SUBJECT: Technical Support Document for Maryland’s Adoption of Control Techniques

Guidelines (CTG) for Paper, Film, and Foil Coatings.

FROM: Ellen Wentworth

Office of Air Program Planning

TO: File

?‘?a44:

THRU: Maria A. Pino, Acting Associate Director

Office of Air Program Planning

A. BACKGROUND

Ground-level ozone, a major component ofsmog, is formed in the atmosphere by reactions of

volatile organic compounds (VOCs) and oxides of nitrogen in the presence ofsunlight. The

formation of ground-level ozone is a complex process that is affected by many variables.

Exposure to ground-level ozone is associated with a wide variety of human health effects, as well

as agricultural crop loss, and damage to forests and ecosystems.

Under section 183(e) of the Clean Air Act (CAA), the Environmental Protection Agency (EPA)

conducted a study of VOC emissions from the use of consumer and commercial products toassess their potential to contribute to ground levels of ozone that violate the national ambient airquality standards (NAAQS) for ozone, and to establish criteria for regulating VOC emissions

from these products. Section 183(e) ofthe CAA directs EPA to list for regulation thosecategories of products that account for at least 80 percent ofthe VOC emissions, on a reactivityadjusted basis, from consumer and commercial products in areas that violate the NAAQS for

ozone (i.e., ozone nonattainment areas), and to divide the list of categories to be regulated intofour groups, one ofwhich will be regulated every two years. EPA published the initial list ofconsumer and commercial products identified for possible regulation and a schedule for

promulgation in the Federal Register on March 23, 1995 (60 FR 15264). In that notice, EPA

stated that it may amend the list and groups of products and the timetable for regulation in order

to achieve an effective regulatory program in accordance with the Agency’s discretion under

CAA section 183(e). EPA has revised andlor amended the categories several times since March

23, 1995. EPA published a revised regulation schedule on March 18, 1999 (64 FR 13422). EPA

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CAA section 1 72(c)( 1) provides that state implementation plans (SIPs) for nonattainment areas

must include reasonably available control measures (RACM), including reasonably available

control technology (RACT), for sources of emissions. EPA defines RACT as the “lowest

emission limitation that a particular source is capable ofmeeting by the application of control

technology that is reasonably available considering technological and economic feasibility(44 FR 53761, September 17, 1979). In subsequent notices, EPA has addressed how States can

meet the RACT requirements ofthe CAA.

CAA section 1 83(e)(3)(C) provides that EPA may issue a control technique guideline (CTG) in

lieu of a national regulation for a product category where the EPA determines that the CTG will

be substantially as effective as regulations in reducing emissions of VOC in ozone nonattainment

areas. CTGs are documents issued by EPA that provide guidance to States concerning what

types of controls could constitute RACT for a given source category. The recommendations inthe CTG are based on available data and information and may not apply to a particular situation

based upon the circumstances. States can follow the CTG and adopt State regulations to

implement the recommendations contained therein, or they can adopt alternative approaches. In

either case, States must submit their RACT rules to EPA for review and approval as part of theSIP process. EPA will evaluate the rules and determine, through notice and comment

rulemaking in the SIP approval process, whether the submitted rules meet the RACTrequirements of the CAA and EPA’s regulations.

CAA section 1 82(b)(2)(A) provides that for certain nonattainment areas, States must revise their

ozone SIPs to include RACT for VOC sources covered by any CTG document issued after

November 15, 1990, and prior to the date of attainment. Those ozone nonattainment areas that

are subject to CAA section 1 72(c)( 1) and submit an attainment demonstration seeking more thanfive years from the date of designation to attain must also meet the requirements of CAA section

182(b)(2) and revise their ozone SIP in response to any CTG issued after November 15, 1990,

and prior to the date of attainment. Other ozone nonattainment areas subject to CAA section

172(c)(1) may take action in response to this guidance, as necessary to attain the NAAQS.

