Federal Operating Permit 

Article 1 

This permit is based upon the requirements of Title V of the Federal Clean Air Act and Chapter 

80, Article 1 of the Commonwealth of Virginia Regulations for the Control and Abatement of Air 

Pollution. Until such time as this permit is reopened and revised, modified, revoked, terminated 

or expires, the permittee is authorized to operate in accordance with the terms and conditions 

contained herein. This permit is issued under the authority of Title 10.1, Chapter 13, §10.1-

1322 of the Air Pollution Control Law of Virginia. This permit is issued consistent with the 

Administrative Process Act, and 9 VAC 5-80-50 through 9 VAC 5-80-300 of the State Air 

Pollution Control Board Regulations for the Control and Abatement of Air Pollution of the 

Commonwealth of Virginia. 

Authorization to operate a Stationary Source of Air Pollution as described in this permit is 

hereby granted to: 

 Permittee Name: Quebecor World San Jose Inc. 

 Facility Name: Quebecor World Richmond Inc. 

 Facility Location: 7400 Impala Drive 

 Richmond, Virginia 23228 

 Registration Number: 50880 

 Permit Number: PRO-50880 

This permit includes the following programs: 

Federally Enforceable Requirements - Clean Air Act (Sections I through IX)

 December 1, 2008 

 Effective Date: 

 December 1, 2013 

 Expiration Date: 

 

 Deputy Regional Director, Department of Environmental Quality 

 December 1, 2008 

 Signature Date 

Table of Contents, 2 pages 

Permit Conditions, 70 pages 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 2 

Table of Contents 

I. FACILITY INFORMATION .................................................................................................. 1

II. EMISSION UNITS ............................................................................................................... 2

III. FUEL BURNING EQUIPMENT REQUIREMENTS – (B001, B002, B003) ......................... 6

III.A. LIMITATIONS ................................................................................................................... 6

III.B. MONITORING .................................................................................................................. 7

III.C. RECORDKEEPING............................................................................................................ 7

III.D. TESTING ......................................................................................................................... 9

III.E. REPORTING .................................................................................................................... 9

IV. PUBLICATION PRINTING PROCESS EQUIPMENT REQUIREMENTS – (P001 

THROUGH P006, P008 AND T001 THROUGH T021) .............................................................. 11

IV.A. LIMITATIONS ................................................................................................................. 11

IV.B. MONITORING ................................................................................................................ 16

IV.C. RECORDKEEPING.......................................................................................................... 25

IV.D. TESTING ....................................................................................................................... 31

IV.E. REPORTING .................................................................................................................. 35

V. CYLINDER ELECTROPLATING PROCESS REQUIREMENTS - (P015 AND P016) ..... 39

V.A. LIMITATIONS ................................................................................................................. 39

V.B. MONITORING ................................................................................................................ 41

V.C. RECORDKEEPING.......................................................................................................... 42

V.D. TESTING ....................................................................................................................... 44

V.E. REPORTING .................................................................................................................. 46

VI. WASTE PAPER HANDLING PROCESS REQUIREMENTS (P017, P018, P019) ........... 50

VI.A. LIMITATIONS ................................................................................................................. 50

VI.B. MONITORING ................................................................................................................ 50

VI.C. RECORDKEEPING.......................................................................................................... 51

VI.D. TESTING ....................................................................................................................... 51

VI.E. REPORTING .................................................................................................................. 52

VII. FACILITY WIDE CONDITIONS ........................................................................................ 53

VII.A. LIMITATIONS ................................................................................................................. 53

VII.B. MONITORING ................................................................................................................ 55

VII.C. RECORDKEEPING.......................................................................................................... 55

VII.D. TESTING ....................................................................................................................... 56

VII.E. REPORTING .................................................................................................................. 57

VIII. INSIGNIFICANT EMISSION UNITS ................................................................................. 58

IX. PERMIT SHIELD .............................................................................................................. 59

X. GENERAL CONDITIONS ................................................................................................. 60

X.A. FEDERAL ENFORCEABILITY ........................................................................................... 60

X.B. PERMIT EXPIRATION ..................................................................................................... 60
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 3 

X.C. RECORDKEEPING AND REPORTING ................................................................................ 60

X.D. ANNUAL COMPLIANCE CERTIFICATION ........................................................................... 61

X.E. PERMIT DEVIATION REPORTING .................................................................................... 62

X.F. FAILURE/MALFUNCTION REPORTING ............................................................................. 62

X.G. SEVERABILITY .............................................................................................................. 63

X.H. DUTY TO COMPLY ......................................................................................................... 63

X.I. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE ................................................... 63

X.J. PERMIT MODIFICATION ................................................................................................. 64

X.K. PROPERTY RIGHTS ....................................................................................................... 64

X.L. DUTY TO SUBMIT INFORMATION .................................................................................... 64

X.M. DUTY TO PAY PERMIT FEES .......................................................................................... 64

X.N. FUGITIVE DUST EMISSION STANDARDS.......................................................................... 64

X.O. STARTUP, SHUTDOWN, AND MALFUNCTION ................................................................... 65

X.P. ALTERNATIVE OPERATING SCENARIOS .......................................................................... 65

X.Q. INSPECTION AND ENTRY REQUIREMENTS ...................................................................... 65

X.R. REOPENING FOR CAUSE ............................................................................................... 66

X.S. PERMIT AVAILABILITY .................................................................................................... 66

X.T. TRANSFER OF PERMITS ................................................................................................ 66

X.U. MALFUNCTION AS AN AFFIRMATIVE DEFENSE ................................................................ 67

X.V. PERMIT REVOCATION OR TERMINATION FOR CAUSE ...................................................... 67

X.W. DUTY TO SUPPLEMENT OR CORRECT APPLICATION ....................................................... 68

X.X. STRATOSPHERIC OZONE PROTECTION .......................................................................... 68

X.Y. ASBESTOS DEMOLITION AND RENOVATION REQUIREMENTS ........................................... 68

X.Z. ACCIDENTAL RELEASE PREVENTION.............................................................................. 68

X.AA. CHANGES TO PERMITS FOR EMISSIONS TRADING .......................................................... 68

X.BB. EMISSIONS TRADING..................................................................................................... 68

XI. STATE-ONLY ENFORCEABLE REQUIREMENTS ......................................................... 70
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 1 

I. Facility Information 

Permittee 

Quebecor World San Jose Inc. 

 dba: Quebecor World Richmond Inc. 

P.O. Box 9579 

Richmond, Virginia 23228 

Responsible Official 

Mr. Stephen Eggleston 

Vice President & General Manager 

Facility 

Quebecor World Richmond Inc. 

7400 Impala Drive 

Richmond, Virginia 23228 

Contact Person 

Mr. Jason Collins 

Environmental/Safety Coordinator 

804-264-3834 

County Plant Identification Number: 087-0130 

Facility Description: SIC Code 2754 – Quebecor operates a rotogravure publication 

printing facility in Henrico County, Virginia. Newspaper inserts, advertising circulars and 

supplements, retail and wholesale catalogs, tabloid magazines, and other commercial work 

are produced using the rotogravure and flexographic process. The rotogravure press rollers 

are machined, electroplated, cleaned, engraved, and polished in the cylinder-manufacturing 

portion of the facility. The printed products are produced “press-finished”, which includes 

the collating, folding, gluing-in of inserts, and trimming, and this is all performed in-line with 

the presses. The facility also operates an automated, parts-washing system (Renzmann 

cylinder cleaning tank) and a chrome plating operation for re-plating of engraved cylinders. 

The six production presses are subject to 40 CFR 60 Subpart QQ. The six presses, all 

storage tanks, ink mixing tanks, the parts cleaning processes, and the Renzmann cylinder 

wash tank are subject to the requirements of 40 CFR 63, Subparts A and KK 

The chrome plating baths are subject to 40 CFR 63 Subpart N. Three natural gas /distillate 

oil fired boilers provide heat and steam to the facility. One boiler is subject to 40 CFR 60 

Subpart Dc, and is rated at 33.48 MMBtu/hr. The other two boilers are not subject to 40 

CFR 60 Subpart Dc and are rated at 29.4 MMBtu/hr and 33.48 MMBtu/hr. 
Quebecor 

Permit 

II. Emission Units 

Equipment to be operated consists of: 

Emission 

Unit ID 

Stack 

ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID 

Fuel Burning Equipment B001 S011 Cleaver Brooks Boiler, 1979 firing natural gas and distillate oil 33.48 MMBtu/hr B002 S012 Cleaver Brooks Boiler, 1985 firing natural gas and distillate oil 29.40 MMBtu/hr B003 S013 Johnson Boiler, 1995 firing natural gas and distillate oil 33.48 MMBtu/hr Rotogravure Presses P001- P006 P001 S001 S002 

Rotogravure Press 740 75 inch width, 1700 fpm 8 stations Goss press, 1981 

861.4 lbs VOC/hr as applied 

Sutcliffe & Croftshaw Carbon Adsorption Systems - Overall Recovery Efficiency of 91% 

C001 C002 (SRA) 

P002 S001 S002 

Rotogravure Press 741 75 inch width, 1700 fpm 8 stations Goss press, 1980 

915.9 lbs VOC/hr as applied 

Sutcliffe & Croftshaw Carbon Adsorption Systems - Overall Recovery Efficiency of 91% 

C001 C002 (SRA) 

P003 S001 S002 

Rotogravure Press 742 96 inch width, 2000 fpm 10 stations Motter press, 1980 

1039.6 lbs VOC/hr as applied 

Sutcliffe & Croftshaw Carbon Adsorption Systems - Overall Recovery Efficiency of 91% 

C001 C002 (SRA) 

P004 S001 S002 

Rotogravure Press 743 75 inch width, 1700 fpm 8 stations Goss press, 1985 

915.9 lbs VOC/hr as applied 

Sutcliffe & Croftshaw Carbon Adsorption Systems - Overall Recovery Efficiency of 91% 

C001 C002 (SRA) 
Quebecor 

Permit 

Emission 

Unit ID 

Stack 

ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID 

P005 S001 S002 

Rotogravure Press 744 94 inch width, 3000 fpm 8 stations Albert Frankenthal press, 1988 

1406.0 lbs VOC/hr as applied 

Sutcliffe & Croftshaw Carbon Adsorption Systems - Overall Recovery Efficiency of 91% 

C001 C002 (SRA) 

P006 S003 

Rotogravure Press 745 125 inch width, 3000 fpm 8 station Albert Frankenthal press, 1995 

1952.0 lbs VOC/hr as applied 

Dedert Carbon Adsorption System & Total Enclosure - Overall Control Efficiency of 97.7% 

C003 (SRB) 

Cylinder Cleaning Tank P008 S001 S002 Cylinder Wash Tank Renzmann, 1986 6 cylinders/hr 

Sutcliffe & Croftshaw Carbon Adsorption Systems - Overall Recovery Efficiency of 91% 

C001 C002 (SRA) 

Cylinder Manufacturing Process P015 S008 

Chromium (hard) Electroplating Tank 12,000 amps Walter, 1995 

(3) 131-inch cylinders/hr 

MAPCO Demister Filter (composite mesh pad) with a Control Efficiency of 99% 

C004 

P016 S008 

Chromium (hard) Electroplating Tank 12,000 amps Max Daetwyler, 2006 

(3) 138-inch cylinders/hr 

MAPCO Demister Filter (composite mesh pad) with a Control Efficiency of 99% 

C004 

Waste Paper Handling System P017 S009 Paper Waste handling System 1 Hogger, Baler, Cyclone 8,000 cfm Steelcraft Fabric Filter rated at 8,000 cfm with a Control Efficiency of 90% C005 P018 S010 Paper Waste handling System 2 Hogger, Baler, Cyclone 12,000 cfm Steelcraft Fabric Filter rated at 12,000 cfm with a Control Efficiency of 90% C006 P019 S011 Paper Waste handling System 3 Hogger, Baler, Cyclone 18,000 cfm Steelcraft Fabric Filter rated at 18,000 cfm with a Control Efficiency of 90% C007 
Quebecor 

Permit 

Emission 

Unit ID 

Stack 

ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID 

Adhesive Process P020 Fugitive Manual Paster Glue Process NA VOC Storage Tanks T001 Fugitive VOC Storage Tank Ink, 1979 5000 gallon T002 Fugitive VOC Storage Tank Ink, 1979 5000 gallon T003 Fugitive VOC Storage Tank Ink, 1979 5000 gallon T004 Fugitive VOC Storage Tank Ink, 1979 5000 gallon T005 Fugitive VOC Storage Tank Extender, 1979 5000 gallon T006 Fugitive VOC Storage Tank Extender, 1979 5000 gallon T007 Fugitive VOC Storage Tank Ink, 1979 5000 gallon T008 Fugitive VOC Storage Tank Ink, 1979 5000 gallon T009 Fugitive VOC Storage Tank Ink, 1979 5000 gallon T0010 Fugitive VOC Storage Tank Ink, 1979 5000 gallon T0011 Fugitive VOC Storage Tank Ink, 1988 5000 gallon T0012 Fugitive VOC Storage Tank Ink, 1991 5000 gallon T0013 Fugitive VOC Storage Tank Ink, 1991 5000 gallon T0014 Fugitive VOC Storage Tank Ink, 1995 5000 gallon 
Quebecor 

Permit 

Emission 

Unit ID 

Stack 

ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID 

T0015 Fugitive VOC Storage Tank Ink, 1988 5000 gallon T0016 Fugitive VOC Storage Tank Extender, 1995 5000 gallon T017 Fugitive 

VOC Storage Tank Reclaimed VOC Adamson, 1986 

6000 gallon 

T018 Fugitive 

VOC Storage Tank Reclaimed VOC Adamson, 1986 

6000 gallon 

T019 Fugitive 

VOC Storage Tank Reclaimed VOC Adamson, 1986 

6000 gallon 

T020 Fugitive VOC Storage Tank Reclaimed VOC, 1988 6000 gallon T021 Fugitive 

VOC Storage Tank Reclaimed VOC Highland, 1995 

6000 gallon 

*The Size/Rated capacity and PCD efficiency is provided for informational purposes only, and is not an applicable r

* Emissions from Units P001, P002, P003, P004, P005, and P008 may be controlled by one of two Sutcliffe & CrofAdsorption Systems (C001or C002) and emitted from the connecting stack (S001 or S002)
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 6 

III. Fuel Burning Equipment Requirements – (B001, B002, B003) 

III.A. Limitations 

III.A.1. Fuel Specifications: The approved fuels for the boilers (B001, B002, and B003) 

are natural gas and distillate oil. Distillate oil is defined as fuel oil that meets the 

specifications for fuel oil numbers 1 or 2 under the American Society for Testing and 

Materials, ASTM D396-97 “Standard Specification for Fuel Oils.” A change in the 

fuels may require a permit to modify and operate. 

(9 VAC 5-80-110 and Condition 12 of September 30, 2008 Permit) 

III.A.2. Fuel Sulfur Limit: Fuel - The distillate oil and natural gas shall meet the 

specifications below: 

DISTILLATE OIL which meets the ASTM [D396] specification for numbers 1 or 2 fuel oil: 

Maximum sulfur content per shipment: 0.5% 

NATURAL GAS: 

Minimum heat content: 1000 Btu/cf HHV. 

(40 CFR 60.42c(d), 9 VAC 5-80-110, and Condition 14 of September 30, 2008 

permit.) 

III.A.3. Fuel Consumption Limits: The boilers (B001, B002, and B003) shall consume 

no more than a total of 409.3 million cubic feet of natural gas and a total of 680,000 

gallons of distillate oil per year, calculated monthly as the sum of the gas or oil 

consumption over the previous consecutive 12 months. 

(9 VAC 5-80-110 and Condition 13 of September 30, 2008 Permit) 

III.A.4. Emission Limits: Emissions from the operation of the three boilers (B001, B002, 

and B003) shall not exceed the limits specified below: 

Boiler Specific Hourly Emissions Combined Hourly and 

Annual Emissions from 

B-1, B-2, and B-3 

B-1 B-2 B-3 Hourly Annual 

TSP 0.9 lbs/hr 0.5 lbs/hr 0.5 lbs/hr 1.8 lbs/hr 2.2 tpy 

PM10 0.4 lbs/hr 0.3 lbs/hr 0.3 lbs/hr 0.9 lbs/hr 1.9 tpy 

SO2 30.3 lbs/hr 17.2 lbs/hr 17.2 lbs/hr 64.7 lbs/hr 24.3 tpy 

NOx 8.5 lbs/hr 4.9 lbs/hr 4.9 lbs/hr 18.2 lbs/hr 27.3 tpy 

CO 2.5 lbs/hr 2.8 lbs/hr 2.8 lbs/hr 8.1 lbs/hr 18.9 tpy 

VOC 0.2 lbs/hr 0.2 lbs/hr 0.2 lbs/hr 0.5 lbs/hr 1.2 tpy 

*Annual emissions shall be determined by the monthly consumption of natural gas 

and distillate oil calculated as the sum of each consecutive 12 month period. 

(9 VAC 5-50-260, 9 VAC 5-80-110, and Condition 20 of September 30, 2008 Permit) 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 7 

III.A.5. Visible Emission Limit: Visible Emissions from each of the boiler stacks (S011, 

S012, S013) shall not exceed 10 percent opacity except during one six-minute period 

in any one hour in which visible emissions shall not exceed 20 percent opacity. 

(9 VAC 5-50-80, 9 VAC 5-80-110, and Condition 25 of September 30, 2008 Permit) 

III.A.6. NSPS Subpart Dc Requirements by Reference - Except where this permit is 

more restrictive than the applicable requirement, the NSPS Subpart Dc equipment as 

described in Section I of this permit shall be operated in compliance with the 

requirements of 40 CFR 60, Subpart Dc. 

(9 VAC 5-80-110 and Condition 27 of September 30, 2008 Permit) 

III.B. Monitoring 

III.B.1. Periodic Monitoring of Visible Emissions from Boiler Stacks (S011, S012, 

S013): For each boiler (B001, B002, and B003) which burns fuel oil for a total of 6 

hours or more during any calendar week, the associated boiler stack shall be 

observed visually for a six minute period at least once during that calendar week 

while the boiler is burning fuel oil in order to determine if there are any visible 

emissions from that boiler other than a short, white condensed-water plume. If 

visible emissions are present at any time during the observation period, a visible 

emission evaluation (VEE) in accordance with 40 CFR Part 60, Appendix A, Method 

9, shall be performed by a certified observer within 48 hours unless corrective 

adjustment, maintenance or repair has corrected the condition within 12 hours of the 

observation. The weekly observation shall not be conducted during periods of 

startup, shutdown, malfunction or maintenance. Observed visible emissions shall 

not be considered a reportable exceedance unless the subsequent VEE confirms a 

violation of the visible emission standard. Records of the observation and any 

corrective adjustment, maintenance or repair performed to correct the abnormal 

emission condition shall be kept in accordance with Condition III.C.2. A visual 

observation of an emission unit is not required during any calendar week in which a 

VEE has been performed on that emission unit. 

(9 VAC 5-80-110 E.3.) 

III.C. Recordkeeping 

III.C.1. Fuel Certifications: The permittee shall obtain a certification from the fuel 

supplier with each shipment of distillate oil. Each fuel supplier certification shall 

include the following: 

a. The name of the fuel supplier, 

b. The date on which the oil was received, 

c. The volume of distillate oil delivered in the shipment, 

d. A statement that the oil complies with the American Society for Testing and 

Materials specifications for fuel oil numbers 1 and 2, and 

e. The sulfur content of the oil. 

(40 CFR 60.48c(i) and f(1), 9 VAC 5-80-110 and Condition 15 of September 30, 

2008 Permit) 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 8 

III.C.2. Compliance Records: The permittee shall maintain records of all emission data 

and operating parameters necessary to demonstrate compliance with this permit. 

The content and format of such records shall be arranged with the Director, 

Piedmont Region. These records shall include, but are not limited to: 

a. The monthly and annual throughput of natural gas (in million cubic feet) and the 

daily, monthly, and annual throughput of distillate oil (in 1000 gallons) for the 

three boilers (B001, B002, and B003). The annual throughput shall be calculated 

as the sum of each consecutive 12 months. 

b. Monthly emission calculations for the boilers B001 and B002 combined well as 

emission factors, rated capacities, fuel characteristics, and formulas used to 

calculate the emissions from boilers B001 and B002 combined, and the 

maximum hourly throughput of fuel the boilers. 

c. Monthly emission calculations for boiler B003 as well as emission factors, rated 

capacity, fuel characteristics, and formulas used to calculate the emissions from 

boiler B003, and the maximum hourly throughput of fuel to the boiler. 

d. All fuel supplier certifications. 

e. All visible emission observations and evaluations 

f. Boiler maintenance schedules and records of completed maintenance, including 

corrective adjustments, maintenance and repair to the boilers as a result of 

weekly visible emission observations or evaluations. 

g. Boiler operator training records. 

h. Records of occurrence of any startup, shutdown, or malfunction in the operation 

of the Johnson boiler (B003), any malfunction of control equipment, or any 

periods during which a continuous monitoring system or monitoring device is 

inoperative. 

i. Records of all measurements associated with the Johnson boiler (B003), 

including continuous monitoring system, monitoring device, and performance 

testing measurements, all monitoring calibration checks, and all adjustments 

maintenance on these systems and devices, and future performance tests or 

future continuous monitoring systems installed to demonstrate compliance in lieu 

of visible emission evaluations or fuel certifications. 

