Via Email: teal.kim@epa.gov

March 16, 2007

Ms. Kim Teal

Environmental Protection Specialist

U.S. EPA/OAR/OAQPS/SPPD/NRCG

E143-03

Research Triangle Park, NC  27711

Re:  Development of CTG for Paper, Film & Foil 

Dear Ms. Teal:

On behalf of the Flexible Packaging Association, we have the following
suggestions and comments to offer on the Control Technique Guidelines
(“CTG”) that the EPA is developing for Paper, Film and Foil
(“PFF”) converters in lieu of national consumer product rules for
Flexible Packaging Coating Materials.  FPA supports EPA’s approach of
issuing a CTG in lieu of a consumer product rule for coatings. We look
forward to meeting with you and your staff about these comments and
additional background for the draft CTG that we hope to receive in
coming days. 

Background and Basis for These Comments and Suggestions:

While FPA’s ability to offer complete comments is hampered by not
having a draft of EPA’s proposed CTG, the following comments are based
on an understanding that EPA is contemplating a draft guideline that
will be based on VOC limits of 0.4 kg VOC per kg of solids applied or
90% overall control on each coating line. 

Coatings in Flexible Packaging:

Flexible packaging manufacturers use a widely diverse assortment of
coatings in the manufacture of their products.  Although the industry
has made significant VOC reductions over the years, there remain many
applications where solvent-based coatings must be used. Since the final
coating selection is dependent on the structure and performance of the
flexible packaging product that is being produced, it is important for
the CTG to recognize that the coating technologies are not necessarily
interchangeable.

Coatings used by the industry include, but are not limited to adhesives,
primers, anchor coatings, wash coatings, barrier coatings, decorative
coatings, coatings that help build the package, and coatings with other
performance and structural properties.  They may be solvent-based
(varying from high to virtually no solvent), water-based, UV & EB-cured,
100% solids coatings, and coatings with less than 1% solids.  The
coatings are applied on paper, film, foil and Tyvek substrates in coat
weights from many pounds-per-ream of material coated to imperceptible
laydown quantities.

Coating Definition:

 To reflect this breadth of materials and avoid confusion regarding the
applicability of the revised PFF CTG, FPA recommends that EPA adopt the
definition of coating such as the one that is used in the final
technical amendments to the Subpart KK MACT rule:

Coating means material applied onto or impregnated into a substrate for
decorative, protective, or functional purposes. Such materials include,
but are not limited  to, solvent-borne coatings, waterborne coatings,
wax coatings, wax laminations, extrusion coatings, extrusion
laminations, 100 percent solid adhesives, ultra-violet cured coatings, 
electron beam cured coatings, hot melt coatings, and cold seal coatings.
Materials used to form unsupported substrates such as calendaring of
vinyl, blown film, cast film, extruded film, and co-extruded film are
not considered coatings. 

See 40 CFR §63.822.  

Provision for In-line Averaging:

Also, in order to accommodate the many process lines with multiple
coating stations and lines using multiple coatings in a day, FPA
strongly urges EPA to retain  the inclusion of in-line averaging in the
2007 CTG as provided in the 1977 RACT guidance.  

	Impact of Proposed RACT:

	In order to meet the original RACT rules of the 1970s, coaters were
forced to maximize the solids content in all of their applied coatings. 
Nevertheless, all solvent-based coatings used today require some level
of add-on controls to meet the existing RACT limit.  The attached excel
table depicts the resulting change in required control efficiency needed
to meet a more stringent 0.4 kg VOC/kg solids when compared with the
current RACT limit of 2.9 pounds VOC per gallon of coating.  The impact
of this limit change varies significantly depending on the solids
content of the coating necessary to manufacture a specific product. 

 Add-On Controls:

 Increasing the stringency of RACT from 2.9 pounds of VOC per gallon of
coating to 0.4 kg VOC/kg solids can partially be accommodated at
facilities with newer control systems where destruction efficiencies
have increased from 90% to 95%.  However, the facilities with older
control devices will have more difficulties in meeting the proposed
limits.  In addition, it is critical to observe in the 2007 CTG, that
there has been little appreciable change to achievable capture
efficiency for existing process lines since the original RACT.  The
proposed limit would necessitate increased capture efficiencies by up to
10% and potentially limit production.  We believe that this significant
increase needs further discussion.

Special Considerations for Low-Solids Based Coatings:

Special considerations also should be included in the 2007 PFF CTG for
low-solids-based coatings.  The 1977 RACT rules failed to properly
acknowledge either very low-solids coatings or water-based coatings.  A
90% overall control option offers a valid RACT compliance approach for
solvent-based coatings with applied solids contents below 20%.  

FPA also strongly supports inclusion of an option in the PFF CTG that
properly acknowledges use of water-based materials, and we recommend
inclusion of a limit of 0.08 kg VOC per kg of coating applied as an
effective RACT option for water-based materials. In acknowledging
water-based materials, it must be understood that water-based materials
are formulated without any excess, unnecessary water.  It is not
practical to dilute with water to meet compliance without impacting
applied viscosity, coat weight, drying, line speed and other detrimental
affects.  As identified in the attached table, the VOC to solids
approach makes use of water-based materials impractical for many
applications.  As illustrated in the attachment, at the transition point
of 20% solids, the three options would provide equivalent control of
emissions.  The 0.08 kg VOC per kg coating would result in emissions
lower than the 0.4 kg VOC per kg solids approach for coatings with
solids content above 20%.  Likewise, the 0.08 kg VOC per kg coating
would provide higher reductions than the 90% control approach for
coatings with solids content below 20%.

	Inclusion of Work Practices for Cleaning for Flexible Packaging
Coaters:

	FPA supports inclusion of work practice standards similar to those
included in the CTG for Flexible Packaging Printing.  Covered equipment
should be defined as “cleaning of a coater, coater parts (in-line or
off-line), or removing dried coating material from areas around a
coater. In general, it would not include cleaning electronic components
of a coater or use of janitorial supplies to clean areas around a
coater.”   

	 The material used for cleaning a coating line typically consists of
the same material as used to employ the solvency to the coating, whether
this is water for water- based coatings or the specific coating solvent
for solvent based coatings.  Use of other cleaning materials tends to
have higher toxicity, disrupt the waste stream or result in use of more
cleaning materials.

	Applicability and Exclusion of Laboratory and R&D Operations:

	FPA also urges EPA to provide a discussion in the PFF CTG regarding
non-applicability of RACT to laboratory and R&D operations conducted
on-site and to equipment used solely for assessing consumer product
acceptability.  These materials are produced in very limited quantities,
and to prevent confusion in RACT implementation, such operations should
be excluded from CTG coverage, provided that the substrate coated is not
offered for sale and is produced in small quantities.

	In closing, we hope these comments are helpful to you, and we look
forward to talking with the PFF team about the comments and other issues
that arise during the CTG development. 

Sincerely,

Ram Singhal

Director, Regulatory & Government Relations

Cc Heather Brown

Attachment:

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971 Corporate Boulevard (  Suite 403 (  Linthicum, Maryland 21090 

phone: 410.694.0800 (  fax: 410.694.0900 (  e-mail: fpa@flexpack.org ( 
web: www.flexpack.org

