PR4Flexographic, packaging rotogravure, and publication rotogravure printing linesusing a capture and control system [OAC rule 3745-21-09(Y)(1)(b)]

Terms Last Revised: 3/18/16

These terms apply to a facility with printing line(s) where:

1.the total maximum usage of coatings and inks in all flexographic, packaging rotogravure, and publication rotogravure printing lines ismore than 148 TPY; or

2.the total maximum usage of VOC in all coatings and inks employed in all flexographic, packaging rotogravure, and publication rotogravure printing lines is more than100 TPY.

[from exemptions in OAC rule 3745-21-09(Y)(2)(b) and (d)]

Note:These terms only cover the requirements of OAC rule 3745-21-09(Y)(1) through (3); the facility might also be subject to national emission standards and work practices for the printing and publishing industry.

Note:Packaging rotogravure printing lines and flexographic packaging printing lines located in Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, and Summit counties, with potential emissions (before control) greater than 25 tons of VOC per year, are also subject to the requirements of OAC rule 3745-21-09(Y)(4), see terms “PR2”.

Additional Terms and ConditionsCollection and control requirements

For a flexographicprinting line use this term:

  1. The VOC collection and control system for the flexographic printing line(s) shall have a capture efficiency of at least 65% by weight and a total control efficiency of at least 90% by weight, both determined using the methods identified in OAC rule 3745-21-10(C)(2) and under the conditions identified in OAC rule 3745-21-10(C)(3).

[OAC rule 3745-21-09(Y)(1)(b)]

For a packaging rotogravure printing line use this term:

  1. The VOC collection and control system for the packaging rotogravure printing line(s) shall have a capture efficiency of at least 70% by weight and a total control efficiency of at least 90% by weight, both determined using the methods identified in OAC rule 3745-21-10(C)(2) and under the conditions identified in OAC rule 3745-21-10(C)(3).

[OAC rule 3745-21-09(Y)(1)(b)]

For a publication rotogravure printing line use this term:

  1. The VOC collection and control system for the publication rotogravure printing line(s) shall have a capture efficiency of at least 80% by weight and a total control efficiency of at least 90% by weight, both determined using the methods identified in OAC rule 3745-21-10(C)(2) and under the conditions identified in OAC rule 3745-21-10(C)(3).

[OAC rule 3745-21-09(Y)(1)(b)]

Operational Requirements

(1)The permittee shall install and operatecontinuous monitoring and recording devices for either temperature or VOC concentration. The continuous monitoring and recording devices shall be capable of accurately measuring the desired parameter and shall be operated and maintained in accordance with the manufacturer's recommendations.

[OAC rule 3745-21-09(B)(3)(n)]

Recordkeeping Requirements

(1)The permittee shall collect and record the following information each day for the control equipment and maintain the information at the facility for a period of three years:

  1. A log of operating time for the capture (collection) system, control device, monitoring equipment, and the associated coating line or printing line.
  2. For a thermal incinerator, all 3-hour periods of operation during which the average combustion temperature was more than 50 degrees Fahrenheit below the average combustion temperature measured during the most recent performance test that demonstrated the printing lineto be in compliance.
  3. For a catalytic incinerator, all 3-hour periods of operation during which the average temperature of the process vent stream immediately before the catalyst bed is more than 50 degrees Fahrenheit below the average temperature of the process vent stream measured during the most recent performance test that demonstrated the printing line to be in compliance; and all 3-hour periods of operation during which the average temperature difference across the catalyst bed is less than 80% percent of the average temperature difference measured during the most recent performance test that demonstrated the printing lineto be in compliance.
  4. For a carbon adsorber, all 3-hour periods of operation during which the average VOC concentration or reading of organics in the exhaust gases is more than 20% greater than the average exhaust gas concentration or reading measured by the organics monitoring device during the most recent determination of the recovery efficiency of the carbon adsorber that demonstrated the printing lineto be in compliance.

[OAC rule 3745-21-09(B)(3)(l)]

(2)The permittee shall maintain the records of the results from the stack testing conducted to demonstrate compliance with the capture and control efficiencyof each of the subject flexographic, packaging rotogravure, and publication rotogravure printing line(s), and the records documenting the VOC content of each coating and ink applied in each printing line.

