### MEMORANDUM
TO : Board ofEnvironmental Protection 

### FROM : Jeff Crawford, Bureau ofAir 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 

### ****************************************************************************** Statutory and Regulatory Reference : A. Statutory authority
. 38 MRSA Section 585-A provides that the Board ofEnvironmen tal Protection "ma y establish and amend regulations to implement ambient air quality standards and emission standards. These regulations sha ll 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 app lic ation of control technology that is reasonably available cons idering technological and economic feasibility. In September 2006, EPA published a CTG for Flexible Package Printers that recommends control options for this source category. Location/ Applicabilitv: The proposed regulations will apply statewide
. Description : The Department is proposing this rule as part ofits effort to sa ti sfy the RACT requirements mandated under the CAA and regulations related to the 1997 8 -hou r 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 s ubmit 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 ei ther 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 n ew 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 ofvolatile organic compounds from flexible package printing operations. Volatile organic compounds react with nitrogen oxides in the presence of s unlight 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 individual s 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 ofVolatile Organic Compounds from Consumer Products to a 30-day comment period with an opportunity fo r public hearing. Estimated Time ofPresentation: 

### 10 

### minutes

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