UNITED STATES ENV IRONMENTAL PROTECTION AGENCY REGION 1


### April8, 2010 Jeff Crawford Bureau ofAir Quality 5 POS7 OFFICE SQUARE, SUITE 100 BOSTON, MA 02109-3912



### Maine Department ofEnvironmental Protection SIIS1 7 Augusta, ME 04333 Dear Mr. Crawford: Thank you for the opportunity to review your proposed regulation, Chapter 154, developed by the Maine Department ofEnvironmental Protection (DEP) aimed at controlling air emissions from flexible package printing. EPA Re gion 1 staffhave reviewed the proposed rule and you will ftnd the Agency ' s comments in the Enclosure. We thank you for the opportunity to provide feedback on the pr

oposed rule. If 

### you have any questions regarding this matter , please contact Ari el 

### Garcia ofmy staff at 61 7-918- 1660. Sincerely,

# 0~~-f /\nne Arnold, Manager Air Quality Planning Un it
cc: Deborah Avalonc-King, ME DEP

T

oll Free •1 -888·372·7341 Internet Addr&ss ( URL) • http :/ /www

.epa.gov/region 1**Recycle~ecyclable** • Printed with Veg•tabl• Oil Based I nks on Recycled Paper (Minimum 30•;, Poatconsumer)

### EPA Comments on Proposed Rule Maine's Chapter 154, "Control of Volatile Organic Compounds from Flexible Package Printing" Major Comment 1) Maine's proposal is consistent 

### v..ith EPA's recommended overall emission reduction efficiencies and VOC content limits given in the CTG for Flexible Package Printing (EPA

453/R-06-003 , September 2006). However, the 

### proposed rule does not contain sufficiently detailed provisions to ensure that the proposed requirements are readily enforceable. For example, Section 5(A)(4) of the proposed rule requires a facility to 

### maintain "documentation of air pollution control equipment efficiency or capture efficiency." The rule should be 

### revised to include appropriate test methods and monitoring procedures to ensure compliance with the required overall control efficiency. Specifically, the rule should include reference to EPA's capture efficiency test procedures (Methods 204 and 204A through F of40 CFR Part 5 1 Appendix M) 

### and other relevant test methods and compliance procedures, such as 

### those found in Appendix A ofMaine's existing Chapter 1 32 graphic arts 

### rule, as well as 

### monitoring provisions to ensure continued compliance, such as 

### those found in Section 7(D)(2)(g) through (k) 

### ofMaine's Chapter 132. · 

### Additional Comments 2) Page 1, Section l .B.: The references made to the work practice requirements and the recordkeeping requirements should be to 

### Sections 4 and 5 , respectively
. 3) Pages 2-3 , Section 4
.A.

- 4 .D. and S.A .: As noted in Section 1 (A), the proposed rule (as we11 as 

### EPA's CTG) applies to, "any flexible package printing press that has the 

### potential to emit from the dryer , prior to controls, of at least 25 

### tons per year ofVOC 

### from the use ofinks, coatings and adhesives combined." In addition, the Section 3(A) VOC 

### content limits apply to the use of inks, coatings, and adhesives. Therefore, the record keeping r equirements ofSection S(A) 

### must be 

### revised to include adhesives. Jn 

### addiiton, the 

### work practice requirements of Section 4 

### should also be 

### revised to include adhesives. 4) Page 3, Section S
.A. : We recommend that the record keeping section ofthe rule include a provision requiring facilities v.ith emissions below the applicability threshold to calculate their potential VOC emissions before the application ofcontrol devices, similar to section 7(A)(l)(d) ofMaine's exi sting Chapter 132 graphic arts 

### rule. 5 ) Page 3, Section S.B.: For consistency with the recordkeeping requirements ofthe state operating permit program, the proposed Chapter 154 Section S.B. should 

