Specialty Forms Printers Indiana

							          RACT Rule Compliance
          for Illinois Printers
Presented by:
       Printing Industry of Illinois and Indiana
       Printing Industries of America
       Illinois EPA
       Environmental Partners, Inc.
       Specialty Graphics Imaging Association
       University of Illinois Sustainable Technology Center
Today’s Moderator

        Joanne Rock
        Executive Vice President
        Printing Industry of IL/IN
          Association
       Webcast Logistics
   Have a question or comment?
   We will not be taking verbal questions today.
   Use the submit question box on the right side of the
    screen.
   This webcast is being recorded.
   The recording will be available on the PII web page
    and you will be provided the link when it is posted.
Today’s Speakers
       Marci Kinter, VP, Government and
       Business Information, Specialty Graphics
       Imaging Association
       Dale Kalina, Principal, Environmental
       Partners, Inc.
       Gary Jones, Director, EHS Affairs,
       Printing Industries of America
       Deb Jacobson, Regional Operations
       Manager, University of Illinois
       Sustainable Technology Center
       David Bloomberg, Compliance Unit
       Manager, Bureau of Air, IL EPA
 Today’s Agenda
 Update to Industrial Solvent Cleaning
  RACT Rule
 Update to Lithographic/Letterpress
  Printing RACT Rule
 Required Air Permit Revisions and
  Certifications
 Compliance toolkit
 Compliance Assistance
 Q&A
Link To Download Regulations

   http://www.ipcb.state.il.us/document
    s/dsweb/Get/Document-69053
Update to Industrial Solvent
Cleaning Operations RACT Rule

   Applicability
       Applies to all facilities emitting 15 pounds a
        day or more of Volatile Organic Materials
        from cleaning operations
       Calculated without air pollution control
        equipment
Exemptions!

   Stripping of cured coatings, inks, or
    adhesives including screen reclamation
    activities
   Cleaning operations in pre-press areas
   Flexible Package Printing
   Lithographic Printing
   Letterpress Printing
   Cleaning of metering rollers, dampening
    rollers and printing plates
   Cleaning operations associated with digital
    printing
The rule does apply to:
Cleaning of Ink Application Equipment
       Printing Process            VOM Content Limit
                                      (lbs/gallon)
Rotogravure, not flexible                  .83
packaging
Screen Printing                            4.2
UV/EB Ink Application                      5.4
Equipment, except for screen
printing
Flexographic Printing, not                 .83
flexible packaging
Alternative compliance option   Low vapor pressure product
                                  8mmHG at 20 degrees C
Reporting/Recordkeeping
Requirements

   If Exempt, by April 1, 2011
       Submit certification to Agency declaring
        that your facility is exempt because you do
        not emit 15 pounds or more VOM on a daily
        basis
       Include calculations demonstrating that
        daily emissions never exceed 15 pounds of
        VOM on a daily basis
Reporting/Recordkeeping
Requirements

   If you emit more than 15 lbs of VOM per
    day, by April 1, 2011
       Declaration that all cleaning operations are
        in compliance
       Identify each cleaning operation and each
        VOM containing material used
       If using emission control system, identify
        the system
       Documentation of compliance
Reporting/Recordkeeping
Requirements

   Identify methods you will use to
    demonstrate compliance
   Describe practices you will use to
    ensure compliance
   Description of any exempt cleaning
    operation including a listing of emission
    units where the exempt activity takes
    place.
Reporting/Recordkeeping
Requirements Prepared At Source

   Name and Identification of each
    cleaning solvent
   VOM content of each solvent used
   Changes to settings of automatic
    equipment, if used
   Proportion of solvent to water
   VOM content, as used, with calculations
   Calibration log
Reporting/Recordkeeping
Requirements Prepared -- Batch

   Name and Identification of each
    cleaning solvent
   Date, time preparation of each batch
   VOM content
   Amount of solvent/water used to create
    batch
   VOM content of product, as used
Compliance Strategies

