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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: February 3, 2011

SUBJECT: Technical Support Document for Pennsylvania’s Adoption of Control 

Techniques Guidelines for Paper, Film, and Foil Surface Coating 

Processes

/s/

FROM: Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO: File

/s/

THRU: Cristina Fernandez, Associate Director 

Office of Air Program Planning

A. BACKGROUND 

Section 172(c)(1) of the Clean Air Act (CAA) 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 sources of volatile organic compound (VOC)

emissions covered by a control techniques guidelines (CTG) document issued after 

November 15, 1990 and prior to the area’s 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 CAA. 

CTGs are intended to provide state and local air pollution control authorities information 

that should assist them in determining RACT for VOCs from various sources, including

paper, film, and foil coatings. In developing these CTGs, EPA, among other things, 

evaluated the sources of VOC emissions from this 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 

VOCs from paper, film, and foil coatings.

In December 1977, EPA published a CTG for surface coating of paper (EPA-450/2-77-
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008). This CTG discusses the nature of VOC emissions from this industry, available 

control technologies for addressing such emissions, the costs of available control options, 

and other items. 

EPA also promulgated a national standard of performance for new stationary sources 

(NSPS) for surface coating of pressure sensitive tape and labels, which is a subset of the 

paper, film, and foil surface coating industry in 1983 (40 CFR part 60, subpart RR), and 

published a national emission standard for hazardous air pollutants (NESHAP) for 

surface coating of paper in 2002 (40 CFR part 63, subpart JJJJ).

In 2006 and 2007, after conducting a review of currently existing state and local VOC 

emission reduction approaches for this industry, reviewing the 1977/1978 CTG and the 

NESHAP for this industry, and taking into account the information that has become 

available since then, EPA developed a new CTG surface coating of paper, entitled 

Control Techniques Guidelines for Paper, Film, and Foil Coatings (Publication No. EPA 

453/R-07-003; September 2007).

Description of Paper, Film, and Foil Coatings

The paper, film, and foil 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; photographic film; industrial and decorative laminates; abrasive products; and 

flexible packaging. The category also includes coatings applied during miscellaneous 

coating operations for several products including: corrugated and solid fiber boxes; diecut 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 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, functional or protective layer to a substrate; (2) saturate a substrate for 

lamination; or (3) 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.

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

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

majority of VOC emissions from these materials occur during coating application/flash-
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off, coating curing/drying, and cleaning. The remaining VOC emissions are from 

cleaning operations.

EPA’s Recommended Control Option for Paper, Film, and Foil Coatings

EPA issued a CTG for Paper, Film, and Foil Coatings in September 2007 (Publication 

No. EPA 453/R-07-003). The following summarizes recommendations for controlling 

VOC emissions from paper, film, and foil coatings:

A. Coatings: To control VOC emissions from coatings used in paper, film, and foil 

surface coating, an overall VOC control efficiency of 90% for each coating line is 

recommended. Alternatively, emission limits that are equivalent to 90 percent overall 

control is recommended. 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 is recommended. 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. It’s also 

recommended that paper, film, and foil surface coating facilities be provided with the 

option of using an enforceable limitation on potential emissions to keep an individual 

paper, film, and foil surface coating line below the 25 tons per year (tpy) potential to emit 

threshold.

An overall VOC control efficiency of 90 percent is recommended as RACT for each 

paper, film, and foil surface coating line. However, as an alternative to an overall 90 

percent control efficiency, VOC content-based emission limits that are equivalent to 90 

percent overall control are recommended, 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), 20 weight percent solids and 80 weight percent solvent 

was used. 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. 

As an alternative to 90 percent emission reduction, a limit of 0.20 kg VOC/kg (0.20 lb 

VOC/lb) solids applied is recommended, and an additional equivalent limit of 0.067 kg 

VOC/kg (0.067 lb VOC/lb) of coating is RACT for pressure sensitive tape and label 

surface coating lines. 
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Table 1: Recommended Emission Limits for Paper, Film, and Foil Coatings

Units

RACT Limits

Pressure Sensitive Tape 

and Label Surface 

Coating

Paper, Film, and Foil 

Surface Coating (Not 

including Pressure 

Sensitive Tape and Label)

kg VOC/kg solids

(lb VOC/lb solids)

0.20 0.40

kg VOC/kg coating

(lb VOC/lb coating)

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). 

B. Cleaning Materials: To control VOC emissions from cleaning materials used in 

paper, film, and foil surface coating, it is recommended 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, the 

following is recommended: (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 VOC-containing 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.

