# Control Techniques Guidelines for

**Paper, Film, and Foil Coatings**

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# EPA 453/R-07-003

**September 2007**



# Control Techniques Guidelines for

Paper, Film, and Foil Coatings

**U.S. Environmental Protection Agency**

**Office of Air Quality Planning and Standards**

**Sector Policies and Programs Division**

**Research Triangle Park, NC**

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# i

TABLE OF CONTENTS

I. Introduction

**................................................... ...................................................**  **..... 1**

II. Background and Overview

**................................................... ................................ 2** 

III. Applicability

**................................................... ...................................................**  **.... 3**

IV. Process Description and Sources of VOC Emissions **......................................... 5**

**A. Process Description.............................**

**................................................... ........... 5** 

**B. Sources of VOC Emissions........................**

**................................................... .... 7** 

V. Available Control Options and Regulatory Approaches **................................ 10**

**A. Available Controls for VOC Emissions from Coatin gs.................................. 11** 

**1. Pollution Prevention Measures ................... .............................................. 11** 

**2. Emission Capture and Add-on Control Systems ..... ................................. 11** 

**B. Available Controls for Cleaning Materials....... .............................................. 14** 

**1. Product Substitution/Reformulation .............. ........................................... 14** 

**2. Work Practice Procedures........................ ................................................. 14** 

**C. Existing Federal, State, and Local Recommendatio ns or Regulations ........... 14** 

**1. The 1977 CTG ....................................**

**................................................... ... 14** 

**2. The 1983 NSPS...................................**

**................................................... ... 15** 

**3. The 2002 NESHAP................................. .................................................. 1**  **5**

**4. Existing State and Local VOC Requirements....... .................................... 16** 

VI. Recommended Control Options

**................................................... ..................... 17** 

**A. Coatings ........................................**

**................................................... ............... 17** 

**B. Cleaning Materials..............................**

**................................................... ......... 19** 

VII. Cost Effectiveness of Recommended Control Options **.................................... 19**

VIII. References

**................................................... ...................................................**  **...... 21**

LIST OF APPENDICES

**Appendix A: Control of Volatile Emissions from Exi sting Stationary Sources - Volume II:** 

**Surface Coating of Cans, Coils, Paper, Fabrics, Aut omobiles, and Light-Duty** 

**Trucks**

**Appendix B: Paper, Film, and Foil Surface Coating Facilities in Current Nonattainment Areas** 

**and Associated State or Local Requirements (Based o n 2002 NEI and December** 

**2006 Nonattainment Designations)**

**Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating** 

**Facilities (not including California)**

**Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating** 

**Facilities**

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# 1

I. Introduction

**Clean Air Act (CAA) section 172(c)(1) provides that state implementation plans (SIPs)** 

**for nonattainment areas must include “reasonably av ailable control measures” (RACM),** 

**including “reasonably available control technology” (RACT), for sources of emissions. Section** 

**182(b)(2)(A) provides that for certain nonattainmen t areas, States must revise their SIPs to** 

**include RACT for each category of volatile organic compound (VOC) sources covered by a** 

**control techniques guidelines (CTG) document issued between November 15, 1990 and the date** 

**of attainment.**

**The United States Environmental Protection Agency ( EPA) defines RACT as “the lowest** 

**emission limitation that a particular source is cap able of meeting by the application of control** 

**technology that is reasonably available considering technological and economic feasibility.” 44** 

**FR 53761 (Sept. 17, 1979). In subsequent Federal R egister notices, EPA has addressed how** 

**states can meet the RACT requirements of the Act.**

**CAA section 183(e) directs EPA to list for regulati on those categories of products that** 

**account for at least 80 percent of the VOC emission s, on a reactivity-adjusted basis, from** 

**consumer and commercial products in areas that viol ate the NAAQS for ozone (i.e., ozone** 

**nonattainment areas). EPA issued the list on March 23, 1995, and has revised the list** 

**periodically.** See **60 FR 15264 (March 23, 1995);** see also **71 FR 28320 (May 16, 2006), 70 FR**

**69759 (Nov. 17, 2005); 64 FR 13422 (Mar. 18, 1999). Paper, film, and foil coatings are included** 

**on the current section 183(e) list.**

**This CTG is intended to provide state and local air pollution control authorities** 

**information that should assist them in determining RACT for volatile organic compounds** 

**(VOCs) from paper, film, and foil coatings. In dev eloping this CTG, EPA, among other things,** 

**evaluated the sources of VOC emissions from the pap er, film, and foil coating industry and the** 

**available control approaches for addressing these e missions, including the costs of such** 

**approaches. Based on available information and dat a, EPA provides recommendations for** 

**RACT for paper, film, and foil coating.**

**States can use the recommendations in this CTG to i nform their own determination as to** 

**what constitutes RACT for VOCs for paper, film, and foil coatings in their particular** 

**nonattainment areas. There are several hazardous a ir pollutants (HAP) that are also VOCs. The** 

**information contained in this document is provided only as guidance. This guidance does not** 

**change, or substitute for, requirements specified i n applicable sections of the CAA or EPA’s** 

**regulations; nor is it a regulation itself. This d ocument does not impose any legally binding** 

**requirements on any entity. It provides only recom mendations for state and local air pollution** 

**control agencies to consider in determining RACT. State and local pollution control agencies are** 

**free to implement other technically-sound approache s that are consistent with the CAA and** 

**EPA’s implementing regulations.**

**The recommendations contained in this CTG are based on data and information currently** 

**available to EPA. These general recommendations ma y not apply to a particular situation based** 

**upon the circumstances of a specific source. Regar dless of whether a State chooses to implement** 

# 2

**the recommendations contained herein through State rules, or to issue State rules that adopt** 

**different approaches for RACT for VOCs from paper, film, and foil coatings, States must submit** 

**their RACT rules to EPA for review and approval as part of the SIP process. EPA will evaluate** 

**the rules and determine, through notice and comment rulemaking in the SIP approval process,** 

**whether the submitted rules meet the RACT requireme nts of the CAA and EPA’s regulations.** 

**To the extent a State adopts any of the recommendat ions in this guidance into its State RACT** 

**rules, interested parties can raise questions and o bjections about the substance of this guidance** 

**and the appropriateness of the application of this guidance to a particular situation during the** 

**development of the State rules and EPA’s SIP approv al process.** 

**Section 182(b)(2) of the CAA requires that a CTG is sued between November 15, 1990,** 

**and the date of attainment include the date by whic h States subject to 182(b) must submit SIP** 

**revisions in response to the CTG. Accordingly, EPA is providing in this CTG a one-year period** 

**for the required submittal. Pursuant to section 18 2(b)(2), States required to submit rules** 

**consistent with section 182(b) must submit their SI P revisions within one year of the date of** 

**issuance of the final CTG for paper, film, and foil coatings. States subject only to the RACT** 

**requirements in CAA section 172(c)(1) may take acti on in response to this CTG, as necessary to** 

**achieve attainment of the national primary ambient air quality standards.** 

II. Background and Overview

**There have been three federal actions relative to s ome or all segments of the paper, film,** 

**and foil surface coating industry. In May 1977, EP A published a CTG for controlling VOC** 

**emissions from surface coating of paper (1977 CTG). 1**  

# In October 1983, EPA promulgated the

**new source performance standards (NSPS) for surface coating of pressure sensitive tape and** 

**labels (1983 NSPS) 2**  

# which is a subset of the paper, film, and foil sur **face coating industry.**

**Finally, in December 2002, EPA promulgated the Nati onal Emission Standards for Hazardous** 

**Air Pollutants: Paper and Other Web Coating (2002 NESHAP).**  **3**



# The 1977 CTG, 1983 NSPS, and 2002 NESHAP provide a **thorough discussion of the**

**paper, film, and foil surface coating industry, the nature of VOC emission (and in the case of the** 

**2002 NESHAP, organic HAP emissions) from the indust ry, available control technologies for** 

**addressing such emissions, the costs of available c ontrol options, and other information. The** 

**1977 CTG recommends and the 1982 NSPS establishes V OC emission limits, whereas the 2002** 

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

**At least 44 State and local jurisdictions have spec ific regulations that control VOC** 

**emissions from paper, film, and foil surface coatin g operations (or segments of the paper, film,** 

**and foil surface coating industry). A discussion o f the applicability and control options found in** 

**the federal actions and State and local rules is pr esented in Section V of this document.** 

**We developed the recommended approaches contained i n this document after reviewing** 

**existing State and local VOC emission reduction app roaches, the 1977 CTG, the 1983 NSPS,** 

**and the 2002 NESHAP, as well as information obtaine d since issuance of the 2002 NESHAP.** 

# 3

**The remainder of this document is divided into six sections. Section III describes the** 

**scope of sources to which the control recommendatio ns in this CTG could apply. Section IV** 

**describes the paper, film, and foil industry, inclu ding the types of paper, film, and foil products,** 

**coating materials (i.e., coatings and adhesives) an d the coating processes, and identifies the** 

**sources of VOC emissions from these processes. Sec tion V describes the available control** 

**approaches for addressing VOC emissions from this p roduct category and summarizes Federal,** 

**State and local approaches for addressing such emis sions. Section VI provides our** 

**recommendations for RACT for paper, film, and foil coating. Section VII discusses the cost** 

**effectiveness of the recommended control approaches . Section VIII contains a list of references.** 

III. Applicability

**This CTG provides control recommendations for redu cing VOC emissions stemming** 

**from the use of coatings in paper, film, and foil s urface coating operations. This section** 

**addresses EPA's recommendations as to the scope of entities to which the RACT** 

**recommendations in this CTG should apply. As expla ined above, this document is a guidance** 

**document and provides information for States to con sider in determining RACT. When State** 

**and local pollution control agencies develop RACT r ules, they may elect to adopt control** 

**approaches that differ from those described in this document and/or promulgate applicability** 

**criteria that differ from those recommended here.**

**In terms of applicability, we recommend that the c ontrol approaches for cleaning** 

**discussed in section VI of this CTG apply to each f acility where the total actual VOC emissions** 

**from all paper, film and foil coating operations, i ncluding related cleaning activities, are equal to** 

**or exceed 6.8 kg/day (15 lb/day), or an equivalent level such as 3 tons per 12-month rolling** 

**period, before consideration of controls.**

**We do not recommend these control approaches for f acilities that emit below this level** 

**because of the very small VOC emission reductions t hat can be achieved. The recommended** 

**threshold level is equivalent to the evaporation of approximately two gallons of solvent per day.** 

**Such a level is considered to be an incidental leve l of solvent usage that could be expected even** 

**in facilities that use very low-solvent coatings, s uch as UV cure coatings. Furthermore, based on** 

**the 2002 NEI data and the 2004 ozone nonattainment designations, facilities emitting below the** 

**recommended threshold level collectively emit less than 2 percent of the total reported VOC** 

**emissions from paper, film, and foil coating facili ties in ozone nonattainment areas. For these** 

**reasons, we are not extending our recommendations i n this CTG to these low emitting facilities.** 

**For purposes of determining whether a facility meet s the 6.8 kg/day (15 lb/day) threshold,** 

**aggregate emissions from all paper, film, and foil surface coating operations and related cleaning** 

**activities at a given facility, prior to controls, are included.** 

**We recommend applying the control recommendations for coatings only to individual** 

**paper, film and foil surface coating lines with the potential to emit at least 25 tons per year (tpy)** 

**of VOC from coatings, prior to controls. We do not extend our control recommendations for** 

**coating operations to coating lines with the potent ial to emit below this threshold because some** 

**of these coating lines cannot use low VOC content c oatings and add-on controls will generally** 

**be too costly for the emission reduction that would be achieved from these low-emitting coating** 

# 4

**lines. We believe that control of a surface coatin g line that has a potential to emit above the 25** 

**tpy threshold (prior to controls) will generally be cost effective. We also recommend providing** 

**paper, film, and foil surface coating facilities wi th 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 potential to emit threshold.**

**In addition, coating performed on or in-line with a ny offset lithographic, screen,** 

**letterpress, flexographic, rotogravure, or digital printing press is part of a printing process and i**  **s**

**not part of the paper, film, and foil coating categ ory. Size presses and on-machine coaters on** 

**papermaking machines apply sizing (e.g., starch) or water-based clays are part of the** 

**papermaking process and are not part of the paper, film, and foil coatings category. Therefore,** 

**the recommendations in this final CTG do not apply to these activities.** 

**For those facilities where actual emissions from al l paper, film and foil surface coating** 

**operations are greater than 15 lb/day before consid eration of controls, and where no individual** 

**coating lines have the potential to emit 25 tpy or more of VOC before controls, we recommend** 

**applying only the recommended work practices for cl eaning.** 

**In developing their RACT rules, State and local age ncies should consider carefully the** 

**facts and circumstances of the affected sources in their States. As noted above, States can adopt** 

**the above recommended 6.8 kg/day (15 lb/day) actual VOC emissions or equivalent applicability** 

**criterion, or they can develop other applicability criteria that they determine are appropriate** 

**considering the facts and circumstances of the sour ces in their particular nonattainment areas.** 

**EPA will review the State RACT rules in the context of the SIP revision process.** 

**Based on the 2002 National Emission Inventory (200 2 NEI), we estimate that there are** 

**716 paper, film, and foil surface coating facilitie s in the United States. Of these, we estimate that** 

**474 facilities are located in current ozone nonatta inment areas (based on April 2004** 

**designations) and 251 of the facilities located in ozone nonattainment areas emit more than the** 

**6.8 kg/day (15 lb/day) VOC applicability threshold described above. The 2002 NEI was also** 

**used as the source of statistical information conce rning the paper, film, and foil surface coating** 

**industry as a whole.**

**According to the 2002 NEI, paper, film, and foil s urface coating facilities are located** 

**throughout the United States, with the Pacific Coas t and the Northeastern States having the** 

**largest numbers of facilities. Appendix B shows th at these facilities are distributed across 21** 

**States. Appendices C and D summarize the current S tate and/or local requirements that are** 

**applicable to paper, film and foil surface coating.**

**In addition to the 2002 NEI, we reviewed relevant information in the Background** 

**Information Document (BID) for the 2002 NESHAP. 4**  

# The BID for the 2002 NESHAP

**indicated that there are about 429 paper, film, and foil surface coating facilities in the United** 

**States. This information was based on the 1996 Tox ic Release Inventory (TRI) database for 12** 

**Standard Industrial Classification (SIC) codes iden tified for the paper and other web industry.** 

**We believe that the NEI data provides a more accura te and current prediction of the total number** 

**of paper, film, and foil surface coating facilities**

**.**

# 5

IV. Process Description and Sources of VOC Emissions

**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 for the following industry sect ors: pressure sensitive tape and labels** 

**(including fabric coated for use in pressure sensit ive tapes and labels); photographic film;** 

**industrial and decorative laminates; abrasive produ cts (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 co atings applied during miscellaneous coating** 

**operations for several products including: corrugat ed and solid fiber boxes; die-cut paper** 

**paperboard, and cardboard; converted paper and pape rboard not elsewhere classified; folding** 

**paperboard boxes, including sanitary boxes; manifol d business forms and related products;** 

**plastic asceptic packaging; and carbon paper and in ked ribbons.** 

**Coating performed on or in-line with any offset li thographic, screen, letterpress,** 

**flexographic, rotogravure, or digital printing pres s is not part of the paper, film and foil coating** 

**category. In addition, size presses and on-machine coaters that function as part of an in-line** 

**papermaking system are not part of the paper, film, and foil coating category. The application of** 

**inks, coatings and adhesives on or in-line with rot ogravure or flexographic printing presses used** 

**in the production of flexible packaging is addresse d in the CTG for Flexible Package Printing** 

**(EPA 453/R-06-003, September 2006). The applicatio n of inks, coatings and adhesives on or in** 

**line with publication rotogravure printing presses is addressed in the CTG for Graphic Arts:** 

**Rotogravure and Flexography (EPA 450/2-78-033). Th e application of inks, coatings and** 

**adhesives on or in-line with offset lithographic or letterpress printing presses is addressed in the** 

**CTG for Offset Lithographic Printing and Letterpres s Printing (EPA 453/R-06-002, September** 

**2006).**

**A. Process Description** 

**The paper, film, and foil surface coating process can be described as a web coating** 

**process, which is a process that applies a continuo us layer of coating material across essentially** 

**the entire width or any portion of the width of a w eb substrate to: (1) provide a covering, finish,** 

**or functional or protective layer to a substrate; ( 2) saturate a substrate for lamination; or (3) to** 

**provide adhesion between two substrates for laminat ion. The web coating operations and** 

**emission control techniques do not vary significant ly among the sectors of the paper, film, and** 

**foil surface coating industry.**

**A typical coating line consists of a series of one or more unwind/feed stations; one or** 

**more coating applicators; the flash-off area (the a rea between two or more consecutive coating** 

**applicators or between the coating applicator and t he drying oven); one or more drying ovens;** 

**and one or more rewind/cutting stations.**

**There are several different types of coating appli cators that may be used to apply** 

**coatings. The most common types of applicators incl ude: rotogravure, reverse roll, slot die,** 

# 6

**knife, flexography, Mayer rod, dip and squeeze, and extrusion/calendering.**  **4** 

# The type of coating

**applicator used may differ among coating applicatio n stations in the same coating line.** 

Rotogravure **(web-fed gravure) coaters are used extensively by the printing industry, but** 

