ANALYSIS AND PRELIMINARY DETERMINATION FOR THE … · 2012. 2. 1. · Preliminary Determination,...

ANALYSIS AND PRELIMINARY DETERMINATION FOR THE PROPOSED

SIGNIFICANT REVISION OF REGISTRATION OPERATION PERMIT ROP-C01

AND THE REVISION OF REGISTRATION CONSTRUCTION PERMIT RCP-C01

FOR

THE TYPE C REGISTRATION PERMITS

COVERING PRINTING FACILITIES

WITH LOW ACTUAL EMISSIONS

THROUGHOUT WISCONSIN

Construction Permit Revision No.: RCP-C02

Significant Operation Permit Revision No.: ROP-C02

This review was performed by the Wisconsin Department of Natural Resources, Air Management Program, in

accordance with Chapter 285, Wis. Stats., and Chapters NR 400 to NR 499, Wis. Adm. Code.

Preliminary Determination Signature Date

Preliminary Determination prepared by: /s/ Alexander Torres 7/15/2020

Stationary source modeling conducted by: /s/ John Roth 7/15/2020

Peer Review conducted by: /s/ Mary Oleson 7/15/2020

Compliance Review conducted by: /s/ Ashley Gray 7/15/2020

Regional Supervisor or Central Office Designee

approved by: /s/ Kristin Hart 7/15/2020

Note: Copies of the permit application, the department’s analysis, preliminary determination and draft permit, and

other materials considered by the department when making its preliminary determination can be viewed by using

the Air Permit Search Tool located at http://dnr.wi.gov/topic/AirPermits/Search.html and searching for Permit

Streamlining, or by contacting the Registration Program Coordinator at [email protected].

http://dnr.wi.gov/topic/AirPermits/Search.html

mailto:[email protected]

Preliminary Determination, Permit Nos. ROP-C02 and RCP-C02 of 27

I. INTRODUCTION

Sections 285.60 through 285.69, Wis. Stats. and chapters NR 405 through NR 409, Wis. Adm. Code require certain

types of stationary sources that emit or may emit air contaminants to obtain air pollution control permits. The

Wisconsin Department of Natural Resources (hereinafter “department”) issues air pollution control permits to new

and existing sources of air pollution. Under ss. 285.60(2g), Wis. Stats., NR 406.17, and NR 407.105, Wis. Adm.

Code, DNR may, by rule, specify types of sources that may obtain registration construction permits and registration

operation permits that cover numerous sources with low actual or potential emissions.

Stationary sources that are not exempt from the requirement to obtain a construction permit under ss. 285.60(2g),

(3), (5m) and (6), Wis. Stats. or ch. NR 406, Wis. Adm. Code may not commence construction, reconstruction,

replacement, relocation, or modification unless a construction permit for the project has been issued by the

department. Owners or operators that choose to obtain coverage under a registration construction permit must

submit a registration construction permit application to the department. The application is reviewed following the

applicable provisions set forth in ss. 285.60 to 285.65, Wis. Stats., and s. NR 406.17, Wis. Adm. Code.

Sources that are not exempt from the requirement to obtain an operation permit under s. NR 407.03, Wis. Adm.

Code, are required to obtain or renew an air pollution control permit to continue operation. Owners or operators that

choose to obtain coverage under a registration operation permit must submit a registration operation permit

application to the DNR. This application is reviewed following the applicable provisions set forth in ss. 285.60 to

265.65, Wis. Stats., and s. NR 407.105, Wis. Adm. Code.

DNR may revise operation permits to incorporate new applicable requirements under s. NR 407.14, Wis. Adm.

Code. The procedures set forth in s. NR 407.14, Wis. Adm. Code, must be followed. Prior to issuance of the revised

air pollution control permit, the department is required to prepare an analysis regarding the effect of the proposed

revision a make a preliminary determination on the approvability based on the criteria in s. 285.63, Wis. Stats. This

document is the department’s analysis and preliminary determination for the air pollution control permit revision

described herein and sets forth the legal and factual basis for the draft permit conditions. Any conditions for

approval are contained in the draft permit prepared by the department. The conditions in the draft permit may be

revised in any final permit issued based on comments received or further evaluation by the department. A final

decision will not be made on any permit until the applicable notification, public comment, and hearing

requirements in ss. 285.61 and/or 285.62, Wis. Stats. and/or ss. NR 406.11 and/or NR 407.14, Wis. Adm. Code

have been met.

This preliminary determination is for the revision of the Type C Registration Construction Permit and Type C

Registration Operation Permit. These standardized permits are issued for a class of sources and then, if an

individual facility demonstrates that it meets the permit eligibility criteria, the facility will be "granted coverage"

under the permit. The coverage under both the Type C Registration Construction Permit (RCP) and the Type C

Registration Operation Permit (ROP) is granted concurrently.

Owner/Operator: Various owners/operators of printing facilities located in Wisconsin. Identifying

information contained in permit applications.

Responsible Official: A person responsible for the overall operation of the facility, specified in the application

and meeting the definition in s. NR 400.02(136), Wis. Adm. Code.

Permit Contact Person: Identifying information contained in permit applications


II. PROJECT DESCRIPTION

This revision is being made to the Type C Registration Permits (hereinafter “ROPC”) to reflect current Wisconsin

Administrative Code and to update recordkeeping and reporting requirements. The proposed revisions do not

change eligibility requirements for facilities currently covered under the ROPC. Any new or revised permit

conditions included in the draft permit will apply to both printing facilities currently covered under the ROPC (i.e.

ROP-C01) and facilities that will obtain coverage after the revised ROPC (i.e. ROP-C02) has been issued. A

summary of the most significant changes included in the draft permit is presented below:

1. Addition of new definitions in the glossary of terms.

2. Addition of an abbreviations list.

3. Substitution of the facility-wide emission limit of total particulate matter (PM) for particulate matter with

size less than 10 microns (PM10) and particulate matter with size less than 2.5 microns (PM2.5).

4. Clarification of the obligation of any facility subject to and not exempt from a Reasonable Available

Control Technology Standard (RACT) in sections NR 422.14 to 422.145 must meet those requirements

instead of LACT. Facilities subject to RACT do not have other alternatives for controlling VOC emissions.

5. Changes to the List of RACT Emission Limits (Table 2 of the draft permit) to incorporate current

requirements, including the revised lithographic rules.

6. Clarification of the air quality analysis requirements in Section B of the draft permit and inclusion of a

modeling threshold for Pb that only applies to letterpress printing.

7. Explanation that alternate control efficiencies can only be used for thermal and catalytic oxidizers.

8. Addition of the word “overall” to the headings of Table 5 of the draft permit.

9. Explicitly listed the requirement of preparing and maintaining an up to date Malfunction Prevention and

Abatement Plan (MPAP).

10. Explicitly listed the requirement of controlling malodorous emissions.

11. Explicitly listed the requirement of calibrating control devices.

12. Addition of the “output of bag leak detection system” as monitoring parameter for facilities that operate

baghouses.

13. Changed the due date of the annual summary of monitoring and certification of compliance to March 1st.

14. Explicitly listed the information required in the annual compliance certification.

15. Explicitly listed the option for submitting an under-threshold notification (UTN) instead of the full air

emission inventory (AEI) report when annual air emissions are below the reporting levels in ch. NR 438.

16. Addition of a reminder for the completion and submittal of notifications and/or reports required for

facilities subject to certain NSPS or NESHAP.

17. Addition of material usage thresholds for rotogravure and letterpress printing in Attachments 1 and 2 of the

draft permit.

18. Maximum allowed content of sulfur in distillate fuel oil changed from 0.05% to 0.0015% wt.


III. BACKGROUND

While developing DNR’s Environmental Results Program (ERP) for printers, it was recognized that a subgroup of

printers would need to be covered by an official permit document. On July 11, 2006, the DNR received a petition

from the Department of Commerce to create a Registration Operation Permit for printers to fit that need. On April

20, 2007, the ROP-C01 for printers was issued to provide that coverage. Only printers as described in the source

description below, that maintain emissions of particulate matter (PM10 and PM2.5), VOCs, nitrogen oxides, sulfur

dioxides, and carbon monoxide below 25% of Part 70 major source thresholds identified in s. NR 407.02(4), Wis.

Adm. Code, and emissions of hazardous air pollutants regulated under s. 112(b) of the clean air act below 50% of

the major source threshold identified in s. NR 407.02(4), Wis. Adm. Code, and limit lead emissions to less than 0.5

tons per year have been eligible for coverage under the ROP-C01. In 2019, the Wisconsin Printers Council, formed

under the Wisconsin Printers Green Tier Charter, expressed the need to update the ROP-C01 because several rules

in the Wisconsin Administrative Code have been revised since 2006, including the lithographic printing rules. As a

result of this request, the department has drafted the ROP-C02 as described in this Preliminary Determination.

