MEMORANDUM

April 18, 2007

To: Dave Salman

From: Gary Jones, Marci Kinter, Doreen Monteleone

Re: Response to Questions Regarding Proposed PFFC CTG Exclusion for
Printing

Please see the responses below to the questions that were raised
regarding the proposed Paper, Film, Foil Coating Control Techniques
Guideline exclusion for printing operations. Each response to the
question has been bolded for easier reference.

I don't have the current draft paper, film and foil CTG for context, but
I think the general direction of this makes sense.  There is "coating"
done on "presses".  When these "presses" or the application of these
"coatings" is within the scope of another CTG (for example, 2006
flexible packaging CTG, 2006 offset lithography and letterpress, 1978
graphic arts CTG) it makes sense for us to say (recommend) that it is
not within the scope of the new paper, film and foil CTG.  The same may
be true in some cases where we don't have a CTG (for example, screen
printing and digital printing).

I have the following comments and questions about the suggested
language:

For purposes of this CTG, any offset lithographic, screen, letterpress,
flexographic, rotogravure, or digital printing and (1) packaging (2)
line including any in-line and (3) auxiliary coating, (4) laminating,
and adhesive application is not subject to the recommendations in this
CTG. (5) Inks, adhesives, and other coating materials used in (6) these
operations are also not subject to the recommended limits of this CTG.

(1)  I don't understand why the word "packaging" is here.  What does it
add that is not already taken care of by listing the various types of
printing?  If it belongs here, why is it "packaging" rather than
"flexible packaging"?

ANSWER:  We included the word packaging to ensure that the definition
includes traditional printing operations as well as packaging operations
that involve printing, such as flexible packaging or other types of
converting, such as folding carton packaging.  If print processes are
considered all-inclusive and not tied to a specific product, then this
term may not be necessary.  

(2) Why "line"?  Why not "press"?

ANSWER:  To the industry, “line” is more inclusive of all activities
associated with the actual production of a product, and includes not
only the printing press but also associated work stations where coating,
adhesive application, laminating, etc., are performed.  Since these work
stations are not “printing” operations, they are not technically
part of a press.  The term “line” has been included in other
printing and coating regulations and CTGs (e.g., 40 CFR 60 Subpart FFF,
40 CFR 63 Subpart OOOO, and the 2006 Flexible Package Printing CTG),
where its use has been essentially interchangeable with the term press. 
Although the printing operations are performed on a “press”, we need
to be clear that these other associated in-line activities and work
stations should be considered part of the printing operation.  

(3) What does "auxiliary" mean?  Does it mean that it is not "in-line"?

If a coating is applied on a machine that is distinct and separate from
a "press", then maybe it should be within the scope of paper, film and
foil.  I am thinking of situations that parallel stand-alone equipment
(formerly stand-alone coating equipment) in the printing and publishing
MACT.  The printing and publishing MACT provided the owner/operator with
the choice of including stand-alone equipment in the printing and
publishing affected source or including it in an affected source under
another MACT (most likely paper and other web coating).  I don't recall
if we discussed this in the 2006 flexible packaging CTG.

ANSWER:  The term “ancillary” is perhaps more appropriate than
“auxiliary”. Ancillary coating would mean a process performed on
equipment and process units that are part of the overall printing and
packaging facility. This equipment could be either in-line or
stand-alone. The off-line ancillary operations perform a similar
function to in-line equipment and the materials used would be the same
as in-line materials.  We do not believe stand-alone equipment should be
covered by the paper, foil, and film CTG if the equivalent in-line
equipment is not.  Our view is that if the materials used on a press or
printing line are excluded from this CTG, then these same materials
should be excluded if applied on a stand alone piece of equipment.  

(4) Why is "laminating" here? Does it add something that is not covered
by "adhesive"?

ANSWER:  Laminating activities are often found in flexographic and
digital operations and should therefore be considered part of the
printing operation.  Laminating typically involves solid materials and
may or may not involve an adhesive. Since coating is so broadly defined,
we believe it is important to include this activity in the definition.  

(5) What is this sentence adding that is not covered by the previous
sentence?

ANSWER:  This sentence specifically identifies the materials, and not
the processes.  Due to EPA’s broad definition of coating materials, we
believe it is important to reiterate in the CTG that these materials,
when used in the printing and packaging processes, are excluded from
this source category and should not be subject to a future VOC content
limit.

(6) What does "these operations" means here?  Is it the same as "lines"

("presses") in the previous sentence? If so, why not say "lines"

("presses") here?

ANSWER:  The term “these operations” refers back to the press,
in-line, and ancillary operations.  Again, if the terms are sufficiently
defined to include these operations, then this sentence may not be
necessary.  

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