Read the NSPS – EG Technical Bulletin
Article by Cheryl Moran, CHMM
Technological advances in traditional printing and the advent of digital printing can make it more challenging to know when you need an air permit and which permit is best for your operations.
There are two main activities that may trigger air permitting – construction and operation; each of these comes with its own permitting requirements. Always check to see if you are required to apply for a construction permit before bringing new equipment on site. Once a source is installed, an operating permit will be necessary, which is the focus of this article.
Federal Title V operating permits (also referred to as Part 70 permits) are required for any facility that is considered a “major source” of air pollution. For purposes of operating permits only[1], a major source is a facility that has the potential to emit (PTE) more than 100 tons per year (tpy) of any criteria pollutant; volatile organic compounds (VOC), carbon monoxide (CO), nitrogen oxides (NOx), sulfur dioxide (SO2), particulate matter less than 10 microns (PM10), or more than 10 tons of any individual hazardous air pollutant (HAP) or more than 25 tpy of combined HAPs . Permitting thresholds are lower for facilities located in non-attainment areas.
Some facilities take limits on material throughputs, hours of operation, or emissions in order to artificially lower their PTE to qualify for a Federally Enforceable State Operating Permit (FESOP). These permits are also called “synthetic minor” permits.
Facilities that do not exceed federal permitting thresholds may still need to acquire a state operating permit. State permitting programs have more options than ever before and several states are summarized below.
ILLINOIS:
All “emission units” are required to secure an air permit, or register with the Illinois EPA, even very small sources of air pollution. An “emission unit” is any piece of equipment located at an emission source that has a potential to emit air pollution. Registration of Smaller Sources (ROSS) is for operations that emit less than 5 tpy of combined criteria pollutants. Sources with a potential to emit more than 5 tpy, but whose emissions are less than the threshold for a FESOP, may qualify for a “life-time” operating permit.
Visit for more information on the Illinois EPA permitting program.
WISCONSIN:
ROP Type A Registration Permit is for facilities with actual emissions of less than 25 tpy for criteria pollutants and 6.25 tons per year for HAPs.
ROP Type B Registration Permit is for facilities with actual emissions of less than 50 tpy for criteria pollutants and 12.5 tpy for HAPs.
ROP C Registration Permit for Printers is only available to printers. To qualify for this permit, emissions of each criteria pollutant are limited to 25 tons per year, and HAPs are limited to 12.5 tons per year.
General Operation Permit (GOP) for Printers applies to digital, screen, lithographic web printing (both heatset and coldset), and lithographic sheetfed printing.
INDIANA:
Source Specific Operating Agreement for Surface Coating or Graphic Arts Operations is available to printers with total VOC and HAPs that do not exceed 15 lb/day (7 lb/day in select counties).
Permit by Rule may be used for facilities that qualify for an operating agreement with criteria pollutant and HAP emissions that do not exceed 20% of the major source limits.
Find more on the Indiana permit options at http://www.in.gov/idem/airquality.
Whether you are applying for a state operating permit, or a federal operating permit, all applications will go through your state environmental regulatory agency.
[1] For construction permitting purposes, the thresholds that define a “major source” are typically higher than the operating permit thresholds.
For more information contact Cheryl Moran at SCS Engineers, Wisconsin or Ann O’Brien at SCS Engineers, Illinois, or for an SCS professional in your state.
Cheryl Moran is a Project Manager with SCS Engineers with more than 20 years of experience in the printing industry. She is a Certified Hazardous Materials Manager (CHMM) and has worked with air, water, and waste issues including permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, environmental compliance audits, and sustainability programs.
Ann O’Brien is a Project Manager with SCS Engineers. During her 32-year career in the printing industry she was responsible for environmental compliance programs, including, but not limited to, air and water quality permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, environmental compliance audits, and environmental site assessments and due diligence associated with real estate transactions and corporate acquisitions.
Author: Ann O’Brien
Alert: Toxic Release Inventory Form A and Form R Reports were due July 1, 2016
The Toxics Release Inventory (TRI) was created by EPA in response to several events that raised public concern about local preparedness for chemical emergencies and the availability of information on hazardous substances.
Printing is one of the industry sectors required to annually report releases of certain chemicals. A printing facility with 10 or more full-time equivalent employees is required to report if the facility exceeds established chemical thresholds. Note that TRI reporting is not based on the amount of emissions to atmosphere or how much waste is generated. Instead, a company that manufactures or processes more than 25,000 pounds or otherwise uses more than 10,000 pounds of a TRI-listed chemical were required to report releases of these chemicals by July 1, 2016.
