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STATE OF MAINE 

BOARD OF ENVIRONMENTAL PROTECTION 

IN RE : CHAPTER 161 : GRAPHIC ARTS -

LITHOGRAPHY AND LETTER PRESS 

PRINTINC 

PRESIDING OFFICER : SUSAN LESSARD, CHAIRPERSON 

This hearing was held pursuant to Notice at the 

Ground Round, Civic Center Drive, Augusta, Maine, 

on August 6, 2009, beginning at 9 :00 a .m . 

L 

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(This hearing was held before the Board 

of Environmental Protection, Ground Round, Civic 

Center Drive, Augusta, Maine, on August t>, 2009, 

beginning at 9 :00 a .m .) 

HEARING OFFICER : Good morning . We are 

holding a public hearing this morning at 9 :00 a .m . 

on Chapter 161 : Graphic Arts, Lithography and 

Letter Press Printing . My name is Susan Lessard 

and I'm the Chair of the Board of Environmental 

Protection, and I will be the presiding officer 

today . Other Board members here today are Wing 

Goodale, Ra ch .ard Gould, Don C.~a i rn~,n~i, I~'r a~ :k: 

Woodard, Nancy Ziegler and Matthew Scott . Staff 

here today from the Department of Environmental 

Protection, Bureau of Air Quality, are Deb 

Avalone-King and Jeff Crawford . Our reporter 

today is Joanne Alley of Al1ey~& Morrisette 

Reporting . 

Today's hearing is being held pursuant to 38 

M .R .S ., sections 585-A, 585-D, 345-A and Public 

Law Chapter 384, Section 14 . In addition, because 

this rule will be submitted as a revision of 

Maine's State Implementation Pian for Aii Quality, 

today's hearing will be conducted pursuant to the 

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requirements of Title 40, Part 51 of the Code of 

Federal Re qulations . 

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Notice of today's hearing was published in 

the Kennebec Journal on July 6, 2009 and in the 

Kennebec Joul: n'a7 , Lewiston li,ti I y W~,l : ivi ll e 

Morning Sentinel , Portland Press Herald and Bancr or 

7 Daily News on July 15th, 2009 . Notice of today's 

hearing was also sent to all persons on the 

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Department's regulatory notice mailing list as 

well as to all potentially affected facilities and 

to other persons who have expressed interest in 

the rule that is the subject of today's hearing . 

The record for written comments shall remain open 

until 5 p .m . on August 17th, 2009 . All written 

testimony should be addressed to the Ri_irPau of Air 

Quality and clearly marked as follows : for 

inclusion in the August 6, 2009 Chapter 161 public 

hearing record . . 

Today's hearing will be transcribed and made 

available to all Board members . Based on the 

complete record, the Board will vote to approve, 

deny or amend the proposed rule at a regularlyscheduled Board meeting . Copies of the final 

staff recommendation will be available upon 

request before the rule is presented for II 

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1 adoption . An attendance sheet is presently 

2 circulating the room for those interested in being 

3 on a mailing list for this rule . Procedures call 

4 for presentations first by proponents ; second, by 

5 opponents ; and third, by other interested parties 

6 neither for nor against . If you plan to speak and 

7 have not already done so, please sign in now on 

8 the appropriate speaker's sheet . 

9 Following each presentat i on l Pt_~ . . w ; ; l be an 

10 opportunity for members of the Board to direct 

11 questions through the Chair . Copies of the 

12 proposed rule are available on the table by the 

1 3 door . 

14 At this time I would ask all persons who 

15 intend to testify to please stand to be sworn in . 

16 Raise your right hand . Do you swear to tell the 

17 whole truth and nothing but the truth? 

18 ' (Witnesses respond in affirmative) . 

19 HEARING OFFICER : Thank you . Are there any 

20 questions? 61e will hear testimony begirining with 

21 staff . Good morning . 

22 MS . AVALONE-KING : Good morning . I'm Deb 

23 Avalone King . Can you all hear me well? Section 

24 184 of the Clean Air Act requires states to 

25 ~~ implement or update reasonably available control_ 

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technique or RACT controls on all major VOC and 

NOx emission sources and on source categories 

covered by a controlled technique guideline 

document . 

In September of 2006 EPA published a CTG for 

offset lithography printing operations and that is 

what this rule is geared for . We had a public 

workshop in May, a webinar workshop with 15 people 

attending with representatives from the Printers 

Industry of New England, Pri tit :i rn(a I i rcs of 

America and Printers National Environmental 

Assistance Center, as well as some possibly 

affected printer shop owners here in the state . 

The manufacturers directory indicated we have 

about 153 printers of all types in the state, 41 

were listed as possibly being offset lithography 

or letter press printing, which would be affected 

y this rule, and we think -- we're not su~re but 

we think about six facilities will be subject to 

the limits from this rule . 

