&EPA
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/3-80-003b
September 1983
Air
Pressure Sensitive
Tape and Label
Surface Coating
Industry —
Background
Information for
Promulgated
Standards
Final
EIS
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EPA-450/3-80-003b
Pressure Sensitive Tape and Label
Surface Coating Industry -
Background Information
for Promulgated Standards
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
September 1983
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This report has been reviewed by the Emission Standards and
Engineering Division of the Office of Air Quality Planning and
Standards, EPA, and approved for publication. Mention of
trade names or commercial products is not intended to constitute
endorsement or recommendation for use. Copies of this report
are available through the Library Services Office (MD-35),
U.S. Environmental Protection Agency, Research Triangle Park,
N.C. 27711, or from National Technical Information Services,
5285 Port Royal Road, Springfield, Virginia 22161.
ii
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ENVIRONMENTAL PROTECTION AGENCY
Background Information and Final
Environmental Impact Statement
for Pressure Sensitive Tape and Label
Surface Coating Industry
Prepared by:
Farmer
Director, Emission Standards and Engineering Division
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
(DaS)
1. The promulgated standards of performance will limit emissions of
volatile organic compounds (VOC) from new, modified, and reconstructed
pressure sensitive tape and label coating lines. Section 111 of the
Clean Air Act (42 U.S.C. 7411), as amended, directs the Administrator
to establish standards of performance for any category of new
stationary source of air pollution that "... causes or contributes
significantly to air pollution which may reasonably be anticipated to
endanger public health or welfare." The northeastern and north central
regions of the country would be particularly affected by the
promulgated standard.
2. Copies of this document have been sent to the Department of Labor;
Department of Agriculture; Department of Commerce; Office of Management
and Budget; Council of Environmental Quality; members of the State and
Territorial Air Pollution Program Administrators, and the Association
of Local Air Pollution Control Officials; EPA Regional Administrators;
and other interested parties.
3. For additional information contact:
Mr. Fred Porter
Standards Development Branch (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
Telephone: (919) 541-5578
4. Copies of this document may be obtained from:
U. S. EPA Library (MD-35)
Research Triangle Park, NC
27711
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
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Chapter 1
SUMMARY
On December 30, 1980, the Environmental Protection Agency (EPA) pro-
posed standards of performance for Pressure Sensitive Tape and Label (PSTL)
Surface Coating Operations (45 FR 86278) under authority of Section 111 of
the Clean Air Act. Also, a draft Environmental Impact Statement (EIS) was
published in a background information document (BID) entitled, Pressure
Sensitive Tape and Label Surface Coating Industry - Background Information
for Proposed Standards (EPA 450/3-80-003a). Public comments were requested
on the proposal in the Federal Register. There were ten commenters repre-
senting the PSTL industry. Comments were also received from the State of
Ohio and two United States senators. In addition to written comments, a
public hearing was held on January 30, 1981.
This BID supports promulgation of the Federal New Source Performance
Standards (NSPS) for limiting volatile organic compound (VOC) vapor
emissions from PSTL coating lines. This document provides a final EIS and a
discussion of changes made after proposal resulting from public comments.
Chapter 1 presents a summary of the changes made to the regulation between
proposal and promulgation with resulting impacts. Chapter 2 contains a
summary of all comments and EPA responses to the comments.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
The requirements of the pressure sensitive tape and label regulation
have not substantially changed since proposal. The most important change
made to the standard involved broadening the proposed affected facility
definition. Other important changes involved: broadening the small solvent
use exemption limit, modifying two compliance equations to correctly use the
data which Reference Method 24 produces, revising a performance test
requirement for incinerator-controlled facilities, and reducing the
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reporting requirements of the standard. Minor word changes were also made
in several miscellaneous items. The substantive changes are discussed in
greater detail in-the succeeding paragraphs.
1.1.1 Affected Facility Definition. The proposed standard defined
affected facility as each individual coating operation located within a PSTL
coating line. Industry sources indicated that under this definition as many
as three affected facilities could be contained within a single coating
line. After careful consideration of the public comments on this issue, the
Administrator determined that the affected facility definition should be
amended in the promulgated standard to encompass the entire coating line,
including all individual coating heads and drying ovens on one line, from
unwind to wind. The term "coating line" was redefined to include all
adhesive, release, and precoat coating operations located between a web
unwind station and a web rewind station on a single coating line. For
clarity the term "precoat" was also redefined to include all coating opera-
tions in which a coating other than an adhesive or release is applied.
An analysis of the points raised in the comments on this issue and of
new data submitted by the industry revealed that the conclusion that the
proposed narrow definition would result in greater emissions reduction was
not presently supportable. These new data showed that the relative cost of
low-solvent technologies has changed since the BID was prepared and that new
low-solvent adhesive systems are now more costly than comparable solvent-
based adhesive systems which are now in use.
Consequently, the narrow definition, which has the effect of imposing
the additional cost of precoat controls on new or modified lines which use
low-solvent adhesive technologies, would encourage continued use of existing
solvent-based adhesive facilities and discourage the construction of new
low-solvent facilities. In contrast, under the broad definition, precoat
facilities would not need to be controlled if the emissions from the
complete line are below the standard. This results in a significant cost
savings and creates an incentive for the construction of new, low-solvent
adhesive facilities. New lines involving low-solvent facilities would have
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significantly lower emission rates that existing solvent-based lines, and
equal or lower emission rates than new solvent-based lines. In view of the
cost incentive for the construction of new low-solvent lines, it was
reasonable to conclude that the broad definition will result in greater
emission reduction than the narrow definition. For this reason the
Administrator decided to adopt the broad definition in the promulgated
standard.
1.1.2 Small Solvent Use Exemption Limit. Based on a reanalysis of VOC
control costs, the small solvent use exemption limit has been broadened to
exclude from compliance with the standard's emission limits, any coating
line which inputs to the coating process 45 Mg (50 tons) of VOC or less per
12 month period. The 125 kg VOC daily and 15 Mg VOC annual limits have been
deleted. Although new or modified coating lines which input 45 Mg (50 tons)
of VOC or less per 12 month period are not subject to the emission limits,
they are affected facilities under the standard and as such are subject to
applicable recordkeeping and reporting requirements.
1.1.3 Compliance Equations. The two equations in the standard which
use the data resulting from the application of Reference Method 24 were
changed. The changes were required because the proposed standard did not
use the correct variables to represent the data that Reference Method 24
gives. Reference Method 24 gives the weight fraction of organics and the
weight fraction of solids of a particular coating. Variables representing
these quantities were added to the standard. These new variables replace
values (in the proposed standard) that are not obtainable from Reference
Method 24. The deleted variables represented the mass of VOC per mass of
solids in a coating and the mass of coating solids in a coating. The changes
made in the equations' variables have no effect on the results achievable
from the equations.
1.1.4 Performance Test Requirements. In the final regulation the
performance test for incinerator-controlled affected facilities has been
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slightly modified in the way that the average VOC content per unit mass of
solids is determined. In the promulgated standard, the performance test for
incinerator-controlled affected facilities will still require three one hour
test runs. The VOC content (and consequently the required level of emission
reduction) will be determined by testing the coatings (with Reference
Method 24) that will be used at the affected facility during each one hour
test. This approach differs from the proposed standard in that the proposed
standard required that a monthly average VOC content be determined based on
all coatings used at the affected facility in the month prior to the perfor-
mance test. The revised method in the final rule is more reasonable because
it will be a more representative and direct measurement of the emission
reduction capabilities of the emission control system.
