**WASHOE COUNTY DISTRICT HEALTH DEPARTMENT**

**TITLE V OPERATING PERMIT**

**ISSUED TO: R. R. DONNELLEY AND SONS COMPANY**

Facility Location: 14100 Lear Blvd. Reno, Nevada 89506

Application Received: September 30, 2002

Nature of Business: Printing operations - Rotogravure Technology

Primary SIC: 2754

Responsible Official: Paul Erickson, Vice President of Manufacturing

Facility Contact Person: John Helmreich, Environmental Health and Safety
Supervisor - Phone: 677-3817

Permit Number: **D65TV**

Permit Issuance date: **JUNE 1, 2005**

Permit Expiration Date: **MAY 31, 2010**

Date of Most Recent Revision:

Approved For Issuance By:

Chris Ralph, Air Quality Engineer Date

Washoe District Health Department,

Air Quality Management Division

Page 1 of 19

**TITLE V OPERATING PERMIT**

**R. R. DONNELLEY & SONS COMPANY**

**RENO PLANT**

**TABLE OF CONTENTS**

Permit Section Page

*I. Introduction and General Description of Operations
\...\...\...\...\...\...\...\...\...\...\....3*

II\. District Regulations and Federally Applicable

Requirements
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*III. General Obligations of the Permittee
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*IV. Compliance Report Requirements
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*V. Emission Limitations and Controls
\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\....7*

*VI. Monitoring and Compliance
\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....10*

*VII.Permit Term
\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\......\...\...\...\...\...\...\...\...\...12*

*VIII. Permit Expiration and Renewal
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*IX. Permit Modifications
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*X. Title IV Implementation
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*Attachment A - Equipment Schedule
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*Attachment B - Emissions Inventory
Table\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\....15*

*Attachment C - Insignificant Activities
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*Attachment D - Compliance Certification Statement
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Page 2 of 19

TITLE V OPERATING PERMIT

R. R. DONNELLEY & SONS COMPANY

RENO PLANT

**I. Introduction and General Description of Operations**

This permit pertains to the operations of the Reno Plant of R. R.
Donnelley & Sons Company which is located at 14100 Lear Blvd., Reno,
Nevada 89506. The Reno Plant prints magazines, catalogs, tabloids,
newspaper inserts and other printed material using the gravure printing
process(SIC \# 2754 / NAICS# 323111) for distribution throughout the
United States. Other process support equipment located at this source
includes boilers, gravure cylinder manufacturing (including chrome and
copper plating equipment), paper cutting and pneumatic byproduct paper
dust collection and handling systems, ink and solvent storage tanks, as
well as other related product finishing equipment.

Emissions from the gravure printing process result from the evaporation
of gravure ink solvent, which is primarily toluene. Toluene is both a
volatile organic compound (VOC) and a listed hazardous air pollutant
(HAP). The ink solvent may also contain trace quantities of other listed
HAPs such as Hexane, Ethyl Benzene and Xylene. Both stack and in plant
fugitive emissions from operations using gravure solvent are captured
and collected for recovery in carbon bed adsorbers for subsequent reuse
or resale to ink supplier(s). The gravure printing operations are
subject to the requirements of the publication rotogravure MACT standard
promulgated by EPA as 40 CFR 63 Subpart KK. The MACT compliance date for
this source was May 30, 1999.

Four boilers provide steam for use in desorbing the gravure ink solvent
from the carbon bed solvent recovery system, for the gravure press
dryers and for plant space heating during the cool weather seasons.
These boilers use natural gas as a primary fuel with No. 2 fuel used as
a backup fuel.

Manufacturing operations at this facility also include the
chrome‑plating of gravure cylinders. The facility's chrome plating tanks
are subject to the requirements of the chrome \"MACT\' standard
promulgated by EPA at 40 CFR 63 Subpart N. The compliance date for this
equipment was January 25, 1997.

Two (2) cyclones are used to collect and convey by‑product paper from
bindery trim and hogger (paper shredder) operations to the baler for
subsequent off site recycling of the paper. These operations result in
emissions of particulate matter (paper dust).

Two Minor source permits have been issued by the District to Donnelley
in the period since the last Title V permit. These changes added no new
applicable requirements to the operation. The terms and conditions of
the minor source permits issued by the District are included in this
Title V permit.

A complete list of equipment (except insignificant sources) from which
emissions are allowed by this permit is given in Attachment A. Emissions
listed in Attachment B entitled \"Emission Inventory Table\" constitute
best engineering estimates of the potential emissions of equipment
subject to regulation as set forth in the permit application. Attachment
C lists insignificant sources.

**II. Listing of District Regulations and Federally Applicable
Requirements:**

**A. Washoe County District Health Dept. Requirements**

The permittee is required to comply with the following general
provisions of the Washoe County District Health Dept. (WCDHD)
Regulations Governing Air Quality Management:

1\. District Regulations which are not Federally enforceable:

020.070 ‑.080 General Provisions

030.000 ‑.020 Source Permitting and Operation

030.200 ‑.280 Washoe County Permit to Operate Requirements

030.410 ‑.480 Toxic or Hazardous Air Pollutants

030.700 ‑.750 Washoe County Control Requirements (LAER & BACT)

040.000‑.030,.060,.085 Prohibited Emissions

040.055 Prohibited Emissions -- Nuisance Odors

050.030 & 050.100 Emergency Episode Plan

These are locally derived regulations and are not federally enforceable.

2\. The relevant terms and conditions set forth in the minor source
Authority to Construct Permits and Permit to Operate issued by the WCDHD
in 1994, which are not otherwise part of any applicable requirement, are
locally derived requirements and are not federally enforceable.
Federally enforceable requirements are listed in section II.B.

Page 3 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant

Title V Operating Permit

**B. Federally Enforceable Regulations and Applicable Requirements:**

The permittee is required to comply with the following general
provisions of the Washoe County District Health Dept. (WCDHD)
Regulations Governing Air Quality Management which are federally
enforceable:

1\. The applicable provisions of PSD Permit \# NSR‑4‑7‑2, NV 84‑01
issued by USEPA Region IX and dated 6/21/85 and as outlined in Section V
of this permit.

2\. Code of Federal Regulations, Title 40, Part 60; Subpart A ‑ General
Provisions - specifically 60.7(a)(4), 60.8, 60.11, 60.12 and 60.14;
Subpart Dc ­Standards of Performance for Small Industrial Steam
Generating Units - specifically 60.42c(d), (g),(h)and (i); 60.44c(h),
60.46c(e), 60.48c(a),(d),(e), (f),(g) and (i); Subpart QQ ­Standards of
Performance for the Graphic Arts Industry - specifically 60.432 through
60.435; Publication Rotogravure Printing, and Subpart Kb ‑ Standards of
Performance for Volatile Liquid Storage Vessels - specifically 60.110b
and 60.116b (a), (b), (d) and (e).