[for OAC rule 3745-21-09(Y)(1)(b)]

(3)The permittee shall collect and record the following information each month and shall maintain the information at the facility for 5 years:

  1. the company identification for each coating, ink, and cleanup material employed in the flexographic, packaging rotogravure, and publication rotogravure printing line(s);
  2. the number of gallons or pounds of each coating and ink employed in the flexographic, packaging rotogravure, and publication rotogravure printing line(s) during the month;
  3. the number of gallons or pounds of each cleanup material employed in the flexographic, packaging rotogravure, and publication rotogravure printing line(s) during the month;
  4. the VOC content of each coating, ink, and cleanup material employed in the flexographic, packaging rotogravure, and publication rotogravure printing line(s), in pounds per gallon or percent by weight;
  1. the total uncontrolled VOC emissionsfrom the coatings and inks employed during the month in each flexographic, packaging rotogravure, and publication rotogravure printing line, i.e., the summation of the products obtained from multiplying“b” times “d” above, for all the coatings and inks applied, in pounds per month for each line;
  2. the total controlled VOC emissions from all coatings and inksemployed during the month in each flexographic, packaging rotogravure, and publication rotogravure printing line, i.e., “e” x (1 - the overall control efficiency of the capture system and control device), as determined during the most recent emission tests that demonstrated the/eachprinting lineto be in compliance;
  3. the VOC emissions from cleanup materials employed in the flexographic, packaging rotogravure, and publication rotogravure printing line(s), i.e., the summation of the products obtained from multiplying “c” times “d” above, for all the cleanup materials applied, in pounds per month for the subject printing line(s);
  4. following the first 12 months or full year of printing operations, the annual VOC emissions, in tons; i.e., the summation of the 12 month emissions from all coatings, inks, and cleanup materials applied, as recorded in “f” and “g” above, divided by 2,000 lbs/ton, in tons per year or per rolling 12 months.

[for OAC rule 3745-21-09(Y)(1)(b)] and [OAC rule 37451503]

Reporting Requirements

Permit Evaluation Reporting (PER) Requirements for non-TV PTIOs (see the “RPT” term for a TV quarterly report)

(1)The permittee shall submit an annual Permit Evaluation Report (PER) to the Ohio EPA District Office or Local Air Agency by the due date identified in the Authorization section of this permit. The permit evaluation report shall cover a reporting period of no more than twelve-months for each air contaminant source identified in this permit. It is recommended that the PER is submitted electronically through the Ohio EPA’s “e-Business Center: Air Services” although PERs can be submitted via U.S. postal service or can be hand delivered. The permittee shall include any deviations from the capture and control efficiency requirements and/or any parameter limitation on the control device(s) for the flexographic, packaging rotogravure, and publication rotogravure printing lines.

[OAC rule 37451503(B)(2)] and [OAC rule 37451503(D)]

Permit Evaluation Reporting (PER) Requirements for FEPTIOs

(2)The permittee shall submit an annual Permit Evaluation Report (PER) to the Ohio EPA. The PER must be completed electronically and submitted via the Ohio EPA eBusiness Center: Air Services by the due date identified in the Authorization section of this permit. The permit evaluation report shall cover a reporting period of no more than twelve-months for each air contaminant source identified in this permit. The permittee shall include any deviations from the capture and control efficiency requirements and/or any parameter limitation on the control device(s) for the flexographic, packaging rotogravure, and publication rotogravure printing lines.

[OAC rule 37451503(B)(2)] and [OAC rule 37451503(D)]

Reporting Requirements for Quarterly Summaries

(1)The permittee shall submit quarterly summaries of the records required by OAC 3745-21-09(B)(l), for the operating time and 3-hour average temperatures or VOC concentrations monitored during the calendar quarter. These quarterly reports shall be submitted by April 30th, July 31st, October 31st, and January 31st, and shall cover the records for the previous calendar quarters.

[OAC rule 3745-21-09(B)(3)(m)]and [for OAC rule 3745-21-09(Y)(1)(b)]

Testing Requirements for the capture and control efficiency

Note:Also see terms J34 and J35 for permanent and temporary total enclosure terms and options for capture efficiency.