1.1.5 Reduction of Reporting Requirements. In the proposed standard
owners and operators of an affected facility were required to report to the
Administrator any exceedances of the allowable VOC emission limit and
incinerator temperature fluctuations established in the standard. These
reports were required to be submitted within 10 days following the end of
the calendar month in which the exceedance occurred. In the promulgated
standard the same exceedance reports are required; however, the owner or
operator is only required to submit the reports semiannually. If no
exceedances occur during a year, the owner or operator is not required to
submit these reports. The change in the required frequency of reporting in
no way affects an owner or operator's recordkeeping requirements. Facili-
ties will still be required to maintain records for two years to indicate
proper operation and maintenance of control equipment and compliance with
the standard. EPA has the authority to inspect these records at any time to
check compliance with the standard. Upon inspection of facility records,
the Administrator can request an additional performance test.
1.1.6 Miscellaneous Revision. The term "VOC" is not explicitly
defined in the promulgated regulation as it had been in the proposed rule.
In the promulgated regulation "VOC" is simply defined as meaning "volatile
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organic compounds". No detailed definition was required in the promulgated
regulation because a definition of "volatile organic compounds" has already
been promulgated with the Automobile and Light-Duty Truck Surface Coating
NSPS (45 FR 85410, December 24, 1980).
For the promulgated regulation, the specifications on sample size for
the use of Reference Method 24 were slightly modified from those presented
in the proposed rule. In the promulgated version it is stated that, "for
Reference Method 24, the coating sample must be a one liter sample taken
into a one liter container at a point where the sample will be representa-
tive of the coating applied to the web substrate." The proposed regulation
only required that a one liter sample be taken with no specifications made
on container size.
1.2 SUMMARY OF IMPACTS OF PROMULGATED ACTION
1.2.1 Alternatives to Promulgated Action. The regulatory alternatives
are discussed in Chapter 6 of the proposal BID. These regulatory alterna-
tives reflect the different levels of emission control from which one is
selected that represents the best demonstrated technology, considering
costs, nonair quality health, and environmental and economic impacts for
pressure sensitive tape and label surface coating operations. These alter-
natives remain the same.
1.2.2 Environmental Impacts of Promulgated Action. The changes in the
regulation as described in Section 1.1 above will have no effect on the
environmental impacts ascribed to the standard as originally proposed.
These impacts are described in Chapter 7 of the proposal BID. That analysis
of environmental impacts now becomes the final Environmental Impact State-
ment (EIS) for the promulgated standards.
1.2.3 Energy and Economic Impacts of Promulgated Action. The energy
impacts of the standards are described in Section 7.4 of the proposal BID.
The changes made in the standards since proposal have no effect on these
impacts.
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The economic impacts of the proposed standards are discussed in
Chapter 8 of the proposal BID. The broadening of the affected facility
definition, in the promulgated standards, may reduce the reporting and
recordkeeping costs incurred by the PSTL industry. However, the economic
impacts of the promulgated standards are expected to remain essentially as
presented in the proposal BID.
1.2.4 Other Considerations
1.2.4.1 Irreversible and Irretrievable Commitment of Resources.
Chapter 7 of the proposal BID concludes that other than fuels required for
steam and electricity generation and the materials required for construction
of the system, there is no apparent irreversible or irretrievable commitment
of resources associated with the construction or operation of the control
systems. This remains unchanged since proposal.
1.2.4.2 Environmental and Energy Impacts of Delayed Standards.
Table 1-1 in the proposal BID summarizes the environmental and energy
impacts associated with delaying promulgation of the standard. Delayed
promulgation would mean affected facilities would be controlled to the State
Implementation Plan (SIP) level. This is the control level used as the
baseline alternative in the model plant analyses. These impacts remain
unchanged since proposal.
1.2.4.3 Urban and Community Impacts. Chapter 8 of the proposal BID
discusses potential socioeconomic impacts. There have been no changes in
the urban or community impacts since proposal of the standards.
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Chapter 2
SUMMARY OF PUBLIC COMMENTS
The list of commenters, their affiliation, and the Environmental
Protection Agency (EPA) docket number of each of the comments are shown in
Table 2-1. In addition to comments made at the public hearing, fourteen
letters commenting on the proposed standard were received. The comments
have been combined into the following nine categories:
2.1 General
2.2 Emission Control Technology
2.3 Modification and Reconstruction
2.4 Economic Impact
2.5 Affected Facility Definition
2.6 Reporting and Recordkeeping
2.7 Small Source Exemption
2.8 Level of Proposed Standard
2.9 NSPS and State Implementation Plan (SIP) Coordination
The comments and responses are discussed in the following sections of
this chapter. A summary of changes made in the regulation is included in
Chapter 1. The docket reference is indicated in parentheses in each
comment. Unless otherwise noted, all docket references are part of Docket
Number A-79-38, Category IV.
2.1 GENERAL
2.1.1 Comment: One commenter (D-ll) made several points concerning
different aspects of hot melt coating. This commenter pointed out that in
Europe the slot-die type hot melt coater discussed in the BID is being
almost completely replaced by roll coating of hot melts. Hot melt roll
coaters eliminate many of the operational and product quality problems
associated with slot-die type coaters. The elimination of these problems
will make hot melt coating applicable to more PSTL products.
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TABLE 2-1
List of Commenters on the Proposed Standards of Performance for
Pressure Sensitive Tape and Label Surface Coating Operations
Docket Number A-79-38, IV
Public Hearing
Comtnenter
Mr. John Quarles
Morgan, Lewis, & Bockius
1800 M Street, N.W.
Washington, D. C. 20036
Mr. Alonzo Moore
Anchor Continental, Inc.
2000 South Beltline Boulevard
Columbia, South Carolina 29250
Docket Reference
F-l
F-l
Letters
Mr. S. F. Straus
W. H. Brady Company
727 West Glendale Avenue
Milwaukee, Wisconsin 53201
Mr. Jerald A. Jacobs and Mr. Richard F. Mann
Leighton, Conklin, Lemov, Jacobs, and Buckley
2033 M. Street, N.W.
Washington, D. C. 20036
Senator Ernest F. Rollings
115 Senate Office Building
Washington, D. C. 20510
Mr. W. Radoslovich
Le Page's Incorporated
Papercraft Park
Pittsburgh, Pennsylvania 15238
D-l
D-2
D-3
D-4
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Commenter
Mr. Patrick J. Dirk
Kroy Industries, Inc.
1728 Gervais Avenue
St. Paul, Minnesota 55164
Mr. Charles R. North
Avery International
250 Chester Street
Painesville, Ohio 44077
Mr. Max L. Ostrow
DAP Incorporated
Post Office Box 277
Dayton, Ohio 45401
Mr. John Quarles
Morgan, Lewis, & Bockius
1800 M. Street, N.W.
Washington, D. C. 20036
Mr. Edwin W. Oldham
Morgan Adhesives Company
4560 Darrow Road
Stow, Ohio 44224
Mr. K. A. Walanski
DeSoto, Inc.
1700 South Mount Prospect Road
Des Plaines, Illinois 60018
Mr. Wolfram Aurin
Paeon Machines Corporation
51 Signal Hill Road
Madison, Connecticut 06443
Mr. James F. McAvoy
State of Ohio Environmental Protection Agency
361 East Broad Street
Columbus, Ohio 43216
Senator Jesse Helms
4213 Dirkson Senate Building
Washington, D. C. 20510
Docket Reference
D-5
D-6
D-7
D-8
D-9, D-12
D-10
D-ll
D-13
D-14
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Commenter D-ll went on to state that for the case of 100 percent solids
silicone release coating, nip-fed smooth roll coaters are replacing the
gravure-type coater discussed in the BID. In Europe these nip-fed roll
systems are being used because of the following advantages: no foaming at
high speeds, no filling of gravure cells with hardened silicone, and no
frequent replacement of gravure rolls. The commenter stated that the
in-line tandem coating of a hot melt adhesive and a 100 percent solids
silicone release would be the most economical way to produce pressure
sensitive adhesive label stock.
