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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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. 

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 ?5 (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'mthe Chair of the Board of Environmental Protection, and I will be the presiding officer today. Other Board members here today are Wing Goodale, Rach.ard Gould, Don C .~airn~,n~i, I~'ra~:k: Woodard, Nancy Ziegler and MatthewScott. 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 LawChapter 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

ALLEY & MORRISETTE REPORTING SERVICE 207-495-3900Page 3 requirements of Title 40, Part 51 of the Code of Federal Requlations. 3 4 5 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 Iy W~,l : ivill e Morning Sentinel , Portland Press Herald and Bancror 7 Daily News on July 15th, 2009
. Notice of today's

hearing was also sent to all persons on the 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 

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ALLEY & MORRISETTE REPORTING SERVICE 207-495-3900Page 4 1 adoption. An attendance sheet is presently 2 circulating the roomfor 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 nowon 8 the appropriate speaker's sheet. 9 Following each presentat ion lPt_~.. 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 13 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'mDeb 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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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 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 fromthe Printers Industry of NewEngland, Pritit: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 showwhic}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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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 ovecviewLli~_ 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.ution and the fount,-jin -:~1ution 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~~ Jeit ,

ALLEY & MORRISETTE REPORTING SERVICE 207-495-3900Page 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 fromthose, 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 themor when they're mixing the cleaning solution or disposing of the rags that they use to clear, oIi 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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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 emission points. The picture on the top left is

an automatic mixing systemw1~~=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 belowis 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 It,- gallon barrel and mixin it into a small container and then they pour it into these little dilution

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 nowwe'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 coiitr0_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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# II solutions containing VOCs in a rolling 12-month

period. The 800 gallons was something that we added because of thF prirntiric~ irn(j~,_,i ~ ;' . ~nncerns about a lot of the small printers not knowing how to do~the calculations. So our engineers agreed with themthat this was probably a conservative estimate for what the three ton emissions limit
-- or what the minimumemissions 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'mhearing that it might be 750 gallons rather than 800 and, if so, I would expect EPA to comment on that in their cumm~~i,ts 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 whict; he~t to dry the ink, cold set which doesn't use heat to dry ,

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 sawin 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(- }-)ratF~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 allowfor 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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# II minimizing fountain solution VOC emissions. For

alcohol they require percent. concc_rltr iti_~,~ 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 allowfor refrigeration options.

So we mentioned there are three types, heatset, cold set and sheet fed. The heatset fountain solution limits are diffP.ront fromthe other fountain solution limits. So fountain solutions with alcohol must maintain a VOC content at or below5 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 below3 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 weight with no alcoYio_i in the tountai_n solution. Small presses are exempt from that requirement, small presses that print smaller than

---- ALLEY & MORRISETTE REPORTING SERVICE 207-495-3900Page 13 11-by-17 sheets of paper, and then there's the sheet fed fountain solution limits with alcohol substitutes at or below5 percent. If it contains alcohol, below5 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 nowwe'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 knowthat 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 systemand 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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# II technology shall reduce VOCs fromeach dryer by at

least 90 percent
. Newly installed control systems shall reduce VOCs fromeach 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 monitorJng 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 themhave 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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7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 fcici1_it if,s 'knowhow 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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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 them . HEARING OFFICER: Matt . MR. SCOTT: I have two questions, Debbie. First of all, the waste streamas 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 rags. W1:-31 ~+bout the liquids?

MS. AVALONE-KING: That's all managed and
one facility we visited here in Augusta was very proud of howthey've been able to reduce the waste fromtheir 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. Howmuch concern or opposition or

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7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 sort of reaction is there to this proposed

regulation?

MS. AVALONE-KING: There was no -- it's a federal requirement so they've it w-rki 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 howto 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, MadamChair.

HEARING OFFICER: Nancy. MS. ZIEGLER: You said this would cover larger facilities and you mernL_i _un(_~d t ij~it there ar(_

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 six that you knowof. 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 knowsomething about it, they make an attempt to vacuumthe 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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25 We only knowthat 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,'J1 I `ieciare the public hearing closed. (Whereupon, the above-named hearing was concluded at 9:30 a.m

.)

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