SUPPLEMENTAL BASIS STATEMENT 

CIIAPTER 154, CONTROL OF VOLATILE ORGANIC COMPOUNDS FROM 

FLEXIBLE PACKAGE PRINTING 

Commenters 

1. Anne Arnold 

EPA Region 1 

2. Dixon Pike 

Pierce Atwood 

(representing MPP A) 

JUNE 2010 

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Applicability 

l. Comment: The proposed regulation provides that facilities with flexible package 

printing presses with the potential to emit less than 25 tons per year ofVOC are required 

to meet the work practices and recordkccping requirements in Sections 4 and 5 of the 

regulation. None of the MPP A-member pulp 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 of their 

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 of various paper products and as a sample for 

potential customers. The amount of printing 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 

and development activities should be exempt from the work practice requirements 

contained in Section 4 of the proposal. These activities will, however, be subject o the 

recordkeeping requirements contained in Section 5 of the proposed rule to ensure 

compliance with the 25 tons per year 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 and has 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, 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 

work practice requirements of Section 4 should also be revised to include adhesives. 

(Commenter 1) 

Response: The Department agrees and has made that change. 

Recordkeeping 

4. Comment: Comment: The proposed rule 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 ofVOC 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 recordkeeping requirements of Section 5(A) must be revised to include 

adhesives. (Commenter 1) 

Response: The Department agrees and has made that change. 

5. Comment: EPA recommends the Section 5(A) recordkeeping section of the rule 

include a provision requiring facilities with 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. (Commenter 1) 

Response: The Department has made the suggested changes 

6. Comment: EPA recommends the Section 5(B) recordkeeping section of this rule be 

revised to be consistent with the recordkeeping requirements of Maine's operating permit 

prO&'Tam as follows: 

"All required records shall be maintained for a period of at 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 suggested change. 

7. 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 proposed rule 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 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 of40 CFR 

Part 51 Appendix M) and other relevant test methods and compliance procedures, such as 

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) ofMaine's Chapter 132. (Commenter 1) 

Response: The Department has made the suggested changes.