Permit-by-Rule User's Guide for Small and Midsize Printing Facilities - Office of Compliance Assistance and Pollution Prevention December 2008
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Office of Compliance Assistance and Pollution Prevention Permit-by-Rule User's Guide for Small and Midsize Printing Facilities Office of Compliance Assistance and Pollution Prevention December 2008
Table of Contents
Introduction ...................................................................................................................................... 1
General Information - Questions & Answers ....................................................................................... 2
What is a permit-by-rule (PBR)? .................................................................................................................. 2
How does a PBR differ from an ordinary permit? .......................................................................................... 2
What are the benefits of a PBR? .................................................................................................................. 2
Can a company that is operating a source according to an existing PTI or PTO switch to the PBR? ............. 2
What printing facility operations are covered by the PBR? ........................................................................... 2
What operations are not covered by the PBR? .............................................................................................. 3
Permit-by-Rule Requirements, Emissions & Material Usage Limits Summary ..................................... 4
Permit-by-Rule Requirements ............................................................................................................ 5
Overall Requirements ................................................................................................................................. 5
General Provisions ...................................................................................................................................... 5
Notification Requirements for New Installations ......................................................................................... 6
Notification Requirements for Existing Installations ................................................................................... 6
Notification Requirements for Existing Permit-by-Rule Sources ................................................................. 7
Records Retention Requirements ................................................................................................................ 7
Reporting Requirements ............................................................................................................................. 7
Scheduled Maintenance/Malfunction Reporting ......................................................................................... 7
Small Printing Facility Permit-by-Rule .............................................................................................. 8
Qualifications ............................................................................................................................................. 8
Applicable Emission Limitations and/or Control Requirements .................................................................. 9
Monitoring and/or Record Keeping Requirements ....................................................................................... 9
Permit-by-Rule Specific Reporting Requirements ....................................................................................... 10
Testing Requirements ................................................................................................................................ 10
Midsize Printing Facility Permit-by-Rule ........................................................................................... 11
Qualifications ............................................................................................................................................. 11
Applicable Emission Limitations and/or Control Requirements .................................................................. 12
Monitoring and/or Record Keeping Requirements ....................................................................................... 12
Testing Requirements ................................................................................................................................ 13
APPENDICES ..................................................................................................................................... 14
Appendix A - Glossary of Terms ................................................................................................................... 14
Appendix B - Air Permit Exemption List (OAC rule 3745-31-03) ................................................................... 17
Appendix C - PBR Notification Form and Instructions .................................................................................. 19
Appendix D - Example Recordkeeping Forms ............................................................................................... 22
Appendix E - Emission Calculation Guidance .............................................................................................. 28
Appendix F - Common Hazardous Air Pollutants in Graphic Arts Materials .................................................. 37
Appendix G - List of Hazardous Air Pollutants (HAP) ..................................................................................... 39
Appendix H - Ohio EPA District Offices/Local Air Agencies ......................................................................... 43
Permit-by-Rule User's Guide for Small and Midsize Printing FacilitiesIntroduction
The purpose of this user's guide is to provide the printing industry with information and guidance on
the proper use of the air pollution permit-by-rule (PBR) provisions specified by Ohio Administrative code
3745-31-03(A)(4)(k) and (l). These provisions exempt printing operations at small or midsize facilities
from traditional permits-to-install and permits-to-operate, but do require compliance with the appropri-
ate requirements specified in the PBR provisions.
About this updated version….
The version (December 2008) of this guide contains the June 30, 2008 version of the PBR rule OAC
3745-31-03(A)(4) that removed the emission limits and recordkeeping requirements for
"photochemically reactive materials" regulated under OAC 3745-21-07 and references the new
permit-to-install and operate (PTIO) program.
This guide supercedes the previous January 2006 version.
Disclaimer:
This guide is intended to be a tool to help printing facilities understand and comply with the permit-by-
rule provisions. It does not include a comprehensive listing of all environmental regulations that may
be applicable to a printing facility. A comprehensive listing would be dependent on regulatory and
business-specific factors, which are beyond the scope of this guide. This guide discusses the specific
permit-by-rule provisions for air pollution permitting exemptions under the new PBR regulations and
further company research on requirements not covered by this guide, such as for hazardous waste
disposal, may be necessary. Use of this guide is not a guarantee that a company meets all applicable
state and federal regulations. It is a tool to be used only for understanding the permit-by-rule provi-
sions.
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
1General Information - Questions & Answers
What is a permit-by-rule (PBR)?
A permit-by-rule (PBR) is a specific permit exemption a company may use to exempt an air pollution
source from the air permit process, but not from the applicable air pollution regulations and compliance
requirements.
The PBR contains qualifying criteria, emission limitations, conditions for operation and requirements
for record keeping and reporting. The air pollution source or facility must continually meet all of the
PBR criteria to qualify for the PBR. Ohio EPA retains the authority to revoke a company's ability to
operate under the PBR provisions and to require the company to obtain traditional permits.
How does a PBR differ from an ordinary permit?
Under traditional air permitting regulations, many air pollution sources, such as printing presses, must
obtain individual air pollution permits from Ohio EPA. A permit-to-install (PTI) is required before in-
stalling the air pollution source or press. Once the PTI is issued and prior to its expiration, a renewable
permit-to-operate (PTO) must be obtained for continued operation of the source or press lines after
installation. An individual PTI and PTO is required for each source or press line.
The PBR exempts these air pollution sources from the PTI and PTO process and functions as both the
installation and operating permit for the source or press line(s). However, the printer must continually
meet all of the PBR criteria. If the printer can no longer comply with the conditions of the PBR, the
company must apply for a traditional PTI and/or PTO. NOTE: In July 2008, the Ohio EPA combined
the PTI and PTO into a single permit, known as a permit-to-install and operate, or PTIO.
What are the benefits of a PBR?
Since printers qualifying for PBRs are exempt from obtaining a PTI, installation of new equipment can
be expedited. In addition, there are no associated fees under the PBR program.
The PBR puts all air pollution requirements in one place, saving time and money in evaluating potential
environmental protection agency requirements. The PBRs also contain simplified record-keeping and
reporting requirements as compared to traditional permits.
