JOHN ELIAS BALDAC'CI GOVERNOR DAVID P. LITTELL COMMISSIONER



### MEMORANDUM TO : Board of Environmental Protection FROM : DebAvalone-King, Bureau ofAir Quality DATE: March 18, 2010 RE: Request to Adopt: Chapter 161 Graphic Arts - Lithography and Letterpress Printing Statutory and R

egulatory Reference: A . Statutory authority. 38 MRSA Section 585-A provides that the Board ofEnvironmental Protection "may establish and amend regulations to implement ambient air quality standards and emission standards. These regulations shall be designed to achieve and maintain ambient air quality standards and emission standards within any region and prevent air pollution." 

### B. Specific legal mandates requiring adoption. Section 184 ofthe Clean Air Act requires states to implement or update reasonably available control technology (RACT) controls on all major VOC and NOx emission sources and on source categories covered by a Control Technique Guideline (CTG) document . EPAdefines RACT as the lowest emission limit that a particular source is capable ofmeeting by the application ofcontrol technology that is reasonably available considering technological and economic feasibility. In September 2006, EPA published a CTGfor offset lithography printing operations which recommended specific limits for chemicals and processes used in these operations. Location/Applicabili ty_ : The proposed regulation will apply statewide.

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.marnc.gov/dcpMemo to BEP

March 18, 2010 Page 2of 2 

### Description: Background: Many inks, fountain and cleaning solutions used in graphic arts contain volatile organic compounds (VOC), which are precursors to ground-level ozone formation. This regulation restricts the VOC emissions fromoffset lithography and letterpress printing operations. Under Section 184 ofthe Clean AirAct Amendments of 1990, the State must submit plans to control VOC emissions fromall sources covered by a Control Technique Guideline (CTG) issued by US EPA . This regulation requires all sources within this category to determine their emission levels and implement reasonable options for keeping such emissions at a minimum, in a cost effective way that includes: control technology approaches, VOC and composite vapor pressure limits and standards for work practices. The rule provides a variety of approaches for managing VOCemissions and complying with the limits stipulated in the rule with flexibility for sources to implement the limits in the manner that is most suitable for their facility. 

### Environmental Issues : Volatile organic compounds contribute to ground-level ozone formation or smog which aggravates respiratory ailments such as asthma, bronchitis, and emphysema. The presence ofozone impedes the breathing of even healthy people and exacerbates existing respiratory and heart health conditions. Epidemiologic studies show that long-termexposure to ozone causes premature aging ofthe lungs and decreases in lung capacity and function. Though children, the elderly and those with heart disease or respiratory problems like asthma and emphysema are at particular risk, about 20percent of otherwise healthy adults are unusually sensitive to ozone's effects, experiencing symptoms like coughing, wheezing and pain when they breathe deeply in highly polluted areas. 

### Significant Changes Were Addressed in Second Opportunity to Comment period: A number ofcomments were received as a result ofthe first comment period that have been incorporated into Chapter 161 including: 1) a clarification ofthe applicability threshold and related recordkeeping requirements; and 2) inclusion of BACT related alternatives for compliance test methodology, recordkeeping requirements and oxidizer operating systemparameters . At that point the Board directed the Department to repost the rule for a.second comment period to allow an additional opportunity for public comment on those significant modifications. 

### Departmental Recommendation: The Bureau now

seeks approval of the proposed new regulation, Chapter 161 ; with amendments as outlined in the Final Rule and Supplemental Basis Statement. Estimated Time of Presentation: 20minutes