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printech, May, 2000
RE: Reducing PTE Possibility


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From:Jeff Adrian(jeffadrian@johnroberts.com)
Date:31 May 00 16:07:11 -0500


RE: Reducing PTE Possibility 5/31/00 Betty: Here are a couple of suggestions that might work for you: To reduce the impact of this press on facility PTE, many permits allow you to take limits on either 1) the number of production hours or limits on 2) the amount of materials used with the press. These limits must be documented as a part of your air permit, and are what are termed "federally enforceable" limits. Because of this federally enforceable requirement, you'll likely have to document how the limits are being observed. This is done by production hours (for example, the facility operates only one shift) or by tracking the VOC content of the materials consumed on the press (ink, fountain solutions, and cleaning solvents). These type of limits are individually negotiated with the regulatory agency. Some people refer to this approach as creating a "synthetic minor" emissions source, allowing the facility to operate with a state operating permit instead of a more complex Title 5 (federal) air permit. We used this approach several years ago and did not find it too burdensome. Try and negotiate your reporting period (if any) to be an annual one, based upon a monthly rolling average record keeping. Hope this solves your concerns. Jeff Adrian Director, Environment & Safety The John Roberts Company



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