I've prepared a slide show whic}i we're going 

to -- we have handouts in front of you rather than 

a screen and there are handouts over there for 

anyone in the audience that would like them . 

were able to cro on a tour of a couple of 

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facilities here in Augusta and Hallowell, and so 

we have some pictures that help us understand 

where the emission points are . So the goals of 

this presentation are to ovecview Lli~_ pr ting 

processes and VOC emission points and to review 

key elements of the regulation . So you see on the 

page that says pre-pressed plates and large 

printing machines, there's an example of a plate 

which is etched with some kind of chemicals . The 

etched plate surfaces on that plate adhere ink so 

that it can then transfer that in the printing 

processes . The -- all the empty spaces between 

the etched areas get filled with something called 

a fountain sol.ut ion and the fount ,-j i n - :~1 ut i on is 

of primary concern for VOC emissions . The picture 

on the right with all the machines that's one 

printing machine . That particular one is here in 

Augusta . Each unit in the line represents a 

different color or coating that gets applied to 

the print job . This particular one is a sheet fed 

offset lithography plant . 

Turn to the next page and there's some 

pictures of examples of smaller printing 

machines . These facilities probably will not be . 

affected by this rule, the one on L1~~ Jei t , 

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because they emit -- we suspect they emit less 

than three tons of VOCs per year, but they give 

you examples of the different size of presses, and 

the one on the right is a small press, a small 

sheet fed press, that will also-probably ~be exempt 

because of the size of the paper that it can 

handle . The common VOC emission sources include 

fountain solution, cleaning .rn l heatset 

dryers . Fountain solutions are the chemicals that 

adhere to the empty spaces on the plate as it's 

printed to keep the ink away from those, you know, 

keep the printed job nice and clear, and the 

cleaning solution is used to clean off the platens 

of any ink or debris left after the print job is 

completed . 

The points of emissions are when they're 

mixing the solutions to dilute them or when 

they're mixing the cleaning solution or disposing 

of the rags that they use to clear, o I i t 'ri~ 

platens, and the heatset dryers are specific to a 

type of printer that uses heat to dry the print --

the ink rather than most of the places that we've 

looked at just use cold air-dried ink processes 

which have much lower emissions . 

So there's pictures of some typical VOC 

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emission points . The picture on the top left is 

an automatic mixing system w1~~= i (i <<<_ , nij :- ~ he 

fountain solution and it gets pumped directly to 

the machines, and there's no handling of mixing of 

batches and bottles and things . The picture to 

the right of that is a refrigerated condenser 

system . That is a technology that helps reduce 

the VOC emissions . It's a fairly sophisticated 

operation if they can afford the refrigerated 

condensers . Down below is two examples of how 

fountain solution reservoirs provide the fountain 

solution to the printing machine . The small one 

on the left uses a five-gallon jug to mix their 

recipe of water to fountain solution concentrate 

and then they pour it into the little reservoir at 

the bottom of the machine and the very small 

printer that we showed you a picture of they just 

use a little bottle . They mix it in a gallon jug 

and then they pour it into these little bottles 

and they get turned upside down on the machine . 

n the next page we look at some VOC emission 

points for cleaning solutions and we mentioned the 

mixing where they're taking i ( (,I I t,- 

gallon barrel and mixin it into a small container 

and then they pour it into these little dilution 

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bottles and squirt it on the platens and wipe it 

off with the rags . The rags are to be stored in 

sealed containers . You see the red container 

under the table, and then the rags are sent away 

-- sent out for cleaning . The-large bucket .you 

see on the right with all the raqs in plastic bags 

are waiting to be taken out for cleaning and all 

the cleaning gets done in a facility for that in 

Massachusetts . They are converting to these 

barrels that you see with the red tops for storage 

rather than the bins with just plastic bags to 

contain the emissions further when they're in the 

plant . 

So now we've had the tour, and we can move 

on to the high points of the regulation . What I'd 

like to focus on here today is the applicability 

thresholds, trie emission coiit r0_1 ; im : '_ : ; : :,c1 the 

monitoring and record-keeping r-equirements, -and 

those are what the printer associations were most 

concerned about . 

So Section 1, applicability, this applies 

statewide to any offset lithography or letter 

press printer whose actual emissions are greater 

than three tons per year or 12-month rolling 

average or who use more than 800 gallons of 

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solutions containing VOCs in a rolling 12-month 

period . The 800 gallons was something that we 

added because of thF pr irntiric~ irn(j~,_,i ~ ;' . ~nncerns 

about a lot of the small printers not knowing how 

to do~the calculations . So our engineers agreed 

with them that this was probably a conservative 

estimate for what the three ton emissions limit --

or what the minimum emissions threshold would be . 

