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Concord Litho Group, Inc. ] FINAL RACT ORDER 92 Old Turnpike Road ] September 17, 2007 Concord, NH 03301 ] ARD07-003

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A. Introduction
This RACT Order is issued by the New Hampshire Depa rtment of Environmental Services, Air Resources Division, to Concord Litho Group, Inc., p ursuant to RSA 125-C.

B. Parties 1. The New Hampshire Department of Environmental Se rvices, Air Resources Division (DES), is a duly constituted administrative agency of the Sta te of New Hampshire having its principal offices at 29 Hazen Drive, Concord, NH 03302, telep hone number (603) 271-1370. 2. Concord Litho Group, Inc. (Concord Litho) is a N ew Hampshire corporation having its principal office at 92 Old Turnpike Road, Concord, NH 03301.

C. Statements of Fact and Law

1. Concord Litho is a commercial offset lithographic p rinting operation that produces greeting cards, brochures, magazines and direct mail inserts

. 2. Effective December 31, 2002, DES re-adopted the New Hampshire Code of Administrative Rules Env-A 1204, Stationary Sources of Volatile Organic Compounds (V OCs) with amendments. This part defines the sources that are subject to Reasonably Available Control Technology (RACT) requirements and specifies the ap plicable RACT requirements. 3. Concord Litho is subject to Env-A 1204.37, Applicability Criteria and Compliance Standards for Offset Lithographic Printing , because the theoretical potential to emit (TPE) e xceeds 50 tons of non-exempt VOCs during any consecutive 12-month period. 4. Concord Litho operates a Recco Unitherm Regene rative Thermal Oxidizer (RTO) and a Retox 2000 RTO to control VOC emissions from five of seve n printing presses. 5. The printing operations, including the RTOs, are currently covered under Temporary Permit FP-T-0084 issued on September 1, 2006. 6. Prior to September 1, 2006, Concord Litho held a Title V Operating Permit, TV-OP-29. Condition VIII.D of the Title V Permit allowed Conc ord Litho to bank, use or trade Discrete Emissions Reductions (DERs) or Emission Reduction C redits (ERCs). Accordingly, Concord Litho has approximately 35 DER credits in its bank to use or to sell. 8. On February 23, 2007, DES and Concord Litho ex ecuted an Administrative Order by Consent (AOC) No. ARD 07-002. The AOC required Concord Lit ho to apply for a RACT Order for compliance purposes when either RTO is shut down du e to maintenance or malfunction. 9. On March 1, 2007, Concord Litho submitted an a pplication for a VOC RACT Order that would allow it to generate and use Discrete Emissions Red uctions (DERs) in order to comply with the VOC reduction requirements during periods when eith er of the RTOs are shut down due to maintenance or malfunction.RACT Order No. ARD07-003 September 17, 2007

Concord Litho Group, Inc. Page 2 of 5 D. Order
Based on the statements of fact and law, DES hereby orders Concord Litho, effective upon issuance of this Order, to comply with the following require ments as RACT:

1. Except as specified in 2., below, Concord Litho sha ll comply with the VOC control standards specified in Env-A 1204.37, Applicability Criteria and Compliance Standards for Offset Lithographic Printing , specifically: The VOC emissions from the dryer exhaust of a heats et web offset lithographic printing press:

a. Shall be reduced by at least 90%, by weight, of tot al organics, less methane and ethane; or

b. Shall not exceed 20 parts per million (ppm) by volu me, prior to dilution.

2. The Recco Unitherm RTO shall be operated at a set p oint combustion chamber temperature of 1480°F.

3. The Retox 2000 RTO shall be operated at a set point combustion chamber temperature of 1580°F.

4. Concord Litho shall operate and maintain equipment to continuously monitor and record the temperatures of the heat exchanger beds, the combus tion chamber and the exhaust of each RTO.

5. Concord Litho shall maintain the RTOs in a manner c onsistent with manufacturer’s recommendations.

6. For times that the capture and control system is un able to meet the 90% reduction requirement specified in Env-A 1204.37 due to a malfunction or during routine maintenance of one or both of the oxidizers, Concord Litho shall be allowed to use DERs in accordance with Condition D.7. of this Order, for the purpose of complying with th e VOC RACT requirements

. 7. Generation and Use of DERs: Concord Litho shall be allowed to generate DERs for VOC emission reductions that exceed the reductions required in Part D.1 of this Order. Con cord Litho shall be allowed to use these DERs for RACT compliance in accordance with D.6 of this Order. The following calculations shall be used to determine the amount of DERs generated and/ or used over any given period, but at least monthly:

a. Calculation of Allowable VOC Emissions For the purposes of complying with the VOC RACT req uirement specified in Env-A 1204.37, Concord Litho shall calculate the allowabl e VOC emissions as follows:

“E al ” means the allowable VOC emissions; “A” means the actual, uncontrolled emissions from t he five web presses;