Can a printer that is operating a source according to an existing PTI or PTO switch to
the PBR?
Yes. The printer must submit a written request to Ohio EPA to revoke the affected permits and must
agree to meet all qualifying and operating conditions of the PBR. Ohio EPA will then make a final writ-
ten determination on the request. If approved, the company can begin operating according to the PBR
on the date the existing PTI or PTO is revoked. The PBR notification form included in this guide con-
tains a section to request that applicable permits be revoked.
Keep in mind that in some cases, the PBR conditions might impose more stringent limitations on the
facility than those specified in their current permits. It's important for the company to evaluate
whether the PBR option is advantageous for their facility.
What printing facility operations are covered by the PBR?
The PBR covers all pressroom equipment, including all press operations (makeready, printing runs, and
press cleaning), in-line or off-line coating, adhesive/binding operations, pre-press activities such as
plate making or screen making and any other press-related activities that involve the use of materials
that contain volatile organic compounds (VOCs) and Hazardous Air Pollutants (HAPs). The PBR covers all
of these operations at the facility. However, any press that utilizes rotogravure printing, or any press
that has a pollution control device, such as a thermal oxidizer, is not eligible for coverage under
the PBR.
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
2General Information - Questions & Answers
What operations are not covered by the PBR?
The PBR is mainly concerned with pressroom emissions that typically account for the majority of total
emissions from a printing facility. Other sources of air pollution at the facility, such as fuel-fired
heaters or boilers, post press equipment, parts washers using solvent, solvent recycling units, etc., may
require air permits unless the equipment or activity is specifically exempted. See the Appendix for a
list of common equipment exempted from air permits.
The PBR only applies to air pollution and does not cover issues related to proper disposal of wastes,
discharges to the local sewer system or other regulatory requirements.
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
3Permit-by-Rule Requirements, Emissions & Material Usage Limits Summary
To summarize, a printer choosing the PBR option is required to:
• submit a written notification to Ohio EPA requesting permission to install and/or operate under the
PBR;
• maintain the records required by the PBR and make them available to an Ohio EPA representative
upon request;
• notify Ohio EPA of administrative changes or when the printer would change PBR categories (for
example, a small facility increases emission enough or uses enough input materials so that it
becomes a midsize facility); and
• notify Ohio EPA in the event any of the PBR emission limitations or material usage restrictions are
exceeded.
Small Printing Facility PBR
Type of printing Annual facility Annual material usage limit
emission limit
Lithographic, heatset 10 tpy VOC 20,000 lbs of ink, cleaning solvent and fountain solution additives
combined
Lithographic, non- 10 tpy VOC 2,850 gallons of cleaning solvent and fountain solution additives
heatset combined
Digital 10 tpy VOC 2,425 gallons of inks, clean-up solutions and other solvent-
containing materials combined
Screen 10 tpy VOC 2,850 gallons of inks, clean-up solutions and other solvent-
containing materials combined
Letterpress 10 tpy VOC 2,850 gallons of inks, clean-up solutions and other solvent-
containing materials combined
Flexographic, water- 10 tpy VOC 80,000 lbs. of water-based inks, coatings, and adhesives
based or UV combined
Flexographic, solvent- 10 tpy VOC 20,000 lbs. of solvent from inks, dilution solvents, coatings,
based cleaning solutions and adhesives combined
All small printing 5 tpy single HAP 1,333 gallons of materials containing the same single HAP
facilities 10 tpy total HAP 2,667 gallons of materials containing any HAPs.
Mid-size Printing Facility PBR
Type of printing Rolling 12-month Rolling 12-month rolling material usage limit
facility emission
limit
Lithographic, heatset 25 tpy VOC 50,000 lbs of ink, cleaning solvent and fountain solution
additives combined
Lithographic, non- 25 tpy VOC 7,100 gallons of cleaning solvent and fountain solution additives
heatset combined
Digital 25 tpy VOC 6,000 gallons of inks, clean-up solutions and other solvent-
containing materials combined
Screen 25 tpy VOC 7,100 gallons of inks, clean-up solutions and other solvent-
containing materials combined
Letterpress 25 tpy VOC 7,100 gallons of inks, clean-up solutions and other solvent-
containing materials combined
Flexographic, water- 25 tpy VOC 200,000 lbs. of water-based inks, coatings, and adhesives
based or UV combined
Flexographic, solvent- 25 tpy VOC 50,000 lbs. of solvent from inks, dilution solvents, coatings,
based cleaning solutions and adhesives combined
All midsize printing 5 tpy single HAP 1,333 gallons of materials containing the same single HAP
facilities 12.5 tpy total HAP 3,333 gallons of materials containing any HAPs
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
4Permit-by-Rule Requirements for Small and Midsize Printing Facilities
The following table provides both the actual text of the PBR rule on the left side of the page and short
explanations and tips to aid understanding on the shaded right side. For a quick understanding of your
PBR obligations, you can scan the right side of the table only. The regulatory text is taken directly from
selected paragraphs of OAC rule 3745-31-03(A)(4). Copies of this rule are available at
www.epa.state.oh.us/dapc/regs/regs.html.
Under the PBR rules, there are three distinct sections:
1) Paragraph (A)(4): Overall requirements that exempt PBR categories from air permits, but not air
pollution regulations;
2) Paragraph (A)(4)(a): General provisions that specify notification, record retention, and reporting
requirements for all PBR categories; and
3) Paragraph (A)(4)(k): Specific requirements for small printing facilities, or Paragraph (A)(4)(l):
Specific requirements for mid-size printing facilities.
Permit-by-Rule Text Explanation
(A)(4) Permit-by-Rule Exemptions
The following air contaminant sources are exempt from the requirement to Printers registering for the
obtain a permit-to-install or PTIO. These exemptions are valid only as long PBR are exempt from permit-
as the owner or operator complies with all of the permit-by-rule general to-install (PTI) or a permit-to-
provisions, meets the qualifying criteria defined in the applicable permit-by- install and operate (PTIO) for
rule and complies with all of the requirements under the applicable permit- equipment that is covered by
by-rule specific provisions. Upon request by the director, the owner or opera- the PBR. You must continually
tor of a facility that has exceeded the permit-by-rule thresholds or that the operate according to the PBR
director finds is causing or may cause a public nuisance in violation of rule conditions and keep the
3745-15-07 of the Administrative Code shall submit an application for a required records to remain
permit-to- install or PTIO. eligible.
