new york air pollution control compliance kit for printing ... · volatile organic compounds...

New York Air Pollution Control Compliance Kit

For Printing Operations

April 16, 2013

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Table of Contents

Letter of Recommendation ......................................................................................................... 3 Background ................................................................................................................................ 4 How to Use this Toolkit .............................................................................................................. 4 Summary of Applicability and Regulatory Requirements ............................................................ 5 General Questions and Answers ................................................................................................ 6

When did the new rules become effective? ............................................................................ 6 Who does Part 234 apply to? ................................................................................................. 6 What is the New York State Severe Ozone Nonattainment Area? .......................................... 6 What is required if the VOC limits/control requirements of Part 234 do not apply to me? ....... 6 What are the monitoring requirements for control devices? .................................................... 6 What are the testing requirements? ........................................................................................ 7 What are the requirements for handling, storage, and disposal? ............................................ 7 What are the prohibition of sale requirements? ...................................................................... 7 What are the opacity requirements? ....................................................................................... 7 What are the record keeping requirements? ........................................................................... 8 What records can be used to show that a facility is below the 3 ton per year on a 12-month rolling basis? .......................................................................................................................... 8 How do I calculate my VOC emissions? ................................................................................. 9 What is Potential to Emit (PTE)? ............................................................................................ 9 What are the new permitting thresholds for the New York State severe ozone nonattainment area? ...................................................................................................................................... 9 What are the new permitting thresholds for facilities outside the severe ozone nonattainment area? .....................................................................................................................................10 What activities are exempt from permit requirements? ..........................................................10

Lithographic Questions and Answers ........................................................................................12 What types of Lithographic facilities does Part 234 apply to? ................................................12 What does Part 234 require?.................................................................................................12 How do I determine the VOC content of materials? ...............................................................12 What are the VOC content limits for lithographic inks? ..........................................................13 What are the VOC content limits for fountain solutions? ........................................................13 What are the VOC content limits for cleaning solutions? .......................................................14 What are the requirements for control devices for heatset web offset presses? ....................14 What records can be used to show that heatset web offset presses are below the threshold? ..............................................................................................................................................15 What testing methods can be used to show that control equipment is meeting the efficiency limits for heatset lithographic presses? ..................................................................................15 How can I obtain additional information? ...............................................................................16

Digital and Screen Printing Questions and Answers..................................................................17 What screen printing operations are subject to Part 234? .....................................................17 What does Part 234 require for inks? ....................................................................................17 What requirements to apply to all screen printing operations?...............................................17 How can I obtain additional information? ...............................................................................17

Flexographic Printing Questions and Answers ..........................................................................18 What flexographic printers must comply? ..............................................................................18 What are the VOC control options for flexographic printers? .................................................18 What control equipment monitoring must be done? ...............................................................18 What are the stack testing requirements? .............................................................................18 How can I obtain additional information? ...............................................................................19

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Recordkeeping Forms ...............................................................................................................20 12 Month Rolling Emissions – Material Usage Option ...........................................................21 Fountain Solution Batch VOC Content Form-One Step .........................................................22 Fountain Solution VOC Addition Form ...................................................................................23 Fountain Solution Batch VOC Content Form-Two Step .........................................................25 Fountain Solution VOC Addition Form ...................................................................................27 Fountain Solution Batch Record ............................................................................................29 Cleaning Solution Batch VOC Content Form .........................................................................30 Cleaning Solution VOC Addition Form ..................................................................................31 Cleaning Solution Batch Record ............................................................................................32 Cleaning Solution Usage Record ..........................................................................................33

Appendix 1 Determining VOC Emissions From Printing Operations (Applicable to All Processes) .................................................................................................................................................34

VOC Emission Calculation Worksheet ...............................................................................35 Emission Factors For Sheetfed and Nonheatset Web Offset Lithographic Printing Operations.........................................................................................................................37 Emission Factors For Heatset Web Offset Lithographic Printing Operations Without Controls .............................................................................................................................37 Emission Factors For Screen Printing Operations .............................................................37 Emission Factors For Digital Printing Operations...............................................................38 Emission Factors For Flexographic and Rotogravure Printing Operations Without Controls ..........................................................................................................................................38

Appendix 2 Determining VOC Emissions From Heatset Web Offset Lithographic Printing Operations ................................................................................................................................39

Background .......................................................................................................................39 VOC Emissions from Heatset Web Offset Lithography ......................................................40 VOC Emission Calculation Worksheet For Heatset Web Offset Lithographic Printing .......42

Appendix 3 Determining VOC Emissions From Non-heatset Web Offset Lithographic Printing Operations ................................................................................................................................46

Background .......................................................................................................................46 VOC Emissions From Non-heatset Web Offset Lithography ..............................................46 VOC Emission Calculation Worksheet For Non-heatset Web Offset Lithographic Printing 48

Appendix 4 Determining VOC Emissions From Sheetfed Offset Lithographic Printing Operations .................................................................................................................................................52

Background .......................................................................................................................52 VOC Emissions From Sheetfed Offset Lithography ...........................................................52 VOC Emission Calculation Worksheet For Sheetfed Offset Lithographic Printing ..............54

Appendix 5 Express Terms Part 201-3, Exemptions and Trivial Activities .................................58 Appendix 6 Express Terms Part 234, Graphic Arts ...................................................................68

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Letter of Recommendation

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Background On July 8, 2010 amendments to Title 6 of the New York Codes, Rules and Regulations (NYCRR), Part 201-3, Exemptions and Trivial Activities and Part 234, Graphic Arts became effective. Changes to the regulations apply to all lithographic, letterpress, rotogravure, flexographic, and screen printing operations in New York State. Part 201-3 includes changes to the permit requirements for printers, including a new exemption from permitting. Part 234 sets emission limits and other requirements for volatile organic compound (VOC) emissions from printing operations. Facilities located in severe ozone non-attainment areas and facilities with actual VOC emissions of greater than 3 tons per year on a 12-month rolling basis are subject to the entire Part 234 as specified, while facilities located outside a severe ozone non-attainment area with actual VOC emissions less than 3 tons per year on a 12-month rolling basis are subject to only some sections of Part 234. Currently, severe ozone nonattainment areas include all of New York City, Nassau, Suffolk, Westchester and Rockland Counties and parts of Lower Orange County (towns of Blooming Grove, Chester, Highland, Monroe, Tuxedo, Warwick and Woodbury). A copy Part 201-3 is included in Appendix 4. A copy of Part 234 is included in Appendix 5. The rule is significant because it targets small printing operations in the severe ozone nonattainment area. The reason for the focus on this geographic area is because of the persistent air pollution problems and continuing non-compliance with the federal ozone standard. Ozone is one of the six air pollutants regulated by the U.S Environmental Protection Agency. Areas that exceed the acceptable level or concentration of ozone are classified as nonattainment and are required to develop and implement air pollution control regulations to reduce the ozone concentration, which is produced by VOC reacting with nitrogen oxides in the presence of sunlight.

How to Use this Toolkit This toolkit is intended to assist printers in complying with the new air pollution control regulation. It contains information and forms that will allow printing operations to understand their compliance obligations and put in place programs to demonstrate compliance with of the rule. Please note that some requirements differ for various printing processes. The toolkit is divided into five main sections. The first includes general questions and answers for all facilities. The next three sections contain process specific information in Part 234. Specific requirements for lithographic, digital/ screen and flexographic operations, see the respective Question and Answer sections. The fifth section includes sample recordkeeping forms that can be used to meet the requirements of the rule. Several appendices are included to provide additional background information.

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6 NYCRR Part 234 ‘Graphic Arts’

Summary of Applicability and Regulatory Requirements Facilities subject to Part 234 engage in: packaging and publication rotogravure, offset

lithographic, letterpress, flexographic and screen printing processes

Facilities located in NYS Severe Ozone Non-Attainment Areas

(Currently all of New York City, Nassau, Suffolk, Westchester and Rockland Counties, and parts of Lower Orange County (towns of Blooming Grove, Chester, Highland, Monroe, Tuxedo, Warwick and Woodbury).

Applicability Regulatory Requirements All subject facilities, regardless of their potential to emit (PTE) volatile organic compounds (VOCs).

NYSDEC permitting requirements of Part 201. All requirements of Part 234 including: recordkeeping, prohibition of sales, handling storage and disposal, opacity, and control requirements. The control requirements include:

VOC content limits for printing materials used in screen printing, gravure and flexographic processes; or control of their VOC emissions.

Control of VOC emissions from heat-set lithographic and heat-set letterpress processes; rotogravure, publication rotogravure and flexographic printing.

VOC content limits on fountain solutions used in lithographic printing.

VOC content limits on cleaning materials used in lithographic and letterpress operations.

Facilities not located in NYS Sever Ozone Non-Attainment Areas

Applicability Regulatory Requirements All subject facilities, regardless of their PTE or actual emissions of VOCs.

The following Part 234 requirements apply: recordkeeping, prohibition of sales, handling storage and disposal, and opacity requirements.

All subject facilities, with total actual emissions of VOCs > 3.0 tons per year (tpy).

NYSDEC permitting requirements of Part 201. All requirements of Part 234 including: recordkeeping, prohibition of sales, handling storage and disposal, opacity requirements, and some control requirements. The control requirements include:

VOC content limits on fountain solutions used in lithographic printing.

VOC content limits on cleaning materials used in lithographic and letterpress operations.

All subject facilities which have a total PTE of > 50 tpy: or for an individual presses which has a PTE > 25 tpy.

Have the following additional control requirements:

VOC content limits for printing materials used in screen printing, gravure and flexographic processes; or control of their VOC emissions.

Control of VOC emissions from heat-set lithographic and heat-set letterpress processes.

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General Questions and Answers

When did the new rules become effective?

The rules became effective on July 8, 2010.

What types of printing facilities does Part 234 apply to?

The rule applies to all printers, including packaging rotogravure, publication rotogravure, flexographic, lithographic, letterpress and screen printing processes, in New York State. All such processes must comply with the recordkeeping, opacity, prohibition of sale, and storage and handling requirements of the regulation, regardless of their location, emissions, or permit requirements. The entire rule applies to lithographic printers with actual VOC emissions of greater than or equal to 3 tons per year (on a 12-month rolling basis), and any lithographic printer located in the severe ozone nonattainment area. Certain sections of the rule apply to printers outside of the severe ozone nonattainment area with actual VOC emissions of less than 3 tons per year, on a 12-month rolling basis. In addition, some requirements of Part 234 apply to flexographic and screen printing. Unless specifically exempt from Part 234, facilities that are exempt from permitting must still comply with Part 234.

What is the New York State Severe Ozone Nonattainment Area?

New York State’s severe ozone nonattainment area includes the five counties of New York City (Bronx, Kings, Queens, Richmond and New York), Nassau, Rockland, Suffolk, and Westchester Counties and parts of lower Orange County (towns of Blooming Grove, Chester, Highland, Monroe, Tuxedo, Warwick and Woodbury).

What is required if the VOC limits/control requirements of Part 234 do not apply to me?

All facilities are subject to the prohibition of sales, handling, storage, disposal, recordkeeping and opacity requirements of the rule. This includes facilities with actual VOC emissions of less than 3 tons per year on a 12-month rolling basis, even if they do not need a permit.

What are the monitoring requirements for control devices?

The following monitoring devices are required for control devices. Monitoring must be continuous.

Carbon adsorption units - VOC breakthrough monitors

Oxidizers - Combustion zone temperature monitors

Catalytic oxidizer bed s- Inlet temperature monitors

For all control devices, any other continuous monitoring device required by the New York State Department of Environmental Conservation (NYSDEC).

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What are the testing requirements?

For VOC/solvent recovery control methods: To show proper removal efficiencies, one of the following test methods: 1. Method 18, Measurement of Gaseous Organic Compound Emissions by Gas Chromatography; 2. Method 25, Determination of Total Gaseous Non-methane Organic Emissions as Carbon; or 3. Method 25A, Determination of Total Gaseous Organic Concentration Using a Flame Ionization Analyzer. 4. Other alternative methods approved in advance by the NYSDEC and the U. S. Environmental Protection Agency. For Control Equipment other than VOC/solvent recovery: The chosen demonstration method must include provisions to determine the overall removal efficiency. Additional Testing requirements: The NYSDEC may request other emissions testing in accordance with Part 202.1. If any stack testing is being conducted to determine compliance with this regulation, NYSDEC must be notified 30 days prior to testing.

What are the requirements for handling, storage, and disposal?

Any used rags (cloth or paper) containing VOCs or solvents must be kept in closed containers. In addition, any containers used to store fresh or used VOCs or solvents must be kept closed.

What are the prohibition of sale requirements?

No person (including printers) may require, specify, or sell any coating, ink, adhesive, or substrate that is prohibited by this rule. These prohibited products are used in the packaging rotogravure, publication rotogravure, screen printing or flexographic printing process, and include inks with VOC content above the limits set by the rule. For more information on VOC content limits of these products see the Digital and Screen Printing Q&A and the Flexographic Q&A sections of this toolkit.

What are the opacity requirements?

Printing facilities must not exceed an average 10% opacity limit for any consecutive six minute period from any emission sources subject to this rule. Opacity, as defined in Part

200 is “The degree to which emissions other than water reduce the transmission of light and obscure the view of an object in the background.”

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What are the recordkeeping requirements?

Purchase, use, and production records for inks, coatings, adhesives, VOCs, solvents, fountain solutions, and cleaning materials must be maintained and submitted to the NYSDEC upon request. These records must be kept at the facility for five years. Any analysis or testing used to determine compliance must be submitted to the NYSDEC. NYSDEC must be allowed to take samples of inks, coatings, adhesives, fountain solutions or cleaning solutions in order to determine compliance. A facility that is not subject to the VOC limits for fountain solution and cleaning solution because of its annual potential to emit and location outside the severe ozone nonattainment area must maintain records to verify that actual annual VOC emissions are below the threshold. These records must be available to the NYSDEC upon request. Sample recordkeeping forms are provided on pages 20 through 33. These forms can be used to keep material use records and determine the VOC content of as-applied fountain solutions and cleaning solution as well as demonstrate compliance.

What records can be used to show that a facility is below the 3 ton per year on a 12-month rolling basis?

To show that emissions are below the 3 ton per year on a 12-month rolling basis, facilities may keep material use records or calculate VOC emissions. Material use below the thresholds in the following chart ensures that VOC emissions will not exceed 3 tons per year on a 12-month rolling basis. These material use records are very conservative. If they are exceeded, a facility may still be below the 3 ton per year on a 12-month rolling basis threshold, however this would have to be demonstrated using calculations. A facility having a combination of printing methods must comply with the smallest usage limit or calculate emissions. In addition, for facilities with multiple printing methods, material use can only be utilized if the material tracking units for all printing methods are compatible (for example gallons to gallons) and the total usage from all processed are below the lowest threshold. If the material tracking units are not compatible (gallons and pounds), emissions must be calculated. For example, if a facility operates both screen and letterpress equipment, the material use threshold can be used, since both require material use to be tracked in gallons. The material use limit of 855 gallons would apply. To determine if a facility exceeds the applicability threshold based on usage figures, the total combined volume of material used by both the screen and letterpress presses would need to be below the 855 gallon threshold.

Type of Printing Operation 12-Month Rolling Material Use Threshold

Sheet-fed Offset Lithographic 855 gallons of cleaning solvent and fountain solution additives combined

Non-heatset Web Offset Lithographic

855 gallons of cleaning solvent and fountain solution additives combined

Heatset Web Offset Lithographic 6,000 pounds of ink, cleaning solvent, and fountain solution additives combined

Screen 855 gallons of inks, cleaning solvents and other solvent containing materials combined

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Letterpress 855 gallons of cleaning solvents and other solvent containing materials combined

Flexographic, water-based or UV 24,000 pounds of water-based inks, coatings and adhesives combined

Flexographic, solvent-based 6,000 pounds of solvent from inks, dilution solvents, coating, cleaning solutions, and adhesives combined

How do I calculate VOC emissions?

