AIR EMISSION PERMIT NO IS ISSUED TO. Quebecor Printing Inc - St Cloud 660 Mayhew Lake Rd NE St Cloud, Benton County, MN 56302

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1 AIR EMISSION PERMIT NO IS ISSUED TO Quebecor Printing Inc - St Cloud 660 Mayhew Lake Rd NE St Cloud, Benton County, MN The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Total Facility Permit April 17, 1995 Minor Amendment August 11, 1995 Minor Amendment March 16, 2000 This permit authorizes the permittee to operate and construct the stationary source at the address listed above unless otherwise noted in Table A. The permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: State; Synthetic Minor Part 70 Issue Date: December 11, 2000 Expiration: Non-expiring All Title I Conditions do not expire. Ann M. Foss Manager North and South Major Facilities for Karen A. Studders Commissioner Minnesota Pollution Control Agency

2 TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals

3 NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area (651) Outside Metro Area TTY (651) The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. FACILITY DESCRIPTION: Quebecor Printing St. Cloud, Division of Quebecor Printing Company, operates a full-service, web offset printing facility located at 660 Mayhew Lake Road NE in St. Cloud, Minnesota. The company is located on an existing site on approximately 24.4 acres and employs approximately 530 people on a permanent basis. Quebecor Printing handles all aspects of full-service web offset lithographic printing at this plant, including film and plate processing, offset web printing, binding and mailing. The facility generally operates 24 hours per day, 7 days per week and 52 weeks per year. AMENDMENT DESCRIPTION:

4 This permit action is for addition of a new printing press (Press No. 4). The permit action is classified as a minor amendment; however, a total facility permit is being issued. A condition of the permit restricts the facility from operating all six presses simultaneously. No more than five presses can be operated at the facility at any one time. The pollution control system is equipped with automatic dampers that prevent operation of more than five presses at any one time. The equipment at the facility after the modification is shown below: EU ID# Stack Vent ID Control Equipment ID Description / /002 Press No / /002 Press No / /002 Press No / /002 Press No / /002 Press No / /002 Press No Prep Area Ventilation Bindery Ventilation Dryer Heat Input (10 6 BTU/hr) Control equipment for the presses consists of two thermal oxidizers (CE 001 and CE 002). A common ductwork manifold system allows emissions from any of the press dryers to be controlled by either CE 001 or CE 002. Emissions from CE 001 and CE 002 are vented to Stack Vents 001 and 002, respectively

5 TABLE A: LIMITS AND OTHER REQUIREMENTS 12/11/00 Facility Name: Quebecor Printing Inc - St Cloud Permit Number: Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C. Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as specified by Minn. R following formal review of a subsequent performance test on the same unit. Monitoring Equipment: Install or make needed repairs to monitoring equipment within 60 days of issuance of the permit if monitoring equipment is not installed and operational on the date the permit is issued. Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment (any requirements applying to continuous emission monitors are listed separately in this permit). Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. Why to do it Minn. R , subp. 14 and Minn. R , subp. 16(J) Minn. R. ch Minn. R Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R Minn. R , subp. 3 Minn. R , subp. 2 At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Minn. R , subp. 1 Minn. R , subp. 1 A-1

6 TABLE A: LIMITS AND OTHER REQUIREMENTS 12/11/00 Facility Name: Quebecor Printing Inc - St Cloud Permit Number: Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R subp. 2), including records of the emissions resulting from those changes. Record keeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). Emissions Inventory Report: due 91 days after the end of each calendar year following permit issuance (April 1). To be submitted on a form approved by the Commissioner. Minn. R , subp. 4 Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R Minn. R through Minn. R Minn. R , subp. 1(H) Minn. R , subp. 5(B) Minn. R , subp. 5(C) Minn. R Minn. R , subp. 16 Minn. R , subp. 9(A) Minn. R through Minn. R Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R through Minn. R Fuel Usage: Fuel used at the facility is limited to natural gas. Volatile Organic Compounds: less than or equal to 99.0 tons/year based on a 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period. Usage records shall be kept on a monthly basis. Total VOC emissions shall be calculated by summing VOC emissions from the usage of materials other than ink, VOC emissions from the usage of ink and VOC emissions from the burning of natural gas. These three values shall be calculated using the equations given below. Monthly VOC emissions from the burning of natural gas shall be calculated as follows: E = NG x where: E = Monthly VOC emissions (tons) NG = Monthly natural gas usage (thousand cubic feet) A-2