There are currently over 650 chemicals covered by the TRI program including chemicals commonly used by printers, such as toluene, xylene, ethylbenzene, 1,2,4-trimethylbenzene, glycol ethers, solvents, and metals. Of particular interest to lithographic printers is the wide use of glycol ethers in fountain solutions and more recently in cleaning solutions, to take the place of solvents with high vapor pressures. It is important to mention that “glycol ethers” is a chemical category and within this category there are hundreds of individual chemicals that are reportable. Safety Data Sheets (SDS) do not indicate the presence of “glycol ethers” as a constituent of a raw material so a printer must look up each listed constituent and compare it to the list of TRI chemicals to determine whether is it reportable.
For more information, contact Ann O’Brien () or Cheryl Moran () at SCS Engineers.
Ann O’Brien is a Project Manager with SCS Engineers. During her 32-year career in the printing industry she was responsible for environmental compliance programs, including, but not limited to, air and water quality permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, environmental compliance audits, and environmental site assessments and due diligence associated with real estate transactions and corporate acquisitions.
Cheryl Moran is a Project Manager with SCS Engineers with more than 20 years of experience in the printing industry. She is a Certified Hazardous Materials Manager (CHMM) and has worked with air, water, and waste issues including permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, environmental compliance audits, and sustainability programs.
SCS periodically prepares technical bulletins to highlight items of interest to our clients and friends. These are published on our website. This SCS Technical Bulletin addresses:
Read and share the SCS Technical Bulletin here.
SCS Coal Combustion Residual Services
Do you have NSPS or EG sites per the new definitions of “new” and “existing”?
Does your EG site have any upcoming planned or permitted expansions, or will it be commencing construction on an expansion permitted after July 17, 2014?
Will you need to submit/resubmit Design Capacity and NMOC reports to establish your sites status as subject to the new NSPS? Over, or under 34 Mg/year of NMOCs?
Are you a candidate for Tier 4? In the closed landfill subcategory?
For EG sites contact the SCS state representative by sending a request to
SCS Engineers will be publishing Pat Sullivan’s Technical Bulletin Summary of Final NSPS/EG Rules for Landfills as soon as it is published in the federal register. Meanwhile, please contact your SCS Project Manager or for answers to your questions or advice. Follow SCS Engineers on your favorite social media site or check our events for new presentations, publications, and webinars explaining the rules in more detail.
On July 11, 2016, multiple organizations representing the full value chain of cellulosic waste feedstock conversion to transportation fuel sent a letter to Gina McCarthy, Administrator of the U.S. Environmental Protection Agency (EPA). The letter supporting the Renewable Fuel Standard Program: Standards for 2017 and Biomass-Based Diesel Volume for 2018 (Proposed Rule) noted that additional information and factors need to be considered.
Read or share a copy of the letter here, contact SCS Engineers, or one of the organizations below:
Tracie Onstad Bills, Northern California Director, Sustainable Materials Management at SCS Engineers
Thank you for the responses and questions about my blog Minimizing Contamination in Recycling. It seems appropriate to provide answers to the most frequently asked questions and send more advice. Any program should be tailored to your current collection system; what works and what doesn’t work for your locality; the demographics of your community; and how your community views recycling.
In light of those considerations, here are some recommendations for ways to minimize contamination in recyclables:
Learn more about recycling programs by reading Success In Selective Routing – Resource Recycling or the SCS project and case studies below:
As always, feel free to send me your questions and comments. Contact Tracie here.
SCS Engineers’ Tracie Onstad Bills and Leslie Lukacs were both selected to receive the California Resource Recovery Association’s (CRRA) prestigious Service Award this year. According to CRRA Executive Director, John H. Dane, the award recognizes “exceptional individual service to the organization and a contribution of time or resources beyond expectations.” That sounds like an SCSer alright.
Tracie Bills is SCS’s Sustainable Materials Management Director and is based in our Pleasanton, CA, location. She has been on the CRRA board for 10 years and has served in several leadership positions within the organization, including as its President for three years. Her expertise revolves around commercial recycling technical assistance, environmental purchasing, large venue and event zero waste programs, research and sustainability planning, garbage hauler franchise compliance and review, construction and demolition program / ordinance analysis and writing, climate inventory compilation, research and feasibility studies to help clients with comprehensive waste prevention and zero waste programs.
