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1 STATE OF MAINE 

2 BOARD OF ENVIRONMENTAL PROTECTION 

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7 IN RE : CHAPTER 123 : CONTROL OF 

VOLATILE ORGANIC COMPOUNDS 

8 FROM PAPER, FILM AND FOIL COATING 

OPERATIONS 

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PRESIDING OFFICER : SUSAN LESSARD, CHAIRPERSON 

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This hearing was held pursuant to Notice at the 

16 Augusta Civic Center, Civic Center Drive, Augusta, 

Maine, on January 7, 2010, beginning at 9 :00 a.m. 

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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 from Paper, Film and 

10 Foil Coating Operations . 

11 My name is Susan Lessard. I am the Chair of 

12 the Board of Environmental Protection, and I will 

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 from the Department of 

17 Environmental Protection, Bureau of Air Quality 

18 are Jeff Crawford and Carolyn Wheeler. Our 

19 recorder is Joanne Alley of Alley & Morrisette 

20 Reporting Services . This is Lissa Widoff, our 

21 other Board Member, who is now here . 

22 Today's hearing is being held pursuant to 38 

23 M.R .S .A ., Sections 585-A and 345-A and the Maine 

24 Administrative Procedures Act . In addition, 

25 because this rule will be submitted as a revision 
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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 hearing was 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 the January 7, 2010 

21 Chapter 123 public hearing record . 

22 Today's hearing will be transcribed and made 

23 available to all Board members . Based on the 

24 complete record, the Board will vote to approve, 
25 deny or amend the proposed rule at a regularly 

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1 scheduled Board meeting. 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 room for 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 now on the appropriate speakers' 

12 sheet in the back of the room where Ms . Bertocci 

13 is . Following each presentation there will be an 

14 opportunity for members of the Board to direct 

15 questions through the Chair . Copies of the 

16 proposed rule are also available on the table by 

17 the door . 

18 At this time I would ask all persons who 

19 intend to testify to please stand to be sworn in . 

20 Do you swear to tell the whole truth and nothing 

21 but the truth? 

22 MR . CRAWFORD : I do . 

23 HEARING OFFICER : Thank you . Are there any 
24 questions? If there are no questions, we will 

25 hear testimony beginning with the staff . Good 

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1 morning, Mr . Crawford . 

2 MR . CRAWFORD : Good morning, Chairperson 

3 Lessard and Members of the Board . I'm Jeff 

4 Crawford and I'm with 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 you will, of VOC and NOx 

13 emissions . In September of 2006, EPA published an 

14 updated CTG that amended the existing paper 

15 coating requirements to also include film and foil 

16 coating operations . 

17 Let me just give you a little bit of 

18 background . What exactly are paper, film and foil 

19 coat operations? Basically we're talking about 

20 the application of coatings across the width or 

21 portion of paper, film and foil to create a 

22 functional or protective layer, saturated 
23 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 which was 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 154 which will 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 Maine we have Panel Lam which also 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 the VOC control limit requirements of this 
22 rule . So I think primarily some of the work 

23 practice requirements, which I will be getting to, 

24 might be the principal changes that would affect 

25 them . 

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1 What we have done is in addition to paper 

2 coating, we've added film and foil coating and 

3 basically allow the use of either a low solvent 

4 coating technology, so you can either go with a 

5 coating that has a very low VOC 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, film and foil, the 

13 Wilsonart laminates, if you will . 

14 I would like to talk very briefly. One 

15 significant addition to the existing rule is for 

16 work practices, and we are proposing that sources 

17 institute a number of new work practices to 

18 control VOC emissions . I mean, many of these are 

19 fairly low-hanging fruit and common sense things, 

20 if you will, keep your containers closed, make 
21 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 leaking container . VOC containing coating or 

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1 solvents should be conveyed from one 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 are a concern to 

9 some of them because what they're using, I 

10 believe, is a water-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 how it 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 from any Board members? Seeing none, we 

19 will -- we had no one signed up to speak either 
20 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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1 HEARING OFFICER LESSARD : Thank you . 

2 (Whereupon, the above-named hearing was concluded 

3 at 9 :16 a .m .) 

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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 the within-named witness who was sworn 

7 to testify to the truth, the whole 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. 

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13 I further certify that I am a disinterested 

14 person in the event or outcome of the 

15 aforementioned cause of action . 

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17 IN WITNESS WHEREOF, I have hereunto set my 
18 hand this 19th day of January, 2010 . 

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20 

21 Joanne P. Alley 

22 Court Reporter/Notary Public 

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24 My commission expires : July 17, 2015 

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ALLEY & MORRISETTE REPORTING SERVICE 

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