COMMONWEALTH OF PENNSYLVANIA
    DEPARTMENT OF ENVIRONMENTAL PROTECTION
    AIR QUALITY PROGRAM
    PROPOSED GENERAL PLAN APPROVAL AND/OR GENERAL OPERATING PERMIT
    (BAQ-GPA/GP – 25)
    HEATSET WEB OFFSET LITHOGRAPHIC PRINTING PRESSES
    1.
    Statutory Authority and General Description
    In accordance with Section 6.1(f) of the Pennsylvania Air Pollution Control Act (APCA),
    35 P.S. § 4006.1(f), 25
    Pa. Code
    §§ 127.514 (relating to general operating permits at
    Title V facilities) and 127.611 (relating to general plan approvals and general operating
    permits), the Department of Environmental Protection (“Department”) hereby issues this
    General Plan Approval and/or General Operating Permit (“General Permit”) for heatset
    web offset lithographic printing presses (“heatset web presses”).
    2.
    Applicability/Source Coverage Limitations
    This General Permit authorizes the construction, modification and/or operation of any
    heatset web press with the following limitations:
    Heatset web press having ink oil emissions exceeding five (5) pounds per hour
    shall be connected to an oxidizer capable of complying with the emission
    limitations specified in Condition 15 of this General Permit. In order to qualify for
    coverage under this General Permit, all of the emissions from the presses and
    dryers must be captured and sent to the oxidizers.
    Control systems for the emissions from the dryers will not be required if ink oil emissions
    from the Heatset web presses are less than or equal to five pounds per hour.
    This General Permit does not apply if the construction, modification, and/or operation of
    the heatset web press qualifies for an exemption under 25
    Pa. Code
    §§127.14 (relating
    to exemptions) or 127.449 (relating to de minimis emission increases).
    If any heatset web press at a facility cannot be regulated under this General Permit, a
    Plan Approval and/or Operating Permit issued by the Department in accordance
    25 Pa.
    Code
    , Chapter 127, Subchapter B (relating to plan approval requirements) and/or
    Subchapter F (relating to operating permit requirements) will be required. If the facility is
    a Title V facility, a Title V Operating Permit issued in accordance with
    25 Pa. Code
    ,
    Chapter 127, Subchapters F and G (relating to Title V operating permits) will be
    required.
    Prohibited Use
    This General Permit has been established in accordance with 25
    Pa. Code
    Chapter 127,
    Subchapter H (relating to general plan approvals and general operating permits) and is
    not applicable to:
    a.
    Any stationary air contamination source that is subject to 25
    Pa. Code
    Chapter
    127, Subchapter D (relating to prevention of significant deterioration);
    b.
    Any stationary air contamination source that is subject to 25
    Pa. Code
    Chapter
    127, Subchapter E (relating to new source review);
    1

    c.
    Any stationary air contamination source that is subject to 25
    Pa. Code
    Chapter
    127, Subchapter G (relating to Title V operating permits).
    Plan Approval
    This General Permit establishes best available technology (BAT) requirements and
    authorizes the construction or modification of any heatset web press that meets the BAT
    requirements established under 25
    Pa. Code
    §§ 127.1 and 127.12(a)(5).
    The installation or modification of each heatset web press that meets the following
    criteria is exempt from plan approval requirements if the press:
    a.
    Emits volatile organic compounds (VOCs) at a rate less than 2.7 tons per year
    (tpy);
    b.
    Emits a single hazardous air pollutant (HAP) at a rate less than 1 tpy; and
    c.
    Emits a combination of hazardous air pollutants (HAPs) at rates less than 2.5 tons
    of all HAPs combined per year.
    For purposes of this General Permit, BAT for heatset web presses shall include the
    requirements specified in Conditions 15 (b),(c) and (d) of this General Permit. The
    modification of a heatset web press includes the addition of or any physical change of a
    printing unit, coating unit, oxidizer or other changes that would increase VOC or HAP
    emissions from the heatset web press above the exemption levels specified above in (a)
    through (c).
    Operating Permit
    This General Permit authorizes the operation of a heatset web press unless the
    respective operation is located at a facility that has or is required to have an Operating
    Permit issued by the Department under 25
    Pa. Code
    , Chapter 127, Subchapter F, or
    25
    Pa. Code
    Chapter 127, Subchapters F and G. A heatset web press that is
    constructed or modified under this General Permit and located at a facility that is subject
    to 25
    Pa. Code
    , Chapter 127, Subchapter F, or Subchapters F and G, may, however, be
    operated under this General Permit on a temporary basis until the Operating Permit
    required under 25
    Pa. Code
    , Chapter 127, Subchapter F, or Subchapters F and G, if
    applicable, has been obtained or amended to include the terms and conditions of this
    General Permit
    .
    Once authorization to use this General Permit is granted, operation may proceed
    provided the owner or operator notifies the Department in accordance with Condition 7
    of the General Permit.
    3.
    Municipal Notifications:
    As required under section 1905-A of the Administrative Code, a facility owner or operator
    proposing to use the General Plan Approval/ General Operating Permit shall submit a
    copy of the application to each municipality in which the sources will be constructed,
    modified or operated under the BAQ-GPA/GP-25 General Permit.
    2

