+----------------------------+-----------------------------------------+
| > **\"Ram Singhal\"        | +----+------------------------------+   |
| > \                        | | To | > Group A-AND-R-DOCKET@EPA   |   |
| <rsinghal@flexpack.org\>** | +----+------------------------------+   |
| >                          | | cc | > Kim Teal/RTP/USEPA/US@EPA  |   |
| > 08/06/2007 10:37 AM      | +----+------------------------------+   |
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|                            | | S  | > Dockets No                 |   |
|                            | | ub | > EPA-HQ-OAR-2007-0454 &     |   |
|                            | | je | > EPA-HQ-OAR-2007-0336       |   |
|                            | | ct |                              |   |
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+----------------------------+-----------------------------------------+

Attached are Flexible Packaging Association comments to be placed in
Dockets No. EPA-HQ-OAR-2007-0454 and Docket EPA-HQ-OAR-2007-0336. Two
hard copies are being mailed to the EPA Docket Center.

Thank you for the opportunity to comment.

Ram K. Singhal

*The Flexible Packaging Association (FPA), established in 1950, is a
national trade association comprised of manufacturers and suppliers of
flexible packaging. The industry produces packaging for food,
healthcare, and industrial products using paper, film, foil, or any
combination of these materials. Examples of flexible packaging include
rollstock, bags, pouches, labels, liners, wraps, and tamper-evident
packaging for food and medicine. Flexible packaging, a \$23.5 billion
industry, employs approximately 80,000 people in the United States and
is the second largest segment of the U.S. packaging market estimated at
\$138 billion.*

**Ram K. Singhal**

Director, Regulatory & Government Relations

Flexible Packaging Association

971 Corporate Blvd., Suite 403

Linthicum, MD 21090-2211

\(410\) 694-0823 \[phone\]

\(410\) 694-0900 \[fax\]

mailto:
[[rsinghal@flexpack.org]{.underline}](mailto:rsinghal@flexpack.org_)

This mailbox protected from junk email by MailFrontier Desktop

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> August 6, 2007
>
> [*a-and-r-docket@epa.gov*](mailto:a-and-r-docket@epa.gov)
>
> *Consumer and Commercial Products, Group III*
>
> *Dockets No. EPA-HQ-OAR-2007-0454 and*
>
> *Docket EPA-HQ-OAR-2007-0336(Paper, Film and Foil Coatings)*
>
> *EPA Docket Center*
>
> *Mail Code 6102T*
>
> *1200 Pennsylvania Ave., NW*
>
> *Washington, DC 20460*
>
> **Re: Consumer and Commercial Products: CTGs in Lieu of Regulations
> for Paper, Film, and Foil Coatings; Metal Furniture Coatings; and
> Large Appliance Coatings 72 Fed. Reg. 37582 (July 10, 2007).**
>
> Dear Mr. Moore:

On behalf of the Flexible Packaging Association, I am submitting
comments supportive of the Agency's decision to issue a CTG in lieu of a
consumer product rule for paper, film and foil coatings used in
manufacturing flexible packaging. The Flexible Packaging Association
(FPA), established in 1950, is a national trade association comprised of
manufacturers and suppliers of flexible packaging. The industry produces
packaging for food, healthcare, and industrial products using paper,
film, foil, or any combination of these materials. Examples of flexible
packaging include rollstock, bags, pouches, labels, liners, wraps, and
tamper-evident packaging for food and medicine. Flexible packaging, a
\$23.5 billion industry, employs approximately 80,000 people in the
United States and is now the second largest segment of the U.S.
packaging market estimated at \$138 billion.

