Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
1
DRAFT
DRAFT
CONTROL
TECHNIQUES
GUIDELINE
FOR
FLEXIBLE
PACKAGE
PRINTING
JULY
2006
US
EPA
OAQPS
RTP
NC
27711
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
2
TABLE
OF
CONTENTS
I.
Introduction
                    
Page
3
II.
Background
and
Overview
              ..
Page
4
III.
Applicability
                    
Page
5
IV.
Process
Description
and
Sources
of
VOC
Emissions
    ..
Page
7
A.
Definition
of
Flexible
Packaging
B.
Printing
Processes
and
Emissions
Rotogravure
Printing
Flexographic
Printing
V.
Available
Control
Options
and
State
and
Local
Regulations .
Page
10
1.
Inks,
Coatings
and
Adhesives
Add­
On
Controls
 
Capture
Systems
Add­
On
Controls
 
Control
Devices
Low­
and
No­
VOC
Inks,
Coatings,
and
Adhesives
2.
Cleaning
Materials
3.
Summary
of
State
and
Local
Regulations
VI.
Recommended
Control
Options
            ..
Page
14
Coatings,
Inks,
and
Adhesives
Cleaning
Materials
VII.
Cost
Effectiveness
of
Recommended
Control
Options
   ...
Page
15
VIII.
References
                     .
Page
16
Appendix
1978
CTG
for
Graphic
Arts       ..          .
Page
18
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
3
I.
Introduction
Clean
Air
Act
(
CAA)
section
172(
c)(
1)
provides
that
state
implementation
plans
(
SIPs)
for
nonattainment
areas
must
include
"
reasonably
available
control
measures"
(
RACM),
including
"
reasonably
available
control
technology
"
(
RACT),
for
sources
of
emissions.
Section
182(
b)(
2)(
A)
provides
that
for
certain
nonattainment
areas,
States
must
revise
their
SIPs
to
include
RACT
for
sources
of
VOC
emissions
covered
by
a
control
techniques
guidelines
(
CTG)
document
issued
after
November
15,
1990
and
prior
to
the
area's
date
of
attainment.

The
United
States
Environmental
Protection
Agency
(
EPA)
defines
RACT
as
"
the
lowest
emission
limitation
that
a
particular
source
is
capable
of
meeting
by
the
application
of
control
technology
that
is
reasonably
available
considering
technological
and
economic
feasibility."
44
FR
53761
(
Sept.
17,
1979).
In
subsequent
Federal
Register
notices,
EPA
has
addressed
how
states
can
meet
the
RACT
requirements
of
the
Act.

CAA
section
183(
e)
directs
EPA
to
list
for
regulation
those
categories
of
products
that
account
for
at
least
80
percent
of
the
VOC
emissions,
on
a
reactivity­
adjusted
basis,
from
consumer
and
commercial
products
in
areas
that
violate
the
NAAQS
for
ozone
(
i.
e.,
ozone
nonattainment
areas).
EPA
issued
the
list
on
March
23,
1995,
and
has
revised
the
list
periodically.
See
60
FR
15264
(
March
23,
1995);
see
also
71
FR
28320
(
May
16,
2006),
70
FR
69759
(
Nov.
17,
2005);
64
FR
13422
(
Mar.
18,
1999).
Flexible
packaging
printing
materials
is
included
on
the
current
section
183(
e)
list.

This
draft
CTG
is
intended
to
provide
state
and
local
air
pollution
control
authorities
information
that
should
assist
them
in
determining
RACT
for
volatile
organic
compounds
(
VOC)
from
flexible
packaging
printing
facilities.
In
developing
this
CTG,
EPA,
among
other
things,
evaluated
the
sources
of
VOC
emissions
from
this
industry
and
the
available
control
approaches
for
addressing
these
emissions,
including
the
costs
of
such
approaches.
Based
on
available
information
and
data,
EPA
provides
recommendations
for
RACT
for
VOC
from
flexible
packaging
printing
facilities.
EPA
solicits
comment
on
all
aspects
of
this
draft
document.

Once
finalized,
States
can
use
the
recommendations
in
this
CTG
for
VOC
from
this
source
category
to
inform
their
own
determination
as
to
what
constitutes
RACT
in
their
particular
nonattainment
areas.
The
information
contained
in
this
document
is
provided
only
as
guidance.
This
guidance
does
not
change,
or
substitute
for,
applicable
sections
of
the
CAA
or
EPA's
regulations;
nor
is
it
a
regulation
itself.
This
document
does
not
impose
any
legally
binding
requirements
on
any
entity.
It
provides
only
recommendations
for
state
and
local
air
pollution
control
agencies
to
consider
in
determining
RACT.
State
and
local
pollution
control
agencies
are
free
to
implement
other
technically­
sound
approaches
that
are
consistent
with
the
CAA
and
EPA's
implementing
regulations.
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
4
The
recommendations
contained
in
this
draft
CTG
are
based
on
data
and
information
currently
available
to
EPA.
These
general
recommendations
may
not
apply
to
a
particular
situation
based
upon
the
circumstances
of
a
particular
source.
Regardless
of
whether
a
State
chooses
to
implement
the
recommendations
contained
herein
through
State
rules,
or
to
issue
State
rules
that
adopt
different
approaches
for
implementation
of
RACT
for
VOCs
from
flexible
packaging
printing.
States
must
submit
their
RACT
rules
to
EPA
for
review
and
approval
as
part
of
the
SIP
process.
EPA
will
evaluate
the
rules
and
determine,
through
notice
and
comment
rulemaking
in
the
SIP
process,
whether
they
meet
the
RACT
requirements
of
the
Act
and
EPA's
regulations.
To
the
extent
a
State
adopts
any
of
the
recommendations
in
this
guidance
into
its
State
RACT
rules,
interested
parties
can
raise
questions
and
objections
about
the
substance
of
this
guidance
and
the
appropriateness
of
the
application
of
this
guidance
to
a
particular
situation
during
the
development
of
the
State
rules
and
EPA's
SIP
approval
process.

CAA
section
182(
b)(
2)
provides
that
a
CTG
issued
after
November
15,
1990
and
before
the
date
of
attainment
must
include
the
date
by
which
States
must
submit
SIP
revisions
in
response
to
the
CTG.
States
subject
to
section
182(
b)
should
submit
their
SIP
revisions
within
one
year
of
the
date
of
issuance
of
the
final
CTG
for
flexible
packaging
printing.
States
subject
to
CAA
section
172(
c)(
1)
may
take
action
in
response
to
this
guidance,
as
necessary
to
attain.

