STATE OF MAINE DEPARTMENT OF ENVIRONMENTAL PROTECTION

JOHN ELIAS BALDACCI GOVERNOR MEMORANDUM

o`st to Public Hearing: Chapter 123 Control of Volatile Organic Compounds FromPaper, Filmand Foil Coating Operations DAVID P . LITTELL COMMISSIONER

Statutory and ReLyulator_y Reference: A . Statutory authority.

B . 38 MRSA Section 585-A provides that the Board of Enviromnental Protection "may establish and amend regulations to implement ambient air quality standards and emission standards . These regulations shall be designed to achieve and maintain ambient air quality standards and emission standards within any region and prevent air pollution." Specific legal mandates requiring adoption. Section 184 of the Clean Air Act requires states to implement or update reasonably available control technology (RACT) controls on all major VOCand NOx emission sources and on source categories covered by a Control Technique Guideline (CTG) document . EPA developed a CTGthat included paper coatings, Control of Volatile Organic EmissionsfromExisting Stationary Sources-Volume II : Surface Coating ofCans, Coils, Paper, Fabrics, Automobiles and Light-Duty Trucks (1977) and created an updated version, Control Technique Guidelinesfor Paper, Filmand Foil Coatings, in September 2007. Location/Applicability: The proposed regulation will apply statewide.

AUGUSTA 17 STATE HOUSE STATION AUGUSTA, MAINE 04333-0017 (207) 287-7688 FAX

: (207) 287-7826 RAY BLDG., HOSPITAL ST. BANGOR PORTLAND PRESQUE ISLE 106 HOGANROAD, SUITE 6 312 CANCOROAD 1235 CENTRAL DRIVE, SKYWAY PARK BANGOR, MAINE 04401 PORTLAND, MAINE 04103 PRESQUE ISLE, MAINE 04679-2094 (207) 941-4570 FAX

: (207) 941-4584 (207) 822-6300 FAX : (207) 822-6303 (207) 764-0477 FAX : (207) 760-3143 web site: www

.maine .gov/depDescription:

Section 184of the Clean AirAct requires states to implement or update reasonably available control technology (RACT) controls on all major VOCand NOx emission sources and on source categories covered by a Control Technique Guideline (CTG) document . EPA defines RACT as the lowest emission limit that a particular source is capable ofmeeting by the application of control technology that is reasonably available considering technological and economic feasibility. In May 1977, EPApublished a CTGfor controlling VOCemissions from surface coating ofpaper, which it updated in September 2007. The paper, filmand foil coatings include coatings that are applied to paper, filmand foil surfaces in the manufacturing of several major product types including pressure sensitive tape and labels, industrial and decorative laminates, and photographic film . This category also includes coatings applied during miscellaneous coating operations of corrugated and solid fiber boxes and folding paperboard boxes. The current Chapter 123 only regulates surface coating of paper. The proposed amendments will add control requirements for the surface coating of filmand foil substrates. In addition, the proposal incorporates work practices to minimize VOCemissions. The Department is proposing these amendments as part of its effort to satisfy the RACT requirements mandated under the CAAand regulations related to the 1997 8-hour ozone NAAQS . Accordingto the EPA's Final Rule to Implement the 8-Hour Ozone NAAQS (70 FR 71612, November 29, 2005), areas classified as "moderate" nonattainment or higherl must submit a revision to the SIP rules for all CTGcategories. The proposed amendments to Chapter 123 will fulfill Maine's requirement to promulgate rules and implement controls meeting the 2007 CTGfor paper, filmand foil coatings. Environmental Issues: Volatile organic compounds contribute to ground-level ozone formation or smog which aggravates respiratory ailments such as asthma, bronchitis, and emphysema. The presence of ozone impedes the breathing of even healthy people. Departmental Recommendation: The Department recommends that the Board hold a public hearing on this proposal on January 7, 2010 . Estimated Time of Presentation: 10 minutes

1 Maine is treated as a moderate nonattainment area under the Clean AirAct by way of its inclusion in the Ozone Transport Region.