These exemptions do not, however, exempt any air contaminant source Ohio EPA can request you to
from requirements of the federal Clean Air Act, including being considered get a permit if your PBR facility
for purposes of determining whether a facility constitutes a major source or is causing a nuisance, such as
is otherwise regulated under Chapter 3745-77 of the Administrative Code or neighborhood property damage
any requirement to list insignificant activities and emission levels in a or demonstrated health effects.
Title V permit application. In addition, this rule does not relieve the owner
or operator from the requirement of including the emissions associated with Although most PBR facilities
the exempt sources into any major NSR permitting action. will not be Title V facilities,
any Title V facility using a PBR
must identify the presses
covered by the PBR in their
Title V operationg permit and
include the emissions in the
required reports and certifica-
tions.
(A)(4)(a) General Provisions
These general provisions apply to all owner or operators who are utilizing There are 11 PBR categories.
one or more of the permit-by-rule exemptions listed in paragraphs (A)(4)(b) Only the small printing PBR,
through (A)(4)(l) of this rule. paragraph (A)(4)(k), and mid-
size printing PBR, paragraph
(A)(4)(l), are included in this
guide.
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
5Permit-by-Rule Requirements for Small and Midsize Printing Facilities
Permit-by-Rule Text Explanation
Recordkeeping Requirements - 3745-31-03(A)(4)(a)(i)
The owner or operator shall collect and maintain the records described for You must maintain the
each air contaminant source exempted under paragraph (A)(4) of this rule records required by the PBR for
and these records shall be retained in the owner or operator's files for a five years and make them
period of not less than five years, unless otherwise specified in each exemp- available to Ohio EPA upon
tion. These records shall be made available to the director or any authorized request.
representative of the director for review during normal business hours.
Notification Requirements for New Installations - 3745-31-03(A)(4)(a)(ii)
For the purposes of this paragraph, a new permit-by-rule air contaminant The printing PBRs became
source is an air contaminant source installed after the promulgation date of available on July 29, 2005.
any new applicable permit-by-rule or July 29, 2005, whichever comes later. You must notify Ohio EPA if
The owner or operator of a new permit-by-rule air contaminant source you want to operate under the
electing to use an applicable permit-by-rule exemption shall submit a writ- PBR. Use the specific notifica-
ten notification in a form and manner prescribed by the director prior to tion form in the Appendix or
installation of the air contaminant source. This notification, or form, shall download it at
be submitted to the appropriate Ohio environmental protection agency www.epa.state.oh.us/dapc/
district office or local air agency, and shall contain the following information, pbr/permitbyrule.html.
at a minimum:
(a) The owner or operator's and the facility contact's name;
(b) The facility mailing address and telephone number;
(c) The location of the air contaminant source(s);
(d) A description of the air contaminant source, including any pollution
control(s); and
(e) A statement by the owner or operator that indicates which permit-by-
rule applies to the air contaminant source.
Notification Requirements for Existing Permitted Sources -
3745-31-03(A)(4)(a)(iii)
The owner or operator of an air contaminant source which is operating If you have existing air per-
under an existing permit-to-install, PTIO and/or permit-to-operate may mits for your presses, you can
continue to operate in compliance with that permit or may submit a written switch them to PBR. Use the
request to the Ohio environmental protection agency to revoke any such PBR notification form to
individual permit or permits and to allow the air contaminant source to request authorization to
operate under the permit-by-rule provisions. The director may revoke a operate under the PBR and to
permit-to-install, PTIO and/or permit-to-operate if the permittee requests revoke existing permits. Your
revocation, agrees to meet all permit-by-rule qualifying and operating condi- Ohio EPA district office or local
tions, and the director determines that the revocation will not result in the air agency will evaluate your
violation of any applicable laws. When a permittee requests a revocation request and notify you in
pursuant to this paragraph, the director, without prior hearing, shall make a writing if approved.
final determination on the request and inform the permittee in writing. If
the director agrees with the request to operate under the permit-by-rule, You must wait until Ohio EPA
then the permit-by-rule becomes applicable to the permittee on the date the revokes your existing permits
existing permit-to-install, PTIO and/or permit-to-operate are revoked. before you can operate under
the PBR.
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
6Permit-by-Rule Requirements for Small and Midsize Printing Facilities
Permit-by-Rule Text Explanation
Notification Requirements for Existing Permit-by-Rule Sources -
3745-31-03(A)(4)(a)(iv)
The owner or operator of an air contaminant source that is operating under NOTE: This provision does not
one of the permit-by-rules that existed prior to July 29, 2005 (emergency apply to printers since they
electrical generators, injection and compression molding, crushing and were not an "existing" PBR
screening plants, soil-vapor extraction and soil-liquid extraction) and desires category before July 29,
to continue operating under the permit-by-rule shall submit a written 2005.
notification which contains all of the elements required in paragraph
(A)(4)(a)(ii) of this rule. This notification shall be submitted to the appropri-
ate Ohio environmental protection agency district office or local air agency
and shall be submitted by July 29, 2006.
Records Retention Requirements - 3745-31-03(A)(4)(a)(v)
Each record of any monitoring data, testing data, and support information You must keep PBR records for
required pursuant to a specific permit-by-rule shall be retained for a period of five years.
five years from the date the record was created. Support information shall
include, but not be limited to, all calibration and maintenance records and
all original strip-chart recordings for continuous monitoring instrumenta-
tion, and copies of all reports required by the specific permit-by-rule. Such
records may be maintained in computerized form.
Reporting Requirements - 3745-31-03(A)(4)(a)(vi)
The owner or operator shall submit required reports in the following manner:
Submit reports to your Ohio
(a) Reports of any monitoring and/or record keeping information required EPA district office or local air
by a specific permit-by-rule shall be submitted to the appropriate Ohio agency.
environmental protection agency district office or local air agency.
