TECHNICAL SUPPORT DOCUMENT

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 requirements 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 source categories. States can follow the CTGs or 

adopt more restrictive standards. MDE proposes to adopt the CTG standards for paper, film and 

foil coatings. 

Background 

In 1977, EPA published a CTG for controlling VOC emissions 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 subset 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 emissions, organic HAP emissions, available control technologies 

for addressing such emissions and the costs of available control option. The 1977 CTG 

recommends and the 1982 NSPS establishes VOC emission limits, whereas the 2002 NESHAP 

establishes organic HAP emission limits and does not address non-HAP VOC. 

The paper, film and foil coatings 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: pressure sensitive tape 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). 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; 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. 

1 
Sources Affected and Location 

These proposed amendments affect sources that coat pressure sensitive tape and labels, 

photographic film, industrial and decorative laminates, abrasive products, flexible packaging, 

corrugated and solid fiber boxes, die-cut paper paperboard, cardboard, converted paper and 

paperboard, folding paperboard boxes, manifold business forms and related products, plastic 

asceptic packaging, and carbon paper and inked ribbons. These sources 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 person subject to this regulation may either meet VOC emission limits 

or use an add-on emission control device 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 per year of VOC from coatings, 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 option of using an enforceable limitation 

on potential emissions to keep an individual paper, film and foil surface coating line below 

25 tons per year potential to emit threshold is also provided in the CTG. 

Coating performed on or in-line with any offset lithographic, screen, letterpress, flexographic, 

rotogravure, or digital printing press 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 coatings 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 combination of NESHAP and CTG standards. This reduction 

will be much less in Maryland as MDE has already 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 amendments has been estimated by EPA on a national 

DRAFT 2 12/15/2009 1:09 PM 
DRAFT 3 12/15/2009 1:09 PM 

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 for approval as a revision to Maryland's State 

Implementation Plan. 

Other State or Federal Requirements 

There are no other state or federal 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 action, 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