New PA Flexible Packaging Requirements

The Pennsylvania Department of Environmental Protection (DEP) has adopted new requirements for owners and operators of affected printing presses.  The requirements will be adopted as part of 25 PA Code Sections 129.67a and 129.67b, which limit volatile organic compound (VOC) emissions from inks, coatings, fountain solutions, adhesives, and cleaning solutions used or applied with flexible packaging printing presses, offset lithographic printing presses, and letterpress printing presses.

The final provisions include information on the following:

  • VOC Content Limits
  • Reporting
  • Requirements for add-on controls
  • Sampling and testing
  • Compliance monitoring
  • Work practices for cleaning activities
  • Recordkeeping

The requirements also include the following compliance methods:

  • The use of add-on controls
  • Federally enforceable limitations on the hours of operation
  • The use and application of low VOC-content or VOC-free inks, coatings, and adhesives; or
  • A combination of these methods

Section 129.67a regulates the flexible packaging printing press facilities.  Affected operations include:

  • Owners and operators of a flexible packaging printing press with total actual VOC emissions from all inks, coatings and adhesives combined from all flexible packaging printing operations at the facility, and all emissions from related cleaning activities, equal to or exceeding 450 pounds per month or 2.7 tons per 12-month rolling period, before consideration of add-on controls.
  • Section 129.67a also applies to an individual flexible packaging printing press with potential VOC emissions from the dryer, before consideration of add-on controls, of at least 25 tons per year (tpy) of VOCs from inks, coatings or adhesives or a combination of these materials.
    • For add-on control devices, the regulation requires an overall VOC control efficiency of 65 percent to 80 percent for each affected flexible packaging printing press, depending on date of first installation of the press and of the control device.
  • The regulation also includes requirements for the control of the VOC content of cleaning solutions and work practice standards for cleaning activities.

Section 129.67b regulates heatset web offset lithographic printing presses and heatset web letterpress printing presses.  Affected operations include:

  • Section 129.67b affects the owner and operator of a heatset web offset lithographic printing press or a heatset web letterpress printing press if the actual VOC emissions from all inks (including varnishes), coatings and adhesives, combined, from all offset lithographic printing presses and all letterpress printing presses, and emissions from related cleaning activities at the facility are equal to or exceed 450 pounds per month or 2.7 tons per 12-month rolling period, before consideration of add-on controls.
  • An individual heatset web offset lithographic printing press or heatset web letterpress printing press with potential VOC emissions from the dryer, before consideration of add-on controls, of at least 25 tpy of VOC emissions from all heatset inks (including varnishes), coatings and adhesives, combined, must install add-on control devices.
    • The regulation requires add-on VOC emission control for affected sources, with a minimum level of VOC control efficiency of 90 percent to 95 percent for the heatset dryer, depending on the first installation date of the air pollution control device.
    • The dryer pressure of these presses must be maintained lower than the press room area pressure so that air flows into the dryer at all times when the press is operating.
  • The regulation also includes requirements for the control of the VOC content of cleaning solutions and work practice standards for cleaning activities.
  • The regulation requires control of the VOC content of the fountain solution for each offset lithographic printing press at a facility except:
    • A sheet-fed offset lithographic printing press with a maximum sheet size of 11 x 17 inches or smaller.
    • An offset lithographic printing press with a total fountain solution reservoir of less than one gallon.

Keep in mind, if your facility does not exceed the emission limits, it is still subject to the regulation because records must be kept at the facility demonstrating the exemption from control provisions.  The compliance date for the new regulations is January 1, 2015.  Any Reasonably Available Control Technology (RACT) requirements in existing Plan Approvals and Operating Permits will be superseded by the new regulations.

This entry was posted in Environmental Regulations and tagged , , , , , , , , . Bookmark the permalink.

Comments are closed.