06-096 DEPARTMENT OF ENVIRONMENTAL PROTECITON 

Chapter 154: Control of Volatile Organic Compounds from Flexible Package 

Printing 

1. Applicability 

SUMMARY: This regulation limits emissions of volatile organic 

compounds from flexible package printers. 

A. This regulation applies to any flexible package printing press that has the potential to 

emit from the dryer, prior to controls, of at least 25 tons per year ofVOC from the use 

of inks, coatings and adhesives combined. 

B. Facilities with flexible package printing presses with a potential to emit of less than 25 

toris per year ofVOC from the use of inks, coatings and adhesives combined, are 

required to meet only the work practice requirements in Section 4 and the 

recordkeeping requirements in Section 5 of this Chapter. 

C. Facilities with flexible package printing presses with a potential to emit of less than 25 

tons per year ofVOC from the use of inks, coatings and adhesives combined that are 

used solely for quality control /quality assurance and for research and development 

purposes are required to meet only the recordkeeping requirements in Section 5 of this 

Chapter. 

2. Definitions 

A. Air pollution control equipment efficiency. "Air pollution control equipment 

efficiency" means the ratio ofVOC emissions recovered or destroyed by the air 

pollution control equipment to the total VOC emissions that are introduced into the air 

pollution control equipment, expressed as a percentage. 

B. Capture efficiency. "Capture efficiency" the ratio of VOC emissions delivered to the 

air pollution control equipment to the total VOC emissions resulting from flexible 

package printing activities, expressed as a percentage. 

C. Cleaning. "Cleaning" means, with respect to a flexible package printing press or 

presses, cleaning of a press or press parts or the removal of dried ink from areas 

around the press. ·'Cleaning" does not include cleaning of electronic components, 

cleaning in platemaking or binding operations, housekeeping activity near a press or 

the use of a parts washer or cold cleaner. 

D. Flexible package. "Flexible package" means any package or part of a package the 

shape of which may be readily changed. A "flexible package" may be in the form of a 

bag, pouch, liner or wrap made of paper, plastic, film, aluminum foil, or metalized or 

coated film or paper, alone or in combination. None of the following are considered a 

"flexible package": a folding carton, self-adhesive labels, gift wrap, wall covering, 

vinyl products, decorative laminates, floor coverings or tissue products. 

E. Flexographic print station. " Fiexographic print station" means a work station on 

which a flexographic printing operation is conducted. A flexographic print station 

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06-096 DEPARTMENT Of ENVIRONMENTAL PROTEClTON 

includes a tlexographic printing plate, which is an image made of rubber or other 

elastomeric material. The image to be printed is raised above the printing plate. 

F. Installation date . .. Installation date" means the first date on which a piece of 

equipment is in place and prepared to operate. The "installation date" does not change 

ifthc equipment is moved to a new location at the same premises. 

G. Overall control efficiency. "Overall control efficiency" means the product of the 

capture efficiency and the air pollution control equipment efficiency. 

H. Press. "Press" means a printing production assembly that is composed of one or more 

work stations, one or more of which is a tlexograph ic or rotogravure print station, that 

produces a printed product. 

I. Quality control /quality assurance and research and development. "Quality 

control/quality assurance" means the testing of products to ensure that they meet 

performance requirements and that the product and/or service is reproducible. 

"Research and development" means a process intended to create new or improved 

products or technology. The products produced as a result of quality control/quality 

assurance and/or research and development activities are not directly sold or marketed 

as a product. 

J. Rotogravure print station. "Rotogravure print station" means a work station on 

which a rotogravure printing operation is conducted. A rotogravure print station 

includes a rotogravure cylinder and ink supply. The image to be printed is etched or 

engraved below the surface of the rotogravure cylinder. 

K. Work station. "Work station" means a unit on a press where material is deposited 

onto a substrate. 

3. Requirements. Beginn~ng January l, 2011, flexible package printing presses that have 

the potential to emit from the dryer, prior to controls, of at least 25 tons per year ofVOC 

from the use of inks, coatings and adhesives combined must use one of the following 

methods to control VOC emissions: 

A. Use only inks, coatings and adhesives with an as applied VOC content that does not 

exceed 0.8 kg VOC/kg of solids (0.8 lb VOC/lb of solids) or 0.16 kg VOC/kg of 

materials (0.16lb VOC/lb of materials). The VOC content limits may be met by 

averaging the VOC content of materials used on a single printing line in a single day; 

or 

B. Install, operate and maintain in accordance with the manufacturer's recommendations, 

an emissions control system, consisting of a capture and a control device, which meets 

the following overall control efficiency levels: 

Installation date of press Installation date of air Overall 

pollution control device control 

efficiency (%) 

Prior to March 14, 1995 Prior to January 1, 2011 65 

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06-096 DEPARTMENT OF ENVIRONMENTAL PROTECITON 

Prior to March 14, 1995 On or after January 1, 2011 70 

On or after March 14, 1995 Prior to January 1, 20 11 75 

On or after March 14, 1995 On or after January 1, 2011 80 

4. Work Practice Requirements. Beginning January 1, 2011, the owner or operator of any 

flexible package printing press must use the following work practices: 

A. New and used VOC-containing ink, adhesives, coating or cleaning solvent, including 

ink or coating mixed on the premises, shall be stored in a nonabsorbent, non-leaking, 

vapor-tight container. Such a container shall be kept closed at all times except when 

the container is being filled, emptied or is otherwise actively in use; 

B. Spills and leaks ofVOC-containing ink, adhesives, coating or cleaning solvent shall 

be minimized. Any leaked or spilled VOC-containing ink, coating or cleaning solvent 

shall be absorbed and removed immediately; 

