PERMIT TO CONSTRUCT/OPERATE EVALUATION
Lithographic Printing Press (new construction)

Applicant's Name:

ACME Lithographic

Company ID No.:

12345

Mailing Address:

123 Industrial Park, Santa Ana, California 92345

Equipment Address:

123 Industrial Park, Santa Ana, California 92345
EQUIPMENT DESCRIPTION:

PRINTING PRESS, LITHOGRAPHIC, RYOBI LIMITED, SHEET-FED, OFFSET, MODEL NO. 685-D, SERIAL NO. 604665, FIVE-COLOR, 27-INCH WIDTH, 24-HP. TOTAL, WITH ELECTRIC HEAT SOURCE, AND INFRARED LAMPS, 47 KW TOTAL.

HISTORY:

ACME submitted this application to the District on October 1, 1999. There is no other permitted equipment at this facility. The applicant requested a maximum facility-wide VOC emission limit of 22 lb/day, or 667 lbs/month. Although the VOC actual emissions are not expected to increase significantly, increasing the maximum potential-to-emit will allow for future operations flexibility. They had also requested a facility-wide emission limit of 22 lb/day. In order to do so, the existing permit to operate under PO #D17552 (A/N 202694) will be reissued. This facility is located in sensitive receptor zone no. 1. The company is a small business with only one facility in the District.

PROCESS DESCRIPTION:

The facility is a commercial printing shop. Their products are primarily color brochures, reports and magazines. They will be using low-VOC printing inks, and an aqueous coating. This lithographic printing press will have an electric-heat source and infrared lamps to dry the inks. The facility is not using any add-on air pollution control equipment. The press that is heat-set has the printed items passed through a drying oven. The exhaust from this oven is vented to a catalytic oxidizer to control the VOC emissions. Natural gas is used during the startup of the burners, which operate within a temperature range of 650 to 800° F. The printing presses will be operated an average of 8 hours/day, 5 days/week, and 52 weeks/year (max of 24 hrs/day, 5 days/wk, and 52 wks/yr).

EMISSION CALCULATIONS:

VOC emissions are expected from the evaporation of solvents contained in the printing inks, fountain solutions, and blanket wash. The applicant has requested that a maximum amount of VOC emissions at 22 lbs/day (667 lbs/month) be granted for this equipment. As shown on the appended emission calculation sheets, the VOC emissions associated with the printing inks was based upon the maximum allowable VOC content under Rule 1130, 300 grams per liter of material. Also, using this and the maximum daily material usage provided by the applicant, the total VOC emissions were scaled up to the requested facility-wide limit of 22 lbs/day. These values will be used for NSR entries, and will be used as the basis for permit conditions.

RULES/REGULATION EVALUATION:

RULE 212, PUBLIC NOTIFICATION

PARAGRAPH 212(c)(1):

This paragraph requires a public notice for all new or modified permit units that may emit air contaminants located within 1,000 feet from the outer boundary of a school. According to the 1999 Thomas Guide, CD-ROM, (Los Angeles and) Orange County(ies) Edition, page 829, grid G7, there is no school within the 1,000 feet of the permit unit boundary. Therefore, public notice will not be required by this paragraph.

PARAGRAPH 212(c)(2):

The equipment modification will not result in on-site emission increases exceeding the daily maximums for VOC emissions as specified in Rule 212(g). Therefore, a 30-day public notice period will not be required under this paragraph.

PARAGRAPH 212(c)(3):

See Rule 1401 evaluation section.

RULE 401, VISIBLE EMISSIONS

With the proper use of the printing press and IR lamps, no visible emissions are expected.

RULE 402, NUISANCE

With the proper operation of the printing press and IR lamps, no nuisance problems are expected at this facility. The facility is located within a commercial-residential area.

RULE 1130, GRAPHIC ARTS

All of printing inks used in the above presses will be below the 300 g/l, less water and exempt compound, VOC limit for printing inks, as required by paragraph (c)(1). The fountain solution will contain less than the 100 g/l VOC requirement of paragraph (c)(2). Compliance with this rule is expected.

