Table of Contents. Photo Marketing Association International, Digital Imaging: Air Permitting and the Clean Air Act

Transcription

1 Air quality regulations are complex and vary across the United States. There are three important pieces of information to consider when determining how digital inkjet printing is affected by clean air regulations: Which chemicals are emitted from your processes? How much of each chemical is released? How is your region of the country designated in terms of air pollution levels? The answers to these questions will determine the air quality rules affecting your business. This document provides a general overview of clean air regulations and how they apply to facilities that use digital inkjet printing to produce photographs. Specifically, this document describes air pollutants and associated air regulations; specific techniques for estimating your emissions; how to determine the air quality status of your geographic area; and the process of working with regulatory agencies to obtain the proper permits or exemptions. Please refer to the glossary for an explanation of terms and acronyms used in this document. Additionally, as shown in the following shaded area, the documents mentioned throughout this bulletin are available from Photo Marketing Association International (PMAI) at environmental@pmai.org. Clean Air Laws and Rules The Clean Air Act (CAA) and its amendments form the foundation of air quality laws in the United States. In its initial form, the act established National Ambient Air Quality Standards (NAAQS), air pollution control regions for monitoring, and common requirements for state-managed air quality programs. Since 1963, the original CAA has been amended several times. The most recent and far-reaching amendments to the CAA were enacted in 1990, when Congress introduced a list of hazardous air pollutants (HAPs) and prescribed a schedule for developing control standards for industrial categories that emit HAPs. In addition, the 1990 amendments enacted the Title V permitting program and other programs to manage acid rain and ozone-depleting compounds. A significant portion of the CAA contains requirements for state legislatures to amend their laws, providing the legal framework necessary to develop and enforce air pollution regulatory programs. The CAA and the general Photo Marketing Association International (PMAI) 3000 Picture Place, Jackson, MI Phone: (517) , Fax: (517) Home page: environmental@pmai.org The following documents are available from Photo Marketing Association International at environmental@pmai.org: Air quality rules and regulations on the Internet Forms for estimating your emissions Internet links for air permitting information List of non-attainment areas for ozone and the extent of non-attainment List of hazardous air pollutants (HAPs) State air quality websites statutes enacted by state legislatures represent the laws governing air pollution in the United States. You can access the federal Code of Federal Regulations (CFR) and state administrative rules on the Internet. (A list of Internet sites for air quality rules and regulations is available from environmental@pmai.org.) CAA-Regulated Compounds The original Clean Air Act established primary (protection of humans) and secondary (protection of plants and animals) standards for the ambient concentrations of six pollutants, also known as criteria air pollutants: ozone, nitrogen oxides, sulfur oxide, carbon monoxide, particulate matter smaller than 10 microns in diameter, and lead. These standards, or NAAQS, represent unhealthy concentrations of each compound in the air we breathe. Most urban areas are required to monitor the Table of Contents Clean Air Laws and Rules CAA-Regulated Compounds Estimating Your Emissions Regulations for Digital Inkjet Printing Finding the Rules and Regulations Working With Regulators On-Site Documentation Requirements Conclusion Case Studies Glossary Photo Marketing Association International, Digital Imaging: Air Permitting and the Clean Air Act