These records shall be available on site for inspection by the DEQ and shall be 

current for the most recent five (5) years. 

(40 CFR 60.7(f) and 60.48c(e)(11), 9 VAC 5-50-50, 9 VAC 5-80-110, and Condition 

41 of September 30, 2008 Permit) 

III.C.3. Operating and Training Procedures: Boiler emissions shall be controlled by 

proper operation and maintenance of combustion equipment. Boiler operators shall 

be trained in the proper operation of all such equipment. Training shall consist of a 

review and familiarization of the manufacturer's operating instructions, at minimum. 

The permittee shall maintain records of the required training including a statement of 

time, place and nature of training provided. The permittee shall have available good 

written operating procedures and a maintenance schedule for the boiler. These 

procedures shall be based on the manufacturer's recommendations, at minimum. All 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 9 

records required by this condition shall be kept on site and made available for 

inspection by the DEQ. 

(9 VAC 5-80-110 and Condition 16 of September 30, 2008 Permit) 

III.D. Testing 

III.D.1. Test Methods: If testing is conducted in addition to the monitoring specified in 

this permit, the permittee shall use the appropriate method(s) in accordance with 

procedures approved by the DEQ. 

 (9 VAC 5-80-110)

III.D.2. Conduct of Performance Tests: Performance tests that are conducted in 

accordance with the methods specified in Condition III.D.1 in addition to the 

monitoring specified in Section III.B of this permit shall be conducted in accordance 

with Section III.B of this permit, except as follows: 

a. Sulfur dioxide testing shall be conducted over 30 consecutive operating days, 

with a separate performance test completed at the end of each steam operating 

day and a 30 day average SO2 emission rate calculated to show compliance with 

the lb/mmBtu standard. The steam generating load during the 30 day 

performance test shall be representative of future operating conditions. 

b. In addition, if the permittee desires to demonstrate compliance with the lb/mmBtu 

sulfur dioxide standard by performance test instead of by fuel sulfur content, the 

permittee shall demonstrate the maximum design heat input capacity of the 

steam generating unit by operating at this capacity for 24 hours. If the 

demonstrated 24-hour averaged firing rate is less than the maximum design heat 

input capacity stated by the manufacturer, the demonstrated value shall be used 

to determine the annual capacity factor; otherwise the capacity stated by the 

manufacturer shall be used. 

c. In the event that a sample is accidentally lost or conditions occur in which one of 

the three runs must be discontinued because of forced shutdown, failure of an 

irreplaceable portion of the sample train, extreme meteorological conditions or 

other circumstances beyond the permittee’s control, compliance may, upon 

approval from the Director, Piedmont Region, be determined using the arithmetic 

mean of the two other runs. 

(9 VAC 5-50-30 G, 40 CFR 60.8(f), and 9 VAC 5-80-110) 

III.E. Reporting 

III.E.1. Fuel Quality Reports: The permittee shall submit fuel quality reports to the 

Director, Piedmont Region within 30 days after the end of each calendar quarter. If 

no shipments of distillate oil were received during the calendar quarter, the quarterly 

report shall consist of the dates included in the calendar quarter and a statement that 

no oil was received during the calendar quarter. If distillate oil was received during 

the calendar quarter, the reports shall include: 

a. The dates included in the calendar quarter; 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 10 

b. A copy of all fuel supplier certifications for all shipments of distillate oil received 

during the calendar quarter or a quarterly summary from each fuel supplier that 

includes the information specified in Condition III.C.1 for each shipment of 

distillate oil; and, 

c. A signed statement from the owner or operator of the facility that the fuel supplier 

certifications or summaries of fuel supplier certifications represent all of the 

distillate oil burned or received at the facility. 

(9 VAC 5-50-50, 9 VAC 5-50-410, 9 VAC 5-80-110, and Condition 43 of September 

30, 2008 Permit) 

III.E.2. Required Notifications: The permittee shall provide written notification to the 

Director, Piedmont Region within 15 calendar days after any physical or operational 

change to any existing boiler which may increase the emission rate of any air 

pollutant to which a standard applies under 40 CFR 60, Subpart Dc (sulfur dioxide 

and particulate) unless that changes is specifically exempted from the definition of 

"modification" under 9 VAC 5-50-410 §60.14. 

(40 CFR 60.7(a)(i)(4) and 60.8 (d) and 9 VAC 5-80-110) 

III.E.3. Performance Testing Notification: The permittee shall furnish written 

notification to the Director, Piedmont Region of the anticipated dates of performance 

tests of the printing facility and testing protocols postmarked at least 30 days prior to 

such tests. 

(40 CFR 60.8(d) and 9 VAC 5-80-110) 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 11 

IV. Publication Printing Process Equipment Requirements – (P001 through 

P006, P008 and T001 through T021) 

IV.A. Limitations 

IV.A.1. Emission Control: Volatile organic compound (VOC) emissions from Presses 

740, 741, 742, 743, 744, and the Renzmann Cylinder Wash (P001, P002, P003, 

P004, P005, and P008) shall be controlled by carbon adsorption solvent recovery 

system (Solvent Recovery A: C001and C002) each with an overall recovery 

efficiency of 91 percent. Compliance with this condition shall be demonstrated 

monthly through a VOC mass balance equation. The solvent recovery system shall 

be provided with adequate access for inspection. 

(9 VAC 5-80-110 and Condition 2 of September 30, 2008 Permit) 

IV.A.2. Emission Control: Volatile organic compound (VOC) emissions from Press 745 

(P006) shall be controlled by a 100 percent efficient permanent total enclosure 

capture system and a dedicated carbon adsorption solvent recovery system (Solvent 

Recovery B: C003) having an overall control efficiency of 97.7 percent. The printing 

press, permanent total enclosure, and carbon adsorption system shall be provided 

with adequate access for inspection. 

(9 VAC 5-80-110 and Condition 3 of September 30, 2008 permit) 

IV.A.3. Emission Controls and Work Practices: No person or owner shall cause or 

permit to be discharged from any affected facility any volatile organic compound 

(VOC) in excess of that resultant from using reasonably available control technology. 

a. All cylinder cleaning solvents and VOC-containing solvents shall be kept in 

closed containers (e.g. capped squirt bottles, covered storage cans, or stoppered 

bottles), except during use, 

b. All waste inks and solvents containing VOC shall be stored in closed containers 

and shall be disposed of by transporting offsite for reclamation or incineration, 

c. Used rags and other cleaning materials that contain residual VOC shall be 

contained in covered bins until shipped offsite, 

(9 VAC 5-50-20 F, 9 VAC 5-50-260 and 9 VAC 5-80-110) 

IV.A.4. Emission Control Requirement: The permanent total enclosure for Press 745 

(P006) shall meet the following criteria: 

a. Any natural draft openings shall be at least 4 equivalent opening diameters from 

each VOC emitting point; 

b. The total area of all natural draft openings shall not exceed 5 percent of the 

surface area of the enclosure’s four walls, floor, and ceiling; 

c. The average facial velocity of air through the natural draft openings shall be at 

least 200 feet per minute and the direction of air flow shall be into the enclosure 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 12 

(or, if differential pressure is measured, the pressure drop shall be at least .007 

in. H2O); 

d. All access doors and windows shall be closed during routine operation of the 

press (except those which are included in determining the area of natural draft 

openings in b above). 

e. All of the exhaust gases from the enclosure shall be directed to the carbon bed 

adsorption system (C003). 

(9 VAC 5-80-30, 9 VAC 5-50-270, 9 VAC 5-80-110 and Condition 5 of September 

30, 2008 permit) 

IV.A.5. Emission Standard: Volatile organic compound (VOC) emissions from the 

operation of each rotogravure press (P001, P002, P003, P004, P005, and P006,) 

shall not exceed 16 percent of the total mass of VOC solvent and water used at that 

press during any one performance averaging period. For continuing compliance 

purposes, the performance-averaging period is one calendar month. 

(40 CFR 60.432, 9 VAC 5-80-110, and Condition 4 of September 30, 2008 permit) 

IV.A.6. Emission Limitation: Hazardous Air Pollutant (HAP) emissions from the 

operation of the publication rotogravure presses P001, P002, P003, P004, P005, 

P006and all equipment ancillary to the proper operation of the publication 

rotogravure presses, including but not limited to, the cylinder wash tank P008, VOC 

storage tanks T001 through T021, ink mixing and all press and floor cleaning 

activities shall not exceed eight percent of the total volatile matter used each month. 

The emission limitation shall be achieved by overall recovery efficiency of 92 percent 

of organic HAP used, by a combination of capture and control technologies and 

substitution of materials. 

(40 CFR 63.824 and 9 VAC 5-80-110) 

IV.A.7. Throughput Limit: The Renzmann cylinder cleaning tank (P008) shall clean no 

more than 10,000 cylinders per year, calculated monthly as the sum of the cylinders 

cleaned over the previous 12 months. 

(9 VAC 5-80-110 and Condition 7 of September 30, 2008 Permit) 

IV.A.8. Throughput Limit: The annual throughput of VOC to Presses No. 740, 741, 

742, and 743 (P001, P002, P003, and P004) shall not exceed 10,585.5 tons per 

year, calculated monthly as the sum of the VOC throughput over the previous 

consecutive 12 months. 

(9 VAC 5-80-110 and Condition 8 of September 30, 2008 Permit) 

IV.A.9. Throughput Limit: The annual throughput of VOC to Press No. 744 (P005) shall 

not exceed 4115.1 tons per year, calculated monthly as the sum of the VOC 

throughput over the previous consecutive 12 months. 

(9 VAC 5-80-110 and Condition 9 of September 30, 2008 Permit) 

IV.A.10. Throughput Limit: The daily throughput of VOC to Press No. 745 (P006) 

shall not exceed 46,848 pounds per day. The annual throughput of VOC to press 

P006 shall not exceed 4500 tons per year, calculated monthly as the sum of the 

VOC throughput over the previous consecutive 12 months. 

(9 VAC 5-80-110 and Condition 10 of September 30, 2008 Permit) 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 13 

IV.A.11. Throughput Limit: The annual throughput of VOC from the paster glue 

(P020) process to Presses Nos. 740, 741, 742, 743, 744, and 745, (P001, P002, 

P003, P004, P005, and P006) shall not exceed 1.5 tons per year, calculated monthly 

as the sum over the previous consecutive 12 months. 

(9 VAC 5-80-110 and Condition 11 of September 30, 2008 Permit) 

IV.A.12. Visible Emission Limit: Visible emissions from the carbon bed adsorption 

systems C001 and C002 shall not exceed 20 percent opacity except during one sixminute period in any one hour in which visible emissions shall not exceed 30 percent 

opacity. 

(9 VAC 5-50-80 and 9 VAC 5-80-110) 

IV.A.13. Visible Emission Limit: Visible emissions from the carbon bed adsorption 

system (C003) dedicated to the Frankenthal press No. 745 (SRB) shall not exceed 5 

percent opacity as determined by EPA Method 9 (reference 40 CFR 60, Appendix 

A). 

(9 VAC 5-50-80, 9 VAC 5-80-110, and Condition 24 of September 30, 2008 Permit) 

IV.A.14. Emission Limit: Volatile Organic Compound (VOC) emissions from the 

operation of the Renzmann cylinder wash (P008) shall not exceed the limits specified 

below: 

Lbs/hr tons/yr

13.4 11.2 

(9 VAC 5-80-110 and Condition 21 of September 30, 2008 Permit) 

IV.A.15. Emission Limits: Volatile Organic Compound (VOC) emissions from the 

operation of the rotogravure presses as determined by mass balance calculation, 

actual press running hours, and VOC CEMS shall not exceed the limits specified 

below: 

Press Number lbs/hr lbs/day tons/yr

Press 740 (P001) 77.5 226.8 

Press 741 (P002) 82.4 211.5 

Press 742 (P003) 93.6 273.7 

Press 743 (P004) 82.4 240.8 

Press 744 (P005) 126.5 370.4 

Press 745 (P006) 54.7 1311.7 126.0 

Paster Glue (P0020) 0.4 1.5 

Total Press VOC Emissions 517.5 1311.7 1450.5 

(9 VAC 5-80-110 and Condition 17 of September 30, 2008 Permit) 

IV.A.16. Emission Limits: Emissions of the following pollutants, as limited in 

Condition IV.A.15 for each press as VOC, shall not exceed the percentages (by 

weight) of each component of the solvent blend as listed below: 

Hexane 1.00 % 

Benzene 0.01 % 

Toluene 96.00 % 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 14 

Ethylbenzene 2.00 % 

Xylenes 5.16 % 

 (9 VAC 5-80-110 and Condition 18 of September 30, 2008 Permit) 

IV.A.17. Permitted Pollutants: Condition IV.A.16 of this permit provides a list of 

HAPs to be emitted by the publication printing process equipment (P001 through 

P006, P008 and T001 through T021). A change in the amounts of these pollutants 

emitted and/or a change in your facility which results in the emissions of additional 

pollutants may require a permit to modify and operate. 

(9 VAC 5-50-180, 9 VAC 5-50-260, 9 VAC 5-80-110, and Condition 53 of September 

30, 2008 Permit) 

IV.A.18. Minimum Stack Heights: The exhaust stack heights for all carbon bed 

adsorber systems (SRA, SRB) located at the printing facility shall be a minimum of 

50 feet, as measured from ground level. There shall be no caps or downturns 

installed at the exit of any carbon bed adsorber exhaust stack. 

(9 VAC 5-80-110 and Condition 54 of September 30, 2008 Permit) 

IV.A.19. Startup, Shutdown, and Malfunction Plan: The permittee shall develop and 

implement a written startup, shutdown, and malfunction plan for the Solvent 

Recovery systems A and B (including any other associated air pollution control 

equipment) for operating and maintaining the affected facility during periods of 

startup, shutdown, and malfunction and a program of corrective action for 

malfunctioning process and air pollution control equipment used to comply with the 

relevant standard. The plan shall identify all routine or otherwise predicable 

Continuous Monitoring System (CMS) malfunctions. This plan is incorporated into 

this permit by reference (see Condition IV.A.24). 

(40 CFR 63.6(e)(3) and 9 VAC 5-80-110) 

IV.A.20. Operation and Maintenance Requirements: During periods of startup, 

shutdown, and malfunction, the permittee shall operate and maintain Solvent 

Recovery systems A and B (including any other associated air pollution control 

equipment) in accordance with the procedures specified in the startup, shutdown, 

and malfunction plan required by Condition IV.A.19 and as follows: 

a. When actions taken by the owner or operator during a startup, shutdown, or 

malfunction (including actions taken to correct a malfunction) are consistent with 

the procedures specified in the affected source's startup, shutdown, and 

malfunction plan, the owner or operator shall: 

i. Keep records for that event that demonstrate that the procedures specified in 

the plan were followed, including records of the occurrence and duration of 

each startup, shutdown, or malfunction of operation and each malfunction of 

the air pollution control equipment and others required by Conditions IV.C.3.c 

and d. 

ii. Confirm that actions taken during the relevant reporting period during periods 

of startup, shutdown, and malfunction were consistent with the affected 

source's startup, shutdown and malfunction plan in the semiannual (or more 

frequent) startup, shutdown, and malfunction report required in Condition 

IV.E.3. 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 15 

b. If an action taken by the owner or operator during a startup, shutdown, or 

malfunction (including an action taken to correct a malfunction) is not consistent 

with the procedures specified in the affected source's startup, shutdown, and 

malfunction plan, the owner or operator shall: 

i. Keep records of the actions taken for that event and other records required 

by Condition IV.C.3.c; 

ii. Report such actions taken for the event to the Director, Piedmont Region 

within 2 working days after commencing actions inconsistent with the plan in 

accordance with Condition IV.E.4.a ; 

iii. Follow up the initial report with a letter to the Director, Piedmont Region 

within 7 working days after the end of the event, in accordance with Condition 

IV.E.4.b ; and 

iv. Revise the plan within 45 days after the event to include detailed procedures 

for operating and maintaining the source during similar malfunction events 

and a program of corrective action for similar malfunctions of process or air 

pollution control equipment, if the plan fails to address (or inadequately 

addresses) an event that meets the characteristics of a malfunction, but was 

not in the plan. 

v. Make reasonable revisions to the startup, shutdown, and malfunction plan 

required by the Director, Piedmont Region, if the Director finds that the plan: 

(a) Does not address a startup, shutdown, or malfunction event that has 

occurred; 

(b) Fails to provide for the operation of the source (including associated air 

pollution control equipment) during a startup, shutdown, or malfunction 

event in a manner consistent with good air pollution control practices 

for minimizing emissions at least to the levels required by all relevant 

standards; or 

(c) Does not provide adequate procedures for correcting malfunctioning 

process and/or air pollution control equipment as quickly as 

practicable. 

(40 CFR 63.6(e) and 9 VAC 5-80-110) 

IV.A.21. Correction of Malfunctions: Malfunctions shall be corrected as soon as 

practicable after their occurrence in accordance with the startup, shutdown, and 

malfunction plan. 

(40 CFR 63.6(e) and 9 VAC 5-80-110) 

IV.A.22. Violation of Hazardous Air Pollutant Emission Standards: Any of the 

publication rotogravure presses (P001, P002, P003, P004, P005 and P006) and any 

equipment ancillary to the proper operation of the publication rotogravure presses, 

including but not limited to the cylinder cleaning tank P008, VOC storage tanks T001 

through T021, ink mixing and all press and floor cleaning activities shall be shut 

down immediately if it is unable to meet the applicable emission standards, and it 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 16 

shall not return to operation until it is in compliance with the applicable emission 

standards. 

(9 VAC 5-20-180 and 9 VAC 5-80-110) 

IV.A.23. NSPS Subpart QQ Requirements by Reference: Except where this permit 

is more restrictive than the applicable requirement, the NSPS Subpart QQ equipment 

as described in Section I shall be operated in compliance with the requirements of 40 

CFR 60, Subpart QQ. 

(9 VAC 5-50-400, 9 VAC 5-50-410, and Condition 28 of September 30, 2008 Permit) 

IV.A.24. MACT Subpart KK Requirements by Reference: Except where this permit 

is more restrictive than the applicable requirement, the MACT Subpart KK equipment 

as described in Section I shall be operated in compliance with the requirements of 40 

CFR 63, Subpart KK. 

(9 VAC 5-60-120 and Condition 29 of September 30, 2008 Permit) 

IV.B. Monitoring 

IV.B.1. Continuous Emission Monitoring System (CEMS) - The carbon bed 

adsorption system for Press No. 745 (SRB) shall be equipped with continuous 

emission monitors which measure and record the concentration of volatile organic 

compounds and shall be equipped with a device which calculates and records a 24 

hour average VOC removal efficiency and which demonstrates compliance daily with 

the VOC removal efficiency requirement of Condition IV.A.2. The continuous 

emissions monitors shall be located at the carbon bed adsorption system inlet 

plenum and exhaust stack and shall be maintained, located, and calibrated in 

accordance with approved procedures outlined in IV.B.6 (Attachment A of 

September 30, 2008 permit). A 30 day notification, prior to the demonstration of 

continuous monitoring system's performance, and subsequent notifications shall be 

submitted to the Director, Piedmont Regional Office. 

(9 VAC 5-50-40 F, 9 VAC 5-80-110, and Condition 32 of September 30, 2008 Permit) 

IV.B.2. Continuous Monitoring Device (CMD)- The permanent total enclosure for 

press No. 745 (P006) shall be equipped with devices which continuously measures 

differential pressure drop across the enclosure boundary or which continuously 

measures the facial velocity of air flow into the enclosure to determine compliance 

with Condition IV.A.4.c. Each monitoring device shall be installed, maintained, 

calibrated and operated in accordance with approved procedures which shall 

include, as a minimum, the manufacturer's written requirements or 

recommendations. Each monitoring device shall be provided with adequate access 

for inspection and shall be in operation when the Press 745 is operating. 

