Control Techniques Guidelines for 

Paper, Film, and Foil Coatings 

 
This page intentionally left blank.
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 
This page intentionally left blank. 
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 Coatings.................................. 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 Recommendations or Regulations ........... 14 

1. The 1977 CTG .......................................................................................... 14 

2. The 1983 NSPS......................................................................................... 15 

3. The 2002 NESHAP................................................................................... 15 

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 Existing Stationary Sources - Volume II: 

Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty 

Trucks 

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

and Associated State or Local Requirements (Based on 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 
ii 

This page intentionally left blank. 
1 

I. Introduction

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

for nonattainment areas must include “reasonably available control measures” (RACM), 

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

182(b)(2)(A) provides that for certain nonattainment 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 capable 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 Register notices, EPA has addressed how 

states can meet the RACT requirements of the Act. 

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

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

consumer and commercial products in areas that violate 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 developing this CTG, EPA, among other things, 

evaluated the sources of VOC emissions from the paper, film, and foil coating industry and the 

available control approaches for addressing these emissions, including the costs of such 

approaches. Based on available information and data, EPA provides recommendations for 

RACT for paper, film, and foil coating. 

States can use the recommendations in this CTG to inform 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 air 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 in applicable sections of the CAA or EPA’s 

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

requirements on any entity. It provides only recommendations 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 approaches 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 may not apply to a particular situation based 

upon the circumstances of a specific source. Regardless 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 requirements of the CAA and EPA’s regulations. 

To the extent a State adopts any of the recommendations in this guidance into its State RACT 

rules, interested parties can raise questions and objections 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 approval process. 

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

and the date of attainment include the date by which 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 182(b)(2), States required to submit rules 

consistent with section 182(b) must submit their SIP 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 action 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 some or all segments of the paper, film, 

and foil surface coating industry. In May 1977, EPA 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 surface coating industry. 

Finally, in December 2002, EPA promulgated the National 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 industry, available control technologies for 

addressing such emissions, the costs of available control options, and other information. The 

1977 CTG recommends and the 1982 NSPS establishes VOC emission limits, whereas the 2002 

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

At least 44 State and local jurisdictions have specific regulations that control VOC 

emissions from paper, film, and foil surface coating operations (or segments of the paper, film, 

and foil surface coating industry). A discussion of the applicability and control options found in 

the federal actions and State and local rules is presented in Section V of this document. 

We developed the recommended approaches contained in this document after reviewing 

existing State and local VOC emission reduction approaches, the 1977 CTG, the 1983 NSPS, 

and the 2002 NESHAP, as well as information obtained 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 recommendations in this CTG could apply. Section IV 

describes the paper, film, and foil industry, including the types of paper, film, and foil products, 

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

sources of VOC emissions from these processes. Section V describes the available control 

approaches for addressing VOC emissions from this product category and summarizes Federal, 

State and local approaches for addressing such emissions. Section VI provides our 

recommendations for RACT for paper, film, and foil coating. Section VII discusses the costeffectiveness of the recommended control approaches. Section VIII contains a list of references. 

III. Applicability

 

 This CTG provides control recommendations for reducing VOC emissions stemming 

from the use of coatings in paper, film, and foil surface 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 explained above, this document is a guidance 

document and provides information for States to consider in determining RACT. When State 

and local pollution control agencies develop RACT rules, 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 control approaches for cleaning 

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

from all paper, film and foil coating operations, including 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 facilities that emit below this level 

because of the very small VOC emission reductions that 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 level of solvent usage that could be expected even 

in facilities that use very low-solvent coatings, such 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 facilities in ozone nonattainment areas. For these 

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

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

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

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 potential to emit below this threshold because some 

of these coating lines cannot use low VOC content coatings 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 coating 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 with the option of using an enforceable limitation 

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

25 tpy potential to emit threshold. 

In addition, coating performed on or in-line with any offset lithographic, screen, 

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

not part of the paper, film, and foil coating category. 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 all paper, film and foil surface coating 

operations are greater than 15 lb/day before consideration 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 cleaning. 

In developing their RACT rules, State and local agencies 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 sources 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 (2002 NEI), we estimate that there are 

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

474 facilities are located in current ozone nonattainment 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 concerning the paper, film, and foil surface coating 

industry as a whole. 

 According to the 2002 NEI, paper, film, and foil surface coating facilities are located 

throughout the United States, with the Pacific Coast and the Northeastern States having the 

largest numbers of facilities. Appendix B shows that these facilities are distributed across 21 

States. Appendices C and D summarize the current State 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 Toxic Release Inventory (TRI) database for 12 

Standard Industrial Classification (SIC) codes identified for the paper and other web industry. 

We believe that the NEI data provides a more accurate 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 sectors: pressure sensitive tape and labels 

(including fabric coated for use in pressure sensitive tapes and labels); photographic film; 

industrial and decorative laminates; abrasive products (including fabric coated for use in abrasive 

products) and flexible packaging (including coating of non-woven polymer substrates for use in 

flexible packaging). The category also includes coatings applied during miscellaneous coating 

operations for several products including: corrugated and solid fiber boxes; die-cut paper 

paperboard, and cardboard; converted paper and paperboard not elsewhere classified; folding 

paperboard boxes, including sanitary boxes; manifold business forms and related products; 

plastic asceptic packaging; and carbon paper and inked ribbons. 

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

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

category. 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 rotogravure or flexographic printing presses used 

in the production of flexible packaging is addressed in the CTG for Flexible Package Printing 

(EPA 453/R-06-003, September 2006). The application of inks, coatings and adhesives on or inline with publication rotogravure printing presses is addressed in the CTG for Graphic Arts: 

Rotogravure and Flexography (EPA 450/2-78-033). The 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 Letterpress 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 continuous layer of coating material across essentially 

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

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

provide adhesion between two substrates for lamination. The web coating operations and 

emission control techniques do not vary significantly 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 area between two or more consecutive coating 

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

and one or more rewind/cutting stations. 

 There are several different types of coating applicators that may be used to apply 

coatings. The most common types of applicators include: 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 application 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 materials (or inks) are picked up in the recessed areas 

of the roll and transferred directly to the substrate. 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 the substrate, usually by 

means of three rollers--a metering roller, a backing 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 coating 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 applicator 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 coater (a discussion of extruders is provided further 

below). In a slot die coater, the coating is extruded 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 knife blade. A continuous sheet of substrate is 

drawn between the knife blade and the support roller. 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 to control the thickness of the coating. Some 

knife coaters use high velocity air as the knife blade; these are known as air-knife coaters. 

