SUPPLEMENTAL BASISSTATEMENT

CHAPTER 123 CONTROL OF VOLATILE ORGANICCOMPOUNDS FROM PAPER, FILM ANDFOIL COATINGOPERATIONS APRIL 15, 2010 Commenters 1 . Thomas Griffin Sappi Skowhegan, Maine 2 . Dixon Pike Pierce Atwood Portland, Maine 3. Joe Lynch Verso Paper Bucksport, Maine 4 . Jeffrey O'Hearn PanolamIndustries Shelton, Connecticut 5 . Steven Whipple Woodard and Curran Portland, Maine (representing Dingley Press) 6 . Michael Obrien Auburn Manufacturing Mechanic Falls, Maine _Applicability l . Comment : Based on language fromthe EPA's Control Techniques Guideline (CTG) document for paper coating, the commenters urge the Department to include a sentence in Section 1(B) clarifying that the rule does not apply to size presses and on-line coaters on paper machines. EPA's CTGdocument states that: "Size presses and onmachine coatings that function as part of an in-line papermaking systemare not part of the paper, filmand foil coatings category." (commenters 1, 2, 3) In addition, commenter 3 requests that the Department exempt off-machine coaters when they are used as part of the papermaking system . The difference between the two types is in machine design. One has the coating applied on the machine and the other istransported fromthe machine to an off-machine coater where the paper making process is

completed. The type and amount ofVOCemissions, while extremely minute, are the same and the end product is no different. Both machines apply water-based clay coatings. The only difference is one machine has an on-machine coater and the other uses an off-machine coater . (commenter 3) Response: To clarify that Chapter 123 does not apply to this process, the Department added a new

subsection (Section 1(C)) thatprovidesfor exempted activities and included a definition for off-machine coater in Section 2 . The Department agrees that the offmachine coater should also be exemptfor the reasons stated by the commenter. Section 1(C) This regulation does not apply to the followinZ activities: 1 Size presses andon-machine coaters on papermaking machines that applysizing (e.g., starch) or water-based clays; 2 Ofmachine coaters used in thepaper making process that use coati ngs with a VOCcontent less than 2.9.lbs VOC/ ag l,_ lon; 3 The application ofinks coatings or adhesives in association with flexible package printing; or 4 Coating performedon or in-line with any offset lithographic, screen, letterpress flexo,~raphic rotogravure or digital printing press. 2 . Comment : Facilities where the total actual VOCemissions fromall paper, film and foil coating operations, including related cleaning activities, do not exceed 6 .8 kg/day (15 lbs/day) or an equivalent level such as 3 tons per 12-month rolling period, before consideration of controls should be exempt . This is consistent with the recommendations in EPA's CTGfor Paper Coaters. (commenter 5, 6) Response: After careful review, the Department has determined that Dingley Press is not subject to Chapter 123 but is regulated by the Department's Chapter 161 GraphicArtsOffset Lithography and Letterpress Printing. Auburn Manufacturing is not subject to Chapter 123, but may be subject to the Department's Chapter 129Surface Coating Facilities ifits VOC

emissions are above the applicability level in the rule. No change to the rule. 3. Commenter 6 adds that his company manufactures technical fabrics and applies coatings to them

. Some ofthe coatings are simple pigmentation for identification purposes, such as pigmenting a fiberglass fabric with a "safety" orange color. Most of our coatings are delivered from water-base, latex systems which generally have very low VOClevels. (commenter 6) Response: Chapter 123 applies to fabric coatingfor use in abrasive products only. Fabric coatingfacilities are subject to Chapter 129Surface Coating Facilities, whichregulates the surface coating offabric, cans, vinyl, fatwoodpaneling, metalfurniture,

and miscellaneous metalparts. Auburn Manufacturing Inc . may be subject to Chapter 129 ifits VOC

emissions are above the applicability level in the rule. 4 . Comment : Coating performed on, or in-line with any offset lithographic, screen, letterpress, flexographic, rotogravure, or digital printing press as it is part ofa printing process and is not part of the paper, filmand foil coating category should be exempt . This is consistent with the recommendations in EPA's CTG for Paper Coaters. (commenter 5) Response: The Department agrees andadded thefollowing language to Section 1(C) indicating the rule does not apply to these activities: The application ofinks, coatinzs or adhesives in association with flexible Package printing; and Coating performed on or in-line with any offset lithographic screen letterpress exo_araphic, roto,eravure ,_ or diQital printinz press. Definitions 5 . Comment : Adefinition should be provided for "filmand foil" . (commenter 4) Response: The Department believes the change in the paper coating definition by adding filmandfoil and a description ofthe coatingprocess in the proposed amendments is sufficient. The commenter does notprovide any reason why the definitions are necessary. Work practices 6 . Comment : The proposed work practice standards found in Section 4 should only apply to coatings containing in excess of 2.9 lbs VOC/gallon of coating (excluding water and negligibly reactive VOC) and not those sources that use coatings that comply with the VOClimits in Section 3(A) of the regulation. The use of closed containers specified in Section 4(A) constitutes a type of emission control equipment, and based on the regulation, use of coatings containing less than 2.9 lbs of VOC/gallon of coating is a pollution prevention approach to compliance which does not require emission control equipment . Most of the coating performed is done with "aqueous-based coating" typically containing only trace amounts of VOC . These are often stored and handled in open tanks. It would be impractical and not cost-effective to force the mills to retrofit all of these existing tanks with covers. (commenters 1, 2) Response: The Department agrees and has added language to Section 4, workpractices, stating that some ofthe workpractices apply to coating applications containing greater than 2.9 lbs VOC

