Section 218.417  Recordkeeping and Reporting for Letterpress Printing Lines

 

a)         By August 1, 2010, or upon initial start-up of a new heatset web letterpress printing line, whichever is later, and upon modification of a heatset web letterpress printing line, an owner or operator of a heatset web letterpress printing line exempt from any of the limitations of Section 218.413 of this Subpart because of the criteria in Section 218.412(a)(1) shall submit a certification to the Agency that includes:

 

1)         A declaration that the source is exempt from the requirements in Section

218.413 of this Subpart because of the criteria in Section 218.412(a)(1) of this Subpart;

 

2)         Calculations which demonstrate that the source's total potential to emit VOM does not equal or exceed 22.7 Mg (25 tons) per year.

 

b)         An owner or operator of a letterpress printing line exempt from any of the limitations of Section 218.413 of this Subpart because of the criteria in Section 218.412(a)(2) shall:

 

1)         By August 1, 2010, or upon initial start-up of a new letterpress printing line, whichever is later, and upon modification of a letterpress printing line, submit a certification to the Agency that includes the information specified in either subsections (b)(1)(A) through (b)(1)(C) of this Section, or subsections (b)(1)(A) and (b)(1)(D) of this Section, as applicable:

 

A)        A declaration that the source is exempt from the control requirements in Section 218.413 of this Part because of the criteria in Section 218.412(a)(2) of this Subpart;

 

B)        Calculations that demonstrate that combined emissions of VOM from all letterpress printing lines (including inks and solvents used for cleanup operations associated with the letterpress printing lines) at the source never equal or exceed 6.8 kg/day (15 lbs/day), in the absence of air pollution control equipment, as follows:

 

i)          To calculate daily emissions of VOM, the owner or operator shall determine the monthly emissions of VOM from all letterpress printing lines at the source (including solvents used for cleanup operations associated with the letterpress printing lines) and divide this amount by the number of days during that calendar month that letterpress printing lines at the source were in operation;

 

ii)         To determine the VOM content of the inks and cleaning solvents, the tests methods and procedures set forth in Section 218.415(c) of this Subpart shall be used;

 

iii)        To determine VOM emissions from inks used on letterpress printing lines at the source, an ink emission adjustment factor of 0.05 shall be used in calculating emissions from all non-heatset inks except when using an impervious substrate, and a factor of 0.80 shall be used in calculating emissions from all heatset inks to account for VOM retention in the substrate except when using an impervious substrate.  For impervious substrates such as metal or plastic, no emission adjustment factor is used.  The VOM content of the ink, as used, shall be multiplied by this factor to determine the amount of VOM emissions from the use of ink on the printing lines; and

 

iv)       To determine VOM emissions from cleaning solutions used on letterpress printing lines at the source, an emission adjustment factor of 0.50 shall be used in calculating emissions from used shop towels if the VOM composite vapor pressure of each associated cleaning solution is less than 10 mmHg measured at 20°C (68°F) and the shop towels are kept in closed containers.  Otherwise, no retention factor is used;

 

C)        A description and the results of all tests used to determine the VOM content of inks and cleaning solvents, and a declaration that all such tests have been properly conducted in accordance with Section 218.415(c)(1) of this Subpart;

 

D)        As an alternative to the calculations in subsection (b)(1)(B), a statement that the source uses less than the amount of material specified in subsections (b)(1)(D)(i) or (b)(1)(D)(ii), as applicable, during each calendar month.  A source may determine that it emits below 6.8 kg/day (15 lbs/day) of VOM based upon compliance with such material use limitations.  If the source exceeds this amount of material use in a given calendar month, the owner or operator must, within 15 days of the end of that month, complete the emissions calculations of subsection (b)(1)(B) to determine daily emissions for applicability purposes. If the source ever exceeds this amount of material use for six consecutive calendar months, it is no longer eligible to use this subsection as an alternative to the calculations in subsection (b)(1)(B).

