Mostardi
Platt
1520
Kensington
Road, Suite
204
Oak
Brook,
Illinois
60523-21
39
Phone
630-993-2100
Fax 630-993-9017
www.mostardiplattenv.com
December
23,
2009
John
Therriault
S
OPF
Clerk
L!EC
2
Illinois
100W.
PollutionRandolphControl
St.,
Ste.
Board
11-500
pO,,PILJNOjS
s
Chicago,
IL 60601
rol
Board
Attn:
Ri 0-8
Rulemaking
— Air:
Lithographic
Printing
Rules
To whom
it may
concern,
I wish
to
submit
comments
regarding
the
proposed
changes
to the Reasonably
Available
Control
Technology
(RACT)
for Volatile
Organic
Material Emissions
Standards
drafted
by
the Illinois
Pollution
Control
Board
(IPCB)
that
incorporates
United
States
Environmental
Protection
Agency
(USEPA)
Control
Techniques
Guideline
(CTG)
into
Illinois
regulations.
I
specifically
wish
to request
clarification
be
added
in the rule
for
control
device destruction
efficiencies.
I am
an environmental
consultant
that
represents
a heatset
offset
lithographic
printer
who
recently
installed
a replacement
catalytic
oxidizer
on three
(3)
older
heatset lithographic
printing
lines.
(Note: older
heatset
presses
did
not have
integrated
afterburners
as the
new
presses
do.)
The
control
device efficiency
was
permitted
at 90%
as
allowed
by current
regulations.
When
USEPA
finalized
the Offset
Lithographic
Printing
Materials
and
Letterpress
Printing
Materials
CTG
they allowed
for existing
printing
lines with
control
devices
to have
minimum
90%
destruction
efficiency.
Illinois has
incorporated
that
language
as
follows:
2 18.407
(a)(i)(C)
An afterburner
is
installed
and
operated
so
that
VOM
emissions
(excluding
methane
and
ethane) from
the
press
dryer exhausts
are
reduced
as
follows:
i)
Prior
to May 1, 2010,
by
90
percent,
by
weight,
or to
a
maximum
afterburner
exhaust
outlet
concentration
of 20
ppmv
(as
carbon);
and
i)
On
and after
May 1, 2010,
by
at least
95 percent,
by
weight,
or
to
a
maximum
afterburner
exhaust
outlet
concentration
of 20 ppmv
(as
carbon)
We request
that
this
language be
a little
clearer
to show
what
is being
addressed,
the
printing
line,
the
afterburner,
or both. Also
we
request
that the
language
be clearer that
ii
is the
installation/operation
date
of the unit
that detennines
what
percent efficiency
must
Page
2
be achieved,
and
not that
all control
devices
must perform
at a higher
destruction
efficiency
after
May
1,
2010.
The following
section
also requires
similar
clarification
that
it is the
date
of installation
of
the control
device
that determines
what
control efficiency
must
be
attained:
2
18.407 (b)
An
owner or
operator
of a
heatset web
offset
lithographic
printing
line
subject
to the
requirements
of(a)(1)(C)
of
this Section
may
use
a control
device
other
than
an
afterburner,
if:
1)
The control
device reduces
VOM
emissions
from the
press
dryer
exhaust(s)
are
reduced
as
follows:
A)
Prior to May
1, 2010,
by
at least
90 percent,
by
weight,
or to
a maximum
afterburner
exhaust
outlet
concentration
of 20
ppmv (as carbon);
and
B)
On and
after
May
1,
2010;
i)
By
at least
95 percent.
by
weight; or
ii)
To
a maximum
control
device
exhaust
outlet
concentration
of 20
ppmv
(as carbon)
Current heatset
lithographic
presses
are designed
with
an integrated
drying
oven
/
thermal
oxidizer
control.
These
units easily
achieve the
proposed
95%
destruction
rate
and
are
cost effective
when purchasing
new heatset
presses. Many
existing
older units,
however,
require
stand
alone control
devices.
They
are
not
engineered
for
optimized
(lower)
dryer
air
flow
rates.
As
control
device
operational
costs (natural
gas
usage)
are high
for these
older
presses
it is
more
cost effective
to
duct
emissions
to catalytic
oxidizers
for control.
Catalyst
efficiency
may
slightly
reduce over
time and
we wish
to
ensure that
it is clear
in
the rules
that
these units
will always
be
able
to comply
with
the
90%
destruction
minimum.
Please provide
clarification
whether
it is
the effective
operation
date
of the
printing line
or
the control
device, or
both in relation
to the
May 1, 2010
control
efficiency
requirement.
Will
existing
printing
lines
installed
and
operated
prior
to
May
1, 2010
that
require
a
stand
alone control
device
be allowed
to install
new
control
devices
that meet
the 90% minimum
destruction
efficiency?
Or will
the
control device
installation
/
operation
date
detennine
what
destruction
efficiency
is required?
(that the
95%
minimum
destniction
efficiency
is for printing
units
“installed and
operated”
after
May
1,
2010).
If the
control
device
installation/operation date is
the determining
factor,
can it be
made
clear that
all
existing
units maintain
their
status
(90%
destruction)
through
all equipment
maintenance
and
repair,
including
replacement
of
catalyst?
This could
create a financial
burden
on
sources
to replace
control devices
that
were
compliant
with the
lithographic
printing
rules
when
the
printing
units
were
installed.
Page
3
Please
note
that the bulk of
heatset lithographic
printing
emissions
come from
cleanup
solvents,
not the inks. Cleanup
solvents
are not controlled
by the oxidizer
when
hand
applied
with
rags. The
destruction
efficiency will not affect
these emissions,
as
they
are
limited
by
the solvent
vapor pressure and
work
practices.
If
you
have
any questions
regarding
this clarification
request, please
feel free
to contact
me at
(630)
993-2138
or by e-mail
at
bmeermanmostardiplattenv.corn.
Thank
you for
your consideration
of our request.
Sii
BrucM.nna4
Senior Environ&iental
Consultant
Mostardi
Platt Environmental