II.
Background
and
Overview
In
December
1978,
EPA
published
a
CTG
for
graphic
arts
(
rotogravure
printing
and
flexographic
printing)
that
included
flexible
packaging
printing.
(
See
Reference
(
a)
in
the
reference
section
for
the
full
citation
to
this
document.).
The
1978
CTG
discusses
the
flexible
packaging
printing
industry,
the
nature
of
VOC
emissions
from
that
industry,
available
control
technologies
for
addressing
such
emissions,
the
costs
of
available
control
options,
and
other
items.
The
1978
CTG
is
included
as
an
Appendix
to
this
draft
CTG.
The
proposed
recommended
approaches
for
RACT
in
this
document
build
upon
those
identified
in
the
1978
CTG
for
graphic
arts.

EPA
also
published
a
national
emission
standard
for
hazardous
air
pollutants
(
NESHAP)
for
the
printing
and
publishing
industry
(
40
CFR
Part
60,
Subpart
KK)
in
May
1996,
which
is
applicable
to
flexible
packaging
printing.
b
The
background
information
document
used
to
support
the
1996
NESHAP
included
an
analysis
of
the
industry
based
on
surveys
completed
by
flexible
packaging
printers.
c
EPA
developed
the
recommended
approaches
contained
in
this
document
after
conducting
a
comprehensive
review
of
current
existing
state
and
local
VOC
emission
reduction
approaches
for
flexible
packaging
printing,
reviewing
the
1978
CTG
and
the
1996
NESHAP
background
information
document,
and
considering
information
obtained
since
promulgation
of
the
NESHAP.
Similar
to
the
1978
CTG,
this
document
contains
recommendations
for
reducing
VOC
emissions
based
on
the
use
of
add
on
controls.
The
recommendations
in
this
CTG
reflect,
however,
the
technological
improvements
that
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
5
have
occurred
with
regard
to
such
controls
since
1978.
This
CTG
also
contains
recommendations
for
limiting
the
vapor
pressure
and
establishing
work
practice
standards
for
cleaning
solvents.

EPA
published
a
guidance
document
in
September
1979
that
sets
forth
model
rules
designed
to
assist
state
and
local
air
pollution
control
agencies
in
preparing
regulations
for
controlling
VOCs
from
ten
stationary
source
categories,
including
graphic
arts.
d
The
model
rule
for
graphic
arts
incorporated
the
recommendations
contained
in
the
1978
CTG
and
provided
a
general
organizational
framework
for
States
to
use
in
developing
their
own
state
rules
implementing
RACT
for
rotogravure
and
flexographic
printing.
The
model
rule
also
contained
sample
regulatory
language.
We
provided
this
model
rule
in
1979,
recognizing
that
each
state
and
local
pollution
control
agency
will
establish
its
own
rules
for
RACT
considering
available
information,
including
specific
information
about
the
sources
to
which
the
rule
will
apply.
The
model
rule
was
updated
in
1992.
e
We
are
considering
including
a
similar
example
rule
when
we
finalize
this
draft
CTG,
and
such
example
rule
would
incorporate
the
recommendations
contained
in
the
final
CTG.
We
are
still
evaluating,
however,
the
utility
of
such
an
example
rule,
in
light
of
our
prior
model
rules
and
the
numerous
state
rules
that
address
this
product
category.
See
Tables
1
and
2
in
Section
IV
for
a
listing
of
some
of
the
state
and
local
agencies
that
have
rules
relating
to
flexible
packaging
printing.
We
solicit
comment
on
whether
an
example
rule
that
incorporates
the
recommendations
contained
in
the
final
CTG
would
be
useful.

The
remainder
of
this
document
is
divided
into
six
(
6)
sections.
Section
III
describes
the
scope
of
sources
to
which
this
CTG
applies.
Section
IV
provides
a
summary
of
the
processes
associated
with
the
flexible
packaging
printing
and
identifies
the
sources
of
VOC
emissions
from
those
processes.
Section
V
describes
the
available
control
approaches
for
addressing
VOC
emissions
from
this
source
category
and
summarizes
state
and
local
regulatory
approaches
for
addressing
such
emissions.
Section
VI
provides
our
proposed
recommendations
for
RACT
for
VOC
emissions
from
flexible
packaging
printing.
Section
VII
discusses
the
cost­
effectiveness
of
the
recommended
control
approaches.
References
are
provided
in
Section
VIII.

III.
Applicability
This
draft
CTG
applies
to
flexible
packaging
printing
operations
that
emit
at
least
6.8
kg/
day
(
15
lb/
day)
of
VOC
before
consideration
of
controls1
1
"
Flexible
packaging
printing"
is
a
printing
process
employing
the
use
of
rotogravure
or
flexographic
printing
presses.
Flexible
packaging
refers
to
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,
labels,
liners,
and
wraps
utilizing
paper,
plastic,
film,
aluminum
foil,
metalized
or
coated
paper
or
film,

or
any
combination
of
these
materials.
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
6
The
applicability
threshold
of
6.8
kg/
day
(
15
lb/
day)
is
consistent
with
the
threshold
level
contained
in
many
previous
final
CTGs.
2
It
is
also
consistent
with
the
purpose
of
the
section
183(
e)
program.
In
section
183(
e),
Congress
directed
EPA
to
assist
States
in
achieving
VOC
emission
reductions
from
consumer
and
commercial
products.
These
products
individually
may
result
in
relatively
small
amounts
of
VOC
emissions,
but,
in
the
aggregate,
they
contribute
significantly
to
ozone
formation
in
nonattainment
areas.
Given
the
nature
of
the
products
and
sources
at
issue
here,
we
believe
that
the
15
lb
VOC
per
day
applicability
threshold
is
appropriate.
For
purposes
of
determining
whether
the
15
lb/
day
threshold
is
met
at
a
given
facility,
a
flexible
packaging
printer
should
consider
emissions
from
all
flexible
packaging
printing
and
related
cleaning
activities
at
the
facility
prior
to
controls.