(9 VAC 5-50-30, 9 VAC 5-80-30 F, 9 VAC 5-80-110, and Condition 33 of September 

30, 2008 Permit) 

IV.B.3. Monitoring Devices - The carbon bed adsorbers (SRA, SRB) shall be equipped 

with continuous emission monitors (CEMS) to continuously measure and record the 

adsorber gas outlet concentration of VOC. The CEMS shall be available to collect 

data at a minimum of 95.0 percent of the total source operating time, calculated on a 

calendar monthly basis. Each monitoring device shall be installed, maintained, and 

operated in accordance with approved procedures which shall include, as a 
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Permit Number: PRO-50880 

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x 100

Total unit operating hours duringthe period

Total unit operating hoursfor which the CEMS provided quality - assured data MDA 

minimum, the manufacturer's written requirements or recommendations. Each 

monitoring device shall be provided with adequate access for inspection. 

(9 VAC 5-80-1180 D, 9 VAC 5-50-20 C, 9 VAC 5-50-2609, VAC 5-80-110, and 

Condition 34 of September 30, 2008 Permit) 

IV.B.4. Monitoring Device Observation - The devices used to continuously measure 

the adsorber gas outlet concentration of VOC on the carbon bed adsorbers (SRA, 

SRB) shall be observed by the permittee with a frequency of not less than once per 

day. The permittee shall keep a log of the observations from the monitoring device. 

(9 VAC 5-80-1180, D, 9 VAC 5-80-110, and Condition 35 of September 30, 2008 

Permit) 

IV.B.5. CEMS Quality Control Program - A CEMS quality control program (see IV.B.6) 

shall be implemented for all continuous monitoring systems. 

(9 VAC 5-50-40, 9 VAC 5-80-110, and Condition 36 of September 30, 2008 Permit) 

IV.B.6. Quality Assurance Requirements for Gas Continuous Emission Monitoring 

Systems Used for Compliance Determination - Introduction - This procedure 

shall be used to evaluate the effectiveness of quality control (QC) and quality 

assurance (QA) procedures and the quality of data produced by the continuous 

emission monitoring system (CEMS) on Solvent Recovery B that is used for 

determining compliance with the emission standards on a continuous basis as 

specified in the applicable permit condition. 

a. Definitions 

Calibration Drift (CD) - The difference in the CEMS output reading from a 

reference value after a period of operation during which no unscheduled 

maintenance, repair or adjustment took place. The reference value or optical filter 

and need not be certified. 

Continuous Emission Monitoring System - The total equipment required for the 

determination of a gas concentration or emission rate. 

Data Accuracy - The absolute mean difference between the pollutant 

concentration determined by the CEMS and the reference value concentration. 

Diluent Gas - A major gaseous constituent in a gaseous pollutant mixture. For 

combustion sources, CO2 and O2 are the major gaseous constituents of interest. 

Minimum Data Availability – The minimum data availability (MDA) shall be: 

Span Value - The upper limit of a gas concentration measurement range that is 

specified for affected source categories in the applicable subpart of the 

regulation. 

Zero, Low-Level, and High-Level Values - The CEMS response values related to 

the source specific span value. Determination of zero, low-level, and high-level 

values is defined in the appropriate PS in appendix B of this part. 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 18 

b. QC Requirements 

The owner or operator must develop and implement a QC program. As a 

minimum, each QC program must include written procedures which should 

describe in detail, complete, step-by-step procedures and operations for each of 

the following activities: 

i. Calibration of CEMS. 

ii. Calibration Drift (CD) determination and adjustment of CEMS. 

iii. Preventive maintenance of CEMS (including spare parts inventory). 

iv. Data recording, calculations, and reporting. 

v. Accuracy audit procedures including sampling and analysis methods. 

vi. Program of corrective action for malfunctioning CEMS. 

As described in Section IV.B.6.d.iii, whenever excessive inaccuracies occur for 

two consecutive quarters, the source owner or operator must revise the current 

written procedures or modify or replace the CEMS to correct the deficiency 

causing the excessive inaccuracies. 

These written procedures must be kept on record and available for inspection by 

the enforcement agency. 

c. CD Assessment 

i. CD Requirement - source owners and operators of CEMS must check, 

record, and quantify the CD at two concentration values at least once weekly 

by passing the calibration gas through all filters, scrubbers, conditioners, and 

other monitor components used during normal sampling, and as much of the 

sampling probe as is practical. At a minimum, the audit gas should be 

introduced at the connection between the probe and the sample line. 

ii. In accordance with procedures approved by the Department, the CEMS 

calibration must, as minimum, be adjusted whenever the weekly zero (or lowlevel) CD or the weekly high-level CD exceeds 2.5 percent of the span value. 

i. Criteria for Excessive CD - if either the zero (or low-level) or high-level CD 

result exceeds 5.0% of the span value the CEMS is out of control unless the 

data accuracy does not exceed 5.0 ppm (for span values ≤ 50 ppm) or does 

not exceed 10.0 ppm (for span values > 50 ppm, but ≤ 200ppm). If the 

CEMS is out-of-control, take necessary corrective action. Following corrective 

action, repeat the CD checks. 

(a) Out-Of-Control Period Definition - the beginning of the out-of-control 

period is the time corresponding to failure of the calibration error test. 

The end of the out-of control period is completion of a successful 

calibration error test. 

(b) CEMS Data Status during Out-of-Control Period - during the period the 

CEMS is out-of-control, the CEMS data may not be counted towards 

meeting minimum data availability. When the CEMS is out of control, 

the CEMS data may not be used in demonstrating compliance with the 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

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efficiency requirement in Condition IV.A.2 for Solvent Recovery 

System B (carbon adsorber 3). 

ii. Data Recording and Reporting - all measurements from the CEMS must be 

retained on file by the source owner for at least 5 years. However, emission 

data obtained on each successive day while the CEMS is out-of-control may 

not be included as part of the minimum data for that period. 

d. Data Accuracy Assessment 

i. Auditing Requirements - Each CEMS must be audited at least once each 

calendar quarter. Successive quarterly audits shall occur no closer than 2 

months. The Cylinder Gas Audit (CGA) shall be conducted as follows: 

(a) Challenge the CEMS with an audit gas of known concentration at two 

points within the following ranges: 

Audit point 

Audit range 

Pollutant monitors 

1 20 to 30% of span value 

2 50 to 60% of span value 

(i) Challenge the CEMS three times at each audit point, and use the 

average of the three responses in determining accuracy. 

(ii) Use of separate audit gas cylinder for audit points 1 and 2. Do not 

dilute gas from audit cylinder when challenging the CEMS. 

(iii) The monitor should be challenged at each audit point for a 

sufficient period of time to assure adsorption-desorption of the 

CEMS sample transport surfaces has stabilized. 

(b) Operate each monitor in its normal sampling mode, i.e., pass the audit 

gas through all filters, scrubbers, conditioners, and other monitor 

components used during normal sampling, and as much of the 

sampling probe as is practical. At a minimum, the audit gas should be 

introduced at the connection between the probe and the sample line. 

(c) Use audit gases that have been certified by comparison to National 

Bureau of Standards (NBS) gaseous Standard Reference Materials 

(SRM's) or as approved by DEQ. The difference between the actual 

concentration of the audit gas and the concentration indicated by the 

monitor is used to assess the accuracy of the CEMS. 

ii. Out of Control Periods 

(a) Out-Of-Control Period Definition -the beginning of the out-of-control 

period is the time corresponding to the completion of the sampling for 

the CGA. The end of the out-of-control period is the time 

corresponding to the completion of the sampling of the subsequent 

successful audit. 
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Permit Number: PRO-50880 

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(b) CEMS Data Status During Out-Of-Control Period - during the period 

the monitor associated with Solvent Recovery B is out-of-control, the 

CEMS data may not be used in calculating emission compliance nor 

be counted towards meeting minimum data availability requirement for 

control efficiency in Condition IV.A.2. 

(c) Criteria for Excessive Audit Inaccuracy - unless specified otherwise in 

the applicable subpart, the criteria for excessive inaccuracy is - for the 

CGA - ±15 percent of the average audit value or ±5 ppm, whichever is 

greater. 

iii. Criteria for Acceptable QC Procedure - repeated excessive inaccuracies (i.e., 

out-of-control conditions resulting from the quarterly audits) indicates the QC 

procedures are inadequate or that the CEMS is incapable of providing quality 

data. Therefore, whenever excessive inaccuracies occur for two consecutive 

quarters, the source owner or operator must revise the QC procedures (see 

Section IV.B.6.b) or modify or replace the CEMS. 

e. Calculations for CEMS Data Accuracy 

CGA Accuracy Calculation - use Equation 1–1 to calculate the accuracy for the 

CGA, which is calculated in units of the appropriate concentration (e.g., ppm SO2 

or percent O2). Each component of the CEMS must meet the acceptable 

accuracy requirement. 

where: 

A=Accuracy of the CEMS, percent. 

Cm=Average CEMS response during audit in units of applicable standard or appropriate 

concentration. 

Ca=Average audit value (CGA certified value or three-run average for RAA) in units of 

applicable standard or appropriate concentration. 

(9 VAC 5-80-110) 

IV.B.7. Continuous Monitoring Device (CMD) - A device shall be installed to indicate 

the cumulative amount of volatile matter recovered by each solvent recovery system 

(C001, C002 and C003). The devices shall be installed, maintained and operated in 

accordance with manufacturer specifications. The devices shall be initially certified 

by the manufacturer to be accurate to within ±2.0 percent. 

(40 CFR 63.824(b)(i)(D)) 

IV.B.8. Periodic Monitoring of the Press Total Enclosure for P006: The permittee 

shall check (and document) compliance of the Press No. 745 (P006) permanent total 

enclosure with the requirements of Condition IV.A.4. prior to each startup of Press 

No. 745 (P006), and shall be checked not less than once per calendar day while the 

press is operating, if the press is operated at any time within that 24 hour period. 

The information needed to document conformance with the five requirements of 

Condition IV.A.4 may be recorded using a checklist in order to reduce the 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 21 

recordkeeping burden for conforming events. Actions taken prior to startup to correct 

nonconforming conditions do not need to be noted. Multiple startups over the period 

of one hour may be considered as one startup. 

(9 VAC 5-80-110 E.3) 

IV.B.9. Periodic Monitoring of VOC Removal Efficiency for C003: The permittee shall 

monitor the 24-hour average VOC removal efficiency of the carbon bed adsorption 

control device C003 on a daily basis for compliance with the overall VOC removal 

efficiency requirement of Condition IV.A.2. 

(9 VAC 5-80-110 and Condition 32 of September 30, 2008 Permit) 

IV.B.10. Periodic Monitoring of VOC Overall Recovery Efficiency for P001-P005, 

and P008: The permittee shall monitor the overall recovery efficiency (ORE) for each 

of the carbon bed solvent recovery systems C001 and C002 by liquid-liquid mass 

balance on a monthly basis for compliance with the overall recovery efficiency (ORE) 

requirements of Conditions IV.A.1. 

(9 VAC 5-80-110 E.3) 

IV.B.11. Periodic Monitoring of VOC Emission Percentage: The permittee shall 

calculate the estimated emission percentage (P) for each affected facility (P001 

through P006) for each performance averaging period and shall demonstrate 

compliance with the VOC emission standard in ConditionIV.A.5 as follows: 

a. For monitoring purposes, the performance averaging period shall be one 

calendar month. 

b. If affected facilities share the same raw ink storage/handling system with existing 

facilities, the total solvent used, solvent recovered and emission percentages for 

the combined facilities may be documented. The combined emission percentage 

is compared to the overall average for the existing and affected facilities 

determined during the most recent performance test. 

c. The permittee may choose to show compliance of the combined performance of 

existing and affected facilities controlled in common by the same solvent 

recovery system. 

d. If all existing and affected facilities within the same plant use solvent recovery 

systems, the permittee may choose to show compliance on a plant-wide basis for 

all the existing and affected facilities together. No separate tests on existing 

facilities and no segregated liquid measurement facilities are required for this 

option. 

e. Temperatures and liquid densities determined during the most recent 

performance test shall be used to calculate corrected volumes and mass 

quantities, except the permittee may choose to measure temperatures for 

determining of actual liquid densities during each performance averaging period. 

A different base temperature may be used for each performance averaging 

period if desired by the permittee. 

f. The emission percentage shall be calculated using the procedures of Conditions 

IV.D.1 and IV.D.7 

(40 CFR 60.433(e), (f), and (g), and 60.434(a), and 9 VAC 5-80-110) 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 22 

IV.B.12. Periodic Monitoring of Overall Effective Organic HAP Recovery 

Efficiency: The permittee shall demonstrate compliance on a monthly basis by 

showing that the HAP emission limitation in Condition IV.A.6 is achieved by 

performing a liquid-liquid material balance for each month as follows: 

a. Measure the mass of each ink, coating, varnish, adhesive, primer, solvent, 

reducer, thinner, cleaning agent, and other material used by the publication 

rotogravure printing source, including but not limited to, ancillary equipment and 

processes such as parts cleaning, cylinder preparation, tank loading, and ink 

mixing and storage. 

b. Determine the organic HAP content of each ink, coating, varnish, adhesive, 

primer, solvent, reducer, thinner, cleaning agents, and other material used by the 

publication rotogravure printing source, including but not limited to ancillary 

equipment and processes such as parts cleaning, cylinder preparation, tank 

loading, and ink mixing and storage, using the procedure in Condition IV.D.5. 

c. Determine the volatile matter content, including water, of each ink, coating, 

varnish, adhesive, primer, solvent, reducer, thinner, cleaning agents, and other 

material used by the publication rotogravure printing source, including but not 

limited to ancillary equipment and processes such as parts cleaning, cylinder 

preparation, tank loading, and ink mixing and storage, using the procedure in 

Condition IV.D.3. 

d. Measure the amount of volatile matter recovered for the month (Mvr). 

e. Calculate the overall effective organic HAP recovery efficiency (Re) for the month 

using the equation contained in Condition IV.D.2. 

f. The affected source is in compliance with the HAP emission limitation in 

Condition IV.A.6 for the month, if Re is at least 92 percent each month. 

(40 CFR 63.824(b)(1)(i) and 9 VAC 5-80-110) 

IV.B.13. Compliance Assurance Monitoring (CAM) - The permittee shall monitor, 

operate, calibrate and maintain the solvent recovery system (SRA) controlling the 

rotogravure printing presses 740, 741, 742, 743 and 744 (P001-P005) according to 

the following*: 

Monitoring, 

Frequency, Records 

Performance Criteria Indicator Range; 

Averaging Period 

1. Mass flow meters 

are read daily and 

recorded 

Located on outlet side of solvent recovery 

system (SRA) and solvent storage tanks. 

Measures total quantity of solvent 

recovered and total solvent metered to 

gravure pressroom. Meter accurate to 

within ± 0.2% mass flow and ± 0.25% 

volume flow. Calibrated annually. 

Meter can measure 

0-192 gallons per 

minute. 

2. Positive 

displacement meters 

are read monthly and 

recorded 

Located on inlet side of gravure presses 

and ink tanks. Measures ink, extender and 

solvent consumption by presses; total ink 

and extender received from supplier; and 

solvent sold. Meter accurate to within ± 

0.5%. Calibrated annually. 

Meter can measure 

0-65 gallons per 

minute. 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 23 

Monitoring, 

Frequency, Records 

Performance Criteria Indicator Range; 

Averaging Period 

3. VOC and HAP 

content of inks, 

solvents, cleaning 

solvents and press 

additives 

Certified Products Data sheet, Method 311 

gas chromatography, Method 24 A and 

MSDS. 

VOC and HAP 

emissions should not 

exceed hourly and 

annual (calculated on 

a monthly basis) 

permitted levels 

4. Liquid-to-liquid 

mass balance 

performed monthly 

As per procedures of 40 CFR 63 Subpart 

KK, section 63.824(b) (1) (i). Consumption 

of VOC for presses 740-744 is calculated 

by subtracting total VOC consumed from 

press 745 from the total VOC consumed by 

facility. 

Overall recovery 

efficiency of 91% is 

required on a monthly 

basis. 

* see CAM Plan Attachment 

IV.B.14. Compliance Assurance Monitoring (CAM) - The permittee shall monitor, 

operate, calibrate and maintain the solvent recovery system (SRB) controlling the 

rotogravure printing press 745 (P006) according to the following*: 

Monitoring, Frequency, 

Records 

Performance Criteria Indicator Range; 

Averaging Period 

1. Measurement of inlet 

and outlet concentration 

is continuous with PLC 

recordings every 1 

minute. 

Data representation - Inlet and 

outlet analyzers to measure the 

solvent concentrations in the air 

stream per the manufacturer have 

an accuracy of ± 1% of the full scale

Readings are averaged 

over five minutes, then 

each five-minute reading is 

averaged over 24 hours. 

An excursion is defined as 

a measured daily average 

overall control efficiency of 

less than 97.7%. 

Each excursion triggers an 

assessment of the 

problem, corrective action, 

and a reporting 

requirement. 

2. Concentration is 

recorded daily in PLC 

Verification of Operational Status 

3. Validation of 

instrumental accuracy 

conducted quarterly 

using CGA methods. 

Weekly gas zero and 

span calibration checks 

QA/QC Practices and Criteria in 

section IV.B.6

* see CAM Plan Attachment 

IV.B.15. Compliance Assurance Monitoring (CAM) - The permittee shall conduct 

the monitoring and fulfill the other obligations specified in 40 CFR 64.7 through 40 

CFR 64.9. 

(9 VAC 5-80-110 E (Article 1) and 40 CFR 64.6 (c)) 

IV.B.16. Compliance Assurance Monitoring (CAM) - At all times, the permittee shall 

maintain the monitoring equipment, including, but not limited to, maintaining 

necessary parts for routine repairs of the monitoring equipment. 

(9 VAC 5-80-110 E (Article 1) and 40 CFR 64.7 (b)) 

IV.B.17. Compliance Assurance Monitoring (CAM) - Except for, as applicable, 

monitoring malfunctions, associated repairs, and required quality assurance or 

control activities (including, as applicable, calibration checks and required zero and 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 24 

span adjustments), the permittee shall conduct all monitoring in continuous operation 

(or shall collect data at all required intervals) at all times that the solvent recovery 

systems (SRA and SRB) are operating. Data recorded during monitoring 

malfunctions, associated repairs, and required quality assurance or control activities 

shall not be used for purposes of compliance assurance monitoring, including data 

averages and calculations, or fulfilling a minimum data availability requirement, if 

applicable. The permittee shall use all the data collected during all other periods in 

assessing the operation of the control device and associated control system. A 

monitoring malfunction is any sudden, infrequent, not reasonably preventable failure 

of the monitoring to provide valid data. Monitoring failures that are caused in part by 

inadequate maintenance or improper operation are not malfunctions. 

(9 VAC 5-80-110 E (Article 1) and 40 CFR 64.7 (c)) 

IV.B.18. Compliance Assurance Monitoring (CAM) - Upon detecting an excursion 

or exceedance, the permittee shall restore operation of the solvent recovery system 

(SRA, SRB) (including the control device and associated capture system) to its 

normal or usual manner of operation as expeditiously as practicable in accordance 

with good air pollution control practices for minimizing emissions. The response 

shall include minimizing the period of any startup, shutdown or malfunction and 

taking any necessary corrective actions to restore normal operation and prevent the 

likely recurrence of the cause of an excursion or exceedance (other than those 

caused by excused startup and shutdown conditions). Such actions may include 

initial inspection and evaluation, recording that operations returned to normal without 

operator action (such as through response by a computerized distribution control 

system), or any necessary follow-up actions to return operation to within the 

indicator, designated condition, or below the applicable emission limitation or 

standard, as applicable. 

(9 VAC 5-80-110 E (Article 1) and 40 CFR 64.7 (d)(1)) 

IV.B.19. Compliance Assurance Monitoring (CAM) - Determination that acceptable 

procedures were used in response to an excursion or exceedance will be based on 

information available, which may include but is not limited to, monitoring results, 

review of operation and maintenance procedures and records, and inspection of the 

control device, associated capture system, and the process. 

(9 VAC 5-80-110 E (Article 1) and 40 CFR 64.7(d)(2)) 

IV.B.20. Compliance Assurance Monitoring (CAM) - If the permittee identifies a 

failure to achieve compliance with an emission limitation or standard for which the 

approved monitoring did not provide an indication of an excursion or exceedance 

while providing valid data, or the results of compliance or performance testing 

document a need to modify the existing indicator ranges or designated conditions, 

the permittee shall promptly notify the Director, Piedmont Regional Office and, if 

necessary, submit a proposed modification to this permit to address the necessary 

monitoring changes. Such a modification may include, but is not limited to, 

reestablishing indicator ranges or designated conditions, modifying the frequency of 

conducting monitoring and collecting data, or the monitoring of additional 

parameters. 

