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printech, June, 2000
Re: Reducing PTE Possibility


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From:gjonesprinting@aol.com(gjonesprinting@aol.com)
Date:Thu, 1 Jun 2000 09:40:57 EDT


Betty: There are several possibilities to limiting the PTE of a press. However, we need to first understand PTE and then examine its application to printing presses. The entire concept of PTE, while seemingly based on good intentions, is very confusing and fraught with uncertainty. EPA wants to know how much pollution could be emitted from any given source of pollution. However, EPA's definition of PTE requires you to make unrealistic assumptions about how an individual printing press will be utilized with respect to operation, coverage, cleaning, makeready, and downtime. The end result of these assumptions is that the total emission characterization of the press is overstated by several orders of magnitude, placing the printer in a classification (e.g., major vs. minor) that is not appropriate. The first approach would be if you are attempting to avoid being classified as a major source. There is some potential relief in an EPA guidance memo released in April of 1998. In essence, the memo states that if your actual emissions are less than 50% of the major source threshold, then you could not be a major source. However, the state or local agency must have adopted a regulation to acknowledge this approach to make it legal. The second approach to limiting PTE is in how it is actually determined. There are several different methods that can be used to determine the PTE of any given printing press, with each of them producing a range of different results. None of them are officially approved by EPA, although we are working with EPA on this topic. The printing industry has developed and present an approach that would strike a balance between meeting EPA's definitional requirements and recognizing how printers actually utilize presses. Some state agencies will specify a given approach, but it is not universal. Whatever approach you use, it needs to be approved by the state agency and in the case of FESOPs or Title V permits, the EPA regional office. The third and probably least desirable approach would be to actually file for and obtain a federally enforceable air permit that limits either the hours of operation, material throughput, or emissions. This will require that forms be completed and the permit be negotiated with the agency. In addition, permits will generally require you to keep records to demonstrate compliance with the terms and conditions as well as file reports. If you are not comfortable with this process, a consultant may be necessary. I hope this gives you some answers to a very complex and confusing subject. >From your email, it is not clear as to the specific reason behind your question. Is it a permitting or compliance issue? You may want to call me so we can discuss the specifics, but I will try to answer your question. Gary Jones Graphic Arts Technical Foundation 200 Deer Run Road Sewickley, PA 15143 412/741-6860 x608 - Phone 412/741-2311 - Fax



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