UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	August 5, 2010

SUBJECT:	Technical Support Document for Maryland’s Adoption of Control
Techniques Guidelines for Flexible Packaging Printing 

			/s/

FROM:	Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO:		File

			/s/	

THRU: 	Maria A. Pino, Acting Associate Director 

Office of Air Program Planning

A.  BACKGROUND  

What is the flexible package printing CTG?

Section 172(c)(1) of the Clean Air Act (CAA) 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 volatile organic
compound (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 CAA. 

The CTG for flexible package printing is intended to provide state and
local air pollution control authorities information that should assist
them in determining RACT for VOCs from flexible package 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 VOCs from flexible package
printing facilities.

In December 1978, EPA published a CTG for graphic arts (rotogravure
printing and flexographic printing) that included flexible package
printing. The 1978 CTG discusses the flexible package 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.  

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
package printing.  

In September 2006, after conducting a review of currently existing state
and local VOC emission reduction approaches for flexible package
printing, reviewing the 1978 CTG and the 1996 NESHAP for the printing
and publishing industry (40 CFR Part 60, Subpart KK), and taking into
account the information that has become available since then, EPA
developed a new CTG for flexible package printing entitled Control
Techniques Guidelines for Flexible Package Printing (Publication No. EPA
453/R-06-003).  

What is 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, liners, and wraps utilizing paper,
plastic, film, aluminum foil, metalized or coated paper or film, or any
combination of these materials.  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 wide-web flexographic printing.

Printing, coating, and laminating may all be performed on or in-line
with a flexible package 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
non-packaging materials such as gift wraps and hot stamp foils. The
industry makes a distinction between labels and wrappers, which are
package components, and a product that becomes the entire package and
should be called a flexible package.  Any printing of shrink-wrap labels
or wrappers conducted on or in-line with a flexible package printing
press is also considered to be included under the flexible packaging
source category.  Printing of self-adhesive labels would not be
considered flexible packaging.

Rigid packaging printing operations are often co-located with flexible
package 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.

There are two types of printing processes used by flexible package
printing facilities: (1) rotogravure printing; and (2) flexographic
printing.  And there are two main sources of VOC emissions from flexible
package printing for both rotogravure and flexographic: (1) evaporation
of VOC from inks, coatings, and adhesives, and (2) evaporation of VOCs
from cleaning materials.

There are two approaches to reducing VOC emissions from inks, coatings,
and adhesives used in the flexible package 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 up-grades 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.

EPA’s Recommended Control Options for Flexible Package Printing

EPA issued a CTG for Flexible Packaging Printing on September 2006 (EPA
453/R-06-003).  Recommendations for controlling VOC emissions from inks,
coatings, adhesives and cleaning materials used in flexible package
printing operations are outlined in the CTG and are as follows: 

Coatings, inks and adhesives used on flexible package printing presses: 

The recommended level of control for VOC emissions from coatings, inks
and adhesives used on flexible package printing presses is tied to the
first installation date of the equipment. The first installation date
for a piece of equipment does not change if the equipment is later moved
to a new location.  For example, a brand new press first installed in
1992 is moved to a new location in 1998 – the first installation date
for this press is still 1992.  Or, if a brand new control device first
installed in 2004 is moved to a new location in 2009 – the first
installation date for this control device is still 2004.  The first
installation date for a control device does not change if it is later
used to control a new press.  For example, if a brand new press is
installed in 2009 and emissions from this press are controlled by a
control device that was first installed in 2002, then the first
installation date for this press is 2009 and the first installation date
for this control device is still 2002. 

      The recommended control levels in EPA’s final CTG include the
following: 

• 65 percent overall control for a press that was first installed
prior to March 14, 1995 and that is controlled by an add-on air
pollution control device (APCD) whose first installation date was prior
to the effective date of the State RACT rule. 

• 70 percent overall control for a press that was first installed
prior to March 14, 1995 and that is controlled by an add-on APCD whose
first installation date was on or after the effective date of the State
RACT rule. 

• 75 percent overall control for a press that was first installed on
or after March 14, 1995 and that is controlled by an add-on APCD whose
first installation date was prior to the effective date of the State
RACT rule. 

• 80 percent overall control for a press that was first installed on
or after March 14, 1995 and that is controlled by an add-on APCD whose
first installation date was on or after the effective date of the State
RACT rule. 

As an alternative to emission reduction percentages specified above, EPA
also recommends 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) 0.8 kg VOC/kg
solids applied, or (2) 0.16 kg VOC/kg materials applied.  These VOC
content limits are consistent with an 80 percent overall emissions
reduction level and reflect similar control levels as the capture and
control option.  The VOC content limits can be met by averaging the VOC
content of materials used on a single press, i.e., within a line.  