> ***[Support for CTG Approach]{.underline} \--*** Despite the fact that
> adoption of a CTG will place the onus for achieving further volatile
> organic compound (VOC) reductions directly on our members, FPA
> supports adoption of a CTG rather than a national consumer product
> rule. A CTG approach will afford our members the greatest flexibility
> to achieve VOC emission reductions, while not compromising our ability
> to meet customer needs by eliminating certain types of coating
> products. The success of our industry is predicated on ingenuity and
> continual development of products with enhanced performance, areas
> that would be significantly compromised in this country if
> restrictions were imposed on our raw materials. In addition, FPA
> agrees with EPA's position that state adoption of CTGs applicable to
> industries that apply these coatings will result in a greater volume
> of emission reductions than through a national rule that attempts to
> limit VOCs in consumer products.
>
> ***[Several Significant Concerns]{.underline} --*** Notwithstanding
> our support, FPA is concerned about several specific issues in the
> draft CTG that might affect the proposed determination. Below we
> provide detailed comments and suggested changes on the following three
> issues:
>
> \(1\) The general applicability provisions are unclear as to what is
> included within a threshold value;
>
> \(2\) The application of control requirements to coating operations
> with VOC emissions at the threshold level in the draft CTG would
> result in cost for controls in excess of \$30,000 per ton of VOC
> emission reduction. This projected cost fails to meet the
> cost-effectiveness requirement for RACT; and
>
> \(3\) The draft CTG neglects to provide guidance to states on methods
> that are deemed acceptable for demonstrating compliance with RACT
> limitations.
>
> In addition, we have provided a number of minor editorial suggestion
> and clarifications to make the final CTG more accurate or eliminate
> confusion. As FPA has suggested in the past, a "model RACT rule,"
> would help rectify many of our concerns, and FPA offers its full
> support in the development of a draft model rule
>
> **1. [EPA should clarify elements of the applicability provisions of
> the proposed RACT CTG to specifically define what is included within
> the scope of an applicability threshold determination]{.underline}.**
>
> FPA objects to the applicability thresholds set forth in the Federal
> Register Notice of Proposed Rulemaking (*hereafter "Notice*") and the
> proposed CTG. First, the thresholds are stated inconsistently and
> ambiguously throughout the documents so that it is unclear whether
> they apply to an individual coating line or apply collectively to all
> coating lines at a facility. In addition, it is not clear if the
> threshold values, whether individual or collective, apply solely to
> emissions from application of coatings or include all VOC emissions
> relating to the coating operations, e.g. clean-up. *Id., at* page
> 37588, col.3. *See also* CTG, pages 3, 16. Lastly the draft CTG fails
> to incorporate standard exclusions for non-production activities.
>
> **[Daily applicability threshold]{.underline} --**Both the notice and
> CTG recommend that the control options apply to facilities whose
> paper, film, and foil surface coating operations emit 6.8 kg VOC/day
> (15 lb VOC/day) or more before the consideration of control. The
> statement is somewhat ambiguous as it does not state if this refers to
> coating operations individually or collectively. Section III, page 3
> of the draft CTG does state that "for purposes of determining whether
> a facility meets the 6.8 kg/day threshold, aggregate emissions from
> all paper, film, and foil surface coating operations at a given
> facility are included. This position is not carried forward into the
> recommendations for either the CTG or the notice. If EPA truly meant
> for the threshold to be applied collectively, FPA would suggest that
> EPA reconsider its position. Historically it would appear that EPA
> meant to apply the 6.8 kg/day threshold to individual process lines.
> In fact, EPA's contractors for the 1979 RACT rule specifically
> suggested thresholds as being applicable sources at 6.8 kg/day (i.e.
> to an individual coating line) and that a 100 ton per year threshold
> was applicable to a facility. A threshold value of 6.8 kg/day, on
> average, equates to only 0.625 lb /hour or roughly one tenth of the
> common permit exemption for individual VOC emission sources. Process
> lines at multi-line facilities, where the cumulative potential
> emissions from the lines were only 6.8 kg/day, would actually meet the
> test for insignificant sources under many state Title V programs. As
> we discuss further below, such a RACT applicability level also would
> be extremely costly and unreasonable. Therefore, we recommend that EPA
> clarify the daily applicability threshold of 6.8 kg of VOC to pertain
> to an individual coating line and not to an entire facility or to a
> collection of coating lines.
>
> **[Annual applicability threshold]{.underline} --** The Notice
> includes an annual applicability threshold of 3 tons VOC/year. While
> the CTG mentions an annual applicability threshold under Section III,
> it is not mentioned in the recommendation. The notice suggests that
> the control options apply for operations that emit 6.8 kg/day
> **[or]{.underline}** 3 tons VOC/year. It is not clear if the intent is
> to suggest including both a daily and an annual applicability
> threshold in a state rule. If the intent was to include both limits,
> the annual limit would be meaningless because the daily limit will be
> more restrictive. For these very low applicability thresholds, FPA
> would suggest that the annual threshold take precedence. As we already
> have discussed immediately above, this value should be applied on a
> line-per-line basis, and not to a collection of coating lines or
> facility-wide.
>
> **[Applicability of clean-up emissions to applicability
> thresholds]{.underline}** -- It is not clear what is included in the
> threshold determinations based on the recommendations. Section III,
> page 3 of the draft CTG does state: "...control approaches discussed
> in section VI of this CTG apply to any paper, film, and foil coating
> operation where the **[actual VOC emissions associated with all
> aspects of the coating operation]{.underline}** are equal to or exceed
> 6.8 kg/day...". However, this statement is not clarified and is not
> carried forward into the recommendations for either the CTG or the
> notice. FPA believes that emissions from clean-up and other incidental
> activities should not be included in the threshold determinations as
> these operations do not relate to a facility's ability to meet the
> RACT limitations and do not figure in the cost-effectiveness
> determination. While we agree that cleanup should be part of the CTG
> guidance, it should not be part of the applicability threshold for
> coating line emission standards. They should not be included in
> determining whether the coating operations are subject to RACT.
>
> **[Exclusion for non-production applications]{.underline}**-- FPA
> believes that certain non-production type activities should be
> excluded from the RACT requirements as they have been in many current
> and prior RACT regulations. In particular, research and development
> coating operations are generally excluded from RACT provided the units
> are used exclusively for the development of new products. Typically,
> these units are operated under the close supervision of technically
> trained personnel and are not engaged in the manufacture of products
> for commercial sale except in a *de minimis* manner. State regulations
> commonly provide that RACT requirements do not pertain to these type
> coating operations as these operations are not an integral part of the
> production process and the emissions from the source are below a set
> limit, (e.g. 363 kilograms (800 pounds) in any one month).