Knife coaters can apply solutions of much higher viscosity than roll coaters, thus less solvent is 

emitted per pound of coating applied. Knife coaters 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, however, usually operate at lower speeds than roll 

coaters and show a greater tendency to break the web.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 other 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 fluid 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. Flexography 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 used to control the 

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

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

coating off the substrate except for the portion which escapes through the spaces between the 

wires. Larger wire diameters result in larger spaces, and therefore heavier coatings.4 

 The dip and squeeze coater, also called a dip coater, impregnates or saturates 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 saturated 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 typical extrusion coater forms a plastic film or 

coating of the hot-melt type by forcing a molten polymer 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 polyethylene (LDPE). They account for a large 

portion of the coatings used in the printing product and packaging industry, divided about evenly 

between cartons/cardboard and flexible materials.4

 In calendering, a process similar to extrusion, material is pressed by a roller or between 

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

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

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

improve the flexibility of the coating/material. After mixing, the mixture is conveyed to the 

calender. In a typical four-roll calender, the molten 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 functions 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 remove coating residue or other unwanted materials 

from equipment related to coating operations, as well 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 foil 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 occur during coating application/flash-off, 

 

a

 In a previous notice, EPA identified specific categories, including paper, film and foil coating, the cleaning 

operations of which would not be covered by EPA’s 2006 CTG for industrial cleaning solvents (71 FR 44522, 

44540, October 5, 2006). In the notice, EPA expressed its intention to address cleaning operations associated with 

these categories in the CTGs for these specified categories if the Agency determines that a CTG is appropriate for 

the respective categories. 
8 

coating curing/drying, and cleaning. The coating applicator(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 web during the heating process in the dryers. 

The remaining VOC emissions are from cleaning operations. In most cases, VOC emissions 

from mixing, surface preparation, handling and storage of coatings and solvents, and 

waste/wastewater operations are small. The following discussion describes the two primary 

emission sources (coatings and cleaning materials).

1. Coatings 

 

 The VOC emissions from paper, film, and foil coatings occur during coating 

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

evaporates from the web into the coating application 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 type of coatings being used. 

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

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

regulation at the federal and State level, the industry 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, film, and foil surface coating industry include 

solvent-borne, waterborne, hot-melt adhesives and other 100 percent solids coatings, reactive, 

and radiation-cure coatings. 

 Solvent-borne coatings are widely used in the paper, film, and foil surface coating 

industry. The solvent content of the coating is highly 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 coaters, therefore could require a higher solvent 

content). For solvent-borne coatings, coating formulations 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 are typically applied at 60 to 90 percent solvent 

by weight and sometimes higher. The primary solvents in solvent-borne coatings include 

methanol, toluene, xylene, methyl ethyl ketone, acetone, 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 waterborne 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 contain waterborne coatings than when they 

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

or agglomeration of their solids. 
9 

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

laminations, extrusion coatings, extrusion laminations, and coal seal coatings contain very little 

or no solvent. Accordingly, these coatings emit very little VOC. 

 In a hot-melt adhesive application, the solid coating material is heated, delivered to the 

coater head in a molten state, and added onto the web by a heated gravure coater, a heated roll 

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

state. Hot-melt adhesives use less energy than waterborne or solvent-borne coating operation 

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

dangers because there are no volatile hydrocarbons.

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

Because the equipment for hot-melt adhesives is quite 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 adhesives 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 dirt accumulation. Cleaning the coater head is 

difficult and time consuming, making changes to coat a different substrate or use a different hotmelt adhesive on the same hot-melt adhesive line more difficult, and therefore reduces the 

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

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

coatings. The hot-melt adhesives are typically darker 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) reaction that forms other 

compounds. The resulting compounds are generally not 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 decorative and industrial laminates and abrasives. 

Reactive coatings include styrene formaldehyde, phenolic, melamine, and epoxy resins. 

 

Radiation-cure coatings (also called prepolymer coatings) are a special type 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 upon exposure to UV or EB radiation. UV-cured 

coatings require the addition of a photoinitiator to catalyze the polymerization reaction; EBcured coatings do not, because the highly excited electrons 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 emissions. 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 integration of ancillary operations (e.g., cutting, 

slitting, folding) into the production line. Because no drying ovens are used, both energy usage 
10 

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

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

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

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

other coatings, such as hot-melt coating. 

 

 Although industry generally perceives UV coating usage 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-cured coatings due to the above-mentioned 

benefits that can offset capital costs. Another industry 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 coating 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 viscosity radiation-cured coatings can be problematic; 

although this factor is less important in the application to web substrates than other substrates 

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

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

of cleaning solvents and the radiation-cured coatings increases dramatically the level of irritation 

to the skin. 

2. Cleaning Materials 

 Cleaning materials are another source of VOC emitted 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 individual solvents. Cleaning materials are used to 

wash the coating applicators and outsides of the coating 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 sources of VOC emissions from paper, film, 

and foil surface coating operations: (1) evaporation 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 and regulatory approaches. 
11 

A. Available Controls for VOC Emissions from Coatings

Common control techniques for reducing VOC emissions from paper, film, and foil 

surface coatings include pollution prevention measures and the operation of emission capture and 

add-on control systems. Provided below is a summary of these control techniques. 

1. Pollution Prevention Measures 

 Product substitution/reformulation is commonly used as a pollution prevention measure 

in the paper, film, and foil surface coating industry 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 emissions by reducing or 

eliminating the organic solvent present in the coating. As previously discussed, these coatings 

include waterborne, hot-melt, reactive and radiation-cure coatings. Coating manufacturers have 

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

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

number of applications. Conversion to these coatings can lower VOC emissions greatly, and 

most paper, film, and foil surface coating operations 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 of 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 emissions from paper, film and foil surface 

coating operations can be reduced by the use of capture 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, collect 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 control 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 used 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 several captured VOC-laden streams and duct 

them to a single control device. 

 The most common types of capture systems used by the 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 Surface Coating

 Add-on control devices reduce the amount of VOC emissions 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 paper, film, and foil industry: combustion 

(thermal or catalytic oxidation) and recovery (adsorption 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 coating 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 paper, film, and foil surface coating industry. 

These alternative control technologies are also discussed below. 

Oxidation destroys VOC emissions in an exhaust stream by exposing the stream to an 

oxidizing atmosphere at high temperatures. Oxidizers 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 reaction. As a result, catalytic oxidizers operate at a

lower combustion temperature relative to that required 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 concentrations 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, such 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 typical 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 the carbon. Adsorber beds are typically 

operated in parallel to avoid interruption of VOC control. 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 regenerated and can be put into service again. 

 Carbon adsorption systems can achieve control device efficiencies greater than 95 

percent.6 In contrast to combustion, carbon adsorption does not destroy the VOC it removes 

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

regenerated, usually by passing steam through the carbon beds.7

 The VOC are removed from the 

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

and the VOC solvent is separated from the water. The recovered solvent can then be decanted 

for sale or reuse. Regeneration can also be achieved with hot air. Hot-air regeneration can be 
13 

quite attractive when dealing with water soluble solvents.7 Carbon adsorption is most easily 

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

they usually are distilled for reuse.8

 There are two options for disposing recovered solvents that cannot be reused. The first is 

to sell the material back to the solvent supplier or 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. Carbon adsorption is generally economically 

attractive only if the recovered solvent can be reused directly.7

 Carbon adsorbers are most suitable for solvents that are immiscible with water, such as 

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

ketone and methyl isobutyl ketone. In the case where 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 substances in the inlet air stream to a 

carbon adsorber may require pretreatment of the inlet 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 volatile VOC require lower temperatures for 

condensation. Therefore, refrigeration is often necessary 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 surface and contact condensers. In 

surface condensers, the coolant does not contact the 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 necessary 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 coating 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 control technique for reducing VOC 

emissions from cleaning materials. The pollution prevention measures applicable to the paper, 

film, and foil surface coating industry include product substitution/reformulation and work 

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

vapor pressure may be used to reduce or eliminate VOC emissions from using these materials. 