Response: At the time EPA developed the process description for hot
melt adhesive and 100 percent solids silicone release coating, slot-die type
and gravure type coaters, respectively, were the predominant methods of
application for these coatings in the United States. Coating equipment
vendors outside of the U. S. were not contacted. Although EPA does strive
to make the BID as current as possible, not all of the latest technological
developments in the tape and label industry can be included. The Adminis-
trator welcomes the submission of such updated industry information and
feels these developments in coating application methods will aid in EPA's
attempts to reduce volatile organic compound (VOC) emissions from the PSTL
surface coating industry. The Administrator acknowledges that the totally
solvent-free coating line configuration proposed in the commenter's letter
would represent a significant achievement in YOC emissions reduction from
the PSTL industry. In this regard, the proposed standards may encourage or
would not adversely affect the use of such technology.
2.1.2 Comment: A manufacturer (D-10) of surface coatings commented on
the treatment of radiation-cured coatings in the proposed standard. The
commenter stated that radiation-cured coatings emit essentially no VOC and
may be considered "in a classical sense" 100 percent solids coatings. The
commenter objected to the analytical methods proposed to measure the
existence and level of VOC in surface coatings. This analytical method
(Reference Method 24) uses a thermal bake procedure to evaporate the
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volatiles and then determine the volatile content based on weight loss of
the sample. With radiation-cured coatings this procedure would cause non-
VOC coating solids constituents to volatilize. Based on a weight loss
examination, the radiation-cured coating would appear to contain significant
VOC. The commenter felt that the Administrator should either exempt
radiation-cured coatings from the standard or permit an alternative
analytical test method to be used in place of Reference Method 24 for
determining the VOC content of such coatings.
Response: This commenter (D-10) was contacted directly (E-3 and E-4)
to clarify what type of alternative analytical test procedure he would
recommend for radiation-cured coatings. It was learned from these conversa-
tions that the commenter is not actually connected with the pressure
sensitive tape and label industry. His company does not supply any type of
adhesive, release, or primer coatings to this industry. The commenter
stated that the reference to surface coating in the title of the proposed
standard initiated his company's comment letter. The commenter1s company
produces surface coatings for lithographic applications to paper products
such as record jackets.
A specific exemption from the standard for radiation-cured coatings is
not necessary. The fact that these coatings contain no VOC and are essen-
tially 100 percent solids formulations would effectively allow them to fall
below the 0.20 kg VOC/kg solids emission limit of the proposed standard,
therefore, no additional control would be required. The affected industry
made no comments on this subject or on the need for a different analytical
test procedure prior to proposal of the regulation or during the public
comment period.
2.1.3 Comment; One commenter (D-5) understood the proposed standard
to say that the water content of coatings would be included as a VOC in
determining whether the affected facility fell below the proposed lower
emission cutoff of 15 megagrams of VOC per year.
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Response: It appears that there was a misunderstanding on the part of
the commenter regarding this question. The inclusion of water as VOC is not
mentioned in the preamble or proposed standard and is clearly not intended.
The proposed standard included the following, "any coating line which causes
the discharge into the atmosphere of not more than 125 kg of VOC per day and
15 Mg of VOC (emphasis added) per year is not considered an affected
facility and is not therefore subject to the emission limits of §60.442(a)."
It should be noted that the 125 kg VOC and 15 Mg VOC lower emissions cutoff
levels have been deleted and replaced by a single value of 45 Mg per year
(see comment 2.7).
2.1.4 Comment: One commenter (D-6) objected to an analysis in the
background information document that examined the additional fuel require-
ments of thermal incinerators operating at various lower explosive limit
(LEL) levels. The commenter felt that the conclusion of the analysis was
that no additional fuel would be required when the incinerator gases were
maintained at 40 percent LEL or greater. The commenter1s objection to this
conclusion stemmed from a 1972 test of his own facility's incinerator. This
test indicated that at LEL levels above 40 percent some additional fuel was
required by the incinerator device.
Response: The comparison raised by the commenter's objection is not a
valid one. The analysis presented in the BID was only a model case based on
realistic information from similar incineration systems currently in use in
the industry. The analysis was presented to make a point that the higher
the LEL level in the incinerator gas stream, the less additional fuel would
be required to operate the incinerator. The example calculations and
numbers given in the BID were not intended to be used as absolute values nor
were they presented as such. The model analysis was only intended to
indicate a trend as the LEL was raised from 5 to 40 percent. No attempt was
made to draw the general conclusion that systems at 40 percent LEL or
greater no longer require any additional fuel.
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The fact that the commenter's 1972 tests do not agree precisely with a
model's example calculation is understandable. The conditions existing at
the time of the commenter's test do not match the assumptions and conditions
used in the BID analysis. In addition, an incinerator operating nine years
ago may not have been as well-designed and efficiently operated as more
current models.
2.1.5 Comment: Several commenters (D-l, D-3, D-13) believe that the
proposed standard is unnecessary because strong economic incentives already
exist for users of petroleum-based solvents to recover the maximum amount of
solvent possible.
Response; In the view of the Administrator, economic incentives are an
important consideration in a facility's attempts to recover solvent
emissions, however, economic incentives alone are not strong enough to
ensure that pressure sensitive tape and label facilities will use the best
demonstrated technology. Section lll(a)(l) of the Clean Air Act Amendments
of 1977, states that a standard of performance shall reflect the degree of
emission limitation achievable through application of the best (emphasis
-added) technological system of continuous emission reduction. Several
facilities examined during the development of the proposed standard used
solvent recovery emission controls, however, these controls were not being
optimally used to recover all the solvent emissions possible. Furthermore,
some facilities examined did not deem it necessary to try to recover any
solvent emissions.
The EPA is establishing an NSPS for pressure sensitive tape and label
coating facilities because this industry is part of the industrial paper
surface coating category which is ranked fourth on the "Priority List and
Additions to the List of Categories of Stationary Sources" promulgated at
44 FR 49222 on August 21, 1979. This list for new source performance
standards ranks emission sources in terms of quantities of air pollutant
emissions, mobility and competitive nature of each source category, and the
extent to which each pollutant endangers public health and welfare.
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2.2 EMISSION CONTROL TECHNOLOGY
2.2.1 Comment: One commenter (D-4) stated that it has not been
demonstrated that the proposed standards have been achieved using a hood
capture system, except on a theoretical basis.
Response: The best system of continuous emission reduction in the PSTL
industry was determined to consist of an emission control device operated in
conjunction with a well-designed VOC capture system. High levels of
emissions capture (particularly fugitive emissions capture) is an important
consideration in an affected facility's attempts to comply with the proposed
standards. At a source test conducted during the development of the
proposed standards, the tested facility did use a hooding system to capture
fugitive emissions around the coating area. The testing results indicated
that the hooding system was doing a very good job of capturing fugitive
solvent emissions. However, at this facility, instead of routing the
captured fugitives back into the drying oven or control device, they were
emitted directly to the atmosphere. For this reason a direct use of the
captured emissions in computing the facility's overall VOC emission reduc-
tion was not possible. Calculations using the actual test data VOC concen-
trations and measured gas flow rates indicate that the level of the proposed
standard would have been met had the facility ducted captured fugitive
emissions to the drying oven or control device. Plant trips to other
well-controlled facilities that use well-designed hooding systems confirmed
that significant emissions capture can be achieved using hoods.