(b) Except as otherwise may be provided in a permit-by-rule specific The small printing facility PBR
reporting requirements paragraph of a specific permit-by-rule, a has a "Permit-by-Rule Specific
written report of any deviations (excursions) from emission limita- Reporting Requirements"
tions, operational restrictions, qualifying criteria, and control equip- paragraph. It requires you to
ment operating parameter limitations that have been detected by the re-notify if switching to the
testing, monitoring, and record keeping requirements specified in the mid-size facility PBR.
permit-by-rule shall be submitted to the appropriate Ohio environ-
mental protection agency district office or local air agency within You must report any
thirty days of the date the deviation occurred. The report shall de- exceedance of a PBR limit or
scribe the specific limitation and/or operational restriction exceeded, condition such as emissions
the probable cause of such deviation, and any corrective actions or above the threshold to your
preventive measures that have been or will be taken. Ohio EPA district office or local
air agency within 30 days.
Scheduled Maintenance/Malfunction Reporting - 3745-31-03(A)(4)(a)(vii)
Any scheduled maintenance of air pollution control equipment shall be This general requirement
performed in accordance with paragraph (A) of rule 3745-15-06 of the Admin- applies to any company that
istrative Code. The malfunction of any emissions units or any associated operates air pollution control
air pollution control system(s) shall be reported to the appropriate Ohio equipment. It does not affect
environmental protection agency district office or local air agency in accor- printers using the PBR since
dance with paragraph (B) of rule 3745-15-06 of the Administrative Code. their presses cannot have the
Except as provided in that rule, any scheduled maintenance or malfunction control systems mentioned.
necessitating the shutdown or bypassing of any air pollution control
system(s) shall be accompanied by the shutdown of the emissions unit(s)
that is served by such control system(s).
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
7Permit-by-Rule Requirements for Small and Midsize Printing Facilities
Permit-by-Rule Text Explanation
Small Printing Facility Permit-by-Rule - 3745-31-03(A)(4)(k)
Qualifications - 3745-31-03(A)(4)(k)(i)
A printing facility that meets the following qualifications is eligible to use
this permit-by-rule: Rotogravure printing and
presses with pollution control
(a) The facility has one or more printing lines which utilize only the devices such as thermal
screen, digital, flexographic, letterpress, non-heatset lithographic, or oxidizers are not eligible for
heatset lithographic printing processes, and which do not utilize add- PBR.
on emissions control equipment.
The tons per year emission
(b) The facility emits no more than ten tons of VOCs, five tons of a single limits are for the whole
hazardous air pollutant (HAP) and ten tons of combined HAPs in any facility. You can either calcu-
calendar year as demonstrated by either calculating actual facility- late your emissions or stay
wide emissions, using methods approved by the Ohio environmental under the total material usage
protection agency, or by electing to comply with the material usage limits each year. See the
limitations specified in paragraph (A)(4)(k)(i)(c) of this rule. Appendix for how to calculate
(c) In lieu of calculating emissions to demonstrate compliance with the emissions.
annual facility emission limitations specified in paragraph
(A)(4)(k)(i)(b) of this rule, the owner or operator may elect to qualify the Total annual usage limits
facility for this permit-by-rule by meeting the following material usage depend on the type of material
limitations for all materials employed at the facility in any calendar and the printing method used.
year:
(i) Uses no more than one thousand three hundred thirty three If you elect to use the material
gallons of materials containing the same single HAP and no usage limits, you must meet
more than two thousand six hundred sixty-seven gallons of all three of these limits:
materials containing any HAPs.
• 1,333 gallons of materials
(ii) Operates only heatset offset lithographic printing lines and containing the same HAP; and
uses no more than twenty thousand pounds of ink, cleaning
solvent, and fountain solution additives combined; or • 2,667 gallons of materials
(iii) Operates only non-heatset offset lithographic printing lines containing any HAPs; and
and uses no more than two thousand eight hundred fifty
gallons of cleaning solvent, and fountain solution additives • the overall usage limit for
combined; or your method of printing.
(iv) Operates only digital printing lines and uses no more than two
thousand four hundred twenty-five gallons of solvent from inks (HAP = hazardous air pollutant)
and clean-up solutions and other solvent-containing materials
combined; or Check the material's MSDS
for HAP content or contact the
(v) Operates only screen or letterpress printing lines and uses no supplier. The Appendix
more than two thousand eight hundred fifty gallons of solvent contains a list of the specific
from inks and clean-up solutions and other solvent-containing HAP compounds.
materials combined; or
(vi) Operates only water-based or ultraviolet (UV)-cured material A facility having a combina-
flexographic printing lines and uses no more than eighty tion of printing methods must
thousand pounds of water-based inks, coatings, and adhesives, comply with smallest usage
combined; or limit OR can calculate emis-
(vii) Operates only solvent based material flexographic printing sions instead.
lines and uses no more than twenty thousand pounds of
solvent from inks, dilution solvents, coatings, cleaning solu- For example, if a company
tions and adhesives, combined; or operates both screen printing
and digital equipment, the
(viii) Operates any combination of screen, digital, flexographic, total volume of material used
letterpress, non-heatset lithographic, or heatset lithographic by both screen and digital
printing lines and the facility uses no more than the most presses need to be below the
stringent of the material usage limitations contained in usage limit for digital, since it
paragraphs (A)(4)(k)(ii) through (A)(4)(k)(vii) above for the type of is smaller than the usage
units at the facility. limit for screen printing.
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
8Permit-by-Rule Requirements for Small and Midsize Printing Facilities
Permit-by-Rule Text Explanation
Applicable Emission Limitations and/or Control Requirements -
3745-31-03(A)(4)(k)(ii)
(a) The applicable rules, emissions limitations and control requirements This table lists the Ohio air
that apply to the facility subject to this permit-by-rule are defined in pollution rules applicable to
the following table: printers.
Applicable Rule(s) Applicable Emission Limitation/Control Requirements These are ANNUAL emission
limits for the whole facility.
