] 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 Depa rtment of Environmental Services, Air Resources Division, to Concord Litho Group, Inc., p ursuant to RSA 125-C.

B. Parties
1. The New Hampshire Department of Environmental Servi ces, Air Resources Division (DES), is a duly constituted administrative agency of the Sta te of New Hampshire having its principal offices at 29 Hazen Drive, Concord, NH 03302, telep hone number (603) 271-1370.
2. Concord Litho Group, Inc. (Concord Litho) is a 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 p rinting operation that produces greeting cards, brochures, magazines and direct mail inserts

. 2. Effective December 31, 2002, DES re-adopted the New Hampshire Code of Administrative Rules Env-A 1204, Stationary Sources of Volatile Or ganic Compounds (VOCs) with amendments. This part defines the sources that are subject to Reasonably Available Control Technology (RACT) requirements and specifies the ap plicable RACT requirements.
3. Concord Litho is subject to Env-A 1216.01, Applicability Criteria and Compliance Standards for Offset Lithographic Printing , because the theoretical potential to emit (TPE) e xceeds 50 tons of non-exempt VOCs during any consecutive 12-month period.
4. Concord Litho operates a Reeco Unitherm Regenerativ e Thermal Oxidizer (RTO) and a Retox 2000 RTO to control VOC emissions from five printin g presses. 5. The printing operations, including the RTOs, are cu rrently covered under a State Permit to Operate.
6. Prior to September 1, 2006, Concord Litho held a Ti tle V Operating Permit, TV-OP-29. Condition VIII.D of the Title V Permit allowed Conc ord Litho to bank, use or trade Discrete Emissions Reductions (DERs) or Emission Reduction C redits (ERCs). Accordingly, Concord Litho has approximately 35 DER credits in its bank to use or to sell.
7. On February 23, 2007, DES and Concord Litho execute d an Administrative Order by Consent (AOC) No. ARD 07-002. The AOC required Concord Lit ho to apply for a RACT Order for compliance purposes when either RTO is shut down du e to maintenance or malfunction.
8. On March 1, 2007, Concord Litho submitted an applic ation for a VOC RACT Order that would allow it to generate and use Discrete Emissions Red uctions (DERs) in order to comply with the VOC reduction requirements during periods when eith er of the RTOs are shut down due to maintenance or malfunction.
9. Effective June 1, 2011, DES readopted Env-A 1200 (f ormerly Env-A 1204), with amendments.RACT Order No. ARD07-003 Modification December 31, 2013

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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 ac cordance with State Permit to Operate FP-S-0291 issued September 11, 2008. The Retox 200 0 RTO demonstrated compliance with the 90% destruction efficiency at 1534 ° F which is lower than the set-point temperature lis ted in RACT Order ARD07-003, issued on September 17, 2007, of 1580 ° F. The Reeco Unitherm RTO demonstrated compliance with the 90% destructio n 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 appl ication, requesting an amendment to link the minimum temperature requirement to stack test c onditions for the Concord Litho RTOs in RACT Order ARD07-003. Concord Litho proposed to ma intain the destruction efficiency requirement of 90% which would be demonstrated thro ugh periodic stack testing.
12. On December 31, 2013, ARD07-003 was revised to remo ve the set-point temperature requirements of 1480°F for the Reeco Unithrem RTO a nd 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 DE S 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 require ments as RACT:
1. Except as specified in a. and b. below, Concord Lit ho 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 heats et web offset lithographic printing press:

a. Shall be reduced by at least 90%, by weight, of tot al organics, less methane and ethane; or
b. Shall not exceed 20 parts per million (ppm) by volu me, prior to dilution.
2. Concord Litho shall perform the following monitorin g and testing of the RTOs:

a. Minimum destruction efficiency the each RTO shall b e at least 90% and the RTO combustion temperature shall not drop below the min imum temperature, based on a one hour average, at which Concord Litho has demonstrat ed compliance through the most recent DES approved stack test demonstrating at lea st 90% destruction efficiency;
b. Concord Litho shall conduct compliance stack testin g once every 5 years within the same calendar quarter of the anniversary of the previous stack test 1 . 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 complia nce with the RACT Order RTO 90% destruction efficiency requirement. In the event t hat 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 comp liance during the stack testing period and

