  SEQ CHAPTER \h \r 1 

  

MEMORANDUM

DATE:	July 2, 2007

SUBJECT:	Summary of the February 12, 2007 Paper, Film, and Foil Surface
Coating CTG Stakeholder Meeting   SEQ CHAPTER \h \r 1 

FROM:	Heather P. Brown, P.E.

TO:		  SEQ CHAPTER \h \r 1 Kim Teal,   SEQ CHAPTER \h \r 1
EPA/OAQPS/SPPD/CCG

	The purpose of this memorandum is to summarize the discussion that took
place during the stakeholder meeting for the paper, film, and foil
surface coating CTG project held on February 12, 2007 at the EPA campus
in Research Triangle Park, NC.  The meeting objectives were to inform
the stakeholders of the current project status, provide a summary of why
EPA is developing this CTG, and present possible regulatory options. 
The meeting presentation slides for the meeting, including the agenda,
are provided in Attachments 1 and 2.

MEETING PARTICIPANTS

U.S. Environmental Protection Agency (EPA)

Mr. Bruce Moore, Office of Air Quality Planning and Standards

Ms. Kim Teal, Office of Air Quality Planning and Standards, Sector
Policies and Programs Division, Natural Resource and Commerce Group

EC/R Inc.

Ms. Heather Brown

Industry Representatives

Flexible Packaging Association (FPA)

Mr. Brian Galley, Alcan Packaging (via teleconference)

Ms. Leslie Ritts, Ritts Law Group

Mr. Howard Hofmeister, Bemis 

Mr. Dan Williams, Sealed Air (via teleconference)

Mr. Bobby Cullom, Sealed Air (via teleconference)

Mr. Ram Singhal, FPA (via teleconference)

Pressure Sensitive Tape Council

Mark Hawes, Shurtape Industries

Graphic Arts Technical Foundation (GATF)

Mr. Gary Jones, GATF (via teleconference)

Specialty Graphics Imaging Associations (SGIA)

Ms. Marci Kinter, SGIA (via teleconference)

SUMMARY OF DISCUSSION

	Ms. Teal opened the meeting by welcoming all of the participants and
allowing each participant to provide a brief introduction.  She then
reviewed the meeting objectives and the agenda.

	Mr. Moore then provided an overview of why EPA is developing control
techniques guidelines (CTG).  He began by reviewing the requirements of
section 183(e) of the Clean Air Act (CAA).  Under section 183(e), EPA
conducted a study of volatile organic compound (VOC) emissions from the
use of consumer and commercial products to assess their potential to
contribute to levels of ozone that violate the national ambient air
quality standards (NAAQS) for ozone, and to establish criteria for
regulating VOC emissions from these products.  The EPA then listed for
regulation those categories of products that account for at least 80
percent of the VOC emissions, on a reactivity-adjusted basis, from
consumer and commercial products in areas that violate the NAAQS for
ozone.

	From that exercise, the Paper, Film, and Foil Coatings category was
identified for regulation, which requires the EPA to promulgate best
available controls (BAC) for this category of consumer products. 
However, section 183(e)(3)(C) provides that EPA may issue CTG based on
reasonable available control technology (RACT) in lieu of regulations if
EPA determines that such guidance will be substantially as effective as
regulations in reducing emissions of VOC.

	Mr. Moore pointed out the CTG currently under development is not a
Federal regulation.  Rather, it is a guidance document to be used by
States to develop their own regulations based on the CTG to meet state
implementation plan (SIP) requirements for nonattainment areas.

	Ms. Teal then summarized the work EPA has completed on this project. 
First, EPA examined regulations that currently affect the paper, film,
and foil coating industry.  Federal regulations include the national
emission standards for hazardous air pollutants (NESHAP) for paper and
other web coating, the new source performance standard (NSPS) for
surface coating of pressure sensitive tape and labels, and a previous
CTG for surface coating paper, fabric, and vinyl.  Both the NSPS and CTG
are directed at VOC emissions, while the NESHAP is directed at emissions
of hazardous air pollutants (HAP).  However, the NESHAP will have a
co-benefit of reducing VOC emissions as well.

	The VOC rules for all 50 States were also examined.  The EPA found that
the majority of State rules followed the existing CTG recommended
limits, and two states had limits more strict than the existing CTG
recommended limits.

