EC-09 Printing Operations Calculation Form

Fill out this form for each printing operation, or attach sheets with equivalent information. EC-09 Printing Operations Calculation Form Air Quality Permit Program If the printing operation emits Hazardous Air Pollutants (HAPs), fill out and attach Form EC-13A and/or EC-13B. If fuel fired curing ovens are used, fill out Form EC-08 for each oven. Doc Type: Permit Application Instructions on Page 2 1a) AQ Facility ID No.: 1b) AQ File No.: 2) Facility Name: 3) Number of presses covered by this form: 4) Emission Unit Identification Number(s): 5) Stack/Vent Designation Number: 6) Operation Type: Non-heatset Web Heatset Web Flexographic Sheetfed Lithographic Gravure Screen Other: 7) Curing: Oven UV Other None 8) Are VOC emissions from this unit controlled with an afterburner? Yes No 9) Describe the composition of all inks, thinning solvents, cleaning solvents and fountain solutions that are used by this unit: 9a) 9b) 9c) 9d) Name of ink, solvent, VOC content Solid Content Density or fountain solution 10) Calculations Summary: 9a) 10a) 10b) 10c) 10d) 10e) 10f) 10g) Name of ink, solvent, or fountain solution Emission Rate Maximum Pollution Control Efficiency Maximum Controlled Limited Controlled Actual Actual Controlled (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) (tons/yr) aq-f1-ec09 2/25/10 Page 1 of 5

10h) Worst-Case Ink 10i) Worst Case Cleaning Solution/Solvent 10j) Worst Case Fountain Solution 10k) Total Potential 10l) Total Actual Limited Actual 11) Operating Limitations, if applicable: Instructions for Form EC-09 Please complete this form for each press, or attach sheets with equivalent information. One form may be filled out for several identical presses if they vent to the same stack, but the calculation summary must include potential emissions from all presses covered by this form. 1a) AQ Facility ID No. -- Fill in your Air Quality (AQ) Facility identification (ID) Number (No.). This is the first eight digits of the permit number for all permits issued under the operating permit program. If your facility has never been issued a permit under this program, leave this line blank. 1b) AQ File No. -- Fill in your AQ File Number, if known. This number can be found in the cc section of correspondence from the MPCA. 2) Facility Name -- Enter your facility name. 3) Number of presses covered by this form -- Fill in the number of identical presses that are covered by this form that exhaust to the same stack. Make sure when you do the potential-to-emit (PTE) calculations that you include the emissions from all this number of units to get the total PTE. 4) Emission Unit Identification Number(s) -- Fill in the identification number of the emission unit. Obtain this number from your Emission Unit Information Form (GI-05B). Indicate total facility or multiple units if applicable. [Note: If you are using this form for Registration Permit Option D, you did not fill out Form GI-05B; instead, just provide information identifying the emission unit.] 5) Stack/Vent Designation Number(s) -- Fill in the designation number of the stack(s) or vent(s) through which the unit will exhaust into the atmosphere. Obtain these numbers from your Stack/Vent Information Form (GI-04). Indicate total facility or multiple stacks if applicable. [Note: If you are using this form for Registration Permit Option D, you may skip this question.] 6) Operation Type -- Indicate the type of printing operation. 7) Curing -- If oven curing is being used for heatset operations, fuel burning emissions from the oven must be calculated separately using Form EC-08. 8) Are VOC emissions from this unit controlled with an afterburner -- If yes, Form GI-05A (if applying for an individual permits) or Form RP-D2 (if applying for Registration Permit Option D) must be filled out for each afterburner used to control printing operations, and fuel burning emissions from the afterburner must be calculated separately using the Form EC-08. 9) Composition Table: 9a) Name of ink, solvent, or fountain solution -- Fill in the name of the ink, thinning solvent, cleaning solvent or fountain solution. (Fill in this same information under item 10, where 9a is repeated.) 9b) VOC content -- Fill in the Volatile Organic Compounds (VOCs) content for each ink, solvent, or fountain solution used, expressed in pounds per gallon. aq-f1-ec09 2/25/10 Page 2 of 5