7 TABLE A: LIMITS AND OTHER REQUIREMENTS 12/11/00 Facility Name: Quebecor Printing Inc - St Cloud Permit Number: Monthly VOC emissions from usage of materials other than ink shall be calculated as follows: E (tons) = E (lbs) / 2000 E (lbs) = [U x VOC x CE x (1-DE)] + [U x VOC x (1-CE)] - W where: E (lbs) = Monthly VOC emissions in pounds E (tons) = Monthly VOC emissions in tons U = Monthly usage (gallons) VOC = VOC content (lb/gal) CE* = Capture efficiency (%) DE = Thermal oxidizer destruction efficiency (%) W = Waste VOC shipped off-site in pounds * For pre-press, manual wash and bindery chemical material usage, the CE shall be 0%. For automatic wash material usage, the CE shall be 40%. For fountain solution material usage, the CE shall be 70%. Monthly VOC emissions from ink usage shall be calculated as follows: E = [U x VOC x (1-P) x (1-DE)] / 2000 where: E = Monthly VOC emissions (tons) U = Monthly ink usage (pounds) VOC = VOC content (% by weight) P = Amount of VOC remaining in product (20%) DE = Thermal oxidizer destruction efficiency (%) HAPs - Total: less than or equal to 24.0 tons/year based on a 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period. Usage records shall be kept on a monthly basis. HAP-Single: less than or equal to 9.0 tons/year based on a 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period. Usage records shall be kept on a monthly basis. Total emissions of each HAP shall be calculated by summing emissions of the HAP from usage of materials other than ink and emissions of the HAP from the usage of ink. HAP emissions shall be calculated using the equations given below. Total HAP emissions from the facility shall be calculated by summing the emissions of all individual HAPs emitted from the facility. Monthly emissions of each hazardous air pollutant (HAP) from usage of materials other than ink shall be calculated as follows: under 40 CFR Section 70.2 and Minn. R under 40 CFR Section 70.2 and Minn. R under 40 CFR Section 70.2 and Minn. R under 40 CFR Section 70.2 and Minn. R E = (U x D x HAP) / 2000 where: E = Monthly HAP emissions (tons) U = Monthly usage (gallons) D = Density (lb/gal) HAP = HAP content (% by weight) Monthly emissions of each HAP from usage of ink shall be calculated as follows: E = (U x HAP) / 2000 under 40 CFR Section 70.2 and Minn. R where: E = Monthly HAP emissions (tons) U = Monthly ink usage (pounds) HAP = HAP content of ink (% by weight) A-3