2 concentrations of these pollutants in their regions. Ozone, the most prevalent of these pollutants, is not emitted directly into the air, but is formed at higher temperatures, and in the presence of sunlight, through complex chemical reactions between volatile organic compounds (VOCs*) and oxides of nitrogen (NOx). Therefore, VOCs are regulated because they are a precursor of ozone, and must be present in order to form ground-level ozone. The air quality status of a region is determined from the number of days that the air contains an excess of the criteria air pollutants. On a hot summer day with several hours of sunshine in the forecast, air quality agencies will ask people to minimize activities that contribute to ozone formation. These days are referred to as ozone action days. An area is allowed only a few days in excess of the ozone NAAQS before it is classified as non-attainment. In areas of non-attainment, air quality rules are more stringent and apply to a greater number of small facilities. While the NAAQS specify unhealthy concentrations of criteria air pollutants, many other chemical compounds are considered hazardous but do not have ambient concentration limits. In 1990, the Environmental Protection Agency (EPA) created the list of HAPs - substances that present tangible health hazards to humans and other mammals. The regulatory threshold for HAP emissions is 10 tons per year for any single HAP or 25 tons per year for any combination of HAPs (indicated as 10/25 tons HAPs). Emissions from the digital inkjet printing industry are characterized as VOCs and HAPs. VOC emissions are the primary triggering mechanism for regulatory requirements in the industry. Estimating Your Emissions The only way to determine which air quality regulations affect your digital inkjet printing operations is to quantify the emissions of all VOCs and HAPs at your facility. As we discuss how to estimate your emissions, follow along on the flowchart shown on the next page. There are three types of emissions estimates: 1. If your facility is located in an attainment area, perform a rough calculation for VOCs and HAPs. (The non-attainment area list is available from environmental@pmai.org.) 2. If your facility is located in a non-attainment area, calculate your facility s potential to emit for both VOCs and HAPs. Potential to emit refers to the highest amounts of VOCs and HAPs that your business could release into the air (even if you have never actually emitted the highest amount). The facility-wide estimate is based on physical and operational designs, including equipment design. Potential to emit estimates are used to determine which (if any) regulations apply to the facility. 3. If your facility is located in a non-attainment area, calculate your facility s actual emissions for both VOCs and HAPs. Actual emissions refer to the actual rather than potential amount of VOCs and HAPs that are released, given a facility s days/ hours of operation, type/size of substrate used, and other characteristics specific to the operation. In the following sections of this bulletin, we discuss each of these three types of estimating your emissions. Blank copies of the forms shown in the following examples are available from environmental@pmai.org. Rough Emissions Estimating If your operation is located in an attainment area, perform a quick calculation to estimate the upper bound of your VOC emissions. Use the following procedure, and chart your information, as shown in Chart 1. When it comes to estimating emissions, we recommend the following activities: Perform the calculations before you purchase inkjet equipment. Even if your VOC and HAP emissions are minimal, perform the calculations and keep them on file to demonstrate that you know what your emissions are. Recalculate your VOC and HAP emissions any time you re considering adding new equipment or making a change in your chemical or ink system. After calculating your VOC and HAP emissions, and before purchasing and taking possession of an inkjet printer, contact your local air permitting officials. If they require a permit, it could take up to 90 days to receive, during which time you will not be allowed to operate the printer. * VOCs are carbon-containing gases and vapors that come from incomplete gasoline combustion and from the evaporation of liquid solvent, such as those used in digital printing inks and printhead cleaners. Chart 1 Rough Calculation for Estimating VOCs + Name of solventcontaining products Amount used annually (in gallons) Inkjet ink (all colors) 550 4,587 Printhead cleaner 130 1,084 Liquid laminate 377 3,144 Totals 257 8,815 + Calculations assume a typical water-based ink. VOCs in lbs. (gallons x 8.34) List all solvent-containing products used in your facility, regardless of their solvent content (e.g., inks, cleaners, liquid laminates). Include information for any inkjet printer(s) you are planning to purchase within the next year. Photo Marketing Association International, Digital Imaging: Air Permitting and the Clean Air Act