9c) Solid Content -- Fill in the solid content for each ink, solvent, or fountain solution used, expressed in pounds per gallon. 9d) Density -- Fill in the density of each ink, solvent, or fountain solution, expressed in pounds per gallon. 10a) Emission Rate -- Use the following guidelines to calculate the maximum uncontrolled hourly emission rate from ink usage, fountain solution, and cleaning solution. Ink Usage Maximum hourly emissions must be calculated assuming maximum press speed (feet/minute for webs and sheets/hour for sheet fed presses), ink coverage, VOC content in the ink, and web width for web presses. Any physical limitations (i.e., dryer capacity) in the process may be used in your calculation, but they must be clearly supported. Web presses: E = S (ft/min) x W (ft) x C (lbs ink/ft 2 web) x V (lb VOC/lb ink) x 60 (min/hour) x (1 [R 100]) E = potential emissions in lbs/hour S = maximum web speed in ft/min W = maximum web width C = maximum ink coverage in pounds of ink per square foot (use manufacturer's information, historical records, or data from a similar press) V = maximum VOC content of the ink R = VOC retention factor in web (generally, r = 95% for non-heatset lithographic presses and 20% for heatset web lithographic presses) Sheet-fed presses: E = S (sheets/hour) x A (ft 2 ) x C (lb ink/ft 2 sheet) x V (lb VOC/lb ink) x (1 [R 100]) E = potential emissions in lbs/hour S = maximum press speed in sheets/hour A = maximum sheet area in square feet C = maximum ink coverage in pounds of ink per square foot (use manufacturer's information, historical records, or data from a similar press) V = maximum VOC content of the ink R = VOC retention factor in web Fountain Solution Usage VOC emissions from fountain solutions are from alcohol added to the water in the fountain solution to decrease the surface tension of the water. The alcohol is assumed to be completely volatilized, so VOC emissions are equal to alcohol use. To calculate your VOC potential-to-emit from fountain solution, determine what your maximum possible usage of fountain solution could be in gallons per day. You may base this calculation on historical records or records from a similar press; however, make sure that you adjust these historical records to reflect the maximum capacity of your press. Once you know the most fountain solution you could ever use in one day, you may calculate potential-to-emit as follows: E = U (gallons solution/day) x V (lb VOC/gallon solution) x 0.04167 (days/hour) E = potential emissions in lbs/hr U = maximum possible fountain solution usage in gal/day V = maximum VOC content of fountain solution You must attach sheets showing your calculations. Remember that your estimate must reflect the maximum possible usage. Cleaning Solution Usage VOC emissions from cleaning solutions are calculated assuming the maximum VOC content of the cleaning solution, and assuming that all of the VOC is completely volatilized. The maximum amount of cleaning solution that would ever be used can be calculated based on historical records or records from a similar press, similar to the fountain solution calculation shown above. Adjust any historical data to reflect maximum production capacity. You must attach sheets showing your calculations. Remember that your estimate must reflect the maximum possible usage. aq-f1-ec09 2/25/10 Page 3 of 5

10b) Maximum -- (You may skip this item if using this form to calculate actual emissions for Registration Permit Option D.) Maximum uncontrolled annual VOC emissions may be calculated from the uncontrolled emission rate in lbs/hr (for ink, fountain solution, or cleaning solution usage) by using the following equation: Max uncontrolled emissions = emission rate (lb/hr) x 8760 (hours/year) x 1 ton/2000 lb [item 10 b] = [item 10a] x 4.38 If you operate an offset lithographic printing press, you may account for the fact that some of the VOCs are retained in the substrate. For heatset equipment, assume 20% of the VOC is retained in the substrate. The equation for maximum uncontrolled emissions then becomes: [item 10 b] = [item 10a] x 4.38 x 0.8 For nonheatset equipment, assume 95% of the VOC is retained in the substrate. The equation for maximum uncontrolled emissions then becomes: [item 10 b] = [item 10a] x 4.38 x 0.05 Also for heatset equipment, you may assume a carry over of VOCs from ink to the dryer of 100%. This means that you may assume that all of the VOCs are emitted from the dryer, rather than at the press itself. 