### be revised to read: "All required records shall be 

### maintained for a period ofat 

### least fiye 

### (5)!!.!..@ years and made available to the Department, or US EPA, to inspect and copy upon request."06-096 Chapter 1 54: DEPAKTMENT OF ENVIRONMENTAL PROTE crTON DRAFT Control of Volatile Organic Compounds from Flexible Package Printing. SUMMARY : This regulation limits emissions of volatile organic compound s from flexible package printers. 1. Applicability. This regulation applies to: A. Any flexible package printing press that has the potential to emit from the dryer, prior to co n trols , ofat least 25 tons per year ofVOC from the use of inks, coatings and adhesives combined. B. Facilities with flexible package printing presses w i th a potential to emit of less than 25 tons per year ofVOC from the use of inks, coa tings and adhesi,ves combined, are required to meet onl y the work practice requirements in Section 5 and the recordkeepi ng requirements in Section 6 ofthis Chapter. 2. Definitions. A. Air pollution control equipment efficiency. 

### "Air pollution control equip ment efficiency" means the ratio ofVOC emissions recovered or destroyed by the air pollution control equipment to the total VOC emissions that are introduced into the air pol luti on control equipment, expressed as a percentage . B. Capture efficiency
. "Capture efficiency" the ratio ofVOC emissions delivered to the air pollution control equipment to the total VOC emissions resulting from flexible package printing activities , expr essed as a percen tage. C. Cleaning. " Cleani ng" means , w i th respect to a flexible package printing press o r presses, cleaning of a press or press parts or the removal of dried ink from areas around the press. " Cleaning" does not include cleaning ofelectronic components, cleaning in platemaking or binding operations, housekeeping activity near a press or the usc of a parts washer or cold c l eaner . D. Flexible package. "Flexible package" means any package or part of a package the shape of w hich may be readily changed. A "flexi ble package" may be in the form of a bag, pouch , liner or wrap made ofpaper, plastic, film, a luminum foil, or metalized or coated film o r paper, alone or in co mbination. None ofthe following are considered a "flexible package" : a folding carton , self-adhesive labels, g ift wrap , wall covering, vinyl products, decorative laminates, floor coverings or tissue products. E. Flexographic print station. "Fiexographi c print station" means a work station on which a flexographic printin g operation is conducted
. A flexographic print station includes a flexographic printing plate , which is an image made ofrubber or other elastomeric material. The image to be printed is raised above the printing plate. F. Installation date. " Installation date " means the first date on which a piece of equipment is in place and prepared to operate. The " installation date " does not change ifthe equipment is moved to a new location at the same prem ises.
Chapter 154: Control ofVolat ile Organic Compound s from F lexible Package Printing

- l -06-096 DEPAKTMENT OF ENVfRONMENTAL PROTEuTON DRAFT
C. Absorbent applicators, such as cloth and paper, which are moistened with VOC containing 

### ink, coating or solvent, shall be stored in a closed, nonabsorbent, nonleaking container for disposal or recycling; 

### D. VOC-containing ink, coating and cleaning solvent shall be conveyed from one location to another in a closed container or pipe; 

### E. Cleaning shall be performed to minimize associated VOC emissions; and NOTE: The handling, storage and disposal ofhazardous wastes, including waste VOC s and cloth or paper impregnated with such waste are subject to hazardous waste manage ment standards as set forth in M aine ' s Hazardous Waste Management Rules, 06- 096 CMR Chapters 850

- 857. 5. Recordkeeping Requirements. A. Beginning January 1, 2011, the owner or operator of any flexible package printing press must maintain records ofthe information necessary to demonstrate compliance wit h the applicable requirements ofthis Chapter, including but not limited to: (1) Name and quantity of any ink, coating or cleaning solvent used, (2) VOC content of each ink, coating or cleaning solvent used, as applied, (3) A catalog ofMaterial Safety Data Sheets for all inks, coatings and cleaning solvents used, · (4) Documentation of air pollution control equipment efficiency or cap ture efficiency, if applicable, and (5) Date and type of maintenance performed on air pollution control or capture equipment, if applicable. B. All required records shall be maintained for a period of at least five (5) years and made available to the Department to inspect and copy upon request.

Chapter 154: Control ofVolatile Organic Compounds from Flexible Package Printing



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