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Texas SIP: 30 TAC 115.432-115.439: Graphic Arts (printing) by Rotogravure and Flexographic Processes; SIP effective 2001.09.14 TXd21 to 2006.03.19

Regulatory Text: 
Chapter 115.  Control of Air Pollution from Volatile Organic Compounds.

SUBCHAPTER E : SOLVENT-USING PROCESSES

[E:3]  GRAPHIC ARTS (PRINTING) BY ROTOGRAVURE AND FLEXOGRAPHIC PROCESSES 
As approved by EPA July 16, 2001 (66 FR 36917) effective September 14, 2001 (TXd21).
Some sections superceded by revisions approved by EPA January 19, 2006 (71 FR 03009) effective March 20, 2006 (TXd73).

Outline:
§115.430.  Flexographic and Rotogravure Printing Definitions.
§115.432.  Control Requirements.
§115.433.  Alternate Control Requirements.
§115.435.  Testing Requirements.
§115.436.  Monitoring and Recordkeeping Requirements.
§115.437.  Exemptions.
§115.439.  Counties and Compliance Schedules.


§115.430.  Flexographic and Rotogravure Printing Definitions.
As adopted by TNRCC December 6, 2000, effective January 18, 2001 (5-69).
Approved by EPA July 16, 2001 (66 FR 36917) effective September 14, 2001 (TXd21).

      The following words and terms, when used in this division, shall have the following meanings, unless the context clearly indicates otherwise.  Additional definitions for terms used in this division are found in §115.10 of this title (relating to Definitions), §101.1 of this title (relating to Definitions), and §3.2 of this title (relating to Definitions).

            (1)  Flexographic printing process - A method of printing in which the image areas are raised above the non-image areas, and the image carrier is made of an elastomeric material.

            (2)  Packaging rotogravure printing - Any rotogravure printing upon paper, paper board, metal foil, plastic film, or any other substrate which is, in subsequent operations, formed into packaging products or labels.

            (3)  Publication rotogravure printing - Any rotogravure printing upon paper which is subsequently formed into books, magazines, catalogues, brochures, directories, newspaper supplements, or other types of printed materials.

            (4)  Rotogravure printing - The application of words, designs, and/or pictures to any substrate by means of a roll printing technique which involves a recessed image area.  The recessed area is loaded with ink and pressed directly to the substrate for image transfer.

Adopted December 6, 2000, Effective January 18, 2001
**** end tx 115.430 adopted by TNRCC 12/06/2000 (5-69)**d21*eb9e***c1i**

§115.432.  Control Requirements.

104E  (a)  For the Beaumont/Port Arthur, Dallas/Fort Worth, El Paso, and Houston/Galveston Areas as defined in §115.10 of this title (relating to Definitions), the following control requirements shall apply.

77C        (1)  No person shall operate or allow the operation of a packaging rotogravure, publication rotogravure, or flexographic printing line that uses solvent-containing ink unless volatile organic compound (VOC) emissions are limited by one of the following:

77C             (A)  application to the substrate of low solvent ink with a volatile fraction containing 25% by volume or less of VOC solvent and 75% by volume or more of water and exempt solvent;

77C             (B)  application to the substrate of high solids solvent-borne ink containing 60% by volume or more of nonvolatile material (minus water and exempt solvent); or

77C             (C)  operation of a carbon adsorption or incineration system to reduce the VOC emissions from an effective capture system by at least 90% by weight.  The design and operation of the capture system for each printing line must be consistent with good engineering practice and shall be required to provide for an overall reduction in VOC emissions, as demonstrated to the satisfaction of the Executive Director, upon request, of at least the following weight percentages:

77C                  (i)  75% for a publication rotogravure process,

77C                  (ii)  65% for a packaging rotogravure process, or

77C                  (iii)  60% for a flexographic printing process.

104E       (2)  Any graphic arts facility that becomes subject to the provisions of paragraph (1)(A), (B), or (C) of this subsection by exceeding provisions of §115.437(a) of this title (relating to Exemptions) will remain subject to the provisions of this subsection, even if throughput or emissions later fall below exemption limits unless and until emissions are reduced to at or below the controlled emissions level existing prior to implementation of the project by which throughput or emission rate was reduced and less than the applicable exemption limits in §115.437(a) of this title and:

104E            (A)  the project by which throughput or emission rate was reduced is authorized by any permit or permit amendment or standard permit or standard exemption required by Chapter 116 of this title (relating to Control of Air Pollution by Permit for New Construction or Modification.)  If a standard exemption is available for the project, compliance with this subsection must be maintained for 30 days after the filing of documentation of compliance with that standard exemption; or

104E            (B)  if authorization by permit or standard exemption is not required for the project, the owner/operator has given the Texas Natural Resource Conservation Commission 30 days' notice of the project in writing.