3 For each material on the list, refer to your purchasing records to determine the total amount of the product used per year. Keep in mind that even water-based inks contain some solvent. Multiply the total volume, in gallons, of all solvent-containing products you consume in one year by 8.34 (the density of water). Most solvents are less dense than water so this serves as a quick upper bound on your annual emissions estimate of VOCs. Finally, total all the VOCs. In our example (Chart 1), the total VOCs are 8,815 lbs. Chart 2 Section 2 Composition/Information on Ingredients Ingredient Weight by % CAS registry no. Diethylene glycol 10-30% Ethylene glycol 7-25% Pyrrolidinone 5-15% Magenta pigment proprietary Flowchart Deionized water 40-95% Acrylic polymer proprietary MSDS information for each ingredient in a product includes its name, weight by % of the total product and its Chemical Abstract Service (CAS) number. While ingredients can be called by many different names (e.g., isopropanol, isopropyl alcohol), the CAS number is always the same. Therefore, as you review each MSDS, rather than comparing ingredient names, compare the CAS numbers to those CAS numbers on the list of HAPs (the list is available from environmental@pmai.org). (If your state operates an air toxics program, check with the state air quality agency to determine if it regulates other hazardous air pollutants in addition to those listed by the EPA.) For each HAP listed on each MSDS, use the following four-step procedure to create a chart similar to the one shown in Chart 3 (on page 4): 1. Record the name, CAS number and maximum weight by % for each HAP listed on the MSDSs. Note: Not all ingredients listed may be HAPs. 2. As determined by your purchasing records, list the amount, in gallons, of the product used annually (not the individual ingredient). 3. Multiply the maximum weight by % by the total amount of the material used annually to find the annual gallons used per single HAP. 4. Finally, multiply the total volume, in gallons, of each HAP by 8.34 (the density of water). Next, you need to estimate your emissions of HAPs. This procedure requires you to review the ingredients listed on the material safety data sheet (MSDS) for each solvent-containing chemical in your facility. Typically, ingredient information is shown in Section 2 of the MSDS s Composition/Information on Ingredients (as shown in Chart 2). Notice that some nonhazardous ingredients may also be listed on the MSDS (e.g., pigment, water). Chart 3 shows the rough HAP estimation for just one ink. In this example, the annual HAP usage was 125 lbs. of diethylene glycol, 104 lbs. of ethylene glycol, and 229 lbs. total HAPs all far below the 10/25 ton HAP threshold (10 tons per year for any single HAP or 25 tons per year for any combination of HAPs). Typically, you won t need to pay too close attention to the HAP content in your liquid consumables until your VOC emissions exceed 10 tons per year. If these rough estimates show that your facility s VOC emissions are less than 5 tons (10,000 lbs.), and your HAP emissions are less than 10/25 tons, you re ready to contact your local air quality agency to check whether your facility is subject to air permitting requirements. With emissions at these levels, Photo Marketing Association International, Digital Imaging: Air Permitting and the Clean Air Act

4 Chart 3 Using an MSDS to Estimate HAPs Name of HAP CAS number Weight by % (max.) Annual use of material (in gallons) Annual HAPs use (in gallons) HAPs in lbs. (weight by % x 8.34) Diethylene glycol % Ethylene glycol % Total HAPs 229 you may find that conducting the calculations and maintaining the results on file are your only obligations. If your estimates are higher than these levels, perform the potential to emit calculations (shown next) before you contact your local air quality regulator. Keep these calculations on file and remember to redo the estimates any time you introduce new equipment or make a change in your chemical or ink system. Estimating Potential to Emit If the estimates you completed on the previous page are greater than 5 tons VOC, 10/25 tons HAPs, OR if you are located in an area designated as non-attainment for ozone (VOCs are precursors to ozone formation), you will need to calculate your facility s potential to emit. Additionally, regulatory agencies will often ask a facility to estimate emissions from equipment they are planning to purchase. Most permit programs also require a new or modified air permit before you begin operating new equipment. (Note: The examples assume the use of water-based ink. Numbers for solvent-based ink will be significantly higher.) VOC Potential to Emit - The following example presents a fairly simple method for calculating the annual potential to emit for VOCs from a single inkjet printer. To perform these calculations, you will need the following information, available from the manufacturer: MSDSs for the ink (review all ink colors and choose the one with the highest VOC content, as