RULE 1171, SOLVENT CLEANING OPERATIONS

ACME will be using blanket wash and roller washes containing no greater than ~800 g VOC/L and a composite vapor pressure less than 9.4 mmHg @ 20° F, which is less than the 900 g/L and 35 mmHg requirements under clause (c)(1)(D)(iii). Therefore, compliance with this rule is expected.

REGULATION XIII

RULE 1303(a), BEST AVAILABLE CONTROL TECHNOLOGY (BACT)

The present BACT guidelines require that lithographic printing press operations, heat-set, include use of low-VOC inks, fountain solutions with low vapor pressure and <8% VOC content by volume. (See attached BACT Report Form for one Heidelberg, lithographic print press at Brothers Printing Company.) ACME will be using such material.

RULE 1303(b)(1), MODELING

There are presently no modeling requirements for VOC emissions. Therefore, no modeling requirements will apply to this equipment.

RULE 1304(c)(1), offset exemptions

The operation of this lithographic printing press will result in a maximum VOC emissions of 22 lbs/day. As there were 4 lbs of VOC (converted) per day associated with the previous permit, the will be a net increase of 18 lbs/day from this application. Yet, t This is within the limits specified in Table A of Rule 1304(d). Therefore, ACME will be exempt from providing emission offsets.

RULE 1401, NEW SOURCE REVIEW OF TOXIC AIR CONTAMINANTS

According to the Material Safety Data Sheets (MSDS) that were submitted with this application, ACME will be using materials that contain toxic air contaminants identified in Table 1 of Rule 1401, with an effective date of August 13, 1999 or earlier. Ammonia is contained in the aqueous coatings, ethylene glycol monobutyl ether (2-butoxyethanol) is contained in fountain solution and blanket and/or roller wash. Toluene and xylene are contained in the blanket and/or roller wash. However, based upon the maximum emission rates of these compounds, the MICRs, chronic and acute Hazard Indices (where applicable) do not exceed the thresholds given in Rule 1401(d). Therefore, these operations are expected to meet the requirements of this rule. In addition, there will be a permit condition disallowing the use of materials that contain toxic air contaminants identified in Rule 1401, as amended on August 13, 1999, with the exception of the four compounds listed above. See the emissions calculations sheet.

Also, according to MSDS provided by the applicant for the materials that will be used within this equipment, the operation of this equipment will not result in the release of any other carcinogenic air contaminants. The operation of this equipment, therefore, is expected to comply with Rule 1401 requirements. The applicant will be limited by permit condition to use only materials in the printing operations which do not contain carcinogenic air contaminants identified in Rule 1401, as amended on December 7, 1990.

Following are calculations for emission rates of EGBE, toluene and xylene:

 

CONCLUSIONS/RECOMMENDATIONS:

As discussed above, this equipment is expected to comply with all the AQMD Rules and Regulations when properly operated. The applicant is in agreement with the permit conditions as shown on the sample permit to construct. Therefore, the issuance of the permit to construct/operate is recommended with the conditions as listed on the sample permit.

1. Printing Ink Usage and VOC Emissions

For VOC emission calculations, the following equation is used:

VOC (lbs/day) = Material VOC Content (lbs/gal)*Ink Usage (gals/day)*EF

There is heat supply for drying for which the emission factor (EF) = 80% (IR lamps)

Ink

VOC Content

Usage

VOC Emissions

Lbs/gal

Gms/L

Max (gals.day)

Ave (Gals/day)

Max (lbs/day)

Ave (lbs/day)

Printing inks, max

2.5

300

0.70

0.40

1.40

0.80

Gloss overprint varn, max

2.5

300

3.00

0.10

6.00

0.20

Coating, aqueous

0.07

9

3.00

0.50

0.18

0.03

Total

N/A

6.70

1.00

7.58

1.03


2. Fountain Solution Usage and VOC Emissions

For VOC emission calculations, the following equation is used:

VOC (lbs/day) = Material VOC Content (lbs/gal)* Material Usage (gals/day)

Material

Material density (lbs/gal)

VOC Content (lbs/gal)

Max mat'l usage (gals/day)

Qty of VOC (gals/day)

VOC emissions

Lbs/day

Gms/day

Fountain Solution Concentration

8.80

1.70

0.50

0.85

0.85

386

Water

0.00

0.0

10.00

0.00

0.00

 

Total

 

10.50

0.85

0.85

386

The weight VOC content of the fountain solution as applied is: 9.71 gms/liter
The volume VOC content of the fountain solution as applied is: 8.10%

3. Clean-up of Solvent and VOC Emissions

For VOC emissions calculations, the following equation is used.