8 TABLE A: LIMITS AND OTHER REQUIREMENTS 12/11/00 Facility Name: Quebecor Printing Inc - St Cloud Permit Number: Subject Item: Associated Items: GP 001 Thermal Oxidizers CE 001 Direct Flame Afterburner w/heat Exchanger CE 002 Direct Flame Afterburner w/heat Exchanger What to do Volatile Organic Compounds: greater than or equal to 96 percent destruction efficiency Thermal Oxidizer Operation: Both thermal oxidizers and the associated VOC capture systems shall be operated whenever any three printing presses are operated. At least one thermal oxidizer and its associated VOC capture systems shall be operated whenever fewer than three printing presses are operated. Thermal Oxidizer Temperature: Greater than or equal to 1200 degrees F at the combustion chamber until a new minimum is set pursuant to Minn. R , subp. 3, based on the average temperature recorded during the most recent MPCA approved performance test where compliance for VOC destruction efficiency was demonstrated. If the temperature drops below the minimum temperature limit, the VOC emissions during that time shall be considered uncontrolled until the minimum temperature limit is once again achieved. This shall be reported as a deviation. For periods when the thermal oxidizer is operated above the minimum combustion chamber temperature, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit: a. The destruction efficiency limit specified in this permit for this equipment (96%); or b. The destruction efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test. Monitoring for the thermal oxidizers shall include: a. Instrumentation or written record to indicate the inlet valve open/close status of each oxidizer and the time that an oxidizer inlet valve is closed. Why to do it ; Minn. R , subp ; Minn. R , subp ; Minn. R , subp ; Minn. R , subp ; Minn. R , subp. 14 b. Instrumentation or written record to indicate the operational status of each press and the time a press is operated. Monitoring Equipment: The Permittee shall install and maintain monitoring equipment necessary for measuring the temperature required to be measured by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever the respective control equipment is required to be operated. The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/ percent of the temperature being measured or +/- 2.5 degrees Celsius. The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings for the combustion chamber. Daily Monitoring: The Permittee shall physically check the temperature recording device at least once each operating day to verify that it is working and recording properly. Annual Inspections: At least once per calendar year, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. Weekly inspections: At least once per week, the Permittee shall inspect the external mechanical and electrical systems of the control equipment. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. Annual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration. The Permittee shall operate and maintain the thermal oxidizer in accordance with the Operation and Maintenance Plan. Minn. R , subp. 4 Minn. R , subp. 4 and 5 Minn. R , subp. 5 Minn. R , subp. 4 and 5 Minn. R , subp. 2, 5, and 14 Minn. R , subp. 2, 5, and 14 Minn. R , subp. 2, 5, and 14 Minn. R , subp. 14 A-4

9 TABLE A: LIMITS AND OTHER REQUIREMENTS 12/11/00 Facility Name: Quebecor Printing Inc - St Cloud Permit Number: Subject Item: GP 002 Thermal Oxidizer Stack Vents Associated Items: SV 001 Thermal Oxidizer No. 1 SV 002 Thermal Oxidizer No. 2 What to do A. EMISSION LIMITS hdr Why to do it Opacity: less than or equal to 20 percent opacity Minn. R , subp. 1(B) Total Particulate Matter: less than or equal to grains/dry standard cubic foot Minn. R , subp. 1(A) of exhaust gas, or the allowable concentration at the exhaust gas flow rate as described in Minn. R This limit is applicable to SV 001. Total Particulate Matter: less than or equal to grains/dry standard cubic foot Minn. R , subp. 1(A) of exhaust gas, or the allowable concentration at the exhaust gas flow rate as described in Minn. R This limit is applicable to SV 002. B. POLLUTION CONTROL REQUIREMENTS hdr Volatile Organic Compounds: greater than or equal to 96 percent destruction efficiency (see GP 001 for monitoring and maintenance requirements). C. TESTING REQUIREMENTS hdr Initial Performance Test: due 180 days after initial startup of Press No. 4 (EU 006) to measure VOC destruction efficiency ; Minn. R , subp. 1 Peformance Test Pre-test Meeting: due 7 days before the initial performance test Minn. R , subp. 4 Performance Test Notification (written): due 30 days before the initial performance Minn. R , subp. 1 test Performance Test Plan: due 30 days before initial performance test Minn. R , subp. 2 and 3 Peformance Test Report: due 45 days after initial performance test Minn. R , subp. 1 Performance Test Report - Microfiche Copy: due 105 days after the initial performance test Minn. R , subp. 2 A-5

