Air Emission Permit NO. 15300017-001 Is Issued to … · obtain information on these programs,...

TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

AIR EMISSION PERMIT NO. 15300017- 001

IS ISSUED TO

Banta Corporation Inc.

BANTA PUBLICATIONS GROUP - LONG PRAIRIE 100 Banta Road

Long Prairie, Todd County, MN 56347 The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Total Facility Operating Permit 04/17/1995 Minor Amendment Application 01/20/1999 Minor Amendment Application 02/15/2000

This permit authorizes the Permittee to the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit.

Permit Type: State; Limits to Avoid Pt 70/Limits to Avoid NSR

Issue Date: December 22, 2005

Expiration: Non-Expiring All Title I Conditions do not expire. Richard J. Sandberg, Manager Air Quality Permits Section Industrial Division for Sheryl A. Corrigan Commissioner Minnesota Pollution Control Agency

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Table C: (Not used in this permit) Appendices: Attached and Referenced in Table A

Appendix I Appendix II Appendix III

NOTICE TO THE PERMITTEE:

Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area (651) 296-6300 Outside Metro Area 1-800-657-3864 TTY (651) 282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. FACILITY DESCRIPTION: Banta Catalog is a commercial printing facility located in Long Prairie, Minnesota. The Facility consists of heatset web offset lithographic printing presses, dryers, ink jet printers, and pollution control equipment. The main sources of emissions are the press operations that have VOC emissions control equipment. The Facility also has several activities that qualify as insignificant activities under Minn. R. 7007.1300, subp. 3.

TABLE A: LIMITS AND OTHER REQUIREMENTS 12/22/05

Banta Publications Group - Long Prairie

15300017 - 001

Facility Name:

Permit Number:

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column ofthe table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you musttake and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it)lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facilityrequirements.

Subject Item: Total Facility

What to do Why to do itFACILITY SPECIFIC REQUIREMENTS hdr

This permit establishes limits on the facility to keep it a minor source under NewSource Review and the Part 70 and NESHAP programs. The Permittee cannotmake any change at the source that would make the source a major source underNew Source Review or the Part 70 or the NESHAP programs until a permitamendment has been issued. This includes changes that might otherwise qualifyas insignificant modifications and minor or moderate amendments.

Title I Condition: Limit to avoid classification as majorsource or modification under 40 CFR Section 52.21and Minn. R. 7007.3000; to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200 and 40 CFR Section 63.2

Total Facility Press Dryers and Control Equipment Capacity: less than or equal to80.0 million Btu/hour

Title I Condition: Limit to avoid classification as majorsource or modification under 40 CFR Section 52.21and Minn. R. 7007.3000 and under 40 CFR Section70.2 and Minn. R. 7007.0200

Equipment Labeling and Inventory: The Permittee shall permanently affix a uniquenumber to each emissions unit for tracking purposes. The numbers shall correlatethe unit to the appropriate EU and GP numbers used in this permit. The numbercan be affixed by placard, stencil, or other means. The number shall be maintainedso that it is readable and visible at all times from a safe distance.

The Permittee shall maintain a written list of all emissions units on site. The listshall correlate the units to the numbers used in this permit (EU, GP, and CE) andshall include the data included in Appendix III of this permit. The Permittee shallupdate the list to include any replaced or modified equipment prior to making thepre-authorized change.

Minn. R. 7007.0800, subp. 2

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735. This appliesseparately to each piece of industrial process equipment. Specifically, it applies toeach press and ink jet printer.

Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity . This applies separately to eachpiece of industrial process equipment. Specifically, it applies to each press.

Minn. R. 7011.0715, subp. 1(B)

The Permittee shall keep records of fuel purchases for the Facility on a monthlybasis.

Minn. R. 7007.0800, subp. 5

OPERATIONAL REQUIREMENTS hdr

The Permittee shall comply, and upon written request demonstrate compliance,with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt.50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to7009.0080.

40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, supbs. 7A, 7L & 7M; Minn. R.7007.0800, subps. 1, 2 & 4; Minn. R.7009.0100-7009.0080

Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution control rule,without reducing the total amount of pollutant emitted.

Minn. R. 7011.0020

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated, unlessotherwise noted in Table A.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,subp. 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation.

The O & M plan shall be completed within 60 days of permit issuance.

Minn. R. 7007.0800, subp. 14 and Minn. R. 7007.0800,subp. 16(J)

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shallimmediately take all practical steps to modify operations to reduce the emission ofany regulated air pollutant. The Commissioner may require feasible and practicalmodifications in the operation to reduce emissions of air pollutants. No emissionsunits that have an unreasonable shutdown or breakdown frequency of process orcontrol equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4

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Facility Name:

Permit Number:

Fugitive Emissions: Do not cause or permit the handling, use, transporting, orstorage of any material in a manner which may allow avoidable amounts ofparticulate matter to become airborne. Comply with all other requirements listed inMinn. R. 7011.0150.

Minn. R. 7011.0150

Noise: The Permittee shall comply with the noise standards set forth in Minn. R.7030.0010 to 7030.0080 at all times during the operation of any emission units.This is a state only requirement and is not enforceable by the EPA Administrator orcitizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures andrequirements as found in Minn. R. 7007.0800, subp. 9(A).

Minn. R. 7007.0800, subp. 9(A)

The Permittee shall comply with the General Conditions listed in Minn. R.7007.0800, subp. 16.

Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING hdr

Performance Testing: Conduct all performance tests in accordance with Minn. R.ch. 7017 unless otherwise noted in Tables A, B, and/or C.

Minn. R. ch. 7017

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See TableB for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy: due 105 days after each PerformanceTest

The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.

Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn.R. 7017.2035, subp. 1-2

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D)

RECORDKEEPING hdr

Record keeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal recordings for continuous monitoring instrumentation, and copies of allreports required by the permit. Records must conform to the requirements listed inMinn. R. 7007.0800, subp. 5(A).