(9 VAC 5-80-110 E (Article 1) and 40 CFR 64.7(e)) 

IV.B.21. Compliance Assurance Monitoring (CAM) - If the number of exceedances 

or excursions exceeds 5 percent duration of the operating time for the solvent 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 25 

recovery systems (SRA & SRB) for a semiannual reporting period, the permittee 

shall develop, implement and maintain a Quality Improvement Plan (QIP) in 

accordance with 40 CFR 64.8. If a QIP is required, the permittee shall have it 

available for inspection. The QIP initially shall include procedures for evaluating the 

control performance problems and, based on the results of the evaluation 

procedures, the permittee shall modify the plan to include procedures for conducting 

one or more of the following, as appropriate: 

a. Improved preventative maintenance practices; 

b. Process operation changes; 

c. Appropriate improvements to control methods; 

d. Other steps appropriate to correct control performance; and 

e. More frequent or improved monitoring. 

(9 VAC 5-80-110 E (Article 1) and 40 CFR 64.8(a) and (b)) 

IV.C. Recordkeeping 

IV.C.1. General Graphic Arts Compliance Records: The permittee shall maintain 

records of all emission data and operating parameters necessary to demonstrate 

compliance with the requirements of Section IV.A of this permit and shall be 

consistent with DEQ policy, AQP 4 - Procedures for Maintaining Records for Surface 

Coating Operations and Graphic Arts Printing Processes. The content of and format 

of such records shall be arranged with the Director, Piedmont Region. These 

records shall include, but are not limited to: 

a. For each press, at all times: 

i. Identification number of the press. 

ii. Hours of operation per day and per year. 

iii. The method of application. 

iv. The number and types of coatings applied to the substrate. 

v. The drying method. 

vi. The substrate type. 

vii. The associated add-on capture system location and type, the actual capture 

efficiency (percent), and the method used to determine the capture efficiency. 

b. For each coating at all times: 

i. The supplier name, coating name and identification number. 

ii. The coating density (pounds per gallon). 

iii. The volatile content of the coating as supplied (percent by weight). 

iv. The water content of the coating as supplied (percent by weight). 

v. The exempt solvent content of the coating as supplied (percent by weight). 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 26 

vi. The solids content of the coating as supplied (percent by volume). 

vii. The name of the diluents, if any. 

viii. The identification number of diluents. 

ix. The diluent VOC density (pounds per gallon). 

x. The VOC content of the diluent (percent by weight). 

xi. The exempt solvent content of the diluent (percent by weight). 

xii. The diluent /coating ratio (gallon diluent per gallon coating). 

c. For each add-on control system: 

i. The control system identification number, manufacturer, model, type and 

installation date. 

ii. The actual removal efficiency, the method used to determine the removal 

efficiency, and the last test date for which the removal efficiency was 

determined. 

iii. Emission test results, including inlet and outlet VOC concentrations (ppmv), 

the method used to determine the concentrations and the last test date for 

which the concentrations were determined. 

iv. The design pressure drop across the adsorber at breakthrough, and the 

specific VOC species analyzed and its concentration at breakthrough. 

d. Daily, for each press operated: 

i. Identification number of the press. 

ii. The time period for each application run. 

iii. The coating identification numbers of each coating applied to the substrate. 

iv. The amount of each coating used. 

v. The diluent and clean up solvent identification numbers. 

vi. The amount of each diluent used. 

vii. The amount of each clean up solvent used. 

viii. Identification number of the associated add-on control device, and whether or 

not the control device was in operation during the entire time the press was in 

operation. 

ix. The calculated VOC emissions. 

These records shall be available for inspection by the DEQ and shall be current for 

the most recent five years. 

(9 VAC 5-50-50, 9 VAC 5-20-121 AQP-4, 9 VAC 5-80-110 and Condition 41 of 

September 30, 2008 Permit) 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 27 

IV.C.2. Compliance Records for the Publication Rotogravure Printing NSPS QQ: In 

addition to the records required above, the permittee shall maintain records of all 

emission data and operating parameters necessary to demonstrate compliance with 

the requirements of Section IV.A of this permit and 40 CFR 60, Subpart QQ and shall 

be consistent with DEQ policy. The content of and format of such records shall be 

arranged with the Director, Piedmont Region. These records shall also include, but 

are not limited to: 

a. Records of the following parameters and the liquid temperatures at which they 

were measured, for each performance averaging period: 

i. The amount of raw inks and related coatings used. 

ii. The VOC content of each raw ink and related coating used determined 

according to Condition IV.D.7. 

iii. The amount of VOC solvent added to the inks and coatings used. 

iv. The amount of VOC solvent used as cleaning agents. 

v. The amount of VOC solvent recovered. 

b. Records of the temperatures and liquid densities and the calculated emission 

percentages (P) determined for compliance with Condition IV.A.5 during the most 

recent performance test. 

c. If actual liquid densities are determined for the performance averaging period, 

records of the density variations with temperature of the raw inks, related 

coatings, VOC solvents used, and VOC solvent recovered using the methods 

stipulated in Condition IV.D.7 for the performance averaging period. 

d. For each performance averaging period, the calculated emission percentage (P) 

calculated in accordance with Condition IV.D.1 as required in Condition IV.B.11. 

e. If the comparison of Condition IV.B.11.b is to be used to avoid separate 

accounting of raw inks, records shall be kept of the overall emission percentage 

as well as all emission percentages for each affected (P001 through P006) 

facility determined during the most recent performance test. 

These records shall be available for inspection by the DEQ and shall be current for 

the most recent five years. 

(40. CFR 60.433 and 60.434, 9 VAC 5-50-50, and 9 VAC 5-80-110) 

IV.C.3. Compliance Records for the Printing and Publishing MACT KK: In addition 

to the records required above, the permittee shall maintain files of all information 

required by this condition recorded in a form suitable and readily available for 

expeditious inspection and review. The files shall be retained for at least 5 years 

following the date of each occurrence, measurement, maintenance, corrective action, 

report, or record. 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. The content and format of such records shall be arranged 

with the Director, Piedmont Region. These records shall include, but are not limited 

to: 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 28 

a. Monthly liquid-liquid material balances of HAP used at the facility, to include: 

i. The mass of each ink, coating, varnish, adhesive, primer, solvent, reducer, 

thinner, cleaning agents, and other material used by the publication 

rotogravure printing source, including but not limited to ancillary equipment 

and processes such as parts cleaning, cylinder preparation, tank loading, and 

ink mixing and storage. 

ii. The organic HAP content of each ink, coating, varnish, adhesive, primer, 

solvent, reducer, thinner, cleaning agents, and other material used by the 

publication rotogravure printing source, including but not limited to ancillary 

equipment and processes such as parts cleaning, cylinder preparation, tank 

loading, and ink mixing and storage. 

iii. The volatile matter content, including water, of each ink, coating, varnish, 

adhesive, primer, solvent, reducer, thinner, cleaning agents, and other 

material used by the publication rotogravure printing source, including but not 

limited to ancillary equipment and processes such as parts cleaning, cylinder 

preparation, tank loading, and ink mixing and storage. 

iv. The total amount of volatile matter recovered by the solvent recovery system 

(C001, C002, and C003). 

b. For each month, the overall effective organic HAP recovery efficiency (Re) 

calculated by liquid-liquid material balance in accordance with Condition IV.D.2. 

c. The occurrence and duration of each startup, shutdown and malfunction of 

operations (i.e. process equipment)(also an NSPS requirement)(See listed items 

in Section II.) 

d. The occurrence and duration of each malfunction of air pollution control 

equipment (also an NSPS requirement)(See listed items in Section II) 

e. All maintenance performed on the air pollution control equipment (See listed 

items in Section II.) 

f. Actions taken during periods of startup, shutdown, and malfunction (including 

corrective actions to restore malfunctioning process and air pollution control 

equipment to its normal or usual manner of operation) when such actions are 

different from the procedures specified in the affected source's startup, 

shutdown, and malfunction plan. 

g. All information necessary to demonstrate conformance with the affected source's 

startup, shutdown, and malfunction plan when all actions taken during periods of 

startup, shutdown, and malfunction (including corrective actions to restore 

malfunctioning process and air pollution control equipment to its normal or usual 

manner of operation) are consistent with the procedures specified in such plan. 

(The information needed to demonstrate conformance with the startup, 

shutdown, and malfunction plan may be recorded using a "checklist,'' or some 

other effective form of recordkeeping, in order to minimize the recordkeeping 

burden for conforming events.) 

h. All results of performance tests and all measurements as may be necessary to 

determine the conditions of performance tests. 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 29 

i. All documentation supporting initial notifications of applicability to the relevant 

standard (ref. 40 CFR 63.9(b)(1)) and notifications of compliance status (ref. 40 

CFR 63.9(h)). 

(40 CFR 60.7(b), 63.829(b)(1) and (c), 63.830(b)(1) and (3), 9 VAC 5-50-50, and 9 

VAC 5-80-110) 

IV.C.4. Additional Compliance Records for the Printing and Publishing MACT KK: 

The permittee shall also maintain the following records necessary to demonstrate 

compliance with this permit. The content and format of such records shall be 

arranged with the Director, Piedmont Region: 

a. The written startup, shutdown and malfunction plan, for the life of the publication 

printing processes or until the processes are no longer subject to the provisions 

of 40 CFR 63, Subpart KK., and 

b. Previous (i.e., superseded) versions of the startup, shutdown and malfunction 

plan, if the startup, shutdown and malfunction plan is revised, for a period of 5 

years after each revision to the plan. 

 

(40 CFR 63.6(e)(v), 9 VAC 5-50-50, and 9 VAC 5-80-110) 

IV.C.5. Additional Permit Compliance Records: In addition to the records required 

above, the permittee shall also maintain records of all emission data and operating 

parameters necessary to demonstrate compliance with the requirements of Section 

IV.A of this permit and shall be consistent with DEQ policy. The content of and 

format of such records shall be arranged with the Director, Piedmont Region. These 

records shall also include, but are not limited to: 

a. Monthly records of the number of cylinders cleaned in the Renzmann cylinder 

cleaning tank (P008), and the number of cylinders cleaned over the previous 

consecutive 12 months. 

b. Monthly records of the throughput of VOCs to the presses, and the monthly total 

of the previous consecutive twelve months’ throughput of VOC as follows: 

i. The total of Presses Nos. 740, 741, 742, 743 (P001 through P004); 

ii. Press No. 744 (P005); and 

iii. Press No. 745 (P006). 

c. Monthly material balances of VOC used at the facility, to include: 

i. The throughput of VOCs to each press (P001- P005) controlled by carbon 

bed adsorption recovery system No. 1 and No. 2 (C001 and C002); 

ii. The throughput of VOCs to Press No. 745 (P006) controlled by carbon bed 

adsorption recovery system No. 3 (C003); 

iii. The throughput of waste VOCs from each of the presses (P001- P006) that is 

disposed of off-site; 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 30 

iv. Amount of VOC recovered by the carbon bed recovery system (C001 - 

C003); 

v. Inventory loss of VOC from the Renzmann cylinder cleaning tank (P008) 

controlled by carbon bed adsorption recovery system No. 1 and No. 2 (C001 

and C002); 

vi. A monthly calculation of VOC emissions by press (P001- P006) and by the 

Renzmann cylinder cleaning tank (P008); and 

vii. A monthly total of the previous twelve months’ VOC emissions by press and 

by the Renzmann cylinder cleaning tank; 

d. Records for the total enclosure, the carbon bed adsorption systems and 

continuous emission monitoring systems, to include: 

i. The manufacturer's recommendations for carbon bed replacement; 

ii. Records of actual carbon bed replacement; 

iii. Records to demonstrate completion of all monitoring equipment calibrations, 

checks and tests; 

iv. Records of monitored carbon bed inlet gas VOC concentrations, as 

applicable, and exhaust gas VOC concentrations; 

v. A 24-hour average VOC removal efficiency (Press 745 – P006 only) 

calculated from the monitored carbon bed inlet and exhaust gas VOC 

concentrations from carbon bed adsorption recovery system No. 3 (C003); 

and 

vi. Records demonstrating compliance with the permanent total enclosure 

showing the differential pressure drop across the enclosure boundary or 

continuous measurement of face velocity of air flow into the enclosure 

e. Operator training records. 

f. Records of the occurrence and duration of any period during which a continuous 

monitoring system or monitoring system required under Section IV.B above (also 

an NSPS requirement) was not operational. 

These records shall be available for inspection by the DEQ and shall be current for 

the most recent five years. 

(9 VAC 5-50-50, 40 CFR 60.7(b), 9 VAC 5-80-110 and Condition 41 of September 

30, 2008 Permit) 

IV.C.6. Compliance Assurance Monitoring (CAM) Recordkeeping - The permittee 

shall maintain records of monitoring data, monitor performance data, corrective 

actions taken, any written quality improvement plan (QIP) required pursuant to §64.8 

and any activities undertaken to implement a quality improvement plan (QIP), and 

other supporting information required to be maintained under this part (such as data 

used to document the adequacy of monitoring, or records of monitoring maintenance 

or corrective actions). 

(9 VAC 5-80-110 E and 40 CFR 64.9(b)) 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 31 

IV.D. Testing 

IV.D.1. Determination of VOC Emission Percentage: The emission percentage (P) 

shall be calculated in accordance with one of the following two equations: 

P = (Lt - Lr) x 100 or P = (Mt - Mr) x 100 

 Lt Mt 

 Where, Lt = Total density-corrected* liquid volume of VOC used†. 

= Lo + Ld + Lg (sum of density-corrected* liquid volumes of VOC used as inks and 

coatings (Lo), VOC diluents (Ld), and VOC cleaning agents (Lg).) 

Lo = Total density-corrected* volume of VOC in raw inks and coatings used†. 

=  VOC volume of mass-measured inks with VOC content by weight % 

+  VOC volume of volume-measured inks with VOC content by weight % 

+  VOC volume of volume-measured inks with VOC content by volume % 

k m n 

=  [(Mci x Wci)/DB] +  [(Lci x Dci x Wci)/DB] +  [(Lci x Doi x Vci)/DB] i=1 i=1 i=1 

Ld = Total density-corrected* volume of VOC in diluents used†

. 

 =  density-corrected* volume of VOC in mass-measured diluents 

+  density-corrected* volume of VOC in volume-measured diluents 

k m 

=  [Mdi/DB] +  [(Ldi x Ddi)/DB] i=1 i=1 

Lg = Total density-corrected* volume of VOC in cleaning agents used†. 

=  density-corrected* volume of mass-measured VOC in cleaning agents 

+  density-corrected* volume of volume-measured VOC in cleaning agents 

k m 

=  [Mgi/DB] +  [(Lgi x Dgi)/DB] i=1 i=1 

Lr = Total density-corrected* liquid volume of VOC in solvent recovered†. 

=  density-corrected* volume of mass-measured VOC in solvent recovered 

+  density-corrected* volume of volume-measured VOC in solvent recovered 

k m 

=  [Mri/DB] +  [(Lri x Dri)/DB] i=1 i=1 

Mt = Total mass of VOC used. 

= Mo + Md + Mg (sum of mass of VOC used as inks and coatings (Mo), VOC diluents 

(Md), and VOC cleaning agents (Mg).) 

Mo = Total mass of VOC in raw inks and coatings used†

. 

 =  VOC mass in mass-measured inks 

+  VOC mass in volume-measured inks with VOC content by weight % 

+  VOC mass in volume-measured inks with VOC content by volume % 

k m n 

=  (Mci x Wci) +  (Lci x Dci x Wci) +  (Lci x Doi x Vci) i=1 i=1 i=1 

Md = Total mass of VOC in solvent diluents used†

. 

 =  mass of VOC in mass-measured solvent diluents 

+  mass of VOC in volume-measured solvent diluents 

k m 

=  (Mdi) +  (Ldi x Ddi) i=1 i=1
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 32 

Mg = Total mass of VOC in cleaning agents used†. 

 mass of VOC in mass-measured solvent cleaning agents 

+  mass of VOC in volume-measured solvent cleaning agents 

k m 

=  (Mgi) +  (Lgi x Dgi) i=1 i=1

 Mr = Total Mass of VOC in solvent recovered†

. 

 mass of VOC in mass-measured recovered VOC solvent 

+  mass of VOC in volume-measured recovered VOC solvent 

k m 

=  [Mri/DB] +  [(Lri x Dri)/DB] i=1 i=1

DB= The density of the VOC solvent used or recovered at an arbitrary base temperature†

. 

Dci=The density of each raw ink or coating used†

. 

Ddi= he density of each VOC solvent diluent used†

. 

Dgi=The density of each solvent cleaning agent used†

. 

Doi=The density of the VOC solvent in each raw ink or coating used†

. 

Dri=The density of each VOC solvent recovered†

. 

Lci=The directly measured liquid volume of each raw ink or coating used†

. 

Ldi=The directly measured liquid volume of each VOC solvent diluent used†

. 

Lgi=The directly measured liquid volume of each solvent cleaning agent used†

. 

Lri=The directly measured liquid volume of each VOC solvent recovered†

. 

Mci=The directly measured mass of each raw ink or coating used†

. 

Mdi=The directly measured mass of each VOC solvent diluent used†

. 

Mgi=The directly measured mass of each solvent cleaning agent used†

. 

Mri=The directly measured mass of each VOC solvent recovered†

. 

k=The total number of raw inks, diluents, cleaning agents or recovered solvents which were 

directly measured by mass. 

m=The total number of raw inks, diluents, cleaning agents or recovered solvents which were 

directly measured by liquid volume and have a known VOC content expressed in mass 

fraction or weight percent. 

n=The total number of raw inks, diluents, cleaning agents or recovered solvents which were 

directly measured by liquid volume and have a known VOC content expressed in 

volume fraction or volume percent. 

* corrected to density at the arbitrary reference base temperature. †

 for just the one performance averaging period. 

The calculated emission percentage (P) may be rounded off to the nearest whole 

number. Frequent press startups and shutdowns are considered normal operations 

and constitute representative conditions for the performance of this test. 

(40 CFR 60.431 and 60.433, and 9 VAC 5-80-110) 

IV.D.2. Determination of Overall Effective Organic HAP Recovery Efficiency: The 

overall effective organic HAP recovery efficiency (Re) shall be calculated in 

accordance with the following equation: 

Re = Mvu - Mhu +[(Mvr) x (Mhu / Mvu)]

 Mvu 

Where, Mvu = The mass of volatile matter, including water, used†

 (lbs). 

 Mhu = The mass of organic HAP used†

 (lbs). 

 Mvr = The measured mass of volatile matter recovered†

 (lbs). 

†

 for just the one month. 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 33 

For the 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 the organic 

HAP used. 

(40 CFR 63.822 and 63.824(b)(1)(i)(F), and 9 VAC 5-80-110) 

IV.D.3. Determination of Volatile Matter Mass: Unless specified otherwise, the mass 

of volatile matter used (Mvu) or recovered (Mvr) for each material may be calculated 

using the measured amount of the material and using the volatile matter content 

mass fraction for that material that was determined in accordance with Condition 

IV.D.6: 

Mass Used =  Mass of volatile matter in mass-measured materials or 

Recovered +  Mass of volatile matter in volume-measured materials 

with a known volatile matter content expressed in terms of a weight 

fraction (weight percent/100) 

k m 

=  (Mvi x Wvi) +  (Lvi x Dvi x Wvi) 

i=1 i=1 

Where, 

Dvi =Density of the ith material in terms of lbs/gal. 

Lvi = The directly measured volume of the material used in terms of gal.†

Mvi =The directly measured mass of material used in terms of lbs.†

Wvi =The volatile matter content of the ith material in terms of a mass (or weight) fraction 

(weight percent/100)(lbs volatile matter/lb material) 

k=The total number of materials which were directly measured by mass. 

m=The total number of materials which were directly measured by liquid volume and have a 

known volatile matter content expressed in terms of mass fraction or weight percent. 

†

 for just the one month. 

(9 VAC 5-50-30 and 9 VAC 5-80-110) 

IV.D.4. Determination of Organic HAP Mass: Unless specified otherwise, the mass of 

organic HAP used (Mhu) may be calculated using the measured amount of the 

material and using the organic HAP content mass fraction of the material determined 

in accordance with Condition IV.D.5. 