    4.
    Application for Use
    Pursuant to
    25 Pa. Code
    § 127.621 (relating to application for use of general plan
    approvals and general operating permits), any person proposing to construct, operate or
    modify a heatset web press
    under the General Permit shall notify the Department using
    the BAQ-GPA/GP-25 General Permit Application and shall receive prior written approval
    from the Department before construction or modification may commence. This
    application shall be accompanied by the appropriate application fee, proof of municipal
    notification and any additional forms and information requested by the Department. The
    Department will take action on the complete application within thirty (30) days of receipt.
    Authorization to operate under this General Permit will be granted by the Department for
    the specific source and location described in the application.
    Words and terms that are not otherwise defined in this General Permit shall have the
    meanings set forth in Section 3 of the Air Pollution Control Act (35 P.S. §4003) and
    25 Pa. Code
    §121.1.
    5.
    Compliance
    The owner or operator authorized to use BAQ-GPA/GP-25 shall comply with the
    specifications in the application and terms and conditions of the General Permit. The
    owner or operator shall keep copies of the
    General Permit and applications at the facility
    and shall make them available to the Department upon request.
    The potential to emit of any heatset web press proposing to operate under this General
    Permit shall be limited by the information including, but not limited to, the hours of
    operation, production rate, etc., as provided in the application. The heatset web press
    shall be:
    a.
    Operated in such a manner as not to cause air pollution, as that term is defined in
    25
    Pa. Code
    § 121.1;
    b.
    Operated and maintained in a manner consistent with good operating and
    maintenance practices;
    c.
    Operated and maintained in accordance with practices based on the
    “manufacturer's specifications”; and
    d.
    Operated and maintained such that no owner or operator permits the emission into
    the outdoor atmosphere of any malodorous air contaminants from any source, that
    the malodors are detectable outside the property of the owner or operator on
    whose land the facility is being operated in accordance with
    25 Pa. Code
    §123.31
    (relating to limitations).
    6.
    Modification, Suspension and Revocation
    This General Permit may be modified, suspended, or revoked if the Department
    determines that the heatset web press cannot be adequately regulated under this
    General Permit.
    Any authorization to construct and/or operate a heatset web press under this General
    Permit may be suspended or revoked if the Department determines that, at any time, the
    owner or operator has failed to construct and/or operate the respective heatset web
    3

    press in compliance with the terms and conditions of this General Permit or information
    identified in the application. Upon suspension or revocation of authorization to construct
    and/or operate a heatset web press under this General Permit, construction shall
    immediately be ceased and/or the respective heatset web press shall not thereafter be
    operated until the Department grants approval, in writing.
    7.
    Notice Requirements
    The applications and notifications required by 25
    Pa. Code
    §127.621 and Condition 4 of
    this General Permit shall be submitted to the appropriate DEP Regional Office
    responsible for issuing general permits in the county in which the heatset web press is,
    or will be, located. In accordance with §127.621(b), the application shall be either hand
    delivered or sent by certified mail, return receipt requested.
    The owner or operator shall notify the Department, in writing, of the owner’s or operator's
    intent to commence operation of the respective heatset web press at least five (5)
    business days prior to commencement of operation. When the heatset web press
    involves multiple sources on different time schedules, notice is required for the
    commencement of operation of each source.
    Malfunctions:
    The owner or operator shall notify the Department by telephone within
    twenty-four (24) hours of the discovery of any malfunction of any heatset web press
    operating pursuant to this General Permit, which results in, or may possibly be resulting
    in, the emission of air contaminants in excess of any applicable limitation specified
    herein or in excess of the limitations specified in any applicable rule or regulation
    contained in 25
    Pa. Code
    , Chapters 121 through 145, or which otherwise results in, or
    may possibly be resulting in, noncompliance with the requirements specified in any
    applicable condition of this General Permit. If the owner or operator is unable to provide
    notification to the appropriate Regional Office within twenty-four (24) hours of discovery
    of a malfunction due to a weekend or holiday, the notification shall be made to the
    Department by no later than 4 p.m. on the first business day for the Department
    following the weekend or holiday. In addition, the owner or operator shall provide
    whatever subsequent written report the Department may request regarding any reported
    malfunction.
    8.
    Term of Authorization to Use General Permit
    The authorization to construct and/or operate any heatset web press under this General
    Permit is granted for a fixed term of five (5) years except that the authorization to
    construct a heatset web press will expire eighteen (18) months from the date of
    Department authorization if the owner or operator fails to commence construction. If
    construction commences within eighteen (18) months of the date of receipt of
    authorization from the Department, but it is not yet completed, the authorization to
    construct the heatset web press under this General Permit is automatically extended,
    provided there is no subsequent lapse in construction activity of eighteen (18) months or
    more, up to a maximum of five years from the date of Department authorization.
    The Department will notify the owner or operator, in writing, when authority to construct
    and/or operate under this General Permit is granted.
    4

