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25 Pa. Code § 129.67a. Control of VOC emissions from flexible packaging printing presses.

§ 129.67a. Control of VOC emissions from flexible packaging printing presses.

 (a)  Applicability.

   (1)  Except as specified in paragraph (3) or (4), this section applies to the owner and operator of a flexible packaging printing press if one or more of the following apply:

     (i)   Potential VOC emissions. An individual flexible packaging printing press has potential emissions from the dryer, before consideration of add-on controls, of at least 25 tpy of VOCs from inks, coatings and adhesives combined. This section supersedes §  129.67 (relating to graphic arts systems).

     (ii)   Actual VOC emissions at or above threshold. The total actual VOC emissions from all inks, coatings and adhesives combined from all flexible packaging printing presses and all VOC emissions from related cleaning activities at the facility are equal to or greater than 450 pounds (204.1 kilograms) per month or 2.7 tons (2,455 kilograms) per 12-month rolling period, before consideration of add-on controls.

     (iii)   Actual VOC emissions below threshold. The total actual VOC emissions from all inks, coatings and adhesives combined from all flexible packaging printing presses and all VOC emissions from related cleaning activities at the facility are less than 450 pounds (204.1 kilograms) per month or 2.7 tons (2,455 kilograms) per 12-month rolling period, before consideration of add-on controls.

   (2)  The owner or operator of a flexographic or rotogravure printing press subject to paragraph (1)(ii) and §  129.67, who was required to install a control device under §  129.67 prior to June 28, 2014, shall continue the operation of that control device and also meet the requirements of this section.

   (3)  VOCs from adhesives used at a facility that are not used or applied on or with a flexible packaging printing press are not subject to this section and may be regulated under §  129.52b, §  129.77 or Chapter 130, Subchapter D (relating to control of VOC emissions from paper, film and foil surface coating processes; control of emissions from the use or application of adhesives, sealants, primers and solvents; and adhesives, sealants, primers and solvents).

   (4)  Surface coating of flexible packaging substrates that is not done with a flexible packaging printing press is regulated under §  129.52b.

 (b)  Existing RACT permit. This section supersedes the requirements of a RACT permit issued to the owner or operator of a source subject to this section prior to January 1, 2015, under § §  129.91—129.95 (relating to stationary sources of NOx and VOCs) to control, reduce or minimize VOCs from a flexible packaging printing press, except to the extent the RACT permit contains more stringent requirements.

 (c)  Emission limits. Beginning January 1, 2015, a person subject to subsection (a)(1)(i) may not cause or permit the emission into the outdoor atmosphere of VOCs from a flexible packaging printing press unless one or more of the following limitations is met:

   (1)  Individual ink, coating or adhesive. The VOC content of each as applied ink, coating or adhesive used on a single flexible packaging printing press meets the following requirements:

     (i)   The VOC content is equal to or less than one or both of the following limits:

       (A)   0.16 lb VOC per lb material as applied.

       (B)   0.8 lb VOC per lb material solids as applied.

     (ii)   The VOC content is calculated as follows for VOC content expressed in units of weight of VOC per weight of material solids:

VOCB = (Wo)/(Wn)

 Where:

 VOCB = VOC content in lb VOC/lb of solids as applied or kg VOC/kg of solids as applied

 Wo = Weight percent of VOC (Wv-Ww-Wex)

 Wv = Weight percent of total volatiles (100%-weight percent solids)

 Ww = Weight percent of water

 Wex = Weight percent of exempt solvents

 Wn = Weight percent of solids of the as applied ink, coating or adhesive

     (iii)   Sampling of the ink, coating or adhesive and testing for the VOC content of the ink, coating or adhesive is performed in accordance with subsection (f).

   (2)  Weighted average. The daily weighted-average VOC content of all inks, coatings and adhesives combined used on a single flexible packaging printing press meets one or both of the VOC content limits in paragraph (1)(i). The use of averaging to meet the VOC content limits may not be used across multiple printing presses. Averaging is available on a single flexible packaging printing press if the following requirements are met:

     (i)   The daily weighted average is calculated using the following equation:

 

 Where:

 VOCw=The daily weighted average VOC content, as applied, of all inks, coatings and adhesives combined used on a single flexible packaging printing press, in lb VOC/gal of coating solids

 n=The number of different inks, coatings and adhesives used each day on the single flexible packaging printing press

 Vi=The volume of solids for each ink, coating and adhesive, as applied, used each day on the single flexible packaging printing press, in gallons

 Ci=The VOC content of each ink, coating and adhesive, as applied, used each day on the single flexible packaging printing press, in lb VOC/gal coating solids

 Vt=The total volume of solids for all inks, coatings and adhesives combined, as applied, used each day on the single flexible packaging printing press, in gallons

     (ii)   Sampling of the inks, coatings and adhesives and testing for the VOC content of the inks, coatings and adhesives is performed in accordance with subsection (f).

   (3)  Add-on air pollution control device. The overall weight of VOCs emitted to the atmosphere from all inks, coatings and adhesives combined used on a single flexible packaging printing press is reduced through the use of vapor recovery or oxidation or another method that is acceptable under §  129.51(a) (relating to general). The overall control efficiency of a control system, as determined by the test methods and procedures specified in subsection (f), may not be less than that listed in Table 1.

