Comment submitted by Doreen M. Monteleone, Director of Membership & EHS Services, The Flexographic Technical Association

The Flexographic Technical Association (FTA) represents the flexographic printing industry in the United States. The FTA questions the need for EPA to issue a CTG for the flexible packaging printing materials industry. Although EPA states it has emissions information about the flexible packaging printers that will be impacted by the CTG, nowhere in the CTG does it address what the anticipated emissions reductions from these facilities will be. The proposed applicability threshold is well below that of Title I of the Clean Air Act for ozone nonattainment areas; even areas designated as ?extreme? nonattainment. There is no justification, based on the lack of accurate industry information, to warrant including small flexible packaging printers. Additionally, the definition of flexible packaging needs to be modified. We also believe the CTG needs to be clear that the proposed VOC emissions threshold should be based on actual emissions before controls, and not potential to emit (PTE) before controls. FTA strongly opposes a threshold established in pounds per day and recommends annual emission rates. The CTG grossly understates the conversion of a solvent-based flexographic printing system to a water-based. FTA supports a higher threshold applicability for sources using add-on controls. However we have concerns about the approach used in the CTG. Cleaning materials are not well defined in the CTG.