On July 13, 1999 (64 FR 37783), EPA issued a notice announcing the reissuance of CTGs for

wood furniture coatings (61 FR 25223, May 20, 1996), shipbuilding and ship repair operations

surface coatings (61 FR 44050, August 27, 1996), and aerospace coatings (63 FR 15006, March

22, 1998). On October 5, 2006 (71 FR 58745), EPA issued a notice ofthe availability of CTGs

for lithographic printing materials, letterpress printing materials, flexible packaging printing

materials, flat wood paneling coatings, and industrial cleaning solvents. On October 9, 2007 (72

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that a CTG would be as effective as regulations 

reducing VOC 

nonattainment areas pursuant to section 183(e) is as follows: wood furniture coatings; aerospace

coatings; shipbuilding and repair coatings; lithographic printing materials; letterpress printing

materials; flexible packaging printing materials; flat wood paneling coatings; industrial cleaning

solvents; paper, film, and foil coatings; metal furniture coatings; large appliance coatings;

miscellaneous metal products coatings; plastic parts coatings; auto and light-duty truck assemblycoatings; fiberglass boat manufacturing materials; and miscellaneous industrial adhesives. EPA

promulgated national regulations that addressed VOC emissions from portable fuel containers onFebruary 26, 2007 (72 FR 8428), autobody refinishing coatings on September 11, 1998 (63 FR

48806), consumer products on September 11, 1998 (63 FR 48819), architectural coatings on

September 11, 1998 (63 FR 48848), and aerosol coatings, March 24, 2008 (73 FR 15604).

In May 1977, EPA published a CTG for controlling VOC emissions from the 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 ofthe paper,

film, and foil coatings surface coating industry. In December 2002, EPA promulgated the

National Emission Standards for Hazardous Air Pollutants: Paper and Other Web Coating (2002NESHAP). On September 28, 2007, after conducting a review of currently existing state and

local VOC emission reduction approaches for paper, film, and foil coatings, reviewing the May

1977 CTG, the 1983 NSPS for surface coating of pressure sensitive tape and labels, and the

December 2002 NESHAP, the EPA developed a new CTG for Paper, Film, and Foil Coatings,(EPA 453/R-07-003, September 2007), which established emission limits and work practices for

controlling VOC emissions from coatings and cleaning materials used in paper, film, and foil

surface coating operations.

Analysis of EPA’s September 2007 CTG for Paper, Film, and Foil Coatings

The paper, film, and foil surface coatings product category listed under section 183(e) ofthe

CAA includes coatings that are applied to paper, film, or foil surfaces in the manufacturing ofseveral major product types 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). 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 not elsewhere classified; folding

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Process Description

The paper, film, and foil surface coating process is a web coating process, which is a process that

applies a continuous layer of coating material across essentially the entire width or any portion of

the width of a web substrate to: (1) provide a covering, finish, or functional or protective layer to

a substrate; (2) saturate a substrate for lamination; or (3) provide adhesion between twosubstrates for lamination. The web coating operations and emission control techniques do not

vary significantly among the sectors ofthe paper, film, and foil surface coating industry. A

typical coating line consists of a series of one or more unwindlfeed stations; one or more coating

applicators; the flash-off area (the area between two or more consecutive coating applicators, or

between the coating applicator and the drying oven); one or more drying ovens; and one or more

rewind]cutting stations. There are several different types of coating applicators that may be usedto apply coatings. The most common types of applicators include: rotogravure, reverse roll, slot

die, knife, flexography, Mayer rod, dip and squeeze, and extrusion/calendaring. The type of

coating applicator used may differ among coating application stations in the same coating line.

For a description ofthese types of application processes please see a copy of EPA’s CTG issued

for Paper, Film, and Foil Coatings (EPA 453/R-07-003, September 2007) which is located in the

docket prepared for this rulemaking.

Applicability

The September 2007 EPA-issued CTG for Paper, Film, and Foil Coatings provides control

recommendations for reducing VOC emissions stemming from the use of coatings in paper, film,

and foil surface coating operations. The CTG is a guidance document and provides informationfor States to consider in determining RACT for this source category. In terms of applicability,

there are separate applicability recommendations for coating operations and cleaning operations.For coating operations, the applicability applies to individual coating lines with the potential to

emit (pte) 25 tons per year (tpy) or more of VOCs before consideration of control. Work practice

recommendations for cleaning apply to paper, film, and foil coating facilities with actual

emissions of 6.8 kg/day (15 lb/day) or more, before consideration of controls, from all covered

paper, film, and foil coating operations and related cleaning activities at the facility. For

purposes of determining whether a facility meets the 6.8/kg/day (15 lb/day) threshold, aggregate

emissions from all paper, film, and foil surface coating operations and related cleaning activitiesat a given facility, prior to controls, should be included.

