SUPPLEMENTAL BASIS STATEMENT Chapter 161 Graphic Arts - Lithography and Letterpress Printing March 18, 2010 COMMENTORS: (1) AnneArnold EPA Region I 1 Congress Street Suite 1100 Boston, Mass (2) Mark Flannery Printing Industries of New England (PINE) 5 Crystal Road Southborough, MA01772-1758 (3) Steve Whipple Environmental Consultant for Dingley Press 119 Lisbon Street Lisbon, ME 04250 1) Comment on Applicability Section 1 .B: EPA recommends that for sheet-fed and coldset printing operations Maine use the EPA/industry agreed upon applicability threshold of: 64 gallons per month or equivalently, 768gallons per year offountain solution, fountain solution additives and cleaning solution purchased or used
. Likewise, for heatset printing operations we recommend that Maine use the EPA/Industry agreed upon applicability weight threshold of 450 pounds per month or equivalently, 5400pounds per year of ink, cleaning solution, fountain solution and fountain solution additives purchased or used
. (Commentor#1) Response: The suggested changes in the applicability threshold havebeen incorporated in Section 113
. 2) Comment on Applicability Section 1Band Record-keeping 5A(7) : The proposed Chapter 161 rule does not clearly state the record-keeping requirements for facilities that are exempt from

the control requirements of the rule due to not meeting the applicability threshold listed in section 1.11. Exemptedfacilities should keep monthly records, for a specified period oftime, documenting the quantities ofcleaning solution, fountain solution, fountain solution additives, and ink used to demonstrate that they fall below the applicability thresholds in section 1 .B
. (Commentor #1) Response: The suggested change for recordkeeping by exempt facilities has been incorporated as follows
. New language: 113
. This regulation applies to any Offset Lithography (Heatset, Sheet Fed or Coldset) and Letterpress printing operation (1) whose maximumactual emissions are greater thanthree tons ofVOCs per rolling 12 month period;(2) for non-heatset printingoperations, whose total volume ofcleaning solution alcohol fountain solution, alcohol substitutes, coatings and ink purchased or used in any 30 _day rolling period is greater than 64gallons per month, or equivalently, 768 gallons in any 12 month rolling period; or (3) for heatset printing operations whose total weight of heatset inks cleaning solution fountain solution and fountain solution additives purchased or used in any 30 day rolling period is greater than 450pounds per month or equivalently, 5400pounds per 12 month rolling period
. Any person claiming exemption pursuant to this subsection shall record and maintain monthlyoperational records sufficient to demonstrate compliance as specified in Subsection 5A(7) ofthis Chapter
. SA(7) Exempted printing operations shall maintain monthly purchase records and Material Safety Data Sheets (MSDS) for each process chemical as used to comply with the Occupational Safety and Health Administration's Hazard Communication Standard, 29 CFR 1910.1200
. The records shall document the quantities and VOC content ofcleaning solution, fountain solution alcohol, fountain solution alcohol substitutes, coatings, and ink used to demonstrate that the printing operation falls below the applicability thresholds in section 1B, or as specified in a BACT analysis included in an air emission license
. The records shall be maintainedonsite for six years. 3) Comment on Applicability Section 1C: Dingley Press is the only Maine facility, currently issued an air emission license and is subject to more stringent BACT requirements
. In their current license mandated testing schedule they are not required to test again until December 31, 2011
. Practically, Dingley has met all the substantive conditions ofthe rule but has not incorporated some ofthe details such as documenting negativepressure in the dryer and would like to incorporate this is the next regularly scheduled test event which will take place in the fall of 2011 . We suggest an amendment to Section 1 Cto accommodate that currently planned testing schedule
. (Commentor #3) Response: This change was incorporated into the rule as shownbelow
. The air emission license specifies the ongoing testing time frame for this facility and provides an adequate means to address this concern. 1C
.Any owner or operator ofan offset lithographic or letterpress printing operation, who is subject to this Chapter, must demonstrate compliance by 12 months fromthe effective date ofthis Chapter
. For a source that commences operationafterthe effective date of this Chapter, the owner or operator must determine compliance status by 12 months after the date on which the source commences operation
. Any owner or operator ofan offset lithog)raphic or letterpress printing operation who is subject to this Chapter and has a BACT analysis included in an air emission license must demonstrate compliance pursuant to their air emission license conditions
. 4) Comment on Applicability Section 1D : Section 1D should be reworded as follows in order to stay consistent with the definitions provided in Section 2 ofthis rule:1 D
. Any facilitythat becomes or is currently subject to these provisions because its emissions, before controls, equal or exceeds 3 tons per rolling twelve monthperiod or, greater than 768 gallons ofcleaning solutions, alcohol fountain solution, alcohol substitutes and heatset ink purchased or use per 12 month rolling period, will remain subject to the provisions for three years after the emissions fall below and remain below the 3 tons per year applicability threshold
. (Commentor #2) Response: PerAGrecommendations, the language has been changed for clarification purposes as shown below