**they are also used for coating. The coating materi als (or inks) are picked up in the recessed areas** 

**of the roll and transferred directly to the substra te. Several gravure coaters may be combined on** 

**one coating line. In gravure coating, the coatings include both solvent and waterborne systems.**  **4**



# The reverse roll **coater applies a constant thickness of coating to t he substrate, usually by** 

**means of three rollers--a metering roller, a backin g roller, and an applicator (transfer) roller. A** 

**metering roller picks up the coating solution from a trough and transfers it to an applicator roller.** 

**(Sometimes there is no metering roller and the coat ing is pumped directly onto an applicator** 

**roller.) The web is supported by a backing roller where the applicator roller contacts the paper.** 

**The applicator roller then transfers the coating to the substrate, as the web passes between the** 

**backing roller and the applicator roller. The appl icator roller turns in a direction opposite to that** 

**of the paper, hence the name reverse roll coater. This reverse direction of the applicator roller** 

**reduces striations in the coating that can form if the applicator roller is turned in the same** 

**direction as the paper web.**

**The** slot die **coater is similar to an extruder but is less heavy -duty than an extruder since** 

**less viscous materials are used with a slot die coa ter (a discussion of extruders is provided further** 

**below). In a slot die coater, the coating is extru ded through an adjustable-width orifice onto the** 

**substrate and is sometimes followed by a smoothing roller. Slot die coaters are typically used for** 

**application of hot-melt coatings and adhesives, but may also be used to apply aqueous coatings.**  **4**



# A knife **coater consists of a blade that scrapes off excess coating from the substrate. The** 

**tray or trough of coating is located behind the kni fe blade. A continuous sheet of substrate is** 

**drawn between the knife blade and the support rolle r. As coating is deposited on the substrate,** 

**the knife blade spreads it across the substrate to the desired thickness. The position of the knife** 

**relative to the substrate surface can be adjusted t o control the thickness of the coating. Some** 

**knife coaters use high velocity air as the knife bl ade; these are known as air-knife coaters.** 

**Knife coaters can apply solutions of much higher vi scosity than roll coaters, thus less solvent is** 

**emitted per pound of coating applied. Knife coater s handle coatings with viscosity up to** 

**10,000 centipoise (cp), while reverse roll coaters operate best with coatings that have a viscosity** 

**ranging from 300 to 1500 cp. Knife coaters, howeve r, usually operate at lower speeds than roll** 

**coaters and show a greater tendency to break the we b.**  **4**



# In flexographic **coating, the area to be coated is delineated by a raised surface on a** 

**flexible plate that is usually made of rubber or ot her elastomeric materials. Because of the ease** 

**in plate preparation, flexography is more suited to short production runs than gravure. Coating** 

**materials applied with flexography must be very flu id to work properly and include waterborne** 

**and solvent-based systems. The solvents used must be compatible with the rubber or polymeric** 

**plates; thus aromatic solvents are not used. Flexo graphy is performed both on wide web (<18** 

**inches) and narrow web (<18 inches), and on sheets as well as web.**  **4**

# 7

**The** Mayer rod

**(or wire-wound rod) coater is a metering device us ed to control the** 

**thickness of an applied coating. Typically, the coa ting is applied via a roller, and the excess** 

**coating is removed by a rod covered by a spiral-wou nd stainless steel wire. The rod wipes the** 

**coating off the substrate except for the portion wh ich escapes through the spaces between the** 

**wires. Larger wire diameters result in larger spac es, and therefore heavier coatings.**  **4**



# The dip and squeeze **coater, also called a dip coater, impregnates or s aturates the** 

**substrate rather than applying a coating to the web surface. The substrate is fed and dipped into** 

**a coating-filled pan by a system of rollers. The s aturated web is then passed through nip rollers** 

**that squeeze off any excess coating. 4** 



# The extrusion **coater creates a web substrate or applies coating materials to a preformed** 

**web substrate by forcing it through a die. A typic al extrusion coater forms a plastic film or** 

**coating of the hot-melt type by forcing a molten po lymer resin through a die as the web passes** 

**below the die. The extruded web is then cooled to restore the coating to a solid state. Nearly all** 

**extrusion coatings are made of low-density polyethy lene (LDPE). They account for a large** 

**portion of the coatings used in the printing produc t and packaging industry, divided about evenly** 

**between cartons/cardboard and flexible materials. 4** 



# In calendering **, a process similar to extrusion, material is press ed by a roller or between** 

**rollers to form a web such as vinyl sheeting. Calen dering may also be used to apply a coating to** 

**a substrate, as in the manufacture of duct tape. P rior to calendering, resins, plasticizers, and** 

**pigments are blended together in a series of blende rs, mixers, and mills. Plasticizers are used to** 

**improve the flexibility of the coating/material. A fter mixing, the mixture is conveyed to the** 

**calender. In a typical four-roll calender, the mol ten coating is rolled into a continuous sheet,** 

**which is then cooled. 4** 



# After the coating application described above, the **applied coating may be heat dried or**

**cured in one or more drying ovens. The major funct ions of the drying oven are to dry the coating** 

**by evaporating the solvent and/or finish the curing of a polymeric coating.** 

**Cleaning activities also occur at paper, film, and foil surface coating facilities. Cleaning** 

**materials are used during these activities to remov e coating residue or other unwanted materials** 

**from equipment related to coating operations, as we ll as spray gun cleaning, etc. Cleaning** 

**materials are typically mixtures of VOC-containing solvents.** 

**B. Sources of VOC Emissions** 

**Primarily, VOC emissions from paper, film, and foi l surface coating operations result** 

**from the evaporation of volatile components of the coatings and cleaning materials.**  **a** 

# The

**majority of VOC emissions from these materials occu r during coating application/flash-off,** 

**a** 

# In a previous notice, EPA identified specific cate **gories, including paper, film and foil coating, the cleaning** 

**operations of which would not be covered by EPA’s 2 006 CTG for industrial cleaning solvents (71 FR 445**  **22,**

**44540, October 5, 2006). In the notice, EPA expres sed its intention to address cleaning operations as**  **sociated with**

**these categories in the CTGs for these specified ca tegories if the Agency determines that a CTG is app**  **ropriate for**

**the respective categories.**

# 8

**coating curing/drying, and cleaning. The coating a pplicator(s)/flash-off area(s) and oven(s) are** 

**the main VOC emissions sources on the coating line. The VOC contained in the coatings** 

**evaporate from the web into the coating application /flash-off area during coating** 

**application/flash-off or are evaporated from the we b during the heating process in the dryers.** 

**The remaining VOC emissions are from cleaning opera tions. In most cases, VOC emissions** 

**from mixing, surface preparation, handling and stor age of coatings and solvents, and** 

**waste/wastewater operations are small. The followi ng discussion describes the two primary** 

**emission sources (coatings and cleaning materials).**

**1. Coatings** 

**The VOC emissions from paper, film, and foil coati ngs occur during coating** 

**application/flash-off and drying/curing of the coat ings. Some of the VOC in the coatings** 

**evaporates from the web into the coating applicatio n area during coating application. Additional** 

**VOC evaporates from the web in the flash-off area ( prior to entering the dryer). The majority,** 

**usually greater than 90 percent, of the VOC in the coatings volatilizes in the drying ovens. The** 

**VOC that evaporates from the web in the drying oven (s) are vented through an exhaust stack.** 

**The amount of VOC emitted varies depending on the t ype of coatings being used.** 

**Traditionally, conventional solvent-based coatings (which generally have higher VOC** 

**content), have been used in the paper, film, and fo il surface coating industry. Due to increased** 

**regulation at the federal and State level, the indu stry has steadily moved toward alternative** 

**coating formulations that reduce the amount of air emissions per unit amount of coating solids** 

**used. The types of coatings used in the paper, fil m, and foil surface coating industry include** 

**solvent-borne, waterborne, hot-melt adhesives and o ther 100 percent solids coatings, reactive,** 

**and radiation-cure coatings.**

Solvent-borne coatings **are widely used in the paper, film, and foil surfac e coating** 

**industry. The solvent content of the coating is hig hly variable in solvent-borne coatings, and** 

**depends primarily on the type of coating applicator used (e.g., reverse roll coaters require the use** 

**of coatings with lower viscosities than knife coate rs, therefore could require a higher solvent** 

**content). For solvent-borne coatings, coating form ulations typically range from 40 to 80 percent** 

**solvents by weight, as supplied by the manufacturer . Users may dilute solvent-borne coatings** 

**with additional solvents. Solvent-borne coatings a re typically applied at 60 to 90 percent solvent** 

**by weight and sometimes higher. The primary solven ts in solvent-borne coatings include** 

**methanol, toluene, xylene, methyl ethyl ketone, ace tone, ethyl acetate, and ethanol. Knife** 

**coaters, reverse roll coaters, and gravure coaters are commonly used to apply solvent-borne** 

**coatings.**

Waterborne coatings **contain water as a significant part of the fluid, although some** 

**organic solvents may be used at up to 30 percent of the fluid. Most coating equipment used for** 

**solvent-borne coatings can also be used for waterbo rne coatings. Knife coaters and gravure** 

**coaters are particularly well suited to application of waterborne coatings. However, troughs or** 

**trays may have to be mixed more often when they con tain waterborne coatings than when they** 

**contain solvent-borne coatings because waterborne c oatings are more susceptible to coagulation** 

**or agglomeration of their solids.**

# 9

Hot-melt adhesives and other 100 percent solids coa tings **such as wax coatings, wax**

**laminations, extrusion coatings, extrusion laminati ons, and coal seal coatings contain very little** 

**or no solvent. Accordingly, these coatings emit ve ry little VOC.** 

**In a hot-melt adhesive application, the solid coat ing material is heated, delivered to the** 

**coater head in a molten state, and added onto the w eb by a heated gravure coater, a heated roll** 

**coater, or an extrusion coater. The coated web is t hen chilled, restoring the coating to its solid** 

**state. Hot-melt adhesives use less energy than wat erborne or solvent-borne coating operation** 

**because there are no dryers. The use of hot-melt a dhesives also minimizes fire and explosion** 

**dangers because there are no volatile hydrocarbons.**

**The use of hot-melt adhesives, although growing, i s still limited by several factors.** 

**Because the equipment for hot-melt adhesives is qui te different from solvent-borne and** 

**waterborne coatings, existing equipment would have to be replaced to implement hot-melt** 

**adhesive use. Controlling the amount of hot-melt a dhesives applied to the substrate can be** 

**difficult with hot-melt coatings, resulting in poor coating quality. The hot-melt coater head is** 

**more susceptible to streaking due to plugging or di rt accumulation. Cleaning the coater head is** 

**difficult and time consuming, making changes to coa t a different substrate or use a different hot** 

**melt adhesive on the same hot-melt adhesive line mo re difficult, and therefore reduces the** 

**flexibility of the coater to coat many different pr oducts. Additionally, hot-melt adhesives do not** 

**have the strength or resistance to environmental st resses such as heat or cold, as do solvent-borne** 

**coatings. The hot-melt adhesives are typically dar ker in color and therefore, are not used on** 

**transparent surfaces. Finally, hot-melt adhesives cannot be used on a film substrate that is** 

**sensitive to heat because the substrate could melt during the coating process.** 

Reactive coatings **are cured via a chemical (usually polymeric) reacti on that forms other** 

**compounds. The resulting compounds are generally n ot VOC and/or stay with the substrate as** 

**residual VOC and is not emitted whether or not the substrate is dried.**  **4** 

# Reactive coatings are

**frequently used in the surface coating of decorativ e and industrial laminates and abrasives.** 

**Reactive coatings include styrene formaldehyde, phe nolic, melamine, and epoxy resins.** 

Radiation-cure coatings **(also called prepolymer coatings) are a special typ e of reactive** 

**coatings. These coatings are cured by exposure to electron beam (EB) or ultraviolet (UV)** 

**radiation. Radiation-cure coatings are solventless and are almost entirely composed of resins.** 

**They are applied in a liquid state via some typical coating application methods (**  e.g **., gravure and**

**flexography), and polymerize into a solid state upo n exposure to UV or EB radiation. UV-cured** 

**coatings require the addition of a photoinitiator t o catalyze the polymerization reaction; EB** 

**cured coatings do not, because the highly excited e lectrons emitted by the EB source are capable** 

**of initiating the polymerization reaction.**

**Benefits of radiation-cured coatings extend beyond decreased solvent usage and the** 

**associated emission reductions, including VOC emiss ions. The instantaneous nature of the** 

**curing process eliminates the need for drying ovens on the production line, which often leads to** 

**production increases and may allow direct integrati on of ancillary operations (**  e.g **., cutting,**

**slitting, folding) into the production line. Becau se no drying ovens are used, both energy usage** 

# 10

**and the space required for a coating line are great ly reduced. Since the coatings will not cure** 

**unless exposed to the proper type of UV or EB radia tion, they will not cure on the production** 

**equipment during operation or during process downti me. As a result, it is not necessary to clean** 

**application devices at the end of each shift or dur ing breaks and cleaning is easier than some** 

**other coatings, such as hot-melt coating.**

**Although industry generally perceives UV coating u sage as expensive because it may be** 

**costly to switch a coating line from solvent-based coating equipment to radiation-cured systems,** 

**there are often savings with the use of radiation-c ured coatings due to the above-mentioned** 

**benefits that can offset capital costs. Another in dustry perception is that the coatings themselves** 

**are more expensive. Although this may be true on a volume-to-volume basis, a radiation-cured** 

**coating will cover a much greater area of substrate (2 to 4 times) than an equal volume of a** 

**solvent-based coating because the radiation-cured c oating is 100 percent solids and has no loss of** 

**volume due to evaporation of solvent.**

**There are, however, several limitations to the use of radiation-curable systems. The** 

**extent of cure penetration can be a problem if the coating is very thick or heavily pigmented,** 

**which could result in coating not being completely cured. Because low viscosity solvents are not** 

**used, application of the relatively higher viscosit y radiation-cured coatings can be problematic;** 

**although this factor is less important in the appli cation to web substrates than other substrates** 

**which use spray coating. Also, skin contact with r adiation-cured coatings has the potential for** 

**irritation and/or allergic reaction. This is espec ially true during cleaning, since the combination** 

**of cleaning solvents and the radiation-cured coatin gs increases dramatically the level of irritation** 

**to the skin.**

**2. Cleaning Materials** 

**Cleaning materials are another source of VOC emitt ed by paper, film, and foil surface** 

**coating operations. 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 individu al solvents. Cleaning materials are used to** 

**wash the coating applicators and outsides of the co ating machines, and to remove residues of** 

**excess coatings between job changes. Cleaning may be done manually, using shop towels for** 

**example.**

V. Available Control Options and Regulatory Approaches

**As previously mentioned, there are two main source s of VOC emissions from paper, film,** 

**and foil surface coating operations: (1) evaporatio n of VOC from the coatings; and** 

**(2) evaporation of VOC from the cleaning materials. This section summarizes the available** 

**control options for reducing these VOC emissions an d regulatory approaches.** 

# 11

**A. Available Controls for VOC Emissions from Coatings** 

**Common control techniques for reducing VOC emission s from paper, film, and foil** 

**surface coatings include pollution prevention measu res and the operation of emission capture and** 

**add-on control systems. Provided below is a summar y of these control techniques.** 

**1. Pollution Prevention Measures** 

**Product substitution/reformulation is commonly use d as a pollution prevention measure** 

**in the paper, film, and foil surface coating indust ry to decrease VOC emissions from coatings.** 

**Lower VOC content coatings (such as waterborne and higher solids content coatings) or coatings** 

**with no solvents (** e.g. **, hot-melt adhesives) may be used to reduce VOC emi ssions by reducing or** 

**eliminating the organic solvent present in the coat ing. As previously discussed, these coatings** 

**include waterborne, hot-melt, reactive and radiatio n-cure coatings. Coating manufacturers have** 

**developed and are continuing to develop waterborne and other alternative coating formulations** 

**that replace conventional organic solvent-borne coa tings. These coatings are available for a** 

**number of applications. Conversion to these coatin gs can lower VOC emissions greatly, and** 

**most paper, film, and foil surface coating operatio ns are capable of converting to these coatings.** 

**However, for some products, the currently available low-VOC coatings or coatings with no** 

**solvents do not meet the performance requirements o f some paper, film, and foil surface coating** 

**operations and therefore are not viable options for production of these products.** 

**2. Emission Capture and Add-on Control Systems** 

**When low-VOC content coatings cannot be used due to performance requirements** 

**calling for higher VOC content coatings, VOC emissi ons from paper, film and foil surface** 

**coating operations can be reduced by the use of cap ture systems in conjunction with add-on** 

**control systems that either destroy or recover the VOC in the exhaust streams.** 

Capture Systems

**Capture systems, such as hoods and enclosures, col lect solvent-laden air from process** 

**vents (** e.g. **, drying oven vents) and/or fugitive emissions (** e.g. **, application and flash-off area)**

**containing VOC and direct the captured air to a con trol device. Emissions from the drying oven** 

**can be ducted directly to a control device, making the drying oven the principal element of the** 

**capture system. In addition, capture systems are u sed to collect fugitive emissions from solvents** 

**that evaporate from other parts of the coating line , such as the coating application and flash-off** 

**areas, and route them to a control device.**

**An efficient capture system maximizes the capture of emissions and minimizes the** 

**quantity of dilution air. Facilities may combine s everal captured VOC-laden streams and duct** 

**them to a single control device.**

**The most common types of capture systems used by t he paper, film, and foil surface** 

**coating industry are hoods or enclosures. Hood and enclosure capturing methods include hoods,** 

# 12

**floor sweeps, partial enclosure of coating stations , room enclosures, and permanent total** 

**enclosure (PTE). There are capture systems in use with efficiencies as high as 100 percent.**  **5**



# Add-on Control Devices in Paper, Film and Foil Surf ace Coating

**Add-on control devices reduce the amount of VOC em issions by either destruction or** 

**recovery with or without recycling of VOC collected from exhaust streams. Two categories of** 

**add-on control devices are typically used by the pa per, film, and foil industry: combustion** 

**(thermal or catalytic oxidation) and recovery (adso rption and condensation). While many** 

**control devices can be used to reduce VOC emissions , the following summary covers those** 

**control devices known to be used with surface coati ng operations: oxidation, adsorption, and** 

**condensation. In addition, there are other control measures that are known to reduce VOC** 

**emissions, but are not frequently in use in the pap er, film, and foil surface coating industry.** 

**These alternative control technologies are also dis cussed below.** 

Oxidation **destroys VOC emissions in an exhaust stream by expo sing the stream to an** 

**oxidizing atmosphere at high temperatures. Oxidize rs may be of thermal or catalytic design and** 

**combust VOC-containing exhaust streams. Catalytic oxidizers are similar to thermal oxidizers** 

**but employ a catalyst to aid in the oxidation react ion. As a result, catalytic oxidizers operate at a** 

**lower combustion temperature relative to that requi red in thermal oxidizers. Both types of** 

**oxidizers generally utilize either regenerative or recuperative techniques to preheat inlet gas in** 

**order to decrease energy costs associated with high oxidation temperatures. They may also use** 

**primary or secondary heat recovery to reduce energy consumption. In general, oxidizers may** 

**achieve destruction efficiencies of greater than 95 percent as applied to surface coating** 

**application operations with high and constant conce ntrations of VOC.** 

Adsorption **occurs when the unbalanced molecular forces on the surface of solids (the** 

**adsorbent) attract and retain gases and particulate matter that come in contact with the solid.** 

**Several materials can be used as the adsorbent, suc h as activated carbon, organic resin polymer,** 

**and inorganic materials. Carbon adsorbers are the type of adsorber most commonly used in the** 

**paper, film, and foil surface coating industry. In a carbon adsorber, activated carbon is used as** 

**the adsorbent in a regenerable fixed bed. In a typ ical carbon adsorber, VOC-laden air is passed** 

**through a fixed bed of granular activated carbon. The VOC in the entering air stream are** 

**adsorbed onto active sites on the surface area of t he carbon. Adsorber beds are typically** 

**operated in parallel to avoid interruption of VOC c ontrol. In this arrangement, when the** 

**adsorption capacity of one bed is exhausted, it can be removed from service and a second** 

**adsorber bed can be put into service, ensuring that a control device is operating at all times. The** 

**spent carbon in the first adsorber bed is then rege nerated and can be put into service again.** 

**Carbon adsorption systems can achieve control devi ce efficiencies greater than 95** 

**percent. 6**  

# In contrast to combustion, carbon adsorption does n **ot destroy the VOC it removes**

**from the air stream. Carbon adsorbers used in pape r, film and foil surface coating are thermally** 

**regenerated, usually by passing steam through the c arbon beds.**  **7** 

# The VOC are removed from the

**carbon (desorbed) and transferred to the steam. Th e VOC-containing steam is then condensed,** 

**and the VOC solvent is separated from the water. T he recovered solvent can then be decanted** 

**for sale or reuse. Regeneration can also be achiev ed with hot air. Hot-air regeneration can be** 

# 13

**quite attractive when dealing with water soluble so lvents.**  **7** 

# Carbon adsorption is most easily

**adaptable to coating lines that use a single solven t; if solvent mixtures are collected by adsorbers,** 

**they usually are distilled for reuse. 8** 



# There are two options for disposing recovered solv **ents that cannot be reused. The first is**

**to sell the material back to the solvent supplier o r an independent firm that specializes in** 

**reclaiming contaminated solvents. The other option is to use the recovered solvent as a fuel in** 

**coating ovens or in boilers. However, many coating ovens and boilers are gas-fired and would** 

**require burner modifications to burn solvent. Carb on adsorption is generally economically** 

**attractive only if the recovered solvent can be reu sed directly.**  **7**



# Carbon adsorbers are most suitable for solvents th **at are immiscible with water, such as**

**toluene and xylene, but are not recommended for wat er-soluble VOC, such as methyl ethyl** 

**ketone and methyl isobutyl ketone. In the case whe re a water-soluble VOC is present, the water** 

**vapor will be adsorbed and desorbed along with the VOC vapor, and the VOC may require** 

**subsequent purification if it is to be reused.**

**The presence of solid particles or polymerizable s ubstances in the inlet air stream to a** 

**carbon adsorber may require pretreatment of the inl et air. Cooling and dehumidification may also** 

**be required as pretreatment in some cases. 6**  

# Adding equipment, such as a dehumidification

**system, increases the costs associated with the use of a carbon adsorption system.** 

Condensation **is where organic compounds (** i.e. **, VOC) are removed from gas streams by**

