Date:		August 25, 2006

Subject:	Minutes to Meeting with the Flexible Packaging Association

		Section 183(e) Controls for Flexible Packaging Printing

EPA Contract No.: 68-D-01-073; EPA Work Assignment No.:  4-15

		RTI International Project No.:  0208220.004.015

From:		Dave Reeves and Roy Neulicht

		

To:		Paula Hirtz

		OAR/OAQPS/SPPD/CCG

		U.S. Environmental Protection Agency

		Research Triangle Park, NC  27711

Introduction

The Flexible Packaging Association (FPA) requested a meeting with the
U.S. Environmental Protection Agency (EPA) to obtain clarifications and
verbally present comments on the proposed control techniques guidelines
(CTG) document under section 183(e) of the Clean Air Act for flexible
packaging printing.  The meeting was held on August 25, 2006 at U.S. EPA
facilities in Research Triangle Park, North Carolina.

Attendees

Ram Singhal, Flexible Packaging Association

Howard Hofmeister, Bemis

David Yount, Oracle Packaging

Dan Williams, Sealed Air.

Leslie Ritts, Hogan and Hartson LLP (by telephone)

David Ellison, Alcan Packaging (by telephone)

Brian Galley, Alcan Packaging (by telephone)

Paula Hirtz, U.S. EPA

Bruce Moore, U.S. EPA 

David Salman, U.S. EPA

K.C. Hustvedt, U. S. EPA

Ragan Tate, U. S. EPA:OGC

Geoff Wilcox, U.S. EPA:OGC

Roy Neulicht, RTI International

Dave Reeves, RTI International

Discussion

Ms. Paula Hirtz opened the meeting by welcoming the attendees, and brief
introductions were made.  Mr. Singhal and the other industry
representatives gave a brief summary of the flexible packaging industry
and stated their purpose for the meeting was to provide some initial
comments regarding the draft CTG that was recently published in the
Federal Register.  They also indicated that they would be providing
consolidated comments to the docket by the end of the comment period
(September 5, 2006). 

Mr. Singhal indicated they had 5 items they wanted to address: 1)
Applicability, 2) Cost effectiveness, 3) Cleaning solvents, 4) Usage of
water-based materials, and 5) The overall emissions standards. 

Applicability

The first item that was discussed involved applicability criteria.  The
draft CTG states that it applies to flexible package printing operations
that emit at least 6.8 kg/day (15 lb/day) VOC before consideration of
controls.   There is concern about the applicability cutoff because most
states with the 15 lb/day limit have it applying to individual lines –
not the overall printing operation.   Mr. Hofmeister commented that much
smaller operations would be included with such a limit and would likely
cause many facilities to change lines or move small print jobs (and
equipment) to other locations.  

The second discussion item also related to applicability and the
exception for flexible package printing operations with potential to
emit at least 25 tons per year (tpy) of VOC from inks, coatings, and
adhesives combined before consideration of controls.  Ms. Ritts asked if
both applicability criteria had to be met, or if they were to be
evaluated separately.  Mr. Salman clarified that for any operation
exceeding the 15 lbs VOC emissions per day and having less than 25 tpy
of potential VOC emissions, that facility would only be subject to the
cleaning material requirements.

There were also comments and concerns about the 25 tpy cutoff being much
lower than the typical state (permit) level of 100 tpy, or 50 tpy for
ozone nonattainment areas.  Ms. Ritts stated that if the final CTG still
includes these applicability criteria, all major sources would have to
comply with the CTG (RACT) requirements.  Mr. Hofmeister asked that the
language on applicability be reviewed and clarified.

Related to the 25 tpy applicability cutoff, several questions were asked
about the cost effectiveness calculations documented in the draft CTG. 
Mr. Hofmeister commented that it appeared the range of costs were based
on cutoffs using 50 and 100 tpy.  Mr. Neulicht stated that the
calculations were based on example facilities with 50 and 100 tpy VOC
emissions.  Mr. Hofmeister then stated that they had done some
calculations and had came up with comparable cost effectiveness values
for 50 and 100 tpy.  However, when they did calculations for 25 tpy, the
cost effectiveness increased significantly.  For the simplest approach
using one printing press, the cost effectiveness increased to $6,000/ton
VOC.  When they used an example facility with 4 presses contributing to
the 25 tpy, the cost effectiveness jumped up to $7,400/ton due to the
increased ductwork and hardware costs.