Table 1


Overall Control Efficiency Requirement of a Control System on a
Single Flexible Packaging Printing Press
with Potential Emissions ›= 25 tpy of VOC Before Control


Control System
Overall Control
Efficiency
Printing Press
First Installation Date1
Air Pollution Control Device
First Installation Date1
Requirement Prior to On or after Prior to On or after
March 14, 1995* March 14, 1995* January 1, 2015** January 1, 2015**
›= 65% X X
›= 70% X X
›= 75% X X
›= 80% X X

 1 First installation date is the first date of operation for a source or a control device. This date does not change if the source or control device is moved to a new location or if the control device is later used to control a new source.

 * March 14, 1995, is the date of the proposed 1996 NESHAP for the printing and publishing industry.

 ** January 1, 2015, is the compliance date of the flexible packaging printing press regulation.

   (4)  Restriction on potential VOC emissions. The Department has issued a plan approval, operating permit or Title V permit to the owner or operator prior to January 1, 2015, establishing a Federally-enforceable limitation to limit the potential emissions of VOC from the flexible packaging printing press below 25 tpy before consideration of add-on controls.

 (d)  Compliance and monitoring requirements for an add-on air pollution control device. The owner or operator of a flexible packaging printing press subject to subsection (a)(1)(i) using an add-on air pollution control device in accordance with subsection (c)(3) shall comply with the following requirements:

   (1)  The add-on air pollution control device shall be equipped with the applicable monitoring equipment and the monitoring equipment shall be installed, calibrated, operated and maintained according to manufacturer’s specifications at all times the add-on air pollution control device is in use. If the add-on air pollution control device is a:

     (i)   Noncatalytic thermal oxidizer, the minimum combustion or operating temperature must be continuously monitored. The temperature reading shall be recorded in accordance with subsection (e)(1) at least once every 15 minutes while the noncatalytic thermal oxidizer is operating.

     (ii)   Catalytic thermal oxidizer:

       (A)   The inlet gas temperature must be continuously monitored. The temperature reading shall be recorded in accordance with subsection (e)(1) at least once every 15 minutes while the catalytic thermal oxidizer is operating.

       (B)   A catalyst activity test shall be performed a minimum of one time per rolling 2-year period.

     (iii)   Control device other than that specified in subparagraph (i) or (ii), parameters specific to the control device must be continuously monitored. The parameters shall be recorded in accordance with subsection (e)(1) at least once every 15 minutes while the control device is operating.

   (2)  The add-on air pollution control device specified in paragraph (1) shall be operated at a 3-hour average temperature not lower than 50°F below the average temperature demonstrated during the most recent compliant source test approved by the Department.

   (3)  The add-on air pollution control device specified in paragraph (1) shall be in operation at all times that the source is operating.

   (4)  The add-on air pollution control device shall be approved, in writing, by the Department in a plan approval, operating permit or Title V permit prior to use.

 (e)  Recordkeeping and reporting requirements. Beginning January 1, 2015, the owner or operator of a flexible packaging printing press subject to this section shall maintain records sufficient to demonstrate compliance with the requirements of this section. Records maintained for compliance demonstrations may include purchase, use, production and other records.

   (1)  An owner or operator subject to subsection (a)(1)(i) using an add-on air pollution control device shall maintain records sufficient to demonstrate compliance with subsection (d), including records of the following information:

     (i)   Temperature reading of the add-on air pollution control device.

     (ii)   Maintenance performed on the add-on air pollution control device and monitoring equipment, including the date and type of maintenance.

     (iii)   Catalyst activity test performed, if applicable.

   (2)  An owner or operator subject to subsection (a)(1)(i) not using an add-on air pollution control device shall maintain records of the as applied VOC content of inks, coatings and adhesives sufficient to demonstrate compliance with the limitations under subsection (c)(1) or (2).

   (3)  An owner or operator claiming exemption from a VOC control provision of this section based on potential or actual VOC emissions, as applicable, shall maintain records that demonstrate to the Department that the press or facility is exempt.

   (4)  The owner or operator may group materials into classes using the highest VOC content in any material in a class to represent that class of material.

   (5)  The records required under paragraphs (1)—(4) shall be maintained for 2 years, unless a longer period is required by a plan approval or operating permit issued under Chapter 127 (relating to construction, modification, reactivation and operation of sources). The records shall be submitted to the Department in an acceptable format upon receipt of a written request.

   (6)  The owner or operator of a flexible packaging printing press subject to subsection (a)(1)(i) that is required to demonstrate overall control efficiency in accordance with subsections (c)(3) and (d) shall submit reports to the Department in accordance with Chapter 139 (relating to sampling and testing).

 (f)  Sampling and testing.

   (1)  Sampling and testing shall be performed as follows:

     (i)   Sampling of an ink or coating and testing for the VOC content of the ink or coating shall be performed in accordance with the procedures and test methods specified in Chapter 139.