Minn. R. 7007.0800, subp. 5(C)

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007. 1250, subp. 3) or changes contravening permit terms(as required by Minn. R. 7007.1350 subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007. 0800, subp. 5(B)

REPORTING/SUBMITTALS hdr

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of aplanned shutdown of any control equipment or process equipment if the shutdownwould cause any increase in the emissions of any regulated air pollutant. If theowner or operator does not have advance knowledge of the shutdown, notificationshall be made to the Commissioner as soon as possible after the shutdown.However, notification is not required in the circumstances outlined in Items A, Band C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner ofthe cause of the shutdown and the estimated duration. The owner or operator shallnotify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3

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Facility Name:

Permit Number:

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

Application for Permit Amendment: If a permit amendment is needed, submit anapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

Minn. R. 7007.1150 through Minn. R. 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendmentto extend a deadline in a permit by no more than 120 days, provided the proposeddeadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

Minn. R. 7007.1400, subp. 1(H)

Emission Inventory Report: due 91 days after end of each calendar year followingpermit issuance (April 1). To be submitted on a form approved by theCommissioner.

Minn. R. 7019.3000 through Minn. R. 7019.3100

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 through Minn. R. 7002.0095

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Facility Name:

Permit Number:

Subject Item: GP 001 Total Facility Limits

Associated Items: EU 001 Press 514

EU 002 Press 509

EU 003 Press 515

EU 006 Press 502

EU 007 Press 512

EU 008 Sheetfed Presses

EU 009 Press 516

EU 018 Inkjet Unit

EU 020 Press 517

EU 022 Press 518

EU 024 Inkjet Unit

EU 025 Inkjet Unit

EU 026 Inkjet Unit

EU 027 Inkjet Unit

EU 028 Inkjet Unit

EU 029 Inkjet Unit

EU 030 Inkjet Unit

EU 031 Inkjet Unit

EU 032 Inkjet Unit

EU 033 Inkjet Unit

EU 034 Inkjet Unit

EU 035 Inkjet Unit

EU 036 Inkjet Unit

EU 037 Inkjet Unit

EU 038 Inkjet Unit

EU 039 Inkjet Unit

EU 040 Inkjet Unit

EU 041 Inkjet Unit

What to do Why to do itA. LIMITS hdr

Volatile Organic Compounds: less than or equal to 88 tons/year using 12-monthRolling Sum to be calculated by the 21st day of each month for the previous12-month period as described later in this permit. This includes all non-combustionemissions of VOC other than those listed in Appendix II of this permit.

If the Permittee replaces any existing VOC-emitting equipment, adds newVOC-emitting equipment, or modifies the existing equipment, such equipment issubject to this permit limit as well as all of the requirements of GP 001. Prior tomaking such a change, the Permittee shall apply for and obtain the appropriatepermit amendment, as applicable. The Permittee is not required to repeat VOCcalculations described in Minn. R. 7007.1200, subp. 2.A permit amendment will still be needed regardless of the emissions increase if thechange will be subject to a new applicable requirement or requires revisions to thelimits or monitoring and recordkeeping in this permit.

Title I Condition: Limit to avoid classification as majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000 and to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200

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15300017 - 001

Facility Name:

Permit Number:

HAPs - Total: less than or equal to 23.5 tons/year using 12-month Rolling Sum tobe calculated by the 21st day of each month for the previous 12-month period asdescribed later in this permit. This limit covers all non-combustion HAP-emittingequipment, other than those listed in Appendix II of this permit.

If the Permittee replaces any existing HAP-emitting equipment or adds newHAP-emitting equipment, such equipment is subject to this permit limit as well as allof the requirements of GP 001. Prior to making such a change, the Permittee shallapply for and obtain the appropriate permit amendment, as applicable. A permitamendment may be needed if the change will be subject to a new applicablerequirement or requires revisions to limits or the monitoring and recordkeeping inthis permit.

Title I Condition: Limit to avoid major sourceclassification under 40 CFR Section 63.2

HAP-Single: less than or equal to 9.0 tons/year using 12-month Rolling Sum to becalculated by the 21st day of each month for the previous 12-month period asdescribed later in this permit. permit. This limit covers all non-combustionHAP-emitting equipment, other than those listed in Appendix II of this permit.

If the Permittee replaces any existing HAP-emitting equipment or adds newHAP-emitting equipment, such equipment is subject to this permit limit as well as allof the requirements of GP 001. Prior to making such a change, the Permittee shallapply for and obtain the appropriate permit amendment, as applicable. A permitamendment may be needed if the change will be subject to a new applicablerequirement or requires revisions to limits or the monitoring and recordkeeping inthis permit.


Pre-Authorized Changes: The Permittee may modify listed emissions units andreplace listed emissions units with emissions units similar to those listed in GP 001,provided VOC and HAP emissions are tracked and calculated as specified in thispermit, and all other permit conditions are met. Emissions from all presses anddryers must be controlled with control equipment meeting the requirements of GP004. See GP 003 for further pre-authorized changes for press operations.

If a proposed change triggers an applicable requirement that is not contained in thispermit, the change must go through the appropriate procedures in Minn. R. ch.7007.

Title I Condition: Limit to avoid classification as majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000; to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200 and 40 CFR Section 63.2

B. MONITORING hdr

VOC Calculations: All emission units included in GP 001 as allowed in this permitshall be included in this calculation. VOC contents for each VOC-containingmaterial shall be determined as described under the Material Content requirementin GP 001. The calculation of VOCs used may take into accountrecovered/recycled VOCs as described under the Waste Credit requirement in GP001.

Title I Condition: Limit to avoid classification as majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000; and to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200

HAP Calculations: All emission units included in GP 001 as allowed in this permitshall be included in this calculation. HAP contents for each HAP-containingmaterial shall be determined as described under the Material Content requirementin GP 001. The calculation of HAPs used may take into accountrecovered/recycled HAPs as described under the Waste Credit requirement in GP001.


Material Usage Recordkeeping.

For ink materials used at the presses: On each day of operation, the Permitteeshall record and maintain the quantity of each ink material dispensed in the pressoperations. This shall be based on written usage logs and meter readings. Therecords shall be sufficient to correlate which control efficiency applies to the inkmaterials (e.g., used at which press and control device).

For fountain and blanket wash solutions: The Permittee shall record the amountand type of solvent material, whenever material is dispensed. The log shall indicateif the material is fountain or blanket wash solution. The records shall be sufficientto correlate which control efficiency applies to the various solutions (e.g., used atwhich press and control device).

Title I Condition: Monitoring for Limit to avoidclassification as major source and modification under40 CFR 52.21 and Minn. R. 7007.3000; to avoid majorsource classification under 40 CFR Section 70.2 and63.2; Minn. R. 7007.0800. subp. 4 and 5

Material Usage Recordkeeping continued.

Hand (manual) wash solutions: The Permittee shall record the amount and type ofmaterial each time material is dispensed.

