UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 1 

April8, 2010 

Jeff Crawford 

Bureau of Air Quality 

5 POS7 OFFICE SQUARE, SUITE 100 

BOSTON, MA 02109-3912 

Maine Department of Environmental Protection 

SIIS17 

Augusta, ME 04333 

Dear Mr. Crawford: 

Thank you for the opportunity to review your proposed regulation, Chapter 154, 

developed by the Maine Department of Environmental Protection (DEP) aimed at 

controlling air emissions from flexible package printing. 

EPA Region 1 staff have 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 

proposed rule. 

If you have any questions regarding this matter, please contact Ariel Garcia of my staff at 

61 7-918-1660. 

Sincerely, 

/\nne 

0~~-f Arnold, Manager 

Air Quality Planning Unit 

cc: Deborah Avalonc-King, ME DEP 

Toll Free •1-888·372·7341 

Internet Addr&ss (URL) • http://www.epa.gov/region1 

Recycle~ecyclable • Printed with Veg•tabl• Oil Based Inks 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 (EPA453/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 of 40 CFR Part 51 Appendix M) and other relevant test 

methods and compliance procedures, such as those found in Appendix A of Maine's existing Chapter 

132 graphic arts rule, as well as monitoring provisions to ensure continued compliance, such as those 

found in Section 7(D)(2)(g) through (k) of Maine'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 of VOC from the use of inks, 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 requirements of Section 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 of the rule include a 

provision requiring facilities v.ith emissions below the applicability threshold to calculate their 

potential VOC emissions before the application of control devices, similar to section 7(A)(l)(d) 

of Maine's existing Chapter 132 graphic arts rule. 

5) Page 3, Section S.B.: For consistency with the recordkeeping requirements of the 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 of at least fiye (5)!!.!..@ years and made 

available to the Department, or US EPA, to inspect and copy upon request." 
06-096 

Chapter 154: 

DEPAKTMENT OF ENVIRONMENTAL PROTEcrTON 

DRAFT 

Control of Volatile Organic Compounds from Flexible Package 

Printing. 

SUMMARY: This regulation limits emissions of volatile organic 

compounds 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 controls, of at least 25 tons per year ofVOC from the use of inks, coatings and 

adhesives combined. 

B. Facilities with flexible package printing presses with a potential to emit of less than 25 

tons per year ofVOC from the use of inks, coatings and adhesi,ves combined, are 

required to meet only the work practice requirements in Section 5 and the 

recordkeeping requirements in Section 6 of this Chapter. 

2. Definitions. 

A. Air pollution control equipment efficiency. "Air pollution control equipment 

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 

pollution 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, expressed as a percentage. 

C. Cleaning. "Cleaning" means, with respect to a flexible package printing press or 

presses, cleaning of a press or press parts or the removal of dried ink from areas 

around the press. "Cleaning" does not include cleaning of electronic components, 

cleaning in platemaking or binding operations, housekeeping activity near a press or 

the usc of a parts washer or cold cleaner. 

D. Flexible package. "Flexible package" means any package or part of a package the 

shape of which may be readily changed. A "flexible package" may be in the form of a 

bag, pouch, liner or wrap made of paper, plastic, film, aluminum foil, or metalized or 

coated film or paper, alone or in combination. None of the following are considered a 

"flexible package" : a folding carton, self-adhesive labels, gift wrap, wall covering, 

vinyl products, decorative laminates, floor coverings or tissue products. 

E. Flexographic print station. "Fiexographic print station" means a work station on 

which a flexographic printing operation is conducted. A flexographic print station 

includes a flexographic printing plate, which is an image made of rubber 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 

if the equipment is moved to a new location at the same premises. 

Chapter 154: Control ofVolatile Organic Compounds from Flexible Package Printing 

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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 of hazardous wastes, including waste VOCs 

and cloth or paper impregnated with such waste are subject to hazardous waste 

management standards as set forth in Maine'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 of the information necessary to demonstrate compliance 

with 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 of Material Safety Data Sheets for all inks, coatings and cleaning 

solvents used, · 

( 4) Documentation of air pollution control equipment efficiency or capture 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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