
A contains
a table
(originally
provided
by Ohio
and modified
to include
proposed
Illinois limits)
that is
a
comparison
of
Illinois’ proposed
limits
with the
above
areas’
limits.
7.5
Flat
Wood
Paneling
Coatings
Section
V and
Appendix
B of the
CTG
for
Flat Wood
Paneling Coating
contains
information
on
state standards
for these
operations
across
the
country.
Rather
than
reproduce
the entire
list here,
the reader
is referred
to that
list. A key
point to note
is that all
states
with ozone
NAAs
will need
to implement
the
same Group
II
CTGs
as
Illinois
is implementing
with
this rulemaking.
8.0
SUMMARY
The
regulations
proposed
in this
rulemaking,
covering
the
CTGs from
Group
II of
USEPA’s
Consumer
and
Commercial
Products
category,
add
new requirements
or
tighten
existing requirements
for
lithographic
printing,
letterpress printing,
flexible
packaging
printing,
flat
wood paneling
coating,
and
industrial
cleaning
solvents.
The Agency
believes
that
all
the
proposed
changes
are
technically
feasible
and economically
reasonable.
Incorporating
these
additions
and
modifications
to existing
Illinois regulations
is required
by
the
CAA and
USEPA;
specifically,
Section
1 82(b)(2)(A)
of the
CAA
requires
that
SIPs
must
be
revised
to include
RACT for
VOM
emissions
sources
that
are covered
by a
CTG issued
by
USEPA
after
November
15,
1990, and before
the
area’s
date
of
attainment.
The
Illinois
EPA made
multiple
rounds
of
outreach
efforts
in relation
to this
proposed
rulemaking.
The
first
was
accomplished
electronically,
with the
second
involving
follow-up
calls from
the
Agency
to
sources that
had submitted
comments
as well
as
detailed discussions
between
the
Agency
and
industry group
representatives.
In
addition,
the
Agency
has
had frequent
discussions
with
USEPA
personnel
in both the
regional
office and
headquarters,
and
has gathered
information
from other
states. After
this extensive
effort,
the
Agency
has proposed
22
this
rulemaking,
which
incorporates
the requirements
of
the
CTGs
and
USEPA
plus
comments
from
industry.
While
the
Agency
recognizes that
it is
difficult
to
quantify
specific
emission
reductions
that
will
be
achieved
through
these
rule
modifications,
the
environment
will
see
a
real
reduction
of VOM
emissions.
As previously
noted,
USEPA
strengthened
the
eight-hour
ozone
standard
last
year.
It
is
likely
that
the
same
areas
in Illinois
that
are
currently
designated
as
nonattainment
for
the
present
standards
will
soon
be
designated
as nonattainment
for
this revised
standard.
Any
reduction
in
VOM
emissions
in
the
NAAs
will
help
Illinois
to
achieve
the
newly
revised
NAAQS
as
well as
satisfy
CAA
obligations.
23
Appendix
A:
Comparison
of
Proposed
Illinois
Industrial
Cleaning
Solvent
Limits
to Those
in
Other
States
Illinois
Rule
Ohio
Rule
South
Coast
Bay Area
Rule
San Joaquin
Wisconsin
Rule
(proposed)
(proposed)
Rule
(2006)
(2002)
Valley
(2003)
(2004)
Solvent
Cleaning
Operation
VOM
content
VOM
content
VOM
content
voii
content
VOM
content
VOM
content
[lbs/gallon.
as
[lb/gallon,
as
jlbs/gallon.
as
flbs/gallon,
as
[lbs/gallon,
as
llbs/gallon,
as
used]
used]
used
J
used
used
I
used]
(a)
Product
cleaning
during
manufacturing
process
or
surface
preparation
for
coating, adhesive,
or
ink
application:
(i) General
0.42
0,42
0.21
0.42
0.42
0.42
(ii)
Electrical
apparatus
components
and
0.83
0.83
0.83
Exempt?
4.2
4.2
electronic
components
(iii)
Medical
devices
and
pharmaceuticals
.
6.7
6.7
6.7
Exempt?
6.7
6.7
(b)
Repair
and
maintenance
cleaning:
(i)
General
0.42
0.42
0.21
0.42
0.42
0.42
(ii) Electrical
apparatus
components
and
0.83
0.83
0.83
Exempt?
7.5
7.5
electronic
components
(iii)
Medical
devices and
pharmaceuticals
.
Exempt?
(a)
Tools, equipment
and_machinery
6.7
6.7
6.7
?
6.7
6.7
(b)
General work
5.0
5.0
5.0
?
