Page 1 1 STATE OF MAINE 2 BOARD OF ENVIRONMENTAL PROTECTION 3 4 5 6 7 IN RE: CHAPTER 123: CONTROL OF VOLATILE ORGANIC COMPOUNDS 8 FROMPAPER, FILMAND FOIL COATING OPERATIONS 9 10 11 12 PRESIDING OFFICER: SUSAN LESSARD, CHAIRPERSON 13 14 15 This hearingwas held pursuant to Notice at the 16 Augusta Civic Center, Civic Center Drive, Augusta,

Maine, on January 7, 2010, beginningat 9:00a.m . 17 18 19 20 21 22 23 24 25ALLEY & MORRISETTE REPORTING SERVICE 207-495-3900 Page 2
1 (This hearing was held before the Board 2 of Environmental Protection, Augusta Civic Center, 3 Civic Center Drive, Augusta, Maine, on January 7, 4 2010, beginning at 9:00 a.m .) 5 6 HEARING OFFICER LESSARD: Good morning. 7 The Board of Environmental Protection is holding a 8 public hearing today on Chapter 123, Control of 9 Volatile Organic Compounds fromPaper, Filmand 10 Foil Coating Operations. 11 My name is Susan Lessard. I amthe Chair of 12 the Board of Environmental Protection, and Iwill 13 be the presiding officer today. Other Board 14 members here today are Richard Gould, Wing 15 Goodale, Andy Nixon, Nancy Ziegler and Frank 16 Woodard. Staff here today fromthe Department of 17 Environmental Protection, Bureau of Air Quality 18 are Jeff Crawford and CarolynWheeler. Our 19 recorder is Joanne Alley of Alley &Morrisette 20 Reporting Services. This is Lissa Widoff, our 21 other Board Member, who is nowhere. 22 Today's hearing is being held pursuant to 38 23 M

.R.S.A., Sections 585-A and 345-Aand the Maine 24 Administrative Procedures Act. In addition, 25 because this rule will be submitted as a revisionALLEY & MORRISETTE REPORTING SERVICE 207-495-3900 Page 3 1 of Maine's State Implementation Plan for Air 2 Quality, today's hearing will be conducted 3 pursuant to the requirements of Title 40, Part 51 4 of the Code of Federal Regulations
. 5 Notice of today's hearing was published in 6 the Kennebec Journal on December 8th, 2009 and in 7 the Kennebec Journal, Lewiston Daily Sun, Morning 8 Sentinel, Portland Press Herald and Bangor Daily 9 News on December 16th, 2009. Notice of today's 10 hearingwas also sent to all persons on the 11 Department's regulatory notice mailing list, 12 affected sources listed in the Bureau's inventory 13 database and to other persons who have expressed 14 interest in the rule that is the subject of 15 today's_hearing. 16 The record for written comments shall remain 17 open until 5 p.m . on January 19th, 2010. All 18 written testimony should be addressed to the 19 Bureau of Air Quality and clearly marked as 20 follows: for inclusion in theJanuary 7, 2010 21 Chapter 123 public hearing record. 22 Today's hearingwill be transcribed and made 23 available to all Board members. Based on the 24 complete record, the Boardwill vote to approve,25 deny or amend the proposed rule at a regularly

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207-495-3900 Page 4 1 scheduled Boardmeeting. Copies of the final 2 staff recommendation will be available upon 3 request before the rule is presented for 4 adoption. An attendance sheet is presently 5 circulating the roomfor those interested in being 6 on a mailing list for this rule. 7 Procedures call for presentations first, by 8 proponents, second, by opponents and, third, by 9 other interested parties neither for nor against. 10 If you plan to speak and have not already done so, 11 please sign in nowon the appropriate speakers' 12 sheet in the back of the roomwhere Ms. Bertocci 13 is. Following each presentation therewill be an 14 opportunity for members of the Board to direct 15 questions through the Chair. Copies of the 16 proposed rule arealso available on the table by 17 the door. 18 At this time I would askall personswho 19 intend to testify to please stand to be sworn in. 20 Do youswear to tell thewhole truth and nothing 21 but the truth? 22 MR. CRAWFORD: I do. 23 HEARING OFFICER: Thank you. Are there any24 questions? If there are no questions, we will 25 hear testimony beginningwith the staff. Good