2.  **[The proposed CTG appears to apply control requirements to coaters
    or facilities that emit as little as 6.8 kg/day or 3 tons/year of
    VOC, which is unreasonable and would violate the economic
    feasibility RACT requirement.\
    ]{.underline}**

> The control requirements, as proposed, would apply to some very small
> emission sources. The costs of applying controls to these very small
> VOC emission sources will be excessive. Attached is a cost calculation
> for a single coating line operating at the emission threshold level as
> suggested under the draft CTG, i.e. 3 tons per year. As demonstrated,
> the cost for this source to meet the RACT limitations by means of an
> add-on control device would be in excess of \$30,000 per ton of VOC
> emission reduction. This cost would be even higher for a 3 ton per
> year emission source if the emissions were the aggregate of multiple
> coating lines. This increase is due to the need for increased oxidizer
> capacity which would increase both the capital and operational cost of
> the oxidizer. This cost is significantly higher than what EPA has
> generally considered to be an economically feasible cost for RACT
> compliance.
>
> Many of the sources subject to the PFF RACT are currently covered
> under existing RACT requirements such as for Paper Coating. Paper
> Coating RACT did set applicability at very low levels, (e.g. 15
> lb/day). Based on projected costs and industry knowledge, it is
> believed that none of the small emission sources subject to Paper
> Coating RACT met the limitations by means of add-on control systems. A
> source currently meeting the Paper Coating RACT standard by means of
> low VOC materials would need to achieve further reductions of
> approximately 19% to meet the proposed PFF limitation. Unless this
> source was already meeting the PFF RACT, a small source (i.e. 3
> ton/year) would be very limited in its ability to economically achieve
> this incremental reduction. As EPA determined in the 2006 CTG for
> Flexible Packaging Printing, it is generally economically infeasible
> for a VOC emitting web process line to apply add-on emission controls
> to lines emtting less than 25 tons per year. This position is provided
> in the following excerpt from the CTG:
>
> *We recommend applying the control recommendations for inks, coatings
> and adhesives only to those presses with potential to emit from the
> dryer, prior to controls, [of at least 25 tpy of VOC (petroleum ink
> oil) from inks, coatings and adhesives combined. We recommend
> providing printers with the option of using an enforceable limitation
> on potential emissions to keep an individual press below this 25 tpy
> potential to emit threshold.]{.underline} Guidance on limiting
> potential to emit from printing operations is provided in the
> Technical Support Document (TSD) for Title V Permitting of Printing
> Facilities (see Appendix A).\*\*\* We recommend this higher threshold
> for the control recommendations concerning inks, coatings, and
> adhesives because not all flexible packaging presses can use low VOC
> content inks, coatings, and adhesives. [We believe that control of a
> press that is above the 25 tpy threshold will generally be cost
> effective. Add-on controls for presses with potential to emit below 25
> tpy will generally be too costly for the emission reduction that would
> be achieved. ]{.underline}*
>
> *For those facilities where actual emissions from flexible packaging
> printing operations are greater than 15 lb/day before consideration of
> controls and where potential to emit is less than 25 tpy of VOC on a
> per press basis before controls, we recommend applying only the
> recommended work practices for cleaning.*
>
> Control Techniques Guidelines for Flexible Package Printing EPA 453/R-
> 06-003, pp. 3-4 (September 2006).
>
> These costs projections and economic feasibility determinations are
> consistent with costs for control on a coating line. Attached is a
> cost assessment for a single coating line with pre-control emissions
> of 25 tons per year. Under this example, calculated costs would be
> just in excess of \$3,500 per ton of VOC emission reduction. This is
> considered to be on the outer bounds of RACT economic feasibility.
> Therefore, based on cost projects coupled with the very marginal
> anticipated VOC reduction realized by controlling small sources, FPA
> recommends that EPA follow the approach of the 2006 CTG for flexible
> packaging, which only provides a low applicability threshold (e.g. 15
> lb/day) for cleaning operations. Recognizing that many small sources
> subject to the PFF RACT are covered under existing RACT requirements,
> FPA recommends that existing RACT requirements remain in place for
> process lines with potential pre-controlled emissions of less than 25
> tpy. We would suggest that these sources be allowed to opt into the
> revised RACT limitations at their request.
>
> **3.** **[EPA needs to provide guidance on how sources may comply with
> the proposed control limitations.]{.underline}**
>
> **[Control Limits on Coating Operations:]{.underline}** The draft CTG