Other VOC and HAP-containing materials: The Permittee shall calculate, record,and maintain monthly usage records showing the quantity of each material used.This shall be based on either written usage logs, or purchase/delivery records.

Title I Condition: Monitoring for Limit to avoidclassification as major source and modification under40 CFR 52.21 and Minn. R. 7007.3000; to avoid majorsource classification under 40 CFR Section 70.2 and63.2; Minn. R. 7007.0800. subp. 4 and 5

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15300017 - 001

Facility Name:

Permit Number:

Vapor Pressure Records: For materials used for either automatic or manualblanket wash, the Permittee shall document if the vapor pressure is equal to, lessthan, or greater than 10 mmHg at 20 degrees centigrade, for each material. If thevapor pressure is unknown, the Permittee shall asssume that it is greater than 10mmHg in the applicable permit calculations until such time that it is determined tobe otherwise.

Minn. R. 7007.0800, subp. 4 and 5

Monthly Recordkeeping -- VOC Emissions.By the 21st of the month, the Permittee shall calculate and record the following:1) The total usage of each VOC-containing material for the previous calendarmonth using the material usage records. This record shall also include the VOCcontents of each material as determined by the Material Content requirement of thispermit.2) The VOC emissions for the previous month using the formulas specified inAppendix I of this permit.3) The 12-month rolling sum VOC emissions for the previous 12-month period bysumming the monthly VOC emissions data for the previous 12 months.

Minn. R. 7007.0800, subp. 4 and 5

Monthly Recordkeeping - HAP Emissions. By the 21st of the month, the Permitteeshall calculate and record the following:1). The total usage of each HAP-containing material used in the previous calendarmonth using the material usage records. This record shall also include theindividual and total HAP contents of each HAP-containing material used in theprevious month, as determined by the Material Content requirement of this permit.2). The total and individual HAP emissions for the previous month using theformulas specified in Appendix I of this permit.3). The 12-month rolling sum total and individual HAP emissions for the previous12-month period by summing the monthly emissions data for the previous 12months.

Minn. R. 7007.0800, subp. 4 and 5

Material Content: VOC and HAPs contents in materials shall be determined byeither 1) a Material Safety Data Sheet (MSDS) or 2) a Letter of Certification,provided by the supplier for each material used. If a material content range isgiven, the highest number in the range shall be used in all compliance calculations.Other alternative methods approved by the MPCA may be used to determine theVOC and HAPs contents. The Commissioner reserves the right to require thePermittee to determine the VOC and/or HAP contents of any material, according toEPA or ASTM reference methods. If an EPA or ASTM reference method is usedfor material content determination, the data obtained shall supersede the MSDS.

Minn. R. 7007.0800, subp. 4 and 5

Waste Credit: If the Permittee elects to obtain credit for HAPs and/or VOC shippedin waste materials, the Permittee shall either use item 1 or 2 to determine the VOCand/or total and individual HAP content for each credited shipment.1) The Permittee shall analyze a composite sample of each waste shipment todetermine the weight content of VOC, total HAP, and each individual HAP.2) The Permittee may use supplier data for raw materials to determine the VOCand total and individual HAP contents of each waste shipment, using the samecontent data used to determine the content of raw materials. If the waste containsseveral materials, the content of mixed waste shall be assumed to be the lowestVOC and total and individual HAP content of any of the materials.

Minn. R. 7007.0800, subp. 4 and 5

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15300017 - 001

Facility Name:

Permit Number:

Subject Item: GP 002 Direct Heating Equipment

Associated Items: EU 010 Press Dryer 514

EU 011 Press Dryer 509







What to do Why to do itFuel Type: natural gas only, or propane (LPG) for backup, by design. Minn. R. 7005.0100, subp. 35a

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735. This appliesseparately to each piece of direct heating equipment.

Minn. R. 7011.0610, subp. 1(A)(1)

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity. This applies separately to eachpiece of direct heating equipment.

Minn. R. 7011.0610, subp. 1(A)(2)

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15300017 - 001

Facility Name:

Permit Number:

Subject Item: GP 003 Press Operations

Associated Items: EU 001 Press 514

EU 002 Press 509

EU 003 Press 515

EU 006 Press 502

EU 007 Press 512

EU 009 Press 516







EU 020 Press 517


EU 022 Press 518


What to do Why to do itFor all Press Operations (presses and dryers), the Permittee shall control theemissions with control devices described by GP 004 at all times that the givenpress is operating. The current control equipment configuration is documented inAppendix III of this permit.

The Permittee may change the equipment configuration (e.g., vent Press 1operations to a control device other than CE 004), may replace the control deviceslisted in Appendix III, or install additional control devices, so long as all pressoperation emissions are controlled, all control devices are described by GP 004,and the dryer and control device capacity limit listed in the Total Facility section ofthis permit is met.


Notification of Control Equipment Changes: The Permittee shall submit anotification to the MPCA of any of the control equipment changes authorized underGP 003 of this permit. The nofitification shall be submitted at least 7 days prior tomaking the change, shall specify the affected emissions unit and control equipmentnumbers used in this permit, and shall include the updated control equipment datalisted on MPCA Form GI-05A and the planned configuration on MPCA FormGI-05B (current data in Appendix III of this permit). The notification shall alsospecify the new total dryer and control equipment capacity in MMBTU/hr.

Minn. R. 7007.0800, subp. 2

Performance Test: due before end of each 36 months starting 06/01/2006 tomeasure VOC destruction efficiency of one of CE in GP 004. The Permittee shallselect a CE that has not previously been tested, until all have been tested.

The first test is due 6/1/06, then every 36 months thereafter.


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15300017 - 001

Facility Name:

Permit Number:

Subject Item: GP 004 Catalytic Oxidizers

Associated Items: CE 001 Catalytic Afterburner w/Heat Exchanger

CE 002 Catalytic Afterburner w/Heat Exchanger




What to do Why to do itThe requirements listed for GP 004 apply separately to each control device listed inGP 004 (i.e., CE 001). This includes each new catalytic oxidizer added as allowedby GP 003.


A. MONITORING SCENARIOS hdr

Monitoring Scenarios: The Permittee is authorized to install a new temperaturemonitoring system that will monitor the 3-hour rolling average temperatures oneach catalytic oxidizer. Prior to installation of such a system, the Permittee shallcomply with and monitor for the absolute minimum temperature limit listed underScenario 1. After installation of the system, the Permittee shall comply with andmonitor for the 3-hour rolling average temperature limit under Scenario 2.

Minn. R. 7007.0800, subp. 11

Notify: due 30 days after Equipment Installation. The Permittee shall notify theMPCA when the installation of the new temperature monitoring system is complete.The notification shall include the date that the Permittee switched to MonitoringScenario 2.

Minn. R. 7007.0800, subp. 11

B. LIMITS APPLICABLE UNDER BOTH SCENARIOS hdr

The Permittee shall operate and maintain the control equipment such that itachieves a destruction efficiency for Volatile Organic Compounds: greater than orequal to 90 percent control efficiency


The Permittee shall operate and maintain each catalytic oxidizer any time that anyprocess equipment controlled by the catalytic oxidizer is in operation.


C. SCENARIO 1 hdr

Temperature: greater than or equal to 650 degrees F absolute minimum at the inlet,whenever the process equipment attached to it is operating, unless a new minimummust be set pursuant to Minn. R. 7017.2025, subp. 3, based on the averagetemperature recorded during the most recent MPCA approved performance testwhere compliance for VOC emissions was demonstrated. If the temperature dropsbelow the minimum temperature limit, the VOC used during that time shall beconsidered uncontrolled until the minimum temperature limit is once againachieved. This shall be reported as a deviation.


D. SCENARIO 2 hdr

Temperature: greater than or equal to 650 degrees F using 3-hour Rolling Averageat the inlet, whenever the process equipment attached to it is operating, unless anew minimum must be set pursuant to Minn. R. 7017.2025, subp. 3, based on theaverage temperature recorded during the most recent MPCA approvedperformance test where compliance for VOC emissions was demonstrated. If thethree-hour rolling average temperature drops below the minimum temperature limit,the VOC used during that time shall be considered uncontrolled until the averageminimum temperature limit is once again achieved. This shall be reported as adeviation.


E. MONITORING hdr

Monitoring Equipment: The Permittee shall install and maintain thermocouples formeasuring the temperatures as required by this permit. The monitoring equipmentmust be installed, in use, and properly maintained whenever the monitored controlequipment is required to be operated.

Minn. R. 7007.0800, subp. 4

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Facility Name:

Permit Number:

The Permittee shall maintain and operate a thermocouple monitoring device thatcontinuously indicates and records both the inlet and outlet temperatures of thecatalytic oxidizer. The monitoring device shall have a margin of error less than thegreater of +/- 0.75 percent of the temperature being measured or +/- 2.5 degreesCelsius. Under Scenario 2, the recording device shall also calculate the three-hourrolling average inlet temperature.

Minn. R. 7007.0800, subp. 4 and 5

The Permittee shall maintain a continuous hard copy readout or computer disk fileof the inlet and outlet temperatures. Once operating under Scenario 2, thePermittee shall also maintain the calculated three-hour rolling average inlettemperature.

Title I Condition: Limit to avoid classification as majorsource or modification under 40 CFR Section 52.21,Minn. R. 7007.3000; to avoid major sourceclassification under 40 CFR Section 70.2 & 40 CFRSection 63.2; Minn. R. 7007.0800, subp. 4 and 5

Daily Monitoring: The Permittee shall physically check the temperature recordingdevice at least once each operating day to verify that it is working and recordingproperly. The Permittee shall maintain a written record of the daily verifications.

Minn. R. 7007.0800, subp. 4 and 5

Monthly Monitoring: At least once each month during normal operation, thePermittee shall record the temperature rise across the catalyst (outlet temp. - inlettemp.) as well as the date and time of the recording, while the process is running.If it is determined that the catalyst reactivity has been impaired, by comparison ofthe observed temperature rise to the past temperature rise records, the Permitteeshall follow the corrective actions in the O & M Plan. The Permittee shall maintainwritten records of the monitoring and any corrective actions taken.

Minn. R. 7007.0800, subp. 4, 5, and 14

Annual Inspections: At least once per calendar year, or more frequently if requiredby the manufacturer specifications, the Permittee shall inspect the controlequipment internal and external system components, including but not limited to therefractory, heat exchanger, and electrical systems. The Permittee shall maintain awritten record of the inspection and any corrective actions taken resulting from theinspection.

Minn. R. 7007.0800, subp. 4, 5, and 14

Annual Calibration: The Permittee shall calibrate the temperature monitor at leastannually and shall maintain a written record of the calibration and any actionresulting from the calibration.

Minn. R. 7007.0800, subp. 4, 5, and 14

For periods when the catalytic oxidizer is operated above the minimum inlettemperature, the Permittee shall use either one of the following when completingthe VOC and HAP calculations as required elsewhere in this permit:a. The destruction efficiency limit specified in this permit for this equipment (90%); orb. The destruction efficiency determined during the most recent MPCA approvedperformance test. If the tested efficiency is less than the efficiency limit in thispermit, the Permittee must use the tested value in all calculations until theefficiency is demonstrated to be above the permit limit through a new test.

Title I Condition: Limit to avoid classification as majorsource or modification under 40 CFR Section 52.21,Minn. R. 7007.3000; to avoid major sourceclassification under 40 CFR Section 70.2 & 40 CFRSection 63.2; Minn. R. 7007.0800, subp. 4 and 5

Corrective Actions: If the temperature is below the minimum specified by this permitor if the catalytic oxidizer or any of its components are found during the inspectionsto need repair, the Permittee shall take corrective action as soon as possible.

Corrective actions shall return the temperature to at least the permitted minimumand/or include completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the catalytic oxidizer. The Permittee shall keep a record of the typeand date of any corrective action taken.

Minn. R. 7007.0800, subp. 4, 5, and 14

The Permittee shall operate and maintain the catalytic oxidizer in accordance withthe Operation and Maintenance (O & M) Plan. The Permittee shall keep copies ofthe O & M Plan available on site for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14

A-10

TABLE B: SUBMITTALSFacility Name: Banta Publications Group - Long Prairie

Permit Number: 15300017 - 001

12/22/05

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table Aor, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately listone-time only and recurrent submittal requirements.

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

Send any application for a permit or permit amendment to:

AQ Permit Technical Advisor Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- changes that contravene a permit term.

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460

B-1

TABLE B: RECURRENT SUBMITTALSFacility Name: Banta Publications Group - Long Prairie

Permit Number: 15300017 - 001

12/22/05

What to send When to send Portion of Facility AffectedSemiannual Deviations Report due 30 days after end of each calendar

half-year following Permit Issuance. The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occured, the Permittee shall submit thereport stating no deviations.

