# T E C H N I C A L 

# S U P P O R T 

# D O C U M E N T

Department of the Environment 

## Amendments to — COMAR 26.11.19.07 Paper, Fabric, Film, Foil, Vinyl, and Other Plastic Parts Coating

Purpose of Amendments

The purpose of this action is to adopt the requi rements of the Environmental Protection Agency (EPA) Control Techniques Guidelines (CTG) for paper, film and foil coating. EPA develops CTGs as guidance on control requirements for sour ce categories. States can follow the CTGs or adopt more restrictive standards. MDE proposes to adopt the CTG standard s for paper, film and foil coatings.

Background

In 1977, EPA published a CTG for controlling VOC em issions from surface coating of paper. In October 1983, EPA promulgated the new source performance standards (NSPS) for surface coating of pressure sensitive tape and labels ( 1983 NSPS) which is a subs et of the paper, film, and foil surface coating industry. In December 2002, EPA promulgated the National Emission Standards for Hazardous Air Pollutants: Paper and Other Web Coating (2002 NESHAP).

The 1977 CTG, 1983 NSPS, and 2002 NESHAP provide information on the paper, film, and foil surface coating industry, VOC emi ssions, organic HAP emissions, available control technologies for addressing such emissions and the cost s of available control option. The 1977 CTG

recommends and the 1982 NSPS establishes VO C emission limits, whereas the 2002 NESHAP establishes organic HAP emission lim its and does not address non-HAP VOC.

The paper, film and foil coatings product ca tegory 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: pressure sensitive tape and labels; photographic film; industrial and decorative laminates; abrasive pr oducts (including fabric coated for use in abrasive products) and flexible packaging (including coating of non-wo ven polymer substrates for use in flexible packaging). The category also includes coatings applied during miscella neous coating operations for several products including: co rrugated and solid fiber boxes; die-cut paper paperboard and cardboard; converted paper and pa perboard; folding paperboard boxes, including sanitary boxes; manifold business forms and related products; pl astic asceptic packaging; and carbon paper and

inked ribbons.

Coating performed on or in-line with any offset lithographic, screen, lett erpress, flexographic, rotogravure, or digital printing pr ess is not part of the paper, film and foil coating category.

1Sources Affected and Location

These proposed amendments affect sources that coat pressure sensitive tape and labels, photographic film, industrial and d ecorative laminates, abrasive products, flexible packaging, corrugated and solid fiber boxes, die-cut paper paperboard, ca rdboard, converted paper and paperboard, folding paperboard boxes, manifold business forms and related products, plastic asceptic packaging, and carbon pape r and inked ribbons. These source s are located in the ozone

and PM non attainment areas.

Requirements of Amendments

These amendments establish VOC requirements for coating lines that have potential to emit 25 tons or greater per year. A pers on subject to this regulation may either meet VOC emission limits

or use an add-on emission control de vice to reduce VOC emissions by 90%.

Basis for Emission Standards

CTG standards are for coatings used by individual paper, film and foil surface coating lines with the potential to emit at least 25 tons or greater pe r year of VOC from coa tings, prior to controls.

At lower emission levels the coating lines cannot use low VOC content coatings and add-on controls are not cost effective. The op tion of using an enforceable limitation on potential emissions to keep an individual pa per, film and foil surface coating line below 25 tons per year potential to emit thre shold is also provided in the CTG.

Coating performed on or in-line with any offset lithographic, screen, lett erpress, flexographic, rotogravure, or digital printing pr ess is part of a printing process and is not part of the paper, film, and foil coating category. Therefore, the CTG standards do not apply.

Expected Emissions Reductions

The proposed amendments establish standards for co atings of paper, film and foil. Emissions of VOC are expected to be reduced by 90 percent on a national basis from paper, film and foil coating operations as a result of the combinati on of NESHAP and CTG st andards. This reduction will be much less in Maryland as MDE has alrea dy had regulations in place which have reduced VOC emissions from the coating of paper, film and foil and cleaning materials. VOC emissions have been reduced by 0.2 tons per day as a result of NESHAP standards.

Health Effects and Ground-Level Ozone

The maximum benefit from these amendments will be provided during the ozone season when VOCs readily combine with NOx to form the pollutant ground level ozone.

Economic Impact

These proposed regulatory amendments adopt the requirements of EPA’s CTG for paper, film and foil. The economic impact of these amendm ents has been estimated by EPA on a national

DRAFT 12/15/2009 1:09 PM 2DRAFT 12/15/2009 1:09 PM 3 level. Cost effectiveness is approximately $1,200 / ton of VOC controlled. The impact on the Department is going to be minimal as some of the applicable standards have changed.

Revision to Maryland's SIP

This action will be submitted to the U.S. EPA fo r approval as a revision to Maryland's State Implementation Plan.

Other State or Federal Requirements

There are no other state or fede ral reasonably available control technology standards for this category. Multiple facilities are covered under this CTG and each may be subject to additional federal requirements.

Comparison to Federal Standards

There is a corresponding federal standard to this proposed acti on, but the proposed action is not more restrictive or stringent.

References

Control Techniques Guidelines for Paper, Film, and Foil Coatings, EPA 453/R-07-003, September 2007