2.3 MODIFICATION AND RECONSTRUCTION
2.3.1 Comment: Three comments (D-2, D-4, D-12) were received
concerning the definition and application of the terms "modification" and
"reconstruction" in the proposed standard. One commenter stated in a letter
(D-2) that there is no definition in the standard for these terms, and
specifically questions whether the addition of a coating head or the normal
replacement of spare parts would make a facility subject to the proposed
standards. Another commenter stated that the interpretation of what is
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allowed under the definitions of modified and reconstructed facilities is
vague and subject to misinterpretation (D-4). The same commenter stated
that these provisions would make the administration more difficult.
Response: There are definitions of the terms "modification" and
"reconstruction" in the General Provisions section of the New Source
Performance Standards regulations at 40 CFR 60.14 (modification) and 60.15
(reconstruction). These definitions are applicable to all new source
standards, unless specifically amended in the standard for a particular
source category. This proposed standard contains no amendment to these
definitions.
The term "modification" applies to any operational or physical change
in a facility which results in an increase in the emissions from the source
of any pollutant regulated by the standard. However, in Section 60.14(e)(l)
routine repair, replacement and maintenance are deemed not to be modifica-
tions under the regulation.
Whether a change to a facility constitutes a "reconstruction" is a
case-by-case determination under 60.15. This determination is made by first
looking at whether the capital cost of the replacements to an existing plant
is greater than fifty percent of the capital costs of construction of a
comparable new facility, then assessing whether it is technologically and
economically feasible to meet the standards at the reconstructed facility.
Thus, the definitions of modification and reconstruction given in
40 CFR 60.14 and 60.15 give reasonably specific requirements which must be
met in order to determine whether specific alterations to a facility would
make the provisions of the proposed standard applicable to the facility. In
addition, consideration was given to the effect of the application of these
provisions to the pressure sensitive tape and label industry during the
development of this standard. Changes in web width, in line speed, in
scheduling efficiency, and in components of the manufacturing operation have
been reviewed in Chapter 5 of the BID and the conditions under which they
would or would not fall under the modification and reconstruction defini-
tions discussed (see the preamble to these proposed standards for a summary
of this discussion). These regulations, the discussion of this issue in the
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BID, and the provisions in 60.15(b) for the determination by the Administra-
tor as to the applicability of the reconstruction provision to specific
facilities provides the certainty in application needed for operation under
the standard.
Under these provisions, the normal replacement of spare parts would not
be anticipated to constitute either a modification or a reconstruction, and
therefore, would not trigger the imposition of the proposed standard. The
addition of a coating head may constitute either a modification or a recon-
struction, depending on the facts of the case. If the addition of the
coating head resulted in an increase in emissions, this change would be a
modification. If the addition of the coating head involved a capital
expenditure greater than one half of the capital cost of a new facility, and
it was technologically and economically feasible to meet the standard at the
facility, the Administrator would determine that the change constituted a
reconstruction and the facility would be considered an affected facility
under the standard.
The difficulties with administration referred to were not detailed.
However, it is assumed from the context of the comment that the major
concern was with the costs of the manpower involved in the operation and
maintenance of the control equipment and related monitoring, recordkeeping
and reporting activities. In this regard, EPA has studied the costs which
will be incurred in these activities. This analysis is contained in the
preamble to the proposed standard at 45 FR 86288 and in the Reports Impact
Analysis which is a part of the docket for this standard setting. Calcula-
tions of the effort which would be required in order to accomplish the
reporting necessitated by the proposed standard reveal that for the first
five years the industry would incur a manpower demand of twelve additional
person-years. When viewed against the emission reductions projected for
this industry as a result of the implementation of these regulations, this
added administrative cost is considered to be reasonable.
2.3.2 Comment: One commenter stated that the conversion of coating
facilities to waterborne technologies should not constitute a modification
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or reconstruction of the facility, thereby triggering the requirements of
the proposed standard (D-7).
Response: The conversion of a solvent-based coating system to a
waterborne system would not, in and of itself, constitute a modification,
since the use of the waterborne system would not ordinarily result in an
increase in VOC emissions, but instead in a reduction in those emissions.
Such a conversion might, however, constitute a reconstruction of the
facility under the definition stated in 40 CFR 60.15 if the capital costs of
the conversion exceeded fifty percent of the capital costs of a new
facility.
Under the reconstruction provisions of the regulation, the Administra-
tor makes a case by case determination as to whether an alteration to a
facility constitutes a reconstruction for the purposes of the standard.
Among the factors in this decision are the extent to which the components
being replaced cause or contribute to the emissions from the facility, and
the economic obstructions to compliance inherent in the proposed change in
the plant.
2.3.3 Comment: In a comment directed toward the reconstruction and
modification elements of the proposed standard, one commenter stated that
the repair, updating, or modification of equipment should not cause the
proposed standard to be applied to that facility (D-12). This commenter
stated that application of the standard to such modifications would result
in greater emissions since a less efficient coater station might be kept in
service for a longer period of time in order to avoid imposition of the new
source standard.
Response: As provided in 40 CFR 60.14(e)(l), the routine maintenance,
repair and replacement of components of a facility would not constitute a
modification for the purpose of triggering the requirements of the proposed
standard. Such activities which are not routine would only be considered
modifications if they resulted in an increase in the emissions from the
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facility, or reconstructions if they resulted in capital expenditures
greater than fifty percent of the capital cost of a new facility. It is
true that the effect of the proposed standards could influence industry
decisions to reconstruct existing facilities. However, it is consistent
with the intent of the Clean Air Act that best technology {and its costs)
should be considered when a decision to construct is made and capital
committed. While it is possible that this could result in prolonging the
use of older equipment, the energy savings and efficiency improvements in
new technology are expected to be overriding considerations in this
industry.
2.4 ECONOMIC IMPACT
2.4.1 Comment: The commenter (D-6) stated that assumptions used as
the basis for the BID cost analysis were not consistent with current values,
The comment specifically stated that the interest rate and the cost of
silicone release coatings were incorrect. The commenter said that the BID
silicone cost of $3.50/lb was correct only for silicone coatings that will
dissolve in solvent. The cost for solventless (100 percent solid) silicone
coatings is $7.15/lb.
Response: The cost analysis for the BID was developed in 1979 and is
based on mid-1979 dollars. All assumptions used as the basis for the cost
analysis reflect prices, interest rates, and labor rates existing in
mid-1979. The cost analysis was performed once under a single set of
assumptions and was not constantly revised as economic variables (such as
interest rates) fluctuated nationwide. Economic multipliers are available
which can approximately translate the mid-1979 numbers to mid-1981 numbers.
The application of such a multiplier would yield values which are correct
for mid-1981 economic conditions.
In the BID economic analysis costs were developed for solvent-based
silicone release plants and for 100 percent solids silicone release plants.
A coating raw material cost of $3.50/lb was used for both types of plants.
A higher raw material cost of $7.15/lb for 100 percent solids silicone
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coatings was not used. In view of this comment, the economic analysis was
reexamined and the raw material cost for TOO percent solids silicone release
facilities increased to $7.15/lb. The Administrator has determined that the
use of the higher raw material cost ($7.15/lb) suggested by the commenter
would not affect the overall conclusion of the economic analysis that the
proposed standards are economically reasonable.
2.4.2 Comment: One commenter (D-7) stated that the proposed standard
would result in additional costs to be passed on to consumers. These
additional costs would have an inflationary impact on the United States
economy.
Response: The economic analysis for the proposed standard examined
two methods that affected firms could use to handle increased costs for
emissions control. The two methods examined were full cost absorption (by
the affected firm) and full cost pass-through (to the consumer). The
economic analysis determined that even if full cost pass-through were
instituted, a maximum product price increase of only 0.9 percent would
result. This impact was considered by the economic analysis to be
reasonable and noninflationary.