Mass Used =  Mass of organic HAP in mass-measured materials used 

+  Mass of organic HAP in volume-measured materials used that have a 

known organic HAP content expressed in terms of a weight fraction 

(weight percent/100) as determined in accordance with Condition IV.D.5. 

k m 

=  (Mvi x Wvi) +  (Lvi x Dvi x Wvi) 

i=1 i=1 

Where, 

Dvi = Density of the ith material in terms of lbs/gal. 

Lvi = The measured volume of the ith material used in terms of gal. 

Mvi = The measured mass of the ith material used in terms of gal. 

Wvi = The organic HAP content of the ith material in terms of a mass (or weight) fraction 

(weight percent/100)(lbs organic HAP/lb material) 

k = The total number of materials which were directly measured by mass. 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 34 

M = The total number of materials which were directly measured by liquid volume and have 

a known organic HAP content expressed in terms of mass fraction or weight percent. 

(40 CFR 63.825, 9 VAC 5-50-30 and 9 VAC 5-80-110) 

IV.D.5. Determination of Organic HAP Content: The permittee shall determine the 

organic HAP content, as the weight fraction of each ink, coating, varnish, adhesive, 

primer, solvent, reducer, thinner, diluent, and other material used in the publication 

rotogravure facility by one of the following three methods: 

a. The permittee may test the material in accordance with Method 311 (ref. 40 CFR 

63, Appendix A). This determination may be performed by manufacturer of the 

material and the results provided to the permittee instead. If these values cannot 

be determined using Method 311, the permittee shall submit an alternative 

technique for determining these values for approval by EPA and the recovery 

efficiency must be determined for all of the target organic HAP and a correction 

factor, if necessary, must be determined and applied. 

b. The permittee may determine the volatile matter content of the material in 

accordance with Condition IV.D.6 and use this value for the organic HAP content 

of the material for all compliance purposes. 

c. The permittee may rely on formulation data which is provided by the 

manufacturer of the material on a Certified Product Data Sheet if the 

manufacturer has included the organic HAP content determination of 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 if the 

manufacturer has determined that HAP content of each raw material present in 

the formulation by Method 311 (ref. 40 CFR 63, Appendix A). In the event of any 

inconsistency between the Method 311 test data and the formulation data (that 

is, if the Method 311 test data is higher), then the Method 311 test data shall 

govern, unless after consultation, the permittee demonstrates to the satisfaction 

of the Director, Piedmont Region that the formulation data are correct. 

(40 CFR 63.824(b) and 9 VAC 5-80-110) 

IV.D.6. Determination of Volatile Matter Content: The permittee shall determine the 

volatile matter content as the weight fraction of each ink, coating, varnish, adhesive, 

primer, solvent, reducer, thinner, diluent, and other material used in the publication 

rotogravure facility by one of the following two methods: 

a. The permittee shall determine the volatile matter weight fraction in accordance 

with Method 24A (ref. 40 CFR 60, Appendix A). This determination may be 

performed by the manufacturer of the material and the results provided to the 

permittee instead. If these values cannot be determined using Method 24A, the 

permittee shall submit an alternative technique for determining these values for 

approval by EPA. 

b. The permittee may determine the volatile matter content based on formulation 

data and may rely on volatile matter content data which is provided by the 

material suppliers. In the event of any inconsistency between the formulation 

data and the results of Test Methods 24 or 24A, the applicable test method shall 

govern, unless after consultations, the permittee can demonstrate to the 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 35 

satisfaction of the Director, Piedmont Region that the formulation data are 

correct. 

(40 CFR63.827(c)(1) and (3), and 9 VAC 5-80-110) 

IV.D.7. Determination of Volatile Organic Compound (VOC) Content and Density: 

The permittee shall determine the VOC content and density of each raw ink and 

related coating used at the publication rotogravure printing facility. 

a. For solvent-borne ink systems, the VOC content shall be determined by: 

i. Analysis using Reference Method 24A (ref. 40 CFR 60, Appendix A) of 

routine weekly samples of raw ink and related coatings in each respective 

storage tank; or 

ii. Analysis using Reference Method 24A (ref. 40 CFR 60, Appendix A) of 

samples of each shipment of all purchased raw ink and related coatings, or 

iii. Determination of the VOC content from formulation data supplied by the ink 

manufacturer with each shipment of raw inks and related coatings used. 

b. The permittee shall use the results of verification analyses by Reference Method 

24A (ref. 40 CFR 60, Appendix A) to determine compliance when discrepancies 

with ink manufacturers’ formulation data occur. 

c. The permittee shall determine the density of raw inks, related coatings, and VOC 

solvents by: 

i. Making a total of three determinations for each liquid sample at specified 

temperatures using the procedures of ASTM D1475-60 (Reapproved 1980) 

Standard Test Method for Paint, Varnish, Lacquer and Related Products. 

The temperature and density is recorded as the arithmetic average of the 

three determinations; or 

ii. Using literature values, at specified temperatures, acceptable to the Director, 

Piedmont Region. 

(40 CFR 60.435(a), (b) and (d), and 9 VAC 5-80-110) 

IV.D.8. Test Methods: If testing is conducted in addition to the monitoring specified in 

this permit, the permittee shall use the appropriate method(s) in accordance with 

procedures approved by the DEQ. 

 (9 VAC 5-80-110) 

IV.D.9. Conduct of Performance Tests: Performance tests that are conducted in 

accordance with methods specified in Condition IV.D.8 in addition to the monitoring 

specified in Section IV.B of this permit shall be conducted in accordance with Section 

VII.D of this permit. 

(9 VAC 5-50-30 G and 9 VAC 5-80-110) 

IV.E. Reporting 

IV.E.1. Semi-annual Reports – Data Assessment Report (DAR) - The permittee shall 

submit a DAR to the Director, Piedmont Regional Office within 30 days after the end 
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Permit Number: PRO-50880 

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of each semi-annual period. As a minimum, the DAR must contain the following 

information: 

a. Source owner or operator name and address. 

b. Identification and location of monitors in the CEMS. 

c. Manufacturer and model number of each monitor in the CEMS. 

d. Assessment of CEMS data accuracy and date of assessment as determined by a 

CGA described in Section IV.B.6.d including the A for the CGA, the cylinder 

gases certified values, the CEMS responses, and the calculations results as 

defined in Section IV.B.6.e. If the accuracy audit results show the CEMS to be 

out-of-control, the CEMS operator shall report both the audit results showing the 

CEMS to be out-of-control the length of the CGA out–of-control period, and the 

results of the audit following corrective action showing the CEMS to be operating 

within specifications. 

e. Summary of all corrective actions taken when CEMS was determined out-ofcontrol, as described in Sections IV.B.6.c and IV.B.6.d.for the quarterly CEMS 

audits. 

(9 VAC 5-170-160, 9 VAC 5-50-50 and Condition 42 of September 30, 2008 Permit) 

IV.E.2. Excess Emission and Summary Reports: The permittee shall submit a 

semiannual summary report to the Director, Piedmont Region for the hazardous air 

pollutants monitored at the affected source. The report shall be entitled “Summary 

Report - Gaseous Excess Emission and Continuous Monitoring System 

Performance” and shall contain the following information: 

a. The company name and address. 

b. An identification of each hazardous air pollutant monitored at the affected source. 

c. The beginning and ending dates of the reporting period. 

d. A brief description of the process units. 

e. The standard contained in Condition IV.A.6. 

f. The total operating time of the affected source during the reporting period. 

g. An emission data summary, including: 

i. Exceedances of the standard contained in Condition IV.A.6, 

ii. The total duration of excess emissions during the reporting period (in hours), 

iii. The total duration of excess emissions expressed as a percent of the total 

affected source operating time during that reporting period, and 

iv. A breakdown of the total duration of excess emissions that are due to control 

equipment problems, process problems, other known causes, and unknown 

causes. 

h. A description of any changes in processes or controls since the last reporting 

period. 

i. The name, title, and signature of the responsible official who is certifying the 

report and the required certification statement (see Condition X.L.2). 
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The summary report shall be postmarked by the 30th day following the end of each 

calendar half. When no excess emissions have occurred, such information shall be 

stated in the report. 

(40 CFR 63.10(e) and 63.830(a), and 9 VAC 5-80-110) 

IV.E.3. Periodic Startup, Shutdown and Malfunction Reports: The permittee shall 

submit semiannual reports by letter to the Director, Piedmont Region if actions taken 

during a startup, shutdown or malfunction (including actions to correct a malfunction) 

during the reporting period are consistent with the procedures in the startup, 

shutdown and malfunction plan, as required in Condition IV.A.20.a.ii. The periodic 

report shall contain the following information: 

a. A statement that the actions taken during the startup(s), shutdown(s), or 

malfunction(s) (and actions taken to correct malfunctions) during the reporting 

period were consistent with the procedures in the plan, and 

b. The name, title and signature of the responsible official who is certifying its 

accuracy and the required certification statement (see Condition X.L.2). 

Reports are only required if a startup, shutdown or malfunction occurred during the 

reporting period. The report, when submitted, shall be postmarked by the 30th day 

following the calendar half. This semiannual report may be submitted simultaneously 

with the semiannual excess emission and summary report or other reports. 

(40 CFR 63.10(d)(5) and 63.830(b)(5), and 9 VAC 5-80-110) 

IV.E.4. Immediate Startup, Shutdown and Malfunction Reports: Any time an action 

taken by the permittee taken during a startup, shutdown or malfunction (including 

actions to correct a malfunction) during the reporting period is not consistent with the 

procedures specified in the startup, shutdown and malfunction plan, the permittee 

shall report the actions as follows; 

a. Within two working days after commencing actions inconsistent with the 

procedures of the plan, the permittee shall report the actions to the Director, 

Piedmont Region. This immediate report shall consist of a telephone call or 

facsimile transmission. 

b. Within seven working days after the end of the event, the permittee shall follow 

up the immediate report with a letter to the Director, Piedmont Region explaining 

the event, the reasons for not following the procedures of the plan, and whether 

any excess emissions and/or parameter monitored are believed to have 

occurred. The follow up letter shall also contain the name, title, and signature of 

the responsible official who is certifying its accuracy, and the required 

certification statement (see Condition X.L.2). 

(40 CFR 63.10(d)(5) and 63.830(b)(5), and 9 VAC 5-80-110) 

IV.E.5. Required Notifications: The permittee shall provide written notifications to the 

Director, Piedmont Region of the following:

a. Within 15 calendar days after any physical or operational change to any existing 

press which may increase the emission rate of any air pollutant to which a 
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standard applies under 40 CFR 60, Subpart QQ (VOC) unless that change is 

specifically exempted from the definition of “modification” under 40 CFR 60.14. 

b. Within 15 calendar days after any change to the information already provided to 

the Director, Piedmont Region in notifications required under 40 CFR 63.9 

(notification of applicability, notification of construction/reconstruction, notification 

of physical or operational change, notifications of planned or actual dates of 

construction or startup, notifications of special compliance requirements, 

notification of planned dates of performance tests, notifications of visible 

emission evaluations, required notifications for continuous monitoring systems, 

and notifications of compliance status). 

(40 CFR 60.7(a), 60.8(d), and 63.9(j) and 9 VAC 5-80-110) 

IV.E.6. Compliance Assurance Monitoring (CAM) Reporting - the permittee shall 

submit CAM reports as part of the Title V semi-annual monitoring reports required by 

General Condition X.C.3 of this permit to the Director, Piedmont Regional Office. 

Such reports shall include at a minimum: 

a. Summary information on the number, duration and cause (including unknown 

cause, if applicable) of excursions or exceedances, as applicable, and the 

corrective actions taken; 

b. Summary information on the number, duration and cause (including unknown 

cause, if applicable) for monitor downtime incidents (other than downtime 

associated with zero and span or other daily calibration checks, if applicable); 

and 

c. A description of the actions taken to implement a quality improvement plan (QIP) 

during the reporting period as specified in §64.8. Upon completion of a QIP, the 

owner or operator shall include in the next summary report documentation that 

the implementation of the plan has been completed and reduced the likelihood of 

similar levels of excursions or exceedances occurring. 

(9 VAC 5-80-110 F and 40 CFR 64.9(a)) 
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V. Cylinder Electroplating Process Requirements - (P015 and P016) 

V.A. Limitations 

V.A.1. MACT Subpart N Requirements by Reference: Except where this permit is 

more restrictive than the applicable requirement, the MACT Subpart N equipment as 

described in Section II shall be operated in compliance with the requirements of 40 

CFR 63, Subpart N.. 

(9 VAC 5-60-120 and Condition 30 of September 30, 2008 Permit) 

V.A.2. Visible Emission Limit: Visible emissions from the small, hard chromium 

electroplating process (P015 and P016) shall not exceed 20 percent opacity except 

during one six-minute period in any one hour in which visible emissions shall not 

exceed 30 percent opacity. 

(9 VAC 5-50-80 and 9 VAC 5-80-110) 

V.A.3. Emission Standards: During the operation of the small, hard chromium 

electroplating process (P015 and P016), the permittee shall control chromium 

emissions discharged to the atmosphere by maintaining the concentration of total 

chromium in the exhaust gas stream below 6.6 x 10-6 gr/dscf. The chromium 

emission limit does not apply during periods of malfunction. The work practice 

standards in Condition V.A.5 address operation and maintenance during 

malfunctions. 

(40 CFR 63.342(b) and (c), 9 VAC 5-40-260, and 9 VAC 5-80-110) 

V.A.4. Operating Limit: To be in compliance with the standards of Condition V.A.3, the 

composite mesh pad demister filter control system shall be operated within ± 2 

inches of water column of the overall pressure drop value established during the 

initial performance test, or shall be operated within the range of compliant values for 

pressure drop established during multiple performance tests. 

(40 CFR 63.343(c) and 9 VAC 5-80-110) 

V.A.5. Work Practice Standards: The permittee shall comply with the following 

operation and maintenance practices: 

a. At all times, including periods of startup, shutdown, and malfunction the permittee 

shall operate and maintain the small hard chromium electroplating process, 

including associated air pollution control devices and monitoring equipment, in a 

manner consistent with good air pollution control practices and consistent with 

the operation and maintenance plan required by Condition V.A.6: 

i. If actions taken by the owner or operator during periods of malfunction are 

inconsistent with the procedures specified in the operation and maintenance 

plan, the owner or operator shall: 

(a) Record the actions taken for that event, and 

(b) Report such actions by phone to the Director, Piedmont Region within 

2 working days after commencing actions inconsistent with the plan, 

and 
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(c) Follow up with a letter to the Director, Piedmont Region within 7 

working days after the end of the event, unless the owner or operator 

makes alternative reporting arrangements, in advance, with the 

Director. 

ii. Malfunctions shall be corrected as soon as practicable after their occurrence 

in accordance with the operation and maintenance plan required by Condition 

V.A.6. 

iii. The operation and maintenance requirements established by this condition 

and by the operation and maintenance plan required by Condition V.A.6 are 

enforceable independent of emissions limitations or other requirements of this 

permit. 

b. Determination of whether acceptable operation and maintenance procedures are 

being used will be based on information available to the Director, Piedmont 

Region, 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 this determination, the Director, Piedmont Region may 

require that the permittee make changes to the operation and maintenance plan. 

Revisions may be required if the Director finds that the plan: 

i. Does not address a malfunction that has occurred; 

ii. Fails to provide for the operation of the affected source, the air pollution 

control techniques, or the control system and process monitoring 

equipment during a malfunction in a manner consistent with good air 

pollution control practices; or 

iii. Does not provide adequate procedures for correcting malfunctioning process 

equipment, air pollution control techniques, or monitoring equipment as 

quickly as practicable. 

(40 CFR 63.342(f) and 9 VAC 5-80-110) 

V.A.6. Operation and Maintenance Plan: The permittee shall develop and implement 

a written operation and maintenance plan for the small hard chromium electroplating 

process (P015 and P016), including associated air pollution control devices and 

monitoring equipment. This plan shall be incorporated into this permit by reference. 

a. The plan is required to include the following elements: 

i. The plan shall specify the operation and maintenance criteria for the small 

hard chromium electroplating process , the associated air pollution control 

device and the process and control system monitoring equipment, and shall 

include a standardized checklist to document the operation and maintenance 

of this equipment; 

ii. The plan shall incorporate the following work practice standards for the 

composite mesh pad demister filter: 
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Permit Number: PRO-50880 

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(a) Quarterly - Visually inspect the device to ensure there is proper 

drainage, no chromic acid buildup on the pads, and no evidence of 

chemical attack on the structural integrity of the device. 

(b) Quarterly - Visually inspect the back portion of the mesh pad closest to 

the fan to ensure there is no breakthrough of chromic acid mist. 

(c) Quarterly - Visually inspect the ductwork from the tank to the control 

device to ensure there are no leaks. 

(d) Perform washdown of the composite mesh pads in accordance with 

manufacturer recommendations; 

iii. The plan shall incorporate the work practice standards recommended by the 

manufacturer for the continuous monitoring device that monitors differential 

pressure across the demister filter; 

iv. The plan shall specify procedures to be followed to ensure that equipment or 

process malfunctions due to poor maintenance or other preventable 

conditions do not occur; and 

v. The plan shall include a systematic procedure for identifying malfunctions of 

process equipment, add-on air pollution control devices, and process and 

control system monitoring equipment and for implementing corrective actions 

to address such malfunctions. 

b. If the operation and maintenance plan fails to address or inadequately addresses 

an event that meets the characteristics of a malfunction at the time the plan is 

initially developed, the owner or operator shall revise the operation and 

maintenance plan within 45 days after such an event occurs. The revised plan 

shall include procedures for operating and maintaining the process equipment, 

add-on air pollution control device, or monitoring equipment during similar 

malfunction events, and a program for corrective action for such events. 

(40 CFR 63.342(f) and 9 VAC 5-80-110) 

V.A.7. Violation of Hazardous Air Pollutant Emission Standards: The small hard 

chromium electroplating process shall be shut down immediately if it is unable to 

meet the applicable emission standards, and it shall not return to operation until it is 

in compliance with the applicable emission standards. 

(9 VAC 5-20-180 F.2 and 9 VAC 5-80-110) 

V.B. Monitoring 

V.B.1. Continuous Monitoring Device (CMD): The composite mesh pad type demister 

filter shall be equipped with a device to continuously measure the differential 

pressure drop across the fabric filter. The device shall be installed in an accessible 

location and shall be maintained by the permittee such that it is in proper working 

order at all times. 

(40 CFR 63.343(c) and 9 VAC 5-80-110) 

V.B.2. Continuous Monitoring Device Installation Requirements: All monitoring 

equipment shall be installed such that representative measurements of emissions or 
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Permit Number: PRO-50880 

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process parameters from the affected source are obtained. For monitoring 

equipment purchased from a vendor, verification of the operational status of the 

monitoring equipment shall include execution of the manufacturer’s written 

specifications or recommendations for the installation, operation and calibration of 

the system. The specification for differential pressure measurement devices used to 

measure pressure drop across a control system shall be in accordance with the 

manufacturer’s accuracy specifications. 

(40 CFR 63.344(d)(2) and 9 VAC 5-80-110) 

V.B.3. Periodic Monitoring For Chromium and Particulate Emissions: The 

permittee shall monitor and record the pressure drop across the composite mesh 

pad type demister filter once each day that the small hard chromium electroplating 

process is operating. 

(40 CFR 63.343(c) and 9 VAC 5-80-110) 

V.C. Recordkeeping 

V.C.1. Compliance Records for the Chromium Electroplating MACT: The permittee 

shall maintain files of all information required by this condition recorded in a form 

suitable and readily available for expeditious inspection and review. The files shall 

be retained for at least 5 years following the date of each occurrence, measurement, 

maintenance, corrective action, report, or record. 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. The content and 

format of such records shall be arranged with the Director, Piedmont Region. These 

records shall include, but are not limited to: 

a. Inspection records for the add-on air pollution control device and monitoring 

equipment, to document that the inspection and maintenance required by the 

work practice standards have taken place. The record can take the form of a 

checklist and should identify the device inspected, the date of 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. 

b. Records of all maintenance performed on the small hard chromium electroplating 

process, the demister filter, and the differential pressure monitoring equipment. 

c. Records of the occurrence, duration, and cause (if known) of each malfunction of 

the small hard chromium electroplating process, the demister filter, and the 

differential pressure monitoring equipment. 

d. Records of actions taken during periods of malfunction when such actions are 

inconsistent with the operation and maintenance plan. 

e. Other records, which may take the form of checklists, necessary to demonstrate 

consistency with the provisions of the operation and maintenance plan. 

f. Test reports documenting results of all performance tests. 

g. All measurements as may be necessary to determine the conditions of 

performance tests. 
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h. Records of monitoring data required by Condition V.B.2 including the date and 

time the data are collected, with the required compliance value determined 

during performance testing. 

i. 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. 

j. 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. 

k. The total small hard chromium electroplating process operating time during the 

reporting period. 

l. Copies of the notifications and reports, and all supporting documentation, 

including, but not limited to, the following: 

i. Initial applicability notifications. 

ii. Notification of performance tests. 

iii. Initial notification of compliance status. 

iv. Ongoing compliance status reports. 

v. Reports of performance test results. 

vi. Notifications of construction or reconstruction, if applicable. 