3\. Code of Federal Regulations, Title 40, Part 63; Subpart A ‑ General
Provisions; Subpart N ‑ National Emission Standards for Hard and
Decorative Chromium Electroplating and Chromium Anodizing Tanks -
specifically 63.342(c)(2), 63.343(c)(1), 63.346 and 63.347(g); and
Subpart KK ‑ National Emission Standards for the Printing and Publishing
Industry Units - specifically 63.824, 63.826(a), 63.827 (a)(3), (b),
(c)(1), (c)(3), 63.829, and 63.830.

4\. Federally enforceable District Regulations (those parts which are
applicable to the facility):

030.100 to 030.1404 Federal Standards (NSPS & NESHAP)

030.503 to 030.504 Federal New Source Review (NSR)

030.600 to 030.630 Prevention of Significant Deterioration (PSD)

030.900 to 030.990 Part 70 Permitting Regulations (CAAA)

5\. The source shall be subject to the provisions of Section 112 of the
Clean Air Act, including the provisions of Section 112(r).

**[All the requirements of this permit noted below shall be considered
as Federally enforceable unless marked with a double
asterisk.]{.underline}**

**III. General Obligations of Permittee** *Pursuant to District
Regulation 030.960*

The permittee shall comply with the following general requirements:

**A. Duty to Comply** ‑ The permittee shall comply with all terms and
conditions of this permit. It shall not be a defense for a permittee in
an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the
conditions of this permit. In addition to compliance with the terms of
the permit, the source shall be operated in a manner consistent with the
operations described in the application for permit. *(Reference 40 CFR
70.6 (a)(6)(i) and (ii)).*

**B. Violation** ‑ Any permit noncompliance constitutes a violation and
is grounds for enforcement actions; for permit termination, revocation
and reissuance, or modification; or for denial of a permit renewal
application. Each day of non-compliance constitutes a separate
violation. *(Reference 40 CFR 70.6 (a)(6)(i)).*

**C. Permit Transfer** ‑ Upon change of control or ownership, the
applicant shall notify any succeeding owner or operator of this facility
of the existence of this permit in writing, a copy of the notification
shall be provided to the District. The terms and conditions of this
permit shall be binding on all subsequent owners or operators. A request
for an Administrative amendment shall be sought for changes in ownership
or address of the facility. *(Reference 40 CFR 70.7(d)(iv); PSD permit
NSR 4-7-2 NV-84-01)).*

**D. Operational Flexibility** ‑ The permittee is authorized to make
physical or operational changes consistent with the conditions of this
permit without applying for or obtaining a new permit or an amendment to
this permit, provided that the emissions from the unit or group of units
will not exceed the applicable regulations and/or permit limitations and
prior notice (if required by District Regulation 030.950) is provided to
the District. *(Reference 40 CFR 70.4 (12), Clean Air Act Section
502(b)10).*

**E. Section 502 (b)(10) Changes** - The permittee shall monitor for and
record, any section 502(b)10 change to the source, which is defined as a
change that would contravene an express permit term as described in
section 030.950 (B). Notice must be given to the Air Quality Division
and the EPA for any such change seven days in advance of enactment. The
changes cannot be modifications under Title I of the CAA, and no permit
shield can cover 502 (b) (10) changes. *(Reference 40 CFR 70.4 (12),
Clean Air Act Section 502(b)10).*

Page 4 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant

Title V Operating Permit

> **F. Emissions Trading** ‑ No permit revision shall be required for
> increases in emissions allowed under any approved economic incentives,
> marketable permits, emissions trading, or other similar programs or
> processes for changes that are provided for elsewhere in this permit
> and that are authorized by the applicable requirement. The permittee
> has requested and has been granted the right for trading emissions
> increases and decreases within the facility to the extent the
> applicable requirements provide for such trading and have been
> approved as tradable by the Control Officer. *(Reference 40 CFR 70.6
> (a)(8)).*

**G. Notification Requirements** ‑ The permittee must promptly report
any event which results in any excess emissions or any other deviation
from the requirements of this permit, including those due to emergency
upset conditions, in accordance with District regulation 020.075 and
020.076. The reporting timeframes shall be as specified in 020.075.
*(Reference 40 CFR 70.6 (a)(3)(iii)(B)).*

**H. Certification of Truth, Accuracy, and Completeness** ‑ Any
application form, report, or compliance certification submitted pursuant
to District Regulations shall contain certification by a responsible
official of truth, accuracy, and completeness and state that based on
information and belief formed after reasonable inquiry, the statements
and information in the document are true, accurate, and complete. See
Attachment D. *(Reference 40 CFR 70.5 (d)).*

**I. Permit Reopenings** ‑ This permit may be terminated, suspended,
reopened, amended for cause. Any request from the permittee for
revisions to the permit, planned non-compliance or other planned changes
shall not stay the conditions of the permit. This permit must be
reopened and revised if any of the following occur *(Reference 40 CFR
70.6 (a)(6)(iii) and 70.7(f)(1)(i-iv)).*

1\. Additional requirements become applicable to the equipment subject
to this permit and three or more years remain before the permit expires;

2\. Additional requirements become applicable to an affected source
under the acid rain program;

3\. The Control Officer or the EPA Administrator determines that the
permit contains a material mistake, inaccurate statements were made in
establishing the emission standards, other terms or conditions of the
permit, or the permit must be revised or revoked to ensure compliance
with the applicable requirements or District regulations.

4\. The EPA Administrator finds that cause exists pursuant to District
Regulation 030.960(D)(1)(a) or (b), or in response to a public petition.