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Primarily, VOC emissions from paper, film, and foil surface coating operations result from the

evaporation of volatile components from the coatings and cleaning materials. The majority of

VOC emissions from these materials occurs during coating applicationJflash-off, coating

curing/drying, and cleaning. The coating applicator(s)/flash-off area(s) and ovens are the mainVOC emissions sources on the coating line. The VOCs contained in the coatings evaporate from

the web into the coating applicationlflash-off area during coating application1flash-off or are

evaporated from the web during the heating process in the dryers. The remaining VOC

emissions are from cleaning operations.Coatings

In the past, conventional solvent-based coatings (which generally have a higher VOC content)have been used in the paper, film, and foil surface coating industry. Due to increased regulationat the federal and state level, the industry has moved toward alternative coating formulations that

reduce the amount of air emissions per unit amount of coating solids used. The types of coatingsused in the paper, film, and foil surface coating industry include solvent-borne, waterborne, hotmelt adhesives and other 100 percent solids coatings, reactive, and radiation-cure coatings. A

description of each ofthese coatings can be found in EPA’s CTG issued for Paper, Film, and FoilCoatings (EPA 453/R-07-003, September 2007) which can be located in the docket prepared for

this rulemaking.Cleaning Materials

Cleaning materials are another source of VOCs emitted by paper, film, and foil surface coatingoperations. Cleaning materials are used to remove excess coatings from coating equipment.

These materials are typically mixtures of organic solvents. The cleaning material may be a

solvent, or a specific mixture of individual solvents. Cleaning materials are used to wash the

coating applicators and outsides ofthe coating machines, and to remove residues of excesscoatings between job changes. Cleaning can be done manually using shop towels, for example.

CTG Recommended Control Options

As stately previously, there are two main sources of VOC emissions from paper, film, and foil

surface coating operations: (1) evaporation of VOCs from the coatings; and (2) evaporation of

VOCs from the cleaning materials. For purposes of this CTG, coatings are defined as materials

applied onto or impregnated into a substrate for decorative, protective, or functional purposes.

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To control VOC emissions from coatings used in paper, film, and foil surface coatings, EPA’s

CTG recommends an overall VOC control efficiency of 90 percent for each coating line.

Alternatively, EPA recommends emission limits that are equivalent to 90 percent overall control,

and recommends applying the control recommendations only to individual surface coating lines

with the pte, prior to controls, at least 25 tpy of VOCs from coatings. The coating line is defined

as a series of coating applicators, flash-off areas, and any associated curing/drying equipment

between one or more unwind/feed stations and one or more rewind/cutting stations. EPA alsorecommends providing paper, film, and foil surface coating facilities with the option of using an

enforceable limitation on potential emissions to keep an individual paper, film, and foil surface

coating line below this 25 tpy pte threshold.

As an alternative to an overall 90 percent control efficienëy, EPA’s CTG recommends VOC

content-based emission limits that are equivalent to 90 percent overall control, which can be met

by the use of low-VOC content materials or combinations ofmaterials and controls. To

determine these equivalent content-based emission limits for this product category (except for

pressure sensitive tape and label surface coating lines), EPA used the same baseline coating, 20weight percent solids and 80 weight percent solvent used to develop similar limits in the 2002

NESHAP. Using this baseline coating content, the VOC content-based emission limits

equivalent to 90 percent emission reduction are 0.40 kg VOC/kg (0.40 lb VOC/Ib) solids applied,

and 0.08 kg VOC/kg (0.08 lb VOC/ib) coating applied. EPA recommends these limits for paper,

film, and foil surface coating, except for pressure sensitive tape and label surface coating lines.

As an alternative to a 90 percent emission reduction for pressure sensitive tapes and labels, EPA

recommends the same alternative limit as the NSPS for pressure sensitive tapes and labels—0.20kg VOC/kg (0.20 lb VOC/ib) solids applied, and an additional equivalent limit of 0.067 kg

VOC/kg (0.067 lb VOC/lb) of coating as RACT for pressure sensitive tape and label surfacecoating lines.

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Units Sensitive Tape Surface Coating (Not

and Label including Pressure

Surface Coating Sensitive Tape and Label)

Emission Reduction (%) 90 90

kg VOC/kg solids

(lb VOC/lb solids) 0.20 0.40

kg VOC/kg coating

(lb VOC!lb solids) 0.067 0.8

The VOC content limits can be met by averaging the VOC content ofmaterials used on a singlesurface coating line each day (i.e., daily within-line averaging). EPA does not recommend the

use of cross-line averaging (i.e., averaging across multiple lines) to meet the VOC content limits.

Control of VOC Emissions from Cleaning Materials

To control VOC emissions from cleaning materials used in paper, film, and foil surface coatings,

EPA’s CTG recommends work practices be implemented in all paper, film, and foil surfacecoating facilities meeting the applicability threshold noted above. EPA’s CTG recommends that

facilities implement work practices to ensure that VOC emissions are minimized from mixing,storage, and handling of cleaning materials, and cleaning-related waste materials. Specifically,

EPA’s CTG recommends storing all VOC-containing cleaning materials in closed containers;

ensuring that mixing and storage containers used for VOC-containing materials be kept closed at

all times except when depositing or removing these materials; minimizing spills of VOC

containing cleaning materials; moving VOC-containing cleaning materials from one location to

another in closed containers or pipes; and minimizing VOC emissions from cleaning ofstorage,

mixing, and conveying equipment.