**cooling the gas to a temperature less than the dew point of the compound. The recovered VOC** 

**compounds can then be reused or sold. Highly volat ile VOC require lower temperatures for** 

**condensation. Therefore, refrigeration is often ne cessary to reach the low temperatures required** 

**for acceptable removal efficiencies. 9**  

# Removal efficiencies usually range from 50 to 90 **percent. 6** 



# The most common types of condensers used are surfa **ce and contact condensers. In**

**surface condensers, the coolant does not contact th e gas stream. Surface condensers allow for** 

**direct recovery of VOC from the gas stream. 9**  

# Unlike surface condensers, contact condensers

**cool through direct contact of the coolant with the gas stream. The contact condenser coolant,** 

**which is a liquid at ambient or chilled temperature , is sprayed into the gas stream. In a contact** 

**condenser, the condensed VOC are contaminated with coolant and therefore cannot usually be** 

**reused or resold directly; further processing is ne cessary to complete the recovery process.**  **10**



# Alternative control technologies **, such as liquid absorbers and biofilters are used**

**infrequently in the paper, film, and foil surface c oating industry. Ultraviolet (UV) oxidation is** 

**not currently utilized by the paper, film, and foil surface coating industry. However, it has been** 

**shown to be an effective control technology for VOC emissions from coatings in other** 

**industries. The use of these types of alternative control technologies would be highly dependant** 

**on facility needs and characteristics.**

# 14

**B. Available Controls for Cleaning Materials** 

**Pollution prevention is the most common emission c ontrol technique for reducing VOC** 

**emissions from cleaning materials. The pollution p revention measures applicable to the paper,** 

**film, and foil surface coating industry include pro duct substitution/reformulation and work** 

**practice procedures. Cleaning materials with low o r no VOC content or low-VOC composite** 

**vapor pressure may be used to reduce or eliminate V OC emissions from using these materials.** 

**Work practice procedures may also reduce VOC emissi ons during cleaning operations by** 

**reducing the amount of VOC that can evaporate due t o exposure to air.** 

**No add-on control technologies are being used spec ifically for reducing VOC emissions** 

**from cleaning operations associated with paper, fil m, and foil surface coating. However, if** 

**cleaning operations are performed within a capture system which is ducted to an add-on control** 

**system, such as a PTE routed to a thermal oxidizer, the VOC emissions from the cleaning** 

**operation would be reduced by destruction in the th ermal oxidizer. Further, there are controlled** 

**cleaning operations where cleaning is automated, en closed, and vented to a control device.** 

**1. Product Substitution/Reformulation** 

**Reducing the composite vapor pressure or VOC conte nt of the cleaning material used,** 

**either by substitution or reformulation, is one pol lution prevention measure that is used to reduce** 

**VOC emissions from cleaning operations. However, l ittle information is available regarding the** 

**types of low-VOC or VOC-free cleaning materials tha t could be used in the paper, film, and foil** 

**surface coating industry.**

**2. Work Practice Procedures** 

**Work practices are widely used in the paper, film, and foil surface coating industry as a** 

**measure of reducing VOC emissions from cleaning mat erials during cleaning operations. These** 

**measures include: covering cleaning material mixing tanks; storing cleaning solvents and** 

**solvent-soaked rags and wipes in closed containers; and cleaning spray guns in an enclosed** 

**system. Use of recycled solvents for cleaning is a lso typical in the industry.** 

**C. Existing Federal, State, and Local Recommendations**  **or Regulations**

**The following discussion is a summary of EPA actio ns, as well as State and local** 

**regulations that address VOC emissions from paper, film, and foil surface coating processes.** 

**Appendices B, C, and D summarize State and local pr ovisions.** 

**1. The 1977 CTG** 

**The 1977 CTG recommended limiting VOC emissions fr om paper coating operations.** 

**The 1977 CTG recommended VOC limits apply to paper coating lines, which are defined as** 

**consisting of the application/flash-off area and th e drying oven. Cleaning materials were not** 

**addressed in the 1977 CTG.**

# 15

**The 1977 CTG recommended RACT for paper coating wa s 0.35 kg/l (2.9 lb/gal) of** 

**coating, excluding water and exempt compounds, as a pplied. This recommended limit was** 

**based on the use of conventional solvent-borne coat ings and oxidation of the dryer exhaust** 

**which achieved an overall control efficiency of 81 percent. The limit was expressed in terms of** 

**a coating VOC content to encourage the development and use of low-VOC content coatings.** 

**Equivalent solid-based limits for paper coating ope rations were presented in**  A Guideline for

Surface Coating Calculations” **(EPA-340/1-86-016). 11**  

# For paper coating , the 1977 CTG**equivalent limit was 0.58 kg/l (4.8 lb/gal) of soli ds using a representative coating solids. These** 

**equivalent limits were calculated using an assumed VOC density of 0.88 kg/l (7.36 lb/gal). This** 

**assumed VOC density is the same as that used in cal culating the limits recommended in the 1977** 

**CTG.**

**2. The 1983 NSPS** 

**In 1983, EPA promulgated new source performance st andards for pressure sensitive tape** 

**and label surface coating operations (1983 NSPS), 4 0 CFR 60, subpart RR. The 1983 NSPS** 

**only applies to pressure sensitive tape and label s urface coating lines that commenced** 

**construction, reconstruction, or modification after December 30, 1980. The 1983 NSPS defines** 

**a coating line to include the coating applicators, flash-off areas, and drying ovens between web** 

**unwind stations and web rewind stations. The 1983 NSPS requires a 90-percent reduction of** 

**VOC emissions. Alternatively, it establishes a lim it of 0.20 kg VOC/kg (0.20 lb VOC/lb) solids** 

**applied, based on a VOC emission reduction of 90 pe rcent. Any pressure sensitive tape and label** 

**surface coating operations that inputs 45 megagrams per year (Mg/yr) VOC (50 tpy) or less into** 

**the coating process are not subject to the 1983 NSP S emission limit (other requirements such as** 

**recordkeeping and reporting do apply). Cleaning ma terials were not addressed in the 1983** 

**NSPS.**

**3. The 2002 NESHAP** 

**In 2002, EPA promulgated the National Emission Sta ndards for Hazardous Air** 

**Pollutants: Paper and Other Web Coating (2002 NESHA P), 40 CFR part 63, subpart JJJJ, which** 

**applies to major sources of HAP emissions (** i.e., **stationary sources that emit or have the potential**

**to emit 10 tpy or more of any one HAP, or 25 tpy or more of any combination of HAP). The** 

**2002 NESHAP addresses organic HAP emissions, includ ing VOC HAP emissions, from all web** 

**coating lines at a paper, film, and foil surface co ating facility, which include coating application** 

**and any associated curing and/or drying equipment b etween an unwind station and a rewind or** 

**cutting station.**

**The 2002 NESHAP has different emission limitations for sources that commenced** 

**construction or reconstruction on or before Septemb er 13, 2000 (existing sources), and sources** 

**that commenced construction or reconstruction after September 13, 2000 (new sources). The** 

**2002 NESHAP limits for existing sources are based o n an overall HAP emission reduction of 95** 

**percent and are expressed as follows: (1) no more than 5 percent of the organic HAP applied; (2)** 

**no more than 0.04 kg/kg (0.04 lb/lb) coatings appli ed; or (3) no more than 0.20 kg/kg (0.20 lb/lb)** 

**solids applied. Similarly, the limits for new sour ces are based on a HAP emission reduction of** 

**98 percent and are expressed as follows: (1) no mo re than 2 percent of the organic HAP applied;** 

# 16

**(2) no more than 0.016 kg/kg (0.016 lb/lb) coatings applied; or (3) no more than 0.08 kg/kg (0.08** 

**lb/lb) solids applied.**

**Compliance with the 2002 NESHAP can be demonstrate d by any of the following** 

**methods: (1) all coatings purchased have organic HA P contents that individually meet the** 

**organic HAP emission limit; (2) all coatings applie d have organic HAP contents that individually** 

**meet the organic HAP emission limit; (3) total mont hly organic HAP applied does not exceed an** 

**equivalent allowable organic HAP (which is a facili ty-specific weighted average calculated** 

**based on HAP content of the coatings applied); (4) use one or more capture systems and control** 

**devices; or (5) use a combination of coatings and c apture systems and control devices meet the** 

**organic HAP emission limit.**

**4. Existing State and Local VOC Requirements** 

**In addition to the EPA actions described above, at least 44 State and local jurisdictions** 

**have regulations that affect VOC emissions from all or part of the paper, film, and foil surface** 

**coating industry. Some of these regulations are ge neral surface coating rules; many are specific** 

**to the paper, film, and foil surface coating indust ry and cover the coating line. Generally, the** 

**State and local regulations allow compliance with t heir requirements to be demonstrated using** 

**low-VOC coating or add-on control devices in conjun ction with higher-VOC coating.** 

**Almost all of the jurisdictions that specifically address all or part of the paper, film, and** 

**foil surface coating industry have adopted the reco mmended VOC emission limits in the 1977** 

**CTG. However, there are fourteen jurisdictions tha t have more stringent requirements than the** 

**1977 CTG. These jurisdictions allow compliance eit her using compliant coatings, or by using an** 

**add-on control system. Seven jurisdictions have VO C emission limits that are more stringent** 

**than the 1977 CTG, five in California and two in Il linois. The California jurisdictions limit VOC** 

**emissions to 265 g/l (2.2 lb/gal) of coating, exclu ding water and exempt compounds, as applied.** 

**The two jurisdictions in Illinois limit VOC emissio ns to 0.28 kg/l (2.3 lb/gal) of coating,** 

**excluding water and exempt compounds, as applied. As an alternative to the VOC emission** 

**limits, these California and Illinois jurisdictions allow facilities to install capture systems and** 

**control devices to reduce VOC emissions from these coating operations. The required overall** 

**emission reduction, including capture and control e fficiency, ranges from 55 percent to 90** 

**percent. Specifically, the San Diego County Air Po llution Control District (San Diego) and the** 

**Ventura County Air Pollution Control District (Vent ura) both require an overall control** 

**efficiency of 90 percent. Finally, there are seven jurisdictions that have VOC emission limits** 

**that are the same as the 1977 CTG. However, these jurisdictions require 95 percent emission** 

**reduction as an alternative to the VOC emission lim it. The 95-percent overall control efficiency** 

**is the most stringent and likely can only be met wi th a permanent total enclosure that achieves** 

**100 percent capture efficiency.**

**Several jurisdictions in California have requireme nts to regulate the VOC content of** 

**cleaning materials used in the paper, film and foil surface coating industry. These regulations** 

**are aimed at reducing VOC emissions from cleaning m aterials by combining work practice** 

**standards with limits on the VOC content or composi te vapor pressure of the solvent being used.** 

**In some cases, the jurisdictions allow the use of a dd-on controls as an alternative to the VOC** 

# 17

**content/vapor pressure limits. The different air p ollution control authorities in California have** 

**established similar work practice standards. Howev er, the cleaning material VOC content/vapor** 

**pressure limits vary by jurisdiction, as do the ove rall control efficiency required when add-on** 

**controls are used as an alternative.**

**There are 10 States that have cleaning material re gulations that apply to paper, film, and** 

**foil surface coating operations. Of these, 9 State s do not limit the VOC content/vapor pressure** 

**of cleaning materials. Instead, they have establis hed equipment standards, work practices, and/or** 

**recordkeeping requirements. There is one State tha t requires work practices as well as limiting** 

**the vapor pressure of the cleaning materials. The cleaning material regulations are summarized** 

**in detail in the CTG.**

VI. Recommended Control Options

**Based on a review of the 1977 CTG, the 1983 NSPS, t he 2002 NESHAP, and the current** 

**State and local requirements discussed above, we re commend emission limits and work practices** 

**for controlling the VOC emissions from coatings and cleaning materials used in paper, film and** 

**foil surface coating operations. The following dis cussion summarizes EPA's recommendations** 

**for controlling VOC emissions.**

**A. Coatings** 

**For the purposes of this CTG, we recommend defining coatings as materials applied onto** 

**or impregnated into a substrate for decorative, pro tective, or functional purposes. Such materials** 

**include, but are not limited to, solvent-borne coat ings, waterborne coatings, adhesives, wax** 

**coatings, wax laminations, extrusion coatings, extr usion laminations, 100 percent solid** 

**adhesives, UV cured coatings, electron beam cured c oatings, hot melt coatings, and cold seal** 

**coatings. Materials used to form unsupported subst rates, such as calendaring of vinyl, blown** 

**film, cast film, extruded film, and co-extruded fil m, are not considered coatings.** 

**To control VOC emissions from coatings used in pap er, film and foil surface coating, we** 

**recommend an overall VOC control efficiency of 90 p ercent for each coating line. Alternatively,** 

**we recommend emission limits that are equivalent to 90 percent overall control. We recommend** 

**applying the control recommendations only to indivi dual surface coating lines with the potential** 

**to emit, prior to controls, at least 25 tpy of VOC 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. We also** 

**recommend providing paper, film, and foil surface c oating facilities with the option of using an** 

**enforceable limitation on potential emissions to ke ep an individual paper, film and foil surface** 

**coating line below this 25 tpy potential to emit th reshold.** 

**We recommend an overall VOC control efficiency of 9 0 percent as RACT for each** 

**paper, film, and foil surface coating line, as defi ned above. This emission reduction is based on** 

**the San Diego and Ventura levels of control, as wel l as the 1983 NSPS. The San Diego and** 

**Ventura regulations require that if an add-on contr ol is used as the compliance option, the control** 

**system must achieve 90 percent overall emission red uction. We are not recommending the 95-** 

# 18

**percent overall emission reduction in the 2002 NESH AP and seven States regulations. A** 

**95 percent overall emission reduction would require facilities to install and operate a PTE (i.e.,** 

**achieve 100 percent capture efficiency) in conjunct ion with a control device that reduces** 

**emission by 95 percent. We do not believe that it is reasonable or feasible to retrofit a PTE in all** 

**cases.**

**As an alternative to an overall 90 percent control efficiency, we recommend VOC** 

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

**by use of low-VOC content materials or combinations of materials and controls. To determine** 

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

**sensitive tape and label surface coating lines), we used the same baseline coating, 20 weight** 

**percent solids and 80 weight percent solvent (organ ic HAP for the NESHAP and VOC for this** 

**CTG), used to develop similar limits in the 2002 NE SHAP. 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/lb) solids applied and 0.08 kg VOC/kg (0.08 lb VOC/lb) coating applied.** 