IV. SITE DESCRIPTION

A facility covered under the ROPC may operate at any location in Wisconsin, as long as it meets the requirements

of ss. 285.60(2g) and 285.63, Wis. Stats., and s. NR 407.105, Wis. Adm. Code, this permit and all other applicable

state and federal air pollution control requirements. This includes facilities located in nonattainment areas of the

state. Note, that facilities that are located in the ozone nonattainment areas may be subject to more stringent

applicable requirements and lower emission thresholds as specified in the state and federal air pollution regulations.

V. SOURCE DESCRIPTION

To qualify for coverage under the ROPC, a facility must be a printer, and must meet the eligibility requirements of

this permit. For the purposes of the ROPC, a printer is any facility that identifies a primary Standard Industrial

Classification (SIC) Code of 23, 26 or 27 or a primary North American Industry Classification System (NAICS)

code of 3231xx or 5111xx for the operations at their business. Printing should not be an ancillary operation at any

business that seeks coverage under this permit.

A facility eligible for coverage under the ROPC may consist of any number of processes, control devices, and

stacks. The types of facilities that may be covered include: non-heatset offset lithographic presses, heatset web

offset lithographic presses, gravure and flexographic presses, screen presses, digital presses, and letterpresses.

Printing-related cleanup operations, fuel burning for building heat, press dryers and some types of control devices

may also be present. The control devices at the facility may include any of those shown in Attachment 1 of this

Preliminary Determination. This permit excludes facilities that have particulate matter emission sources other than

those specifically listed in the permit.

VI. EMISSION UNITS NOT SUBJECT TO CERTAIN REQUIREMENTS

The department and EPA have determined that certain activities at printing operations can be excluded from certain

requirements. In addition to the emissions units, operations and activities listed in s. NR 407.05(4)(c)9., Wis. Adm.

Code, the Technical Support Document (TSD) For Title V Permitting Of Printing Facilities published by the EPA’s

Office of Air Quality Planning and Standards in January 2005 and revised in June 2007 (Pages 29-30)

(https://www.epa.gov/air-emissions-monitoring-knowledge-base/technical-support-document-title-v-permitting-

printing), lists activities in the printing industry that permitting agencies may consider insignificant and which do

not require emissions calculations to be submitted with an application. Additionally, for facilities meeting the

eligibility requirements of the ROPC, calculations included below show that emissions from natural gas fired

control devices, press dryers, and other heating units are also insignificant. The additional insignificant emission

units for printing facilities eligible for coverage under this permit are listed in Attachment 2 of this document.

VII. EMISSION CALCULATIONS

This section provides information describing how air pollution emissions from printing facilities are determined.

This information provides the department’s legal and factual basis for how the emission estimates support the draft

https://www.epa.gov/air-emissions-monitoring-knowledge-base/technical-support-document-title-v-permitting-printing

https://www.epa.gov/air-emissions-monitoring-knowledge-base/technical-support-document-title-v-permitting-printing


permit conditions. The following emission calculations were included in the Preliminary Determination for the

ROP-C01 issued on April 20, 2007.

Calculations to show eligibility under the ROPC:

The pollutants of concern at printing facilities are volatile organic compounds (VOCs) and hazardous air pollutant

(HAP) emissions. HAP emission estimates are included in Hazardous Air Pollutant Section of this Preliminary

Determination. Emissions of nitrogen oxides (NOx), particulate matter (PM10 and PM2.5), carbon monoxide (CO),

and sulfur dioxide (SO2) emitted from fuel combustion sources are considered insignificant as long as facilities

burn only natural gas, propane, or distillate fuel oil with a sulfur content of 0.0015% by weight or less. Additional

particulate matter is emitted from paper trim systems but, calculations included below show that these systems are

insignificant sources of emissions. Facilities that use heatset web offset printers may have particulate matter

emissions from the volatilization of ink oils in dryers. The permit contains requirements for facilities using heat set

web offset presses that ensure protection of ambient air quality standards for particulate matter emissions.

VOC Emissions

Compliance assistance tools have been created to help printers determine their VOC emissions. These tools provide

printers with two options to determine their VOC emissions for purposes of ROPC eligibility. The options are

either to use the Annual Material and Fuel Usage Thresholds or to calculate actual emissions. Attachment 3 of this

Preliminary Determination contains the Annual Material and Fuel Usage Thresholds developed by DNR based on

the EPA’s Technical Support Document for Title V Permitting of Printing Facilities dated June 2007. A standard

VOC content of 7.0 lb VOC/gal was used to calculate the material usage thresholds. Printers applying for coverage

under the ROPC can use the Annual Material and Fuel Usage Thresholds to determine whether or not they can meet

the 25 TPY emission cap for VOCs.

Emissions from Fuel Combustion Sources

Attachment 3 of this Preliminary Determination also contains the fuel usage rates and heat input capacities that can

be used by facilities to ensure that NOx, SO2 and CO emissions will be less than 25 TPY. There are no other

expected sources of NOx, CO and SO2 at printers other than the fuel combustion.

Particulate Matter Emissions

Particulate matter less than 10 micrometers in diameter (PM10) and particulate matter less than 2.5 micrometers in

diameter (PM2.5) will primarily come from the ink oils used in heatset web offset printers. Small amounts of PM10

come from paper trim systems, and emission from fuel combustion units must also be considered. It is the

department’s policy that emission from mechanical and low temperature sources do not emit PM2.5. Based on

definitions in ss. NR 400.02(123m) and (124), Wis. Adm. Code, direct PM2.5 emissions cannot exceed PM10

emissions. Since PM10 and PM2.5 have the same major source thresholds, emission estimates of PM10 are sufficient

for determining if the source can meet the ROPC emission limits.

Particulate Matter Emissions from Paper Trim Systems

Generally, paper trim systems are considered to be insignificant sources of air pollution. For the purposes of

calculating facility wide particulate matter emissions, it will be assumed that paper trim systems contribute 1 TPY

PM10 to the facility wide total PM10 emissions.

Particulate Matter Emissions from Fuel Combustion

The draft ROPC limits fuels to natural gas, propane, and distillate fuel oil with less than 0.0015% sulfur by weight

or less. At the fuel usage rates listed in Attachment 3, PM10 emissions from fuel combustion will be not exceed 2.5

TPY from fuel oil or 1 TPY from gaseous fuels. It will be assumed that fuel combustion contributes 2.5 TPY PM10

to the facility wide total PM10 emissions.


Particulate Matter Emissions from Heatset Web Offset Presses (ink oils)

The only printing operations at facilities eligible for coverage under this permit that generate significant amounts of

particulate matter emissions are heatset web offset presses. A heatset web offset press that has dryer exhaust, will

generate particulate matter from the ink oil vaporization. In order to ensure that emissions are less than 25 tons per

year, other sources of particulate matter emitted from the facility must be included. If fuel combustion emits no

more than 2.5 TPY of PM10 and a paper trim system emits less than 1 TPY, then the heatset web offset presses can

emit up to 21 TPY of PM10, and the printing facility is still eligible for the ROPC.

Ink usage rate and air flow are two variables most likely to fluctuate between facilities when determining how

much PM10 a heatset web offset press emits. The molecular weight and vapor pressure of the ink oils can vary.

According to a printing trade association contact, five different oils are used to formulate heatset inks as shown in

Table 1.

Table 1. Vapor Pressure and Molecular Weight of Magie Brother’s© Heatset Litho Magie Ink Oils

Ink Oil Vapor Pressure in mmHg @ 68oF Molecular Weight

M500 0.001 228

M52 0.001 230

M40 0.004 168

M47 0.008 203

M470 0.012 207

The spreadsheet titled WI_HeatsetPMCalcs.xls

(https://dnr.wi.gov/topic/AirPermits/documents/WI_HeatsetPMCalc.xls) is used to calculate corresponding ink

usage rates from particulate matter emissions based on ink oil properties and air flow.

Uncontrolled Presses

The maximum ink usage rates that would result in compliance with the VOC emission caps in this permit are listed

in Attachment 3 of this Preliminary Determination. This attachment shows that the VOC eligibility threshold for

uncontrolled heatset web offset presses, based on material usage, is 50,000 pounds of ink per year. Using

WI_HeatsetPMCalcs.xls it can be shown that an ink usage rate of 50,000 pounds per year results in, at most, 8.9

TPY PM10 emissions from volatilization of ink oils.

Total PM10 would be a maximum of 12.4 TPY from any facility with uncontrolled heatset printers.

