Date: Sat Apr 17 1999 - 14:47:08 CDT
The question regarding opacity monitoring requirements is not tied directly
to size of the facility. Under most state/local air pollution regulations,
opacity limits are rather generic and apply to any source of emissions. Most
state requirements set an opacity limit of 20% for some average time period
typically 5-10 minutes. Some states have a 0% opacity limit. If a facility
would violate the opacity limit, then they would usually be required to
obtain a permit and take corrective action.
In some instances, facilities who have to obtain a permit to operate for
another reasons such as VOC emissions or the presence of a fuel combustion
source with a firing rate exceeding the permit threshold (e.g., boiler),
opacity limits may be required as one of the emission limits. The permits
incorporating opacity limits do not necessary have to be Title V permits, but
can be state or local construction or operating permits. The specifics depend
upon the particular state/local code.
In order to ensure that a violation of the opacity limit will not occur, the
facility will be required to conduct some type of monitoring. This monitoring
can involve a visual examination using USEPA Method 9 or some type of
instrument. The frequency of monitoring can either be continuous as with an
instrument, or some other frequency such as hourly, daily, or monthly.
Since some uncontrolled heatset web offset presses can violate opacity
limits, the issue of opacity monitoring has received more attention as a
result of Title V. It is important to remember that not all uncontrolled
heatset web offset presses will actually violate opacity standards. The
amount of "smoke" or condensed ink oil depends upon several factors including
the size of the press, coverage, substrate, and ink composition.
Nevertheless, under Title V, the company is required to identify all
applicable requirements and propose methods of compliance.
As part of the P4 project with EPA, one of the goals is to identify which
pieces of equipment or process lines within a printing operation are actually
subject to opacity. One of the other goals under this aspect of the project
is to develop an acceptable monitoring scheme that meets the regulations, but
does not impose an impossible resource burden on printers.
Let me know if you need additional information.
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