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2006 and 2008 Graphic Arts Emissions Inventory for the Austin-Round Rock

Metropolitan Statistical Area

FINAL REPORT, Task 3.4d, Rider 8 Phase II Work Plan

Prepared by the Capital Area Council of Governments

July 2013

Prepared in Cooperation with the Texas Commission on Environmental Quality

The preparation of this report was financed through grants from the State of Texas

through the Texas Commission on Environmental Quality

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Executive Summary The Capital Area Council of Governments (CAPCOG) has updated the graphic arts area source emissions

inventory for the Austin-Round Rock Metropolitan Statistical Area (Austin MSA) for 2006 and 2008 using a

statewide survey conducted by Eastern Research Group, Inc. in 2001, data on ink consumption in the

manufacturing sector from the U.S. Census Bureau, and employment data from 2006 and 2008. Based on the

Texas Commission on Environmental Quality’s (TCEQ’s) 2008 Area Source Emissions Inventory, graphic arts

facilities made up a significant portion of the anthropogenic emissions of volatile organic compounds (VOC) in

the Austin MSA. If the Austin MSA is ever designated nonattainment for ozone, graphic arts facilities may be

required to reduce their VOC emissions as part of a “reasonably available control technology” (or “RACT”)

rulemaking or as a measure to contribute to a required 15% reduction in local anthropogenic VOC emissions.

Improving the estimates of emissions from this category can help establish the extent to which graphic arts

emissions reductions would be able to contribute to a 15% RFP requirement if the area was designated

nonattainment – moderate for ozone. CAPCOG’s research indicated that TCEQ’s 2008 inventory for the Austin

MSA, which is based on national default data produced by Pechan, is much higher than estimated by CAPCOG.

The table below shows CAPCOG’s updated estimates for each county in the Austin MSA.

Table 1: Graphic Arts VOC Emissions, 2006 and 2008 (tons per day)

County 2006 2008 2008-Default

Bastrop 0.0137 0.0022 0.0434

Caldwell 0.0014 0.0014 0.0174

Hays 0.0257 0.0121 0.3328

Travis 0.3690 0.3873 4.7990

Williamson 0.0265 0.0249 0.4331

TOTAL 0.4363 0.4279 5.6257

This report details CAPCOG’s research into this source category and the basis for CAPCOG’s estimates. The first

section provides an overview of this emissions inventory category and some of the existing methodologies and

studies used for estimating emissions from this source. Next, CAPCOG provides the basis for the activity

estimates and emissions factors used for calculating this inventory. Next, CAPCOG compares these emissions

data to other emissions data and estimates available for this source category. The report concludes by

evaluating the strengths of this inventory relative to other estimates and offering recommendations for future

inventory work on this source category.

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Contents Executive Summary ................................................................................................................................................... 2 Introduction ............................................................................................................................................................... 5 Activity Estimates .................................................................................................................................................... 11

ERG Statewide Graphic Arts Inventory ................................................................................................................ 11 Graphic Arts Establishments and Employment in the Austin MSA ..................................................................... 12 Calculation of Activity Estimates for Manufacturing ........................................................................................... 13 CAPCOG Graphic Arts Survey and Estimation of Institutional Printing Activity .................................................. 13

Emissions Rates ....................................................................................................................................................... 16 Derivation of Gravure Printing Emissions Rate ................................................................................................... 16 Adjustments to Account for Ink Consumption Variation .................................................................................... 17

Emissions Estimates ................................................................................................................................................ 19 Comparison to Existing Estimates ........................................................................................................................... 20

Manufacturing Energy Consumption Survey ....................................................................................................... 22 Point Source Emissions Data ............................................................................................................................... 23 Control Technique Guidelines ............................................................................................................................. 24 Census Bureau Data and EIIP Emission Rates ...................................................................................................... 25

Conclusion and Recommendations ......................................................................................................................... 26 Appendix A: CAPCOG Graphic Arts Survey Form .................................................................................................... 28 Appendix B: PIAM Letter Accompanying Survey ..................................................................................................... 31 Table 1: Graphic Arts VOC Emissions, 2006 and 2008 (tons per day) ....................................................................... 2

Table 2: Source Classification Codes for Graphic Arts Area Source VOC Emissions .................................................. 5

Table 3: Printing Technologies and Associated Products .......................................................................................... 6

Table 4: Printing Ink Consumed in the U.S. by Manufacturing Industry, 2007 ......................................................... 8

Table 5: Estimated Ink Consumption in Undisclosed NAICS Codes, 2007 ................................................................. 9

Table 6: U.S. Printing Ink Shipments by Ink Type, 2007 ............................................................................................ 9

Table 7: CAPCOG assignment of NAICS codes to Printing Inks/Technologies ......................................................... 10

Table 8: Approximate Material Consumption Rates by Printing Technology, 1999 (gallons/employee) ............... 11

Table 9: Assignment of NAICS Codes to Printing Technology ................................................................................. 12

Table 10: Average Austin MSA Employment by Printing Technology Type ............................................................ 13

Table 11: Materials Consumed by Printing Technology in Manufacturing, 2006 (gallons/year) ............................ 13

Table 12: Materials Consumed by Printing Technology in Manufacturing, 2008 (gallons/year) ............................ 13

Table 13: Governmental Print Shops Responding to Survey ................................................................................... 14

Table 14: Responses from Private Firms (material in gallons/year) ........................................................................ 15

Table 15: Average Material Consumption Rates and Ranges by Technology Type (gallons/employee) ................ 15

Table 16: Controlled VOC Emission Rates by Process (lbs per employee per year) ................................................ 16

Table 17: VOC Emissions from Point Source Gravure Facilities 2008-2010 (tpy) .................................................... 16

Table 18: Calculation of Employee-Based Emissions Rates for Gravure Printing ................................................... 17

Table 19: Emission Rate Adjustments by NAICS Code ............................................................................................ 18

Table 20: Private Sector Graphic Arts VOC Emissions, 2006 and 2008 (tons per year) .......................................... 19

Table 21: VOC Emissions at Governmental and Institutional Print Shops (pounds/year) ...................................... 19

Table 22: Typical Ozone Season Day VOC Emissions, 2006 and 2008 ..................................................................... 19

Table 23: TCEQ Ozone Season Day VOC Emissions Estimates from Graphic Arts for 2005 and 2008 (tons per day)

................................................................................................................................................................................. 20

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Table 24: NAICS Codes and Employment Estimates used for 2008 NEI Employment-Based Graphic Arts Emissions

Factor ....................................................................................................................................................................... 21

Table 25: Component VOC Emission Factors for Graphic Arts Operations from Table 7.5-2 (lbs of VOC per lb of

ink used) .................................................................................................................................................................. 25

Table 26: Calculated Nationwide Emissions from Printing using Economic Census and EIIP Factors, 2007........... 26

Figure 1: Ink Expenses per Employee by NAICS Code, 2007 ..................................................................................... 7

Figure 2: VOC Emissions by Printing Type, 2006 ..................................................................................................... 20

Figure 3: Energy Consumption Per Employee by Establishment Size in the Printing Industry ............................... 22

Figure 4: Percent of Printing Establishments by Employment Size Category (2008) .............................................. 23

Figure 5: Approximate VOC Emissions/Employee for Point Sources (pounds) ....................................................... 24

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Introduction The graphic arts source category falls under the “solvent usage” class of area source VOC emissions. The U.S.

EPA source classification codes (SCCs) for this category include a number of printing processes and solvents used

in those processes, although the default emissions inventory uses a general source classification code grouping

all of these processes and solvents together. The table below lists the SCCs included in the “graphic arts”

category.