VOC (lbs/day) = Material VOC Content (lbs/gal) * Solvent Usage (gals/day)

Clean up solvent

VOC Content

Usage

VOC emissions

Lbs/gal

Gms/l

Max (gals/day)

Avg (gals/day)

Max (lbs/day)

Ave (lbs/day)

Blanket wash

5.94

713

1.00

0.50

5.94

2.97

Roller wash, max

6.60

792

0.50

0.20

3.30

1.32

Total

 

1.50

0.70

9.24

4.29

4. Summary of VOC Emissions

(a) Operating Schedule

Average

Maximum

8 hrs/day

24 hrs/day

5 days/wk

5 days/wk

23 days/month

23 days/month

52 weeks/yr

52 weeks/yr

(b) Emissions Summary

Values as per supplied usages

NSR

AEIS

Lbs/hr

Lbs/day

30 day

Lbs/hr

Lbs/yr

2.250

18

14

0.771

1,604

The above emissions are based upon material usage provided by the applicant. However, the values entered into the NSR database will reflect a facility-wide VOC emissions of 22 lbs/day or 667 lb/month, as allowed under Rule 1304(d).

Values as requested for NSR purposes (facility bubble)

NSR

AEIS

Lbs/hr

Lbs/day

30 day

Lbs/hr

Lbs/yr

3.536

28

22

1.212

2,521


Permit To Construct/Operate

 

Equipment Location: 123 Industrial Park, Santa Ana, California 92707

Equipment Description:

PRINTING PRESS, LITHOGRAPHIC, RYOBI LIMITED, SHEET-FED, MODEL NO. 685-D, FIVE-COLOR,
27-INCH WIDTH, WITH ELECTRIC HEAT SOURCE, AND INFRARED LAMPS, 47 KW TOTAL.

Conditions:

1) OPERATION OF THIS EQUIPMENT SHALL BE CONDUCTED IN ACCORDANCE WITH ALL DATA AND SPECIFICATIONS SUBMITTED WITH THE APPLICATION UNDER WHICH THIS PERMIT IS ISSUED UNLESS OTHERWISE NOTED BELOW.

2) THIS EQUIPMENT SHALL BE PROPERLY MAINTAINED AND KEPT IN GOOD OPERATING CONDITION AT ALL TIMES.

3) THIS EQUIPMENT SHALL BE OPERATED IN COMPLIANCE WITH RULES 1130 AND 1171.

4) THE TOTAL QUANTITY OF VOLATILE ORGANIC COMPOUND (VOC) EMISSIONS FROM ALL PERMITTED EQUIPMENT AND ASSOCIATED OPERATIONS SHALL BE LESS THAN 667 POUNDS IN ANY CALENDAR MONTH. ASSOCIATED OPERATIONS SHALL INCLUDE, BUT NOT BE LIMITED TO, SURFACE PREPARATION, EQUIPMENT CLEAN-UP, AND THE APPLICATION OF ANY OTHER MATERIALS TO PARTS THAT ARE SUBSEQUENTLY PROCESSED IN THE PERMITTED EQUIPMENT.

5) THE FOUNTAIN SOLUTION USED IN THIS EQUIPMENT SHALL NOT CONTAIN MORE THAN EIGHT PERCENT (8%) BY VOLUME OF VOLATILE ORGANIC COMPOUNDS, AS APPLIED.