8.9 TPY PM10 inks + 2.5 TPY PM10 fuels + 1 TPY PM10 paper handling = 12.4 TPY PM10

Therefore, a facility with uncontrolled heatset web offset presses will not exceed the PM10 emission cap in the

ROPC as long as the Annual Material and Fuel Usage Thresholds in Attachment 3 are met.

Controlled Presses

Control devices used at printing facilities mainly control VOC emissions. However, these control devices also

greatly reduce the particulate matter emissions generated from ink oils. A destruction efficiency of >90% VOCs is

required by Wisconsin’s RACT rule for printers found in ss. NR 422.14, NR 422,142, NR 422.143, and NR

422.145, Wis. Adm. Code. WI_HeatsetPMVCalcs.xls can again be used to estimate the particulate matter emissions

at maximum ink usage rates at controlled heatset web offset presses. The spreadsheet shows that a maximum ink

usage rate of 89 pounds per hour will result in emissions just below the cap at controlled printing facilities. At a

maximum ink usage rate of 89 pounds ink per hour and a control efficiency of 90% the maximum particulate matter

emissions will be approximately 13.1 TPY PM10. This results in total PM10 emissions of:

https://dnr.wi.gov/topic/AirPermits/documents/WI_HeatsetPMCalc.xls


13.1 TPY PM10 controlled heatset + 2.5 TPY PM10 fuel + 1 TPY PM10 paper trim = 16.62 TPY PM10

Therefore, a facility with controlled heatset web offset presses will not exceed the PM10 emission cap in the ROPC

as long as the Annual Material and Fuel Usage Thresholds in Attachment 3 is met.

Lead Emissions

Lead (Pb) is primarily emitted from letterpress printing. The use of Pb had decreased but still continues to be used

at some facilities. Pb particulates are emitted from type metal production. The melting pot is the major source of

emissions. Pb emissions can be controlled using baghouses. In the Locating and Estimating Air Emissions from

Sources of Lead and Lead Compounds published by the EPA’s Office of Air Quality Planning and Standards in

May 1998 (https://www3.epa.gov/ttn/chief/le/lead.pdf) emissions of Pb lead are estimated at 35% of the total

particulate matter from type metal production and remelting. The average emission factor is 2.5 x 10-1 lb of Pb per

ton of lead processed.

In order to meet the 0.5 TPY Pb limit of the draft ROPC, the maximum amount of Pb that can be processed at

facility is 8 x 106 lb per year. This amount of processed material is unrealistic for small printing facilities eligible

for coverage under ROPC. Therefore, letterpress printing will not exceed the Pb emission cap in the ROPC.

VIII. APPLICABLE REQUIREMENTS

The draft ROPC contains a cap on facility emissions and restricts the equipment allowed at a facility covered by

this permit. While registration permits identify and explain most applicable requirements, they do not specifically

identify and explain all applicable requirements. A facility covered under the ROPC must meet all applicable air

pollution regulations in chs. NR 400 to 499, Wis. Adm. Code, and all other applicable state, local, and federal air

pollution requirements. The ROPC contains compliance demonstration methods, monitoring and record keeping

requirements necessary to demonstrate compliance with emission caps and other applicable requirements. The

department’s Small Business Environmental Assistance Program (SBEAP), has developed, and continues to

develop, guidance to assist facilities that will be covered under the Registration Permits in determining and

complying with their applicable air pollution regulations.

Some printer-specific applicable requirements are included in the ROPC. Those are identified below.

VOC Emissions

All printers are required to follow the organic compound material handling requirements in s. NR 419.03, Wis.

Adm. Code, as well as the DNR policy regarding retention in shop rags, as appropriate. Printing facilities that meet

the Reasonably Available Control Technology (RACT) applicability under ss. NR 422.14 to 422.145 are required

to comply with the VOC limits, work practices, testing and recordkeeping requirements listed in the rules. The

printer RACT requirements are summarized in Attachment 4 of this document.

If the printing facility is not subject to any section in ss. NR 422.14 to 422.145 and emits more than 15 pounds per

day of organic compounds, it shall meet one of the VOC control requirements below for each process line:

• Apply 85% control as applicable below:

o For a process line constructed or last modified before August 1, 1979, control photochemically

reactive organic compound emissions from the process line by at least 85%.

o For a process line constructed or last modified on or after August 1, 1979, control volatile organic

compound emissions from the process line by at least 85%.

• Apply Latest Available Control Techniques (LACT) and Operating Practices demonstrating best current

technology for the process line:

o For each process line on which construction or modification last commenced prior to August 1,

1979, and electing to meet LACT, the owner or operator shall limit emissions of photochemically

https://www3.epa.gov/ttn/chief/le/lead.pdf


reactive organic compounds to less than 10 tons per calendar year.

o For each process line on which construction or modification commenced on or after August 1,

1979, and electing to meet LACT, the owner or operator shall limit emissions of volatile organic

compounds to less than 10 tons per calendar year.

• If a printing process line meets the specific applicability requirements in any section from ss. NR 422.14 to

422.145, Wis. Adm. Code, but is not subject to that section based on an applicable exemption in ch. NR

422, Wis. Adm. Code,, the owner or operator may elect to meet the emission limitations in ss. NR 422.14

to 422.145, Wis. Adm. Code for the process line in lieu of meeting 85% control or LACT.

For the purposes of this permit, the definition of a process line for printing operations includes a press and its

associated on-machine and off-machine cleaning operations. A general demonstration has been made by the

department in the Preliminary Determination for ROP-A01 that 85% control of VOCs is infeasible when VOCs from

each process line are capped at 10 tons per year. Cost may be considered when determining whether or not a control

technology is considered to be technologically infeasible. The Preliminary Determination for ROP-A01 used the

EPA's Air Compliance Advisor program to estimate the control cost for 10 tons per year of organic compounds. Table

2, below, contains the costs calculated for control of two common organic compounds, methanol, and toluene. As

can be seen in Table 2, the least expensive control device has a cost of control over $8,000 per ton. This is considered

to be technologically infeasible for this analysis.

Table 2. Cost of VOC Control

Control Device Cost of control for methanol

($/ton)

Cost of control for toluene

($/ton)

Water absorption $42,245 $8,113

2 bed carbon adsorption $29,459 $9,173

3 bed carbon adsorption $29,803 $9,231

Regenerative thermal oxidizer $8,819 $16,260

Fixed bed catalytic incinerator $9,636 $20,317

Fluidized bed catalytic incinerator $9,917 $21,371

Recuperative thermal incinerator $14,092 $28,186

Self-support flare $128,769 $581,463

Multi-stage condenser $41,731 -

Eligible facilities can demonstrate compliance with LACT by meeting Annual Material and Fuel Usage Thresholds

listed in Table 9 of Attachment 3. Facilities must indicate the VOC control elections in the ROPC application.

Particulate Matter Emissions

Facilities that have sources of particulate matter other than the sources specifically listed in the draft ROPC are not

eligible for the permit coverage. The only allowed sources of particulate matter include sources listed in

Attachment 2, particulate matter from fuel combustion where the allowed fuels are natural gas, propane, and

distillate fuel oil with a sulfur content of 0.0015% by weight or less, and printing presses. The only press type with

any particulate matter emissions is the heatset web offset lithographic press. Particulate matter is generated from the

ink oils as they are vaporized after the press dryer. Particulate matter emissions from printing presses and fuel

combustion are subject to the limitations in ss. NR 415.05 and 415.06, respectively.

Visible Emissions

Facilities that have heatset web offset presses emitting particulate matter are subject to visible emission limitations

under ss. NR 431.04 and 431.05. Because other types of printing operations covered by this permit will not have

visible emissions, this section of the permit only applies to facilities with heat set web offset presses or fuel

combustion units.


Recordkeeping Requirements

All printers are required to maintain raw material purchase or usage records and calculate total emissions on a

calendar year basis. All materials and fuels must be included. If the total heat input capacity of all fuel combustion

units combined at a facility is 39 MMBtu/hr, or less, the facility may keep a list of combustion units and their heat

input capacities and all fuel types combusted each year in lieu of actual fuel purchase or usage records.

Printers will need to keep records necessary to demonstrate that they comply with the cap of 10 TPY VOCs at each

process line if subject to LACT, or other records to demonstrate they comply with applicable VOC emissions

standards outlined in the two tables in Attachment 3 of this document.

Appropriate records are required if visible emissions observations are required.

Additional Requirements

The draft ROPC also includes the following requirements:

• Maintain calculations of the calendar year emissions of criteria pollutants and federal hazardous air

pollutants.

