Facility DEC ID: 9143000213

 PERMIT

 Under the Environmental Conservation Law (ECL)

IDENTIFICATION INFORMATION

Permit Type: Air Title V Facility

Permit ID: 9-1430-00213/00110

Effective Date: 08/30/2007 Expiration Date: 08/29/2012

Permit Issued To: QUEBECOR WORLD BUFFALO INC

2475 GEORGE URBAN BLVD

DEPEW, NY 14043-2019

Contact: ROBERT J SCHEIFFLEE

QUEBECOR PRINTING BUFFALO INC

2475 GEORGE URBAN BLVD

DEPEW, NY 14043

(716) 686-2730

Facility: QUEBECOR WORLD BUFFALO INC

2475 GEORGE URBAN BLVD

DEPEW, NY 14043-2098

Contact: JANET E SCHMIDT

QUEBECOR WORLD BUFFALO INC

2475 GEORGE URBAN BLVD

DEPEW, NY 14043-2098

(716) 686-2500

Description:

Quebecor World Buffalo, Inc. is a commercial printing facility situated on 69 acres of property in the 

Village of Depew, Erie County, New York. The main building for the facility has approximately 850,000 

square feet of floor space which houses six rotogravure presses, eitght offset presses, and six flexographic 

presses. Other operations used to support the printed product include prepress imaging, cylinder 

engraving, perfect binding lines, and saddle stitched binding lines. The SIC code for this facility is 2754 - 

Commercial Printing, Gravure.

The facility potential emissions of sulfur dioxide, oxides of nitrogen, volatile organic compounds, toluene, 

and xylene exceed the major source thresholds for Title V applicability. As such, the facility is subject to 

the permitting requirements stated in 6 NYCRR Part 201-6. The printing operations are subject to the 

Reasonably Available Control Technology (RACT) provisions of 6NYCRR Part 234 and the Maximum 

Achievable Control Technology (MACT) requirements of 40 CFR63 Subpart KK. One of the 

rotogravure printing presses must comply with the New Source Performance Standards (NSPS) 

specified in 40CFR60 Subpart QQ. Other operations at the facility associated with the printing 

production include a hard chromium electroplating process which is applicable to the MACT standard 

specified in 40CFR63 Subpart N and surface coating operations subject to the RACT requirements of 

6NYCRR Part 228.

Renewal 1/FINAL
Facility DEC ID: 9143000213

The Title V permit includes nine emission units identified as E-G0001 through E-G0009. A brief 

description of each emission unit and the associated processes are provided below:

E-G0001 includes eight book bindery trimmers and three inserter trimmers which produce paper 

trimmings sent for recycling. Four cyclones, used to control emissions of particulate matter, exhaust to 

five baghouses which discharge air back into the main building;

E-G0002 includes seven offset, cold set lithographic printing presses and one offset heatset press. The 

eight six presses control VOC emissions through the VOC content of the fountain solution. In addition, 

Press 200 of process 02B uses a catalytic afterburner to control odors and opacity. Ink emissions from 

non-heatset operations are controlled by low vapor pressure ink oils. 95% of the ink oil applied to the 

web substrate stays in the web permanently. Ink emissions from heatset are also controlled by low vapor 

pressure ink oils. None of the ink oils emit ahead of the dryer. After passing through the dryer, 20% 

remain with the web and the balance are routed to a catalytic afterburner where 95% of them are 

destroyed;

E-G0003 includes three dual fuel package boilers each with a maximum heat input capacity of 25 

mmBtu/hr. The boilers were constructed prior to June 9, 1989 and, thus, are not subject to 40CFR60 

Subpart Dc. The boilers are capable of burning no. 4, 5, or 6 fuel oil or natural gas. . The sources 

comply with the annual tune-up requirement to satisfy NOx RACT. All three of the boilers are subject to 

the initial notification requirements of 40CFR63 Subpart DDDDD;

E-G0004 includes six rotogravure printing presses. The VOC emissions from all presses are controlled 

by a solvent recovery system. In addition, the HAP emissions from all presses are subject to 40CFR63 

Subpart KK;

E-G0005 includes two hard chromium electroplating tanks. Chromium emissions are subject to 

40CFR63 Subpart N. The facility uses a fume suppressant and add-on control devices to control 

chromium emissions from the tanks;

E-G0006 includes eight book binders. Process 06A includes the process of melting and applying glue to 

the books. Process 06B includes the staining of the book edges. The VOC emissions from these sources 

are controlled by limiting the volatile fraction of the glue and stain;

E-G0007 includes three horizontal carbon steel tanks each with a capacity of 10,000 gallons. The tanks 

are exempt from 6NYCRR Part 229 because they are horizontal. In addition, the tanks do not qualify for 

40CFR60 Subpart Kb due to the size being less than 40 cubic meters. This emission unit has no 

associated conditions in the Title V permit;

E-G0008 includes six flexographic presses. VOC emissions are controlled by limiting the volatile 

fraction of the ink; and

E-G0009 includes nine ink jet printing operations. VOC emissions are controlled by limiting the volatile 

fraction of the ink.

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Facility DEC ID: 9143000213

By acceptance of this permit, the permittee agrees that the permit is contingent upon strict compliance

with the ECL, all applicable regulations, the General Conditions specified and any Special Conditions

included as part of this permit.

Permit Administrator: DAVID S DENK

 DIVISION OF ENVIRONMENTAL PERMITS

 270 MICHIGAN AVE

 BUFFALO, NY 14203-2999

Authorized Signature: _________________________________ Date: ___ / ___ / _____

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Facility DEC ID: 9143000213

Notification of Other State Permittee Obligations

Item A: Permittee Accepts Legal Responsibility and Agrees to Indemnification

The permittee expressly agrees to indemnify and hold harmless the Department of Environmental

Conservation of the State of New York, its representatives, employees, and agents ("DEC") for all

claims, suits, actions, and damages, to the extent attributable to the permittee's acts or omissions

in connection with the permittee's undertaking of activities in connection with, or operation and

maintenance of, the facility or facilities authorized by the permit whether in compliance or not in

compliance with the terms and conditions of the permit. This indemnification does not extend to

any claims, suits, actions, or damages to the extent attributable to DEC's own negligent or

intentional acts or omissions, or to any claims, suits, or actions naming the DEC and arising

under article 78 of the New York Civil Practice Laws and Rules or any citizen suit or civil rights

provision under federal or state laws.

Item B: Permittee's Contractors to Comply with Permit

The permittee is responsible for informing its independent contractors, employees, agents and 

assigns of their responsibility to comply with this permit, including all special conditions while

acting as the permittee's agent with respect to the permitted activities, and such persons shall

be subject to the same sanctions for violations of the Environmental Conservation Law as

those prescribed for the permittee.

Item C: Permittee Responsible for Obtaining Other Required Permits

The permittee is responsible for obtaining any other permits, approvals, lands, easements and

rights-of-way that may be required to carry out the activities that are authorized by this

permit.

Item D: No Right to Trespass or Interfere with Riparian Rights

This permit does not convey to the permittee any right to trespass upon the lands or interfere

with the riparian rights of others in order to perform the permitted work nor does it authorize

the impairment of any rights, title, or interest in real or personal property held or vested in a

person not a party to the permit.

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Facility DEC ID: 9143000213

LIST OF CONDITIONS

 

DEC GENERAL CONDITIONS

General Provisions

Facility Inspection by the Department

Relationship of this Permit to Other Department Orders and Determinations

Applications for permit renewals, modifications and transfers

Applications for Permit Renewals and Modifications

Permit modifications, suspensions or revocations by the Department

Permit Modifications, Suspensions and Revocations by the Department

Facility Level

Submission of application for permit modification or renewal-REGION 9 

HEADQUARTERS

 DEC Permit Conditions

Page 1 of 4 Renewal 1/FINAL
Facility DEC ID: 9143000213

 DEC GENERAL CONDITIONS

 **** General Provisions  

For the purpose of your Title V permit, the following section contains state-only enforceable

 terms and conditions

GENERAL CONDITIONS - Apply to ALL Authorized Permits.

Condition 1: Facility Inspection by the Department

Applicable State Requirement: ECL 19-0305

Item 1.1:

The permitted site or facility, including relevant records, is subject to inspection at reasonable hours and 

intervals by an authorized representative of the Department of Environmental Conservation (the 

Department) to determine whether the permittee is complying with this permit and the ECL. Such 

representative may order the work suspended pursuant to ECL 71-0301 and SAPA 401(3).

Item 1.2:

The permittee shall provide a person to accompany the Department's representative during an inspection 

to the permit area when requested by the Department.

Item 1.3:

A copy of this permit, including all referenced maps, drawings and special conditions, must be available 

for inspection by the Department at all times at the project site or facility. Failure to produce a copy of 

the permit upon request by a Department representative is a violation of this permit.

Condition 2: Relationship of this Permit to Other Department Orders and Determinations

Applicable State Requirement: ECL 3-0301.2(m)

Item 2.1:

Unless expressly provided for by the Department, issuance of this permit does not modify, supersede or 

rescind any order or determination previously issued by the Department or any of the terms, conditions or 

requirements contained in such order or determination.

Condition 3: Applications for permit renewals, modifications and transfers

Applicable State Requirement: 6NYCRR 621.11

Item 3.1:

The permittee must submit a separate written application to the Department for renewal, modification or 

transfer of this permit. Such application must include any forms or supplemental information the 

Department requires. Any renewal, modification or transfer granted by the Department must be in 

writing.

Item 3.2:

The permittee must submit a renewal application at least 180 days before expiration of permits for Title 

V Facility Permits, or at least 30 days before expiration of permits for State Facility Permits. 

Item 3.3:

 DEC Permit Conditions

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Facility DEC ID: 9143000213

Permits are transferrable with the approval of the department unless specifically prohibited by the statute, 

regulation or another permit condition. Applications for permit transfer should be submitted prior to 

actual transfer of ownership.

Condition 4: Applications for Permit Renewals and Modifications

Applicable State Requirement: 6NYCRR 621.13

Item 4.1:

The permittee must submit a separate written application to the Department for renewal, modification or 

transfer of this permit. Such application must include any forms or supplemental information the 

Department requires. Any renewal, modification or transfer granted by the Department must be in 

writing.

Item 4.2:

The permittee must submit a renewal application at least 180 days before expiration of permits for Title V 

Facility Permits, or at least 30 days before expiration of permits for State Facility Permits. 

Item 4.3:

Permits are transferrable with the approval of the department unless specifically prohibited by the statute, 

regulation or another permit condition. Applications for permit transfer should be submitted prior to actual 

transfer of ownership.

Condition 5: Permit modifications, suspensions or revocations by the Department

Applicable State Requirement: 6NYCRR 621.13

Item 5.1:

The Department reserves the right to modify, suspend, or revoke this permit in accordance with 

6NYCRR Part 621. The grounds for modification, suspension or revocation include:

a) materially false or inaccurate statements in the permit application or supporting papers;

b) failure by the permittee to comply with any terms or conditions of the permit;

c) exceeding the scope of the project as described in the permit application;

d) newly discovered material information or a material change in environmental conditions, 

relevant technology or applicable law or regulations since the issuance of the existing permit;

e) noncompliance with previously issued permit conditions, orders of the commissioner, any 

provisions of the Environmental Conservation Law or regulations of the Department 

related to the permitted activity.

Condition 6: Permit Modifications, Suspensions and Revocations by the Department

Applicable State Requirement: 6NYCRR 621.14

Item 6.1:

The Department reserves the right to modify, suspend, or revoke this permit in accordance with 6NYCRR 

Part 621. The grounds for modification, suspension or revocation include:

a) materially false or inaccurate statements in the permit application or supporting papers;

b) failure by the permittee to comply with any terms or conditions of the permit;

 DEC Permit Conditions

Page 3 of 4 Renewal 1/FINAL
Facility DEC ID: 9143000213

c) exceeding the scope of the project as described in the permit application;

d) newly discovered material information or a material change in environmental conditions, 

relevant technology or applicable law or regulations since the issuance of the existing permit;

e) noncompliance with previously issued permit conditions, orders of the commissioner, any 

provisions of the Environmental Conservation Law or regulations of the Department 

related to the permitted activity.

 ** ** Facility Level  

Condition 7: Submission of application for permit modification or renewal-REGION 9 

HEADQUARTERS

Applicable State Requirement: 6NYCRR 621.6(a)

Item 7.1:

Submission of applications for permit modification or renewal are to be submitted to:

NYSDEC Regional Permit Administrator 

Region 9 Headquarters

Division of Environmental Permits

270 Michigan Avenue

Buffalo, NY 14203-2999

(716) 851-7165

 DEC Permit Conditions

Page 4 of 4 Renewal 1/FINAL
Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Permit Under the Environmental Conservation Law (ECL)

 ARTICLE 19: AIR POLLUTION CONTROL - TITLE V PERMIT

IDENTIFICATION INFORMATION

Permit Issued To: QUEBECOR WORLD BUFFALO INC

2475 GEORGE URBAN BLVD

DEPEW, NY 14043-2019

Facility: QUEBECOR WORLD BUFFALO INC

2475 GEORGE URBAN BLVD

DEPEW, NY 14043-2098

Authorized Activity By Standard Industrial Classification Code:

2754 - COMMERCIAL PRINTING, GRAVURE

2759 - COMMERCIAL PRINTING, NEC

9999 - NONCLASSIFIABLE ESTABLISHMENTS

Permit Effective Date: 08/30/2007 Permit Expiration Date: 08/29/2012

 Air Pollution Control Permit Conditions

Renewal 1 Page 1 of 86 FINAL
Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

LIST OF CONDITIONS

 

FEDERALLY ENFORCEABLE CONDITIONS

Facility Level

1 6NYCRR 200.6: Acceptable Ambient Air Quality

2 6NYCRR 201-6.5(a)(7): Fees

3 6NYCRR 201-6.5(c): Recordkeeping and reporting of compliance monitoring

4 6NYCRR 201-6.5(c)(2): Monitoring, Related Recordkeeping, and 

Reporting Requirements.

5 6NYCRR 201-6.5(c)(3)(ii): Compliance Certification

6 6NYCRR 201-6.5(e): Compliance Certification

7 6NYCRR 202-2.1: Compliance Certification

8 6NYCRR 202-2.5: Recordkeeping requirements

9 6NYCRR 215: Open Fires Prohibited at Industrial and Commercial Sites

10 6NYCRR 200.7: Maintenance of Equipment

11 6NYCRR 201-1.7: Recycling and Salvage

12 6NYCRR 201-1.8: Prohibition of Reintroduction of Collected 

Contaminants to the air

13 6NYCRR 201-3.2(a): Exempt Sources - Proof of Eligibility

14 6NYCRR 201-3.2(a): Compliance Certification

15 6NYCRR 201-3.3(a): Trivial Sources - Proof of Eligibility

16 6NYCRR 201-6.5(a)(4): Standard Requirement - Provide Information

17 6NYCRR 201-6.5(a)(8): General Condition - Right to Inspect

18 6NYCRR 201-6.5(d)(5): Standard Requirements - Progress Reports

19 6NYCRR 201-6.5(f)(6): Off Permit Changes

20 6NYCRR 202-1.1: Required Emissions Tests

21 6NYCRR 211.3: Visible Emissions Limited

22 40CFR 68: Accidental release provisions.

23 40CFR 82, Subpart F: Recycling and Emissions Reduction

24 6NYCRR 200.3: False statement

25 6NYCRR 201-6: Emission Unit Definition

26 6NYCRR 212.6(a): Compliance Certification

27 6NYCRR 234.1(g): Compliance Certification

28 6NYCRR 234.3(e): Compliance Certification

29 6NYCRR 234.6: Handling, storage, and disposal of volatile organic 

compounds

30 40CFR 60.4, NSPS Subpart A: EPA Region 2 address.

31 40CFR 60.434(a), NSPS Subpart QQ: Compliance Certification

32 40CFR 63.6(e)(3), Subpart A: Compliance Certification

Emission Unit Level

33 6NYCRR 201-6: Emission Point Definition By Emission Unit

34 6NYCRR 201-6: Process Definition By Emission Unit

 EU=E-G0002,Proc=02A

35 6NYCRR 234.3(b)(2): Compliance Certification

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

 EU=E-G0002,Proc=02B

36 6NYCRR 234.3(b)(1): Compliance Certification

 EU=E-G0002,Proc=02B,ES=EQ200

37 6NYCRR 234.4(c)(2): Compliance Certification

 EU=E-G0003

38 6NYCRR 225-1.2(a)(2): Compliance Certification

39 6NYCRR 225-1.8(a): Compliance Certification

40 6NYCRR 227-1.3(a): Compliance Certification

41 6NYCRR 227-2.4(d): Compliance Certification

42 40CFR 63.7506(b), Subpart DDDDD: Compliance Certification

 EU=E-G0004

43 6NYCRR 234.4(c)(3): Compliance Certification

44 40CFR 60.7(b), NSPS Subpart A: Recordkeeping requirements.