The
only
exception
to
the
15
lb/
day
threshold
relates
to
the
control
recommendations
provided
below
for
emissions
from
inks,
coatings
and
adhesives,
and
that
exception
is
described
below.
Specifically,
these
control
recommendations
apply
only
to
flexible
packaging
printing
operations
with
potential
to
emit
at
least
25
tpy
of
VOC
from
inks,
coatings
and
adhesives
combined
before
consideration
of
controls.
We
are
proposing
this
higher
threshold
for
the
control
recommendations
concerning
inks,
coatings,
and
adhesives
because
not
all
flexible
packaging
facilities
can
use
low
VOC
content
inks,
coatings
and
adhesives,
and
because
the
limited
information
currently
available
to
us
suggests
that
add­
on
controls
for
small
printers
may
be
more
costly
for
a
given
amount
of
emission
reduction.

The
Flexible
Packaging
Association
(
FPA)
estimated
that
in
2005,
there
were
1,071
flexible
packaging
facilities.
f
FPA
did
not
identify
which
of
these
facilities
conduct
flexible
packaging
printing
operations
(
to
which
this
draft
CTG
is
applicable),
but
EPA
concluded
that
the
number
of
flexible
packaging
printing
facilities
is
less
than
1,071.
To
estimate
the
total
number
of
flexible
packaging
printing
facilities
and
subsequently
estimate
the
number
of
facilities
in
current
nonattainment
areas
that
would
meet
the
applicability
threshold
in
this
CTG,
EPA
reviewed
data
obtained
during
development
of
the
1996
NESHAP
and
data
from
the
2002
NEI.
g
The
1996
NESHAP
background
information
document
reported
that
the
Gravure
Association
of
America
estimated
that
in
1994
there
were
an
estimated
400
locations
within
the
U.
S.
that
conducted
rotogravure
printing
operations,
but
made
no
distinction
between
rotogravure
package/
product
printing
(
to
which
this
draft
CTG
is
applicable)
and
rotogravure
publication
printing
locations
(
to
which
this
draft
CTG
is
not
applicable).
As
part
of
the
NESHAP
project,
EPA
identified
108
locations
thought
to
operate
package/
product
rotogravure
printing
equipment.
The
108
package/
product
rotogravure
facilities
include
both
area
and
major
sources
of
HAP.
EPA
also
identified
520
facilities
2
See.
e.
g.,
Model
Volatile
Organic
Compound
Rules
for
Reasonably
Available
Control
Technology:
Planning
for
Ozone
Nonattainment
Pursuant
to
Title
I
of
the
Clean
Air
Act,
dated
June
1992
(
establishing
the
15
lb
of
VOC
per
day
applicability
threshold
for
coating
applications
for
eleven
industries,
including,
automobile
and
light
duty
truck
coating
operations
and
coating
of
cans,
coil,
paper,
fabric,
vinyl,
metal
furniture,
large
appliances,
magnet
wire,
miscellaneous
metal
parts,
and
flatwood
paneling).
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
7
conducting
wide
web
flexographic
printing
operations
(
to
which
this
draft
CTG
is
applicable)
as
part
of
the
NESHAP
project.
The
520
wide­
web
flexographic
facilities
include
both
area
and
major
sources
of
HAP.
Of
these
520
facilities
conducting
wideweb
flexography,
EPA
estimates
that
approximately
221
facilities
are
potential
flexible
packaging
printers.
Thus,
the
NESHAP
data
indicate
that
there
are
approximately
329
potential
flexible
packaging
printers.

An
additional
search
of
the
2002
NEI
(
April
11,
2006
version)
database
for
SIC
codes
2671,
2673,
2674,
and
3497,
identified
146
unique
facilities
(
i.
e.,
not
already
identified
as
part
of
the
NESHAP
project).
This
number
may
be
artificially
high
because
many
of
the
facilities
could
not
be
definitively
confirmed
as
flexible
packaging
printers;
however,
these
facilities
were
not
omitted
from
the
facility
list.
A
search
of
the
2002
NEI
(
April
11,
2006
version)
database
for
NAICS
codes
322221,
326112,
322223,
326111,
322224,
322225,
and
332999
was
conducted
to
identify
additional
flexible
packaging
printing
facilities.
The
number
of
unique
facilities
(
i.
e.,
not
already
identified
as
part
of
the
NESHAP
project
or
as
part
of
the
2002
NEI
SIC
search
discussed
above)
identified
that
107
facilities
could
be
flexible
packaging
printers.
This
number
may
be
artificially
high
because
many
of
the
facilities
could
not
be
definitively
confirmed
as
flexible
packaging
printers;
however,
these
facilities
were
not
omitted
from
the
facility
list.
In
total,
the
NEI
search
resulted
in
253
potential
flexible
packaging
printers.

The
NESHAP
and
the
NEI
search
combined
identified
a
total
of
582
facilities
that
could
be
flexible
packaging
printers.
Of
the
582
facilities
identified
as
potential
flexible
packaging
printers,
a
total
of
219
facilities
are
located
in
ozone
nonattainment
areas
(
based
on
April
2006
designations).
Based
on
VOC
emissions
data,
we
estimate
that
there
are
approximately
100
facilities
in
ozone
nonattainment
areas
that
have
emissions
of
greater
than
15
pounds
per
day
(
lb/
day).

IV.
Process
Description
and
Sources
of
VOC
Emissions
A.
Definition
of
Flexible
Packaging
Flexible
packaging
refers
to
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,
labels,
liners,
and
wraps
utilizing
paper,
plastic,
film,
aluminum
foil,
metalized
or
coated
paper
or
film,
or
any
combination
of
these
materials.
h
Flexible
package
manufacturers
are
sometimes
referred
to
as
"
converters."
The
word
"
converted"
in
this
use
is
an
industry­
specific
term
that
refers
to
the
fact
that
flexible
packaging
materials
start
out
as
rolls
of
paper
or
foil,
or
beads
of
plastic
resin,
and
are
"
converted"
into
a
package
or
roll
of
packaging
material.

Printing
on
flexible
packaging
is
almost
entirely
conducted
by
rotogravure
and
flexographic
printing.
The
ratio
of
rotogravure
printing
to
flexographic
printing
among
converters
is
approximately
1:
4.
Flexible
packaging
printers
are
likely
to
be
included
under
SIC
codes
2671,
2673,
2674,
and
3497.
Typical
NAICS
codes
for
this
industry
include
322221,
326112,
322223,
326111,
322224,
322225,
and
332999.
Flexible
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
8
packaging
printers
could
also
be
classified
under
other
SIC
and
NAICS
codes
as
well
depending
on
other
processes
conducted
at
the
facility.