**J. Severability** ‑ The provisions of this permit are severable, and
should any one or more be determined to be illegal or unenforceable, the
validity of the other provisions shall not be affected. The rights and
obligations of the permittee shall be construed and enforced as if the
permit did not contain the particular provision held to be invalid and
the applicable requirements underlying these provisions shall remain in
force. *(Reference 40 CFR 70.6 (a)(5)).*

**K. Property Rights** ‑ This permit does not convey any property rights
of any sort, or any exclusive privilege. This permit does not release
the permittee from the duty to comply with any requirements of any
applicable statute, ordinance, code or law, including any Federal
requirements, statues of the State of Nevada, County of Washoe, city
ordinances or other legal requirements. *(Reference 40 CFR 70.6
(a)(6)(iv)).*

**L. Duty to Pay** ‑ Failure to pay fines, fees or other approved
charges from the District may result in enforcement action or
termination of the permit or both. All fines, fees or other approved
charges are due and payable within 30 days of receipt of the invoice by
the permittee. *(Reference 40 CFR 70.6 (a)(7)).*

> **M. Compliance Statement** ‑ The permittee shall submit a compliance
> statement signed by a responsible official due each year on the
> anniversary of the date of issuance. The statement shall conform to
> the provisions of District Regulation 030.970(A). *(Reference 40 CFR
> 70.6 (c)(3)).*

**N. Defenses to Enforcement Actions** -

1\. Need to Halt Activity ‑ It shall not be a defense for a permittee in
an enforcement action that it would have been necessary to halt or
reduce activity to maintain compliance. *(Reference 40 CFR 70.6
(a)(6)(ii)).*

> 2\. Emergency Upset, Breakdown or Scheduled Maintenance ‑ An emergency
> upset or breakdown condition shall be an affirmative defense to an
> enforcement action only if the conditions set forth in District
> Regulation 020.075 are met. *(Reference 40 CFR 70.6 (g)(3)(i - iv).*

Page 5 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant

Title V Operating Permit

**\*\* O. Posting of Permit** - This permit shall be posted on or near
the equipment listed above. This permit shall be readily available for
inspection at all times while the equipment is operating. (*Reference
Washoe County Regulation 030.240)*

**P. Maintenance of records** - Any records of operation which will
effect the potential of the source to emit air pollutants, such as fuel
or products consumed, products produced, hours of operation, solvents or
inks used in source operation must be maintained for a period of at
least 5 years and made available to the control officer upon request.
*(Reference 40 CFR 70.6 (a)(3)(ii)(B)).*

**Q. Provision of Records** - The permittee shall furnish, in a timely
manner, any information or records requested by the Air Quality Division
pertaining to emissions compliance, production records, equipment and
facility operations, or other air quality related information.
*(Reference 40 CFR 70.6 (a)(6)(v)).*

**R. Confidential Records** - Any request for confidential designation
of records must be made in writing to Control Officer as specified in
District Regulation 020.055. *(Reference 40 CFR 70.6 (a)(6)(v)).*

**S. Section 112r Compliance** - The operator shall prepare and submit
an risk management plan in compliance with the applicable sections of 40
CFR 68 on or before June 21, 1999, the date such plan is required.
*(Reference 40 CFR 70.6 (a)(1)(i)).*

**T. Terms** - Terms not otherwise defined in the permit shall have the
meanings assigned to such terms in the referenced regulations.
*(Reference 40 CFR 70.2 ).*

\*\* **U. Falsification** - The permittee shall not knowingly falsify or
render inaccurate any monitoring device or method of record required to
be maintained or followed by this permit. (*Reference Washoe County
Regulation 030.216)*

**V. Asbestos removal** - The permittee shall comply with the provisions
of District regulations 030.105 and 030.107 and 40 CFR Part 61, subpart
M (Asbestos) during any renovation or demolition activity at this
facility. *(Reference 40 CFR 70.6 (a)(1)(i ) and 40 CFR Part 61, subpart
M (Asbestos)* *).*

**W. Stratospheric Ozone** - The permittee shall comply with the
standards for recycling and emissions reduction pursuant to 40 CFR Part
82, subpart F Recycling and Emissions Reduction. *(Reference 40 CFR 70.6
(a)(1)(i ) and 40 CFR Part 82, subpart F).*

**X. Right to Enter** ‑ Upon presentation of proper credentials and
other documents as may be required by law and in accordance with
constitutional limitations, the permittee shall allow the District, the
Regional Administrator or any authorized representatives to perform the
following *(Reference 40 CFR 70.6 (b)(2))*:

1\. Enter upon the premises where an actual or potential source is
located or where any records are kept as required to demonstrate
compliance with the terms and conditions of this permit and to have
access to and copy, at reasonable times, these records;

2\. Inspect at any time while the plant is open for business or in
production any facilities, equipment (including monitoring and control
equipment), practices or operations regulated or required under this
permit;

3\. Sample or monitor any substances or parameters at any location and
obtain and remove samples of any discharge or emission of pollutants.
The permitee may conduct parallel sampling for verification purposes.

**IV. Compliance Report Requirements:**

**A. Compliance Plan:** *Reference Washoe County Regulation 030.970(A)*

Insofar as the Permittee is currently in compliance, the compliance plan
consists of continued adherence to the requirements of this permit and
those requirements set forth in applicable regulations and statutes. The
permittee shall submit a statement of compliance as required in section
030.970(A). The permittee shall also submit a compliance schedule,
certification and any other information as required to comply with the
applicable provisions of 40 CFR 68. For the purposes of the compliance
certification reports, the permittee shall use, at a minimum, the
information obtained from the monitoring requirements of section VI of
this permit.

> **B. Compliance Schedule:** *Reference Washoe County Regulation
> 030.970(B)*
>
> Insofar as the Permittee is in compliance at the time of the issuance
> of this permit, no schedule is required to attain compliance.

Page 6 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant

Title V Operating Permit

**V. Emission Limitations and Controls:**

**A. Allowable Emissions** ‑ Emissions of the following regulated
pollutants from the source, not

considering activities listed as insignificant sources in Attachment C,
shall not exceed the following:

**Overall Source Emission Limits**

**for Regulated Pollutants**

Limits for CO, PM, NOx and Lead emission limits are Washoe County only
enforceable. The overall source emissions shall be determined by adding
all process group emissions. Compliance with the annual emission limits
as given above shall be determined on a running total for twelve months.

Based on 1999 and 2000 operating records, the facility has also banked
the following emission credits due to the removal of the web offset
printing operations: Nitrogen Oxides: 1.6 tons

**B. Emission Standards for VOCs from the rotogravure production
printing presses**

*\[40 CFR 60 Subparts A and QQ and PSD Permit \# NSR‑4‑7‑2, NV 84‑01\].*
The permittee shall meet all applicable requirements of 40 CFR 60
Subparts A and QQ, including the following:

1\. Volatile organic material emissions from the production rotogravure
presses shall not exceed more than 16 percent of the total mass of VOCs
used during any one performance averaging period, pursuant to 40 CFR
60.432.