45 40CFR 60.11(d), NSPS Subpart A: Compliance with Standards and 

Maintenance Requirements

46 40CFR 60.435, NSPS Subpart QQ: Compliance Certification

47 40CFR 63.823, Subpart KK: Part 63 General Provisions requirements

48 40CFR 63.824(b)(1)(i), Subpart KK: Compliance Certification

49 40CFR 63.827(a)(3), Subpart KK: Exemption from performance test for 

solvent recovery devices

50 40CFR 63.827(b)(1), Subpart KK: Compliance Certification

51 40CFR 63.829(b), Subpart KK: Compliance Certification

52 40CFR 63.829(c), Subpart KK: Compliance Certification

53 40CFR 63.830(b)(5), Subpart KK: Compliance Certification

 EU=E-G0004,Proc=04A,ES=EQ210

54 6NYCRR 234.3(a)(3)(i): Compliance Certification

 EU=E-G0005

55 6NYCRR 212.4(b): Compliance Certification

56 40CFR 63.340(b), Subpart N: Part 63 General Provisions requirements

57 40CFR 63.342(b)(1), Subpart N: Standards apply during all tank operation

58 40CFR 63.342(c)(3), Subpart N: Compliance Certification

59 40CFR 63.342(f), Subpart N: Compliance Certification

60 40CFR 63.343(c)(5), Subpart N: Compliance Certification

61 40CFR 63.344(d)(1), Subpart N: Compliance Certification

62 40CFR 63.346(b), Subpart N: Compliance Certification

63 40CFR 63.347(g)(1), Subpart N: Compliance Certification

 EU=E-G0005,Proc=05A,ES=CHR03

64 40CFR 63.343(c)(1), Subpart N: Compliance Certification

 EU=E-G0005,Proc=05A,ES=CHR04

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

65 40CFR 63.343(c)(1), Subpart N: Compliance Certification

 EU=E-G0006,Proc=06A

66 6NYCRR 212.10(c)(1): Compliance Certification

 EU=E-G0006,Proc=06B

68 6NYCRR 228.7: Compliance Certification

67 6NYCRR 228.10: Compliance Certification

 EU=E-G0008

69 6NYCRR 234.3(a)(1): Compliance Certification

70 40CFR 63.821(b)(2), Subpart KK: Compliance Certification

STATE ONLY ENFORCEABLE CONDITIONS

Facility Level

71 ECL 19-0301: Contaminant List

72 6NYCRR 201-1.4: Unavoidable noncompliance and violations

73 6NYCRR 211.2: Air pollution prohibited

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

FEDERALLY ENFORCEABLE CONDITIONS

** ** Facility Level  

NOTIFICATION OF GENERAL PERMITTEE OBLIGATIONS

The items listed below are not subject to the annual compliance certification

 requirements under Title V. Permittees may also have other obligations

under regulations of general applicability.

Item A: Emergency Defense - 6NYCRR Part 201-1.5

An emergency constitutes an affirmative defense to an 

action brought for noncompliance with emissions 

limitations or permit conditions for all facilities in New

York State.

(a) The affirmative defense of emergency shall be 

demonstrated through properly signed, contemporaneous 

operating logs, or other relevant evidence that:

(1) An emergency occurred and that the facility owner 

and/or operator can identify the cause(s) of the 

emergency;

(2) The equipment at the permitted facility causing the 

emergency was at the time being properly operated;

(3) During the period of the emergency the facility owner

and/or operator took all reasonable steps to minimize 

levels of emissions that exceeded the emission standards, 

or other requirements in the permit; and

(4) The facility owner and/or operator notified the 

Department within two working days after the event 

occurred. This notice must contain a description of the 

emergency, any steps taken to mitigate emissions, and 

corrective actions taken.

(b) In any enforcement proceeding, the facility owner 

and/or operator seeking to establish the occurrence of an 

emergency has the burden of proof.

(c) This provision is in addition to any emergency or 

upset provision contained in any applicable requirement.

Item B: Public Access to Recordkeeping for Title V Facilities - 

6NYCRR Part 201-1.10(b)

The Department will make available to the public any 

permit application, compliance plan, permit, and 

monitoring and compliance certification report pursuant to

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Section 503(e) of the Act, except for information entitled

to confidential treatment pursuant to 6NYCRR Part 616 - 

Public Access to records and Section 114(c) of the Act.

Item C: Timely Application for the Renewal of Title V Permits - 6

NYCRR Part 201-6.3(a)(4)

Owners and/or operators of facilities having an issued 

Title V permit shall submit a complete application at 

least 180 days, but not more than eighteen months, prior 

to the date of permit expiration for permit renewal 

purposes.

Item D: Certification by a Responsible Official - 6 NYCRR Part 

201-6.3(d)(12)

Any application, form, report or compliance certification

required to be submitted pursuant to the federally 

enforceable portions of this permit shall contain a 

certification of truth, accuracy and completeness by a 

responsible official. This certification shall state that 

based on information and belief formed after reasonable 

inquiry, the statements and information in the document 

are true, accurate, and complete.

Item E: Requirement to Comply With All Conditions - 6 NYCRR Part 

201-6.5(a)(2)

The permittee must comply with all conditions of the 

Title V facility permit. Any permit non-compliance 

constitutes a violation of the Act and is grounds for 

enforcement action; for permit termination, revocation and

reissuance, or modification; or for denial of a permit 

renewal application.

Item F: Permit Revocation, Modification, Reopening, Reissuance or

Termination, and Associated Information Submission 

Requirements - 6 NYCRR Part 201-6.5(a)(3)

This permit may be modified, revoked, reopened and 

reissued, or terminated for cause. The filing of a request

by the permittee for a permit modification, revocation and

reissuance, or termination, or of a notification of 

planned changes or anticipated noncompliance does not stay

any permit condition.

Item G: Cessation or Reduction of Permitted Activity Not a 

Defense - 6NYCRR Part 201-6.5(a)(5)

It shall not be a defense for a permittee in an 

enforcement action to claim that a cessation or reduction 

in the permitted activity would have been necessary in 

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

order to maintain compliance with the conditions of this 

permit.

Item H: Property Rights - 6 NYCRR Part 201-6.5(a)(6)

This permit does not convey any property rights of any 

sort or any exclusive privilege.

Item I: Severability - 6 NYCRR Part 201-6.5(a)(9)

If any provisions, parts or conditions of this permit are

found to be invalid or are the subject of a challenge, the

remainder of this permit shall continue to be valid.

Item J: Permit Shield - 6 NYCRR Part 201-6.5(g)

All permittees granted a Title V facility permit shall be

covered under the protection of a permit shield, except as

provided under 6 NYCRR Subpart 201-6. Compliance with the

conditions of the permit shall be deemed compliance with 

any applicable requirements as of the date of permit 

issuance, provided that such applicable requirements are 

included and are specifically identified in the permit, or

the Department, in acting on the permit application or 

revision, determines in writing that other requirements 

specifically identified are not applicable to the major 

stationary source, and the permit includes the 

determination or a concise summary thereof. Nothing herein

shall preclude the Department from revising or revoking 

the permit pursuant to 6 NYCRR Part 621 or from exercising

its summary abatement authority. Nothing in this permit 

shall alter or affect the following:

i. The ability of the Department to seek to bring suit on 

behalf of the State of New York, or the Administrator to 

seek to bring suit on behalf of the United States, to 

immediately restrain any person causing or contributing to

pollution presenting an imminent and substantial 

endangerment to public health, welfare or the environment 

to stop the emission of air pollutants causing or 

contributing to such pollution;

ii. The liability of a permittee of the Title V facility 

for any violation of applicable requirements prior to or 

at the time of permit issuance;

iii. The applicable requirements of Title IV of the 

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Act;

iv. The ability of the Department or the Administrator to 

obtain information from the permittee concerning the 

ability to enter, inspect and monitor the facility.

Item K: Reopening for Cause - 6 NYCRR Part 201-6.5(i)

This Title V permit shall be reopened and revised under 

any of the following circumstances:

i. If additional applicable requirements under the Act 

become applicable where this permit's remaining term is 

three or more years, a reopening shall be completed not 

later than 18 months after promulgation of the applicable 

requirement. No such reopening is required if the 

effective date of the requirement is later than the date 

on which this permit is due to expire, unless the original

permit or any of its terms and conditions has been 

extended by the Department pursuant to the provisions of 

Part 201-6.7 and Part 621.

ii. The Department or the Administrator determines that 

the permit contains a material mistake or that inaccurate 

statements were made in establishing the emissions 

standards or other terms or conditions of the 

permit.

iii. The Department or the Administrator determines that 

the Title V permit must be revised or reopened to assure 

compliance with applicable requirements.

iv. If the permitted facility is an "affected source" 

subject to the requirements of Title IV of the Act, and 

additional requirements (including excess emissions 

requirements) become applicable. Upon approval by the 

Administrator, excess emissions offset plans shall be 

deemed to be incorporated into the permit.

 Proceedings to reopen and issue Title V facility permits 

shall follow the same procedures as apply to initial 

permit issuance but shall affect only those parts of the 

permit for which cause to reopen exists.

 Reopenings shall not be initiated before a notice of such

intent is provided to the facility by the Department at 

least thirty days in advance of the date that the permit 

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

is to be reopened, except that the Department may provide

a shorter time period in the case of an emergency.

Item L: Permit Exclusion - ECL 19-0305

The issuance of this permit by the Department and the 

receipt thereof by the Applicant does not and shall not be

construed as barring, diminishing, adjudicating or in any 

way affecting any legal, administrative or equitable 

rights or claims, actions, suits, causes of action or 

demands whatsoever that the Department may have against 

the Applicant for violations based on facts and 

circumstances alleged to have occurred or existed prior to

the effective date of this permit, including, but not 

limited to, any enforcement action authorized pursuant to 

the provisions of applicable federal law, the 

Environmental Conservation Law of the State of New York 

(ECL) and Chapter III of the Official Compilation of the 

Codes, Rules and Regulations of the State of New York 

(NYCRR). The issuance of this permit also shall not in any

way affect pending or future enforcement actions under the

Clean Air Act brought by the United States or any person.

Item M: Federally Enforceable Requirements - 40 CFR 70.6(b)

All terms and conditions in this permit required by the 

Act or any applicable requirement, including any 

provisions designed to limit a facility's potential to 

emit, are enforceable by the Administrator and citizens 

under the Act. The Department has, in this permit, 

specifically designated any terms and conditions that are 

not required under the Act or under any of its applicable 

requirements as being enforceable under only state 

regulations.

MANDATORY FEDERALLY ENFORCEABLE PERMIT CONDITIONS SUBJECT 

TO ANNUAL CERTIFICATIONS AT ALL TIMES

The following federally enforceable permit conditions are mandatory for all Title V permits

and are subject to annual compliance certification requirements at all times.

Condition 1: Acceptable Ambient Air Quality

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 200.6

Item 1.1:

Notwithstanding the provisions of 6 NYCRR Chapter III, Subchapter A, no person shall allow or permit 

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

any air contamination source to emit air contaminants in quantities which alone or in combination with 

emissions from other air contamination sources would contravene any applicable ambient air quality 

standard and/or cause air pollution. In such cases where contravention occurs or may occur, the 

Commissioner shall specify the degree and/or method of emission control required.

Condition 2: Fees

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-6.5(a)(7)

Item 2.1:

The owner and/or operator of a stationary source shall pay fees to the Department consistent with the fee 

schedule authorized by ECL 72-0302.

Condition 3: Recordkeeping and reporting of compliance monitoring

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-6.5(c)

Item 3.1:

The following information must be included in any required compliance monitoring records and reports:

(i) The date, place, and time of sampling or measurements;

(ii) The date(s) analyses were performed;

(iii)The company or entity that performed the analyses;

(iv) The analytical techniques or methods used including quality assurance and quality control procedures 

if required;

(v) The results of such analyses including quality assurance data where required; and

(vi) The operating conditions as existing at the time of sampling or measurement.

Any deviation from permit requirements must be clearly identified in all records and reports. Reports 

must be certified by a responsible official, consistent with Section 201-6.3 of this Part 201.

Condition 4: Monitoring, Related Recordkeeping, and Reporting 

Requirements.

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-6.5(c)(2)

Item 4.1:

Compliance monitoring and recordkeeping shall be conducted according to the terms and conditions 

contained in this permit and shall follow all quality assurance requirements found in applicable 

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

regulations. Records of all monitoring data and support information must be retained for a period of at 

least 5 years from the date of the monitoring, sampling, measurement, report, or application. Support 

information includes all calibration and maintenance records and all original strip-chart recordings for 

continuous monitoring instrumentation, and copies of all reports required by the permit. 

Condition 5: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-6.5(c)(3)(ii)

Item 5.1:

The Compliance Certification activity will be performed for the Facility.

Item 5.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

To meet the requirements of this facility permit with 

respect to reporting, the permittee must:

Submit reports of any required monitoring at a minimum 

frequency of every 6 months, based on a calendar year 

reporting schedule. These reports shall be submitted to 

the Department within 30 days after the end of a reporting

period. All instances of deviations from permit 

requirements must be clearly identified in such reports. 

All required reports must be certified by the responsible 

official for this facility.

Notify the Department and report permit deviations and 

incidences of noncompliance stating the probable cause of 

such deviations, and any corrective actions or preventive 

measures taken. Where the underlying applicable 

requirement contains a definition of prompt or otherwise 

specifies a time frame for reporting deviations, that 

definition or time frame shall govern. Where the 

underlying applicable requirement fails to address the 

time frame for reporting deviations, reports of deviations

shall be submitted to the permitting authority based on 

the following schedule:

(1) For emissions of a hazardous air pollutant (as 

identified in an applicable regulation) that continue for 

more than an hour in excess of permit requirements, the 

report must be made within 24 hours of the 

occurrence.

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

(2) For emissions of any regulated air pollutant, 

excluding those listed in paragraph (1) of this section, 

that continue for more than two hours in excess of permit 

requirements, the report must be made within 48 

hours.

(3) For all other deviations from permit requirements, 

the report shall be contained in the 6 month monitoring 

report required above.

(4) This permit may contain a more stringent reporting 

requirement than required by paragraphs (1), (2) or (3) 

above. If more stringent reporting requirements have been

placed in this permit or exist in applicable requirements 

that apply to this facility, the more stringent reporting 

requirement shall apply.

If above paragraphs (1) or (2) are met, the source must 

notify the permitting authority by telephone during normal

business hours at the Regional Office of jurisdiction for 

this permit, attention Regional Air Pollution Control 

Engineer (RAPCE) according to the timetable listed in 

paragraphs (1) and (2) of this section. For deviations 

and incidences that must be reported outside of normal 

business hours, on weekends, or holidays, the DEC Spill 

Hotline phone number at 1-800-457-7362 shall be used. A 

written notice, certified by a responsible official 

consistent with 6 NYCRR Part 201-6.3(d)(12), must be 

submitted within 10 working days of an occurrence for 

deviations reported under (1) and (2). All deviations 

reported under paragraphs (1) and (2) of this section must

also be identified in the 6 month monitoring report 

required above.

The provisions of 6 NYCRR 201-1.4 shall apply if the 

permittee seeks to have a violation excused unless 

otherwise limited by regulation. In order to have a 

violation of a federal regulation (such as a new source 

performance standard or national emissions standard for 

hazardous air pollutants) excused, the specific federal 

regulation must provide for an affirmative defense during 

start-up, shutdowns, malfunctions or upsets. 

Notwithstanding any recordkeeping and reporting 

requirements in 6 NYCRR 201-1.4, reports of any deviations

shall not be on a less frequent basis than the reporting 

periods described in paragraphs (1) and (4) above. 

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

In the case of any condition contained in this permit 

with a reporting requirement of "Upon request by 

regulatory agency" the permittee shall include in the 

semiannual report, a statement for each such condition 

that the monitoring or recordkeeping was performed as 

required or requested and a listing of all instances of 

deviations from these requirements.

In the case of any emission testing performed during the 

previous six month reporting period, either due to a 

request by the Department, EPA, or a regulatory 

requirement, the permittee shall include in the semiannual

report a summary of the testing results and shall indicate

whether or not the Department or EPA has approved the 

results.

All semiannual reports shall be submitted to the 

Administrator (or his or her representative) as well as 

two copies to the Department (one copy to the regional air

pollution control engineer (RAPCE) in the regional office 

and one copy to the Bureau of Quality Assurance (BQA) in 

the DEC central office). Mailing addresses for the above 

referenced persons are contained in the monitoring 

condition for 6 NYCRR Part 201-6.5(e), contained elsewhere

in this permit.