2.4.3 Comment: Several commenters (D-l, D-3, D-4, D-5, D-6, D-12,
F-2) stated that the new source performance standard for the pressure
sensitive tape and label industry should be based on the existing or newly
proposed regulations which are incorporated into State Implementation Plans
(SIPs). These requirements were identified during the development, of the
standard and were incorporated into Alternative I. Two commenters stated
that this alternative should be adopted in lieu of the proposed standard
because the amount of emissions reduction which would result from the
proposed standard over that accomplished under the existing regulations is
disproportional to the costs involved in achieving that additional reduction
(D-l, D-3).
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Response: EPA has made an analysis of the costs which would be
incurred as a result of the adoption of Alternative III (the proposed
standard) rather than Alternative I (the existing State regulations), and
the relative benefit derived from each in terms of reduced emissions. These
analyses are discussed in the preamble to the proposed regulation and in the
BID at Chapters 7 .and 8.
Under Alternative I emissions of VOC from pressure sensitive tape and
label facilities would be 27,400 Mg per year in 1985, whereas emissions from
those same facilities under Alternative III would only be 23,100 Mg per
year, a reduction in emissions of 16 percent.
The costs of achieving these reductions in the quantity of pollutants
emitted under Alternative III, on the other hand, are expected to be
reasonable. The increase in product price for the industry as a result of
the imposition of the standard would be less than 0.9 percent. If the
increased cost were borne by the manufacturer the return on investment for
the industry would be reduced by 1.0 percent or less. Neither of these
increases could reasonably be considered major increases in costs to
consumers or to industry. Neither could these costs or the requirements of
the proposed standard be considered significant in terms of their impacts on
the productivity or competitiveness of the industry, or on innovation in
either production or pollution control technology.
It should be noted that States have neither equivalent standards nor
standards which are in all cases as stringent as Alternative I. Thus, even
if emission reductions were less than currently projected, the proposed
standards would have the benefits intended by the Clean Air Act of
eliminating competition between States based on varying emission standards.
The proposed standards would also ensure that best technology is used on all
new sources in the industry.
2.4.4 Comment: Another comment comparing Alternative I with the
proposed standard was that Alternative I provided more incentive for the
conversion of facilities from high-solvent to low-solvent or solventless
technologies by reducing the requirements placed on new, modified, or
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reconstructed facilities which convert to these innovative technoloaies
(D-l, D-3).
Response: Because solventless technologies have no, or essentially no
emissions of VOC, these technologies will be unaffected by the adoption of '
the proposed standard or by the retention of the present SIP regulations
under Alternative I. Therefore, the adoption of the proposed standard would
have no adverse impact in the movement toward this technology by the
industry.
Low-solvent technologies are treated essentially equally by the
proposed standard and Alternative I. Because the proposed standard contains
an emissions floor of 0.20 kg VOC/kg of coating solids, the majority of
low-solvent technologies will not be required to perform any additional VOC
control. No further control would be required because the level of VOC
emissions from these technologies is expected to fall below this emissions
floor.
Further, it was determined that economic factors outside of the
operation of this proposed standard (such as high solvent costs, other
regulations, and the increasing availability of low-solvent technology) made
these innovative technologies sufficiently attractive that the costs of
compliance with this standard would not adversely affect this conversion.
2.4.5 Comment: Four commenters stated that the economic analyses of
the costs and effectiveness of the proposed standard are insufficient,
particularly with reference to the impact of the regulation on small
facilities (D-l, D-2, D-3, D-4).
Response: Chapter 8 of the BID contains an analysis of the costs and
economic impacts of this proposed standard on the pressure sensitive tape
and label industry. This analysis was thorough and detailed, examining the
relevant facets of the pressure sensitive tape and label industry. The
market for tape and label products was examined as well and the performance
of elements of the industry during variations in that market. The costs
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which would be incurred by the industry and the impact on the tape and label
industry of changes in prices for materials, processes, and finished
products were examined for each of three regulatory alternatives.
The economic impact of the proposed standard on the pressure sensitive
tape and label industry was analyzed for small facilities specifically, as
well as large and medium facilities. Further, the inflationary impacts of
the proposed regulatory alternatives were computed and analyzed. As a
result of these efforts, it was determined that the proposed standards could
be attained at reasonable costs to all size plants in the industry and to
the economy at large.
The economic analyses and the examination of the cost effectiveness of
the proposed standards are necessarily representative rather than inclusive
of every facility in the industry. It is the Agency's conclusion that the
population of facilities reviewed and the assumptions and data used in the
course of this analysis accurately reflect the economics of the industry and
its operation under the standard.
2.4.6 Comment: One commenter (D-5) states that the standard should be
applied to a facility only after a case-by-case analysis of the costs and
benefits of the standard had been performed for each facility. Adding this
flexibility to the standard, the commenter maintained, would encourage the
development of low-solvent coatings.
Response; The regulatory program established by Section 111 of the
Clean Air Act requires that standards be established for categories of
sources which are found to contribute to air pollution, and requires the
Administrator to publish a list of categories that are to be the subject of
standard setting. Section lll(b)(2) allows the Administrator to establish
subcategories and classes of sources for the application of the standard,
but at no point does this section indicate that standards may be developed
or made applicable on an individual facility basis. The various typical
subcategories of the pressure sensitive tape and label industry were
examined in the preparation of the standard (based on size and technology
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employed) and the application of the standard to these subcategories of the
industry were determined to be reasonable on a technological, economic, and
environmental basis. Further, it is not expected, on the basis of this
examination, that any individual plant within the industry would vary from
these models to the extent that the application of the standard would be
made unreasonable.
Further, the proposed standard does provide flexibility for the
affected facility. This flexibility lies in the fact that the level of
control required of a facility is determined by the VOC content of its
coatings. According to the formula stated in the proposed standard for
determining the percentage reduction of emissions required of a facility,
the lower the VOC content of the coating, the lower the requirement for the
reduction of those emissions. Therefore, the operator of an affected
facility can exercise control over the level of control required of his
facility by his choice of the types of coatings used.
2.5 AFFECTED FACILITY DEFINITION
2.5.1 Comment: In the preamble to the proposed standard, at 45 FR
86280, the Agency solicited comments from industry and other interested
parties on the definition of "affected facility" .contained in the proposal.
Several commenters, both at the hearing and in subsequent letters, stated
that the definition should be broadened from each individual coating head
and accompanying drying oven to include the entire coating line from the
unwinding of the web to rewind after all coating procedures have taken
place.
The broadened definition would allow the emissions from several coating
heads and drying ovens on the same line to be averaged together for the
purposes of determining compliance. In this way, emissions from one coating
head/drying oven could be above the standard if emissions at a second are
sufficiently below the standard. This, according to the commenters, would
encourage the development of solventless of low-solvent coatings which would
be used to offset the need for add-on controls for high solvent coatings
used on the same line. The commenters maintain that this approach would
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offer the potential for significant cost savings and added flexibility
while, not increasing emission levels above that which would be achieved
under individual affected facility standards (D-6, D-8, D-12, F-l, F-2).
Response:
Upon consideration of these comments and the issues raised by the
definition of affected facility contained in the proposed standard, the
Administrator has determined that the definition of affected facility should
be amended in the promulgated standard to encompass the entire coating line,
including all individual coating heads and drying ovens on one line, from
unwind to wind.
An analysis of the points raised in the comments on this issue and of
new data submitted by the industry has revealed that the conclusion that the
proposed narrow definition would result in greater emissions reduction is no
longer supportable. These new data show that the relative cost of low-
solvent technologies has changed since the BID was prepared and that new
low-solvent adhesive systems are now more costly than comparable solvent-
based adhesive systems which are now in use.