 

i)          The sum of all sheetfed and nonheatset web letterpress printing operations at the source: 242.3 liters (64 gallons) of cleaning solvent; or

 

ii)         The sum of all heatset web letterpress printing operations at the source: 204.1 kg (450 lbs) of ink and cleaning solvent;

 

2)         For sources complying with subsection (b)(1)(B) of this Section, notify the Agency in writing if the combined emissions of VOM from all letterpress printing lines (including inks and solvents used for cleanup operations associated with the letterpress printing lines) at the source ever equal or exceed 6.8 kg/day (15 lbs/day), in the absence of air pollution control equipment, within 30 days after the event occurs;

 

3)         For sources complying with subsection (b)(1)(D) of this Section, comply with the following:

 

A)        Maintain material use records showing that the source uses less than the amount of material specified in subsections (b)(1)(D)(i) and (b)(1)(D)(ii) during each calendar month, or, if the source exceeds the material use limitations, records showing that the source exceeded the limitations but did not emit 6.8 kg/day (15 lbs/day) or more of VOM.  On and after January 1, 2012, such records shall include the name, identification number, and VOM content of each cleaning solvent and ink used per calendar month, the volume of each cleaning solvent used per calendar month for each sheetfed and nonheatset web letterpress printing operation, and the weight of each cleaning solvent and ink used per calendar month for each heatset web letterpress printing operation;

 

B)        Notify the Agency in writing if the source exceeds the material use limitations for six consecutive calendar months, or if the source changes its method of compliance from subsection (b)(1)(D) to subsection (b)(1)(B) of this Section, within 30 days after the event occurs.

 

c)         Unless complying with subsections (b)(1)(D) and (b)(3) of this Section, on and after August 1, 2010, an owner or operator of a letterpress printing line exempt from any of the limitations in Section 218.413 of this Subpart because of the criteria in Section 218.412(a)(1) or (a)(2) shall collect and record either the information specified in subsection (c)(1) or (c)(2) of this Section for all letterpress printing lines at the source:

 

1)         Standard recordkeeping, including the following:

 

A)        The name and identification of each letterpress ink and cleaning solvent used on any letterpress printing line, recorded each month;

 

B)        A daily record that shows whether a letterpress printing line at the source was in operation on that day;

 

C)        The VOM content and the volume of each letterpress ink and cleaning solvent used on any letterpress printing line, recorded each month;

 

D)        The total VOM emissions at the source each month, determined as the sum of the product of usage and VOM content for each cleaning solvent and letterpress ink (with the applicable ink VOM emission adjustment) used at the source, calculated each month; and

 

E)        The VOM emissions in lbs/day for the month, calculated in accordance with subsection (b)(1)(B) of this Section;

 

2)         Purchase and inventory recordkeeping, including the following:

 

A)        The name, identification, and VOM content of each letterpress ink and cleaning solvent used on any letterpress printing line, recorded each month;

 

B)        Inventory records from the beginning and end of each month indicating the total volume of each letterpress ink, and cleaning solvent to be used on any letterpress printing line at the source;

 

C)        Monthly purchase records for each letterpress ink and cleaning solvent used on any letterpress printing line at the source;

 

D)        A daily record that shows whether a letterpress printing line at the source was in operation on that day;

 

E)        The total VOM emissions at the source each month, determined as the sum of the product of usage and VOM content for each cleaning solvent and letterpress ink (with the applicable ink VOM emission adjustment factor) used at the source, calculated each month based on the monthly inventory and purchase records required to be maintained pursuant to subsections (c)(2)(A), (c)(2)(B), and (c)(2)(C) of this Section; and

 

F)         The VOM emissions in lbs/day for the month, calculated in accordance with subsection (b)(1)(B) of this Section;

 

d)         An owner or operator of a heatset web letterpress printing lines subject to the control requirements of Section 218.413(a)(1)(B) or (b)(1) of this Subpart shall comply with the following:

 

1)         By August 1, 2010, or upon initial start-up of a new printing line, whichever is later, and upon initial start-up of a new control device for a heatset web printing line, submit a certification to the Agency that includes the following:

 

A)        An identification of each heatset web letterpress printing line at the             source;

 

B)        A declaration that each heatset web letterpress printing line is in compliance with the requirements of Section 218.413 (a)(1) or (b) of this Subpart, as appropriate;

 

C)        The type of afterburner or other approved control device used to comply with the requirements of Section 218.413(a)(1)(B) or (b)(1) of this Subpart, and the date that such device was first constructed at the subject source;

 

D)        The control requirements in Section 218.413(a)(1)(B) or (b)(1) of this Subpart with which the letterpress printing line is complying;

 

E)        The results of all tests and calculations necessary to demonstrate compliance with the control requirements of Section 218.413(a)(1)(B) or (b)(1) of this Subpart, as applicable; and

 

F)         A declaration that the monitoring equipment required under Section 218.413(a)(1)(C) or (b) of this Subpart, as applicable, has been properly installed and calibrated according to manufacturer's specifications;

 

2)         If testing of the afterburner or other approved control device is conducted pursuant to Section 218.415(b) of this Subpart, the owner or operator shall, within 90 days after conducting such testing, submit a copy of all test results to the Agency and shall submit a certification to the Agency that includes the following:

 

A)        A declaration that all tests and calculations necessary to demonstrate whether the letterpress printing lines is in compliance with Section 218.413(a)(1)(B) or (b)(1) of this Subpart, as applicable, have been properly performed;

 

B)        A statement whether the heatset web letterpress printing lines are or are not in compliance with Section 218.413(a)(1)(B) or (b)(1) of this Subpart, as applicable; and

 

C)        The operating parameters of the afterburner or other approved control device during testing, as monitored in accordance with Section 218.416(a) or (b) of this Subpart, as applicable;

 

3)         Except as provided in subsection (d)(3)(D) of this Section, collect and record daily the following information for each heatset web letterpress printing line subject to the requirements of Section 218.413(a)(1)(B) or (b)(1) of this Subpart:

 

A)        Afterburner or other approved control device monitoring data in accordance with Section 218.416(a) or (b) of this Subpart, as applicable;

 

B)        A log of operating time for the afterburner or other approved control device, monitoring equipment, and the associated printing line;

 

C)        A maintenance log for the afterburner or other approved control device and monitoring equipment detailing all routine and non-routine maintenance performed, including dates and duration of any outages; and

 

D)        A log detailing checks on the air flow direction or air pressure of the dryer and press room to ensure compliance with the requirements of Section 218.413(a)(1)(A) of this Subpart at least once per calendar month while the line is operating;

 

4)         Notify the Agency in writing of any violation of Section 218.413(a)(1)(B) or (b)(1) of this Subpart within 30 days after the occurrence of such violation.  Such notification shall include a copy of all records of such violation;

 

5)         If changing the method of compliance between Sections 218.413(a)(1)(B) and 218.413(b) of this Subpart, certify compliance for the new method of compliance in accordance with Section 218.413(b) at least 30 days before making such change, and perform all tests and calculations necessary to demonstrate that such printing lines will be in compliance with the requirements of Section 218.413(a)(1) of this Subpart, or Section 218.413(b) of this Subpart, as applicable.

 

e)         For letterpress printing line cleaning operations, an owner or operator of a letterpress printing line subject to the requirements of Section 218.413 of this Subpart shall:

 

1)         By August 1, 2010, or upon initial start-up of a new letterpress printing line, whichever is later, certify to the Agency that all cleaning solutions, other than those excluded pursuant to Section 218.412(b), and the handling of all cleaning materials will be in compliance with the requirements of Section 218.413(a)(2)(A) or (a)(2)(B) and (a)(3) of this Subpart.  Such certification shall include:

 

A)        A statement that the cleaning solution will comply with the limitations in Section 218.413(a)(2);

 

B)        Identification of the methods that will be used to demonstrate continuing compliance with the applicable limitations;

 