   Demonstration compliance through add
    on control technology
       Testing and Monitoring
       Recordkeeping
   Testing Requirements
       VOM content limitations
       Demonstrate effectiveness of add on
        controls
Industrial Solvent Cleaning Rule

   Providing highlights of new regulatory
    requirements
   Impacted?
       Section 218.187, Other Industrial Solvent
        Cleaning Operations
          Update to Lithographic/
          Letterpress RACT Rule
   Reasonably Available Control Technology
   Proposed by the Illinois EPA in July 2009 based on
    USEPA’s 2006 Control Techniques Guidelines for Offset
    Lithographic Printing and Letterpress Printing
   PII worked with IEPA to modify the original proposed
    rule
   Final rule issued June 2010
       Lithography - Ill. Adm. Code 218.405-218.411/219.405-219.411
       Letterpress - Ill. Adm. Code 218.412-218.417/219.412-219.417
   Compliance date of August 1, 2010
         Update to Lithographic/
         Letterpress RACT Rule
   Applies to lithographic and letterpress printing
    operations in nonattainment areas:
      Chicago area
         • Cook, DuPage, Kane, Lake, McHenry, and Will
           Counties, Goose Lake and Aux Sable Townships in
           Grundy County, and Oswego Township in Kendall
           County
       St. Louis/Metro East area
         • Jersey, Madison, Monroe, and St. Clair
          Update to Lithographic/
          Letterpress RACT Rule
   IEPA sees no reduction in VOM emissions from heatset
    lithography
   IEPA believes 98 lithographic printing sources in the
    Chicago area and 3 sources in the East St. Louis area
    have emissions above the new applicability threshold
       Of these, 66 facilities in the Chicago area and all 3 in the East
        St. Louis area will be newly subject to the requirements
       Only 2 letterpress facilities identified, with 1 facility above the
        threshold
   IEPA predicts a 25-90% reduction in VOM emissions
    from the newly regulated lithographic printing
    sources(!)
          Update to Lithographic/
          Letterpress RACT Rule
   Current rule applies only to lithographic printers
    and only if:
      Operating heatset presses, unless
         • Maximum theoretical emissions from all heatset
           presses never exceeded 100 tons of VOM per year
           before capture and control, or
         • Permit limits VOM emissions to less than 100 tons
           of VOM per year before capture and control
       Daily VOM emissions from all lithographic
        presses (heatset and nonheatset) ever
        exceeded 100 lb/day
          Lithographic RACT Rule –
          Changes
   Applicability threshold has been lowered from 100 lb/day
    VOM to 15 lb/day
       Exemption if below 15 lb/day (Exempt)
       Most stringent requirements for facilities >100 lb/day (Large)
       Some exclusions for 15-100 lb/day facilities (Intermediate)
   Method of calculating daily emissions revised
   Small changes in fountain solution VOM limits
   Change to heatset dryer monitoring requirement
   Increased destruction efficiency requirement for new
    heatset pollution controls
   Change to coating regulation applicability
       The paper coating limitation will no longer apply to any paper
        coating on lithographic or letterpress presses complying with
        the lithographic or letterpress RACT requirements
          Lithographic RACT Rule –
          Calculation of Daily Emissions
   Calculate monthly VOM emissions (before
    capture and control) and divide by the number
    of days in the month presses were in operation
       Use ink oil VOM retention factor of 95% for
        nonheatset and 20% for heatset on porous substrate
       Use 50% VOM solvent retention for cleaning solvents
        with 10 mm Hg vapor pressure and used cleaning
        towels stored in closed containers
         • Change from current 0% factor
       Use 100% VOM emission factor for all other materials
          Lithographic RACT Rule –
          Requirements Applicable to All
          Sources
   Submit certification to Illinois EPA
       By August 1, 2010 or start-up of a new lithographic
        press, whichever is later, and
       Upon modification of an existing press
       Content of certification depends upon daily
        emissions level
   Maintain monthly records
       Level of recordkeeping depends upon daily emissions
        level
          Lithographic RACT Rule –
          Requirements for Exempt Sources –
          Emissions <15 lb/day
   Submit certification of exemption based on VOM
    emissions of less than 15 lb/day
   Maintain monthly records for 3 years:
       Materials usage, VOM content, press operating days, monthly
        emissions and calculated daily emissions, or
       Usage of less than 64 gallons/month of cleaning solvent and
        fountain solution additives (nonheatset) or less than 450 pounds
        of ink, cleaning solvent and fountain solution additives
        combined (heatset)
   Notify IEPA within 30 days if emissions exceed 15
    lb/day
          Lithographic RACT Rule – Fountain
          Solution Limits* for Intermediate and
          Large Sources – Emissions >15 lb/day
   Heatset
       5% VOM by weight if alcohol free,
       3% VOM by weight if refrigerated to 60°F and contains alcohol,
        or
       1.6% VOM by weight if not refrigerated and contains alcohol
   Nonheatset Web
       5% VOM by weight – must be alcohol free
   Sheetfed
       8.5% VOM by weight if refrigerated to 60°F, or
       5.0% VOM by weight if not refrigerated