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207-495-3900 Page 5 1 morning, Mr. Crawford. 2 MR. CRAWFORD: Good morning, Chairperson 3 Lessard and Members of the Board. I'mJeff 4 Crawford and I'mwith the Bureau of Air Quality
. 5 Today's public hearing is in regard to 6 proposed amendments to our existing Chapter 123 7 Paper Coating Regulation. Chapter 123 originally 8 addressed only the coating of paper, and EPA 9 recently updated its control technique 10 guidelines. These are requirements that EPA 11 publishes occasionally to address major sources or 12 larger sources, if youwill, of VOC and NOx 13 emissions. In September of 2006, EPApublished an 14 updated CTGthat amended the existing paper 15 coating requirements to also include filmand foil 16 coating operations. 17 Let me just give you a little bit of 18 background. What exactly are paper, filmand foil 19 coat operations? Basicallywe're talkingabout 20 the application of coatings across thewidth or 21 portion of paper, filmand foil to create a 22 functional or protective layer, saturated23 substrate for lamination or provide adhesion 24 between two substrates for lamination. There's a 25 lot of coating and printing operations covered by

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1 various control technique guidelines or CTGs. I 2 believe we're currently in rulemaking on Chapter 3 161 whichwas the offset lithography. There are a 4 variety of surface coating operations and, in 5 fact, later this morning I will be posting I hope 6 Chapter 154whichwill be addressing flexible 7 package printing. So this is a very specific 8 subset of those operations. 9 An example of type of operations would be 10 primarily the coating and lamination of substrates 11 such as Formica, Wilsonart and, in fact, here in 12 Mainewe have Panel Lamwhichalso makes these 13 products. During the posing to these proposals, 14 the question came up whether or not this rule 15 would, in fact, affect any of the paper mills and 16 it has subsequently come to my attention that 17 there are several mills that do some operations 18 that fall under these definitions, and they will 19 be submitting comments. I believe, my 20 understanding is, that, in fact, they are already 21 meeting theVOCcontrol limit requirements of this22 rule
. So I think primarily some of thework 23 practice requirements, which Iwill be getting to, 24 might be the principal changes that would affect 25 them

.

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207-495-3900 Page 7 1 What we have done is in addition to paper 2 coating, we've added filmand foil coating and 3 basically allowthe use of either a lowsolvent 4 coating technology, so you can either go with a 5 coating that has a very lowVOC concentration or 6 add on equipment, and this is consistent with most 7 of our surface coating and coating operation 8 rules. For pressure sensitive tape and label 9 coatings we've also established a slightly 10 different standard, a different operation and it 11 does not really fall completely the same as, you 12 know, coating of paper, filmandfoil, the 13 Wilsonart laminates, if youwill . 14 I would like to talk very briefly
. One 15 significant addition to the existing rule is for 16 work practices, andwe are proposing that sources 17 institute a number of newwork practices to 18 control VOCemissions
. I mean, many of these are 19 fairly low-hanging fruit and common sense things, 20 if you will, keep your containers closed, make21 sure that the containers are not leaking or are 22 nonabsorbent . If we are going to be using 23 absorbent applicators such as cloth and paper they 24 should be stored in a closed, non-absorbant, non25 leakingcontainer. VOCcontaining coating or

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207-495-3900 Page 8 1 solvents should be conveyed fromone location to 2 another in a closed container or pipe and, in 3 general, cleaning should be performed to minimize 4 associated VOC emissions. 5 I previously mentioned that subsequently it 6 had come to my attention that one or two of the 7 mills, perhaps three, do some operations that fall 8 under -- these work practices area concern to 9 some of thembecausewhat they're using, I 10 believe, is awater-based coating and there is 11 some level of VOC in it. So I think they are 12 going to be submitting specific comments on those 13 work practices and howit would affect their 14 operation. 15 With that, I would like to entertain any 16 questions that the Board may have. 17 HEARING OFFICER LESSARD: Are there any 18 questions fromany Board members? Seeing none, we 19 will -- we had no one signed up to speak either20 for or against or general questions or comments
. 21 Going once, going twice, I would remind everyone 22 that there is a deadline for written comments that 23 can also be submitted as well, and with that I'll 24 close the public hearing. 25 MR. CRAWFORD: Thank you.

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207-495-3900 Page 9 1 HEARING OFFICER LESSARD: Thank you. 2 (Whereupon, the above-named hearingwas concluded 3 at 9:16 a.m .) 4 5 6 7 8 9 10 11 12 13 14 15 16 17 1819 20 21 22 23 24 25

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1 CERTIFICATE 2 3 I, Joanne P. Alley, a Notary Public in and 4 for the State of Maine, hereby certify that on the 5 7th day of January, 2010, personally appeared 6 before me thewithin-named witnesswhowas sworn 7 to testify to the truth, thewhole truth, and 8 nothing but the truth in the aforementioned cause 9 of action and that the foregoing is a true and 10 accurate record as taken by me by means of 11 computer-aided machine shorthand. 12 13 I further certify that I ama disinterested 14 person in the event or outcome of the 15 aforementioned cause of action. 16 17 IN WITNESS WHEREOF, I have hereunto set my18 hand this 19th dayof January, 2010. 19 20 21 Joanne P. Alley 22 Court Reporter/Notary Public 23 24 My commission expires: July 17, 2015 25

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