See Appendix 1 for instructions on how to calculation VOC emissions that can be used to determine VOC emissions from any printing operation. For information on how to calculate VOC emissions from specific lithographic operations, refer to the following appendices:

Appendix 2 - Determining VOC Emissions From Heatset Web Offset Lithographic Printing Operations

Appendix 3 - Determining VOC Emissions From Non-heatset Web Offset Lithographic Printing Operations

Appendix 4 - Determining VOC Emissions From Sheetfed Offset Lithographic Printing Operations

What is Potential to Emit (PTE)?

Potential to Emit (PTE) is the basis for determining permitting requirements. Part 200 defines PTE as “The maximum capacity of an air contamination source to emit any regulated air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the emission source to emit a regulated air pollutant, including air pollution control equipment and/or restrictions on the hours of operation, or on the type or amount of material combusted, stored, or processed, shall be treated as part of the design if the limitation is enforceable by the department...”

What are the new permitting thresholds for the New York State severe ozone nonattainment area?

No recent changes have been made to the permitting requirements for facilities in the severe ozone nonattainment area. They remain as follows:

Facilities that use only UV-cured inks are exempt from permitting

All printers must register or obtain a permit, depending on emission rates o Registration is required for facilities that emit less than 12.5 tons of VOC

per year. o State minor source permits are required if a facility’s VOC emissions

exceed 12.5 tons per year. o Title V permits are required for facilities with the potential to emit 25 tons

of VOC per year or more.

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Facilities located in New York City also need an air permit from the New York City Department of Environmental Protection (NYCDEP). For additional information please contact Bruce MacDonald at the Small Business Environmental Assistance Program at 718-595-4454 or go to http://www.nyc.gov/html/dep/html/home/home.shtml.

Facilities located in Westchester County also need an air permit from Westchester County Department of Health. For more information, contact Natasha Court, PE at 914-813-5149 or go to http://westchestergov.com.

What are the new permitting thresholds for facilities outside the severe ozone nonattainment area?

Changes made to Subpart 201-3 affect the permitting thresholds for printers located outside of severe ozone nonattainment areas. The new permitting thresholds are as follows:

If actual facility wide VOC emissions are less than 3 tons per year on a 12-month rolling basis, registration is not required. Material use records and emissions records must be kept to demonstrate exempt status.

Printers must register or obtain a permit if their actual VOC emissions are greater than 3 tons per year on a 12-month rolling basis.

o If actual facility wide VOC emissions are greater than 3 tons per year on a 12-month rolling basis but less than 25 tons per year, a registration certificate is required.

o If actual facility wide VOC emissions are greater than 25 tons per year a state minor source permit is required.

o If potential to emit VOC is greater than 50 tons per year, a Title V permit is required.

State minor source permits can contain enforceable emission limitations to avoid Title V permit requirements and/or control requirements for individual or multiple printing processes.

What activities are exempt from permit requirements?

The following activities are exempt from permit requirements for Minor Facility Registration (201-4) and State Facility Permits (201-5). However, these items MUST be included in all calculations for determining potential to emit VOCs for Title V permits.

Screen printing inks/coatings or adhesives which are applied by a hand-held squeegee. A hand-held squeegee is one that is not propelled through the use of mechanical conveyance and is not an integral part of the screen printing process.

Graphic arts processes at facilities located outside a severe ozone nonattainment area with facility-wide VOC emissions from ink, coating, adhesive, fountain solution and cleaning solution less than 3 tons per year on a 12-month rolling basis.

Graphic label and/or box labeling operations where inks are applied by stamping or rolling.

Graphic arts processes exempt from Part 234, with respect to emissions of VOCs which are not given an A rating

o “A” rated VOCs: “An air contaminant whose discharge results, or may result, in serious adverse effects on receptors or the environment. These effects may be of a health, economic or aesthetic nature or any combination of these.” Any

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emissions from VOCs that fall in the “A” rating would have to be included in permitting calculations and application. These compounds are not typically found in inks, cleaning solutions or fountain solutions used in lithographic printing.

The following activities are exempt from permit requirements for Minor Facility Registration (201-4) and State Facility Permits (201-5). Additionally, these items do not have to be included in Title V Permits (201-6).

Lead melting pots

Blueprint machines

Photocopying, photographic processing, or related equipment

Proof press operations

Heat sealing operations used to seal and separate polyethylene and polypropylene bags

The sources listed above must be included in calculations to determine applicability to Title V facility permitting, new source review, and prevention of significant deterioration (Part 231).

Owners/Operators of emission sources that are eligible to be exempt or considered trivial may be required to certify that the sources meet the requirements. All records related to such sources must be kept on-site for five years, and be made available to the NYSDEC upon request.

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Lithographic Questions and Answers

What types of lithographic facilities does Part 234 apply to?

The rule applies to all printers in New York State. The entire rule applies to lithographic printers with actual VOC emissions of greater than or equal to 3 tons per year (on a 12-month rolling basis), and any lithographic printer located in the severe ozone nonattainment area. Certain sections of the rule apply to printers outside of the severe ozone nonattainment area with actual VOC emissions of less than 3 tons per year, on a 12-month rolling basis.

What does Part 234 require?

All lithographic printing facilities in the severe ozone nonattainment area or with 12-month rolling VOC emissions of greater than 3 tons must limit the VOC in their fountain solutions and cleaning solutions and keep records to document this requirement. They must also meet prohibition of sales, handling storage and disposal, and opacity requirements of the rule. Heatset web operations at facilities in the severe ozone nonattainment area, or with the potential to emit 25 tons or more VOC per year, or located at a facility with a potential to emit 50 tons or more VOC per year must meet additional emission control requirements. Lithographic printing facilities located outside the severe ozone nonattainment area with 12-month rolling VOC emissions of less than 3 tons must maintain emissions records to show their emissions are less than 3 tons per 12-month rolling period. They must also meet prohibition of sales, handling storage and disposal, and opacity requirements of the rule.

How do I determine the VOC content of materials?

To determine the VOC content of fountain solutions:

1. If diluted prior to use, a calculation that combines EPA Method 24 analytical data for the concentrated materials used to prepare the fountain solution and the proportions in which they are mixed to make the as-applied material. The analysis of the concentrated materials may be performed by the supplier of those materials. Owners or operators may use formulation information provided with the concentrated materials used to prepare the fountain solution, such as the container label, the product data sheet, or the Safety Data Sheet (SDS, formerly Material Safety Data Sheet or MSDS)to document the VOC content of the concentrated material; or

2. If not diluted prior to use, SDS or formulation information from the supplier may

be used; or

3. Analysis by EPA Method 24 of a sample of as-applied fountain solution. To determine the VOC content or partial vapor pressure of cleaning solutions:

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1. Analysis by EPA Method 24 for VOC content or by an appropriate method for VOC composite partial vapor pressure of a sample of the cleaning solution. The analysis may be performed by the supplier of those materials; or

2. Calculation for VOC content that combines EPA Method 24 analytical data for the

concentrated materials used to prepare the cleaning solution and the proportions in which they are mixed to make the as-applied cleaning solution Owners or operators may use formulation information provided with the concentrated materials used to prepare the cleaning solution, such as the container label, the product data sheet, or the SDS sheet to document the VOC content of the concentrated material.

For all other materials (excluding publication rotogravure inks and coatings), EPA Method 24 for VOC content should be used. The analysis may be performed by the material supplier. Owners or operators may use the information provided with the materials, such as the container label, the product data sheet, or the SDS to document the VOC content of the material. For publication rotogravure inks and publication rotogravure coatings, EPA Method 24A should be used to determine VOC content.

What are the VOC content limits for lithographic inks?

Due to the low volatility of the solvents used in lithographic inks, there are no requirements to reformulate inks or use inks with a specific VOC content. This is important, as use of soy or other vegetable oil based inks is not being required. However, certain heatset presses are required to install and operate add-on control devices that will reduce ink oil emissions. For information on VOC content limits for screen printing inks, see the Digital and Screen Question and Answer section.

What are the VOC content limits for fountain solutions?

The VOC content limits for fountain solution apply to facilities located in the severe ozone nonattainment area, or facilities that have actual VOC emissions of three tons or more on a 12-month rolling basis. The limits are based on the type of lithographic printing, use of alcohol, and refrigeration of the fountain solution. Alcohol and alcohol substitute percentage limits are determined based on VOC content by weight in the fountain solution as-applied. These limits are as follows: Heatset - The VOC content in the as-applied fountain solution must meet one of the following conditions:

1.6% alcohol or less, by weight, or

3% alcohol or less, by weight, if the temperature of the fountain solution is maintained below 60°F, or

5% alcohol substitute or less, by weight, if the as-applied fountain solution contains no alcohol.

Non-heatset web - The VOC content of the as-applied fountain solution must be 5% alcohol substitute or less, by weight, and the as-applied fountain solution must contain no alcohol. Sheet-fed -The VOC content of the as-applied fountain solution must be:

5% alcohol or less, by weight, or

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8.5% alcohol or less, by weight, if the temperature of the fountain solution is maintained below 60°F, or

5% alcohol substitute or less, by weight, if the as-applied fountain solution contains no alcohol.

Two types of presses are excluded from the above limitations. They are:

1. Sheet-fed offset lithographic presses with a sheet size of 11 inches by 17 inches or smaller.

2. Any press with a fountain solution reservoir of less than one gallon.

What are the VOC content limits for cleaning solutions?

For facilities located in the Severe ozone nonattainment area, or any facility with 3 tons or more actual VOC emissions on a 12-month rolling basis, the required composition of cleaning solvents (blanket wash, roller wash, metering roller cleaner, plate cleaner, impression cylinder washes, rubber rejuvenators, and other cleaners used for cleaning a press, press parts, or to remove dried ink from areas around the press) are as follows:

70% by weight VOC content, or

VOC composite partial vapor pressure less than or equal to 10 mm Hg at 20°C

The regulation allows for the use of 110 gallons on a 12-month rolling basis of cleaning solutions that do not meet the vapor pressure or VOC content limits listed above, provided appropriate records are maintained.

What are the requirements for control devices for heatset web offset presses?

Heat-set web offset printing presses must meet control equipment requirements if they are located in the severe ozone nonattainment area, have an annual potential to emit 25 tons of VOC or more, or are located at a facility with an annual potential to emit 50 tons of VOC per year or more. Such facilities must have pollution control equipment with a removal efficiency of 90% if the control equipment was installed prior to July 8, 2010, and 95% removal efficiency if it was installed after July 8, 2010. An alternative option to the use of removal efficiencies is provided. A facility may demonstrate that the outlet concentration is less than 20 parts per million volume measured as hexane on a dry basis. Measuring the outlet concentration is an excellent alternative for those presses that use a combined dryer and afterburner or when the printer consistently prints light coverage work that would not generate a high inlet concentration. Some presses are exempt from this control requirement. They include heat-set web presses used for printing books and heat-set web presses with a maximum web width of 22 inches.

Additionally, NYSDEC may allow sources that use natural gas fired afterburners to shut them down from November 1st through March 31st, to conserve natural gas, if the commissioner has determined that doing so will not negatively affect air quality.

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What records can be used to show that heatset web offset presses are below the threshold?

For facilities with heatset web offset operations, the threshold for control equipment is 25 tons of VOC per year per press, or be located at a facility with an annual potential to emit 50 tons of VOC per year or more. Material use can be used to determine annual VOC emissions for this threshold. The following chart is for determining the threshold for control devices for heatset web offset presses. If the facility has both heatset web offset and other types of printing processes, emissions must be calculated.

Threshold, Heatset Only 12-Month Rolling Material Use Threshold

25 tons per year per press

50,000 pounds of ink, cleaning solvent, and fountain solution additives per any one press

50 tons per year per facility

100,000 pounds of ink, cleaning solvent, and fountain solution additives, or any other sources combined facility wide

What testing methods can be used to show that control equipment is meeting the efficiency limits for heatset lithographic presses?

Stack testing of the printing industry presents unique challenges due to variability in production. Due to these difficulties, the affected source may run at typical operating conditions and flow rates compatible with scheduled production during any emission testing. Each test should consist of three separate runs, each lasting at least 60 minutes. If the anticipated outlet VOC concentration of the control device is less than 50 ppmv as carbon, Method 25A is recommended. If using EPA Method 25:

a. EPA Method 25 specifies a minimum probe temperature of 265°F. To prevent condensation, the probe should be heated to at least the gas stream temperature, typically close to 350°F.

If using EPA Method 25A:

a. The outlet readings from a thermal or catalytic oxidizer may be corrected by using Method 18 or 25 to determine non-VOC components (methane and ethane) and subtracting these from the Method 25A result.

b. EPA Method 25A specifies a minimum temperature of 220°F for the

sampling components leading to the analyzer. To prevent condensation when testing heatset web offset presses, the sampling components and flame ionization detector block should be heated to at least the gas stream temperature, typically close to 350°F.

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Several EPA approved methods are recommended for determining other sampling parameters and data. Method 1 or 1A, as appropriate, should be used to select the sampling sites. EPA Method 2, 2A, 2C, or 2D, as appropriate, should be used to determine the velocity and volumetric flow rate of the exhaust stream. EPA Method 3 or 3A, as appropriate, should be used to determine the concentration of O2 and CO2. EPA Method 4 should be used to determine the moisture content. Additionally, capture efficiency testing for heatset dryers is not required if it is demonstrated that pressure in the dryer is negative relative to the surrounding press room and the airflow is into the dryer. The negative dryer pressure may be established during the initial test using an airflow direction indicator, such as a smoke stick or aluminum ribbons, or differential pressure gauge. Continuous dryer air flow monitoring is not required.

How can I obtain additional information?

Additional information on this rule can be obtained by contacting Gary Jones, Assistant Vice President of EHS Affairs, Printing Industries of America by telephone at 412-259-1794 or by email at [email protected]

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Digital and Screen Printing Questions and Answers

What screen printing operations are subject to Part 234?

The rule applies to all screen printers in New York State. The entire rule applies to screen printers with potential VOC emissions of greater than or equal to 50 tons per year (on a 12-month rolling basis), and any screen printer located in the Severe ozone nonattainment area. Certain sections of the rule apply to printers outside of the Severe ozone nonattainment area with actual VOC emissions of less than 3 tons per year, on a 12-month rolling basis. The following activities are exempt from Part 234:

digital printing presses;

screen printing processes that only use conductive ink to produce electronic circuits that permit electric current flow through the printed line or pattern;

screen printing processes that only use sterilization indicating ink to monitor the sterilization of medical instruments, autoclave efficiency, and the thermal processing of foods for the prevention of spoilage;

proof presses; or

the use of specialty ink, coating or adhesive where the facility's total actual annual usage of all specialty ink, coating and adhesive is no more than 55 gallons, on a 12-month rolling basis.

What does Part 234 require for inks?

Facilities outside the severe ozone nonattainment area whose annual PTE VOC emissions are more than 50 tons per year must use inks with no more than:

3.3 pounds of VOC per gallon, as applied, for application to paper, glass, metal, plastic, vinyl, reflective sheeting, textile/imprinted garments or pressure sensitive decals; or

5.0 pounds of VOC per gallon, as applied for serigraphic printing. In lieu of using reformulated inks to meet the control requirements, facilities can opt to use a capture system and control equipment that provides a minimum overall removal efficiency of 80.0 percent.

What requirements to apply to all screen printing operations?

All screen printing operations are required to meet the prohibition on sales, handling and storage of VOC containing containers, recordkeeping requirements, and opacity requirements. (See pages 7 and 8)


Additional information on this rule can be obtained by contacting Marci Kinter, Vice President-Government and Business Information, Specialty Graphic Imaging Association, [email protected].

mailto:[email protected]

18

Flexographic Printing Questions and Answers

What flexographic printers must comply?

Packaging flexographic printing presses located in a severe ozone non-attainment area; have an annual potential to emit VOC of 25 tons per year or more; or is located in a facility that has an annual potential to emit VOC of 50 tons per year or more.

What are the VOC control options for flexographic printers?

There are two compliance options, low VOC content inks or the installation of a capture system with emissions control equipment.

Low VOC ink limits: 0.8 kilograms of VOC per kilogram of solids as applied (0.8 lbs VOC/ lb of solids as

applied); or

0.16 kilograms of VOC per kilogram of ink, coating and adhesive as applied (0.16 lbs VOC/lb of ink as applied); VOC content limits can be met by averaging the VOC content of materials used on a single press (i.e., within a line).