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 6: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-6.5(e)

Item 6.1:

The Compliance Certification activity will be performed for the Facility.

Item 6.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Requirements for compliance certifications with terms and

conditions contained in this facility permit include the 

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

following:

i. Compliance certifications shall contain:

- the identification of each term or condition of the 

permit that is the basis of the certification;

- the compliance status;

- whether compliance was continuous or intermittent;

- the method(s) used for determining the compliance status

of the facility, currently and over the reporting period 

consistent with the monitoring and related recordkeeping 

and reporting requirements of this permit;

- such other facts as the Department may require to 

determine the compliance status of the facility as 

specified in any special permit terms or conditions; 

and

- such additional requirements as may be specified 

elsewhere in this permit related to compliance 

certification.

ii. The responsible official must include in the annual 

certification report all terms and conditions contained in

this permit which are identified as being subject to 

certification, including emission limitations, standards, 

or work practices. That is, the provisions labeled herein

as "Compliance Certification" are not the only provisions 

of this permit for which an annual certification is 

required.

iii. Compliance certifications shall be submitted 

annually. Certification reports are due 30 days after the

anniversary date of four consecutive calendar quarters. 

The first report is due 30 days after the calendar quarter

that occurs just prior to the permit anniversary date, 

unless another quarter has been acceptable by the 

Department.

iv. All compliance certifications shall be submitted to 

the Administrator (or his or her representative) as well 

as two copies to the Department (one copy to the regional 

air pollution control engineer (RAPCE) in the regional 

office and one copy to the Bureau of Quality Assurance 

(BQA) in the DEC central office). Please send annual 

compliance certifications to Chief of the Stationary 

Source Compliance Section, the Region 2 EPA representative

for the Administrator, at the following address:

USEPA Region 2

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Air Compliance Branch

290 Broadway

New York, NY 10007-1866

The address for the RAPCE is as follows:

270 Michigan Avenue

Buffalo, NY 14203-2999

The address for the BQA is as follows:

NYSDEC 

Bureau of Quality Assurance

625 Broadway

Albany, NY 12233-3258

Monitoring Frequency: ANNUALLY

Reporting Requirements: ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due on the same day each year

Condition 7: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 202-2.1

Item 7.1:

The Compliance Certification activity will be performed for the Facility.

Item 7.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Emission statements shall be submitted on or before April

15th each year for emissions of the previous calendar 

year.

Monitoring Frequency: ANNUALLY

Reporting Requirements: ANNUALLY (CALENDAR)

Reports due by April 15th for previous calendar year

Condition 8: Recordkeeping requirements

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 202-2.5

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Item 8.1:

(a) The following records shall be maintained for at least five years:

(1) a copy of each emission statement submitted to the department; and

(2) records indicating how the information submitted in the emission statement was 

determined, including any calculations, data, measurements, and estimates used.

(b) These records shall be made available at the facility to the representatives of the department 

upon request during normal business hours.

Condition 9: Open Fires Prohibited at Industrial and Commercial Sites

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 215

Item 9.1:

No person shall burn, cause, suffer, allow or permit the burning in an open fire of garbage, refuse, 

rubbish for salvage, or rubbish generated by industrial or commercial activities.

MANDATORY FEDERALLY ENFORCEABLE PERMIT CONDITIONS SUBJECT

TO ANNUAL CERTIFICATIONS ONLY IF APPLICABLE

The following federally enforceable permit conditions are mandatory for all Title V

permits and are subject to annual compliance certification requirements only if

effectuated during the reporting period. [NOTE: The corresponding annual

compliance certification for those conditions not effectuated during the reporting

 period shall be specified as "not applicable".]

Condition 10: Maintenance of Equipment

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 200.7

Item 10.1:

Any person who owns or operates an air contamination source which is equipped with an emission 

control device shall operate such device and keep it in a satisfactory state of maintenance and repair in 

accordance with ordinary and necessary practices, standards and procedures, inclusive of manufacturer's 

specifications, required to operate such device effectively.

Condition 11: Recycling and Salvage

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-1.7

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Item 11.1:

Where practical, any person who owns or operates an air contamination source shall recycle or salvage 

air contaminants collected in an air cleaning device according to the requirements of the ECL.

Condition 12: Prohibition of Reintroduction of Collected Contaminants to

the air

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-1.8

Item 12.1:

No person shall unnecessarily remove, handle or cause to be handled, collected air contaminants from an 

air cleaning device for recycling, salvage or disposal in a manner that would reintroduce them to the 

outdoor atmosphere.

Condition 13: Exempt Sources - Proof of Eligibility

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-3.2(a)

Item 13.1:

The owner and/or operator of an emission source or unit that is eligible to be exempt may be required to 

certify that it operates within the specific criteria described in this Subpart. The owner or operator of any 

such emission source must maintain all required records on-site for a period of five years and make them 

available to representatives of the department upon request. Department representatives must be granted 

access to any facility which contains emission sources or units subject to this Subpart, during normal 

operating hours, for the purpose of determining compliance with this and any other State and Federal air 

pollution control requirements, regulations, or law.

Condition 14: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-3.2(a)

Item 14.1:

The Compliance Certification activity will be performed for the Facility.

Item 14.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

As proof of exempt eligibility for the emergency 

generators, the facility must maintain monthly records 

which demonstrate that each engine is operated less than 

500 hours per year, on a 12-month rolling total basis.

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Monitoring Frequency: MONTHLY

Averaging Method: ANNUAL MINIMUM ROLLED MONTHLY

Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY

Condition 15: Trivial Sources - Proof of Eligibility

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-3.3(a)

Item 15.1:

The owner and/or operator of an emission source or unit that is listed as being trivial in this Part may be 

required to certify that it operates within the specific criteria described in this Subpart. The owner or 

operator of any such emission source must maintain all required records on-site for a period of five years 

and make them available to representatives of the department upon request. Department representatives 

must be granted access to any facility which contains emission sources or units subject to this Subpart, 

during normal operating hours, for the purpose of determining compliance with this and any other State 

and Federal air pollution control requirements, regulations, or law.

Condition 16: Standard Requirement - Provide Information

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-6.5(a)(4)

Item 16.1:

The owner and/or operator shall furnish to the department, within a reasonable time, any information that 

the department may request in writing to determine whether cause exists for modifying, revoking and 

reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the 

permittee shall also furnish to the department copies of records required to be kept by the permit or, for 

information claimed to be confidential, the permittee may furnish such records directly to the 

administrator along with a claim of confidentiality, if the administrator initiated the request for 

information or otherwise has need of it.

Condition 17: General Condition - Right to Inspect

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-6.5(a)(8)

Item 17.1:

The department or an authorized representative shall be allowed upon presentation of credentials and 

other documents as may be required by law to:

(i) enter upon the permittee's premises where a facility subject to the permitting requirements of this 

Subpart is located or emissions-related activity is conducted, or where records must be kept under the 

conditions of the permit;

(ii) have access to and copy, at reasonable times, any records that must be kept under the conditions of the 

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

permit;

(iii) inspect at reasonable times any emission sources, equipment (including monitoring and air pollution 

control equipment), practices, and operations regulated or required under the permit; and

(iv) sample or monitor at reasonable times substances or parameters for the purpose of assuring 

compliance with the permit or applicable requirements.

Condition 18: Standard Requirements - Progress Reports

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-6.5(d)(5)

Item 18.1:

Progress reports consistent with an applicable schedule of compliance are to be submitted at least 

semiannually, or at a more frequent period if specified in the applicable requirement or by the 

department. Such progress reports shall contain the following:

(i) dates for achieving the activities, milestones, or compliance required in the schedule of compliance, 

and dates when such activities, milestones or compliance were achieved; and

(ii) an explanation of why any dates in the schedule of compliance were not or will not be met, and any 

preventive or corrective measures adopted.

Condition 19: Off Permit Changes

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-6.5(f)(6)

Item 19.1:

No permit revision will be required for operating changes that contravene an express permit term, 

provided that such changes would not violate applicable requirements as defined under this Part or 

contravene federally enforceable monitoring (including test methods), recordkeeping, reporting, or 

compliance certification permit terms and conditions. Such changes may be made without requiring a 

permit revision, if the changes are not modifications under any provision of title I of the act and the 

changes do not exceed the emissions allowable under the permit (whether expressed therein as a rate of 

emissions or in terms of total emissions) provided that the facility provides the administrator and the 

department with written notification as required below in advance of the proposed changes within a 

minimum of seven days. The facility owner or operator, and the department shall attach each such notice 

to their copy of the relevant permit.

(i) For each such change, the written notification required above shall include a brief description of the 

change within the permitted facility, the date on which the change will occur, any change in emissions, 

and any permit term or condition that is no longer applicable as a result of the change.

(ii) The permit shield described in section 6 NYCRR 201-6.6 shall not apply to any change made 

pursuant to this paragraph.

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Condition 20: Required Emissions Tests

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 202-1.1

Item 20.1:

For the purpose of ascertaining compliance or non-compliance with any air pollution control code, rule or 

regulation, the commissioner may require the person who owns such air contamination source to submit 

an acceptable report of measured emissions within a stated time. Such person shall bear the cost of 

measurement and preparing the report of measured emissions. Failure of such person to submit a report 

acceptable to the commissioner within the time stated shall be sufficient reason for the commissioner to 

suspend or deny a certificate to operate.

Condition 21: Visible Emissions Limited

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 211.3

Item 21.1:

Except as permitted by a specific part of this Subchapter and for open fires for which a restricted burning 

permit has been issued, no person shall cause or allow any air contamination source to emit any material 

having an opacity equal to or greater than 20 percent (six minute average) except for one continuous sixminute period per hour of not more than 57 percent opacity.

Condition 22: Accidental release provisions.

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 68

Item 22.1:

If a chemical is listed in Tables 1,2,3 or 4 of 40 CFR §68.130 is present in a process in quantities greater 

than the threshold quantity listed in Tables 1,2,3 or 4, the following requirements will apply:

a) The owner or operator shall comply with the provisions of 40 CFR Part 68 and;

b) The owner or operator shall submit at the time of permit issuance (if not previously submitted) one of 

the following, if such quantities are present: 

1) A compliance schedule for meeting the requirements of 40 CFR Part 68 by the date provided in 40 

CFR §68.10(a) or,

2) A certification statement that the source is in compliance with all requirements of 40 CFR Part 68, 

including the registration and submission of the Risk Management Plan. Information should be submitted 

to:

Risk Management Plan Reporting Center

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

C/O CSC

8400 Corporate Dr

Carrollton, Md. 20785

Condition 23: Recycling and Emissions Reduction

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 82, Subpart F

Item 23.1:

The permittee shall comply with all applicable provisions of 40 CFR Part 82.

The following conditions are subject to annual compliance certification requirements

for Title V permits only.

Condition 24: False statement

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 200.3

Item 24.1:

No person shall make a false statement in connection with applications, plans, specifications and/or 

reports submitted pursuant to this Subchapter.

Condition 25: Emission Unit Definition

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-6

Item 25.1:

The facility is authorized to perform regulated processes under this permit for:

Emission Unit: E-G0001

Emission Unit Description: 

Emission unit E-G0001 consists of eight book bindery 

trimmers identified as TR401, TR411, TR421, TR431, TR441, 

TR461, TR471, and TR481; and three inserter trimmers 

identified as TR332, TR334, and TR338. Each trimmer has 

pickup points ducted to one of four cyclones located on 

the roof of the main building. The cyclones are 

identified as 00CCY, 00NCY, 00SCY, and 00WCY. This 

emission unit also includes a hogger which has a stand 

alone cyclone/baler, identified as HOGCY, for paper waste 

fed into a hopper at the hogger. The exhaust from the 

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cyclones vents to one of five baghouses that discharge air

back into the main building. The baghouses are identified

as NWBH, SCBH, HOGBH, DUST1, and DUST2. Dust collector 

fans pick up dust at the book bindery trimmers and 

discharge the dust to bins which feed the dust into the 

bales of paper waste.

Building(s): MAIN

Item 25.2:

The facility is authorized to perform regulated processes under this permit for:

Emission Unit: E-G0002

Emission Unit Description: 

Emission unit E-G0002 consists of seven (7) offset, 

coldset lithographic printing presses and one (1) offset, 

heatset press. Lithography is a planeographic method in 

which the image and nonimage areas are on the same plane. 

The image plate is chemically modified into a hydrophobic,

ink-receptive, image area and a hydrophillic, 

water-loving, nonimage area. Image and nonimage areas 

remain electrostatically distinct because of the presence 

of a fountain solution. The fountain solution adheres to 

the nonimage area while the ink adheres to the image area.

 The term offset refers to the process where the image is 

offset or transferred from the plate cylinder to an 

intermediate blanket cylinder before being transferred to 

the substrate.

Building(s): MAIN

Item 25.3:

The facility is authorized to perform regulated processes under this permit for:

Emission Unit: E-G0003

Emission Unit Description: 

Emission unit E-G0003 includes three dual fuel package 

boilers identified as emission sources EQ063, EQ064, and 

EQ065. Emission sources EQ063, EQ064, and EQ065 each have

a maximum rated heat input capacity of 25 mmBtu/hr. The 

three boilers are each capable of firing fuel oil (no. 4, 

5, or 6) and natural gas. The boilers are used to provide 

the gravure printing process with steam for ink drying and

room/web humidification, and for building heat. 

Condensate water decanted from the solvent recovery system

is used in the boilers for steam generation. 

Emission sources EQ064 and EQ065 were constructed in 1961 

and emission source EQ065 was constructed in 1979, which 

is prior to the applicability date of 40CFR60 Subpart Dc. 

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All three of the boilers are subject to the initial 

notification requirements of 40CFR63 Subpart DDDDD.

Building(s): BOILER

Item 25.4:

The facility is authorized to perform regulated processes under this permit for:

Emission Unit: E-G0004

Emission Unit Description: 

Emission unit E-G0004 contains six rotogravure printing 

presses and three carbon adsorption units. Gravure 

printing is a type of printing in which the image area is 

etched or engraved relative to the surface of the image 

plate or cylinder. The image area consists of small, 

recessed cells etched into a copper wrap around a plate. 

The copper layer is protected from wear by a thin 

electroplated layer of chromium. As the image cylinder 

rotates in a bath of ink, ink is picked up in the engraved

image area and any excess is removed from the non-image 

area of the plate by a doctor blade. Ink is transferred 

from the etched wells in the image area directly to the 

substrate when the substrate is pressed against the image 

plate by a rubber covered impression roller. Each 

printing station is followed by a high-volume air dryer, 

before the next ink is applied. Gravure inks have to be 

highly fluid with a low viscosity and fast drying. The 

ink in the press fountains can contain as much as 75% 

solvent by weight. Most of the solvents are evaporated in

the press dryers and sent to a solvent recovery system for

reclaiming. 

Quebecor utilizes three solvent recovery systems to 

capture and recover VOC emissions from each of the 

publication rotogravure printing processes at the 

facility. In the operation of the solvent recovery 

systems, the exhaust air from the rotogravure printing 

operations are collected and passed through large beds of 

activated carbon. The carbon beds adsorb all but trace 

amounts of the solvent vapor. When a bed is saturated, 

the exhaust stream is diverted to a nonsaturated bed and 

the saturated bed is regenerated by steaming. The 

resulting steam-solvent-vapor mixture is condensed. The 

solvent and the condensed water are separated by gravity 

in a decanter vessel. The solvents are composed of 

toluene and mixtures of similar boiling point aliphatic 

hydrocarbons. The recovered solvents are used within the 

plant for ink dilution and viscosity control, and some 

solvent is returned to the ink supplier for reuse. The 

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condensed water is used in the boilers for steam 

generation.

The existing six rotogravure presses are identified as 

emission sources EQ210, EQ211, EQ212, EQ214, EQ217, and 

EQ218. The three carbon adsorption units are identified 

as CT068, CT071, and CT075. Emission source CT068 is 

more commonly referred to as the RD solvent recovery 

system. The RD solvent recovery system is a three carbon 

bed system primarily used to recover the solvent laden air

(SLA) captured from rotogravure press 211. Emission 

source CT071 is more commonly referred to as the NE 

solvent recovery system. The NE system is a five carbon 

bed system used primarily to recover SLA captured from 

presses 217 and 218. Emission source CT075 is more 

commonly referred to as the Dayton solvent recovery 

system. The Dayton system is a four horizontal carbon bed

system primarily used to recover the SLA captured from 

rotogravure presses 210, 212, and 214. Even though 

certain presses are generally directed to certain recovery

systems, Quebecor does have the flexibility and capability

to direct the captured SLA to any of the three solvent 

recovery systems. The three systems each interact 

together and are viewed as a single total system.