(40 CFR 63.346, 63.347, and 63.10(b)(1), 9 VAC 5-50-50, and 9 VAC 5-80-110) 

V.C.2. Additional Compliance Records for the Chromium Electroplating MACT N: 

The permittee shall also maintain the following records necessary to demonstrate 

compliance with this permit. The content and format of such records shall be 

arranged with the Director, Piedmont Region: 

a. The written operation and maintenance plan, for the life of the small hard 

chromium electroplating process or until the process is no longer subject to the 

provisions of 40 CFR 63, Subpart N., and 

b. Previous (i.e., superseded) versions of the operation and maintenance plan, if 

the operation and maintenance plan is revised, for a period of 5 years after each 

revision to the plan. 

(40 CFR 63.342(f)(3), 9 VAC 5-50-50, and 9 VAC 5-80-110) 

V.C.3. Additional Compliance Records: In addition to the records required in 

Condition V.C.2 above, the permittee shall also maintain records of all emission data 

and operating parameters necessary to demonstrate compliance with the 

requirements of this permit and shall be consistent with DEQ policy. The content of 
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Permit Number: PRO-50880 

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and format of such records shall be arranged with the Director, Piedmont Region. 

These records shall also include, but are not limited to: 

a. Monthly records of ampere-hours used by the hard chromium-electroplating 

tanks. 

b. Monthly calculations of the controlled particulate emissions from the hard 

chromium-electroplating tanks, including any emission factors used in the 

calculation. 

c. Annual particulate emissions from the hard chromium-electroplating tanks, 

calculated monthly as the sum of emissions over the previous consecutive 12 

months. 

d. Records of the occurrence and duration of each startup and shutdown of the 

small hard chromium electroplating process and any periods during which the 

differential pressure monitoring equipment is inoperative. (Malfunction records 

are included with other records required Condition V.C.1) These records shall be 

available for inspection by the DEQ and shall be current for the most recent five 

years. 

(9 VAC 5-50-50 F, 9 VAC 5-60-50 C, and 9 VAC 5-80-110) 

V.D. Testing 

V.D.1. Performance Test Methods: If testing is conducted in addition to the monitoring 

specified in this permit, the permittee shall use the appropriate method(s) in 

accordance with procedures approved by the DEQ. 

 (9 VAC 5-80-110) 

V.D.2. The Site-Specific Test Plan: Before conducting a performance test on the hard 

chromium electroplating facility, the permittee shall develop and, upon request, 

submit a site-specific test plan to the Director, Piedmont Region for approval. If 

requested, the permittee shall submit the site-specific test plan to the Director, 

Piedmont Region at least 60 calendar days before the performance test is scheduled 

to take place, and simultaneously with the notification of intention to conduct a 

performance test, or on another mutually agreed upon date. 

(40 CFR 63.7(b) and 63.344(a), and 9 VAC 5-80-110) 

V.D.3. Conduct of Performance Tests: Performance tests shall be conducted under 

such conditions as the Director, Piedmont Region specifies to the owner or operator 

based on representative performance (i.e., performance based on normal operating 

conditions) of the affected source. Operations during periods of startup, shutdown, 

and malfunction shall not constitute representative conditions for the purpose of a 

performance test. Upon request, the owner or operator shall make available to the 

Administrator such records as may be necessary to determine the conditions of 

performance tests. 

(40 CFR 63.7(e), 9 VAC 5-60-30 C, and 9 VAC 5-80-110) 

V.D.4. Conduct of Performance Test Runs: Each performance test shall consist of 

three separate runs using the applicable test methods. The sampling time and 

sample volume for each run of Methods 306 and 306A (ref. 40 CFR 63, Appendix A) 
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shall be at least 120 minutes and 60 dscf, respectively. For the purposes of 

determining compliance with the relevant standard, the arithmetic mean of the results 

of the three runs shall apply. Upon receiving approval from the Director, Piedmont 

Region, results of a test run may be replaced with results of an additional test run in 

the event that: 

a. A sample is accidentally lost after the testing team leaves the site; or

b. Conditions occur in which one of the three runs must be discontinued because of 

forced shutdown; or 

c. Extreme meteorological conditions occur; or 

d. Other circumstances occur that are beyond the owner or operator's control. 

(40 CFR 63.7(e) and 63.344(c), and 9 VAC 5-80-110) 

V.D.5. Performance Test Requirements: If additional performance testing is 

conducted, the permittee shall: 

a. Determine the outlet total chromium concentration; 

b. Determine the particulate emission rate; 

c. Establish as a site-specific operating parameter, the overall pressure drop across 

the system, setting the new value that corresponds to compliance with the 

applicable emission limitation. The permittee may conduct multiple performance 

tests to establish a range of compliant pressure drop values, or may set as the 

compliant value the average pressure drop measured over the three test runs of 

one performance test and accept ± 2 inches of water column from this value as 

the compliant range; 

d. Install pressure taps at one of the following locations: 

i. At the inlet and outlet of the control system. The inlet tap should be installed 

in the ductwork just prior to the control device and the corresponding outlet 

pressure tap should be installed on the outlet side of the control device prior 

to the blower or on the downstream side of the blower, or 

ii. On the front side of the first mesh pad and back side of the last mesh pad 

within the control system; 

e. Site the pressure taps at locations that are: 

i. Free from pluggage as possible and away from any flow disturbances such 

as cyclonic demisters, and 

ii. Situated such that no air infiltration at measurement site will occur that could 

bias the measurement; 

f. Install pressure taps that are constructed of either polyethylene, polybutylene, or 

other nonreactive materials; 

g. Connect the pressure taps to the device that is used to measure pressure drop 

using nonreactive plastic tubing; 
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h. Use one of the following types of pressure gauges monitor pressure drop: a 

magnehelic gauge, an inclined manometer, or a "U'' tube manometer; and 

i. Zero each gauge prior to connecting any pressure lines to the pressure gauge(s). 

No calibration of the pressure gauges is required. 

j. Make a report of the performance test results in accordance with Condition 

V.E.2. 

(40 CFR 63.343(c) and (d), and 9 VAC 5-80-110) 

V.D.6. Performance Testing Facilities: If required to do performance testing, the 

permittee shall provide, in addition to those required in Condition V.D.1, any other 

performance testing facilities that the Director, Piedmont Region deems necessary 

for safe and adequate testing of a source. 

(40 CFR 63.7(d) and 9 VAC 5-80-110) 

V.E. Reporting 

V.E.1. Approved Reporting Methods: Reports and notifications required by Section V 

of this permit may be sent by U.S. mail, fax, or by another courier as follows: 

a. Submittals sent by U.S. mail shall be postmarked on or before the specified date. 

b. Submittals sent by other methods shall be received by the Director, Piedmont 

Region on or before the specified date. 

c. If acceptable to both the Director, Piedmont Region and the permittee, reports 

may be submitted on electronic media. 

 (40 CFR 63.347(f) and 9 VAC 5-80-110) 

V.E.2. Performance Test Report: The permittee shall report the results of the 

performance test to the Director, Piedmont Region before the close of business on 

the 60th day following the completion of the performance test and shall be submitted 

as part of the notification of compliance status. Performance test results shall be 

documented in complete test reports that contain the following information: 

a. A brief process description; 

b. Sampling location description(s); 

c. A description of sampling and analytical procedures and any modifications to 

standard procedures; 

d. Test results; 

e. Quality assurance procedures and results; 

f. Records of operating conditions during the test, preparation of standards, and 

calibration procedures; 

g. Raw data sheets for field sampling and field and laboratory analyses; 

h. Documentation of calculations; and 
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i. Any other information required by the test method. 

(40 CFR 63.344(a) and 63.347(f) and 9 VAC 5-80-110) 

V.E.3. Ongoing Compliance Status Reports: The permittee shall submit a summary 

report to the Director, Piedmont Region to document the ongoing compliance status 

of the small hard chromium electroplating process (P015 and P016). The report shall 

be submitted semiannually except when the Director, Piedmont Region determines 

that more frequent reporting is necessary to accurately assess the compliance status 

or the monitoring data collected by the permittee in accordance with Condition V.B.3 

shows (by exceeding the range of compliant differential pressure values) that the 

emission limit has been exceeded. Once an owner or operator of an affected source 

reports an exceedance, ongoing compliance status reports shall be submitted 

quarterly until a request to reduce reporting frequency is approved. The report shall 

contain the following information: 

a. The company name and address of the small hard chromium electroplating 

process (P015 and P016); 

b. An identification of the operating parameter that is monitored for compliance 

determination (differential pressure across the demister filter control device or 

composite mesh pad); 

c. The relevant emission limitation for the small hard chromium electroplating 

process, and the operating parameter value, or range of values, that correspond 

to compliance with this emission limitation, as reported in the initial compliance 

notification or subsequent performance test report; 

d. The beginning and ending dates of the reporting period; 

e. A description of the type of process performed in the small hard chromium 

electroplating tank; 

f. The total operating time of the affected source during the reporting period; 

g. 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; 

h. A certification by a responsible official (as defined in 9 VAC 5-80-80 G) that the 

work practice standards in Condition V.A.5 were followed in accordance with the 

operation and maintenance plan required by Condition V.A.6; 

i. If the operation and maintenance plan required by Condition V.A.6 was not 

followed, an explanation of the reasons for not following the provisions, an 

assessment of whether and excess emissions and /or parameter monitoring 

exceedances are believed to have occurred and a copy of the report(s) required 

by Condition V.A.5.a.i documenting that the operation and maintenance plan was 

not followed; 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 48 

j. A description of any changes in monitoring, processes or controls since the last 

reporting period; 

k. The name, title, and signature of the responsible official who is certifying the 

accuracy of the report; and 

l. The date of the report. 

(40 CFR 63.347(g)(1) and (3), and 9 VAC 5-80-110) 

V.E.4. Requests to Reduce the Frequency of Ongoing Compliance Status 

Reports: A permittee who is required to submit ongoing compliance status reports 

on a quarterly (or more frequent) basis, may reduce the frequency of reporting to 

semiannual if all of the following conditions are met: 

a. For 1 full year (e.g., 4 quarterly or 12 monthly reporting periods), the ongoing 

compliance status reports demonstrate that the small hard chromium 

electroplating process (P015 and P016) is in compliance with the relevant 

emission limit; 

b. The owner or operator continues to comply with all applicable recordkeeping and 

monitoring requirements of Section V of this permit; and 

c. The Director, Piedmont Region does not object to a reduced reporting frequency 

for the affected source. The frequency of submitting ongoing compliance status 

reports may be reduced only after the owner or operator notifies the Director, 

Piedmont Region in writing of his or her intention to make such a change, and 

the Administrator does not object to the intended change. Review of the request 

and notice of disapproval will be made in accordance with 9 VAC 5-60-100 40 

CFR 63.346(g)(2)(ii). In the absence of a notice of disapproval from the Director 

within 45 days, approval is automatically granted. 

As soon as the monitoring data required Condition V.B.3 shows that the source is 

not in compliance with the relevant emission limit, the frequency of reporting shall 

revert to quarterly, and the owner shall state this exceedance in the ongoing 

compliance status report for the next reporting period. After demonstrating ongoing 

compliance with the relevant emission limit for another full year, the owner or 

operator may again request approval from the Director, Piedmont Region to reduce 

the reporting frequency. 

(40 CFR 63.347(g)(2) and 9 VAC 5-80-110) 

V.E.5. Required Notifications: The permittee shall provide written notifications to the 

Director, Piedmont Region of the following:

a. At least 60 calendar days before the performance test is scheduled to begin, of 

the permittee’s intention to conduct a performance test, to allow the DEQ to 

review and approve the site specific test plan and to have an observer present 

during the test. Observation of the performance test by the DEQ is optional at 

the DEQ’s discretion. In the event that the permittee is unable to conduct the 

performance test on the date specified due to unforeseeable circumstances 

beyond his or her control, the permittee shall notify the Director, Piedmont 

Region within 5 days prior to the scheduled performance test date and specify 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 49 

the date when the performance test is rescheduled. This notification of delay in 

conducting the performance test shall not relieve the owner or operator of legal 

responsibility for compliance with any other applicable provisions of this permit or 

with any other applicable Federal, State, or local requirement. 

b. Within 15 calendar days after any change to the information already provided to 

the Director, Piedmont Region in notifications required under 40 CFR 63.9 

(notification of applicability, notification of construction/reconstruction, notification 

of physical or operational change, notifications of planned or actual dates of 

construction or startup, notifications of special compliance requirements, 

notification of planned dates of performance tests, notifications of visible 

emission evaluations, required notifications for continuous monitoring systems, 

and notifications of compliance status). 

(40 CFR 63.7(b), 63.9(j), 63.347(d) and (g)(2), and 9 VAC 5-80-110) 
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Permit Number: PRO-50880 

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VI. Waste Paper Handling Process Requirements (P017, P018, P019) 

VI.A. Limitations 

VI.A.1. Emission Controls - Particulate and PM10 emissions from the operation of the 

waste paper handling system shall be controlled by proper operation and 

maintenance of the waste paper handling system including the cyclone and 

baghouse units (P017, P018, and P019). The cyclones shall be provided with 

adequate access for inspection. An annual inspection shall be conducted on the 

cyclone for the purpose of identifying leaks, cracks, or other structural problems. 

The baghouses shall meet a control efficiency of 90%. 

(9 VAC 5-80-110 and Condition 6 of September 30, 2008 Permit) 

VI.A.2. Visible Emissions Limits - Visible emissions from the waste paper handling 

system shall not exceed 5 percent opacity as determined by EPA Method 9 

(reference 40 CFR 60, Appendix A). 

(9 VAC 5-80-110 and Condition 26 of September 30, 2008 Permit) 

VI.A.3. Emission Limits - Emissions vented outside of the building from the waste 

paper handling system shall not exceed the limits specified below. Annual emissions 

shall be calculated as the sum of each consecutive 12 month period: 

Total Suspended 0.01 grains/dscf 0.3 lb/hr 1.4 tons/yr 

Particulates 

PM10 0.01 grains/dscf 0.3 lb/hr 1.4 tons/yr 

(9 VAC 5-80-110 and Condition 22 of September 30, 2008 Permit) 

VI.A.4. Written Operating Procedures: The permittee shall have available written 

operating procedures for all air pollution control equipment associated with the waste 

paper handling systems (C005, C006, C007). Operators shall be trained in the 

proper operation of all such equipment and shall be familiar with the written operating 

procedures. These procedures shall be based on the manufacturer's 

recommendations, at minimum. The permittee shall maintain records of the required 

training including names of trainees, a statement of time, place and nature or training 

provided. 

(9 VAC 5-80-110) 

VI.B. Monitoring 

VI.B.1. Continuous Monitoring Device (CMD): The fabric filter baghouses (C005, 

C006, C007) shall be equipped with a device to continuously monitor the differential 

pressure drop across the fabric filter. The device shall be installed in an accessible 

location and shall be maintained by the permittee such that it is in proper working 

order at all times. 

(9 VAC 5-80-110 and Condition 37 of September 30, 2008 Permit) 
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Permit Number: PRO-50880 

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VI.B.2. Periodic Monitoring for Visible Emissions for Waste Paper Handling 

Exhaust (P017, P018, P019): If at anytime the waste paper handling system is 

vented outside the facility building, an inspection for visible emissions shall be 

conducted daily in accordance with Condition IV.D.1 until which time the exhaust 

from the waste paper handling system is vented indoors again. 

(9 VAC 5-80-110 E.3.) 

VI.B.3. Periodic Monitoring of Waste Paper Handling System (C005, C006, C007): 

The permittee shall monitor and record the pressure drop across the fabric filters at 

least once per week that the waste paper handling system is operating. 

(9 VAC 5-80-110 E.3.) 

VI.C. Recordkeeping 

VI.C.1. Compliance Records: The permittee shall maintain records of all emission data 

and operating parameters necessary to demonstrate compliance with this permit. 

The content and format of such records shall be arranged with the Director, 

Piedmont Region. These records shall include, but are not limited to: 

a. The number of hours of operation that the waste paper handling system is vented 

to outside of the building; 

b. Annual particulate emissions from the waste paper handling system venting 

outside the building, calculated monthly as the sum of emissions for the previous 

consecutive 12 months; 

c. Annual inspection records of the cyclones at the waste paper handling system; 

and 

d. Differential pressure drop across fabric filters (C005, C006, C007); and 

e. Any and all visible emission observations and evaluations. 

These records shall be available for inspection by the DEQ and shall be current for 

the most recent five years. 

(9 VAC 5-80-110 and Condition 41 of September 30, 2008 Permit) 

VI.D. Testing 

VI.D.1. Visible Emissions Evaluation: Inspection for the presence of visible emissions 

from the waste paper handling system shall be conducted each time the system 

malfunctions and is vented outside of the building. If during the inspection, visible 

emissions are observed, timely corrective action shall be initiated within four hours of 

the inspection such that the waste paper handling system resumes operation and 

there are no visible emissions within 24 hours of the initial observation. If timely 

corrective action cannon be taken within the timeframe specified above, an EPA 

Method 9 (40 CFR Part 60, appendix A) visible emissions evaluation (VEE) shall be 

conducted on each source of visible emissions. Each VEE shall be conducted for a 

minimum period of six minutes. 

(9 VAC 5-80-110 and Condition 39 of September 30, 2008 Permit) 
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Permit Number: PRO-50880 

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VI.D.2. Performance Test Methods: If testing is conducted in addition to the monitoring 

specified in this permit, the permittee shall use the appropriate method(s) in 

accordance with procedures approved by the DEQ. 

(9 VAC 5-80-110)

VI.D.3. Conduct of Performance Tests: Performance tests that are conducted in 

accordance with methods specified in Condition VI.D in addition to the monitoring 

specified in Section VI.B of this permit shall be conducted in accordance with Section 

VI.B of this permit. 

(9 VAC 5-50-30 C and 9 VAC 5-80-110) 

VI.E. Reporting 

VI.E.1. Required Notifications: The permittee shall provide written notifications to the 

Director, Piedmont Region at least 30 days prior to any performance test used to 

demonstrate compliance with a standard under Section VI.A of this permit. The 

permittee shall submit a test protocol with the notification, at least 30 days prior to 

testing. 

(9 VAC 5-50-30 B and A.4 and 9 VAC 5-80-110) 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

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VII. Facility Wide Conditions 

VII.A. Limitations 

VII.A.1. Applicable New or Revised MACT Standards: An owner or operator of an 

affected source who is subject to an emission standard promulgated under 40 CFR 

63 shall comply with the requirements of that standard by the date established in the 

applicable 40 CFR 63 subpart regardless of whether this permit has been revised or 

modified to incorporate the emission standard. 

(40 CFR 63.4(a)(5) and 9 VAC 5-80-110) 

VII.A.2. Visible Emission Standard: Unless specified otherwise in this permit, visible 

emissions from any affected facility shall not exceed 20 percent opacity, except 

during one six-minute period in any one hour in which visible emissions shall not 

exceed 30 percent opacity. 

(9 VAC 5-50-80 and 9 VAC 5-80-110) 

VII.A.3. VOC Emission Standards: At all times, the disposal of VOC shall be 

accomplished, to the extent practicable, consistent with air pollution control practices 

for minimizing emissions. VOC shall not be intentionally spilled, discarded into 

sewers which are not connected to a treatment plant or stored in open containers or 

handled in any other manner that would result in evaporation beyond that consistent 

with air pollution control practices for minimizing emissions. 

(9 VAC 5-50-20 F. and 9 VAC 5-80-110) 

VII.A.4. Facility Wide Emission Limits: Emissions from the operation of the facility 

shall not exceed the limits specified below: 

Total Suspended 

Particulate 2.1 lbs/hr 3.6 tons/yr (9 VAC 5-50-260) 

PM10 1.2 lbs/hr 3.3 tons/yr (9 VAC 5-50-260) 

Sulfur Dioxide 64.7 lbs/hr 24.3 tons/yr (9 VAC 5-50-260) 

Nitrogen Oxides 

(as NO2) 18.2 lbs/hr 27.3 tons/yr (9 VAC 5-50-260) 

Carbon Monoxide 8.1 lbs/hr 18.9 tons/yr (9 VAC 5-50-260) 

Volatile Organic 

Compounds 531.5 lbs/hr 1462.9 tons/yr (9 VAC 5-50-260) 

Toluene 458.5 lbs/hr 1259.9 tons/yr (9 VAC 5-50-260) 

Xylene 24.7 lbs/hr 67.7 tons/yr (9 VAC 5-50-260) 

Hexane 4.8 lbs/hr 13.1 tons/yr (9 VAC 5-50-260) 

Ethylbenzene 9.6 lbs/hr 26.2 tons/yr (9 VAC 5-50-260) 

(9 VAC 5-80-110 and Condition 23 of September 30, 2008 Permit) 

VII.A.5. Minimizing Emissions: At all times, including startup, shutdown, soot 

blowing, and malfunction, the permittee shall, to the extent practicable, maintain and 

operate any affected facility including associated control equipment in a manner 

consistent with air pollution control practices for minimizing emissions. 