Printing,
coating,
and
laminating
may
all
be
performed
on
or
in­
line
with
a
flexible
packaging
printing
press
and
these
activities
are
included
in
the
source
category.
One
portion
of
the
flexible
packaging
industry
provides
fully
printed
packaging
materials
(
designated
"
preformed
specialty
bags")
to
contract
packagers.
Another
portion
provides
combination
or
laminated
materials
(
designated
converted
wrap)
for
printing
and/
or
final
packing
by
captive
packaging
operations.
Applying
coatings
is
a
major
capability
of
flexible
packaging
converters,
so
the
same
facilities
may
be
used
to
manufacture
nonpackaging
materials
such
as
gift
wraps
and
hot
stamp
foils.
The
industry
makes
a
distinction
between
labels
and
wrappers,
which
are
package
components,
from
a
product
that
becomes
the
entire
package
and
should
be
called
a
flexible
package.
Any
printing
of
labels
or
wrappers
conducted
on
or
in­
line
with
a
flexible
packaging
printing
press
is
also
considered
to
be
included
under
the
flexible
packaging
source
category.

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

B.
Printing
Processes
and
Emissions
There
are
two
types
of
printing
processes
used
by
flexible
packaging
printing
facilities:
(
1)
rotogravure
printing;
and
(
2)
flexographic
printing.

Rotogravure
Printing
Rotogravure
printing
is
a
printing
process
in
which
an
image
(
type
and
art)
is
etched
or
engraved
below
the
surface
of
a
plate
or
cylinder.
On
a
rotogravure
cylinder,
the
printing
image
consists
of
millions
of
minute
cells.
Rotogravure
requires
very
fluid
inks
which
will
flow
from
the
cells
to
the
substrate
at
high
press
speeds.
In
addition
to
inks,
coatings
and
adhesives
may
be
applied
with
rotogravure
cylinders.
These
materials
dry
by
evaporation
as
the
substrate
passes
through
hot
air
dryers.
Solvent­
borne
or
waterborne
ink
systems
can
be
used
but
these
ink
systems
are
not
interchangeable.
Both
the
printing
cylinders
and
the
drying
systems
are
specific
to
the
solvent
system
in
use.
The
evaporated
components
of
the
ink
and
other
materials
contain
VOC
to
varying
extents.
Additional
VOC
may
be
present
in
solvents
used
to
clean
presses
and
press
components.
Rotogravure
can
be
divided
into
the
publication,
product,
and
packaging
segments.
For
this
source
category,
we
are
interested
in
the
flexible
packaging,
which
is
a
part
of
the
packaging
segment.
Because
of
the
expense
and
complexity
of
rotogravure
cylinder
engraving,
it
is
particularly
suited
to
long
run
printing
jobs.

Rotogravure
package
printing
uses
a
wide
variety
of
different
ink
systems,
including
aromatic
VOC
based
ink
systems
and
waterborne
ink
systems.
Numerous
specially
mixed
colors
are
applied
at
various
times
in
this
industry
segment.
In
addition,
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
9
a
wide
range
of
materials
are
applied
with
rotogravure
cylinders
in
this
segment
of
the
industry.
A
variety
of
coatings
and
adhesives
are
applied
on
or
in­
line
with
rotogravure
presses.
Because
of
the
variety
of
materials
applied,
the
approach
to
VOC
control
in
packaging
rotogravure
facilities
varies.
Packaging
gravure
facilities
use
a
variety
of
thermal
and
catalytic
oxidizers
and
activated
carbon
based
solvent
recovery
systems.
Use
of
waterborne
inks
for
rotogravure
printing
is
increasing.,
However,
there
may
be
problems
with
the
use
of
waterborne
inks
at
press
speeds
above
1,000
feet
per
minute.
i
Also,
in
order
to
use
waterborne
inks
the
rotogravure
cylinders
need
to
be
re­
engraved.

Printing
is
only
one
stage
(
often
minor)
in
the
manufacturing
and
is,
in
many
cases,
a
relatively
small
part
of
the
total
packaging
production
process.
In
many
cases,
operations
such
as
laminating,
cutting,
and
folding
make
up
a
greater
proportion
of
the
value
of
the
package
than
the
printing
operation.

Due
to
the
wide
variety
of
ink
types
and
colors
that
are
used
in
this
segment
of
the
printing
industry,
ink
is
typically
received
in
drums
(
or
smaller
container
sizes)
and
tote
bins.
Only
rarely
is
bulk
ink
received
and
stored
in
tanks.

Flexographic
Printing
In
flexographic
printing,
the
image
is
raised
above
the
printing
plate,
and
the
image
carrier
is
made
of
rubber
or
other
elastomeric
materials.
The
major
applications
of
flexographic
printing
are
flexible
and
rigid
packaging;
tags
and
labels;
newspapers,
magazines,
and
directories;
and
paper
towels,
tissues,
etc.
Because
of
the
ease
of
plate
making
and
press
set
up,
flexographic
printing
is
more
suited
to
short
production
runs
than
rotogravure.

Flexographic
inks
must
be
very
fluid
to
print
properly.
Flexographic
inks
include
both
waterborne
and
solvent
based
systems.
Solvents
used
must
be
compatible
with
the
rubber
or
polymeric
plates;
thus,
aromatic
solvents
are
not
used.
Some
of
the
components
of
solvent
based
flexographic
ink
include
ethyl,
n­
propyl
and
iso­
propyl
alcohols;
glycol
ethers,
aliphatic
hydrocarbons,
acetates
and
esters.
A
variety
of
coatings
and
adhesives
are
applied
on
or
in­
line
with
flexographic
presses
including
solvent­
borne,
waterborne,
wax
coatings,
wax
laminations,
extrusion
coatings,
extrusion
laminations,
100
percent
solid
adhesives,
ultra­
violet
cured
coatings,
electron
beam
cured
coatings,
hot
melt
coatings,
and
cold
seal
coatings.

Flexographic
printing
can
be
divided
between
publication,
packaging,
and
product
printing.
For
this
source
category,
only
the
flexible
packaging
segment
is
considered.
Typically,
wide
web
flexographic
presses
(
defined
to
include
presses
of
18
inches
or
greater
in
width)
are
used
to
print
flexible
and
rigid
packaging.