Table 2: Source Classification Codes for Graphic Arts Area Source VOC Emissions

SCC Description

2425000000 Graphic Arts: All Processes: All Solvent Types

2425000055 Graphic Arts: All Processes: Butyl Acetate

2425000370 Graphic Arts: All Processes: Special Napthas

2425000999 Graphic Arts: All Processes: Solvents – NEC

2425010000 Graphic Arts: Lithography: All Solvent Types

2425010055 Graphic Arts: Lithography: Butyl Acetate

2425010370 Graphic Arts: Lithography: Special Napthas

2425010999 Graphic Arts: Lithography: Solvents – NEC

2425020000 Graphic Arts: Letterpress: All Solvent Types

2425020055 Graphic Arts: Letterpress: Butyl Acetate

2425020370 Graphic Arts: Letterpress: Special Napthas

2425020999 Graphic Arts: Letterpress: Solvents – NEC

2425030000 Graphic Arts: Rotogravure: All Solvent Types

2425030055 Graphic Arts: Rotogravure: Butyl Acetate

2425030370 Graphic Arts: Rotogravure: Special Napthas

2425030999 Graphic Arts: Rotogravure: Solvents – NEC

2425040000 Graphic Arts: Flexography: All Solvent Types

242040055 Graphic Arts: Flexography: Butyl Acetate

2425040370 Graphic Arts: Flexography: Special Naptha

2425040999 Graphic Arts: Flexography: Solvents – NEC

The Emissions Inventory Improvement Program (EIIP), Volume III, Chapter 7, provides a detailed description of

the graphic arts as an emissions source category (Eastern Research Group, 1996). It identifies three different

ways to segment the industry: by printing technology, by substrate used, and by type of product or end use. The

EIIP identifies six different printing technology segments in the graphic arts source category:

1. Rotogravure,

2. Flexographic,

3. Offset Lithographic,

4. Letterpress,

5. Screen, and

6. Plateless.

The material that is printed upon can also be categorized, including flexible substrates like paper, foil, and film,

and rigid substrates like cardboard, vinyl, and metal cans. Textiles are specifically excluded from this source

category.

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Products or end uses also can be grouped into three broad categories: publications, packaging, or products.

Examples of publications include newspapers, magazines, books, and advertising; examples of packaging

includes paper, plastic, and foil bags, wrappers, and cardboard cartons, and metal cans; examples of products

include wall and floor covering, greeting cards, and paper towels.

The EIIP document provides a summary of the technologies used and types of products produced:

Table 3: Printing Technologies and Associated Products

Technology Products

Rotogravure Packaging, advertising, greeting cards, art books, catalogues, and directories

Flexography Packaging, advertising newspapers, books, magazines, financial and legal

document directories

Offset Lithography

Magazines, catalogues and directories, newspapers, books, stationery, financial and legal documents, advertising, journals, packaging, metal cans

Letterpress Magazines, catalogues and directories, newspapers, books, stationery, financial

and legal documents, advertising, journals, packaging, metal cans

Screen Signs, electronics, wallpaper, greeting cards, ceramics, decals, banners, plastic

bottles

Plateless Images printed on paper by laser printers, xerographic copiers, fax machines, and

ink jets

The EIIP document also points out that graphic arts operations may be present at establishments that may

conduct some printing but is not classified as primarily a print operation. The document identifies SIC Codes 27,

26 (Paper and Allied products), 30 (Rubber and Miscellaneous Plastic Products), 32 (Stone, Clay, and Glass

Products), 34 (Fabricated Metal Products), 39 (Miscellaneous Manufacturing Industries), and 86 (Membership

Organizations) as potentially including some graphic arts operations, however, some may be covered by other

area source solvent usage categories. For the purposes of this emissions inventory, any facility that consumes

printing ink that would contain some kind of solvent or that otherwise uses solvents in its printing process is

considered a graphic arts facility and is included in this inventory.

The Census Bureau collects detailed data on material consumption and production by industry, which is useful in

identifying which NAICS codes should be included in a graphic arts inventory. It is also useful for characterizing

the relative importance of each NAICS code within the inventory. The Economic Census, conducted once every

five years, also provides detailed data on the amount of ink consumed (in thousands of dollars) by each NAICS

Code in the manufacturing sector. Using these data helps identify the scope of the manufacturing facilities

(NAICS Codes 31-33) that should be included in this emissions inventory. It also can be used in conjunction with

employment data for 2007 to calculate the shipments of ink consumed per employee for each industry. Figure 1

below shows the ink consumption rate for each NAICS. The table that follows shows the actual values of the

shipments and the number of employees, along with the description of each NAICS code. The ink consumption

data are based on the 2007 Economic Census (U.S. Census Bureau, February 2011) and nationwide employment

in 2007 for each corresponding NAICS code from the Census Bureau’s County Business Patterns for the U.S. (U.S.

Census Bureau, 2012).

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Figure 1: Ink Expenses per Employee by NAICS Code, 2007

$0.00 $5,000.00 $10,000.00 $15,000.00 $20,000.00 $25,000.00

339950332431326112326111323121323119323118323117323116323115323114323113323112323111323110322299322231322225322224322223322222322215322213322212322211

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Table 4: Printing Ink Consumed in the U.S. by Manufacturing Industry, 2007

NAICS Description Ink Consumed Employees $ per

employee

322211 Corrugated and Solid Fiber Box

Manufacturing $225,028,000 109,747 $2,050.43

322212 Folding Paperboard Box Manufacturing $172,292,000 34,437 $5,003.11

322213 Setup Paperboard Box Manufacturing $4,845,000 3,603 $1,344.71

322215 Nonfolding Sanitary Food Container

Manufacturing $39,539,000 11,040 $3,581.43

322222 Coated and Laminated Paper Manufacturing $43,894,000 34,086 $1,287.74

322223 Coated Paper Bag and Pouch Manufacturing $13,948,000 3,048 $4,576.12

322224 Uncoated Paper and Multiwall Bag

Manufacturing $25,618,000 12,396 $2,066.63

322225 Laminated Aluminum Foil Manufacturing for

Flexible Packaging Uses $27,178,000 3,545 $7,666.57

322231 Die-cut paper and paperboard office

supplies manufacturing $13,959,000 9,318 $1,498.07

322299 All other converted paper product

manufacturing $4,582,000 19,858 $230.74

323110 Commercial Lithographic Printing $1,104,138,000 309,375 $3,568.93

323111 Commercial Gravure Printing $385,852,000 18,736 $20,594.15

323112 Commercial Flexographic Printing $151,198,000 32,036 $4,719.63

323113 Commercial Screen Printing $74,609,000 67,158 $1,110.95

323114 Quick Printing $6,333,000 40,771 $155.33

323115 Digital Printing $48,817,000 26,161 $1,866.02

323116 Manifold Business Forms Printing $17,551,000 24,235 $724.20

323117 Books Printing $57,970,000 32,913 $1,761.31

323118 Blankbook, looseleaf binders, and devices

Manufacturing $2,484,000 8,693 $285.75

323119 Other Commercial Printing $11,927,000 23,332 $511.19

323121 Tradebinding and Related Work $8,269,000 23,880 $346.27

326111 Plastic Bag and Pouch Manufacturing $65,035,000 29,894 $2,175.52

326112 Plastics Packaging Film and Sheet (including

Laminated) manufacturing $196,764,000 23,753 $8,283.75

332431 Metal Can Manufacturing $58,780,000 19,500 $3,014.36

339950 Sign Manufacturing $25,007,000 90,931 $275.01

MANUFACTURING SUBTOTAL $2,785,617,000 1,012,446 $2,751.37

There are four NAICS codes that reported consuming printing inks in the 2007 Economic Census for which the

specific amounts were not disclosed: 322214, 322226, 322232, and 322233. There were a total of 32,678

employees in these four NAICS Codes in 2007 was 32,678. If this figure is multiplied by the total dollar value of

ink consumed per employee rate for all of the NAICS Codes where data did exist ($2,751.37), the result is

$89,909,380 of ink consumed.