• Maintain records of stack parameters;

• Maintain records of all air quality analyses conducted for, or under, the Registration Permit;

• Monitor air pollution control devices and maintain records of control device parameters as specified in

Attachment 1;

• Maintain a list of the control device operating parameters that are representative of proper operation of

those devices;

• If the facility may emit hazardous substances or may emit more than 15 pounds in any day or 3 pounds in

any hour of any air contaminant for which emissions limits have been adopted, the source is required to

prepare and follow a malfunction prevention and abatement plan to prevent, detect and correct

malfunctions or equipment failures which may cause any applicable emission limitation to be violated or

which may cause air pollutant. This plan shall be in writing and updated at least every 5 years;

• Perform monitoring and maintain records sufficient to demonstration compliance with all applicable

requirements, including those in ch. 285, Wis. Stats., chs. NR 400 to NR 499, Wis. Adm. Code, 40 CFR

Parts 60 and 63 (New Source Performance Standards and National Emission Standards for Hazardous Air

Pollutants) and all other applicable sections of the federal Clean Air Act.;

• Submit an annual summary of monitoring and certification of compliance;

• Submit an annual air emission inventory report, or notification that emissions were below ch. NR 438, Wis.

Adm. Code, thresholds;

• Notify the department of any ownership change; and

• Prior to making a change that renders the facility ineligible for the Registration Permit, submit a

construction and operation permit application, or an application for an exemption, and a request to

withdraw the permit coverage.

Prohibitions

• The owner or operator may not add or change emission units, operations, or stacks so that they cause or

exacerbate a violation of an ambient air quality standard;


• The owner or operator may not add or change emission units or operations so that the emissions of HAPs

regulated under ch. NR 445, Wis. Adm. Code, require a case-by-case BACT or LAER determination.

• The owner or operator may not add or change equipment or raw materials or operations such that the

calendar actual emission rates would exceed an emission limit in A.1 of the draft ROPC.

• The owner or operator may not make a change that results in the facility being classified as a major source

under chs. NR 405, NR 407 or NR 408, Wis. Adm. Code or that requires the source to obtain a Part 70

(Title V) permit.

• The owner or operator may not make a change to the primary activity that would result in the facility not

been classified as a printing facility, or result in printing becoming an ancillary operation.

IX. HAZARDOUS AIR POLLUTANT REVIEW

State HAPs (ch. NR 445)

A facility covered under the ROPC is required to comply with ch. NR 445, Wis. Adm. Code. The facility shall

demonstrate compliance using any of the methods described in s. NR 445.08, Wis. Adm. Code. However, facilities

eligible for coverage under the ROPC may not be subject to Best Available Control Technology (BACT) or Lowest

Achievable Emission Rate (LAER) under ch. NR 445, Wis. Adm. Code.

All facilities covered under this registration permit are required to be in compliance with ch. NR 445, Wis. Adm.

Code. Attachment 3 of this document contains the material usage levels that protect the standards for HAPs that are

most often found in press materials used by printers. Printers may use these material at or below these usage levels

to help demonstrate compliance with ch. NR 445. Fuels allowed under the ROPC are classified as group 1 virgin

fossil fuels, and therefore any HAPs resulting from combustion of those fuels are exempt from the requirements of

s. NR 407.05(1), Wis. Adm. Code, per s. NR 445.07(5)(a), Wis. Adm. Code. Also, because of the nature of printing

operations, particulate based HAPs are not expected to be emitted at significant rates.

Facilities must calculate HAP emissions from non-combustion units and determine the usage level at which they

can demonstrate compliance with the hazardous air pollution regulations. In general, because of the restrictions on

ink usage and the other sources of volatile organic compound emissions from printers allowed coverage under this

permit, all printing facilities covered by this permit are expected to be in compliance with ch. NR 445, Wis. Adm.

Code.

Federal HAPs

A facility covered under the ROPC is required to comply with 40 CFR Part 63 (NESHAP). Printing facilities

eligible for coverage under the ROPC are an area source of federal HAPs and, therefore, not subject to 40 CFR Part

63, Subpart KK for the Printing and Publishing Industry. Facilities operating emergency generators are eligible for

coverage under ROPC and must comply with the applicable requirement in NESHAP Subpart ZZZZ for Stationary

Reciprocating Internal Combustion Engines. Facilities that operate a boiler subject to the requirements in NESHAP

Subpart JJJJJJ or NSPS Dc are also eligible for ROPC and must comply with any applicable requirements of

NESHAP Subpart JJJJJJ or NSPS Dc.

X. CONTROL TECHNOLOGY REVIEW

Air pollution emission control technologies at the facility may include those listed in Attachment 1 of this

Preliminary Determination. Facilities covered under the ROPC that use control devices to meet requirements listed

in the permit are required to operate, monitor, and maintain the control devices at the facility. Control devices used

to demonstrate eligibility under the permit must meet, at a minimum, the overall control efficiencies listed in the

ROPC. Facilities may use higher control efficiencies (i.e. alternate control efficiency) than those listed in the permit

for thermal and catalytic oxidizers, if they perform department- approved stack tests every 5 years to verify the

control device is meeting the control efficiency they are using.


To ensure that covered facilities meet pollution control device compliance demonstration requirements, the

following conditions are included in the draft ROPC:

Control Device Operation: Monitor the operation of all control devices to ensure they are operating properly

according to the requirements listed in Table 5 of Attachment 1.

Calibrate or inspect measurement instruments: All instruments used to measure operational variables for air

pollution control equipment shall be calibrated yearly or at a frequency based on good engineering practice as

established by operational history, whichever is more frequent. When calibration is not appropriate, equipment

must be inspected for proper operation.

Maintenance: Maintain control devices as recommended by the manufacturer, or at a frequency based on good

engineering practice as established by operational history, whichever is more frequent.

Records: Temperature logs shall be kept electronically or on continuous hard copy printout, at the frequency

indicated. Keep a log recording when maintenance takes place and what actions were taken.

Malfunctions and Excess Emissions: Facilities must notify DNR by the next business day following any event that

causes them to operate any part of the printing operation connected to a control device without operating the control

device.

Operation without the control device may cause the facility to exceed emission standards unless they are:

1. operating without the control device to prevent explosions solely during cold start-up of the equipment, or

2. if the device is out of service, using only materials that meet the emission standards as applied until the

device is back in service.

Records: Keep a log of when control device has been shut down and restarted while the unit is still in operation.

This information may be necessary to calculate actual emissions.

Malfunction Prevention and Abatement Plans: If the source may emit hazardous substances or may emit more

than 15 pounds in any day or 3 pounds in any hour of any air contaminant, they are required to prepare and follow a

malfunction prevention and abatement plan to prevent, detect and correct malfunctions or equipment failures which

may cause any applicable emission limitation to be violated or which may cause air pollution. This plan must be in

writing and updated at least every 5 years. The plan must include the items listed in ss. NR 439.11(1)(a) – (h), Wis.

Adm. Code.

Control of Malodorous Emissions: The owner or operator of a facility shall not cause, allow or permit emission

into the ambient air of any substance or combination of substances in such quantities that an objectionable odor is

determined to result unless preventive satisfactory to the department are taken to abate or control such emission.

The abatement or control requirement may include but are not limited to the corrective actions listed in ss. NR

429.03(3)(a) – (e), Wis. Adm. Code.

XI. CONSTRUCTION UNDER THE ROPC

Pursuant to s. NR 407.105(5)(a), Wis. Adm. Code, no construction permit is required prior to commencing

construction, reconstruction, replacement, relocation or modification of a stationary source if the facility is covered

under a registration operation permit and the construction, reconstruction, replacement, relocation or modification

will not result in the facility violating any term or condition of the registration operation permit. When constructing

under the ROPC, the permittee may be required to conduct an air quality analysis prior to making the change to

ensure that the change will not violate any air quality standard. These air quality analysis requirements are further

discussed in the Air Quality Review section of this document.


XII. AIR QUALITY REVIEW

Section 285.63(1)(b), Wis. Stats. allows the department to approve a permit application if it finds the source will

not cause or exacerbate a violation of any ambient air quality standard or ambient air increment. See the Criteria for

Permit Approval section for additional information and other criteria for permit approval. This section describes the

department’s finding under s. 285.63(1)(b), Wis. Stats.

Printers are primarily sources of volatile organic compounds (VOC) emissions, and VOCs are precursors to ozone.

Ozone is a regional pollutant which is formed in the atmosphere through complex chemical reactions. There is no

approved regulatory dispersion model for predicting the impact that VOC emissions from direct stationary sources

will have on ozone concentrations. There are no ambient air quality standards specifically for VOCs. Therefore,

dispersion modeling of VOC emissions from direct stationary sources is not performed. The ROPC requires

compliance with all RACT and other regulations that apply in ozone nonattainment counties that are in place to

address compliance with the ozone standards.

Printing facilities can also emit other criteria pollutants from combustion units. Emissions of PM10 may be emitted

from printers using heatset web offset presses. A modeling analysis to show the facility’s impact on the PM10

standard is required as described in the next section.