. The three tons ofVOC emissions is equivalent to the product thresholds that were identified in 1B
. Those equivalent product thresholds approved by EPAwere included in 1Bto simplify the recordkeeping process for small printing operations
. 1D
. Any printing operation that is subject to this Chapter due solely to exceeding the applicability threshold of three tons ofVOCemissions per year in subsection 1 B and whose VOCemissions subsequently fall belowthat applicability threshold for a rolling 12 month period will remain subject to the requirements of this Chapter for three years following the conclusion of that 12 month rolling period
. The printing operation will become subject to this Chapter anew upon exceeding any applicability threshold set forth in subsection 113
. 5) Comments on Definitions Section 2 E and F, and Emission Control Limits Section 3B(4) : There are some differences in the way the control device requirements in this newrule conflict with procedures currently in place as BACT license requirements for the Dingley Press facility
. (Commentor#3) Response: The following definitions and modifications to allowfor optional BACT/CAM protocol were added to the rule in Sections 2 and 3B(4) : 2E
. BACT
. "BACT" means Best Available Control Technology as defined in Definitions Regulation 06-096 CMR100(last amended December 24-2005)
. 2F
. CAM

. "CAM" means Compliance Assurance Monitoring as described in 40CFR Part 64. . 3B (4)An owner or operator ofa heatset lithographic or heatset letter press printing press and dryer(s) equipped with a control systemshall maintain the dryer air pressure lower than the pressroomair pressure at all times the press is operating; and ensurethat : (a) The capture systemand control device are operated at all times thatthe printing press is in operation; and the manufacturer's minimumrecommended operating temperature for the control device or licensed limit or as otherwise specified in a BACT or CAM

analysis included in a license issued after 1997 shall bemaintained whenever the presses are in operation, and (b) The control device is equipped with the applicable monitoring equipment specified in Section 4Compliance Test methods, and the monitoring equipment is installed, calibrated, operated, and maintained according to the manufacturer's specifications or as otherwise specified in a BACT or CAM analysis included ina license issued after 1997 at all times the control device is in use.6) Comment on Emission Control Limits Section 3A(4) : This suggested language may help

adjust limits to accommodate scalable need ofsmall verses larger facilities: Section 3A(4)
. Cleaning Solution Limits: For non - press or press parts cleaning processes, a facility is allowedto use a maximum110 gallons of higherVOCcontent cleaning solvents for each .press line at the facility within any consecutive twelve month period
. (Commentor #3) Response: This change was not incorporated into the rule because it would alter the applicability threshold beyond the levels that are specified bythe EPA CTGlimits
. 7) Comment on Compliance Test Methods Section 4A(3)(e) : Dingley requests some modifications to the control systemtesting requirements in this rule
. (Commentor #3) a) Pursuant to the Dingley Press 1997 BACT/CAM analysis and EPA method 25 and 25A, stack testing protocol has previously allowed for modification of probe temperature to prevent condensation and the riskof fire damage
. Dingley Press very often uses Method 18 testing to determine methane (exempt VOC) concentration and subtract this fromthe VOCmeasurement . b) The testers typically heat the lines to about 320degrees F but the requirement to at least match the flue gas temperature may be challenging
. Functionally APCC and DEPstack testers have worked this out. APCC uses very hot (350+) sample lines to minimize/eliminate condensation to ensure accurate results
. This is all disclosed in the stack testing protocol reviewed and approved by DEP on a case by case basis
. Response: To maintain as much flexibility as possible for other facility; the AGhas recommended the following changes in order to ensure the process meets license and EPA requirements, yet prevents fire damage concerns. 4A(3)(e) (iii) US EPA Method 25 specifies a minimumprobe temperature oftwo hundred sixtyfive degrees Fahrenheit
. The probe shall be heated to at least the temperature required to prevent condensation as specified in the stacktest protocol required by the governing air emission license, or otherwise approved in writing by the Department and EPA
. (iv) US EPA Method 25Aspecifies a minimum temperature of two hundred twenty degrees Fahrenheit for the sampling components leading to the analyzer
. The sampling components and flame ionization detector block shall be heated to at least the temperature required to prevent condensation as specified in the stack test protocol required by the air emission license, or otherwise approved in writing by the Department and EPA
. 8) Comments on Section 5A Recordkeeping: a) Dingley Press is concerned about the added expense ofoperating the thermal oxidizers and its catalytic oxidizer with the new 3-hr temperature averaging requirements specified in this draft rule
. The facility's license requirements currently allowrecording and downloading data every fewseconds with no averaging requirements
. To meet the new requirements would require Dingley to purchase and implement a new and expensive software programthat wouldcalculate the averaging times
. In addition, theirexisting protocol shuts the systemdown as soon