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Table 5: Estimated Ink Consumption in Undisclosed NAICS Codes, 2007

NAICS Code Description Employment Estimated Ink Consumption

322214 Fiber can, tube, drum, and similar product

manufacturing 8,056 $22,165,037

322226 Surface-coated paperboard manufacturing 2,510 $6,905,939

322232 Envelope manufacturing 18,025 $49,593,444

322233 Stationery, tablet, and related product

manufacturing 4,087 $11,244,849

Total n/a 32,678 $89,909,269

The estimated consumption of ink in manufacturing – about $2.9 billion in 2007 - only accounts for about 63% of

all ink shipments within the U.S. in 2007, however. In addition to the estimated consumption of ink in the

manufacturing sector, the U.S. Census Bureau also collects data on the total value of products shipped, including

inks. The table below summarizes the nation-wide value of shipments of printing ink by type for 2007 from the

Annual Survey of Manufactures (U.S. Census Bureau, March 2010):

Table 6: U.S. Printing Ink Shipments by Ink Type, 2007

Code Description Shipments ($) Percentage of Total

3259101 Letterpress Printing Inks $117,479,000 3%

3259104 Lithographic and Offset Inks $1,663,375,000 36%

3259107 Gravure Printing Inks $394,849,000 9%

325910A Flexographic Printing Inks $983,011,000 21%

325910E Nonimpact/Digital Inks $682,647,000 15%

325910H All Other Printing Inks $515,023,000 11%

325910W Printing Ink Manufacturing, NSK, Total $264,074,000 6%

325910 Printing Ink Manufacturing $4,620,458,000 100%

CAPCOG contacted staff at the US Census Bureau to seek to understand what the distinction between “all other

printing inks” and “printing ink manufacturing, NSK, Total” was. Staff spoke to Casey Bretz (301-763-7822) and

Sue Sunderman (301-763-4837), and according to them, these should be grouped together. Since all other types

of printing are accounted for in the list above, CAPCOG assumes that these products are inks used for screen

printing. In order to compare the two sets of data, CAPCOG assigned a primary printing ink type to each NAICS

code by cross-referencing the NAICS industry description with: (1) the technology/product relationships outlined

in the EIIP, (2) a NAICS listing in the control technique guidelines (CTG) document for flexible packaging printing

published by EPA (U.S. EPA, September 2006) and (3) assignments made by ERG in its 2001 report (Eastern

Research Group, Inc., 2001). Since digital and nonimpact inks do not produce VOC emissions, they were left out

of this process.

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Table 7: CAPCOG assignment of NAICS codes to Printing Inks/Technologies

Printing Ink/Technology

Assigned NAICS Codes Ink Shipped Ink Consumed Difference

Lithography 322232, 322233, 322299, 323110, 323114, 323116, 323117, 323121, 332431

$1,663,375,000 $1,318,461,293 -$344,913,707

(-21%)

Flexography

322211, 322212, 322213, 322214, 322215, 322222, 322223, 322224, 322225, 322226, 322231, 323112, 322218, 326111, 326112

$983,011,000 $1,010,852,976 +$27,841,976

(+3%)

Gravure 323111 $394,849,000 $385,852,000 -$8,997,000

(-2%)

Letterpress 323119 $111,479,000 $11,927,000 -$105,552,000

(-90%)

Other 323113, 339950 $679,481,000 $99,616,000 -$679,481,000

(-87%)

These assignments produce excellent agreement between shipments and consumption for the rotogravure and

flexographic ink types and fairly good agreement with the estimated shipments of lithographic inks, although

they leave large amounts of letterpress inks and other printing inks unaccounted for. Overall, 72% of all of non-

digital inks are accounted for using the consumption in the manufacturing sector in the 2007 Economic Census

(gap-filled for the four NAICS codes),

Once these adjustments are made, 72% of all emissions-related printing ink shipments are accounted for by the

ink consumed in the manufacturing sector. CAPCOG believes that the remaining 28% of the ink shipments are

consumed by some combination of newspaper printing facilities and institutional/governmental printing

facilities that would not report under the manufacturing NAICS codes. Many facilities may also have multiple

types of printing, such as an establishment that primarily uses offset lithographic presses but also has a

letterpress.

CAPCOG was able to identify some specific graphic arts facilities within the region that were engaged in graphic

arts production but were not listed in any of the records in the County Business Patterns or elsewhere as a

manufacturing establishment. These include:

University of Texas – Austin Print Shop,

University of Texas – Austin Sign Shop,

Texas Health and Human Services Commission Print Shop,

Texas Workforce Commissions Print Shop,

Texas Department of Public Safety Print Shop,

Texas Department of Transportation Print Shop,

Travis County Print Shop,

Travis County Sign Shop, and

Texas State University Print & Mail Services.

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These governmental and institutional printing facilities provide centralized printing services for whatever state

or local government or institution they are attached to. In absence of any better information, CAPCOG will

assume that the list above makes up 100% of the graphic arts emissions outside of the manufacturing sector

(NAICS Code 31-33).

Activity Estimates CAPCOG estimated activity levels using employment data in each of the NAICS code identified by the Economic

Census as consumers of printing inks for 2006 and 2008 in conjunction with survey data. ERG’s 2001 statewide

survey of Texas graphic arts facilities and a survey conducted by CAPCOG in April 2012 were used to develop

material consumption rates based on employment in the NAICS Codes of interest.

ERG Statewide Graphic Arts Inventory Eastern Research Group, Inc. (ERG) conducted a statewide graphic arts emissions inventory in 2001 that

produced employee-based material consumption and emissions rates tied to specific printing technologies

based on survey data (Eastern Research Group, Inc., 2001). ERG received 111 responses from 2,348 surveys

mailed out, with the vast majority reporting lithographic printing activity. ERG’s report included material

consumption rates for ink, blanket and roller wash, and fountain solution for lithographic, flexographic,

letterpress, and screen printing. ERG’s material consumption rates were presented as gallons of material per

establishment in the employment ranges used by the County Business Patterns reports, but they were based on

a gallons-per-employee rate that was then multiplied by the midpoint of those employment ranges. CAPCOG

calculated these emissions rates in order to derive the material consumption rates, although due to some

rounding errors, they may be slightly different than the actual consumption rate ERG calculated for its report.

ERG made the following assumptions:

Quick printing facilities, manifold business printing facilities, and book printing facilities were assigned to the lithographic model facilities,

Letterpress printing facilities were assigned to other commercial printing,

No gravure printing was assumed to be an area source, and

Emissions were reduced at all facilities to account for waste removal and disposal – 7.3% of incoming VOC is removed from the facility when waste inks, washes, etc. are collected and taken offsite for disposal.

This survey provides the best bottom-up data available to CAPCOG for estimating emissions from graphic arts

facilities within the region.

Table 8: Approximate Material Consumption Rates by Printing Technology, 1999 (gallons/employee)

Type Ink Blanket and Roller Wash Fountain Solution

Offset Lithography 27.8 25.7 11.4

Flexography 35.5 1.9 NA

Letterpress 0.05 2.86 NA

Screen 2.8 6.3 NA

ERG did not provide material consumption rates for gravure printing facilities, which it assumed were all point

sources. In addition to the material consumption rates, ERG also data on the average VOC content of these

materials and calculated emission rates for ozone attainment and non-attainment area based on the expected

level of VOC controls in each type of area. An explanation of these data is provided in the emissions rates

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section of this report. ERG also did not specify how to classify many of the establishment types that were

reported to consume printing in in the 2007 Economic Census.

Graphic Arts Establishments and Employment in the Austin MSA In order to calculate material consumption estimates for each type of printing provided by ERG, it was necessary

to obtain data on employment in printing establishments from the U.S. Census Bureau’s County Business

Patterns (CBP) database (U.S. Census Bureau, 2012). Since ERG’s study did not specify how certain printing

establishments that were not listed under NAICS code 323 – Printing should be categorized according to its

model facilities, CAPCOG assigned each of these NAICS codes to one of the printing technologies listed in table 2

of this report.