Fine particulate matter may be emitted from high temperature and combustion sources at facilities eligible for

coverage under the ROPC. For the reasons described in Appendix B of the “Wisconsin Air Dispersion Modeling

Guidelines”, dated March 2018, the department has concluded that direct PM2.5 emissions from existing sources,

minor new sources, and minor modifications of sources do not cause or exacerbate violation of the PM2.5 air quality

standard or increment. This conclusion and the information contained in Appendix B of the “Wisconsin Air

Dispersion Modeling Guidelines” (https://dnr.wi.gov/files/PDF/pubs/am/AM528.pdf) serves as the department’s

finding pursuant to s. 285.63(1)(b), Wis. Stats for the PM2.5 air quality standard and increment and sets forth the

legal and factual basis for the draft permit conditions.

The “Wisconsin Air Dispersion Modeling Guidelines”, dated March 2018, stipulates that direct NOx emissions

from stationary sources that are not large and comparatively steady sources of direct NOx emissions, do not cause

or exacerbate violation of the 1-hour NO2 ambient air quality standard. This conclusion and the information

contained in Appendix C of the “Wisconsin Air Dispersion Modeling Guidelines” serves as the department’s

finding pursuant to s. 285.63(1)(b), Wis. Stats for the 1-hour NO2 air quality standard and sets forth the legal and

factual basis for the draft permit conditions. Large and comparatively steady sources of NOx emissions include

sources with one or more individual combustion units with a maximum heat input rating of 250 MMBtu/hr, or

more. Printing facilities eligible for coverage by the ROPC do not operate individual combustion units with a

maximum heat input of 250 MMBtu/hr, or more. Therefore, an air dispersion modeling analysis is not required to

assess the impact of these facilities on 1-hour NO2 concentrations.

Air emissions from intermittent units that do not have a set operating schedule, operate for short periods of time

during the year (generally outside of the facility’s control) and do not contribute to the normal operation of the

facility are not required to be included in the dispersion modeling analysis.

Permit Requirements to Protect Air Quality

The draft ROPC contains the following requirements that will ensure that all facilities covered by the permit attain

and maintain the ambient air quality standards:

First, the permit contains an annual emission cap of 25% of major source threshold for emissions of PM10, PM2.5,

SO2, NOx, CO, and VOC, a cap of 0.5 tons per year on lead, and a cap of 50% of major source threshold for

emissions from federally regulated hazardous air pollutants. These emission caps reduce the facility’s longer term

impact on air quality.

Second, the permit requires compliance with ch. NR 445, Wis. Adm. Code, which includes most hazardous air

pollutants regulated under the Clean Air Act and a number of hazardous air contaminants not regulated under the


Clean Air Act. The requirements of ch. NR 445, Wis. Adm. Code protect ambient air standards for each regulated

contaminant.

Third, coverage under this permit is restricted to printers and the draft ROPC contains restrictions on the types of

particulate matter emitting equipment and fuels that may be used at the eligible printing facility as follows:

• Combustion units at the facility covered by this permit may burn only natural gas, propane, or distillate fuel

oil containing 0.0015% sulfur or less by weight. This ensures only insignificant quantities of SO2 will be

emitted.

• A facility covered by this permit may emit particulate matter only from emission units listed in Attachment

2, heatset web offset presses, and combustion units.

By limiting the types of fuel and equipment that may be used, the ROPC not only limits the annual emissions of air

pollutants, but also restricts the hourly emission rates of pollutants with short term air standards, like PM10 and SO2.

However, annual emission caps and equipment and material restrictions alone will not assure protection of ambient

air quality standards for all pollutants, all the time. Stack configurations must also be considered. Because

eligibility for this permit is limited to small printers with specified fuels and sources of particulate matter emissions,

only certain stacks will have emissions of pollutants for which there are ambient air quality standards, such as SO2,

NOx, CO, or PM10. All other stacks will emit insignificant quantities of these pollutants or will emit VOC, a

pollutant for which there is no ambient air quality standard. To assure protection of the ambient air quality

standards for stacks venting emissions from heatset web offset presses and combustion units, the permit contains

the following stack requirements:

• The stack-vented emissions shall be exhausted from unobstructed discharge points that are within 10

degrees of vertical;

• Each stack must be taller than any building that influences the dispersion of emissions from the stack.

A building is considered to influence the dispersion of emissions from any stack that exists within a

circle around the building, the radius of which is 5 times the height of the building.

Facilities with heatset web offset presses and combustion units venting to stacks that do not meet the above stack

requirements may still apply for coverage under the ROPC, provided they must submit air quality modeling results

that show that maximum controlled emissions will not cause or exacerbate a violation of ambient air quality

standards.

Additional Requirements for Facilities with Heat Set Web Offset Presses and that do not Meet Stack Parameter

Requirements

The stack requirements, coupled with the annual emission caps and equipment and fuel restrictions, will provide

protection of all air pollution standards for printing facilities eligible for coverage, with the possible exception of

facilities with heatset web offset presses. Additional considerations are necessary to ensure protection of the 24-

hour PM10 standard for facilities with heatset web offset presses.

PM10 could be emitted from stacks venting heatset web offset printing presses at rates that may cause a violation of

the standard, especially when operated without control devices. For that reason, the department has included

additional requirements in the draft ROPC for facilities with heatset web offset presses.

Facilities that have heatset web offset presses must undergo ambient air quality modeling to ensure protection of the

24-hour PM10 standard before they receive coverage under the permit and if they make changes that would affect

their ability to comply with the air quality standards after they are covered, with the exceptions noted below. Only

facilities with heatset presses will require air quality modeling of PM10 emissions. If PM10 modeling is required,

then emission rates from all particulate matter sources, including emissions from combustion units must be

included in the model.

In some cases, facilities with heatset presses will not emit particulate matter at rates that would cause a violation of

the PM10 standard. A facility does not have to model if it can meet one of the following:


• All heatset web offset presses used at the facility emit less than 0.5 pounds of PM10 per hour from each

stack.

• Annual maximum controlled emissions of PM10 from all heatset web offset presses and combustion units

combined at the facility are less than 5 tons/year, excluding emissions from the heatset web offset presses

that emit less than 0.5 pounds of PM10 per hour.

Generally, heatset web offset presses that operate controls are able to meet the above rates.

Facilities that don’t meet stack requirements outlined above and facilities that have heatset web offset presses with

particulate matter emissions greater than the rates listed above (generally uncontrolled presses) may have the

potential to cause or exacerbate a violation of the 24-hour PM10 standard. Therefore, those facilities will be required

to provide information to the DNR so that air quality modeling can be performed prior to granting coverage under

the Registration Permits, and perform air quality modeling prior to making changes at their facility that would

affect their ability to comply with the PM10 standard.

Modeling Requirements for Letterpress Printing

Letterpress printing may have the potential to emit lead (Pb) at a rate that may cause or exacerbate a violation of the

rolling 3-month average standard. Any letterpress facility with maximum controlled emissions of lead exceeding

0.2 tons per year is required to conduct an air quality modeling analysis prior to DNR granting coverage under the

ROPC. Under the current Wisconsin Administrative Code, facilities with emission less than 0.2 tons of lead per

year are not required to report such emissions in air pollution operation permit applications or the Wisconsin

Annual Air Emission Inventory.

XIII. COMPLIANCE DEMONSTRATION

The draft ROPC includes compliance demonstration methods for the limitations contained in the permit. Covered

facilities must ensure that appropriate methods for demonstrating compliance with all other applicable emission

limitations in chs. NR 400 - 499, Wis. Adm. Code, and in any applicable state or federal requirement are in place

and followed. The ROPC requires submittal of an annual compliance certification and monitoring report and the

department performs evaluations of all sources covered under a registration permit to ensure that the emissions

reported to the Wisconsin Air Emissions Inventory are below the facility-wide emission limits in the permit.

XIV. FACILITY EMISSIONS

The draft ROPC contains emission limits of less than 25% of the Part 70 major source thresholds for PM10, PM2.5,

VOC, NOx, SO2 and CO, 50% of the major source thresholds for single and combined federal, and 0.5 tons per

year of lead. A summary of the annual emission limits are included in Table 3 below. These limits are expressed as

calendar year emission caps. Note: The emission limits depend on the attainment status of the area where the

facility is located. The permit contains monitoring and recordkeeping requirements necessary to demonstrate

compliance with these limits.

The ROPC allows a facility to take credit for emission reductions through use of a control device only if the control

device is listed as an allowed control device and meets the minimum overall control efficiency listed in the permit.