        * Exclusions apply to intermediate sources
          Lithographic RACT Rule – Cleaning
          Solvent Limits* for Intermediate and
          Large Sources – Emissions >15 lb/day
   All Lithographic Processes
       30% VOM by weight, or
       VOM composite partial vapor pressure less than 10
        mm Hg at 20°C
         * Exclusions apply to intermediate sources
           Lithographic RACT Rule – Heatset
           Requirements* for Intermediate and
           Large Sources – Emissions >15 lb/day
   Air pressure in the press dyer must be negative to
    surrounding pressroom so that all air flow is into
    the dryer
   A control device (oxidizer or approved alternative)
    must be operated to reduce VOM emissions from
    the dryer by:
       90% if constructed at the facility before January 1, 2010
       95% if constructed at the facility after January 1, 2010
   A system to continuously monitor and record the
    oxidizer temperature or other parameter must be
    operated
   The control device must be operated at all times
         *Exemption applies to intermediate sources
          Lithographic RACT Rule – Fountain
          Solution Monitoring Requirements for
          Intermediate and Large Sources –
          Emissions >15 lb/day
   VOM Content
       Manually prepared
        •Record date and time of preparation of each batch and
        modification, quantity and VOM content of components, or
        •Test each batch with a hydrometer, refractometer or conductivity
        meter
       Automatically prepared
        •Determine VOM content from mixing system settings
   Temperature (if applicable)
       Operate continuous temperature monitoring and recording
        system accurate to 2°F
       Record temperature every 2 hours during recorder malfunction
        and repair recorder ASAP
          Lithographic RACT Rule – Cleaning
          Solvent Monitoring Requirements for
          Intermediate and Large Sources –
          Emissions >15 lb/day
   VOM Content or VOM Composite Vapor Pressure
       Operate and calibrate automatic mixing equipment
        with settings so that as-mixed solvent meets VOM
        content or vapor pressure limitation,
       Record date and time of preparation of each batch
        and modification, quantity and VOM content or
        vapor pressures of components, or
       If used as-supplied, use manufacturer’s
        specifications if determined using approved methods
          Lithographic RACT Rule – Heatset
          Monitoring Requirements for
          Intermediate and Large Sources –
          Emissions >15 lb/day
   Check airflow direction or press dryer air
    pressure relative to pressroom once per month
    when press is operating
       Change from current daily monitoring requirement
   Operate continuous temperature monitoring
    and recording system accurate to 5°F
           Lithographic RACT Rule –
           Recordkeeping Requirements for
           Intermediate and Large Sources –
           Emissions >15 lb/day
   Fountain Solution
       If using hydrometer, refractometer or conductivity meter
         •Date and time of preparation or modification of each batch, results
         of each measurement, meter calibration data and documentation of
         meter temperature adjustment
       If using batch records
         •Date and time of preparation or modification of each batch,
         quantity and VOM content of each fountain solution component, and
         calculated VOM content
       If using automatic mixing equipment
         •VOM content corresponding to setting, date and time of setting
         changes, and documentation of calibration
       If relying on temperature
         •Continuous temperature records and maintenance log for
         continuous monitoring and recording system
           Lithographic RACT Rule –
           Recordkeeping Requirements for
           Intermediate and Large Sources –
           Emissions >15 lb/day
   Cleaning Solvent
       If relying on VOM content
         •Automatic mixing system settings, proportion and VOM content of
         constituents, VOM content of as-used solution, and calibration log for mixing
         equipment;