Consequently, the narrow definition, which has the effect of imposing
the additional cost of precoat controls on new or modified lines which use
low-solvent adhesive technologies, would encourage continued use of existing
solvent-based adhesive facilities and discourage the construction of new
low-solvent facilities. In contrast, under the broad definition, precoat
facilities would not need to be controlled if the emissions from the
complete line are below the standard. This results-in a significant cost
savings and creates an incentive for the construction of new, low-solvent
adhesive facilities. New lines involving low-solvent facilities would have
significantly lower emission rates than existing solvent-based lines, and
equal or lower emission rates than new solvent-based lines. In view of the
cost incentive for the construction of new low-solvent lines, it is
reasonable to conclude that the broad definition will result in greater
emission reduction than the narrow definition. Therefore, the Administrator
has determined that the definition of an affected facility adopted in this
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standard shall include the entire coating line, including all individual
coating heads and drying ovens in one line, from unwind to wind.
2.6 REPORTING AND RECORDKEEPING
2.6.1 Comment: Several commenters (D-2, D-3, D-7, D-12) feel that the
recordkeeping and reporting requirements of the proposed standards are
onerous, complex, and costly in terms of the resources required. Two of the
three commenters (D-7 and D-12) went on to say that the recordkeeping and
reporting requirements of the proposed standards would deter the development
and use of innovative low-solvent coatings because their use would bring a
facility under the recordkeeping and reporting requirements of the standard.
Response: EPA has been investigating alternative ways of reducing
monitoring, recordkeeping and reporting burdens on owners and operators.
The goal is to reduce all recordkeeping and reporting that is not essential
to ensuring proper operation and maintenance. After reviewing the require-
ments in the proposal, EPA determined that monitoring and compiling data are
essential for both the owner or operator and EPA to ensure proper operation
and maintenance, and compliance with the standard. A responsible owner or
operator would need monitoring information compiled in a useable form to
determine when adjustments in the control system are needed to ensure that
it is performing at its intended effectiveness level. EPA is therefore
requiring only the additional step of filing the information in an access-
ible location. Because EPA judges that monitoring and recordkeeping are
essential for proper operation and maintenance, these requirements have not
been changed since proposal. However, in its review of the reporting
requirements EPA determined that a reduction in the number of exceedance
reports required per year was warranted. Therefore, in the promulgated
standard owners and operators are only required to semi annually report
instances when the temperature fluctuations of an incinerator control device
and the VOC emissions of an affected facility exceed the allowable levels
established in the standard. The requirement to only report exceedances
semi annually reflects a reduction from the proposed schedule of calendar
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monthly reporting. These reporting requirements may be waived in States
where the program has been delegated, if EPA, in the course of delegation,
approves reporting requirements or an alternative means of facility surveil-
lance adopted by the State. Such facilities would be required to comply
with the requirements adopted by the State. The other proposed reporting
requirement involving the reporting of initial and any subsequent perfor-
mance test results to the Administrator has not been changed since proposal.
The Administrator does not believe that the recordkeeping and reporting
requirements of the proposed standard would deter the development and use of
low-solvent coating technology. The supporting rationale for the use of
low-solvent coatings, presented in the response to Comment 2.7.1, would
apply in this case. The use of low-solvent coatings would not, in and of
itself, constitute a modification since the use of low-solvent coatings
would not ordinarily result in an increase in VOC emissions, but instead in
a reduction in those emissions. Such a conversion might, however,
constitute a reconstruction of the facility under the definition stated in
40 CFR 60.15 if the capital costs of the conversion exceeded fifty percent
of the capital costs of a new facility.
Under the reconstruction provisions of the regulation, the Administra-
tor makes a case-by-case determination as to whether an alteration to a
facility constitutes a reconstruction for the purposes of the standard.
Among the factors in this decision are the extent to which the components
being replaced cause or contribute to the emissions from the facility, and
the economic obstructions to compliance inherent in the proposed change in
the plant.
2.6.2 Comment: One of the comment letters (D-7) stated that affected
coating lines using low-solvent or totally solvent-free coatings should be
exempt from all sections of the proposed standards, including the record-
keeping and reporting requirements. The commenter felt that mandatory
compliance with the proposed standards, for these types of coatings, would
be unnecessary and irrelevant.
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Response: All coatings with a VOC content less than 0.20 kg VOC/kg of
coating solids would essentially be exempt from all requirements of the
proposed standards except those involving recordkeeping of coating use. The
Administrator must have some mechanism by which he can determine when an
affected facility uses a compliance coating. For EPA to make this determi-
nation the affected facility must keep records of what types of coatings are
used. Based on the Administrator's knowledge of the use of low-solvent
coatings, the inability to consistently run all products using low-solvent
coatings forces a coater to switch a line back and forth between solvent-
based and low-solvent coatings. Without adequate recordkeeping of the use
of low-solvent coatings neither the Administrator nor the affected facility
would ever know when the affected facility was subject to the emission
limits of the proposed standard.
As stated in the response to comment 2.6.1, only the reporting of
performance test results and exceedances will be required in the final
regulation. Once the performance test is passed, it is highly unlikely that
coaters using low-solvent coatings will ever have to report anything to EPA.
2.7 SMALL SOLVENT USE EXEMPTION
2.7.1 Comment: One of the comment letters (D-5) stated that small
PSTL production sources should be exempted from compliance with the proposed
standard. The commenter felt that the 15 megagram per year exemption limit
in the proposed standard is unreasonably stringent and should be modified to
exempt small production sources. The commenter went on to state that small
sources should be exempted from the proposed standard because: small
sources contribute a "de minimis" portion to the total industry VOC
emissions, the cost for emission control devices is unreasonable for small
sources compared to potential benefits, and it would encourage the develop-
ment of low-solvent type coatings.
To support the "de minimis" argument for an exemption, the commenter
referenced two sources of information which discuss VOC emissions and the
percentage of emissions which each facility size contributes. One of the
referenced sources was an article in the August 1979 issue of Paper, Film,
and Foil Converter. This article contained a summary of a study which was
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done on VOC emissions from the flexographic printing industry. This study
concluded that facilities with VOC emissions less than 250 tons per year
emit less than 7.6 percent of the total VOC emissions from the flexographic
printing industry. The comment letter (D-5) stated that all conclusions
made in this study concerning the flexographic printing industry are equally
valid for the PSTL industry.
The second source of support for the "de minimis" argument is data
which the commenter states were compiled by the Association of Industrial
totalizers, Coaters, and Laminators (AIMCAL). These data show that two
percent of total PSTL industry VOC emissions are contributed by facilites
with VOC emissions less than 250 tons per year.
Response: The Administrator does not believe that the "de minimis"
argument is a valid rationale for exempting small sources. If it is
technically and economically feasible for small production sources to be
controlled, the Clean Air Act requires that they be controlled. In addi-
tion, it is the Administrator's view that a small source exemption (or the
lack of one) from the proposed standard will not be a determining factor in
whether affected facilities will change a product over to low-solvent or
solventless technology. Based on currently available information, the
Administrator believes that when sufficient technical and economic incen-
tives exist to induce changeovers to low-solvent or solventless technolo-
gies, the change will be made regardless of the existence (or nonexistence)
of an exemption.