shown on the MSDS or as provided by the manufacturer). Ink consumption (usually in milliliters per meter 2 ). Equipment operating speed. Potential hours of operation (i.e., 24 hrs./day x 365 days/year = 8,760 hours). The following scenario was used to create Chart 4 (example of potential to emit from a single inkjet printer using a water-based Chart 4 ink). A manufacturer claims that ink consumption is very low for this printer: 7.98 ml/m 2 at 720 dpi. The printer is capable of printing 3.6 m 2 /hr. at this resolution. Multiplying 7.98 x 3.6 gives us an ink consumption of 28.7 ml/hr. If you ran this printer continuously for a year, or 8,760 hrs., you would consume 251 liters of ink (28.7 x 8,760 /1,000), roughly 66 gallons per year (3.79 liters/gallon). If you were running ink that contained 5 lbs./gallon VOCs (as disclosed on the MSDS or by the manufacturer), this inkjet printer would emit 330 pounds of VOCs per year (66 gallons x 5). This number represents the single inkjet printer s annual potential to emit. The hourly potential to emit would be lb. (330/8,760 hrs.). (Note: Expect VOC emissions from solvent-based inkjet ink to be significantly higher.) Ink consumption will vary significantly between printers and between substrates and applications. It is usually sufficient to identify the worst-case product for estimating emissions. If a printer can run multiple inks, examine the MSDS for each ink or coating and select the one with the highest VOC content. Next, assume the highest ink-consuming setting for that printer. Using the above procedure with the specific values for your printer, you can calculate the potential to emit for this process. Add all of the worst-case emissions from all of your processes to estimate your entire facility s potential to emit for VOCs. HAPs Potential to Emit - To calculate your HAPs potential to emit from an inkjet printer, you ll need some additional information: The potential ink consumption, in gallons (see Chart 4). The precise weight of the HAP, rather than using the weight of water (8.34). (Note: This weight can be found by asking the chemical manufacturer or by conducting an Internet search on the CAS number of the specific HAP (e.g., diethylene glycol is CAS number ). Look for an MSDS for the HAP to determine its weight in lbs./gal.) For each inkjet ink containing HAPs, use the following procedure, as detailed in Chart 5: Record the name, CAS number and maximum weight by % for each HAP listed on the inkjet ink MSDSs. Potential to Emit From an Inkjet Printer Ink consumption Printer speed Ink consumption (per hour) Potential ink consumption (1,000 ml = 1 L) Potential ink consumption (3.79 L = 1 gal.) VOC content of ink (as per manufacturer) Potential VOC/year (in lbs.) 7.98 ml/m m 2 /hr ml/hr. 251 liters 66 gallons 5 lbs./gallon 330 lbs. Photo Marketing Association International, Digital Imaging: Air Permitting and the Clean Air Act

5 Chart 5 Estimating HAPs Potential to Emit Name of HAP CAS number Weight by % (max.) Potential material use (in gal.) Potential HAP use (in gal.) Weight of HAP in lbs./gal. HAPs in lbs. (weight of HAP x potential use, in gal.) Diethylene glycol % Ethylene glycol % Total HAPs 337 Record the potential ink consumption, as estimated in Chart 4 (e.g., 66 gallons). Multiply the maximum weight by % by the potential ink consumption to find the potential HAP use (in gallons) for each HAP (e.g.,.30 x 66 = 19.8). Record the weight of each HAP, as disclosed by the manufacturer or as found via the Internet (e.g., diethylene glycol is 9.31). Multiply the total potential volume, in gallons, of each HAP by the weight of each HAP (e.g., 19.8 x 9.31 = 184). Total all HAPs. In the example shown in Chart 5, the ink contains two HAPs: the potential to emit for diethylene glycol is 184 lbs. annually and for ethylene glycol is 153 lbs. annually. Total HAPs are 337 lbs. All totals are less than the 10/25 ton HAPs threshold. You have now calculated your facility s potential to emit for both VOCs and HAPs. Before calling your local air quality agency, you should estimate your actual emissions. Estimating Actual Emissions Actual emissions are generally used to estimate compliance with applicable emission standards or permit limits. To perform these estimates, simply change the following variables in your potential to emit calculations to reflect actual operation conditions at your facility: Ink consumption - becomes your average ink consumption in ml/m 2 (of substrate). Printer speed - becomes the speed at which you typically run the printer. Hours/year in operation - become the number of hours per year the printer is in actual operation. After estimating the emissions for every inkjet printer in