10 TABLE A: LIMITS AND OTHER REQUIREMENTS 12/11/00 Facility Name: Quebecor Printing Inc - St Cloud Permit Number: Subject Item: GP 003 Printing Activities Associated Items: EU 001 Heatset Web Offset Press #5 EU 002 Heatset Web Offset Press #6 EU 003 Heatset Web Offset Press #7 EU 004 Heatset Web Offset Press #8 EU 005 Heatset Web Offset Press #9 EU 006 Heatset Web Offset Press #4 SV 003 Prep Area SV 004 Bindery What to do No more than five printing presses may be operated at the facility at any time. The Permittee shall maintain a written record of the operational status of each press and the time a press is operated. Why to do it To maintain classification as a minor permit amendment under Minn. R , subp. 2 A-6

11 TABLE B: SUBMITTALS Facility Name: Quebecor Printing Inc - St Cloud Permit Number: /11/00 Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements. Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts to must be certified by a responsible official, defined in Minn. R , subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. Send any application for a permit or permit amendment to: Permit Technical Advisor Permit Section Air Quality Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term. Unless another person is identified in the applicable Table, send all other submittals to: Supervisor Compliance Determination Unit Air Quality Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Send submittals that are required to be submitted to the U.S. EPA regional office to: Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Send submittals that are required by the Acid Rain Program to: U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C B-1

12 TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: Quebecor Printing Inc - St Cloud 12/11/00 Permit Number: What to send When to send Portion of Facility Affected Testing Frequency Plan due 90 days after Initial Performance Test for VOC destruction efficiency. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. GP002 B-2

13 TABLE B: RECURRENT SUBMITTALS Facility Name: Quebecor Printing Inc - St Cloud 12/11/00 Permit Number: What to send When to send Portion of Facility Affected Semiannual Deviations Report due 30 days after end of each calendar Total Facility half-year following Permit Issuance. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations. Compliance Certification due 30 days after end of each calendar year following Permit Issuance (for the previous calendar year). To be submitted on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. Total Facility B-3

14 TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO This technical support document is for all the interested parties of the permit. The purpose of this document is to set forth the legal and factual basis for the permit conditions, including references to the applicable statutory or regulatory provisions. 1. General Information 1.1. Applicant and Stationary Source Location: Owner and Operator Address and Phone Number (list both if different) Quebecor Printing 612 James Street North Montreal, Canada H3C4M8 Facility Contact: Scott Gray (320) Facility Address (SIC Code: 2752) Quebecor Printing, Inc. 660 Mayhew Lake Rd NE St. Cloud Benton County 1.2. Description of the facility Quebecor Printing St. Cloud, Division of Quebecor Printing Company, operates a fullservice, web offset printing facility located at 660 Mayhew Lake Road NE in St. Cloud, Minnesota. The company is located on an existing site on approximately 24.4 acres and employs approximately 530 people on a permanent basis. Quebecor Printing handles all aspects of full-service web offset lithographic printing at this plant, including film and plate processing, offset web printing, binding and mailing. The facility generally operates 24 hours per day, 7 days per week and 52 weeks per year. The Printing/Publishing MACT Standard (40 CFR 63, Subpart KK) was promulgated on May 30, This standard applies to any major HAP source at which publication rotogravure, product and packaging rotogravure, and wide web flexographic printing presses are operated. Since the presses at the Quebecor facility are web offset lithography printing presses, the standard is not applicable. 1.3 Description of any changes allowed with this permit issuance Permit Action Number: Date: 2/26/2004