Building(s): MAIN

Item 25.5:

The facility is authorized to perform regulated processes under this permit for:

Emission Unit: E-G0005

Emission Unit Description: 

Emission unit E-G0005 consists of two hard chromium 

electroplating tanks with a maximum cumulative potential 

rectifier capacity of greater than 60 million amp-hr per 

year. Quebecor has limited the rectifier capacity to 

below 60 million amp-hr/yr, pursuant to 

40CFR63.342(c)(2)(i). The chrome plating bath utilizes a 

fume suppressant to reduce misting. A plate and baffle 

mist eliminator is used in the exhaust stream. A mesh pad 

filter removes particles from the exhaust stream and is 

the primary compliance indicator for the emission unit. 

Building(s): MAIN

Item 25.6:

The facility is authorized to perform regulated processes under this permit for:

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Emission Unit: E-G0006

Emission Unit Description: 

Emission unit E-G0006 consists of eight (8) book binders 

with hot melt glue pots for attaching the covers to 

paperback books. Binders EQ430 and EQ460 have open glue 

pots with stack emissions. Binders EQ400, EQ420, EQ410, 

EQ440, EQ470, and EQ480 have closed glue pots with no 

stack emissions. A stain booth, identified as EQ481, 

applies yellow stain to book edges. Binders 430, 440, and 

470 are associated with the stain booth.

Building(s): MAIN

Item 25.7:

The facility is authorized to perform regulated processes under this permit for:

Emission Unit: E-G0007

Emission Unit Description: 

Emission unit E-G0007 consists of three horizontal carbon

steel solvent tanks, each with a maximum capacity of 9908 

gallons. The material contained in the tanks is recovered

solvent from the solvent recovery system. There is also 

one 9908 gallon capacity storage tank which is temporarily

out of service. The tanks are located indoors in a 

secondary containment vault. The tanks do not directly 

vent outdoors, but do have emergency relief vents. The 

four 9908 gallon capacity carbon steel solvent storage 

tanks are not subject to the requirements of 6NYCRR Part 

229.3(g) and 6NYCRR Part 229.3(e)(2)(iv) since the tanks 

are horizontal volatile organic liquid storage tanks, as 

specified in 6NYCRR Part 229.3(f)(4). The tanks are not 

subject to 40CFR60 Subpart Kb since the capacity is less 

than 40 cubic meters. This emission unit has no 

associated conditions in the permit.

Building(s): MAIN

Item 25.8:

The facility is authorized to perform regulated processes under this permit for:

Emission Unit: E-G0008

Emission Unit Description: 

Emission unit E-G0008 includes six (6) flexographic 

printing presses. Flexography is rotary web letterpress 

printing. It is the application of words or pictures to a

substrate by means of a relief technique in which the 

image area is raised above the non-image area. Image 

plates are mounted to cylinders with adhesives. Ink is 

applied to these image carriers which are made of rubber 

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

or other elastomeric material. The ink image is then 

transferred from the flexible plate to the substrate. 

These presses use a cold-set, isoparaphinic (wax) solvent 

based ink and are capable of printing one color on a 

newsprint web.

Building(s): MAIN

Item 25.9:

The facility is authorized to perform regulated processes under this permit for:

Emission Unit: E-G0009

Emission Unit Description: 

Emission unit E-G0009 contains nine ink jet printing 

operations which print identifying information onto 

cardboard boxes. There are no associated emission points 

with these sources.

Building(s): MAIN

Condition 26: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 212.6(a)

Item 26.1:

The Compliance Certification activity will be performed for the facility:

The Compliance Certification applies to:

Emission Unit: E-G0001

Emission Unit: E-G0005

Emission Unit: E-G0006

Regulated Contaminant(s):

CAS No: 0NY075-00-0 PARTICULATES

Item 26.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: MONITORING OF PROCESS OR CONTROL 

 DEVICE PARAMETERS AS SURROGATE

Monitoring Description: 

No person shall cause or allow emissions having an 

average opacity during any six consecutive minutes of 20 

percent or greater from any emission source, except only 

the emission of uncombined water. The Department reserves

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

the right to perform or require the performance of a 

Method 9 opacity evaluation at any time during facility 

operation.

The permittee will conduct observations of visible 

emissions from the facility on a daily basis. The 

permittee will immediately investigate any instance where 

there is cause to believe that visible emissions above 

those that are normal and in compliance are occurring or 

have occurred.

If visible emissions above those that are normal (this may

be zero percent opacity for many or all emission sources) 

and in compliance with 6NYCRR Part 212.6(a) are detected, 

the permittee shall determine the cause, make the 

necessary correction, and verify that the excess visible 

emissions problem has been corrected. 

If visible emissions above those that are normal and in 

compliance continue to be present after corrections are 

made, the permittee will immediately notify the Department

and conduct a Method 9 assessment within 24 hours to 

determine the degree of opacity.

Records of these observations, investigations and 

corrective actions will be kept on-site in a format 

acceptable to the Department.

Parameter Monitored: OPACITY

Upper Permit Limit: 20 percent

Monitoring Frequency: DAILY

Averaging Method: MAXIMUM - NOT TO EXCEED STATED VALUE -

 SEE MONITORING DESCRIPTION

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 27: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 234.1(g)

Item 27.1:

The Compliance Certification activity will be performed for the Facility.

Regulated Contaminant(s):

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

CAS No: 0NY998-00-0 VOC

Item 27.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Any printing process that is subject to the provisions of

6NYCRR Part 234 will remain subject to these provisions 

even if the emissions of volatile organic compounds from 

the facility later fall below the applicability criteria.

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY

Condition 28: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 234.3(e)

Item 28.1:

The Compliance Certification activity will be performed for the facility:

The Compliance Certification applies to:

Emission Unit: E-G0002

Emission Unit: E-G0004

Emission Unit: E-G0008

Regulated Contaminant(s):

CAS No: 0NY075-00-0 PARTICULATES

Item 28.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: MONITORING OF PROCESS OR CONTROL 

 DEVICE PARAMETERS AS SURROGATE

Monitoring Description: 

No person shall cause or allow emissions having an 

average opacity during any six consecutive minutes of 10 

percent or greater from any emission source subject to 

6NYCRR Part 234, except only the emission of uncombined 

water. The Department reserves the right to perform or 

require the performance of a Method 9 opacity evaluation 

at any time during facility operation.

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

The permittee will conduct observations of visible 

emissions from the facility on a daily basis. The 

permittee will immediately investigate any instance where 

there is cause to believe that visible emissions above 

those that are normal and in compliance are occurring or 

have occurred.

If visible emissions above those that are normal (this may

be zero percent opacity for many or all emission sources) 

and in compliance are detected, the permittee shall 

determine the cause, make the necessary correction, and 

verify that the excess visible emissions problem has been 

corrected. 

If visible emissions above those that are normal and in 

compliance continue to be present after corrections are 

made, the permittee will immediately notify the Department

and conduct a Method 9 assessment within 24 hours to 

determine the degree of opacity.

Records of these observations, investigations and 

corrective actions will be kept on-site in a format 

acceptable to the Department.

Parameter Monitored: OPACITY

Upper Permit Limit: 10 percent

Monitoring Frequency: DAILY

Averaging Method: MAXIMUM - NOT TO EXCEED STATED VALUE -

 SEE MONITORING DESCRIPTION

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 29: Handling, storage, and disposal of volatile organic 

compounds

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 234.6

Item 29.1:

No owner or operator of a facility subject to 6NYCRR Part 234 shall:

(a) use open containers to store or dispose of cloth or paper impregnated with VOC and/or solvents that 

are used for surface preparation, cleanup or ink/coating removal;

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

(b) store in open containers spent or fresh VOC and/or solvents to be used for surface preparation, 

cleanup or ink/coating removal;

(c) use open containers to store or dispose of inks and/or surface coatings; or

(d) use open containers to store or dispense inks and/or surface coatings unless production, sampling, 

maintenance or inspection procedures require operational access. This provision does not apply to the 

actual device or equipment designed for the purposes of applying an ink or coating to a substrate.

Condition 30: EPA Region 2 address.

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 60.4, NSPS Subpart A

Item 30.1:

All requests, reports, applications, submittals, and other communications to the Administrator pursuant 

to this part shall be submitted in duplicate to the following address:

Director, Division of Enforcement and Compliance Assistance

USEPA Region 2

290 Broadway, 21st Floor

New York, NY 10007-1886

Copies of all correspondence to the administrator pursuant to this part shall also be submitted to the 

NYSDEC Regional Office issuing this permit (see address at the beginning of this permit) and to the 

following address:

NYSDEC

Bureau of Quality Assurance

625 Broadway

Albany, NY 12233-3258

Condition 31: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 60.434(a), NSPS Subpart QQ

Item 31.1:

The Compliance Certification activity will be performed for the facility:

The Compliance Certification applies to:

Emission Unit: E-G0004

Process: 04A Emission Source: EQ211

Emission Unit: E-G0004

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Process: 04A Emission Source: EQ212

Emission Unit: E-G0004

Process: 04A Emission Source: EQ214

Emission Unit: E-G0004

Process: 04A Emission Source: EQ217

Emission Unit: E-G0004

Process: 04A Emission Source: EQ218

Regulated Contaminant(s):

CAS No: 0NY998-00-0 VOC

Item 31.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: MONITORING OF PROCESS OR CONTROL 

 DEVICE PARAMETERS AS SURROGATE

Monitoring Description: 

Quebecor maintains records of the amount of solvent used,

solvent recovered, and estimated solvent recovery 

percentage for each performance averaging period, to 

demonstrate continued compliance with 40CFR60 Subpart QQ. 

Compliance is demonstrated on a plant-wide basis for all 

existing and affected facilities combined. Quebecor 

chooses to use the plant-wide demonstration, since the 

existing facilities are required by 6NYCRR Part 234 to 

maintain identical records for demonstration of 

compliance. Quebecor has accepted a greater control 

efficiency of 84% for the existing facilities, as opposed 

to the 75% control efficiency required by 6NYCRR Part 234.

The solvent recovery system provides for an overall 

reduction in volatile organic compound (VOC) emissions of 

at least 84%. The overall removal efficiency of the 

capture system and air cleaning devices is calculated as 

the ratio of "recovered solvent" to "solvent used". The 

"solvent used" consists of solvent present in the ink and 

dilution solvent. The ink solvent and dilution solvent 

values are each determined by recording the volume, in 

gallons, from non-resettable totalizing meters. The 

recorded ink volumes are multiplied by the density of the 

ink and by the percent by weight VOC content to obtain the

pounds of VOC used in the ink. The pounds of VOC from the 

ink is then converted to gallons by using the density of 

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

the solvent. The ink solvent and dilution solvent are then

added together to obtain a total solvent usage in 

gallons.

The "recovered solvent" is determined by adding the 

solvent sold, dilution solvent, wash tank solvent, and the

gain or loss of the solvent tanks. The solvent sold is 

determined based on stick measurements of the tanks. The 

dilution solvent and wash tank solvent are determined by 

totalizing meters. The gain or loss of solvent from the 

solvent tanks is determined based on stick measurements of

the tanks. The "recovered solvent" value is divided by the

"solvent used" value which is then multiplied by 100 to 

obtain the efficiency of the solvent recovery 

system.

Quebecor performs a liquid-to-liquid material balance 

several times throughout the month for internal tracking 

purposes. The liquid-to-liquid material balance is 

calculated on a facility-wide basis. The information from 

the internal reports are used to prepare a monthly summary

report. Quebecor must complete a monthly summary report to

demonstrate continued compliance with the 

regulations.

The solvent and ink meters are read several times per 

month. The mechanical meters are calibrated on a yearly 

basis. The coreolis meters do not require calibration. 

Quebecor uses certification from the ink manufacturer to 

obtain the composition of the ink and solvent for use in 

the liquid-to-liquid material balance 

calculations.

Records of the amount of solvent used, solvent recovered, 

and estimated solvent recovery percentage shall be 

maintained on-site for a period of 2 years and be made 

available for review upon request by the Department.

Parameter Monitored: SOLVENT RECOVERY RATE

Lower Permit Limit: 84 percent reduction by weight

Monitoring Frequency: MONTHLY

Averaging Method: CALENDAR MONTH AVERAGE

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Condition 32: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.6(e)(3), Subpart A

Item 32.1:

The Compliance Certification activity will be performed for the Facility.

Regulated Contaminant(s):

CAS No: 0NY100-00-0 HAP

Item 32.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

As required by 40CFR63.6(e)(3), Quebecor developed and 

implemented a written Startup, Shutdown, and Malfunction 

Plan, dated May 30, 1999, for operating and maintaining 

the source during periods of startup, shutdown, and 

malfunction. The Plan includes corrective action for 

malfunctioning process and/or air pollution control 

equipment. This Plan was submitted with the original 

Title V permit application and is made part of this permit

by reference.

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

** ** Emission Unit Level  

Condition 33: Emission Point Definition By Emission Unit

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-6

Item 33.1:

The following emission points are included in this permit for the cited Emission Unit:

Emission Unit: E-G0001

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Emission Point: 00001

Height (ft.): 41 Diameter (in.): 72

NYTMN (km.): 4758.32 NYTME (km.): 196.429 Building: MAIN

Emission Point: 00002

Height (ft.): 41 Length (in.): 84 Width (in.): 36

NYTMN (km.): 4758.32 NYTME (km.): 196.429 Building: MAIN

Emission Point: 00003

Height (ft.): 68 Length (in.): 84 Width (in.): 36

NYTMN (km.): 4758.32 NYTME (km.): 196.429 Building: MAIN

Emission Point: 00004

Height (ft.): 40 Diameter (in.): 60

Item 33.2:

The following emission points are included in this permit for the cited Emission Unit:

Emission Unit: E-G0002

Emission Point: 00078

Height (ft.): 48 Length (in.): 18 Width (in.): 18

NYTMN (km.): 4758.32 NYTME (km.): 196.429 Building: MAIN

Item 33.3:

The following emission points are included in this permit for the cited Emission Unit:

Emission Unit: E-G0003

Emission Point: 00063

Height (ft.): 50 Diameter (in.): 24

NYTMN (km.): 4758.32 NYTME (km.): 196.429 Building: BOILER

Emission Point: 00064

Height (ft.): 50 Diameter (in.): 24

NYTMN (km.): 4758.32 NYTME (km.): 196.429 Building: BOILER

Emission Point: 00065

Height (ft.): 50 Diameter (in.): 24

NYTMN (km.): 4758.32 NYTME (km.): 196.429 Building: BOILER

Item 33.4:

The following emission points are included in this permit for the cited Emission Unit:

Emission Unit: E-G0004

Emission Point: 0068A

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Height (ft.): 24 Diameter (in.): 30

Emission Point: 0068B

Height (ft.): 24 Diameter (in.): 30

Emission Point: 0068C

Height (ft.): 24 Diameter (in.): 30

Emission Point: 0071A

Height (ft.): 24 Diameter (in.): 30

Emission Point: 0071B

Height (ft.): 24 Diameter (in.): 30

Emission Point: 0071C

Height (ft.): 24 Diameter (in.): 30

Emission Point: 0071D

Height (ft.): 24 Diameter (in.): 30

Emission Point: 0071E

Height (ft.): 24 Diameter (in.): 30

Emission Point: 0075A

Height (ft.): 24 Diameter (in.): 30

Emission Point: 0075B

Height (ft.): 24 Diameter (in.): 30

Emission Point: 0075C

Height (ft.): 24 Diameter (in.): 30

Emission Point: 0075D

Height (ft.): 24 Diameter (in.): 30

Emission Point: 0075E

Height (ft.): 24 Diameter (in.): 30

Item 33.5:

The following emission points are included in this permit for the cited Emission Unit:

Emission Unit: E-G0005

Emission Point: 00085

Height (ft.): 36 Diameter (in.): 16

NYTMN (km.): 4758.32 NYTME (km.): 196.429 Building: MAIN

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Emission Point: 00089

Height (ft.): 34 Diameter (in.): 13

NYTMN (km.): 4758.32 NYTME (km.): 196.429 Building: MAIN

Emission Point: CHR03

Height (ft.): 33 Diameter (in.): 20

Item 33.6:

The following emission points are included in this permit for the cited Emission Unit:

Emission Unit: E-G0006

Emission Point: 00037

Height (ft.): 36 Diameter (in.): 15

NYTMN (km.): 4758.32 NYTME (km.): 196.429 Building: MAIN

Emission Point: 00066

Height (ft.): 39 Diameter (in.): 18

NYTMN (km.): 4758.32 NYTME (km.): 196.429 Building: MAIN

Emission Point: 00067

Height (ft.): 39 Diameter (in.): 18

NYTMN (km.): 4758.32 NYTME (km.): 196.429 Building: MAIN

Condition 34: Process Definition By Emission Unit

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 201-6

Item 34.1:

This permit authorizes the following regulated processes for the cited Emission Unit:

Emission Unit: E-G0001

Process: 01A Source Classification Code: 3-07-012-01

Process Description: 

Emission unit E-G0001, Process 01A is the process where 

bound books are stacked and cut for squareness. The paper

trimmings are collected from five pickup points from each 

of the eight trimmers and two inserter machines. The 

paper trimmings are vacuumed into the cyclone/baler and 

formed into bales for recycling. The particulate 

emissions are passed through cyclones and then ducted to 

baghouses which vent back into the main building.