Fill in XXXX’s below:

Note:The testing frequency can be modified as appropriate in “a” of this term

XXXX1Specify any other limitation contained in the permit, i.e. the hourly VOC limit and/or PM limit (delete Method 5 if there is no PM limit).

(1)Emission Limitation:

Reduce VOC emissions from the flexographic, packaging rotogravure, and/or publication rotogravure printing line(s) by a minimum of 90% by weight; with a capture efficiency, by weight, of no less than: 65% for the flexographic printing line(s), 70% for the packaging rotogravure printing line(s), and 80% for the publication rotogravure printing line(s).

Applicable Compliance Method:

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the following requirements:

  1. The emission testing shall be conducted within 60 days of achieving the maximum production rate at which the emissions unit(s) will be operated, but not later than 180 days after initial startup and as required by the Director.
  2. The emission testing shall be conducted to demonstrate compliance with the capture efficiency, the control efficiency, the VOC limitation, and[XXXX1].
  3. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission rate(s) and the capture and control efficiencies:
  4. For capture efficiency, unless determined otherwise by the Director (regulating District Office or local air agency):

Methods 204 A through F, as appropriate, from 40 CFR Part 51, Appendix M

  1. The mass emissions of VOC as carbon shall be employed in the control efficiency determination; for VOC concentration in the gas stream and exhaust vent:

Method 25A, from 40 CFR Part 60, Appendix A

  1. For sampling and velocity traverses:

Method 1, from 40 CFR Part 60, Appendix A

  1. For stack gas velocity and volumetric flow rate:

Method 2, from 40 CFR Part 60, Appendix A

  1. For gas analysis for carbon dioxide, oxygen, excess air, and dry molecular weight:

Method 3, from 40 CFR Part 60, Appendix A

  1. For moisture content inthe stack gases:

Method 4, from 40 CFR Part 60, Appendix A

  1. For particulate emissions:

Method 5, 40 CFR Part 60, Appendix A

  1. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.
  1. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless otherwise specified or approved by the appropriate Ohio EPA District Office or local air agency.
  1. The VOC emission rateshall be based upon the average of three test runs. Each run shall have aminimum duration of one hour and a minimum sample volume of .003 drystandard cubic meter. Gas stream samplesshall be taken simultaneously at the inlet and the outlet of the vapor controlsystem.
  2. The total mass emission rate of VOC from the printing line(s) shall be the sum of VOC emissions from the vapor control system, VOC emissions not collected by the vapor collection system, andVOC emissions from any losses associated with the vapor collection systemand vapor control system.
  1. The capture efficiency of the vapor collection system shall be the percent of total mass emissions of VOC from the printing line(s) that are captured and vented to the vapor control system.
  2. The control efficiency of the control device (vapor control system) shall be the percent reduction in mass emissions of VOC between the inlet and the outlet of the control device.
  1. The overall control efficiency (in percent) for VOC shall be the vapor capture efficiency multiplied by the vapor control efficiency, divided by one hundred.
  1. The permittee may request to use an alternative method or procedure for the determination of capture efficiency in accordance with the USEPAGuidelines for Determining Capture Efficiency,” dated January 9, 1995. (The Ohio EPA will consider the request, including an evaluation of the applicability, necessity, and validity of the alternative, and may approve the use of the alternative if such approval does not contravene any other applicable requirement.)
  2. Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test" notification to the appropriate Ohio EPA District Office or local air agency. The "Intent to Test" notification shall describe in detail the proposed test methods and procedures, the emissions unit operating parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA District Office's or local air agency's refusal to accept the results of the emission test(s).
  3. Personnel from the appropriate Ohio EPA District Office or local air agency shall be permitted to witness the test(s), examine the testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the performance of the control equipment.
  4. A comprehensive written report on the results of the emissions test(s) shall be signed by the person or persons responsible for the tests and submitted to the appropriate Ohio EPA District Office or local air agency within 30 days following completion of the test(s). The permittee may request additional time for the submittal of the written report, where warranted, with prior approval from the appropriate Ohio EPA District Office or local air agency.

[OAC rule 3745-21-10(C)(2)and (3)] and[for OAC rule 3745-21-09(Y)(1)(b)]