Specialty Graphic Imaging Association 1001 5 Main S treet , F airfa x, V irginia 22031-348 9 USA 70

3.385
.1335 ·703.273
.0456 (fax) SG IA

.org • sg ia@ sg ia org January 21, 2010
Ms. Deborah Rabin Regulations Coordinator Air and Radiation Management Administration Department ofthe Environment 1800 Washington Boulevard Suite 730 Baltimore, MD 21230-1720 Dear Ms. Rabin, The Specialty Graphic Imaging Association (SGIA), representing the interests of facilities engaged in the use ofscreen printing and wide format digital imaging and their associated supplier base, submits the following comments to the draft revisions to COMAR 26.11.19.09-01, Control ofVOC Emission from Industrial Solvent Cleaning Operations other than Cold and Vapor Degreasing
. We support the Department's decision to exempt industrial categories with specific requirements for cleaning solvents from this rulemaking. However, SGIA opposes the implementation ofthe limit of 50 grams VOC per liter to digital printing operations. We believe that the provisions contained in 26.11
. 19.18 (F) includes the use ofcleaning solvents by digital printing operations, therefore, digital operations should be exempted from this proposed regulation
. While the current regulatory language does not specifically reference cleaning materials, the language clearly states: "General Requirements for Digital Imaging. A person who owns or operates digital imaging that is subject to this regulation may not cause the discharge ofVOC emissions into the atmosphere in excess of 100 pounds on any day from all digital printing at the premises." Digital printing activities does include cleaning ofthe equipment, therefore, cleaning solvents are already regulated by the State. Due to the low applicability threshold proposed, this rule will impact more than the 19 facilities as depicted in Appendix D, Number ofnonattainment facilities organized by State, that are estimated to meet the applicability criteria recommended in the CTG. There are over 200 facilities operating in the state ofMaryland with digital capabilities

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When for Industrial Solvents was drafted, the did not sectors. And, when finally industry andas

information currently available to to a upon the

50 grams limit was proposed by on a cleaning operations: spray gun cleaning, spray booth cleaning, components, parts**_~'U",..."** equipment cleaning, and manufactured components a study in 1994. Since

must review the as they 2006, and the developing the 2006 Bay Air Quality solvent only

to environmental controls. promulgation regulatory should allow an industry sector to use the aretechnologically compatible with their manufacturing process. The comments we offer seek to explore alternative means to promulgate this regulation that will result in environmental benefit without sacrificing an entire industrial sector. SGlA proposes that Section (A)(6)(b) be expanded to include digital printing operations. Digital printing was not recognized by the US EPA as a source category for implementation ofthis CTG. Conclusion The intent ofthe US EPA's Control Technique Guideline for Industrial Cleaning Solvents was to provide States with guidance on how to develop effective regulations for a variety ofindustrial sectors using cleaning solvents. It was not a document that mandated that only one VOC limit be established. SGlA believes that the Maryland Department of the Environment does indeed have the authority and flexibility to craft a regulation that will not only reduce air emissions, but allow industrial sectors to use cleaning solvents that are technologically feasible. Before moving forward to finalize this rule, the Agency needs to craft a regulation that does not economically cripple an entire industry sector. Thank you for the opportunity to comment on this important rulemaking. Ifyou have any questions regarding these comments or ifyou would like to further discuss, please do not hesitate to contact me directly
. Sincerely,

Vice President-Government & Business Information