**We recommend these limits for paper, film and foil surface coating except for pressure sensitive** 

**tape and label surface coating lines.**

**As an alternative to 90 percent emission reduction, the NSPS for pressure sensitive tapes** 

**and labels provides an alternative limit of 0.20 kg VOC/kg (0.20 lb VOC/lb) solids applied. We** 

**recommend the same alternative limit of 0.20 kg VOC /kg (0.20 lb VOC/lb) solids applied and an** 

**additional equivalent limit of 0.067 kg VOC/kg (0.0 67 lb VOC/lb) of coating as RACT for** 

**pressure sensitive tape and label surface coating l ines. See Table 1 for a summary of the** 

**recommended RACT limits for the paper, film, and fo il surface coating source category.** 

Table 1. Summary of Recommended RACT Limits

RACT Limits

Units Pressure

Sensitive Tape

and Label

Surface Coating Paper, Film, and Foil

Surface Coating (Not

including Pressure

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 0.08** 

**The VOC content limits can be met by averaging the VOC content of materials used on a** 

**single surface coating line each day (** i.e., **daily within-line averaging). We do not recommend**

**the use of cross-line averaging (i.e., averaging ac ross multiple lines) to meet the VOC content** 

**limits. However, we have previously provided guida nce on cross-line averaging.**  **12** 

# The

# 19

**guidance is directed to State and local agencies th at elect to adopt a discretionary economic** 

**incentive programs (EIP) and includes guidance on t he use of cross-line averaging.** 

**B. Cleaning Materials** 

**For cleaning materials, we are recommending work pr actices to reduce VOC emissions.** 

**We are not recommending the application of add-on c ontrols. Add-on controls would be a costly** 

**alternative for reducing VOC emissions from cleanin g materials because the area to be** 

**controlled is quite large and a large volume of air would be captured and directed to a control** 

**device. However, as mentioned previously, any clea ning activities that occur within a capture** 

**device would be controlled by the associated contro l device. We are also not recommending the** 

**use of a VOC content or VOC composite vapor pressur e limit for cleaning materials because we** 

**do not have information available regarding current VOC content or VOC composite vapor** 

**pressure usage to determine a RACT limit for cleani ng materials used in paper, film, and foil** 

**surface coating operations.**

**To control VOC emissions from cleaning materials u sed in paper, film, and foil surface** 

**coating, we recommend work practices for use in all paper, film, and foil surface coating** 

**facilities meeting the applicability threshold note d above. We recommend that facilities** 

**implement work practices to ensure that VOC emissio ns are minimized from mixing, storage,** 

**and handling of cleaning materials, and cleaning-re lated waste materials. Specifically, we** 

**recommend the following: (1) store all VOC-containi ng cleaning materials in closed containers;** 

**(2) ensure that mixing and storage containers used for VOC-containing materials are kept closed** 

**at all times except when depositing or removing the se materials; (3) minimize spills of VOC** 

**containing cleaning materials; (4) convey VOC-conta ining cleaning materials from one location** 

**to another in closed containers or pipes; and (6) m inimize VOC emissions from cleaning of** 

**storage, mixing, and conveying equipment.**

VII. Cost Effectiveness of Recommended Control Options

**We estimated the cost effectiveness of our recommen dations in this CTG based on** 

**information collected during the development of the 2002 NESHAP. Although there is limited** 

**cost information available, we believe that the cos t estimates and other related studies developed** 

**for the 2002 NESHAP are appropriate for estimating the cost impact of our recommendations in** 

**the CTG for the following reasons. The recommended level of control covers the same** 

**processes as the 2002 NESHAP (i.e., all coating app licators and any associated drying/curing** 

**equipment between the unwind/feed station and the r ewind/cutting station). In addition, both the** 

**2002 NESHAP emission limits and the recommended lim its are based on the use of similar** 

**control measures (i.e., product substitution/reform ulation, add-on control systems, or a** 

**combination of these two options). Finally, the 20 02 NESHAP cost data is the most recent** 

**available.**

**To develop emission and cost impacts for the 2002 N ESHAP, EPA conducted a model** 

**plant analysis, in which it evaluated HAP emissions associated with different kinds of coating** 

**processes, the emission reduction capabilities of v arious control options, and the costs of such** 

**controls. The model plants were developed to repres ent a range of sizes and emissions. Table 2** 

# 20

**presents a summary of the model plant characteristi cs, the approach for complying with the** 

**requirements of the 2002 NESHAP, the HAP emission r eduction associated with compliance,** 

**and the associated capital and annual cost estimate s. We believe that the model plant analysis** 

**performed in the development of the 2002 NESHAP is representative of current operations in the** 

**paper, film, and foil surface coating industry.**

**The annual costs of complying with the 2002 NESHAP were estimated using 1998** 

**dollars related to the use of thermal oxidizers to achieve a 95 percent HAP overall control** 

**efficiency. 4**  

# The control option based on use of thermal oxidiz **ers was chosen because this option**

**was expected to be the worst-case for costs. All o ther control options are expected to have lower** 

**annual costs. These costs estimates were scaled to 2005 dollars and used to estimate annual** 

**costs and cost effectiveness for this CTG.**

**Based on the 2002 NEI database, we estimate that th ere are a total of 474 paper, film, and** 

**foil surface coating facilities located in ozone no nattainment areas (using April 2004** 

**designations). As previously mentioned, we are rec ommending that the control options** 

**described in this CTG apply to facilities in ozone nonattainment areas with individual coating** 

**lines with a potential to emit 25 tpy of VOC or gre ater, prior to the consideration of controls.** 

**Based on VOC emissions data in the 2002 NEI databas e, 251 of the facilities in ozone** 

**nonattainment areas have individual coating lines t hat have the potential to emit VOC at or** 

**above this level.**

**To estimate the costs associated with the add-on co ntrol recommendation in this CTG, we** 

**assumed that 47 percent of the facilities in the 20 02 NEI database (119 facilities) are currently** 

**complying with the 2002 NESHAP. Since the 2002 NES HAP requires a 95-percent HAP** 

**emission reduction, which also achieves a 95-percen t VOC emission reduction and is higher than** 

**the recommended 90-percent emission reduction, we a ssume that facilities already in compliance** 

**with the 2002 NESHAP would not be required to upgra de or install a thermal oxidizer to** 

**implement the emission reduction recommended in the CTG and therefore would have no** 

**additional annual costs. In addition, we assumed t hat since the facilities represented by Model** 

**Plant 4 (see Table 2) already have an overall contr ol efficiency of 90 percent, these facilities** 

**would not be required to upgrade the thermal oxidiz er.** 

**Using the 2002 NEI, we found that 57 of the remaini ng 132 facilities reported the use of** 

**control devices. Therefore, we removed 57 faciliti es from the model plant analysis. We then** 

**distributed the remaining 75 facilities across the model plants in the same ratios as those used** 

**during the development of the 2002 NESHAP and apply the annual costs (scaled to 2005 dollars)** 

**for each model plant. Based on the average number of coating lines per facility identified in** 

**Table 2, all of these facilities have individual co ating lines with the potential to emit of 25 tpy** 

**VOC or greater, prior to the consideration of contr ols. Using this approach, we estimate that the** 

**total annual cost associated with this CTG is $24.5 million per year.** 

**We used the 2002 NESHAP model plant emissions to es timate the aggregate VOC** 

**emission reduction. Table 3 presents the nationwid e emission estimates using the model plant** 

**approach. As shown in Table 3, we estimate that VO C emissions from facilities in ozone** 

**nonattainment areas are approximately 21,000 Mg/yr (23,100 tpy). Applying the 90-percent** 

# 21

**emission reduction to facilities above the emission cutoffs and that are located in ozone** 

**nonattainment areas yielded an emission reduction o f approximately 18,900 Mg/yr (20,800 tpy).** 

**Therefore, the cost effectiveness was estimated to be $1,300 per Mg ($1,200 per ton) of VOC.** 

**Table 3 presents the nationwide annual cost estimat es for the paper, film, and foil surface coating** 

**industry.**

**We believe that our work practice recommendations i n this CTG will result in a net cost** 

**savings. Implementing work practices reduces the a mount cleaning materials used by reducing** 

**the amount that evaporates and is wasted.**

VIII. References

**1.** Control Of Volatile Organic Emissions From Existing Stationary Sources, Volume II:

Surface Coating Of Cans, Coils, Paper Fabrics, Auto mobiles, And Light Duty Trucks

**, EPA-450/2-77-008, U. S. Environmental Protection Ag**  **ency, Research Triangle Park,**

**NC, May 1977. The 1977 CTG is included as Appendix A to this CTG.** 

**2**

**.** 

# U.S. Environmental Protection Agency. Standards of **Performance for Pressure Sensitive**

**Tape and Label Surface Coating Operations. 40 CFR part 60, subpart RR. October 18,** 

**1983.**

**3**

**.** 

# U.S. Environmental Protection Agency. National Em **ission Standards for Hazardous Air**

**Pollutants: Paper and Other Web Coating. 40 CFR p art 63, subpart JJJJ. December 4,** 

**2002.**

**4**

**.** 

# National Emission Standards for Hazardous Air Pollu tants for Source Categories:

Paper and Other Web Coating Operations -- Backgroun d Information for Proposed

Standards. **EPA-453/R-00-002. U.S. Environmental Protection Agency. Research** 

**Triangle Park, NC. April 2000.**

**5**

**.** 

# Docket No. A-99-09. U.S. Environmental Protection **Agency, Washington, DC. 1999.**

**Responses from the paper and other web coating NESH AP survey.** 

**6.** Handbook: Control Technologies for Hazardous Air P ollutants. **EPA-625/6-91-014,**

**U.S. Environmental Protection Agency, Cincinnati, O hio. June 1991.** 

**7.** Pressure Sensitive Tape and Label Surface Coating I ndustry--Background Information

for Proposed Standards. **EPA-450/3-80-003a, U.S. Environmental Protection A gency,** 

**Research Triangle Park, North Carolina. September 1 980. pp. 3-14 to 3-15.** 

**8.** Compilation of Air Pollutant Emission Factors (AP-4 2), Volume I (Fifth Edition) **. U.S.**

**Environmental Protection Agency, Research Triangle Park, North Carolina. January** 

**1995. p. 4.2.2.6-3.**

**9.** OAQPS Control Cost Manual, 4th ed. **EPA-450/3-90-006, U.S. Environmental**

**Protection Agency, Research Triangle Park, North Ca rolina. January 1990.** 

# 22

**10. Telecommunication. Sutton, L., EC/R Inc., Durh am, North Carolina, with T. Godonis,** 

**American Biltrite, Inc., Moorestown, New Jersey. M arch 19, 1998. Question regarding** 

**condensers.**

**11.** A Guideline for Surface Coating Calculations. **EPA-340/1-86-016. U.S. Environmental**

**Protection Agency, Washington, DC. July 1986.**

**12**

**.** 

# Improving Air Quality with Economic Incentive Progr ams. **U.S. Environmental**

**Protection Agency. Research Triangle Park, NC. EP A-452/R-01-001. January 2001.** **23**Table 2. Specifications for Model Plants Developedfor the 2002 NESHAP4ModelPlantNo.Percent ofDatabaseMajorSourcesOverallHAPControlEfficiency(%)Approach forCapture andControlaAverageNumberofCoatingLinesAverageNumberofCoatingStationsCoatingUse(tpy)UncontrolledCoating LineHAPEmissions(tpy)HAPEmissionReduction(tpy)Total ModelPlantCapitalCosts ($)bTotal ModelPlantAnnual Cost($/yr)b**1a 20 0 PTE and new control** **device 2 5 2,108 99 94 2,479,820 713,596** **1b 3 0 PTE and new control** **device 12 9 7,521 1,765 1,677 6,780,733 1,923,790** **1c c,d** **10 0 No change 2a 25 50** **PTE and increase T.O. efficiency** **5 11 8,607 276 124 531,481 174,162 2b 1 50 PTE 31 154 369,929** **2,522 1,135 1,686,000 873,287 3a 11 80** **PTE and increase T.O. efficiency** **3 8 7,518 915 137 473,044 161,250 3b 1 80 PTE 8 15 14,516 6,890 1,034 290,000 120** **,638 4** **d 24 90 No change** **5 d** **5 95 No change a** **PTE = permanent total enclosure; T.O. = thermal ox idizer** **b Costs developed in 1998 dollars.** **c Although a control efficiency of zero is stated, t** **his model plant is assumed to be using compliant co atings.** **d These model plants were not included in the analys** **is because they are assumed to be already in operat ing at the CTG's recommended level of control** **24**Table 3. Annual Cost Estimates for Paper, Film, and Foil Surface Coating Industry1998Dollars2005 DollarsModelPlant(a)ModelPlant VOCEmissions(tpy) (b)Percent ofFacilitiesRequiringAdditionalControlControl Approachfor Complying withDraft CTGRecommendationsModelPlant TotalAnnualCost ($/yr)Number ofFacilitiesImpactedby CTG (c)Total VOCEmissions inOzoneNonattaimentAreas (tpy)ModelPlantTotalAnnualCost ($/yr)NationwideTotalAnnual Cost($/yr)CostEffectiveness($/ton)**1a 198** **20% Install capture system** **and new T.O. $713,596** **15 2,970** **$857,781 $12,866,713** **$4,814 1b** **3,530 3%** **Install capture system and new T.O.** **$1,923,790 2** **7,943 $2,312,499** **$5,203,123 $728** **1c 96** **10% None** **$0 7** **$0 $0** **$0 2a** **276 25%** **Install Capture system and Increase T.O.** **destruction efficiency $174,162** **19 5,175** **$209,352 $3,925,352** **$843 2b** **2,522 1%** **Install capture system $873,287** **1 1,892** **$1,049,738 $787,304** **$462 3a** **366 11%** **Install capture system and Increase T.O.** **destruction efficiency $161,250** **8 3,020** **$193,831 $1,599,107** **$588 3b** **2,756 1%** **Install capture system $120,638** **1 2,067** **$145,013 $108,760** **$58 4** **d 198** **24% None** **$0 18** **$0 $0** **$0 5** **e 80** **5% None** **$0 4** **$0 $0** **$0 75** **23,066 $24,490,359** **$1,180 (a) Model plants were defined during the developme** **nt of the POWC NESHAP (40 CFR 63, subpart JJJJ). (S ee Table 2)** **(b) Model plant HAP emissions multiplied by 2:1 VOC to HAP ratio** **(c) The number of facilities in the 2002 NEI located within ozone nonattainment areas and with individu** **al coating lines with the potential to emit at leas t 25 tons per year of VOC from coatings, prior** **to controls. Distributed across model plants using the percent of facilities subject to the NESHAP. (** **See Reference 10). (d) In the 2002 NESHAP, facilities in this model pla** **nt category operate with an overall control efficie ncy of 90 percent, therefore, no upgrade in equipme** **nt would be necessary in order to comply with the 90-percent recommended level of control in the** **draft CTG. (e) In the 2002 NESHAP, facilities in this model pla** **nt category operate with an overall control efficie ncy of 95 percent, therefore, no upgrade in equipme** **nt would be necessary in order to comply with the 90-percent recommended level of control in the** **draft CTG.**

# Appendix A

Control of Volatile Organic Emissions from Existing Stationary

Sources - Volume II: Surface Coating of Cans, Coil s, Paper,

Fabrics, Automobiles, and Light-Duty Trucks

# This page intentionally left blank.

# A-1

Appendix A: Control of Volatile Emissions from Exi sting Stationary Sources - Volume II:

Surface Coating of Cans, Coils, Paper, Fabrics, Aut omobiles, and Light-Duty Trucks

# A-2 This page intentionally left blank.

# Appendix B

Paper, Film, and Foil Surface Coating Facilities in Current

Nonattainment Areas and Associated State or Local R equirements

(Based on 2002 NEI and December 2006 Nonattainment

Designations)

# This page intentionally left blank.**B-1**Appendix B: Paper, Film, and Foil Surface CoatingFacilities in Current Nonattainment Areas and Associated State or LocalRequirements (Based on 2002 NEI and December 2006 Nonattainment Designations)**State or Local Jurisdiction Number of** **Facilities in Ozone** **Nonattainment Areas Product Applicability** **Applicable State Emission Limit Alternative Control Device Limits** **California 38 Bay Area AQMD 11 Paper, Fabric, and Film** **Applies to coating lines that emit more than 14.3 lb VOC per day** **2.2 lb VOC per gallon coating (excluding water) or** **1 lb VOC per gallon (excluding water) if using a** **control device) Use capture and control system to** **meet emission limit Paper, Fabric, and Film** **Applies to coating lines that emit less than 14.3 lb VOC per day** **VOC emission limit of 5 tpy or 3.5 lb VOC per gallon** **coating (excluding water) Overall control efficiency of 85%** **or an incinerator with a control efficiency of 90%** **Cleaning Materials VOC emission limit of 50 g VOC/l (0.42 lb/gal)** **Overall control efficiency of 85% or use specified work practices** **Mojave Desert AQMD 1 Organic solvents or solvent containing materials** **1,190 lb VOC per month Overall control efficiency o f 90%** Appendix B: Paper, Film, and Foil Surface CoatingFacilities in Current Nonattainment Areas and Associated State or LocalRequirements (Based on 2002 NEI and December 2006 Nonattainment Designations) (continued)**B-2 State or Local Jurisdiction** **Number of Facilities in** **Ozone Nonattainment** **Areas Product Applicability** **Applicable State Emission Limit Alternative Control Device Limits** **San Joaquin Valley Unified APCD** **3 Organic solvents or solvent containing materials that come into** **contact with a flame, or are baked, heat cured, or heat-polymerized in the** **presence of O2 15 lb/ day (emissions from** **air or heat drying for the first 12 hours must be included)** **Overall control efficiency of 85% Organic solvents or solvent** **containing photochemically reactive solvent (except solvents that are** **baked, heat cured, or heat polymerized)** **40 lb/day (emissions from air or heat drying for the first 12** **hours must be included) Overall control efficiency of 85%** **Organic solvents or solvent containing non-photochemically** **reactive solvent (except solvents that are baked, heat cured or heat** **polymerized) 3,000 lb/day (emissions from** **air or heat drying for the first 12 hours must be included)** **Overall control efficiency of 85% South Coast AQMD 23 Paper, Film, and Fabric Coating** **lines and wash primer: 265 g/l (excluding** **water) Plastisol: 20 g/l (excluding** **water) Overall control efficiency of 90%** **Cleaning Materials VOC limits of 25 g/l (0.21 lb/gal)** **Use specified work practices Colorado 8 Paper, Fabric, Plastic-Film, and Vinyl** **Coating 1977 CTG Limits** **b Use capture and control system to** **meet emission limit b** **1977 CTG recommended limits: Paper Coating = 0.35 kg/l (2.9 lb/gal) coating, as applied (minus water** **and exempt compounds); Fabric Coating= 0.35 kg/l (2.9 lb/gal) coating, as applied (minus water and e** **xempt compounds); Vinyl Coating = 0.45 kg/l (3.8 lb /gal) coating, as applied (minus water and exempt** **compounds).**Appendix B: Paper, Film, and Foil Surface CoatingFacilities in Current Nonattainment Areas and Associated State or LocalRequirements (Based on 2002 NEI and December 2006 Nonattainment Designations) (continued)**B-3 State or Local Jurisdiction** **Number of Facilities in** **Ozone Nonattainment** **Areas Product Applicability** **Applicable State Emission Limit Alternative Control Device Limits** **Connecticut 4 Paper, Fabric, and Vinyl Coating 1977 CTG Limits** **b Overall control efficiency of 95%** **Delaware 2 Paper, Fabric, and Vinyl Coating 1977 CT G Limits** **b Overall control efficiency of 95%** **Cleaning Materials Composite vapor pressure no more than 45 mmHg @** **20 o** **C; OR solvent must be at least 80% water** **Use work practices to minimize emissions** **Georgia 5 Paper, Fabric, and Vinyl Coating 1977 CTG Limits** **b Overall control efficiency of 95%** **Illinois 29 Outside Chicago and Metro** **East Areas Unknown** **c Paper, Fabric, and Vinyl Coating 1977 CTG Limits** **b Overall control efficiency of 81%** **(control device must get 90%) Unknown** **c Paper coating** **Specialty High Gloss Catalyzed Coating** **3.5 lb VOC per gallon coating (except water)** **Overall control efficiency of 81% (control device must get 90%)** **Chicago and Metro East Areas** **Paper, Fabric, and Vinyl Coating 2.3 lb VOC per ga llon** **coating (except water) Overall control efficiency of 81%** **(control device must get 90%) Indiana 9 Paper, Fabric, and Vinyl Coating 1977 CTG** **Limits b** **Overall control efficiency of 67.5% (Fabric and Vinyl only)** **Maine 1 Paper, Fabric, and Vinyl Coating 1977 CTG L imits** **b Overall control efficiency of 95%** **Maryland 5 Paper, Fabric, and Vinyl Coating 1977 CT G Limits** **b Use capture and control system to** **meet emission limit Michigan 11 Paper, Fabric, and Vinyl Coating 1977 C** **TG Limits b** **Use capture and control system to meet emission limit** **Missouri 3 Paper, Fabric, and Vinyl Coating 1977 CT G Limits** **b Use capture and control system to** **meet emission limit New Jersey 27 Paper, Fabric, and Vinyl Coating 1977** **CTG Limits b** **Control emissions by 90% c** **The number of facilities located within the Illino is jurisdictions is unknown.** Appendix B: Paper, Film, and Foil Surface CoatingFacilities in Current Nonattainment Areas and Associated State or LocalRequirements (Based on 2002 NEI and December 2006 Nonattainment Designations) (continued)**B-4 State or Local Jurisdiction** **Number of Facilities in** **Ozone Nonattainment** **Areas Product Applicability** **Applicable State Emission Limit Alternative Control Device Limits** **New York 6 Paper, Fabric, and Vinyl Coating 1977 CT G Limits** **b Control emissions by 80% using an** **incinerator Cleaning Materials No numeric limit Use work prac** **tices to minimize VOC emissions** **North Carolina 23 Paper, Fabric, and Vinyl Coating -** **CTG limits (on a lb/gal coating basis) apply only if using a control device** **1977 CTG Limits b** **None Pennsylvania 29 Paper and Fabric Coating 4.4 lb VOC** **per gallon coating solids** **Use capture and control system to meet emission limit** **Vinyl Coating 7.69 lb VOC per gallon coating solids** **Use capture and control system to meet emission limit** **Rhode Island 1 Paper, Fabric, and Vinyl Coating 197 7 CTG Limits** **b Control emissions by 95%** **Cleaning Material No numeric limit Keep records o f cleaning materials** **usage South Carolina 4 Paper, Fabric, and Vinyl Coating 1** **977 CTG Limits b** **Control emissions by 90% using an incinerator** **Cleaning Material No numeric limit Keep records o f cleaning materials** **usage Tennessee 7 Paper, Fabric, and Vinyl Coating 1977 C** **TG Limits b** **Overall control efficiency of 95% Virginia 11 Paper, Fabric, and Vinyl Coating 1977 C** **TG Limits b** **Use capture and control system to meet emission limit** **West Virginia 1 Paper, Fabric, and Vinyl Coating 19 77 CTG Limits** **b Overall control efficiency of 95%** **Cleaning Materials 6.8 kg/day (15 lb/day) Use wor k practices to minimize** **emissions; Do not use VOCs for cleanup activities unless equipment** **is used to collect the cleaning compounds and to minimize** **evaporation**Appendix B: Paper, Film, and Foil Surface CoatingFacilities in Current Nonattainment Areas and Associated State or LocalRequirements (Based on 2002 NEI and December 2006 Nonattainment Designations) (continued)**B-5 State or Local Jurisdiction** **Number of Facilities in** **Ozone Nonattainment** **Areas Product Applicability** **Applicable State Emission Limit Alternative Control Device Limits** **Wisconsin 7 Paper, Fabric, and Vinyl Coating 1977 C TG Limits** **b Control emissions by 90% using an** **incinerator**

# B-6 This page intentionally left blank.

# Appendix C

Summary of State-Specific Regulations for Paper, Fi lm, and Foil

Surface Coating Facilities (not including Californi a)