Overall control efficiency is the fraction of an air contaminant captured and controlled by the air pollution control

system. When calculating emissions for units controlled by a control device, the minimum overall control

efficiency listed in Attachment 1 of this document must be used unless a higher efficiency is required by an

applicable requirement or, as specified in the ROPC, the facility has performed a department approved stack test

within the last 5 years demonstrating a higher control efficiency. Stack testing must be repeated every 5 years in

order to continue using the higher control efficiency. Emission Determination for the Printing Industry can be found

at https://dnr.wi.gov/files/PDF/pubs/am/am525.pdf.

All air emissions units shall be included in the calculations of annual emissions except the units listed in

Attachment 2 of this Preliminary Determination. The permit applicant shall list all insignificant emission units in

the application, but these units are exempt from being further evaluated in the application pursuant to section NR

407.05(4)(c)9., Wis. Adm. Code.

https://dnr.wi.gov/files/PDF/pubs/am/am525.pdf


Table 3. Facility-Wide Emission Limits

Pollutant Calendar Year Emission Limits

PM10 and PM2.5 • 25 ton/year for PM10 and PM2.5 attainment & moderate nonattainment

areas

• 17.5 ton/year for serious PM10 nonattainment areas

VOC • 25 ton/year for ozone attainment and basic, rural transport, marginal or

moderate ozone nonattainment areas

• 12.5 ton/year for serious ozone nonattainment or areas within ozone

transport regions except for any severe or extreme nonattainment area

for ozone

• 6.25 ton/year for severe ozone nonattainment areas

• 2.5 tons/year for extreme ozone nonattainment areas

NOx • 25 ton/year for ozone attainment and basic, rural transport, marginal or

moderate ozone nonattainment areas

• 12.5 ton/year for serious ozone nonattainment or areas within ozone

transport regions except for any severe or extreme nonattainment area

for ozone

• 6.25 ton/year for severe ozone nonattainment areas

• 2.5 tons/year for extreme ozone nonattainment areas

SO2 • 25 ton/year

CO • 25 ton/year for attainment and moderate carbon monoxide

nonattainment areas

• 12.5 tons/year for serious nonattainment areas, where the department

determines a stationary source contributes significantly to CO levels in

the area

Pb • 0.5 tons/year

Section 112(b) Hazardous Air

Pollutants (HAPs) • 5.0 ton/year for any single HAP

• 12.5 ton/year for a combination of all HAPs


XV. SOURCE CLASSIFICATION

Facilities eligible for coverage under the draft ROPC are either natural minor or synthetic minor sources under Part

70 because, either maximum theoretical emissions are less than 25% of the major source thresholds for criteria

pollutants and to less than 50% of major source thresholds of federally regulated hazardous air pollutants as shown

in Table 4, or potential emissions are capped by the permit to less than 25% of the major source thresholds for

criteria pollutants and to less than 50% of major source thresholds of federally regulated hazardous air pollutants as

shown in Table 4. Therefore, potential emissions from eligible facilities are below the attainment area major source

thresholds of 100 tons per year for criteria pollutants, 10 tons per year for individual s. 112(b) federal hazardous air

pollutants and 25 tons per year for any combination of s. 112(b) federal hazardous air pollutants for areas

designated as attainment. The draft ROPC sets emission caps based on the major source thresholds applicable to the

area in which the facility is located. Eligible facilities located in a nonattainment area have potential emissions that

are below the part 70 major source thresholds for the nonattainment area.

Eligibility criteria for ROPC or facility status will not change as result of this significant permit revision.

Summary of Possible Source Status of Facilities Covered by ROPC:

Table 4. Facility Classification a

Program b

Existing Facility After Permit Issuance

Major c Synthetic Minor d Minor Major Synthetic

Minor Minor

PSD X X X X

NAA NSR X X X X

Part 70 e X X X X

Federal HAPs X X X X

EPA Class Code f SM B SM B

a A facility can only have one overall classification for each program. If a facility has potential emissions of a single pollutant which

exceed the major source thresholds for Part 70, the facility is a Part 70 source. The same applies for the EPA class code and the source

status for PSD. The exception is for CAA HAPs. A facility can be a Part 70 source for criteria pollutants and an area (i.e. minor) source

of HAPs. If a facility is a major source of HAPs, it is a Part 70 source. b As required by 40 CFR s. 70.5(c)(3)i., emission estimates sufficient to verify which requirements are applicable to the source are

included in this analysis. Based on the definitions in ss. NR 400.02(123m) and (124), Wis. Adm. Code, direct PM2.5 emissions cannot

exceed PM10 emissions. Since PM10 and PM2.5 have the same major source thresholds, emission estimates of PM10 are sufficient for

determining Part 70 and PSD source status with respect to both PM2.5 and PM10. c For PSD, major stationary source has the meaning given in s. NR 405.02(22), Wis. Adm. Code. For nonattainment areas (NAA), major

stationary source has the meaning given in s. NR 408.02(21), Wis. Adm. Code. For Part 70, major source has the meaning given in s.

NR 407.02(4), Wis. Adm. Code. d A source classified as synthetic minor is a stationary source that has maximum theoretical emissions greater than the major source

threshold and has its potential to emit limited by practicably enforceable permit conditions so that it is not a major source. There are two

categories of synthetic minor sources for EPA Class Code, SM80 and SM. e Part 70 source is defined in s. NR 407.02(6), Wis. Adm. Code. A stationary source that directly emits, or has the potential to emit, 100

tpy or more of any air contaminant subject to regulation under the Act other than particulate matter is defined as a major source for Part

70. For particulate matter, a stationary source is a Part 70 major source if it emits or has the potential to emit, 100 tpy or more of PM10

per s. NR 407.02(4)(b), Wis. Adm. Code. f EPA Class Codes: “A” means the source’s maximum theoretical emissions and potential to emit for one or more pollutants are greater

than Part 70 major source thresholds. “SM80” means the source’s maximum theoretical emissions of one or more pollutants are greater

than Part 70 major source thresholds and potential to emit is at least 80% but less than 100% of Part 70 major source thresholds. “SM”

means the source’s maximum theoretical emissions of one or more pollutants are greater than Part 70 major source thresholds but

potential to emit for all pollutants is less than 80% of Part 70 major source thresholds. “B” means the source’s maximum theoretical

emissions and potential to emit for all pollutants are less than major source thresholds.


XVI. STATUS UNDER WISCONSIN ENVIRONMENTAL POLICY ACT (WEPA)

An operation permit revision is considered a minor action under s. NR 150.20(1m)(o), Wis. Adm. Code and as

such, is compliant with WEPA and does not require a determination prior to permit issuance.

XVI. CRITERIA FOR PERMITS APPROVAL

Section 285.63, Wis. Stats., sets forth the specific language for permit approval criteria. The department finds that:

1. Qualifying sources will meet emission limitations.

2. Qualifying sources will not cause or exacerbate a violation of an air quality standard or ambient air

increment.

3. Qualifying sources are operating or seek to operate under an emission reduction option. Not Applicable

4. Qualifying sources will not preclude the construction or operation of another source for which an air

pollution control permit application has been received.

XVII. PRELIMINARY DETERMINATION

The Wisconsin Department of Natural Resources makes a preliminary determination that facilities that meet the

permit eligibility criteria may be covered under the draft ROP-C02 provided they can comply with the permit

conditions and all other applicable requirements. A final decision regarding conditions will be made after the

department has reviewed and evaluated all comments received during the public comment period. The proposed

emission limits and other proposed conditions in the draft ROP-C02 are written as they will appear in the Final

Permit. These proposed conditions may be changed as a result of public comments or further evaluation by the

department.