Emission Source/Control: 00CCY - Control

Control Type: CENTRIFUGAL

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Emission Source/Control: 00NCY - Control

Control Type: CENTRIFUGAL

Emission Source/Control: 00SCY - Control

Control Type: CENTRIFUGAL

Emission Source/Control: 00WCY - Control

Control Type: CENTRIFUGAL

Emission Source/Control: 0NWBH - Control

Control Type: HIGH EFFICIENCY PARTICULATE AIR FILTER

Emission Source/Control: 0SCBH - Control

Control Type: HIGH EFFICIENCY PARTICULATE AIR FILTER

Emission Source/Control: DUST1 - Control

Control Type: HIGH EFFICIENCY PARTICULATE AIR FILTER

Emission Source/Control: DUST2 - Control

Control Type: HIGH EFFICIENCY PARTICULATE AIR FILTER

Emission Source/Control: HOGBH - Control

Control Type: FABRIC FILTER

Emission Source/Control: HOGCY - Control

Control Type: CENTRIFUGAL

Emission Source/Control: TR332 - Process

Emission Source/Control: TR334 - Process

Emission Source/Control: TR338 - Process

Emission Source/Control: TR401 - Process

Emission Source/Control: TR411 - Process

Emission Source/Control: TR421 - Process

Emission Source/Control: TR431 - Process

Emission Source/Control: TR441 - Process

Emission Source/Control: TR461 - Process

Emission Source/Control: TR471 - Process

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Emission Source/Control: TR481 - Process

Item 34.2:

This permit authorizes the following regulated processes for the cited Emission Unit:

Emission Unit: E-G0002

Process: 02A Source Classification Code: 4-05-004-01

Process Description: 

Emission unit E-G0002, Process 02A includes seven offset 

lithographic printing presses which print on paper 

substrates utilizing cold set inks. The nonheat-set or 

cold-set printing process is distinguished by its unique 

ink and paper requirements. Nonheat-set inks are 

semifluid materials whose function depends on the rapid 

absorption of the liquid component by the surface of the 

paper. The capillary action of the paper surface draws 

the liquid into the paper surface and sets the ink. This 

process does not require the application of heat to cure 

the resin or evaporate the liquid component. Since most 

of the materials are retained in the printed sheet, 

emissions during press operation are minimal.

The six offset lithographic printing presses were 

installed and operated on or after September 1, 1988 and 

are required to utilize a fountain solution containing 

less than 10 percent VOC by weight. Details of each press

are specified below:

(1) Press EQ033 is a nonheat-set, sheet fed, offset 

press with an in-line coating unit that uses a water based

coating with infrared curing. This press has a 

ventilation point for removing excess heat.

(2) Press EQ038 is a non-heat set, sheet fed, offset 

press. This press has no direct emission points to the 

outside atmosphere.

(3) Press EQ101 is a non-heat set, sheet fed, offset 

press which uses a UV lamp for curing. This press has no 

direct emission points to the outside atmosphere.

(4) Press EQ104 is a non-heat set, sheet fed, offset 

press. This press has no direct emission points to the 

outside atmosphere.

(5) Press EQ125 is a two-unit, one color, non-heat set, 

web offset press. This press has no direct emission 

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

points to the outside atmosphere.

(6) Press EQ 126 is a two-unit, one color, non-heat set, 

web offset press. This press has no direct emission 

points to the outside atmosphere.

(7) Press EQ 127 is a two-unit, one color, non-heat set, 

web offset press. This press has no direct emission 

points to the outside atmosphere.

Emission Source/Control: EQ033 - Process

Emission Source/Control: EQ038 - Process

Emission Source/Control: EQ101 - Process

Emission Source/Control: EQ104 - Process

Emission Source/Control: EQ125 - Process

Emission Source/Control: EQ126 - Process

Emission Source/Control: EQ127 - Process

Item 34.3:

This permit authorizes the following regulated processes for the cited Emission Unit:

Emission Unit: E-G0002

Process: 02B Source Classification Code: 4-05-004-11

Process Description: 

Emission unit E-G0002, Process 02B includes one offset 

lithographic printing presses which prints on paper 

substrates utilizing heat set inks. Heatset offset 

lithography is similar to the cold set process due to the 

type of plates used and the requirement for fountain 

solution to maintain a printing image. However, the 

difference is the inks require energy to dry; thus, dryers

are used to cause the ink oil to evaporate, and web 

cooling devices or chill rollers are used to allow for an 

increased web speed.

The offset heatset press was installed and operated before

September 1, 1988 and is required to utilize a fountain 

solution containing less than 15 percent VOC by weight. 

Press 200 is a heat set, web fed, offset press. This press

has five double printing units for printing one color on 

each side of the web. The ink is dried onto the web as it 

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passes through a gas fired dryer. Although VOC emissions 

from Press 200 are controlled by limiting the amount of 

VOC in the fountain solution, additional control of VOC 

emissions is maintained through the operation and 

maintenance of a catalytic afterburner.

Emission Source/Control: CT078 - Control

Control Type: CATALYTIC AFTERBURNER

Emission Source/Control: EQ200 - Process

Item 34.4:

This permit authorizes the following regulated processes for the cited Emission Unit:

Emission Unit: E-G0003

Process: 03A Source Classification Code: 1-02-004-02

Process Description: 

Emission unit E-G0003, Process 03A, consists of three 

boilers which combust No. 4, 5, or 6 fuel oil to produce 

steam.

Emission Source/Control: EQ063 - Combustion

Emission Source/Control: EQ064 - Combustion

Emission Source/Control: EQ065 - Combustion

Item 34.5:

This permit authorizes the following regulated processes for the cited Emission Unit:

Emission Unit: E-G0003

Process: 03B Source Classification Code: 1-03-006-02

Process Description: 

Emission unit E-G0003, Process 03B, consists of three 

boilers which combust natural gas to produce steam.

Emission Source/Control: EQ063 - Combustion

Emission Source/Control: EQ064 - Combustion

Emission Source/Control: EQ065 - Combustion

Item 34.6:

This permit authorizes the following regulated processes for the cited Emission Unit:

Emission Unit: E-G0004

Process: 04A Source Classification Code: 4-05-005-11

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Process Description: 

Emission unit E-G0004, Process 04A, consists of printing 

on a paper substrate via six rotogravure presses. Press 

214 was constructed after October 28, 1980 and is subject 

to 40CFR60 Subpart QQ. The remaining five presses were 

each constructed prior to October 28, 1980 and are not 

subject to 40CFR60 Subpart QQ but are subject to a less 

stringent regulation, 6NYCRR Part 234. Due to the 

interconnected operation of the six presses and the three 

solvent recovery systems, Quebecor has chosen to have all 

six presses subject to 40CFR60 Subpart QQ, superseding 

the requirements of 6NYCRR Part 234.

Emission Source/Control: CT068 - Control

Control Type: ACTIVATED CARBON ADSORPTION

Emission Source/Control: CT071 - Control

Control Type: ACTIVATED CARBON ADSORPTION

Emission Source/Control: CT075 - Control

Control Type: ACTIVATED CARBON ADSORPTION

Emission Source/Control: EQ210 - Process

Emission Source/Control: EQ211 - Process

Emission Source/Control: EQ212 - Process

Emission Source/Control: EQ214 - Process

Emission Source/Control: EQ217 - Process

Emission Source/Control: EQ218 - Process

Item 34.7:

This permit authorizes the following regulated processes for the cited Emission Unit:

Emission Unit: E-G0005

Process: 05A Source Classification Code: 3-09-010-06

Process Description: 

Emission unit E-G0005, Process 05A, is a hard chromium 

electroplating process where engraved copper plates are 

plated with 3 microns of chromium. The chromium-plated 

copper plates are used on the gravure cylinders for 

production printing. The chrome plating bath utilizes a 

fume suppressant to reduce misting. A plate and baffle 

mist eliminator is used in the exhaust stream. A mesh pad 

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

filter removes particles from the exhaust stream and is 

the primary compliance indicator for the emission unit. 

Emission Source/Control: CTR3A - Control

Control Type: MIST ELIMINATOR

Emission Source/Control: CTR3B - Control

Control Type: MIST ELIMINATOR

Emission Source/Control: CTR4A - Control

Control Type: MIST ELIMINATOR

Emission Source/Control: CTR4B - Control

Control Type: MIST ELIMINATOR

Emission Source/Control: CHR03 - Process

Emission Source/Control: CHR04 - Process

Item 34.8:

This permit authorizes the following regulated processes for the cited Emission Unit:

Emission Unit: E-G0006

Process: 06A Source Classification Code: 3-07-007-27

Process Description: 

Emission unit E-G0006, Process 06A, consists of melting 

glue beads and application of the melted glue to the book 

binder.

Emission Source/Control: EQ400 - Process

Emission Source/Control: EQ410 - Process

Emission Source/Control: EQ420 - Process

Emission Source/Control: EQ430 - Process

Emission Source/Control: EQ440 - Process

Emission Source/Control: EQ460 - Process

Emission Source/Control: EQ470 - Process

Emission Source/Control: EQ480 - Process

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Item 34.9:

This permit authorizes the following regulated processes for the cited Emission Unit:

Emission Unit: E-G0006

Process: 06B Source Classification Code: 4-02-013-01

Process Description: 

Emission unit E-G0006, Process 06B, consists of applying 

stain to book edges using a staining booth.

Emission Source/Control: EQ430 - Process

Emission Source/Control: EQ440 - Process

Emission Source/Control: EQ470 - Process

Emission Source/Control: EQ481 - Process

Item 34.10:

This permit authorizes the following regulated processes for the cited Emission Unit:

Emission Unit: E-G0007

Process: 07A Source Classification Code: 4-07-158-12

Process Description: 

Emission unit E-G0007, Process 07A, consists of the 

storage of recovered solvent in three - 10,000 gallon 

capacity horizontal storage tanks. These storage tanks are

identified as TAK6A, TANK7, and TANK8. The source 

identified as TK14A is a 10,000 gallon storage tank which 

is temporarily out of service.

Emission Source/Control: TAK6A - Process

Emission Source/Control: TANK7 - Process

Emission Source/Control: TANK8 - Process

Emission Source/Control: TK14A - Process

Item 34.11:

This permit authorizes the following regulated processes for the cited Emission Unit:

Emission Unit: E-G0008

Process: 08A Source Classification Code: 4-05-003-01

Process Description: 

Emission unit E-G0008, Process 08A, consists of printing 

on a paper substrate utilizing flexographic presses.

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Emission Source/Control: EQ112 - Process

Emission Source/Control: EQ114 - Process

Emission Source/Control: EQ116 - Process

Emission Source/Control: EQ117 - Process

Emission Source/Control: EQ118 - Process

Emission Source/Control: EQ119 - Process

Item 34.12:

This permit authorizes the following regulated processes for the cited Emission Unit:

Emission Unit: E-G0009

Process: 09A Source Classification Code: 4-05-004-31

Process Description: 

Emission unit E-G0009, Process 09A, includes ink jet 

printing of identifying information onto cardboard boxes 

and books.

Emission Source/Control: EQIK9 - Process

Condition 35: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 234.3(b)(2)

Item 35.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0002

Process: 02A

Regulated Contaminant(s):

CAS No: 0NY998-00-0 VOC

Item 35.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: WORK PRACTICE INVOLVING SPECIFIC 

 OPERATIONS

Monitoring Description: 

Compliance with the maximum allowable 10 percent by 

weight or less of volatile organic compounds (VOC) content

of the fountain solution for presses EQ033, EQ038, EQ100, 

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

EQ104, and EQ125 will be demonstrated through dilution 

calculation records and sample test results.

 

The fountain solution is purchased in a concentrated form.

 The manufacturer of the fountain solution recommends a 

certain dilution to obtain the recommended operating 

formulation. Quebecor shall prepare the as-applied 

fountain solution in accordance with the recommended 

formulation. Alternatively, Quebecor may calculate a 

formulation using the VOC content of the concentrated 

fountain solution and a predetermined amount of water to 

obtain a diluted solution with a VOC content less than the

regulated value.

Quebecor has a centralized fountain solution formulation 

which was tested to determine the VOC content in June, 

2006. This formulation typically does not change. The 

fountain solution will be analyzed if the formulation is 

changed.

In order to demonstrate continued compliance with the 

maximum allowable VOC content of the fountain solution, 

Quebecor will maintain the following records: (1) Material

Safety Data Sheets or other similar certification from the

manufacturer of the fountain solution to document the 

concentrated VOC content, and (2) records of the dilution 

methods or calculations used to prepare the as-applied 

fountain solution used in the off-set lithographic 

presses. 

 

Acceptable analytical methods for determining the volatile

content, water content, density, volume of solids and 

weight of solids of the fountain solution are presented in

Appendix A, Methods 24, of 40CFR60. Alternate analytical 

methods must be approved by the commissioner and the 

USEPA. 

All records are to be kept on site for a period of five 

years and made available to Department representatives 

during normal business hours. Department representatives 

shall be permitted, during reasonable business hours, to 

obtain fountain solution samples to determine compliance.

Work Practice Type: PARAMETER OF PROCESS MATERIAL

Process Material: FOUNTAIN SOLUTION

Parameter Monitored: VOC CONTENT

Upper Permit Limit: 10 percent by weight

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Reference Test Method: Method 24 (40CFR60)

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Averaging Method: MAXIMUM - NOT TO BE EXCEEDED AT ANY 

 TIME (INSTANTANEOUS/DISCRETE OR GRAB)

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 36: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 234.3(b)(1)

Item 36.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0002

Process: 02B

Regulated Contaminant(s):

CAS No: 0NY998-00-0 VOC

Item 36.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: WORK PRACTICE INVOLVING SPECIFIC 

 OPERATIONS

Monitoring Description: 

Compliance with the maximum allowable 15 percent by 

weight or less of volatile organic compounds content in 

the fountain solution for press EQ200 will be demonstrated

through dilution calculation records and sample test 

results.

The fountain solution is purchased in a concentrated form.

 The manufacture of the fountain solution recommends a 

certain dilution to obtain the recommended operating 

formulation. Quebecor shall prepare the as-applied 

fountain solution in accordance with the recommended 

formulation. Alternatively, Quebecor may calculate a 

formulation using the VOC content of the concentrated 

fountain solution and a predetermined amount of water to 

obtain a diluted solution with a VOC content less than the

regulated value.

 Air Pollution Control Permit Conditions

Renewal 1 Page 46 of 86 FINAL
Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Quebecor has a centralized fountain solution formulation 

which was tested to determine the VOC content in June, 

2006. This formulation typically does not change. The 

fountain solution will be analyzed if the formulation is 

changed.

In order to demonstrate continued compliance with the 

maximum allowable VOC content of the fountain solution, 

Quebecor will maintain the following records: (1) Material

Safety Data Sheets or other similar certification from the

manufacturer of the fountain solution to document the 

concentrated VOC content, and (2) records of the dilution 

methods or calculations used to prepare the as-applied 

fountain solution used in the off-set lithographic 

presses. These records must be maintained at the 

facility for a period of five years, and upon request be 

submitted to the department's 

representative.

Acceptable analytical methods for determining the volatile

content, water content, density, volume of solids and 

weight of solids of the fountain solution are presented in

Appendix A, Methods 24, of 40CFR60. Alternate analytical 

methods must be approved by the commissioner and the 

USEPA. 

All records are to be kept on site for a period of five 

years and made available to Department representatives 

during normal business hours. Department representatives 

shall be permitted, during reasonable business hours, to 

obtain fountain solution samples to determine compliance.

Work Practice Type: PARAMETER OF PROCESS MATERIAL

Process Material: FOUNTAIN SOLUTION

Parameter Monitored: VOC CONTENT

Upper Permit Limit: 15 percent by weight

Reference Test Method: method 24 (40CFR60)

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Averaging Method: MAXIMUM - NOT TO BE EXCEEDED AT ANY 

 TIME (INSTANTANEOUS/DISCRETE OR GRAB)

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 37: Compliance Certification

 Air Pollution Control Permit Conditions

Renewal 1 Page 47 of 86 FINAL
Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 234.4(c)(2)

Item 37.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0002

Process: 02B Emission Source: EQ200

Regulated Contaminant(s):

CAS No: 0NY998-00-0 VOC

Item 37.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: MONITORING OF PROCESS OR CONTROL 

 DEVICE PARAMETERS AS SURROGATE

Monitoring Description: 

The off-set lithographic web press, identified as Press 

200, is operated using a fountain solution with a 15% by 

weight or less of volatile organic compounds as the 

compliance method. A Regenerative Thermal Oxidizer 

(catalytic afterburner), identified as emission source 

CT078, was installed with the press as original 

equipment.