/gallon.7. Comment : Section 4is overly broad and should only apply to sources/process

lines that do not meet the low solvent content technology defined in Section 3(A) or that are subject to 3(B) . Other similar rules such as the EPAFabric Coating MACT Rule have similar work practices requirements that only apply to coatings that are subject to add on controls and not those that are considered "compliant" . In our case, we have a number of coating formulations that are considered compliant under this rule and under the MACT rules and are not controlled in compliance with this regulation. It doesn't seem realistic to be subject to the proposed work practice requirements for VOCin coatings that will normally emit to the atmosphere during their use. Commenter 3 is also requesting that the proposed work practices not applyto those units that use the low solvent content coating technology to meet the proposed limits . (comment 3, 4) Response: The Department agrees that certain workpractices listed in Section 4ofthe rule should only apply to applications using coatings with a VOCcontent greater than 2.9 lbs VOC/gallon and has made that change to the rule. 8 . Comment : While at first glance the work practices look fairly simple, they are not simple for large processes. The large applicators on the coating lines are open as well as the catch basins under the coaters. Whenever there is a break on the machine or when we are changing applicator blades, the applicator vat as well as the catch basins would no longer be in use. It is technically impossible to cover them . They are very large and are part of a very complex machine that requires removable applicators and basins to perform necessary maintenance. Their very design precludes covers. (commenter 3) Response: To clarify that Chapter 123 does not apply to this process, the Department has addeda new

subsection (Section 1(C)) that providesfor exempted activities. Section 1(C) This regulation does not apply to the following activities: 1 Size presses and on-machine coaters on papermaking machines that avplvsizinz (ex

., starch) or water-based clays; 2 Off-machine coaters used in the paper making process that use coatings wi th a VOCcontent less than 2.9 lbs VOC/gallon. 9 . Comment : Section 4(B) should be amended to allowfacilities to treat spills or unused coatings using the facility's wastewater treatment plant . Spills and coating leaks, for example, when changing paper grades (e.g. fromgloss to semi-gloss), cleaning of filters, and coating contamination are washed to the sewer systemand effectively treated by the mills' wastewater treatment systems. Certain coatings contain more than 2.9 lbs VOC/gallon. (commenter l, 2, 3,) Response: The Department agrees that thefacility's wastewater treatment plant can treat spills effectively rather than using absorbent materials that generate additional solid waste

. Also, see response to comment# 1 .10. Comment : The requirement to collect absorbent rags and paper (Section 4(C)) is

overly burdensome and not practical . Section 4(C) requires that absorbent applicators, such as cloth and paper, which are moistened with VOC-containing coatings be stored in closed containers. The term"absorbent applicators" is not defined and therefore it is unclear what is covered under this term . Furthermore, to collect cloth and paper which contain VOCcoating less than 2.9 lb VOC/gallon constitutes a type of emission control . To apply standards which are similar to the collection of flammable hazardous waste rags is not practical and overly burdensome. In addition, commenter 3 states that considering the extremely low

VOCcontent of our coating, it makes no sense to clean up the miscellaneous spills with absorbent materials and thereby generate additional solid waste that needs to be disposed of. This is especially true ifwe were to have avalve or hose break. Several hundred gallons could be spilled. It makes much more environmental sense to flush the coating to the sewer where it can be properly treated. (commenter 1, 2, 3) Response: The Department agrees it is appropriatefor thefacility's wastewater treatmentplant to treat spills rather than using absorbent materials because ofthe potentially large volume ofspills and the generation ofadditional solid waste . Also, see response to comment # 1 . Recordkeeping, ret~orting and compliance 11 . Comment : If a source has submitted information in the past under the former version of Chapter 123, is it required to resubmit that information? (commenter 4) Response: Ifa source has submitted information in thepast under the existing Chapter 123, it is not required to resubmit that information. 12. Comment : As a small company with relatively few employees, the cost of record keeping and compliance with Chapter 123 would be burdensome. We would have to divert resources fromother functions for compliance with no benefit for the state and certainly a burden (time/money) for the company. (commenter 6) Response: Thisfacility is not subject to Chapter 123 .