Work practice procedures may also reduce VOC emissions during cleaning operations by 

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

 No add-on control technologies are being used specifically for reducing VOC emissions 

from cleaning operations associated with paper, film, 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 thermal oxidizer. Further, there are controlled 

cleaning operations where cleaning is automated, enclosed, and vented to a control device. 

1. Product Substitution/Reformulation 

 Reducing the composite vapor pressure or VOC content of the cleaning material used, 

either by substitution or reformulation, is one pollution prevention measure that is used to reduce 

VOC emissions from cleaning operations. However, little information is available regarding the 

types of low-VOC or VOC-free cleaning materials that 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 materials 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 also typical in the industry. 

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

 The following discussion is a summary of EPA actions, 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 provisions. 

1. The 1977 CTG 

 The 1977 CTG recommended limiting VOC emissions from 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 the drying oven. Cleaning materials were not 

addressed in the 1977 CTG. 
15 

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

coating, excluding water and exempt compounds, as applied. This recommended limit was 

based on the use of conventional solvent-borne coatings 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 operations were presented in A Guideline for 

Surface Coating Calculations” (EPA-340/1-86-016).11 For paper coating , the 1977 CTGequivalent limit was 0.58 kg/l (4.8 lb/gal) of solids 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 calculating the limits recommended in the 1977 

CTG. 

2. The 1983 NSPS 

 In 1983, EPA promulgated new source performance standards for pressure sensitive tape 

and label surface coating operations (1983 NSPS), 40 CFR 60, subpart RR. The 1983 NSPS 

only applies to pressure sensitive tape and label surface 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 limit of 0.20 kg VOC/kg (0.20 lb VOC/lb) solids 

applied, based on a VOC emission reduction of 90 percent. 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 NSPS emission limit (other requirements such as 

recordkeeping and reporting do apply). Cleaning materials were not addressed in the 1983 

NSPS. 

3. The 2002 NESHAP 

 In 2002, EPA promulgated the National Emission Standards for Hazardous Air 

Pollutants: Paper and Other Web Coating (2002 NESHAP), 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, including VOC HAP emissions, from all web 

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

and any associated curing and/or drying equipment between 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 September 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 on 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 applied; or (3) no more than 0.20 kg/kg (0.20 lb/lb) 

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

98 percent and are expressed as follows: (1) no more 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 demonstrated by any of the following 

methods: (1) all coatings purchased have organic HAP contents that individually meet the 

organic HAP emission limit; (2) all coatings applied have organic HAP contents that individually 

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

equivalent allowable organic HAP (which is a facility-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 capture 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 general surface coating rules; many are specific 

to the paper, film, and foil surface coating industry and cover the coating line. Generally, the 

State and local regulations allow compliance with their requirements to be demonstrated using 

low-VOC coating or add-on control devices in conjunction 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 recommended VOC emission limits in the 1977 

CTG. However, there are fourteen jurisdictions that have more stringent requirements than the 

1977 CTG. These jurisdictions allow compliance either using compliant coatings, or by using an 

add-on control system. Seven jurisdictions have VOC emission limits that are more stringent 

than the 1977 CTG, five in California and two in Illinois. The California jurisdictions limit VOC 

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

The two jurisdictions in Illinois limit VOC emissions 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 efficiency, ranges from 55 percent to 90 

percent. Specifically, the San Diego County Air Pollution Control District (San Diego) and the 

Ventura County Air Pollution Control District (Ventura) 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 limit. The 95-percent overall control efficiency 

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

100 percent capture efficiency. 

 

 Several jurisdictions in California have requirements 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 materials by combining work practice 

standards with limits on the VOC content or composite vapor pressure of the solvent being used. 

In some cases, the jurisdictions allow the use of add-on controls as an alternative to the VOC 
17 

content/vapor pressure limits. The different air pollution control authorities in California have 

established similar work practice standards. However, the cleaning material VOC content/vapor 

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

controls are used as an alternative. 

 There are 10 States that have cleaning material regulations that apply to paper, film, and 

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

of cleaning materials. Instead, they have established equipment standards, work practices, and/or 

recordkeeping requirements. There is one State that 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, the 2002 NESHAP, and the current 

State and local requirements discussed above, we recommend 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 discussion 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, protective, or functional purposes. Such materials 

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

coatings, wax laminations, extrusion coatings, extrusion laminations, 100 percent solid 

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

coatings. Materials used to form unsupported substrates, such as calendaring of vinyl, blown 

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

 To control VOC emissions from coatings used in paper, film and foil surface coating, we 

recommend an overall VOC control efficiency of 90 percent 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 individual 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 coating facilities with the option of using an 

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

coating line below this 25 tpy potential to emit threshold. 

 

We recommend an overall VOC control efficiency of 90 percent as RACT for each 

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

the San Diego and Ventura levels of control, as well as the 1983 NSPS. The San Diego and 

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

system must achieve 90 percent overall emission reduction. We are not recommending the 95-
18 

percent overall emission reduction in the 2002 NESHAP 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 conjunction 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 to 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 (organic HAP for the NESHAP and VOC for this 

CTG), used to develop similar limits in the 2002 NESHAP. Using this baseline coating content, 

the VOC content-based emission limits equivalent to 90-percent emission reduction are 0.40 kg 

VOC/kg (0.40 lb VOC/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 (0.067 lb VOC/lb) of coating as RACT for 

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

recommended RACT limits for the paper, film, and foil 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 across multiple lines) to meet the VOC content 

limits. However, we have previously provided guidance on cross-line averaging.12 The 
19 

guidance is directed to State and local agencies that elect to adopt a discretionary economic 

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

B. Cleaning Materials

For cleaning materials, we are recommending work practices to reduce VOC emissions. 

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

alternative for reducing VOC emissions from cleaning 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 cleaning activities that occur within a capture 

device would be controlled by the associated control device. We are also not recommending the 

use of a VOC content or VOC composite vapor pressure 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 cleaning materials used in paper, film, and foil 

surface coating operations. 

 To control VOC emissions from cleaning materials used 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 noted above. We recommend that facilities 

implement work practices to ensure that VOC emissions are minimized from mixing, storage, 

and handling of cleaning materials, and cleaning-related waste materials. Specifically, we 

recommend the following: (1) store all VOC-containing 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 these materials; (3) minimize spills of VOCcontaining cleaning materials; (4) convey VOC-containing cleaning materials from one location 

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

storage, mixing, and conveying equipment. 

VII. Cost Effectiveness of Recommended Control Options

We estimated the cost effectiveness of our recommendations 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 cost 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 applicators and any associated drying/curing 

equipment between the unwind/feed station and the rewind/cutting station). In addition, both the 

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

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

combination of these two options). Finally, the 2002 NESHAP cost data is the most recent 

available. 