your facility, as well as any other process that uses solvent-containing materials, you are ready to contact your local air quality agency to determine your regulatory obligations. Regulations for Digital Inkjet Printing CAA regulations that potentially affect the digital inkjet printing industry include the following: Permit exemptions Permit requirements Restrictions on ink formulations Daily limits on VOC emissions Annual limits on potential to emit As we learned, the most important factors in the regulatory process are potential to emit and the regional non-attainment status of the facility. Those facilities designated as a major source are most heavily regulated. Refer to Major Sources on the following page for a discussion of major sources and their regulatory requirements. Finding the Rules and Regulations To find the rules and regulations that might affect your operations, refer to the list of Internet resources available from environmental@pmai.org. Check first to see if your area has a local air quality program. Where there isn t one, refer to the state government site, and look for departments of environmental quality, protection, or resources. Always review the exemptions to determine if your operation is exempt from permitting and other rules and regulations. Working With Regulators We recommend that you contact a local permitting official before you purchase and begin operating new inkjet printing equipment. If you are required to get an air permit, it will generally take 90 days, during which time you may not be allowed to install or operate your new equipment. If your facility operates in violation of air permitting regulations, you may be subject to fines. Begin with a phone call to the air permits section or branch of your local air quality management program. You will need your estimated potential emissions from your existing facility and the potential emission from your proposed additional equipment. Photo Marketing Association International, Digital Imaging: Air Permitting and the Clean Air Act

6 Major Sources A major source is a very specific designation used to describe a business, based on its emissions of criteria air pollutants and HAPs, and whether it is located in a non-attainment area. As it applies to digital inkjet printing, a major source is generally defined in terms of VOCs and HAPs, as described in the boxes below: HAPs - A major source is a business that has a potential to emit at least 10 tons per year of any one of the air toxics listed as HAPs or at least 25 tons per year of total HAPs. Some states designate other substances as air toxics in addition to those listed by the EPA. VOCs - A major source is a business that has a potential to emit more than 100 tons per year of VOCs if it is located in an attainment area, to as low as 10 tons per year of VOCs if it is located in a non-attainment area. Requirements for Major Sources The following requirements may apply to major sources, depending upon the attainment status of your area: Obtain a Title V permit, which may include limits on emissions, and monitoring and reporting requirements. Comply with New Source Review (NSR) requirements, which may mean obtaining a Title V permit, installing pollution abatement equipment to achieve the lowest achievable emission rates (LAER) or installing best available control technology (BACT), depending upon the attainment status of your county. NSR permitting in attainment areas is also known as prevention of significant deterioration, or PSD. Note: Sources with potential emissions that render them major sources, but which never utilize their equipment for 8,760 hours/year, can apply for special permit conditions that limit their actual emissions to less than the major source thresholds. In this case, the local permitting agency would issue a synthetic minor permit and the facility would be required to keep detailed records of product usages to demonstrate compliance with the permit limits. As a synthetic minor source, the facility would no longer be required to comply with the stringent requirements of NSR and/or maximum achievable control technology (MACT), or the Title V permitting requirements. Ask for the VOC exemption levels in your area for inkjet printing. Also ask about any emissions limits for HAPs. The exemption levels may influence your choice of equipment. Since ink composition and consumption rates vary significantly between manufacturers, you may be required to permit one printer that uses a high VOC ink and be exempt from permitting another printer that uses water-based inks. On-Site Documentation Requirements Maintain the following important documents at your facility: Detailed list of equipment, models, and