Flexographic
presses
can
be
divided
into
three
main
types
depending
on
the
relative
relationship
of
the
print
stations.
Stack
presses
have
individual
print
stations
oriented
vertically
with
the
unwind
and
rewind
sections
on
the
same
side
of
the
print
stations.
Stack
presses
are
easily
accessible
for
rapid
changeovers
between
press
runs.
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
10
Stack
presses
are
a
vintage
design
that
is
not
easily
enclosed
for
VOC
emissions
capture.
Common
impression
presses
(
also
called
central
impression
presses)
have
the
print
stations
around
the
circumference
of
a
single
large
impression
cylinder.
The
web
is
constantly
supported
between
print
stations,
which
is
an
advantage
for
printing
on
stretchable
materials.
More
recent
models
of
central
impression
presses
include
capture
systems
within
the
press
design.
In­
line
presses
have
the
print
stations
in
a
horizontal
row
(
the
geometry
is
similar
to
rotogravure
presses).
These
presses
have
an
advantage
when
used
with
additional
converting
(
such
as
cutting,
gluing,
and
laminating)
equipment.

The
flexographic
printing
industry
has
converted
some
of
its
operations
to
waterborne
inks.
Waterborne
inks
are
available
for
many
flexographic
printing
applications.
Waterborne
inks
contain
relatively
low
proportions
of
VOC.

V.
Available
Controls
and
State
and
Local
Regulatory
Approaches
There
are
two
main
sources
of
VOC
emissions
from
flexible
packaging
printing
for
both
rotogravure
and
flexographic:
(
1)
evaporation
of
VOC
from
inks,
coatings
and
adhesives,
and
(
2)
evaporation
of
VOC
from
cleaning
materials.

There
are
two
approaches
to
reducing
VOC
emissions
from
inks,
coatings
and
adhesives
used
in
the
flexible
packaging
printing
industry:
(
1)
adding/
improving
add­
on
controls,
and
(
2)
material
reformulation
or
substitution.
The
first
approach
includes
improving
capture
and/
or
control
systems
or
adding
control
systems
where
none
are
in
use.
Capture
and
control
can
be
addressed
separately,
although
in
many
cases,
improved
capture
is
achieved
through
an
increase
in
the
amount
of
air
handled
and
can
necessitate
upgrades
to
existing
control
devices.
The
second
approach,
focusing
on
pollution
prevention,
is
to
substitute
low
VOC
or
VOC­
free
materials
for
materials
(
inks,
coatings,
and
adhesives)
presently
in
use.

1.
Inks,
coatings,
and
adhesives
Add­
On
Controls
­
Capture
Systems
Capture
systems
are
designed
to
collect
solvent
laden
air
and
direct
it
to
a
control
device.
In
rotogravure
and
flexographic
printing
processes,
most
of
the
solvent
is
removed
from
the
printed
substrate
by
evaporation
in
a
dryer.
The
exhaust
from
the
dryer
can
be
ducted
to
a
control
device.
Additional
systems
such
as
floor
sweeps
and
hoods
are
often
used
to
collect
solvents
that
evaporate
from
other
parts
of
the
printing
press,
in
addition
to
those
collected
from
the
dryer.
Pressroom
ventilation
air
can
also
be
exhausted
to
a
control
device.
Some
presses
are
contained
and
operated
within
permanent
total
enclosures.
Solvent
laden
air
from
several
presses
may
be
combined
and
ducted
to
a
common
control
device
Differences
in
capture
efficiency
of
the
exhaust
contribute
much
more
to
the
variation
in
overall
efficiencies
than
the
choice
of
control
device.
Test
procedures
have
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
11
been
established
for
determining
capture
efficiency
and
for
confirming
the
presence
of
permanent
total
enclosures
(
PTE).
Capture
efficiency
can
be
determined
according
to
the
EPA
protocols
for
testing
with
temporary
total
enclosures
that
are
specified
in
Methods
204
and
204A
through
F
of
40
CFR
Part
51
Appendix
M.
In
order
to
assume
a
capture
efficiency
of
100
percent
you
must
confirm
that
your
capture
system
is
a
PTE
by
demonstrating
that
it
meets
the
requirements
of
Section
6
of
Method
204
of
40
CFR
Part
51
Appendix
M
and
that
all
exhaust
gases
from
the
enclosure
are
delivered
to
a
control
device.
More
information
on
determining
capture
efficiency
for
rotogravure
and
flexographic
printing
presses,
including
alternative
capture
efficiency
test
procedures
that
do
not
use
temporary
total
enclosure,
is
presented
in
the
Printing
and
Publishing
NESHAP
(
40
CFR
Part
63
Subpart
KK).

Capture
systems
can
be
improved
through
collection
of
additional
solvent
laden
air
from
the
press
area
and
through
construction
of
additional
hooding
and
press
enclosures.
In
theory,
capture
can
be
improved
to
(
nearly)
100
percent
for
any
press
or
pressroom
by
retrofitting
walls
and
increasing
ventilation
to
meet
the
requirements
of
permanent
total
enclosures.
Many
new
presses
have
been
installed
within
permanent
total
enclosures.
Some
existing
facilities
have
modified
their
pressrooms
to
serve
as
permanent
total
enclosures.
There
may
be
space
constraints,
such
as
close
proximity
to
other
machines,
that
limit
the
ability
of
some
presses
to
be
enclosed.
Enclosing
some
presses
may
limit
access
to
the
unit
and
may
cause
increased
temperatures
within
the
enclosure,
which
could
be
an
exposure
concern
for
workers.

The
RACT
recommendations
in
the
1978
CTG
considered
capture
and
control
of
VOC
emissions
from
flexographic
and
rotogravure
presses.
Packaging
rotogravure
presses
were
estimated
to
have
a
capture
efficiency
of
75
percent.
A
lower
capture
efficiency
of
70
percent
was
estimated
for
flexographic
presses
due
to
the
manner
of
construction
of
the
stacked
presses
and
central
impression
presses
in
use
at
that
time.

There
have
been
significant
improvements
in
capture
efficiency
of
flexographic
presses
and
rotogravure
presses
since
1978.
These
improvements
can
be
attributed
to
replacement
of
aging
presses
with
newer
presses,
enclosed
doctor
blades
and
improvements
in
dryer
technology.
In
addition,
more
recent
models
of
central
impression
presses
used
for
flexographic
printing
and
in­
line
presses
used
for
flexographic
printing
or
rotogravure
printing
now
incorporate
capture
systems
within
the
press
design.
Since
around
1990,
many
vendors
have
guaranteed
capture
efficiency
of
85
to
90
percent
without
use
of
a
permanent
total
enclosure.