88C        (3)  Any capture efficiency testing of the capture system must be conducted in accordance with §115.435(a) of this title (relating to Testing Requirements).


88C   (b)  For Gregg, Nueces, and Victoria Counties, no person shall operate or allow the operation of a packaging rotogravure, publication rotogravure, or flexographic printing line that uses solvent-containing ink unless volatile organic compound (VOC) emissions are limited by one of the following:

88C        (1)  application to the substrate of low solvent ink with a volatile fraction containing 25% by volume or less of VOC solvent and 75% by volume or more of water and exempt solvent;

88C        (2)  application to the substrate of  high solids solvent-borne ink containing 60% by volume or more of nonvolatile material (minus water and exempt solvent); or

88C        (3)  operation of a carbon adsorption or incineration system to reduce the VOC emissions from an effective capture system by at least 90% by weight.  The design and operation of the capture system for each printing line must be consistent with good engineering practice and shall be required to provide for an overall reduction in VOC emissions, as demonstrated to the satisfaction of the Executive Director, upon request, of at least the following weight percentages:

88C             (A)  75% for a publication rotogravure process,

88C             (B)  65% for a packaging rotogravure process, or

88C             (C)  60% for a flexographic printing process.

********************* end 115.432 ***********************

§115.433.  Alternate Control Requirements.

105K  (a)  For all affected persons in the Beaumont/Port Arthur, Dallas/Fort Worth, El Paso, and Houston/Galveston Areas, alternate methods of demonstrating and documenting continuous compliance with the applicable control requirements or exemption criteria in this section may be approved by the Executive Director in accordance with §115.910 of this title (relating to Availability of Alternate Means of Control) if emission reductions are demonstrated to be substantially equivalent.

105K  (b)  For all affected persons in the Gregg, Nueces, and Victoria Counties, alternate methods of demonstrating and documenting continuous compliance with the applicable control requirements or exemption criteria in this section may be approved by the Executive Director in accordance with §115.910 of this title if emission reductions are demonstrated to be substantially equivalent.

********************* end 115.433 *************************
§115.435.  Testing Requirements.

88C   (a)  For the Beaumont/Port Arthur, Dallas/Fort Worth, El Paso, and Houston/Galveston Areas, compliance shall be determined by applying the following test methods, as appropriate:

77A        (1)  Test Methods 1-4 (40 Code of Federal Regulations 60, Appendix A) for determining flow rates, as necessary;

77A        (2)  Test Method 24 (40 Code of Federal Regulations 60, Appendix A) for determining the volatile organic compound content and density of printing inks and related coatings;

77A        (3)  Test Method 25 (40 Code of Federal Regulations 60, Appendix A) for determining total gaseous nonmethane organic emissions as carbon;

77A        (4)  Test Methods 25A or 25B (40 Code of Federal Regulations 60, Appendix A) for determining total gaseous organic concentrations using flame ionization or nondispersive infrared analysis;

105K       (5)  United States Environmental Protection Agency (EPA) guidelines series document "Procedures for Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink, and Other Coatings," EPA-450/3-84-019, as in effect December, 1984;

88C        (6)  additional performance test procedures described in 40 Code of Federal Regulations (CFR) 60.444;

88C        (7)  the capture efficiency shall be measured using applicable procedures outlined in 40 CFR, Part 52.741, Subpart O, Appendix B.  These procedures are:

77D              Procedure T   - Criteria for and Verification of a Permanent or Temporary Total Enclosure

77D              Procedure L   - Volatile Organic Compounds (VOC) Input

77D              Procedure G.2 - Captured VOC Emissions (Dilution Technique)

77D              Procedure F.1 - Fugitive VOC Emissions from Temporary Enclosures

77D              Procedure F.2 - Fugitive VOC Emissions from Building Enclosures


77D             (A)  Exemptions to capture efficiency testing requirements:

77D                  (i)  if a source installs a permanent total enclosure (PTE) which meets the specifications of Procedure T and which directs all VOC to a control device, then the capture efficiency is assumed to be 100%, and the source is exempted from capture efficiency testing requirements. This does not exempt the source from performance of any control device efficiency testing that may be required.  In addition, a source must demonstrate all criteria for a PTE are met during testing for control efficiency.