15 EU ID# This permit action is for the installation of a new printing press which will be designated as Press No. 4. The new press will have a capacity of 253 lb/hr of ink, while the existing press has a capacity of 150 lb/hr of ink. The permit action is classified as a minor amendment; however, a total facility permit is being issued. To maintain classification as a minor amendment, a condition of the permit restricts the facility from operating all six presses simultaneously. No more than five presses can be operated at the facility at any one time. The pollution control system is equipped with automatic dampers that prevent operation of more than five presses at any one time. The last total facility permit issued to the facility was on April 17, Amendments to this permit were issued on August 18, 1992, February 3, 1993 and August 10, 1993 (these amendments are discussed in Section 1.4). A total facility permit application for the facility was received on April 17, 1995 and a minor amendment application was received on August 11, No permits were issued in response to these applications. The August 11, 1995 application was for a minor amendment to remove the press previously designated as Press No. 4 and install Press No. 9. Since this was a minor amendment, a permit was not necessary prior to construction and operation of the new equipment. The equipment at the facility after the current modification is shown below: Stack Vent ID Control Equipment ID Description Capacity (lb/hr ink) / /002 Press No / /002 Press No / /002 Press No / /002 Press No / /002 Press No / /002 Press No Prep Area Ventilation Bindery Ventilation Dryer Heat Input (10 6 Btu/hr) Control equipment for the presses consists of two thermal oxidizers (CE 001 and CE 002). A common ductwork manifold system allows emissions from any of the press dryers to be controlled by either CE 001 or CE 002. Emissions from CE 001 and CE 002 are vented to Stack Vents 001 and 002, respectively. 1.4 Description of all amendments issued since the issuance of the last total facility permit and to be included in the permit. Permit Number and Issuance Date 2219B-91-OT-2 April 17, 1991 Action Authorized Last total facility permit. Permit Action Number: Date: 2/26/2004

16 Amendment #1 to 2219B-91-OT-2 August 18, 1992 Amendment #2 to 2219B-91-OT-2 February 3, 1993 Amendment #3 to 2219B-91-OT-2 September 1, 1995 Installation and operation of the thermal oxidizer for Press Nos. 2 and 4. Installation of Press No. 8 and removal of Press No. 2. Transfer of Press Nos. 5, 6 and 7 from heat exchanger/condenser pollution control to thermal oxidizer control, and to add a new thermal oxidizer to operate in conjunction with the existing thermal oxidizer Facility Emissions: Table 1. Total Facility Potential to Emit Summary: PM tpy PM10 tpy SO2 Tpy NOx tpy CO tpy VOC tpy Pb tpy Single HAP tpy All HAPs tpy Total Facility Limited Potential Emissions Total Facility Actual Emissions See discussion in Section 3.2 below. 2 Emissions of PM 10, SO 2, NO x, CO and Pb are based on 1997 data. Emissions of PM, VOC and HAPs are based on 1999 emissions. 3 Includes emissions from natural gas combustion. Maximum potential emissions from natural gas combustion are 0.5 tpy for total HAPs and 0.5 tpy for any single HAP (hexane). Calculations are attached. Table 2. Facility(TF) and Permit Classification PSD Classification Major/Affected Source *Synthetic Minor *Minor PM, PM 10, SO 2, NO x, CO, VOC, Pb NAAR (Not Applicable) VOC, HAPs PM 10, SO 2, Part 70 Permit Program NO x, CO, Pb * Refers to potential emissions that are less than those specified as major by 40 CFR 52.21, 40 CFR pt. 51 Appendix S, and 40 CFR pt. 70. Permit Action Number: Date: 2/26/2004

