UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	February 3, 2011

SUBJECT:	Technical Support Document for Pennsylvania’s Adoption of
Control Techniques Guidelines for Paper, Film, and Foil Surface Coating
Processes 

			/s/

FROM:	Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO:		File

			/s/	

THRU: 	Cristina Fernandez, Associate Director 

Office of Air Program Planning

A.  BACKGROUND  

Section 172(c)(1) of the Clean Air Act (CAA) provides that state
implementation plans (SIPs) for nonattainment areas must include
reasonably available control measures (RACM), including reasonably
available control technology (RACT), for sources of emissions.  Section
182(b)(2)(A) provides that for certain nonattainment areas, States must
revise their SIPs to include RACT for sources of volatile organic
compound (VOC) emissions covered by a control techniques guidelines
(CTG) document issued after November 15, 1990 and prior to the area’s
date of attainment. 

The United States Environmental Protection Agency (EPA) defines 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.” (44 FR
53761, Sept. 17, 1979).  In subsequent Federal Register notices, EPA has
addressed how states can meet the RACT requirements of the CAA. 

CTGs are intended to provide state and local air pollution control
authorities information that should assist them in determining RACT for
VOCs from various sources, including paper, film, and foil coatings.  In
developing these CTGs, EPA, among other things, evaluated the sources of
VOC emissions from this industry and the available control approaches
for addressing these emissions, including the costs of such approaches. 
Based on available information and data, EPA provides recommendations
for RACT for VOCs from paper, film, and foil coatings.

In December 1977, EPA published a CTG for surface coating of paper
(EPA-450/2-77-008).  This CTG discusses the nature of VOC emissions from
this industry, available control technologies for addressing such
emissions, the costs of available control options, and other items.  

EPA also promulgated a national standard of performance for new
stationary sources (NSPS) for surface coating of pressure sensitive tape
and labels, which is a subset of the paper, film, and foil surface
coating industry in 1983 (40 CFR part 60, subpart RR), and published a
national emission standard for hazardous air pollutants (NESHAP) for
surface coating of paper in 2002 (40 CFR part 63, subpart JJJJ).

In 2006 and 2007, after conducting a review of currently existing state
and local VOC emission reduction approaches for this industry, reviewing
the 1977/1978 CTG and the NESHAP for this industry, and taking into
account the information that has become available since then, EPA
developed a new CTG surface coating of paper, entitled Control
Techniques Guidelines for Paper, Film, and Foil Coatings (Publication
No. EPA 453/R-07-003; September 2007).

Description of Paper, Film, and Foil Coatings

The paper, film, and foil product category listed under section 183(e)
of the CAA includes coatings that are applied to paper, film, or foil
surfaces in the manufacturing of several major product types for the
following industry sectors:  pressure sensitive tape and labels;
photographic film; industrial and decorative laminates; abrasive
products; and flexible packaging. The category also includes coatings
applied during miscellaneous coating operations for several products
including:  corrugated and solid fiber boxes; die-cut paper paperboard
and cardboard; converted paper and paperboard not elsewhere classified;
folding paperboard boxes, including sanitary boxes; manifold business
forms and related products; plastic asceptic packaging; and carbon paper
and inked ribbons.

Coating performed on or in-line with any offset lithographic, screen,
letterpress, flexographic, rotogravure, or digital printing press is not
part of the paper, film, and foil coating category.  In addition, size
presses and on-machine coaters that function as part of an in-line
papermaking system are not part of the paper, film, and foil coating
category.  

The paper, film, and foil surface coating process can be described as a
web coating process, which is a process that applies a continuous layer
of coating material across essentially the entire width or any portion
of the width of a web substrate to:  (1) provide a covering, finish,
functional or protective layer to a substrate; (2) saturate a substrate
for lamination; or (3) provide adhesion between two substrates for
lamination.  The web coating operations and emission control techniques
do not vary significantly among the sectors of the paper, film, and foil
surface coating industry.

VOC emissions from paper, film, and foil surface coating operations
primarily result from the evaporation of volatile components of the
coatings and cleaning materials.  The majority of VOC emissions from
these materials occur during coating application/flash-off, coating
curing/drying, and cleaning.  The remaining VOC emissions are from
cleaning operations.

