7 DE Admin Code 1124 "Control of Volatile Organic Compound Emissions" 

16.0 Paper, Film, and Foil Coating 

03/11/2011 

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 permit conditions for up to one year 

after the effective date of this revision of 16.0 of this regulation. On and after the date 

one year after the effective date of this revision of 16.0 of this regulation, 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 equipment between one or more unwind/feed stations and one or 

more rewind/cutting stations to apply a coating onto a continuous strip of substrate (a web). 

Printing presses are not considered 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 sensitive tapes and labels. Coating 

lines inclUde, but are not limited to, application by impregnation or saturation or by the use of 

roll, knife, or rotogravure coating. A coating line may include more than one coating unit 

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"Paper. film, or foil coating unit" means any coating unit applying a coating to paper, film, or 

foil substrates used in the manufacturing of several 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). 

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 requirements 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, no application of any coating on that unit 

with vac content in excess of 0.40 kilogram vac per kilogram of solid applied (kg/kg) 

(0.40 pound of vac per pound of solid [Ibllb]). 

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

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

(kg/kg) (0.20 pound of vac per pound of solid [Ib/lbn. 

16.3.3	 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 may meet the 

requirements of 16.4 or 16.5 of this 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 dailyweighted 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. 

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16.5.1.4	 Demonstrating each day thallhe overall emission reduction efficiency achieved 

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

than or equal to the overall emission reduction efficiency 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 unilsubject 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 coaling 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 requirements in 4.2 

of this regulation within six months after March 11, 2011, and with the recordkeeping and 

reporting requirements in 4.2 of this regulation on and after March 11, 2011. 

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 March 

11, 2011, and with the recordkeeping and reporting requirements in 4.3 of this regulation 

on and after March 11,2011. 

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 within six months after March 11, 2011, 

and with the reporting and recordkeeping requirements in 4.5 of this regulation on and 

after March 11, 2011. 

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