Texas Air Permitting Issues

Printing operations (including, but not limited to, screen printers, ink-jet printers, presses using electron beam or ultraviolet light curing, and labeling operations) and supporting equipment (including, but not limited to, corona treaters, curing lamps, preparation, and cleaning equipment) which directly supports the printing operation are permitted by rule, provided that all the following conditions of this section are satisfied:

• 15 tons per year (TPY) for any single printing operation proposed to be covered by this section; and
• 25 TPY for all printing operations on the property covered by permits by rule.

Facilities which release 10 tons per year or more of VOC emissions from all printing operations permitted by rule at the site must register with the commission using Form PI-7. Printing presses covered by this section shall not utilize heat set, thermo set, or oven-dried inks. Heated air may be used to shorten drying time, provided the temperature does not exceed 194 degrees Fahrenheit (90 degrees Celsius). This does not include screen printing operations requiring temperatures greater that 194 degrees Fahrenheit (90 degrees Celsius) to set the ink.

Records of ink and solvent usage shall be kept in sufficient detail to show compliance with the facility’s emissions and must be maintained for a two-year rolling retention period.

There is a $100 fee to submit a permit by rule. Facilities located in ozone nonattainment areas must ensure that all contains of VOC containing materials are covered.

Texas does have a Title V permit program in place. Sources with the potential to emit more than 100 tons of VOCs per year, or 10 tons of one hazardous air pollutant (HAP) or 25 tons of a combination of HAPs are required to apply for a Title V permit.

The state's program does contain provisions for a synthetic minor designation. Synthetic minors include those facilities that agree to federally enforceable limits that restrict their potential to emit to less than the major source threshold.

• 15 tons per year (TPY) for any single printing operation proposed to be covered by this section; and
• 25 tpy for all printing operations on the property covered by permits by rule.