1 The State Permit to Operate issued to Concord Li tho specifies that compliance stack testing is to b e performed at 5 year intervals.RACT Order No. ARD07-003 Modification December 31, 2013

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c. Concord Litho shall maintain copies of the most rec ent 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 c onsistent with manufacturer’s recommendations.
5. For times that the capture and control system is un able to meet the 90% reduction requirement specified in Env-A 1216.03(A)(1) due to a malfuncti on or during routine maintenance of one or both of the oxidizers, Concord Litho shall be allow ed to use DERs in accordance with Condition D.6. of this Order, for the purpose of complying wi th 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. Con cord Litho shall be allowed to use these DERs for RACT compliance in accordance with D.6 of this Order. The following calculations shall be used to determine the amount of DERs generated and/ or used over any given period, but at least monthly:

a. Calculation of Allowable VOC Emissions For the purposes of complying with the VOC RACT req uirement specified in Env-A 1216.03(A)(1), Concord Litho shall calculate the al lowable VOC emissions as follows:
“E al ” means the allowable VOC emission rate; “A” means the actual, uncontrolled emissions from t he five web presses;
“E al ” shall be calculated as in the following equation:
E al = (A)*(1-0.90)
b. Emission Credit Use and Generation Calculations To determine if Concord Litho will either generate DERs or need to use DERs for compliance with RACT, Concord Litho shall subtract the actual VOC emissions (E ac ) from the five web presses, from the allowable VOC emissi ons (E al ) as calculated in accordance with 6.a. of this Order. i.) Generation of DERs: If the result of the subtraction is a positive numb er, then the actual emissions are below the requirements of RACT and the amount equal to the difference between E al and E ac will count towards the generation of DERs. The ac tual DERs shall be calculated by taking the amount of credited emissio ns and multiplying them by a safety factor of 0.9. ii.) Use of DERs: If the result of the subtraction is a negative numb er, then the actual emissions exceed the VOC RACT requirements and emission credits equa l to the difference between E al and E ac shall be used to offset these excess emissions. T he actual DERs required to offset the excess emissions shall be calculated by dividing the excess emissions by an environmental benefit factor of 0.9.RACT Order No. ARD07-003 Modification December 31, 2013

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7. Recordkeeping Requirements
Concord Litho shall maintain all records of the cal culations related to the generation and use of DERs as specified in Condition D.6. in order to dem onstrate 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 Generatio n submitted by the generator source to the State (for paperwork reduction purpos es, a certified statement that the notice is on file with DES will suffice); iii.) The protocol used to document the amount of DERs ne eded to demonstrate compliance; and iv.) Information documenting that Concord Litho is in co mpliance with Env-A 1400, Regulated Toxic Air Pollutants

. b. Annually by April 15, Concord Litho shall submit a report to DES on the balance of credits for the previous calendar year. This report shall meet the requirements of Env-A 3103.08, Notice and Certification of Generation and Env-A 3104.09, Notice and Certification of Use , including the following information: i.) The name and location of the owner or operator of t he source; ii.) A brief description of the generation activity; iii.) A list of the source’s applicable allowable emissio n rates; iv.) The amount of DERs generated each month; v.) A calculation of the amount of DERs generated; vi.) The amount of DERs used each month; vii.) A calculation of the amount of DERs required to dem onstrate compliance with the emission limits stated in Part D, above. viii.) A statement that the reductions were calculated in accordance with Env-A 3103.07; ix.) A statement that the DERs were not generated in who le or in part from actions prohibited pursuant to Env-A 3103.07; x.) A statement that due diligence was made to verify t hat the DERs were not previously used, and not generated as a result of actions proh ibited under the regulations or other provisions of law; xi.) A statement that the DERs were not used in a manner prohibited under the regulation or other provisions of law; andRACT 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 respo nsible official that states:
1. Based on information and belief formed after reason able 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 Ambie nt 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