1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103
DATE: February

3, 2011 SUBJECT: Technical Support Document for Penns yl vania’s Adoption of Control

Techniques Guidelines for Paper, Film, and Fo il Surface Coating Processes /s/ FROM: Irene Shandruk, Phy sical Scientist

Office of Air Program Planning TO: File

/s/ THRU: Cristina Fernandez, Associate Director

Office of Air Program Planning
A. BACKGROUND S ection 172(c)(1) of the Cle an 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) pr ovides that for certain nonattainment areas, States must revise their SIPs to include RACT for sources of volatile organic compound ( VOC ) emissions covered b y a control techniques guidelines (CTG) document issued after November 15, 1990 and prior to the ar ea’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 b y the application of control technology

that is reasonabl y available considering technological and economic feasibility .” (44 FR 53761, Sept. 17, 1979 )
. Insubsequent Federal Register notices, EPA has addressed how states can mee t the RACT requirements of the CAA
. CTG s are intended to provide state and local air pollution contro l 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 p ublished a CTG for surface coating of paper (EPA

- 450/2

- 77
-2

008 ). Th is CTG discuss es the nature of VOC emissions from th is industry , available control technologies for addressing such emissions, the costs of available control options, and other items. EP A also promulgated a national standard of performance for new stationary sources (NSPS) for s urface 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 publi shed a national emission standard for hazardous air pollutants (NESHAP) for s urface coating of paper in 2002 (40 CFR part 63, subpart JJJJ)
. In 2006 and 2007, after conducting a review of currentl y existing state and local VOC emiss ion reduction approaches for this industry , reviewing the 1977/1978 CTG and the NESHAP for th is industr y , and taking into account the information that has become available since then, EPA developed a new CTG surface coating of paper, entitled Control Techniques Guideli nes 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 t ypes 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; die

cut paper paperboard and cardboard; converted paper and paperboard not elsewhere classified; foldin g 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, ro togravure, 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 sy stem are not part of the paper, film, and foil coating categ ory . 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 t o: (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

-3

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

- 0 7
- 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. Applyi ng 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, an d an y 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 limi tation on potential emissions to keep an individual paper, film, and foil surface coating line below the 25 tons per y ear ( tpy) potential to emit threshold. An overall VOC control efficiency of 90 percent is recommended as RACT for each paper, film, and f

oil 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 i s RACT for pressure sensitive tape and label surface coating lines.4

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 solid s (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 b y averaging the VOC content of materials used on a single surface coating line each day (i.e. daily

within

- line averaging). B. Cleani ng 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 clean ing 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 kep t 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 VO C 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, an d 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 adopt ed EPA’s CTG standards for paper, fi lm, and foil surface coating processes. These regulations are in 25 Pa. Code Chapter 121

– General Provisions and in Chapter 129

– S tandards for Sources
. Specifically , this revision ame nds 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.5

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” defi nition 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 : C ontrol 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 whic h are consistent with EPA’s CTG for paper, film, and foil surface coating processes. The requirements in section 129.52 b supersede the requirements in 129.52 relating to control of VOC emissions from paper, film, and foi l 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 requi rements.  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) explain s 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 follo wing coating application methods: 1. Rotogravure coating 2. Reverse roll coating6 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 comm ercial acceptance if the quantity of coating used does not exceed 50 gallons per ye ar 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 p rior to use of the coating
.  Subsection (h) establishes work practice requirements for cleaning material s .
 Additionally , VOC emission limits for paper coatings onl y and the associated applicability

criteria that were in section 129.52(a)(2) were added to s ectio n 129.52 b in order to carry

forward previousl y 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 tp y in any y ear 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 E VALUATION 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 durin g the ozone season when VOCs readil y combine with NO x to form ground

- level ozone. Specificall y, 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.7

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 Penns yl vania 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.