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Technical Support Document for Title V Permitting of Printing Facilities

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Technical Support Document for Title V Permitting of Printing Facilities TECHNICAL SUPPORT DOCUMENT (TSD) FOR TITLE V PERMITTING OF PRINTING FACILITIES Office of Air Quality Planning and Standards U.S. Environmental Protection Agency Research Triangle Park, NC 27711 Revised June 2007 CONTENTS TABLES AND FIGURES ...................................................... vi ACRONYMS AND ABBREVIATIONS ......................................... vii CHAPTER 1 OVERVIEW .............................................................1 1.1 WHAT IS THE PURPOSE OF THIS DOCUMENT?..........................2 1.2 HOW IS THIS DOCUMENT TO BE USED?................................3 1.3 WHAT ARE THE TITLE V ISSUES RELATED TO THE PRINTING INDUSTRY? 4 1.4 HOW IS THIS REPORT ORGANIZED? ...................................5 CHAPTER 2 TITLE V PERMITTING REQUIREMENTS ...................................13 2.1 WHAT ARE THE TITLE V APPLICABILITY CRITERIA THAT APPLY TO PRINTING FACILITIES?..............................................13 2.1.1 How Can Major Printing Facilities Estimate Potential to Emit? ...............13 2.1.2 What are the Major Source Thresholds? .................................14 2.1.3 How Does One Maintain Minor Source Status? ...........................15 2.1.4 NESHAP Sources ...................................................17 2.1.4.1 How Can I Avoid Being a Major Source Under Subpart KK? ...........17 2.1.4.2 What If an Owner or Operator has a Minor Source Subject to Subpart N? . 18 2.1.5 NSPS Sources ......................................................19 2.2 HOW CAN OWNERS OR OPERATORS OF NEW SOURCES BE EXEMPT FROM TITLE V? ...........................................................19 2.3 WHAT ARE THE APPLICABLE REQUIREMENTS?.......................19 2.3.1 Summary of Applicable Requirements for the Major Printing Technologies .....21 2.3.2 How Can Printing Equipment be Described in a Title V Permit? ..............28 2.3.3 Insignificant Units and Activities .......................................29 CHAPTER 3 MACT STANDARDS PERMITTING ........................................31 3.1 OVERVIEW OF SUBPART KK.........................................31 3.1.1 What Facilities and Equipment Are Subject to Subpart KK? .................31 3.1.2 What Are the Applicable Requirements of Subpart KK? ....................32 3.2 MAINTAINING COMPLIANCE FLEXIBILITY UNDER SUBPART KK .......34 3.3 INTERFACE OF SUBPART KK WITH THE MACT GENERAL PROVISIONS . 34 3.3.1 Who Should Submit a Notification of Compliance Status? ...................34 3.3.2 Who Should Submit Semi-Annual Summary Reports, and When? .............35 3.4 SUBPART JJJJ .......................................................36 3.4.1 What Facilities and Equipment Are Subject to Subpart JJJJ? .................36 3.4.2 What Are the Emissions Limits and Compliance Options for Subpart JJJJ? ......37 3.4.3 What Is the Compliance Schedule for Subpart JJJJ? ........................38 ii CHAPTER 4 MONITORING AND PRACTICAL ENFORCEABILITY ........................40 4.1 WHAT MONITORING IS APPROPRIATE UNDER THE CAM RULE? ........40 4.2 WHAT MONITORING MAY BE AVAILABLE TO DEMONSTRATE COMPLIANCE WITH A PTE LIMIT?....................................41 4.3 HOW CAN MATERIALS MONITORING BE USED TO DEMONSTRATE COMPLIANCE? .....................................................44 4.3.1 How Does a Printer Monitor or Track Material Consumption? ................45 4.3.2 What General Principles Are Relevant To Measuring Material Usage? .........45 4.4 WHAT MAY BE APPROPRIATE OPACITY MONITORING FOR CLEAN FUEL COMBUSTION?.....................................................51 4.5 SPECIFIC ISSUES RELATED TO MONITORING UNDER SUBPART KK .....51 4.5.1 What Are Recommendations for Continuous Parameter Monitoring Systems for Subpart KK? .......................................................51 4.5.2 What Is Our Interpretation of Subpart KK’s CEMS Compliance Options? ......54 CHAPTER 5 TESTING REQUIREMENTS...............................................56 5.1 WHAT ARE SOURCES OF MATERIAL COMPOSITION DATA? ............56 5.2 WHAT ARE THE ISSUES CONCERNING THE USE OF M24 AND M24A WITHIN THE PRINTING INDUSTRY? ..........................................57 5.2.1 For What Printing Materials Does M24 and M24A Apply? ..................58 5.2.2 How Can M24 Be Adjusted for High Water Content Coatings and Inks? ........58 5.2.3 How is the VOC Content to Be Determined for Thin-Film Radiation Cured Inks and Coatings, and Non-Ink Products, Such as Fountain Solutions and Cleaning Compounds? .......................................................59 5.2.4 What Is the Relationship Between Material Composition Testing Under Subpart KK and the MACT Rule General Provisions on Performance Testing? .........60 5.3 