10c) Pollution Control Efficiency, % -- Fill in the Pollution Control Efficiency of your pollution control equipment, in percent, if applicable. This information can be obtained from Form GI-05A. If no control equipment, enter zero. The control efficiency is the product of the capture efficiency and the destruction/collection efficiency. For instance, if the capture efficiency is 70% and the destruction efficiency of your thermal oxidizer is 95%, the control efficiency is 66.5%. control efficiency = 0.70 x 0.95 = 0.665 10d) Maximum Controlled -- (You may skip this item if using this form to calculate actual emissions for Registration Permit Option D.) Maximum controlled VOC emissions are calculated from the maximum uncontrolled emissions and the pollution control efficiency using the following equation: Max Controlled (lb/hr) = Max (lb/hr) x ([100 pollution control efficiency] 100) [item 10d] = [item 10b] x ( (100 [item 10c]) 100) 10e) Limited Controlled -- (You may skip this item if using this form to calculate actual emissions for Registration Permit Option D.) The Limited Controlled are calculated by taking into account all limitations on operation of the source you are proposing to comply with in this application. These limitations include limits on hours of operation, limits on the VOC content of the materials used, limits on the rate or amount of materials used, etc. You start the calculation of Limited Controlled by recalculating the Maximum Emission Rate and taking into account the limits you propose. If an emission unit is subject to an emission limitation specified in 40 CFR pt. 60, 40 CFR pt. 61, 40 CFR pt. 63 or Minn. R. ch. 7011, you must take this into account in calculating the Limited Controlled. If you choose to propose to comply with more a stringent limit, you should state this clearly in item 11 and show the resulting allowed emissions in this calculation. 10f) Actual -- (Complete this item only if you are using this form to calculate actual emissions for Registration Permit Option D, or if you did not submit an emission inventory to the MPCA Air Quality program for the previous year.) Actual uncontrolled annual VOC emissions may be calculated from the uncontrolled emission rate in lbs/hr (for ink, fountain solution, or cleaning solution usage) by using the following equation: Mac uncontrolled emissions = emission rate (lb/hr) x H (hours/year) x 1 ton/2000 lb [item 10f] = [item 10a] x H x 0.0005 where H = the number of hours operated per year. A. As an alternative, if you have records of actual VOC usage from the past two calendar years, you may use these historical records when filling in item 10f. B. If you operate an offset lithographic printing press, you may account for the fact that some of the VOCs are retained in the substrate. For heatset equipment, assume 20% of the VOC is retained in the substrate. The equation for maximum uncontrolled emissions of VOCs then becomes: [item 10f] = [item 10a] x H x 0.0005 x 0.80 For nonheatset equipment, assume 95% of the VOC is retained in the substrate. The equation for maximum uncontrolled emissions then becomes: [item 10f] = [item 10a] x H x 0.0005 x 0.05 aq-f1-ec09 2/25/10 Page 4 of 5

C. Also for heatset equipment, you may make the following assumptions when calculating actual emissions: You may assume a carry over of VOCs from ink to the dryer of 100%. This means that you may assume that all of the VOCs are emitted from the dryer, rather than at the press itself. You may assume a carry over of VOCs from fountain solution to the dryer of 70% of alcohol substitutes. This means that if there are alcohol substitutes in your fountain solution, you may assume that 70% of the VOCs emitted from the fountain solution occur at the dryer, and 30% occur at the press. You may assume a carry over of VOCs from cleaning solution used in an automatic blanket wash system of 40%, when the vapor pressure is 10 mmhg or less at 20 C. This means that if you operate an automatic blanket wash system, and the vapor pressure is 10 mmhg or less at 20 C, then you may assume that 40% of the VOCs from the cleaning solution occur at the dryer, and 60% occur at the press. There is no carry over for any cleaning system other than an automatic blanket wash system. D. For both heatset and nonheatset equipment, when using cleaning solution with rags or wipes, you may assume that 50% of the VOCs from the cleaning solution remains in the rags or wipes. 