To develop emission and cost impacts for the 2002 NESHAP, EPA conducted a model 

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

processes, the emission reduction capabilities of various control options, and the costs of such 

controls. The model plants were developed to represent a range of sizes and emissions. Table 2 
20 

presents a summary of the model plant characteristics, the approach for complying with the 

requirements of the 2002 NESHAP, the HAP emission reduction associated with compliance, 

and the associated capital and annual cost estimates. 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 oxidizers was chosen because this option 

was expected to be the worst-case for costs. All other 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 there are a total of 474 paper, film, and 

foil surface coating facilities located in ozone nonattainment areas (using April 2004 

designations). As previously mentioned, we are recommending 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 greater, prior to the consideration of controls. 

Based on VOC emissions data in the 2002 NEI database, 251 of the facilities in ozone 

nonattainment areas have individual coating lines that have the potential to emit VOC at or 

above this level. 

To estimate the costs associated with the add-on control recommendation in this CTG, we 

assumed that 47 percent of the facilities in the 2002 NEI database (119 facilities) are currently 

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

emission reduction, which also achieves a 95-percent VOC emission reduction and is higher than 

the recommended 90-percent emission reduction, we assume that facilities already in compliance 

with the 2002 NESHAP would not be required to upgrade 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 that since the facilities represented by Model 

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

would not be required to upgrade the thermal oxidizer. 

Using the 2002 NEI, we found that 57 of the remaining 132 facilities reported the use of 

control devices. Therefore, we removed 57 facilities 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 coating lines with the potential to emit of 25 tpy 

VOC or greater, prior to the consideration of controls. 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 estimate the aggregate VOC 

emission reduction. Table 3 presents the nationwide emission estimates using the model plant 

approach. As shown in Table 3, we estimate that VOC 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 of 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 estimates for the paper, film, and foil surface coating 

industry. 

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

savings. Implementing work practices reduces the amount 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, Automobiles, And Light Duty Trucks, 

EPA-450/2-77-008, U. S. Environmental Protection Agency, 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 Emission Standards for Hazardous Air 

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

2002. 

4. National Emission Standards for Hazardous Air Pollutants for Source Categories: 

Paper and Other Web Coating Operations -- Background 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 NESHAP survey. 

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

U.S. Environmental Protection Agency, Cincinnati, Ohio. June 1991. 

7. Pressure Sensitive Tape and Label Surface Coating Industry--Background Information 

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

Research Triangle Park, North Carolina. September 1980. pp. 3-14 to 3-15. 

8. Compilation of Air Pollutant Emission Factors (AP-42), 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 Carolina. January 1990. 
22 

10. Telecommunication. Sutton, L., EC/R Inc., Durham, North Carolina, with T. Godonis, 

American Biltrite, Inc., Moorestown, New Jersey. March 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 Programs. U.S. Environmental 

Protection Agency. Research Triangle Park, NC. EPA-452/R-01-001. January 2001.
23 

Table 2. Specifications for Model Plants Developed for the 2002 NESHAP4

Model 

Plant 

No. 

Percent of 

Database 

Major 

Sources 

Overall 

HAP 

Control 

Efficiency 

(%) 

Approach for 

Capture and 

Controla

Average 

Number 

of 

Coating 

Lines 

Average 

Number 

of 

Coating 

Stations 

Coating 

Use 

(tpy) 

Uncontrolled 

Coating Line 

HAP 

Emissions 

(tpy) 

HAP 

Emission 

Reduction 

(tpy) 

Tot

C

Co

1a 20 0 PTE and new control device 2 5 2,108 99 94 2,

1b 3 0 PTE and new control device 12 9 7,521 1,765 1,677 6,

1cc,d 10 0 No change 

2a 25 50 PTE and increase T.O. efficiency 5 11 8,607 276 124 5

2b 1 50 PTE 31 154 369,929 2,522 1,135 1,

3a 11 80 PTE and increase T.O. efficiency 3 8 7,518 915 137 4

3b 1 80 PTE 8 15 14,516 6,890 1,034 2

4d 24 90 No change 5d 5 95 No change 

a PTE = permanent total enclosure; T.O. = thermal oxidizer b Costs developed in 1998 dollars. c Although a control efficiency of zero is stated, this model plant is assumed to be using compliant coatings. d These model plants were not included in the analysis because they are assumed to be already in operating at the CTG's recommended 
24 

Table 3. Annual Cost Estimates for Paper, Film, and Foil Surface Coating Industry 

1998 

Dollars 

200

Model 

Plant 

(a) 

Model 

Plant VOC 

Emissions 

(tpy) (b) 

Percent of 

Facilities 

Requiring 

Additional 

Control 

Control Approach 

for Complying with 

Draft CTG 

Recommendations 

Model 

Plant Total 

Annual 

Cost ($/yr) 

Number of 

Facilities 

Impacted 

by CTG (c) 

Total VOC 

Emissions in 

Ozone 

Nonattaiment 

Areas (tpy) 

Model 

Plant Total 

Annual 

Cost ($/yr) 

Nati

T

Annu

($

1a 198 20% Install capture system 

and new T.O. 

$713,596 15 2,970 $857,781 $12,8

1b 3,530 3% Install capture system 

and new T.O. 

$1,923,790 2 7,943 $2,312,499 $5,2

1c 96 10% None $0 7 $0 2a 276 25% Install Capture system 

and Increase T.O. 

destruction efficiency 

$174,162 19 5,175 $209,352 $3,9

2b 2,522 1% Install capture system $873,287 1 1,892 $1,049,738 $78

3a 366 11% Install capture system 

and Increase T.O. 

destruction efficiency 

$161,250 8 3,020 $193,831 $1,5

3b 2,756 1% Install capture system $120,638 1 2,067 $145,013 $10

4d 198 24% None $0 18 $0 

5e 80 5% None $0 4 $0 

75 23,066 $24,4

(a) Model plants were defined during the development of the POWC NESHAP (40 CFR 63, subpart JJJJ). (See 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 individual coating lines with the potential to emit at least 25 tons per yeto 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 plant category operate with an overall control efficiency of 90 percent, therefore, no upgrade in equipment would be nthe 90-percent recommended level of control in the draft CTG. (e) In the 2002 NESHAP, facilities in this model plant category operate with an overall control efficiency of 95 percent, therefore, no upgrade in equipment would be nthe 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, Coils, Paper, 

Fabrics, Automobiles, and Light-Duty Trucks
 

This page intentionally left blank. 
 

