MEGTEC
Systems
A
Unit
of
Sequa
Corporation
830
Prosper
Road,
PO
Box
5030
De
Pere,
WI
54115­
5030
Telephone:
(
920)
339­
2789
Fax:
(
920)
339­
2784
Email:
srach@
megtec.
com
21
June
2006
Mr.
David
Salman
United
States
EPA
U.
S.
EPA
(
MD­
13)
Research
Triangle
Park,
NC
27711
Dear
David:

In
our
discussion
on
the
13th
of
this
month,
we
discussed
your
desire
to
obtain
data
on
flows
and
VOC
loading
for
both
flexographic
and
rotogravure
presses
used
in
flexible
packaging.
This
request
is
due
to
your
providing
assistance
to
your
associates
in
relationship
to
the
183e
determination
on
a
national
rule
vs.
a
CTG
for
flexible
packaging.

As
I
noted,
both
flows
and
VOC
loading
for
these
presses
are
extremely
variable
due
to
factors
like,
age
of
the
press,
printed
product
layout,
press
speeds,
and
many
other
items.
In
our
conversation
we
did
not
discuss
the
subject
of
capture
and
destruction
efficiency,
which
I
noted
was
covered
in
the
materials
sent
to
you
by
Ram
Singhal
of
the
Flexible
Packaging
Association
following
the
visit
to
RTP
on
May
22nd
by
some
of
the
Environmental
Committee
members
of
the
association.
Therefore,
let's
address
what
I
found
based
on
your
request
on
the
13th.

I
have
spend
the
past
few
evenings
reviewing
various
client
project
files
to
look
at
existing
as
well
as
new
presses.
What
I
found
was
even
more
diverse
than
I
thought
I
would
find.
We
can
start
with
flexographic
presses,
where
the
exhaust
flows
vary
from
1,500
scfm
to
9,000
scfm
for
existing
presses.
The
variables
include;
web
width,
number
of
colors,
web
speed,
if
recirculation
is
included
or
not.
For
new
presses
the
range
is
even
larger,
due
to
some
of
the
presses
being
provided
to
operate
at
speeds
approaching
2,000
fpm
and
web
widths
that
are
double
what
was
offered
a
number
of
years
ago.
At
the
opposite
end
are
small
presses
designed
for
specific
market
segments
that
can
have
flows
as
low
as
1,000
scfm.
When
we
at
MEGTEC
Systems
look
at
a
press,
we
are
concerned
with
the
maximum
VOC
loading
to
insure
the
oxidizer
can
handle
that
loading,
while
also
looking
at
averages
to
insure
the
technology
can
operate
in
a
manner
that
is
energy
efficient.
A
"
typical"
flexible
packaging
application
would
have
an
average
VOC
loading
of
1.5
to
2.5%
LFL
concentrations,
with
the
upper
end
being
in
the
10%
range.
Mr.
David
Salman
21
June
2006
United
States
EPA
Page
2
In
the
rotogravure
packaging
printing
presses,
I
looked
at
the
same
data
on
flows
and
VOC
loading.
The
variability
in
both
areas
mirrors
what
is
seen
in
the
flexographic
process.
At
one
time
rotogravure
was
a
technology
that
was
almost
exclusively
for
high
speed,
heavy
ink
coverage,
long
run
printing
projects.
In
the
past
few
years
that
has
changed
with
newer
presses
that
allow
for
fast
changeover
and
short
runs,
to
compete
with
the
flexographic
vendors.
We
have
seen
gravure
presses
with
exhaust
rates
under
2,000
scfm
and
at
the
other
end
of
the
spectrum
we
see
flows
of
over
30,000
scfm.
There
has
always
been
a
perception
that
VOC
loading
from
gravure
presses
were
very
high
and
the
clients
of
the
flexible
packaging
gravure
printers
and
the
press
manufacturers
have
changed
that.
Today
we
see
VOC
loadings
from
1.5%
to
5%
LFL,
so
the
amount
of
VOCs
are
similar,
but
the
average
may
be
slightly
higher
due
to
the
number
of
older
presses
still
installed
and
in
operation.

The
data
I
reviewed
are
those
clients
who
we
have
worked
on
in
the
US
where
we
have
between
400
&
450
units
installed.
In
addition
I
also
looked
at
an
added
50
printers
in
Canada
where
they
are
still
awaiting
final
regulations
for
the
flexible
packaging
printing
community.
In
my
initial
effort
to
delve
into
this
subject,
I
had
some
pre­
conceived
notions
that
the
flows
and
VOC
loadings
would
be
rather
tightly
grouped
together.
In
looking
at
the
detailed
data,
I
found
I
was
wrong,
the
variability
is
quite
high
and
the
numbers
I
was
looking
for
were
based
on
market
sub­
segment,
age
of
presses,
and
how
the
printers
accomplish
their
goals
of
meeting
client
expectations.
This
supports
my
long
held
belief
that
of
the
hundreds
of
industries
we
supply
equipment
to;
the
flexible
packaging
industry
has
due
to
product
and
client
expectations,
the
highest
variability
in
their
facilities
of
any
other
industry.

I
would
guess
with
a
couple
weeks
time,
I
could
prepare
a
detailed
chart
showing
all
of
those
variables,
but
at
this
point,
I
wanted
to
get
this
letter
back
to
you
as
soon
as
possible
as
you
noted
you
are
under
a
very
tight
schedule.
If
you
have
questions
on
this
letter
or
I
can
be
of
added
assistance,
please
let
me
know.

Sincerely,

Steven
E.
Rach
MEGTEC
Systems,
Industrial
Emission
Control
Products
CC:
R.
Singhal
 
Flexible
Packaging
Association
K.
Zak
­­
MEGTEC
Systems
