MEMORANDUM 

TO: Board of Environmental Protection 

FROM: Jeff Crawford, Bureau of Air Quality 

DATE: January 7, 20 l 0 

RE: Post to a 30-day comment period with an opportunity for public hearing: 

Chapter 154 Control of Volatile Organic Compounds from Flexible Package Printing 

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Statutory and Regulatory Reference: 

A. Statutory authority. 

38 MRSA Section 585-A provides that the Board of Environmental 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." 

B. 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 VOC and 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 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 Printers that 

recommends control options for this source category. 

Location/ Applica bilitv: 

The proposed regulations will apply statewide. 

Description: 

The Department is proposing this rule as part of its effort to satisfy the RACT requirements 

mandated under the CAA and regulations related to the 1997 8-hour ozone NAAQS. According 

to the EPA's Final Rule to Implement the 8-Hour Ozone NAAQS (70 FR 71612, November 29, 

2005), areas classified as "moderate" nonattainment or higher 1 must submit a demonstration, as a 

revision to the SIP, that their current rules fulfill 8-hour ozone RACT requirements for all CTG 

categories and all major, non-CTG sources. This demonstration can be made with either a new 

RACT determination or a certification that previously-required RACT controls represent RACT 

for the 8-hour ozone NAAQS. For those cases in which states have new stationary sources not 

covered by existing RACT regulations, or when new data or technical information indicates that a 

1 Maine is treated as a moderate nonattainment area under the Clean Air Act by way of its inclusion in the Ozone 

Transport Region. 
previously adopted RACT measure does not represent a newly-available RACT control level, 

states are required to update their rules. 

Environmental Issues: 

The proposed regulation will reduce emissions of volatile organic compounds from flexible package 

printing operations. Volatile organic compounds react with nitrogen oxides in the presence of 

sunlight to form ground level ozone, which is responsible for exacerbating a variety of 

respiratory ailments, such as asthma. Although children, the elderly and those with respiratory 

problems are most at risk, even healthy individuals may experience increased respiratory 

ailments and other symptoms when they are exposed to ambient ozone while engaged in activity 

that involves physical exertion. Although these symptoms are often temporary, repeated 

exposure can result in permanent lung damage. 

Departmental Recommendation: 

The Department recommends that the Board post Chapter 154 Control of Volatile Organic 

Compounds from Consumer Products to a 30-day comment period with an opportunity for public 

hearing. 

Estimated Time of Presentation: 

10 minutes 

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