A-1 

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

Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, 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 Requirements 

(Based on 2002 NEI and December 2006 Nonattainment 

Designations) 
 

This page intentionally left blank.
B-1 

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

Requirements (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 Alternativ

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 captu

m

 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 c

or an in

e

 Cleaning Materials VOC emission limit of 

50 g VOC/l (0.42 lb/gal) 

Overall c

or use sp

Mojave Desert AQMD 1 Organic solvents or solventcontaining materials 1,190 lb VOC per month Overall c
Appendix B: Paper, Film, and Foil Surface Coating Facilities in Current Nonattainment Areas and Assoc

Requirements (Based on 2002 NEI and December 2006 Nonattainment Designations) (conti

B-2 

State or Local Jurisdiction 

Number of 

Facilities in 

Ozone 

Nonattainment 

Areas Product Applicability 

Applicable State Emission 

Limit Alternativ

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 c

 Organic solvents or solvent 

containing photochemically reactive 

solvent (except solvents that are 

baked, heat cured, or heatpolymerized) 

40 lb/day (emissions from air 

or heat drying for the first 12 

hours must be included) 

Overall c

 Organic solvents or solvent 

containing non-photochemically 

reactive solvent (except solvents that 

are baked, heat cured or heatpolymerized) 

3,000 lb/day (emissions from 

air or heat drying for the first 

12 hours must be included) 

Overall c

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 c

 Cleaning Materials VOC limits of 25 g/l 

(0.21 lb/gal) 

Use sp

Colorado 8 Paper, Fabric, Plastic-Film, and Vinyl 

Coating 

1977 CTG Limitsb Use captu

m

b 1977 CTG recommended limits: Paper Coating = 0.35 kg/l (2.9 lb/gal) coating, as applied (minus water and exempt compounds); Fab

(2.9 lb/gal) coating, as applied (minus water and exempt compounds); Vinyl Coating = 0.45 kg/l (3.8 lb/gal) coating, as applied (minus 

compounds). 
Appendix B: Paper, Film, and Foil Surface Coating Facilities in Current Nonattainment Areas and Assoc

Requirements (Based on 2002 NEI and December 2006 Nonattainment Designations) (conti

B-3 

State or Local Jurisdiction 

Number of 

Facilities in 

Ozone 

Nonattainment 

Areas Product Applicability 

Applicable State Emission 

Limit Alternativ

Connecticut 4 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Overall cDelaware 2 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Overall c Cleaning Materials Composite vapor pressure no 

more than 45 mmHg @ 

20oC; OR solvent must be at 

least 80% water 

Use wor

Georgia 5 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Overall cIllinois 29 Outside Chicago and Metro East Areas 

Unknownc Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Overall c

(contro

 Unknownc Paper coating 

Specialty High Gloss Catalyzed 

Coating 

3.5 lb VOC per gallon 

coating (except water) 

Overall c

(contro

Chicago and Metro East Areas 

 Paper, Fabric, and Vinyl Coating 2.3 lb VOC per gallon 

coating (except water) 

Overall c

(contro

Indiana 9 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Overal

67.5% (

Maine 1 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Overall cMaryland 5 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Use captu

m

Michigan 11 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Use captu

m

Missouri 3 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Use captu

m

New Jersey 27 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Contr

c The number of facilities located within the Illinois jurisdictions is unknown. 
Appendix B: Paper, Film, and Foil Surface Coating Facilities in Current Nonattainment Areas and Assoc

Requirements (Based on 2002 NEI and December 2006 Nonattainment Designations) (conti

B-4 

State or Local Jurisdiction 

Number of 

Facilities in 

Ozone 

Nonattainment 

Areas Product Applicability 

Applicable State Emission 

Limit Alternativ

New York 6 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Control em

 Cleaning Materials No numeric limit Use wor

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 Limitsb 

Pennsylvania 29 Paper and Fabric Coating 4.4 lb VOC per gallon 

coating solids 

Use captu

m

 Vinyl Coating 7.69 lb VOC per gallon 

coating solids 

Use captu

m

Rhode Island 1 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Contr Cleaning Material No numeric limit Keep recoSouth Carolina 4 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Control em Cleaning Material No numeric limit Keep recoTennessee 7 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Overall cVirginia 11 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Use captu

m

West Virginia 1 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Overall c Cleaning Materials 6.8 kg/day (15 lb/day) Use wor

emission

cleanup ac

is used 

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

Requirements (Based on 2002 NEI and December 2006 Nonattainment Designations) (conti

B-5 

State or Local Jurisdiction 

Number of 

Facilities in 

Ozone 

Nonattainment 

Areas Product Applicability 

Applicable State Emission 

Limit Alternativ

Wisconsin 7 Paper, Fabric, and Vinyl Coating 1977 CTG Limitsb Control em
B-6 

This page intentionally left blank.
Appendix C 

Summary of State-Specific Regulations for Paper, Film, and Foil 

Surface Coating Facilities (not including California) 
This page intentionally left blank.
C-1 

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

California) 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit1 Compliance Method 

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

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-2 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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. 

Alaska

a

Arizona POWC – Incorporated by Reference, Subpart JJJJ Arizona/Pima POWC – Incorporated by Reference, Subpart JJJJ Arizona/Pinal POWC – Incorporated by Reference, Subpart JJJJ 

a Alaska does not have applicable air regulations. No cleaning material regulations. 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-3 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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

oC Work practices to minimize emissions 

Arkansas

b

b Arkansas does not have applicable air regulations. No cleaning material regulations. 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-4 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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 lb/hr). 

No cleaning materials regulations 

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

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-5 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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 lb VOC/day 

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

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-6 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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/galcoating 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 within Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding, or Rockdale counties with actual VOC emissions are less than 15 lb/day; total use of coatings, inks and other VOC-containing materials is less than 55 gal/yr 

No cleaning material regulations. 

Hawaii

c

Idaho POWC – Incorporated by Reference, Subpart JJJJ

c Hawaii does not have applicable air regulations. No cleaning material regulations. 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-7 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

Fabric Coating 0.35 kg/l 

(3.8 lb/gal) 

Paper coatingSpecialty 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 the 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 to 

22.7 Mg/yr (25 tpy); or the total coating usage does not exceed 9,463 l/yr (2,500 gal/yr); or touch-up and repair coatings used by a vinyl if the source-wide volume is 

less than 0.95 l (1 quart) per eight-hour period orexceeds 209 l/yr (55 gal/yr) for any rolling twelve- month period. 

No cleaning material regulations. 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-8 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-9 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-10 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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 capture 

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, Porter, and St. Joseph Counties which have potential emissions less than 90.7 Mg/yr (100 tpy); Facilities constructed 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, Marion, 

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/day 

No cleaning material regulations. 

Iowa POWC – Incorporated by Reference, Subpart JJJJ Kansas

d

d Kansas has no applicable air regulations. No cleaning material regulations. 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-11 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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 based on maximum production and 8,760 hr/yr. Low use coating if plantwide consumption is less than or equal to 55 gal/previous 12 months 

No cleaning material regulations. 

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. 

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

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-12 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

Vinyl Coating 0.45 kg/l 

(3.8 lb/gal) 

Exemptions: maximum theoretical VOC emissions from all coating units, lines or operations under the same surface coating category less than 10 tpy. Or Coating units, lines or operations whose total actual 

coatings usage from all coating units, lines or operations under the same surface coating category is less than 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. 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-13 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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-monthrolling period and facilities with uncontrolled VOCemissions less than 15 lb/day Keep records of cleaning materials usage 

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/month and facilities may exclude low-use coatings that total 55 gallons or less per rolling 12-month period. 