manufacturers MSDSs and supporting emissions calculations Air permit or exemption letters or analysis Copy of applicable rules Conclusion The rules and regulations affecting small sources are much more obscure than those affecting large facilities. Every local air quality permit program has a different way of dealing with small sources and there is no universal cutoff for the requirements. Fortunately, the procedures for evaluating the applicability of regulations are consistent. Begin with a rough estimate of VOCs and HAPs, and if your estimates warrant it, conduct a more accurate estimate. Because application thresholds are applied on a facility-wide basis, be sure to add up the separate emissions for all of your potential sources of air pollution. Next, compare your potential to emit with the major source thresholds in your area. These can range from 10 tons of VOCs per year in areas of extreme nonattainment, up to 100 tons of VOCs per year in attainment areas. The major source threshold for HAPs is always 10 tons per year per HAP, or 25 tons per year for any combination. It is up to you to learn about the air quality regulations in your area and to understand the emissions at your facility. Use this document as a guide in estimating emissions and determining the important thresholds in your area. Then, work with your local agencies to determine the specific requirements that apply to your operations. For most small facilities, it is best to work directly with the local permitting agency to determine applicable air quality requirements. Before contacting the agency, you should have estimates of the VOC and HAP emissions from your shop or proposed equipment. Disclaimer This document is intended for use only as a general guideline. Information contained herein is accurate as of January 1, 2004, to the best of our knowledge. It is not, however, meant to replace or supersede any federal, state or local documents or publications pertaining to worker safety or health practices, equipment or standards. To ensure total compliance, consult your legal counsel and the appropriate agency with jurisdiction for your area. Photo Marketing Association International, Digital Imaging: Air Permitting and the Clean Air Act

7 Case Studies The following pages are permitting scenarios involving typical digital inkjet printing equipment in two different areas of the country: Los Angeles County, Calif. Houston, Texas All of the emissions used in the case studies are based on a hypothetical large-format inkjet printer that has the maximum capacity specifications listed in Chart 6. Chart 6 Case Studies: Potential to Emit Rates Potential to emit VOCs lbs./yr. Potential to emit total HAPs lbs./yr. Potential to emit diethylene glycol lbs./yr. Potential to emit ethylene glycol lbs./yr. Permitting a Small Source in Los Angeles County, California Non-Attainment Status of County Extreme NSR Major Source Threshold tons VOC emissions/year Potential to Emit VOCs lbs./year; 39.6 lbs./month; 1.3 lbs./day Potential to Emit HAPs lbs./year Local Permitting Agency South Coast Air Quality Management District Our Procedure The first step is to locate the website of the local permitting agency, and find their rule section. In this case it is: We are looking for permit procedures, so select the permits link in section II: Look for the following rules that govern inkjet printing operations: 219, 1171, 109, and 442 Regulatory References Rule The following equipment is not required to obtain a permit in L.A. County, according to Rule 219: (h) Printing and Reproduction Equipment (1) Printing and related coating and/or laminating equipment and associated dryers: (A) provided such dryers are exempt pursuant to paragraph (b)(2) and the equipment is (i) not emitting more than three (3) pounds per day or 66 pounds per calendar month of VOC emissions; or (ii) not using more than six (6) gallons per day or 132 gallons per calendar month of plastisols type, including cleanup solvent; or (iii) not using more than two (2) gallons per day or 44 gallons per calendar month of any other graphic arts materials. (B) using not more than six (6) gallons per day or 132 gallons per calendar month of ultra violet/electron beam (UV/EB) coatings including cleanup solvents, or (C) UV/EB coatings containing fifty (50) grams of VOC per liter of material, and using exclusively cleanup solvents containing fifty (50) grams of VOC per liter of material, or less (Graphic arts materials are any inks, coatings, adhesives, fountain solutions (excluding water), thinners (excluding water), retarders, or cleaning solutions (excluding water), used in printing or related coating or laminating processes.) (2) Photographic process equipment by which an image is reproduced upon material sensitized by radiant energy and control equipment exclusively venting such equipment, excluding wet gate printing utilizing perchloroethylene and its associated control equipment. (3) Lithographic printing equipment which uses laser printing. (4) Printing equipment used exclusively for training and non-production at educational institutions. (5) Flexographic plate-making and associated processing equipment. Photo Marketing Association International, Digital Imaging: Air Permitting and the Clean Air Act

