Via Email: teal.kim@epa.gov

March 5, 2007

Ms. Kim Teal

Environmental Protection Specialist

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

E143-03

Research Triangle Park, NC 27711

Re: Paper, Film & Foil CTGs

Dear Ms. Teal:

The Flexible Packaging Association (FPA) would like to provide the
following input concerning the development of CTGs for paper, film and
foil surface coatings, particularly because we have become concerned
with your note last Friday that EPA may be modeling the CTG closely on
the Paper and Other Web Coating MACT (40 CFR Part 63, Subpart JJJJ). As
you know, FPA is a national trade association, representing businesses
in the paper, foil, plastic and film converting industry. FPA members
use multiple printing and coating materials and processes to meet
ever-changing technical product demands and regulatory requirements for
the packaging of foods, pharmaceuticals, household goods, garden
supplies, cosmetics and other industrial, institutional and agricultural
applications. Flexible packaging is an over \$21 billion industry in the
United States and is the second largest segment of the U.S. packaging
market.

FPA's members understand the tight timeframe that the Court has imposed
on the Agency with respect to this project. We feel that we could be
helpful in providing data to EPA on the industry and our processes and
available controls, and therefore are requesting that you share a draft
of the CTG, and if that is not possible, that you arrange a meeting *as
soon as possible* to discuss data needs and questions relating to the
industry that have arisen as the CTG is being drafted. A similar
dialogue appeared particularly helpful to both EPA and the industry with
drafting and expediting the analysis of the printing and publishing
alternative §183(b) determination. We are also including the following
discussion to provide additional technical information and to amplify
our concern about modeling the CTG too closely on the POWC MACT.

FPA is aware that the relationship between HAPs and VOCs used in
industry are sometimes misunderstood, particularly with respect to the
interchangeability of HAPs with VOCs and the notion that a HAP
requirement will have an equivalent reduction in VOCs. For certain
industries, that rely heavily on HAP utilization, there may be merit to
this understanding, but for other industries, like flexible packaging,
this understanding is incorrect. The mechanism overwhelmingly used by
flexible packaging manufacturers to comply with both subpart JJJJ and KK
was through elimination of HAPs [by substitution with non-HAP
VOCs]{.underline}. The industry has expended huge amounts of time and
money on research & development efforts to eliminate utilization of
hazardous air pollutants from our manufacturing operations. Today only a
very few HAPs remain in use in our industry and typically only in low
quantities. However, substitution of VOCs with non-VOCs is not
technically feasible or economically available.

The flexible packaging industry utilizes a wide array of coatings,
including high solids, high VOC and high water content. Solids content
in a coating at application can vary from virtually 100% to less than
1%. The type of coating ultimately used is totally dependent on
functionality and performance. There is no one technology that can
accommodate all of our manufacturing needs. This industry has a vested
interest in avoiding VOC use where possible. For example, certain high
performance resins cannot be applied at 100 % solids and are not
dispersible for fluid application in water or other non-VOC solvents.
Consequently while we have some latitude in finding alternatives to
HAPs, there are applications that require the use of VOC solvents. For
these applications we commonly use control devices; importantly, the
control efficiencies achieved on many of these lines could not meet
subpart JJJJ requirements.

To better evaluate the impact of using subpart JJJJ criteria as a
replacement for currently RACT, we should look at a few illustrations
involving solvent-based coatings and water- based coatings. The current
Paper Coating RACT typically sets out a limit of 2.9 pounds of VOC per
gallon of coating applied minus water. This would equate to a solvent
based coating at roughly 60% solids/ 40% solvent by volume (≈66.6%
solids by weight). In terms of the NESHAP limit, current RACT would
equate to ≈0.5 pounds VOC per pound of solids. Conversely, the POWC sets
out HAP limits of 0.2 pounds HAP per pound of solids for existing
sources and 0.08 pounds of HAP per pound of solids for new sources.
These represent further reductions over the current RACT by 60 to 84%.
The upper bound for gravure application of solvent based coatings is
typically 40% solids by weight. At current RACT, a 40% solids coating
would need to be controlled to 67% efficiency to meet the limit.
However, the same coating at the POWC limits would require control
efficiencies of 87 to 95%. This level of efficiency would necessitate
the installation of total enclosures on all such applications. This is a
significant change that would not be either technologically or
economically feasible in many cases and would certainly not fall within
the technological and economic feasibility assessments that were
conducted for the POWC MACT development.

Another helpful illustration is provided by looking at water-based
coatings. The original RACT did not handle water-based coatings well
because of a misperception that an entity could just continually add
water to make a non-compliant coating compliant. Unfortunately, the POWC
approach compounds that problem. Since the original RACT ignored water,
a water-based coating needed to meet the same 66.6% solids/33.4% VOC
(2/1) ratio as a solvent based coating. However for any existing
operation where the coating VOC was above 4%, the solids to VOC ratio
would now become 5/1 to meet a POWC based RACT. And for any new
operation where the coating VOC was above 1.6%, the solids to VOC ratio
would need to be 12.5/1. Consequently a coating with 5% VOC and 85%
water would need to be controlled to meet a RACT limit based on the 0.2
POWC limit.

These illustrations of the problems with a RACT based on POWC limits
underscore our concern that the Agency would model the CTG it is
developing on the Subpart JJJJ MACT rule. Such a CTG would create an
enormous hardship on the industry and would without question make
manufacture of a number of commercial products infeasible. While we have
concerns that there may be other issues in the current RACT draft
document that we could help to clarify, we cannot stress strongly enough
that there is no transferability of the POWC based HAP limit to VOC
RACT.

FPA is willing to assist the EPA in any way possible to avoid lengthy
delays in developing appropriate guidance to meet court-imposed
deadlines on the Agency. The most expeditious way for us to provide your
project team input, of course, would be to be able to review drafts as
they are developed. If that is not possible, then we request that you
schedule a meeting with us prior to submission of the draft CTG for OMB
review.

Please call me at 410-694-0823 to arrange such a meeting and to discuss
any questions that you have for us.

Sincerely,

Ram K. Singhal

Director, Regulatory & Government Relations.

Cc: Bruce Moore (US EPA)

Heather Brown (EC/R Incorporated)