EPA’s Recommended Control Option for Paper, Film, and Foil Coatings

EPA issued a CTG for Paper, Film, and Foil Coatings in September 2007
(Publication No. EPA 453/R-07-003).  The following summarizes
recommendations for controlling VOC emissions from paper, film, and foil
coatings:

A.  Coatings:  To control VOC emissions from coatings used in paper,
film, and foil surface coating, an overall VOC control efficiency of 90%
for each coating line is recommended.  Alternatively, emission limits
that are equivalent to 90 percent overall control is recommended. 
Applying the control recommendations only to individual surface coating
lines with the potential to emit, prior to controls, at least 25 tpy of
VOC from coatings is recommended.  The coating line is defined as a
series of coating applicators, flash-off areas, and any associated
curing/drying equipment between one or more unwind/feed stations and one
or more rewind/cutting stations.  It’s also recommended that paper,
film, and foil surface coating facilities be provided with the option of
using an enforceable limitation on potential emissions to keep an
individual paper, film, and foil surface coating line below the 25 tons
per year (tpy) potential to emit threshold.

An overall VOC control efficiency of 90 percent is recommended as RACT
for each paper, film, and foil surface coating line.  However, as an
alternative to an overall 90 percent control efficiency, VOC
content-based emission limits that are equivalent to 90 percent overall
control are recommended, which can be met by use of low VOC content
materials or combinations of materials and controls.  To determine these
equivalent content-based emission limits for this product category
(except for pressure sensitive tape and label surface coating lines), 20
weight percent solids and 80 weight percent solvent was used.  Using
this baseline coating content, the VOC content-based emission limits
equivalent to 90 percent emission reduction are 0.40 kg VOC/kg (0.40 lb
VOC/lb) solids applied and 0.08 kg VOC/kg (0.08 lb VOC/lb) coating
applied.  

As an alternative to 90 percent emission reduction, a limit of 0.20 kg
VOC/kg (0.20 lb VOC/lb) solids applied is recommended, and an additional
equivalent limit of 0.067 kg VOC/kg (0.067 lb VOC/lb) of coating is RACT
for pressure sensitive tape and label surface coating lines.  

Table 1:  Recommended Emission Limits for Paper, Film, and Foil Coatings

Units	RACT Limits

	Pressure Sensitive Tape and Label Surface Coating	Paper, Film, and Foil
Surface Coating (Not including Pressure Sensitive Tape and Label)

kg VOC/kg solids

(lb VOC/lb solids)	0.20	0.40

kg VOC/kg coating

(lb VOC/lb coating)	0.067	0.08

 

The VOC content limits can be met by averaging the VOC content of
materials used on a single surface coating line each day (i.e. daily
within-line averaging).  

B.  Cleaning Materials:  To control VOC emissions from cleaning
materials used in paper, film, and foil surface coating, it is
recommended that facilities implement work practices to ensure that VOC
emissions are minimized from mixing, storage, and handling of cleaning
materials, and cleaning-related waste materials.  Specifically, the
following is recommended:  (1) store all VOC-containing cleaning
materials in closed containers; (2) ensure that mixing and storage
containers used for VOC-containing materials are kept closed at all
times except when depositing or removing these materials; (3) minimize
spills of VOC-containing cleaning materials; (4) convey VOC-containing
cleaning materials from one location to another in closed containers or
pipes; and (6) minimize VOC emissions from cleaning of storage, mixing,
and conveying equipment.

B.  STATE SUBMITTAL

On January 4, 2011, Pennsylvania Department of Environmental Protection
(PADEP) submitted to EPA a SIP revision concerning the adoption of the
EPA paper, film, and foil surface coating processes.  EPA develops CTGs
as guidance on control requirements for source categories.  States can
follow the CTGs or adopt more restrictive standards.  The Commonwealth
of Pennsylvania has adopted EPA’s CTG standards for paper, film, and
foil surface coating processes.  These regulations are in 25 Pa. Code
Chapter 121 – 

General Provisions and in Chapter 129 – Standards for Sources. 
Specifically, this revision amends the existing regulations at §§
121.1, 129.51 and 129.52 and adds new § 129.52b.  Section 129.52b,
which covers control of VOC emissions from paper, film, and foil surface
coating processes, supersedes the existing paper surface coating
requirements and limits in § 129.52.  The requirements of § 129.52b
also supersede the requirements of a RACT permit issued to the owner or
operator of a source subject to § 129.52(b)(a) prior to January 1, 2012
under §§ 129.91 – 129.95 to control, reduce, or minimize VOC
emissions from a paper, film, or foil surface coating process, except to
the extent the RACT permit contains more stringent requirements.