Many
package/
product
rotogravure
printing
and
wide­
web
flexographic
printing
facilities
use
low
VOC
and
low
HAP
inks
and
coatings.
Dryer
exhausts
from
these
facilities,
presses
or
individual
work
stations
may
be
vented
to
the
atmosphere
without
the
use
of
a
control
device.
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
12
Add­
On
Controls
­
Control
Devices
The
control
devices
in
use
in
flexible
packaging
rotogravure
and
flexographic
printing
processes
include
carbon
adsorbers,
thermal
oxidizers,
and
catalytic
oxidizers.
In
contrast
to
oxidation
techniques,
carbon
adsorption
does
not
destroy
the
VOC
in
the
treated
air
but
recovers
it
for
reuse.
The
selection
of
a
control
device
is
influenced
by
the
type
of
inks,
coatings
and
adhesives
applied
on
the
press,
the
volume
of
solvent
laden
air
to
be
treated,
and
the
operating
schedule
of
the
facility.
The
RACT
recommendations
in
the
1978
CTG
considered
carbon
adsorbers
and
oxidizers
with
90
percent
control
device
efficiency.
Today,
these
control
devices
can
achieve
at
least
95
percent
control
device
efficiency.

Low­
and
No­
VOC
Inks,
Coatings
and
Adhesives
Pollution
prevention
has
been
achieved
by
many
facilities
in
the
packaging
rotogravure
and
flexographic
printing
industries.
Many
facilities
use
waterborne
inks,
and
these
inks
typically
contain
a
small
proportion
of
alcohols
or
glycol
ethers
which
function
to
reduce
surface
tension
and
improve
flow
characteristics.
Waterborne
inks
are
being
successfully
used
for
printing
on
paper
packaging
and
for
printing
on
nonabsorbent
packaging
substrates
such
as
plastics,
aluminum,
and
laminates.
Use
of
waterborne
inks
for
rotogravure
printing
is
increasing;
however,
problems
still
limit
their
use
at
press
speeds
above
1,000
feet
per
minute.
Their
use
may
require
redesign
of
the
system
(
changes
in
ink
formulation,
cylinder
engraving,
press
operation,
and
dryer
design)
for
rotogravure
flexible
packaging
printing.
While
use
of
waterborne
inks
reduces
or
eliminates
VOC
emissions,
their
higher
surface
tension
and
slower
drying
rate
continue
to
be
obstacles
to
their
expanded
use.
Flexographic
printing
is
more
easily
adapted
to
the
use
of
waterborne
inks
and
may
not
require
redesign
of
the
system.
There
is
widespread
use
of
waterborne
inks
in
flexographic
printing.
In
addition,
flexible
packaging
printers
use
a
wide
variety
of
coatings
and
adhesives
including
solvent­
borne,
waterborne,
wax
coatings,
wax
laminations,
extrusion
coatings,
extrusion
laminations,
100
percent
solid
adhesives,
ultra­
violet
cured
coatings,
electron
beam
cured
coatings,
hot
melt
coatings,
and
cold
seal
coatings.

Packaging
rotogravure
facilities
and
flexographic
facilities
produce
a
wide
variety
of
products,
and
flexible
packaging
producers,
in
particular,
print
on
many
different
substrates
within
the
same
facility.
Many
facilities
use
hundreds
of
different
inks
to
print
various
custom
colors
required
by
their
packaging
customers.
Low
VOC
inks,
coatings
and
adhesives
may
not
be
available
to
meet
all
of
the
performance
requirements.
Low
VOC
inks
may
not
be
available
for
all
of
the
substrates
and
in
all
of
the
colors
required
by
some
facilities.

2.
Cleaning
Materials
There
are
two
approaches
to
reducing
VOC
emissions
from
cleaning
materials
used
in
flexible
packaging
printing,
work
practices
and
reducing
the
composite
vapor
pressure
of
the
material
used.
Work
practices
such
as
keeping
solvent
containers
closed
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
13
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
reduce
VOC
emissions.
Cleaning
materials
with
lower
composite
vapor
pressure
(
e.
g.
25
mm
Hg
at
20
º
C)
evaporate
less
readily
than
higher
composite
vapor
pressure
cleaning
materials.
As
a
result,
these
lower
composite
vapor
pressure
materials
generate
less
VOC
emissions
than
higher
composite
vapor
pressure
cleaning
materials
3.
Summary
of
State
and
Local
Regulations
Many
States
and
local
agencies
have
adopted
regulations
for
controlling
emissions
from
flexible
packaging
printing.
At
least
34
States
and
several
more
local
agencies
have
regulations
that
control
VOC
emissions
from
rotogravure
and
flexographic
printing
for
flexible
packaging.
The
majority
of
these
agencies
have
adopted
control
levels
consistent
with
the
1978
RACT
levels
of
65
percent
overall
control
for
rotogravure
and
60
percent
overall
control
for
flexography,
or
use
of
waterborne
or
other
low
VOC
inks
with
less
than
or
equal
to
25
percent
by
volume
VOC
in
their
volatile
fraction,
more
than
60
percent
volume
solids
less
water
and
less
exempt
compounds,
or
less
than
0.5
kg
VOC
per
kg
solids.
The
65
percent
overall
control
efficiency
for
rotogravure
was
based
on
a
90
percent
control
device
efficiency
and
approximately
72
percent
capture
efficiency;
the
60
percent
overall
control
efficiency
for
flexography
was
based
on
a
90
percent
control
device
efficiency
and
approximately
66
percent
capture
efficiency.

The
requirements
for
several
State
and
local
agencies
that
have
adopted
regulations
more
stringent
than
the
current
RACT
requirements
are
summarized
below
in
Table
1.
Local
agencies
in
California
with
regulations
more
stringent
than
RACT
have
requirements
ranging
from
66
to
85
percent
overall
control
efficiency.

A
few
local
air
pollution
control
agencies
have
also
adopted
requirements
for
cleaning
materials.
A
cleaning
materials
summary
is
provided
in
Table
2.
There
is
a
wide
range
of
VOC
limits
for
cleaning
materials,
from
0.42
lb
VOC/
gal
material
to
6.8
lb
VOC/
gal
including
water.