    9.
    Fees
    The General Permit establishes the following fees:
    a.
    General Plan Approval application fee:
    One thousand dollars ($1,000)
    A new application and fee, as indicated above, is required each time the owner or
    operator installs or modifies any heatset web press. The installation or
    modification of any heatset web press must be conducted according to the terms
    and conditions of this General Permit.
    b.
    General Operating Permit fees to be submitted along with General Plan Approval
    application:
    Three hundred seventy-five dollars ($375)
    c.
    Annual operating permit administration fee, payable on an annual basis:
    Three hundred seventy-five dollars ($375)
    The fees shall be paid on or before March 1
    st
    of each calendar year for the
    previous calendar year.
    d.
    General Operating Permit renewal fee payable every five years:
    Three hundred seventy-five dollars ($375)
    10.
    Expiration and Renewal of Authorization
    The owner’s or operator's right to construct and/or operate under this General Permit
    terminates on the date of expiration of the authorization granted by the Department to
    construct and/or operate under this General Permit unless a complete renewal
    application is submitted to the Department at least thirty (30) days prior to the expiration
    date of the authorization.
    Upon receipt by the Department of a timely and complete application for renewal to
    operate under this General Permit, the owner or operator may continue to operate the
    respective heatset web press subject to final action by the Department on the renewal
    application, provided that the heatset web press is operated in compliance with all terms
    and conditions of this General Permit. However, this authorization shall cease to exist if
    the owner or operator fails to submit, by the deadline specified by the Department, any
    information required by the Department to process the renewal application.
    11.
    Applicable Laws
    Nothing in this General Permit relieves the owner or operator of his obligation to comply
    with all applicable Federal, state and local laws and regulations. The issuance of this
    General Permit does not prevent the future adoption by the Department of any rules,
    regulations or standards, or the issuance of orders necessary to comply with the
    requirements of the federal Clean Air Act or the APCA or regulations adopted under the
    acts to achieve or maintain ambient air quality standards. The issuance of this General
    Permit shall not be construed to limit the Department's enforcement authority.
    5

    12.
    Public Records and Confidential Information
    a.
    The records, reports or information obtained by the Department under this General
    Permit shall be available to the public, except as provided in paragraph (b) of this
    condition.
    b.
    Upon cause shown by the owner or operator that the records, reports or
    information, or a particular portion thereof, but not emission data, to which the
    Department has access under the APCA, if made public, would divulge production
    or sales figures or methods, processes or production unique to that person or
    would otherwise tend to affect adversely the competitive position of that person by
    revealing trade secrets, including intellectual property rights, the Department will
    consider the record, report or information, or particular portion thereof confidential
    in the administration of the APCA. The Department will implement this section
    consistent with sections 112(d) and 114(c) of the federal Clean Air Act (42
    U.S.C.A. §§ 7412(d) and 7414(c)). Nothing in this section prevents disclosure of
    the report, record or information to federal, state or local representatives as
    necessary for purposes of administration of federal, state or local air pollution
    control laws, or when relevant in a proceeding under the act.
    13.
    Transfer of Ownership
    The owner or operator may not transfer the authorization to construct and/or operate a
    heatset web press under this General Permit to another owner or operator. A
    subsequent owner or operator must submit a new General Permit application and fee in
    accordance with Conditions 4 and 9 of this General Permit
    .
    14.
    Definitions
    For purposes of this General Permit, the following definitions apply:
    a.
    Alcohol
    - A class of compounds containing a single hydroxyl group OH. When
    used as a fountain solution additive for offset lithographic printing, the term
    includes: ethanol, n-propanol, and isopropanol.
    b.
    Alcohol Substitutes
    - Nonalcohol additives that contain VOCs and are used in the
    fountain solution. The term includes additives used to reduce the surface tension
    of water or prevent piling (ink build-up).
    c.
    Automatic Blanket Wash System
    - Equipment used to remotely clean lithographic
    blankets which may include, but is not limited to those utilizing a cloth and
    expandable bladder, brush, spray, or impregnated cloth system.
    d.
    Batch
    - A supply of fountain solution that is prepared and used without alteration
    until completely used or removed from the printing process. For the purposes of
    this general permit, this term includes solutions that are either prepared in discrete
    batches or solutions that are continuously blended with automix units.
    e.
    Cleaning Solution
    - Liquid solvents or solutions used to remove ink and debris from
    the operating surfaces of the printing press and its parts.
    f.
    Dampening System
    - Equipment used to deliver the fountain solution to the
    lithographic plate.
    6