     (ii)   Sampling and testing of an add-on air pollution control device shall be performed in accordance with the procedures and test methods specified in Chapter 139 and meet one of the following:

       (A)   Sampling and testing shall be performed no later than 180 days after the compliance date of the press.

       (B)   Sampling and testing shall have been performed within 5 years prior to January 1, 2015, and previously approved by the Department. Capture efficiency retesting may be waived for capture systems that are not permanent total enclosures if the operating parameters indicate that a fundamental change has not taken place in the operation or design of the equipment, unless retesting is required under Subpart C, Article III (relating to air resources) or a plan approval, operating permit or an order issued by the Department. For purposes of this clause, fundamental changes include adding printing stations to a press, increasing or decreasing the volumetric flow rate from the dryer or changing the static duct pressure.

   (2)  The overall control efficiency of the add-on air pollution control device shall be determined by the following test methods and procedures subject to prior written approval by the Department.

     (i)   The capture efficiency shall be determined in accordance with either of the following methods:

       (A)   40 CFR Part 51, Appendix M, Methods 204—204F, including updates and revisions.

       (B)   40 CFR Part 63, Subpart KK, Appendix A (relating to data quality objective and lower confidence limit approaches for alternative capture efficiency protocols and test methods).

     (ii)   The control efficiency shall be determined using one or more of the following methods, as applicable. The method used to measure the inlet concentration of VOC may be the same method used to determine the outlet concentration of VOC unless use of the same method is determined to be technically infeasible.

       (A)   EPA Reference Method 25, Determination of Total Gaseous Nonmethane Organic Emissions as Carbon, codified in 40 CFR Part 60, Appendix A, including updates and revisions. EPA Reference Method 25 may be used if the total gaseous nonmethane organic compound concentration is equal to or greater than 50 parts per million by volume, measured as carbon.

       (B)   EPA Reference Method 25A, Determination of Total Gaseous Organic Concentration Using a Flame Ionization Analyzer, codified in 40 CFR Part 60, Appendix A, including updates and revisions. EPA Reference Method 25A may not be used if the total gaseous nonmethane organic compound concentration at the outlet of the add-on air pollution control device is equal to or greater than 50 parts per million by volume, measured as carbon.

       (C)   EPA Reference Method 18, Measurement of Gaseous Organic Compound Emissions by Gas Chromatography, codified in 40 CFR Part 60, Appendix A, including updates and revisions. EPA Reference Method 18 may be used if the total gaseous nonmethane organic compound concentration is equal to or greater than 50 parts per million by volume, measured as carbon. EPA Reference Method 18 may be used in conjunction with EPA Reference Method 25A to subtract emissions of exempt VOCs.

   (3)  Other test methods demonstrated to provide results that are acceptable for purposes of determining compliance with this section may be used if prior approval is obtained in writing from the Department and the EPA.

 (g)  Work practice requirements for cleaning activities.

   (1)  Except as specified in paragraph (3), beginning January 1, 2015, the owner or operator of a flexible packaging printing press subject to subsection (a)(1)(i), (1)(ii) or (2) shall comply with the following work practices for cleaning activities at the facility:

     (i)   Store all VOC-containing cleaning solutions, waste cleaning solutions and used shop towels in closed containers.

     (ii)   Ensure that mixing vessels and storage containers used for VOC-containing cleaning solutions, waste cleaning solutions and used shop towels are kept closed at all times, except when depositing or removing these solutions or shop towels.

     (iii)   Minimize spills of VOC-containing cleaning solutions and waste cleaning solutions and clean up spills immediately.

     (iv)   Convey VOC-containing cleaning solutions, waste cleaning solutions and used shop towels from one location to another in closed containers or pipes.

   (2)  The requirements in paragraph (1) apply to the following activities:

     (i)   Cleaning of ink, coating or adhesive from a press.

     (ii)   Cleaning of ink, coating or adhesive from press parts, including press parts that have been removed from the press for cleaning.

     (iii)   Cleaning of ink, coating or adhesive from areas around a press.

   (3)  The requirements in paragraph (1) do not apply to the following activities:

     (i)   Cleaning electronic components of a press.

     (ii)   Cleaning in pre-press (for example, platemaking) operations.

     (iii)   Cleaning in post-press (for example, binding) operations.

     (iv)   Using janitorial supplies (for example, detergents or floor cleaners) for general cleaning around a press.

     (v)   The use of parts washers or cold cleaners at a flexible packaging printing facility. The use of parts washers and cold cleaners is regulated under §  129.63 (relating to degreasing operations).

Authority

   The provisions of this §  129.67a issued under section 5(a)(1) and (8) of the Air Pollution Control Act (35 P.S. §  4005(a)(1) and (8)).

Source

   The provisions of this §  129.67a adopted June 27, 2014, effective June 28, 2014, 44 Pa.B. 3929.

Cross References

   This section cited in 25 Pa. Code §  121.1 (relating to definitions); 25 Pa. Code §  129.51 (relating to general); 25 Pa. Code §  129.67 (relating to graphic arts systems); 25 Pa. Code §  129.96 (relating to applicability); and 25 Pa. Code §  129.111 (relating to applicability).



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