(9 VAC 5-50-20 E and 9 VAC 5-80-110) 
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Permit Number: PRO-50880 

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VII.A.6. Maintenance/Operating Procedures - The permittee shall take the following 

measures in order to minimize the duration and frequency of excess emissions, with 

respect to air pollution control equipment, monitoring devices, and process 

equipment which affect such emissions: 

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance. 

b. Maintain an inventory of spare parts. 

c. Have available written operating procedures for equipment. These procedures 

shall be based on the manufacturer's recommendations, at a minimum. 

d. Train operators in the proper operation of all such equipment and familiarize the 

operators with the written operating procedures. The permittee shall maintain 

records of the training provided including the names of trainees, the date of 

training and the nature of the training. 

(9 VAC 5-80-110 and Condition 49 of the permit dated September 30, 2008) 

VII.A.7. Circumvention: No owner or other person shall: 

a. Cause or permit the installation of any device or any means which, without 

resulting in reduction of the total amount of air pollutants emitted, conceals or 

dilutes an air emission of air pollutants which would otherwise violate the state or 

federal regulations or this permit Such concealment includes, but is not limited 

to, any of the following: 

i. The use of gaseous diluents to achieve compliance with a standard which is 

based upon the concentration of a pollutant in the gases discharged to the 

atmosphere. 

ii. The use of gaseous diluents to achieve compliance with a visible emission 

standard. 

iii. The piecemeal carrying out of an operation to avoid coverage by a standard 

that applies only to operations larger than a specified size. 

b. Cause or allow a pattern of ownership or development over a geographic area of 

a source which, except for a pattern of ownership or development would 

otherwise require a permit. 

(9 VAC 5-20-70 A, 40 CFR 60.12, 40 CFR 63.5(b), 9 VAC 5-80-10 P, 9 VAC 5-80-

1790, 9 VAC 5-80-2100 and 9 VAC 5-80-110) 

VII.A.8. Violation of Ambient Air Quality Standard: The permittee shall, upon 

request of the DEQ, reduce the level of operation or shut down a facility, as 

necessary to avoid violating any primary ambient air quality standard and shall not 

return to normal operation until such time as the ambient air quality standard will not 

be violated. 

(9 VAC 5-20-180 I) 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

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VII.B. Monitoring 

VII.B.1. Continuous Monitoring Systems and Measuring Devices - All continuous 

monitoring systems and measuring devices shall be installed and operational prior to 

conducting initial performance tests. Performance evaluations of the continuous 

monitoring system must take place during the performance tests under 9 VAC 5-50-

30 of the Regulations or within 30 days thereafter. Two copies of the performance 

evaluation report shall be submitted to the Director, Piedmont Regional Office within 

45 days of said evaluation. Verification of operational status shall, as a minimum, 

include completion of the manufacturer's written requirements or recommendations 

for installation, operation and calibration of the device. 

(9 VAC 5-50-40 B and C, 9 VAC 5-80-110, and Condition 38 of September 30, 2008 

permit) 

VII.B.2. Continuous Monitoring System Requirements: All continuous monitoring 

systems required by this permit shall be installed, calibrated, maintained, and 

operated in accordance with the manufacturer’s written requirements or 

recommendations for installation, operation and calibration of the system or device. 

(9 VAC 5-50-40 D and 9 VAC 5-80-110) 

VII.C. Recordkeeping 

VII.C.1. Required Compliance Records: The permittee shall maintain records of all 

emission data and operating parameters necessary to demonstrate compliance with 

this permit. The content and format of such records shall be arranged with the 

Director, Piedmont Region. These records shall include, but are not limited to: 

a. All documentation used to support emission calculations; 

b. All visible emission observations and evaluations; 

c. Records of occurrence and duration of each start up, shutdown, and malfunction 

operations; 

d. Maintenance schedules and records of completed maintenance; and 

e. Operator training records. 

(9 VAC 5-50-50, 9 VAC 5-80-110 and Condition 41 of September 30, 2008 Permit) 

VII.C.2. Keeping Records: Unless otherwise specified in this permit, records 

required by the terms of this permit shall be kept: 

a. On-site, readily accessible and available for inspection by the DEQ; 

b. As either paper or electronic records in a permanent form suitable for inspection; 

and 

c. For the at least two years following the date of such measurements, 

maintenance, reports and records. 

(9 VAC 5-50-50 D, 9 VAC 5-80-110 and Condition 41 of September 30, 2008 Permit) 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 56 

VII.D. Testing 

VII.D.1. Testing/Monitoring Ports: The permitted facility shall be constructed so as 

to allow for emissions testing at any time using appropriate methods. Upon request 

from the Department, test ports shall be provided at the appropriate locations. 

(9 VAC 5-50-30 F, 9 VAC 5-80-110, and Condition 31 of September 30, 2008 Permit) 

VII.D.2. Performance Testing Notification - The permittee shall furnish written 

notification to the Director, Piedmont Regional Office of the anticipated dates of 

performance tests of the printing facility and testing protocols postmarked at least 30 

days prior to such dates. 

(9 VAC 5-50-50) 

VII.D.3. Performance Test Methods: If testing is conducted in addition to the 

monitoring specified in this permit, the permittee shall use the appropriate method(s) 

in accordance with procedures approved by the DEQ. 

 (9 VAC 5-80-110) 

VII.D.4. Conduct of Performance Test Runs: Unless otherwise specified in this 

permit, each performance test shall consist of three separate runs using the 

applicable test methods. Each run shall be conducted for the time and under the 

conditions specified in the applicable standard or method. For the purposes of 

determining compliance with the relevant standard, the arithmetic mean of the results 

of the three runs shall apply. In the event that a sample is accidentally lost or 

conditions occur in which one of the three runs must be discontinued because of 

forced shutdown, failure of an irreplaceable portion of the sample train, extreme 

meteorological conditions or other circumstances beyond the permittee’s control, 

compliance may, upon approval from the Director, Piedmont Region, be determined 

using the arithmetic mean of the two other runs. 

(9 VAC 5-50-30 E and 9 VAC 5-80-110) 

VII.D.5. Performance Test Guidelines: Performance tests shall be subject to testing 

guidelines approved by the Director, Piedmont Region. Procedures may be adjusted 

or changed by the DEQ to suit specific sampling conditions based upon good 

practice, judgement and experience. When such tests are adjusted, consideration 

shall be given to the effect of such a change on the established emission standards. 

Tests shall be performed under the direction of persons whose qualifications are 

acceptable to the Director, Piedmont Region. 

(9 VAC 5-50-30 B and 9 VAC 5-80-110) 

VII.D.6. Conduct of Performance Tests: Unless otherwise specified in this permit, 

performance tests shall be conducted under such conditions as the Director, 

Piedmont Region shall specify to the permittee based on representative performance 

of the affected source. The permittee shall make available to the Director such 

records as may be necessary to determine the conditions of performance tests. 

Unless otherwise specified in this permit, operation during periods of startup, 

shutdown and malfunction shall not constitute representative conditions for the 

purpose of a performance test. 

(9 VAC 5-50-30 C and 9 VAC 5-80-110) 
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Permit Number: PRO-50880 

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VII.D.7. Performance Testing Facilities: The DEQ may test emissions of air 

pollutants from any source of air pollutants. Upon request of the Director, Piedmont 

Region, the permittee shall provide performance testing facilities as follows: 

a. Sampling ports adequate for test methods applicable to such source. 

b. Safe sampling platforms; 

c. Safe access to sampling platforms; 

d. Utilities for sampling and testing equipment; and 

(9 VAC 5-50-30 F and 9 VAC 5-80-110) 

VII.E. Reporting 

VII.E.1. Required Notifications: Unless otherwise specified in this permit, the 

permittee shall provide written notifications to the Director, Piedmont Region of the 

following:

a. The date of commencement of construction, reconstruction or modification of a 

new or modified source postmarked no later than 30 days after such date. 

b. The anticipated date of initial startup of a new or modified source postmarked no 

later than 30 days prior to such date. 

c. The actual date of initial startup of a new or modified source postmarked no later 

than 15 days after such date. 

d. The date of any performance tests the owner wishes DEQ to consider in 

determining compliance with a standard. Notification shall be postmarked not 

less than 30 days prior to such date. 

e. The date upon which demonstration of a continuous monitoring system 

performance begins. Notification shall be postmarked not less than 30 days prior 

to such date. 

(9 VAC 5-50-50 A and 9 VAC 5-80-110) 

VII.E.2. Notification for Control Equipment Maintenance - The permittee shall 

furnish notification to the Director, Piedmont Region of the intention to shut down or 

bypass, or both, air pollution control equipment for necessary scheduled 

maintenance, which results in excess emissions for more than one hour, at least 24 

hours prior to the shutdown. The notification shall include, but is not limited to, the 

following information: 

a. Identification of the air pollution control equipment to be taken out of service, as 

well as its location, and registration number; 

b. The expected length of time that the air pollution control equipment will be out of 

service; 

c. The nature and quantity of emissions of air pollutants likely to occur during the 

shutdown period; 

d. Measures that will be taken to minimize the length of the shutdown or to negate 

the effect of the outage. 

(9 VAC 5-80-110 and Condition 46 of September 30, 2008 Permit) 
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Permit Number: PRO-50880 

Page 58 

VIII. Insignificant Emission Units 

The following emission units at the facility are identified in the application as insignificant 

emission units under 9 VAC 5-80-720: 

Emission 

 Unit No. 

Emission Unit 

Description 

Citation Pollutant 

Emitted 

(5-80-720 B) 

Rated 

Capacity 

(5-80-720 C) 

T022 Petroleum Storage Tank 

(No. 2 Fuel Oil) 

5-80-720 B.2 & 5 VOC 24,990 

gallons 

CM001 Chemical Dechrome Tank 5-80-720 B.5 None NA 

CM002 Mechanical Dechrome Tank 5-80-720 B.5 None NA 

CM003 Degreasing Tank (non-VOC 

process) 

5-80-720 B.5 None NA 

CM004 Copper Plating Tank 5-80-720 B.5 None NA 

CM005 Polishing Tank 5-80-720 B.5 None NA 

CM006 Electro-mechanical Engraving 

Tank (closed loop) 

5-80-720 B.5 None NA 

CM007 Copper Plating Tank 5-80-720 B.5 None NA 

CM008 Emergency diesel-powered 

generator 

5-80-720 C.4.b NOx, CO, 

SO2, PM-10 

300 hp 

CM009 Backup diesel fire pump 5-80-720 A.27 NOx, CO, 

SO2, PM-10 

175 hp 

These emission units are presumed to be in compliance with all requirements of the 

federal Clean Air Act as may apply. Based on this presumption, no monitoring, 

recordkeeping, or reporting shall be required for these emission units in accordance with 

9 VAC 5-80-110. 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

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IX. Permit Shield 

Compliance with the provisions of this permit shall be deemed compliance with all 

applicable requirements in effect as of the permit issuance date as identified in this 

permit. This permit shield covers only those applicable requirements covered by terms 

and conditions in this permit and the following requirements which have been specifically 

identified as being not applicable to this permitted facility: 

Citation Title of Citation Description of Applicability 

none 

 

Nothing in this permit shield shall alter the provisions of §303 of the federal Clean Air 

Act, including the authority of the administrator under that section, the liability of the 

owner for any violation of applicable requirements prior to or at the time of permit 

issuance, or the ability to obtain information by the administrator pursuant to §114 of the 

federal Clean Air Act, (ii) the Board pursuant to §10.1-1314 or §10.1-1315 of the Virginia 

Air Pollution Control Law or (iii) the Department pursuant to §10.1-1307.3 of the Virginia 

Air Pollution Control Law. 

(9 VAC 5-80-140) 
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X. General Conditions 

X.A. Federal Enforceability 

All terms and conditions in this permit are enforceable by the administrator and citizens 

under the federal Clean Air Act, except those that have been designated as only stateenforceable. 

(9 VAC 5-80-110 N) 

X.B. Permit Expiration 

This permit has a fixed term of five years. The expiration date shall be the date five 

years from the date of issuance. Unless the owner submits a timely and complete 

application for renewal to the Department consistent with the requirements of 9 VAC 5-

80-80, the right of the facility to operate shall be terminated upon permit expiration. 

X.B.1. The owner shall submit an application for renewal at least six months but no 

earlier than eighteen months prior to the date of permit expiration. 

If an applicant submits a timely and complete application for an initial permit or 

renewal under this section, the failure of the source to have a permit or the operation 

of the source without a permit shall not be a violation of Article 1, Part II of 9 VAC 5 

Chapter 80, until the Board takes final action on the application under 9 VAC 5-80-

150. 

X.B.2. No source shall operate after the time that it is required to submit a timely and 

complete application under subsections C and D of 9 VAC 5-80-80 for a renewal 

permit, except in compliance with a permit issued under Article 1, Part II of 9 VAC 5 

Chapter 80. 

X.B.3. If an applicant submits a timely and complete application under section 9 VAC 5-

80-80 for a permit renewal but the Board fails to issue or deny the renewal permit 

before the end of the term of the previous permit, (i) the previous permit shall not 

expire until the renewal permit has been issued or denied and (ii) all the terms and 

conditions of the previous permit, including any permit shield granted pursuant to 9 

VAC 5-80-140, shall remain in effect from the date the application is determined to 

be complete until the renewal permit is issued or denied. 

X.B.4. The protection under subsections F 1 and F 5 (ii) of section 9 VAC 5-80-80 F 

shall cease to apply if, subsequent to the completeness determination made 

pursuant section 9 VAC 5-80-80 D, the applicant fails to submit by the deadline 

specified in writing by the Board any additional information identified as being 

needed to process the application. 

(9 VAC 5-80-80 B, C and F, 9 VAC 5-80-110 D, and 9 VAC 5-80-170 B) 

X.C. Recordkeeping and Reporting 

X.C.1. All records of monitoring information maintained to demonstrate compliance with 

the terms and conditions of this permit shall contain, where applicable, the following: 

a. The date, place as defined in the permit, and time of sampling or measurements. 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 61 

b. The date(s) analyses were performed. 

c. The company or entity that performed the analyses. 

d. The analytical techniques or methods used. 

e. The results of such analyses. 

f. The operating conditions existing at the time of sampling or measurement. 

(9 VAC 5-80-110 F) 

X.C.2. Records of all monitoring data and support information shall be retained for at 

least five years from the date of the monitoring sample, 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. 

(9 VAC 5-80-110 F) 

X.C.3. The permittee shall submit the results of monitoring contained in any applicable 

requirement to DEQ no later than March 1 and September 1 of each calendar year. 

This report must be signed by a responsible official, consistent with 9 VAC 5-80-80 

G, and shall include: 

a. The time period included in the report. The time periods to be addressed are 

January 1 to June 30 and July 1 to December 31. 

b. All deviations from permit requirements. For purposes of this permit, deviations 

include, but are not limited to: 

i. Exceedance of emissions limitations or operational restrictions; 

ii. Excursions from control device operating parameter requirements, as 

documented by continuous emission monitoring, periodic monitoring, or 

compliance assurance monitoring which indicates an exceedance of emission 

limitations or operational restrictions; or, 

iii. Failure to meet monitoring, recordkeeping, or reporting requirements 

contained in this permit. 

c. If there were no deviations from permit conditions during the time period, the 

permittee shall include a statement in the report that “no deviations from permit 

requirements occurred during this semi-annual reporting period.” 

(9 VAC 5-80-110 F) 

X.D. Annual Compliance Certification 

Exclusive of any reporting required to assure compliance with the terms and conditions 

of this permit or as part of a schedule of compliance contained in this permit, the 

permittee shall submit to EPA and DEQ no later than March 1 each calendar year a 

certification of compliance with all terms and conditions of this permit including emission 

limitation standards or work practices. The compliance certification shall comply with 

such additional requirements that may be specified pursuant to §114(a)(3) and §504(b) 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 62 

of the federal Clean Air Act. This certification shall be signed by a responsible official, 

consistent with 9 VAC 5-80-80 G, and shall include: 

a. The time period included in the certification. The time period to be addressed is 

January 1 to December 31. 

b. The identification of each term or condition of the permit that is the basis of the 

certification. 

c. The compliance status. 

d. Whether compliance was continuous or intermittent, and if not continuous, 

documentation of each incident of non-compliance. 

e. Consistent with subsection 9 VAC 5-80-110 E, the method or methods used for 

determining the compliance status of the source at the time of certification and 

over the reporting period. 

f. Such other facts as the permit may require to determine the compliance status of 

the source. 

g. One copy of the annual compliance certification shall be sent to EPA at the 

following address: 

Clean Air Act Title V Compliance Certification (3AP00) 

U. S. Environmental Protection Agency, Region III 

1650 Arch Street 

Philadelphia, PA 19103-2029. 

(9 VAC 5-80-110 K.5) 

X.E. Permit Deviation Reporting 

The permittee shall notify the Director, Piedmont Region within four daytime business 

hours after discovery of any deviations from permit requirements which may cause 

excess emissions for more than one hour, including those attributable to upset 

conditions as may be defined in this permit. In addition, within 14 days of the discovery, 

the permittee shall provide a written statement explaining the problem, any corrective 

actions or preventative measures taken, and the estimated duration of the permit 

deviation. The occurrence should also be reported in the next semi-annual compliance 

monitoring report pursuant to General Condition X.C.3 of this permit. 

(9 VAC 5-80-110 F.2 and 9 VAC 5-80-250) 

X.F. Failure/Malfunction Reporting 

In the event that any affected facility or related air pollution control equipment fails or 

malfunctions in such a manner that may cause excess emissions for more than one 

hour, the owner shall, as soon as practicable but no later than four daytime business 

hours, notify the Director, Piedmont Region by facsimile transmission, telephone or 

telegraph of such failure or malfunction and shall within fourteen (14) days of discovery 

provide a written statement giving all pertinent facts, including the estimated duration of 

the breakdown. When the condition causing the failure or malfunction has been 

corrected and the equipment is again in operation, the owner shall notify the Director, 

Piedmont Region. 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 63 

a. Each owner required to install a continuous monitoring system subject to 9 VAC 

5-40-41 or 9 VAC 5-50-410 shall submit a written report of excess emissions (as 

defined in the applicable emission standard) to the board for every calendar 

quarter. All quarterly reports shall be postmarked by the 30th day following the 

end of each calendar quarter and shall include the following information: 

i. The magnitude of excess emissions computed in accordance with 40 CFR 

60.13(h) or 9 VAC 5-40-41 B 6, any conversion factors used, and the date 

and time of commencement and completion of each period of excess 

emissions; 

ii. Specific identification of each period of excess emissions that occurs during 

startups, shutdowns, and malfunctions of the source. The nature and cause of 

any malfunction (if known), the corrective action taken or preventative measures 

adopted; 

iii. The date and time identifying each period during which the continuous 

monitoring system was inoperative except for zero and span checks and the 

nature of the system repairs or adjustments; and

iv. When no excess emissions have occurred or the continuous monitoring 

systems have not been inoperative, repaired or adjusted, such information shall 

be stated in the report.

b. All emission units not subject to 9 VAC 5-40-50 C and 9 VAC 5-50-50 C must 

make written reports within 14 days of the malfunction occurrence. 

(9 VAC 5-20-180 C and 9 VAC 5-50-50) 

X.G. Severability 

The terms of this permit are severable. If any condition, requirement or portion of the 

permit is held invalid or inapplicable under any circumstance, such invalidity or 

inapplicability shall not affect or impair the remaining conditions, requirements, or 

portions of the permit. 

(9 VAC 5-80-110 G.1) 

X.H. Duty to Comply 

The permittee shall comply with all terms and conditions of this permit. Any permit 

noncompliance constitutes a violation of the federal Clean Air Act or the Virginia Air 

Pollution Control Law or both and is grounds for enforcement action; for permit 

termination, revocation and reissuance, or modification; or, for denial of a permit renewal 

application. 