Capture System and Control Equipment requirements: 75.0 percent for a publication rotogravure printing process, unless a higher overall

removal efficiency is required by clause 'e' of this subparagraph;

65.0 percent for a printing process that was first installed prior to March 14,1995, and that is controlled by an add-on capture system and air cleaning equipment that was first installed prior to July 8, 2010;

70.0 percent for a printing process that was first installed prior to March 14,1995, is controlled by an add-on air capture system and air cleaning equipment that was first installed on or after July 8, 2010;

75.0 percent overall removal efficiency for a printing process that was first installed on or after March 14,1995, and that is controlled by an add-on capture system and air cleaning equipment that was first installed prior to July 8, 2010; or

80.0 percent for a printing process that was first installed on or after March 14, 1995, and that is controlled by an add-on capture system and air cleaning equipment that was first installed on or after July 8, 2010.

What control equipment monitoring must be done?

Continuous control equipment monitors for the following parameters must be installed, periodically calibrated, and operated at all times that the associated control equipment is operated:

Combustion zone temperature of all oxidizers;

Inlet temperature at the catalytic oxidizer bed;

Break-through of VOC on a carbon adsorption unit; and

Any other continuous monitoring or recording device required by the Department

What are the stack testing requirements?

Printing processes that use control equipment to comply with the provisions of Part 234 must conduct a stack test of the control equipment to ensure the overall removal efficiency. U.S. EPA approved test methods must be used in conjunction with the

19

protocols and procedures specified in Subpart 202-1, Emissions Testing, Sampling and Analytical Determinations.


Additional information on this rule can be obtained by contacting Doreen M. Monteleone, Director, Flexographic Technical Association, [email protected]

mailto:[email protected]

20

Recordkeeping Forms

21

12 Month Rolling Emissions – Material Usage Option Select one of the following:

- Sheet-fed (768 total gallons) - Non-heatset Web(768 total gallons) - Sheetfed – Non-heatset Web combination (768

total gallons)

- Heatset Web (5,400 total pounds) - Digital (649 total gallons) - Screen (768 total gallons) - Water-based or UV Flexographic (21,600 total

pounds) - Solvent-based Flexographic (5,400 total pounds)

Year: _________

VOC (gal or lb.)

Jan Feb Mar April May June July Aug Sept Oct Nov Dec

Ink

Fountain Solution

Diluents

Cleaning Solution

Miscellaneous

Total Month

12 Month total (current month plus 11 previous months)

Year: _________

VOC (lbs.)

Jan Feb Mar April May June July Aug Sept Oct Nov Dec

Ink

Fountain Solution

Diluents

Cleaning Solution

Miscellaneous

Total Month

12 Month total (current month plus 11 previous months)

22

Fountain Solution Batch VOC Content Form-One Step

Fountain Solution Concentrate Name: ________________________________________ Formula Number: _______________________________________________________ Press(es) Fountain Solution Used on: _______________________________________ Date Use Began: __________________ Date Use Ended: _____________________

Data Inputs Fountain Solution Density (lbs/gal)*: _______________ VOC Content (lbs/gal)**: __________ Ounces of Concentrate Added to Prepare Gallon of As-applied Fountain Solution: _____ * Density can either be found on the Safety Data Sheet or determined by multiplying the specific gravity from the SDS by 8.34 pounds per gallon. ** VOC content can either be found on the Material Safety Data Sheet, conducting USEPA Method 24, or determined by summing the percent composition of each individual VOC and multiplying it by the density. Do not include exempt VOCs. Calculation

1. To find the weight (lbs) of VOC in the concentrate, multiply the ounces of concentrate by the VOC content and divide by 128 oz/gal.

Oz. Concentrate x VOC Content (lbs/gal) 128 oz/gal

2. To find the weight percent of VOC, multiply the result of Step 1 by 128 oz/gal and divide by

the sum of the oz of concentrate plus 128 ounces of water (128 oz per gallon), multiplied by 8.34 lbs/gal of water.

Answer to Step 1x 128 oz/gal (Oz of concentrate + 128 oz) x 8.34 lbs/gal 3. Multiply the answer to Step 3 by 100 to convert from a decimal to a percent. Answer to Step 3 x 100 = % VOC by weight

Answer % VOC by Weight: _______________________

23

Fountain Solution VOC Addition Form

Indicate when any VOC is added to the As-Applied Fountain Solution

Date Quantity in Press

or Fountain

Reservoir (gal)

Weight Percent

VOC Prior to

Addition

Amount

Added In

Ounces

VOC Content

of Additive

(lbs/gal)

New VOC

Concentration of the As-

Applied Fountain

Solution (In Weight

Percent)

Calculation New As-Applied Fountain Solution VOC Concentration:

1. To calculate the weight of VOC in As-applied Fountain Solution before addition, multiply the gallons of fountain solution in the reservoir (second column) by the weight percent VOC in the fountain solution prior to the addition of extra VOC (third column) and 8.34 lbs/gal of water.

Gallons Fountain Solution Reservoir x Weight Percent VOC x 8.34 lb/gal 2. To calculate the weight of VOC in the additive multiply the ounces of additive (fourth column)

by the VOC Content of the additive (fifth column) in lbs/gal and divide this result by 128 oz/gal. Oz. Additive Added x VOC Content (lbs/gal) 128 oz/gal 3. To find the weight percent VOC, add the answers from Step 1 and 2 together and multiply by

128 oz/gal. Divide this by the gallons of fountain solution in the reservoir (second column) multiplied by 128 oz plus the ounces of additive added (third column) multiplied by 8.34 lbs/gal.

(Result of Steps 1+2) x 128 oz/gal [(Gal of Fountain Solution x 128 oz) + oz of Additive Added] x 8.34 lbs/gal

24

4. Multiply the answer to Step 3 by 100 to convert from a decimal to percent. Answer to Step 3 x100=% VOC by weight Answer % VOC by weight____________

25

Fountain Solution Batch VOC Content Form-Two Step

Fountain Solution Concentrate Name: ________________________________________ Formula Number: _______________________________________________________ Fountain Solution Additive Name: ___________________________________________ Formula Number: ________________________________________________________ Press(es) Fountain Solution Used on: _______________________________________ Date Use Began: __________________ Date Use Ended: _____________________ Data Inputs Concentrate Density (lbs/gal)*: _______________ Concentrate VOC Content (lbs/gal)**: __________ Ounces of Concentrate Added to Prepare Gallon of As-applied Fountain Solution: _____ Additive Density (lbs/gal)*: _______________ Additive VOC Content (lbs/gal)**: __________ Ounces of Additive Added to Prepare Gallon of As-applied Fountain Solution: ______ * Density can either be found on the Safety Data Sheet or determined by multiplying the specific gravity from the SDS by 8.34 pounds per gallon. ** VOC content can either be found on the Material Safety Data Sheet, conducting USEPA Method 24, or determined by summing the percent composition of each individual VOC and multiplying it by the density. Do not include exempt VOCs. Calculation

1. To find the weight of VOC in the concentrate, multiply the ounces of concentrate by the VOC content and divide by 128 oz/gal.


2. To find the weight of VOC in the additive, multiply the ounces of concentrate by the VOC

content and divide by 128 oz/gal. Oz. Additive x VOC Content (lbs/gal) 128 oz/gal

26

3. To find the weight percent of VOC, add the answers from Steps 1 and 2 , multiply the result by 128 oz/gal and divide by the sum of the ounces of concentrate plus the ounces of additive plus 128 ounces of water (128 oz per gallon), multiplied by 8.34 lbs/gal of water.

(Answer to Step 1+ Answer to Step 2) x 128 oz/gal (Oz of concentrate+ Oz of additive + 128 (oz water)) x 8.34 lbs/gal 4. Multiply the answer to Step 3 by 100 to convert from a decimal to a percent. Answer to Step 3 x 100= % VOC by weight


27

Fountain Solution VOC Addition Form

Indicate when any VOC is added to the As-Applied Fountain Solution

Date Quantity in

Press or

Fountain

Reservoir

(gal)

Weight

Percent

VOC Prior

to

Addition

Amount

Concentrate

Added In

Ounces

Amount

of

Additive

Added

in

Ounces

VOC

Content of

Concentrate

(lbs/gal)

VOC

Content

of

Additive

(lbs/gal)

New VOC

Concentration

of the As-

Applied

Fountain

Solution (In

Weight

Percent)

Calculation

New As-Applied Fountain Solution VOC Concentration:

1. To calculate the weight of VOC in As-applied Fountain Solution before addition, multiply the gallons of fountain solution in the reservoir (second column) by the weight percent VOC in the fountain solution prior to the addition of extra VOC (third column) and 8.34 lbs/gal of water.

Gallons Fountain Solution Reservoir x Weight Percent VOC x 8.34 lb/gal 2. To calculate the weight of VOC in the concentrate added (if adding concentrate), multiply the

ounces of concentrate (fourth column) by the VOC Content of the concentrate (sixth column) in lbs/gal and divide this result by 128 oz/gal.

Oz. Concentrate Added x VOC Content (lbs/gal) 128 oz/gal

28

3. To calculate the weight of VOC in the additive added (if adding additive) multiply the ounces of additive (fifth column) by the VOC Content of the additive (seventh column) in lbs/gal and divide this result by 128 oz/gal.

Oz. Additive Added x VOC Content (lbs/gal) 128 oz/gal 4. To find the weight percent VOC, add the answers from Steps one, and/or two, and three

together and multiply by 128 oz/gal. Divide this by the gallons of fountain solution in the reservoir (second column) multiplied by 128 oz plus the ounces of concentrate added (fourth column) and/or ounces of additive added (fifth column) multiplied by 8.34 lbs/gal.

(Result of Steps 1+2+3) x 128 oz/gal [(Gal of Fountain Solution x 128 oz) + oz of concentrate + oz of additive] x 8.34 lbs/gal

5. Multiply the answer to Step 4 by 100 to convert from a decimal to percent. Answer to Step 3 x100=% VOC by weight

Answer

% VOC by weight____________

29

Fountain Solution Batch Record

Press ID or Description Date

Prepared Time

Prepared Recipe Number

Batch prepared per recipe

Prepared by:

Yes No

30

Cleaning Solution Batch VOC Content Form

Cleaning Solution Concentrate Name: _______________________________________ Formula Number: _______________________________________________________ Press(es) Cleaning Solution Used on: _______________________________________ Date Use Began: __________________ Date Use Ended: _____________________

Data Inputs Cleaning Solution Density (lbs/gal)*: _______________ VOC Content (lbs/gal)**: __________ Ounces of Concentrate Added to Prepare Gallon of As-applied Cleaning Solution: _____ * Density can either be found on the Safety Data Sheet or determined by multiplying the specific gravity from the SDS by 8.34 pounds per gallon. ** VOC content can either be found on the Material Safety Data Sheet, conducting USEPA Method 24, or determined by summing the percent composition of each individual VOC and multiplying it by the density. Do not include exempt VOCs. Calculation

1. To find the weight (lbs) of VOC in the concentrate, multiply the ounces of concentrate by the VOC content and divide by 128 oz/gal.


2. To find the weight percent of VOC, multiply the result of Step 1 by 128 oz/gal and divide by

the sum of the oz of concentrate plus 128 ounces of water (128 oz per gallon), multiplied by 8.34 lbs/gal of water.

Answer to Step 1x 128 oz/gal (Oz of concentrate + 128 oz) x 8.34 lbs/gal 3. Multiply the answer to Step 3 by 100 to convert from a decimal to a percent. Answer to Step 3 x 100 = % VOC by weight


31

Cleaning Solution VOC Addition Form

Indicate when any VOC is added to the As-Applied Cleaning Solution

Date Quantity in Press

or Cleaning

Reservoir (gal)

Weight Percent

VOC Prior to

Addition

Amount

Added In

Ounces

VOC Content

of Additive

(lbs/gal)

New VOC

Concentration of the As-

Applied Cleaning

Solution (In Weight

Percent)

Calculation

New As-Applied Cleaning Solution VOC Concentration:

1. To calculate the weight of VOC in As-applied Cleaning Solution before addition, multiply the

gallons of cleaning solution in the reservoir (second column) by the weight percent VOC in the

cleaning solution prior to the addition of extra VOC (third column) and 8.34 lbs/gal of water.

Gallons Cleaning Solution Reservoir x Weight Percent VOC x 8.34 lb/gal

2. To calculate the weight of VOC in the additive multiply the ounces of additive (fourth column)

by the VOC Content of the additive (fifth column) in lbs/gal and divide this result by 128 oz/gal.

Oz. Additive Added x VOC Content (lbs/gal)

128 oz/gal

3. To find the weight percent VOC, add the answers from Step 1 and 2 together and multiply by

128 oz/gal. Divide this by the gallons of cleaning solution in the reservoir (second column)

multiplied by 128 oz plus the ounces of additive added (third column) multiplied by 8.34

lbs/gal.

(Result of Steps 1+2) x 128 oz/gal

[(Gal of Cleaning Solution x 128 oz) + oz of Additive Added] x 8.34 lbs/gal

4. Multiply the answer to Step 3 by 100 to convert from a decimal to percent.

Answer to Step 3 x100 = % VOC by weight

Answer

% VOC by weight____________

32

Cleaning Solution Batch Record

Press ID or Description Date Prepared

Time Prepared

Recipe Number

Batch prepared per recipe

Prepared by:

Yes No

33

Cleaning Solution Usage Record

Year: _______

Month Cleaning Solution Exceeding

Allowable Limit (gal)

January

February

March

April

May

June

July

August

September

October

November

December

Total (Not to Exceed 110 gallons)

34

Appendix 1 Determining VOC Emissions From Printing Operations (Applicable to All Processes)

Step 1: Assemble list of products currently used, purchase records, SDSs, and other information such as VOC/HAP content test data. Be sure to include

Blanket wash/roller wash/press wash/type wash

Parts cleaner (solvent)

Inks

Diluents

Varnishes

Coatings

Cleaning solvents, including screen reclamation chemicals

Adhesives

Alcohol or alcohol substitutes (including fountain solution concentrate)

Laminates

Any other VOC/HAP -containing products you use in excess of 25 gal/product/year, such as film cleaner

Step 2: Complete worksheets for VOC and HAP emissions. Either complete one VOC

and HAP emissions worksheet for the year to calculate annual emissions or one VOC and HAP emissions worksheet for each month or total all previous twelve months to determine annual emissions.

For the VOC Emissions Calculation Worksheet, the data required for Columns A, B, and C is general information that can be obtained from either purchase or use records, Safety Data Sheets (SDSs, formerly Material Safety Data Sheets or MSDSs), or your supplier. It may be necessary to contact the supplier for additional information. Column D is the quantity of VOC used as calculated by multiplying Column B times Column C. The emission factors that are appropriate for specific type of printing process are included in Column E. Column F represents the VOC emissions in pounds and is the result of multiplying Column D by Column E. Column G represents the VOC emissions in tons, which is the result of dividing Column F by 2000 (i.e., the number of pounds in a ton).

35

VOC Emission Calculation Worksheet

Column A Column B Column C Column D Column E Column F Column G

Product Name Company (optional)

Usage (Gal Or Lbs)

X

VOC Content Lbs/Gal

Or Lbs/Lb (wt%)

=

VOCs (Lbs.)

X

Emission Factor (See

Below)

Total VOC Emissions

(Lbs)

2000 lbs.

Per Ton

=

Total VOC Emissions

(Tons)

X

=

X

2000

=

X

=

X

2000

=

X

=

X

2000

=

X

=

X

2000

=

X

=

X

2000

=

X

=

X

2000

=

X

=

X

2000

=

X

=

X

2000

=

X

=

X

2000

=

X

=

X

2000

=

Total For All Products _________ _____________ ________________

36

Col. A: Enter product name.

Col. B: Enter total amount used either per month or for the year, either in gallons or for inks, coatings, adhesives and other materials purchased by weight, enter pounds (lbs.). To make the calculations easier, the purchase amount can be used. However, if the calculations indicate that you exceed a threshold, then it is advised to “sharpen your pencil” by determining the exact amount of material used. This is accomplished by adding the beginning inventory to the yearly purchase amount and subtracting the ending inventory and any waste shipped off-site.