Table 9: Assignment of NAICS Codes to Printing Technology

NAICS Description Technology

322211 Corrugated and Solid Fiber Box Manufacturing Flexography

322212 Folding Paperboard Box Manufacturing Flexography

322213 Setup Paperboard Box Manufacturing Flexography

322214 Fiber Can, Tube, Drum, and Similar Products Manufacturing Flexography

322215 Nonfolding Sanitary Food Container Manufacturing Flexography

322222 Coated and Laminated Paper Manufacturing Flexography

322223 Coated Paper Bag and Pouch Manufacturing Flexography

322224 Uncoated Paper and Multiwall Bag Manufacturing Flexography

322225 Laminated Aluminum Foil Manufacturing for Flexible Packaging Uses Flexography

322226 Surface-Coated Paperboard Manufacturing Flexography

322231 Die-Cut Paper and Paperboard Office Supplies Manufacturing Flexography

322232 Envelope Manufacturing Lithography

322233 Stationery, Tablet, and Related Product Manufacturing Lithography

323299 All Other Converted Paper Product Manufacturing Lithography

323110 Commercial Lithographic Printing Lithography

323111 Commercial Gravure Printing Gravure

323112 Commercial Flexographic Printing Flexography

323113 Commercial Screen Printing Screen

323114 Quick Printing Lithography

323115 Digital Printing Plateless

323116 Manifold Business Forms Printing Lithography

323117 Books Printing Lithography

323118 Blankbook, looseleaf binders, and devices Manufacturing Flexography

323119 Other Commercial Printing Letterpress

323121 Tradebinding and Related Work Lithography

326111 Plastic Bag and Pouch Manufacturing Flexography

326112 Plastics Packaging Film and Sheet (including Laminated) manufacturing Flexography

332431 Metal Can Manufacturing Lithography

339950 Sign Manufacturing Screen

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For some NAICS codes, only employment ranges were available because of rules on avoiding disclosing data that

could enable someone to derive the employment data for a specific establishment in a county. The tables below

show the number of establishments and employees for each of the NAICS codes reporting ink consumption in

the 2007 Economic Census. In these cases, CAPCOG calculated the maximum and minimum number of

employees that could be in that NAICS code. These numbers were based on the number of establishments in

each employment range and used the midpoint of the computed countywide employment range.

The employment data for the Austin MSA grouped by technology type is provided in the table below.

Table 10: Average Austin MSA Employment by Printing Technology Type

Technology 2006 2008

Lithography 1417.0 1538.5

Flexography 63.5 49.0

Screen 723.5 791.0

Letterpress 140.5 83.0

Gravure 2.5 7.0

TOTAL 2,347.0 2,468.5

Calculation of Activity Estimates for Manufacturing CAPCOG used the employment estimates and ERG’s material consumption rates for the four technologies ERG

used in their report to calculate the total printing-related materials consumed in the region in 2006 and 2008.

These estimates are provided in the tables below.

Table 11: Materials Consumed by Printing Technology in Manufacturing, 2006 (gallons/year)

Material Lithography Flexography Screen Letterpress

Ink 39,393 2,254 36 393

Blanket and Roller Wash 36,417 121 2,069 885

Fountain Solution 16,154 0 0 0

Table 12: Materials Consumed by Printing Technology in Manufacturing, 2008 (gallons/year)

Material Lithography Flexography Screen Letterpress

Ink 42,770 1,740 40 232

Blanket and Roller Wash 39,539 93 2,262 523

Fountain Solution 17,539 0 0 0

Since ERG’s estimates did not include activity rates for gravure printing, CAPCOG instead developed an

employee-based emissions factor for gravure printing facilities that will be described later on in this report.

CAPCOG Graphic Arts Survey and Estimation of Institutional Printing Activity Initially, CAPCOG had hoped to use a local survey to estimate emissions from this source in the region. After

analyzing the existing studies, CAPCOG reached out to Mr. Joe Polanco of the Printing Industries of America-Mid

America (PIAM) to assist in the design of a survey and to gain a more in-depth understanding of what some of

the trends in the industry have been over the last ten years that could have affected VOC emissions from this

category. Mr. Polanco identified at least two trends that could affect the emissions from the printing industry: 1)

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a shift towards digital printing, and 2) a shift towards the use of substitutes for fountain solution in lithographic

printing.

CAPCOG drafted a survey based on the ERG study and the Emissions Inventory Improvement Program, Volume

III, Chapter 7: Graphic Arts report from EPA. (Eastern Research Group, 1996) CAPCOG then revised the survey

based on input from Mr. Polanco before finalizing it for distribution. A copy of the form is available as an

appendix to this report. The survey asked for the number of employees, hours of operation, the percentage of

printing by process type, material consumption, material properties, whether the facility has an air quality

permit, and what types of emission controls might be present at the facility. The survey asked respondents to

report for the year 2011.

CAPCOG developed a mailing list of 767 survey recipients within CAPCOG’s Rider 8 Program area, which includes

Bastrop, Blanco, Burnet, Caldwell, Fayette, Hays, Lee, Llano, Milam, Travis, and Williamson Counties. Recipients

were intended to be any establishment that could be engaged in printing processes, not just those that would

be listed under the NAICS code for printing (32311). Establishments such as government printing facilities and

newspaper companies were also included in the list. CAPCOG conducted internet searches on manta.com,

bizfind.us, and Google to identify establishments to survey and to identify their contact information. CAPCOG

also used a confidential database obtained from CAMPO of businesses in within the Austin MSA in 2007 that had

the number of employees, NAICS Code, and address.

In order to try to ensure a decent response rate, CAPCOG asked PIAM to do some outreach to its members

within the region to alert them that the survey would be coming and encouraging them to participate. PIAM also

provided a letter that was included with the survey encouraging the recipients to participate in the survey. A

copy of that letter is included as an appendix to this report. CAPCOG mailed out the surveys during the first

week of April 2012.

Unfortunately, CAPCOG only received 9 total completed surveys from respondents other than establishments

engaged only in digital printing. Of these, five were governmental or institutional print shops that were not

classified under NAICS code 323. These included print shops operated by the Texas Department of Public Safety

(DPS), the Health and Human Services Commission (HHSC), Texas State University Print & Mail Services (Texas

State), the University of Texas at Austin (UT-Austin), and the Texas Workforce Commission (TWC). These

facilities only reported lithographic printing and digital printing. Of the remaining responses from private

establishments, three conducted lithographic printing and one conducted flexographic printing.

The table below shows the responses from the five institutional/governmental print shops. Since respondents

were asked to report ink in pounds rather than gallons, CAPCOG assumed a density of 8.1 pounds per gallon of

ink based on input from PIAM.

Table 13: Governmental Print Shops Responding to Survey

Name Employees Lithography Ink Wash Fountain Solution or Sub

DPS 23 100% 57 60 10

HHSC 48 80% 98 660 40

Texas State 8 25% 1 10 8

UT-Austin 55 67% 259 150 30

TWC 7 0% 0 0 0

TOTAL 141 74% 415 880 88

15

In order to protect the confidentiality of the private businesses that responded to this survey, CAPCOG had

masked each respondent’s identity – only their printing technology is identified. The table below shows their

responses, with the digital percentage of each respondent’s printing activity listed for reference. In total, these

respondents represented 102 employees, which account for about 4% of the employment in the printing sector

in the region.

Table 14: Responses from Private Firms (material in gallons/year)

Name Employees Digital Ink Wash Fountain Solution or Sub

Litho-1 50 2% 437 220 220

Litho-2 23 30% 154 60 50

Litho-3 8 0% 182 0 35

Flexo-1 21 0% 1,148 0 0

TOTAL 102 6% 1,921 280 280

CAPCOG calculated the material consumption rates by technology type to compare to ERG’s consumption rates.