77D                  (ii)  if a source uses a control device designed to collect and recover VOC (e.g., carbon adsorber), an explicit measurement of capture efficiency is not necessary if the following conditions are met.  The overall control of the system can be determined by directly comparing the input liquid VOC to the recovered liquid VOC.  The general procedure for use in this situation is given in 40 Code of Federal Regulations (CFR) 60.433 with the following additional restrictions:

77D                       (I)  the source must be able to equate solvent usage with solvent recovery on a 24-hour (daily) basis, rather than a 30-day weighted average.  This must be done within 72 hours following each 24-hour period.

77D                       (II)  the solvent recovery system (i.e., capture and control system) must be dedicated to a single process line (e.g., one process line venting to a carbon absorber system); or if the solvent recovery system controls multiple process lines, the source must be able to demonstrate that the overall control (i.e., the total recovered solvent VOC divided by the sum of liquid VOC input to all process lines venting to the control system) meets or exceeds the most stringent standard applicable for any process line venting to the control system.

77D             (B)  The capture efficiency shall be calculated using one of the following four protocols referenced. Any affected source must use one of these protocols, unless a suitable alternative protocol is approved by the Executive Director and EPA.

77D                  (i)  Gas/gas method using Temporary Total Enclosure (TTE).  EPA specifications to determine whether a temporary enclosure is considered a TTE are given in Procedure T.  The capture efficiency equation to be used for this protocol is:

CE  =  Gw / (Gw + Fw)

Where:  
     CE  =  capture efficiency, decimal fraction
     Gw  =  mass of VOC captured and delivered to control device  using a TTE (use Procedure G.2)
     Fw  =  mass of fugitive VOC that escapes from a TTE (use  Procedure F.1)


77D                  (ii)  Liquid/gas method using TTE.  EPA specifications to determine whether a temporary enclosure is considered a TTE are given in Procedure T.  The capture efficiency equation to be used for this protocol is:

CE  =  (L - F) / L

Where:  
     CE  =  capture efficiency, decimal fraction

     L  =  mass of liquid VOC input to process (use Procedure L)

     F  =  mass of fugitive VOC that escapes from a TTE (use  Procedure F.1)


77D                  (iii)  Gas/gas method using the building or room in which the affected source is located as the enclosure (BE) and in which G and F are measured while operating only the affected facility.  All fans and blowers in the BE must be operating as they would under normal production.  The capture efficiency equation to be used for this protocol is:

CE  =  G / (G + Fb)

Where:
     CE  =  capture efficiency, decimal fraction
     G  =  mass of VOC captured and delivered to a control device (use Procedure G.2)
     Fb  =  mass of fugitive VOC that escapes from building enclosure  (use Procedure F.2)

77D                  (iv)  Liquid/gas method using a BE in which L and F are measured while operating only the affected facility.  All fans and blowers in the building or room must be operated as they would under normal production.  The capture efficiency equation to be used for this protocol is: 

CE  = (L - Fb) / L

Where:
     CE  =  capture efficiency, decimal fraction
     L  =  mass of liquid VOC input to process (use Procedure L)
     Fb  =  mass of fugitive VOC that escapes from BE (use Procedure F.2)

77D             (C)  The following conditions must be met in measuring capture efficiency:

77D                  (i)  Any error margin associated with a test protocol may not be incorporated into the results of a capture efficiency test.

88C                  (ii)  All affected facilities shall accomplish the initial capture efficiency testing July 31, 1992 in Brazoria, Dallas, El Paso, Galveston, Harris, Jefferson, Orange, and Tarrant Counties, and by July 31, 1993 in Chambers, Collin, Denton, Fort Bend, Hardin, Liberty, Montgomery, and Waller Counties.