Col. C: From Section III (Physical and Chemical Properties), enter value for "VOC content”. Ideally, the results should be based on a "Method 24" test. Do not include exempt VOCs such as Methylene Chloride, 1,1,1 Trichloroethane, Methyl Acetate, Acetone, or t-Butyl Acetate. For ink VOC content, you can determine the VOC emissions for each ink or use the highest VOC containing ink in each category (e.g., sheetfed, heatset, web, and nonheatset web).

If VOC content is provided in pounds of VOC per gallon, the quantity in Column B should be in gallons. If VOC content is provided in weight percent (wt% or pound VOC per pound material), the quantity in Column B should be in pounds. If weight percent of ingredients is given and the quantity in Column B is in gallons, total the weight percentage of the ingredients and multiply by the density of the material. The density can be determined by multiplying the specific gravity (found in Section III of the SDS) by 8.33 lbs./gal.

If no value is given and/or cannot be determined, contact your supplier and request the information.

Col. D: Multiply Column B by Column C to obtain value for VOCs in each product and write the answer in Column D.

Col. E: Multiply Column D by the emission factor in Column E and write the answer in Column F.

Col. G: Divide Column F by 2000 (lbs./ton) to convert to tons per year and write answer in Column G.

37

Emission Factors - Use The Following Emission Factors

Emission Factors For Sheetfed and Nonheatset Web Offset Lithographic Printing Operations Ink 0.05*

Fountain Solution Concentrate 1.00

Fountain Solution Additive 1.00

Cleaning Solution 0.50**

Automatic Blanket Wash 1.00

Adhesives 1.00

UV Coatings 1.00

Water-based Coatings 1.00

Conventional Varnish 0.05***

*Conventional Nonheatset Offset Lithographic Inks Have A 95% VOC Retention Factor.

**Only If VOC Composite Vapor Pressure Of Cleaning Solution Is less than 10 mm Hg At 20 oC (68oF) and Used Shop Towels Kept In Closed Containers. Otherwise, use 1.00.

*** Conventional Varnish Is Virtually Identical To Conventional Offset Lithographic Inks.

Emission Factors For Heatset Web Offset Lithographic Printing Operations Without Controls

Ink 0.80*

Fountain Solution Concentrate 1.00

Fountain Solution Additive 1.00


Automatic Blanket Wash 1.00

Adhesives 1.00

UV Coatings 1.00


Conventional Coatings Before Dryer 0.80***

Conventional Coatings After Dryer 0.05****

*Conventional (petroleum-based) Heatset Offset Lithographic Inks Have a 20% Retention Factor and 100% Capture efficiency Is Assumed If Airflow Into Dryer Is Demonstrated To Be Negative. Non-conventional inks must use an emission factor of 1.00.

**Only If VOC Composite Vapor Pressure Of Cleaning Solution Is less than 10 mm Hg At 20 oC (68oF) and Used Shop Towels Kept In Closed Containers. Otherwise, use 1.00.

*** Conventional Varnish Is Virtually Identical To Conventional Offset Lithographic Inks.

Emission Factors For Screen Printing Operations Ink 1.00

Cleaning Solution 0.50*

Adhesives 1.00

UV Coatings 1.00


Solvent-based Coatings 1.00

*Only If VOC Composite Vapor Pressure Of Cleaning Solution Is less than 10 mm Hg At 20oC (68oF) and Used Shop Towels Kept In Closed Containers. Otherwise, use 1.00

38

Emission Factors For Digital Printing Operations

Ink 1.00

Cleaning Solution 0.50*

Adhesives 1.00

UV Coatings 1.00



*Only If VOC Composite Vapor Pressure Of Cleaning Solution Is less than 10 mm Hg At 20oC (68oF) and Used Shop Towels Kept In Closed Containers. Otherwise, use 1.00.

Emission Factors For Flexographic and Rotogravure Printing

Operations Without Controls

Ink 1.00

Diluents 1.00*


Adhesives 1.00

UV Coatings 1.00



*Diluents Includes Ink, Coating, and Adhesive Dilution Solvents. **Only If VOC Composite Vapor Pressure Of Cleaning Solution Is less than 10 mm Hg At 20oC (68oF) and Used Shop Towels Kept In Closed Containers. Otherwise, use 1.00.

39

Appendix 2 Determining VOC Emissions From Heatset Web Offset Lithographic Printing Operations

Background

The two most important aspects involved in air pollution control regulations for the printer is knowing how much air pollution is being released from their operation and what specific air pollution permit and possible control regulations need to be met. The first step in determining what permit or possible control requirements apply is to determine both the actual and potential emissions of air pollutants. The two principal pollutants of concern are volatile organic compounds (VOC) and hazardous air pollutants (HAPs). VOCs are those chemicals that will evaporate and lead to the formation of ozone in the lower atmosphere. There is a small list of chemicals that are considered exempt from the definition of VOC and the ones possibly found in offset printing include acetone, methyl acetate, and methylene chloride. For more information see PNEAC fact sheet “What are VOCs and do printing related material contain them?” (http://www.pneac.org/sheets/all/vocs.cfm ). There is a list of 188 Hazardous Air Pollutants (http://www.epa.gov/ttn/atw/188polls.html) that are subject to regulation. Calculations of HAP emissions will not be discussed in this fact sheet, please contact PNEAC or Printing Industries of America for more information on HAP emissions. The principal reason why a printer needs to know their VOC emissions is because of construction and/or operating permits and emission inventory reporting requirements. Many states and local air pollution control agencies have instituted a system of permitting that requires a source of air pollution to obtain either a permit to construct or a permit to operate and in some cases a single construction and operation permit. Permits can be viewed as a contract between the printer and the permitting authority allowing the printer to pollute at a given rate. If permits are required, they are required to be in hand prior to accepting delivery of a new press, modifying an existing press such as adding a coating unit, or actually running the press. The need to obtain an air pollution control permit depends on the threshold that has been set by the state and/or local air pollution control agency responsible for your area. The thresholds can be based on several different parameters. Some state and local agencies use an actual emission rate or amount while others use a potential emission rate or amount threshold. Some agencies use actual material consumption rates to determine if permits are required. Permits can be required for a single piece of equipment or for an entire facility. In addition, if the emissions exceed certain thresholds, then the use of an afterburner, either a stand-alone unit or one that is integrated into the dryer could be required. The permitting and control thresholds can vary quite dramatically and it is important to know what the permit threshold is for your particular location. Even if a printer is not required to obtain an air pollution control permit, good environmental management practice dictates that emission calculations should be performed at lease annually, when a new piece of equipment that emits air pollution such as a press is purchased, or when an existing piece of equipment emitting air pollution is modified such as adding a coating unit on a press. In order to verify that a permit is not required, some state and local air permitting authorities require printers to calculate the emissions. For more information see PNEAC fact sheet “Understanding Air Pollution Permits” (http://www.pneac.org/sheets/all/airpollutionpermits.cfm ).

http://www.pneac.org/sheets/all/vocs.cfm

http://www.epa.gov/ttn/atw/188polls.html

http://www.pneac.org/sheets/all/airpollutionpermits.cfm

40

VOC Emissions from Heatset Web Offset Lithography

The majority of VOCs emitted from the heatset web process are emitted from the dryer due to the evaporation of the ink oil during the drying process. The remainder is emitted through general pressroom ventilation air. Since not all of the emissions are released from a definitive point, the direct measurement of all emissions (or emissions over time for an emission rate) is difficult, if not impractical. Therefore, emissions have to be calculated from material use and material content information. This approach is quite acceptable to permitting authorities. In fact, this same approach is used for printing and coating operations (e.g., flexographic printing or rotogravure printing) where most or all of the VOCs are emitted through process stacks or vents. The materials utilized in heatset web offset lithographic printing process that contain VOCs are the fountain solution with isopropyl alcohol or isopropyl alcohol substitutes/extenders, cleaning solvents used to clean ink and other press components, ink oils, and other materials that are applied inline such as coatings and adhesives. Other sources of emissions in a heatset web offset lithographic printing operation include parts washers, binding and finishing equipment, and some prepress equipment. While these sources are generally not significant, their emissions need to be included in a total facility emission inventory. In some instances, such as an ink jetting operation using solvent-based inks, some of the other sources of VOC emissions may have to be permitted as the emissions could exceed the specified threshold. Determining VOC Emissions From Heatset Presses VOC emissions from materials used in heatset web printing operations are a function of consumption multiplied by the VOC content and then multiplied any applicable release factor or carry over/capture efficiency. There are several important release and carry over factors that should be used in determining emissions from input materials. These factors allow the printer to show that not all of the VOC contained in a product is actually emitted. These factors have been reviewed and approved by USEPA and are based on the physical characteristics, how the materials are used and managed in the process, and have been supported with testing. In determining VOC emissions from heatset web inks printed on paper, a retention factor of 20% has been accepted by USEPA. The 20% retention factor equates into an 80% release factor and was established a result of ink oil retention studies conducted by the printing industry. In addition, the capture/carry over efficiency for the ink oil or VOC emissions is 100% as the ink oils are only released in the dryer. The 80% retention factor and 100% capture efficiency are included in several key USEPA documents including the 1993 draft Control Techniques Guideline for Offset Lithography and the final 2006 Control Techniques Guideline for Offset Lithographic and Letterpress Printing (EPA 453/R-06-002). These references have been widely accepted by many state/local air permitting authorities as authoritative. In addition, the ink release and capture efficiency factor can also to be used for any conventional varnishes that would be applied as an overprint coating as they are essentially printing inks without pigments. The carry over/capture efficiency for fountain solutions containing alcohol substitutes has been established at 70%. This means that 30% of the VOC in fountain solution is released into the pressroom air and not controlled. The carry over/capture efficiency for automatic blanket washes that have a vapor pressure less than 10 mm Hg at 20oC (68oF) is 40%, which means 60% of the solvent is emitted uncontrolled.

41

Another important retention factor for determining VOC emissions is the one for low vapor pressure cleaning solutions used in manual cleaning and in conjunction with shop towels. USEPA has established a 50% shop towel retention factor for cleaning solutions with VOC composite vapor pressures less than 10 mm Hg at 20oC (68oF). The shop towels need to be kept in a closed container when not being used. This retention factor was included in the Alternative Control Techniques Guideline for Offset Lithography, released in June 1994 (EPA 453/R-94-054) and the 2006 Control Techniques Guideline for Offset Lithographic and Letterpress Printing (EPA 453/R-06-002). The ACT was released to supplement the draft CTG and provides significant revisions to some of the elements contained in the CTG. No retention or release factors have been established for VOCs used in water-based or UV-cured coatings, adhesives, or other materials used in heatset web lithographic printing operations. Therefore, all of the VOCs in these materials would all be considered released into the atmosphere. The only “credit” or reduction in for VOC not released would be for the VOC contained in discarded wastes. In some instances, state and local permitting agencies will require proof that of the volume discarded as well as the VOC content that is in the waste.

42

VOC Emission Calculation Worksheet For Heatset Web Offset Lithographic Printing

The following worksheet presents both the formulas and assumptions that can be used to determine both actual and potential VOC emissions from heatset web offset lithographic printing operations. The assumptions on retention and release factors are taken directly from principally three EPA documents entitled 2006 Control Techniques Guideline for Offset Lithographic and Letterpress Printing (EPA 453/R-06-002) ), the November 1993 draft Control Techniques Guideline for Offset Lithography, and the Alternative Control Techniques Guideline issued in June 1994 (EPA 453/R-94-054).

Material Usage1 Units VOC Content2

Units Release Factor3

Control Factor4

VOC Emissions5

Ink pounds/yr % by weight

Fountain Solution (FS) Concentrate

gallons/yr lbs VOC/gal

FS Additive gallons/yr lbs VOC/gal

Cleaning Solution




Coatings and Conventional Varnishes

pounds/yr % by weight


Misc. gallons/yr lbs VOC/gal

Total VOC Emissions

1. Usage is defined as purchase amount minus change in standing inventory, minus the amount that

is discarded. 2. List either percent VOC content (by weight) or pounds of VOC per gallon for the product.

a. The VOC content information may be provided by the supplier via the SDS, USEPA Method 24 analysis, or summing % content of all VOCs and multiplying it by the density to calculate VOC. If density is unknown, multiply specific gravity from SDS by 8.33 lbs/gal.

b. Do not include exempt VOCs such as methylene chloride, 1,1,1-trichloroethane, acetone, methyl

acetate, or T-butyl acetate (see http://www.dec.ny.gov/regs/13427.html for the definition of a VOC).

c. For Ink VOC content, the applicant can determine the VOC emissions for each ink used or

use the highest VOC containing ink in each category. 3. Use the following VOC release factor:

http://www.dec.ny.gov/regs/13427.html

43

Material Release Factor Ink 0.8 Fountain Solution Concentrate 1.0 Fountain Solution Additive 1.0 Automatic Blanket Wash 1.0 Cleaning Solution (Manual) 0.5*

Coating UV 1.0 Water-Based 1.0 Conventional Varnish 0.8

* The VOC composite vapor pressure of the cleaning solution must be less than 10 mm Hg at

20oC (68oF). 4. The control factor is the combination of the carry over factor and the destruction/removal

efficiency of any control device used to oxidize or remove VOCs from the dryer exhaust. Common control devices are afterburners that are either stand alone or integrated into the dryer. The control factor is represents the amount of VOC in a decimal format that is not destroyed, which is the amount of VOC that is not captured or destroyed by a control device. Use the following VOC carry over factor:

Material Carry Over Factor Ink 1.0 Fountain Solution Concentrate 0.7 Fountain Solution Additive 0.7 Automatic Blanket Wash 0.4 Cleaning Solution (Manual) N/A

Coating UV N/A Water-Based N/A Conventional Varnish 1.0

For example, the control factor for fountain solution with alcohol substitutes used on a press with an afterburner with a destruction efficiency or 95% is [1-(0.7 x 0.95)] or 0.335. This represents the fraction of the material that is not captured and oxidized or destroyed. If there is no afterburner, then the use of the control factor should not be used.

5. The actual VOC emissions are determined by multiplying the Usage, VOC Content, and Release

Factor, and Control Factor together. The total VOC emissions are the result of adding all of the individual VOC emission determinations together.

To convert the total pounds per year into tons per year, divide the total pounds by 2,000 because there are 2,000 pounds in one ton.

