25 Pa. Code § 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:
Click to view image
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
Part I, 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).
Notes
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)).
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