17 2. Regulatory and/or Statutory Basis Summary Regulatory and/or Statutory Basis of the Emission or Operational Limit Regulatory Overview of Facility EU, GRP, or SV # EU 001 through EU 006 Applicable Regulations Minn. R Comments: Standards of Performance for Post-1969 Industrial Process Equipment 3. Technical Information 3.1 Emissions Increase from the Modification To qualify as a minor amendment, the emissions increase must be less than 9.13 pounds per hour. Since only five presses can be operated at any one time, emissions from the press with the smallest ink usage (Press No. 8) will be subtracted from the emissions from the new press to obtain the increase in emissions from the modification. Maximum VOC emissions from Press No. 4 are tons per year (calculations are attached). Dividing the tons (111,040 lbs) by 8,760 hours per year (which was assumed when calculating potential to emit) yields a maximum hourly VOC emission rate for Press No. 4 of lb/hr. The maximum hourly VOC emission rate from Press No. 8 is calculated by dividing the Press No. 8 maximum ink usage of 80 lb/hr by the Press No. 4 maximum ink usage of 253 lb/hr and multiplying this factor by the lb/hr emission rate. This yields a maximum hourly VOC emission rate for Press No. 8 of 4.01 lb/hr. Subtracting 4.01 lb/hr from lb/hr yields a maximum hourly VOC emission increase from the modification of 8.67 lb/hr, which is below the threshold of 9.13 lb/hr for a minor amendment. 3.2 PM/PM 10 Emissions Calculation Condensible PM (from usage of ink) Calculations for previous permit amendments included VOC emissions from the usage of ink as condensible particulate matter. This methodology was continued here by calculating the maximum VOC emissions from the usage of ink as follows: PM (ink) = VOC emissions from usage of ink PM (ink) = 1063 lb/hr ink usage(40% VOC)(80%*)(1-0.96**) = 13.6 lb/hr VOC (PM) *Assume that 20% of the VOC remains in the product ** The required destruction efficiency is 96%. PM (ink, tpy) = 13.6 lb/hr(8,760 hr/yr)(1 ton/2,000 lb) = 59.6 ton/yr Permit Action Number: Date: 2/26/2004

18 Actual annual emissions of PM are expected to be considerably lower than calculated above due to the restriction of total VOC emissions below 100 tons per year. PM/PM 10 from the Paper Waste Recycling System The facility has a paper waste recycling system which includes two fabric filters with two separate exhaust vents which vent inside the building. Emissions from insignificant activities need to be accounted for if emissions have the potential to affect applicability. Emissions from the fabric filters are calculated as follows: PM/PM 10 (fabric filters) = 75,500 dscfm (60 min/hr) (0.02 gr/dscf) 1 (1 lb/7,000 gr) = 12.9 lb/hr PM/PM 10 (fabric filters, tpy) = 12.9 lb/hr(8,760 hr/yr)(1 ton/2,000 lb) = 56.5 ton/yr 1 A grain loading of 0.02 gr/dscf is assumed for emissions from the fabric filter. Total Facility-wide Limited PM/PM 10 Emissions Total facility-wide limited PM/PM 10 emissions are calculated as follows: PM Emissions = PM (ink) + PM (fabric filters) + PM (natural gas combustion) = 59.6 tpy tpy tpy = tpy PM 10 Emissions = PM 10 (fabric filters) + PM 10 (natural gas combustion) = 59.6 tpy tpy = 61.5 tpy 3.3 Total Facility-Wide Limited VOC Emissions The permit limits VOC emissions from the facility to 99.0 tons per year. 3.4 Total Facility-Wide Limited HAP Emissions The permit limits emissions from non-combustion sources of any single HAP to 9.0 tons per year and total HAP emissions to 24.0 tons per year. Maximum potential HAP emissions from fuel combustion equate to 0.5 tons per year of both hexane and total HAPs (calculations attached). Summing the applicable values gives total facility-wide limited emissions for any single HAP of 9.5 tons per year and for total HAPs of 24.5 tons per year. 3.5 Total Facility-Wide Limited Emissions of NO x, SO 2 and CO Permit Action Number: Date: 2/26/2004

19 The permit does not restrict operation of the fuel burning equipment, so limited emissions of NO x, SO 2 and CO are equal to maximum potential emissions. Maximum potential emissions of NO x, SO 2 and CO are 25.1, 0.15 and 21.1 tons per year, respectively (calculations are attached). 4. Conclusion Based on the information provided by Quebecor Printing, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Craig Thorstenson, Dave Crowell, Stuart Arkley Peer Review: John Chikkala Attachment: Emission Calculations Permit Action Number: Date: 2/26/2004