    g.
    Fountain Solution - A mixture of water, non-volatile printing chemicals, and an
    additive (liquid) that reduces the surface tension of the water so that it spreads
    easily across the printing plate surface. The fountain solution wets the non-image
    area so that the ink is maintained within the image areas. Non-volatile additives
    may include but not be limited to mineral salts and hydrophilic gums. For the
    purpose of this general permit, the additives may include a VOC content of 5.0% or
    less. Alcohol and alcohol substitutes, including isopropyl alcohol, glycol ethers,
    and ethylene glycol, are the most common VOC additives used to reduce the
    surface tension of the fountain solution.
    h.
    Inking System
    - A series of rollers used to meter the ink onto the lithographic plate.
    The system can include agitators, pumps, and totes and other types of ink
    containers.
    i.
    Lithography
    - A planographic printing process where the image and non-image
    areas are chemically differentiated; the image area is oil receptive and the non-
    image area is water receptive. This method differs from other printing methods,
    where the image is typically printed from a raised or recessed surface.
    j.
    Heatset
    - A lithographic printing process where the printing inks are set with the
    use of heat. Traditional heatset inks set and dry by evaporation of the ink oils.
    k.
    Heatset dryer -
    A device used in lithography to heat the printed substrate and to
    promote the evaporation of ink oils.
    l.
    Offset
    - A printing process that transfers the ink film from the lithographic plate to
    an intermediary surface (blanket), which, in turn, transfers the ink film to the
    substrate.
    m. Press
    - A printing production assembly composed of one or more units used to
    produce a printed substrate or a web. The term includes any associated coating,
    adhesive application, or infra-red heating units.
    n.
    Unit
    - The smallest complete printing component composed of inking and
    dampening systems of a printing press.
    o.
    VOC Composite Partial Vapor Pressure
    - The sum of the partial pressure of the
    compounds defined as VOCs. VOC composite partial pressure is calculated as
    follows:
    PP
    c
    =
    (
    W
    i
    )(
    VP
    i
    )/
    MW
    i
    W
    w
    MW
    w
    +
    W
    c
    MW
    c
    +
    W
    i
    i
    =1
    MW
    i
    n
    i
    =1
    n
    Where:
    W
    i
    = Weight of the “i”th VOC compound, in grams
    W
    w
    = Weight of water, in grams
    W
    c
    = Weight of exempt compound, in grams
    MW
    i
    = Molecular weight of the “i”th VOC compound, in g/g-mole
    MW
    w
    = Molecular weight of water, in g/g-mole
    MW
    c
    = Molecular weight of exempt compound, in g/g-mole
    PP
    c
    = VOC composite partial pressure at 20°C, in mm Hg
    VP
    i
    = Vapor pressure of the “i”th VOC compound at 20°C, in mm Hg
    7

    p.
    Web - A continuous roll of paper used as the printing substrate in a printing
    process.
    15.
    Limitations and Requirements (Including Best Available Technology)
    a.
    The addition of any new printing press or any modification to the existing heatset
    web press connected to an existing oxidizer that was constructed after July 1,
    1972, but prior to the effective date of this General Permit and had a valid plan
    approval pursuant to 25
    Pa. Code
    § 127.11, shall comply with the BAT established
    pursuant to 25
    Pa. Code
    §§ 127.1 and 127.12(a)(5), in the previously issued plan
    approval.
    b.
    Any heatset web press with an oxidizer as described in Condition 2 that is
    constructed after the effective date of this General Permit, and a facility
    constructed after July 1, 1972, but prior to the effective date of this General Permit
    and for which no plan approval was obtained pursuant to 25
    Pa. Code
    § 127.11,
    shall comply with the following BAT requirements:
    i.
    The emissions from the press and dryer shall be captured and controlled by
    an oxidizer with a non-methane hydrocarbon (NMHC) destruction and
    removal efficiency of at least 98.0% or a post-control NMHC concentration of
    20 ppmvd or less as methane (CH
    4
    ), whichever is less stringent.
    ii.
    For presses utilizing an integrated dryer and oxidizer, the post-control NMHC
    concentration shall be 20 ppmvd or less as CH
    4
    .
    c.
    Any owner or operator operating heatset web press with oxidizer(s) as described in
    Condition 2 that are authorized to use to this General Permit shall maintain the
    oxidizer temperature at or above the Department approved set-point operating
    temperature on any 3-hour average to demonstrate compliance with Condition 15
    (a) or (b) of this General Permit.
    d.
    The owner or operator of any heatset web press authorized to use to this General
    Permit shall comply with the following limitations and requirements:
    i.
    Heatset Dryers
    Any heatset web press subject to this General Permit must be operated with
    the dryer air pressure lower than the pressroom air pressure such that air
    flows into the dryer at all times when the press is operating.
    ii.
    Fountain Solutions
    Any heatset web press subject to this General Permit shall meet one of the
    following requirements for the fountain solution used on that press:
    1.
    The as-applied VOC content of the fountain solution must be
    maintained at or below 1.6% by weight;
    2.
    The as-applied VOC content of the fountain solution must be
    maintained at or below 3.0%, by weight; refrigerate the fountain solution
    to 60
    o
    F or less;
    8

