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Background

OFFJC~AL FILE COPY

SOUTHWEST REGIONAL OFFICE

Air Quality Permit File SOOP # 65-01027 Leedsworld, Inc. I Logo Printing Facility

Sheila A. Shaffer ~ Air Quality Engineering Specialist Bureau of Air Quality ~

Barbara R. Hatch, P .E. 9 Environmental Engineering Manager Bureau of Air Quality

December 17, 2014

Mar~~ Air Quality Manager Bureau of Air Quality

Review of State Only Operating Permit Initial Application Upper Burrell and Washington Township, Westmoreland County APS# 857305 ; AUTH# 1050091 ; PF# 761418

MEMO

On November 7, 2014, a State Only Operating Permit (SOOP) initial application was received by the Department for Leedsworld, Inc. I Logo Printing Facility for its printing facility located in Upper Burrell and Washington Township, Westmoreland County. Leedsworld has complied with the municipal notification requirements contained in 25 Pa. Code § 127. 413 and the application fee requirements contained in 25 Pa. Code § 127.703(b)(3). On November 25, 2014, the SOOP application was determined Administratively Complete. The facility is currently operating under Plan Approval 65-01027A that was authorized on July 9, 2014 and expires January 9, 2015. On December 9, 2014, the Department received a Plan Approval Extension Form to extend Plan Approval 65-01027 A to permit operation pending the issuances of a permit. Authorization of the plan approval extension was issued and the plan approval will now expire July 9, 2015 .

Leedsworld commenced operation in October 1998 without authorization from the Department. On February 14, 2013 , the Department sent Leedsworld a notice ofviolation (NOV) for construction and operation of an air contamination source without authorization from the Department. On August 6, 2013 , the Department received a plan approval application from Leedsworld. On September 16, 2013 , Leedsworld entered into a Consent Order and Agreement (CO&A) with the Department establishing the violations, corrective actions to be taken, civil penalty settlement, etc. On September 18, 2013, a Civil Penalty payment in the amount of$65,850.00 was received by the Department from Leedsworld. Under the CO&A, Leedsworld agreed to consumption restrictions, emissions tracking, and recordkeeping and monitoring requirements, limiting VOC and individual and cumulative HAP emissions below the major source thresholds

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that were conditioned into the issuance of Plan Approval 65-01027 A authorized on July 9, 2014.

This facility engages in the imprinting of promotional logos to a wide variety of finished goods including golfbag covers, tote bags, briefcases, plates, pens, etc. Types of printing include transfer printing, silkscreen printing, silkscreen bag printing, laser printing, color printing, and drinkware printing. The facility consists of approximately 200 individual printing processes, electric curing ovens, natural gas-fired emergency generator and various natural gas-fired building heat combustion sources.

On September 17, 2014, the Department determined that the replacement of 40-60 percent of the primary solvent, Chromaline 210, with Clean Air Press Wash CA-3 and/or Clean Air Press Wash CA-PW4 is exempt from the Plan Approval/Operating Permit requirements per 25 Pa. Code §127.14(c)(l). It' s the Department's understanding that the proposed solvents contain less than 5 percent VOC and no HAPs compared to 99 percent VOC in the Chromaline. As of August 2014, Leedsworld has been phasing out the use of Chromaline 210 with the above authorized solvents.

On August 19, 2014, the Department determined that the construction and operation of an additional warehousing and production building is exempt from plan approval requirements. The new building (Alvin Drive Building) is adjacent to the existing production and warehousing building (Hunt Valley Road Building). The construction of the Alvin Drive Building includes the relocation of existing process equipment with no change in operation or controls; does not involve VOC or HAP containing solvents and/or inks; and the facility wide emissions, including emissions from new combustion equipment, do not exceed the current limitation of 49.9 tpy VOC. The facility installed various natural gas-fired building heat combustion sources in the Alvin Drive Building that total a combined rated heat input of 6.8 MMBtulhr.