Total Facility

Annual Report due 31 days after end of each calendar yearfollowing Permit Issuance. The Permittee shallsubmit an annual report by January 31st thatdescribes the changes made at the facilityduring the previous calendar year using thelatest MPCA application forms. The reportshall include the emission unit, stack/vent,group, and control equipment data for anynew or replaced units or control devices. Thereport shall document the VOC and HAP12-month rolling sum calculations for theprevious calendar year. The report shall alsodocument the total facility dryers and controlequipment capacity. The report shall besubmitted with the annual ComplianceCertification listed in Table B. As part of theAnnual Report, the Permittee shall verify andcertify that the facility has maintained minorsource status for New Source Review, Part 63and Part 70.

Total Facility

Compliance Certification due 31 days after end of each calendar yearfollowing Permit Issuance (for the previouscalendar year). To be submitted to theCommissioner on a form approved by theCommissioner. This report covers alldeviations experienced during the calendaryear.

Total Facility

B-2

APPENDIX I Facility Name: Banta Catalog

Permit Number: 15300017-001

Appendix I, Page 1

VOC Calculation Methods

The Permittee shall calculate monthly VOC emissions using the formulas below. If the Permittee tracks material usage on a volume basis, the Permittee shall also record the necessary material density or VOC content in pounds/gallon, and perform the necessary conversions to calculate emissions in tons/month. VOC (tons) = A + B + C + D + E + F + G – H A = VOC emissions, in tons, from ink usage

A = [(U1 x V1 x (1-R) x (1-DE)) + (U2 x V2 x (1-R) x (1-DE)) + …..]/2000 U# = amount of each VOC-containing ink material used in the previous month, in pounds V# = weight percent VOC in U#, as a fraction (e.g., 10 % is 0.10) R = weight fraction of ink material retained in product, 0.20 DE = destruction efficiency of the applicable control system.

B = VOC emissions, in tons, from fountain solution usage that is carried over to the dryer

B = [(U1 x V1 x (CA) x (1-DE)) + (U2 x V2 x (CA) x (1-DE)) + …..]/2000 U# = amount of each VOC-containing fountain solution used in the previous month, in pounds V# = weight percent VOC in U#, as a fraction (e.g., 10 % is 0.10) CA = carryover of fountain solution to the dryer, 0.70 DE = destruction efficiency of the applicable control system.

C = VOC emissions, in tons, from fountain solution usage that is not carried over to the dryer

C = [(U1 x V1 x (1-CA)) + (U2 x V2 x (1-CA)) + …..]/2000 U# = amount of each VOC-containing fountain solution used in the previous month, in pounds V# = weight percent VOC in U#, as a fraction (e.g., 10 % is 0.10) CA = carryover of fountain solution to the dryer, 0.70

D = VOC emissions, in tons, from automatic blanket wash that is carried over to the dryer

D = [(U1 x V1 x (CA) x (1-DE)) + (U2 x V2 x (CA) x (1-DE)) + …..]/2000 U# = amount of each VOC-containing automatic blanket wash used in the previous month, in pounds V# = weight percent VOC in U#, as a fraction (e.g., 10 % is 0.10) CA = carryover of automatic blanket wash to the dryer. For materials that have a vapor pressure < 10 mm Hg, CA = 0.40, for materials that have a vapor pressure > 10 mm Hg, CA = 0. DE = destruction efficiency of the applicable control system.



Appendix I, Page 2

E = VOC emissions, in tons, from automatic blanket wash that is not carried over to the dryer

E = [(U1 x V1 x (1-CA)) + (U2 x V2 x (1-CA)) + …..]/2000 U# = amount of each VOC-containing automatic blanket wash used in the previous month, in pounds V# = weight percent VOC in U#, as a fraction (e.g., 10 % is 0.10) CA = carryover of automatic blanket wash to the dryer. For materials that have a vapor pressure < 10 mm Hg, CA = 0.40, for materials that have a vapor pressure > 10 mm Hg, CA = 0.

F = VOC emissions, in tons, from manual wash solution

F = [(U1 x V1 x (CA)) + (U2 x V2 x (CA)) + …..]/2000 U# = amount of each VOC-containing manual wash solution used in the previous month, in pounds V# = weight percent VOC in U#, as a fraction (e.g., 10 % is 0.10) CA = weight fraction of wash solution remaining in rags as waste. For materials that have a vapor pressure < 10 mm Hg, CA = 0.50, for materials that have a vapor pressure > 10 mm Hg, CA = 0.

G = VOC emissions, in tons, from all other VOC-containing materials

G = [(U1 x V1) + (U2 x V2) + …..]/2000 U# = amount of each VOC-containing material used in the previous month, in pounds V# = weight percent VOC in U#, as a fraction (e.g., 10 % is 0.10)

H = the amount of VOC shipped in waste, other than rags, in tons

H = [(W1 x V1) + (W2 x V2) + …..]/2000 W# = amount, in pounds, of each VOC-containing waste shipped in the previous month. If the Permittee chooses to not take credit for waste shipments, this parameter would be zero. V# = weight percent VOC in W#, as a fraction (e.g., 10 % is 0.10) Waste may be credited at the individual variable level (e.g., A, B, C, etc.) or as a separate variable, H.



Appendix I, Page 3

Total and Individual HAP Calculation Methods The Permittee shall calculate the monthly emissions of each individual HAP and total HAP, separately, using the formulas below. If the Permittee records material usage on a volume basis, the Permittee shall also record the necessary material density or HAP contents in pounds/gallon, and perform the necessary conversions to calculate emissions in tons/month. Pollutant (tons) = A + B + C + D + E + F + G – H Pollutant = each individual HAP and total HAP A = pollutant emissions, in tons, from ink usage

A = [(U1 x V1 x (1-R) x (1-DE)) + (U2 x V2 x (1-R) x (1-DE)) + …..]/2000 U# = amount of each HAP-containing ink material used in the previous month, in pounds V# = weight percent of pollutant in U#, as a fraction (e.g., 10 % is 0.10) R = weight fraction of ink material retained in product, 0.20 DE = destruction efficiency of the applicable control system.

