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Printing and Publishing Monitoring Information

​Monitoring Information Specific to Printing and Publishing

A variety of monitoring approaches are used in the printing industry. The applicable monitoring approach(es) will be dependent on the type of control technique employed by the facility, as well as other factors. General monitoring approaches used in this industry include:

  • Documentation of Compliant Inks and Coatings
  • Liquid-Liquid Mass Balance (solvent recovery systems)
  • Parametric Monitoring (add-on controls)
  • Continuous Emission Monitoring Systems (add-on controls)

The EPA has published a document entitled "Technical Support Document (TSD) for Title V Permitting of Printing Facilities." Chapter 3 of this document addresses "Monitoring and Practicable Enforceability;" Appendix C of the TSD provides monitoring protocols for capture and control systems for this industry; and, Appendix D discusses monitoring material usage.

Documentation of Compliant Inks and Coatings
The VOC or HAP content of inks and coatings used in the operation is determined and documented to monitor compliance with regulations that limit the VOC or HAP content of each coating used. In other cases, compliance with regulations that limit the average VOC or HAP content of the coatings used . In this case, documenting the amount of each coating used, as well as the VOC and HAP content of each coating is required. The monitoring related to this compliance approach typically is recordkeeping; that is, maintaining proper records of material content and usage (if applicable) to assure compliance can be determined. In some cases this may include records of material usage determined using measurement instrumentation such as flow meters or weigh scales.

Two brief illustrations of these monitoring approaches are included in "Technical Examples for Title V Monitoring" prepared by EPA. The examples are identified as C-1 and C-2 in the following document:
Technical Examples for Title V Monitoring(54 pp, 97 K, About PDF)
 
Liquid-Liquid Mass Balance (solvent recovery systems)
If the printing operations use a control system based on capture and solvent recovery, a mass balance can be performed to determine the combined capture and control efficiency (overall efficiency). The overall efficiency is determined by comparing the mass of the recovered solvent to the mass of the solvent input to the system (100 percent evaporation assumed) which is determined by the quantity of inks and coatings used and the solvent content of each ink and coating. The monitoring approach for this compliance technique relies on recordkeeping; that is, maintaining proper records of material content and usage. The amount of material recovered from the solvent recovery unit also must be quantitated; this involves the use measurement instrumentation such as volume meters, or weigh scales. A monitoring protocol (Protocol No. 4) for solvent recovery systems is included in Appendix C of the Technical Support Document for Title V Permitting and Printing Facilities.
 
Parametric Monitoring for Capture and Control Systems

Parametric monitoring involves monitoring key operating parameters of the capture system, add-on control system, or process to ensure proper performance of the capture system and add-on control device on an on-going basis. Parametric monitoring for capture and control systems for the printing industry is addressed in the TSD, Appendix C of the Technical Support Document for Title V Permitting and Printing Facilities.

For general information on parametric monitoring or for additional information on parametric monitoring for specific types of control devices see the Sources of General Monitoring Information and Monitoring Information Specific to Control Technologies sections below for links to additional information.

Continuous Emission Monitoring Systems (CEMS)

CEMS directly monitor the VOC or HAP content (as concentration) of an emissions stream; e.g., the stack gas from the outlet of an add-on control device. The VOC or HAP mass emission rate can be determined if the exhaust gas flow rate also is monitored. CEMS that might be applied in this industry include "Total Hydrocarbon Analyzers" (THC Analyzers), or analyzers that measure specific organic compounds. For General Information on CEMS see the Sources of General Monitoring Information section below.

Monitoring Requirements of Selected Regulations

This table summarizes the key monitoring requirements of the NSPS and NESHAP for the printing and publishing industry.
 

Monitoring Information Specific to Control Technologies

For more information on monitoring the performance of the control technologies typically used in the printing and publishing industry go to the following control technology links:

Catalytic Oxidizers

Sources of General Monitoring Information

Available sources of general monitoring information which may be of interest include:

Chapter 4 of the Compliance Assurance Monitoring Technical Guidance Document (CAM TGD).(135 pp, 952 K, About PDF)  This chapter identifies sensors, their measurement principles, and basic calibration techniques for common measurement systems. 

The Title V Operating Permits rule requires periodic monitoring and sufficiency monitoring for all applicable requirements. Some examples of monitoring for Title V (primarily for sources without add-on control) are included in the Technical Examples for Title V Monitoring(54 pp, 97 K, About PDF)

The Emission Measurement Center provides a website for Continuous Emission Monitoring Systems. This site provides guidance documents, as well as proposed and promulgated performance specifications for different types of CEMS.
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Last updated on December 16, 2021