Quebecor will assure that the VOC-laden gas stream from an

operating Press 200 will be routed to a properly operating

catalytic afterburner. This is accomplished by the 

interlocked afterburner and press system, which only 

allows operation of the press if the catalyst bed 

temperature is at least 700 degrees F. This assures that 

the VOC-laden gas stream from the press in printing mode 

can not pass through an insufficiently warmed afterburner 

which would be incapable of a sufficient destruction 

efficiency. 

Quebecor will continuously monitor the temperature of the 

inlet gas stream to the afterburner. The temperature will

be maintained at or above 675 degrees F to assure the 

minimum destruction efficiency based on catalyst analyses.

Continuous monitors to measure the temperature at the 

inlet and outlet of the catalytic incinerator bed must be 

installed, periodically calibrated, and operated at all 

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

times the associated control equipment is operating. 

Operation and calibration procedures shall be performed in

accordance with manufacturer specifications. The catalyst

beds will be inspected for cracks, gaps, and leaks on a 

quarterly basis, with inspection results recorded in a log

format acceptable to the Department. This log shall be 

maintained on-site for a period of 5 years and be made 

available for review upon request by the Department.

Parameter Monitored: TEMPERATURE

Upper Permit Limit: 675 degrees Fahrenheit

Monitoring Frequency: CONTINUOUS

Averaging Method: MINIMUM - NOT TO FALL BELOW STATED 

 VALUE AT ANY TIME

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 38: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 225-1.2(a)(2)

Item 38.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0003

Item 38.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: WORK PRACTICE INVOLVING SPECIFIC 

 OPERATIONS

Monitoring Description: 

No person shall use, purchase, sell, or offer for sale 

any residual fuel oil which has a sulfur content greater 

than the limit presented below. A log of the sulfur 

content in oil per delivery must be maintained on site for

a minimum of five years after the date of the last 

entry.

Work Practice Type: PARAMETER OF PROCESS MATERIAL

Process Material: RESIDUAL FUEL (#4, #5 AND/OR #6 FUEL OIL)

Parameter Monitored: SULFUR CONTENT

Upper Permit Limit: 1.5 percent

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

 DESCRIPTION

Averaging Method: MAXIMUM - NOT TO BE EXCEEDED AT ANY 

 TIME (INSTANTANEOUS/DISCRETE OR GRAB)

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 39: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 225-1.8(a)

Item 39.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0003

Item 39.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

The permittee shall retain fuel oil supplier 

certifications for each shipment of oil received. Such 

certifications shall contain, as a minimum: supplier 

name, date of shipment, quantity shipped, heating 

value of the oil, oil sulfur content, and the method used 

to determine the sulfur content. Such certifications 

shall be available for inspection by, or submittal to, 

NYSDEC upon request.

Monitoring Frequency: PER DELIVERY

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 40: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 227-1.3(a)

Item 40.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0003

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Item 40.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: MONITORING OF PROCESS OR CONTROL 

 DEVICE PARAMETERS AS SURROGATE

Monitoring Description: 

No person shall cause or allow emissions having an 

average opacity during any six consecutive minutes of 20 

percent or greater from any emission source, except for 

one six-minute period per hour of not more than 27 percent

opacity, or only the emission of uncombined water. The 

Department reserves the right to perform or require the 

performance of a Method 9 opacity evaluation at any time 

during facility operation.

The permittee will conduct observations of visible 

emissions from the facility on a daily basis. The 

permittee will immediately investigate any instance where 

there is cause to believe that visible emissions above 

those that are normal and in compliance are occurring or 

have occurred.

If visible emissions above those that are normal (this may

be zero percent opacity for many or all emission sources) 

and in compliance with 6NYCRR Part 227.1.3(a) are 

detected, the permittee shall determine the cause, make 

the necessary correction, and verify that the excess 

visible emissions problem has been corrected. 

If visible emissions above those that are normal and in 

compliance continue to be present after corrections are 

made, the permittee will immediately notify the Department

and conduct a Method 9 assessment within 24 hours to 

determine the degree of opacity.

Records of these observations, investigations and 

corrective actions will be kept on-site in a format 

acceptable to the Department.

Parameter Monitored: OPACITY

Upper Permit Limit: 20 percent

Monitoring Frequency: DAILY

Averaging Method: MAXIMUM - NOT TO EXCEED STATED VALUE -

 SEE MONITORING DESCRIPTION

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 41: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 227-2.4(d)

Item 41.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0003

Item 41.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

A boiler tune-up shall be performed annually. The owner 

or operator of a small boiler shall maintain a log (in the

format acceptable to the Department) containing the 

following information: (1) The date which the equipment 

was adjusted; and (2) The name, title, and affiliation of 

the person who adjusted the equipment.

Monitoring Frequency: ANNUALLY

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 42: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.7506(b), Subpart DDDDD

Item 42.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0003

Item 42.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Quebecor’s three dual-fuel boilers are capable of burning

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

natural gas and residual fuel oils. Each has a rated heat 

input capacity of 25 MMBtu/hr. The boilers identified as 

EQ064 and EQ065 were constructed in 1961, while emission 

source EQ063 was constructed in 1979. The boilers are 

subject to 40CFR63 Subpart DDDDD, Industrial, Commercial 

and Institutional Boilers, and are considered “existing 

large liquid fuel units”. This boiler category is subject 

to only the initial notification requirements in 40CFR63 

Subpart A, §63.9(b) and is not subject to the emission 

limits, operating limits, or work practice standards in 

40CFR63 Subpart DDDDD. The initial notification mustbe 

submitted to the Administrator no later than September 13,

2007.

Monitoring Frequency: SINGLE OCCURRENCE

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 43: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 234.4(c)(3)

Item 43.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0004

Regulated Contaminant(s):

CAS No: 0NY998-00-0 VOC

Item 43.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Quebecor utilizes three solvent recovery systems, 

identified as CT068, CT071, and CT075, to capture and 

recover VOC emissions from each of the publication 

rotogravure printing presses, identified as emission 

sources EQ210, EQ211, EQ212, EQ214, EQ217, and 

EQ218.

The solvent recovery systems are designed and operated to 

adsorb organic vapors from the exhaust air collected from 

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

the rotogravure printing processes by passing the gas 

stream through carbon beds. Each carbon bed has a maximum

organic vapor adsorption capacity. The point at which the

maximum capacity is reached is called breakthrough. The 

carbon beds are operated so that any one bed of the total 

system never reaches the breakthrough point. 

There are VOC detectors on the outlet of each carbon bed 

to indicate if high VOC concentrations exist in the gas 

stream that is leaving the carbon bed and entering the 

ambient air. A set point of 50 parts per million (ppm) is 

used to determine when the working capacity of a carbon 

bed has been reached. Once the working capacity has been 

reached, the solvent laden air is directed to the next 

on-line nonsaturated carbon bed and the saturated bed is 

regenerated by steaming. VOC detectors, serving as a 

continuous monitoring device, are operated at all times 

the associated solvent recovery systems are operated. 

Calibration of the three VOC detectors using a span gas of

100 ppm toluene is completed on a weekly basis. This 

information along with any variation from the setpoint 

before resetting is recorded in a log book, in a format 

acceptable to the Department, which will be maintained 

on-site for a period of 5 years and be made available for 

review upon request by the Department. 

In addition, the solvent recovery systems are backed up by

a system that schedules steaming on a time basis to ensure

breakthrough does not occur.

Monitoring Frequency: CONTINUOUS

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 44: Recordkeeping requirements.

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 60.7(b), NSPS Subpart A

Item 44.1:

This Condition applies to Emission Unit: E-G0004

Item 44.2:

Affected owners or operators shall maintain records of occurrence and duration of any startup, 

shutdown, or malfunction in the operation of an affected facility; any malfunction of the air pollution 

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

control equipment; or any periods during which a continuous monitoring system or monitoring device is 

inoperative.

Condition 45: Compliance with Standards and Maintenance Requirements

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 60.11(d), NSPS Subpart A

Item 45.1:

This Condition applies to Emission Unit: E-G0004

Item 45.2:

At all times, including periods of startup, shutdown, and malfunction, owners and operators of this facility 

shall, to the extent practicable, maintain and operate any affected facility including associated air pollution 

control equipment in a manner consistent with good air pollution control practice for minimizing 

emissions. Determination of whether acceptable operating and maintenance procedures are being used 

will be based on information available to the Department and the Administrator which may include, but is 

not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, 

and inspection of the source

Condition 46: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 60.435, NSPS Subpart QQ

Item 46.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0004

Item 46.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

At facilities with both existing and affected publication

rotogravure printing presses, both the existing and 

affected presses are subject to the test methods and 

procedures specified below.

The owner or operator of any affected facility using 

solvent-borne ink systems shall:

1. Determine the VOC content of the raw inks and related 

coatings used at the affected facility by:

a. Analysis using Reference Method 24A of routine weekly 

 Air Pollution Control Permit Conditions

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

samples of raw ink and related coatings in each respective

storage tank; or 

b. Analysis using Reference Method 24A of samples of each

shipment of all purchased raw inks and related coatings; 

or

c. Determination of the VOC content from the formulation 

data supplied by the ink manufacturer with each shipment 

of raw inks and related coatings.

2. Determine compliance when discrepancies with ink 

manufacturers' formulation data occur using the results of

verification analysis by Reference Method 24A.

3. Determine the density of raw inks, related coatings, 

and VOC solvents by using literature values, at specified 

temperatures, acceptable to the Administrator.

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 47: Part 63 General Provisions requirements

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.823, Subpart KK

Item 47.1:

This Condition applies to Emission Unit: E-G0004

Item 47.2:

Table 1 to 40CFR63 Subpart KK provides cross references to the 40CFR Part 63 Subpart A, General 

Provisions, indicating the applicability of the General Provisions requirements to Subpart KK. 

Condition 48: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.824(b)(1)(i), Subpart KK

Item 48.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0004

Regulated Contaminant(s):

 Air Pollution Control Permit Conditions

Renewal 1 Page 56 of 86 FINAL
Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

CAS No: 0NY100-00-0 HAP

Item 48.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: MONITORING OF PROCESS OR CONTROL 

 DEVICE PARAMETERS AS SURROGATE

Monitoring Description: 

Quebecor utilizes a solvent recovery system to capture 

and recover hazardous air pollutant (HAP) emissions from 

each of the publication rotogravure printing processes at 

the facility. The solvent recovery system provides for an 

overall control of at least 92% of organic HAP used. 

Quebecor performs a liquid-to-liquid material balance for 

each month to demonstrate continued compliance. The 

overall effective organic HAP control efficiency (Re) is 

calculated using the following formula:

Re = (100) X (Mvu-Mhu) + ((Mvr)(Mhu/Mvu))

 

------------------------------------------ 

 

 

Mvu

where,

Mvu = the mass of volatile matter, including water, used 

in a month, pounds mass

Mhu = the mass of organic HAP used in a month, pounds 

mass

Mvr = the mass of volatile matter recovered in a month, 

pounds mass

The mass of volatile matter used consists of VOC present 

in the ink and dilution solvent. The ink and dilution 

solvent values are each determined by recording the 

volume, in gallons, from non-resettable totalizing meters.

The recorded volumes are multiplied by the appropriate 

density and percent VOC content to obtain the mass of VOC 

used. The ink solvent and dilution solvent are then added 

together to obtain a total VOC usage in 

pounds.

Quebecor determines the mass of volatile matter recovered 

by measuring the solvent sold, dilution solvent used, wash

tank solvent used, and the gain or loss of the solvent 

tanks. The solvent sold is determined based on stick 

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measurements of the tank and compared with metered values 

obtained from the purchaser of the recovered solvent. The 

dilution solvent and wash tank solvent are determined by 

totalizing meters. The gain or loss of solvent from the 

solvent tanks is determined based on stick measurements of

the tanks. 

The mass of organic HAP used is determined by multiplying 

the mass of volatile matter used by the organic HAP weight

fraction of the recovered solvent. As stated in the 

regulation, for purposes of this calculation, the mass 

fraction of organic HAP present in the recovered volatile 

matter is assumed to be equal to the mass fraction of 

organic HAP present in the volatile matter used. Quebecor

relies on formulation data provided by the manufacturer on

a Certified Product Data Sheet (CPDS) to obtain the weight

percent of HAP present in the recovered 

solvent.

Quebecor operates, maintains, and calibrates totalizing 

meters, according to manufacturer specifications, that 

indicate the cumulative amount of ink and solvent 

materials used. The solvent and ink totalizing meters are

read several times per month. The mechanical meters are 

calibrated on a yearly basis. The coreolis meters do not 

require calibration.

Parameter Monitored: OVERALL ORGANIC HAP CONTROL EFFICIENCY

Lower Permit Limit: 92 percent reduction by weight

Monitoring Frequency: MONTHLY

Averaging Method: CALENDAR MONTH AVERAGE

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 49: Exemption from performance test for solvent recovery 

devices

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.827(a)(3), Subpart KK

Item 49.1:

This Condition applies to Emission Unit: E-G0004

Item 49.2: An owner or operator using a control device to comply with with requirements of 

40CFR63.824-63.825 (Printing and Publishing NESHAP) is not required to conduct an initial 

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performance test to demonstrate compliance if the control device is a solvent recovery device and the 

owner or operator chooses to comply by means of a monthly liquid-liquid material balance.

Condition 50: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.827(b)(1), Subpart KK

Item 50.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0004

Regulated Contaminant(s):

CAS No: 0NY100-00-0 HAP

Item 50.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Quebecor has elected to rely on formulation data provided

by the manufacturer to determine the organic HAP 

weight-fraction of each ink, coating, solvent, and other 

material used in the publication rotogravure process. The

formulation data is provided on a Certified Product Data 

Sheet (CPDS) from the manufacturer and conforms with the 

following requirements:

(i) The manufacturer has included in the organic HAP 

content determination all HAP present at a level greater 

than 0.1 percent in any raw material used, weighted by the

mass fraction of each raw material used in the material, 

and

(ii) The manufacturer has determined the HAP content of 

each raw material present in the formulation by Method 311

of appendix A of 40CFR63, or by an alternate method 

approved by the Administrator, or by reliance on a CPDS 

from a raw material supplier prepared in accordance with 

40CFR63.827(b)(1)(iii)(A).

Monitoring Frequency: SINGLE OCCURRENCE

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

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Condition 51: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.829(b), Subpart KK

Item 51.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0004

Item 51.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Each owner or operator of an affected major source that 

is subject to 40CFR Part 63 Subpart KK shall maintain the 

following records on a monthly basis, in accordance with 

the requirements of 40CFR63.10(b)(1):

(1) Records specified in 40CFR63.10(b)(2), of all 

measurements needed to demonstrate compliance with Subpart

KK, such as continuous emission monitor data, control 

device and capture system operating parameter data, 

material usage, HAP usage, volatile matter usage, and 

solids usage that support data that the source is required

to report.

(2) Records specified in 40CFR63.10(c) for each 

continuous monitoring system operated by the owner or 

operator in accordance with the requirements of 

40CFR63.828(a).

Monitoring Frequency: MONTHLY

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 52: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.829(c), Subpart KK

Item 52.1:

The Compliance Certification activity will be performed for:

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Emission Unit: E-G0004

Regulated Contaminant(s):

CAS No: 0NY100-00-0 HAP

Item 52.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Each owner or operator of an affected source which is 

using a solvent recovery device to comply with Subpart KK 

and is performing a liquid-liquid material balance for 

each month in order to demonstrate 

compliance with Subpart KK shall maintain records of all 

liquid-liquid material balances performed. 

The records shall be kept for a period of five years and 

shall be maintained in accordance with the requirements of

40CFR63.10(b). The requirements of 40CFR63.10(b) include,

but are not limited to, the following:

1. Files of all information shall be maintained in a form

suitable and readily available for expeditious inspection 

and review. 

2. At a minimum, the most recent 2 years of data shall be

retained on site. The remaining 3 years of data may be 

retained off site. Such files may be maintained on 

microfilm, on a computer, on computer floppy disks, on 

magnetic tape disks, or on microfiche.

3. The facility owner shall maintain records of all 

malfunctions and the actions taken to correct these 

malfunctions.

4. The facility owner shall maintain records of all 

measurements related to calibrations, adjustments, and 

maintenance on the system.

Monitoring Frequency: MONTHLY

Averaging Method: CALENDAR MONTH TOTAL

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 53: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Applicable Federal Requirement: 40CFR 63.830(b)(5), Subpart KK

Item 53.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0004

Item 53.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Each owner or operator of an affected source subject to 

40CFR63 Subpart KK that is using a control device to 

comply with Subpart KK shall submit start-up, shutdown, 

and malfunction reports as specified in Section 

63.10(d)(5). 