No cleaning materials regulations 

Minnesota POWC – Incorporated by Reference, Subpart JJJJ Mississippi POWC – Incorporated by Reference, Subpart JJJJ 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-14 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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 with total uncontrolled potential VOC emissions is less than 6.8 kg/day (2.7 tpy). 

No cleaning material regulations.

Montana POWC – Incorporated by Reference, Subpart JJJJ 

Nebraska POWC – Incorporated by Reference, Subpart JJJJ 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. 

e Nevada has no air regulations applicable to the PFF industry. No cleaning material regulations. 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-15 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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 gallon 

per hour and 2 1⁄2 gallons per day No cleaning materials regulations. 

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. 

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 Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-16 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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. 

North Dakota

g

g North Dakota does not have applicable air regulations. 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-17 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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 with 

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 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 coating 

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

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-18 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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 with 

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 VOC. 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 coating 

lines 

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

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-19 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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 long 

as emissions are no more than they would be using compliant coatings, and at least 85% overall control efficiency 

Include VOC emissions from clean up in determining compliance 

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 MedfordAshland 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/day actual). Keep records of cleaning materials usage 

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 calendar year since January 1, 1987 

No cleaning material regulations. 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-20 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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. 

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 any one day (nominal size - 100 tons per year) or more than 

150 pounds (68 kilograms) in any one hour. Keep records of cleanup materials 

South Dakota POWC – Incorporated by Reference, Subpart JJJJ 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-21 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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 paper 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. Facilities in Hamilton or Shelby County with potential VOC emissions from all paper coating operations less than 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. 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-22 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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 less 

than 100 lb in any consecutive 24-hr period if documentation is received and approved that demonstrates that the performance criteria cannot be achieved with compliant coatings and control equipment is not technically or economically feasible. (3) a source with total coating and solvent usage is less than 150 gal in any consecutive 12-month period. (4) aerosol spray cans 

No cleaning material regulations. 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-23 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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. 

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

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-24 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

Vermont Paper Coating 2.9 lb/gal 

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 overall 

reduction efficiency is greater than or equal to the required reduction efficiency (an efficiency is notspecified). 

Exemptions: Paper coating sources that have actual uncontrolled VOC emissions less than 15 lb/day. Other 

VOC sources with allowable VOC emissions less than 50 tpy any year since 1/1/90. 

No cleaning material regulations. 

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

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-25 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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 kg 

(40 lb)/24-hr period. 

No cleaning material regulations. 

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 compoundsand to minimize their evaporation to the atmosphere. 
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilit

California) (continued) 

1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted. 

C-26 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit

1 Compliance Method 

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. 

Wyoming POWC – Incorporated by Reference, Subpart JJJJ 
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 for Paper, Film, and Foil Surface Coating F

Operation Material 

VOC 

limitation Compliance Requirements 

Antelope 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 control 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 must be applied 

using hand application methods; 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: wipe cleaning; closed 

containers or hand held spray bottles w/out propellant-induced force; cleaning equipment which has a solvent container that is closed at all times (except when adding or removing parts or during 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 container or collection 
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-2 

Operation Material 

VOC 

limitation Compliance Requirements 

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

oC (68

oF) 

system that is closed at all times except for solvent collection and 

pressure relief (as needed) openings (discharged solvent must be 

collected into containers without atomizing into the air and solvent may be flushed through the system by air or hydraulic pressure or by 

pumping). 

5. All VOC-containing solvents must be stored in non-absorbent, nonleaking containers which must be kept closed at all times, except when 

filling or emptying. Cloth and paper containing with VOC-laden solvents should be stored in closed, non-absorbent, non-leaking containers. 

6. Use closed containers for disposal of cloth or paper used in stripping 

cured coatings that are impregnated with solvent containing VOC 

Exemptions: operations using aerosol coating products, application of 

coatings to fine arts paintings, scenic or theatrical backgrounds for motion 

pictures, television, and theater. 
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-3 

Operation Material 

VOC 

limitation Compliance Requirements 

Bay 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 limit 

3. Keep all containers storing organic solvents or tanks for mixing 

coatings covered at all times except when material is being added or removed, when the tank or container is being cleaned, 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 surface 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 containers. 

Exemptions:. Operations that manufacture flexible packaging materials 

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). 
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-4 

Operation Material 

VOC 

limitation Compliance Requirements 

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 use an emission 

control system with an overall efficiency of 85% or 90% for an incinerator. 

2. For solvents used for surface preparation or cleanup must either use a 

control system with an overall control efficiency of 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 cleanup 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-atomizing container, and collected and stored in a closed container until recycled or 

properly disposed of offsite; or (b) a spray gun washer 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 exclusively 

El Dorado County Air Quality Management District 

Any that come into contact with a flame, or are 

baked, heat cured, 

or heatpolymerized in the presence of O2

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 process with BACT 

2. Do not dispose or allow the release of organic compounds 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 gal; (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 March 1, 1984. 
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-5 

Operation Material 

VOC 

limitation Compliance Requirements 

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

oC 

(68

oF) 

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

oC 

(68

oF) 

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

oC 

(68

oF) 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 that can be, and 

is, closed during cleaning operations, except when depositing and 

removing objects, and is closed during non-operation 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 which is closed except for solvent collection openings and, if necessary, openings 

to avoid excessive pressure build-up inside the container; 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 excessive pressure 

build-up inside the container. The discharged solvent from the 

equipment must be collected into containers without atomizing 

into the open air. The solvent may be flushed through the system 

by air or hydraulic pressure, or by pumping. 

2. Use a collection and control system that collects at 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 carbon) 
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-6 

Operation Material 

VOC 

limitation Compliance Requirements 

Great Basin Unified Air Pollution Control District 

Any that come into contact with a flame, or are 

baked, heat cured, 

or heatpolymerized in the presence of O2

15 lb/day and 

3 lb/hr 

Photochemically

a

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 

Nonphotochemically 

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 control. 

Exemptions: (1) transport of storage of organic containing materials; (2) 

the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing 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 water and nonphotochemically reactive organic solvents and more than 50% by volume of VOC is evaporated prior to entering a chamber heated 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-photochemically reactive organic solvents, and does not come into contact with a flame. 

a A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceed

percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketones having 

type of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A comb

having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classi

into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the leas

total volume of solvents.
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-7 

Operation Material 

VOC 

limitation Compliance Requirements 

Imperial County Air Pollution Control District 

Any that come into contact with a flame, or are 

baked, heat cured, 

or heatpolymerized in the presence of O2

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 heatpolymerized) 

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 reactive 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 reduction of 90% or 

more). 