> recommends three optional approaches to define RACT for coating
> operations; an overall control efficiency for each applicable coating
> line and two low VOC content approaches. Clarification and further
> discussion is necessary to define acceptable methods that a source may
> use to achieve and demonstrate compliance with these limitations. The
> following are standard approaches allowed by other CAA regulations
> applicable to coating equipment.
>
> ***Equivalency-*** FPA strongly recommends that EPA modify the draft
> CTG to include the recognition of equivalency for meeting the
> limitations. The draft CTG is conspicuously silent with respect to
> this fundamental tool for meeting the proposed RACT requirements. The
> principle approach utilized by industry to meet the original RACT
> requirements was through a combination of pollution prevention
> measures in conjunction with add-on controls. This approach has
> carried through into most regulatory programs impacting coating type
> limitations, e.g. Paper Coating RACT, Subparts KK and JJJJ pertaining
> to Printing and POWC MACT and the recent CTG for Flexible Packaging
> Printing. To date there are no solvent-borne coatings that we know of
> that can meet even the 1979 Paper Coating RACT requirements without
> controls. A solvent borne coating would have to have been applied at
> roughly 67% solids, by weight, to meet the original Paper Coating RACT
> and roughly 71.5% solids to meet the current draft RACT proposal. In
> 1979 laminating adhesives were commonly applied at 25 % solids. Driven
> by the Paper Coating RACT, today most laminating adhesives are applied
> at roughly 40% solids. Further, omitting equivalency from the
> compliance options removes the pollution prevention incentive from the
> rule and greatly diminishes the incentive to minimize solvent content
> in the applied coating. In the absence of an equivalency provision,
> there is no incentive in the RACT requirements for increasing solids
> content above 28%, by weight, (20% by volume) in the application of
> coatings.
>
> For this reason, FPA recommends inclusion of language parallel to the
> provisions included in the CTG for Flexible Package Printing. Section
> VI. A of the 2006 CTG, i.e. "*As an alternative to emission reduction
> percentages specified above, we also recommend providing the following
> two equivalent VOC content limits which can be met by use of low VOC
> content materials **[or combinations of materials and
> controls]{.underline}** as follows..."*
>
> **A*veraging-*** FPA also urges EPA provide guidance in the CTG
> regarding compliance averaging, both in terms of time duration and
> application. EPA discusses averaging on page 37585 of the Notice, but
> no mention of averaging is made in the proposed CTG "recommended
> options." FPA recommends that EPA include as a minimum in-line daily
> averaging of all coatings applied at all coating stations in a single
> process line within a day as had been commonly included in previous
> RACT requirements (e.g. Control Techniques Guidelines for Flexible
> Package Printing -- Section VI. A. "The VOC content limits can be met
> by averaging the VOC content of materials used on a single press
> (i.e., within a line."). FPA also recommends that EPA consider
> cross-line averaging given the advancements that have been made in
> recordkeeping since imposition of original RACT requirements in the
> late 1970's early 1980's. This would afford facilities the flexibility
> to set control based on best feasibility. Regardless of the
> recommended equivalency approach, EPA should provide specific clear
> direction on its recommendation, in the final CTG (and hopefully in a
> model RACT rule for paper, film and foil).
>
> ***Low VOC control approach-*** The draft CTG recommends two low VOC
> compliance options: (1) 0.4 kg VOC/kg solids applied and (2) 0.08 kg
> VOC/kg material applied for this product category (excluding pressure
> sensitive tape and label surface coating lines). Taking from the
> approach utilized in 40 CFR Part 60, Subpart JJJJ, the two options
> properly accommodate both high solids coating applications (option 1)
> and low solids coating applications (option 2). While water-based and
> solvent-less coatings are available for many applications; they are
> not as available for replacement of solvent borne materials as
> suggested in the draft CTG. Nevertheless, FPA fully endorses this
> approach provided that compliance can be achieved through equivalency
> and averaging as allowed under previous RACT and MACT limitations.
>
> ***Cleaning Materials:*** FPA agrees with EPA's proposal to include
> work practice standards as part of the RACT. While application of
> controls is infeasible because of the way that cleaning is performed
> on and off-line, the work practices outlined in the proposed CTG will
> provide substantial environmental benefits and are cost-effective.
>
> ***[Minor Editorial suggestions \--]{.underline}*** In addition to the
> specific comments presented above, FPA would like to point out the
> following minor suggestions with respect to the draft CTG:

-   On page 4, Section IV. Process Description -- EPA should clarify
    that woven polymer substrates such as Tyvek™ are included under this
    CTG to eliminate confusion regarding coverage, especially since the
    coating of these materials are used particularly in medical
    packaging. (This will reduce confusion by clarifying that these
    substrates are not defined as textiles.)

-   On page 6, Section IV. A. Process Description -- Under definition of
    "extrusion" the word conveyor is used. This is not a term that is
    used in the coating industry. To eliminate confusion, it should be
    removed from the paragraph.

-   On page 8, Section IV. B. 1. Coatings, *Solvent-borne coatings* --
    For clarity, FPA suggests adding "Solvent borne coatings are
    typically applied at 60 to 90 % solvent by weight and sometimes
    higher."

-   On page 8, Section IV. B. 1. Coatings, *Solvent-borne coatings* --
    The draft CTG includes a statement that: "The primary solvents in
    solvent-borne coatings include methanol, toluene, xylene, methyl
    ethyl ketone, acetone and ethanol." The notice includes a similar
    statement excluding acetone and ethanol. This supposition is not
    reflective of the primary solvents used by the flexible packaging
    industry in coating applications. Methanol, xylene and acetone are
    rarely used and toluene and MEK are typically used only in certain
    applications, e.g. toluene is used in certain medical packaging
    applications. The primary solvents used in solvent-borne coatings in
    our industry are ethyl acetate and ethanol.

-   On page 8, Section IV. B. 1. Coatings, *Water-borne coatings* --
    Oven temperatures are not typically set higher for water borne
    coatings due to temperature constraints of the substrates. Water
    borne coatings are more apt to require either slower line speeds or
    increased dryer length. The text of the final CTG should be modified
    accordingly.

-   On page 8, Section IV. B. 1. Coatings, *Hot-melt, ...coatings* --
    FPA suggest deleting the word "typically" and replacing it with the
    phrase "very little or no solvents".

-   On page 9, Section IV. B. 1. Coatings, *Radiation-cure coatings*
    --Second paragraph, at the end of the line, EPA should add "&".

-   On page 10, Section IV. B. 2. Cleaning Materials -- The final CTG
    should substitute "job" for "color" in the second to last line.

-   On page 10, Section IV. B. 2. Cleaning Materials -- We are not sure
    what "automatic wash systems" refers to in this section. Cleaning of
    most coating line components are performed by hand or through use of
    soak tanks, as presently covered under existing Cold Cleaning RACT
    requirements. (FPA is not quarreling, however, with coverage of
    cleaning materials under this RACT.)

-   On page 10, Section V. A. 1. Pollution Prevention Measures -- Change
    first sentence. "Product substitution/reformulation is commonly used
    as a pollution prevention measure in the PFF surface coating
    industry to decrease VOC emissions from coatings.

-   On page 10, Section V. A. 1. Pollution Prevention Measures --
    Further changes: "These coatings are available for a number of
    applications. Conversion to these coatings can lower VOC emissions
    greatly.

-   On page 11, Section V. A. 2. *Capture Systems* -- In the last
    paragraph, we suggest deleting the word "canopy, which is not used
    in the industry to describe hoods or fume collection devices.

-   On page 11, Section V. A. 2. *Add-on Control devices* -- EPA should
    remove the phrase "with or without recycling of VOC emissions in the
    exhaust streams" in the second sentence because it is confusing and
    inaccurate.

-   On page 12, Section V. A. 2. *Adsorption* -- EPA should modify this
    section to state that "Carbon adsorbers are "*the type of adsorber"*
    most commonly used in the PFF..."

> **Conclusion *\-- ***The Flexible Packaging Association appreciates
> this opportunity to comment on the proposed EPA determination and
> draft CTG. If you have any questions, please feel free to contact me
> at 410/694-0823.
>
> Respectfully submitted,
>
> ![](media/image4.png)
>
> Ram Singhal
>
> Director, Regulatory & Government Relations
>
> Flexible Packaging Association