The start-up, shutdown, and malfunction report shall be 

submitted semiannually. The report shall be delivered or 

postmarked by the 30th day following the end of each 

calendar half. Reports shall only be 

required if a start-up, shutdown, or malfunction occurred 

during the reporting period. 

If actions taken by an owner or operator during a 

start-up, shutdown, or malfunction of an affected source 

(including actions taken to correct a malfunction) are not

completely consistent with the procedures specified in the

source's start-up, shutdown, and malfunction plan 

specified in Section 63.6(e)(3), the owner or operator 

shall state such information in the report. The start-up,

shutdown, or malfunction plan shall consist of a letter 

containing the name, title, and signature of the 

responsible official who is certifying its accuracy, that 

shall be submitted to the Department.

Separate start-up, shutdown, or malfunction reports are 

not required if the information is included in the 

semiannual report for the affected source.

Monitoring Frequency: CONTINUOUS

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

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Condition 54: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 234.3(a)(3)(i)

Item 54.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0004

Process: 04A Emission Source: EQ210

Regulated Contaminant(s):

CAS No: 0NY998-00-0 VOC

Item 54.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: MONITORING OF PROCESS OR CONTROL 

 DEVICE PARAMETERS AS SURROGATE

Monitoring Description: 

Quebecor utilizes a solvent recovery system to capture 

and recover VOC emissions from each of the publication 

rotogravure printing processes at the facility. In 

accordance with 6NYCRR Part 234.3, the capture system and 

the air cleaning device must provide for an overall 

reduction in volatile organic compound emissions of at 

least 75% where a publication rotogravure process is 

employed. One of the six rotogravure presses is subject 

to a more stringent regulation, 40CFR60 Subpart QQ, which 

requires an overall reduction of 84%. Quebecor has chosen 

to have all of the six presses subject to 40CFR60 Subpart 

QQ, superseding the requirement for 6NYCRR Part 234. 

Parameter Monitored: SOLVENT RECOVERY RATE

Lower Permit Limit: 75 percent reduction

Monitoring Frequency: MONTHLY

Averaging Method: CALENDAR MONTH AVERAGE

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 55: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Applicable Federal Requirement: 6NYCRR 212.4(b)

Item 55.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0005

Regulated Contaminant(s):

CAS No: 007738-94-5 CHROMIC ACID

Item 55.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Chromic acid is given an environmental rating of A. The 

emission rate potential of chomic acid from the 

electroplating process is less than 1.0 pound per hour. In

accordance with 6NYCRR Part 212.4(b), the degree of air 

cleaning required for these stated emissions shall be 

specified by the Department. The Department considers 

demonstration of compliance with 40CFR63 Subpart N, the 

"National Emission Standards for Chromium Emissions from 

Hard and Decorative Chromium Anodizing Tanks", as 

satisfying the emission requirements of Part 212.4.

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 56: Part 63 General Provisions requirements

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.340(b), Subpart N

Item 56.1:

This Condition applies to Emission Unit: E-G0005

Item 56.2:

Owners or operators of affected sources subject to 40CFR63 Subpart N must also comply with the 

requirements of Subpart A of Part 63, according to the applicability of Subpart A to such sources, as 

identified in Table 1 of Subpart N. Subpart A is the General Provisions for the NESHAP for Source 

Categories regulations. The General Provisions contain requirements for performance testing, monitoring, 

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notification, recordkeeping, reporting, and control devices that may apply to the source.

Condition 57: Standards apply during all tank operation

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.342(b)(1), Subpart N

Item 57.1:

This Condition applies to Emission Unit: E-G0005

Item 57.2:

The emission limits of 40CFR63.342 apply only during tank operation, and also apply during periods of 

start-up and shutdown as these are routine occurrences for affected sources subject to 40CFR63 Subpart 

N. The emission limitations do not apply during periods of malfunction, but the work practice standards 

that address operation and maintenance and that are required by 40CFR63.342(f) must be followed during 

malfunctions.

Condition 58: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.342(c)(3), Subpart N

Item 58.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0005

Regulated Contaminant(s):

CAS No: 007440-47-3 CHROMIUM

Item 58.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: MONITORING OF PROCESS OR CONTROL 

 DEVICE PARAMETERS AS SURROGATE

Monitoring Description: 

The potential cumulative rectifier capacity of the two 

chromium electroplating tanks, identified as emission 

sources CHR03 & CHR04, is greater than 60 million 

ampere-hours per year which classifies Quebecor as a large

electroplating facility. Quebecor has chosen to 

demonstrate the actual cumulative rectifier capacity is 

less than 60 million amp-hr/yr for the facility. This 

demonstration allows Quebecor to alternatively be 

considered a small hard chromium electroplating 

facility.

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Quebecor is required to keep monthly records of actual 

ampere-hr usage for each rectifier using nonresettable 

ampere-hr meters on each rectifier. Quebecor is also 

required to compute the actual cumulative rectifier 

capacity for each 12-month rolling period. This shall be 

tabulated by adding the capacity for the current month to 

the capacities for the previous 11 months.

If the monthly records show the actual cumulative 

rectifier capacity exceed the 60 million ampere-hr/yr 

limit, the source must comply with the emission limit of 

0.015 milligrams of total chromium per dry standard cubic 

meter of ventilation air, which is the limit for a large 

hard chromium electroplating facility. Compliance with 

the lower limit must be demonstrated no later than one 

year after the month in which monthly records show the 60 

million ampere-hr/yr limit is exceeded.

Process Material: PLATED PRODUCT

Parameter Monitored: CUMULATIVE POTENTIAL RECTIFIER CAPACITY

Upper Permit Limit: 60 millions of amp hours per year

Monitoring Frequency: MONTHLY

Averaging Method: ANNUAL MAXIMUM ROLLED MONTHLY

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 59: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.342(f), Subpart N

Item 59.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0005

Regulated Contaminant(s):

CAS No: 007440-47-3 CHROMIUM

Item 59.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Quebecor is subject to the work practice standards for 

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the hard chromium electroplating tanks, identified as 

emission sources CHR03 & CHR04. In accordance with these 

requirements, Quebecor prepared an Operation and 

Maintenance Plan (Plan) for the electroplating tanks. The

Plan specifies procedures for the proper operation and 

maintenance of the tanks, use of the fume suppressant, and

operation of the mist eliminators. The Plan also includes

a summary of the work practice standards to be followed 

for each control technique. Quebecor will evaluate the 

results of the work practice standard check lists to 

ensure that malfunctions due to poor maintenance and other

preventable conditions do not occur. 

At all times, including periods of startup, shutdown, and 

malfunction, Quebecor shall operate and maintain the 

electroplating tanks, including associated air pollution 

control devices and monitoring equipment, in a manner 

consistent with good air pollution control practices, 

consistent with the Plan. Malfunctions shall be corrected 

as soon as practicable after their occurrence in 

accordance with the Plan.

Determination of whether acceptable operation and 

maintenance procedures are being used will be based on 

information available to the Administrator, which may 

include, but is not limited to, monitoring results; review

of the operation and maintenance plan, procedures, and 

records; and inspection of the source. Based on the 

results of a determination, the Administrator may require 

that Quebecor make changes to the Plan for that source. 

Revisions may be required if the Administrator finds that 

the plan:

(A) Does not address a malfunction that has 

occurred;

(B) Fails to provide for the operation of the 

electroplating tanks, the air pollution control system and

process monitoring equipment during a malfunction in a 

manner consistent with good air pollution control 

practices; or

(C) Does not provide adequate procedures for correcting 

malfunctioning process equipment, air pollution control 

techniques, or monitoring equipment as quickly as 

possible.

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

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Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 60: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.343(c)(5), Subpart N

Item 60.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0005

Regulated Contaminant(s):

CAS No: 007440-47-3 CHROMIUM

Item 60.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: MONITORING OF PROCESS OR CONTROL 

 DEVICE PARAMETERS AS SURROGATE

Monitoring Description: 

During the initial performance tests for the chromium 

electroplating tanks identified as CHR03 & CHR04 conducted

on October 25 & 26, 2000, and April 4, 2002, respectively,

Quebceor measured the surface tension of the chrome 

electroplating baths as site-specific operating 

parameters. The average surface tensions measured were 

22.9 and 22 dynes/cm, for CHR03 & CHR04, respectively. 

Quebecor has designated the composite mesh pad filters of 

the two electroplating tanks as the control technique to 

be used as the main compliance indicator. Pressure drops 

across each filter is monitored daily in accordance with 

40CFR63.343(c)(1) and Permit Conditions #64 & 65. 

Monitoring of the surface tension of each tank is a 

secondary indicator which is not required for compliance 

with 40CFR63 Subpart N. 

40CFR63.343(c)(5) allows for the acceptance of 35 dynes/cm

as the maximum surface tension value that corresponds to 

compliance with the applicable emission limitation in lieu

of establishing the maximum surface tension during the 

performance test, if the criteria 40CFR63.343(b)(2) are 

met. Since Quebecor met those criteria and are monitoring 

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surface tension voluntarily on a monthly basis as an 

additional compliance indicator, the acceptable surface 

tension limit is set at 35 dynes/cm.

Parameter Monitored: SURFACE TENSION

Upper Permit Limit: 35 dynes per centimeter

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Averaging Method: MAXIMUM - NOT TO BE EXCEEDED AT ANY 

 TIME (INSTANTANEOUS/DISCRETE OR GRAB)

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 61: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.344(d)(1), Subpart N

Item 61.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0005

Regulated Contaminant(s):

CAS No: 007440-47-3 CHROMIUM

Item 61.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: WORK PRACTICE INVOLVING SPECIFIC 

 OPERATIONS

Monitoring Description: 

During the initial performance tests for the chromium 

electroplating tanks identified as CHR03 & CHR04 conducted

on October 25 & 26, 2000, and April 4, 2002, respectively,

Quebecor chose to limit the number of rotogravure 

cylinders processed through the plating tanks. A maximum 

of two (2) cylinders per hour were electroplated during 

the performance tests. The facility is limited to 

electroplating a maximum of two (2) rotogravure cylinders 

per hour in each individual tank. The facility will 

maintain a log book to document the date and time each 

cylinder is electroplated in the tanks. The log book shall

be maintained on-site for a period of 5 years, and be made

available for review upon request by the Department.

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Work Practice Type: PROCESS MATERIAL THRUPUT

Process Material: ITEMS

Upper Permit Limit: 2 number (or quantity) per hour

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Averaging Method: 1 HOUR MAXIMUM - NOT TO BE EXCEEDED AT

 ANY TIME

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 62: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.346(b), Subpart N

Item 62.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0005

Regulated Contaminant(s):

CAS No: 007440-47-3 CHROMIUM

Item 62.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Quebecor shall maintain the following records for the two

hard chromium electroplating tanks:

(1) Inspection records for the add-on air pollution 

control device and monitoring equipment, to document the 

inspection and maintenance required by the work practice 

standards have taken place. The records can take the form

of a checklist and should identify the device inspected, 

the date of the inspection, a brief description of the 

working condition of the device during the inspection, and

any actions taken to correct deficiencies found during the

inspection;

(2) Records of all maintenance performed on the affected 

source, the add-on air pollution control device, and 

monitoring equipment;

(3) Records of the occurrence, duration, and cause (if 

known) of each malfunction of process, add-on air 

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pollution control, and monitoring equipment;

(4) Records of actions taken during periods of 

malfunction when such actions are inconsistent with the 

operation and maintenance plan;

(5) Test reports documenting results of all performance 

tests;

(6) Records of surface tension measurements, number of 

cylinders processed per hour, and magnehelic gauge 

readings that are used to demonstrate compliance with the 

standard including the date and time the data are 

collected;

(7) The specific identification (i.e., the date and time 

of commencement and completion) of each period of excess 

emissions, as indicated by monitoring data, that occurs 

during malfunction of the process, add-on air pollution 

control, or monitoring equipment;

(8) The specific identification (i.e., the date and time 

of commencement and completion) of each period of excess 

emissions, as indicated by monitoring data, that occurs 

during periods other than malfunction of the process, 

add-on air pollution control, or monitoring 

equipment;

(9) The total process operating time of the affected 

source during the reporting period;

(10) Records of the actual cumulative rectifier capacity 

of the hard chromium electroplating tanks expended during 

each month of the reporting period, and the total capacity

expended to date for a reporting period;

(11) Records of the date and time that fume suppressants 

are added to the electroplating bath;

(12) All documentation supporting the notifications and 

reports required by 40CFR63.9, 40CFR63.10, and 

40CFR63.347.

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 63: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.347(g)(1), Subpart N

Item 63.1:

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The Compliance Certification activity will be performed for:

Emission Unit: E-G0005

Item 63.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Quebecor shall submit a summary report to the 

Administrator to document the ongoing compliance status of

the chromium electroplating tanks. The report shall be 

submitted semiannually, except if: 

(i) The Administrator determines on a case-by-case basis 

that more frequent reporting is necessary to accurately 

assess the compliance status of the source; or 

(ii) The monitoring data collected by Quebecor in 

accordance with 40CFR63.343(c) show that the emission 

limit has been exceeded, in which case quarterly reports 

shall be submitted. Once an exceedance is detected, 

ongoing compliance status reports shall be submitted 

quarterly until a request to reduce reporting frequency 

per 40CFR63.347(g)(2) is approved.

The report must contain the following information: 

(1) The company name and address of the affected source; 

(2) An identification of the operating parameter that is 

monitored for compliance determination, as required by 

40CFR63.343(c); 

(3) The relevant emission limitation for the affected 

source, and the operating parameter value, or range of 

values, that correspond to compliance with this emission 

limitation as specified in the notification of compliance 

status required by 40CFR63.347; 

(4) The beginning and ending dates of the reporting 

period; 

(5) A description of the type of process performed in the 

affected source; 

(6) The total operating time of the affected source during

the reporting period; 

(7) If the affected source is a hard chromium 

electroplating tank and the owner or operator is limiting 

the maximum cumulative rectifier capacity in accordance 

with 40CFR63.342(c)(2), the actual cumulative rectifier 

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capacity expended during the reporting period, on a 

month-by-month basis; 

(8) A summary of operating parameter values, including the

total duration of excess emissions during the reporting 

period as indicated by those values, the total duration of

excess emissions expressed as a

percent of the total source operating time during that 

reporting period, and a breakdown of the total duration of

excess emissions during the reporting period into those 

that are due to process upsets,

control equipment malfunctions, other known causes, and 

unknown causes; 

(9) A certification by a responsible official, as defined 

in 40CFR63 §63.2, that the work practice standards in 

40CFR63.342(f) were followed in accordance with the 

operation and maintenance plan for the source; 

(10) If the operation and maintenance plan required by 

40CFR63.342(f)(3) was not followed, an explanation of the 

reasons for not following the provisions, an assessment of

whether any excess emission and/or parameter monitoring 

exceedances are believed to have occurred, and a copy of 

the report(s) required by 40CFR63.342(f)(3)(iv) 

documenting that the operation and maintenance plan was 

not followed; 

(11) A description of any changes in monitoring, 

processes, or controls since the last reporting period; 

(12) The name, title, and signature of the responsible 

official who is certifying the accuracy of the report; and

(13) The date of the report.

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 64: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.343(c)(1), Subpart N

Item 64.1:

The Compliance Certification activity will be performed for:

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Emission Unit: E-G0005

Process: 05A Emission Source: CHR03

Regulated Contaminant(s):

CAS No: 007738-94-5 CHROMIC ACID

Item 64.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: MONITORING OF PROCESS OR CONTROL 

 DEVICE PARAMETERS AS SURROGATE

Monitoring Description: 

Quebecor completed the required performance test for the 

chromium electroplating tank identified as CHR03 on 

October 25 & October 26, 2000. The test results 

demonstrated compliance with the total chromium emissions 

limit of 0.03 mg/dscm. Continued compliance is assured via

the surrogate compliance indicator described below. 

CHR03 is equipped with multiple control devices. A fume 

suppressant is followed by a plate and baffle scrubber 

which catches droplets of chromium mist. A composite mesh 

pad filter removes particles within the exhaust stream. 

The mesh pad is considered the main compliance indicator 

for the electroplating tanks. A magnehelic gauge measures 

the pressure drop across the mesh pad filter.

During the performance test conducted on October 25 & 26, 

2000, the pressure drop across the mesh pad filter as 

measured by the magnehelic gauge was 0.5 inches of water 

column. Quebecor must record the pressure drop readings a 

minimum of one time during each day of operation. The 

compliant range for pressure drop readings is no more than

+/- 2 inches of water column from the performance test 

values. 

The pressure drop readings shall be documented, maintained

on-site for a period of 5 years, and be made available for

review upon request by the Department. Quebecor must 

ensure that appropriate maintenance procedures are 

followed so that the mesh pad filter performs 

effectively.

