The Department of Environmental Affairs (DEA) proposed new regulations in respect of air emissions for the printing sector in January 2012, in terms of an amendment to the Section 21 Notice of the National Environmental Management: Air Quality Act, 2004 (AQA). The printing works draft regulations (draft regulation) are provided under ‘Category 11’ of the draft amendment to the Section 21 Notice.

1: What Does the Draft Section 21 Listing Require?

The draft regulation dated 27th February provides that all printing processes exceeding 15 tonnes of organic solvent consumption per annum are required to apply and pay for an Atmospheric Emissions License (AEL) in terms of the AQA. Facilities that use less than 15 tonnes per annum will be exempt. Earlier drafts of the printing sector regulation in the Section 21 amendment regulated facilities on the basis of 25 tonnes of solvent consumption per annum.

If your facility, based on the annual organic solvent consumption, falls within the S21 regulation, you will be required to meet emission limits of Volatile Organic Compounds (VOCs) at all vents associated with printing processes. Organic solvent consumption refers to:

• Any form / type of solvents purchased to be used in the printing process (including that purchased for cleaning purposes)
• Organic solvents present in ‘solvent based’ inks (as sold by the various ink suppliers)

The emission limits are as follows:

Category 11: Printing Works

Requirements relating to ‘Particulates’ and ‘Oxides of Nitrogen’ refer to limits for a particular type of VOC emission control equipment, thermal oxidation.

The draft regulation currently indicates that facilities operating any printing methods must meet ‘existing’ emission limits within five years from the date of promulgation (likely to be in 2013), and facilities must meet ‘new facility’ emission limits in 10 years. Given the significant cost of VOC emission controls, operators will have to install VOC controls that achieve both existing and new emission limits in a single step within a five year period, rather than implement two separate systems capable of achieving ‘existing’ and ‘new’ in order to comply with the five and 10 year compliance periods.

2: What is PRINTING SA doing about this?

Following the publication of the draft regulation in January 2012, PIFSA initiated an investigation with the overall objectives of determining the impact of this regulation on the printing sector and to propose amendments to the regulation where technically and economically justified.

The six month study was initiated in March 2012 and has been led by PRINTING SA and representatives of the printing sector elected to a working group (Environmental Interest Group). The study has been supported legally by Norton Rose and technically by WardKarlson Consulting Group.

3: What are the Outcomes of the Working Group’s Assessment of the Draft Regulations?

The working group has determined that a number of changes to the draft regulation could be beneficial to the printing sector. These include:

• Category 11 Description Changed to: “Printing, coating and lamination processes using rotogravure, flexography, rotary screen printing, heat set lithography, varnishing and printing systems that incorporate elements of these technologies”
• This means coldset and sheet-fed lithography, and digital printing would not be regulated
• Emission Limit for New Facilities: The Working Group Committee accepts the proposed emission limit of 75mgC/m3 for new facilities which reflects international best practice. However the following amendments are proposed:
  1. 75mgC/Nm3 VOC or 95% control efficiency of VOC in vents or a VOC containing Solvent Reduction Mechanism
  2. Solvent reduction mechanism may be permitted, whereby emission limits or control efficiency can be met through the use of non-VOC containing printing materials
  3. A single emission limit (reflecting the ‘new facility’ standard) would be adopted with a ten year compliance timeframe from the date of promulgation. This avoids the need to implement VOC controls within the initial five year period

The working group has considered the impact of alternative solvent consumption thresholds. Whilst a low solvent threshold may regulate a large part of the printing sector, adopting VOC controls for small operators may be more economically challenging when compared to larger facilities. Conversely, a higher solvent consumption threshold may infer a competitive advantage in the market place for small operators when compared to those operators forced to implement costly VOC emission controls.

The use of solvent consumption as a basis for regulating a facility is an approach adopted in the European Union.

4: What Happens When These Regulations are Promulgated and if my Facility Exceeds the Organic Solvent Consumption Threshold?

Each facility regulated by S21 will need to prepare an ‘organic solvent consumption plan’, detailing the total weight in tonnes of organic solvent consumed each year. If the facility exceeds the threshold defined in the final regualtion, an application for an Air Emissions License (AEL) will need to be made.

Part of the AEL application process will include the monitoring of exhausts to either a) demonstrate compliance with the S21 emission limits or b) if non-compliant, propose approaches to meet the emission limit within the prescribed period. Monitoring of vents will cost between R40,000 and R70,000 per annum depending upon the size of facility.

The Working Group will request to the DEA a 12 month period for each regulated facility to apply for an AEL from date of promulgation of the final regulation.

5: What are my Options to Reduce VOC Emissions to Allow My Facility to Meet S21 Limits ?

There are a number of options:

• Replace printing materials with those that have a low VOC content
• Purchase pollution control equipment (thermal oxidizers, biological treatment, carbon adsorption)

For most facilities included in the regulation, thermal oxidation will be the most reliable and effective methodology. Costs for thermal oxidation range significantly from scale of application, however for a small printing facility the capital costs may exceed R2M, and annual operating costs may exceed R1M. For large facilities the capital may exceed R10M and operational costs exceed R2M.

6: What if I Increase Printing Capacity or Replace Listed Printing Processes soon after Promulgation of the final regulation ?

Section 21 States:

“New Plant” shall mean any plant or process where the application for authorisation in terms of the National Environmental Management Act 1998 (Act No.107 of 1998), as amended, was made on or after the date on which this Notice takes effect.

The amendments to the S21 Notice incorporating the printing sector is likely to be promulgated in 2013, after which it is understood that installing printing processes that are listed under Category 11 will require that these new printing processes achieve ‘new facility’ emission limits for VOCs immediately.

This presents a complicated situation for operators planning to expand their existing operations or replace old equipment soon, as the capital cost of installing VOC controls for existing printing processes infers that many operators would prefer to install one control system for all regulated printing processes within a five or ten year period (rather than a single VOC control system for the newly installed printing process in the next few years).

PRINTING SA is considering further discussions with the DEA regarding this topic.

6: What if I Increase Printing Capacity or Replace Listed Printing Processes soon after Promulgation of the final regulation ?

Section 21 States:

“New Plant” shall mean any plant or process where the application for authorisation in terms of the National Environmental Management Act 1998 (Act No.107 of 1998), as amended, was made on or after the date on which this Notice takes effect.

The amendments to the S21 Notice incorporating the printing sector is likely to be promulgated in 2013, after which it is understood that installing printing processes that are listed under Category 11 will require that these new printing processes achieve ‘new facility’ emission limits for VOCs immediately.

This presents a complicated situation for operators planning to expand their existing operations or replace old equipment soon, as the capital cost of installing VOC controls for existing printing processes infers that many operators would prefer to install one control system for all regulated printing processes within a five or ten year period (rather than a single VOC control system for the newly installed printing process in the next few years).

PRINTING SA is considering further discussions with the DEA regarding this topic.

7: Do You Have Comments On the Proposal Organic Solvent Consumption Threshold Limit?

PRINTING SA has agreed a two week consultation period with effect from 7th September 2012 on the topic of the solvent consumption threshold. Should you have comments or suggestions in this regard, you are requested to submit these urgently to lmoralee@pifsa.org or wogle@pifsa.org. Should you require any additional information, please contact Louise Moralee or Warren Ogle at 011 287 1160.

Please consider the following:

• Do you support a stringent solvent consumption threshold of 15 tonnes per annum, whereby the majority of printing facilities, including small businesses would be regulated?
•  Do you support a higher (less stringent) solvent consumption threshold, whereby fewer facilities (larger facilities) would be regulated?
•  Any other Comments?