Paragraph (A)(3) of Facility emissions shall not exceed ten tons of VOC,
rule 3745-31-05 of five tons of a single HAP and ten tons of combined The qualifying criteria of the
the Administrative HAPs for any calendar year. PBR ensure that the total
Code usage of coatings and inks
does not exceed 148 tons per
Paragraph (Y)(2)(b) of Exempt from the requirements of paragraph (Y)(1) of year or that total facility VOC
rule 3745-21-09 of rule 3745-21-09 of the Administrative Code since the emissions do not exceed 100
the Administrative qualifying criteria ensure that the combined maxi- tons per year. Therefore,
Code (flexographic mum usage of coatings and inks in all presses at the more stringent requirements,
presses only) facility is less than on hundred forty-eight tons per
such as ink solvent content
year.
limits or add-on control sys-
tems, are not necessary for
flexographic operations.
Monitoring and/or Record Keeping Requirements - 3745-31-03(A)(4)(k)(iii)
(a) The owner or operator of the printing facility shall maintain annual You are required to keep
records at the facility that list the following information for each annual materials usage
graphic arts material (ink, fountain solution additives, clean-up records. EPA inspectors will
solvents, etc.) employed in the facility during each calendar year: want to see these if they
(i) The name and identification number of each material em- inspect your facility.
ployed.
(ii) The quantity of each material employed, in gallons or pounds. Check the material's MSDS
(iii) The OC content of each material, in pounds per gallon, or for VOC and HAP content or
percent, by weight. contact the supplier.
(iv) The individual HAP content for each HAP-containing material,
in pounds of individual HAP per gallon of material. Total annual usage of all
materials.
(v) The total combined HAP content of each material, in pounds of
total HAP per gallon of material. Calculate emissions annually
(vi) The annual summation of usage in gallons, or pounds, of each if choosing this option.See
graphic arts material if the facility elects to demonstrate Ohio EPA Engineering Guides
compliance with the material usage limitations specified in #56 and #68 or the Appendix
paragraph (A)(4)(k)(c) of this rule; or for how to calculate emissions.
(vii) The annual summation of total facility emissions of VOC, Engineering Guides can be
individual HAP, and combined HAP from all graphic arts found at www.epa.state.oh.us/
materials employed if the facility elects to calculate actual dapc/engineer/eguides.html.
emissions to demonstrate compliance with the emission
limitations specified in paragraph (A)(4)(k)(b) of this rule.
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
9Permit-by-Rule Requirements for Small and Midsize Printing Facilities
Permit-by-Rule Text Explanation
Permit-by-Rule Specific Reporting Requirements - 3745-31-03(A)(4)(k)(iv)
(a) If a small printing facility exempt under paragraph (A)(4)(k) of this rule If you're switching from a
should elect to operate under the permit-by-rule provisions for a small printing PBR to a mid-
midsize printing facility specified by paragraph (A)(4)(l) of this rule, the size PBR, a new notification
owner or operator of such facility shall comply with the notification form to Ohio EPA is required.
requirements of paragraph (A)(4)(a)(ii) of this rule prior to operating More record keeping and
under the permit-by-rule provisions for midsize printing facilities. limits for cleaning solutions
are required under the mid-
size PBR.
Testing Requirements - 3745-31-03(A)(4)(k)(v)
(a) Compliance with the annual material usage limitations shall be Your usage records should be
based upon the record keeping requirements specified in paragraph able to show how you comply
(A)(4)(k)(iii)(a) of this rule. with the material usage
(b) For screen, letterpress, and non-heatset lithographic printing, compli- limits.
ance with the annual VOC emission limitation is based on the an-
nual material usage limitations, in gallons, multiplied by a maximum This is background informa-
VOC content of 7.0 pounds per gallon, and divided by two thousand tion to explain how the facil-
pounds per ton. For digital printing, compliance with the annual VOC ity-wide emission limits of 10
emission limitation is based on the annual material usage limita- tons/yr VOC, 5 tons/yr single
tions, in gallons, multiplied by a maximum VOC content of 7.5 pounds HAP and 10 tons/yr combined
per gallon, and divided by two thousand pounds per ton. For water- HAPs relate to the material
based or UV-cured flexographic printing, compliance with the annual usage limits. These calcula-
VOC emission limitation is based on the annual material usage tions assume high VOC
limitation, in pounds, multiplied by an assumed maximum VOC content materials and are
content of twenty five percent, and divided by two thousand pounds per very conservative to allow for a
ton. For solvent-based flexographic printing and heatset lithographic margin of error.
printing, compliance with the annual VOC emission limitation is
based on the annual material usage limitation, in pounds, multiplied
by an assumed maximum VOC content of one hundred percent, and
divided by two thousand pounds per ton. For all printing types, compli-
ance with the annual HAP emission limitations is based on the
annual material usage limitations specified in paragraph
(A)(4)(k)(i)(c)(i) of this rule, in gallons, multiplied by a maximum HAP
content of 7.5 pounds per gallon, and divided by two thousand pounds
per ton.
(c) An owner or operator of the facility electing to demonstrate compli-
ance with the annual VOC, HAP, and combined HAP emission limita-
tions by calculating the actual facility emissions may use the actual
material VOC contents and usage rates from records required by
paragraph (A)(4)(k)(iii) of this rule. The calculations shall be per-
formed annually using methods approved by the Ohio environmental
protection agency.
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
10Permit-by-Rule Requirements for Small and Midsize Printing Facilities
Permit-by-Rule Text Explanation
Midsize Printing Facility Permit-by-Rule - 3745-31-03(A)(4)(l)
Qualifications - 3745-31-03(A)(4)(l)(i)
A printing facility that meets the following qualifications is eligible to use
this permit-by-rule: Rotogravure printing and
presses with pollution control
(a) The facility has one or more printing lines which utilize only the devices, such as thermal
screen, digital, flexographic, letterpress, non-heatset lithographic, or oxidizers, are not eligible for
heatset lithographic printing processes, and which do not utilize add- PBR
on emissions control equipment.