77D                  (iii)  During an initial pretest meeting, the Texas Natural Resource Conservation Commission (TNRCC), and the source owner or operator shall identify those operating parameters which shall be monitored to ensure that capture efficiency does not change significantly over time.  These parameters shall be monitored and recorded initially during the capture efficiency testing and thereafter during facility operation.  The TNRCC may require a new capture efficiency test if the operating parameter values change significantly from those recorded during the initial capture efficiency test.

88C        (8)  minor modifications to these test methods and procedures approved by the Executive Director.


88C   (b)  For Gregg, Nueces, and Victoria Counties, compliance shall be determined by applying the following test methods, as appropriate:

88C        (1)  Test Methods 1-4 (40 CFR 60, Appendix A) for determining flow rates, as necessary;

88C        (2)  Test Method 24 (40 CFR 60, Appendix A) for determining the volatile organic compound content and density of printing inks and related coatings;

88C        (3)  Test Method 25 (40 CFR 60, Appendix A) for determining total gaseous nonmethane organic emissions as carbon;

88C        (4)  Test Methods 25A or 25B (40 CFR 60, Appendix A) for determining total gaseous organic concentrations using flame ionization or nondispersive infrared analysis;

105K       (5)  EPA guidelines series document "Procedures for Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink, and Other Coatings," EPA-450/3-84-019, as in effect December, 1984;
88C        (6)  additional performance test procedures described in 40 CFR 60.444; or

88C        (7)  minor modifications to these test methods and procedures approved by the Executive Director.

*********************** end 115.435 *************************

§115.436.  Monitoring and Recordkeeping Requirements.

105K  (a)  For the Beaumont/Port Arthur, Dallas/Fort Worth, El Paso, and Houston/Galveston Areas, the owner or operator of any rotogravure or flexographic printing facility shall:

88C        (1)  maintain records of the volatile organic compound (VOC) content of all inks as applied to the substrate. Additionally, records of the quantity of each ink and solvent used shall be maintained.  The composition of inks may be determined by the methods referenced in §115.435(a) of this title (relating to Testing Requirements) or by examining the manufacturer's formulation data and the amount of dilution solvent added to adjust the viscosity of inks prior to application to the substrate;

88C        (2)  maintain daily records of the quantity of each ink and solvent used at a facility subject to the requirements of an alternate means of control approved by the Executive Director in accordance with §115.433(a) of this title (relating to Alternate Control Requirements) which allows the application of inks exceeding the applicable control limits.  Such records must be sufficient to demonstrate compliance with the applicable emission limitation on a daily weighted average;

88F        (3)  install and maintain monitors to continuously measure and record operational parameters of any emission control device installed to meet applicable control requirements.  Such records must be sufficient to demonstrate proper functioning of those devices to design specifications, including:

77A             (A)  the exhaust gas temperature of direct-flame incinerators and/or the gas temperature immediately upstream and downstream of any catalyst bed,

77C             (B)  the total amount of VOC recovered by a carbon adsorption or other solvent recovery system during a calendar month,

88F             (C)  the VOC concentration of any carbon adsorption system exhaust to determine if breakthrough has occurred, and

77C             (D)  the dates and reasons for any maintenance and repair of the required control devices and the estimated quantity and duration of VOC emissions during such activities;

88C        (4)  maintain the results of any testing conducted at an affected facility in accordance with the provisions specified in §115.435(a) of this title (relating to Testing Requirements);

88C        (5)  maintain all records at the affected facility for at least two years and make such records available upon request to representatives of the Texas Natural Resource Conservation Commission (TNRCC), United States Environmental Protection Agency (EPA), or the local air pollution agency having jurisdiction in the area; and

88C        (6)  maintain on file the capture efficiency protocol submitted under §115.435(a)(7) of this title (relating to Testing Requirements).  The owner or operator shall submit all results of the test methods and capture efficiency protocols to  the TNRCC within 60 days of the actual test date.  The source owner or operator shall maintain records of the capture efficiency operating parameter values on-site for a minimum of one year.  If any changes are made to capture or control equipment, the owner or operator is required to notify the Executive Director in writing within thirty (30) days of these changes and a new capture efficiency and/or control device destruction or removal efficiency test may be required.