The average consumption rate was calculated as the total of the material reported consumed by the total

number of employees reported, adjusted to reflect the portion of printing that was non-digital. The calculated

lithographic ink consumption rate is 79% lower than ERG’s, the blanket and roller wash consumption rate is 71%

lower, and the fountain solution or substitute consumption rate is 74% lower. The one flexography’s ink

consumption rate was somewhat higher than ERG’s calculated average for flexographic printing

Table 15: Average Material Consumption Rates and Ranges by Technology Type (gallons/employee)

Technology Ink Wash Fountain Solution or Sub.

Lithography 5.8 (0.6 – 22.8) 7.4 (0 – 17.2) 2.7 (0.4 – 7.5)

Flexography 54.7 n/a n/a

CAPCOG called Joe Polanco, President of PIA Mid America to consult with him on the results of the survey. Mr.

Polanco conveyed that one likely explanation for the substantially lower blanket/roller wash consumption rate

was that there has been a substantial shift away from manual cleaning systems that would require substantial

quantities of this type of solvent and towards much more efficient automated cleaning systems. For fountain

solutions, Mr. Polanco indicated that there has also been a trend over the past ten years to move away from

using isopropyl alcohol in fountain solutions and to change to different wetting agents, since this is one of the

easiest ones for the industry to reduce its VOC emissions. Mr. Polanco also advised that he would not have

expected the ink consumption rate to have changed since the last survey.

CAPCOG decided to compare the quantities of ink consumed by the survey respondents to the expected range

of ink consumption for lithographic printing calculated from the 2007 Economic Census, using a range of $10 -

$40 per pound of ink (based on prices listed on commercial websites). The average value of ink consumed per

employee in offset lithographic printing was $3,568.93, corresponding to 89 to 357 pounds per employee. At a

density of 8.1 pounds per gallon, that corresponds to a range of 11 to 44 gallons per employee, with a midpoint

of 27.5, almost exactly the same as ERG’s survey result of 27.8 gallons per employee. This suggests that

CAPCOG’s survey responses were not likely to be representative of a typical lithographic printing facility in the

region.

In light of the low number of responses for this survey and the closer agreement between ERG’s estimated

material consumption rate and the 2007 Economic Census data, CAPCOG does not believe that adjusting ERG’s

16

material consumption rates is warranted at this time, especially since the emissions rates for point source

printing facilities would seem to indicate much higher material consumption rates within this industry (as will be

discussed in a later section of this report). However, they do suggest that there may be reduced solvent usage

for blanket/roller washing and fountain solution.

Emissions Rates CAPCOG used ERG’s emission rates for ozone attainment areas for offset lithography, flexography, letterpress,

and screen printing, and calculated an emissions rate for rotogravure printing using county business pattern

data and point source emissions inventories for rotogravure printing facilities in Texas.

Table 16: Controlled VOC Emission Rates by Process (lbs per employee per year)

Process ERG

Offset Lithography 181

Gravure 5,497

Flexography 80

Letterpress 17

Screen 48

In conducting initial research prior to conducting its survey, CAPCOG heard anecdotally that a number of

operators had been switching to low-VOC materials over the previous 10 years and that automation processes

reduced the need for blanket and roller wash. The responses CAPCOG received indicated as much, but due to

the low response rate, CAPCOG did not feel that there was enough technical justification for lowering the

emissions rates to reflect the survey data. However, CAPCOG does believe that these emission rates are likely

quite conservative, and that emission rates are likely significantly lower than these.

Derivation of Gravure Printing Emissions Rate There is one gravure printing facility in the Austin MSA, and since gravure was not included in ERG’s study,

CAPCOG needed to identify an employment-based emissions factor appropriate for this type of printing. ERG

had assumed that no gravure facilities were area sources, but while there are 12 gravure printing facilities in

Texas, there are only 2 that have reported to the point source inventory in recent years, neither of which was in

the Austin MSA. There were two options available for estimating emissions from this facility: 1) develop an

emissions rate based on data available in the point source emissions inventory, or 2) use the ink consumption

rate per employee for gravure printing, emissions inventory development documents for gravure printing

developed by EPA, and scale an emissions factor using the other printing types as reference points.

The table below shows the data from the point source database for the two gravure facilities that reported to it:

Table 17: VOC Emissions from Point Source Gravure Facilities 2008-2010 (tpy)

Owner Facility County 2008 2009 2010

Quebecor World Dallas Quebecor Printing Dallas Dallas 94.3741 21.8397 0.0000

Bureau of Engraving and Printing

BEP Western Facility Tarrant 19.6909 19.2393 20.8066

17

CAPCOG used these data in conjunction with employment data from Count Business Patterns to estimate the

emissions rates for each facility. In Dallas County, there was enough data that the total number of employees in

NAICS Code 323111 – Gravure Printing was available. CAPCOG calculated the number of employees using the

midpoints of each employment range for the establishments in Dallas County for 2008 and 2009, and the totals

were very close to the actual total. CAPCOG then estimated the number of employees for the two facilities

based on the assumption that they were the largest establishments in this category in each county. Using this

method, CAPCOG then calculated the approximate emissions rate for each facility.

Table 18: Calculation of Employee-Based Emissions Rates for Gravure Printing

Item Dallas 08 Dallas 09 Tarrant 08 Tarrant 09 Tarrant 10

Employees 47 26 ND ND ND

Employees using midpoints 44 24 n/a n/a n/a

Est. with 1-4 employees 1 1 2 1 1

Est. with 5-9 employees 1 1 1 1 1

Est. with 10-19 employees 0 1 1 0 0

Est. with 20-49 employees 1 0 0 0 0

VOC emissions (tpy) 94.3741 21.8397 19.6909 19.2393 20.8066

Midpoint of Largest Facility 34.5 14.5 2.5 7 7

Tons VOC /Employee 2.7355 1.5062 7.8764 2.7485 2.9724

The only establishment in the Austin MSA is located in Travis County and had 1-4 employees in 2006 and 5-9

employees in 2008. Using the midpoints of these ranges along with the median emissions rate of the 5

calculated, CAPCOG calculated the following emissions for 2006 and 2008:

2.5 (midpoint of 2006 employment) * 2.7485 tons/employee (median emissions rate) = 6.8713 tpy

7 (midpoint of 2008 employment) * 2.7485 tons/employee (median emissions rate) = 19.2395 tpy

Under TCEQ’s emissions inventory guidelines, sources that emit 10 tpy or more of VOC in the five-county Austin

MSA must report their emissions to the TCEQ’s point source emissions inventory. Since there is no record of any

gravure facility in Travis County submitting such an inventory, CAPCOG assumes that the emissions would be no

more than 10 tpy for 2008, rather than the 19.2395 tons calculated using the above method.

Adjustments to Account for Ink Consumption Variation Since not all industries that consume ink were accounted for in ERG’s study, and since some of them (such as

quick printing facilities) had far lower ink consumption rates than the NAICS code printing type they were paired

with, CAPCOG also calculated adjustment factors that would be applied to facility types that were not discussed

in ERG’s study. CAPCOG divided each industry’s ink consumption rate listed earlier (dollars per employee) by the

corresponding consumption rate for the printing NAICS codes. While certain industries may use more expensive

inks, CAPCOG believes that these adjustments provide the most accurate means of comparing the printing

activity per employee across industries. The table below shows the adjusted emission rates for each NAICS code

reporting ink consumption in the 2007 Economic Census, with the reference NAICS codes italicized.

