Public Webinar: Chapter 161 Offset Lithography and Letter Press printing Regulation

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Public Webinar Chapter 161Offset Lithography
and Letter Press printing Regulation

• May 8, 2009
• Webinar hosted by
• Maine DEP Air Bureau
• Deb Avalone-King
• Lisa Higgins
• Ed Cousins

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Webinar Goals

• Review key elements of the regulation
• Examine draft worksheet on how to calculate
  emission levels
• Consider questions and concerns
• Identify additional resource info needed

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New Regulation Chapter 161

• Section 1 Applicability
• Section 2 Definitions
• Section 3 Emission Control Limits
• Section 4 Compliance Test Methods
• Section 5 Monitoring Recordkeeping
• Section 6 Retention Factors,
• Capture Efficiencies
• Section 7 Handling, Storage Disposal

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Section 1 Applicability(Applies Statewide)
Applies to any offset lithograhy or letterpress
printers whose actual emissions are greater
than 3 tons VOCs per rolling 12 month period.
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What are VOCs?
Volatile Organic Compounds (VOC)means any
compound of carbon, excluding carbon monoxide,
Carbon dioxide, carbonic acid, metallic carbides
or carbonates, and ammonium carbonate, which
participates in atmospheric photochemical
reactions. e.g. alcohol, a common ingredient
in fountain solution is a VOC

• This definition excludes organic compounds which
  have been
• determined to have negligible photochemical
  reactivity.
• A list of excluded compounds can be found in
  definition 162 at
• http//www.maine.gov/sos/cec/rules/06/096/096c100
  .doc

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Section 3 Emission Control Limits

• Work Practices
• Fountain Cleaning Solution VOC limits
• Emission Control System Requirements for Heatset
  Dryers (gt25 tons/year emissions)

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Work practices

• New and used VOC-containing ink, fountain
  solution, cleaning solutions to be stored in
  closed/sealed containers when not in use.
• Spills minimized
• Applicators stored in closed containers

Handling, storage and disposal in accordance with
Hazardous Waste Management laws where applicable.
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There are 3 types of Fountain Solution approaches
for minimizing VOC emissions

• Alcohol substitute means any non-alcohol
  additives that contain VOCs and are used in the
  fountain solution including but not limited to
  ethylene glycol or glycol ether compounds. Some
  additives are used to reduce the surface tension
  of water others are added to prevent piling (ink
  build-up).
• Alcohol means any of the following compounds,
  when used as a fountain solution additive for
  offset lithographic or letterpress printing
  ethanol, n-propanol, and isopropanol.
• Fountain Solution Reservoir. Fountain Solution
  Reservoir means the collection tank that accepts
  fountain solution recirculated from printing
  unit(s). In some cases, the tanks are equipped
  with cooling coils for refrigeration of the
  fountain solution.

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Heatset Fountain Solution Limits

• Fountain solutions with alcohol substitutes,
  maintain VOC content at or below 5.0
• Fountain solutions with alcohol, maintain VOC
  content below 1.6 by weight, or
• Refrigerated fountain solutions with alcohol at
  or below 3.0 VOC by weight _at_ 60 o F

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Sheet-Fed Fountain Solution Limits

• Fountain solution with alcohol substitutes with
  VOC at or below 5.0, by weight
• Fountain solution contains alcohol, maintain
  as-applied VOC content at or below 5.0, by
  weight
• Refrigerated Fountain solution w/alcohol,
  maintain as-applied VOC content at or below 8.5
  by wt. _at_ 60 o F

Exemption sheet-fed presses with sheet size
11x17 inches or smaller, or with total fountain
solution reservoir of less than one gallon.
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Coldset Fountain Solution Limits

• Maintain the Fountain Solution, as-applied VOC
  content at or below 5.0, by weight with no
  alcohol in the fountain solution

Exemption sheet-fed presses with sheet size of
11x17 inches or smaller or with fountain solution
reservoir of less than one gallon
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Cleaning Solvent Limits

• Use cleaning solvents that have
• a composite partial vapor pressure less than 10
  mm HG _at_20 o C or
• VOC content less than 70 by weight.
• (refer to msds sheet)

• Exemption For non-press or press parts cleaning
  may use up to 110 gallons of higher VOC content
  solvents in any 12 month period.