         •Date and time of preparation or modification of each manually prepared
         batch, proportion and VOM content of constituents, and VOM content of as-
         used solution, or
         •VOM content of as-purchased material based on manufacturer’s
         specifications if determined using approved methods
       If relying on vapor pressure
         •Date and time of preparation or modification of each batch, proportion,
         vapor pressure, molecular weight and density of constituents, and VOM
         composite vapor pressure of content of as-used solution, or
         •VOM composite vapor pressure of as-purchased material based on
         manufacturer’s specifications if determined using approved methods
       Date and time of closed container inspections and corrective actions
          Lithographic RACT Rule –
          Recordkeeping Requirements for
          Intermediate and Large Sources –
          Emissions >15 lb/day
   Heatset
       Control device monitoring data
       Log of operating time for control device, monitoring
        equipment and printing presses
       Maintenance log for control device and monitoring
        equipment
       Log of monthly dryer airflow direction or pressure
          Lithographic RACT Rule – Exclusions
          for Intermediate Sources – Emissions
          15 -100 lb/day
   The following exclusions apply to facilities with VOM
    emissions of 15 to 100 lb/day if a certification is
    submitted requesting them:
       Fountain solution limits do not apply to presses with fountain
        solution reservoirs of <1 gal
       Sheetfed fountain solution limits do not apply to presses of
        11x17 inches or smaller
       VOM content of cleaning solutions is limited to 70% by weight
        (not 30%)
       Up to 110 gallons of cleaning solvent not meeting the VOM
        content or VOM composite partial vapor pressures may be used
        per year
   Heatset presses are exempt from control requirements
          Lithographic RACT Rule – Requirements
          for Exclusions at Intermediate Sources –
          Emissions 15-100 lb/day
   By August 1, 2010 or start-up of a new lithographic press, subject
    to any of the exclusions for intermediate facilities:
      Submit a certification stating the applicable exclusions that
        will apply or that the facility will not take advantage of any of
        the exclusions
      Perform calculations on a monthly basis that VOM emissions do
        not exceed 100 lb/day before capture and control
      Record the amount of cleaning solvent not meeting the VOM
        content or VOM composite partial vapor pressure
      Notify IEPA within 30 days if VOM emissions exceed 100 lb/day
        before capture and control
      Certify compliance to IEPA within 30 days if opting in or out of
        any of the exclusions or if there is a change such that any
        exclusions no longer apply
           Air Permitting and Certifications
   Printers newly subject to the RACT rule are not
    required to get an air permit because of the rule.
       Requirements of rule still apply and must be met
       Printers without permits should ensure that a permit is
        not required
   Current air permit threshold for lithographic and
    letterpress printing operations is 750 gallons of
    VOM-containing material per year.
       Exceeding the threshold requires the printer to have
        an air permit – the source should apply before the
        threshold is exceeded
       Total annual emissions and potential emissions
        determine the type of permit that is required
         • Lifetime Operating Permit, FESOP, or Title V
         Air Permitting and Certifications
   Most printers with existing permits now subject
    to RACT do not have to modify the air permit.
       Requirements of the new rule still apply and must
        be met
   Title V sources with three or more years before
    renewal must apply for a modification to
    incorporate the new requirements.
       The type of modification depends on case-by-case
        situation
       Such sources should check with their permit analyst
        or Michael Reed at 217-782-2113
          Air Permitting and Certifications