105K  (b)  For Gregg, Nueces, and Victoria Counties, the owner or operator of any rotogravure or flexographic printing facility shall:

88C        (1)  maintain records of the VOC content of all inks as applied to the substrate.  Additionally, records of the quantity of each ink and solvent used shall be maintained.  The composition of inks may be determined by the methods referenced in §115.435(b) of this title (relating to Testing Requirements) or by examining the manufacturer's formulation data and the amount of dilution solvent added to adjust the viscosity of inks prior to application to the substrate;

88C        (2)  maintain daily records of the quantity of each ink and solvent used at a facility subject to the requirements of an alternate means of control approved by the Executive Director in accordance with §115.433(b) of this title (relating to Alternate Control Requirements) which allows the application of inks exceeding the applicable control limits.  Such records must be sufficient to demonstrate compliance with the applicable emission limitation on a daily weighted average;

88F        (3)  install and maintain monitors to continuously measure and record operational parameters of any emission control device installed to meet applicable control requirements.  Such records must be sufficient to demonstrate proper functioning of those devices to design specifications, including:

88C             (A)  the exhaust gas temperature of direct-flame incinerators and/or the gas temperature immediately upstream and downstream of any catalyst bed,

88F             (B)  the total amount of VOC recovered by a carbon adsorption or other solvent recovery system during a calendar month,

88F             (C)  in Victoria County, the VOC concentration of any carbon adsorption system exhaust to determine if breakthrough has occurred, and

88F             (D)  the dates and reasons for any maintenance and repair of the required control devices and the estimated quantity and duration of VOC emissions during such activities;

88C        (4)  maintain the results of any testing conducted at an affected facility in accordance with the provisions specified in §115.435(b) of this title (relating to Testing Requirements);

88C        (5)  maintain all records at the affected facility for at least two years and make such records available upon request to representatives of the Texas Natural Resource Conservation Commission (TNRCC), United States Environmental Protection Agency (EPA), or the local air pollution agency having jurisdiction in the area; and

*********************** end 115.436 **********************

§115.437.  Exemptions.

88C   (a) For the Beaumont/Port Arthur, Dallas/Fort Worth, El Paso, and Houston/Galveston Areas, the following exemptions shall apply.

105K       (1) In the Beaumont/Port Arthur, Dallas/Fort Worth, and El Paso areas, all rotogravure and flexographic facilities on a property which, when uncontrolled, have a maximum potential to emit a combined weight of volatile organic compounds (VOC) less than 50 tons in one year (based on historical ink and VOC solvent usage, and at maximum production capacity) are exempt from the requirements of §115.432(a) of this title (relating to Control Requirements).

105K       (2) In the Houston/Galveston Areas, all rotogravure and flexographic facilities on a property which, when uncontrolled, have a maximum potential to emit a combined weight of VOC less than 25 tons in one year (based on historical ink and VOC solvent usage, and at maximum production capacity) are exempt from the requirements of §115.432(a) of this title.


88C   (b)  For Gregg, Nueces, and Victoria Counties, all rotogravure and flexographic facilities on a property which, when uncontrolled, emit a combined weight of VOC less than 100 tons (91 metric tons) in one year (based on historical ink and VOC solvent usage) are exempt from the requirements of §115.432(a) of this title (relating to Control Requirements).

******************** end 115.437 ***********************

§115.439.  Counties and Compliance Schedules.

88C   (a)  All affected persons in Chambers, Collin, Denton, Fort Bend, Hardin, Liberty, Montgomery, and Wallar Counties shall be in compliance with
§115.432(a) of this title (relating to Control Requirements),
§115.433(a) of this title (relating to Alternate Control Requirements),
§115.435(a) of this title (relating to Testing Requirements),
§115.436(a) of this title (relating to Recordkeeping Requirements), and
§115.437(a) of this title (relating to Exemptions)
as soon as practicable, but no later than July 31, 1993.

105K  (b)  All affected persons in Dallas, El Paso, Jefferson, Orange, and Tarrant Counties shall be in compliance with §115.437(a)(1) of this title as soon as practicable, but no later than July 31, 1993.

105K  (c)  All affected persons in Brazoria, Galveston, and Harris Counties shall be in compliance with §115.437(a)(2) of this title as soon as practicable, but no later than July 31, 1993.

88F   (d)  All affected persons in Victoria County shall be in compliance with §115.436(b)(3)(C) of this title (relating to Recordkeeping Requirements) as soon as practicable, but no later than July 31, 1993.

****************** end 115.439 ************************
*********** end tx §§115.432 - 115.439 *******e93v**95m**