16.0 Paper, Film, and Foil Coating 

(2010 revision, draft 1) 

Q1111/1QQJ mm/ddJ2010 

16.1	 Applicability 

16.1.1	 The provisions of 16.0 of this regulation apply to any paper. film. or foil coating unit. 

16.1.2	 The provisions of 16.0 of this regulation do not apply to any paper. film. or foil coating unit 

within a facility whose actual emissions (including related cleaning activities) without 

control devices from all paper, film. and foil coating units within the facility are less than 

6.8 kilograms (kg) (15 pounds [Ib]) of volatile organic compounds (VOCs) per day. 

16.1.3	 An owner or operator of a facility whose emissions are below the applicability threshold in 

16.1.2 of this regulation shall comply with the certification, recordkeeping, and reporting 

requirements of 16.7.1 of this regulation. 

16.1.4	 Any facility that becomes or is currently subject to the provisions of 16.0 of this regulation 

by exceeding the applicability threshold in 16.1.2 of this regulation will remain subject to 

these provisions even if its emissions later fall below the applicability threshold. 

16.1.5	 Any facility that is currently subject to a state or federal rule promulgated pursuant to the 

Clean Air Act Amendments of 1977 by exceeding an applicability threshold is and will 

remain subject to these provisions, even if its throughput or emissions have fallen or later 

fall below the applicability threshold. 

16.1.6	 The provisions of 16.0 of this regulation does not apply to any coating unit in-line with 

any offset lithographic, screen, letterpress, flexographic, rotogravure, or digital printing 

operation. Such coating units may be subject to 37.0 or 47.0 of this regulation, 

whichever is applicable. 

16.1.7	 Transition period for existing permitted sources. Every owner or operator of any paper 

coating unit that is subject to a permit issued pursuant to 7 DE Admin Code 1102 or 

1130 containing all applicable conditions of 16.0 of this regulation, as that regulation 

existed on January 11, 1993, shall comply with those penmit conditions until December 

31, 2010. On and after January 1, 2011, every such owner or operator of any paper 

coating unit shall comply with the provisions of 16.0 of this regulation. 

16.2	 Definitions. As used in 16.0 of this regulation, all terms not defined herein shall have the 

meanings given them in the November 15, 1990 Clean Air Act Amendments (CAAA), or in 

2.0 of this regulation. 

"Coating" means a material being applied, or an action of applying such a material, onto or 

impregnated into a substrate for decorative, protective, or functional purpose. 

"Paper, film, or foil coating line" means a series of coating applicators, flash-off areas, and 

any associated curing/drying eguipment between one or more unwindlfeed stations and one 

or more rewind/cutting stations to apply a coating onto a continuous strip of substrate (a 

web). a web cgaliR!! liRe wRere cgaliR!! is applies Ig paper. film, gr foil, Printing presses are 

not considered pap8f coating lines. Products produced on a paper, film, or foil coating line 

include, but are not limited to, adhesive tapes and labels, book covers, post cards, office 

copier paper, drafting paper, and pressure sensnive tapes and labels, Paper cCoating lines 

include, but are not limited to, application by impregnation or saturation or by the use of roll, 
knife, or rotogravure coating. A !lB!l!!F coating line may include more than one !lB!l!!F coating 

units. 

"Paper, film, or foil coating unit" means a sealiRg applisalieR stalieR aRd ils assesialed 

tlasR eft area, er:yiR€I 3Fe3, 9r eveR V'ReFeiR seatiRQ is applies aRe dried er G~Fee SR a paper 

sealiRg liRe. A paper seatiRg liRe may iRslude mere IRaR eRe paper sealiRg URi!. any coating 

unit applying a coating to paper. film. or foil substrates used in the manufacturing of several 

major prodUct Noes for the following industry sectors: pressure sensitive tape and labels 

(including fabric coated for use in pressure sensitive tapes and labels): photographic film: 

industrial and decorative laminates: abrasive products (including fabric coated for use in 

abrasive products) and flexible packaging (including coating of non-woven polymer 

substrates for use in flexible packaging). Paper. film or foil coating unit also includes a 

coating unit applying a coating 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 aseptic 

packaging: and carbon paper and inked ribbons. 

16.3	 Standards. No owner or operator of any paper. film. or foil coating unit shall operate the 

coating unit unless the owner or operator meets the applicable reguirements listed under 

16.3.1	 16.3.2,16.3.3. and 16.3.4 of this regulation. 

16.3.1	 Except as specified in 16.3.2 of this regulation. NG no eWRer er eperaler ef a 

pa~eFG9atiRg IoIRit 6b1sjeGt is 16.g af tRis Fe€lbllatieR GRail Gabl69, aIl9lo..', SF permit tRe 

application of any coating on that unit with vac content in excess of 9.35 kilegrams per 

liler (kglbJ (2.9 peuRds per galiaR (Ill/gall) ef saaliRg, ellsludiRg waler aRa ellempl 

sampauRds, as applied 0.40 kilogram vac per kilogram of solid applied (kg/kg) (0.40 

pound of vac per pound of solid !Ibllbll. 