	Ms. Teal then discussed the scope of the paper, film, and foil coatings
category.  Ms. Teal explained that the scope of the paper, film, and
foil coatings category was not defined in the March 1995 section 183(e)
listing.  The three federal actions that impact facilities that use
paper, film, and foil coatings do not have consistent definitions. 
Options for the scope being considered by EPA include defining the
category to be the same as that covered by the paper and other web
coating source category, or to create new category definition.

	Ms. Teal explained that the CTG under development must be based on
RACT.  The EPA has defined RACT as “the lowest emission limitation
that a particular source is capable of meeting by the application of
control technology that is reasonably available considering
technological and economic feasibility.”  Because of these factors,
RACT will tend to change over time.  Therefore, EPA is assessing the
current level of control imposed by Federal and State regulations as
part of the RACT determination and is developing regulatory options
based on these regulations.

	Ms. Teal provided the stakeholders with the project schedule.  The EPA
plans to finalize the CTG document and publish a final Federal Register
notice on the determination that the CTG is at least as effective as a
national rule no later than September 30, 2007.  Mr. Moore clarified
that EPA is not proposing or promulgating a CTG.  The Federal Register
notice will be for the determination.  However, the notice for the
proposed determination will also request comment on the draft CTG.

	Following EPA's presentations, Ms. Teal opened the floor for
discussion.  The following is a summary of major points discussed by
industry and are not presented in chronological order.

Scope of the Source Category and Definition of Affected Source

	Industry stated that the scope of the category and the definition of
the affected source are very important.  Mr. Moore stated that EPA is
not requiring anything but recommending requirements to be used by the
States.  The States choose what to include in their rules.  The
following summarizes the major issues regarding the scope and definition
of the affected source.

The original source category definition for paper and other web coating
was confusing.  One particular problem was that as far as the regulation
was concerned, the distinction between the surface coating of foil and
the surface coating of coil was not clear.  

The exemptions in the paper and other web coating NESHAP should be
included in the CTG.   Mr. Moore agreed that using the exemptions
already in place as a result of the paper and other web coating NESHAP
was appropriate.  

The FPA coats paper, film, and foil and has problems with overlap with
the printing and publishing NESHAP.  

The scope should be narrow to keep the printing operations from being
covered under the CTG.  If the scope was too broad, it could become an
issue for small businesses.

Including sources in the CTG that are already subject to State rules is
confusing and that stringent RACT requirements are already in place.  

Facilities should not be covered by more than one CTG.

Industry would like ancillary equipment (as defined in the paper and
other web coating NESHAP) to be included in the paper, film, and foil
category.  It was not included in the NESHAP but is now regulated as
part of the organic liquid distribution category, which may have
resulted in more reductions.

Should cleaning operations be included as a part of the CTG?  Mr. Moore
stated that he would like to follow the paper and other web coating
NESHAP and not include cleaning under the paper, film, and foil CTG. 
EPA is considering including housekeeping and work practice measures
under the CTG.  Mr. Moore suggested that industry may want to provide
suggested language for cleaning.

Control Methodologies

	Mr. Moore asked whether a lot of coaters would be using add-on controls
or compliant materials to meet the RACT requirements.  According to the
industry, the choice of control measures varied.  Source size versus
control is an issue that is resolved on a line-by-line basis.  The 20
ppmv limitation is easier to implement for VOC.  The following are
specific issues raised during the meeting regarding control
methodologies.

A line-by-line limit might work best for paper, film, and foil surface
coating facilities.  However, a line-by-line limit could be confusing
and an average promotes the use of low-VOC coatings. 

The industry has changed in response to the paper and other web coating
NESHAP.  Measures were taken by the industry in response to the rule and
a comparison of toxic release inventory (TRI) data shows a large
reduction in HAP.

The requirements in the Printing and Publishing rule (40 CFR part 63,
subpart KK) might be a good model 

.

	In summary, Mr. Moore stated that any suggestions for scope and method
of control would be very helpful if received before the comment period. 
Additionally, it might be possible to send a paragraph regarding the
scope and a list of control options to the industry for review and
input.  Mr. Moore also requested that examples or data regarding
emission reductions would also be helpful, as well as information on
facilities suggesting or supporting the VOC reduction from the NESHAP. 
Industry indicated that any information could be submitted no earlier
than between March 9th and March 16th.



Attachment 1

Consumer and Commercial Products

 and the Clean Air Act



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Attachment 2

Development of Control Techniques Guidelines for Paper, Film, and Foil
Surface Coatings



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