2\. The permittee shall not discharge or cause the discharge into the
atmosphere hydrocarbons in excess of 1365 lbs/hour or 16 percent of the
total mass of hydrocarbons used by the rotogravure presses based on a 30
day calendar average. *(Reference PSD permit NSR 4-7-2 NV-84-01
Condition H (1),(2) ).*

3\. Emissions Limits, NR624 -- All applicable record keeping provisions
of 40 CFR 63 Subpart KK apply to the operations of press NR642. The
operator will maintain records of all ink and other materials consumed
in the operations of press NR624, and the VOC and HAP content of those
materials. The permitee shall limit the operations of NR624 such that
net emissions increase due to this press shall not exceed 54.5 tons per
year, which is based on limiting press emissions to no more than 39.0
tons per year, with all banked creditable emissions decreases taken into
account. Emissions from press NR624 shall be calculated monthly and
annual emissions shall be determined each month using a 12 month rolling
average. The permitee shall limit the operations of press NR624 such
that emissions do not exceed the limitations in this condition for all
rolling 12 month periods. The permitee shall use the quantities and of
inks and other materials consumed by press NR624, the VOC and HAP
content of those materials, and the control efficiency of the carbon
absorption system as determined by the monitor required in condition VI
(E) to calculate emissions from press NR624. All solvent emissions from
the press systems shall be considered as both HAPs and VOC. *(Reference
40 CFR 52.21 - Note that press NR 624 was added as a minor modification
to a major source. The emissions limit therefore references the major
source limitations of 40 CFR 52.21, in that the press must not exceed
that limitation in order to remain minor.)*

4\. Emissions Offsets - The operator shall maintain all emissions
decreases used in the netting calculations as proposed in the
application for Authority to Construct which was issued by the Air
Quality Division of the District Health Department July 1, 1996.
*(Reference 40CFR 52.21).*

Page 7 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant

Title V Operating Permit

> 5\. Emissions Limits, NR630 -- All applicable record keeping
> provisions of 40 CFR 63 Subpart KK apply to the operations of press
> NR630. The operator will maintain records of all ink and other
> materials consumed in the operations of press NR630, and the VOC and
> HAP content of those materials. The permitee shall limit the
> operations of NR630 such that net emissions increase due to this press
> shall not exceed 45.4 tons per year, which is based on limiting press
> emissions to no more than 39.0 tons per year, with all banked
> creditable emissions decreases taken into account. Emissions from
> press NR630 shall be calculated monthly and annual emissions shall be
> determined each month using a 12 month rolling average. The permitee
> shall limit the operations of press NR630 such that emissions do not
> exceed the limitations in this condition for all rolling 12 month
> periods. The permitee shall use the quantities and of inks and other
> materials consumed by press NR630, the VOC and HAP content of those
> materials, and the control efficiency of the carbon absorption system
> as determined by the monitor required in condition VI (E) to calculate
> emissions from press NR630. All solvent emissions from the press
> systems shall be considered as both HAPs and VOC. *(Reference 40 CFR
> 52.21 - Note that press NR 630 is added as a minor modification to a
> major source. The emissions limit therefore references the major
> source limitations of 40 CFR 52.21, in that the press must not exceed
> that limitation in order to remain minor.)*

6\. Emissions Offsets - The operator shall maintain all emissions
decreases used in the netting calculations as proposed in the
application for Authority to Construct which was issued by the Air
Quality Division of the District Health Department January 26, 2005.
*(Reference 40CFR 52.21).*

**C. Special Conditions**

*\[PSD Permit \# NSR‑4‑7‑2, NV 84-01\].*

1\. [Air Pollution Control Equipment ‑]{.underline} The permittee shall
install, operate and maintain the following air pollution controls to
minimize emissions. The permittee shall operate the following control
devices for each production line as follows:

a\. An activated carbon adsorption system to control emissions from the
rotogravure press operations. All rotogravure presses shall be vented to
the carbon adsorption system which must capture enough of the solvents
from the presses to enable the facility to meet the requirements of the
printing and publishing MACT, 40 CFR, Subpart KK. The carbon adsorption
system will be maintained in good working condition in accordance with
designed operating specifications.

2\. [Fuel Usage and Sulfur Content]{.underline} The permittee shall
limit fuel consumption for all boiler systems as follows *(Reference PSD
permit NSR 4-7-2 NV-84-01 Condition IX. E (1) and (2)*:

a\. The No. 2 fuel oil fired as an auxiliary fuel shall contain no more
than 0.5% sulfur by weight.

b\. For Boilers Nos. 1-3, the permittee shall not burn more than 2.5
million gallons of No. 2 fuel oil in any 12 month period. For Boiler No.
4, the permitee shall not burn more than 1.0 million gallons of oil in
any 12 month period.

3\. [Monitoring of Operations and Record Keeping]{.underline} ‑ The
permittee shall record hours of operation for both the boilers and
presses, fuel use in boilers and sulfur content of the fuel oil, the
amount of solvents used in the gravure operations, gravure solvent
recovered, and calculated liquid-liquid balance results (as per 40 CFR
824(b)(1)(i)) for gravure operations for each calendar month. The
operator shall also keep records of materials needed to demonstrate
compliance with 40 CFR 829 (b)(1) and 40 CFR 63.10(b)(2). The permittee
shall furnish the District with a written report of gravure solvent use
and recovery for every calendar month, and a quarterly report to the
Regional Administrator of solvent use and recovery. *(Reference PSD
permit NSR 4-7-2 NV-84-01 Condition IX.J; Publishing MACT Standard, 40
CFR 63.824-830)*

4\. [Benzene Content Limitation]{.underline} - Ink and solvents used at
this facility shall contain no more than 0.1 percent benzene based on an
annual average. *(Reference PSD permit NSR 4-7-2 NV-84-01 Condition IX.
F)*

5\. [Sulfur Dioxide Emissions Limits]{.underline} - The permittee shall
not discharge or cause the discharge into the atmosphere Sulfur oxides
in excess of 51 lbs/hour (based on a 2 hour average) from boilers Nos.
1 - 3. The permittee shall not discharge or cause the discharge into the
atmosphere Sulfur oxides in excess of 14.5 lbs/hour from boiler 4.
*(Reference PSD permit NSR4-7-2 NV-84-01 Condition IX.G)*

6*.* [Operating Limits, All Rotogravure Presses]{.underline} - The
permitee shall limit the operations of each rotogravure press such that
no press operates for more than 6400 hours per year. Only hours where
the press is applying ink to product and the press is creating emissions
shall be counted as "in operation" and applied to the 6400-hour
limitation. Maintenance, repair and replacement operations shall not be
counted into the 6400 hours limitation. *(Reference PSD permit NSR4-7-2
NV-84-01 Condition IX.D (1))*

Page 8 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant

Title V Operating Permit

**D. Emission Standards for Boiler Operations.** *\[Washoe District*

*Health Dept. Control Requirements. 030.217\]*

1\. The permittee shall maintain the fuel burning equipment according to
manufacturers specifications.