The tons per year emission
(b) The facility emits no more than twenty-five tons of VOCs, five tons of limits are for the whole
a single HAP and 12.5 tons of combined HAPs in any rolling, 12-month facility. You can either calcu-
period as demonstrated by either calculating actual facility-wide late your emissions or stay
emissions, using methods approved by the Ohio environmental under the total material usage
protection agency, or by electing to comply with the material usage limits each year. A rolling 12-
limitations specified in paragraph (A)(4)(l)(i)(c) of this rule. month period begins each
month as the last month's
usage is added to the previous
11 months. See the Appendix
(c) In lieu of calculating emissions to demonstrate compliance with the for how to calculate emissions.
facility emission limitations specified in paragraph (A)(4)(l)(i)(b) of this
rule, the facility may elect to qualify for this permit-by-rule by meet- Total annual usage limits
ing the following material usage limitations for all materials employed depend on the type of material
at the facility in any rolling, twelve-month period: and the printing method used.
(i) Uses no more than one thousand three hundred thirty-three
gallons of materials containing the same single HAP and no If you elect to use the material
more than three thousand three hundred thirty-three gallons usage limits, you must meet
of materials containing any HAPs. all three of these limits:
(ii) Operates only heatset offset lithographic printing lines and
uses no more than fifty thousand pounds of ink, cleaning • 1,333 gallons of materials
solvent, and fountain solution additives combined; or containing the same HAP; and
(iii) Operates only non-heatset offset lithographic printing lines • 3,333 gallons of materials
and uses no more than seven thousand one hundred gallons of containing any HAPs; and
cleaning solvent and fountain solution additives combined; or
(iv) Operates only digital printing lines and uses no more than six • the overall usage limit for
thousand gallons of solvent from inks and clean-up solutions your method of printing.
and other solvent containing materials combined; or
(v) Operates only screen or letterpress printing lines and uses no
more than seven thousand one hundred gallons of solvent from
inks and clean-up solutions and other solvent containing Check the material's MSDS
materials combined; or for HAP content or contact the
supplier. The Appendix
(vi) Operates only water-based or ultraviolet (UV)-cured material contains a list of the specific
flexographic printing lines and uses no more than two hundred HAP compounds.
thousand pounds of water-based inks, coatings, and adhe-
sives, combined; or
(vii) Operates only solvent based material flexographic printing
lines and uses no more than fifty thousand pounds of solvent
from inks, dilution solvents, coatings, clean-up solutions and
adhesives, combined; or
(viii) Operates any combination of screen, digital, flexographic, A facility having a combina-
letterpress, non-heatset lithographic, or heatset lithographic tion of printing methods must
printing processes and the facility uses no more than the most comply with smallest usage
stringent of the material usage limits contained in paragraphs limit OR can calculate emis-
(A)(4)(l)(ii) through (A)(4)(l)(vii) above for the type of units at the sions instead.
facility.
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
11Permit-by-Rule Requirements for Small and Midsize Printing Facilities
Permit-by-Rule Text Explanation
Qualifications - 3745-31-03(A)(4)(l)(i)
(d) The facility employs cleanup solutions which meet all of the following
standards:
(i) Cleanup solutions either shall not exceed thirty percent VOC, NOTE: Specifications for
by weight, as applied, or shall have a VOC composite partial cleanup solutions are addi-
pressure of ten millimeters of mercury (mmHg) or less at tional requirements for
twenty degrees Celsius (sixty-eight degrees Fahrenheit). midsize facilities. Consult
(ii) Cleanup solutions shall be kept in covered containers during MSDS or supplier to ensure
transport and storage. that cleaning solutions meet
(iii) Shop towels contaminated with cleanup solution shall be kept, these formulation criteria.
when not in use, in covered containers.
(iv) The use of cleanup solutions not meeting the condition in
paragraph (A)(4)(l)(i)(d)(i) of this rule shall not exceed a com-
bined total of one hundred ten gallons in any rolling, twelve-
month period.
Applicable Emission Limitations and/or Control Requirements -
3745-31-03(A)(4)(l)(ii)
(a) The applicable rules, emission limitations, and control requirements
that apply to the facility subject to this permit-by-rule are defined in
the following table: These are rolling, 12-month
emission limits for the whole
Applicable Rule(s) Applicable Emission Limitation/Control Requirements facility, not per calendar year
as with the small printing
Paragraph (A)(3) of Facility emissions shall not exceed twenty-five tons of PBR.
rule 3745-31-05 of VOC, five tons of a single HAP and 12.5 tons of com-
the Administrative bined HAPs for any rolling, twelve-month period. The qualifying criteria of the
Code PBR ensure that the total
usage of coatings and inks
Paragraph (Y)(2)(b) of Exempt from the requirements of paragraph (Y)(1) of does not exceed 148 tons per
rule 3745-21-09 of rule 3745-21-09 of the Administrative Code since the year or that total facility VOC
the Administrative qualifying criteria ensure that the combined maxi- emissions do not exceed 100
Code (flexographic mum usage of coatings and inks in all presses at the tons per year. Therefore,
presses only) facility is less than one hundred forty-eight tons per more stringent requirements,
year. such as ink solvent content
limits or add-on control sys-
tems, are not necessary for
flexographic operations.
Monitoring and/or Record Keeping Requirements - 3745-31-03(A)(4)(l)(iii)
You are required to keep
(a) The owner or operator of the printing facility shall maintain monthly monthly materials usage
records at the facility that list the following information for each records. EPA inspectors will
graphic arts material (ink, fountain solution additives, cleanup want to see these if they
solvents, etc.) employed in the facility: inspect your facility.
(i) The name and identification number of each material em-
ployed.
(ii) The quantity of each material employed, in gallons or pounds.
(iii) The OC content of each material, in pounds per gallon, or Check the material's MSDS
percent by weight. for VOC and HAP content or
(iv) The individual HAP content for each HAP-containing material, contact the supplier.
in pounds of individual HAP per gallon of material.
(v) The total combined HAP content of each material, in pounds of
combined HAP per gallon of material.