COMMONLY USED ACRONYMS AND ABBREVIATIONS

acfm Actual cubic feet per minute MTE Maximum Theoretical Emissions

AP-42 Compilation of Air Pollutant

Emission Factors

MW Megawatts

BACT Best Available Control Technology n/a Not Applicable

BTU or btu British Thermal Unit N2O Nitrous Oxide

ºC Degrees Celsius NAA Non-Attainment Area

CAA Federal Clean Air Act NAAQS National Ambient Air Quality

Standards

CAMS Compliance Assurance Monitoring

System

NESHAP National Emission Standard for

Hazardous Air Pollutants

CEM Continuous Emission Monitoring NMOC Non-methane Organic Compounds

CFR Code of Federal Regulations NO2 Nitrogen Dioxide

CH4 Methane NOx Oxides of Nitrogen

CI Compression Ignition NSCR Non-Selective Catalytic Reduction

CO Carbon Monoxide NSPS New Source Performance Standards

CO2 Carbon Dioxide NSR New Source Review

CO2e Carbon Dioxide Equivalents Pb Lead

COMS Continuous Opacity Monitoring

System

PHAP Hazardous Air Pollutant Emitted as a

Particulate

department Wisconsin Department of Natural

Resources

PM Particulate Matter

dscf Dry standard cubic foot PM10 Particulate Matter less than 10 microns

in diameter

dscm Dry standard cubic meter PM2.5 Particulate Matter less than 2.5 microns

in diameter

EPA United States Environmental

Protection Agency

ppm Parts per million

ESP Electrostatic Precipitator ppmdv Parts per million dry volume

ºF Degrees Fahrenheit ppmv Parts per million by volume

FESOP Federal Enforceable State Operating

Permit

ppmw Parts per million by weight

FID Facility Identification Number PSD Prevention of Significant Deterioration

FOP Federal Operating Permit psia Pounds per square inch absolute

ft Feet psig Pounds per square inch gauge

g Grams PTE Potential to Emit

GACT Generally Available Control

Technology

RACT Reasonable Available Control

Technology

GCP General Construction Permit RCP Registration Construction Permit

GHG Greenhouse Gas RICE Reciprocating Internal Combustion

Engine

GOP General Operation Permit ROG Reactive Organic Gases

gr Grains ROP Registration Operating Permit

GWP Global Warming Potential s. Section

HAP Hazardous Air Pollutant scf Standard cubic feet


COMMONLY USED ACRONYMS AND ABBREVIATIONS

Hg Mercury sec Seconds

hr Hour SCR Selective Catalytic Reduction

hp Horsepower SDS Safety Data Sheet

H2S Hydrogen Sulfide SI Spark Ignition

HVLP High Volume Low Pressure SNCR Selective Non-Catalytic Reduction

Kg Kilogram SO2 Sulfur Dioxide

kW Kilowatt SOP State Operating Permit

LACT Latest Available Control Techniques Temp Temperature

LAER Lowest Achievable Emission Rate THC Total Hydrocarbons

lb Pound TPY Tons per year

m Meter µg Microgram

MACT Maximum Achievable Control

Technology

VE Visible Emissions

MPAP Malfunction, Prevention, and

Abatement Plan

VHAP Hazardous Pollutant Emitted as a

Vapor

mg Milligram VOC Volatile Organic Compounds

mm Millimeter Wis. Adm.

Code

Wisconsin Administrative Code

MM Million Wis. Stats. Wisconsin Statutes

MMBtu/hr Million British Thermal Units Per

Hour

yr Year

MSDS Material Safety Data Sheet MTE Maximum Theoretical Emissions


ATTACHMENT 1

AIR POLLUTION CONTROL REQUIREMENTS AND EFFICIENCIES

Table 5. Air Pollution Control Monitoring Parameters

If the facility operates this

control device:

The permittee must monitor

this parameter:

The permittee must record a reading this

often:

Centrifugal collector

(cyclone)

Pressure drop Once every 8 hours of source operation or

once per day, whichever yields the greater

number of measurements

Fabric filter and HEPA filter,

including baghouses and

cartridge collectors

Pressure drop

or

Output of bag leak detection

system

Pressure drop: once every 8 hours of

source operation or once per day,

whichever yields the greater number of

measurements

Bag leak detection system: once per day of

operation

Thermal oxidizer Temperature in the combustion

chamber

Once every 15 minutes

Catalytic oxidizer Temperature in the inlet to

the catalytic bed;

and

Catalyst bed reactivity

Once every 15 minutes

As per manufacturer specification

Condenser Condenser outlet gas temperature Once every 15 minutes

Bio-filter Bed temperature, moisture

content

Once every 8 hours of source operation or

once per day, whichever yields the greater

number of measurements

Table 6. Air Pollution Control Device Efficiencies

Control Device

Overall Control Efficiency

for Total Enclosures


for Hoods

PM PM10/

PHAP

VOC/

VHAP PM

PM10/

PHAP

VOC/

VHAP

Low efficiency cyclone* 40% 20% - 32% 16% -

Medium efficiency cyclone 60% 40% - 48% 32% -

High efficiency cyclone 80% 60% - 64% 48% -

Wall filters (including paint

overspray filters and rotary

drum filters)

95% 95% - 76% 76% -

* See next table to determine a cyclone’s efficiency level.


Table 6. Air Pollution Control Device Efficiencies

Control Device


for Total Enclosures


for Hoods

PM PM10/

PHAP

VOC/

VHAP PM

PM10/

PHAP

VOC/

VHAP

Fabric filter and HEPA

filter, including baghouses

and cartridge collectors

98% 92% - 78% 73% -

Thermal oxidizers - - 90% - - 76%

Catalytic oxidizers - - 90% - - 76%

Condenser - - 70% - - 56%

Bio-filter - - 80% - - 64%

Table 7. Cyclone Efficiency Table

Ratio Dimensions High Efficiency Medium Efficiency Low Efficiency

Height of inlet, H/D 0.44 >0.44 and <0.8 0.8

Width of inlet, W/D 0.2 >0.2 and <0.375 0.375

Diameter of gas exit, De/D 0.4 >0.4 and <0.75 0.75

Length of vortex finder, S/D 0.5 >0.5 and <0.875 0.875

If one or more of the "ratio dimensions," as listed in the cyclone efficiency table are in a different efficiency category (high,

medium, low), then the lowest efficiency category shall be applied.

D

S

W

De

H


ATTACHMENT 2

EMISSION UNITS NOT SUBJECT TO CERTAIN REQUIREMENTS

1. Convenience space heating units with heat input

capacity of less than 5 million Btu per hour that burn

gaseous fuels, liquid fuels or wood

2. Convenience water heating

3. Maintenance of grounds, equipment, and buildings,

including lawn care, pest control, grinding, cutting,

welding, painting, woodworking, general repairs, and

cleaning, but not including use of organic compounds as

cleanup solvents

4. Boiler, turbine, generator, heating, and air conditioning

maintenance

5. Pollution control equipment maintenance

6. Internal combustion engines used for warehousing and

material transport, forklifts and courier vehicles, front

end loaders, graders and trucks, carts, and maintenance

trucks

7. Fire control equipment

8. Janitorial activities

9. Office activities

10. Fuel oil storage tanks with a capacity of 10,000 gallons

or less

11. Stockpiled contaminated soils

12. Demineralization and oxygen scavenging of water for

boilers.

13. Purging of natural gas lines.

14. Particulate matter from natural gas combustion in press

dryers, control device, and other heating units so long as

fuel usage or heat input capacity caps in Attachment 1

are met.

15. Aerosol cans

16. Pad printing

17. Pre-press equipment, such as: photo-processing,

typesetting, or image-setting equipment;

18. Proofing systems utilizing water-based, ink jet, dry

toner, or dye sublimation or proof press designed to

evaluate product quality;

19. Plate-making equipment or screen preparation activities

utilizing water-based developing solutions;

20. Equipment used to make blueprints.

21. Cold cleaning manual parts washers with less than 10

square feet of surface area.

22. Dry toner or other digital presses that apply water-based

inks.

23. Substrate finishing activities which involve paper

folding, cutting, folding, trimming, die cutting,

embossing, foil stamping, drilling, saddle stitching,

sewing, perfect binding, vacuum forming or other

activities that do not generate VOCs and whose

particulate emissions are vented inside the facility.

24. Adhesive application activity involving hot melt,

extrusion, catalyzed solvent-less, or water-based

adhesives.

25. Pneumatic system for collecting paper/film/paperboard

scrap from cutting operations.

26. Any emission unit, operation, or activity that has, for

each air contaminant, maximum controlled emissions

that are less than the level specified in Table 4 of ch. NR

407, Wis. Adm. Code. Multiple emissions units,

operations, or activities that perform identical or similar

functions shall be combined for the purposes of this

determination.

27. If the maximum controlled emissions of any air

contaminants listed in Table 4 of ch. NR 407, Wis.

Adm. Code, from all emission units, operations or

activities at a facility are less than 5 times the level

specified in Table 4, for those air contaminants, any

emission unit operation or activity that emits only those

air contaminants.


ATTACHMENT 3

ANNUAL MATERIAL AND FUEL USAGE THRESHOLDS

† The material usage threshold for heatset presses has been shown to restrict the PM10 emissions to level below the 25 TPY emission cap,

even for uncontrolled presses. ‡ Natural gas includes propane.

Table 8. The following annual material and fuel usage threshold ensure that emission will not exceed the

facility-wide emission caps in A.1. of the draft ROPC-CO2.

Press Type Material Usage†

Sheetfed/Non-heatset Lithographic 7,125 gallons of cleaning solvent and fountain solution additives,

combined

Heatset Web Offset Lithographic 50,000 lbs of ink, cleaning solvent and fountain solution additives,

combined

Digital Printing 5,500 gallons of solvent from inks and clean up solutions, combined

Rotogravure Printing (Water-based

and UV)

200,000 lbs of water-based and/or UV inks, coatings, and adhesives

Rotogravure Printing (Solvent) 50,000 lbs of solvent from inks, dilution solvents, coatings, and

adhesives.