Table
1.
Summary
of
State
and
Local
Agency
Rules
with
Requirements
More
Stringent
than
the
Recommendations
for
RACT
Provided
in
the
1978
CTG
State
or
Local
Agency
Summary
of
State
or
Local
requirements
New
Jersey
75
percent
capture
efficiency
for
rotogravure,
70
percent
capture
efficiency
for
flexography,
and
95
percent
control
device
efficiency
for
thermal
oxidizers.
North
Carolina
95
percent
control
device
efficiency
California:
Antelope
Valley
67
percent
overall
control
efficiency
Bay
Area
85
percent
overall
control
efficiency
El
Dorado
County
95
percent
control
device
efficiency
and
70
percent
capture
efficiency
Kern
County
95
percent
control
device
efficiency
and
90
percent
capture
efficiency;
or
75
percent
overall
control
on
a
daily
basis
Placer
County
95
percent
control
device
efficiency
and
70
percent
capture
efficiency
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
14
Santa
Barbara
67
percent
overall
control
efficiency
South
Coast
75
percent
overall
control
efficiency
San
Joaquin
Valley
67
percent
overall
control
efficiency
San
Diego
County
85
percent
overall
control
efficiency
Sacramento
Metro
95
percent
control
device
efficiency
and
70
capture
efficiency
Ventura
County
75
percent
overall
control
efficiency
Yolo­
Solano
County
75
percent
overall
control
efficiency
Table
2.
Summary
of
State
and
Local
Agency
Limits
for
Cleaning
Solvents
Used
for
Flexible
Packaging
Printing
State
or
Local
Agency
Cleaning
Requirement
California:
Bay
Area
Rotogravure
Printing:
6.7
lb
VOC/
gal
including
water
or
partial
pressure
of
25
mm
Hg
at
20C
Flexographic
Printing:
6.8
lb
VOC/
gal
including
water
and
partial
pressure
of
21
mm
Hg
at
20C
Santa
Barbara
Ink
Application
Equipment
Cleaning,
Printing:
3.75
lb
VOC/
gal
and
33
mm
Hg
at
20C
San
Joaquin
Valley
Ink
Application
Equipment,
Flexographic
Printing:
0.42
lb
VOC/
gal
material
Ink
Application
Equipment,
Rotogravure
Printing,
Packaging:
0.42
lb
VOC/
gal
material
San
Diego
County
Cleaning
Solvent:
1.66
lb
VOC/
gal
material
or
total
vapor
pressure
of
45
mm
Hg
at
20C
Sacramento
Metropolitan
Application
Equipment,
Flexographic
Printing:
0.83
lb
VOC/
gal
including
water
and
exempt
compounds
South
Coast
Ink
Application
Equipment,
Flexographic
Printing:
0.21
lb
VOC/
gal
Ink
Application
Equipment,
Rotogravure
Printing,
Packaging:
0.21
lb
VOC/
gal
Ventura
County
Ink
Application
Equipment,
Flexographic
Printing,
Other
Flexographic:
0.83
lb
VOC/
gal
and
3
mm
Hg
at
20C
Ink
Application
Equipment,
Rotogravure
Printing,
Packaging:
0.83
lb
VOC/
gal
and
3
mm
Hg
at
20C
VI.
Recommended
Control
Options
Recommendations
for
controlling
VOC
emissions
from
inks,
coatings,
adhesives
and
cleaning
materials
used
in
flexible
packaging
printing
operations
are
as
follows:

Coatings,
inks
and
adhesives
used
on
flexible
packaging
printing
presses
The
recommended
level
of
control
for
VOC
emissions
from
coatings,
inks
and
adhesives
used
on
flexible
packaging
printing
presses
is
based
on
the
installation
date
of
the
equipment
as
follows:

 
70
percent
overall
control
for
presses
first
installed
prior
to
March
14,
1995,
and
 
80
percent
overall
control
for
presses
first
installed
on
or
after
March
14,
1995.
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
15
March
14,
1995
was
the
proposal
date
for
the
1996
NESHAP
for
the
printing
and
publishing
industry.
The
70
percent
overall
control
efficiency
is
based
on
a
capture
efficiency
of
75
percent
and
a
control
device
efficiency
of
95
percent.
The
80
percent
overall
control
efficiency
is
based
on
a
capture
efficiency
of
85
percent
and
a
control
device
efficiency
of
95
percent.
As
an
alternative
to
emission
reduction
percentages
specified
above,
we
also
recommend
providing
the
following
two
equivalent
VOC
content
limits
which
can
be
met
by
use
of
low
VOC
content
materials
or
combinations
of
materials
and
controls
as
follows:
(
1)
0.5
kg
VOC/
kg
solids
applied,
or
(
2)
0.10
kg
VOC/
kg
materials
applied
Cleaning
materials
used
on
flexible
packaging
printing
presses
The
recommended
level
of
control
for
cleaning
materials
is
a
composite
vapor
pressure
limit
of
25
mm
Hg
at
at
20
º
C.
This
composite
vapor
pressure
limit
is
based
on
the
limit
in
the
Bay
Area
Air
Quality
Management
District
regulation.
We
also
recommend
that
the
following
work
practices
be
employed:
keeping
cleaning
materials
and
used
shop
towels
in
closed
containers,
and
conveying
cleaning
materials
from
one
location
to
another
in
closed
containers
or
pipes.

VII.
Cost
Effectiveness
of
Recommended
Control
Options
Emissions
data
are
available
for
most
of
the
facilities
identified.
The
emissions
data
include
VOC
data
for
those
facilities
identified
in
the
2002
NEI
database.
The
VOC
data
available
from
the
2002
NEI
were
supplemented
with
additional
HAP
data
available
from
the
1996
NESHAP
where
appropriate.
For
facilities
identified
as
part
of
the
1996
NESHAP
only,
the
HAP
data
from
the
NESHAP
were
used.
In
the
instance
that
only
HAP
data
are
available
for
a
specific
facility,
the
assumption
was
made
that
VOC
emissions
are
equal
to
HAP
emissions,
with
the
recognition
that
most
facilities
use
and
emit
some
VOC
that
are
not
HAP.
(
HAP
emissions
data
from
the
1996
NESHAP
reflect
pre­
implementation
levels
of
that
rule
and
do
not
account
for
reductions
made
to
comply
with
the
NESHAP.)
In
addition,
the
VOC
data
obtained
from
the
NEI
are
the
total
emissions
from
the
source
and
may
include
VOC
emissions
data
from
other
source
categories
at
the
facility
in
addition
to
emissions
from
flexible
packaging
printing.

