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
SCS Engineers is pleased to announce that Karen Luken has partnered with us as a Sustainable Materials Management Specialist. She will provide environmental consulting services to the firm’s Sustainable Materials Management clients and will be based in SCS’s Cincinnati, Ohio office.
Luken brings 25 years of professional experience helping communities, governments, and business leaders achieve their waste management goals. She specializes in the planning, design, and implementation of integrated waste management systems. Most recently, working as the Global Waste Director for the Clinton Foundation Climate Initiative, Luken provided the environmental, socio-political, and financial expertise to design national waste management strategies and establish public-private partnerships for waste systems typically requiring a $30 million capital expenditure.
Luken works with businesses and communities within the waste life cycle, including suppliers, producers, consumers, collectors, and facility operators. Her success springs from her ability to prove, and then leverage, the technical feasibility and economic viability of decreasing dependency on landfills by maximizing the use of waste as a resource to produce green products and generate renewable energy.
Luken’s accomplishments include:
“Karen is an internationally recognized expert in strategic waste management, implementing local, national, and international programs successfully,” said Michelle Leonard, an SCS Vice President and the current President of SWANA. “Her ability to deliver benefits to retailers, consumers, producers, and governments will provide value for our clients and encourage environmental solutions that will have a lasting impact.”
SCS Engineers to provide environmental services and technical support to help enhance LA County’s Department of Public Works sustainable materials management.
SCS will provide research and consultation services supporting the County’s waste reduction and recycling practices for businesses, multi-family residences, large venues, County facilities, other public agencies, and more in the Unincorporated County Area. SCS promotes reuse, recycling, and conservation programs, and, more importantly, emphasizes program sustainability by considering the entire life-cycle of products, processes, and systems.
SCS’s responsibilities will include assistance with organics management and micro-composter systems, County departmental recycling, creating resource management plans and waste-free events, developing an awards and recognition program, and outreach and education.
Today, society recycles more solid waste than ever before. SCS’s recycling and sustainability programs are grounded in models that leverage new technologies and approaches that make the County’s goals possible to achieve. Recycling and waste reduction are key elements in the County’s comprehensive solid waste management program. SCS professionals are providing the strategies and support that will help Public Works integrate its management of solid waste using recycling, reduction, and organics management as essential elements. Implementing this plan will help the County achieve its health and welfare goals and regulatory requirements, and manage the operational costs of waste disposal.
“Our extensive understanding and experience planning and implementing waste management and recycling programs will allow us to create a more environmentally friendly County of Los Angeles,” said Michelle Leonard, a vice president with SCS Engineers. “Diverting organic material, as well as recyclable items, from the landfills continues to move us closer to a Sustainable Waste Management Future.”
The unique nature of landfill decomposition and the demands of safety, environmental compliance, and energy recovery create a dynamic environment under which Landfill Gas (LFG) management systems perform. These conditions place long term stresses on system components and increasingly challenge the ability of operators to effectively and efficiently manage the collection and control of LFG in a cost effective manner.
This case study concerns an aging LFG system located in northern Virginia nicknamed the I-95 Landfill. Operation and maintenance had become onerous and expensive as the system aged. Plans to evaluate, redesign, and rebuild the system with the intention to simplify operation and optimize performance while reducing lifecycle operation and maintenance costs were implemented. This paper presents the site history of the I-95 Landfill along with the approach from system evaluation findings, the design recommendations, construction, and the lessons learned.
Survivability of leachate collection pipes depends upon the gravel placed on all sides of the pipe. Proper placement of gravel around the pipe and the granular soil material over the completed pipe/gravel/geotextile burrito is of significant importance in the protection of the leachate collection pipe.
Read the article by Dr. Ali Khatami here.
SCS Advice from the Field is a collection of blogs, articles, and white papers written by SCS professionals like Dr. Khatami. Search “advice from the field” to browse all of the topics.
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.
Construction and Demolition Recycling Inc. is a California state certified C&D recycling facility which handles debris from the renovation, construction, and demolition of commercial interior spaces. CDR is the only facility in California that accepts only commercial interior debris, and the only facility in the country that can show a better than 80% diversion rate of these materials traditionally buried in landfills.
CDR’s staff also salvages usable items such as furniture, desks, chairs, file cabinets, and more, for reuse, donating more than 50 tons of these materials every month to not-for-profit agencies and other organizations. All of this allows CDR to divert over 80% of all inbound debris from landfills, a diversion rate that has been third party-verified by the Recycling Certification Institute.
The CDR facility in South Gate, California is a fully permitted C&D/inert debris processing and transfer facility. The facility is owned and operated by Interior Removal Specialist, Inc. (IRS), a demolition company that conducts demolition activities primarily of the interior of offices and other commercial buildings. Construction and Demolition Recycling Incorporated’s goal is to lead by example; showing that the diversion of tenant improvement demolition debris can be accomplished as efficiently and cost effectively as the debris from more traditionally recognized demolition debris. CDR has become the first and so far only recycling facility in Southern California that has earned Third Party Diversion Certification from The Recycling Certification Institute, making CDR the only facility in Southern California that is eligible to provide the US Green Building Council LEED Pilot Point for facilities with 3rd party verification.
Read the full article to learn some of the innovative strategies of this successful recycling company in “Construction and Demolition Debris Recycling Program; How CDR was Conceived and How CDR Remains Sustainable.”
Solid Waste Management, Sustainability, and Recycling Programs
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:
