06-096 C.M.R. ch. 161, § 5 - Monitoring and Recordkeeping Requirements

A. Recordkeeping and reporting. The records required in this section shall be available for inspection during normal business hours and copies shall be provided to the Department or US EPA upon request. All records must be maintained on site for a period of 6 years. The periods of retention are extended automatically during the course of any unresolved enforcement action regarding regulated activity or as requested by the Department or by an Administrator of the USEPA.

(1) The owner or operator of any heatset offset lithographic or letterpress printing press that is subject to the control system requirements specified in Section 3 B of this Chapter, shall install and operate continuous temperature monitoring and recording equipment that measures and records temperature data at least once every fifteen minutes or as otherwise approved in writing by the Department and EPA, and shall collect and record the following information and maintain the information at the facility for a period of 6 years:

(a) For each day of operation of the press, a log or record of the operating time for the control device, monitoring equipment, and the associated press.

(b) For thermal oxidizers, for each day of operation of the press;

(i) A log or record showing all three-hour averaged periods of operation during which the average thermal oxidizer chamber temperature was more than fifty degrees Fahrenheit below the average temperature of the thermal oxidizer chamber temperature during the most recent emission test that demonstrated that the press was in compliance, or

(ii) A log or record using a shorter averaging period approved in writing by the Commissioner and EPA, and as applicable, documenting any shutdowns triggered by an oxidizer shutdown threshold temperature as otherwise specified in a BACT analysis or CAM requirement included in an air emissions license after 1997; and

(iii) A log or record showing all events when the unit shuts down due to malfunction, including an automatic shutdown or any events when alarms are activated shall be recorded, and any time that the unit is not operating.

(c) For catalytic oxidizers, for each day of operation of the press:

(i) A log or record showing all three-hour averaged periods of operation during which the average catalytic oxidizer chamber temperature was more than fifty degrees Fahrenheit below the average temperature of the catalytic oxidizer chamber during the most recent emission test that demonstrated that the press was in compliance, or

(ii) A log or record using a shorter averaging period approved in writing by the Commissioner and EPA, and as applicable, documenting any shutdowns triggered by an oxidizer shutdown threshold temperature as otherwise specified in a BACT Analysis or CAM requirement included in an air emissions license after 1997; and

(iii) A log or record showing all events when the unit shuts down due to malfunction, including an automatic shutdown or any events when alarms are activated shall be recorded, and any time that the unit is not operating.

Note: For thermal oxidizers, an owner or operator must comply with either 5A subsection (1)(b)(i) or (1)(b)(ii), but must also comply with subsection (1)(b)(iii).

For catalytic oxidizers, an owner or operator must comply with either 5A subsection (1)(c)(i) or (1)(c)(ii), but must also comply with subsection (1)(c)(iii).

(d) For catalytic oxidizers, the catalyst bed material shall be inspected annually, for years in which the unit is operated for at least 1000 hours, for general catalyst condition and any signs of potential catalyst depletion. The owner or operator shall also collect a representative sample of the catalyst from the oxidizer, per manufacturer's recommendations, and have it tested to evaluate the catalyst's capability to continue to function at or above the required control efficiency. An evaluation of the catalyst bed material shall be conducted whenever the results of the inspection indicate signs of potential catalyst depletion or poor catalyst condition based on manufacturer's recommendations, but not less than once per year, but not less than once every five years, regardless of usage.

(2) The owner or operator of a heatset web or sheet-fed offset lithographic printing press subject to the requirements for Fountain Solution containing alcohol limits pursuant to this Chapter shall measure:

(a) The VOC (alcohol) content, in accordance with Section 4 B(4)of this Chapter, of any altered fountain solution, at the time of alteration, in percent by weight, of the fountain solution employed in the press and shall maintain records of the results of the measurements at the facility for a period of six years.

(b) On a daily basis, the temperature, in degrees Fahrenheit, of the fountain solution, if the owner or operator refrigerates the fountain solution containing alcohol in accordance with paragraph 3A(2)(a)(iii) and 3A(b)(iii) of this Chapter, and shall maintain records of the results of the measurements at the facility for a period of six years.

(3) The owner or operator of a subject lithographic printing press shall maintain records of all recipes used to prepare the as-applied fountain solution to meet the limits specified in Section 3 A(2) Fountain Solution VOC requirements. A fountain solution that is continuously blended with an automatic mixing unit is considered to be the same batch until such time that the recipe or mix ratios change. Each recipe shall be maintained in the recipe log for a period of six years from the date the recipe was last prepared for a press. Each recipe shall clearly identify the following:

(a) The volume and VOC content of each concentrated alcohol substitute, added to make a batch of fountain solution, based upon the manufacturer's laboratory analysis using US EPA Method 24.

(b) The proportions in which the fountain solution is mixed, including the addition of alcohol and/or water. The proportion may be identified as a volume when preparing a discrete batch or may be identified as the settings when an automatic mixing unit is employed.

(c) The calculated VOC content of a final, mixed batch recipe.

(d) The date, time and any recipe changes or deviations of fountain solution batches that are used on a press.

(4) The owner or operator of a subject lithographic printing press not maintaining a recipe log in accordance with Section 5 A(3) above, shall maintain records for each batch of fountain solution prepared for use in the press, including:

(a) The volume and VOC content of any concentrated alcohol substitute, added to make a batch of fountain solution, based upon the manufacturer's laboratory analysis using US EPA Method 24.

(b) The volume of any alcohol added to make each batch of fountain solution.

(c) The volume of water added to make the batch of fountain solution.

(d) The calculated VOC content of the final, mixed batch.

(e) The date and time the batch was prepared.

(5) The owner or operator shall maintain records of the VOC content or VOC composite partial vapor pressure of all cleaning materials employed in all the lithographic and letterpress printing operations.

(6) The owner or operator of a subject lithographic printing press or letterpress printing press shall maintain records of the following information:

(a) The total amount, in gallons, of all the cleanup materials used; and

(b) The total amount, in gallons, of the entire cleanup materials used that exceeds the allowable VOC content or VOC composite vapor pressure.

(7) Exempted printing operations shall maintain monthly purchase records and Material Safety Data Sheets (MSDS) for each process chemical, as used to comply with the Occupational Safety and Health Administration's Hazard Communication Standard, 29 CFR 1910.1200. The records shall document the quantities and VOC content of cleaning solution, fountain solution alcohol, fountain solution alcohol substitutes, coatings, and ink used, to demonstrate that the printing operation falls below the applicability thresholds in Section 1 B, or as specified in a BACT analysis included in an air emission license. The records shall be maintained onsite for six years.

B. Reporting Requirements for Monitoring and Record Keeping

The owner or operator of a lithographic or letterpress printing facility that is subject to this Chapter shall notify the Department of exceedances within forty-five days after the instance occurs, and it shall include a copy of the record showing the instance(s):

(1) Each hydrometer measurement that shows an exceedance of the applicable alcohol content limits specified in this Chapter.

(2) Each temperature reading that shows an exceedance of the temperature limits specified in this Chapter.

(3) Each calculated VOC content that exceeds the VOC content limits specified in this Chapter.

(4) Each instance when an exceedance of the alcohol usage restriction as specified for fountain solutions in this Chapter occurs.

(5) Each instance when alcohol is used in the fountain solution for a non-heatset web offset lithographic printing press.

(6) Each instance when an exceedance of the VOC content or VOC composite partial vapor pressure specified in this Chapter for cleanup materials occurs.

(7) All periods of operation during which the average combustion temperature within the thermal oxidizer was below the temperature limits specified in Section 5 A(1)(b) of this Chapter.

(8) All periods of operation during which the average temperature of the catalyst bed was below the temperature limits specified Section 5 A(1)(c) of this Chapter.

Notes

06-096 C.M.R. ch. 161, § 5