Printing, Publishing, and Surface Coating Operations Air Regulation

MGKF attorneys and in-house technical consultants have considerable experience addressing air quality permitting and compliance issues critical to our clients engaged in printing, publishing, and surface coating activities. In particular, with continued efforts at both the state and federal level to control and reduce volatile organic compound ("VOC") emissions from all sources, printing, publishing, and surface coating operations remain a primary focus for regulatory agencies.

We are familiar with and have advised our clients on interpreting and applying New Source Performance Standards ("NSPS") and National Emission Standards for Hazardous Air Pollutants ("NESHAP") governing emissions from printing, publishing, and surface coating operations. In addition, we have assisted our clients in interpreting and applying categorical and individualized standards for Reasonably Available Control Technology ("RACT"). Where our clients have planned new facilities or modifications to existing facilities, we have worked directly with them to address the new source requirements that may apply in such circumstances, including Best Available Technology ("BAT") in state-based permitting activities, as well as Lowest Achievable Emission Rate ("LAER") and Best Available Control Technology ("BACT") as may be necessary under federally mandated nonattainment New Source Review ("NSR") and Prevention of Significant Deterioration ("PSD") programs.

From a permitting standpoint, we have extensive experience working with emission estimation techniques for printing, publishing, and surface coating sources, scrutinizing and tailoring permit terms to ensure operational flexibility and securing permits on an expedited basis. We are sensitive to the unique demands of these industries, including the operational flexibility needed in batch process operations, as well as the speed with which our clients need to respond to customer demands for new or reformulated products. We seek to ensure that our clients' air quality permits do not interfere with these needs for flexibility and responsiveness.

Our technical consultants have worked directly with clients to evaluate appropriate control technology for printing, publishing, and surface coating sources. We are aware of the typical difficulties that may confront the operation of add-on controls or emissions monitoring systems in these industry sectors, for example due to the unique characteristics associated with the VOC exhaust streams from these source. We have assisted our clients in addressing such issues and in minimizing the enforcement implications associated with them. Where necessary, we have assisted our clients in responding to agency enforcement actions relating to these regulatory requirements.

Our professionals can assist you in identifying relevant emission units, projecting emissions, securing permits, responding to enforcement actions, and devising effective and efficient client strategies for all air quality requirements applicable to your printing, publishing, or surface coating operations.