] FINAL RACT ORDER ISSUED 

Concord Litho Group, Inc. ] September 17, 2007 

92 Old Turnpike Road ] ARD07-003 

Concord, NH 03301 ] Amended December 31, 2013 

] 

A. Introduction 

This RACT Order is issued by the New Hampshire Department of Environmental Services, Air 

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

B. Parties 

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

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

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

2. Concord Litho Group, Inc. (Concord Litho) is a New Hampshire corporation having its principal 

office at 92 Old Turnpike Road, Concord, NH 03301. 

C. Statements of Fact and Law 

1. Concord Litho is a commercial offset lithographic printing operation that produces greeting 

cards, brochures, magazines and direct mail inserts. 

2. Effective December 31, 2002, DES re-adopted the New Hampshire Code of Administrative 

Rules Env-A 1204, Stationary Sources of Volatile Organic Compounds (VOCs) with 

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

Technology (RACT) requirements and specifies the applicable RACT requirements. 

3. Concord Litho is subject to Env-A 1216.01, Applicability Criteria and Compliance Standards 

for Offset Lithographic Printing, because the theoretical potential to emit (TPE) exceeds 50 tons 

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

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

2000 RTO to control VOC emissions from five printing presses. 

5. The printing operations, including the RTOs, are currently covered under a State Permit to 

Operate. 

6. Prior to September 1, 2006, Concord Litho held a Title V Operating Permit, TV-OP-29. 

Condition VIII.D of the Title V Permit allowed Concord Litho to bank, use or trade Discrete 

Emissions Reductions (DERs) or Emission Reduction Credits (ERCs). Accordingly, Concord 

Litho has approximately 35 DER credits in its bank to use or to sell. 

7. On February 23, 2007, DES and Concord Litho executed an Administrative Order by Consent 

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

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

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

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

VOC reduction requirements during periods when either of the RTOs are shut down due to 

maintenance or malfunction. 

9. Effective June 1, 2011, DES readopted Env-A 1200 (formerly Env-A 1204), with amendments. 
RACT Order No. ARD07-003 Modification December 31, 2013 

Concord Litho Group, Inc. Page 2 of 5 

10. On September 13, 2012 and October 17, 2012, Concord Litho conducted stack testing on the 

Retox 2000 RTO and the Reeco RTO respectively in accordance with State Permit to Operate 

FP-S-0291 issued September 11, 2008. The Retox 2000 RTO demonstrated compliance with 

the 90% destruction efficiency at 1534°F which is lower than the set-point temperature listed in 

RACT Order ARD07-003, issued on September 17, 2007, of 1580°F. The Reeco Unitherm 

RTO demonstrated compliance with the 90% destruction efficiency at 1497°F which is higher 

than the set-point temperature listed in RACT Order ARD07-003, issued on September 17, 

2007, of 1480°F. 

11. On August 21, 2013, Concord Litho submitted an application, requesting an amendment to link 

the minimum temperature requirement to stack test conditions for the Concord Litho RTOs in 

RACT Order ARD07-003. Concord Litho proposed to maintain the destruction efficiency 

requirement of 90% which would be demonstrated through periodic stack testing. 

12. On December 31, 2013, ARD07-003 was revised to remove the set-point temperature 

requirements of 1480°F for the Reeco Unithrem RTO and 1580°F for the Retox 2000 RTO with 

the requirements that the RTOs temperature will not drop below the minimum temperature, 

based on a one hour average, at which the facility has demonstrated compliance with the VOC 

reduction requirements through the most recently DES approved stack test. 

D. Order 

Based on the statements of fact and law, DES hereby orders Concord Litho, effective upon issuance 

of this Order, to comply with the following requirements as RACT: 

1. Except as specified in a. and b. below, Concord Litho shall comply with the VOC control 

standards specified in Env-A 1216.01, Applicability Criteria and Compliance Standards for

Offset Lithographic Printing, specifically: 

The VOC emissions from the dryer exhaust of a heatset web offset lithographic printing press: 

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

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

2. Concord Litho shall perform the following monitoring and testing of the RTOs: 

a. Minimum destruction efficiency the each RTO shall be at least 90% and the RTO 

combustion temperature shall not drop below the minimum temperature, based on a one 

hour average, at which Concord Litho has demonstrated compliance through the most 

recent DES approved stack test demonstrating at least 90% destruction efficiency; 

b. Concord Litho shall conduct compliance stack testing once every 5 years within the same 

calendar quarter of the anniversary of the previous stack test1

. For stack testing purposes 

only, Concord Litho shall be allowed to operate at a lower temperature than identified in 

item 2.a. above in an effort to demonstrate compliance with the RACT Order RTO 90% 

destruction efficiency requirement. In the event that Concord Litho does not meet the 

provisions of the RACT Order during the stack test, then Concord Litho shall be allowed to 

use DERs as described in item 6 below for RACT compliance during the stack testing 

period and 

 

1

 The State Permit to Operate issued to Concord Litho specifies that compliance stack testing is to be performed at 5 

year intervals. 
RACT Order No. ARD07-003 Modification December 31, 2013 

Concord Litho Group, Inc. Page 3 of 5 

c. Concord Litho shall maintain copies of the most recent DES approved compliance stack 

test records on site. These records shall be made available to DES/US EPA upon request. 