Letterpress Printing 50,000 lbs of ink and cleaning solvent

Screen Printing 7,125 gallons of solvent from inks and clean up solutions

Flexographic (Water-based and UV) 200,000 lbs of water-based and/or UV inks, coatings, and adhesives

Flexographic (Solvent) 50,000 lbs of solvent from inks, dilution solvents, coatings, and

adhesives.

Multiple press types at one facility Find the lowest threshold above that applies to at least one of the

presses at the facility and compare total material usage to that

threshold. If material usage is greater than that threshold, then facility

must calculate emissions to determine if eligible.

Federal HAPs Material Usage

Federal HAPs, individual 1,333 gallons of all press materials containing that federal HAP,

regardless of the percentage content

Federal HAPs, combined 3,333 gallons of all press materials containing at least one federal HAP,

regardless of the percentage content

Fuel (Unit Size) Fuel Usage

Natural Gas‡ (<10 million Btu/hr) 500 million cubic feet/yr

Natural Gas (10-100 million Btu/hr) 350 million cubic feet/yr

Distillate Fuel Oil (sulfur = 0.0015%

wt. or less ) 2,500,000 gallons/yr

Fuel Total Heat Input Capacity Cap

Natural Gas and Distillate Fuel Oil

(sulfur = 0.0015% wt. or less) 39 MMBtu/hr


Table 9. The following annual material usage thresholds ensure that emissions will not exceed the LACT

limit in A.7.a. of the draft ROPC.

Press Type Material Usage

Sheetfed/ Non-heatset Lithographic 768 gallons of cleaning solvent and fountain solution additives

Heatset Web Offset Lithographic 5,400 lbs of ink, cleaning solvent and fountain solution additives

Digital Printing 2,425 gallons of solvent from inks, clean up solutions

Rotogravure Printing (Water-based

and UV)

80,000 lbs of water-based and/or UV inks, coatings, and adhesives

Rotogravure Printing (Solvent) 20,000 lbs of solvent from inks, dilution solvents, coatings, and

adhesives.

Letterpress Printing 20,000 lbs of ink and cleaning solvent

Screen Printing 2,840 gallons of solvent from inks, clean up solutions

Flexographic (Water-based and UV) 80,000 lbs of water-based and/or UV inks, coatings, and adhesives

Flexographic (Solvent) 20,000 lbs of solvent from inks, dilution solvents, coatings, and

adhesives.


ATTACHMENT 4

RACT EMISSION LIMITS§

Material Non-heatset Offset Lithographic Printing Heatset Web Offset Lithographic Printing

Printing Ink Not applicable Control devices requirements:

(1) For the presses subject to NR 422.142:

90% destruction of VOCs, minus methane and ethane, or

outlet concentration of 20 ppmv as carbon.


(a) ≥ 90% destruction of VOCs as carbon, minus

methane and ethane, or outlet concentration of ≤ 20

ppmv as carbon, minus methane, and ethane, for

existing control devices installed prior to May 1, 2010.

(b) ≥ 95% destruction of VOCs as carbon, minus

methane and ethane, or outlet concentration of ≤ 20

ppmv as carbon, minus methane, and ethane, for new

control devices installed on and after May 1, 2010.

Fountain Solution Web-fed Presses:


≤ 5% VOC by weight (bw) and no restricted

alcohol

≤ 13.5% VOC bw if printing on metal or plastic

and refrigerated

(2) For the presses subject to NR 422.143: 7

≤ 5% VOC bw and no restricted alcohol

Sheet-fed Presses:


≤ 5% VOC bw

≤ 8.5% VOC bw if refrigerated

≤ 13.5% VOC bw if printing on metal or plastic,

contains restricted alcohol and refrigerated


≤ 5% VOC bw if not refrigerated

≤ 8.5% VOC bw if refrigerated


≤ 1.6% VOC bw if not refrigerated and contains restricted

alcohol

≤ 3% VOC bw if refrigerated and contains restricted alcohol

≤ 5% VOC bw if no restricted alcohol

≤ 13.5% VOC bw if printing on metal or plastic, contains

restricted alcohol and refrigerated


≤ 1.6% VOC bw if not refrigerated and contains restricted

alcohol

≤ 3% VOC bw if refrigerated and contains restricted alcohol

≤ 5% VOC bw and no restricted alcohol

§ RACT requirements are specific to each type of printing press as follows: [ss. NR 422.14(2)-(4), 422.141(2), 422.142(2),

422.143(3), 422.144(4), and 422.145(2) and (2m), Wis. Adm. Code.


Press Cleaning

Solution

≤ % 70 VOC bw, OR

≤ 10 mm Hg composite partial vapor pressure at 68

°F

≤ 70% VOC bw OR

≤ 10 mmHg composite partial vapor pressure at 68°F

Material Rotogravure, Flexographic Printing Screen Printing

Printing Ink Rotogravure and Flexographic presses subject

to NR 422.14:

(1) Volatiles in ink ≤ 25% VOC by volume and

≥75% or more of water by volume; OR

(2) ink, minus water, 60% nonvolatile material by

volume; OR

(3) 90% reduction of VOCs via:

(a) vapor recovery system that reduces VOCs

from capture system by 90% by weight,

(b) incineration or catalytic oxidation system

that oxidizes ≥ 90% by weight of VOCs, as

combustible carbon, that enter the oxidation unit,

(c) an alternate system with demonstrated

reduction efficiency 90% by weight (only

Biofilters are currently approved by the

department and EPA); AND

(4) overall control VOCs by weight, 75% for

publication rotogravure, 65% for packaging

rotogravure, or 60% for flexographic.

Presses subject to NR 422.145(2):

≤ 400 g VOC/l (3.3 lbs. VOC/gal)

Special purpose inks and coatings AND Roll coating: ≤

800 g VOC/l (6.7 lbs. VOC/gal)

Industrial Cleaning

Operations

≤ 0.05 kg VOC/L (0.42 lb VOC/gal) for product

cleaning or surface preparation during

manufacturing process

≤ 0.05 kg VOC/L (0.42 lb VOC/gal) for repair

cleaning or maintenance cleaning

Cleaning of ink application equipment:

≤ 0.05 kg VOC/L (0.42 lb VOC/gal)

Flexographic except flexible packaging and

except ultraviolet

≤ 0.05 kg VOC/L (0.42 lb VOC/gal) for

non−flexible packaging rotogravure except

ultraviolet

≤ 0.10 kg VOC/L (0.83 lb VOC/gal) for

publication rotogravure except ultraviolet

< 0.65 kg VOC/L (5.4 lb VOC/gal) for

ultraviolet

≤ 0.05 kg VOC/L (0.42 lb VOC/gal) for product cleaning or

surface preparation during manufacturing process

≤ 0.50 kg VOC/L (4.2 lb VOC/gal) for repair cleaning or

maintenance cleaning

≤ 0.50 kg VOC/L (4.2 lb VOC/gal) for cleaning of ink

application equipment

Material Flexible package printing

Subject to NR 422.141:

(1) VOC control devices with the following minimum overall control efficiency:

(a) 65% by weight of VOCs as carbon, for a press that was first installed prior to March 14, 1995 and the

control device that was installed prior to August 1, 2009.


(b) 70% by weight of VOCs as carbon, for a press that was first installed prior to March 14, 1995 and the

control device that was installed on or after August 1, 2009.

(c) 75% by weight of VOCs as carbon, for a press that was first installed on or after March 14, 1995 and the

control device that was installed prior to August 1, 2009.

(d) 80% by weight of VOCs as carbon, for a press that was first installed on or after March 14, 1995 and the

control device that was installed on or after August 1, 2009.

OR

(2) inks, coatings, and adhesives, as applied

≤ 0.8 kg VOC/kg solids (0.8 lbs. VOC/lb solids), or

≤ 0.16 kg VOC/kg material (0.16 lbs. VOC/lb material)

Material Non-heatset Web Letter Printing Heatset Web Letter Printing

Printing Ink Not applicable

(1) ≥ 90% destruction bw of carbon, minus methane and

ethane, or outlet concentration of ≤ 120 ppmv as carbon,

minus methane, and ethane, for existing control devices

installed prior to February 1, 2012.

(2) ≥ 95% destruction bw of carbon, minus methane and

ethane, or outlet concentration of ≤ 120 ppmv as carbon,

minus methane, and ethane, for new control devices

installed on and after February 1, 2012.

Blanket or roller

wash

≤ 70% VOC by weight (bw), or

≤ 10 mmHg composite vapor pressure at 68°F.

≤ 70% VOC bw, OR

≤ 10 mmHg composite vapor pressure at 68°F.

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