44

Example of VOC Emission Calculation For Heatset Web Press With 95% Efficient Afterburner Material Annual Usage VOC Content Heatset Ink, Process 400,000 pounds 40% by weight Fountain Solution Concentrate 1,200 gallons 1.0 pound/gallon Fountain Solution Additive 800 gallons 6.7 pounds/gallon Cleaning Solution - Blanket Wash 2,200 gallons 6.24 pounds/gallon Cleaning Solution - Roller Wash 400 gallons 5.9 pounds/gallon Automatic Blanket Wash 2,000 gallons 7.0 pounds/gallon Coating - Conventional 6,000 pounds 45% by weight Misc – Plate Cleaner 8 gallons 2.5 pounds/gallon

Material Usage Units VOC Content

Units Release Factor

Control Factor1

VOC Emissions

Ink 400,000 pounds/Yr 0.40 % by weight 0.8 0.052 6,400


1,200 gallons/Yr 1.0 lbs VOC/gal 1.0 0.3353 402

FS Additive 800 gallons/Yr 6.7 lbs VOC/gal 1.0 0.3353 1,796

Blanket Wash (Manual)

1,200 gallons/Yr 6.24 lbs VOC/gal 0.5 14 3,744

Roller Wash 300 gallons/Yr 5.9 lbs VOC/gal 0.5 14 885

Blanket Wash (Auto)

2,000 gallons/Yr 7.0 lbs VOC/gal 1.0 0.625 8,680

Coating –Conventional

6,000 pounds/Yr 0.45 % by weight 0.8 0.052 108

Misc. 8 gallons/Yr 2.5 lbs VOC/gal 1.0 14 20

Total VOC Emissions

22,032 lbs/yr 11.02 tons/yr

1. Control Factor – [1-(release factor X destruction efficiency of add-on control device)] 2. Ink control factor - [1-(1 x 0.95)] = 0.05 (conventional coating is ink without pigment) 3. Fountain Solution control factor for alcohol substitutes – [1-(0.7 x 0.95)] = 0.335 4. Blanket wash, roller wash, and misc control factor – [1 – (0 x 0.95)] = 1 (not used when dryer is

running) 5. Automatic blanket wash control factor for low vapor pressures (less than 10 mm Hg) – [1-(0.6 x

0.95)] = 0.62

45

References 1. Control Techniques Guideline for Offset Lithographic and Letterpress Printing (EPA 453/R-06-002) September 2006 is available at http://www.epa.gov/glo/SIPToolkit/ctg_act/200609_voc_epa453_r-06-002_litho_letterpress_printing.pdf 2. Draft Control of Volatile Organic Compound Emissions from Offset Lithographic Printing, September 1993 is available at www.epa.gov/ttn/atw/print/printpg.html under Closely Related Rules, Policies or Program Guidance 3. Alternative Control Techniques Document: Offset Lithographic Printing (EPA-453/R-94-054), June 1994, is available at www.epa.gov/ttn/atw/print/printpg.html under Closely Related Rules, Policies or Program Guidance 4. Printers’ Simplified Total Environmental Partnership (PrintSTEP), August 2006 Workbooks are available through www.epa.gov/compliance/assistance/sectors/printstep.html under PrintSTEP Products. 5. Potential to Emit (PTE) Guidance for Specific Source Categories, April 1998, Memo and Attached Technical Support Document are available at www.epa.gov/ttn/oarpg/t5pgm.html - scroll down to item dated 4-14-98. 6. EIIP Volume III, Chapter 7 on Graphic Arts, November 2006 is available at www.epa.gov/ttn/chief/eiip/techreport/volume03/iii07.pdf

http://www.epa.gov/glo/SIPToolkit/ctg_act/200609_voc_epa453_r-06-002_litho_letterpress_printing.pdf


46

Appendix 3 Determining VOC Emissions From Non-heatset Web Offset Lithographic Printing Operations

Background

The two most important aspects involved in air pollution control regulations for the printer is knowing how much air pollution is being released from their operation and what specific air pollution permit and possible control regulations need to be met. The first step in determining what permit or possible control requirements apply is to determine both the actual and potential emissions of air pollutants. The two principal pollutants of concern are volatile organic compounds (VOC) and hazardous air pollutants (HAPs). VOCs are those chemicals that will evaporate and lead to the formation of ozone in the lower atmosphere. There is a small list of chemicals that are considered exempt from the definition of VOC and the ones possibly found in offset printing include acetone, methyl acetate, and methylene chloride. For more information see PNEAC fact sheet “What are VOCs and do printing related material contain them?” (http://www.pneac.org/sheets/all/vocs.cfm ). There is a list of 188 Hazardous Air Pollutants (http://www.epa.gov/ttn/atw/188polls.html) that are subject to regulation. Calculations of HAP emissions will not be discussed in this fact sheet, please contact PNEAC or Printing Industries of America for more information on HAP emissions. The principal reason why a printer needs to know their VOC emissions is because of construction and/or operating permits and emission inventory reporting requirements. Many states and local air pollution control agencies have instituted a system of permitting that requires a source of air pollution to obtain either a permit to construct or operate. Permits can be viewed as a contract between the printer and the permitting authority allowing the printer to pollute at a given rate. If permits are required, they are required to be in hand prior to accepting delivery of a new press, modifying an existing press such as adding a coating unit, or actually running the press. The need to obtain an air pollution control permit depends on the threshold that has been set by the state and/or local air pollution control agency responsible for your area. The thresholds can be based on several different parameters. Some state and local agencies use an actual emission rate or amount while others use a potential emission rate or amount threshold. Some agencies use actual material consumption rates to determine if permits are required. Permits can be required for a single piece of equipment or for an entire facility. The permitting thresholds can vary quite dramatically and it is important to know what the permit threshold is for your particular location. Even if a printer is not required to obtain an air pollution control permit, good environmental management practice dictates that emission calculations should be performed at lease annually, when a new piece of equipment that emits air pollution such as a press is purchased, or when an existing piece of equipment emitting air pollution is modified such as adding a coating unit on a press. In order to verify that a permit is not required, some state and local air permitting authorities require printers to calculate the emissions.

VOC Emissions From Non-heatset Web Offset Lithography

The majority of VOCs emitted from the non-heatset web process are emitted through general pressroom ventilation air rather than through process stacks or vents. As a result of the lack of a definitive point of emissions from the non-heatset web press, the direct measurement of emissions (or



47

emission rates) is difficult, if not impractical. Therefore, emissions have to be calculated from material use and material content information. This approach is quite acceptable to permitting authorities. In fact, this same approach is used for printing and coating operations (e.g., flexographic printing or rotogravure printing) where most or all of the VOCs are emitted through process stacks or vents. The materials utilized in non-heatset web offset lithographic printing process that contain VOCs are the fountain solution with isopropyl alcohol or isopropyl alcohol substitutes/extenders, cleaning solvents used to clean ink and other press components, ink oils, coatings, and adhesives. Other sources of emissions in a non-heatset web offset lithographic printing operation include parts washers, binding and finishing equipment, and some prepress equipment. While these sources are generally not significant, their emissions need to be included in a total facility emission inventory. In some instances, such as an ink jetting operation using solvent-based inks, some of the other sources of VOC emissions may have to be permitted as the emissions could exceed the specified threshold. VOC emissions from materials used in non-heatset web printing operations are a function of consumption multiplied by the VOC content and any applicable release factor. There are two extremely important release factors that should be used in determining emissions from input materials. These retention factors allow for a reduction in VOC emissions because it has been established with USEPA that due to their physical characteristics and how certain materials are used and handled, they are not released into the air. For determining VOC emissions from non-heatset web inks printed on paper, a retention factor of 95% has been accepted by USEPA. The 95% retention factor equates into a 5% release factor and was established a result of ink oil retention studies conducted by the printing industry. The 95% retention factor was included in a document entitled Control Techniques Guideline for Offset Lithography, which was released in draft form in November 1993 and in final form in 2006 as the Control Techniques Guideline for Offset Lithographic and Letterpress Printing (EPA 453/R-06-002). This reference has been widely accepted by many state/local air permitting authorities as authoritative. This retention factor is also to be used for any varnishes that would be applied as an overprint coating as they are essentially printing inks without pigments. The other important retention factor for determining VOC emissions is the one for low vapor pressure cleaning solutions used in conjunction with shop towels. USEPA has established a 50% shop towel retention factor for cleaning solutions with VOC composite vapor pressures less than 10 mm Hg at 20oC (68oF). The shop towels need to be kept in a closed container when not being used. This retention factor was included in the Alternative Control Techniques Guideline for Offset Lithography, released in June 1994 (EPA 453/R-94-054) and the 2006 Control Techniques Guideline for Offset Lithographic and Letterpress Printing (EPA 453/R-06-002). The ACT was released to supplement the draft CTG and provides significant revisions to some of the elements contained in the CTG. No retention or release factors have been established for VOCs used in fountain solutions, coatings, adhesives, or other materials used in non-heatset web lithographic printing operations. Therefore, all of the VOCs in these materials would all be released into the atmosphere. The emissions from automatic blanket washers would all be considered released into the atmosphere. The only “credit” for VOC not released would be for that contained in discarded wastes.

48

VOC Emission Calculation Worksheet For Non-heatset Web Offset Lithographic Printing

The following worksheet presents both the formulas and assumptions that can be used to determine both actual and potential VOC emissions from non-heatset web offset lithographic printing operations. The assumptions on retention and release factors are taken directly from three EPA documents entitled Control Techniques Guideline for Offset Lithography issued as a draft in November 1993, the final 2006 Control Techniques Guideline for Offset Lithographic and Letterpress Printing (EPA 453/R-06-002), and the Alternative Control Techniques Guideline issued in June 1994 (EPA 453/R-94-054).



VOC Emissions4

Ink Pounds/Yr % by Weight


Gallons/Yr Lbs VOC/Gal

FS Additive Gallons/Yr Lbs VOC/Gal

Cleaning Solution





Pounds/Yr % by Weight


Misc. Gallons/Yr Lbs VOC/Gal

Total VOC Emissions




b. Do not include exempt VOCs - Methylene Chloride, 1,1,1-Trichloroethane, Acetone, or Methyl

Acetate (see http://www.dec.ny.gov/regs/13427.html for the definition of a VOC).

49

c. For Ink VOC content, the applicant can determine the VOC emissions for each ink used or use the highest VOC containing ink in each category.

3. Use the following for the appropriate VOC release factor:

Ink 0.05 Fountain Solution Concentrate 1.0 Fountain Solution Additive 1.0 Cleaning Solution 0.5* Coating

UV 1.0 Water-Based 1.0 Conventional 0.05

* The VOC composite vapor pressure of the cleaning solution must be less than 10 mm Hg at 20oC (68oF).


Factors together. The total VOC emissions are the result of adding all of the individual VOC emission determinations together. To convert the total pounds per year into tons per year, divide the total pounds by 2,000 because there are 2,000 pounds in one ton.

50

Example of VOC Emission Calculation Using Above Approach and Worksheet

Material Annual Usage VOC Content Non-heatset Web Ink, Process 25,200 pounds 35% by weight Fountain Solution Concentrate 420 gallons 0.717 pounds/gallon Fountain Solution Additive 120 gallons 6.7 pounds/gallon Cleaning Solution - Blanket Wash 1,200 gallons 6.24 pounds/gallon Cleaning Solution - Roller Wash 300 gallons 5.9 pounds/gallon Coating - UV 180 gallons 8.5 pounds/gallon Coating - Conventional 6,000 pounds 35% by weight

Material1 Usage2 Units VOC Content3


VOC Emissions5

Ink 25,200 Pounds/Yr 0.35 % by Weight 0.05 441


420 Gallons/Yr 0.717 Lbs VOC/Gal 1.0 301.14

FS Additive 120 Gallons/Yr 6.7 Lbs VOC/Gal 1.0 804

Cleaning Solution

1,200 Gallons/Yr 6.24 Lbs VOC/Gal 0.5 3,744

300 Gallons/Yr 5.9 Lbs VOC/Gal 0.5 885


Coatings – UV 180 Pounds/Yr 8.5 % by Weight 1.0 15.3


6,000 Gallons/Yr 0.35 Lbs VOC/Gal 0.05 105



Total VOC Emissions


51

References 1. Control Techniques Guideline for Offset Lithographic and Letterpress Printing (EPA 453/R-06-002) September 2006 is available at http://www.epa.gov/glo/SIPToolkit/ctg_act/200609_voc_epa453_r-06-002_litho_letterpress_printing.pdf 2. Draft Control of Volatile Organic Compound Emissions from Offset Lithographic Printing, September 1993 is available at www.epa.gov/ttn/atw/print/printpg.html under Closely Related Rules, Policies or Program Guidance 3. Alternative Control Techniques Document: Offset Lithographic Printing (EPA-453/R-94-054), June 1994, is available at www.epa.gov/ttn/atw/print/printpg.html under Closely Related Rules, Policies or Program Guidance 4. Printers’ Simplified Total Environmental Partnership (PrintSTEP), August 2006 Workbooks are available through www.epa.gov/compliance/assistance/sectors/printstep.html under PrintSTEP Products. 5. Potential to Emit (PTE) Guidance for Specific Source Categories, April 1998, Memo and Attached Technical Support Document are available at www.epa.gov/ttn/oarpg/t5pgm.html - scroll down to item dated 4-14-98. 6. EIIP Volume III, Chapter 7 on Graphic Arts, November 2006 is available at www.epa.gov/ttn/chief/eiip/techreport/volume03/iii07.pdf



52

Appendix 4 Determining VOC Emissions From Sheetfed Offset

Lithographic Printing Operations

Background

The two most important aspects involved in air pollution control regulations for the printer is knowing how much air pollution is being released from their operation and what specific air pollution permit and possible control regulations need to be met. The first step in determining what permit or possible control requirements apply is to determine both the actual and potential emissions of air pollutants. The two principal pollutants of concern are volatile organic compounds (VOC) and hazardous air pollutants (HAPs). VOCs are those chemicals that will evaporate and lead to the formation of ozone in the lower atmosphere. There is a small list of chemicals that are considered exempt from the definition of VOC and the ones possibly found in offset printing include acetone, methyl acetate, and methylene chloride. For more information see PNEAC fact sheet “What are VOCs and do printing related material contain them?” (http://www.pneac.org/sheets/all/vocs.cfm ). There is a list of 188 Hazardous Air Pollutants (http://www.epa.gov/ttn/atw/188polls.html) that are subject to regulation. Calculations of HAP emissions will not be discussed in this fact sheet, please contact PNEAC or Printing Industries of America for more information on HAP emissions. The principal reason why a printer needs to know their VOC emissions is because of construction and/or operating permits and emission inventory reporting requirements. Many states and local air pollution control agencies have instituted a system of permitting that requires a source of air pollution to obtain either a permit to construct or operate. Permits can be viewed as a contract between the printer and the permitting authority allowing the printer to pollute at a given rate. If permits are required, they are required to be in hand prior to accepting delivery of a new press, modifying an existing press such as adding a coating unit, or actually running the press. The need to obtain an air pollution control permit depends on the threshold that has been set by the state and/or local air pollution control agency responsible for your area. The thresholds can be based on several different parameters. Some state and local agencies use an actual emission rate or amount while others use a potential emission rate or amount threshold. Some agencies use actual material consumption rates to determine if permits are required. Permits can be required for a single piece of equipment or for an entire facility. The permitting thresholds can vary quite dramatically and it is important to know what the permit threshold is for your particular location. Even if a printer is not required to obtain an air pollution control permit, good environmental management practice dictates that emission calculations should be performed at lease annually, when a new piece of equipment that emits air pollution such as a press is purchased, or when an existing piece of equipment emitting air pollution is modified such as adding a coating unit on a press. In order to verify that a permit is not required, some state and local air permitting authorities require printers to calculate the emissions. For more information see PNEAC fact sheet “Understanding Air Pollution Permits” (http://www.pneac.org/sheets/all/airpollutionpermits.cfm ).

VOC Emissions From Sheetfed Offset Lithography

The majority of VOCs emitted from the sheetfed process are emitted through general pressroom ventilation air rather than through process stacks or vents. As a result of the lack of a definitive point



http://www.pneac.org/sheets/all/airpollutionpermits.cfm

53

of emissions from the sheetfed press, the direct measurement of emissions (or emission rates) is difficult, if not impractical. Therefore, emissions have to be calculated from material use and material content information. This approach is quite acceptable to permitting authorities. In fact, this same approach is used for printing and coating operations (e.g., flexographic printing or rotogravure printing) where most or all of the VOCs are emitted through process stacks or vents. The materials utilized in sheetfed offset lithographic printing process that contain VOCs are the fountain solution with isopropyl alcohol or isopropyl alcohol substitutes/extenders, cleaning solvents used to clean ink and other press components, ink oils, coatings, and adhesives. Other sources of emissions in a sheetfed offset lithographic printing operation include parts washers, binding and finishing equipment, and some prepress equipment. While these sources are generally not significant, their emissions need to be included in a total facility emission inventory. In some instances, such as an ink jetting operation using solvent-based inks, some of the other sources of VOC emissions may have to be permitted as the emissions could exceed the specified threshold. VOC emissions from materials used in sheetfed printing operations are a function of consumption multiplied by the VOC content and any applicable release factor. There are two extremely important release factors that should be used in determining emissions from input materials. These retention factors allow for a reduction in VOC emissions because it has been established with USEPA that due to their physical characteristics and how certain materials are used and handled, they are not released into the air. For determining VOC emissions from sheetfed inks printed on paper, a retention factor of 95% has been accepted by USEPA. The 95% retention factor equates into a 5% release factor and was established a result of ink oil retention studies conducted by the printing industry. The 95% retention factor was included in a document entitled Control Techniques Guideline for Offset Lithography, which was released in draft form in November 1993 and final form in 2006 as the Control Techniques Guideline for Offset Lithographic and Letterpress Printing (EPA 453/R-06-002). This reference has been widely accepted by many state/local air permitting authorities as authoritative. This retention factor is also to be used for any varnishes that would be applied as an overprint coating as they are essentially printing inks without pigments. The other important retention factor for determining VOC emissions is the one for low vapor pressure cleaning solutions used in conjunction with shop towels. USEPA has established a 50% shop towel retention factor for cleaning solutions with VOC composite vapor pressures less than 10 mm Hg at 20oC (68oF). The shop towels need to be kept in a closed container when not being used. This retention factor was included in the Alternative Control Techniques Guideline for Offset Lithography, released in June 1994 (EPA 453/R-94-054) and the 2006 Control Techniques Guideline for Offset Lithographic and Letterpress Printing (EPA 453/R-06-002). The ACT was released to supplement the draft CTG and provides significant revisions to some of the elements contained in the CTG. No retention or release factors have been established for VOCs used in fountain solutions, coatings, adhesives, or other materials used in sheetfed lithographic printing operations. Therefore, all of the VOCs in these materials would all be released into the atmosphere. The emissions from automatic blanket washers would all be considered released into the atmosphere. The only “credit” for VOC not released would be for that contained in discarded wastes.