# This page intentionally left blank.**C-1**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia)State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric coating 0.35 kg/l (2.9 lb/gal)** **Paper coating 0.35 kg/l (2.9 lb/gal)** **Alabama (Jefferson County)** **Vinyl coating 0.45 kg/l (3.8 lb/gal)** **For sources located in Jefferson County: 1.** **Use low solvent coating technology; or 2.** **A capture and control system that have an overall VOC emission reduction that meet the applicable** **emission limit each day; or 3.** **Use powder coating technology; or 4.** **Average two or more coatings on a coating line that has no add-on VOC control equipment if:** **a. The coating is the same type of operation (source** **category) and is subject to the same limits; and b.** **The coatings are on the same coating line; and c.** **The coatings are averaged on the basis of pounds of VOC emitted per gallon of coating solids** **applied to the substrate; and d.** **The compliance demonstration is on a 24-hour period (calendar day); and** **e. The VOC emissions shall be equal to or less than** **those emitted when all the surface coatings delivered to the application system comply with** **the applicable regulated VOC emission rate restriction.** Exemption:**55 gallons of “low-use coatings” may be exempted on an annual rolling basis** **Keep records of cleaning materials. Alabama DEM Air** **Division Chapter 335- 3-6-.24 and 335-3-6-** **.32(6), (7), and (9)**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-2** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric coating 0.35 kg/l (2.9 lb/gal)** **Paper coating 0.35 kg/l (2.9 lb/gal)** **Alabama (except Jefferson County)** **Vinyl coating 0.45 kg/l (3.8 lb/gal)** **For sources NOT located in Jefferson County: 1.** **Use low solvent coating technology; or 2.** **90 percent emission reduction using incineration; or** **3. Another equivalent control technology** Exemptions:**Sources with the potential to emit less than 100 ton VOC/yr and paper coating (335-3-6-.11(** **6) doesn’t apply to any sources except sources in the** **State which manufacture audio or video recording tape.** **Keep records of cleaning material usage. Alabama DEM Air** **Division Chapters 335-3-6-.01 and 335-** **3-6-.11(6), (7), and (9)** **Alaska a** **Arizona POWC – Incorporated by Reference, Subpart JJ JJ** **Arizona/Pima POWC – Incorporated by Reference, Subpa rt JJJJ** **Arizona/Pinal POWC – Incorporated by Reference, Subp art JJJJ** **a Alaska does not have applicable air regulations. N** **o cleaning material regulations.**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-3** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric coating 0.35 kg/l (2.9 lb/gal)** **Paper coating 0.35 kg/l (2.9 lb/gal)** **Vinyl coating 0.45 kg/l (3.8 lb/gal)** **Apply all coatings containing more than 240 g VOC/L (2 lb/gal), minus exempt compounds using:** **1. Low pressure spray gun; or** **2. An electrostatic system; or** **3. Hydraulic pressure atomizer (including airless and** **air assisted airless); or 4.** **Non-atomizing or non-spraying application methods; or** **5. Alternate methods approved by regulatory** **authorities Use control systems meeting the following:** **1. Prevent at least 85% of the VOC emitted, except as** **controlled using the alternative for very dilute streams (see 3 below)** **2. Use an 87% efficient capture system;** **3. Use a 90% efficient control system or for VOC** **input less than 100 ppm – control to less than 20 mg VOC/M** **3 and the control system gets 85%** **control**Exemptions:**coatings and solvents with a VOC content less than 18g VOC/L (0.15 lb VOC/gal)** **Arizona/Maricopa Cleaning** **Materials 35 mm Hg at 20** **o C Work practices to minimize emissions** **Regulation III, Rule 336, section 301** **through 306 Arkansas** **b b** **Arkansas does not have applicable air regulations. No cleaning material regulations.** Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-4** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric Coating 0.35 kg/l (2.9 lb/gal)** **Paper Coating 0.35 kg/l (2.9 lb/gal)** **Plastic-Film Coating** **0.35 kg/l (2.9 lb/gal)** **Colorado Vinyl Coating 0.45 kg/l** **(3.8 lb/gal) 1.** **Use compliant coatings; 2.** **Use emissions averaging; 3.** **Use a capture system approved by the authority or a system that meets the NSPS for Magnetic Tape** **4. Use an add-on control system to meet the limit** Exemptions**: fabric and paper coating operations with** **uncontrolled actual emissions (including fugitives) are** **less than 6.8 kg/day (15 lb/day) and 1.4 kg/hr (3 l b/hr).** **No cleaning materials regulations CO DPHE** **AQCC Regulation No. 7** **5 CCR 1001-9 Section IX.E, I, J, and** **K Fabric coating 0.35 kg/l** **(2.9 lb/gal) Paper coating 0.35 kg/l** **(2.9 lb/gal) Connecticut** **Vinyl coating 0.45 kg/l (3.8 lb/gal)** **1. Compliant coatings; 2. Daily-weighted average coating content;** **3. Install capture and control system that reduces emissions by 95 percent** Exemptions**: any coating unit with uncontrolled actual emissions from all coating units are less than 6.8** **kg VOC per day (15 lb/day) combined** **No cleaning materials regulations. RSCA Title 22a** **Section 22a-174-3c,**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-5** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric coating 0.35 kg/l (2.9 lb/gal)** **Paper coating 0.35 kg/l (2.9 lb/gal)** **Vinyl coating 0.45 kg/l (3.8 lb/gal)** **1. Compliant coatings;** **2. Daily weighted average coating content** **3. Install capture and control system that reduces** **emissions by 95 percent**Exemptions**: any coating unit with uncontrolled actual emissions from all coating units are less than 15 l** **b VOC/day** **DNREC Regulation 24, Section 16, 17,** **and 18 Delaware** **Cleaning Materials** **Composite vapor pressure of 45 mm** **Hg at 20 °C Or** **Solvent must be at least 80% water, as** **applied Does not apply to** hand-wipe cleaning operation**Use work practices to minimize emissions Fabric Coating 0.35 kg/l** **(2.9 lb/gal) Paper Coating 0.35 kg/l** **(2.9 lb/gal) Florida** **Vinyl Coating 0.46 kg/l (3.8 lb/gal)** **1. Use of compliant coatings; 2. Use of incineration that reduces VOC emissions** **by 90 percent.** Exemptions:**all emission units subject to the same limitation that emit less than 6.8 kg VOC per day (** **15 lb/day) and 1.4 kg/hr (3 lb/hr) combined** **No cleaning material regulations. FAC Chapter 62-** **296.500, 503, and 504**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-6** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric Coating 2.9 lb/gal OR** **4.79 lb/gal coating solids (if coating** **content is > 2.9 lb/gal)** **Paper coating 2.9 lb/gal OR** **4.79 lb/gal coating solids (if coating** **content is > 2.9 lb/gal)** **Georgia Vinyl coating 3.8 lb/gal** **OR 7.86 lb/gal coating** **solids (if coating content is >** **3.8 lb/gal) 1.** **Use low solvent compliant coating technology 2.** **Use 24-hr weighted average of low solvent coating on a single coating line that meets 4.79 lb VOC/gal** **coating solids for fabric and paper or 7.86 lb/gal coating solids for vinyl (averaging across coating** **lines is not allowed) 3.** **Use capture and control that reduces VOC emissions by 90 percent and overall VOC** **emissions do not exceed 4.79 lb VOC/gal coating solids for fabric and paper or 7.86 lb/gal coating** **solids for vinyl**Exemptions:**Sources located outside Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette,** **Forsyth, Fulton, Gwinnett, Henry, Paulding, and Rockdale counties with potential VOC emissions** **are less than 100 tons per year; Sources located wi thin** **Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding** **, or Rockdale counties with actual VOC emissions are les** **s than 15 lb/day; total use of coatings, inks and oth** **er VOC-containing materials is less than 55 gal/yr** **No cleaning material regulations. GDNR** **OGCA 12-9-1 391-3-1-.03(2)(w) and** **(x) Hawaii** **c Idaho POWC – Incorporated by Reference, Subpart JJJJ** **c Hawaii does not have applicable air regulations. N** **o cleaning material regulations.**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-7** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric Coating 0.35 kg/l (3.8 lb/gal)** **Paper coating Specialty High** **Gloss Catalyzed** **Coating 0.42 kg/l** **(3.5 lb/gal) Paper coating –** **all others 0.35 kg/l** **(2.9 lb/gal) Illinois (not** **including Chicago and Metro East** **areas) Vinyl Coating 0.45 kg/l** **(3.8 lb/gal) 1.** **Control emissions by an afterburner system which provides an overall 81% VOC emission from the** **coating line, and 90% of the nonmethane VOC (measured as total combustible carbon) which** **enters the afterburner. 2.** **The combined actual emissions from selected coating lines (not including those constructed or** **modified after 7/1/79), is less than or equal to th e** **combined allowable emissions calculated using the formula provided in the regulation.** Exemptions:**Coating plants in which uncontrolled VOC emissions are limited by the operating permit t** **o 22.7 Mg/yr (25 tpy); or the total coating usage doe** **s not exceed 9,463 l/yr (2,500 gal/yr); or touch-up and r** **epair coatings used by a vinyl if the source-wide volume** **is less than 0.95 l (1 quart) per eight-hour period or** **exceeds 209 l/yr (55 gal/yr) for any rolling twelve -** **month period. No cleaning material regulations.** **Title 35, Subtitle B, Chapter I; Subchapter** **c, Part 215, Subpart F, sections 215.204(c),** **(e) and (f) and 215.205(b) and** **215.206 (a) and (b)**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-8** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric Coating 0.28 kg/l (2.3 lb/gal)** **Paper coating 0.28 kg/l (2.3 lb/gal)** **Illinois (Chicago areas)** **Vinyl Coating 0.28 kg/l (2.3 lb/gal)** **1. Apply coatings that, during each day, do not exceed** **the daily-weighted average VOC content limit 2.** **Use a capture and control system which has an overall VOC emission reduction of 81% and the** **control device has a 90% efficiency 3.** **Capture and control system reduces VOC emissions to meet the applicable VOC emission** **limit.**Exemptions:**Coating plants in which combined actual uncontrolled VOC emissions do not exceed 6.8 kg/day** **(15 lb/day); or touch-up and repair coatings used b y a** **vinyl if the source-wide volume is less than 0.95 l (1** **quart) per eight-hour period or exceeds 209 l/yr (5 5** **gal/yr) for any rolling twelve-month period. No cleaning material regulations.** **Title 35, Subtitle B, Chapter I; Subchapter** **c, Part 218, Subpart F, sections 218.204(c),** **(e) and (f) and 218.205(a) and** **218.207(b) and 218.208(a) and (c)** Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-9** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric Coating 0.28 kg/l (2.3 lb/gal)** **Paper coating 0.28 kg/l (2.3 lb/gal)** **Illinois (Metro East areas)** **Vinyl Coating 0.28 kg/l (2.3 lb/gal)** **1. Apply coatings that, during each day, do not exceed** **the daily-weighted average VOC content limit 2.** **Use a capture and control system which has an overall VOC emission reduction of 81% and the** **control device has a 90% efficiency 3.** **Capture and control system reduces VOC emissions to meet the applicable VOC emission** **limit.**Exemptions:**Coating plants in which combined actual uncontrolled VOC emissions do not exceed 6.8 kg/day** **(15 lb/day); or touch-up and repair coatings used b y a** **vinyl if the source-wide volume is less than 0.95 l (1** **quart) per eight-hour period or exceeds 209 l/yr (5 5** **gal/yr) for any rolling twelve-month period. No cleaning material regulations.** **Title 35, Subtitle B, Chapter I; Subchapter** **c, Part 219 Subpart F, sections 219.204(c),** **(e) and (f) and 219.205(a) and** **219.207(b) and 219.208(a) and (c)** Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-10** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric Coating 0.35 kg/l** **(2.9 lb/gal) Paper coating** **0.35 kg/l (2.9 lb/gal)** **Indiana Vinyl Coating 0.58 kg/l** **(4.8 lb/gal) 1.** **Use compliant coatings or 2.** **Fabric and vinyl coating operations can install capture and control devices with an overall** **efficiency greater than 67.5% given that the captur e** **efficiency is greater than 75% and the control device efficiency is greater than 90%** Exemptions:**Facilities existing before 1/1/80 not located in Clark, Elkhart, Floyd, Lake, Marion, Por** **ter, and St. Joseph Counties which have potential emissi** **ons less than 90.7 Mg/yr (100 tpy); Facilities construc** **ted after 1/1/80 located in any county with potential** **emissions less than 22.7 Mg/yr (25 tpy), Facilities existing before 7/1** **/90 and not located in Clark, Elkhart, Floyd, Lake, Mar** **ion, Porter, and St. Joseph Counties and facilities** **constructed after 7/1/90 and located in any county with** **actual uncontrolled emissions less than 15 lb VOC/d ay** **No cleaning material regulations. IDEM Air Pollution** **Control Board title 326** **326 IAC 8-2-1, 8-2-5, 8-2-11** **Iowa POWC – Incorporated by Reference, Subpart JJJJ Kansas** **d d** **Kansas has no applicable air regulations. No clean ing material regulations.** Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-11** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric Coating 15 % by weight of VOCs net input into** **the facility OR 0.35 kg/l** **(2.9 lb/gal) Paper Coating 15 % by weight of** **VOCs net input into the facility OR** **0.35 kg/l (2.9 lb/gal)** **Kentucky Vinyl Coating 15 % by weight of** **VOCs net input into the facility OR** **0.45 kg/l (3.8 lb/gal)** Exemptions:**facility with actual uncontrolled emissions less than 3 lb/hr; 15 lb/day; or 10 tpy b** **ased on maximum production and 8,760 hr/yr. Low use** **coating if plantwide consumption is less than or eq ual to** **55 gal/previous 12 months No cleaning material regulations.** **401 KAR 61:120 Fabric Coating 0.28 kg/l** **(2.3 lb/gal) Paper coating 0.28 kg/l** **(2.3 lb/gal) Louisiana** **Vinyl Coating 0.28 kg/l (2.3 lb/gal)** **1. Capture system with at least 80% efficiency** **2. Low solvent coating** **3. Incinerator with at least 90% control efficiency** **4. Carbon adsorption** Exemptions:**all emission units subject to the same limitation that emit less than 6.8 kg VOC per day (** **15 lb/day) and 1.4 kg/hr (3 lb/hr) combined** **No cleaning material regulations. LAC Title 33 2123.A,** **C Fabric Coating 0.35 kg/l** **(2.9 lb/gal) Maine** **Paper coating 0.35 kg/l (2.9 lb/gal)** **1. Low solvent coating** **2. Capture and control system that gets 95% control** **or 4.9 lb/gal solids 06 096 Chapter 123** **3.A and B; and Chapter 129 1.E, 3.B** **and C**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-12** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Vinyl Coating 0.45 kg/l (3.8 lb/gal)** Exemptions:**maximum theoretical VOC emissions from all coating units, lines or operations under t** **he same surface coating category less than 10 tpy. Or** **Coating units, lines or operations whose total actu al** **coatings usage from all coating units, lines or ope rations** **under the same surface coating category is less tha n 50** **gal/yr of coatings. OR facilities that use powder coatings or other non-VOC coating methods.** **No cleaning material regulations. Fabric Coating 0.35 kg/l** **(2.9 lb/gal) Paper Coating 0.35 kg/l** **(2.9 lb/gal) Maryland** **Vinyl Coating 0.45 kg/l (3.8 lb/gal)** **1. Use low VOC coatings or adhesives;** **2. Use a control device that, results in an emission** **reduction equal to or greater than the emission reduction that would have been achieved by** **complying low use VOC coatings 3.** **Reduce emissions by using water-based coatings, resins, inks, or similar products that contain less** **than 25 percent VOC by volume of the volatile portion of the product; or** **4. A alternative method approved by authority** Exemptions:**Facilities with emissions less than 20 lb VOC/day** **No cleaning material regulations. ACM Subtitle 11** **26.11.19.02 and .07**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-13** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric Coating 4.8 lb/gal solids, as applied (does not** **exclude water) Paper Coating 4.8 lb/gal solids, as** **applied (does not exclude water)** **Massachusetts Vinyl Coating 7.8 lb/gal solids, as** **applied (does not exclude water)** **1. Use low/no solvent coatings** **2. Use add-on controls** **3. Use Daily weighted averaging** Exemptions:**facilities for which the total amount of all coatings exempted is less than 55 gal on a 12-month** **rolling period and facilities with uncontrolled VOC emissions less than 15 lb/day** **Keep records of cleaning materials usage 310 CMR 7.18(14),** **(15) and (16) Fabric Coating 2.9 lb/gal** **Paper Coating 2.9 lb/gal Michigan** **Vinyl Coating 3.8 lb/gal 1.** **Use compliant coatings 2.** **Use volume weighted average emissions coating content** **3. Use add-on controls combined with volume** **weighted average**Exemptions:**Facilities with a combined actual VOC emission rate less than 100 lb/day or 2,000 lb/mont** **h and facilities may exclude low-use coatings that to** **tal 55 gallons or less per rolling 12-month period.