SUPPLEMENTAL BASISSTATEMENT C

IIAPTER 154, CONTROL OF VOLATILE ORGANIC COMPOUNDSFROM FLEXIBLEPACKAGEPRINTING

Commenters 1. Anne Arnold EPA Region 1 2. Dixon Pike Pierce Atwood (representing MPP A) JUNE 2010



### ******************************************************************* Applicability l. Comment: The proposed regulation provides that facilities with flexible package printing presses with the potential to emit less than 25 tons peryear ofVOC are required to meet the work practices and recordkccping requirements in Sections 4 and 5 ofthe regulation. None ofthe MPPA-member pu lp and paper mills operate flexible package printing presses to produce marketable flexible package products. However, several of the mills operate flexographic and/or rotogravure printing presses as part oftheir laboratory quality control/quality assurance operations and for research and development purposes. The paper printed for these purposes is not sold or marketed as a product, but is used internally to assess the qualities ofvarious paperproducts and as a sample for potential customers. The amount ofprinting performed is minimal and therefore, the amount ofVOC emitted is very small. The commenter is requesting that printing done for research and development purposes and for quality assurance/control be exempt from this regulation. (Commenter 2) Response: The Department agrees that quality control/quality assurance and research anddevelopment activities shouldbe exempt from the workpractice requirements contained in Section 4 of theproposal. These activities will, however, besubject o the recordkeeping requirements contained in Section 5 of theproposed rule to ensure compliance with the 25 tonsperyear emission threshold. 2. Comment: The references made to work practices requirements and recordkeeping in Section l(B) should be to Sections 4 and 5, respectively. (Commenter l) Response: The Department agrees andhas made that change.Work Practices 3. Comment: The proposed rule applies to any flexible package printing press that has the potential to emit from the dryer, prior to controls, ofat least 25 tons peryear ofVOC from the use ofinks, coatings and adhesives combined. In addition, the Section 3(A) VOC content limits apply to the use ofinks, coatings, and adhesives. Therefore, the work practice requirements ofSection 4 should also be revised to include adhesives. (Commenter 1) Response: The Department agrees andhas made that change.
Recordkeeping 4. Comment: Comment: Theproposed rule applies to any flexible package printing press that has the potential to emit from the dryer, prior to controls, ofat 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 ofinks, coatings, and adhesives. Therefore, the recordkeeping requirements ofSection 5(A) must be revised to include adhesives. (Commenter 1) Response: The Department agrees andhas made that change. 5. Comment: EPA recommends the Section 5(A) recordkeeping section ofthe rule include a provision requiring facilities with emissions below the applicability threshold to calculate their potential VOC emissions before the application ofcontrol devices, sim ilar to Section 7(A)(l)(d) ofMaine's existing Chapter 132 graphic arts rule. (Commenter 1) Response: The Department has made the suggested changes 6. Comment: EPA recommends the Section 5(B) recordkeeping section ofthis rule be revised to be consistent with the recordkeeping requirements ofMaine's operating permit prO&'Tam as follows: "All required records shall be maintained for a period ofat least five (5) six (6) years and made available to the Department, or US EPA, to inspect and copy upon request." (Commenter 1) Response: The Department has made the suggestedchange

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. Comment: Maine's proposal is consistent with EPA's recommended overall emission reduction efficiencies and VOC content limits given in the CTG for Flexible Package Printing. However, the proposedrule does not contain sufficiently detailed provisions to ensure that the proposed requirements are readily enforceable.For example, Section 5(A)( 4) requires a facility to maintain "documentation ofair 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 51 Appendix M) and otherrelevant test methods and compliance procedures, such as found in Appendix A ofMaine'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) ofMaine's Chapter 132. (Commenter 1) Response: The Department has made the suggested changes.