However, the Agency has reanalyzed the cost effectiveness (i.e., the
cost of VOC emissions control relative to the emission reduction which is
achieved by such controls) over the range of line sizes found in this
industry. For each type of line, annualized control costs were calculated
and compared to the emission reductions which would occur if potential,
uncontrolled emissions are reduced to the level of the standard. This
analysis showed that the cost effectiveness of controls is primarily a
function of the quantity of solvent used, and that the parameters are
inversely related. That is, as solvent use (and therefore potential
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emissions) increases, the cost effectiveness decreases. It should be noted
that this cost curve does not necessarily represent the actual amounts of
money that will be spent to install and operate VOC controls for any
particular coating line. Rather, the costs are estimates which are repre-
sentative of facilities likely to be built. The costs for a VOC control
system will vary according to coating line size, system airflow rate,
solvent loading level, the lower explosive limit levels maintained in the
oven, the degree of solvent or heat recovery practiced, and other'factors.
However, the cost curve provides a useful guide for judging the reasonable-
ness of requiring VOC controls at different potential VOC emission levels.
In the past, the maximum estimated cost per megagram of pollutant
material removed (VOC, particulate matter, SO,,) has ranged from somewhat
less than $1,000 to $2,000. This package has a maximum estimated cost per
megagram of $2,000. In prior source categories for which NSPS have been
developed, VOC maximum estimated control costs have generally not exceeded
$1,000 per megagram. In this case, because of the "worst case" character of
the cost calculations, EPA believes the proposed standards are reasonable.
The maximum estimated cost in this package will not be viewed as a
precedent for future actions. Instead, in the future, we will continue to
evaluate each package on an individual basis.
The cost curve for the'application of VOC controls to coating lines
shows that the potential cost per Mg of VOC controlled is greater than $2000
for input solvent levels of about 45 Mg (50 tons) per year or less.
Therefore, in the promulgated standard, coating lines which input to the
coating process 45 Mg (50 tons) per 12 month period or less of VOC will not
be subject to the standard's emission limits. These lines will, however, be
subject to all applicable recordkeeping and reporting requirements given in
the standard.
2.8 LEVEL OF PROPOSED STANDARD
2.8.1 Comment: One commenter (D-5) stated that the 90 percent reduc-
tion of VOC emissions in the proposed standard seemed to be an arbitrary
figure.
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Response: The Administrator's choice of the 90 percent overall VOC
emission reduction was not an arbitrary one. The 90 percent reduction level
was selected because it represents the highest VOC emission reduction
reasonably achievable by plants using the best demonstrated VOC emission
control system. In determining the 90 percent control level and the best
demonstrated control system, environmental, energy, and economic impacts
were considered. Chapters 7 and 8 of the background information document
examine these three impacts.
The basis for the proposed 90 percent overall VOC emission reduction is
explained in the preamble to the proposed standard (45 FR 86281). The
analyses presented in the preamble contain an examination of two aspects of
emission control, capture system efficiency and control device efficiency.
In the proposed standard overall VOC emission reduction efficiency is
defined as control device efficiency times capture system efficiency. The
commenter's letter seemed to indicate some degree of misunderstanding on how
capture, control device, and overall control efficiency were defined and how
these concepts were combined to determine the 90 percent control level. A
capture efficiency and a control device efficiency of 95 percent each were
determined to be reasonable after studying the VOC control systems of
well-controlled existing tape and label facilities. The product of these
efficiencies (0.95 x 0.95) is 90 percent overall control.
Data on well-controlled tape and label facilities indicate that overall
VOC emission reductions as high as 93 percent are achievable. However, the
Administrator does not believe that 93 percent overall control is a
reasonable emission reduction level that could be achieved continually over
a long term period. The Administrator does believe that 90 percent overall
emission control represents the control level achievable on a continual
basis by the best demonstrated system of emission reduction.
2.8.2 Comment: One commenter (D-6) stated that the oven exhaust air
turndown ratio of 10 to 1, discussed in the BID, was not achievable. Turn-
down ratio refers to the degree by which oven exhaust air can be reduced
from design exhaust levels in response to reduced solvent loadings. The
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commenter felt that the best achievable ratio was 4 to 1. The inability to
turndown the oven exhaust sufficiently would result in higher air volumes
than necessary for a certain quantity of solvent. The excess air causes
reduced VOC concentrations to be sent to the control device and consequently
the control device has a lower reduction efficiency. According to the
commenter, this problem is the most difficult when coating lines are
operated at slow line speeds (40 feet per minute). The commenter recom-
mended a reduction in the level of the proposed standards from 90 to
85 percent overall VOC control citing the inability to achieve a 10 to 1
turndown ratio as the reason for the decreased control efficiency
achievable.
The commenter was contacted by telephone (E-8, E-9) to clarify the
reasons for the low turndown ratio. Several reasons were given: (1) oven
air balancing problems due to leaks in seals and other oven equipment,
(2) minimum air flows required to keep ovens at negative pressure to prevent
solvent leakage back into the coating room, (3) limited ability to close
dampers due to insurance regulations, and (4) additional combustion air
required in ovens with natural gas burners.
The commenter noted that his company had purchased a coating system
from the equipment vendor referenced in the BID (EPA-450/3-80-003a, p. 4-23,
reference 23) who stated that a 10 to 1 ratio was achievable. However, the'
purchased system has never achieved a turndown ratio greater than 4 to 1.
ResP°nse: The turndown ratio reported in the BID was determined by
contacting drying oven equipment vendors serving the PSTL industry. These
contacts indicated that turndown ratios of 10 to 1 were possible. The BID
clearly references the source of the 10 to 1 ratio statements.
As a result of this comment, the vendor contact referenced in the BID,
that quoted the 10 to 1 turndown ratios, was recontacted (E-7) in order to'
verify that such turndown ratios are achievable. The vendor reported that
10 to 1 ratios (and even 15 and 20 to 1) are achievable with oven exhaust
air flows. However, he did indicate that several operating conditions may
be present in a coating system that prohibit the turndown from exceeding 4
to 1. The primary conditions mentioned were frequent or excessive system
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leakage problems, insurance regulations limiting the degree of damper
closure, and the minimum flow requirements needed to keep solvent vapors
from flowing out of the oven into the coating room. These reasons are
noticeably similar to those given by the commenter in his explanation of why
low turndown occurs. The vendor stated that the problems and conditions
mentioned by the commenter (D-6) could effectively make 4 to 1 the highest
turndown achievable for that particular system. He emphasized that the
determination of turndown ratios was very case-specific and depended heavily
on the complexity of the coating line.
The effect of turndown ratios on control efficiencies was analyzed by
EPA during the development of the proposed standards. Generally, the
technical points made by the commenter are valid (especially for his
particular facility). However, it is the Administrator's position that a
new coating line, designed and operated properly, with the best system of
control, can achieve the level of the proposed standard even with a 4 to 1
turndown.
A plant trip was made to the commenter's facility during the develop-
ment of the proposed standards. It was learned that lower levels of solvent
are being applied than the plant was optimally designed for. This non-
optimum design results in excess air flows and low LEL levels. High turn-
down would be difficult to achieve with this overdesign condition.
An examination of the commenter's emission reduction calculations at a
4 to 1 ratio indicates that the efficiency of the control device and the
overall VOC control efficiency would meet the levels of the proposed
standard if the control equipment was operated at its optimum capability.