8 Permitting a Small Source in Los Angeles County, California continued Rule Solvent-Cleaning Operations: The purpose of Rule 1171 is to reduce the emissions of VOCs from solvent-cleaning operations and activities. Inkjet printing is specifically exempt until 7/1/05 from using low VOC solvent BUT is not exempt from recordkeeping requirements: (h) Exemptions (7) For the cleaning of ink application equipment used in inkjet printing, the VOC limit of 25 g/l specified in clause (c)(1)(d)(i) shall not apply until July 1, 2005 (c) Requirements (6) Recordkeeping Requirements - Records shall be maintained pursuant to Rule 109 for all applications subject to this rule, including those exempted under paragraphs (h)(3) through (h)(8), except facilities required to keep records of VOC used pursuant to any other Regulations XI rules. Rule Recordkeeping for Volatile Organic Compound Emissions: The purpose of Rule 109 is to require businesses that use VOCs to keep records of that usage. Rule 109 outlines the acceptable recordkeeping requirements for either a daily, monthly or an alternative recordkeeping system. Rule Usage of Solvents: The purpose of Rule 442 is to reduce the emissions of VOCs from equipment and materials that are not subject to the VOC limits in any Regulation XI rule (there is no XI rule for inkjet printing): (d) Requirements (2) Effective January 1, 2003, a person shall not emit VOCs to the atmosphere from all VOC-containing materials, equipment or processes subject to this rule, in excess of 833 pounds per month per facility. Emissions may be reduced through the use of the following: (A) Product reformulation or substitution, process changes, improvement of operational efficiency, and/or the development of innovative technology; or (B) Any combination of emission control device and subparagraph (d)(2)(a) provided that the operator submits an Alternative Compliance Plan that is approved by the Executive Officer. The Executive Officer shall not approve an alternative compliance plan, unless the plan has demonstrated real, quantifiable, and verifiable emission reductions. The Bottom Line Based on Rule 219 (h)(1)(a)(i), the owner of the facility is not required to obtain a permit for this specific large-format printer. Keep in mind that if you had three printers at the location (3 x 1.3 = 3.9 lbs./day), you would exceed the limit and would need to be permitted. At that point, you should contact the agency directly and confirm your findings. Based on Rule 1171, the owner of the facility is not required until July 1, 2005, to limit the inkjet printing solvent used to 25 g/l. The owner is required to keep records of VOCs used. Based on Rule 442, the owner of the facility is not required to change processes or implement control technology (the VOC emissions from a total facility do not exceed 833 pounds of VOCs per month). Photo Marketing Association International, Digital Imaging: Air Permitting and the Clean Air Act

9 Permitting a Small Source in Houston, Texas Non-Attainment Status of County Severe 17 (17 years to bring the county into compliance with NAAQS) NSR Major Source Threshold tons VOC emissions per year Potential to Emit VOCs lbs./year; 1.3 lbs./day; 0.05 lb./hour Potential to Emit HAPs lbs./year Local Permitting Agency Harris County Public Health and Environmental Services Our Procedure In this case, the local agency does not have its own rules governing air pollution permits and we will use the rules published by the state. Therefore, the local permitting agency is the Texas Commission on Environmental Quality. Again, you should begin looking for help in a section of their website dedicated to the permitting process: ( permitting/airperm/index.html#oppermits) TNRCC RULE Printing Presses describes the facilities (including inkjet printers) covered under the permit by rule procedures of the Texas Administrative Code. Permit by rule is a program that allows small sources to register and self-regulate. This reduces the administrative burden on the agency of monitoring a large number of small sources, whose emissions cannot significantly change the non-attainment