FAX TRANSMISSION

Headquarters, US EPA

401 M St., S.W.

Washington, D.C. 20460

Date: November 7, 1995

To: Davika Misir, New York Department of Environmental Protection

Fr: Mark Ingle, Project Officer, Metal Products and Machinery, Phase II

Re: Classification of Engraving Process

Summary

On November 2, 1995, you faxed me some information on an engraving process and asked for an EPA category determination. Based on an analysis of the 40 CFR 433, "Metal Finishing" category requirements, the process in question would not be covered.

Discussion

Attached is a copy of the 40 CFR 433 "Metal Finishing" regulation. As shown in section 40 CFR 433.10 (c), ". . . metallic platemaking and gravure cylinder preparation conducted in publishing facilities; . . ." are operations that are specifically exempt from regulation. In your November 2, 1995 fax transmission, the process in question that you described is typical of techniques used to make printing plates (i.e., a pattern is etched or engraved into a surface to hold ink) and appears to be conducted in a publishing or printing plant. Thus, because the technology employed is basically that of making printing plates and the operation is performed at a printing plant, the process in question satisfies the 40 CFR 433.10 (c) criteria for not covering this process under 40 CFR 433.

The Federal EPA does not have any other categorical standards related to the manufacture of printing plates. As such, you are free to apply applicable local limits in the development of a permit for the process in question.

If you have any questions, or need additional information, please feel free to call me at (202) 260-7191.