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 fromPaper, 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 AirAct requires states to implement or update reasonably available control technology (RACT) controls on all majorVOCand NOx emission sources and on source categories covered by a Control Technique Guideline (CTG) document . EPAdeveloped a CTGthat included paper coatings, Control of Volatile Organic EmissionsfromExisting Stationary Sources- Volume IT Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles and Light-Duty Trucks (1977) and created an updated version, Control Technique Guidelinesfor Paper, Filmand Foil Coatings, in September 2007. Location/Applicabi lity: Theregulation will apply statewide.

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Board of Environmental Protection

BANGOR PORTLAND PRESQUE ISLE 106 HOGANROAD, SUITE 6 312 CANCOROAD 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/depBackground:

Section 184of the Clean Air Act requires states to implement or update reasonably available control technology (RACT) controls on all major VOCand 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, EPApublished a CTGfor controllingVOCemissions fromsurface coating ofpaper, which it updated in September 2007. The paper, filmand foil coatings include coatings that are applied to paper, filmand 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 offilmand foil substrates. In addition, the proposal incorporates work practices to minimize VOCemissions. The Department is proposing these amendments as part ofits 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 higherl must submit a revision to the SIP rules for all CTGcategories. The proposed amendments to Chapter 123 will fulfill Maine's requirement to promulgate rules and implement controls meeting the 2007 CTGfor paper, filmand 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 VOCcontent 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 ofits 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. Departm

ental Recommendation: The Department recommends that the Board adopt Chapter 123 as presented. Estimated Time of Presentation : 15 minutes