The commenter indicated that a low LEL (8% or 960 ppm) gas stream would
exist in the inlet to the control device. The VOC in this stream would be
reduced to an outlet concentration of 120 ppm which would be indicative of a
control device efficiency of 87.5 percent. However, a closer study of the
commenter's data revealed some apparent inaccuracies. First, the 8 percent
LEL figure on the control device inlet stream should be 12.2 percent to be
consistent with other data presented in the comment. A 12.2 percent LEL
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equals an inlet concentration of 1464 ppm. If the outlet concentration
remained at 120 ppm, a control device efficiency of 91.8 percent would be
indicated. Secondly, after contacting the commenter (E-9), it appears that
the reported outlet concentration of 120 ppm is misleading and is not
representative of best technology. The commenter indicated on the telephone
that the 120 ppm figure is the automatic setpoint at which his carbon beds
start steam regeneration and, therefore, is the maximum outlet concentra-
tion. The average VOC outlet concentration would have to be significantly
lower than the 120 ppm value. Therefore, by correctly calculating the
control device efficiency by using the average VOC outlet concentration
(estimated at 65 ppm) and not the breakthrough setpoint concentration, an
efficiency of 95 percent could be obtained. The Administrator believes that
the commenter's control device efficiency of 87.5 percent is not representa-
tive of the best system of continuous emission reduction, which requires
that the emission control device achieve 95 percent efficiency over a month
Further contact with the commenter (E-9) indicated that the carbon adsorber
was not being operated at its peak control efficiency.
Data developed during the tape and label NSPS study show that even
though lines may run at slow speeds and have consistently low LEL (10% and
less) gas streams going to a control device, high reduction efficiencies can
be achieved. EPA has presented data in BID-Volume I which show a PSTL
facility operating small lines (28 inch width) at an average line speed of
about 45 feet per minute and an LEL level less than ten percent. This
facility achieved a 93 percent overall emission reduction (over a four week
period) and a carbon adsorber operating efficiency of approximately
97 percent. Based on the favorable experiences of other coaters with condi-
tions similar to those of the commenter, the Administrator believes that the
problem of limited turndown ratio can be solved to the extent that affected
facilities would be able to comply with the proposed standards.
2.8.3 Comment: One commenter (D-6) believed that the proposed mass
emission limit of 0.20 kg VOC/kg of coating solids applied should be raised
to 0.25 kg VOC/kg of coating solids applied. The commenter was contacted by
2-27
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telephone (E-8) to better understand the reasons for the requested change in
the standard. Although not providing any definite technical support for the
change, the commenter believed that a limit of 0.25 kg VOC/kg coating solids
would provide more flexibility and more incentive to coaters to use low-
solvent (emulsion) coatings.
Response: During the development of the proposed standards, the EPA
studied several types of low-solvent coatings. Several of these coatings
were examined and tested and each met the proposed 0.20 level. The Adminis-
trator believes that the 0.20 kg VOC/kg coating solids level achieves
emission reductions comparable to those of solvent-based systems required to
achieve 90 percent overall control. The 0.25 kg VOC/kg of coating solids
level achieves only an 87.5 percent reduction when compared to that required
from the average solvent-based facility. The Administrator has determined
that emission reductions down to 0.20 kg VOC/kg coating solids are reason-
able considering economic and energy requirements. The commenter presented
no definitive information contradicting this determination.
Though some individual low-solvent coatings may not, by and of them-
selves, achieve the 0.20 kg limit, such coatings would still be useful in
PSTL applications. When used on a line with other low-solvent coatings over
a month time period, coatings in the 0.25 kg VOC range would help keep the
monthly compliance average below 0.20. When used on a line with other
solvent-based coatings over a month time period, coatings in the 0.25 kg VOC
range would significantly reduce the required level of control for the line.
During the first public comment session on December 13, 1979 at
National Air Pollution Control Techniques Advisory Committee (NAPCTAC)
meeting, the largest manufacturer in the PSTL industry stated that the
0.20 kg VOC/kg coating solids level was reasonable.
2.9 NSPS AND SIP COORDINATION
2.9.1 Comment: Two commenters suggested that the implementation of
the new source standards for the pressure sensitive tape and label industry
be delayed for five to ten years in order to determine the benefits to be
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derived from the newly recommended limit for SIPs of 2.9 pounds of VOC for
every gallon of applied coating (D-6, D-12).
ResP°nse: The Projected impact that the requirements of the SIP
regulations will have on emissions from pressure sensitive tape and label
facilities has been included in the analyses that led to the development of
this proposed standard. These regulations form the baseline against which
the regulatory alternatives have been compared. The costs and benefits of
continued operation under the SIP regulations alone have been calculated, as
well as the expected reduction in pollutant emissions under the SIPs. The
outcome of the comparison of these regulations to the proposed standard is
the Administrator's determination that the proposed standard is based on the
application of the best demonstrated system of control technology, '
considering costs, nonair quality health and environmental impacts, and
energy requirements. Further delay in the adoption of this standard in
order to determine the effects of the SIP regulations is not necessary
since these effects have already been considered by the Administrator and
constitute a major portion of the analysis that supports the proposed
regulation.
2.9.2 Comment: Two commenters (D-2 and D-12) thought that there were
conflicts between the requirements of the proposed standard and some SIP
regulations. In particular, there are conflicts between the units of the
proposed standard (kg VOC/kg coating solids) and the units of many SIP's
(pounds/gallon of coating minus water). The commenters felt this conflict
put affected facilities in a position of having to choose between compliance
with conflicting regulations.
Response: EPA developed the mass/mass format of the standard to clear
up some of the problems that PSTL companies had encountered in interpreting
and implementing the mass/volume SIP's. Contacts and discussions with the
industry during the development of the proposed standard indicated that a
mass/mass format was familiar to and extensively used throughout the PSTL
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industry. The mass/mass format is much simpler to understand and generally
can be determined from typical coating formulation data. Although expressed
in the proposed standard as kg VOC/kg coating solids, the format of the
emission limit is not designed to be in metric units as one commenter (D-12).
noted. The proposed emission limit is simply a ratio of the mass of VOC to
the mass of coating solids. The units of the ratio are irrelevant.
Affected facilities will not be put in the position of having to choose
between compliance with conflicting regulations. Firms will always have to
comply with the most stringent applicable regulation be it SIP or NSPS. The
EPA expects that most States will be delegated the authority to enforce the
NSPS, thus further reducing any possible conflict.
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REPORT,
1. REPORT NO! : ^><™*'e«u instructions on the reverse ,
, .EPA-45n/3-an-nn^
[4. TITLE AND SUBTITLE
Pressure Sensitive Tape and Label Surface Coating
Standard" Background Information for Promulgated
7. AUTHOR(S)
». INFORMING OHGANIZAT.ON NAME AND ADDRESS"
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air, Noise and Radiation
U.S. Environmental Protection Agency
Dac-^^ vt,*-.U "Tt«~ — *i _ r\ i •. , , _ ^ **
North Carolina 27711
3. RECIPIENT'S ACCESSION NO."
s. REPORT DATE"
September 1983
6. PERFORMING ORGANIZATION CODE~
8. PERFORMING ORGANIZATION REPORT NoT
10. PROGRAM ELEMENT NO."
1. CONTRACI/GRANT NO.
68-02-3058
3 TYPE OF REPORT AND PERIOD COVERED
r 1 Del I
4. SPONSORING AGENCY CODE
EPA/200/4
pie. ABSTRACT"
posal of the regulations.
This document
the date of
———
DESCRIPTORS
Air pollution
Pollution control
Pressure sensitive coating
Pressure sensitive tape and label coatinq
lines ' y
Release coatings
Volatile organic compound (VOC) emissions
"18. DISTRIBU f ION STATEMENT
Unlimited
KEY WORDS AND DOCUMENT ANALYSIS
b.lDENTIFIERS/OPEN ENDED '
EPA Form 2220-1 (Rev A
I (Kev. 4-7
PREVIOUS EDITION IS OBSOLETE
Air pollution control
a. SECURITY CLASS (This Report/
zo. SECURITY CLASS (Thispage)
Unclassified
c. COSATl Field/Group
13.B .
21. NO. OF PAGES
3|
22. PRICE
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