6) MATERIAL SAFETY DATA SHEETS FOR ALL PRINTING MATERIALS AND OTHER VOC-CONTAINING MATERIALS USED AT THIS FACILITY SHALL BE KEPT CURRENT, AND SHALL BE MADE AVAILABLE TO DISTRICT PERSONNEL UPON REQUEST.

7) ALL PRINTING MATERIALS, INCLUDING INKS AND OTHER VOC-CONTAINING MATERIALS, USED IN THIS EQUIPMENT SHALL NOT CONTAIN ANY TOXIC AIR CONTAMINANTS IDENTIFIED IN TABLE I OF RULE 1401, WITH AN EFFECTIVE DATE OF AUGUST 13, 1999, OR EARLIER, WITH THE EXCEPTION OF AMMONIA, ETHYLENE GLYCOL MONOBUTYL ETHER (2-BUTOXYETHANOL), TOLUENE AND XYLENE.

8) THE OPERATOR SHALL COMPLY WITH RULE 109 (RECORDKEEPING FOR VOLATILE ORGANIC COMPOUND EMISSIONS).

9) IN ADDITION TO THE RECORDKEEPING REQUIREMENTS FOR RULE 109, THE OPERATOR SHALL KEEP ADEQUATE RECORDS FOR THE EQUIPMENT TO VERIFY THE FOLLOWING ON A MONTHLY BASIS:

A. DENSITY OF EACH INK IN POUNDS PER GALLON

B. THE PERCENTAGE BY WEIGHT OF LITHOGRAPHIC OILS IN EACH INK.

C. THE INK ABSORPTION FACTOR, AS SPECIFIED BY CURRENT DISTRICT GUIDELINES.

D. THE VOC CONTENT OF FOUNTAIN SOLUTIONS, WASH MATERIALS AND ANY OTHER MATERIALS USED, IN POUNDS PER GALLON AS APPLIED, INCLUDING WATER AND EXEMPT COMPOUNDS.

E. THE MONTHLY VOC EMISSIONS, IN POUNDS.

F. OTHER DATA AS REQUIRED TO VERIFY COMPLIANCE WITH THE CONDITIONS SPECIFIED IN THIS PERMIT. ALL RECORDS SHALL BE PREPARED IN A FORMAT THAT IS ACCEPTABLE TO THE DISTRICT, AND SHALL BE MADE AVAILABLE UPON THE REQUEST OF THE EXECUTIVE OFFICER, OR HIS REPRESENTATIVE.

10) WITHIN 14 CALENDAR DAYS AFTER THE END OF EACH MONTH, THE OPERATOR SHALL TOTAL AND RECORD VOC EMISSIONS FOR THE MONTH FROM ALL EQUIPMENT COVERED BY THE MONTHLY LIMIT. THE RECORD SHALL INCLUDE ANY PROCEDURES USED TO ACCOUNT FOR CONTROL DEVICE EFFICIENCIES AND/OR WASTE DISPOSAL. IT SHALL BE SIGNED AND CERTIFIED FOR ACCURACY BY THE HIGHEST RANKING INDIVIDUAL RESPONSIBLE FOR COMPLIANCE WITH DISTRICT RULES.

11) THE OPERATOR SHALL MAINTAIN A SINGLE LIST THAT INCLUDES ONLY THE NAME AND ADDRESS OF EACH PERSON FROM WHOM THE FACILITY ACQUIRED VOC-CONTAINING MATERIAL REGULATED BY THE DISTRICT THAT WAS USED OR STORED AT THE FACILITY DURING THE PRECEDING 12 MONTHS.

12) THE OPERATOR SHALL RETAIN FOR 36 MONTHS ALL PURCHASE INVOICES FOR ALL VOC-CONTAINING MATERIAL USED OR STORED AT THE FACILITY, AND ALL WASTE MANIFESTS FOR ALL WASTE VOC-CONTAINING MATERIAL REMOVED FROM THE FACILITY.

13) ALL RECORDS REQUIRED BY THIS PERMIT SHALL BE RETAINED AT THE FACILITY FOR 36 MONTHS, AND SHALL BE MADE AVAILABLE TO ANY DISTRICT REPRESENTATIVE UPON REQUEST.