    3.
    The as-applied VOC content of the fountain solution must be
    maintained at or below 5.0%, by weight, and use no alcohol in the
    fountain solution.
    iii.
    Blanket and Roller Cleaning Solutions
    Any blanket and roller cleaning solution used on a heatset web press subject
    to this General Permit shall meet one of the following requirements:
    1.
    VOC content, as applied, must be less than or equal to 30% by weight;
    2.
    VOC composite partial vapor pressure, as used, must be less than or
    equal to 10 mm Hg at 20
    o
    C (68
    o
    F);
    3.
    Cleaning solutions not meeting Conditions 15 (d)( iii)(1) or ( 2) are
    permitted provided that the quantity used does not exceed 55 gallons
    over any (12) twelve consecutive months.
    e.
    Visible and Odor Emission Limitations
    i.
    Any heatset web press with a pollution control system shall not emit visible
    air contaminants in such a manner that the opacity of the emissions is equal
    to or greater than 10% for a period or periods aggregating more than three
    (3) minutes in any one hour or equal to or greater than 30% at any time.
    ii.
    For any press without an oxidizer, visible air contaminants shall not be
    emitted in such a manner that the opacity of the emissions is equal to or
    greater than 20% for a period or periods aggregating more than three (3)
    minutes in any one hour or equal to or greater than 60% at any time.
    iii.
    Operation of the heatset web press shall not cause any odor emissions in
    such a manner that the malodors are detectable outside the property of the
    owner or operator as specified in 25
    Pa. Code
    §123.31.
    16.
    Performance Testing of Control System(s) and Dryer(s)
    Any owner or operator operating a heatset web press with an oxidizer as described in
    Condition 2 of this General Permit shall comply with the following requirements:
    a.
    The owner or operator shall perform a stack test within one hundred eighty (180)
    days after the initial start-up of the heatset web press connected to a new oxidizer
    to establish the destruction and removal efficiency of the control device and
    demonstrate compliance with the requirements of Condition 15(b) of this General
    Permit. For any heatset web press connected to an existing oxidizer, stack testing
    shall be required only if the press will increase flow rate to the oxidizer or if the
    owner or operator establishes a lower set-point operating temperature that is no
    lower than the manufacturer’s recommended minimum operating temperature for
    the oxidizer.
    b.
    The owner or operator shall perform a stack test in accordance with 25
    Pa. Code
    Chapter 139, the current revision of the Department’s Source Testing Manual and
    the following methods and requirements:
    i.
    Methods in Appendix A of 40 CFR Part 60 or any alternate methods
    approved by the Department:
    9

    1.
    Methods 1 through 4 shall be used to determine the volumetric flow rate
    of the effluent entering and exiting the air pollution control device.
    2.
    Method 25A shall be used to determine the total hydrocarbon (THC)
    concentration.
    3.
    Method 18 shall be used to determine the methane concentration of the
    effluent entering and exiting the air control device.
    ii.
    Testing shall be conducted under normal or representative operating
    conditions. Such operating conditions should strive to minimize downtime
    while running as many presses as practicable, when a common control
    device is serving multiple presses. Because activities such as cycling of
    automatic blanket washing systems, press speed variations, web breaks or
    other short-term events in which the print quality is being checked, may be a
    part of normal, representative operations, sampling should continue during
    these short-term events while the control device is being tested.
    iii.
    The following process data shall be recorded during each test run to
    document the operation of the heatset web press:
    1.
    Line speed (fpm)
    2.
    Web width
    3.
    Ink usage
    4.
    Number of colors
    5.
    Press downtime (minutes)
    iv.
    The following data shall be recorded in fifteen (15) minute intervals during
    each test run to document the operation of the oxidizer:
    1.
    Oxidizer inlet temperature (°F) (for catalytic oxidizer only)
    2.
    Oxidizer operating temperature (°F) (for thermal oxidizer only)
    c.
    Dryers shall be demonstrated to operate at a negative pressure relative to the
    surrounding by using such devices as differential pressure gauge, smoke stick or
    aluminum ribbons.
    d.
    An oxidizer set-point operating temperature shall be set at the time of initial testing
    with demonstrating performance by complying with the emission limits stipulated in
    Condition 15 (b) of this General Permit. The set-point operating temperature for
    the oxidizer(s) shall be an average of temperature values recorded at least once
    per fifteen (15) minute interval during a three (3) hour block of the test. Under no
    circumstances shall the oxidizer(s) have a set-point operating temperature lower
    than the manufacturer’s recommended minimum operating temperature. The
    Department shall approve the set-point operating temperature.
    e.
    An excursion shall be identified as any three (3) hour average temperature that is
    up to 50°F below the set-point operating temperature.
    17.
    Testing of Fountain Solutions
    The owner or operator of any heatset web press subject to this General Permit shall
    determine the VOC content of fountain solution by one of the following procedures:
    a.
    Analysis by USEPA Method 24 of a fountain solution sample;
    10