Leslie Lukacs serves as a Sustainable Materials Management Specialist in our Santa Rosa, CA, office. She has been on the CRRA board for 12 years and also served in a variety of leadership positions. She also founded CRRA’s Green Initiatives for Venues and Events technical council and was an instructor for CRRA’s Resource Management Certification Program for 5 years. Leslie specializes in the design and implementation of sustainable materials management and zero waste programs and is a pioneer in the greening of venues and events throughout the nation. Her extensive expertise in the logistics of zero waste, recycling, and composting programs, such as outreach management, business assistance, master planning, waste audits and characterization studies, extended producer responsibility ordinance preparation and implementation, compliance, grant writing, and administration are all key to successful long-term programs.
Both women were selected by the CRRA Board of Directors to be the 2016 recipients of the Service Award. The awards will be presented at the organization’s Annual Conference Awards Ceremony on August 9 in Sacramento.
CRRA is California’s statewide recycling association. It is the oldest and one of the largest non-profit recycling organizations in the U.S. CRRA is dedicated to achieving environmental sustainability in and beyond the state through Zero Waste strategies including product stewardship, waste prevention, reuse, recycling and composting. The organization provides its members with resources to advance local, regional and statewide waste reduction efforts which result in critical environmental and climate protection outcomes. Members represent all aspects of California’s reduce-reuse-recycle-compost economy and work for cities, counties, municipal districts, and businesses as well as hauling companies, material processors, non-profit organizations, state agencies, and allied professionals.
SCS Engineers has published two Technical Bulletins summarizing the O&G NSPS final rule and outlining the new LDAR requirements. The two Bulletins explain the modification of how oil and gas sources will be permitted under the Clean Air Act and the new requirements to reduce methane leaks from new oil and gas facilities consistent with the EPA’s New Source Performance Standards.
Reference the U.S. Environmental Protection Agency (EPA) new source performance standards for Crude Oil and Natural Gas Production, Transmission and Distribution (O&G NSPS), which includes amendments to 40 CFR Part 60, Subpart OOOO and a new Subpart OOOOa. Subpart OOOOa will apply to facilities constructed, modified or reconstructed after September 18, 2015.
Click to read or share the Technical Bulletins:
https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry
Pat Sullivan, REPA, CPP, BCES
(916) 361-1297
Question: I have a small oxidation event at my landfill and am continually testing for carbon monoxide (CO) in the surrounding landfill gas (LFG) extraction wells. Using colorimetric tubes, I am monitoring the readings which range from 5-10 parts per million (ppm). Is there an accepted standard for background carbon monoxide in LFG? Moreover, how much inaccuracy is expected using the colorimetric tube testing?
Answer: Carbon monoxide (CO) can be found in small quantities even when there is no landfill fire. If your concern is landfill fire, most reputable resources state that a landfill fire generates readings of at least 100 ppm CO and more typically in the 500-1000 ppm range with 1000 ppm a reliable indicator that a landfill fire event may be present.
CO readings on colorimetric tubes are inherently less accurate and tend to run higher than laboratory results. Colorimetric tubes do provide value as a real-time indicator versus subsequent lab results, and can be used as an index reading, calibrated by lab results later. If you’ve had a landfill fire event before, with CO levels greater than 100 ppm, the lab confirmed 5-10 ppm CO could be residual left over from the earlier event.
Although some people believe that the presence of CO at almost any level is an indicator of landfill fire, recent laboratory tests show that CO can be generated at values up to and over 1000 ppm by elevating refuse temperatures without the presence of combustion (fire). Other tests have shown that high values of CO are found in some landfills with no current landfill fire and no indication of a past landfill fire. This information supports that it is possible that Elevated Temperature (ET) Landfills can have CO levels over 1000 ppm CO without the presence of combustion or landfill fire.
In the end, CO can be an indicator of landfill fire, but not always, as described here. Low methane, high carbon dioxide, and even landfill temperatures above 131 degrees F may or may not be indicators of past or current landfill fire. Physical indicators of a landfill fire may include rapid settlement in a localized area, cracks and fissures, smoke and flame, melted landfill gas system components, and char on the inside of LFG headers and blower/flare station components such as a flame arrester. However, most of these indicators can occur at ET landfills as well without the presence of fire or combustion.
A professional landfill gas engineer is needed to assess these conditions as a whole, and make a judgment on the underlying driver, condition, and resolution.
Have a question for our SCS Professional Engineers or Field Staff? Just ask here.
Landfill and Landfill Gas Services at SCS Engineers.
Corporate Headquarters
3900 Kilroy Airport Way Suite 300
Long Beach, CA 90806
Telephone
1 (800) 767-4727
1 (562) 427-0805 | FAX
Contact Us