Cleaning Materials Work Practices at Flexible Package Printing Presses: 
Recommended work practices for cleaning materials are to keep cleaning
materials and used shop towels in closed containers, and convey cleaning
materials from one location to another in closed containers or pipes.

B.  STATE SUBMITTAL

On April 23, 2010, Maryland Department of the Environment (MDE)
submitted to EPA a SIP revision concerning the adoption of the EPA CTG
for flexible packaging printing.  EPA develops CTGs as guidance on
control requirements for source categories.  States can follow the CTGs
or adopt more restrictive standards.  MDE is adopting EPA’s CTG
standards for flexible packaging printing and work practices (see EPA
453/R-06-003, September 2006).  This SIP revision includes amendments to
Regulation .10 and a new regulation .10-1 under COMAR 26.11.19, Volatile
Organic Compounds from Specific Processes.  This action affects sources
that use flexographic and rotogravure presses to print flexible
packaging materials.  

COMAR 26.11.19.10 – Flexographic and Rotogravure Printing is amended
as follows to include language pertaining to flexible packing printing:

Section .10(B)(2):  The provisions of this regulation (ie. COMAR
26.11.19.10) do not apply to printing on fabric, metal, plastic, or to
flexible package printing subject to COMAR 26.11.19.10-1.

Section .10(C)(1):  A person who owns or operates a printing press that
uses flexographic, packaging rotogravure, or publication rotogravure
methods and is a major stationary source shall reduce emissions by using
water-based inks that contain less than 25 percent VOC by volume of the
volatile portion of the ink, or high solids inks that contain not less
than 60 percent by weight nonvolatiles.

COMAR 26.11.19.10-1 – Flexible Packaging Printing is being added:

Section .10-1(A):  Includes definitions for flexible packaging, flexible
packaging coatings, flexible packaging printing, and flexible packaging
printing line.

	Section .10-1(B):  Describes the applicability of this regulation.

Section .10-1(C):  Describes emission standards and requirements for
major stationary sources that perform flexible packaging printing.  

Section .10-1(C)(1):  Emissions are either reduced by using water-based
inks that contain less than 25 percent VOC by volume of the volatile
portion of the ink, or high solids inks that contain not less than 60
percent nonvolatiles.  

Section .10-1(C)(2):  If compliance cannot be achieved through use of
the water-based inks or high solids inks described above in (C)(1), the
source shall reduce the VOC content of each ink, or reduce the average
VOC content of inks used at each press as follows:

60 percent reduction for flexographic presses;

65 percent reduction for packaging rotogravure presses; and

75 percent reduction for publication rotogravure presses.

Section .10-1(D):  Describes additional emission standards and
requirements for a person who owns or operates a flexible packaging
printing line with potential to emit VOCs of 25 tons or more per year. 
Compliance is met by:

Section .10-1(D)(1):  Limiting the VOC content of each flexible
packaging coating or limiting the average VOC content of flexible
packaging coatings of the line to not more than:

0.8 lb VOC/lb or kg VOC/kg solids applied; or

0.16 lb VOC/lb or kg VOC/kg materials applied; or by that described in
Section .10-1(D)(2).

Section .10-1(D)(2):  Venting the dryer exhaust of the line through a
control device that is constructed, operated, and maintained to achieve
an overall control efficiency of:

65 percent overall control for a press that was first installed prior to
March 14, 1995 and that is controlled by an add-on APCD whose first
installation date was prior to the effective date.

70 percent overall control for a press that was first installed prior to
March 14, 1995 and that is controlled by an add-on APCD whose first
installation date was on or after the effective date of the rule.

75 percent overall control for a press that was first installed on or
after March 14, 1995 and that is controlled by an add-on APCD whose
first installation date was prior to the effective date of the rule.

80 percent overall control for a press that was first installed on or
after March 14, 1995 and that is controlled by an add-on APCD whose
first installation date was on or after the effective date of the rule.

C.  EPA EVALUATION

The State of Maryland has adopted the standards and requirements of the
CTG for flexible packaging printing and is amending its SIP to reflect
these amendments.  The maximum benefit from these amendments will be
provided during the ozone season when VOCs readily combine with NOx to
form ground-level ozone.  Therefore, this revision will help Maryland
attain and maintain the NAAQS for ozone.  

D.  CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The adoption of the EPA CTG requirements for flexible packaging printing
by the State of Maryland will result in the reduction of VOC emissions
from flexible packaging printing.  EPA approval of the SIP revision is
recommended

  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.