Baseline
VOC
emissions
are
estimated
at
28,000
tons
per
year
(
ton/
yr)
for
390
of
the
582
facilities
identified
with
available
emissions
data.
The
average
VOC
emissions
per
facility
were
71
ton/
yr.
An
upper
bound
on
the
nationwide
baseline
VOC
emissions
for
flexible
packaging
printing
can
be
estimated
by
assuming
that
there
may
be
up
to
1,071
facilities
and
that
the
facilities
with
emissions
data
are
representative
of
the
total
population.
In
this
case,
nationwide
baseline
VOC
emissions
from
flexible
packaging
printing
would
be
approximately
76,000
ton/
yr.
As
a
lower
bound
on
the
nationwide
baseline
VOC
emissions,
it
was
estimated
that
there
are
approximately
582
facilities.
In
this
case,
nationwide
baseline
VOC
emissions
from
flexible
packaging
printing
would
be
approximately
42,000
ton/
yr.
Therefore
the
nationwide
baseline
emissions
range
from
approximately
42,000
to
76,000
ton/
yr.
Nonattainment
area
VOC
emissions
from
flexible
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
16
packaging
printing
facilities
(
based
on
April
2006
designations)
are
estimated
to
range
from
8,636
to
16,364
Mg/
yr
(
9,500
to
18,000tpy).

Many
facilities
located
in
ozone
nonattainment
areas
are
already
meeting
the
control
levels
being
recommended
in
this
CTG.
These
facilities
may
be
using
capture
and
control
systems
or
low
VOC
content
inks,
coatings
and
adhesives.
The
costs
for
facilities
not
using
low
VOC
content
inks,
coatings
and
adhesives
that
are
not
already
using
control
equipment,
will
vary
depending
on
the
flow
rate,
hourly
solvent
use
rate,
and
operating
hours.
Although
we
do
not
have
detailed
information
for
the
industry
as
a
whole,
we
have
information
for
some
sources
from
which
we
can
estimate
the
likely
emissions
reductions
and
costs
for
a
typical
source
subject
to
control
for
the
first
time.
For
a
press
exhausting
approximately
5,800
cubic
feet
per
minute,
operating
2000
hours
per
year,
and
achieving
70
percent
capture
efficiency,
we
estimate
the
VOC
emission
reduction
to
range
from
30
to
60
mega
grams
(
Mg)
(
33
to
66
tons)
per
year
and
the
cost
effectiveness
to
range
from
$
1,400/
Mg
to
$
3,100/
Mg
($
1,300/
ton
to
$
2,800/
ton)
depending
on
the
average
hourly
solvent
use
rate.
j
At
lower
solvent
use
rates,
the
cost
per
ton
of
emission
controlled
would
likely
be
higher.
Increasing
the
hourly
solvent
use
rate,
annual
operating
hours,
or
capture
efficiency
of
this
size
press
would
increase
the
annual
VOC
emission
reduction
and
improve
the
cost
effectiveness.
Larger
presses
with
proportionately
larger
hourly
solvent
use
rates
would
also
have
larger
annual
VOC
emission
reductions
and
better
cost
effectiveness
than
smaller
presses.

VIII.
References
a.
Control
of
Volatile
Organic
Emissions
from
Existing
Stationary
Sources
 
Volume
VIII:
Graphic
Arts
 
Rotogravure
and
Flexography.
EPA
Publication
No.
EPA­
450/
2­
78­
033.
U.
S.
Environmental
Protection
Agency.
Research
Triangle
Park,
NC.
December
1978.

b.
40
CFR
part
63,
subpart
KK.
National
Emissions
Standards
for
Hazardous
Air
Pollutants:
Printing
and
Publishing
Industry.

c.
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Printing
and
Publishing
Industry
Background
Information
for
Proposed
Standards.
EPA
Publication
No.
EPA­
453/
R­
95/­
002a.
U.
S.
Environmental
Protection
Agency.
Research
Triangle
Park,
NC.
February
1995.

d.
Guidance
to
State
and
Local
Agencies
in
Preparing
Regulations
to
Control
VOCs
from
Ten
Stationary
Source
Categories.
EPA
Publication
No.
EPA­
450
2­
79­
004.
U.
S.
Environmental
Protection
Agency.
Research
Triangle
Park,
NC.
September
1979.

e.
Model
Volatile
Organic
Compound
Rules
for
Reasonable
Available
Control
Technology:
Planning
for
Ozone
Nonattainment
Pursuant
to
Title
I
of
the
Clean
Air
Act.
U.
S.
Environmental
Protection
Agency.
Research
Triangle
Park,
NC.
June
1992.
Available
at
<
http://
www.
epa.
gov/
ttn/
naaqs/
ozone/
ozonetech/
voc_
modelrules.
pdf>.
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
17
f.
2005
State
of
the
Flexible
Packaging
Industry
Report.
Flexible
Packaging
Association
(
FPA).
Linthicum,
Maryland.

g.
2002
National
Emissions
Inventory.
U.
S.
Environmental
Protection
Agency.
Dated
April
11,
2006.

h.
40
CFR
part
63,
subpart
JJJJ.
National
Emissions
Standards
for
Hazardous
Air
Pollutants:
Paper
and
Other
Web
Coating.

i.
Printing
Industry
and
Use
Cluster
Profile.
U.
S.
Environmental
Protection
Agency.
EPA
Publication
No.
744­
R­
94­
003.
June
1994.

j.
Flexographic
Ink
Options:
A
Cleaner
Technologies
Substitutes
Assessment.
EPA
Publication
No.
EPA
744­
R­
02­
001­
A.
U.
S.
Environmental
Protection
Agency.
Draft
CTG
for
Flexible
Packaging
Printers;
EPA
Docket
No.
EPA­
HQ­
OAR­
2006­
0537
18
Appendix
Control
of
Volatile
Organic
Emissions
from
Existing
Stationary
Sources
 
Volume
VIII:
Graphic
Arts
 
Rotogravure
and
Flexography
(
to
be
inserted
here)