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
12Permit-by-Rule Requirements for Small and Midsize Printing Facilities
Permit-by-Rule Text Explanation
Monitoring and/or Record Keeping Requirements - 3745-31-03(A)(4)(l)(iii)
(vi) The rolling, twelve-month summation of usage in gallons of Add the new month's usage
each graphic arts material employed if the facility elects to total to the previous 11
demonstrate compliance with the material usage limitations months for the rolling, 12-
specified in paragraph (A)(4)(l)(i)(c) of this rule; or (vii) The month period.
rolling, twelve-month summation of total facility emissions of
VOC, individual HAP, and combined HAP from all graphic arts
materials employed if the facility elects to calculate actual
emissions to demonstrate compliance with the emission If you choose to calculate
limitations specified in paragraph (A)(4)(l)(i)(b) of this rule. emissions, add each month's
(vii) The rolling, twelve-month summation of total facility emis- emissions to the emissions of
sions of VOC, individual HAP, and combined HAP from all the previous 11 months for
graphic arts materials employed if the facility elects to calcu- the rolling, 12-month total.
late actual emissions to demonstrate compliance with the See Ohio EPA Engineering
emission limitations specified in paragraph (A)(4)(l)(i)(b) of this Guides #56 and #68 or Appen-
rule. dix for how to calculate emis-
sions. Engineering Guides
can also be found at
Testing Requirements - 3745-31-03(A)(4)(l)(iv) www.epa.state.oh.us/dapc/
engineer/eguides.html.
(a) Compliance with the rolling, twelve-month material usage thresholds
and/or emission limitations shall be based upon the record keeping Your usage records should be
requirements specified in paragraph (A)(4)(l)(iii)(a) of this rule. able to show how you comply
with the material usage
(b) For screen, letterpress, and non-heatset lithographic printing, compli- limits.
ance with the annual VOC emission limitation is based on the an-
nual material usage limitations, in gallons, multiplied by a maximum This is background informa-
VOC content of 7.0 pounds per gallon, and divided by two thousand tion to explain how the facility-
pounds per ton. For digital printing, compliance with the annual VOC wide emission limits of 25
emission limitation is based on the annual material usage limita- tons/yr VOC, 5 tons/yr single
tions, in gallons, multiplied by a maximum VOC content of 7.5 pounds HAP and 12.5 tons/yr com-
per gallon, and divided by two thousand pounds per ton. For water- bined HAPs relate to the
based or UV-cured flexographic printing, compliance with the annual material usage limits. These
VOC emission limitation is based on the annual material usage calculations assume high
limitation, in pounds, multiplied by an assumed maximum VOC VOC content materials and
content of twenty five percent, and divided by two thousand pounds per are very conservative to allow
ton. For solvent-based flexographic printing and heatset lithographic for a margin of error.
printing, compliance with the annual VOC emission limitation is
based on the annual material usage limitation, in pounds, multiplied
by an assumed maximum VOC content of one hundred percent, and
divided by two thousand pounds per ton. For all printing types, compli-
ance with the annual HAP emission limitations is based on the
annual material usage limitations specified in paragraph
(A)(4)(l)(i)(c)(i) of this rule, in gallons, multiplied by a maximum HAP
content of 7.5 pounds per gallon, and divided by two thousand pounds
per ton.
(c) An owner or operator of the facility electing to demonstrate compli-
ance with the annual VOC, HAP, and combined HAP emission limita-
tions by calculating the actual facility emissions may use the actual
material VOC contents and usage rates from records required by
paragraph (A)(4)(l)(iii) of this rule. The calculations shall be performed
using methods approved by the Ohio environmental protection agency.
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
13Appendix A - Glossary of Terms
Adhesive - any substance that is used to bond one surface to another surface.
Air contaminant source - each separate operation, or activity that results or may result in the
emission of any air contaminant. This definition applies to operations or activities that emit air con-
taminants, whether regulated under Ohio law or regulated under the Clean Air Act.
Aqueous coating - a water-based surface coating applied directly over ink on a printed substrate for
the purpose of enhancing or protecting the printed surface.
Cleaning solution - liquid solvents or solutions used to remove ink and debris from the operating
surfaces of the printing press and its parts.
Clear coating - a varnish or any coating which is transparent or lacks pigment.
Coating or surface coating - a material applied onto or saturated within a substrate for decorative,
protective or functional purposes. Such materials include, but are not limited to, paints, varnishes,
sealers, adhesives and inks.
Coating applicator - an apparatus used to apply a surface coating.
Day - a period of twenty-four consecutive hours beginning at midnight local time, or beginning at a
time consistent with a facility’s operating schedule.
Digital printing (direct-to-media printing) line - a printing line where the transfer of elec-
tronic files occurs directly from the computer to an electronically driven output device that prints the
image directly on the selected media (substrate). Electronic images and four-color process images can
be printed virtually any size.
Exempt solvent - any of the compounds which are specifically identified as not being volatile organic
compounds. See definition of “Volatile organic compound” below.
Flexographic printing line - a printing line in which each roll printer uses a roll with raised areas
for applying an image to the substrate. The image carrier on the roll is made of rubber or other flexible
elastomeric material.
Fountain solution - a surface coating applied to the plate roll of an offset lithographic printing line
for the purpose of wetting only the nonimage areas so that they are not ink receptive.
Fountain solution additives - volatile and non-volatile chemicals, alcohols, and other additives,
which are blended with water to form the fountain solution used in the lithographic printing process.
Hazardous air pollutant (also denoted as “HAP”) - any air pollutant listed in or pursuant to
Section 112(b) of the Clean Air Act.
Ink - a coating applied by a roll printer.
Letterpress printing line - a printing process where the image area is raised relative to the non-
image area and the paste ink is transferred to the paper directly from the image surface without the
use of an anilox roller.
Lithographic printing line - a printing line, except that the substrate is not necessarily fed from
an unwinding roll, in which each roll printer uses a roll where both the image and nonimage areas are
essentially in the same plane (planographic).
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
14Appendix A - Glossary of Terms
Non-heatset - an offset lithographic printing process where the printing inks dry by oxidation and
absorption without the use of heat. For the purposes of this chapter, ultraviolet-cured (UV) and electron
beam-cured inks employed in an offset lithographic printing process are considered non-heatset.
Offset lithographic printing line - a lithographic printing line where the image is applied from a
plate roll to an intermediate (blanket) roll and then transferred onto the substrate.
Organic compounds (also denoted as “OC”) - any chemical compound containing carbon,
excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides, metallic carbonates, am-
monium carbonate, non landfill gas methane and ethane.