** **No cleaning materials regulations R336.1610(2), (7) and** **(8) and R 336.2040(12)(a)** **and (b) Minnesota POWC – Incorporated by Reference, Subpart** **JJJJ Mississippi POWC – Incorporated by Reference, Subpar** **t JJJJ**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-14** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric Coating 2.9 lb/gal Paper Coating 2.9 lb/gal** **Vinyl Coating 3.8 lb/gal Missouri** **Other coatings 3 lb/gal 1.** **Comply with daily volume-weighted average, as applied, on a lb/gal coating basis** **2. Comply with daily volume-weighted average, as** **applied, on a lb/gal coating solids basis; 3.** **Comply with a combination of capture and control system and daily volume-weighted average.** Exemptions:**Does not apply to sources located outside** **of Clay, Jackson, and Platte counties and sources w ith** **total uncontrolled potential VOC emissions is less than** **6.8 kg/day (2.7 tpy). No cleaning material regulations.** **10 CSR 10- 2.230(1)(A) and (B),** **(4) and (5) Montana POWC – Incorporated by Reference, Subpart JJ** **JJ Nebraska POWC – Incorporated by Reference, Subpart J** **JJJ Nevada** **e Fabric Coating 0.35 kg/l** **(2.9 lb/gal) Paper Coating 0.35 kg/l** **(2.9 lb/gal) New Hampshire** **Vinyl Coating 0.45 kg/l (3.8 lb/gal)** **1. Use compliant coatings** **2. Use add-on controls** **3. Implement a “bubble” and comply with the** **calculated solids-based emission rate limit 4.** **Meet either an approved coatings-based or an approved solids-based modified emission limit** **using RACT order provisions**Exemptions:**(1) sources with theoretical potential emissions less than 10 tons VOC per any consecutive** **12-month period since December 31, 1989; (2) No cleaning materials regulations.** **NH CAR Chapter Env-A1200** **e Nevada has no air regulations applicable to the PF** **F industry. No cleaning material regulations.**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-15** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric Coating 0.35 kg/l (2.9 lb/gal)** **Paper Coating 0.35 kg/l (2.9 lb/gal)** **New Jersey Vinyl Coating 0.45 kg/l** **(3.8 lb/gal) 1.** **Control emissions by 90 percent 2.** **Control emissions such that the hourly VOC emission rate does not exceed a calculated max** **hourly emission rate**Exemptions:**total surface coating formulation containing VOC are applied at a rate less than 1⁄2 ga** **llon per hour and 2 1⁄2 gallons per day** **No cleaning materials regulations. NJAC Title 7, Chapter** **27, subchapter 16 7:27-16.7** **New Mexico f** **POWC – Incorporated by Reference, Subpart JJJJ Fabric Coating 2.9 lb/gal** **Paper Coating 2.9 lb/gal New York** **Vinyl Coating 3.8 lb/gal 1.** **Use a VOC incinerator that with 80% removal efficiency** **2. Determine overall removal efficiency of an air** **cleaning device on a solids as applied basis unless the air cleaning device has an 85% removal** **efficiency**Exemptions:**Low-use coatings where the combined facility-wide usage is less than 55 gallons on a 12** **- month rolling average** **Use work practices to minimize VOC emissions from cleaning materials.** **NY ECL part 228 Sections 228.1, 3, and** **7 f** **New Mexico has a local agency with air regulations , but they could not be accessed on the Internet.** Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-16** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric Coating 4.8 lb/gal coating solids, OR** **2.9 lb/gal if using a control device** **Paper Coating 4.8 lb/gal coating solids, OR** **2.9 lb/gal if using a control device** **North Carolina Vinyl Coating 7.9 lb/gal coating** **solids, OR 3.8 lb/gal if using a** **control device**Exemptions:**Sources with VOC emissions less than 15 lb/day** **No cleaning material regulations. NCAC 2D.0920 and** **21 North Dakota** **g g** **North Dakota does not have applicable air regulati ons.** Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-17** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric coating 4.8 lb/gal solids (if using a control** **system) OR** **2.9 lb/gal coating Paper coating 4.8 lb/gal solids (if** **using a control system)** **OR 2.9 lb/gal coating** **Ohio (Ashtabula, Butler, Clark,** **Clermont, Cuyahoga,** **Delaware, Franklin, Geauga, Greene,** **Hamilton, Lake, Licking, Lorain,** **Lucus, Mahoning, Medina, Miami,** **Montgomery, Portage, Stark,** **Summit, Trumbull, Warren, and Wood** **Counties) Vinyl coating 4.8 lb/gal coating** **(excluding water and exempt** **solvents) OR** **25% VOC by volume of the** **volatile matter of the coating** **1. Use complying coatings** **2. Use a capture and control system with overall VOC** **emission reduction greater than 81%, by weight, in the overall VOC emissions from the coating line;** **and the control equipment has an VOC emission reduction efficiency of 90% by weight** **3. Vinyl coating line only: install capture system wit** **h 75% by weight control efficiency and a control** **system that reduces emissions by 90% by weight**Exemption:**Emissions from all coating lines at the** **facility is less 15 lb VOC/day (before add-on contr ols)** **and a paper coating line which has a maximum application of coating materials less** **than or equal to 3 gal/day No cleaning material regulations apply to paper coa** **ting lines** **OAC 3745-21-09 (F), (G), and (H)** Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-18** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric coating 4.8 lb/gal solids (if using a control** **system) OR** **2.9 lb/gal coating Paper coating 4.8 lb/gal solids (if** **using a control system)** **OR 2.9 lb/gal coating** **Ohio (remaining 64 counties)** **Vinyl coating 4.8 lb/gal coating (excluding water** **and exempt solvents)** **OR 25% VOC by** **volume of the volatile matter of** **the coating 1.** **Use complying coatings 2.** **Use a capture and control system with overall VOC emission reduction greater than 81%, by weight, in** **the overall VOC emissions from the coating line; and the control equipment has an VOC emission** **reduction efficiency of 90% by weight 3.** **Vinyl coating line only: install capture system wit h** **75% by weight control efficiency and a control system that reduces emissions by 90% by weight** Exemption:**Existing facilities (for which construction or modification commenced before October 19, 1979)** **and have the potential to emit less than 100 tpy VO C.** **Emissions from all coating lines at the facility is less 15** **lb VOC/day (before add-on controls) and a paper coating line which has a maximum application of** **coating materials less than or equal to 3 gal/day** **No cleaning material regulations apply to paper coa ting** **lines OAC 3745-21-09 (F),** **(G), and (H) Oklahoma -** **attainment areas not in Tulsa County** **Coating Operations** **Ranges from 4.8 to 6.5 lb/gal** **(depending on type of coating)** **1. Compliant coatings** **2. Incineration, absorption, adsorption, or other** **process so long as emissions are no more than they would be using compliant coatings** Exemptions**: sources that emit less than 100 lb/day of VOC.** **Include VOC emissions from clean up in determining compliance** **Title 252, Chapter 100, 252:100-37-25** Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-19** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Oklahoma - Tulsa County** **Coating operations** **Ranges from 3.0 to 4.3 lb/gal** **(depending on type of coating)** **1. Compliant coatings** **2. Incineration, absorption, or other equipment so lon** **g as emissions are no more than they would be using** **compliant coatings, and at least 85% overall contro l** **efficiency Include VOC emissions from clean up in determining** **compliance Title 252, Chapter** **100, 252:100-39-46 Fabric Coating 2.9 lb/gal** **Paper Coating 2.9 lb/gal Vinyl Coating 3.8 lb/gal** **Oregon Existing** **Coating of Paper & Film in** **the Medford Ashland** **AQMA 55 lb/100 sq yards** **of material per pass 1.** **Use low solvent coatings; 2.** **Use an incineration system that gets 90% control or 3.** **An equivalent means of control**Exemptions:**Sources whose potential VOC emissions are less than 10 tpy (or 3 lb VOC/hr or 15 lb VOC/d** **ay actual).** **Keep records of cleaning materials usage OAR 340-232-0160** **Fabric Coating 0.58 kg/l coating solids (4.84 lb/gal)** **Paper Coating 0.58 kg/l coating solids (4.84 lb/gal)** **Pennsylvania Vinyl Coating 0.92 kg/l coating** **solids (7.69 lb/gal) 1.** **Use compliant coatings, as applied. 2.** **Use combination of compliant coatings and capture and control systems** Exemptions:**A facility that has had actual VOC emissions less than 1.4 kg/hr (3 lb/hr), 7 kg/day** **(15 lb/day) or 2,455 kg/yr (2.7 tpy) during any cal endar** **year since January 1, 1987 No cleaning material regulations.** **129-52**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-20** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric coating 4.8 lb/gal coating solids or** **2.9 lb/gal coating Paper coating 4.8 lb/gal coating** **solids or 2.9 lb/gal coating** **Rhode Island Vinyl coating 3.8 lb/gal coating** **solids or 7.86 lb/gal coating** **1. Reduce VOC emissions by 95% using a control** **system; 2.** **Use compliant coatings; 3.** **Use control systems to meet coating content limits; 4.** **Use daily-weighted averaging 5.** **Use an approved alternative method**Exemptions:**Actual uncontrolled VOC emissions are less than 15 lb/day since 12/31/89.** **Keep records of cleaning materials usage. Air Pollution Control** **Regulation No. 19 Fabric coating 0.35 kg/l** **(2.9 lb/gal) Paper coating 0.35 kg/l** **(2.9 lb/gal) South Carolina** **Vinyl coating 0.45 kg/l (3.8 lb/gal)** **1. Low solvent technology** **2. Incineration that reduces VOC emissions by 90** **percent 3.** **Carbon bed solvent recovery or 4.** **Alternative technology**Exemptions:**plants with total potential VOC emissions less than 550 pounds (250 kilograms) in a** **ny one day (nominal size - 100 tons per year) or more** **than 150 pounds (68 kilograms) in any one hour.** **Keep records of cleanup materials 62.5, St. 5, Part B and** **C South Dakota POWC – Incorporated by Reference, Subpa** **rt JJJJ**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-21** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric coating 0.35 kg/l (2.9 lb/gal)** **Paper coating 0.35 kg/l (2.9 lb/gal)** **Tennessee Vinyl coating 0.45 kg/l** **(3.8 lb/gal) 1.** **Use compliant coatings; 2.** **Meet limit using weighted average VOC content 3.** **Reduce emissions by 95% using capture and control system** Exemptions:**Facilities located in Davidson, Rutherford, Sumner, Williamson, or Wilson County** **with actual uncontrolled VOC emissions from all pap er** **coating operations less than 6.8 kg (15 lb) per day or** **whose max theoretical VOC emissions from all paper coating operations are less than 10 tpy. Facilitie** **s in Hamilton or Shelby County with potential VOC** **emissions from all paper coating operations less th an 25** **tpy, Facilities located in any other county with potential VOC emissions from all paper coating** **operations less than 100 tpy. No cleaning material regulations.** **1200-3-18-14, 15, 16**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-22** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric Coating 2.9 lb/gal (0.35 kg/l)** **Paper Coating 2.9 lb/gal (0.35 kg/l)** **Texas – Beaumont/Port** **Arthur, Dallas/ Fort Worth, El Paso, and** **Houston/ Galveston Areas** **Vinyl Coating 3.8 lb/gal (0.45 kg/l)** **not including plastisol** **1. Use compliant coatings;** **2. Use a vapor control system that gets 80% overall** **control or 3.** **Any alternate methods of control must be approved**Exemptions:**(1) Sources that emit uncontrolled VOC less than 3 lb/hr or 15 lb in any consecutive 24-hr** **period. (2) sources that emit uncontrolled VOC les s** **than 100 lb in any consecutive 24-hr period if documentation is received and approved that** **demonstrates that the performance criteria cannot b e** **achieved with compliant coatings and control equipment is not technically or economically feasib** **le. (3) a source with total coating and solvent usage i** **s less than 150 gal in any consecutive 12-month period. (4** **) aerosol spray cans** **No cleaning material regulations. TAC Title 30, Part 1,** **Chapter 115, Subchapter E,** **Division 2, Rule §§115.420 through** **115.427**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-23** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric Coating 2.9 lb/gal (0.35 kg/l)** **Paper Coating 2.9 lb/gal (0.35 kg/l)** **Texas – Gregg, Nueces, and** **Victoria Counties Vinyl Coating 3.8 lb/gal** **(0.45 kg/l) not including** **plastisol 1.** **Use compliant coatings; 2.** **Use a vapor control system that gets 80% overall control or** **3. Any alternate methods of control must be approved** Exemptions:**(1) Sources that emit uncontrolled VOC less than 550 lb in any consecutive 24-hr period.** **(2) aerosol spray cans** **No cleaning material regulations. TAC Title 30, Part 1,** **Chapter 115, Subchapter E,** **Division 2, Rule §§115.420 through** **115.427 Fabric coating 0.35 kg/l** **(2.9 lb/gal) OR 4.8 lb/gal coating** **solids Paper coating 0.35 kg/l** **(2.9 lb/gal) OR 4.8 lb/gal coating** **solids Utah** **Vinyl coating 0.45 kg/l (3.8 lb/gal) OR** **7.9 lb/gal coating solids** **1. Use low solvent technology coatings;** **2. Reduce VOC emissions by 90% using an** **incinerator or using a carbon adsorber**Exemptions:**Sources whose VOC emissions are less than 6.8 kg (15 lb) in any 24 hour period, nor more** **than 1.4 kg (3 lb) in any one hour** **Work practices to minimize VOC emissions from cleaning materials** **R307-340-2 and 11**Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-24** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Paper Coating 2.9 lb/gal Vermont** **Other coating sources** **3.5 lb/gal 1.** **Daily weighted average of VOC content must comply with VOC limit.** **2. Install capture and control device where the overal** **l reduction efficiency is greater than or equal to th** **e required reduction efficiency (an efficiency is not** **specified).**Exemptions:**Paper coating sources that have actual uncontrolled VOC emissions less than 15 lb/day. Ot** **her VOC sources with allowable VOC emissions less than** **50 tpy any year since 1/1/90. No cleaning material regulations.** **5-253.10 Fabric Coating 2.9 lb/gal** **Paper Coating 2.9 lb/gal Virginia** **Vinyl coating 3.8 lb/gal 1.** **Use of waterborne coatings; 2.** **Use of high-solids coatings; 3.** **Carbon adsorption; 4.** **Incineration; or 5.** **Any technology with an equivalent control efficiency when compared to the use of a coating** **complying with the VOC limit**Exemptions:**Coating plants with actual VOC emissions less than 2.7 tpy, 15 lb/day and 3 lb/hr.** **All VOC emissions from purging or washing solvents must** **be included. No cleaning material regulations.** **9 VAC 5-40-4330 and 9 VAC 5-40-4480** Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-25** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric coating 0.35 kg/l (2.9 lb/gal)** **Paper coating 0.35 kg/l (2.9 lb/gal)** **Washington Vinyl coating 0.45 kg/l** **(3.8 lb/gal)**Exemption:**Coating and dryer operations with potential uncontrolled VOC emissions less than 18 k** **g (40 lb)/24-hr period.** **No cleaning material regulations. WAC 173-490-040(6)** **Fabric coating 0.35 kg/l (2.9 lb/gal)** **Paper coating 0.35 kg/l (2.9 lb/gal)** **Vinyl coating 0.45 kg/l (3.8 lb/gal)** **1. Daily weighted emission limitation** **2. Use a capture and control system with an overall** **emission reduction of 95%**Exemptions:**coating operations at facilities with uncontrolled actual VOC emissions less than 0.68 kg** **(15 lb) per day. West Virginia** **Cleaning Materials** **6.8 kg/day (15 lb/day)** **Use work practices to minimize emissions. Do not use VOCs for cleanup activities unless** **equipment is used to collect the cleaning compounds and to minimize their evaporation to the atmosphere** **. §42-21-13, 14, and 15** Appendix C: Summary of State-Specific Regulationsfor Paper, Film, and Foil Surface Coating Facilities (not includingCalifornia) (continued)**1 Numerical limits are as applied, minus water and e** **xempt compounds, unless otherwise noted. C-26** State/LocalityOperationsCoveredVOC NumericalLimit1Compliance Method Citation**Fabric coating 0.35 kg/l (2.9 lb/gal) OR** **4.8 lb/gal coating solids** **Paper coating 0.35 kg/l (2.9 lb/gal) OR** **4.8 lb/gal coating solids** **Wisconsin Vinyl coating 0.45 kg/l** **(3.8 lb/gal) OR 7.9 lb/gal coating** **solids 1.** **Use of low solvent coatings 2.** **Use a vapor recovery system 3.** **Use incinerator with a 90% emission reduction 4.** **Daily volume-weighted average**Exemptions:**coating operations at facilities with uncontrolled actual VOC emissions less than 0.68 kg** **(15 lb) per day. No cleaning material regulations.** **NR 422.04 , 07 and 08 Wyoming POWC – Incorporated by Reference, Subpart JJJ** **J**