Exemptions: (1) transport of storage of organic containing materials; and 

(2) the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing less than 20% by volume of VOC, and does not come into contact with a flame; and (3) use, application, evaporation, or drying halogenated hydrocarbons or 

perchloroethylene. 

b A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the chemical compounds classified belo

following individual percentage composition limitations, referred to the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, cyclo-olefinic type of unsaturation: 5 percent; (2) a combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percenethylbenzene, ketones having branched hydrocarbon structures, or toluene: 20 percent. 
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-8 

Operation Material 

VOC 

limitation Compliance Requirements 

Kern County Air Pollution Control District 

Any that come into contact with a flame, or are 

baked, heat cured, 

or heatpolymerized in the presence of O2

15 lb/day 

Photochemically

c

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

40 lb/day 

(emissions 

from air or 

heat drying for 

the first 12 

hours must be 

included) 

Organic solvents or solvent containing materials 

Nonphotochemically 

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 with an emission 

reduction of 90%; or adsorption, or another approved method of control. 

Exemptions: (1) transport of storage of organic containing materials; (2) 

the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing 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-photochemically reactive organic solvents and does not come into contact with a flame; and 

(4) use, application, evaporation, or drying halogenated hydrocarbons or 

perchloroethylene. 

c A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceed

percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having 

of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combinati

having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classi

into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the leas

total volume of solvents.
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-9 

Operation Material 

VOC 

limitation Compliance Requirements 

Mojave 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 reduces emissions by 

85% or more provided that capture system has a capture efficiency of 90% by weight and the control system has a destruction efficiency of 95% or more by weight or an output concentration of 50 ppm (as carbon) 

2. Non-VOC organic compounds 

a. include the drying period of 12 hrs after application 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 materials; (2) use 

of 1,1,1-trichloroethylene, methylene chloride, and trichlorofluoroethane; and (3) aerosol products 
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-10 

Operation Material 

VOC 

limitation Compliance Requirements 

Monterey Bay Unified Air Pollution Control District

Any that come into contact with a flame, or are 

baked, heat cured, 

or heatpolymerized at a temperature of 194

oF (90

oC) in 

the presence of O2

Organic 15 lb/day 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 O2

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 included in compliance 

determination 

2. Reduce VOC emissions by 85% or more using a capture and control 

system (an incinerator must have an emission reduction 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 emissions less than 15 lb/day (solvents that are baked, heat-cured, heat-polymerized or exposed to flame) or 40 lb/day (solvents that are not baked, heat-cured, heatpolymerized or exposed to flame) 
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-11 

Operation Material 

VOC 

limitation Compliance Requirements 

Placer County Air Pollution Control District 

Any that come into contact with a flame, or are 

baked, heat cured, 

or heatpolymerized in the presence of O2

15 lb/day and 

3 lb/hr 

Photochemically

d

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 

Nonphotochemically 

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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), adsorption, or another approved method of control. 

2. Do not dispose or allow the release of organic compounds from storage 

or transfer operations of more than 1.5 gal of liquid (or equivalent amount of vapor). 

3. Emissions from cleanup with solvents must be included in compliance 

determination 

Exemptions: (1) transport of storage of organic containing materials; (2) 

the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing 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-photochemically reactive organic solvents, and does not come into contact with a flame. 

d A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of chemicals compounds classified below o

following individual percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, eth

or cyclo-olefinic type of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 pe

ethylbenzene, ketones having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organiits chemical structure into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, thaallowable percentage of the total volume of solvents.
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-12 

Operation Material 

VOC 

limitation Compliance Requirements 

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. 

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

oC 

(68

oF) 

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

oC 

(68

oF) 

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 at 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 carbon) 
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-13 

Operation Material 

VOC 

limitation Compliance Requirements 

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

oC 

(68

oF) or 

solvent 

reclamation 

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

D-14 

Operation Material 

VOC 

limitation Compliance Requirements 

Sacramento Metropolitan Air Quality Management District 

Any that come into contact with a flame, or are 

baked, heat cured, 

or heatpolymerized in the presence of O2

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 heatpolymerized) 

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 

Nonphotochemically 

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 incinerator 

(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 included in compliance 

determination 

3. Do not dispose of 5 liters (1.3 gal) per day of photochemically reactive 

solvent or solvent containing materials such that they are emitted to the atmosphere. 

Exemptions: (1) transport of storage of organic containing materials; (2) 

the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing 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-photochemically reactive organic solvents and does not come into contact with a flame; and 

(4) use, application, evaporation, or drying halogenated hydrocarbons or 

perchloroethylene. 

e A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceed

percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having 

of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combinati

having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classi

into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the leas

total volume of solvents.
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-15 

Operation Material 

VOC 

limitation Compliance Requirements 

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 held spray 

bottles or containers without a propellant-induced force; 

c. Using cleaning equipment which has a solvent container that is 

closed during cleaning operations, except when depositing and removing objects, and is closed during non-operation with the exception of maintenance and repair to the cleaning equipment itself; 

d. Using a remote reservoir degreaser, non-vapor degreaser, or vapor 

degreaser used as required under Rule 454. 

e. Using 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 excessive 

pressure build-up inside the container. The discharged solvent 

from the equipment must be collected into containers without atomizing into the open air. The solvent may be flushed through the system by air or hydraulic pressure, or by pumping. 

2. Use a collection and control system that collects at 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 carbon) 
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-16 

Operation Material 

VOC 

limitation Compliance Requirements 

San 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 using a control 

system with a combined collection and abatement efficiency of 90% by weight or more; 

2. Containers and mixing tanks must be free from liquid 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 that totally encloses 

the component parts being cleaned during washing, rinsing, and draining or the cleaning 

4. Transfer the cleaning solvent through the application equipment, 

without exposure to air, into a container which has completely covers the container and has no visible holes, breaks, openings 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-114, or CFC115 

Exemption: Any application process that has VOC emissions less than 

14.3 lb (6.5 kg) per day 

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% overall over a 

calendar month or calculate a weighted average emission reduction 

Exemption: VOC input is less than 45 Mg (49.6 tons) of VOC per 12-

month period
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-17 

Operation Material 

VOC 

limitation Compliance Requirements 

Any that come into contact with a flame, or are 

baked, heat cured, 

or heatpolymerized in the presence of O2

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 heatpolymerized) 

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 

Nonphotochemically 

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 incinerator; or 

adsorption; or another approved method of control. 

2. Emissions from cleanup with solvents must be included in compliance 

determination 

3. Do not dispose of 5 liters (1.3 gal) per day of photochemically reactive 

solvent or solvent containing materials such that they are emitted to the atmosphere. 

Exemptions: (1) the organic solvent content of surface coating 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 exempt 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) and (4) any equipment, 

process or operation which has implemented BACT or LAER as a result of 

NSR 

f The compositional limitations of any organic solvent referred to are the volume percentages of the following photochemically reactive compounds, compared to the t

combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketones having an olefinic or cyclo-olefinic type of unsaturation: 5 percent; (2) A combination of a

more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketones having branched hydrocarbon structures, trichloroethyl

Any aggregate of (1), (2), or (3) above, provided their individual volume percentages are not exceeded: 20 percent. Whenever any organic solvent or any constituent of classified from its chemical structure into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical g

the least allowable percentage of the total volume of solvents.
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-18 

Operation Material 

VOC 

limitation Compliance Requirements 

San Joaquin Valley Unified Air Pollution Control District 

Any that come into contact with a flame, or are 

baked, heat cured, 

or heatpolymerized in the presence of O2

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 heatpolymerized) 

40 lb/day 

(emissions 

from air or 

heat drying for 

the first 12 

hours must be 

included) 

Organic solvents or solvent containing materials 

Nonphotochemically 

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 incinerator 

(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 included in compliance 

determination 

3. All solvents must be stored in non-absorbent, non-leaking containers 

which must be kept closed at all times, except when filling or emptying. Cloth and paper containing laden with solvents should be stored in 

closed, non-absorbent, non-leaking containers. 