Printing line - an operation consisting of a series of one or more roll printers and any associated in-
line roll coaters, in-line extrusion coaters, drying areas and ovens wherein one or more surface coat-
ings are applied, dried, and/or cured. It is not necessary for an operation to have an oven or drying area
in order to be included within this definition.
Roll coater - an apparatus in which a uniform layer of coating material is applied by means of a roll or
rolls across the entire width of a moving substrate, which is fed from an unwinding roll.
Roll printer - an apparatus in which a surface coating is applied by means of a roll or rolls with only
partial coverage across the width of a moving substrate, which is fed from an unwinding roll. The
partial coverage results in the formation of words, designs or pictures on the substrate.
Rotogravure printing line - a printing line in which each roll printer uses a roll with recessed
areas for applying an image to the substrate.
Screen printing line - a printing a process where the printing ink passes through a web or a fabric
to which a refined form of stencil has been applied. The stencil openings determine the form and
dimensions of the imprint.
Varnish coating - an oil-based surface coating applied directly over ink on a printed substrate for the
purpose of enhancing or protecting the printed surface.
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
15Appendix A - Glossary of Terms
Volatile organic compound (VOC) - any organic compound that participates in atmospheric
photochemical reactions. This includes any organic compound other than the following compounds:
• Acetone, ethane, methane, methyl acetate, methyl chloroform (1,1,1-trichloroethane),
methylene chloride, methyl formate, perchloroethylene (tetrachloroethylene), PCBTF
(parachlorobenzotrifluoride) t-butyl acetate;
• Chlorofluorocarbons (CFCs): CFC-11, CFC-12, CFC-113, CFC-114, CFC-115;
• Hydrochlorofluorocarbons (HCHCs): HCFC-22, HCFC-31, HCFC-123, HCFC-123a, HCFC-
124, HCFC-141b, HCFC-142b, HCFC-151a, HCFC-225ca, HCFC-225cb;
• Hydrofluorocarbons (HFCs): HFC-23, HFC-32, HFC-42-10mee, HFC-125, HFC-134, HFC-134a
HFC-143a, HFC-152a, HFC-161, HFC 227ea, HFC-236ea, HFC-236fa, HFC-245ca, HFC-
245ea, HFC-245eb, HFC-245fa, HFC-365mfc;
• Hydrofluorethers (HFEs): HFE-7000, HFE-7100, HFE-7200, HFE-7500;
• (CF3)2-CFCF2OCH3, (CF3)2-CFCF2OC2H5;
• Cyclic, branched, or linear completely methylated siloxanes;
• Any organic compound listed in 40 CFR 51.100(s)(1) or (s)(5); and
• Any class of perfluorocarbon compounds that consists of (a) cyclic, branched, or linear,
completely fluorinated alkanes, (b) cyclic, branched, or linear, completely fluorinated
ethers with no unsaturations, (c) cyclic, branched, or linear, completely fluorinated ter-
tiary amines with no unsaturations, or (d) sulfur-containing perfluorocarbons with no
unsaturations and with sulfur bonds only to carbon and fluorine.
These compounds have been determined to have negligible photochemical reactivity. For purposes of
determining compliance with emission limits, VOC will be measured by the approved test methods.
Where such a method also inadvertently measures compounds with negligible photochemical reactivity,
an owner or operator may exclude these negligibly reactive compounds when determining compliance
with an emission standard.
Water-based ink/coating/adhesive - an ink, coating or adhesive with a VOC content less than
or equal to ten per cent by weight as applied.
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
16Appendix B - Air Permit Exemption List
Common equipment and activities exempt from air permits per OAC 3745-31-03(A)(1)*
• Fossil fuel-fired boilers, preheaters, air heaters, water heaters, or heaters used for other heat
exchange media less than ten million British thermal units per hour burning only natural gas,
distillate oil (with less than or equal to 0.5 per cent by weight sulfur), or liquid petroleum gas.
• Fossil fuel or wood fuel-fired boilers, preheaters, air heaters, or water heaters less than one
million British thermal units per hour except units burning waste fuels or waste oil.
• Fossil fuel-fired furnaces or dryers less than ten million British thermal units per hour and
burning only natural gas, distillate oil (with less than or equal to 0.5 per cent by weight sulfur), or
liquid petroleum gas and the only emissions are from the products of combustion from fuel and
water vapor and where no melting or refining occurs nor where any burning of any material
occurs.
• Tumblers used for the cleaning or deburring of metal products without abrasive blasting.
• Equipment used exclusively for the packaging of lubricants or greases, and water-borne adhe-
sives, coatings or binders.
• Equipment used exclusively for the mixing and blending of materials at ambient temperature to
make water-borne adhesives, coatings or binders.
• Laboratory equipment and laboratory fume hoods used exclusively for chemical or physical analy-
ses and bench scale laboratory equipment.
• Photographic process equipment by which an image is reproduced upon material sensitized to
radiant energy.
• Equipment used for injection molding of resins where no more than one million pounds of resins
(thermoplastic or thermosetting) per rolling twelve-month period are used in injection machines
at the facility.
• Storage tanks for:
(i) Inorganic liquids including water (at standard temperature and pressure) except for tanks
storing acids as described in paragraph (vii); or
(ii) Pressurized storage for inorganic compounds or propane, butane, isobutane, and liquid
petroleum gases; or
(iii) Liquids with a capacity of less than seven hundred gallons; or
(iv) Organic liquids with a capacity of less than seventy-five cubic meters (19,815 gallons) and
equipped with submerged fill, except gasoline storage tanks located at bulk gasoline plants
which are subject to the requirements of paragraph (P) of rule 3745-21-09 of the Adminis-
trative Code; or
(v) Organic liquids with a capacity greater than or equal to seventy-five cubic meters (19,815
gallons) but less than one hundred fifty-one cubic meters (39,894 gallons) storing a liquid
with a maximum true vapor pressure, as defined in 40 CFR 60.111b, of less than 15.0
kilopascals (2.176 pounds per square inch absolute) and equipped with submerged fill; or
Permit-by-Rule User's Guide for Small and Midsize Printing Facilities
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