___________________________________ 

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 Department of Environmental Services, Air 

Resources Division, to Concord Litho Group, Inc., pursuant to RSA 125-C. 

B. Parties

1. The New Hampshire Department of Environmental Services, Air Resources Division (DES), is 

a duly constituted administrative agency of the State of New Hampshire having its principal 

offices at 29 Hazen Drive, Concord, NH 03302, telephone number (603) 271-1370. 

2. Concord Litho Group, Inc. (Concord Litho) is a New 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 printing 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 (VOCs) with 

amendments. This part defines the sources that are subject to Reasonably Available Control 

Technology (RACT) requirements and specifies the applicable 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) exceeds 50 tons 

of non-exempt VOCs during any consecutive 12-month period. 

4. Concord Litho operates a Recco Unitherm Regenerative Thermal Oxidizer (RTO) and a Retox 

2000 RTO to control VOC emissions from five of seven 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 Concord Litho to bank, use or trade Discrete 

Emissions Reductions (DERs) or Emission Reduction Credits (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 executed an Administrative Order by Consent 

(AOC) No. ARD 07-002. The AOC required Concord Litho to apply for a RACT Order for 

compliance purposes when either RTO is shut down due to maintenance or malfunction. 

9. On March 1, 2007, Concord Litho submitted an application for a VOC RACT Order that would 

allow it to generate and use Discrete Emissions Reductions (DERs) in order to comply with the 

VOC reduction requirements during periods when either 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 requirements as RACT: 

1. Except as specified in 2., below, Concord Litho shall 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 heatset web offset lithographic printing press: 

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

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

2. The Recco Unitherm RTO shall be operated at a set point 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 combustion chamber and the exhaust of each RTO. 

5. Concord Litho shall maintain the RTOs in a manner consistent with manufacturer’s 

recommendations. 

6. For times that the capture and control system is unable 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 the 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. Concord 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 requirement specified in Env-A 

1204.37, Concord Litho shall calculate the allowable VOC emissions as follows: 

“Eal” means the allowable VOC emissions; 

“A” means the actual, uncontrolled emissions from the five web presses; 

“Eal” shall be calculated as in the following equation:

Eal = (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 (Eac) from 

the five web presses, from the allowable VOC emissions (Eal) as calculated in accordance 

with 7.a. of this Order. 

(i) Generation of DERs: 

 If the result of the subtraction is a positive number, then the actual emissions are below 

the requirements of RACT and the amount equal to the difference between Eal and Eac

will count towards the generation of DERs. The actual DERs shall be calculated by 

taking the amount of credited emissions and multiplying them by a safety factor of 0.9. 

(ii) Use of DERs: 

If the result of the subtraction is a negative number, then the actual emissions exceed 

the VOC RACT requirements and emission credits equal to the difference between Eal

and Eac shall be used to offset these excess emissions. The 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 at least five years. 

a. Records of all air pollution control equipment activities, including: 

 (i) Records of temperature readings taken on the RTOs; 

 (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 to demonstrate compliance with this Order: 

a. Annually by November 30, Concord Litho shall submit a report to DES on the projected use 

of credits for the upcoming year. This report shall 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 Generation submitted by the generator 

source to the State (for paperwork reduction purposes, a certified statement that the 

notice is on file with DES will suffice); 

(iii.) The protocol used to document the amount of DERs needed to demonstrate 

compliance; and 

(iv.) Information documenting that Concord Litho is in compliance 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 the source; 

(ii.) A brief description of the generation activity; 

(iii.) A list of the source’s applicable allowable emission 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 demonstrate 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 whole or in part from actions 

prohibited pursuant to Env-A 3103.07; 

(x.) A statement that due diligence was made to verify that the DERs were not previously 

used, and not generated as a result of actions prohibited 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 responsible official that states: 

(i) Based on information and belief formed after reasonable 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 Ambient 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) 271-6796 
RACT 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 Order\Concord Litho_RACT Order_draft.doc