Small-Unit Exemption

Mr. Ellison asked if there could be a small unit exemption – similar
to what they currently have in a lot of their state permits.  He stated
that there are several small printing presses using less than 500 pounds
of VOC per year and they are not vented to an oxidizer currently.  Mr.
Wilcox then asked what the mechanism is for keeping track of the
production or material usage data for such equipment.  Ms. Ritts
commented that many facilities use the same inks on different presses. 
Mr. Ellison further commented that the recordkeeping approach is largely
dependent on how the facility is permitted.  Often times, presses are
grouped together and material usage is tracked for the group. 

Averaging Provisions

Mr. Hofmeister asked about averaging provisions.  Mr. Wilcox stated that
the Agency has difficulty with averaging provisions for certain
industries where the recordkeeping and calculations are overly
burdensome and end up being nothing more than paper exercises with no
real environmental benefit. Mr. Salman responded that they (EPA)
envisioned some type of daily weighted averaging being allowed on a
single press, but not cross-line or multi-line averaging. 

Mr. Hofmeister asked if the recommended level of control for VOC
emissions from coatings, inks, and adhesives and cleaning materials was
an overall control (e.g., 70 or 80 percent), or was the basis for the
overall numbers (cited in the examples) to be included as part of the
recommended control option.  Ms. Hirtz clarified that only the overall
control value should be considered and stated that additional language
will be added to the final CTG to make sure that is understood.   

VOC Content Limits

Mr. Williams asked about the alternative compliance option involving VOC
content limits based on different units.  Mr. Salman responded by
stating that the VOC content limit was derived from the 1978 CTG and the
intent of the different units was to have them be equivalent for typical
materials used by the flexible package printing industry.  There was
further discussion of what a typical ink is and the volatile portion
versus the exempt portion.  Mr. Williams commented that waterborne inks
are most compatible for paper substrates, but do not always work on film
or foil.  The proposed limits could drive some applications away from
water-based materials.

Cleaning Materials

Mr. Hofmeister then mentioned some concern with the vapor pressure limit
for clean-up materials.  One of industry’s primary concerns is that
the recommended level of control for cleaning materials is a composite
vapor pressure limit of 25 mm mercury (Hg) at 20º C and several of
their common cleaning solvents used on printing presses, such as ethyl
acetate, have vapor pressures greater than 25 mm Hg.  Acetates tend to
be good cleaners and if industry had to switch to alcohols, cleaning
operations would require more cleaning material and increase disposal
costs.  Mr. Hofmeister commented that the best use of cleaning solvent
is being able to reuse the material in the printing process.  Ms. Ritts
asked how strongly EPA feels about the cleaning material requirements. 
Mr. Hofmeister stated that the industry as a whole agrees with the work
practice recommendations.  Mr. Yount also stated the North Carolina
Department of the Environment and Natural Resources (DENR) regulates
cleaning solvent containers as they sit at the facility and has periodic
inspections.

Mr. Williams stated that many of the newer presses have automatic
solvent reclaim systems and the cleaning solvent is purged through the
lines, captured, and sent back to a holding reservoir.  There was some
additional discussion about total enclosures and other limits used in
different parts of the country.  Bay Area Air Quality Management
District (BAAQMD) Rule 820-309 for Specialty Flexible Packaging has the
same vapor pressure limit (25 mm Hg) and a density limit of 7.4 lbs/gal
(880 g/L).  Mr. Ellison commented that such limits have resulted in a
very few flexible packaging facilities remaining in BAAQMD. 

Model Rule

The last discussion topic was model rule language.  Ms. Ritts asked if
such language would be included in the final CTG.  Mr. Wilcox stated
that as a general proposition, model rule language associated with a CTG
gets close to actual rule language.  There is a disincentive to have
such language included in the CTGs because of the court-mandated
schedule and potential legal issues.  Several of the industry
representatives expressed their concerns with consistency issues from
state to state and the likely confusion. They then asked if a model rule
might be developed later (after the final CTG) as part of the
implementation effort.  Mr. Moore commented that there is no budget for
any follow-on activities.  Mr. Hofmeister requested that some type of
implementation document be made available to states prior to their SIP
submittal.  He also stated that such RACT rules will likely be
implemented beyond non-attainment states and will have significant
implementation/integration issues.

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