18

Table 19: Emission Rate Adjustments by NAICS Code

NAICS Description Printing

Type Adjustment

VOC Rate (lbs/employee

322211 Corrugated and Solid Fiber Box Manufacturing Flexography 0.43 35

322212 Folding Paperboard Box Manufacturing Flexography 1.06 85

322213 Setup Paperboard Box Manufacturing Flexography 0.28 23

332214 Fiber Can, Tube, Trum, and Similar Product

Manufacturing Flexography 0.58 47

322215 Nonfolding Sanitary Food Container Manufacturing Flexography 0.76 61

322222 Coated and Laminated Paper Manufacturing Flexography 0.27 22

322223 Coated Paper Bag and Pouch Manufacturing Flexography 0.97 78

322224 Uncoated Paper and Multiwall Bag Manufacturing Flexography 0.44 35

322225 Laminated Aluminum Foil Manufacturing for

Flexible Packaging Uses Lithography 2.15 389

332226 Surface-Coated Paperboard Manufacturing Flexography 0.58 106

322231 Die-cut paper and paperboard office supplies

manufacturing Flexography 0.32 25

322232 Envelope Manufacturing Flexography 0.58 47

322233 Stationery, tablet, and related product

manufacturing Flexography 0.58 47

323299 All other converted paper product manufacturing Lithography 0.06 12

323110 Commercial Lithographic Printing Lithography 1.00 181

323111 Commercial Gravure Printing Gravure 1.00 5497

323112 Commercial Flexographic Printing Flexography 1.00 80

323113 Commercial Screen Printing Screen 1.00 48

323114 Quick Printing Lithography 0.04 8

323115 Digital Printing Plateless 1.00 0

323116 Manifold Business Forms Printing Lithography 0.20 37

323117 Books Printing Lithography 0.49 89

323118 Blankbook, looseleaf binders, and devices

Manufacturing Flexography 0.06 5

323119 Other Commercial Printing Letterpress 1.00 17

323121 Tradebinding and Related Work Lithography 0.10 18

326111 Plastic Bag and Pouch Manufacturing Lithography 0.61 110

326112 Plastics Packaging Film and Sheet (including

Laminated) manufacturing Lithography 2.32 420

332431 Metal Can Manufacturing Lithography 0.84 153

339950 Sign Manufacturing Screen 0.25 12

CAPCOG directly calculated the emissions for the governmental print shops using their survey responses. These

totals will be presented in the next section.

19

Emissions Estimates In order to calculate the county-wide emission totals, CAPCOG multiplied the employment in the estimated

employment in county for each of the 29 NAICS codes reporting ink consumption in the 2007 Economic Census

by the adjusted emissions rates presented in the previous section. This provided estimates of emissions from

private sector establishments in each of the five counties.

Table 20: Private Sector Graphic Arts VOC Emissions, 2006 and 2008 (tons per year)

County 2006 2008

Bastrop 3.45 0.55

Caldwell 0.35 0.35

Hays 6.45 3.06

Travis 92.61 98.00

Williamson 6.65 6.29

TOTAL 109.51 108.25

The large change in emissions in Bastrop County was due to a medium-sized commercial lithographic printing

establishment closing in the intervening period. The large change in emissions in Hays County is due to the

closure of two corrugated and solid fiber box manufacturing establishments in the intervening period. CAPCOG

then calculated the emissions from each governmental/institutional establishment that responded to CAPCOG’s

survey. These estimates are provided in the table below.

Table 21: VOC Emissions at Governmental and Institutional Print Shops (pounds/year)

Name Employees Ink Blanket or

Roller Wash Fountain Solution

Total Rate (lbs per

employee)

HHS Printing 38 136 4,389 55 4,580 119

UT-Austin 37 360 998 3 1,361 37

DPS 23 79 399 5 483 34

TxState 2 2 67 0 68 21

SURVEY TOTAL

104 577 5,852 63 6,492 63

CAPCOG did not receive a complete survey back from the Texas Department of Transportation (TxDOT), but it

did find out that their print shop has 35 employees and that 100% of their printing is offset lithography. CAPCOG

used the average of the emissions rate for the HHS, UT-Austin, and DPS print shops (since these all are used for

in-house printing for the state government, as is the TxDOT print shop) and calculated a total of 2,294 pounds

per year.

CAPCOG then added the emissions from these facilities to their appropriate county to get county-wide annual

totals. CAPCOG then divided the annual totals by the number of work-week days in 2006 and 2008 (251 and 253,

respectively) to calculate the typical ozone season day emissions for each county.

Table 22: Typical Ozone Season Day VOC Emissions, 2006 and 2008

County 2006 2008

Bastrop 0.0137 0.0022

Caldwell 0.0014 0.0014

20

County 2006 2008

Hays 0.0257 0.0121

Travis 0.3690 0.3873

Williamson 0.0265 0.0249

TOTAL 0.4363 0.4279

Offset lithographic printing makes up the vast majority of these emissions, followed by screen printing, gravure,

and flexography.

Figure 2: VOC Emissions by Printing Type, 2006

Comparison to Existing Estimates CAPCOG’s estimates for 2006 and 2008 represent a significant reduction from the 2008 NEI estimate. The most

recent estimates of emissions from graphic arts establishments in Central Texas is TCEQ’s A1 2008 AREA SOURCE

V4-2008 emissions inventory available through the Texas Air Emissions Repository (TxAER) system. However,

these estimates are much more in line with the 2005 inventory.

Table 23: TCEQ Ozone Season Day VOC Emissions Estimates from Graphic Arts for 2005 and 2008 (tons per day)

County 2005 2008

Bastrop 0.0121 0.0434

Caldwell 0.0000 0.0174

Hays 0.0291 0.3328

Travis 0.4470 4.7990

Williamson 0.0391 0.4331

TOTAL 0.5273 5.6257

Based on a conversation with TCEQ’s Charlie Rubick, CAPCOG learned that the 2005 estimate was based on

ERG’s statewide survey, while the 2008 data was based on national default data developed by E.H. Pechan &

4%

82%

6%

7%

0% 1%

Flexography

Lithography

Gravure

Screen

Plateless

Letterpress

21

Associates (Pechan) for the U.S. Environmental Protection Agency in support of the 2008 National Emission

Inventory (NEI) (E.H. Pechan, 2010).

There are two sets of emission factors that were developed by Pechan for the 2008 NEI – an employment-based

factor and a population-based factor. The factors used the quantity of solvents sold for the printing inks market

in 2007 (1,325 million pounds) from a report by The Freedonia Group (Report # 2357, Solvents to 2012, June

2008), in conjunction with nationwide employment and population data to develop the factors. The

employment-based factor (1,482 pounds per employee) was based on 894,170 employees nationwide in 2006 in

the following NAICS Codes:

Table 24: NAICS Codes and Employment Estimates used for 2008 NEI Employment-Based Graphic Arts Emissions Factor

NAICS Code Description Employees

32311 Printing 591,496

322211 Corrugated and Solid Fiber Box Manufacturing 115,231

322212 Folding Paperboard Box Manufacturing 35,209

322213 Setup Paperboard Box Manufacturing 4,131

322214 Fiber Can, Tube, Drum, and Similar Products Manufacturing 8,327

322215 Nonfolding Sanitary Food Container Manufacturing 11,404

322221 Coated and Laminated Packaging Paper Manufacturing 4,699

322222 Coated and Laminated Paper Manufacturing 32,956

322223 Coated Paper Bag and Pouch Manufacturing 2,943

322224 Uncoated Paper and Multiwall Bag Manufacturing 12,366

322225 Laminated Aluminum Foil Manufacturing for Flexible Packaging Uses 3,498

322226 Surface-Coating Paperboard Manufacturing 2,306

322231 Die-Cut Paper and Paperboard Office Supplies Manufacturing 9,545

322232 Envelope Manufacturing 18,719

322233 Stationery, Tablet and Related Product Manufacturing 4,209

322291 Sanitary Paper Product Manufacturing 17,372

322299 All Other Converted Paper Product Manufacturing 19,759

N/A ALL 894,170

If employment data from 2007 were used and all of the manufacturing NAICS codes reporting printing ink

consumption were used rather than the 2006 employment data used by Pechan, the adjusted emissions rate

would be 1,268 pounds per employee.

Pechan’s estimates and the underlying assumptions can be compared to a number of other data sources to

evaluate their strength relative to the survey-based data used in CAPCOG’s inventory for the Austin MSA.

CAPCOG’s analysis of these data sources led to the conclusion that the default estimates for this category

significantly over-estimate area source emissions from this category because the existing methodology does not

account for the disproportionate share of emissions that come from larger printing facilities that would be

reported in the point source inventory and because there are large variations in solvent use by the type of

printing taking place. For the smaller print shops that would typically make up this area source, the emissions

are likely better characterized by ERG’s 2001 survey, although even that survey may over-estimate current

emissions levels following over a decade of technological changes.