status of an area. Regulatory Reference Here are the key points of Rule that apply to our printer. Printing operations (including, but not limited to inkjet printers) shall meet the following conditions of this section to be permitted by rule: (1) The uncontrolled emission of volatile organic compounds (VOC) and solvents (including, but not limited to, those used for printing, cleanup, or makeup) shall not exceed the following rates: (A) 15 tons per year (tpy) for any single printing operation proposed to be covered by this section; and (B) 25 tpy for all printing operations on the property covered by permits by rule. (2) Facilities which release 10 tpy or more of VOC emissions from all printing operations permitted by rule at the site must register with the commission using Form PI-7. (5) Records of ink and solvent usage shall be kept in sufficient detail to show compliance with paragraph (1) of this section and shall be maintained for a two-year rolling retention period. The Bottom Line Our printer qualifies for the permit-by-rule procedures and does not need to go through the formal permit application process. Additionally, since our emissions are less than 10 tpy, our facility does not need to register. However, the facility must keep records of ink and solvent usage to be able to demonstrate that it is eligible for the permit by rule. Photo Marketing Association International, Digital Imaging: Air Permitting and the Clean Air Act

10 Glossary of Terms and Acronyms Attainment area A geographical area that meets NAAQS for criteria air pollutants. BACT Best available control technology. Applies to PSD sources. CAA Clean Air Act. This act is the foundation of air regulations in the U.S. CAS Chemical Abstract Service. CFR Code of Federal Regulations. Title 40 (40 CFR) contains the regulations for protection of the environment. Criteria air pollutants One of six air pollutants or classes of pollutants regulated by the EPA for which NAAQS have been established. The six air pollutants are ozone (including VOCs), carbon monoxide, particulate matter, nitrogen oxides, sulfur dioxide and lead. EPA Environmental Protection Agency. HAP Hazardous air pollutant. One of 188 hazardous air pollutants that are regulated. LAER Lowest achievable emission rate. This is the required emission rate in non-attainment NSR permits. MACT Maximum achievable control technology. Applies to major sources of HAPs and some very specific minor sources of HAPs. Major source A business that has a potential to emit for a regulated pollutant that is at or greater than an emission threshold set by the government. MSDS Material safety data sheet. NAAQS National Ambient Air Quality Standards. Standards exist for six pollutants known as the criteria air pollutants; NOx, SOx, lead, ozone, particulate matter less than 10 microns in diameter, and carbon monoxide (CO). NESHAP National Emissions Standards for Hazardous Air Pollutants. Emission standards for specific source categories that emit or have the potential to emit one or more HAPs. NESHAPs are modeled on the best practices and most effective emission reduction methodologies in use at the affected facilities. Non-attainment area A geographical area that does not meet NAAQS for criteria air pollutants. NOx Oxides of nitrogen. NSPS New Source Performance Standards. These apply only to predetermined process and source categories. There are no NSPS standards for inkjet printers. NSR New Source Review. There are two different sets of permitting procedures and requirements based on the attainment status of a region. They apply to major sources of criteria air pollutants. PSD Prevention of significant deterioration. NSR permitting requirements in regions of attainment. PTE Potential to emit. The maximum capacity of a business to emit a pollutant, given its physical or operation design, and considering certain controls and limitations. RACT Reasonably Available Control Technology standards. These standards are implemented by states in areas of non-attainment to reduce VOC and NOx emissions. UV/EB Ultraviolet/electron beam. VOC Volatile organic compound. VOCs are regulated because they are precursors to ozone. VOCs are carbon-containing gases and vapors that come from incomplete gasoline combustion and from the evaporation of liquid solvent, such as those used in digital printing inks and printhead cleaners. Acknowledgments This document was developed by Photo Marketing Association International in conjunction with ICF Consulting, 9300 Lee Highway, Fairfax, Virginia, and Envision Compliance Ltd., 124 Connie Crescent, Concord, Ontario, Canada. Photo Marketing Association International, Digital Imaging: Air Permitting and the Clean Air Act