STATE OF MAINE 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

JOHN ELIAS BALDACCI 

GOVERNOR 

MEMORANDUM 

TO : 

FROM: 

DATE: 

RE: 

wford, Bureau of Air Quality 

il 15, 2010 

Adoption: Chapter 123 Control of Volatile Organic Compounds from Paper, Film 

and Foil Coating Operations 

Statutory and Regulatory Reference: 

A. 

B. 

Statutory authority. 

38 MRSA Section 585-A provides that the Board of Environmental 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." 

Specific legal mandates requiring adoption. 

Section 184 of the 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. 

EPA developed a CTG that included paper coatings, Control of Volatile Organic 

Emissions from Existing Stationary Sources- Volume IT Surface Coating of Cans, Coils, 

Paper, Fabrics, Automobiles and Light-Duty Trucks (1977) and created an updated 

version, Control Technique Guidelines for Paper, Film and Foil Coatings, in September 

2007. 

Location/Applicability: 

The regulation will apply statewide. 

AUGUSTA 

17 STATE HOUSE STATION 

AUGUSTA, MAINE 04333-0017 

(207) 287-7688 FAX: (207) 287-7826 

RAY BLDG., HOSPITAL ST. 

DAVID P. LITTELL 

COMMISSIONER 

Board of Environmental Protection 

BANGOR PORTLAND PRESQUE ISLE 

106 HOGAN ROAD, SUITE 6 312 CANCO ROAD 1235 CENTRAL DRIVE, SKYWAY PARK 

BANGOR, MAINE 04401 PORTLAND, MAINE 04103 PRESQUE ISLE, MAINE 04679-2094 

(207) 941-4570 FAX: (207) 941-4584 (207) 822-6300 FAX: (207) 822-6303 (207) 764-0477 FAX: (207) 760-3143 

web site : www.maine .gov/dep 
Background: 

Section 184 of the 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. EPA defines RACT as 

the lowest emission limit that a particular source is capable of meeting by the application of 

control technology that is reasonably available considering technological and economic 

feasibility. In May 1977, EPA published a CTG for controlling VOC emissions from surface 

coating of paper, which it updated in September 2007. 

The paper, film and foil coatings include coatings that are applied to paper, film and foil surfaces 

in the manufacturing of several major product types including pressure sensitive tape and labels, 

industrial and decorative laminates, and photographic film. This category also includes coatings 

applied during miscellaneous coating operations of corrugated and solid fiber boxes and folding 

paperboard boxes. 

The current Chapter 123 only regulates surface coating of paper. The proposed amendments will 

add control requirements for the surface coating of film and foil substrates . In addition, the 

proposal incorporates work practices to minimize VOC emissions. 

The Department is proposing these amendments as part of its effort to satisfy the RACT 

requirements mandated under the CAA and regulations related to the 1997 8-hour ozone 

NAAQS. According to the EPA's Final Rule to Implement the 8-Hour Ozone NAAQS (70 FR 

71612, November 29, 2005), areas classified as "moderate" nonattainment or higher l must 

submit a revision to the SIP rules for all CTG categories . The proposed amendments to Chapter 

123 will fulfill Maine's requirement to promulgate rules and implement controls meeting the 

2007 CTG for paper, film and foil coatings . 

Discussion: 

Based on comments received from six people during the comment period, the Department 

amended its original proposal in the following areas (shades areas in the attached rule): 

Applicability: The rule explicitly states that the following activities as outlined in the CTG 

guideline are not regulated by Chapter 123 : (1) size presses and on-machine coaters on 

papermaking machines that apply sizing or water-based clays; (2) the application of inks, 

coatings or adhesives in association with flexible package printing; and (3) coating performed on 

or in-line with any offset lithographic, screen, letterpress, flexographic, rotogravure or digital 

printing press. In addition, an exemption is included for off-machine coaters used in the 

papermaking process that use coatings with a VOC content less than 2.9 lbs VOC/gallon. 

Definitions: The Department added a definition for off-machine coater used in the paper making 

process. 

1 Maine is treated as a moderate nonattainment area under the Clean Air Act by way of its inclusion in the Ozone 

Transport Region . 
Work practices: The Department clarified that most of the work practices listed in Section 4 of 

the rule apply to coatings or cleaning solvents containing greater than 2.9 lbs VOC/gallon. In 

addition, the amendments give the sources some flexibility in disposal of VOC-containing 

coating and cleaning solvents by complying with their air emission license requirements . 

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 of 

ozone impedes the breathing of even healthy people. 

Departmental Recommendation: 

The Department recommends that the Board adopt Chapter 123 as presented. 

Estimated Time of Presentation : 

15 minutes