22

Manufacturing Energy Consumption Survey One data source that can be used to better understand the relationship between employment and the scale of

production in the printing industry is to examine data on energy consumption per employee for this industry.

While the current project is not trying to estimate emissions from energy consumption, to the extent that

energy consumption may better represent the scale of printing activity than employment, these data can help us

understand whether one of the basic assumptions that have been used for emission inventories in this category

– that there is a linear relationship between printing activity and employment – is valid or not.

The Energy Information Administration (EIA) conducts the Manufacturing Energy Consumption Survey (MECS)

every four years, with the last published results for 2006. These data provide detailed pictures of the energy

consumption in a wide range of manufacturing establishments, including the printing industry (NAICS code 323).

One of the tables provided in the survey provides the energy consumption per employee by overall employment

range (Energy Information Administration, June 2009). The data from Table 6-4 shows that energy consumption

per employee increases with the size of employment in the printing industry, with establishments of 100-249

employees consuming

Figure 3: Energy Consumption Per Employee by Establishment Size in the Printing Industry

These data show that establishments in the 50-99 employee range use 29% more energy per employee than

establishments with less than 50 employees, and that establishments in the 100-249 range and 250-499 range

use 133% more energy and 369% more energy per employee, respectively, than establishments with less than

50 employees. These data suggest significant economies of scale – with larger energy inputs required per

employee for larger output rates per employee at larger facilities. Since, according to the 2008 County Business

Patterns data, over 90% of printing establishments (nationwide and within the Austin MSA) have less than 50

employees, any survey of printing facilities could be expected to have significantly lower emission rates per

employee than larger facilities. The average energy consumption rate for all establishments – 164.6

MMBTU/employee – is much higher than the average rate of 72.3 MMBTU/employee for establishments with

72.3 93.6

168.6

339.1

412.1 428.0

0.0

50.0

100.0

150.0

200.0

250.0

300.0

350.0

400.0

450.0

Under 50 50-99 100-249 250-499 500-999 1000 and Over

Ene

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Co

nsu

mp

tio

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ate

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# Employees Per Establishment

23

fewer than 50 employees. CAPCOG expects that if the <50 range were further broken down, a similar pattern

would be evident. This suggests that one of the major problems with estimating emissions from this source

category using top-down methods is that unless they can account for economies of scale, they will tend to over-

predict the amount of emissions for a given county since the vast majority of printing establishments are smaller

and likely engage in far less activity than a straight emissions-per-employee rate using national data would

reflect. It also suggests that VOC emissions from the graphic arts industry may be highly concentrated at the

largest facilities.

Figure 4: Percent of Printing Establishments by Employment Size Category (2008)

Point Source Emissions Data One way to evaluate the validity of Pechan’s employment-based emissions rate is to compare it to data in

TCEQ’s point source emissions database and printing industry employment data. The most recent point source

emissions inventory available is the 2010 point source inventory

(http://www.tceq.texas.gov/assets/public/implementation/air/ie/pseisums/2010statesum.xlsx). Under the

Texas Administrative Code requirements for point source emissions inventories, sources that emit more than 10

tpy of VOC in the Houston-Galveston-Brazoria (HGB) and Dallas-Fort Worth (DFW) ozone nonattainment areas,

and a number of “near-nonattainment” counties, including all five counties in the Austin MSA, were required to

submit emissions inventories for 2010 to the TCEQ

(http://www.tceq.texas.gov/assets/public/comm_exec/pubs/rg/rg360/rg36010/rg-360a.pdf). If Pechan’s

emissions rate of 1,482 pounds of VOC per employee was used to calculate the minimum threshold for

employment that would be expected to trigger a reporting requirement, it would translate to 13.5 employees.

However, there are far fewer graphic arts facilities in the point source inventory than would be expected for this

emissions rate. In the Austin MSA, there were 22 printing (NAICS code 323) establishments in the 10-19

employee range, 17 in the 20-49 employee range, 6 in the 50-99 employee range, and 2 in the 100-249

employee range, but no graphic arts sources in the Austin MSA reported to the point source inventory. In Dallas

County, there were 61 graphic arts facilities with 10 employees or more, and 37 with 20 or more employees, but

only five submitted point source emissions inventories. Similarly, there was only one lithographic printing facility

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Lithographic

Gravure

Flexographic

Screen

Quick Printing

Manifold Business Forms

Books Printing

Blankbook, looseleaf binders, and devices…

Other Commercial Printing

Tradebinding and Related Work

TOTAL PRINTING

CAPCOG

1-4 5-9 10-19 20-49 50-99 100-249 250-499 500-999 1000+

24

in Harris County that reported to the point source inventory, but 27 establishments with over 20 employees, and

44 establishments with over 10 employees.

If the actual emissions rates are estimated based on the assumption that the facilities with the largest

employment within a NAICS code would correspond to the largest amount of emissions from the corresponding

SIC code point source account in a given county, the emission rates for lithographic printing, other commercial

printing, and paper product manufacturing appear much lower than Pechan’s estimates. The chart below shows

the total VOC emissions divided by the midpoint of the employment range the account was matched to, with

blue data bars (accounts CP0080 – TA1234I) representing commercial printing-NEC, red data bars (accounts

DF0089H – TA0172M) representing commercial lithographic printing, and purple data bars (accounts DB0787U –

MB0168G) representing paper products manufacturing. CAPCOG did not include the single gravure printing

facility on this list – its emissions rate would have dwarfed the others, at 10,403 pounds per employee.

Figure 5: Approximate VOC Emissions/Employee for Point Sources (pounds)

The average emissions rate for the ten lithographic printing facilities was 214 pounds per employee, with a

range of 156 -345 averaged across all lithographic facilities. ERG’s survey-based emissions rate of 181 pounds

per employee for lithographic printing is consistent with these data.

Control Technique Guidelines Existing estimates of emissions from lithographic printing, letterpress printing, and flexible package printing

used in the EPA’s control technique guidelines (CTGs) for these industries provide estimates of VOC emissions

for these industries that are largely consistent with what would be expected using Pechan’s estimate. The CTG

for lithographic and letterpress printing (U.S. EPA, September 2006) estimates a total of 400,000 – 500,000 tons

per year of VOC emissions from lithographic printing and a total of 28,000 tons per year for letterpress printing

in 1990, while the CTG document for flexible packaging printing (U.S. EPA, September 2006) estimated current

emissions of 42,000 – 76,000 tpy. This translates into a total of between 940 million pounds and 1,208 million

pounds of VOC emissions from these types of printing, compared to the Freedonia report’s 1,325 million pounds

0

200

400

600

800

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1200

1400

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Pechan Emissions Rate

25

for 2007. Although there is a temporal discrepancy between these two periods, the general agreement is

notable, and might suggest some validity to Pechan’s estimated emissions rate.

However, the difference in the timing of the estimates should also produce some big discrepancies that are not

accounted for. The 1990 estimate for lithographic printing included 62,000 tpy from ink, 126,000 tpy from

cleaning, and 212,000 – 312,000 tpy from fountain solution. The CTG for lithographic printing did state that,

“over the last 20 years, printers have greatly reduced the alcohol content of fountain solution,” and given that

fountain solutions were estimated to account 53-62% of all VOC emissions from lithographic printing, a shift

towards using alcohol-free or other low-VOC substitutes ought to greatly reduce the emissions rate from this

source.

Looking further back at a 1978 CTG document for rotogravure printing and flexographic printing (U.S. EPA,

December 1978), there are studies referenced that would tend to indicate far lower emissions from this

industry. One estimate indicated total solvent usage of 380,000 tons in 1976, which would translate into 1,791

million pounds in 2007 if there was an annual growth rate of 3%. The CTG used two other data sources to

estimate that gravure printing accounted for 41% of all VOC emissions from the printing industry, while

lithography accounted for 28%, letterpress accounted for 18%, and flexography accounted for 13%. If this is the

case, then gravure printing solvent consumption would significantly skew any industry-average emissions rate

much higher than it should be.

