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

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