B. STATE SUBMITTAL

On January 4, 2011, Pennsylvania Department of Environmental Protection (PADEP) 

submitted to EPA a SIP revision concerning the adoption of the EPA paper, film, and foil 

surface coating processes. EPA develops CTGs as guidance on control requirements for 

source categories. States can follow the CTGs or adopt more restrictive standards. The 

Commonwealth of Pennsylvania has adopted EPA’s CTG standards for paper, film, and 

foil surface coating processes. These regulations are in 25 Pa. Code Chapter 121 –

General Provisions and in Chapter 129 – Standards for Sources. Specifically, this 

revision amends the existing regulations at §§ 121.1, 129.51 and 129.52 and adds new § 

129.52b. Section 129.52b, which covers control of VOC emissions from paper, film, and 

foil surface coating processes, supersedes the existing paper surface coating requirements 

and limits in § 129.52. The requirements of § 129.52b also supersede the requirements of 

a RACT permit issued to the owner or operator of a source subject to § 129.52(b)(a) prior 

to January 1, 2012 under §§ 129.91 – 129.95 to control, reduce, or minimize VOC 

emissions from a paper, film, or foil surface coating process, except to the extent the 

RACT permit contains more stringent requirements.
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Chapter 121: General Provisions

Section 121.1: Definitions

 “coating line” definition is added

 “coating” definition is amended for purposes of section 129.52(b)

 “paper coating” definition was amended to correspond to the broader terms 

“paper, film, or foil” and “paper, film, or foil surface coating,” which are used in 

other sections of Chapter 129

Chapter 129: Standards for Sources – Sources of VOCs

Section 129.51: General

 Section 129.51(a) is amended to extend its coverage to paper, film, and foil 

surface coating processes

Section 129.52: Surface coating processes

 Subsection (j) is added clarifying that the requirements and limits already

specified in section 129.52 for paper coatings are superseded by the requirements 

and limits adopted in this revision.

Section 129.52b: Control of VOC emissions from paper, film, and foil surface coating 

processes

 This section includes VOC emission limits, work practices, and recordkeeping 

and reporting requirements, all of which are consistent with EPA’s CTG for 

paper, film, and foil surface coating processes. The requirements in section 

129.52b supersede the requirements in 129.52 relating to control of VOC 

emissions from paper, film, and foil surface coating processes beginning January

1, 2012. 

 Subsection (a) establishes applicability for the emission limits, work 

practice requirements and related compliance monitoring, and 

recordkeeping and reporting requirements.

 Subsection (b) explains that the requirements of section 129.52b 

supersede the requirements of a RACT permit from a paper, film, or 

foil surface coating operation already issued to the owner or operator 

subject to section129.52b unless the RACT permit contains more 

stringent requirements.

 Subsection (c) establishes VOC emission limits which take effect 

beginning January 1, 2012.

 Subsection (d) establishes compliance monitoring procedures and 

identifies daily records that must be kept in order to demonstrate 

compliance.

 Subsection (e) establishes recordkeeping and reporting requirements.

 Subsection (f) explains that VOCs may not be emitted into the 

atmosphere from the application of paper, film, or foil surface 

coatings, unless the coatings are applied using one or more of the 

following coating application methods:

1. Rotogravure coating

2. Reverse roll coating
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3. Knife coating

4. Dip coating

5. Slot die coating

6. Flexographic coating

7. Extrusion coating

 Subsection (g) exempts coatings which are used exclusively for 

determining product quality and commercial acceptance if the quantity

of coating used does not exceed 50 gallons per year for all coatings 

combined for the facility and if the owner or operator of the facility

requests this exemption in writing and PADEP approves, in writing, 

the exemption prior to use of the coating.

 Subsection (h) establishes work practice requirements for cleaning 

materials.

 Additionally, VOC emission limits for paper coatings only and the associated 

applicability criteria that were in section 129.52(a)(2) were added to section 

129.52b in order to carry forward previously regulated paper coating sources so as 

to eliminate the potential for backsliding. These VOC emission limits apply only

to paper coatings if actual VOC emissions have exceeded 3 pounds per hour, 15 

pounds per day or 2.7 tpy in any year since January 1, 1987. The limits are shown 

in Table 2.

Table 2: Emission Limits of VOCs for Paper Coating 

Units RACT Limit for Paper Coating

lb VOC/gal coating solids 4.84

kg VOC/l coating solids 0.58

C. EPA EVALUATION

PADEP has adopted the standards and requirements of EPA’s CTG for paper, film, and 

foil surface coating processes and is amending the Pennsylvania SIP to reflect these 

amendments. The maximum benefit from these amendments will be provided during the 

ozone season when VOCs readily combine with NOx to form ground-level ozone. 

Specifically, a maximum of 176 tons of additional annual VOC emission reductions are 

anticipated from the paper, film, or foil surface coatings facilities in Pennsylvania as a 

result of this rulemaking. Therefore, this revision will help Pennsylvania attain and 

maintain the NAAQS for ozone. 
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D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The adoption of the EPA CTG requirements for paper, film, and foil surface coating

processes by the Commonwealth of Pennsylvania will result in the reduction of VOC 

emissions from paper, film, and foil surface coating processes. EPA’s approval of the 

SIP revision is recommended.