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,