    b.
    Material safety data sheets (MSDS), Certified product data sheets (CPDS), or
    other data provided by the manufacturer that indicates the VOC content;
    c.
    Calculation which combines USEPA Method 24 analytical VOC content data for the
    concentrated materials used to prepare the press-ready fountain solution and
    records of the proportions in which they are mixed. The calculation shall only be
    performed once for each type of press-ready fountain solution and kept in the form
    of a batch log. The analysis of the concentrated fountain solution may be
    performed by the supplier(s) of those materials.
    18.
    Testing of Blanket and Roller Cleaning Solutions
    The owner or operator of any heatset web press subject to this General Permit shall
    determine the VOC content or VOC composite partial vapor pressure of cleaning
    solutions by one of the following procedures:
    a.
    Analysis by USEPA Method 24 of a cleaning solution sample for VOC content or
    by an appropriate method for composite partial vapor pressure;
    b.
    Material safety data sheets (MSDS), Certified product data sheets (CPDS), or
    other data provided by the manufacturer that indicates the VOC content and/or
    VOC composite partial vapor pressure;
    c.
    Calculation which combines USEPA Method 24 analytical VOC content data for the
    concentrated materials used to prepare the press-ready cleaning solution and
    records of the proportions in which they are mixed. The calculation shall only be
    performed once for each press-ready cleaning solution and kept in the form of a
    batch log. The analysis of the concentrated cleaning solution may be performed by
    the supplier(s) of those materials;
    d.
    Calculation for VOC composite partial vapor pressure which combines analytical
    VOC vapor pressure data for the concentrated materials used to prepare the
    press-ready cleaning solution and records of the proportions in which they are
    mixed. The analysis and vapor pressure determinations of the concentrated
    material may be performed by the suppliers of the material.
    19.
    Sampling and Testing
    a.
    At least sixty (60) calendar days prior to commencing an emission testing program
    required by this General Permit, a Test Protocol shall be submitted to the
    Department’s Division of Source Testing and Monitoring and the appropriate
    Regional Office for review and approval. The Test Protocol shall meet all
    applicable requirements specified in the most current version of the Department’s
    Source Testing Manual. The emissions testing shall not commence prior to receipt
    of a protocol acceptance letter from the Department.
    b.
    At least fifteen (15) calendar days prior to commencing an emission testing
    program required by this General Permit, written notification of the date and time of
    testing shall be provided to the Department’s appropriate Regional Office.
    Notification, in writing, shall also be sent to the Department’s Bureau of Air Quality,
    Division of Source Testing and Monitoring. The Department is under no obligation
    to accept the results of any testing performed without adequate advance written
    notice to the Department of such testing. Notification shall also be sent to the
    11

    Department’s Division of Source Testing and Monitoring so that an observer may
    be present.
    c.
    Within fifteen (15) calendar days after completion of the on-site testing portion of
    an emission test program required by this General Permit, if a complete test report
    has not yet been submitted, an electronic mail notification shall be sent to the
    Department’s Division of Source Testing and Monitoring at
    RA-epstacktesting@state.pa.us
    and the appropriate Regional Office indicating the
    completion date of the on-site testing.
    d.
    A complete test report shall be submitted to the Department no later than sixty (60)
    calendar days after completion of the on-site testing portion of an emission test
    program required by this General Permit.
    e.
    A complete test report shall include a summary of the emission results on the first
    page of the report indicating if each pollutant measured is within permitted limits
    and a statement of compliance or non-compliance with all applicable permit
    conditions. The summary results will include, at a minimum, the following
    information:
    i. A statement that the owner or operator has reviewed the report from the
    emissions testing body and agrees with the findings;
    ii. Permit number(s) and condition(s) which are the basis for the evaluation;
    iii. Summary of results with respect to each applicable permit condition; and
    iv. Statement of compliance or non-compliance with each applicable permit
    condition.
    f.
    All submittals shall meet all applicable requirements specified in the most current
    version of the Department’s Source Testing Manual.
    g.
    All testing shall be performed in accordance with 25
    Pa. Code
    Chapter 139
    (relating to sampling and testing).
    h.
    All submittals, except notifications, shall be accomplished through PSIMS*Online
    available through https://www.depgreenport.state.pa.us/ecomm/Login.jsp. If
    internet submittal is not feasible, one (1) copy of the submittal shall be sent to the
    appropriate Pennsylvania Department of Environmental Protection Regional Office
    and to the attention of the Department’s Bureau of Air Quality, Division of Source
    Testing and Monitoring, 400 Market Street, 12
    th
    Floor Rachel Carson State Office
    Building, Harrisburg, PA 17105-8468 with deadlines verified through document
    postmarks.
    i.
    The owner or operator shall ensure that all applicable federal reporting
    requirements are followed, including timelines more stringent than those contained
    herein. In the event of an inconsistency or any conflicting requirements between
    federal and state laws and regulation, the permittee shall comply with the most
    stringent provision, term, condition, method or rule
    j.
    If, at any time, the Department has reason to believe that the air contaminant
    emissions from the heatset web press is, or may be, in excess of any applicable air
    contaminant emission limitation, the owner or operator shall conduct such stack
    tests or source tests as are deemed necessary by the Department to determine the
    actual air contaminant emission rate. The owner or operator shall, upon the
    request of the Department, provide input material analyses, or input material
    12

