SUPPLEMENTAL BASIS STATEMENT 

CHAPTER 123 CONTROL OF VOLATILE ORGANIC COMPOUNDS FROM PAPER, 

FILM AND FOIL COATING OPERATIONS 

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 

Panolam Industries 

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 from the 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 CTG document states that: "Size presses and onmachine coatings that function as part of an in-line papermaking system are not part of 

the paper, film and 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 is 
transported from the machine to an off-machine coater where the paper making process is 

completed. The type and amount of VOC emissions, 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)) that provides for exempted activities and included 

a definition for off-machine coater in Section 2. The Department agrees that the offmachine coater should also be exempt for the reasons stated by the commenter. 

Section 1(C) This regulation does not apply to the followinZ activities : 

1 Size presses and on-machine coaters on papermaking machines that 

apply sizing (e.g., starch) or water-based clays; 

2 Of machine coaters used in the paper making process that use 

coatings with a VOC content less than 2.9.lbs VOC/ ag l,_ lon; 

3 The application of inks coatings or adhesives in association with 

flexible package printing ; or 

4 Coating performed on or in-line with any offset lithographic, screen, 

letterpress flexo,~raphic rotogravure or digital printing press. 

2. Comment: Facilities where the total actual VOC emissions from all 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 CTG for 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 Graphic ArtsOffset Lithography and Letterpress Printing. Auburn Manufacturing is not subject to 

Chapter 123, but may be subject to the Department's Chapter 129 Surface Coating 

Facilities if its 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 of the 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 

VOC levels . (commenter 6) 

Response: Chapter 123 applies to fabric coating for use in abrasive products only. 

Fabric coating facilities are subject to Chapter 129 Surface Coating Facilities, which 
regulates the surface coating offabric, cans, vinyl, fatwood paneling, metal furniture, 

and miscellaneous metal parts. Auburn Manufacturing Inc. may be subject to Chapter 

129 if its 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 of a printing 

process and is not part of the paper, film and 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 and added the following language to Section 1(C) 

indicating the rule does not apply to these activities : 

The application of inks, 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: A definition should be provided for "film and foil". (commenter 4) 

Response: The Department believes the change in the paper coating definition by adding 

film and foil and a description of the coating process in the proposed amendments is 

sufficient. The commenter does not provide 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 VOC limits 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 of the work practices apply to coating applications containing greater 

than 2.9 lbs VOC /gallon. 
7. Comment: Section 4 is 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 EPA Fabric 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 VOC in 

coatings that will normally emit to the atmosphere during their use. Commenter 3 is also 

requesting that the proposed work practices not apply to those units that use the low 

solvent content coating technology to meet the proposed limits . (comment 3, 4) 

Response: The Department agrees that certain work practices listed in Section 4 of the 

rule should only apply to applications using coatings with a VOC content 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 added a new subsection (Section 1(C)) that provides for 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 

avplv sizinz (ex., starch) or water-based clays; 

2 Off-machine coaters used in the paper making process that use 

coatings with a VOC content less than 2.9 lbs VOC/gallon. 

9. Comment: Section 4(B) should be amended to allow facilities 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. from gloss to semi-gloss), cleaning of 

filters, and coating contamination are washed to the sewer system and 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 the facility'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 VOC coating 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 VOC content 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 if we were to have a valve 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 appropriate for the facility's wastewater 

treatment plant to treat spills rather than using absorbent materials because of the 

potentially large volume of spills and the generation of additional 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: If a source has submitted information in the past 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 from other functions for compliance with no benefit for the state and 

certainly a burden (time/money) for the company. (commenter 6) 

Response: This facility is not subject to Chapter 123.