New Flexible Packaging Regulations: Compliance Date January 1, 2015

New Flexible Packaging Regulations: Compliance Date January 1, 2015

Jul 25, 2014

From DEP's Fact Sheet:

Owners and operators of affected printing presses will be subject to newly adopted requirements in 25 Pa. Code §§ 129.67a and 129.67b, which limits volatile organic compound (VOC) emissions from inks, coatings, fountain solutions, adhesives and cleaning solutions used or applied on or with flexible packaging printing presses, offset lithographic printing presses and letterpress printing presses.

The Chapter 129 amendments will become effective upon publication as a final-form regulation in the Pennsylvania Bulletin. The compliance date is Jan. 1, 2015.

The final-form provisions codified in §§ 129.67a and 129.67b include the following:

  •  VOC content limits
  •  requirements for add-on controls
  •  compliance monitoring
  •  recordkeeping
  •  reporting
  •  sampling and testing
  •  work practices for cleaning activities

Compliance methods include the following:

  •  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.

The provisions in 25 Pa. Code §§ 129.67a and 129.67b supersede the requirements of Reasonably Available Control Technology (RACT) requirements included in Plan Approvals and Operating Permits issued by the Department of Environmental Protection (DEP) prior to Jan. 1, 2015, to the extent the provisions are more stringent than existing RACT requirements.

Records must be maintained onsite for at least two years unless a longer period is required under Plan Approvals or Operating Permits including Title V Operating Permits.

Section 129.67a -- Affected flexible packaging printing press facilities:

  • Section 129.67a applies to the owner and operator of a flexible packaging printing press if the 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, are equal to or exceed 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.
  • o 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 -- Affected heatset web offset lithographic printing presses or heatset web letterpress printing presses:

  • 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: o A sheet-fed offset lithographic printing press with a maximum sheet size of 11 x 17 inches or smaller. o An offset lithographic printing press with a total fountain solution reservoir of less than one gallon.

 NOTE: Sections 129.67a and 129.67b also affect the owner and operator of a heatset web offset lithographic printing press or a heatset web letterpress printing press and the owner and operator of a flexible packaging printing press whose emissions fall below the listed applicability thresholds. Records must be kept to demonstrate to DEP that the press or facility is exempt from the control provisions of the regulations.

Contact: For more information on the regulation or compliance requirements, contact DEP, Bureau of Air Quality, Compliance and Enforcement Division at 717-787-9257.

Frequently Asked Questions.

Small businesses qualify for free, confidential environmental management assistance through the Environmental Management Assistance Program (EMAP). EMAP is a specialized consulting service of the Pennsylvania Small Business Development Centers that provides free and confidential environmental compliance assistance to small businesses in Pennsylvania at www.askemap.org