   Other permits being modified or renewed for
    other reasons will have the new RACT
    requirements incorporated.
   Printers desiring incorporation of RACT rules
    into an existing permit can apply using the
    forms found online:
       For Title V permits-www.epa.state.il.us/air/caapp/index.html
       For all other permits-www.epa.state.il.us/air/stateforms/
       Not necessarily a priority for Permit Section action
      Air Permitting and Certifications
 There are various certifications
  depending on whether the source is
  subject to/exempt from the different
  provisions of the rule.
 All of the litho-related certifications are
  due by August 1, 2010
 Certifications also required upon initial
  start-up of any new presses and are
  required upon modification of printing
  lines in some cases.
          Air Permitting and Certifications
               All Printing Operations
   Exempt printing operations (<15 lbs/day VOM
    emissions) must certify by August 1, 2010.
      Can submit calculations or material use info
       Notify IEPA within 30 days if emissions exceed 15
        lb/day VOM emissions
   Printers with emissions >15 lb/day VOM
    must certify by August 1, 2010.
Air Permitting and Certifications

   For cleaning solutions used within a
    source other than on a lithographic line
       Certification that the VOM content limit is
        being met, or
       Certification that a control system is being
        used for cleaning solutions
   For example, fully-enclosed cleaning
    systems where the vapors are collected
    and sent to a condenser or carbon
    absorber.
          Air Permitting and Certifications
                   Heatset Presses
   Certify emissions for all presses that exceed 15
    lbs/day VOM but are below 100 lbs/day.
   Presses that exceed 100 lbs/day VOM
       Subject to the control device requirements
       Subject to testing control device
   Notification 30 days PRIOR to changing the
    method of control device compliance.
           Air Permitting and Certifications

                       All Presses
   Certification for fountain solution VOM
    compliance option
       Press specific options
   Certification for cleaning solution compliance
    option
       VOM content or vapor pressure limit
       Do not need to certify compliance of up to 110
        gallons of a cleaning solution that does not meet
        either limit if using this exclusion
          Air Permitting and Certifications
                      All Presses
   Certification for fountain solution exclusions:
       Total fountain solution reservoir of less than 3.8
        liters (1 gallon)
       Sheet-fed offset lithographic printing lines with
        maximum sheet size of 11x17 inches or smaller
   Certification that you will be using the 110
    gallon cleaning solution exclusion.
   Certification that you qualify for the 70% by
    weight VOM limit for cleaning solutions
    because the facility VOM emissions are >15
    lbs/day but < 100 lbs/day.
        Air Permitting and Certifications

                      All Presses
   Presses that have already certified that they
    will be using the exclusions, but then decide to
    opt out of the exclusion
   Presses that were not using exclusions, but
    decide to take advantage of the exclusion.
    Notifications
               Due within 30 Days
   Violation of any limitation or requirement.
   Emissions exceeding 100 lbs/day and are
    using exclusions.
   Emissions exceeding 15 lbs/day if they had
    been completely exempt from the rule.
   Sources with heatset web offset lines and
    which exceed 100 lbs/day from all
    lithographic printing lines at the source.
      Certifications and Notifications

   All of the certifications and notifications that
    have been mentioned here should be sent to:

       Illinois EPA
       Bureau of Air/Compliance Section (#40)
       1021 North Grand Ave. East
       P.O. Box 19276
       Springfield, IL 62794-9276