C. Absorbent applicato·rs, such as cloth and paper, which are moistened with VOC 

containing ink, adhesives, coating or solvent, shall be stored in a closed, nonabsorbent, 

nonleaking container for disposal or recycling; 

D. VOC-containing ink, adhesives, coating and cleaning solvent shall be conveyed from 

one location to another in a closed container or pipe; and 

E. Cleaning shall be performed to minimize associated VOC emissions. 

NOTE: The handling, storage and disposal of hazardous wastes, including waste VOCs 

and cloth or paper impregnated with such waste are subject to hazardous waste 

management standards as set forth in Maine's Hazardous Waste Management Rules, 06-

096 CMR Chapters 850-857. 

5. Recordkeeping Requirements 

A. By January l, 2011, or upon initial startup of a new flexible package printing press, or 

upon changing the method of compliance for an existing flexible package printing 

press from use of complying coatings or daily-weighted averaging to control devices, 

the owner or operator of the subject printing press shall perform all tests and submit 

to the Department the results of all tests and calculations necessary to demonstrate 

that the subject flexible package printing press will be in compliance with the 

emissions reductions required by Section 3 of this Chapter on and after January 1, 

2011, or on and after the initial startup date. Testing shall be performed according to 

Procedures A, B, C, E, and F as specified in Appendix A to Chapter 132 of the 

Department's regulations. 

B. Beginning January 1, 2011, the owner or operator of any flexible package printing press 

must maintain records of the information necessary to demonstrate compliance with the 

applicable requirements of this Chapter, including but not limited to: 

( l) Name and quantity of any ink, adhesives, coating or cleaning solvent used; 

(2) VOC content of each ink, adhesives, coating or cleaning solvent used, as applied; 

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06-096 DEPARTMENT OF ENVIRONMENTAL PROTECITON 

(3) A catalog of Material Safety Data Sheets for all inks, adhesives, coatings and 

cleaning solvents used; 

(4) Documentation of air pollution control equipment efficiency or capture efficiency, 

if applicable; 

(5) Date and type of maintenance performed on air pollution control or capture 

equipment, if applicable; and 

(6) Calculations demonstrating that the potential emissions ofVOC from all flexible 

package printing presses at the facility are and will be less than 25 tons per 

calendar year before the application of capture systems and control devices. Total 

potential emissions ofVOC for a flexible package printing faci lity is the sum of 

potential emissions ofVOC from each flexible package printing press at the 

facil ity. The following equation shall be used to calculate total potential 

emissions of VOC per calendar year before the application of capture systems and 

control devices for each flexible package printing press at the facility: 

where: 

E p = A X B 

Ep=Total potential emissions ofVOC from one flexible package printing press in 

units of pounds per year (lb/yr). 

A=Weight ofVOC per volume of solids of the coating or ink with the highest 

VOC content, as applied, each year on the printing press in units of pounds of 

VOC per gallon (lb VOC/gal) of coating or ink solids. 

B=Total volume of solids for all coatings and inks that can potentially be applied 

each year on the printing press in units of gallons per year (gal/yr.). The 

instrument and/or method by which the owner or operator accurately measured or 

calculated the volume of coating and ink solids applied and the amount that can 

potentially be applied each year on the printing press. 

(7) The actual overall emission reduction efficiency achieved for each day for each 

flexible package printing press as determined using Procedure E of Appendi.'<. A. 

(8) Control device monitoring data; 

(9) A log of operating time for the capture system, control device, monitoring 

equipment and the associated flexible package printing press; and 

(I 0) A maintenance log for the capture system, control device, and monitoring 

equipment detailing all routine and non-routine maintenance performed, 

including dates and duration of any outages. 

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06-096 DEPARTMENT OF ENVIRONMENTAL PROTECITON 

(11) For thermal incinerators, all continuous 3-hour periods of operation in which 

the average combustion temperature was more than 28 degrees C (50 degrees F) 

below the average combustion temperature during the most recent performance 

test that demonstrated that the facility was in compliance; 

( 12) For catalytic incinerators, all continuous 3-hour periods of operation in which 

the average temperature of the process vent stream immediately before the 

catalyst bed is more than 28 degrees C (50 degrees F) below the average 

temperature recorded during the most recent performance test that demonstrated 

that the facility was in compliance; and 

(13). For carbon adsorbers, all continuous 3-hour periods of operation during 

which either the average VOC concentration or the reading of organics in the 

exhaust gases is more than 20 percent greater than the average exhaust gas 

concentration or reading measured by the organics monitoring device during the 

most recent determination of the recovery efficiency of the carbon adsorber that 

demonstrated that the facility was in compliance. 

C. All required records shall be maintained for a period of at least six (6) years and made 

available to the Department or US EPA to inspect and copy upon request. 

AUTHORITY: 38 M.R.S.A., Section 585-A 

EFFECTNE DATE: July 20, 2010 

BASIS STATEMENT 

Section 184 of the Clean Air Act requires states to implement or update reasonably available 

control technology (RACT) controls on all major VOC and NOx emission sources and on source 

categories covered by a Control Technique Guideline (CTG) document. EPA defines RACT as 

the lowest emi·ssion limit that a particular source is capable of meeting by the application of 

control technology that is reasonably available considering technological and economic 

feasibility. In September 2006, EPA published a CTG for Flexible Package Printing that 

recommends control options for this source category. 

In addition to the Basis Statement above, the Department has filed with the Secretary of State 

response to representative comments received during the comment period. 

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