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Emission Control Systems for Heatset Dryers

• Units with gt25 tons/year VOC, before controls,
  shall be equipped with a control system and meet
  operational requirements.

Exemption Heatset presses used for book printing
or with maximum web width of 22 inches or less do
not require control system.
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Heatset PressesEmission Control Technology
operational requirements

• Existing control systems shall reduce VOCs from
  each dryer by at least 90 with a maximum outlet
  concentration of 20 ppmv, as hexane on a dry
  basis
• Newly installed control systems shall reduce VOCs
  from each dryer by at least 95.

• Dryer pressure to be maintained lower than
  pressroom air pressure at all times in operation.
• Control device operating at all times press in
  operation
• Device and monitoring equipment calibrated,
  operated and maintained to manufacturers specs
  and in compliance with all test method
  requirements.

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Monitoring Recordkeeping

• Records to be kept for 6 years, available for
  inspection during normal business hours and
  copies provided to DEP/EPA upon request
• Heatset dryers log of operating conditions,
  calibrations, with continuous temperature
  monitoring and recording every 15 minutes.
• Control System - Log of operating times (control
  device, monitor and presses)
• thermal oxidizers (3 hour temperature log)
  catalytic oxidizers (3 hour temp. log), and
• catalytic beds (annual inspections).

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Recordkeeping for Heatset or Sheet-fed systems
w/ Fountain solution containing alcohol

• Altered solutions measured with hydrometer /-
  0.5 accuracy
• Daily temperatures (refrigerated w/alcohol
  content)
• Batch mixing records
• Volume/VOC content of concentrated alcohol
  substitutes added
• Volume of alcohol added, volume of water added,
  calculated VOC content of final batch
• Date and time each batch prepared

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Recordkeeping for Coldset systemsFountain
solution containing alcohol

• Document all periods of time fountain solution
  containing alcohol is used, its VOC content and
  volume.

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Record keeping of Cleaning Solutions

• Monthly records of VOC content or VOC composite
  partial vapor pressure of all cleaning materials
  used
• Amount in gallons of all clean up materials
• Amount in gallons of exempted higher VOC content
  cleaning materials.

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How to calculate VOC emissions?

• Information needed
• Name and quantity of any ink, fountain solution,
  cleaning solvent and any other material used for
  operation, maintenance or cleaning
• Material Safety Data Sheets with VOC info for all
  inks, fountain solutions and cleaning solvents
  purchased and used.

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1) Invoices and usage records provide info on
what chemicals you purchased and how much.2)
Inventory whats left each month and whats been
disposed of as waste.
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3) Use MSDS sheets to find VOC data
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• 4) Complete
• a VOC Emissions Worksheet using data
• from
• Invoices,
• Inventory
• MSDS sheets.

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Example Heatset VOC Worksheet
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Questions or Comments?

• Send comments on Chapter 161 Working Draft
  Regulation via email to
• debbie.j.avalone-king_at_maine.gov
• Deadline for comments on working draft
• May 22, 2009

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FMI

• Air
• Chapter 161 Working Draft and worksheets
  www.maine.gov/dep/air/regulations/specialntc.htm
• Chapter 100 Definitions www.maine.gov/sos/cec/rul
  es/06/096/096c100.doc
• Chapter 132 Graphic Arts-Rotagravure and
  Flexography
• www.maine.gov/sos/cec/rules/06/096/096c132.doc
• BHWM Handbook for Hazardous Waste Generators
• www.maine.gov/dep/rwm/hazardouswaste/pdf/hwhandbo
  ok.pdf
• Also see Chapter 851 Standards for Generators
  of Hazardous Waste
• www.maine.gov/sos/cec/rules/06/096/096c851.doc
• BHWM Chapter 850 Identification of Hazardous
  Wastes
• www.maine.gov/sos/cec/rules/06/096/096c850.doc
• More useful and informative site, an Industry
  association sponsored
• www.pneac.org/sheets/PrintingSector.cfm?PrintingS
  ector4