2\. The operator must notify the Air Quality Management Division
whenever the primary fuel is switched from gas to oil or from oil to
gas. The notification must be made by the end of the next business day
following the change.

**E. Emission Standards for hydrocarbons from the Rotogravure Cylinder
Manufacture.** *\[Washoe*

*District Health Dept. Control Requirements. 030.217\]*

\*\* 1. Solvent containers used in the process must be covered whenever
practical to minimize emissions.

\*\* 2. Emissions from the rag dryer shall be vented into the Carbon
Adsorption system.

**F. Emission Standards for hydrocarbons from the Ink and Solvent
storage tanks.** *\[Washoe*

*District Health Dept. Control Requirements. 030.217\]*

\*\* 1. All equipment associated with delivery, storage, transfer and
loading operations shall be maintained in a leak free and vapor tight
condition and in good working order. During transfer and loading it
shall be permissible to vent the equipment to prevent over pressurizing
the system.

\*\* 2. All working loss emissions from the bulk storage tank and tank
farm ink and solvent storage tanks shall be vented into the Carbon
Adsorption system.

**G. Opacity Limits** *\[Washoe County Control Requirements pursuant to
040.005.A.\]*

Emissions from any single source shall not discharge into the atmosphere
emissions which equal or exceed 20% opacity for a period aggregating 3
minutes in any one hour. Opacity shall be determined by a trained and
qualified individual using the procedures for visual plume density
evaluation using the methods specified in USEPA method 9 as stated in 40
CFR 60 Appendix. A. Readings will be taken as necessary on equipment
repair or maintenance, but not less than once per month.

**H. Prohibited Emissions ‑ Dust and Fumes** *\[Washoe County Control
Requirements pursuant to*

*040.020\]*

> Emissions from the two (2) by‑product paper collection systems and
> their cyclone based pollution control devices shall not exceed the
> applicable process weight based emission limitations of 12.5 pounds
> per hour.

**I. Fuel Combustion Regulations:**

1\. *Pursuant to Washoe County Regulation 040.010 ‑* Emissions of
particulate matter shall not exceed 0.15 gr/dscf.

2\. *Pursuant to Washoe County Regulation 040.015 ‑* Emissions of SO2
shall not exceed 0.2% by volume.

**J. Chromium Electroplating Standards** *\[40 CFR § 63 Subpart N\]*

Under the requirements of 40 CFR 63 Subpart N, the plating portion of
this plant is classified as a hard chromium electroplating facility. The
permittee shall comply with the 0.015 mg/dscm emission standard and the
applicable work practice standards set forth in 40 CFR § 63 Subpart N.
The pressure drop across the mesh and filter control system shall be
between 1.4 and 3.4 inches of water (gauge). The facility shall have and
keep an operation and maintenance plan per the requirements of subpart
N.

**K. Printing and Publishing MACT Standard - Rotogravure Presses** *(40
CFR part 63, Subpart KK)*

Each publication rotogravure affected source shall limit emissions of
organic HAP to no more than eight percent of the total volatile matter
used each month. The emission limitation may be achieved by overall
control of at least 92 percent of organic HAP used, by substitution of
Non-HAP materials for organic HAP, or by a combination of capture and
control technologies and substitution of materials. The operator shall
demonstrate compliance by the use of the procedures described in 40 CFR
63.824 (b)(1)(i) -- Liquid-Liquid material balance.

Page 9 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant

Title V Operating Permit

> **L. Emissions Collection Enclosure** - The operator shall construct
> and maintain emissions
>
> control enclosures around both press NR624 and press NR630. The
> presses are at separate locations in the facility, and the enclosures
> are separate as well. The enclosures shall be rigid and stable and
> meet all the terms and requirements of a "permanent total enclosure"
> as described and defined in Federal EPA Method 204 (40 CFR part 51,
> Appendix M). All emissions captured in the enclosures shall be vented
> to the existing carbon adsorption system, and subject to MACT control
> requirements. *(Reference District Regulation 030.700 ).*
>
> **M. Large (100,000 Gallon) Solvent Storage Tank** - Working and
> breathing losses from the large solvent storage tank shall be vented
> to the gravure emissions control system. *(Reference District
> Regulation 030.217 ).*

\*\* **N. Prohibited Emissions -- Nuisance Odors** *\[Washoe Co.
Requirements pursuant to 040.055\]*

> Emissions from the Creo-Acigraf cylinder etching process line shall
> not discharge or cause the discharge of odorous emissions which result
> in confirmed violations of District regulations Governing Air Quality
> Management, specifically Section 040.055 (nuisance odors). Upon
> confirmation of a violation of the odor regulation, the operator must
> submit a plan to reduce the odorous emissions within 30 days of the
> notice by the Control Officer.
>
> **O. Chlorine Emissions Control** -- The operator will operator a
> packed tower wet scrubber system to control chlorine emission from the
> copper recovery for the cylinder etch systems. The scrubber shall be
> of a type approved by the Control Officer and will reduce chlorine
> emissions to acceptable nuisance odor levels. The operator will vent
> air from the copper recovery unit through this scrubber. The chlorine
> scrubber shall be properly maintained as per the manufacturers
> specifications. The unit shall be operated such that the pressure drop
> across the scrubber is within the range recommended by the
> manufacturer for optimum efficiency. The fluid used in the scrubber
> shall be maintained at proper levels, and shall be replaced as needed
> to maintain the scrubber's required efficiency. *(Reference District
> minor source permit dated May 25, 2004 ).*

P.  **Changes in Cylinder etching Chemicals -- Creo-Acigraf Process** --
    For any Future changes in the cleaning, coating, or etching
    solutions that will be used in the Creo-Acigraf cylinder etching
    process, including the degreaser, for which copies of the MSDS have
    not been previously supplied for this process, the permitee shall
    provide notification of the change to the District before the
    facility begins use of the new product. The permitee shall provide
    MSDS or other product information upon request. No specific permit
    approval or revision shall be required from the District before
    changing or adding new products, but the permitee shall maintain a
    list of all materials in use, along with the VOC content, HAP
    content and other information necessary to determine the emissions
    from these products. Emissions usage of all VOC containing materials
    related to this permit shall not exceed emission limits specified in
    condition 8. *(Reference District minor source permit dated May 25,
    2004).*