- B. STATE SUBMITTAL

On April 23, 2010, the Maryland Department ofthe Environment (MDE) submitted a SIP

revision to EPA adopting EPA’s CTG for Paper, Film, and Foil Coatings (EPA 453/R-06-003,

September 2007. This SIP revision includes amendments to Regulation .07, Paper, Fabric,

Vinyl, and Other Plastic Parts Coating, Section A--Definitions, and Section B--Applicability. In

addition, the amendments establish a new Section D--Emission Standards for Paper, Film, and

Foil Product Coatings with VOC Emissions (Potential to Emit) of 25 Tons or Greater Per Year.

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Processes, Section A--Definitions, by adding definitions used in the substantive provisions oftheregulation. This SIP revision adds the following definitions: “Coating line,” “Coating solids

applied,” “Flash-off area,” “Paper, film, and foil product,” “Paper, film, and foil product

coating,” and “Pressure sensitive tape and label surface coating.” The regulation has been

renumbered to reflect these changes.

COMAR 26.11.19., Regulation .07, Section B--Applicability

The April 23, 2010 SIP revision amends MDE’s Regulation .07, Paper, Fabric, Vinyl, and Other

Plastic Parts Coating, under COMAR 26.11.19, Volatile Organic Compounds from Specific

Processes, Section B--Applicability, by removing the existing language ofB(1), and replacingB(1) with the existing language ofB(2). A new provision for B(2) and B(3) has been added.

(See below). Section B--Applicability has been renumbered to reflect these changes.

Deleted provision:

B. Applicability.

(1) This regulation applies to a person who owns or operates any coating or printing

installation that is listed in and that has VOC emissions equal to or greater than the

applicability levels in §(C(2) and (3) ofthis regulation.

Revised/Additional provisions:

B. Applicability.

Former B. (2), now B. (1) and renumbered to reflect this change.

(1) This regulation does not apply to a person who is subject to the provisions of

Regulation.]] ofthis chapter fthe coating is applied at the same premises where the

printing is done.

New Provisionsfor B. (2) and B. (3):

(2) This regulation does not apply to any adhesive application that is subject to the provisions of

Regulation .]5 ofthis chapter.

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The April 23, 2010 SIP revision amends MDE’s Regulation .07, Paper, Fabric, Vinyl, and Other

Plastic Parts Coating, under COMAR 26.11.19, Volatile Organic Compounds from Specific

Processes by adding a new Section D to the existing regulation in order to comply with the CTG

emission standards for Paper, Film, and Foil Product Coatings. Listed below are the new

provisions ofthe regulation:

D. Emission Standardsfor Paper, Film, and Foil Product Coatings with VOC Emissions

(Potential to Emit) of25 Tons or Greater Per Year.

(1) A person who meets the applicability level of§B(3) ofthis regulation shall:

(a) Use add-on air pollution control equipment or reduce VOCfrom the

coating line by an overall capture and control efficiency ofat least 90

percent, by weight; or

(b) Meet thefollowing emission standardfor each coating line installation:

Paper, Film, and Foil Emission Standard (Ratio)

Coating lb VOC/lb solids or lb VOC/ib coating or

kg VOC/kg solids kg VOC/kg coating

Paper Film, and Foil 0.40 0.08

Coating other than a

Pressure Sensitive Tape

and Label Surface CoatingPressure Sensitive Tape 0.20 0.06

and Label Surface Coating

(2) Ifair pollution control equipment is used to meet §D(]) ofthis regulation, the

following requirements apply:

(a) Ifa thermal oxidizer is used, the combustion zone temperature shall be

continuously monitored;

(b) Ifa catalytic oxidizer is used, inlet and exhaust gas temperatures shall be

continuously monitored; and

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C. EPA EVALUATION AND RECOMMENDED AGENCY ACTION

The State of Maryland has adopted the standards and requirements ofthe September 2007 EPA

CTG for Paper, Film, and Foil Coatings, and is amending its SP to reflect these amendments.

This action will result in the reduction of VOC emissions from paper, film, and foil coating

sources and will help Maryland attain and maintain the NAAQS for ozone. EPA recommends

approval ofthis SIP revision.

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