Exemptions: (1) transport of storage of organic containing materials; (2) 

the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing less than 20% by volume of VOC and does not come into contact with a flame; (3) use, application, evaporation, or drying halogenated hydrocarbons or 

perchloroethylene; (4) solvents containing less than 50 grams of VOC/liter 

of material.; (5) operation that uses 55 gallons or less of organic solvents on a 365-day rolling average. 

g A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which excee

percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having 

of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combinati

having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classi

into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the leas

total volume of solvents.
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-19 

Operation Material 

VOC 

limitation Compliance Requirements 

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

oC (68

oF) 
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-20 

Operation Material 

VOC 

limitation Compliance Requirements 

San Luis Obispo County Air Pollution Control District 

Any that come into contact with a flame, or are 

baked, heat cured, 

or heatpolymerized in the presence of O2

15 lb/day and 

3 lb/hr 

Photochemically

h

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 

Nonphotochemically 

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 (the incinerator 

must have an emission reduction of 90%); or adsorption, or another approved method of control. 

2. Include emissions from the cleanup with photochemically reactive 

solvents in compliance determination 

Exemptions: (1) transport of storage of organic containing materials; 

(2) the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing less than 20% by volume of VOC and does not come into contact with a flame; (3) use, application, evaporation, or drying halogenated hydrocarbons or 

perchloroethylene. 

h A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which excee

percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having 

of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combinati

having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classi

into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the leas

total volume of solvents.
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-21 

Operation Material 

VOC 

limitation Compliance Requirements 

Santa Barbara County Air Pollution Control District

Any that come into contact with a flame, or are 

baked, heat cured, 

or heatpolymerized in the presence of O2

15 lb/day and 

3 lb/hr 

Photochemically

i

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 

Nonphotochemically 

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 (the incinerator 

must have an emission reduction of 90%); or adsorption, or another approved method of control. 

2. Include emissions from the cleanup with photochemically reactive 

solvents in compliance determination 

Exemptions: (1) transport of storage of organic containing materials; 

(2) the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing less than 20% by volume of VOC and does not come into contact with a flame; (3) use, application, evaporation, or drying halogenated hydrocarbons or 

perchloroethylene. 

i A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceed

percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having 

of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combinati

having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classi

into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the leas

total volume of solvents.
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-22 

Operation Material 

VOC 

limitation Compliance Requirements 

Shasta County Air Quality Management District 

Any that come into contact with a flame, or are 

baked, heat cured, 

or heatpolymerized in the presence of O2 at temperatures above 400

oF 

15 lb/day 

Photochemically

j

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 photochemically reactive 

solvents in compliance determination 

Exemptions: (1) use, application, evaporation, or drying halogenated 

hydrocarbons or perchloroethylene. 

j A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceed

percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having 

of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combinati

having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classi

into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the leas

total volume of solvents.
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-23 

Operation Material 

VOC 

limitation Compliance Requirements 

South 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 system that has a capture 

efficiency of at least 90 % by weight and the control 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 methods; 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: wipe cleaning; closed 

containers or hand held spray bottles w/out propellant-induced force; cleaning equipment which has a solvent container that is closed at all times (except when adding or removing parts or during 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 container or collection system that is closed at all times except for solvent collection and 

pressure relief (as needed) openings (discharged solvent must be 

collected into containers without atomizing into the air and solvent may 

be flushed through the system by air or hydraulic pressure or by pumping). 

5. All VOC-containing solvents must be stored in non-absorbent, nonAppendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-24 

Operation Material 

VOC 

limitation Compliance Requirements 

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 with VOC-laden solvents should be stored in closed, non-absorbent, non-leaking containers. 

6. Use closed containers for disposal of cloth or paper used in stripping 

cured coatings that are impregnated with solvent containing 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 heatpolymerized in the presence of O2 at temperatures above 400

oF 

Organic 15 lb/day solvents or solvent containing materials 

Photochemically

k

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

40 lb/day 

1. Reduce VOC emissions by 85% 

2. Include emissions from the cleanup with photochemically reactive 

solvents in compliance determination 

Exemptions: (1) use, application, evaporation, or drying halogenated 

hydrocarbons or perchloroethylene. 

k A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which excee

percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having 

of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combinati

having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classi

into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the leas

total volume of solvents.
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-25 

Operation Material 

VOC 

limitation Compliance Requirements 

Any 

photochemically 

reactive substance 

40 lb/day 
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-26 

Operation Material 

VOC 

limitation Compliance Requirements 

Ventura 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 combined capture 

and destruction efficiency of 90%, on a 24-hr rolling average or if the coating applied contains more than 1,200 g/l or ROC as applied (excluding water and exempt solvents), limit ROC emissions 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 for when adding or removing materials. 

Exemptions:. ROC emission limits do not apply during the first 24 hours 

of a scheduled carbon adsorption system startup. 
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-27 

Operation Material 

VOC 

limitation Compliance Requirements 

Yolo-Solano Air Quality Management District 

Any that come into contact with a flame, or are 

baked, heat cured, 

or heatpolymerized in the presence of O2

15 lb/day and 

3 lb/hr 

Photochemically

l

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 

Nonphotochemically 

reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

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 photochemically reactive 

solvents in compliance determination 

3. Do not dispose or allow the release of photochemically reactive 

solvents more than 1.5 gal of liquid (or equivalent amount of vapor). 

Exemptions: (1) transport of storage of organic containing materials; 

(2) the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing less than 20% by volume of VOC and does not come into contact with a flame; (3) use, application, evaporation, or drying saturated halogenated organic solvents or perchloroethylene. 

l A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceed

percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having 

of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combinati

having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classi

into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the leas

total volume of solvents.
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilit

D-28 

Operation Material 

VOC 

limitation Compliance Requirements 

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

oC 

(68

oF) 

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

oC 

(68

oF) 

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

oC 

(68

oF) 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 that can be, and 

is, closed during cleaning operations, except when depositing and 

removing objects, and is closed during non-operation with the exception of maintenance and repair to the cleaning equipment itself; 

c. Cleaning device or mechanism which has been determined by the 

Air Pollution Control Officer to result in equivalent 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 which is closed except for solvent collection openings and, if necessary, openings 

to avoid excessive pressure build-up inside the container; 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 excessive pressure 

build-up inside the container. The discharged solvent from the 

equipment must be collected into containers without atomizing 

into the open air. The solvent may be flushed through the system 

by air or hydraulic pressure, or by pumping. 

2. Use a collection and control system that collects at 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 carbon) 

United States 

Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Air Quality Strategies and Standards Division 

Research Triangle Park, NC 

Publication N