(9 VAC 5-80-110 G.2) 

X.I. Need to Halt or Reduce Activity not a Defense 

It shall not be a defense for a permittee in an enforcement action that it would have been 

necessary to halt or reduce the permitted activity in order to maintain compliance with 

the conditions of this permit. 

(9 VAC 5-80-110 G.3) 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 64 

X.J. Permit Modification 

A physical change in, or change in the method of operation of, this stationary source 

may be subject to permitting under State Regulations 9 VAC 5-80-50, 9 VAC 5-80-1100, 

9 VAC 5-80-1790, or 9 VAC 5-80-2000 and may require a permit modification and/or 

revisions except as may be authorized in any approved alternative operating scenarios. 

(9 VAC 5-80-190 and 9 VAC 5-80-260) 

X.K. Property Rights 

The permit does not convey any property rights of any sort, or any exclusive privilege. 

(9 VAC 5-80-110 G.5) 

X.L. Duty to Submit Information 

X.L.1. The permittee shall furnish to the Board, within a reasonable time, any 

information that the Board 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 

Board copies of records required to be kept by the permit and, for information 

claimed to be confidential, the permittee shall furnish such records to the Board 

along with a claim of confidentiality. 

(9 VAC 5-80-110 G.6) 

X.L.2. Any document (including reports) required in a permit condition to be submitted 

to the Board shall contain a certification by a responsible official that meets the 

requirements of 9 VAC 5-80-80 G. 

(9 VAC 5-80-110 K.1) 

X.M. Duty to Pay Permit Fees 

The owner of any source for which a permit under 9 VAC 5-80-50 through 9 VAC 5-80-

300 was issued shall pay permit fees consistent with the requirements of 9 VAC 5-80-

310 through 9 VAC 5-80-350. The actual emissions covered by the permit program fees 

for the proceeding year shall be calculated by the owner and submitted to the 

Department by April 15 of each year. The calculations and final amount of emissions 

are subject to verification and final determination by the Department. 

(9 VAC 5-80-110 H and 9 VAC 5-80-340 C) 

X.N. Fugitive Dust Emission Standards 

During the operation of a stationary source or any other building, structure, facility, or 

installation, no owner or other person shall cause or permit any materials or property to 

be handled, transported, stored, used, constructed, altered, repaired, or demolished 

without taking reasonable precautions to prevent particulate matter from becoming 

airborne. Such reasonable precautions may include, but are not limited to, the following: 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 65 

X.N.1. Use, where possible, of water or chemicals for control of dust in the demolition of 

existing buildings or structures, construction operations, the grading of roads, or the 

clearing of land; 

X.N.2. Application of asphalt, water, or suitable chemicals on dirt roads, materials 

stockpiles, and other surfaces which may create airborne dust; the paving of 

roadways and the maintaining of them in a clean condition; 

X.N.3. Installation and use of hoods, fans, and fabric filters to enclose and vent the 

handling of dusty material. Adequate containment methods shall be employed 

during sandblasting or other similar operations; 

X.N.4. Open equipment for conveying or transporting material likely to create 

objectionable air pollution when airborne shall be covered or treated in an equally 

effective manner at all times when in motion; and, 

X.N.5. The prompt removal of spilled or tracked dirt or other materials from paved 

streets and of dried sediments resulting from soil erosion. 

(9 VAC 5-50-90) 

X.O. Startup, Shutdown, and Malfunction 

At all times, including periods of startup, shutdown, soot blowing, and malfunction, 

owners shall, to the extent practicable, maintain and operate any affected facility 

including associated air pollution control equipment in a manner consistent with air 

pollution control practices for minimizing emissions. Determination of whether 

acceptable operating and maintenance procedures are being used will be based on 

information available to the Board, which may include, but is not limited to, monitoring 

results, opacity observations, review of operating and maintenance procedures, and 

inspection of the source. 

(9 VAC 5-50-20 E) 

X.P. Alternative Operating Scenarios 

Contemporaneously with making a change between reasonably anticipated operating 

scenarios identified in this permit, the permittee shall record in a log at the permitted 

facility a record of the scenario under which it is operating. The permit shield described 

in 9 VAC 5-80-140 shall extend to all terms and conditions under each such operating 

scenario. The terms and conditions of each such alternative scenario shall meet all 

applicable requirements including the requirements of 9 VAC 5 Chapter 80, Article 1. 

(9 VAC 5-80-110 J) 

X.Q. Inspection and Entry Requirements 

The permittee shall allow DEQ, upon presentation of credentials and other documents 

as may be required by law, to perform the following: 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 66 

X.Q.1. Enter upon the premises where the source is located or emissions-related activity 

is conducted, or where records must be kept under the terms and conditions of the 

permit. 

X.Q.2. Have access to and copy, at reasonable times, any records that must be kept 

under the terms and conditions of the permit. 

X.Q.3. Inspect at reasonable times any facilities, equipment (including monitoring and 

air pollution control equipment), practices, or operations regulated or required under 

the permit. 

X.Q.4. Sample or monitor at reasonable times substances or parameters for the 

purpose of assuring compliance with the permit or applicable requirements. 

(9 VAC 5-80-110 K.2) 

X.R. Reopening For Cause 

The permit shall be reopened by the Board if additional federal requirements become 

applicable to a major source with a remaining permit term of three years or more. Such 

reopening shall be completed no 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 the permit is due to expire, unless the 

original permit or any of its terms and conditions has been extended pursuant to 9 VAC 

5-80-80 F. 

X.R.1. The permit shall be reopened if the Board 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. 

X.R.2. The permit shall be reopened if the administrator or the Board determines that 

the permit must be revised or revoked to assure compliance with the applicable 

requirements. 

X.R.3. The permit shall not be reopened by the Board if additional applicable state 

requirements become applicable to a major source prior to the expiration date 

established under 9 VAC 5-80-110 D. 

(9 VAC 5-80-110 L) 

X.S. Permit Availability 

Within five days after receipt of the issued permit, the permittee shall maintain the permit 

on the premises for which the permit has been issued and shall make the permit 

immediately available to DEQ upon request. 

(9 VAC 5-80-150 E) 

X.T. Transfer of Permits 

X.T.1. No person shall transfer a permit from one location to another, unless authorized 

under 9 VAC 5-80-130, or from one piece of equipment to another. 

(9 VAC 5-80-160) 

X.T.2. In the case of a transfer of ownership of a stationary source, the new owner shall 

comply with any current permit issued to the previous owner. The new owner shall 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 67 

notify the Board of the change in ownership within 30 days of the transfer and shall 

comply with the requirements of 9 VAC 5-80-200. 

(9 VAC 5-80-160) 

X.T.3. In the case of a name change of a stationary source, the owner shall comply with 

any current permit issued under the previous source name. The owner shall notify 

the Board of the change in source name within 30 days of the name change and 

shall comply with the requirements of 9 VAC 5-80-200. 

(9 VAC 5-80-160) 

X.U. Malfunction as an Affirmative Defense 

X.U.1. A malfunction constitutes an affirmative defense to an action brought for 

noncompliance with technology-based emission limitations if the requirements of 

paragraph 2 of this condition are met. 

X.U.2. The affirmative defense of malfunction shall be demonstrated by the permittee 

through properly signed, contemporaneous operating logs, or other relevant 

evidence that show the following: 

X.U.3. A malfunction occurred and the permittee can identify the cause or causes of the 

malfunction. 

X.U.4. The permitted facility was at the time being properly operated. 

X.U.5. During the period of the malfunction the permittee took all reasonable steps to 

minimize levels of emissions that exceeded the emission standards, or other 

requirements in the permit. 

X.U.6. The permittee notified the board of the malfunction within two working days 

following the time when the emission limitations were exceeded due to the 

malfunction. This notification shall include a description of the malfunction, any steps 

taken to mitigate emissions, and corrective actions taken. The notification may be 

delivered either orally or in writing. The notification may be delivered by electronic 

mail, facsimile transmission, telephone, or any other method that allows the 

permittee to comply with the deadline. This notification fulfills the requirements of 9 

VAC 5-80-110 F 2 b to report promptly deviations from permit requirements. This 

notification does not release the permittee from the malfunction reporting 

requirement under 9 VAC 5-20-180 C. 

X.U.7. In any enforcement proceeding, the permittee seeking to establish the 

occurrence of a malfunction shall have the burden of proof. 

X.U.8. The provisions of this section are in addition to any malfunction, emergency or 

upset provision contained in any applicable requirement. 

(9 VAC 5-80-250) 

X.V. Permit Revocation or Termination for Cause 

In addition the permit may be revoked or terminated prior to its expiration date if the 

owner knowingly makes material misstatements in the permit application or any 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 68 

amendments thereto or if the permittee violates, fails, neglects or refuses to comply with 

the terms or conditions of the permit, any applicable requirements, or the applicable 

provisions of 9 VAC 5 Chapter 80 Article 1. The Board may suspend, under such 

conditions and for such period of time as the Board may prescribe, any permit for any of 

the grounds for revocation or termination or for any other violations of these regulations. 

(9 VAC 5-80-190 C and VAC 5-80-260) 

X.W. Duty to Supplement or Correct Application 

Any applicant who fails to submit any relevant facts or who has submitted incorrect 

information in a permit application shall, upon becoming aware of such failure or 

incorrect submittal, promptly submit such supplementary facts or corrections. An 

applicant shall also provide additional information as necessary to address any 

requirements that become applicable to the source after the date a complete application 

was filed but prior to release of a draft permit. 

(9 VAC 5-80-80 E) 

X.X. Stratospheric Ozone Protection

If the permittee handles or emits one or more Class I or II substances subject to a 

standard promulgated under or established by Title VI (Stratospheric Ozone Protection) 

of the federal Clean Air Act, the permittee shall comply with all applicable sections of 40 

CFR Part 82, Subparts A to F. 

(40 CFR Part 82, Subparts A-F) 

X.Y. Asbestos Demolition and Renovation Requirements 

The permittee shall comply with the requirements of National Emissions Standards for 

Hazardous Air Pollutants (40 CFR 61) Subpart M, National Emission Standards for 

Asbestos as it applies to demolition and renovation, (40 CFR 61.146) 

(9 VAC 5-60-70 and 9 VAC 5-80-110 A.1) 

X.Z. Accidental Release Prevention 

If the permittee has more, or will have more than a threshold quantity of a regulated 

substance in a process, as determined by 40 CFR 68.115, the permittee shall comply 

with the requirements of 40 CFR Part 68. 

(40 CFR Part 68) 

X.AA. Changes to Permits for Emissions Trading 

No permit revision shall be required under any federally approved economic incentives, 

marketable permits, emissions trading and other similar programs or processes for 

changes that are provided for in this permit. 

(9 VAC 5-80-110 I) 

X.BB. Emissions Trading 

Where the trading of emissions increases and decreases within the permitted facility is 

to occur within the context of this permit and to the extent that the regulations provide for 

trading such increases and decreases without a case-by-case approval of each 

emissions trade: 
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 69 

X.BB.1. All terms and conditions required under 9 VAC 5-80-110, except subsection 

N, shall be included to determine compliance. 

X.BB.2. The permit shield described in 9 VAC 5-80-140 shall extend to all terms and 

conditions that allow such increases and decreases in emissions. 

X.BB.3. The owner shall meet all applicable requirements including the requirements 

of 9 VAC 5-80-50 through 9 VAC 5-80-300. 

(9 VAC 5-80-110 I)
Quebecor World Richmond Inc. 

Permit Number: PRO-50880 

Page 70 

XI. State-Only Enforceable Requirements 

The following terms and conditions are not required under the federal Clean Air Act or 

under any of its applicable federal requirements, and are not subject to the requirements 

of 9 VAC 5-80-290 concerning review of proposed permits by EPA and draft permits by 

affected states. 

none 

(9 VAC 5-80-110 N and 9 VAC 5-80-300) 
Quebecor World Richmond Inc. 

CAM Plan for Solvent Recover Systems 

Page 1 

Quebecor World Richmond Inc. 

Compliance Assurance Monitoring 

Liquid to Liquid Mass Balance 

I. Applicability 

This protocol is applicable to the solvent recovery systems (SR-1/SR-2 or SR-A) controlling 

rotogravure printing presses 740, 741, 742, 743 and 744 (P001-P005) for volatile organic 

compounds and organic hazardous air pollutants. 

This approach addresses the combined capture and control efficiency for solvent recovery 

#1 and #2 (Sutcliffe & Croftshaw systems). Additional monitoring of the control device or 

capture systems associated with these systems is not required. 

II. Monitoring Approach 

The solvent recovered is quantified through mass flow metering and a liquid-to-liquid mass 

balance is completed each calendar month. 

III. Rationale for Selection of Performance Indicators 

Use of the liquid-to-liquid mass balance is an accepted compliance determination method 

for determining VOC and HAP emissions from solvent recovery systems. 

IV. Rationale for Selection of Indicator Ranges 

Not applicable. 

V. Procedures 

Perform a liquid-to-liquid mass balance for each month (30 days) following the liquid-toliquid material balance procedures of 40 CFR 63, subpart KK, section 63.824(b)(1)(i). 

HAP content and VOC content values are based on the Certified Product Data sheet 

provided by the material supplier for rotogravure inks, method 311 gas chromatograph 

analyticals for solvent consumed for HAP content, method 24A for volatile matter weight 

fraction, and Material Safety Data sheets for cleaning solvents or press additives consumed. 

A. Inventory – ink and solvent is inventoried in storage tanks with receipts and usage based 

on weight determinations from meter readings, and float levels. Drum product, when 

used, is based on simple inventory. 

1. Approach used – consumption of VOC for presses 740-744 is calculated by 

subtracting the total VOC consumed from press 745 from the total VOC consumed 

facility wide. VOC consumption is based on the meter readings, from the total 

inventory change, and volumetric flow meters, for that same period. Drummed 

material usage is based on change in inventory. 

2. Location – ink is inventoried from 16 ink/extender tanks located in the tank farm on 

the northwest side of the facility. Solvent is inventoried in five tanks in the same area 

of the facility. 

B. Instrumental 
Quebecor World Richmond Inc. 

CAM Plan for Solvent Recover Systems 

Page 2 

1. Type of instrumentation – ink and solvent consumption as well as solvent recovered 

is measured using the following – mass flow meters and volumetric flow meters. 

2. Specifications 

a. Positive displacement meters: meter accurate to within ± 0.5% over a 40:1 

range. 

b. Mass flow meters: meter accurate to within ± 0.2% mass flow and ± 0.25% flow 

volume accuracy at 20:1 range. 

3. Measurement span 

a. Positive displacement meters: 0-65 gallons per minute 

b. Mass flow meters: 0-192 gallons per minute 

4. Scaling 

a. Positive displacement meters: smallest unit that can be read from the instrument 

is 0.1 gallon. 

b. Mass flow meters: smallest unit that can be read from the instrument is 0.1 

gallon. 

5. Location in the process – 

a. Positive displacement meters: located on the inlet side of the gravure presses for 

ink, extender and solvent consumption. Also located at the ink tanks to 

determine total ink and extender received from ink supplier. Solvent sold is also 

measured using a positive displacement meter. 

b. Mass flow meter: located on the outlet side of solvent recovery #1 and #2 to 

measure total quantity of solvent recovered. Also located on outlet side of 

solvent storage tanks to record total solvent metered to gravure pressroom, all 

presses. 

C. Measurement Frequency – 

1. Positive displacement meters: monthly readings for inks and solvents consumed on 

presses 740-745. 

a. Readings are completed by environmental coordinator in gravure pressroom. 

b. Readings are completed for ink and extender receipts from ink supplier. 

2. Mass flow meters: daily readings fro solvent recovered and solvent consumed press 

side, in addition meter reading when solvent sales are completed. Readings are 

completed by building operations operator and forwarded to Environmental and 

Accounting. 
Quebecor World Richmond Inc. 

CAM Plan for Solvent Recover Systems 

Page 3 

3. Ink Tank Floats: daily reading for inventory changes as well as readings when 

deliveries of ink completed. Readings are completed by Receiving Bui9lding Ops 

Operator and forwarded to Accounting. 

D. Calculations 

1. Copy of solvent recovery efficiency report (solvent ledger – daily) attached to 

demonstrate calculations of liquid-to-liquid mass balance 

2. Copy of daily tank inventory report attached. 

E. Record keeping 

1. Coating compositions 

a. Percent solids by volume 

b. Percent solvent by volume 

c. Percent water by volume 

d. Pound of VOC per gallon 

e. Density of ink in pounds per gallon 

2. The daily ink quantity in gallons and pounds as applied 

3. These records will be maintained for five years 

F. Quality Assurance/Quality Control Procedures 

1. Positive displacement meters annual calibration by outside contractor. 

a. Meter failure is noted when readings are historically too high or too low and the 

meter consumption does not match inventory changes based on ink tank floats. 

b. Press side meter accuracy is determined by contractor during annual calibration 

check. 

2. Mass flow meters annual calibration by outside contractors. Meter failure would 

indicate zero flow. 

3. Ink tank floats checked annually by QW personnel. Ink float failure would be 

indicated if material purchased by bill of lading not consistent with volume received. 

4. Computers where liquid-to-liquid mass balance calculations are maintained are 

backed up on a weekly basis. 

G. Periodic Data Accuracy Assessments. 

1. Total VOC content of inks as reported on CPDS checked quarterly via test method 

24A. Data corrected as required and reported to DEQ only if impacts compliance 

with emission cap. 

2. Mass flow meter density checked monthly against GC analysis from ink supplier. 
Quebecor World Richmond Inc. 

CAM Plan for Solvent Recover Systems 

Page 4 

3. Semi annual comparisons of daily meter reading vs. inventory. If variance exceeds 

10%, a review of the entire tracking system will be completed.
Quebecor World Richmond Inc. 

CAM Plan for Solvent Recover Systems 

Page 5 

Quebecor World Richmond Inc. 

Compliance Assurance Monitoring 

Solvent Recovery B (SR-3) Dedert System 

 Indicator #1 Indicator #2 

I. Indicator Measurement 

Approach 

Percent removal efficiency Work practice 

 A CEMS is used to measure 

the VOC concentration at the 

inlet an outlet. 

Inspect structural, 

mechanical and electrical 

integrity of the system. 

II. Indicator Range An excursion is defined as a 

measured daily average 

overall control efficiency of 

less than 97.7% 

An excursion is identified as 

any finding that the integrity 

of the system has bee 

jeopardized and it no longer 

operates as designed. 

Corrective Action Each excursion triggers an 

assessment of the problem, 

corrective action, and a 

reporting requirement 

Each excursion triggers an 

assessment of the problem, 

corrective action, and a 

reporting requirement 

III. Performance Criteria 

 A. Data Representation Inlet and outlet analyzers to 

measure the solvent 

concentrations in the air 

stream per the manufacturer 

have an accuracy of ±1% of 

the full scale 

Inspections will adequately 

identify problems 

 B. Verification of Operational 

Status 

Concentration recorded daily 

in PLC 

Database electronic file; daily 

reports, inspection records 

 C. QA/QC Practices and 

Criteria 

Validation of instrument 

accuracy conducted 

quarterly using CGA 

methods. 

Weekly gas zero & span 

calibration checks 

Calibrations and quarterly 

CGA's of the analyzers are 

performed in accordance 

with Appendix A QA/QC 

procedures (Condition 

IV.B.6). Calibration records. 

 D. Monitoring Frequency Measurement of inlet and 

outlet concentrations is 

continuous with PLC 

recordings every 1 minute 

Internal adsorber inspection 

annually. External system 

inspection monthly. 

 Data Collection Procedure Recorded in PLC on a 5 

minute integration (every 

minute included in 5 minute 

average) while press 745 is 

operating. The 5 minute 

average is written to the 

database to be included as 

one of a possible 288 data 

points for the entire 24-hour 

averaging period 

Electronic file of database 

Record of results of 

inspections and observations 
Quebecor World Richmond Inc. 

CAM Plan for Solvent Recover Systems 

Page 6 

 Indicator #1 Indicator #2 

 Averaging Period 5 minutes for individual data 

point, then averaged 

together for the daily 24-hr 

average (daily average 

determined by X #s of 5 

minute averages; X is only 

recorded if press is operating

PLC Logic 

 E. Record Keeping Maintain for a period of 5 

years paper and/or 

electronic media and 

corrective actions taken in 

response to excursions 

Maintain for a period f 5 

years records of inspections 

and corrective actions taken 

in response to excursions 

 F. Reporting Number, duration, cause of 

any excursion and the 

corrective action taken 

Number, duration, cause of 

any excursion and the 

corrective action taken 

 Frequency Per occurrence and semiannually Per occurrence and semiannually