Printers' guide to air permits and environmental opportunities

Air permit overview

Federal and state laws set thresholds for the amount of several different pollutants that facilities can emit into the air over the course of a year. Air pollution control permits lay out these thresholds and other requirements facilities must meet to comply with air regulations. These thresholds are based on both the pollution the facility actually emits and on the potential emissions of a facility's equipment, depending on the permit.

Not all facilities need air permits. A printing facility's need for a permit, and the type of permit required, is based on facility size, type and quantity of pollutants emitted, printing processes used (e.g., sheetfed litho or digital), whether the facility is located in an ozone attainment or nonattainment area, and other factors specific to each permit.

In general, there are two main categories of permits:

Facilities need construction permits to modify or add new air pollution sources, such as a printing press or boiler. The construction permit is critical because it ensures that the equipment will meet all appropriate regulations before being operated.

Facilities need operation permits to cover their entire operations. Operation permits set limits on emissions and establish monitoring, record-keeping and reporting requirements. In some cases, operation permits allow construction and modification of equipment.

Some facilities and construction projects may be eligible for permit exemptions. To determine whether you need a permit, see the If you need a permit tab.

Permit options

Many of DNR's newer permit options have significantly reduced review and approval times and offer greater flexibility in the construction or modification of equipment. The air permit options include:

• permit exemptions based on actual emissions;
• Registration permits designed specifically for printers;
• General Construction and General Operation Permits; and
• source-specific operation permits.

Permit exemptions based on actual emissions

Operation permit exemptions allow facilities with low actual emissions greater flexibility and reduced paperwork. Construction permit exemptions allow facilities with traditional air permits to make minor changes to equipment without a construction permit. A facility may be eligible for a permit exemption if it emits below certain thresholds for pollutants such as volatile organic compounds (VOCs), particulate mater (PM), SO2, CO, NOx, lead and hazardous air pollutants (HAPs), or is planning to add or change equipment where the project will not exceed eligibility thresholds for the pollutants.

Get more information about Permit Exemptions or download fact sheets for the Operations Permit Exemption Based on Actual Emissions [PDF] or the Construction Permit Exemption Based on Actual Emissions [PDF]. To request the DNR approve the use of an exemption, complete Form 4530-100 [PDF] and indicate the exemption option being requested.

Registration permits for printers

Type C Registration Permits provide printing facilities that have low emissions with an easier application process and increased operational flexibility. These permits complement the Environmental Results Program for Printers compliance assistance workbook. Complete permit applications are reviewed within 15 business days.

Learn more about Registration Permits or download a fact sheet [PDF] with more detailed information. Get more information on the Environmental Results for Printers Program in the Other programs tab.

General construction and general operation permits

General Operation Permits (GOPs) provide facilities with certain printing operations a fast, straightforward permit that allows some construction and modification of equipment. General Construction Permits (GCPs) provide facilities with certain printing operations flexibility in constructing or modifying those operations with a fast, straightforward permit. There are 15 different GOPs and 15 different GCPs, available for facilities classified as minor, synthetic minor or major under federal clean air rules with the following types of printing operations:

• digital (solvent-based and liquid toner units);
• lithographic heatset (web) offset;
• lithographic non-heatset web;
• lithographic non-heatset sheetfed; and
• screen printing operations.

Get more information about General Permits or download a fact sheet [PDF] with more details.

Source-specific air permits

Source-specific air permits, such as Title V permits, give facilities a comprehensive, individualized permit that lists out every applicable air pollution requirement and limitation and includes detailed compliance demonstration requirements. These permits are available to any size facility for both construction of new or modified equipment and facility-wide operations. For large or complex printing operations, these permits may be the only option. Because the permits are individualized, the review and approval process is longer than for most of the other permits - generally between 30 and 180 days.

For more information, please visit source-specific air permits.

If you need a permit

Steps for determining if you need a permit

To determine which of the permit options (including the permit exemptions) is best for your printing business, you first need to locate and/or calculate some basic information.

1. List all air pollution emitting equipment in your facility. This includes presses, stand-alone coaters, binding and finishing equipment that apply adhesives or have ink jet units, fuel combustion equipment (e.g., boilers, dryers, heating units, back-up generators, etc.) and cyclones or other paper or scrap handling devices if they emit dust or other particulate matter. In developing your list, include any future planned activities, such as adding or modifying a press or other piece of equipment.
2. Next, calculate the air pollution emissions for your facility. For any fuel combustion units, calculate emissions for each fuel used. A Small Business Environmental Assistance Program fact sheet [PDF], describes how to calculate emissions. For other equipment, calculate your annual emissions of volatile organic compounds (VOCs), hazardous air pollutants (HAPs) and criteria pollutants - carbon monoxide, sulfur dioxide, nitrogen oxides, particulate matter.
3. Compare the results of the calculations with the thresholds in the permit exemption fact sheets. If your emissions for any of the pollutants exceed the thresholds for those pollutants, you will need to apply for the appropriate construction and/or operating permit.
4. If the equipment or entire facility is exempt because the emissions do not exceed the thresholds, make sure you have adequate recordkeeping systems in place. You will need to continue tracking emissions and be able to demonstrate to inspectors that you are meeting emissions limits.

You can calculate your emissions of the three categories of pollutants above by either:

• using product usage records - e.g., how much of a certain solvent you've used during the previous year; or
• using formulas to calculate actual facility emissions. You must choose this option if you use pollution control devices to limit emissions.

You can find step-by-step instructions for doing these initial calculations in the Wisconsin Printers Environmental Compliance Assistance Workbook.

Other programs

Green Tier

The DNR's Green Tier program creates benefits for businesses aspiring to differentiate themselves by systematically delivering superior environmental performance in addition to meeting basic environmental requirements. Green Tier is based on a collaborative system of contracts and charters crafted jointly by participating businesses and the DNR. These contracts and charters streamline environmental requirements in many cases and encourage new environmental technologies.

Performance-based permit pilot project

Thanks to an EPA State Innovation Grant awarded in 2005, DNR began to work with four printing facilities to more fully develop the concept of Performance-based Permitting for this industry. The goals of the Pilot Project were to assess whether this type of flexible permitting can:

• reduce emissions beyond the legal requirement;
• more effectively identify and manage environmental risks;
• provide operational flexibility for participating facilities;
• reduce adminstrative burden; and
• provide more effective public involvement.

The results of this project can be found at EPA's State Innovation Grants [exit DNR].

Environmental Results Program for printers

To make the environmental requirements that apply to printers easier to understand, the Small Business Environmental Assistance Program worked with the DNR and representatives of the printing trade associations to develop an Environmental Results Program (ERP) for Wisconsin printers. Any business in which the primary activity is printing using offset, flexographic, screen, letterpress, gravure and digital (i.e. solvent-based and liquid toner) presses can participate.

The ERP includes an Environmental Compliance Assistance Workbook and Environmental Compliance Self-Certification Checklist. The workbook and checklist are written in plain language and are designed to walk facilities through the requirements and explain exactly what needs to be done for compliance. The air pollution requirements in the workbook match the Type C Registration Permit for Printers. Using the ERP self-certification form will satisfy the annual certification requirement found in the Type C permit.

At this time, the DNR is not accepting new ERP self-certifications, but printers can continue to use the workbook and the DNR will notify printers when the next round of self-certifications for the program will be accepted.

Contacts and resources

• The DNR has a permit primer for small businesses.
• The DNR Small Business Environmental Assistance Program has air permit resources for businesses.
• Contact the DNR Service Center nearest you and ask for your air compliance inspector.