Parameter Monitored: PRESSURE CHANGE

Lower Permit Limit: 0 inches of water

Upper Permit Limit: 2.5 inches of water

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Monitoring Frequency: DAILY

Averaging Method: RANGE - NOT TO FALL OUTSIDE OF STATED 

 RANGE AT ANY TIME

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 65: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.343(c)(1), Subpart N

Item 65.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0005

Process: 05A Emission Source: CHR04

Regulated Contaminant(s):

CAS No: 007738-94-5 CHROMIC ACID

Item 65.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: MONITORING OF PROCESS OR CONTROL 

 DEVICE PARAMETERS AS SURROGATE

Monitoring Description: 

Quebecor completed the required performance test for the 

chromium electroplating tanks identified as CHR04 on April

4, 2002. The test results demonstrated compliance with the

total chromium emissions limit of 0.03 mg/dscm. Continued 

compliance is assured via the surrogate compliance 

indicator described below. 

CHR04 is equipped with multiple control devices. A fume 

suppressant is followed by a plate and baffle scrubber 

which catches droplets of chromium mist. A composite mesh 

pad filter removes particles within the exhaust stream. 

The mesh pad is considered the main compliance indicator 

for the electroplating tanks. A magnehelic gauge measures

the pressure drop across the mesh pad filter.

During the performance test conducted on April 4, 2002, 

the pressure drop across the mesh pad filter as measured 

by the magnehelic gauge was 2.2 inches of water column. 

Quebecor must record the pressure drop readings a minimum 

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

of one time during each day of operation. The compliant 

range for pressure drop readings is no more than +/- 2 

inches of water column from the performance test values. 

The pressure drop readings shall be documented, maintained

on-site for a period of 5 years, and be made available for

review upon request by the Department. Quebecor must 

ensure that appropriate maintenance procedures are 

followed so that the mesh pad filter performs 

effectively.

Parameter Monitored: PRESSURE CHANGE

Lower Permit Limit: .20 inches of water

Upper Permit Limit: 4.2 inches of water

Monitoring Frequency: DAILY

Averaging Method: RANGE - NOT TO FALL OUTSIDE OF STATED 

 RANGE AT ANY TIME

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 66: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 212.10(c)(1)

Item 66.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0006

Process: 06A

Regulated Contaminant(s):

CAS No: 0NY998-00-0 VOC

Item 66.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: MONITORING OF PROCESS OR CONTROL 

 DEVICE PARAMETERS AS SURROGATE

Monitoring Description: 

Quebecor has demonstrated a RACT non-applicability for 

the process which involves melting of glue beads and 

application of the melted glue to the book binders. The 

glue contains 2% of volatile organic compounds. The nine

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glue machines are each vented to separate emission points.

 The emission rate for each machine is determined based 

on the total pounds of glue used in each glue machine, 

multiplied by 0.0002, and divided by the total hours of 

operation for each machine. The actual emission rate of 

each emission point was demonstrated to be less than 3 

pounds per hour. Quebecor will reevaluate the RACT 

applicability if a new glue formulation with a greater VOC

content is used.

Parameter Monitored: VOC CONTENT

Upper Permit Limit: 3 pounds per hour

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Averaging Method: 1 HOUR MAXIMUM - NOT TO BE EXCEEDED AT

 ANY TIME

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 68: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 228.7

Item 68.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0006

Process: 06B

Regulated Contaminant(s):

CAS No: 0NY998-00-0 VOC

Item 68.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: WORK PRACTICE INVOLVING SPECIFIC 

 OPERATIONS

Monitoring Description: 

Paper coating lines may contain a maximum of 2.9 pounds 

of VOC (minus water and excluded VOC) per gallon of 

coating as applied.

Work Practice Type: PARAMETER OF PROCESS MATERIAL

Process Material: COATING

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Parameter Monitored: VOC CONTENT

Upper Permit Limit: 2.9 pounds per gallon

Averaging Method: MAXIMUM - NOT TO BE EXCEEDED AT ANY 

 TIME (INSTANTANEOUS/DISCRETE OR GRAB)

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 67: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 228.10

Item 67.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0006

Process: 06B

Item 67.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

Monitoring Description: 

Within the work area(s) associated with a coating line, 

the owner or operator of a facility subject to this Part 

must:

(a) use closed, non-leaking containers to store or 

dispose of cloth or other absorbent applicators 

impregnated with VOC solvents that are used for surface 

preparation, cleanup or coating removal;

(b) store in closed, non-leaking containers spent or 

fresh VOC solvents to be used for surface preparation, 

cleanup or coating removal;

(c) not use VOC solvents to cleanup spray equipment 

unless equipment is used to collect the cleaning compounds

and to minimize VOC evaporation;

(d) not use open containers to store or dispense surface 

coatings and/or inks unless production, sampling, 

maintenance or inspection procedures require operational 

access. This provision does not apply to the actual device

or equipment designed for the purpose of applying a 

coating material to a substrate. These devices may 

include, but are not limited to: spray guns, flow coaters,

dip tanks, rollers, knife coaters, and extrusion 

coaters;

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

(e) not use open containers to store or dispose of spent 

surface coatings, or spent VOC solvents;

(f) minimize spills during the handling and transfer of 

coatings and VOC solvents; and

(g) beginning on January 1, 2005, clean spray guns used 

to apply mobile equipment repair and refinishing or 

color-matched coatings by one of the following: 

(1) an enclosed spray gun cleaning system that is kept 

closed when not in use;

(2) non-atomized discharge of VOC solvent into a paint 

waste container that is kept closed when not in use;

(3) disassembling and cleaning of the spray gun in a vat 

that is kept closed when not in use; or

(4) atomized spray into a paint waste container that is 

fitted with a device designed to capture atomized VOC 

solvent emissions. 

Open containers, if found, shall be covered and such 

deviations shall be noted in a log maintained in the 

operating area. The log shall include the following 

information:

- date and time of observation 

- description of observed deviation from this permit 

condition 

- corrective measures taken, if necessary

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 69: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 6NYCRR 234.3(a)(1)

Item 69.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0008

Regulated Contaminant(s):

CAS No: 0NY998-00-0 VOC

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Item 69.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: WORK PRACTICE INVOLVING SPECIFIC 

 OPERATIONS

Monitoring Description: 

Quebecor operates six flexographic printing presses which

use a cold-set, isoparaphinic (wax), solvent-based, 

VOC-containing ink. Much like newspaper printing, the 

isoparaphinic ink is designed to dry by adsorption of the 

oils into the paper substrate. The USEPA has allowed the 

newsprint industry to use a 95% VOC retention factor into 

the newspaper when estimating emissions. Based on the 

Department's discussions with the USEPA, it was concluded 

the 95% retention factor also applies when estimating 

emissions from these presses. 

The volatile fraction of the ink, as it is applied to the 

substrate, shall be determined by using the equation 

specified in 6NYCRR Part 234.3(a)(1) and then multiplied 

by 0.05 to account for the 95% VOC retained by the 

substrate. Quebecor shall not operate, cause, allow or 

permit the operation of these presses unless the volatile 

fraction of ink, as it is applied to the substrate, 

contains 25% by volume or less of VOC and 75% by volume or

more of nonreactive volatiles. Compliance will be 

demonstrated through sample test data, required 

calculations, and manufacturer certifications. 

Quebecor generally has a specific ink formulation, which 

rarely changes, for the flexographic presses. An initial 

analysis of the as-applied, flexographic ink was completed

on May 5, 2000. The ink must be re-analyzed if the 

formulation is changed. The results of the analysis will 

be used to calculate the actual "volume fraction volatile 

organic compounds of ink" value using the equation in 

6NYCRR Part 234.3(a)(1)(i) and then multiplying the value 

by 0.05 to account for the 95% VOC retained by the 

substrate. In addition, the results of the analysis will 

be used to calculate the "maximum volume fraction of 

volatile organic compounds in a complying ink" value using

the equation in 6NYCRR Part 234.3(a)(1)(ii). Compliance 

is demonstrated by comparing the two values to show that 

the "volume fraction VOC in the actual ink" is less than 

the "maximum volume fraction VOC in the complying 

ink".

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Acceptable analytical methods for determining the volatile

content, water content, density, volume of solids and 

weight of solids of printing inks are presented in 

Appendix A, Methods 24 and 24A respectively, of 40CFR60. 

To demonstrate continued compliance with the maximum 

percent by volume of VOC in the ink, Quebecor will 

maintain Material Safety Data Sheets or other similar 

certification from the manufacturer of the ink to document

the volume fraction VOC of ink. Records must be 

maintained at the facility for five years.

The results of any analysis or other procedure used for 

establishing compliance with this Part must be provided to

the Department's representative. Department 

representatives shall be permitted, during reasonable 

business hours, to obtain ink samples for the purpose of 

determining compliance with this Part.

Work Practice Type: PARAMETER OF PROCESS MATERIAL

Process Material: INK

Parameter Monitored: VOC CONTENT

Upper Permit Limit: 25 percent by volume

Reference Test Method: Method 24

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING 

 DESCRIPTION

Averaging Method: MAXIMUM - NOT TO BE EXCEEDED AT ANY 

 TIME (INSTANTANEOUS/DISCRETE OR GRAB)

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

Condition 70: Compliance Certification

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable Federal Requirement: 40CFR 63.821(b)(2), Subpart KK

Item 70.1:

The Compliance Certification activity will be performed for:

Emission Unit: E-G0008

Regulated Contaminant(s):

CAS No: 0NY100-00-0 HAP

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Item 70.2:

Compliance Certification shall include the following monitoring:

Monitoring Type: WORK PRACTICE INVOLVING SPECIFIC 

 OPERATIONS

Monitoring Description: 

The six wide-web flexographic presses identified as 

emission sources EQ112, EQ114, EQ116, EQ117, EQ118, and 

EQ119 are subject to 40CFR60 Subpart KK since they are 

located at a facility which is a major source of hazardous

air pollutants (HAPs). Quebecor has chosen to limit use 

of organic HAP per wide-web flexographic press per month 

to no more than 400 kilograms to comply with the criteria 

stated in 40CFR 63.821(b)(2). This allows the wide-web 

flexographic presses to be subject only to compliance 

demonstration and initial notification requirements as 

stated below.

If any wide-web flexographic press does not comply with 

the limited HAP usage criteria for any month, it will 

immediately be subject to all relevant requirements of 

Subpart KK and will no longer be eligible to use the 

exempt provision even if in subsequent months the affected

source does comply with the criteria.

Quebecor must maintain the appropriate records to 

demonstrate compliance with the limited HAP usage 

criteria. The total monthly volume of ink usage and the 

organic HAP content of the ink must be maintained for each

wide-web flexographic press. A Certified Product Data 

Sheet (CPDS) from the ink supplier or manufacturer may be 

used to determine the organic HAP content of the ink. A 

CPDS will be required for each separate ink formulation. 

These records shall be maintained for five years, and upon

request be submitted to the Department. 

Quebecor is also required to submit an initial 

notification as required by 40CFR63.9(b), Subpart A.

Work Practice Type: PARAMETER OF PROCESS MATERIAL

Process Material: INK

Parameter Monitored: ORGANIC HAP CONTENT

Upper Permit Limit: 400 kilograms per month

Monitoring Frequency: MONTHLY

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

Averaging Method: CALENDAR MONTH TOTAL

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 1/30/2008.

Subsequent reports are due every 6 calendar month(s).

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

 STATE ONLY ENFORCEABLE CONDITIONS

 ** ** Facility Level ****

NOTIFICATION OF GENERAL PERMITTEE OBLIGATIONS

 This section contains terms and conditions which are not federally enforceable. Permittees may also

have other obligations under regulations of general applicability

Item A: General Provisions for State Enforceable Permit Terms and

Condition - 6 NYCRR Part 201-5

Any person who owns and/or operates stationary sources 

shall operate and maintain all emission units and any 

required emission control devices in compliance with all 

applicable Parts of this Chapter and existing laws, and 

shall operate the facility in accordance with all 

criteria, emission limits, terms, conditions, and 

standards in this permit. Failure of such person to 

properly operate and maintain the effectiveness of such 

emission units and emission control devices may be 

sufficient reason for the Department to revoke or deny a 

permit.

The owner or operator of the permitted facility must 

maintain all required records on-site for a period of five

years and make them available to representatives of the 

Department upon request. Department representatives must 

be granted access to any facility regulated by this 

Subpart, during normal operating hours, for the purpose of

determining compliance with this and any other state and 

federal air pollution control requirements, regulations or

law.

STATE ONLY APPLICABLE REQUIREMENTS

The following conditions are state applicable requirements and are not subject to compliance

 certification requirements unless otherwise noted or required

under 6 NYCRR Part 201.

Condition 71: Contaminant List

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable State Requirement: ECL 19-0301

Item 71.1:

Emissions of the following contaminants are subject to contaminant specific requirements in this 

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Permit ID: 9-1430-00213/00110 Facility DEC ID: 9143000213

permit(emission limits, control requirements or compliance monitoring conditions).

CAS No: 007738-94-5

Name: CHROMIC ACID

CAS No: 007440-47-3

Name: CHROMIUM

CAS No: 0NY100-00-0

Name: HAP

CAS No: 0NY075-00-0

Name: PARTICULATES

CAS No: 0NY998-00-0

Name: VOC

Condition 72: Unavoidable noncompliance and violations

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable State Requirement: 6NYCRR 201-1.4

Item 72.1:

At the discretion of the commissioner a violation of any applicable emission standard for necessary 

scheduled equipment maintenance, start-up/shutdown conditions and malfunctions or upsets may be 

excused if such violations are unavoidable. The following actions and recordkeeping and reporting 

requirements must be adhered to in such circumstances.

(a) The facility owner and/or operator shall compile and maintain records of all equipment 

maintenance or start-up/shutdown activities when they can be expected to result in an exceedance of any 

applicable emission standard, and shall submit a report of such activities to the commissioner's 

representative when requested to do so in writing or when so required by a condition of a permit issued 

for the corresponding air contamination source except where conditions elsewhere in this permit which 

contain more stringent reporting and notification provisions for an applicable requirement, in which case 

they supercede those stated here. Such reports shall describe why the violation was unavoidable and shall 

include the time, frequency and duration of the maintenance and/or start-up/shutdown activities and the 

identification of air contaminants, and the estimated emission rates. If a facility owner and/or operator is 

subject to continuous stack monitoring and quarterly reporting requirements, he need not submit reports 

for equipment maintenance or start-up/shutdown for the facility to the commissioner's representative.

(b) In the event that emissions of air contaminants in excess of any emission standard in 6 NYCRR 

Chapter III Subchapter A occur due to a malfunction, the facility owner and/or operator shall report such 

malfunction by telephone to the commissioner's representative as soon as possible during normal working 

hours, but in any event not later than two working days after becoming aware that the malfunction 

occurred. Within 30 days thereafter, when requested in writing by the commissioner's representative, the 

facility owner and/or operator shall submit a written report to the commissioner's representative 

describing the malfunction, the corrective action taken, identification of air contaminants, and an estimate 

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of the emission rates. These reporting requirements are superceded by conditions elsewhere in this 

permit which contain reporting and notification provisions for applicable requirements more stringent 

than those above.

(c) The Department may also require the owner and/or operator to include in reports described 

under (a) and (b) above an estimate of the maximum ground level concentration of each air contaminant 

emitted and the effect of such emissions depending on the deviation of the malfunction and the air 

contaminants emitted.

(d) In the event of maintenance, start-up/shutdown or malfunction conditions which result in 

emissions exceeding any applicable emission standard, the facility owner and/or operator shall take 

appropriate action to prevent emissions which will result in contravention of any applicable ambient air 

quality standard. Reasonably available control technology, as determined by the commissioner, shall be 

applied during any maintenance, start-up/shutdown or malfunction condition subject to this paragraph.

(e) In order to have a violation of a federal regulation (such as a new source performance standard or 

national emissions standard for hazardous air pollutants) excused, the specific federal regulation must 

provide for an affirmative defense during start-up, shutdowns, malfunctions or upsets.

Condition 73: Air pollution prohibited

Effective between the dates of 08/30/2007 and 08/29/2012

Applicable State Requirement: 6NYCRR 211.2

Item 73.1:

No person shall cause or allow emissions of air contaminants to the outdoor atmosphere of such quantity, 

characteristic or duration which are injurious to human, plant or animal life or to property, or which 

unreasonably interfere with the comfortable enjoyment of life or property. Notwithstanding the existence 

of specific air quality standards or emission limits, this prohibition applies, but is not limited to, any 

particulate, fume, gas, mist, odor, smoke, vapor, pollen, toxic or deleterious emission, either alone or in 

combination with others.

 Air Pollution Control Permit Conditions

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