3. Concord Litho shall operate and maintain equipment to continuously monitor the temperature of 

the combustion chamber of each RTO. 

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

recommendations. 

5. For times that the capture and control system is unable to meet the 90% reduction requirement 

specified in Env-A 1216.03(A)(1) due to a malfunction or during routine maintenance of one or 

both of the oxidizers, Concord Litho shall be allowed to use DERs in accordance with Condition 

D.6. of this Order, for the purpose of complying with the VOC RACT requirements. 

6. Generation and Use of DERs: 

Concord Litho shall be allowed to generate DERs for VOC emission reductions that exceed the 

reductions required in Part D.1 of this Order. Concord Litho shall be allowed to use these DERs 

for RACT compliance in accordance with D.6 of this Order. The following calculations shall be 

used to determine the amount of DERs generated and/or used over any given period, but at least 

monthly: 

a. Calculation of Allowable VOC Emissions 

For the purposes of complying with the VOC RACT requirement specified in Env-A 

1216.03(A)(1), Concord Litho shall calculate the allowable VOC emissions as follows: 

“Eal” means the allowable VOC emission rate; 

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

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

Eal = (A)*(1-0.90) 

b. Emission Credit Use and Generation Calculations 

To determine if Concord Litho will either generate DERs or need to use DERs for 

compliance with RACT, Concord Litho shall subtract the actual VOC emissions (Eac) from 

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

with 6.a. of this Order. 

i.) Generation of DERs: 

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

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

and Eac will count towards the generation of DERs. The actual DERs shall be 

calculated by taking the amount of credited emissions and multiplying them by a 

safety factor of 0.9. 

ii.) Use of DERs: 

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

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

Eal and Eac shall be used to offset these excess emissions. The actual DERs required 

to offset the excess emissions shall be calculated by dividing the excess emissions by 

an environmental benefit factor of 0.9. 
RACT Order No. ARD07-003 Modification December 31, 2013 

Concord Litho Group, Inc. Page 4 of 5 

7. Recordkeeping Requirements 

Concord Litho shall maintain all records of the calculations related to the generation and use of 

DERs as specified in Condition D.6. in order to demonstrate compliance with this Order, and 

shall be kept for a period of at least five years. 

8. Reporting Requirements 

Concord Litho shall submit the following reports to demonstrate compliance with this Order: 

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

use of credits for the upcoming year. This report shall meet the requirements of Env-A 

3104.08, Notice of Intent to Use DERs, including the following information: 

i.) The name and location of the user; 

ii.) A copy of the Notice and Certification of Generation submitted by the generator 

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

notice is on file with DES will suffice); 

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

compliance; and 

iv.) Information documenting that Concord Litho is in compliance with Env-A 1400, 

Regulated Toxic Air Pollutants. 

b. Annually by April 15, Concord Litho shall submit a report to DES on the balance of credits 

for the previous calendar year. This report shall meet the requirements of Env-A 3103.08, 

Notice and Certification of Generation and Env-A 3104.09, Notice and Certification of 

Use, including the following information: 

i.) The name and location of the owner or operator of the source; 

ii.) A brief description of the generation activity; 

iii.) A list of the source’s applicable allowable emission rates; 

iv.) The amount of DERs generated each month; 

v.) A calculation of the amount of DERs generated; 

vi.) The amount of DERs used each month; 

vii.) A calculation of the amount of DERs required to demonstrate compliance with the 

emission limits stated in Part D, above. 

viii.) A statement that the reductions were calculated in accordance with Env-A 3103.07; 

ix.) A statement that the DERs were not generated in whole or in part from actions 

prohibited pursuant to Env-A 3103.07; 

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

used, and not generated as a result of actions prohibited under the regulations or other 

provisions of law; 

xi.) A statement that the DERs were not used in a manner prohibited under the regulation 

or other provisions of law; and 
RACT Order No. ARD07-003 Modification December 31, 2013 

Concord Litho Group, Inc. Page 5 of 5 

xii.) The report shall contain a certification by a responsible official that states: 

1. Based on information and belief formed after reasonable inquiry, the statements 

and information in the document are true, accurate and complete; and 

2. The user source is in compliance with all National Ambient Air Quality 

Standards, except ground level ozone, and all Ambient Air Limits for Regulated 

Toxic Air Pollutants. 

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

Air Permits Program Manager 

NHDES, Air Resources Division 

Bureau of Permitting and Environmental Health 

29 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

603) 271-1370 

Please address any correspondence and communication in reference to the ERCs or DERs to the 

following: 

Mr. Joe Fontaine 

NHDES, Air Resources Division 

29 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-6794 

Craig A. Wright 

Director 

Air Resources Division 

cc: Timothy Drew, PIP Office 

Curt Spalding, USEPA Region 1 

City of Concord