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Q.  **Minor Modification Limitations -- Creo-Acigraf Process** -- The
    permittee shall calculate annual emissions for the Creo-Acigraf
    portion of the cylinder making process each month. The results of
    the calculations will be reported with the annual facility emission
    reports. Annual emissions from the Creo-Acigraf cylinder etching
    process will not exceed in aggregate any of the following
    limitations: 15.8 tons per year for all volatile organics (VOCs);
    9.5 tons per year of any combination of Hazardous Air Pollutants.
    Compliance with the annual emission limits shall be calculated
    monthly, using the methodology specified in condition 13, and will
    be calculated on a rolling 12 month total. Emissions must remain
    below the limitations specified in this condition for all rolling
    12-month periods. *(Reference District minor source permit dated May
    25, 2004).*

R.  **Emissions Calculation Methodology -- Creo-Acigraf Process** -- The
    permittee shall maintain records of the usage, VOC and HAP content
    of the cleaning materials, coatings etching solutions and other
    materials containing VOC used in the process on a monthly basis. The
    permitee shall calculate monthly VOC emissions from the Creo-Acigraf
    cylinder etching process using mass balance methods, based on the
    material consumption and VOC content of the materials as provided by
    the manufacturer, and assuming 100% of the VOC in the materials are
    released into the atmosphere. All required records of materials
    consumption and composition and VOC emissions, plus any records of
    operation which affect the potential of the source to emit air
    pollutants, such as fuels or products consumed, products produced,
    hours of operation, chemicals or supplies used in source operation,
    must be maintained for a period of at least 5 years and made
    available to the Control Officer upon request. *(Reference District
    minor source permit dated May 25, 2004).*

Page 10 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant

Title V Operating Permit

**VI. Monitoring and Compliance** *Pursuant to PSD Permit \# NSR4‑7‑2,
NV 84-01, 40 CFR 70.6 (c) and Washoe County Regulations 030.218 &
030.9701­* This section fulfills the requirements of 030.960 (C) for
periodic monitoring.

**A. General**

1\. Pursuant to District regulation 030.218, the Control Officer may
require the permittee to provide any applicable data to demonstrate
compliance with permit conditions.

2\. Pursuant to District regulation 020.075, the permittee shall notify
the Control Officer within two (2) hours after the occurrence or within
two (2) hours of opening on the next business day of any event (upset,
breakdown, or scheduled maintenance) resulting in excess emissions. A
written report must be submitted to the Control Officer and the Regional
Administrator within fifteen (15) days of the event. Phone notification
of any event (upset, breakdown, or scheduled maintenance) resulting in
excess emissions must be made to the Regional Administrator within 48
hours.

**B. Monitoring, Testing And Record Keeping** ‑ The permittee shall
record:

1\. The quantity of fuel (natural gas, propane or No. 2 fuel oil) burned
in the boilers and the sulfur content of the No. 2 fuel oil burned.
Emissions estimations from these units shall be based on records of fuel
consumption and AP42 factors for commercial boilers (10‑100 MMBTU/hr) or
other equivalent emission factors as approved by the Control Officer.

2\. The boilers will be operated so that visible emissions from the
exhaust stack do not exceed 20% opacity for more than 3 minutes per
hour. The permittee will verify compliance with this requirement by
performing regular maintenance on the systems combined with regular
visual evaluations of opacity. The permittee will conduct one opacity
observation by an EPA Reference Method 9 certified VE reader at least
once during each period when the boilers are burning No. 2 fuel oil, but
no less than once per week.

3\. The amount of volatile organics used in and recovered from gravure
operations and the resultant overall solvent recovery efficiency and
emissions calculated for each calendar month. The volatile matter (VOC)
content of all volatile materials shall be determined using methods
specified in 40CFR 63.827(c)(1-3). The VOC information shall include the
specific contents of both benzene and toluene for each solvent
containing product used in the rotogravure press systems. A test to
determine the benzene and toluene content of the solvent shall be
performed at least once during the term of this permit, but is not
required for each monthly report. The organic HAP content of these
materials shall be calculated using methods specified in 40CFR
63.827(b)(1)(i-iii). The calculations of volatile matter and HAP as
required under 40CFR 63.827(b)(1) and 40CFR 63.827(c) shall consider all
inks, coatings, varnishes, adhesives primers, solvents thinners,
reducers, thinners and other materials considered for the purposes of
meeting the requirements of 40 CFR 824. The permitee shall furnish a
written report of solvent use and recovery to the EPA administrator
quarterly. *(Reference 40 CFR 60 Subpart QQ - Standards for Publication
Rotogravure Printing.; Rotogravure MACT Standard -- 40CFR 63.827(b)(1)
and 40CFR 63.827(c)(1); PSD Permit \# NSR4‑7‑2 Condition IX C.1).*

4\. Solvent Cleaning Cylinder Preparation and Proof Press Operations -
The total annual consumption of solvents in both cylinder preparation
and all proof press operations shall be limited to no more than 13000
gallons of solvent. The operator shall track the solvent consumption of
the cylinder preparation process and limit operations as required. The
operator shall also track the solvent and ink consumption of this proof
press and limit operations as required. *(Reference 40 CFR 52.21 ).*

5\. Chromium emissions from the chrome plating line. Calculation of the
emissions shall be based on the results of the emission performance test
required by 40 CFR 63 Subpart N. The permittee shall comply with the
0.015 mg/dscm emission standard and work practices for composite mesh
pad systems set forth in 40 CFR § 63 Subpart N for the two (2) gravure
cylinder chromium plating tanks. The operator shall also record daily
observations of the pressure drop across the mesh and filter control
system. The pressure drop shall be between 1.4 and 3.4 inches of water
(gauge).

\*\* 6. Emissions of particulate matter from the pneumatic paper
collection systems shall be determined based on the records of annual
throughput and an emission factor of 1.78 lb/ton of by‑product paper
processed through the cyclones. Visual observations of opacity will be
performed and recorded on a regular basis to verify proper operation of
the by‑product paper cyclones. Observations will be performed not less
than once per month.

7\. Hourly data from any continuous monitoring system specified in the
conditions of this permit may be maintained an optical or
Magnetic/electronic format. However, the permittee must maintain the
capability of reading the electronic media and providing a report, on
paper, to the Air Quality Division upon request as per the provisions of
District Regulation 030.217.

Page 11 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant

Title V Operating Permit

8\. The operator shall demonstrate compliance with the requirements of
40 CFR 63.824 - Standards for Publication Rotogravure Printing. The
procedure to be used shall be the one described in 40 CFR 63.824
(b)(1)(i). Because compliance with this standard will be demonstrated by
means of a liquid-liquid materials balance, no capture efficiency
performance test will be required.