    samples used in any heatset web press authorized to operate under this general
    permit.
    k.
    Subsequent compliance testing of the control system(s) shall be conducted every
    five (5) years and whenever different operating conditions (e.g., new or different
    equipment or control devices) may adversely affect compliance with the emissions
    standards.
    20.
    Monitoring, Recordkeeping, and Reporting
    The owner or operator shall comply with applicable monitoring, recordkeeping and
    reporting requirements set forth in 25
    Pa. Code
    Chapter 139 (relating to sampling and
    testing), the APCA, the Clean Air Act, and the applicable regulations under the acts.
    21.
    Monitoring Requirements for Control System(s) and Dryer(s)
    a.
    The owner or operator shall install, calibrate, maintain, and operate a temperature
    monitoring and recording system. Temperatures shall be monitored and recorded
    continuously by an analog or digital recording device. The temperature monitoring
    equipment shall be equipped with a continuous recorder and shall have an
    accuracy of ±1.0% of the temperature measured.
    i.
    For catalytic oxidizer(s), the temperature monitoring equipment shall monitor
    the catalyst bed inlet temperature.
    ii.
    For thermal oxidizer(s), the temperature monitoring equipment shall monitor
    the oxidizer(s) combustion chamber/zone temperature(s).
    b.
    Dryer static pressure shall be monitored at least once a day to assure proper
    airflow and negative pressure inside the dryer.
    22.
    Monitoring Requirements for Automatic Blanket Wash Systems
    The owner or operator using an automatic blanket wash system that mixes cleaning
    solution at the point of application must demonstrate compliance with the VOC limitation
    in Condition 15 (d)(iii) of this General Permit and shall document that flow meters or
    fixed volume spray systems result in the VOC content or VOC composite partial vapor
    pressure of the mixed solution complies with Condition 15(d)(iii).
    23.
    Monitoring Requirements for Visible and Odor Emissions
    a.
    Visible emissions may be measured using either a device approved by the
    Department and maintained to provide accurate opacity measurements, or by an
    observer trained and qualified to measure plume opacity with the naked eye or with
    the aid of any devices approved by the Department.
    b.
    The owner or operator shall perform monitoring of the facility at least once per
    operating day for the presence of visible emission and malodors.
    c.
    If any deviations from the visible or odor emissions standards in Condition 15(e) of
    this General Permit are apparent, the owner or operator shall take immediate
    action to eliminate them. Any such deviations shall be reported to the facility
    13

    management or individual designated by the owner or operator and recoded in a
    permanent log.
    d.
    If the visible emissions are still not in compliance after the corrective action, the
    operations of the heatset web press shall be ceased until the owner or operator
    can verify compliance with the standards specified in Condition 15(e)(i), (ii) or ( iii)
    of this General Permit. The owner or operator shall notify the Department of the
    event in accordance with Condition 7.
    24.
    Recordkeeping Requirements
    a.
    The owner or operator shall record:
    i.
    Continuously the catalytic bed inlet temperature.
    ii.
    Continuously the combustion chamber/zone operating temperatures.
    iii.
    All 3-hour blocks of time (when the emissions unit was in operation) during
    which the average operating temperature for an oxidizer was up to 50°F
    below the set-point operating temperature, which is defined as excursion in
    Condition 16(e) of this General Permit.
    iv.
    All observations made for recommended work practices listed under
    Conditions 26 (a)(ii) through (viii).
    v.
    Any downtime for the capture (collection) system, control device, and
    monitoring equipment.
    vi.
    For each heatset web offset lithographic ink or conventional varnish used:
    the monthly consumption in pounds or gallons; the percent by weight VOC
    and HAP content, as applied; and, an estimate of VOC and HAP emissions.
    Alternately, the ink with the highest VOC and HAP content may be used to
    represent all inks used by all heatset web presses.
    vii. For each fountain solution and additive: the monthly consumption in pounds
    or gallons; the percent by weight or weight to volume ratio (lbs/gal) VOC and
    HAP content and an estimate of VOC and HAP emissions. Alternately, the
    fountain solution and additive with the highest VOC and HAP content may be
    used to represent all inks used by all heatset web presses.
    viii. For each blanket and roller cleaning solution used: the monthly consumption
    in pounds or gallons; the percent by weight or weight to volume ratio (lbs/gal)
    VOC and HAP content and an estimate of VOC and HAP emissions.
    Alternately, the blanket and roller cleaning solution with the highest VOC and
    HAP content may be used to represent all inks used by all heatset web
    presses.
    ix.
    For each month of operation, the volume of all cleaning solution used which
    does not meet Condition 15(d)(iii)(1) or (2) of this General Permit.
    x.
    For each month of operation, an estimate of VOC and HAP emissions during
    the latest 12 months (using a 12 month rolling average recordkeeping
    system).
    14