54

VOC Emission Calculation Worksheet For Sheetfed Offset Lithographic Printing

The following worksheet presents both the formulas and assumptions that can be used to determine both actual and potential VOC emissions from sheetfed offset lithographic printing operations. The assumptions on retention and release factors are taken directly from three EPA documents entitled Control Techniques Guideline for Offset Lithography issued as a draft in November 1993, the final 2006 Control Techniques Guideline for Offset Lithographic and Letterpress Printing (EPA 453/R-06-002), and the Alternative Control Techniques Guideline issued in June 1994 (EPA 453/R-94-054).



VOC Emissions4

Ink Pounds/Yr % by Weight



FS Additive Gallons/Yr Lbs VOC/Gal

Cleaning Solution





Pounds/Yr % by Weight



Total VOC Emissions




b. Do not include exempt VOCs - Methylene Chloride, 1,1,1-Trichloroethane, Acetone, or Methyl

Acetate (see http://www.dec.ny.gov/regs/13427.html for the definition of a VOC).

55

c. For Ink VOC content, the applicant can determine the VOC emissions for each ink used or use the highest VOC containing ink in each category.

3. Use the following for the appropriate VOC release factor:

Ink 0.05 Fountain Solution Concentrate 1.0 Fountain Solution Additive 1.0 Cleaning Solution 0.5* Coating

UV 1.0 Water-Based 1.0 Conventional 0.05

* The VOC composite vapor pressure of the cleaning solution must be less than 10 mm Hg at 20oC (68oF).


Factors together. The total VOC emissions are the result of adding all of the individual VOC emission determinations together. To convert the total pounds per year into tons per year, divide the total pounds by 2,000 because there are 2,000 pounds in one ton.

56

Example of VOC Emission Calculation Using Above Approach and Worksheet

Material Annual Usage VOC Content Sheetfed Ink, Process 25,200 pounds 35% by weight Fountain Solution Concentrate 420 gallons 0.717 pounds/gallon Fountain Solution Additive 120 gallons 6.7 pounds/gallon Cleaning Solution - Blanket Wash 1,200 gallons 6.24 pounds/gallon Cleaning Solution - Roller Wash 300 gallons 5.9 pounds/gallon Coating - UV 180 gallons 8.5 pounds/gallon Coating - Conventional 6,000 pounds 35% by weight

Material1 Usage2 Units VOC Content3


VOC Emissions5

Ink 25,200 Pounds/Yr 0.35 % by Weight 0.05 441


420 Gallons/Yr 0.717 Lbs VOC/Gal 1.0 301.14

FS Additive 120 Gallons/Yr 6.7 Lbs VOC/Gal 1.0 804

Cleaning Solution

1,200 Gallons/Yr 6.24 Lbs VOC/Gal 0.5 3,744

300 Gallons/Yr 5.9 Lbs VOC/Gal 0.5 885


Coatings – UV 180 Pounds/Yr 8.5 % by Weight 1.0 15.3


6,000 Gallons/Yr 0.35 Lbs VOC/Gal 0.05 105



Total VOC Emissions


57

References 1. Control Techniques Guideline for Offset Lithographic and Letterpress Printing (EPA 453/R-06-002) September 2006 is available at http://www.epa.gov/glo/SIPToolkit/ctg_act/200609_voc_epa453_r-06-002_litho_letterpress_printing.pdf

2. Draft Control of Volatile Organic Compound Emissions from Offset Lithographic Printing, September 1993 is available at www.epa.gov/ttn/atw/print/printpg.html under Closely Related Rules, Policies or Program Guidance 3. Alternative Control Techniques Document: Offset Lithographic Printing (EPA-453/R-94-054), June 1994, is available at www.epa.gov/ttn/atw/print/printpg.html under Closely Related Rules, Policies or Program Guidance 4. Printers’ Simplified Total Environmental Partnership (PrintSTEP), August 2006 Workbooks are available through www.epa.gov/compliance/assistance/sectors/printstep.html under PrintSTEP Products. 5. Potential to Emit (PTE) Guidance for Specific Source Categories, April 1998, Memo and Attached Technical Support Document are available at www.epa.gov/ttn/oarpg/t5pgm.html - scroll down to item dated 4-14-98. 6. EIIP Volume III, Chapter 7 on Graphic Arts, November 2006 is available at www.epa.gov/ttn/chief/eiip/techreport/volume03/iii07.pdf



58

Appendix 5 Express Terms Part 201-3, Exemptions and Trivial Activities Subpart 201-3: Exemptions and Trivial Activities Contents: Sec. 201-3.1 Applicability 201-3.2 Exempt activities 201-3.3 Trivial activities §201-3.1 Applicability

(a) Except as provided in Subdivision (c) of this Section, the owner or operator of an emission source listed as an exempt or trivial activity in this Subpart is exempt from the registration and permitting provisions of Subparts 201-4, 201-5, and 201-6 of this Part. This does not mean that these activities are exempted from other applicable requirements or from applicable registration and/or permitting requirements of local air pollution control agencies.

(b) Unless otherwise provided for in this Chapter, emissions from exempt and trivial activities must be included in potential to emit calculations when determining whether an emission source is subject to:

(1) Title V facility permitting pursuant to Subpart 201-6 of this Part; and/or

(2) New source review pursuant to Part 231 of this Title.

(c) If the total potential to emit for all exempt and trivial activities at a facility exceeds, or causes the facility to exceed, the major facility threshold, as defined in Subpart 201-2 of this Part, the facility is both subject to the provisions of Subpart 201-6 of this Part and no longer considered exempt or trivial for permitting purposes.

(d) If physical and/or operational restrictions are required to maintain the total potential to emit for one or more of the listed exempt and trivial activities below the title V applicability thresholds described in Subpart 201-6 of this Part, or new source review requirements described in Part 231 of this Title, the activity is no longer considered exempt or trivial for permitting purposes.

§201-3.2 Exempt activities

(a) The owner or operator of an emission source or activity that is listed as being exempt may be required to certify that it is operated within the specific criteria described in this Subpart. The owner or operator of any such emission source or activity must maintain all records necessary for demonstrating compliance with this Subpart on-site for a period of five years, and make them available to representatives of the department upon request.

(b) The owner or operator of any emission source or activity that is listed as being exempt on the basis of the use of appropriate emission controls shall operate and maintain those controls in a manner consistent with manufacturer's specifications and good engineering practices. Failure to do so constitutes a violation of this Part.

(c) The category headings used in the following listing of exempt activities are strictly for organizational purposes and are not intended to be definitive. The following activities are exempt from permitting requirements at non-title V facilities, but must be listed in title V facility permit applications:

Combustion









59

(1) Stationary or portable combustion installations with:

(i) a maximum rated heat input capacity less than 10 million Btu/hr burning fuels other than coal or wood; or

(ii) a maximum rated heat input capacity of less than one million Btu/hr burning coal or wood.

This activity does not include combustion equipment burning any material classified as a solid waste, as defined in Part 360 of this Title, or waste oil, as defined in Subpart 225-2 of this Title.

(2) Space heaters burning waste oil at automotive service facilities, as defined in Subpart 225-2 of this Title, generated on-site or at a facility under common control, alone or in conjunction with used oil generated by a do-it-yourself oil changer as defined in Subpart 374-2 of this Title.

(3) Stationary or portable internal combustion engines which meet the following criteria:

(i) are liquid or gaseous fuel powered, and located within the New York City metropolitan area or the Orange County towns of Blooming Grove, Chester, Highlands, Monroe, Tuxedo, Warwick, or Woodbury, and have maximum mechanical power rating of less than 200 brake horsepower; or

(ii) are liquid or gaseous fuel powered, and located outside of the New York City metropolitan area or the Orange County towns of Blooming Grove, Chester, Highlands, Monroe, Tuxedo, Warwick, or Woodbury, and have maximum mechanical power rating of less than 400 brake horsepower; or

(iii) are gasoline powered and have a maximum mechanical power rating of less than 50 brake horsepower.

(4) Reserved.

(5) Gas turbines with a heat input at peak load less than 10 million Btu per hour.

(6) Emergency power generating stationary internal combustion engines, as defined in Subdivision 200.1(cq) of this Chapter, and engine test cells at engine manufacturing facilities that are utilized for research and development, reliability performance testing, or quality assurance performance testing. Stationary internal combustion engines used for peak shaving and/or demand response programs are not exempt.

Combustion - Related

(7) Non-contact water cooling towers and water treatment systems for process cooling water and other water containers designed to cool, store or otherwise handle water that has not been in direct contact with gaseous or liquid process streams.

Agricultural

(8) Feed and grain milling, cleaning, conveying, drying and storage operations including grain storage silos, where such silos exhaust to an appropriate emission control device, excluding grain terminal elevators with permanent storage capacities over 2.5 million U.S. bushels, and grain storage elevators with capacities above one million bushels.

(9) Equipment used exclusively to slaughter animals, but not including other equipment at slaughterhouses, such as rendering cookers, boilers, heating plants, incinerators, and electrical power generating equipment.

Commercial - Food Service Industries


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(10) Flour silos at bakeries, provided all such silos are exhausted through an appropriate emission control device.

(11) Emissions from flavorings added to a food product where such flavors are manually added to the product.

Commercial - Graphic Arts

(12) Screen printing inks/coatings or adhesives which are applied by a hand-held squeegee. A hand-held squeegee is one that is not propelled through the use of mechanical conveyance and is not an integral part of the screen printing process.

(13) Graphic arts processes at facilities located outside the New York City metropolitan area or the Orange County towns of Blooming Grove, Chester, Highlands, Monroe, Tuxedo, Warwick, or Woodbury whose facility-wide total emissions of volatile organic compounds from inks, coatings, adhesives, fountain solutions and cleaning solutions are less than three tons per year on a 12-month rolling basis.

(14) Graphic label and/or box labeling operations where the inks are applied by stamping or rolling.

(15) Graphic arts processes which are specifically exempted from regulation under Part 234 of this Title, with respect to emissions of volatile organic compounds which are not given an A rating as described in Part 212 of this Chapter.

Commercial - Other

(16) Gasoline dispensing sites registered with the department pursuant to Part 612 of this Chapter.

(17) Surface coating and related activities at facilities which use less than 25 gallons per month of total coating materials. Coating materials include all paints and paint components, other materials mixed with paints prior to application, and cleaning solvents, combined, subject to the following:

(i) the facility is located outside of the New York City metropolitan area or the Orange County towns of Blooming Grove, Chester, Highlands, Monroe, Tuxedo, Warwick, or Woodbury; and

(ii) all abrasive cleaning and surface coating operations are performed in an enclosed building where such operations are exhausted into appropriate emission control devices.

(18) Abrasive cleaning operations which exhaust to an appropriate emission control device.

(19) Ultraviolet curing operations.

Municipal/Public Health Related

(20) Landfill gas ventilating systems at landfills with design capacities less than 2.5 million megagrams (3.3 million tons) and 2.5 million cubic meters (2.75 million cubic yards), where the systems are vented directly to the atmosphere, and the ventilating system has been required by, and is operating under, the conditions of a valid Part 360 permit, or order on consent;

Storage Vessels

(21) Distillate fuel oil, residual fuel oil, and liquid asphalt storage tanks with storage capacities below 300,000 barrels.

(22) Pressurized fixed roof tanks which are capable of maintaining a working pressure at all times to prevent emissions of volatile organic compound to the outdoor atmosphere.


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(23) External floating roof tanks which are of welded construction and are equipped with a metallic-type shoe primary seal and a secondary seal from the top of the shoe seal to the tank wall.

(24) External floating roof tanks which are used for the storage of a petroleum or volatile organic liquid with a true vapor pressure less than 4.0 psi (27.6 kPa), are of welded construction and are equipped with one of the following:

(i) a metallic-type shoe seal;

(ii) a liquid-mounted foam seal;

(iii) a liquid-mounted liquid-filled type seal; or

(iv) equivalent control equipment or device.

(25) Storage tanks, including petroleum liquid storage tanks as defined in Part 229 of this Title, with capacities under 10,000 gallons, except those subject to either Part 229 or Part 233 of this Title.

(26) Horizontal petroleum or volatile organic liquid storage tanks.

(27) Storage silos storing solid materials, provided all such silos are exhausted through an appropriate emission control device. This exemption does not include raw material, clinker or finished product storage silos at Portland cement plants.

Industrial

(28) Processing equipment at existing sand and gravel and stone crushing plants which were installed or constructed before August 31, 1983, where water is used for operations such as wet conveying, separating and washing. This exemption does not include processing equipment at existing sand and gravel and stone crushing plants where water is used for dust suppression.

(29) Any sand and gravel processing or crushed stone processing line at a non-metallic mineral processing facility that:

(i) is a permanent or fixed installation with a maximum rated processing capacity of 25 tons of minerals per hour or less;

(ii) is a portable emission source with a maximum rated processing capacity of 150 tons of minerals per hour or less; or

(iii) is used exclusively to screen minerals at a facility where no crushing or grinding takes place.

(30) Reserved.

(31) Surface coating operations which are specifically exempted from regulation under Part 228 of this Title, with respect to emissions of volatile organic compounds which are not given an A rating pursuant to Part 212 of this Chapter.

(32) Pharmaceutical tablet branding operations.

(33) Thermal packaging operations, including but not limited to, therimage labeling, blister packing, shrink wrapping, shrink banding, and carton gluing;

(34) Powder coating operations.

(35) All tumblers used for the cleaning and/or deburring of metal products without abrasive blasting.



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(36) Presses used exclusively for molding or extruding plastics except where halogenated carbon compounds or hydrocarbon solvents are used as foaming agents.

(37) Concrete batch plants where the cement weigh hopper and all bulk storage silos are exhausted through fabric filters, and the batch drop point is controlled by a shroud or other emission control device.

(38) Cement storage operations not located at Portland cement plants where materials are transported by screw or bucket conveyors.

(39) Solvent metal cleaning processes:

(i) Cold cleaning degreasers with an open surface area of 11 square feet or less and an internal volume of 93 gallons or less or, having an organic solvent loss of 3 gallons per day or less.

(ii) Cold cleaning degreasers that use a solvent with a VOC content of five percent or less by weight, unless subject to the requirements in 40 CFR 63, subpart T.

(iii) Conveyorized degreasers with an air/vapor interface smaller than 22 square feet (2.0 m2), unless subject to the requirements in 40 CFR 63, subpart T.

(iv) Open-top vapor degreasers with an open-top area smaller than 11 square feet (1.0 m2), unless subject to the requirements in 40 CFR 63, subpart T.

Miscellaneous

(40) Ventilating and exhaust systems for laboratory operations. Laboratory operations do not include processes having a primary purpose to produce commercial quantities of materials.

(41) Exhaust or ventilating systems for the melting of gold, silver, platinum and other precious metals.

(42) Exhaust systems for paint mixing, transfer, filling or sampling and/or paint storage rooms or cabinets, provided the paints stored within these locations are stored in closed containers when not in use.

(43) Exhaust systems for solvent transfer, filling or sampling, and/or solvent storage rooms provided the solvent stored within these locations are stored in closed containers when not in use.