“E al ” shall be calculated as in the following equation:

E al = (A)*(1-0.90)RACT Order No. ARD07-003 September 17, 2007

Concord Litho Group, Inc. Page 3 of 5
b. Emission Credit Use and Generation Calculations To determine if Concord Litho will either generate DERs or need to use DERs for compliance with RACT, Concord Litho shall subtract the actual VOC emissions (E ac ) from the five web presses, from the allowable VOC emissi ons (E al ) as calculated in accordance with 7.a. of this Order. (i) Generation of DERs: If the result of the subtraction is a positive num ber, then the actual emissions are below the requirements of RACT and the amount equal to th e difference between E al and E ac will count towards the generation of DERs. The act ual DERs shall be calculated by taking the amount of credited emissions and multipl ying them by a safety factor of 0.9. (ii) Use of DERs: If the result of the subtraction is a negative numb er, then the actual emissions exceed the VOC RACT requirements and emission credits equa l to the difference between E al and E ac shall be used to offset these excess emissions. T he actual DERs required to offset the excess emissions shall be calculated by dividing the excess emissions by an environmental benefit factor of 0.9. 8. Recordkeeping Requirements Concord Litho shall maintain the following records in order to demonstrate compliance with this order. Each record shall be kept for a period of a t least five years. a. Records of all air pollution control equipment a ctivities, including: (i) Records of temperature readings taken on the R TOs; (ii) A log of operating times of the RTOs; and (iii) All pollution control equipment maintenance records, including preventative maintenance and annual visual inspections. Records shall include the date and duration of any outages.
b. Concord Litho shall maintain all records of the calculations related to the generation and use of DERs as specified in Condition D.7. 9. Reporting Requirements Concord Litho shall submit the following reports t o demonstrate compliance with this Order: a. Annually by November 30, Concord Litho shall sub mit a report to DES on the projected use of credits for the upcoming year. This report shal l meet the requirements of Env-A 3104.08, Notice of Intent to Use DERs , including the following information: (i.) The name and location of the user; (ii.) A copy of the Notice and Certification of Generatio n submitted by the generator source to the State (for paperwork reduction purpos es, a certified statement that the notice is on file with DES will suffice); (iii.) The protocol used to document the amount of DERs ne eded to demonstrate compliance; and (iv.) Information documenting that Concord Litho is in co mpliance with Env-A 1400, Regulated Toxic Air Pollutants

.RACT Order No. ARD07-003 September 17, 2007

Concord Litho Group, Inc. Page 4 of 5
b. Annually by April 15, Concord Litho shall submit a report to DES on the balance of credits for the previous calendar year. This report shall meet the requirements of Env-A 3103.08, Notice and Certification of Generation and Env-A 3104.09, Notice and Certification of Use

, including the following information: (i.) The name and location of the owner or operator of t he source; (ii.) A brief description of the generation activity; (iii.) A list of the source’s applicable allowable emissio n rates; (iv.) The amount of DERs generated each month; (v.) A calculation of the amount of DERs generated; (vi.) The amount of DERs used each month; (vii.) A calculation of the amount of DERs required to dem onstrate compliance with the emission limits stated in Part D, above. (viii.) A statement that the reductions were calculated in accordance with Env-A 3103.07; (ix.) A statement that the DERs were not generated in who le or in part from actions prohibited pursuant to Env-A 3103.07; (x.) A statement that due diligence was made to verify t hat the DERs were not previously used, and not generated as a result of actions proh ibited under the regulations or other provisions of law; (xi.) A statement that the DERs were not used in a manner prohibited under the regulation or other provisions of law; and (xii.) The report shall contain a certification by a respo nsible official that states:

(i) Based on information and belief formed after reason able inquiry, the statements and information in the document are true, accurate and complete; and (ii) The user source is in compliance with all National Ambient Air Quality Standards, except ground level ozone, and all Ambie nt Air Limits for Regulated Toxic Air Pollutants.

Please address any correspondence and communication in reference to this Order to the following:

Ms. Barbara Dorfschmidt NHDES, Air Resources Division Bureau of Permitting and Environmental Health 29 Hazen Drive P.O. Box 95 Concord, NH 03302-0095 (603) 271-6796RACT Order No. ARD07-003 September 17, 2007

Concord Litho Group, Inc. Page 5 of 5 Please address any correspondence and communication in reference to the ERCs or DERs to the following:

Mr. Joe Fontaine NHDES, Air Resources Division 29 Hazen Drive P.O. Box 95 Concord, NH 03302-0095 (603) 271-6794

_____________________________ Robert R. Scott Director Air Resources Division

cc: Timothy Drew, PIP Office Ann Arnold, USEPA City of Concord Mark Flannery, Printing Industries of New England

H:\Permitting\Source Files\Concord Litho\VOC RACT O rder\Concord Litho_RACT Order_draft.doc