B = pollutant emissions, in tons, from fountain solution usage that is carried over to the dryer

B = [(U1 x V1 x (CA) x (1-DE)) + (U2 x V2 x (CA) x (1-DE)) + …..]/2000 U# = amount of each HAP-containing fountain solution used in the previous month, in pounds V# = weight percent of pollutant in U#, as a fraction (e.g., 10 % is 0.10) CA = carryover of fountain solution to the dryer, 0.70 DE = destruction efficiency of the applicable control system.

C = pollutant emissions, in tons, from fountain solution usage that is not carried over to the dryer

C = [(U1 x V1 x (1-CA)) + (U2 x V2 x (1-CA)) + …..]/2000 U# = amount of each HAP-containing fountain solution used in the previous month, in pounds V# = weight percent of pollutant in U#, as a fraction (e.g., 10 % is 0.10) CA = carryover of fountain solution to the dryer, 0.70

D = pollutant emissions, in tons, from automatic blanket wash that is carried over to the dryer

D = [(U1 x V1 x (CA) x (1-DE)) + (U2 x V2 x (CA) x (1-DE)) + …..]/2000 U# = amount of each HAP-containing automatic blanket wash used in the previous month, in pounds V# = weight percent of pollutant in U#, as a fraction (e.g., 10 % is 0.10) CA = carryover of automatic blanket wash to the dryer. For materials that have a vapor pressure < 10 mm Hg, CA = 0.40, for materials that have a vapor pressure > 10 mm Hg, CA = 0. DE = destruction efficiency of the applicable control system.



Appendix I, Page 4

E = pollutant emissions, in tons, from automatic blanket wash that is not carried over to the dryer

E = [(U1 x V1 x (1-CA)) + (U2 x V2 x (1-CA)) + …..]/2000 U# = amount of each HAP-containing automatic blanket wash used in the previous month, in pounds V# = weight percent of pollutant in U#, as a fraction (e.g., 10 % is 0.10) CA = carryover of automatic blanket wash to the dryer. For materials that have a vapor pressure < 10 mm Hg, CA = 0.40, for materials that have a vapor pressure > 10 mm Hg, CA = 0.

F = pollutant emissions, in tons, from manual wash solution

F = [(U1 x V1 x (CA)) + (U2 x V2 x (CA)) + …..]/2000 U# = amount of each HAP-containing manual wash solution used in the previous month, in pounds V# = weight percent of pollutant in U#, as a fraction (e.g., 10 % is 0.10) CA = weight fraction of wash solution remaining in rags as waste. For materials that have a vapor pressure < 10 mm Hg, CA = 0.50, for materials that have a vapor pressure > 10 mm Hg, CA = 0.

G = pollutant emissions, in tons, from all other HAP-containing materials

G = [(U1 x V1) + (U2 x V2) + …..]/2000 U# = amount of each HAP-containing material used in the previous month, in pounds V# = weight percent of pollutant in U#, as a fraction (e.g., 10 % is 0.10)

H = the amount of the specific HAP shipped in waste, other than rags, in tons

H = [(W1 x V1) + (W2 x V2) + …..]/2000 W# = amount, in pounds, of each HAP-containing waste shipped in the previous month. If the Permittee chooses to not take credit for waste shipments, this parameter would be zero. V# = weight percent of pollutant in W#, as a fraction (e.g., 10 % is 0.10) Waste may be credited at the individual variable level (e.g., A, B, C, etc.) or as a separate variable, H.

APPENDIX II Facility Name: Banta Catalog


Insignificant Activities and General Applicable Requirements The table below lists the insignificant activities that are currently at the Facility and their associated general applicable requirements.

Minn. R. 7007.1300,

subp.

Rule Description of the Activity

General Applicable Requirement

3(A) Fuel use: space heaters fueled by, kerosene, natural gas, or propane. Banta has 39 space heaters with a total capacity of 16.92 MMBtu/hr

Minn. R. 7011.0515 (PM and opacity)

3(D)(2) 3(I) Individual emissions units at a stationary source, each of which

have a PTE of the following pollutants in amounts less than: 2 tpy of CO and 1 tpy each of NOx, SO2, PM/PM10, VOC, and ozone. Banta has several gluing operations and 18 water-based ink jet units that qualify under this subpart.


Minn. R. 7008.4110

Equipment venting PM/PM10 inside a building, provided that emissions from the equipment are filtered through an air cleaning system and vented inside of the building 100% of the time. Banta has paper scrap generation and collection that is controlled and vented internally.


Under Minn. R. 7007.1250, subp. 1(A), the Permittee may add insignificant activities to the stationary source throughout the term of the permit without getting permit amendments. Certain exclusions apply and are listed in Minn. R. 7007.1250, subp. 2. In addition, this permit specifically prohibits the Permittee from making any modifications that would make the source major under NSR. The following table is a listing of the insignificant activities that the Permittee is somewhat likely to add and their associated applicable requirements.

Minn. R. 7007.1300,

subp.

Rule Description of the Activity

General Applicable Requirement(s)

3(B)(1) Infrared electric ovens Minn. R. 7011.0110 (opacity)

3(H)(5) Blueprint copiers and photographic processes; Minn. R. 7011.0110 (opacity)

3(H)(4) Brazing, soldering or welding equipment. Minn. R. 7011.0715 (PM and opacity)

3(H)(8) Cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners.


3(K) Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source.


APPENDIX II Facility Name: Banta Catalog


APPENDIX III Facility Name: Banta Catalog


Emissions Units Description from Delta paper copy only

1

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 15300017-001 This Technical Support Document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp.1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the permit. 1. General Information

1.1. Applicant and Stationary Source Location:

Owner Address Stationary Source/Address (SIC Code: 2752)

Banta Corporation Banta Publications Group – Long Prairie 225 Main Street 100 Banta Road

Menasha, WI 54952 Long Prairie, MN Todd County Andrea Foote (320) 732-2121

1.2. Description of the Permit Action Banta Catalog is a commercial printing facility located in Long Prairie, Minnesota. The Facility consists of heatset web offset lithographic printing presses, dryers, ink jet printers, and pollution control equipment. The main sources of emissions are the press operations that have VOC emissions control equipment. The Facility also has several activities that qualify as insignificant activities under Minn. R. 7007.1300, subp. 3.

1.3. Permit History The original facility was operated under the name The Hart Press, Incorporated, located at 333 Central Avenue in Long Prairie. In 1988, a permit was issued to the facility at its current location; several presses were moved to the new facility from the previous location. The table below shows the permit history of the old and new facilities. Permit Number and Issuance Date

Action Authorized

420-72-I-1; August 8, 1972 Permit issued to The Hart Press, Incorporated, located at 333 Central Avenue, Long Prairie. Installation of control equipment for paper trimming operations.