    xi.
    Monthly usage of natural gas, propane or any other cleaner fuel.
    xii. Results of daily stack observation and inspection around the facility property
    as required in Condition 23.
    b.
    Pursuant to 25
    Pa. Code
    § 135.5, air contamination source owners or operators
    shall maintain and make available to the Department, upon request, any records as
    may be necessary to demonstrate compliance with 25
    Pa. Code
    § 135.3 (relating
    to reporting). These records may include records of production, fuel usage,
    maintenance of production or pollution control equipment or other information
    determined by the Department to be necessary for identification and quantification
    of potential and actual air contaminant emissions. The records shall be retained
    for a minimum of five (5) years and shall be made available to the Department
    upon request.
    25.
    Reporting Requirements
    a.
    The owner or operator of a heatset web press with an oxidizer subject to this
    General Permit shall submit semiannual written reports of the following to the
    Department’s Regional Office responsible for authorizing the use of the General
    Permit:
    i.
    Any excursions that have been detected;
    ii.
    The probable cause of such excursions; and
    iii.
    Any corrective actions or preventive measures that have been taken.
    A semiannual reporting period shall begin after each performance test of an
    oxidizer. Submission of a semiannual report is not required if excursions are not
    detected during the period.
    b.
    Pursuant to 25
    Pa. Code
    § 135.3, a person who owns or operates an air
    contamination source which is subject to 25
    Pa. Code
    , Chapter 135 and who has
    previously been advised by the Department to submit an annual emissions report
    shall submit by March 1 of each year an emission report for the previous year. The
    report shall include information for all previously reported air contamination
    sources, new air contamination sources that were first operated during the
    preceding calendar year and air contamination sources modified during the same
    period that were not previously reported.
    c.
    A person who receives initial notification by the Department that an emission report
    is necessary shall submit the report within sixty (60) days after receiving
    notification or by March 1 of the year following the year for which the report is due,
    whichever is later.
    26.
    Work Practice Standards
    a.
    Control System(s) and Dryer(s)
    i.
    The owner or operator must maintain the oxidizer(s) at or above the
    Department approved set-point operating temperature at all times to
    demonstrate reasonable assurance of compliance.
    15

    ii.
    The owner or operator shall take immediate corrective action in response to
    an excursion as defined in Condition 16(e) of this General Permit. If in spite
    of the corrective action the operating temperature cannot be brought above
    the set-point operating temperature as established in accordance with
    Condition 16(d) the operation of the heatset web press shall cease until the
    situation is corrected.
    iii.
    The catalyst bed material shall be inspected annually for general catalyst
    condition and any signs of potential catalyst depletion as recommended by
    the manufacturer. The owner or operator shall also collect a representative
    sample of the catalyst from the oxidizer, per manufacturer's
    recommendations, and have it tested annually to evaluate the catalyst's
    capability to continue to function at or above the stipulated destruction and
    removal efficiency. Selection of the testing company and procedures shall be
    in accordance with catalyst manufacturer's recommendations. Inspections of
    the catalyst bed shall also be conducted when temperatures recorded
    indicate a problem with the bed. An evaluation of the catalyst bed material
    shall be conducted whenever the results of the inspection indicate signs of
    potential catalyst depletion or poor catalyst condition based on
    manufacturer's recommendations.
    iv.
    For regenerative oxidizers, the chamber sequencing valves shall be
    assessed for leakage annually. This assessment may be comprised of an
    internal inspection, or other method of assessment for leakage.
    v.
    For recuperative oxidizers, the heat exchangers shall be assessed for
    leakage annually. This assessment may be comprised of an internal
    inspection, or other method of assessment for leakage.
    vi.
    Burners shall be inspected and adjusted annually for proper operations.
    vii. Dryers shall be maintained and operated according to the manufacturer’s
    recommendations.
    viii. Dryers shall be inspected and tested semiannually, or whenever the location
    of dryer is disrupted to assure that it is operating at a negative pressure
    relative to the surrounding pressroom to verify compliance with Condition 16
    (c) of this General Permit.
    ix.
    Natural gas, propane or any cleaner fuel shall be used as fuel.
    x.
    The heatset web press with oxidizer(s) shall be provided with interlock(s) to
    assure operation in conjunction with oxidizer(s) only.
    b.
    Solvent Laden Shop Towels
    The owner or operator shall keep all solvent laden shop towels in a closed
    container when not being used.
    c.
    Solvent Containers
    The owner or operator shall keep all solvent containers closed at all times unless
    filling, draining, or performing cleanup operations.
    16

    27.
    Start-up and Shut-down Exclusion:
    The limitations stated in Condition 15(a) or (b) of this General Permit shall apply at all
    times except during periods of start-up and shut-down of the oxidizer(s), provided,
    however, that the duration of start-up and shut-down do not exceed two hours per
    occurrence.
    28. Circumvention
    a.
    The owner or operator, or any other person, may not circumvent the new source
    review requirements of
    25 Pa. Code
    Chapter 127, Subchapter E by causing or
    allowing a pattern of ownership or development, including the phasing, staging,
    delaying or engaging in incremental construction, over a geographic area of a facility
    which, except for the pattern of ownership or development, would otherwise require
    a permit or submission of a plan approval application.
    b.
    No person may permit the use of a device, stack height which exceeds good
    engineering practice stack height, dispersion technique or other technique which,
    without resulting in reduction of the total amount of air contaminants emitted,
    conceals or dilutes an emission of air contaminants which would otherwise be in
    violation of this plan approval, the APCA or the regulations promulgated thereunder,
    except that with prior approval of the Department, the device or technique may be
    used for control of malodors.
    Approved by:
    Joyce E. Epps
    Director
    Bureau of Air Quality
    Date approved:
    17

    Back to top