So I have -- you notice it's in red, though, 

because I just recently learned two weeks ago that 

EPA has negotiated with the National Printers 

Association and I'm hearing that it might be 750 

gallons rather than 800 and, if so, I would expect 

EPA to comment on that in their cumm~~i,t s in this 

rule public hearing . 

So VOCs are any compound which participates 

in atmospheric photochemical reactions and the 

comporient of most~concer~n with printers is 

alcohol . A lot of printers are converting over to 

non-alcohol based fountain solution and so this 

rule is designed to encourage that . 

It's a pretty complex rule because there's a 

lot of different types of offset lithography 

printing . Tri-re's heat :;et wh i ct; he ~t to dry 

the ink, cold set which doesn't use heat to dry , 

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the ink but they -- those are both usin rolls of 

paper, and then there's sheet fed which is single 

sheets of paper that you saw in the picture . They 

use flat sheets rather than rolls . The emission 

control limits that EPA set out include work 

practices, fountain and cleaning solution limits, 

VOC limits, and emission control system 

requirements for facilities that us(- }-)rat F~et 

dryers and specific to heatset dryers that emit 

more than 25 tons per year of emissions . I should 

point out that any facility that emits more than 

25 tons per year of emissions is also required to 

have a minor air emission license, a minor source 

air emission license . 

The work practices include making sure you 

use sealed containers for the rags as you use them 

and then they're stored in sealed containers, that 

spills are*minirnized-and the-applicators are 

stored in closed containers at. a_il times . Looking 

at the Bureau of Remediation and Waste Management 

rules for HAPS, because those apply to these 

facilities as well, they allow for a plastic bag 

to be considered a sealed container . So, hence, 

that was a surprise to me . 

There are three types of approaches for 

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minimizing fountain solution VOC emissions . For 

alcohol they require percent. concc_rltr it i_~,~ limits 

in the batch recipe that you mix . They prefer to 

see people use alcohol substitutes which are ethyl 

glycols or ethylene glycols, and then they also 

are concerned about the fountain solution 

reservoir and making sure that that doesn't have 

any leaks and that it might allow for 

refrigeration options . 

So we mentioned there are three types, 

heatset, cold set and sheet fed . The heatset 

fountain solution limits are diffP .ront from the 

other fountain solution limits . So fountain 

solutions with alcohol must maintain a VOC content 

at or below 5 percent, and fountain solutions with 

alcohol -- I'm sorry, that was with alcohol 

substitutes . The second one with alcohol they 

must be-below-1 .6 percent by weight or 

refrigerated fountain solutions must be below 3 

percent VOC by weight at 60 degrees Fahrenheit . 

Your next one I believe is the cold set 

fountain solution limits, and that limit is 5 

percent by we i ght with no alcoYio_i in t he t ountai_n 

solution . Small presses are exempt from that 

requirement, small presses that print smaller than 

----

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11-by-17 sheets of paper, and then there's the 

sheet fed fountain solution limits with alcohol 

substitutes at or below 5 percent . If it contains 

alcohol, below 5 percent ; or if it's refrigerated 

with alcohol., they're allowed to be as high as 8 .5 

percent at a ~,ai ticular tempei_ai.u~ ~~ . 

And now we'll move on to the cleaning 

solvents which they use to clean the platens off 

between print jobs . Those requirements are to 

have -- the solution must have a composite partial 

vapor pressure less than 10 millimeters of mercury 

at 20 degrees centigrade or a VOC content less 

than 70 percent by weight, and they know that 

weight by referring to the MSDS sheet they're 

required to have . They are allowed to have -- use 

up to 110 gallons of higher VOC content solvents 

for things that are harder to clean arid that they 

can't -- that the lower VOC content solutions 

won't work . Emission control systems for heatset 

dryers include they shall -- they shall be 

equipped with a control system and meet 

operational requirements . There are certain 

printing units that are exempt . Those that have a 

web width of 22 inches or less do not require a 

control system . Heat set presses emission control 

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technology shall reduce VOCs from each dryer by at 

least 90 percent . Newly installed control systems 

shall reduce VOCs from each dryer by at least 95 

percent . So it's 90 for existing and 95 for newly 

installed . The dryer pressure has to be 

maintained lower than the air pressure at all 

times and the control device operating -- must be 

operating at all times that the press is in 

operation . 

The device and monitor J ng c :~.]u .i~~],uWc;t have to 

be calibrated and operated and maintained 

according to manufacturer specs . 

