&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

-------
'•**;.


-------
                                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

-------
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

-------
                       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

-------

-------
                                  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
                                     1-1

-------
 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
                                     1-2

-------
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
                                     1-3

-------
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
                                     1-4

-------
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.
                                     1-5

-------
     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.
                                     1-6

-------
                                   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.
                                     2-1

-------
                                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
                                   2-2

-------
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
                                  2-3

-------
      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
                                     2-4

-------
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.
                                     2-5

-------
      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.
                                     2-6

-------
      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.
                                     2-7

-------
 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
                                     2-8

-------
 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
                                     2-9

-------
 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
                                    2-10

-------
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
                                    2-11

-------
 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
                                    2-12

-------
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).
                                    2-13

-------
     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
                                    2-14

-------
  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
                                    2-15

-------
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
                                     2-16

-------
  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
                                    2-17

-------
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
                                      2-18

-------
 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
                                    2-19

-------
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.
                                      2-20

-------
       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
                                    2-21

-------
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
                                      2-22

-------
  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.
                                    2-23

-------
     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
                                      2-24

-------
  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
                                    2-25

-------
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
                                      2-26

-------
  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

-------
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
                                      2-28

-------
  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
                                    2-29

-------
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.
                                      2-30

-------
   	                                   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

-------

-------

-------
bl J - .. C

hgggs

I O-TD.C
COO) 2C

O3 -•
Q Q) O
  3-"
                                                                                                         >mc



                                                                                                         111
                                                                                                         q O Q.
            » s
            i.
            03

            a

-------