Sources, Control Devices and Emissions

Printing is conducted at approximately 200 individual work stations. Each work station includes process operating equipment including silkscreen frames, paper cutters, application presses, lasers, rubber stampers, and electric dryers for curing. Ancillary emission points include solvent dispensers and rag disposal containers. Solvent is stored in spring loaded containers to minimize evaporation. Emissions of regulated pollutants from the printing processes include fugitive VOC and HAPs from the inks and solvents used. The printing inks represent approximately 7-8% of printing process emissions while the cleanup/preparation solvents make up approximately 92-93%. The station operator dispenses solvent to a cloth rag to facilitate manual application and used rags are disposed of in a separate floor container for disposal. Each station operator moves throughout each work station potentially releasing emissions during solvent to rag dispensing, solvent application along the printing line, and solvent (used rag) disposal.

The primary source of emissions from this facility is VOC and HAPs emissions from evaporation of the inks and solvents used in the printing process. Depending on the

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product/design being printed, Leedsworld uses a number of different inks/solvents. Previously the primary solvent used and source of emissions was Chromaline 210. It accounted for approximately 60% ofthe facility-wide VOC emissions. However, since August 2014, Leedsworld has been phasing out the use of Chromaline 210 with either Clean Air Press Wash CA-3 and/or Clean Air Press Wash CA-PW4.

Emissions from the inks and solvents have been calculated by the applicant based upon the VOC/HAPs content from each product MSDS, total annual usage, and 100% liberation of air contaminants (VOC/HAPs). Emissions have been calculated to be representative of the expected worst case scenario. Emissions from all natural gas-fired building heat combustion sources (total of 13 .6 MMBtu/hr between both buildings) and fugitive paved road emissions are included in the potential emissions. The facility-wide potential emissions are: 5.96 tpy NOx, 5.01 tpy CO, 0.04 tpy SOx, 49.91 tpy VOC, 5.0 tpy cumulative HAPs, 4.42 tpy PM, 1.25 tpy PM10, 0.65 tpy PM2 5• The actual emissions for 2013 submitted in the Emission Inventory Production Report were: 0.095 tpy NOx, 0.080 tpy CO, 0.001 tpy SOx, 37.039 tpy VOC, 2.845 tpy HAPs, 0.315 tpy PM10, and 0.079 tpy PM2.s ·

Due to the nature of the operations at this facility, it is impractical to control emissions directly from each individual work station. Therefore it has been determined that the appropriate methods and techniques that will prevent and reduce emissions of air contaminants to the maximum degree possible. This includes the use of low VOC/HAP and low vapor pressure solvents, use of spring loaded dispensing containers to minimize evaporation, solvent usage tracking and recordkeeping, employee training, and continued examination of alternative low VOC products that can effectively perform the required results.

Regulatory Analysis

25 Pa. Code§ 129.52 Surface Coating Processes - does not apply to this facility. Per 25 Pa. Code § 121 .1, surface coating process is defined as "The application and solidification of a coating onto or into a substrate as the substrate proceeds through the equipment and activities of the manufacturing process." The operations at this facility do not meet the definition of a surface coating process.

25 Pa. Code § 129.67 - Graphic arts systems - does not apply to this facility. This section applies to facilities whose rotogravure and flexographic printing presses by themselves or in combination with a surface coating operation subject to § 129.52 (relating to surface coating process) have the potential to emit or have emitted VOCs in quantities greater than 1,000 lbs/day or 100 tpy during any calendar year since January 1, 1987. This facility does not include rotogravure or flexographic printing presses, and the PTE is not greater than the specified thresholds and has not exceeded the thresholds in the past, therefore this section does not apply.

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25 Pa. Code§ 129.77 - Control of emissions from the use or application of adhesives, sealants, primers and solvents does not apply since this facility does not engage in the application of adhesives, sealants, or primers to substrates.

New Source Performance Standards (NSPS) from 40 CFR 60 Subpart QQ­Standards of· Performance for the Graphic Arts Industry: Publication Rotogravure Printing does not apply to this facility. Per §60.431, Rotogravure printing unit means any device designed to print one color ink on one side of a continuous web or substrate using a gravure cylinder. This facility does not perform publication printing and does not operate a rotogravure printing unit; therefore this subpart does not apply

NSPS from 40 CFR 60 Subpart FFF-Standards of Performance for Flexible Vinyl and Urethane Coating and Printing does not apply to this facility. This facility does not operate a rotogravure printing line used to print or coat flexible vinyl or urethane products.