420-84-I/O-3; July 27, 1984 Install printing press and dryer. 420-87-OT-1; August 20, 1987 Permit type was reissuance for existing facility.

Six offset presses and dryers.

2

Facility moved; subsequent permits issued under new AQ number (420A rather than 420):

420A-88-OT-1; August 26, 1988 Construction of a new facility; one press, to be controlled by catalytic afterburner. Other presses to be moved to this location from previous location, under a separate permit amendment.

Amendment No. 1 to Permit No. 420A-88-OT-1; August 2, 1989

Five presses from old facility permitted under Permit No. 420-87-OT-1 to be installed and operated at new facility, along with a new press. All presses to be controlled by catalytic afterburner.

Operating Permit Application; April 1995

Application for issuance of permit to existing facility.

Minor amendment application; January 20, 1999

Submitted amendment for minor amendment; adding new press. MPCA responded on 3/9/1999 concurring that action is a minor amendment. The amendment was not issued but was to be incorporated into the Title V permit.

Applicability Determination; February 15, 2000

Applicability determination for application for a minor amendment for installation of a new press; application submitted February 11, 2000. MPCA concluded that proposed modification is minor amendment. Authorized to begin construction on February 18, 2000.

1.4. Description of any Changes Allowed with this Permit Issuance

This permit authorizes several changes that can occur during the life of the permit. Specifically, the permit authorizes the installation, replacement and reconfiguration of control equipment, and modification and replacement of the existing emissions units. The permit also incorporates changes as described in the permit amendment applications.

1.5. Facility Emissions:

Table 1. Total Facility Potential to Emit Summary

PM tpy

PM10 tpy

SO2 tpy

NOx tpy

CO tpy

VOC tpy

Single HAP tpy

All HAPs

tpy Total Facility Limited Potential Emissions

2.5 2.5 1.2 74 28 90 9 23.5

Total Facility Actual Emissions (2003)

0.17 0.17 0.01 2.2 0.18 57 HAPs not reported in emission inventory

3

Table 2. Facility Classification

Classification Major Source Synthetic Minor Minor Prevention of Significant Deterioration VOC Part 70 Permit Program VOC Part 63 National Emissions Standards for Hazardous Air Pollutants (NESHAP)

X

2. Regulatory and/or Statutory Basis

New Source Review

The facility has taken limits to avoid major source classification for New Source Review (40 CFR § 52.21).

Part 70 Permit Program

The facility has taken limits to avoid being classified as a major source under the Part 70 permit program.

New Source Performance Standards (NSPS)

There are no New Source Performance Standards applicable to the operations at this facility.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

The facility has accepted limits on Hazardous Air Pollutant (HAP) usage such that it is a non-major source under 40 CFR pt. 63. Thus, no NESHAPs apply.

Minnesota State Rules

Portions of the facility are subject to the following Minnesota Standards of Performance:

• Minn. R. 7011.0610 Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment

• Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment

4

Table 3. Regulatory Overview of Facility

EU, GP, or SV

Applicable Regulations Comments:

FC (Facility)

40 CFR § 52.21 Prevention of Significant Deterioration (PSD). Limits to avoid major source classification under PSD for combustion emissions from the control equipment and dryers.

Minn. R. 7011.0715 Standards of Performance for Post 1969 Industrial Process Equipment. This applies to the press operations and is listed here to simplify the permit.

GP 001 (Total Facility VOC Limits)

40 CFR § 52.21 and 40 CFR § 70.2

Prevention of Significant Deterioration (PSD) and Part 70. Limits to avoid major source classification under PSD and under Part 70 for all non-combustion sources of VOC. It is a rolling limit due to substantial and unpredictable variations in operation.

40 CFR § 63.2 NESHAP for Source Categories. Limits taken to avoid major source classification under the NESHAPs for both total and individual HAPs.

GP 002 (Dryers and Oxidizers)

Minn. R. 7011.0610 Standards of Performance for Direct Heating Equipment. Fuel limited to natural gas only.

GP 003 (Press Operations)

40 CFR § 52.21; 40 CFR § 70.2; 40 CFR § 63.2

PSD, Part 70, NESHAPs. Limits taken to avoid major source and modification classification under PSD, Part 70, and NESHAP programs. This includes a requirement to control emissions from press operations with pre-authorization to replace, reconfigure, or add control equipment meeting the requirements of the permit. Only catalytic oxidizers are pre-authorized for replacement or addition.

Minn. R. ch. 7017 Minnesota Performance Testing Rule. Requirements to test specific oxidizers for VOC control efficiencies.

GP 004 (Catalytic Oxidizers)

40 CFR § 52.21; 40 CFR § 70.2; 40 CFR § 63.2

PSD, Part 70, NESHAPs. Control efficiency and other operating parameter requirements to limit VOC PTE to avoid major source classification under PSD and Part 70 (for future modifications) and NESHAP.

5

3. Technical Information 3.1 Pre-authorized Changes

As briefly described earlier, the permit pre-authorizes certain changes. The Permittee may modify or replace the existing equipment, and add, modify, or reconfigure the various air pollution control equipment, so long as all permit conditions are met.

While the permit allows the replacement or installation of certain equipment, it does not allow any changes that would trigger a new applicable requirement not contained in the permit. The permit sets 12-month rolling limits on VOC and HAP emissions, so annual VOC and HAP emissions cannot increase due to any of the pre-authorized changes. All applicable requirements and necessary monitoring are in the permit. The replacement of existing units with similar technology and capacity units, and the changing or modification of existing units as specified in the permit, will not cause an emissions increase; so they are not modifications and can be made without the need for an amendment.

3.2 Calculations of Potential to Emit

Attachment 1 contains detailed spreadsheets and supporting information prepared by the MPCA and the Permittee. These calculations were performed with the assumption that the ink had a 45 percent VOC content. If the ink content of the ink changes, an amendment may be required depending on the size of the emissions increase.

3.3 Periodic Monitoring

In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements.

In evaluating the monitoring included in the permit, the MPCA considers the following:

• The likelihood of violating the applicable requirements;

• Whether add-on controls are necessary to meet the emission limits;

• The variability of emissions over time;

• The type of monitoring, process, maintenance, or control equipment data already available for the emission unit;

• The technical and economic feasibility of possible periodic monitoring methods; and

• The kind of monitoring found on similar units elsewhere.