Chapter 121:  General Provisions

Section 121.1:  Definitions

“coating line” definition is added

“coating” definition is amended for purposes of section 129.52(b)

“paper coating” definition was amended to correspond to the broader
terms “paper, film, or foil” and “paper, film, or foil surface
coating,” which are used in other sections of Chapter 129

Chapter 129: Standards for Sources – Sources of VOCs

Section 129.51:  General

Section 129.51(a) is amended to extend its coverage to paper, film, and
foil surface coating processes

Section 129.52:  Surface coating processes

Subsection (j) is added clarifying that the requirements and limits
already specified in section 129.52 for paper coatings are superseded by
the requirements and limits adopted in this revision.

Section 129.52b:  Control of VOC emissions from paper, film, and foil
surface coating processes

This section includes VOC emission limits, work practices, and
recordkeeping and reporting requirements, all of which are consistent
with EPA’s CTG for paper, film, and foil surface coating processes. 
The requirements in section 129.52b supersede the requirements in 129.52
relating to control of VOC emissions from paper, film, and foil surface
coating processes beginning January 1, 2012.  

Subsection (a) establishes applicability for the emission limits, work
practice requirements and related compliance monitoring, and
recordkeeping and reporting requirements.

Subsection (b) explains that the requirements of section 129.52b
supersede the requirements of a RACT permit from a paper, film, or foil
surface coating operation already issued to the owner or operator
subject to section129.52b unless the RACT permit contains more stringent
requirements.

Subsection (c) establishes VOC emission limits which take effect
beginning January 1, 2012.

Subsection (d) establishes compliance monitoring procedures and
identifies daily records that must be kept in order to demonstrate
compliance. 

Subsection (e) establishes recordkeeping and reporting requirements.

Subsection (f) explains that VOCs may not be emitted into the atmosphere
from the application of paper, film, or foil surface coatings, unless
the coatings are applied using one or more of the following coating
application methods:

Rotogravure coating

Reverse roll coating

Knife coating

Dip coating

Slot die coating

Flexographic coating

Extrusion coating

Subsection (g) exempts coatings which are used exclusively for
determining product quality and commercial acceptance if the quantity of
coating used does not exceed 50 gallons per year for all coatings
combined for the facility and if the owner or operator of the facility
requests this exemption in writing and PADEP approves, in writing, the
exemption prior to use of the coating.

Subsection (h) establishes work practice requirements for cleaning
materials.

Additionally, VOC emission limits for paper coatings only and the
associated applicability criteria that were in section 129.52(a)(2) were
added to section 129.52b in order to carry forward previously regulated
paper coating sources so as to eliminate the potential for backsliding. 
These VOC emission limits apply only to paper coatings if actual VOC
emissions have exceeded 3 pounds per hour, 15 pounds per day or 2.7 tpy
in any year since January 1, 1987.  The limits are shown in Table 2.

Table 2:  Emission Limits of VOCs for Paper Coating 

Units	

RACT Limit for Paper Coating

lb VOC/gal coating solids	4.84

kg VOC/l coating solids	0.58



C.  EPA EVALUATION

PADEP has adopted the standards and requirements of EPA’s CTG for
paper, film, and foil surface coating processes and is amending the
Pennsylvania SIP to reflect these amendments.  The maximum benefit from
these amendments will be provided during the ozone season when VOCs
readily combine with NOx to form ground-level ozone.  Specifically, a
maximum of 176 tons of additional annual VOC emission reductions are
anticipated from the paper, film, or foil surface coatings facilities in
Pennsylvania as a result of this rulemaking.  Therefore, this revision
will help Pennsylvania attain and maintain the NAAQS for ozone.  

D.  CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The adoption of the EPA CTG requirements for paper, film, and foil
surface coating processes by the Commonwealth of Pennsylvania will
result in the reduction of VOC emissions from paper, film, and foil
surface coating processes.  EPA’s approval of the SIP revision is
recommended.

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