50% of the VOC is then assumed to be emitted at the point of cleaning. E. For both heatset and non heatset equipment, if you dispose of, recycle, or reuse VOC-containing materials offsite, and you appropriately document the actions and quantities, you may take credit for that quantity of VOC that is not emitted at this particular location. 10g) Actual -- (Complete this item only if you are using this form to calculate actual emissions for Registration Permit Option D, or if you did not submit an emission inventory to the MPCA Air Quality program for the previous year.) Actual controlled VOC emissions are calculated from the actual uncontrolled emissions and the pollution control efficiency using the following equation: Actual Controlled (lb/hr) = Actual (lb/hr) x ([100 pollution control efficiency] 100) [item 10g] = [item 10f] x ( (100 [item 10c]) 100) 10h) Worst-Case Ink -- (You may skip this item if using this form to calculate actual emissions for Registration Permit Option D.) Look at maximum uncontrolled emissions (column 10b) from the inks and ink-like solutions entered in item 9a. Choose the highest uncontrolled emissions and enter that number under uncontrolled in item 10h. Next look at the limited controlled emissions (column 10e) from the inks and ink-like solutions entered in item 9a. Choose the highest limited controlled emission and enter that number under limited in item 10h. 10i) Worst-Case Cleaning Solution/Solvent -- (You may skip this item if using this form to calculate actual emissions for Registration Permit Option D.) Look at maximum uncontrolled emissions (column 10b) from the cleaning solutions/solvents entered in item 9a. Choose the highest uncontrolled emissions and enter that number under uncontrolled in item 10h. Next look at the limited controlled emissions (column 10e) from the cleaning solutions/solvents entered in item 9a. Choose the highest limited controlled emission and enter that number under limited in item 10h. 10j) Worst-Case Cleaning Solution/Solvent -- (You may skip this item if using this form to calculate actual emissions for Registration Permit Option D.) Look at maximum uncontrolled emissions (column 10b) from the fountain solutions entered in item 9a. Choose the highest uncontrolled emissions and enter that number under uncontrolled in item 10h. Next look at the limited controlled emissions (column 10e) from the fountain solutions entered in item 9a. Choose the highest limited controlled emission and enter that number under limited in item 10h. 10k) Total Potential -- (You may skip this item if using this form to calculate actual emissions for Registration Permit Option D.) Add up the numbers listed under uncontrolled for items 10h, 10i, and 10j, and enter the sum for item 10k. This is the worst case, uncontrolled potential emission from equipment listed in item 4 of this form. Next add up the number listed under limited for items 10h, 10i, and 10j, and enter the sum for item 10k. This is the emissions that would be allowed from the equipment listed in item 4, after accounting for any control equipment that is used and any operating limitations listed in item 11. 10l) Total Actual -- (Complete this item only if you are using this form to calculate actual emissions for Registration Permit Option D, or if you did not submit an emission inventory to the MPCA Air Quality program for the previous year.) Add all of the numbers under column 10g, and enter the sum in item 10l. These are the total actual controlled VOC emissions from the equipment listed in item 4. 11) Operating Limitations, if applicable -- If you are willing to accept limitations on hours of operation, operating rate, VOC content of materials used, etc., please state these limitations here or attach additional sheets as necessary to describe. These limitations should be used in the calculation of the Limited Controlled. Also include these limits on Form CD-01. aq-f1-ec09 2/25/10 Page 5 of 5