(44) Research and development activities, including both stand-alone and activities within a major facility, until such time as the administrator completes a rule making to determine how the permitting program should be structured for these activities.

(45) The application of odor counteractants and/or neutralizers.

(46) Hydrogen fuel cells.

(47) Dry cleaning equipment that uses only water-based cleaning processes or those using liquid carbon dioxide.

(48) Manure spreading, handling and storage at farms and agricultural facilities.

§201-3.3 Trivial activities

(a) The owner or operator of an emission source or activity that is listed as being trivial in this Section may be required to certify that it is operated within the specific criteria described in this Subpart. The owner or operator of any such emission source or activity must maintain all required records on-site for a period of five years and make them available to representatives of the department upon request.

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(b) The owner or operator of any emission source or activity that is listed as being trivial in this Section, on the basis of the use of appropriate emission controls, shall operate and maintain those controls in a manner consistent with manufacturer's specifications and good engineering practices. Failure to do so constitutes a violation of this Part.

(c) The category headings used in the following listing of trivial activities are strictly for organizational purposes and are not intended to be definitive. The following activities are trivial and are exempt from permitting requirements and do not need to be listed in the title V facility permit application:

Combustion

(1) Boiler water treatment operations.

Domestic / Work Station Comfort and Related

(2) Any emission source or process constructed or operated at a domestic residence strictly for domestic use.

(3) Vacuum cleaning systems used exclusively for office type areas at industrial facilities, or commercial or residential housekeeping.

(4) Ventilating systems used exclusively for temperature and humidity control of buildings for the comfort of people living or working within the building except those systems which are subject to applicable requirements under title VI of the act.

(5) Exhaust systems for the storage of portable containers, drums, and bags of chemicals in rooms, buildings and warehouses, subject to the following:

(i) the rooms, buildings and warehouses subject to this exemption are solely for the purpose of chemical storage, and no mixing, transfer or filling operations with the exception of sampling for quality assurance/quality control purposes, take place within such areas; and

(ii) the chemicals stored in such areas are maintained in sealed containers.

(6) Smoking rooms and areas.

(7) Bathroom/toilet vents.

(8) Beauty salons and barber shops.

(9) Laundry dryers, extractors, or tumblers used to clean fabrics with water solutions of bleach and detergents, where the emissions of such operations are controlled by appropriate emission control devices.

Mobile Sources and Mobile Source Related

(10) Engine exhaust emissions and/or refueling emissions generated from mobile and portable powered vehicles and equipment used for the propulsion or operation of passengers and/or freight transportation vehicles, marine vehicles and equipment, construction and vehicles and equipment powered by non-road engines, farm vehicles and equipment, competition and entertainment vehicles and equipment, and/or any other type of mobile or portable engine powered vehicles or equipment when these vehicles or equipment are operated anywhere outside of an enclosed facility for the purpose of their design and intended use or for compliance assessment with any safety or emission control or inspection programs sanctioned by New York State, the Federal government or any governmental entity empowered to carry out such activities.

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(11) Engine exhaust emissions and/or refueling emissions generated from mobile and portable powered vehicles and equipment such as competition and entertainment vehicles and equipment, farm vehicles and equipment, construction and vehicles and equipment powered by non-road engines, automobiles, motorcycles, trucks, buses, marine vehicles and equipment, small engine powered tools and equipment, or any other type of mobile or portable engine powered vehicles or equipment which are collected and/or vented in any manner to the outdoor atmosphere when these vehicles and equipment are operated inside of an enclosed structure or under a covered structure for the purposes of their design and intended use, public safety, comfort or entertainment, facility maintenance, vehicle or equipment repair, adjustment or testing, or compliance assessment with any safety or emission control or inspection programs sanctioned by New York State, the Federal government, or any governmental entity empowered to carry out such activities.

(12) The use of products such as antifreeze and fuel additives for the purpose of maintaining motor vehicles.

(13) Fugitive emissions related to movement of passenger vehicles, provided the emissions are not counted for applicability purposes and any required fugitive dust control plan or its equivalent is submitted.

Agricultural

(14) Ventilating systems used in buildings to house animals.

Commercial - Food Service Industries

(15) Emissions from process, exhaust or ventilating systems in bakeries and restaurants which derive over 50 percent of their revenues from retail sales on premises.

(16) Non-conveyorized bakery ovens, including batch ovens, which are defined as a non-conveyor belt oven operating a single baking cycle in which a determinate amount of product is cooked at one baking.

(17) Bakery ovens used exclusively to produce baked goods leavened chemically in the absence of yeast.

(18) Process or exhaust or ventilating systems involved in the preparation of food, food blanching or cooking in water.

(19) Process, exhaust or ventilating systems or stationary combustion installations exclusively involved in the production of maple syrup.

Commercial - Graphic Arts

(20) Lead melting pots used in printing establishments.

(21) Blueprint machines.

(22) Photocopying, photographic processing or related equipment.

(23) Proof press operations.

(24) Heat sealing operations which are used to seal and separate polyethylene and polypropylene bags.

Commercial - Other

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(25) Batch process kilns used for firing ceramic ware, subject to the following:

(i) the exhaust stream does not contain emissions of fluorides, lead, and/or beryllium; and

(ii) the total heat input is less than one million Btu/hr.

Municipal/Public Health Related

(26) Equipment used exclusively to generate ozone for water treatment processes.

(27) Air stripping processes utilized on public drinking water supplies.

(28) Air strippers and soil vents used to remediate gasoline spills, where the air stripper or soil vent is located at a State-funded site, or required under the provisions of an order on consent or stipulation agreement, and the operation of the air strippers or soil vents are conducted under the supervision of the department and are properly controlled as required by the department.

(29) Air strippers and soil vents required under the provisions of an order on consent or stipulation agreement, or in operation at a superfund site.

(i) required by the provisions of an order on consent; or

(ii) operated under an agreement with, and under the supervision of, the department; or

(iii) operated at a Superfund site.

(30) Air strippers and soil vents operating for test purposes to qualify and quantify air emissions for remediation projects and for a time period acceptable to the department.

(31) Emissions from the storage and application of road salt (calcium chloride or sodium chloride).

(32) All process emission sources which are located at private, public, or vocational education institutions, where the emissions are primarily the result of teaching and training exercises, and the institution is not engaged in the manufacture of products for commercial sale.

(33) Emergency relief vents, stacks and ventilating systems except any with the potential to emit vinyl chloride located at a facility where ethylene dichloride, vinyl chloride and/or polyvinyl chloride are produced. This activity does not include bypass stacks or vents on incinerators or any other equipment, or any other vents or stacks that operate or release air contaminants to the outdoor atmosphere on a frequent or regular basis.

(34) Snow plowing, street sweeping, sanding and ashing of streets and roads to abate traffic hazards.

(35) Emergency road flares.

(36) Road and lot paving and striping operations.

(37) Public or private roadways, parking lots.

(38) Manhole covers.

(39) Sewers.

(40) Storm drains and vents.

(41) Solid waste handling equipment, including but not limited to: dumpsters, transfer stations, wood chippers, recycling operations, composting operations, tub grinders, construction and demolition

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waste crushers and associated activities. This activity does not include solid waste incinerators and other thermal treatment technologies.

(42) Excavation for the repair of underground utility lines such as water, electric, or natural gas.

(43) Asbestos demolition and removal work subject to 40 CFR part 61, subpart M and/or 12 NYCRR Part 56.

Storage Vessels

(44) Storage vessels, tanks and containers with a capacity of less than 750 gallons.

Maintenance and Construction Related Activities

(45) The following activities are considered trivial when they occur strictly for maintenance or construction activities: plastic pipe welding, soldering, brazing, cutting torches, janitorial activities, steam cleaning, water washing, acid and caustic washing activities, miscellaneous use of solvents, adhesives and caulking, miscellaneous sandblasting, non-asbestos insulation removal, application of refractory and insulation, the periodic use of air for clean-up, and, the process of demolition and rebricking boilers, smelters, furnaces and kilns (this does not include the subsequent operation of such equipment), the surface coating of equipment and buildings as is related to maintenance and construction, and activities which occur for maintenance of grounds such as lawn care, weed control and pest control.

(46) Excavation for new construction.

Industrial

(47) Degreasing units which exclusively use non-hazardous air pollutant acids.

(48) Degreasing units which exclusively use caustics (e.g., potassium hydroxide and sodium hydroxide).

(49) Remote reservoir parts cleaners whose use of solvent is contained to the immediate cleaning of the part, after which time the solvent is drained through a drain opening, not to exceed 16 square inches, and is returned to a remote reservoir containing the solvent.

(50) Reserved.

(51) Cold cleaning degreasers with an internal volume less than or equal to two gallons.

(52) Hand-held or manually operated equipment used for buffing, polishing, carving, cutting, drilling, machining, routing, sanding, sawing, surface grinding, sand blasting or turning ceramic art work, ceramic precision parts, leather, metal parts, plastics, fiberboard, fiberglass, masonry, carbon, glass, graphite, wood or rubber.

(53) Manual surface coating/painting processes which exclusively use brushes, rollers, hand held spray guns with a capacity less than three ounces, or aerosol cans.

(54) Hand-held or manually operated welding, brazing and soldering equipment.

(55) Acetylene, butane, and propane torches.

(56) Equipment used for hydraulic or hydrostatic testing.

(57) Equipment lubricating systems, including metal cutting coolants and oils.

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(58) Pneumatic starters used to start reciprocating engines, turbines, and other equipment.

(59) Instrument air systems, excluding fuel-fired compressors.

(60) Air vents from air compressors and pneumatically operated equipment emitting ambient air.

(61) Drum washing operations, where such operations are necessary to meet Resource Conservation and Recovery Act (RCRA) standards.

(62) Vacuum producing devices where only ambient air and the oil emissions from the vacuum producing mechanism itself are exhausted.

(63) Woodworking operations where no surface coating takes place, provided such operations exhaust to a sawdust collection system controlled by an appropriate emission control device.

(64) Sawmills, provided all processes are located at least 500 feet from any recreational area, school, or private residence and all residues from debarking, planing, sawing, etc., are contained in such a manner as to minimize fugitive emissions.

(65) Equipment used to mix and package soaps, vegetable oil, grease, animal fat, and nonvolatile aqueous salt solutions, provided appropriate lids and covers are utilized.

(66) Drop hammers or hydraulic presses for forging or metalworking.

(67) Transportable chemical containers including rail cars, portable tanks, totes and trailers.

Miscellaneous

(68) Open fires as described in Part 215 of this Title.

(69) Fire training activities as described in Part 215 of this Title.

(70) Fire suppression systems.

(71) Fecal incinerators with a charging rate not exceeding 10 pounds per hour, such as those used on certain vehicles or other special cases.

(72) Paint mixing operations located at retail paint, hardware or department stores where the paint is sold in five gallon or smaller containers.

(73) Rifle and pistol ranges.

(74) Aircraft de-icing operations.

(75) Contaminant detectors, sampling devices and recorders.

(76) Emissions from natural gas odoring activities.

(77) Battery charging areas except those located at battery manufacturing plants.

(78) Incubators.

(79) The venting of compressed natural gas, butane or propane gas cylinders.

(80) Coal car thaw-pit burners.

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(81) Use of office equipment and products including, but not limited to, desktop printers, fax machines, scanners and photocopiers used as printers, but not including graphic arts processes as defined in Part 234 of this Chapter.

(82) Consumer use of paper trimmers/binders.

(83) Blacksmith forges.

(84) Carbon dioxide lasers, used only on metals and other materials which do not emit hazardous air pollutants in the process.

(85) Laser trimmers using appropriate emission control devices.

(86) Environmental chambers not using hazardous air pollutant gases.

(87) Shock chambers.

(88) Humidity chambers.

(89) Solar simulators.

(90) Process water filtration systems and demineralizers.

(91) Demineralized water tanks and demineralizer vents.

(92) Steam leaks.

(93) Steam vents.

(94) Emissions of water vapor, oxygen, nitrogen, inert gases such as argon, helium, neon, krypton and xenon, hydrogen, ethane, and trace constituents included in raw materials where the constituents are less than one percent by weight for any regulated air pollutant, or 0.1 percent by weight for any carcinogen listed by the United States Department of Health and Human Services' Twelfth Annual Report on Carcinogens (2011) (see Table 1, Section 200.9 of this Title).

(95) Emissions of carbon dioxide and methane, except where specifically regulated by a federal or state law or regulation.

(96) Solvent cleaning of parts and equipment performed exclusively by hand wiping or hand cleaning.

Appendix 6 Express Terms Part 234, Graphic Arts A new Part 234 is added as follows: Sec. 234.1 General applicability and exemptions 234.2 Definitions 234.3 Control requirements 234.4 Testing and monitoring 234.5 Prohibition of sale or specification 234.6 Handling, storage and disposal of volatile organic compound (VOC) 234.7 Recordkeeping 234.8 Opacity

Section 234.1 General applicability and exemptions

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(a) The owner or operator of a graphic arts facility is subject to all requirements of this Part, as specified, if the facility is located in a severe ozone non-attainment area or emits total actual annual volatile organic compound (VOC) graphic arts emissions of three tons or more on a 12-month rolling basis.

(b) The owner or operator of a graphic arts facility is subject only to sections: 234.5 Prohibition of sale or specification; 234.6 Handling storage and disposal of VOC; 234.7 Recordkeeping; and 234.8 Opacity if the facility is located outside a severe ozone non-attainment area and emits total actual annual VOC graphic arts emissions less than three tons on a 12-month rolling basis.

(c) A printing process that is subject to the provisions of this Part will remain subject to these provisions even if the emission of VOC from the facility or printing press later falls below the applicability criteria.

(d) This Part does not apply to:

(1) digital printing presses;

(2) screen printing processes that only use conductive ink to produce electronic circuits that permit electric current flow through the printed line or pattern;

(3) screen printing processes that only use sterilization indicating ink to monitor the sterilization of medical instruments, autoclave efficiency, and the thermal processing of foods for the prevention of spoilage;

(4) proof presses; or

(5) the use of specialty ink, coating or adhesive where the facility's total actual annual usage of all specialty ink, coating and adhesive is no more than 55 gallons, on a 12-month rolling basis, provided that each specialty ink, coating and adhesive excluded from the requirements are recorded in accordance with section 234.7 of this Part.

Section 234.2 Definitions. (a) For the purpose of this Part, the general definitions of Part 200 of this Title apply.

(b) For the purpose of this Part, the following definitions also apply:

(1) 'Alcohol.' Ethanol, n-propanol, and isopropanol.

(2) 'Alcohol substitute.' A non-alcohol additive that contains VOC and is used in a fountain solution to reduce the surface tension of water or to prevent piling (ink build-up).

(3) 'As applied.' The VOC concentration of ink, coating, or adhesive at the time it is applied to a substrate; or the alcohol (or alcohol substitute) concentration of a fountain solution at the time it is applied to lithographic press plates.

(4) 'Capture system.' All equipment including, but not limited to, hoods, ducts, fans, booths, ovens, or dryers that contain, collect, and transport an air pollutant to control equipment.

(5) 'Cleaning materials.' A liquid solvent or solution used to remove ink and debris from the operating surfaces of the printing press and its parts. For purposes of this rule, cleaning solutions include, but are not limited to blanket wash, roller wash, metering roller cleaner, plate cleaner, impression cylinder washes, rubber rejuvenators, and other cleaners used for cleaning a press, press parts, or to remove dried ink or coating from areas around the press.

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(6) 'Cold-set printing process.' Or 'Non-heatset printing process.' A printing process that uses absorption, oxidation, ultraviolet light, electron bean or other non-heat method to cure the printing ink.

(7) 'Composite Partial Vapor Pressure.' The sum of the partial pressure of the compounds defined as VOCs. VOC composite partial vapor pressure is calculated as follows:

Where:

Wi = Weight of the "i"th VOC compound, in grams

Ww = Weight of water, in grams

Wc = Weight of exempt compound, in grams

Mwi = Molecular weight of the "i"th VOC compound, in g/g-mole

MWw = Molecular weight of water, in g/g-mole

MWc = Molecular weight of exempt compound, in g/g-mole

PPc = VOC composite partial vapor pressure at 20°C (68°F), in mm Hg

Vpi = Vapor pressure of the "i"th VOC compound at 20°C (68°F), in mm Hg

(8) 'Control equipment.' The equipment used to destroy or remove VOC emissions from graphic art printing processes.