C)        A sample of the records that will be kept pursuant to subsection (e)(2) of this Section; and

 

D)        A description of the practices that ensure that VOM-containing cleaning materials are kept in closed containers;

 

2)         Collect and record the following information for each cleaning solution used on each letterpress printing line:

 

A)        For each cleaning solution for which the owner or operator relies on the VOM content to demonstrate compliance with Section 218.413(a)(2)(A) of this Subpart and that is prepared at the source with automatic equipment:

 

i)          The name and identification of each cleaning solution;

 

ii)         The VOM content of each cleaning solvent in the cleaning solution, as determined in accordance with Section 218.415(c) of this Subpart;

 

iii)        Each change to the setting of the automatic equipment, with date, time, description of changes in the cleaning solution constituents (e.g., cleaning solvents), and a description of changes to the proportion of cleaning solvent and water (or other non-VOM);

 

iv)        The proportion of each cleaning solvent and water (or other non-VOM) used to prepare the as-used cleaning solution;

 

v)         The VOM content of the as-used cleaning solution, with supporting calculations; and

 

vi)        A calibration log for the automatic equipment, detailing periodic checks;

 

B)        For each batch of cleaning solution for which the owner or operator relies on the VOM content to demonstrate compliance with Section 218.413(a)(2)(A) of this Subpart, and that is not prepared at the source with automatic equipment:

 

i)          The name and identification of each cleaning solution;

 

ii)         Date and time of preparation, and each subsequent modification, of the batch;

 

iii)        The VOM content of each cleaning solvent in the cleaning solution, as determined in accordance with Section 218.415(c) of this Subpart;

 

iv)        The total amount of each cleaning solvent and water (or other non-VOM) used to prepare the as-used cleaning solution; and

 

v)         The VOM content of the as-used cleaning solution, with supporting calculations.  For cleaning solutions that are used as purchased, the manufacturer's specifications for VOM content may be used if such manufacturer's specifications are based on results of tests of the VOM content conducted in accordance with methods specified in Section 218.105(a) of this Part;

 

C)        For each batch of cleaning solution for which the owner or operator relies on the vapor pressure of the cleaning solution to demonstrate compliance with Section 218.413(a)(2)(B) of this Subpart:

 

i)          The name and identification of each cleaning solution;

 

ii)         Date and time of preparation, and each subsequent modification, of the batch;

 

iii)        The molecular weight, density, and VOM composite partial vapor pressure of each cleaning solvent, as determined in accordance with Section 218.415(e) of this Subpart.  For cleaning solutions that are used as purchased, the manufacturer’s specifications for VOM composite partial vapor pressure may be used if such manufacturer's specifications are based on results of tests conducted in accordance with methods specified in Sections 218.105(a) and 218.110 of this Part;

 

iv)        The total amount of each cleaning solvent used to prepare the as-used cleaning solution; and

 

v)         The VOM composite partial vapor pressure of each as-used cleaning solution, as determined in accordance with Section 218.415(e) of this Subpart.  For cleaning solutions that are used as purchased, the manufacturer's specifications for VOM composite partial vapor pressure may be used if such manufacturer's specifications are based on results of tests conducted in accordance with methods specified in Sections 218.105(a) and 218.110 of this Part;

 

D)        The date, time, and duration of scheduled inspections performed to confirm the proper use of closed containers to control VOM emissions, and any instances of improper use of closed containers, with descriptions of actual practice and corrective action taken, if any;

 

E)        The amount of cleaning materials used on letterpress printing lines at the source that do not comply with the cleaning material limitations set forth in Section 218.413(a)(2) of this Subpart;

 

3)         Notify the Agency in writing of any violation of Section 218.413 of this Subpart within 30 days after the occurrence of such violation.  Such notification shall include a copy of all records of such violation.

 

f)         The owner or operator shall maintain all records required by this Section at the source for a minimum period of three years and shall make all records available to the Agency upon request.

 

(Source:  Amended at 35 Ill. Reg. 13473, effective July 27, 2011)