**C. Compliance Reporting & Certification**

**1. Annual Emissions Report and Certification Statement**

In order to demonstrate compliance with the provisions of this permit,
the permittee shall submit an Annual Emissions Report and Certification
Statement by the anniversary date of the permit describing the emissions
of regulated pollutants for the previous calendar year, pursuant to
Washoe County Regulations 030.219 and 030.970.The compliance statement
shall address each term or condition of operation on an item by item
basis. The compliance statement shall contain the following:

**1)** Identification of each term or condition of operation that is the
basis for certification.

**2)** The compliance status of the facility with respect to each term
or condition of operation and a statement that the operator will
continue to comply with such requirements.

**3)** Whether the compliance with each term or condition of operation
was continuous or intermittent.

**4)** The method(s) used for determining the compliance status of the
source including a description of monitoring, record keeping and
reporting requirements, and test methods.

**5)** For any term or condition of operation for which the source is
not in compliance, the source must submit a compliance schedule and a
narrative description of how the source will achieve compliance with
such requirements as described in 030.970 (B) of these regulations.

**6)** For any source for which the Control Officer has established
requirements for progress reports on compliance schedules, the source
must provide these progress reports in a timely manner and address dates
milestones and other activities that have been specified by the Control
Officer. The progress report shall also include the dates on which any
milestones were achieved and an explanation of any dates or milestones
that were not or are not expected to be met, why they were not met and
any corrective actions to be taken as a result.

**7)** Any other specific information needed to determine compliance as
required by the Control Officer.

**8)** A certification of the truth, accuracy and completeness of the
compliance statement by a responsible official.

**9)** Any additional requirements as may be specified pursuant to
sections 114(a) and 504(b) of the Act.

All Statements of compliance must be made in writing to both the EPA
Administrator as well as to the Control Officer. Failure to submit a
statement of compliance in a timely manner may result in citation,
penalties, suspension or revocation of the Part 70 permit. .
*((Reference 40 CFR 70.6 (c)(1); Clean Air Act (1990 Revisions) Section
182 (a)(3)(b) and Section 184 (b)(2)).*

Page 12 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant Title V Operating Permit

> **2. Semi-Annual Emissions Monitoring Report and Certification
> Statement**
>
> In order to demonstrate compliance with the provisions of 40 CFR
> 70.6(a)3, the permitee shall submit a report of any required
> monitoring at least every 6 months*.* All instances of non-compliance
> with the permit shall be clearly identified. At a minimum, the report
> shall include the following:
>
> **1)** A report of any Start-up, shutdown or malfunction as required
> in *40* *CFR 63.830(b) 5* of the Printing and Publishing MACT
> *(Subpart KK)*
>
> **2)** A summary report of any emission exceedance as required in *40*
> *CFR 63.830(b) 6* of the Printing and Publishing MACT *(Subpart KK)*
>
> **3)** A summary report of liquid -- liquid mass balance emissions
> results as calculated per *40* *CFR 63.824(b)1(*i*)* of the Printing
> and Publishing MACT *(Subpart KK)*
>
> **4)** A report of pressure drop observations across the Chrome
> plating exhaust emissions control system as require in 40 CFR 63
> Subpart N.
>
> **5)** A summary report of all opacity observation results.
>
> **6)** A certification of the truth, accuracy and completeness of the
> monitoring report statement by a responsible official, consistent with
> 40 CFR 70.5(d).

**D. Fee Payment**

\*\* Permit fees shall be assessed by the District and paid by the
permittee pursuant to Washoe County Regulations 030.300‑030.330, based
on the Annual Emissions Report submitted in compliance with Part VI.C.
of this permit.

**E. Emissions testing and Periodic Monitoring**

1\. The permittee will install and operate an emissions monitoring
system to track the volatile

organic compound concentration of both the input and exhaust gases from
the carbon bed adsorption solvent recovery system. The primary purpose
of this device is to monitor the carbon adsorption system for
breakthrough. An additional usage is that presses NR624 and NR630 will
use the capture efficiency across the carbon adsorption system as
measured by this device to calculate their emissions. The monitoring
device shall be calibrated at least annually, and more often if
necessary to insure accurate readings. The monitor shall be an NDIR
design or equivalent as approved by the Control Officer. Emissions from
the presses must be determined based on the liquid-liquid mass balance
efficiency for the carbon bed adsorption solvent recovery system as
specified in the Rotogravure MACT. It is both allowable and understood
that the monitor shall operate in a semi-continuous mode, cycling back
and forth between several intake points in sequence in order to monitor
the overall efficiency of the collection system. The location of input
gas collection probe shall be downstream of the all press dryer
collection ducts. The exhaust probe shall be at least 3 stack diameters
distance upstream from the exhaust exit point or some equivalent point
as approved by the Control Officer. (*Reference Washoe County Regulation
030.700)*.

**VII. Permit Term** *Pursuant to 40 CFR § 70.6(a)(1) and District
Regulation 030.910*

This permit shall be valid for a period of five (5) years from the date
of issuance.

**VIII. Permit Expiration and Renewal** *Pursuant to District Regulation
030.9201*

The right to operate terminates on the permit expiration date. If a
written application for renewal of the permit is submitted at least six
(6) months (but not more than 12 months) prior to expiration, the
permittee may continue to operate equipment in accordance with the
conditions of the previous Title V permit until final action is taken by
the District on the renewal application.

**IX. Permit Modifications** *Pursuant to 40 CFR §70.7(d) and (e) and
District Regulation 030.950*

This permit may be modified to reflect changes in operation, procedure,
ownership or other provisions as necessary. Any modification other than
normal repair and maintenance, or a change which is not allowed under
the operation of this permit or District regulation 030.950, shall
require a revised or new Permit. If a new or revised permit is required,
the operator shall make application to the Control Officer and follow
the procedures as specified in District Regulation 030.950.

Page 13 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant Title V Operating Permit

> **IX. Permit Modifications (Continued)**
>
> The statue of limitations for construction of any equipment under the
> 1984 PSD permit has expired. No new equipment may be installed under
> the provisions of that permit. This restriction does not include
> normal repair and maintenance of existing equipment installed previous
> to the issuance of this permit as allowed under federal or District
> rules. Installation or construction of any new presses, including any
> offset presses, would require that Donnelley seek and obtain new
> pre-construction permits, and revision of the Title V permit, as
> applicable, depending on the nature of the proposed modification.