NSPS from 40 CFR 60 Subpart JJJJ-Standards of Performance for Stationary Spark Ignition (SI) Internal Combustion Engines (ICE) does not apply to the emergency generator engine at this facility. Per§ 60.4230(a)(4)(iv), the provisions of this subpart are applicable to owners and operators of stationary SI ICE that commence construction after June 12, 2006, where the stationary SI ICE are manufactured on or after January 1, 2009, for emergency engines with a maximum engine power greater than 19 KW (25 HP). The emergency engine at this facility commenced construction in 2005 and was manufactured in approximately 1990, therefore this subpart does not apply.

40 CFR Part 63 Subpart KK -National Emission Standards for the Printing and Publishing Industry does not apply. This subpart applies to each new and existing facility that is a major source of hazardous air pollutants (HAP), as defined in 40 CFR 63.2, at which publication rotogravure, product and packaging rotogravure, or wide-web flexographic printing presses are operated. This facility does not operate publication rotogravure, product and packaging rotogravure, or wide-web flexographic printing presses; therefore this subpart does not apply.

40 CFR Part 63 Subpart ZZZ~National Emission Standards for Stationary Reciprocating Internal Combustion Engines (RICE) applied to the 118 bhp emergency diesel engine at this facility prior to execution of the CO&A. Per §63.6595(a)(l), if you have an existing stationary CI RICE with a site rating ofless than or equal to 500 brake HP located at a major source of HAP emissions, you must comply with the applicable emission limitations, operating limitations, and other requirements no later than May 3, 2013 . Per §63.6612, you must conduct any initial compliance demonstration within 180 days after the compliance date (by November 3, 2013).

On September 16, 2013 , under execution of a CO&A, the facility became a synthetic minor source of HAP emissions, triggering different requirements under Subpart ZZZZ. Regardless of the applicable requirements prior to the CO&A, Leedsworld was not

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required to demonstrate initial compliance since it became a minor source prior to the applicable compliance date.

Per §63 .6645(a)(5), regarding initial notifications, this requirement does not apply if you own or operate an existing stationary emergency RICE; therefore Leedsworld was not required to submit an initial notification.

Upon execution ofthe CO&A on September 16, 2013, this subpart does not apply to the emergency generator engine at this facility. Per§ 63.6585(±)(2), "Existing commercial emergency stationary RICE located at an area source of HAP emissions that do not operate or are not contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in §63.6640(f)(2)(ii) and (iii) and that do not operate for the purpose specified in§ 63.6640(f)(4)(ii) are not subject to this subpart." The emergency engine at this facility has not historically operated nor is it contractually obligated to be available more than 15 hours per calendar year. The engine operates approximately 6 hours per year and is therefore not subject to this subpart. If the engine is operated more than 15 hours in a calendar year, additional requirements may be triggered.

40 CFR Part 98 Subparts A and C -Mandatory Greenhouse Gas Reporting establishes mandatory greenhouse gas (GHG) reporting requirements for owners and operators of certain facilities. The Department has been advised by EPA that GHG emission information cannot be requested under the authority of 40 CFR Part 98 at this time. GHG emissions reporting under the Mandatory Reporting Rule is not currently considered an applicable requirement under EPA regulations implementing Title V and therefore does not have to be included in an operating permit for minor or major sources. 40 CFR Part 98 and associated subparts may be applicable but this is to be determined by EPA.

In recent plan approvals, the Department has elected to require GHG emission reporting under 25 Pa. Code § 127 .12b where warranted on a case-by-case basis. In this case, since GHG PTE is well below the 25 ,000 tpy reporting threshold of Part 98, the Department has determined that requiring GHG emission reporting is not warranted at this time.

Compliance

The emissions from all sources and associated air pollution control equipment covered under this Operating Permit must not equal or exceed any of the following on a 12-month rolling basis: 50 tons VOC, 10 tons any individual hazardous air pollutant (HAP) and 25 tons total hazardous air pollutants (HAPs). Particulate matter emissions are not to exceed 0.04 gr/dscf. The opacity is limited to 20/60 percent based on 25 Pa Code§ 123.41. A facility-wide inspection during daylight hours for the presence of any visible stack emissions, fugitive emissions, and any potentially objectionable odors at the property line at a minimum of once each week while the sources are operating must be performed. Records of each inspection must be maintained in a log on-site. The following records must be maintained: purchase and use of all inks, solvents, alcohols, and any other

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product used containing VOC or HAP on a 12-month rolling basis; MSDS for each solvent and ink used; the percent by weight VOC and HAP content of each solvent and ink used; VOC and HAPs emissions of a 12-month rolling basis; natural gas used on a 12-month rolling basis; and hours of operation of the emergency generator engine. All solvent containers must be closed at all times unless filling, draining, or performing cleanup operations. Notification must be made to the Department if the emergency generator engine is operated greater than 15 hours per calendar year.