5.0
5.0
(c)
Cleaning
of ink
application
equipment:
(i)
General
0.42
0.42
0.21
0.42
0.42
0,42
(ii) Flexographic
and
Rotogravure
printing
that
does not
print
0.83
0.42
0.21
6.8
0.42
0.42
flexible_packaging
(iii)
Screen
printing
4.2
4.2
4.2
2.5
6.3
6.4
(iv)
Ultraviolet
ink and
electron
beam
ink
application
equipment,
5.4
5.4
6.7
6.7
6.7
except_screen_printing
24
Appendix
B:
Potentially
Affected
Sources
Lithographic
Printing
Sources
Chicago
Nonattainment
Area:
BOA
ID
Number
Source
Name
O31O12AGH
Nuart
O31O15AAR
Sleepeck
Printing
Co
031015ACC
Douglas
Press
Inc
O31O18AAK
The
Buhi
Press
Inc
03103
OACU
Kelvyn
Press
Inc
03103
OACW
H&W
Graphics
Inc
03103
OADM
Rapid
Impressions
Inc
03105
1ABM
Unique
Printers
& Lithographers
03105
1ADK
Royal
Continental
Box
Co
03 1O63AHP
Chromatech
Printing
Inc
031063AHU
Des
Plaines
Printing
LLC
031096AAD
TIN
Inc
DBA
Temple-Inland
031096ANR
TukaizLLC
031
12OAAF
Cadore-Miller Printing
Inc
031
123ABZ
Darwill
0311
23ACD
Creative
Automation
031126AAZ
Liberty
Suburban
Chicago
Newspaper
0311
86AGD
MeadWestvaco
Consumer
Packaging
Group
LLC
03120
1ADU
Johnson
&
Quin
Inc
O312O1AEG
Ed
Garvey
&
Co
O312O1AEQ
SKM
Ventures
LLC
031288AJJ
Great
Lakes
Graphics
031297ABT
Calumet
Carton
Co
03
144OAFJ
Bruce
Offset
Co /
Pearson
I Inc
03
144OALJ
Elk
Grove
Graphics
03
1440AL0
Quality
Color
Graphics
Inc
03144 OALR
Premier
Card
Solutions
LLC
03144
OAMW
Impact
Printers
&
Lithographers
031
600AWL
Lakeside
Lithography
LLC
03
1600BGU
Color
Communications
Inc
O31600BKC
Goes
Lithographing
Co
Inc
O31600CAG
Chicago
Press
Corp
O31600CHZ
Cardinal
Colorprint
Printing
031
600FAN
Chicago
Tribune
Co
031
600FOV
Seven
Worldwide
Inc
O31600GBC
Newsweb
Corp
03 1600GFC
Melar
Litho
Inc
03 1600GHF
American
Thiessen
LLC
031600GH1
Palmer
Printing
Inc
031
600GYN
Enteron
Group
LLC
O31600GQV
Diemand
Printing
Co
031821ABB
Ideal
Box
Co
25
BOA
ID
Number
Source
Name
043005ALJ
Advantage
Printing
Inc
043005AMK
Lakewood
Printing
Inc
043005AMS
ABS
Graphics
Inc
043
O2OABI
Tempo
Graphics
Inc
043020ACM
Flint
Ink
North
America
Corp
043030ADL
Johnson
Printers
04303
OAEG
Diamond
Web
Printing
Inc
043030AEL
Jet
Litho
color
Inc
043
O65ACG
Dow
Jones
&
Co
Inc
0431
2OAAR
Madden
Communication
043452AAW
Vis-o-Graphics
0890
1OACG
Tegrant
Alloyd
Brands
Inc
089020ABH
Carlith
Printing
Co
089407AA0
Voris
Communications
Co
Inc
dlb/a
Kelmscott
Press
08943
8AFT
Hagg
Press
Inc
089483ACC
InterCo
Print
LLC
089483ACM
Perfect
Plastic
Printing
Corp
089800ABV
Freedom
Imaging
Systems
Inc
097
19OACR
Nosco
Inc
0971
9OAFK
Lake
County
Press
Inc
11101
5ACP
Corporate
Express
197025AAM
Joliet
Pattern
Works
Inc
1
97080AAN
Fox
Valley
Publications
197491AAD
Vision
Integrated
Graphics
LLC
Metro-East
Nonattainment
Area:
BOA
ID
Number
Source
Name
11
9055AAZ
Dow
Jones
and
Co
Inc
1
198
19AAA
Highland
Supply
Corp
133025AAK
Mar
Graphics
Letterpress
Printing Sources
Chicago Nonattainment
Area:
BOA
ID
Number
Source
Name
031
288ABA
Federal-Mogul
Corp
1110
I5ADP
Stephen
Fossler
Company
26
Flexible
Packaging
Printing
Sources
Chicago
Nonattainment
Area:
BOA
ID Number
Source
Name
031003AcU
Duro
Bag Mfg
Co
03 1009AAS
Weber
Marking
Systems
Inc
031012ACA
Packaging
Corp of IL
d!b/a Acorn
Corrugated
Box
Co
03101
2AFM
International
Paper
Co
03101
2AGJ
International
Paper Co
O31O15AAM
Alcan
Packaging
Food
& Tobacco
Inc
031 O27AAS
Smurfit-Stone
Container
Corp
031 045AG1
CFC International
Inc
031 063
ADM
International
Paper Co
031 O63AFT
Deluxe
Manufacturing
Operations
Inc
O31O63AHT
Pamco
Printed
Tape
& Label Co
031 O96AMM
Formel
Industries
Inc
03 1096A0B
Prairie
State
Group
0311 86AFK
Wagner
Zip
Change
03
144
OAHX
Clear-Lam
Packaging
Inc
03
1489AAU
Paddock
Printing
Center
03 1497AAM
Bio-Industries
031 600ACL
Bagcrafl
Packaging
LLC
031
600AIL
Solo
Cup
Operating
Corporation
031 600BGU
Color
Communications
Inc
03 1600BTT
General
Packaging
Products
O31600CKM
MeadWestvaco
Packaging
Systems LLC
031 600DNZ
Bio
Star
Films
LLC
031600GE1
Cenveo
O31600GFH
TIN Inc
dlb/a Temple
- Inland
031 600GIB
American
Labelmark
Co
031
600GLJ
General
Packaging
Products
Inc
031 820AA1
Bluegrass
Flexible
Packaging
Co LLC
043005AJS
Rollprint Packaging
Products
Inc
043005ALB
Quality Bags
Inc
043020AAC
Graphic
Packaging International
Inc
043020ACH
Meyercord
Revenue
Co
043020ACJ
Packaging
Personified
Inc
043035ACX
Bema
Poly Tech
dlb/a Bema
Film
Sys
Inc
043462AAA
Genesis
Packaging
& Design
043806AAN
Pro-pak
Industries Inc
0890 1OACC
Pechiney
Plastic Packaging
Inc
089055AAK
International
Paper
089407AAZ
Covalence
Specialty
Materials
Corp
08943 8ADW
Printpack
Inc
089438AFL
Multiflim
Packaging
Corp.*
089438AGQ
TIN
Inc DBA Elgin
Corrugated
Box
089483ABV
Dopaco
Inc
089483ACY
Moore
Wallace
North
America
Inc
27
BOA
ID
Number
Source
Name
097035ABE
Nosco
Inc
097080AAY
Colbert
Packaging
Corp
097084AA1
Vonco
Products
Inc
0971
15ABC
Amcor
Flexibles
Healthcare
Inc
0971
15ACJ
Parade
Packaging
097
125AAY
Stone
Container
Corp
097190ACR
Nosco
Inc
09741
8AAL
Fisher
Container Corp
097803AAB
CTI
Industries Corp
097809ABG
Kraftseal
Corp
11
1O1OAAT
AMPAC
Flexicon LLC
11 1O35AAP
HS Crocker
Co Inc
111 O65AAR
Diversapack
LLC
1118O3AAF
CattyCorp
Metro-East
Nonattainment
Area:
BOA ID Number
Source
Name
11
9O4OATD
Gateway
Packaging
Inc
1 19055AAL
Highland
Supply Corp
1198 19AAA
Highland
Supply
Corp
Flat
Wood
Paneling
Coating
Sources
Chicago
Nonattainment
Area:
BOA
ID Number
Source
Name
031 600AFA
William
Yuenger Manufacturing
Co
031
600FZW
Interior
Crafts Inc
O31600GGJ
FCI
Inc
1978 15AAH
Illinois Flush
Door
Inc
28
REFERENCES
1. The
Clean Air
Act
as amended
in
1990 (42
U.S.C.
Section
7401 et
seq.).
2. Control
Techniques
Guidelines
for
Offset Lithographic
Printing and
Letterpress
Printing,
United
States
Environmental
Protection
Agency,
Office
of Air
Quality
Planning
and
Standards,
Research
Triangle
Park,
NC,
September
2006.
3.
Control
Techniques
Guidelines
for Flexible
Package
Printing, United
States
Environmental
Protection
Agency,
Office
of Air
Quality
Planning and
Standards,
Research
Triangle
Park,
NC, September
2006.
4. Control
Techniques
Guidelines:
Industrial
Cleaning
Solvents,
United States
Environmental
Protection
Agency,
Office of
Air Quality
Planning
and
Standards,
Research
Triangle
Park, NC,
September
2006.
5.
Control
Techniques
Guidelines
for
Flat
Wood
Paneling
Coatings,
United
States
Environmental
Protection
Agency,
Office
of Air
Quality
Planning
and
Standards,
Research
Triangle
Park, NC,
September
2006.
6.
Technical
Support
Document
for
Controlling
VOM
Emissions
from
Lithographic
Printing
Operations,
Illinois
Environmental
Protection
Agency,
Air Quality
Planning
Section, Springfield,
IL, October
1994.
7.
Control
Techniques
Guideline
Series:
Control
of Volatile
Organic
Compound
Emissions
from
Offset
Lithographic
Printing
(DRAFT),
United
States
Environmental
Protection
Agency,
Office
of Air Quality
Planning
and
Standards,
Research
Triangle
Park,
NC,
September
1993.
29