# Appendix D

Summary of California Regulations for Paper, Film, and Foil

Surface Coating Facilities

# This page intentionally left blank.**D-1**Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating FacilitiesOperation MaterialVOClimitationCompliance Requirements CitationAntelope Valley Air Pollution Control District**Coating Content limit of 265 g/l as** **applied (except water and** **exempt compounds)** **Plastisol Content limit of 20 g/l as** **applied (except water and** **exempt compounds)** **Paper, fabric and film** **Wash primer Content limit of 265 g/l** **material used 1.** **Use compliant coatings; or use an collection system that has a capture** **efficiency of at least 90 %, by weight and the cont rol device has an** **emission reduction efficiency of 95 % by weight or to an outlet** **concentration of 50 ppmv (as carbon) 2.** **Coatings containing 20 g VOC/l material or more mus t be applied** **using hand application methods; HVLP spray (air dri ed coatings only);** **or one of the following coaters: flow, roll, dip, f oam, and die.** **Alternative coating methods must be approved. 3.** **Containers and mixing tanks must be free from leaks and covered** **except when adding or removing materials, cleaning or when the** **container is empty. 4.** **Solvent cleaning must use one of the following: wip e cleaning; closed** **containers or hand held spray bottles w/out propell ant-induced force;** **cleaning equipment which has a solvent container th at is closed at all** **times (except when adding or removing parts or duri ng repair); remote** **reservoir cleaner; non-atomized solvent flow where solvent is collected** **in a container or collection system that is closed at all times except for** **solvent collection and pressure relief (as needed) openings; and solvent** **flushing methods where solvent is collected in a co ntainer or collection** **AVAQMD Rule 1128 and 1171** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-2**Operation MaterialVOClimitationCompliance Requirements Citation**Solvent cleaning materials** **(excluding hand wiping)** **Content limit of 950 g/l** **(7.9l g/gal) and VOC** **composite partial pressure** **of 35 mm Hg @20** **o C (68** **o F)** **system that is closed at all times except for solve nt collection and** **pressure relief (as needed) openings (discharged so lvent must be** **collected into containers without atomizing into th e air and solvent** **may be flushed through the system by air or hydraul ic pressure or by** **pumping). 5.** **All VOC-containing solvents must be stored in non-a bsorbent, non** **leaking containers which must be kept closed at all times, except when** **filling or emptying. Cloth and paper containing wi th VOC-laden** **solvents should be stored in closed, non-absorbent, non-leaking** **containers. 6.** **Use closed containers for disposal of cloth or pape r used in stripping** **cured coatings that are impregnated with solvent co ntaining VOC** Exemptions:**operations using aerosol coating products, applic ation of** **coatings to fine arts paintings, scenic or theatric al backgrounds for motion** **pictures, television, and theater.**Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-3**Operation MaterialVOClimitationCompliance Requirements CitationBay Area Air Quality Management District**Paper, fabric, and film** **Coating lines that emit more than** **6.5 kg/day (14.3 lb/day)** **Content limit of 265 g/l** **(2.2 lb/gal), as applied** **(excluding water) or** **emission limit of 120 g/l** **(1 lb/gal) as applied,** **excluding water (using** **an approved control** **system) 1.** **Use an approved control system 2.** **Use low-solvent coatings that meet the content limi t** **3. Keep all containers storing organic solvents or tan** **ks for mixing coatings covered at all times except when material** **is being added or removed, when the tank or container is being cleane** **d, or when the container is empty.** **4. Do not allow leaks from containers storing organic** **solvents or from tanks used for mixing coatings.** **5. Do not utilize open containers to store or dispose** **of cloth or paper laden with organic compounds that is used for surfa** **ce preparation, cleanup or coating removal.** **6. Do not store spent or fresh organic compounds to be** **used for surface preparation, cleanup or coating removal in open con** **tainers.**Exemptions:**. Operations that manufacture flexible packaging m aterials** **for packaging food or healthcare products for human or animal** **consumption and where the coating is applied on the same line as printing** **or decorative design. These operations are subject to Rule 20 (Graphic Arts** **Printing and Coating Operations). BAAQMD 8-12** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-4**Operation MaterialVOClimitationCompliance Requirements Citation**Coating lines that emit less than** **6.5 kg/day (14.3 lb/day)** **Emission limit of 4,533 kg/yr** **(5 tpy); or Coating** **content limit of 420 g/l (3.5** **lb/gal), as applied** **(excluding water or** **exempt compounds)** **and solvent content limit** **of 50 g/l (0.42 lb/gal)** **1. Meet emission limit or use compliant coatings or us** **e an emission control system with an overall efficiency of 85% or** **90% for an incinerator.** **2. For solvents used for surface preparation or cleanu** **p must either use a control system with an overall control efficiency o** **f 85% or more; or one of the following (1) use closed containers for** **the storage or disposal of cloth or paper used for solvent surface** **preparation and cleanup; and (2) use organic solvent for the cleanu** **p of spray equipment, including paint lines, with a compliant** **VOC content unless either the (a) solvent is pressurized though spray** **equipment with atomizing air off or dispensed from a small non-ato** **mizing container, and collected and stored in a closed container unti** **l recycled or properly disposed of offsite; or (b) a spray gun wa** **sher subject to and in compliance with the requirements of Regulation 8** **, Rule 16 is used; and (3) close containers of solvent or coating when** **not in use.**Exemptions:**surface coating using non-refillable aerosol cans ; film** **cleaning operations using 1,1,1-trichloroethane exc lusively** **BAAQMD 8-4**El Dorado County Air Quality Management District**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized in** **the presence of O 2** **15 lb/day and 3 lb/hr** **Machinery, process, or** **operation with the potential** **to emit organic** **compounds Any that are** **conducted at or below ambient** **temperatures 40 lb/day and** **8 lb/hr (emissions** **from air or heat drying for** **the first 12 hours must be** **included) 1.** **Reduce VOC emissions by 85% or more; or equip proce ss with BACT** **2. Do not dispose or allow the release of organic comp** **ounds from storage or transfer operations of more than 1.5 gal** **of liquid (or equivalent amount of vapor).** Exemptions:**(1) stationary storage containers less than 250 g al; (2) any** **single use or operation which annually uses a total volume of VOC which is** **less than the emission limits, unless it is part of a large operation subject to** **regulation; and (3) sources in existence before Mar ch 1, 1984.** **EDCAQMD Rule 216**Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-5**Operation MaterialVOClimitationCompliance Requirements Citation**Solvents used on substrates during** **the manufacturing process or for** **surface preparation** **70 g VOC/l material** **Solvents used for maintenance and** **repair 900 g VOC/l** **material and a composite** **partial pressure of 20 mm Hg** **or less at 20 o** **C (68** **o F)** **Solvents used for cleaning coatings** **or adhesives application** **equipment 950 g VOC/l** **material and a composite** **partial pressure of 35 mm Hg** **or less at 20 o** **C (68** **o F)** **Solvent Cleaners** **Solvents used for cleaning polyester** **resin application equipment** **200 g VOC/l material; or** **1,100 g VOC/l and composite** **partial pressure of 1.0 mm Hg** **or less at 20 o** **C (68** **o F) or** **solvent reclamation** **system 1.** **Use complaint cleaning materials AND Use one of the following** **cleaning devices or methods: a.** **Wipe cleaning; b.** **Non propellant spray bottles or containers c.** **Cleaning equipment which has a solvent container th at can be, and** **is, closed during cleaning operations, except when depositing and** **removing objects, and is closed during non-operatio n with the** **exception of maintenance and repair to the cleaning equipment** **itself; d.** **Non-atomized solvent flow method where the cleaning solvent is** **collected in a container or a collection system whi ch is closed** **except for solvent collection openings and, if nece ssary, openings** **to avoid excessive pressure build-up inside the con tainer; or** **e. Solvent flushing method where the cleaning solvent** **is discharged into a container which is closed except for solvent** **collection openings and, if necessary, openings to avoid exces** **sive pressure build-up inside the container. The discharged solve** **nt from the equipment must be collected into containers without** **atomizing into the open air. The solvent may be flushed throu** **gh the system by air or hydraulic pressure, or by pumping.** **2. Use a collection and control system that collects a** **t least 90 percent of the emissions and reduces VOC emissions by at least** **95 percent or has an outlet concentration less than 50 ppmw (as c** **arbon) EDCAQMD Rule 235** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-6**Operation MaterialVOClimitationCompliance Requirements CitationGreat Basin Unified Air Pollution Control District**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized in** **the presence of O 2** **15 lb/day and 3 lb/hr** **Photochemically a** **reactive solvent (except solvents** **that are baked, heat cured or** **heat polymerized)** **40 lb/day and 8 lb/hr** **(emissions from air or** **heat drying for the first 12** **hours must be included)** **Organic solvents or** **solvent containing** **materials Non** **photochemically reactive solvent** **(except solvents that are baked,** **heat cured or heat** **polymerized) 3,000 lb/day** **and 450 lb/hr (emissions** **from air or heat drying for** **the first 12 hours must be** **included) 1.** **Reduce VOC emissions by 85% or more 2.** **Control emissions by incineration with an emission reduction of 90%** **or use adsorption, or another approved method of co ntrol.** Exemptions:**(1) transport of storage of organic containing ma terials; (2)** **the volatile content of materials consists of only water and non** **photochemically reactive organic solvents containin g less than 20% by** **volume of VOC, and does not come into contact with a flame; (3) the** **volatile content of materials consists of only wate r and non** **photochemically reactive organic solvents and more than 50% by volume of** **VOC is evaporated prior to entering a chamber heate d above ambient** **temperature, and does not come into contact with a flame; and (4) the** **solvent content is less than 5% by volume of non-ph otochemically reactive** **organic solvents, and does not come into contact wi th a flame.** **GBUAPCD Rule 417 a** **A photochemically reactive solvent is any solvent w ith an aggregate of more than 20 percent of its tot** **al volume composed of the following chemicals or wh ich exceeds ay of the following individual** **percentage composition limitations, referred to by the total volume of solvent: (1) A combination of h** **ydrocarbons, alcohols, aldehydes, esters, ethers, o r ketones having an olefinic or cyclo-olefinic** **type of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon ato** **ms to the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketons** **having branched hydrocarbon structures, trichloroet hylene or toluene: 20 percent. Whenever any organi** **c solvent or any constituent of an organic solvent may be classified from its chemical structure** **into more than one of the above groups or organic c ompounds, it shall be considered as a member of the** **most reactive chemical group that is, that group h aving the least allowable percentage of the** **total volume of solvents.**Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-7**Operation MaterialVOClimitationCompliance Requirements CitationImperial County Air Pollution Control District**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized in** **the presence of O 2** **15 lb/day and 3 lb/hr** **Organic solvents or** **solvent containing** **materials Photochemically** **b reactive solvent** **(except solvents that are baked,** **heat cured or heat** **polymerized) 40 lb/day and** **8 lb/hr (emissions** **from air or heat drying for** **the first 12 hours must be** **included) 1.** **Emissions from cleanup with photo-chemically reacti ve solvents must** **be included in compliance determination 2.** **Reduce VOC emissions by 85% or more using a capture and control** **system (an incinerator must have an emission reduct ion of 90% or** **more).**Exemptions:**(1) transport of storage of organic containing ma terials; and** **(2) the volatile content of materials consists of o nly water and non** **photochemically reactive organic solvents containin g less than 20% by** **volume of VOC, and does not come into contact with a flame; and (3) use,** **application, evaporation, or drying halogenated hyd rocarbons or** **perchloroethylene. ICAPCD Rule 417** **b A photochemically reactive solvent is any solvent w** **ith an aggregate of more than 20 percent of its tot al volume composed of the chemical compounds classi** **fied below or which exceeds any of the following individual percentage composition limitat** **ions, referred to the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes,** **esters, ethers, or ketones having an olefinic or cyclo-olefinic type of unsaturation: 5 percent; (2)** **a combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenze** **ne: 8 percent; (3) a combination of ethylbenzene, ketones having branched hydrocarbon s** **tructures, or toluene: 20 percent.**Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-8**Operation MaterialVOClimitationCompliance Requirements CitationKern County Air Pollution Control District**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized in** **the presence of O 2** **15 lb/day Photochemically** **c reactive solvent** **(except solvents that are baked,** **heat cured or heat** **polymerized) 40 lb/day** **(emissions from air or** **heat drying for the first 12** **hours must be included)** **Organic solvents or** **solvent containing** **materials Non** **photochemically reactive solvent** **(except solvents that are baked,** **heat cured or heat** **polymerized) 3,000 lb/day** **(emissions from air or** **heat drying for the first 12** **hours must be included)** **1. Reduce VOC emissions by 85% using an incinerator wi** **th an emission reduction of 90%; or adsorption, or another approve** **d method of control.** Exemptions:**(1) transport of storage of organic containing ma terials; (2)** **the volatile content of materials consists of only water and non** **photochemically reactive organic solvents containin g less than 20% by** **volume of VOC and does not come into contact with a flame; (3) the** **solvent content is less than 20% by volume of non-p hotochemically** **reactive organic solvents and does not come into co ntact with a flame; and** **(4) use, application, evaporation, or drying haloge nated hydrocarbons or** **perchloroethylene. KCAPCD Rule 410** **c A photochemically reactive solvent is any solvent w** **ith an aggregate of more than 20 percent of its tot al volume composed of the following chemicals or wh** **ich exceeds ay of the following individual percentage composition limitations, referred to by** **the total volume of solvent: (1) A combination of h ydrocarbons, alcohols, aldehydes, esters, ethers, o** **r ketons having an olefinic or cyclo-olefinic type of unsaturation: 5 percent; (2) A combination of ar** **omatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A** **combination of ethylbenzene, ketons having branched hydrocarbon structures, trichloroet** **hylene or toluene: 20 percent. Whenever any organi c solvent or any constituent of an organic solvent** **may be classified from its chemical structure into more than one of the above groups or organic c** **ompounds, it shall be considered as a member of the most reactive chemical group that is, that group h** **aving the least allowable percentage of the total volume of solvents.** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-9**Operation MaterialVOClimitationCompliance Requirements CitationMojave Desert Air Quality Management District**All VOC containing** **materials 540 kg/month** **(1,190 lb/ month)** **Organic solvents or** **solvent containing** **materials Non-VOC** **containing organic solvent** **272 kg/day (600 lb/day)** **on a 30-day rolling average** **1. For VOC-containing materials:** **a. use product reformulation or substitution;** **b. process changes;** **c. improvement of operational efficiency;** **d. development of innovative technology; or** **e. install a collection and control system that reduce** **s emissions by 85% or more provided that capture system has a capt** **ure efficiency of 90% by weight and the control system has a destr** **uction efficiency of 95% or more by weight or an output co** **ncentration of 50 ppm (as carbon)** **2. Non-VOC organic compounds** **a. include the drying period of 12 hrs after applicati** **on of solvent 3.** **Store all VOC containing materials in nonabsorbent, non-leaking** **containers which must be kept closed at all times ( except during** **emptying or filling). 4.** **Dispose of all VOC containing materials to prevent evaporation into** **the atmosphere.**Exemptions:**(1) transport or storage of organic solvent mater ials; (2) use** **of 1,1,1-trichloroethylene, methylene chloride, and trichlorofluoroethane;** **and (3) aerosol products MDAQMD Rule 442** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-10**Operation MaterialVOClimitationCompliance Requirements CitationMonterey Bay Unified Air Pollution Control District**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized at a** **temperature of 194** **o F (90** **o C) in** **the presence of O 2** **15 lb/day Organic** **solvents or solvent** **containing materials** **Any that do not come into contact** **with a flame, or are not baked,** **heat cured, or heat-polymerized** **in the presence of O** **2 40 lb/day** **(emissions from air or** **heat drying for the first 12** **hours must be included)** **1. Emissions from cleanup with solvents must be includ** **ed in compliance determination** **2. Reduce VOC emissions by 85% or more using a capture** **and control system (an incinerator must have an emission reduct** **ion of 90% or more).** Exemptions:**(1) transport or storage of solvent materials; (2 ) any source in** **existing prior to March 19, 2001 with actual VOC em issions less than 15** **lb/day (solvents that are baked, heat-cured, heat-p olymerized or exposed to** **flame) or 40 lb/day (solvents that are not baked, h eat-cured, heat** **polymerized or exposed to flame) MBUAPCD Rule 416** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-11**Operation MaterialVOClimitationCompliance Requirements CitationPlacer County Air Pollution Control District**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized in** **the presence of O 2** **15 lb/day and 3 lb/hr** **Photochemically d** **reactive solvent (except solvents** **that are baked, heat cured or** **heat polymerized)** **40 lb/day and 8 lb/hr** **(emissions from air or** **heat drying for the first 12** **hours must be included)** **Organic solvents or** **solvent containing** **materials Non** **photochemically reactive solvent** **(except solvents that are baked,** **heat cured or heat** **polymerized) 3,000 lb/day** **and 450 lb/hr (emissions** **from air or heat drying for** **the first 12 hours must be** **included) 1.** **Reduce VOC emissions by 85% or more by incineration (if incinerator** **has an emission reduction of 90% or more), adsorpti on, or another** **approved method of control. 2.** **Do not dispose or allow the release of organic comp ounds from storage** **or transfer operations of more than 1.5 gal of liqu id (or equivalent** **amount of vapor). 3.** **Emissions from cleanup with solvents must be includ ed in compliance** **determination**Exemptions:**(1) transport of storage of organic containing ma terials; (2)** **the volatile content of materials consists of only water and non** **photochemically reactive organic solvents containin g less than 20% by** **volume of VOC, and does not come into contact with a flame; and (3) the** **solvent content is less than 20% by volume of non-p hotochemically** **reactive organic solvents, and does not come into c ontact with a flame.** **PLAAPCD Rule 219 d** **A photochemically reactive solvent is any solvent w ith an aggregate of more than 20 percent of its tot** **al volume composed of chemicals compounds classifie d below or which exceed any of the** **following individual percentage composition limitat ions, referred to by the total volume of solvent: (** **1) A combination of hydrocarbons, alcohols, aldehyd es, esters, ethers, or ketones having an olefinic** **or cyclo-olefinic type of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight** **or more carbon atoms to the molecule except ethylbe nzene: 8 percent; (3) A combination of** **ethylbenzene, ketones having branched hydrocarbon s tructures, trichloroethylene or toluene: 20 percent** **. Whenever any organic solvent or any constituent of an organic solvent may be classified from** **its chemical structure into more than one of the ab ove groups or organic compounds, it shall be consid** **ered as a member of the most reactive chemical grou p that is, that group having the least** **allowable percentage of the total volume of solvent s.** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-12**Operation MaterialVOClimitationCompliance Requirements Citation**Melamine resin coating** **0.1 lb VOC/gal coating as** **applied (except for water and** **exempt compounds)** **Paper treating operations** **Phenolic resin coating** **1.75 lb VOC/gal** **coating as applied (except** **for water and exempt** **compounds) 1.** **Use compliant coatings or us a capture and control system that has an** **overall efficiency of 85% by weight 2.** **Total VOC emissions including control must meet the level of coating** **content limits. PLAAPCD Rule 230** **Solvents used on substrates during** **the manufacturing process or for** **surface preparation** **70 g VOC/l material** **Solvents used for maintenance and** **repair 900 g VOC/l** **material and a composite** **partial pressure of 20 mm Hg** **or less at 20 o** **C (68** **o F)** **Solvent Cleaners** **Solvents used for cleaning coatings** **or adhesives application** **equipment 950 g VOC/l** **material and a composite** **partial pressure of 35 mm Hg** **or less at 20 o** **C (68** **o F)** **1. Use complaint cleaning materials AND Use one of the** **following cleaning devices or methods:** **a. Wipe cleaning;** **b. Non propellant spray bottles or containers** **c. No spray discharge into open air** **2. Use a collection and control system that collects a** **t least 90 percent of the emissions and reduces VOC emissions by at least** **95 percent or has an outlet concentration less than 50 ppmw (as c** **arbon) PLAAPCD Rule 240** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-13**Operation MaterialVOClimitationCompliance Requirements Citation**Solvents used for cleaning polyester** **resin application equipment** **200 g VOC/l material; or** **1,100 g VOC/l and composite** **partial pressure of 1.0 mm Hg** **or less at 20 o** **C (68** **o F) or** **solvent reclamation** **system**Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-14**Operation MaterialVOClimitationCompliance Requirements CitationSacramento Metropolitan Air Quality Management District**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized in** **the presence of O 2** **6.8 kg (15 lb) per day and** **1.4 kg (3.1lb) per hour** **Photochemically e** **reactive solvent (except solvents** **that are baked, heat cured or** **heat polymerized)** **18 kg (40 lb) per day and** **3.6 kg (7.9 lb) per hour** **(emissions from air or** **heat drying for the first 12** **hours must be included)** **Organic solvents or** **solvent containing** **materials Non** **photochemically reactive solvent** **(except solvents that are baked,** **heat cured or heat** **polymerized) 1,350 kg** **(3,000 lb)/day and 200 kg** **(441 lb)/hr (emissions** **from air or heat drying for** **the first 12 hours must be** **included) 1.** **Reduce VOC emissions by 85% overall using an incine rator** **(incinerator must have an emission reduction of 90% or more); or** **adsorption, or another approved method of control. 2.** **Emissions from cleanup with solvents must be includ ed in compliance** **determination 3.** **Do not dispose of 5 liters (1.3 gal) per day of pho tochemically reactive** **solvent or solvent containing materials such that t hey are emitted to the** **atmosphere.**Exemptions:**(1) transport of storage of organic containing ma terials; (2)** **the volatile content of materials consists of only water and non** **photochemically reactive organic solvents containin g less than 20% by** **volume of VOC and does not come into contact with a flame; (3) the** **solvent content is less than 20% by volume of non-p hotochemically** **reactive organic solvents and does not come into co ntact with a flame; and** **(4) use, application, evaporation, or drying haloge nated hydrocarbons or** **perchloroethylene. KCAPCD Rule 410** **e A photochemically reactive solvent is any solvent w** **ith an aggregate of more than 20 percent of its tot al volume composed of the following chemicals or wh** **ich exceeds ay of the following individual percentage composition limitations, referred to by** **the total volume of solvent: (1) A combination of h ydrocarbons, alcohols, aldehydes, esters, ethers, o** **r ketons having an olefinic or cyclo-olefinic type of unsaturation: 5 percent; (2) A combination of ar** **omatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A** **combination of ethylbenzene, ketons having branched hydrocarbon structures, trichloroet** **hylene or toluene: 20 percent. Whenever any organi c solvent or any constituent of an organic solvent** **may be classified from its chemical structure into more than one of the above groups or organic c** **ompounds, it shall be considered as a member of the most reactive chemical group that is, that group h** **aving the least allowable percentage of the total volume of solvents.** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-15**Operation MaterialVOClimitationCompliance Requirements Citation**Solvent Cleaning** **Materials General cleaning** **activities, product cleaning during** **manufacturing or surface** **preparation for coatings,** **adhesives, sealants, or ink** **application; Repair and** **maintenance cleaning** **50 g VOC/l (0.42 lb/gal)** **1. Use complaint cleaning materials AND Use one of the** **following cleaning devices or methods:** **a. Wipe cleaning;** **b. Cleaning with closed containers or by using hand he** **ld spray bottles or containers without a propellant-induced** **force; c.** **Using cleaning equipment which has a solvent contai ner that is** **closed during cleaning operations, except when depo siting and** **removing objects, and is closed during non-operatio n with the** **exception of maintenance and repair to the cleaning equipment** **itself; d.** **Using a remote reservoir degreaser, non-vapor degre aser, or vapor** **degreaser used as required under Rule 454. e.** **Using solvent flushing method where the cleaning so lvent is** **discharged into a container which is closed except for solvent** **collection openings and, if necessary, openings to avoid excessive** **pressure build-up inside the container. The dischar ged solvent** **from the equipment must be collected into container s without** **atomizing into the open air. The solvent may be flu shed through** **the system by air or hydraulic pressure, or by pump ing.** **2. Use a collection and control system that collects a** **t least 90 percent of the emissions and reduces VOC emissions by at least** **95 percent or has an outlet concentration less than 50 ppmw (as c** **arbon) KCAPCD Rule 466** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-16**Operation MaterialVOClimitationCompliance Requirements CitationSan Diego County Air Pollution Control District**Coating lines Content limit of 265 g/l as** **applied (excluding** **water) Paper, Film** **and Fabric Cleaning** **materials Content limit** **of 200 g/l 1.** **Use compliant coatings or reduce VOC emissions usin g a control** **system with a combined collection and abatement eff iciency of 90% by** **weight or more; 2.** **Containers and mixing tanks must be free from liqui d leaks and must** **be covered except when adding or removing materials , cleaning, or** **when the container is empty; 3.** **Use compliant cleaning materials or use a system th at totally encloses** **the component parts being cleaned during washing, r insing, and** **draining or the cleaning 4.** **Transfer the cleaning solvent through the applicati on equipment,** **without exposure to air, into a container which has completely covers** **the container and has no visible holes, breaks, ope nings or separations** **between adjoining components 5.** **Coating or cleaning solvent container must display the content of** **methylene chloride, CFC-11, CFC-12, CFC-113, CFC-11 4, or CFC** **115**Exemption:**Any application process that has VOC emissions less than** **14.3 lb (6.5 kg) per day SDAPCD Rule 67.5** **Pressure sensitive tap** **and label manufacturing** **Coating lines Content limit of 0.20 kg** **VOC/kg coating solids** **as applied (average for** **month) 1.** **Use compliant coatings or reduce emissions by 90% o verall over a** **calendar month or calculate a weighted average emis sion reduction** Exemption:**VOC input is less than 45 Mg (49.6 tons) of VOC p er 12-** **month period SDAPCD Rule 260.440** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-17**Operation MaterialVOClimitationCompliance Requirements Citation**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized in** **the presence of O 2** **6.8 kg (15 lb) per day and** **1.4 kg (3.1lb) per hour** **Photochemically f** **reactive solvent (except solvents** **that are baked, heat cured or** **heat polymerized)** **18 kg (40 lb) per day and** **3.6 kg (7.9 lb) per hour** **(emissions from air or** **heat drying for the first 12** **hours must be included)** **Organic solvents or** **solvent containing** **materials Non** **photochemically reactive solvent** **(except solvents that are baked,** **heat cured or heat** **polymerized) 1,350 kg** **(3,000 lb)/day and 200 kg** **(441 lb)/hr (emissions** **from air or heat drying for** **the first 12 hours must be** **included) 1.** **Reduce VOC emissions by 85% overall using an incine rator; or** **adsorption; or another approved method of control. 2.** **Emissions from cleanup with solvents must be includ ed in compliance** **determination 3.** **Do not dispose of 5 liters (1.3 gal) per day of pho tochemically reactive** **solvent or solvent containing materials such that t hey are emitted to the** **atmosphere.**Exemptions:**(1) the organic solvent content of surface coatin g do not** **exceed 30% by volume, excluding water and does not come into contact** **with a flame; (2) the use of any air-dried material which contains less than** **420 g/l of coating applied (excluding water or exem pt compounds) (3) the** **use of a baked coating material which contains less than 360 g/l of coating** **as applied (excluding water or exempt compounds) an d (4) any equipment,** **process or operation which has implemented BACT or LAER as a result of** **NSR SDAPCD Rule 66** **f The compositional limitations of any organic solven** **t referred to are the volume percentages of the fol lowing photochemically reactive compounds, compare** **d to the total solvent volume: (1) A combination of hydrocarbons, alcohols, aldehydes, e** **sters, ethers, or ketones having an olefinic or cyc lo-olefinic type of unsaturation: 5 percent; (2) A** **combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenze** **ne: 8 percent; (3) A combination of ethylbenzene, k etones having branched hydrocarbon structures, tric** **hloroethylene or toluene: 20 percent. (4) Any aggregate of (1), (2), or (3) above, provided t** **heir individual volume percentages are not exceeded : 20 percent. Whenever any organic solvent or any** **constituent of an organic solvent may be classified from its chemical structure into more th** **an one of the above groups or organic compounds, it shall be considered as a member of the most reacti** **ve chemical group that is, that group having the least allowable percentage of the total volume** **of solvents.**Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-18**Operation MaterialVOClimitationCompliance Requirements CitationSan Joaquin Valley Unified Air Pollution Control District**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized in** **the presence of O 2** **15 lb/ day (emissions** **from air or heat drying for** **the first 12 hours must be** **included) Photochemically** **g reactive solvent** **(except solvents that are baked,** **heat cured or heat** **polymerized) 40 lb/day** **(emissions from air or** **heat drying for the first 12** **hours must be included)** **Organic solvents or** **solvent containing** **materials Non** **photochemically reactive solvent** **(except solvents that are baked,** **heat cured or heat** **polymerized) 3,000 lb/day** **(emissions from air or** **heat drying for the first 12** **hours must be included)** **1. Reduce VOC emissions by 85% overall using an incine** **rator (incinerator must have an emission reduction of 90%** **or more); or adsorption, or another approved method of control.** **2. Emissions from cleanup with solvents must be includ** **ed in compliance determination** **3. All solvents must be stored in non-absorbent, non-l** **eaking containers which must be kept closed at all times, except when** **filling or emptying. Cloth and paper containing laden with solvents shou** **ld be stored in closed, non-absorbent, non-leaking containers.** Exemptions:**(1) transport of storage of organic containing ma terials; (2)** **the volatile content of materials consists of only water and non** **photochemically reactive organic solvents containin g less than 20% by** **volume of VOC and does not come into contact with a flame; (3) use,** **application, evaporation, or drying halogenated hyd rocarbons or** **perchloroethylene; (4) solvents containing less tha n 50 grams of VOC/liter** **of material.; (5) operation that uses 55 gallons or less of organic solvents on** **a 365-day rolling average. SJVUAPCD Rule 4661** **and 4663 g** **A photochemically reactive solvent is any solvent w ith an aggregate of more than 20 percent of its tot** **al volume composed of the following chemicals or wh ich exceeds ay of the following individual** **percentage composition limitations, referred to by the total volume of solvent: (1) A combination of h** **ydrocarbons, alcohols, aldehydes, esters, ethers, o r ketons having an olefinic or cyclo-olefinic type** **of unsaturation: 5 percent; (2) A combination of ar omatic compounds with eight or more carbon atoms to** **the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketons** **having branched hydrocarbon structures, trichloroet hylene or toluene: 20 percent. Whenever any organi** **c solvent or any constituent of an organic solvent may be classified from its chemical structure** **into more than one of the above groups or organic c ompounds, it shall be considered as a member of the** **most reactive chemical group that is, that group h aving the least allowable percentage of the** **total volume of solvents.**Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-19**Operation MaterialVOClimitationCompliance Requirements Citation**Solvent cleaning materials** **(excluding hand wiping)** **Content limit of 550 g/l** **(4.6 g/gal) and VOC** **composite partial pressure** **of 35 mm Hg @20** **o C (68** **o F)** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-20**Operation MaterialVOClimitationCompliance Requirements CitationSan Luis Obispo County Air Pollution Control District**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized in** **the presence of O 2** **15 lb/day and 3 lb/hr** **Photochemically h** **reactive solvent (except solvents** **that are baked, heat cured or** **heat polymerized)** **40 lb/day and 8 lb/hr** **(emissions from air or** **heat drying for the first 12** **hours must be included)** **Organic solvents or** **solvent containing** **materials Non** **photochemically reactive solvent** **(except solvents that are baked,** **heat cured or heat** **polymerized) 3,000 lb/day** **and 450 lb/hr (emissions** **from air or heat drying for** **the first 12 hours must be** **included) 1.** **Reduce VOC emissions by 85% using an incinerator (t he incinerator** **must have an emission reduction of 90%); or adsorpt ion, or another** **approved method of control. 2.** **Include emissions from the cleanup with photochemic ally reactive** **solvents in compliance determination**Exemptions:**(1) transport of storage of organic containing ma terials;** **(2) the volatile content of materials consists of o nly water and non** **photochemically reactive organic solvents containin g less than 20% by** **volume of VOC and does not come into contact with a flame; (3) use,** **application, evaporation, or drying halogenated hyd rocarbons or** **perchloroethylene. SLOCAPCD Rule 407** **h A photochemically reactive solvent is any solvent w** **ith an aggregate of more than 20 percent of its tot al volume composed of the following chemicals or wh** **ich exceeds ay of the following individual percentage composition limitations, referred to by** **the total volume of solvent: (1) A combination of h ydrocarbons, alcohols, aldehydes, esters, ethers, o** **r ketons having an olefinic or cyclo-olefinic type of unsaturation: 5 percent; (2) A combination of ar** **omatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A** **combination of ethylbenzene, ketons having branched hydrocarbon structures, trichloroet** **hylene or toluene: 20 percent. Whenever any organi c solvent or any constituent of an organic solvent** **may be classified from its chemical structure into more than one of the above groups or organic c** **ompounds, it shall be considered as a member of the most reactive chemical group that is, that group h** **aving the least allowable percentage of the total volume of solvents.** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-21**Operation MaterialVOClimitationCompliance Requirements CitationSanta Barbara County Air Pollution Control District**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized in** **the presence of O 2** **15 lb/day and 3 lb/hr** **Photochemically i** **reactive solvent (except solvents** **that are baked, heat cured or** **heat polymerized)** **40 lb/day and 8 lb/hr** **(emissions from air or** **heat drying for the first 12** **hours must be included)** **Organic solvents or** **solvent containing** **materials Non** **photochemically reactive solvent** **(except solvents that are baked,** **heat cured or heat** **polymerized) 3,000 lb/day** **and 450 lb/hr (emissions** **from air or heat drying for** **the first 12 hours must be** **included) 1.** **Reduce VOC emissions by 85% using an incinerator (t he incinerator** **must have an emission reduction of 90%); or adsorpt ion, or another** **approved method of control. 2.** **Include emissions from the cleanup with photochemic ally reactive** **solvents in compliance determination**Exemptions:**(1) transport of storage of organic containing ma terials;** **(2) the volatile content of materials consists of o nly water and non** **photochemically reactive organic solvents containin g less than 20% by** **volume of VOC and does not come into contact with a flame; (3) use,** **application, evaporation, or drying halogenated hyd rocarbons or** **perchloroethylene. SBAPCD Rule 317** **i A photochemically reactive solvent is any solvent w** **ith an aggregate of more than 20 percent of its tot al volume composed of the following chemicals or wh** **ich exceeds ay of the following individual percentage composition limitations, referred to by** **the total volume of solvent: (1) A combination of h ydrocarbons, alcohols, aldehydes, esters, ethers, o** **r ketons having an olefinic or cyclo-olefinic type of unsaturation: 5 percent; (2) A combination of ar** **omatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A** **combination of ethylbenzene, ketons having branched hydrocarbon structures, trichloroet** **hylene or toluene: 20 percent. Whenever any organi c solvent or any constituent of an organic solvent** **may be classified from its chemical structure into more than one of the above groups or organic c** **ompounds, it shall be considered as a member of the most reactive chemical group that is, that group h** **aving the least allowable percentage of the total volume of solvents.** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-22**Operation MaterialVOClimitationCompliance Requirements CitationShasta County Air Quality Management District**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized in** **the presence of O 2** **at temperatures above 400** **o F** **15 lb/day Photochemically** **j reactive solvent** **(except solvents that are baked,** **heat cured or heat** **polymerized) 40 lb/day** **Organic solvents or** **solvent containing** **materials Any** **photochemically reactive substance** **40 lb/day 1.** **Reduce VOC emissions by 85% 2.** **Include emissions from the cleanup with photochemic ally reactive** **solvents in compliance determination**Exemptions:**(1) use, application, evaporation, or drying halo genated** **hydrocarbons or perchloroethylene. SHAAQMD Rule 3:4** **j A photochemically reactive solvent is any solvent w** **ith an aggregate of more than 20 percent of its tot al volume composed of the following chemicals or wh** **ich exceeds ay of the following individual percentage composition limitations, referred to by** **the total volume of solvent: (1) A combination of h ydrocarbons, alcohols, aldehydes, esters, ethers, o** **r ketons having an olefinic or cyclo-olefinic type of unsaturation: 5 percent; (2) A combination of ar** **omatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A** **combination of ethylbenzene, ketons having branched hydrocarbon structures, trichloroet** **hylene or toluene: 20 percent. Whenever any organi c solvent or any constituent of an organic solvent** **may be classified from its chemical structure into more than one of the above groups or organic c** **ompounds, it shall be considered as a member of the most reactive chemical group that is, that group h** **aving the least allowable percentage of the total volume of solvents.** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-23**Operation MaterialVOClimitationCompliance Requirements CitationSouth Coast Air Quality Management District**Coating lines Content limit of 265 g/l as** **applied (excluding** **water and exempt** **compounds) Plastisol Content limit** **of 20 g/l as applied (except** **water and exempt** **compounds) Paper, Film** **and Fabric Wash primer Content limit** **of 265 g/l material used** **1. Use compliant materials ; or use an collection syst** **em that has a capture efficiency of at least 90 % by weight and the contr** **ol device has an emission reduction efficiency of 95 % by weight or** **to an outlet concentration of 50 ppmv (as carbon)** **2. Coatings must be applied using hand application met** **hods; HVLP spray (air dried coatings only); or one of the following** **coaters: flow, roll, dip, foam, and die. Alternative coating methods must be** **approved. 3.** **Containers and mixing tanks must be free from leaks and covered** **except when adding or removing materials, cleaning or when the** **container is empty. 4.** **Solvent cleaning must use one of the following: wip e cleaning; closed** **containers or hand held spray bottles w/out propell ant-induced force;** **cleaning equipment which has a solvent container th at is closed at all** **times (except when adding or removing parts or duri ng repair); remote** **reservoir cleaner; non-atomized solvent flow where solvent is collected** **in a container or collection system that is closed at all times except for** **solvent collection and pressure relief (as needed) openings; and solvent** **flushing methods where solvent is collected in a co ntainer or collection** **system that is closed at all times except for solve nt collection and** **pressure relief (as needed) openings (discharged so lvent must be** **collected into containers without atomizing into th e air and solvent may** **be flushed through the system by air or hydraulic p ressure or by** **pumping). 5.** **All VOC-containing solvents must be stored in non-a bsorbent, non** **SCAQMD Rule 1128 and 1171** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-24**Operation MaterialVOClimitationCompliance Requirements Citation**Cleaning materials** **Content limit of 25 g/l (or** **0.21 lb/gal) leaking containers which must be kept closed at all** **times, except when filling or emptying. Cloth and paper containing wi** **th VOC-laden solvents should be stored in closed, non-absorbent,** **non-leaking containers.** **6. Use closed containers for disposal of cloth or pape** **r used in stripping cured coatings that are impregnated with solvent co** **ntaining VOC**Exemption:**Any application process that has VOC emissions less than** **14.3 lb (6.5 kg) per day**Tehama County Air Pollution Control District**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized in** **the presence of O 2** **at temperatures above 400** **o F** **15 lb/day Organic** **solvents or solvent** **containing materials** **Photochemically k** **reactive solvent (except solvents** **that are baked, heat cured or** **heat polymerized)** **40 lb/day 1.** **Reduce VOC emissions by 85% 2.** **Include emissions from the cleanup with photochemic ally reactive** **solvents in compliance determination**Exemptions:**(1) use, application, evaporation, or drying halo genated** **hydrocarbons or perchloroethylene. TCAPCD Rule 4:22** **k A photochemically reactive solvent is any solvent w** **ith an aggregate of more than 20 percent of its tot al volume composed of the following chemicals or wh** **ich exceeds ay of the following individual percentage composition limitations, referred to by** **the total volume of solvent: (1) A combination of h ydrocarbons, alcohols, aldehydes, esters, ethers, o** **r ketons having an olefinic or cyclo-olefinic type of unsaturation: 5 percent; (2) A combination of ar** **omatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A** **combination of ethylbenzene, ketons having branched hydrocarbon structures, trichloroet** **hylene or toluene: 20 percent. Whenever any organi c solvent or any constituent of an organic solvent** **may be classified from its chemical structure into more than one of the above groups or organic c** **ompounds, it shall be considered as a member of the most reactive chemical group that is, that group h** **aving the least allowable percentage of the total volume of solvents.** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-25**Operation MaterialVOClimitationCompliance Requirements Citation**Any photochemically** **reactive substance 40 lb/day** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-26**Operation MaterialVOClimitationCompliance Requirements CitationVentura County Air Pollution Control District**Coating materials Content limit of 265 g/l, as** **applied (excluding** **water and exempt** **compounds) Reactive organic** **compound (ROC) emissions** **Emission limit of 120 g/l** **(1 lb/gal) as applied,** **excluding water and** **exempt compounds)** **Paper, Fabric, and Film** **Cleanup solvents 200 g ROC/l material used** **1. Use compliant materials or reduce emissions by a co** **mbined capture and destruction efficiency of 90%, on a 24-hr rolli** **ng average or if the coating applied contains more than 1,200 g/l or ROC** **as applied (excluding water and exempt solvents), limit ROC em** **issions to 120 g/l as applied (excluding water and exempt solvents) on** **a 24-hr average. 2.** **All containers and mixing equipment containing ROC material must** **not leak and must be covered when in use, except fo r when adding or** **removing materials.**Exemptions:**. ROC emission limits do not apply during the firs t 24 hours** **of a scheduled carbon adsorption system startup. VCAPCD Rule 74.3** Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-27**Operation MaterialVOClimitationCompliance Requirements CitationYolo-Solano Air Quality Management District**Any that come into contact with** **a flame, or are baked, heat cured,** **or heat polymerized in** **the presence of O 2** **15 lb/day and 3 lb/hr** **Photochemically l** **reactive solvent (except solvents** **that are baked, heat cured or** **heat polymerized)** **40 lb/day and 8 lb/hr** **(emissions from air or** **heat drying for the first 12** **hours must be included)** **Organic solvents or** **solvent containing** **materials Non** **photochemically reactive solvent** **(except solvents that are baked,** **heat cured or heat** **polymerized) 3,000 lb/day** **and 450 lb/hr (emissions** **from air or heat drying for** **the first 12 hours must be** **included) 1.** **Reduce VOC emissions by 85% 2.** **Include emissions from the cleanup with photochemic ally reactive** **solvents in compliance determination 3.** **Do not dispose or allow the release of photochemica lly reactive** **solvents more than 1.5 gal of liquid (or equivalent amount of vapor).** Exemptions:**(1) transport of storage of organic containing ma terials;** **(2) the volatile content of materials consists of o nly water and non** **photochemically reactive organic solvents containin g less than 20% by** **volume of VOC and does not come into contact with a flame; (3) use,** **application, evaporation, or drying saturated halog enated organic solvents** **or perchloroethylene. l** **A photochemically reactive solvent is any solvent w ith an aggregate of more than 20 percent of its tot** **al volume composed of the following chemicals or wh ich exceeds ay of the following individual** **percentage composition limitations, referred to by the total volume of solvent: (1) A combination of h** **ydrocarbons, alcohols, aldehydes, esters, ethers, o r ketons having an olefinic or cyclo-olefinic type** **of unsaturation: 5 percent; (2) A combination of ar omatic compounds with eight or more carbon atoms to** **the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketons** **having branched hydrocarbon structures, trichloroet hylene or toluene: 20 percent. Whenever any organi** **c solvent or any constituent of an organic solvent may be classified from its chemical structure** **into more than one of the above groups or organic c ompounds, it shall be considered as a member of the** **most reactive chemical group that is, that group h aving the least allowable percentage of the** **total volume of solvents.**Appendix D: Summary of California Regulations forPaper, Film, and Foil Surface Coating Facilities (continued)**D-28**Operation MaterialVOClimitationCompliance Requirements Citation**Solvents used on substrates during** **the manufacturing process or for** **surface preparation** **200 g VOC/l material** **Solvents used for maintenance and** **repair 900 g VOC/l** **material and a composite** **partial pressure of 20 mm Hg** **or less at 20 o** **C (68** **o F)** **Solvents used for cleaning coatings** **or adhesives application** **equipment 950 g VOC/l** **material and a composite** **partial pressure of 35 mm Hg** **or less at 20 o** **C (68** **o F)** **Solvent Cleaners** **Solvents used for cleaning polyester** **resin application equipment** **200 g VOC/l material; or** **1,100 g VOC/l and composite** **partial pressure of 1.0 mm Hg** **or less at 20 o** **C (68** **o F) or** **solvent reclamation** **system 1.** **Use complaint cleaning materials AND Use one of the following** **cleaning devices or methods: Wipe cleaning; a.** **Spray bottles or containers with a maximum capacity of 16 fluid** **ounces without a propellant-induced force; b.** **Cleaning equipment which has a solvent container th at can be, and** **is, closed during cleaning operations, except when depositing and** **removing objects, and is closed during non-operatio n with the** **exception of maintenance and repair to the cleaning equipment** **itself; c.** **Cleaning device or mechanism which has been determi ned by the** **Air Pollution Control Officer to result in equivale nt or lower** **emissions; d.** **Remote reservoir cold cleaner used e.** **Non-atomized solvent flow method where the cleaning solvent is** **collected in a container or a collection system whi ch is closed** **except for solvent collection openings and, if nece ssary, openings** **to avoid excessive pressure build-up inside the con tainer; or** **f. Solvent flushing method where the cleaning solvent** **is discharged into a container which is closed except for solvent** **collection openings and, if necessary, openings to avoid exces** **sive pressure build-up inside the container. The discharged solve** **nt from the equipment must be collected into containers without** **atomizing into the open air. The solvent may be flushed throu** **gh the system by air or hydraulic pressure, or by pumping.** **2. Use a collection and control system that collects a** **t least 90 percent of the emissions and reduces VOC emissions by at least** **95 percent or has an outlet concentration less than 50 ppmw (as carbo** **n) YSAQMD 2.31,** **Section 300 United States** **Environmental Protection Agency** **Office of Air Quality Planning and Standards Air Quality Strategies and Standards Division** **Research Triangle Park, NC Publication No. EPA 453/R-07-003** **September 2007**