Leedsworld has requested the following conditions in the Plan Approval, 65-01027A, not to be incorporated into the SOOP:

1. Section C, Condition #015: "The owner/operator shall keep all solvent laden shop towels in a closed container when not being used (i.e. when a floor employee is not active in the vicinity of the work station)." Leedsworld argues this condition is intended for good housekeeping work practice standard and removal of this condition will not cause an increase in actual or potential emissions from the facility.

As required by other regulations, the Department requires certain work practice standards to minimize VOC emissions from cleaning materials, thus specified in 25 Pa. Code § 129.52a(i), "Store all VOC-containing cleaning materials and used shop towels in closed containers." However, Leedsworld is not considered an operator of a large appliance or metal furniture surface coating process. The volume of the solvent used and the equipment being cleaned (i.e. printing tips) are relatively small compared to a printing press like Creps. Furthermore, the solvent containers that are spring loaded with a plunger type applicator prevent the shop towels from being saturated in solvent and the container itself holds approximately \12-1 gallon. Furthermore, the used shop towels are described by the applicant as moist to mostly dry. Moreover, the proposed SOOP incorporates Condition #0 14 of Section C from Plan Approval 65-01027 A, "The owner/operator shall keep all solvent containers closed at all times unless filing, draining, or performing cleanup operations." Leedsworld is required to maintain records of all solvent purchased and used on a 12-month rolling basis and calculates I 00 percent liberation of air contaminants (VOC/HAPs). After discussion with Mark Gorog, NSR Section Chief, and Alex Sandy, Air Quality Review of Plan Approval65-01027A oftheir observations of the work stations, solvent usage, solvent containers, and used shop towels; the condition at hand will not be incorporated into the proposed SOOP.

2. Section C, Condition #016: "Consumption ofChromaline 210 shall not exceed 8,400 gallons in any consecutive 12-month period." Per the Request for Determination, authorized by the Department on September 17, 2014, Chromaline 210 how now been partially replaced by approved alternatives, largely eliminating the effectiveness of this separate limitation.

On August 1, 2013 , Leeds world proposed this limitation of Chromaline 21 0 to ensure that the major source threshold will not be exceeded. This limitation was included in the Consent Order and Agreement (CO&A) executed on September 16, 2013 and later incorporated into Plan Approval65-01027A authorized on July 9, 2014. However, as

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stated in Plan Approval 65-01027 A Section C. Condition #006, "The emissions from all sources and associated air pollution control equipment ... shall not equal or exceed any of the following on a 12-month rolling basis: 50 tons VOC, 10 tons any individual HAP, and 25 tons total HAPs." Although the emissions from Chromaline 210 are more than 50 percent of the facility-wide potential emissions, limiting the use of Chromaline 210 will not necessarily keep the facility in a 'compliance status. ' Moreover, the important limitations are the emission restrictions to maintain the Synthetic Minor status. Likewise, Leedsworld has already reduced the usage ofChromaline 210 with Clean Air Press Wash CA-3 and/or Clean Air Press Wash CA-PW4 (referenced on page 2 of this document). Furthermore, Leedsworld is required to maintain records of all solvent purchased and used and VOC and HAP emissions on a 12-month rolling basis; therefore the condition at hand will not be incorporated into the proposed SOOP.

Public Notice:

On December 13, 2014, the Notice oflntent to Issue was published in the PA Bulletin for a 30-day public comment. The proposed initial Operating Permit will be submitted to Leedsworld for review as well as the Department's Air Quality Specialist.

Recommendation:

On September 18, 2014, an initial operating permit inspection was performed by Mr. Alex Sandy, Air Quality Engineering Specialist. Mr. Sandy did not note any violations at the time of the inspection. It is my recommendation that the initial State Only Operating Permit for Leedsworld, Inc. I Logo Printing Facility, SOOP 65-01027, be issued with the proposed conditions/restrictions summarized above.

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