as temperature limits are exceeded; it is therefore more protective ofair quality
. (Commentor #3) b) The temperature parameters specified in the rule are atypical for the current operating systemand are not appropriate for use as the required systemshutdown threshold
. This is tricky because Dingleys RTOs (thermal oxidizers) were each required by BACT after 1997 and some ofthe monitoring conditions have been amendedover the years by Chapter 115 and 140 licensing actions including CAM
. We believe that for minor modifications it is possible that DEP issue BACT conditions without EPAreview/approval
. (Commentor #3) c) In addition, Dingley is currently making changes to its control configuration and may not use its catalytic oxidizer much, ifat all, over the next few years. We request DEPadd an alternative testing timeframe for this systembased on usage. (Commentor #3) Response: Dingley Press is subject to BACT, a more stringent level ofair emission control
. The BACT analysis and air emission license protocol currently in place for this facility are more protective ofair quality than RACT requirements specified in Chapter 161 and have, therefore, been incorporated into the rule to accommodate these concerns. Arecordkeeping protocol based on oxidizer systemusage is a reasonable and cost effective strategyand has been incorporated into the rule and additional clarification in the formofa note was addedto reduce confusion for facilities that operate both types ofsystems. 5Alb (ii) For thermal oxidizers, for each dayofoperation ofthe press: Alog or record using a shorter averaging period approved in writingbythe Commissioner and EPA, and as applicable, documenting any shutdowns trig eg red by an oxidizer shutdown threshold temperature as otherwise specified in a BACT analysis or CAM

requirement included in an air emissions license after 1997: and 5A1(c) (ii) For catalytic oxidizers, for each day ofoperation ofthe press: A log or record using a shorter averaging period approved in writing by the Commissioner and EPA, and as applicable, documenting any shutdowns triggered by an oxidizer shutdown threshold temperature as otherwise specified in a BACT Analysis or CAM

requirement included in an air emissions license after 1997; and Note: For thermal oxidizers, an owner or operator must comply with either subsection (1)(b)(i) or (1)(b)(ii), but must also comply with subsection (1 (b)(iii)
. Forcatalytic oxidizers, an owner or operator must comply with either subsection (l)(c)(i or (1)(c) ii , but must also comply with subsection (1 )(c)(iii)
. 5A(1)(d) For catalytic oxidizers, the catalyst bed material shall be inspected annually, for years in which the unit is operated for at least 1000 hours, for general catalyst condition and any signs ofpotential catalyst depletion
. The owner oroperator shall also collect a representative sample ofthe catalyst fromthe oxidizer, per manufacturer's recommendations, and have ittested to evaluate the catalyst's capability to continue to function at or above the requiredcontrol efficiency
. An evaluation ofthe catalyst bed material shall be conducted whenever the results ofthe inspection indicate signs ofpotential catalyst depletion or poor catalyst conditionbased on manufacturer's recommendations, but not less than once every five years, ret;ardless ofusage. 9) Comment onthe Recordkeeping Section 5A(2)(a) : The correct reference in Section 5A(2)(a) should be 4B(4) of the rule instead ofthe previously numbered 3 B(4) . (Commentor #2) Response: The suggestedcorrection has been incorporated
. 10) Comment on Recordkeeping, paragraph 5A(4) - The terminology "non-heatset web offset" was removed fromparagraph 5A(4) in order to capture the recordkeeping ofany type of lithographic press that does not use a recipe log or that alters a batch offountain solution
. Ifthe Department prefers to keep a separate paragraph for non-heatset web offset lithographic printing, item(b) should be removed because alcohol is not allowed in fountain solutions for non-heatset web offset lithographic printing
. A separate paragraph for heatsetweb or sheet-fed offset lithographic printing presses should include items (a through (e) as written since alcohol is allowed inthe fountain solutions for these types of presses. (Commentor #3) Response: The suggested terminology has been clarified to cover both alcohol and alcohol substitute processes yet avoid further redundancy inthe rule as follows
. 5A (4) The owner or operator ofa subject non h°a's°' web off set lithographic printing press not maintaining a recipe log in accordance with Section 5A(3) above, shall maintain records for each batch offountain solution prepared for use inthe press, including: (a) The volume and VOC content of M concentrated alcohol substitute, addedto make a batch offountain solution, based upon the manufacturer's laboratory analysis using US EPA Method 24
. (b) The volume ofany alcohol addedto make eachbatch offountain solution
.