Page 14 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant Title V Operating Permit

ATTACHMENT A ‑ EQUIPMENT SCHEDULE

**NOTE -** The following is a complete list of the equipment (except
insignificant sources) from which emissions are allowed under this
permit:

1\. GRAVURE PRESS NR 624

2\. GRAVURE PRESS N R 625

3\. GRAVURE PRESS NR 626

4\. GRAVURE PRESS N R 627

5\. GRAVURE PRESS N R 628

6\. GRAVURE PRESS N R 629

7\. GRAVURE PROOF PRESS NCM 649

8\. NCM CORRECTION / CLEANING SINKS (3)

9\. NCM WIPES DRYER

10\. NCM GRAVURE CYLINDER & PARTS WASHER

11\. BULK (100,000 GALLON) SOLVENT STORAGE TANK

12\. SECONDARY SOLVENT STORAGE TANKS (1 @ 2400 GALLONS)

13\. TANK FARM TANKS (16)

NUMBER MATERIAL STORED CAPACITY (GALS)

1 TO 10 GRAVURE INKS AND VARNISH 8,000 (EACH)

11 TO 14 GRAVURE SOLVENT 10,000 (EACH)

15 GRAVURE INK 5,400

16 VARNISH 5,400

14\. CARBON BED ADSORPTION SOLVENT RECOVERY SYSTEM

15\. GRAVURE CYLINDER CHROMIUM PLATING TANKS (2)

16\. BY‑PRODUCT PAPER CYCLONES (2)

17\. BOILERS (Nos. 1-3), each rated at 29.291 MMBTU

18\. BOILER No. 4 rated at 28.41 MMBTU

Page 15 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant Title V Operating Permit

ATTACHMENT B ‑ EMISSIONS INVENTORY TABLE

**NOTE -** EMISSION FIGURES PRESENTED IN THIS TABLE REPRESENT GOOD FAITH
ESTIMATES OF EMISSIONS SUBJECT TO REGULATION, AS SET FORTH IN THE PERMIT
APPLICATION.

EMISSION EQUIPMENT AIR POTENTIAL EMISSIONS

SOURCE(S) SCHEDULE CONTAMINANT (TONS/YR)

NUMBER(S) (With Controls as applicable)

HAPS

Gravure Solvent 1 - 14, VOC (total) 2544.9

Operations Toluene (HAP) 2468.5

Ethyl Benzene (HAP) 25

Xylenes (HAP) 38

Hexane (HAP) 38

Chromium 15 Chromium (HAP) 0.0123 0.0245

Plating Tanks

By‑Product 16 Particulate 28.1

Paper Cyclones

Boilers 17, 18 VOC 1.33

CO 17.12

N0x 68.45

Particulate 6.75

S02 124.39

Lead (HAP) 0.0022 0.0022

Page 16 of 19

**R. R. Donnelley & Sons Company ‑ Reno Plant Title V Operating Permit**

ATTACHMENT C ‑ LIST OF INSIGNIFICANT ACTIVITIES

No source which is subject to any applicable requirement can be included
in the following list. If an applicable requirement is promulgated or
any change is made subjecting the source to any applicable requirement,
the source can no longer be considered as \"insignificant\".

[LOCATION]{.underline} [EMISSION SOURCE]{.underline}

Administration Building Computer Fire Protection (Halon)

Electrostatic Copiers

Laser Printers

Blueprint Machine (Ammonia)

Bathrooms Sewer Gas (Methane)

Battery Charging Area Recharging Batteries (Fumes)

Bindery Lubrication Oils

Building Operations Chemical Storage Working Losses

Emergency Generator (500 KW)

Emergency Generator Fuel Tank (300 gals No. 2)

Propane Storage Tanks

Propane Vaporizer

Bulk No. 2 Fuel Oil Storage Tank (150,000 gals)

Two (2)Fire Pumps

Fire Pump Diesel Storage Tanks ( 2 @ 300 gals)

Cylinder Making Re‑etch \"Ink\"

Lubricating Oil for Polishmaster

Various Commercial Cleaners

Fire Protection System (Halon)

Helio Klishograph Lubricating Solution

Ethanol

Asphaltum

Photoflo

Lacquer/Thinner

3 Copper Plating Tanks

Dechrome Tank (Sulfuric Acid)

Electrical Equipment Room High Voltage Transformers (Ozone)

Gravure Pressroom Flexographic Imprinter (Press NR626)

(Upper) Vacuum Systems (Dust)

Silicone Applicators (Presses 624, 625, 626, 627, 628, 629)

(Lower) Paster Glue

Maintenance Welding Fumes \"Spray\" Welding

Acetylene

Metal Grinding, Cutting & Milling

Metal Working Coolants/Lubricants

Mechanical Equipment Room Air Compressors (Oil Fumes)

Two (2) Chillers (Refrigerants)

Cooling Towers

**\*\*NOTE\*\*** These cooling units are **not** subject to the
Industrial Cooling Tower MACT - 40 CFR 63 Subpart Q. No Chrome is used.

Page 17 of 19

**R. R. Donnelley & Sons Company ‑ Reno Plant Title V Operating Permit**

LIST OF INSIGNIFICANT ACTIVITIES - Continued

[LOCATION]{.underline} [EMISSION SOURCE]{.underline}

Paper Roll Stock & Finished Goods Plastic Strap Sealing Operation

Storage Propane Forklift Truck (Combustion)

Propane Forklift Truck Fueling Operations

Trackmobile (Railcar Spotting Tractor)

Platemaking Imprinter Platemaking

Forklift Repair Parts Washers

Offline Bindery \" \"

Roller Grinder \" \"

Gravure Pressroom \" \"

Maintenance Shop \" \"

Wastewater \"Metals\" Treatment Wastewater Storage & Treatment Tank
Fumes

General Pump\\Motor Lubricants

Electrical Ozone (i.e. tubes, transformers, video)

Water Coolers (Refrigerant)

Janitorial Supplies

Spray Lubricants (i.e. WD40)

Electrical Contact Cleaner

Landscape & Grounds Maintenance Equipment

Road Dust

Page 18 of 19

R. R. Donnelley & Sons Company ‑ Reno Plant

Title V Operating Permit

ATTACHMENT D ‑ COMPLIANCE CERTIFICATION STATEMENT

This document and any additional reports or compliance certifications
submitted with this document shall be certified by a responsible
official for truth, accuracy, and completeness. Submission of fraudulent
data or information may be deemed a criminal violation. This document is
submitted in accordance with the provisions of Section 030.970, and
under penalty of forgery, to the best of my knowledge after reasonable
inquiry, the information in this document is true, accurate and
complete.

Signature of Responsible Official Date

Print or Type Name and Title

Page 19 of 19