(9) 'Digital printing press.' A printing press that transfers electronic files from a computer to an electronically driven output device that prints the image directly on a substrate. Also known as direct-to-media printing.

(10) 'Excluded compound.' A compound expressly excluded from the definition of VOC in section 200.1 of this Title.

(11) 'Flexographic printing process.' A printing process that raises the image to be applied above the non-image area and uses an image carrier made of rubber or other elastomeric materials.

(12) 'Fountain solution.' A solution of water, VOC, gum arabic, and surfactants used for wetting lithographic press plates.

(13) 'Graphic arts.' Packaging rotogravure, publication rotogravure, flexographic, offset lithographic, letterpress and screen printing processes.

(14) 'Heat-set printing process.' A printing process that uses heat to evaporate ink oils from the printing ink. Hot air dryers are used to deliver the heat.

(15) 'Letterpress printing process.' A printing process in which the image is raised relative to the non-image and a paste ink is transferred from the image surface directly to the substrate.

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(16) 'Maximum permitted pounds of VOC per gallon of ink, coating or adhesive, minus water and excluded compounds, at application.' The permissible quantity of VOC per gallon of ink, coating or adhesive minus water and excluded compounds; calculated as follows:

(VOC)a = (Dc)a ((Wv)a - (Ww)a - (We)a) / 1 - ((Vw)a + (Ve)a)

where:

(VOC)a = VOC content of ink, coating or adhesive as applied, expressed as a mass of VOC, in pounds, per volume of coating, in gallons, minus water and excluded compounds

(Dc)a = Ink, coating or adhesive density as applied, in pounds per gallon

(Wv)a = the weight fraction of total VOC in the ink, coating or adhesive as applied

(Ww)a = the weight fraction of water in the ink, coating or adhesive as applied

(Vw)a = the volume fraction of water in the ink, coating or adhesive as applied

(We)a = the weight fraction of excluded compounds in the ink, coating or adhesive as applied

(Ve)a = the volume fraction of excluded compounds in the ink, coating or adhesive as applied.

(17) 'Offset lithographic printing process.' A planographic printing process that chemically differentiates the image and non-image areas and uses a lithographic plate to transfer the image to an intermediate surface which in turn transfers the image to the substrate.

(18) 'Overall removal efficiency.' The total reduction in VOC emissions considering the efficiency of both the capture system and subsequent destruction or removal of these emissions by the control equipment prior to their release into the atmosphere.

(19) 'Packaging rotogravure printing process.' A rotogravure printing process upon substrates that are subsequently formed into wallpaper, packaging products, or labels for articles to be sold.

(20) 'Printing press.' The equipment used to apply words, pictures, or designs to either a web, or a sheet. A web is a continuous substrate of paper, plastic, or other material that is unwound from a roll, passed through ink or coating applicators and any associated drying areas. The press includes all ink and coating applicators and drying areas between unwind and rewind of the continuous substrate. A sheet consists of paper, plastic, or other material that is fed through the press sequentially and carried through the process on a moving belt. The press includes all ink and coating applicators and drying operations from the time that the sheet is put on the moving belt until it is taken off.

(21) 'Printing process.' Any of the various ways a printing press is operated.

(22) 'Proof press.' A printing press used only to check the quality of print color and editorial content.

(23) 'Publication rotogravure printing process.' A rotogravure printing process used to produce books, magazines, catalogs, brochures, directories, newspaper supplements and similar types of printed material.

(24) 'Rotogravure printing process.' An intaglio printing process that transfers the inked image from minute etched or engraved wells on a plate or cylinder to the substrate that is supported by an impression roller.

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(25) 'Screen printing process.' A printing process that delivers ink through a woven mesh fitted with an ink blocking stencil. The stencil and mesh openings determine the form and dimensions of the imprint. Screen printing processes where the ink is applied by a hand held squeegee are excluded from this definition.

(26) 'Serigraph.' Fine art created or reproduced using a screen printing press.

(27) 'Solvent.' A substance that is liquid at standard conditions and is used to dissolve or dilute another substance; this term includes, but is not limited to, organic materials used as dissolvers, viscosity reducers, degreasing agents, or cleaning agents. An excluded compound is not a solvent.

Section 234.3 Control requirements. (a) (1) A packaging rotogravure, publication rotogravure, or flexographic printing process that uses ink, coating or adhesive containing VOC shall not operate if it: is located in a severe ozone non-attainment area; has an annual potential to emit VOC of 25 tons per year or more; or is located in a facility that has an annual potential to emit VOC of 50 tons per year or more, unless the printing process uses one of the following strategies to control VOCs.

(i) Ink, coating or adhesive with low VOC content equal to or less than

('a') 0.8 kilograms of VOC per kilogram of solids as applied (0.8 kg VOC/ kg solids as applied); or

('b') 0.16 kilograms of VOC per kilogram of ink, coating and adhesive as applied (0.16 kg VOC/ kg material as applied);

VOC content limits can be met by averaging the VOC content of materials used on a single press (i.e., within a line).

(ii) A capture system and control equipment that provides for overall removal efficiency of at least

('a') 75.0 percent for a publication rotogravure printing process, unless a higher overall removal efficiency is required by clause 'e' of this subparagraph;

('b') 65.0 percent for a printing process that was first installed prior to March 14,1995, and that is controlled by an add-on capture system and air cleaning equipment that was first installed prior to the effective date of this regulation;

('c') 70.0 percent for a printing process that was first installed prior to March 14,1995, and that is controlled by an add-on air capture system and air cleaning equipment that was first installed on or after the effective date of this regulation;

('d') 75.0 percent overall removal efficiency for a printing process that was first installed on or after March 14,1995, and that is controlled by an add-on capture system and air cleaning equipment that was first installed prior to the effective date of this regulation; or

('e') 80.0 percent for a printing process that was first installed on or after March 14, 1995, and that is controlled by an add-on capture system and air cleaning equipment that was first installed on or after the effective date of this regulation.

(2) Radiation cured material via ultra-violet light or electron beam printing processes are not subject to the control requirements of this subdivision.

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(b) (1) A heat-set web offset lithographic printing process or heat-set letterpress printing process that uses ink, coating or adhesive containing VOC shall not operate if it: is located in a severe ozone non-attainment area; has an annual potential to emit VOC of 25 tons per year or more; or is located at a facility that has an annual potential to emit VOC of 50 tons per year or more, unless the control equipment provides for an

(i) overall removal efficiency of 90.0 percent or greater for control equipment that was first installed prior to the effective date of this regulation;

(ii) overall removal efficiency of 95.0 percent or greater for control equipment that was first installed on or after the effective date of this regulation; or

(iii) outlet concentration of VOC from the emission control equipment equal to or less than 20 parts per million by volume (20 ppmv) as hexane on a dry basis.

(2) The following printing processes are not subject to the control requirements of this subdivision:

(i) heat-set web offset lithographic printing processes used for printing books;

(ii) heat-set web offset lithographic printing processes with a maximum web width of 22 inches;

(iii) cold-set offset lithographic printing processes;

(iv) cold-set letterpress printing processes;

(v) sheet-fed or coldset web varnishes; and

(vi) radiation cured material via ultra-violet light or electron beam.

(c) (1) An offset lithographic or letterpress printing process that uses cleaning materials containing VOC shall not operate if it is located in a severe ozone non-attainment area or at a facility with total actual annual VOC graphic arts emissions of 3 tons or more on a 12-month rolling basis, unless:

(i) The cleaning material, as applied, contains less than 70.0 percent by weight VOC (70 percent by weight VOC); or

(ii) The cleaning material, as applied, has a composite vapor pressure of less than or equal to 10 millimeters mercury at 20 degrees Celsius (10 mm Hg at 20°C).

(2) One hundred and ten (110) gallons of cleaning material per year on a 12-month rolling basis are excluded from the requirements of this subdivision provided that the use and quantity of the cleaning material excluded from the requirements are recorded in accordance with section 234.7 of this Part.

(d) (1) An offset lithographic printing process that uses fountain solutions containing VOC shall not operate if it is located in a severe ozone non-attainment area or is located at a facility with total actual annual VOC graphic arts emissions of three tons or more on a 12-month rolling basis, unless:

(i) For heat-set web offset lithographic printing processes:

('a') The fountain solution as applied contains no more than 1.6 percent alcohol by weight or equivalent;

('b') The fountain solution as applied contains no more than 3.0 percent alcohol by weight when the fountain solution is refrigerated to less than 60 degrees Fahrenheit (60°F) or 15.5 degrees Celsius (15.5°C); or

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('c') The fountain solution as applied contains no more than a 5.0 percent alcohol substitute by weight and no alcohol.

(ii) For sheet-fed offset lithographic printing processes:

('a') The fountain solution as applied contains no more than five percent alcohol by weight or equivalent;

('b') The fountain solution as applied contains no more than 8.5 percent alcohol by weight when the fountain solution is refrigerated to less than 60 degrees Fahrenheit (60°F) ) or 15.5 degrees Celsius (15.5°C); or

('c') The fountain solution as applied contains no more than five percent alcohol substitute by weight and no alcohol.

(iii) For cold-set web offset lithographic printing presses the fountain solution as applied contains no more than 5.0 percent alcohol substitute by weight and no alcohol.

(2) Sheet-fed offset lithographic presses with a sheet size of 11 inches by 17 inches or smaller or any press with a fountain solution reservoir of less than one gallon are not subject to the requirements of this subdivision.

(e) (1) A screen printing process that uses ink, coating or adhesive containing VOC shall not operate if it is located in a severe ozone non-attainment area, or is located in a facility that has an annual potential to emit VOC of 50 tons per year or more, unless the printing process uses one of the following strategies to control VOC.

(i) ) The maximum permitted pounds of VOC per gallon of ink, coating or adhesive, minus water and excluded compounds, at application is

('a') 3.3 pounds as applied to paper, glass, metal, plastic, vinyl, reflective sheeting, textile/imprinted garments or pressure sensitive decals,; or

('b') 5.0 pounds as applied for serigraph.

(ii) A capture system and control equipment that provides a minimum overall removal efficiency of 80.0 percent.

(2) Screen printing ink, coating or adhesive which is applied by a hand-held squeegee (a squeegee that is not propelled through the use of mechanical conveyance and is not an integral part of the screen printing process) are not subject to the control requirements of this subdivision.

(f) The Department may allow printing processes to operate with a lesser degree of control than is required by this section provided that a process specific reasonably available control technology (RACT) demonstration has been made to the satisfaction of the Department. Such process specific RACT demonstrations will be submitted by the Department to the United States Environmental Protection Agency as a revision to the State Implementation Plan and must address the technical and economic feasibility of using:

(1) low VOC content ink, coating or adhesive;

(2) demonstrated and proven emission control technologies that will achieve the required overall removal efficiency as required by this section;

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(3) demonstrated and proven emission control technologies that will achieve a degree of overall removal efficiency less than required by this section; and

(4) demonstrated and proven production modifications methods that will result in real, documented, and enforceable reductions in the VOC emissions from the printing process.

(g) Facilities with printing processes subject to this Part with an annual potential to emit less than five tons of VOC are only required to comply with paragraphs 234.3(f)(1) and (4) of this section in order to demonstrate that a lesser degree of control is RACT for these processes.

(h) For printing processes subject to this Part, the Department may allow sources that use control equipment with natural gas fired afterburners to shut down the natural gas fired afterburners from November 1st through March 31st for the purposes of natural gas conservation, provided that the commissioner has determined that this action will not jeopardize air quality.

Section 234.4 Testing and monitoring (a) Printing processes that use control equipment to comply with the provisions of this Part must test and monitor the control equipment to ensure the overall removal efficiency. Test methods included in this section must be used to demonstrate the overall removal efficiency.

(1) For control equipment that uses VOC/solvent recovery, overall removal efficiency must be demonstrated using methods described in paragraphs 234.4(b)(1) and (2) of this section.

(2) For control equipment other than VOC/solvent recovery, the chosen demonstration method must include provisions to determine the overall removal efficiency.

(b) The owner or operator of a printing process subject to this Part must follow notification requirements and test procedures in Part 202-1 of this Title.

(1) One of the following test methods from appendix A of 40 CFR 60 (see Table l, section 200.9 of this Title) must be used to measure the VOC concentration of a gas stream at the inlet and outlet of the control equipment:

(i) Method 18, Measurement of Gaseous Organic Compound Emissions by Gas Chromatography;

(ii) Method 25, Determination of Total Gaseous Non-methane Organic Emissions as Carbon; or

(iii) Method 25A, Determination of Total Gaseous Organic Concentration Using a Flame Ionization Analyzer.

(iv) Methods not listed above must be approved in advance by the Department and the United States Environmental Protection Agency.

(2) Acceptable analytical methods for determining the VOC content, water content, density, volume of solids and weight of solids of surface coatings and printing inks are presented in appendix A, methods 24 and 24A (as appropriate), of 40 CFR 60 (see Table l, section 200.9 of this Title). Alternate analytical methods for surface coating and printing ink analysis must be approved by the Department and the United States Environmental Protection Agency. Instead of analytical methods, the Department may accept the manufacturer's certification of VOC content of ink coating or adhesives, if supported by actual batch records.

(c) Continuous control equipment monitors for the following parameters must be installed, periodically calibrated, and operated at all times that the associated control equipment is operated:

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(1) Combustion zone temperature of all oxidizers;

(2) Inlet temperature at the catalytic oxidizer bed;

(3) Break-through of VOC on a carbon adsorption unit; and

(4) Any other continuous monitoring or recording device required by the Department.

Section 234.5 Prohibition of sale or specification. (a) A person shall not sell, specify, or require the application of a coating, ink or adhesive on a substrate if such activity is prohibited by any of the provisions of this Part. The prohibition of this section shall apply to all written or oral contracts under the terms of which a coating, ink or adhesive is to be applied to a substrate. This prohibition shall not apply to the following:

(1) Ink, coating, or adhesive used in printing processes where control equipment has been installed to demonstrate compliance with this Part; or

(2) Ink, coating, or adhesive used in printing processes that have been granted variances for reasons of technological and economic feasibility per section 234.3(f) of this Part.

(b) A person selling an ink, coating, or adhesive used in a printing process subject to this Part must, upon request, provide the buyer with certification of the VOC content of the coating, ink or adhesive supplied.

Section 234.6 Handling, storage and disposal of volatile organic compounds (VOC). An owner or operator of a facility subject to this Part shall not:

(a) Use open containers to store or dispose of cloth or paper impregnated with VOC or solvents that are used for surface preparation, cleanup or the removal of ink, coating or adhesive;

(b) Use open containers to store or dispose of spent or fresh VOC or solvents used for surface preparation, cleanup or the removal of ink, coating or adhesive;

(c) Use open containers to store, dispose or dispense ink, coating or adhesive unless production, sampling, maintenance or inspection procedures require operational access. This provision does not apply to the actual device or equipment designed for the purposes of applying an ink, coating or adhesive to a substrate.

Section 234.7 Recordkeeping (a) Purchase, use, and production records of ink, coating, adhesive, VOCs, solvent, fountain solution and cleaning material must be maintained in a format acceptable to the Department, and upon request, submitted to the Department. Any other information required to determine compliance with this Part must be provided to the Department in an acceptable format. Records must be maintained at the facility for five years.

(b) The results of an analysis or other procedure used to establish compliance with this Part must be provided to the Department. Department representatives shall be permitted, during reasonable business hours, to obtain ink, coating, adhesive, cleaning material and fountain solution samples to determine compliance with this Part.

(c) The owner or operator of a graphic art facility which is not subject to the control requirements of this Part because its annual potential to emit VOC or its total actual VOC emissions, whichever applies is below the applicability criteria, must maintain records in a format acceptable to the Department that verify the facility's annual potential to emit VOC or its total actual VOC emissions. Upon request, these records must be submitted to the Department.

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Section 234.8 Opacity A person shall not cause or allow emissions having an average opacity of 10 percent or greater for any consecutive six minute period from any emission source subject to this Part into the outdoor atmosphere.

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