There are a number of monitoring and record 

keeping requirements for different parts of the 

operation . Obviously heatset dryers and control 

systems have to have an ongoing log . Heatset or 

sheet fed systems that use fountain solution with 

alcohol must measure and record each batch that 

they make . Refrigerated systems must maintain 

daily temperatures and fountain solutions 

containing alcohol or alcohol substitutes maintain 

a log of their batch recipes ; in fact, many of 

them have the automatic mixing systems so that 

they don't have to make individual gallons or 

five-gallon containers full . That was a big 

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concern for the printing industry . They didn't 

want to overburden the small printers with a lot 

of record keeping requirements so we modified that ' 

so that they wouldn't have to do exce : .~~~ivc record 

.keeping, and then there's record keeping for cold 

set systems with fountain solution containing 

alcohol . They have to document all periods of 

time that they're using alcohol, its VOC content 

and volume . They also have to maintain records of 

their cleaning solutions by the month and amount 

of gallons they used and any that are exempted . 

So other than that, I have -- I don't know 

if you've been passed out the worksheet . We're 

preparing a worksheet to help fcici 1 _i t if,s 'know how 

to calculate what their emissions are . If they 

think they're above the 800 gallon cutoff, they 

would have to go through this worksheet to figure 

out what their emissions are to determine their 

threshold applicability, and on the back is an 

example of what they have to do to determine 

whether their batch recipe for fountain solution 

meets the 1 .6 to 8 percent limits that are set for 

each solution . 

So that is about what I have to offer and if 

you have any questions, I'll be giad Lo answer 

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them . 

HEARING OFFICER : Matt . 

MR . SCOTT : I have two questions, Debbie . 

First of all, the waste stream as far as the solid 

waste and the liquid waste that are generated, 

where does that go to? It goes to Massachusetts 

you said? 

MS . AVALONE-KING : The rags go to 

Massachusetts for cleaning . 

MR . SCOTT : Just the r ags . W1 : -31 ~+bout the 

liquids? 

MS . AVALONE-KING : That's all managed and 

one facility we visited here in Augusta was very 

proud of how they've been able to reduce the waste 

from their systems, but a lot of it -- a lot of 

the cleaning solution evaporates . 

MR . SCOTT : Okay, all right . On the 

calculation page, I just -- I think I've got the 

answer now . I just noticed the percent over to 

the left-hand side of the page is 1 .h4 percent 

then . 

MR . WOODARD : Yeah . 

MR . SCOTT : Good . I just wanted to make 

sure . Another question is about the 

stakeholders . How much concern or opposition or 

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sort of reaction is there to this proposed 

regulation? 

MS . AVALONE-KING : There was no -- it's a 

federal requi rement so they've it w-r k i i1g with 

EPA since the early eighties to develop these 

standards . There were a number of iterations of 

the control technique guideline document, so 

they've known it's been coming down the pike for a 

long time and it's happening in all the other 

states, but they were concerned about making it 

simpler for the small printers who might not 

understand how to go through these calculations to 

have that 800 gallon cutoff and they were very 

concerned about the record ke.epinq . That was 

their primary concerns . 

MR . SCOTT : Thank you . I was curious about 

that, what the reaction was . 

MS . AVALONE-KING : But they didn't even 

come today because they felt they were comfortable 

with the rule . 

MR . SCOTT : All right, good . Thank you . 

Thank you, Madam Chair . 

HEARING OFFICER : Nancy . 

MS . ZIEGLER : You said this would cover 

larger facilities and you mernL_i _un(_~d t ij~it t here ar(_ 

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six that you know of . Where are they and what are 

they? 

MS . AVALONE-KING : We don't have the 

specific information . The Printers Association 

wouldn't tell us who they were . 

MS . ZIEGLER : Oh, really? That's 

interesting . 

MS . AVALONE-KING : Yeah, so there have been 

two very large printers in the state ihat are 

controlled by -- they are major sources and they 

have over 50 tons of VOC emissions per year . One 

just went out of business so some of the smaller 

ones may pick up some of their business along the 

way but these are mostly -- this rule affects 

mostly medium-sized printers, 3 to 25 tons a 

year . 

MS . ZIEGLER : Thanks . 

HEARING OFFICER : Any other questions? 

Frank . 

MR . WOODARD : Yeah, Debbie, this facility 

in Massachusetts I know something about it, they 

make an attempt to vacuum the stuff and recycle 

it . What percentage of -- is it a hundred percent 

of the rags that are collected in Maine go there? 

MS . AVALONE-KING : That's a good question . 

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We only know that the facility we visited here in 

Augusta sends all their rags there and the 

facility in Hallowell . So I was led to k>elieve 

that there are only a couple of places that offer 

this service . 

MR . WOODARD : Okay . 

HEARING OFFICER : Any other questions? 

Thank you very much . 

MS . AVALONE-KING : Okay . 

HEARING OFFICER : Is there anyone else who 

wishes to speak in favor of this rule? Anyone in 

opposition? Anyone with general comments neither 

for nor against :' Seeing none, 1 'v ,'J 1 I `ieci are the 

public hearing closed . 

(Whereupon, the above-named hearing was concluded 

at 9 :30 a .m .) 

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