        Illinois RACT Rule - Overview
      PII/PIA Compliance Toolkit for Members
   Rule explanation
   Copy of final rule
   Certification forms and instructions
   Compliance recordkeeping forms
   VOM calculation fact sheets
    University of Illinois
    Sustainable Technology Center (ISTC)
   Established in 1985
        A Unit of the Institute of Natural Resource Sustainability at the
         University of Illinois
        Originally A division of the IL Department of Natural Resources
        One of the State Scientific Surveys
          •   Natural History Survey
          •   Water Survey
          •   Geological Survey
          •   Formerly the IL Waste Management & Research Center (WMRC)
   State Scientific Surveys Transferred to University of Illinois – July
    1, 2008
        Changed our Name to Illinois Sustainable Technology Center
         (ISTC)
University of Illinois
Sustainable Technology Center
(ISTC)
Headquarters               Satellite Offices
One East Hazelwood Drive   Chicago Region
Champaign, Illinois        188 Industrial Drive
                           Elmhurst, Illinois

                           Central Illinois
                           1320 S.W. Monarch
                           Peoria, Illinois

                           Southern Illinois
                           8450 Montclair Avenue
                           Brighton, Illinois
ISTC’s Mission & Objective

   ISTC is a change agency that performs
    research, spreads awareness, and
    facilitates implementation regarding
    practices, technology and systems that
    improve sustainability.
ISTC Mission Implementation

ISTC helps businesses and citizens:
 Reduce solid and hazardous wastes
  before they are released to the air,
  water and land.
 Works with companies to identify and
  implement opportunities to meet their
  waste reduction goals.
ISTC’s Assistance to Printers

   On-site Compliance Assessment &
    Assistance
   On-site Process and Energy Efficiency
   Waste Minimization Assistance
   Access to Fact Sheets, Case Studies,
    etc. Specific to Printers
          What is PNEAC?
   Small Business Compliance Assistance Center Funded
    by EPA
       Established in 1995
   A Unique Partnership between University-Based
    Technical Assistance Organizations & Printing Trade
    Organizations
       EPA’s Office of Enforcement and Compliance Assurance
       U of I Sustainable Technology Center (ISTC)
       U of WI Solid & Hazardous Waste Education Center (SHWEC)
       Printing Industries of America (PIA)
   For All Types of Printers and Printing Technologies
How Can PNEAC Help You?
   Increase access to printing-specific,
    understandable compliance information
   Give you practical, tested suggestions on how
    to reduce wastes and associated costs
   Improve your understanding of printing and
    environmental challenges facing printers
   Improve your access to the best technical and
    training resources to support your work with
    printers
   Help you connect with experts and peers to
    assist you
       PNEAC Services & Resources
       www.pneac.org

   Hot News
   Ask PNEAC
   Archives of Technical & Compliance
     Discussions
   Training
   Fact Sheets & Case Studies
   Compliance & Pollution Prevention Checklists
   Federal Compliance Info & Contacts
   Info on State and Regional Printing Regulations
   Links to Other Printing-Specific Web Resources
Contact PNEAC
   Web: www.pneac.org

   Deb Jacobson, Director
   630/833-1027
   djacobson@istc.illinois.edu

   Gary Jones, Co-Director
   412/259-1794
   GJones@printing.org

   Wayne Pferdehirt, Co-Director
   608/265-2361
   pferdehi@EPD.engr.wisc.edu
Time for Questions

   Click on Question button to submit your
    questions online.
   Please try to indicate who should
    answer the question.
       Thanks for Listening!
     Contact Information for Speakers
   Marci Kinter, marcik@sgia.org, (703)359-1313
   Dale Kalina, dale.kalina@enviro-partners.com,
    (630) 527-4773
   David Bloomberg, David.Bloomberg@Illinois.gov,
    (217) 782-5811
   Gary Jones, GJones@printing.org, (412) 259-
    1794
   Deb Jacobson, djacobson@istc.illinois.edu,
    (630) 833-1027