Census Bureau Data and EIIP Emission Rates Another point of reference for estimating the solvent usage in the graphic arts industry would be to compare

the ink consumption data from the Census Bureau to estimated ratios of VOC emissions to ink consumption

from the EIIP. The EIIP estimates the amount of VOC emissions per pound of ink consumed in each of the various

printing technologies that can then be used to estimate the range of solvents consumed by the printing industry

in 2007.

Table 25: Component VOC Emission Factors for Graphic Arts Operations from Table 7.5-2 (lbs of VOC per lb of ink used)

Type of Printing Ink Fountain Solution

Cleaning Solution

Total

Rotogravure 0.70 NA 0.03 0.73

Flexography 0.60 NA 0.04 0.64

Offset Lithography-Heatset 0.32 0.90 0.03 1.25

Offset Lithography-Nonheatset Web 0.02 0.53 0.03 0.58

Offset Lithography-Nonheatset Sheet 0.02 0.07 0.07 2.37

Offset Lithography – Newspaper 0.02 0.07 0.07 0.16

Letterpress 0.24 NA 0.07 0.31

Screen Unknown NA Unknown Unknown

Planographic Unknown NA Unknown Unknown

CAPCOG estimated an average ink price of $2.33 using an EPA document estimating the cost of VOC controls for

flexography (http://www.epa.gov/dfe/pubs/flexo/ctsa/ch5-cost.pdf). This would yield a total of 1.7 billion

pounds of ink shipped in 2007. The quantities of each type of ink can then be multiplied by the emission factors

from the EIIP to estimate the nationwide VOC emissions for each type of printing. For these calculations,

CAPCOG used the highest emission rate for lithographic printing – for non-heatset sheet-fed printing – and used

ERG’s estimate for screen printing since no other emissions factor was available.

26

Table 26: Calculated Nationwide Emissions from Printing using Economic Census and EIIP Factors, 2007

Ink Type Value of Shipments Pounds of Ink Lb VOC/lb Ink VOC Emissions

Lithographic $1,663 million 714 million pounds 2.37 1,692 million pounds

Flexographic $983 million 421 million pounds 0.64 270 million pounds

Screen $779 million 334 million pounds 0.45 150 million pounds

Rotogravure $395 million 170 million pounds 0.73 124 million pounds

Letterpress $117 million 50 million pounds 0.31 16 million pounds

Total Non-Digital $3,938 million 1,690 million pounds N/A 2,251 million pounds

This quantity of VOC emissions is actually significantly higher than the Freedonia estimate of the amount of

solvents consumed by the graphic arts sector, although it is highly sensitive to the assumptions for the

lithographic printing sector. Using a density of 8.1 pounds of ink per gallon, it is possible to calculate ERG’s

emission rates in units comparable to the EIIP, and for lithography, its uncontrolled rate is 1.01 pounds of VOC

per pound of ink. Using the calculated ERG’s emission rate for lithographic printing would result in an estimated

total of 1,281 pounds of solvents consumed in 2007, which is actually quite close to the Freedonia data.

Conclusion and Recommendations CAPCOG updated the graphic arts emissions inventory for 2006 and 2008 based on an extensive literature

review, data analysis, and its own survey of local graphic arts establishments. The resulting emissions inventory

is less than 10% of the existing 2008 inventory, and was based primarily on employment-based emission factors

developed by ERG in its 2001 report for TCEQ. CAPCOG believes that – considering all of the various data sources

available – ERG’s emission rates are most representative of the emission rates for graphic arts facilities in the

Austin MSA. The top-down methodology used for the existing inventory appears to over-estimate solvent usage

at smaller graphic arts facilities and facilities that do not use gravure printing. CAPCOG’s own survey, although it

did not produce nearly enough responses to form the basis for a full-scale inventory of this category, did provide

more evidence that the Pechan emissions rate of 1,482 pounds of VOC per employee is quite a bit higher than it

should be, and certainly doesn’t reflect the emissions rate of smaller graphic arts facilities, which make up the

vast majority of such establishments. The most compelling evidence for this is the lack of graphic arts facilities

reporting to TCEQ’s point source emissions inventory – Pechan’s emissions rate would imply that there would be

dozens of printing facilities reporting to the point source inventory in each major metropolitan area in the state,

when in fact there are only a handful of such large printing facilities. CAPCOG’s research indicates that these

large printing facilities make up a disproportionate amount of VOC emissions and/or solvent consumption from

the graphic arts sector relative to their share of employment within the sector. Qualitatively, CAPCOG believes

that ERG’s emissions rates are actually probably too high, based on technological changes in the sector in the

past 10 years. However, in absence of a robust survey of graphic arts facilities, which would likely need to be

done on the state level rather than the local level, ERG’s data provides the best basis for this area source

category.

In light of CAPCOG’s research into this source category, CAPCOG makes the following recommendations for

future work on area source graphic arts emissions inventories:

The ink consumption rates derived from the Economic Census should be used to derive emission rates specific to each NAICS code in this category,

If statewide inventories don’t already do this, graphic arts emissions inventories should subtract out not only the emissions, but the actual solvents used at graphic arts point sources,

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The the number of employees from each point source should be subtracted from county employment totals,

Efforts should be made to account for technological change that has occurred in this industry, especially the substitution of low-VOC fountain solutions and the implementation of automation in cleaning, that would affect the emission rates, and

Local surveys for this category may be of little value unless sources are required to respond to the survey.

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Appendix A: CAPCOG Graphic Arts Survey Form

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Capital Area Council of Governments Graphic Arts Emissions Survey

The Capital Area Council of Governments is conducting a survey of Graphic Arts businesses in the region to improve estimates of emissions. The information will be used to help improve the accuracy of estimating pollution levels in the region, especially ground-level ozone. Your individual company’s responses will be kept confidential. Please e-mail responses to Andrew Hoekzema in CAPCOG’s Air Quality Program at ahoekzema@capcog.org by April 30, 2012. If you have questions about this survey, please feel free to call Andrew Hoekzema at (512) 916-6043.

Company Name and Address

Question 1: What was the average number of employees at this establishment in 2011?

Question 2: What percentage of your printing uses the following technologies?

Rotogravure: Flexography:

Offset Lithography:

Screen: Digital:

Question 3: What Are Your Hours of Operation? Monday-Friday:

Saturday: Sunday:

Question 4: How many gallons of fountain solution did your business consume in 2011 and what was the % Isopropyl Alcohol content by volume?

Gallons Fountain Solution Consumed in 2011:

% Isopropyl Alcohol Content :

Question 5: If you used “alcohol free” fountain solutions in 2011, how many gallons of alcohol substitute were used as a fountain solution additive, what was the manufacturer and brand name, and what was the % VOC content of the substitute?

Gallons of Substitute Consumed in 2011:

Manufacturer and Brand Name:

% VOC Content of the Substitute:

Question 6: How many gallons of blanket and roller wash were used in 2011?

Question 7: How many pounds of ink were purchased in 2011 in the following categories?

Flexography (Water-Based): (Solvent-Based):

Offset Lithography (Sheetfed): (Heatset Web):

Rotogravure:

Question 8: Does your facility have an air quality permit? If so, what is the permit number?

Question 9: Does your facility employ any of the following emission controls?

Add-On Controls Thermal Oxidizer: Catalytic Oxidizer: Chiller Condenser (Condenser Filter): Material Controls: U.V. Inks: Cooling Fountain Solution: Low-Vapor Pressure Cleaning Solvents: Low-VOC Content Cleaning Solvents: Work Practices: Keeping solvent containers closed: Keeping used shop towels in closed containers:

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Appendix B: PIAM Letter Accompanying Survey

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