16.3.2	 For pressure sensitive tape and label surface coating. no application of any coating on 

that unit with VOC content in excess of 0.20 kilogram VOC per kilogram of solid applied 

(kg/kg) (0.20 pound of VOC per pound of solid [lbOb]). 

16.3.~ As an alternative to compliance with the emission limit in 16.3.1 or 16.3.2 of this 

regulation, an owner or operator of a paper, film, or foil coating unit sulljaGlle 16.9 af IRis 

ragulaliaR may meet the requirements of 16.4 or 16.5 ofthis regulation. 

16.3.4	 When handling cleaning materials, an owner or operator of a paper, film, or foil coating 

unit shall comply with 8.0 of this regulation. 

16.4	 Daily-weighted average limitation. No owner or operator of a paper, film. or foil coating unit 

subject to 16.0 of this regulation shall apply, during any day, coatings on that unit whose 

daily-weighted average vac content, calculated in accordance with the procedure specified 

in Appendix C of this regulation, exceeds the emission limit in 16.3.1 or 16.3.2 of this 

regulation. whichever is applicable. 

16.5	 Control devices 

16.5.1	 An owner or operator of a paper. film. or foil coating unit subject to 16.0 of this regulation 

may comply with 16.0 of this regulation by: 

16.5.1.1 Installing and operating a capture system on that unit. 

16.5.1.2 Installing and operating a control device on that unit. 
16.5.1.3	 Determining for each day the overall emission reduction efficiency needed to 

demonstrate compliance. The overall emission reduction needed for a day is the 

lesser of the value calculated according to the procedure in 3.0 of Appendix C of 

this regulation for that day or 95%. If the calculated efficiency is less than 90%. 

use 90% as the needed efficiency. 

16.5.1.4	 Demonstrating each day that the overall emission reduction efficiency achieved 

for that day, as determined in 3.0 of Appendix D of this regulation, is greater than 

or equal to the overall emission reduction efficiency req~ired needed for that day 

as determined in 16.5.1.3 of this regulation. 

16.5.2	 An owner or operator of a paper. film, or foil coating unit subject to 16.0 of this regUlation 

shall ensure that: 

16.5.2.1	 A capture system and control device are operated at all times the coating unit is 

in operation, and the owner or operator demonstrates compliance with 16.0 of 

this regulation through the applicable coating analysis and capture system and 

control device efficiency test methods specified in Appendix B, Appendix D and 

Appendix E of this regulation and in accordance with the capture efficiency test 

methods in Appendix D of this regulation. 

16.5.2.2	 The control device is equipped with the applicable monitoring equipment 

specified in 2.0 of Appendix D of this regulation, and the monitoring equipment is 

installed, calibrated, operated, and maintained according to the vendor's 

specifications at all times the control device is in use. 

16.6	 Test methods. The test methods found in Appendix A through Appendix D of this regUlation 

shall be used to determine compliance with 16.0 of this regulation. 

16.7	 Recordkeeping and reporting 

16.7.1	 An owner or operator of a paper. film, or foil coating unit that is exempt from the emission 

limitations in 16.3 of this regulation shall comply with the certification reguirements in 4.2 

of this requlation within six months after [insert the effective date of this revision of 16.01, 

and with the recordkeeping, and reporting requirements in 4.2 of this regulation on and 

after [insert the effective date of this revision of 16.01. 

16.7.2	 An owner or operator of a paper, film, or foil coating unit subject to 16.0 of this regulation 

and complying with 16.3 of this regulation by the use of complying coatings shall comply 

with the certification reqUirements in 4.3 of this regulation within six months after [insert 

the effective date of this revision of 16.01, and with the recordkeeping, and reporting 

requirements in 4.3 of this regulation on and after [insert the effective date of this revision 

of 16.01. 

16.7.3	 An owner or operator of a paper. film or foil coating unit subject to 16.0 of this regUlation 

and complying with 16.4 of this regulation by daily-weighted averaging shall comply with 

the certification, recordkeeping, and reporting reqUirements in 4.4 of this regUlation. 

16.7.4	 An owner or operator of a paper. film, or foil coating unit subject to 16.0 of this regulation 

and complying with 16.5 of this regulation by the use of control devices shall comply with 

the testing requirements in 4.5 of this regulation wilhin six months after [insert the 

effective date of this revision of 16.01. and with the reporting, and recordkeeping 

requirements in 4.5 of this regUlation on and after [insert the effective date of this revision 

of 16.01.