ARE NON-LITHOGRAPHIC PROCESSES ELIGIBLE FOR USE OF A RETENTION FACTOR TO ESTIMATE EMISSIONS FROM MANUAL CLEANING ACTIVITIES WHEN USING LOW VAPOR PRESSURE CLEANING SOLVENTS WITH SHOP TOWELS? ....................................61 5.4 UNDER WHAT CONDITIONS CAN METHOD 25A (M25A) BE USED TO DETERMINE THE DESTRUCTION EFFICIENCY OF AN OXIDIZER? ........62 5.5 WHAT GENERAL PRINCIPLES ARE RELEVANT TO PERFORMING CONTROL DEVICE AND CAPTURE EFFICIENCY TESTING? .....................62 5.5.1 Control Device Efficiency Testing ......................................63 5.5.1.1 Initial Control Device Efficiency Testing .......................63 5.5.1.2 Ongoing Control Device Efficiency Testing ....................63 5.5.2 Initial Capture Efficiency Testing ......................................63 5.5.2.1 Liquid-Liquid Material Balance (LLMB) ..........................64 5.5.2.2 Heatset Web Offset Lithographic Printing Presses - Inks and Coatings 64 iii 5.5.2.3 Automatic Blanket Wash Materials and Alcohol Substitutes in Fountain Solution.................................................65 5.5.2.4 Presses Without Add-on Control Devices ......................65 5.5.3 Ongoing Capture Efficiency Testing ....................................65 5.5.3.1 Permanent Total Enclosure ..................................65 5.5.3.2 Other than Permanent Total Enclosure .........................65 5.5.3.3 Examples ....................................................66 5.6 SPECIFIC ISSUES RELATED TO PERFORMANCE TESTS UNDER SUBPART KK ................................................................66 5.7 WHAT ARE THE APPROPRIATE PERFORMANCE TEST CONDITIONS? ...68 5.8 HOW CAN DESTRUCTION EFFICIENCY REQUIREMENTS BE MET DURING PERIODS WITH LOW CONTROL DEVICE INLET CONCENTRATIONS? .....69 CHAPTER 6 ADDITIONAL PERMITTING APPROACHES - STREAMLINING PERMIT CONTENT AND MINIMIZING UNNECESSARY PERMIT REVISIONS .....................70 6.1 OVERVIEW.........................................................70 6.2 STREAMLINING PERMITS FOR PRINTING FACILITIES..................71 6.2.1 What Principles Govern Streamlining? ..................................71 6.2.2 Overlapping Requirements for Printing Facilities ..........................72 6.2.3 How Do Control Strategies Influence Streamlining? ........................73 6.2.3.1 Capture and Control Systems ....................................73 6.2.3.2 Use of Compliant Materials .....................................75 6.2.4 Streamlining Example ...............................................76 6.3 EXISTING PERMIT CONDITIONS RESTRICTING OPERATION ............77 6.3.1 Formula-Based Approaches ...........................................79 6.3.2 Averaging Periods ..................................................81 6.3.3 What is an Example of a Mass-Balance Formula Approach? .................83 6.3.4 Are There Any Limitations to Using Replacement Conditions for the Mass Balance Equation-Based Approach? ...........................................87 CHAPTER 7 REFERENCES...........................................................88 APPENDIX A PRINTING INDUSTRY DESCRIPTION AND RELATIONSHIP TO GUIDANCE . A-1 APPENDIX B EXAMPLE APPLICABLE REQUIREMENTS ................................B-1 APPENDIX C MACT COMPLIANCE OPTIONS FOR COMPLIANCE COATINGS APPROACH . C-1 iv APPENDIX D MONITORING PROTOCOLS FOR THE PRINTING AND FLEXIBLE PACKAGING INDUSTRIES ......................................................... D-1 APPENDIX E EXAMPLE QA/QC PLAN FOR A SOURCE THAT MONITORS MATERIAL USAGE ...............................................................E-1 v TABLES AND FIGURES Tables 1-1. Summary of Approaches For Addressing Title V and Other Permitting Issues for Printers 6 2-1. VOC Emissions Thresholds.................................................15 2-2. SUMMARY OF POTENTIALLY APPLICABLE REQUIREMENTS Product and Packaging Rotogravure or Wide-Web Flexographic (WWF) with Oxidizer Control Strategy ....................................................................22 3-1. Summary of Applicable Requirements for Subpart KK ...........................33 3-2. Summary of Subpart JJJJ Emissions Limits ....................................37 4-1. Example Monitoring Components for a Lithographic Printing Press Subject to a PTE Limit.......................................................................42 4-2. Example Monitoring Components for Subpart KK HAP Limits - Wide Web Flexographic Press Using Compliant Coatings.................................................49 4-3. Example Monitoring Components for Subpart KK HAP Limits – Publication Rotogravure Source Complying by Monthly Liquid-Liquid Mass Balance...........................50 Figures 4-1. Example permit conditions for temperature monitoring devices ....................53 4-2. Example permit conditions for pressure monitoring devices .......................54 6-1. Sample Existing Permit Limits
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