Table 4 summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate.

6

Table 4. Periodic Monitoring Emission Unit or Group

Requirement (basis)

Additional Monitoring

Discussion

Total Facility (FC)

Combustion Capacity ≤ 80 MMBtu/hr

Recordkeeping and notifications (see GP 003), annual reporting of total capacity.

PM: ≤ variable depending on airflow; Opacity: ≤ 20% (Minn. R. 7011.0715)

The limits are applicable to each piece of industrial process equipment. Due to the nature of the equipment at the facility, and the material used in the process, the likelihood of violating these emission limits is very small. Therefore, there is no additional monitoring required for these limits.

VOC Limits: GP 001

VOC < 88 tons per year, on a 12-month rolling basis (limit to avoid NSR and Part 70)

Recordkeeping: Daily records of coating usage; On-going MSDS records of coating contents; Monthly calculations of emissions.

Records can be generated on a daily basis for inks, based on meter readings. Records are generated whenever fountain and wash solutions are used, also from meter readings – sometimes this happens multiple times during the day and sometimes every couple days. The remaining materials are very low volume and will be based on monthly usage records.

Individual HAP < 9 tpy on a 12-month rolling basis (limit to avoid NESHAP)Total HAP < 23.5 tpy on a 12-month rolling basis (limit to avoid NESHAP)

Credit can be taken for waste materials collected and shipped off-site (dispensed - waste = emissions). Since this is done at most monthly, calculating emissions more frequently than monthly would result in large spikes (while waste is accumulating) and dips (when waste is shipped) – resulting in possible paperwork violations and days with negative emissions. For these reasons, 12-month rolling limits are reasonable for this Facility.

The VOC and total HAP limits are set low enough to account for the increased VOC and HAP emissions from the pre-authorized combustion sources.

7

Direct Heating Equipment: GP 002

PM: < variable depending on airflow; Opacity: < 20 % (Minn. R. 7011.0610)

None All units use natural gas; therefore, the likelihood of violating either of the emission limits is very small. The Permittee can demonstrate that these units will continue to operate such that emissions are well below the emission limits by only burning natural gas. Since this is a permit condition, the semi-annual deviations report will document any deviations from this condition.

Limited to natural gas and propane, by design

Fuel purchase records.

The requirement to keep fuel purchased records is listed at FC, Total Facility level.

Press Operations: GP 003

Control requirement

See GP 004 for monitoring of controls

Testing requirements are listed at GP 003 in order to streamline the permit. The permit phases the testing over time in order to spread out the costs; one performance test, for one of the CE at the facility, is to be performed every 3 years. The first test is required by 6/1/06, which will be approximately 6 months after permit is expected to be issued. No specific controls are specified to be tested; the Permittee should test an oxidizer that has not previously been tested, however.

More frequent testing is not considered necessary. Temperature monitoring and inspections, as required by the permit, should be sufficient for the most part to maintain good operation of the oxidizers. However, since some deterioration of good operation can occur, and since the calculations used to determine compliance with the synthetic minor limit relies on the controls, it was determined that some testing for destruction efficiency should be conducted.

Replacement, reconfiguration, and installation of additional controls

Recordkeeping and Notification

7-day notice prior to making a control equipment change as well as records and annual report of all changes made.

8

Catalytic Oxidizers: GP 004

VOC: Control Efficiency of 90% (limit to avoid NSR, NESHAP, Part 70)

Temperature limit > 650 °F inlet

Temperature monitoring, Recordkeeping, O & M, inspections

Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance.

The permit allows two temperature-monitoring scenarios. Currently, the Permittee does not have the capability to monitor the 3-hour rolling average temperature and must use the absolute minimum option (e.g., any temperature below the 3-hour tested average is considered a deviation). They may, at some point, purchase software that will calculate the 3-hour averages during the permit term. When it is installed, the Permittee must notify the MPCA that they have begun monitoring the average temperatures.

9

3.4 Insignificant Activities

Banta Direct Marketing has several operations which are classified as insignificant activities. These are listed in Appendix II to the permit. The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per U.S. Environmental Protection Agency’s (EPA) guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Periodic monitoring is not necessary for the insignificant activities at the site for the following reasons.

Based on the fuel used and published emissions factors, it is highly unlikely that the space heaters could violate the applicable requirement. These units, and the inkjet printers, are vented inside a building, so testing is not feasible. For the units vented inside and filtered through an air cleaning system, based on control equipment performance, it is highly unlikely that they could violate the applicable requirement. In addition, these units are operated and vented inside a building, so testing for Particulate Matter (PM) or opacity is not feasible. There are Volatile Organic Compounds (VOC)-emitting units that consist of gluing and water-based inkjet printers. Neither is reasonably expected to generate particulate matter. It is highly unlikely that they could violate the applicable requirement. In addition, these units are operated and vented inside a building, so testing for PM or opacity is not feasible. 3.5 Permit Organization

In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be tracked (e.g., limits, submittals, etc.), should be in Table A or B. The main reason is that the appendices are word processing sections and are not part of the tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these.

Appendix I contains the specific calculation procedures for VOC and HAP emissions. These procedures are too complex to enter into Delta and must go in an Appendix.

Appendix II is a listing of the Facility’s Insignificant Activities and their applicable requirements. This is a fairly standard way to include these in the permit, since it is highly unlikely the MPCA would need to have these as trackable items in Delta.

Appendix III is a printout from Delta of the control equipment and emissions unit description, Forms GI-0BA and GI-05B. This documents the correlation of specific emissions units to specific control equipment. Delta does not show this data as part of the “associated items” in Table A of the permit.

Another area where the permit deviates from guidance is in the use of groups for requirements that apply to individual pieces of equipment. This is done in order to streamline the permit.

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3.6 Comments Received

Public Notice Period: November 16, 2005 – December 15, 2005 EPA 30-day Review Period: November 16, 2005 – December 15, 2005 No comments were received during the notice period. 4. Conclusion Based on the information provided by Banta Corporation, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 15300017-001, and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Paula Connell (permit writer/engineer) David Crowell (enforcement) Andrew Place (stack testing) Elisabeth Freymiller (peer reviewer) Attachments: 1. Calculation Spreadsheets

2. Facility Description and CD-01 Forms

Air Emission Permit NO. 15300017-001 Is Issued to … · obtain information on these programs,...

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