— New Source Performance Standards-
Pressure Sensitive Tape and Label Surface Coating Operations
Impacts
(continued)
The maximum increase expected in national solid
waste, resulting from the NSPS, would be 55 metric
tons per year by 1985.
Economic: Only minimal economic impacts on the
PSTL industry are anticipated from the proposed
standards. A savings is possible if carbon adsorption
is used to control emissions because of a credit for
usable recovered solvent offsetting recovery costs.
The expected price increase resulting from the NSPS
would be a maximum of 0.9 percent. The anticipated
incremental annualized cost of compliance, including
depreciation and interest would be 2.6 million dollars
nationwide in 1985. Large facilities would be af-
fected more than mid-sized and smaller plants, but
not enough to make large plants less competitive. No
significant changes in industry structure, growth or
profitability are expected.
Public
Participation
A public hearing on the proposed regulation is sched-
uled for January 30, 1981 at 9 a.m. at the EPA Office
of Administration Auditorium at Research Triangle
Park, N.C. Invited to participate are individuals wish-
ing to present additional data, views, or other com-
ments on this NSPS regulation, especially concerning
the definition of affected facilities. Those wishing to
speak at the hearing should contact Naomi Durkee,
Emissions Standards and Engineering Division (MD-
13), U.S. EPA, Research Triangle Park, N.C. 27711,
telephone (919) 541-5271, by January 23, 1981.
Written comments will be accepted on or before
March 2,1981, and should be addressed to: Central
Docket Section (A-130), Attention: Docket Number
A-79-38, U.S. EPA, 401 M Street SW, Washington,
D.C. 20460. The docket is open for inspection and
contains all information considered by EPA during
the development of this standard.
The Background Information Document, "Pressure
Sensitive Tape and Label Surface Coating Industry,
Background Information Document for Proposed
Standards" (EPA-450/3-80-003a), is available from
the EPA Library (MD-35), Research Triangle Park,
N.C. 27711, telephone (919) 541-2777.
Status of
Regulation
This proposed NSPS was published in the Federal
Register December 30, 1980, (45FR86278). A pub-
lic hearing is scheduled January 30, 1981, and the
final regulation is expected around December, 1981.
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United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
January 1981
New Source Performance Standards
Pressure Sensitive Tape and
Label Surface Coating Operations
Proposed Regulation
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-New Source Performance Standards
Pressure Sensitive Tape and Label Surface Coating Operations
New Source
Performance
Standards
The Clean Air Act, as amended in 1977, calls for a
comprehensive national program to reduce air pol-
lution and improve air quality. The act requires the
U.S. Environmental Protection Agency (EPA) to
establish nationwide emission standards for selected
new stationary industrial sources. These New Source
Performance Standards (NSPS), in accordance with
Section 111 of the Act, are designed to prevent new
air pollution problems. NSPS apply to categories of
new, modified, or reconstructed stationary sources
that cause or contribute significantly to air pollution
that could endanger public health or welfare. The
recently proposed NSPS for pressure sensitive tape
and label (PSTL) surface coating operations is dis-
cussed below.
Pressure Sensitive
Tape and Label Surface
Coating Operations
Section 111 of the Clean
Air Act requires EPA to
identify stationary sources
which are major contribu-
tors to air pollution. EPA
has ranked the paper coat-
ing industry as the fourth
highest priority stationary
source of nationwide or-
ganic emissions to be con-
trolled for air pollutants. Pressure sensitive tape and
label (PSTL) surface coating operations make up the
largest source of emissions within the paper coating
industry.
The PSTL industry coats paper, cellophane, cloth or
other backing materials to create a tape or label that
sticks on contact, without wetting or heating. During
the process of applying organic solvent-based coatings
to the tape or label material, volatile organic com-
pounds (VOC) are emitted. PSTL manufacturing is
the largest segment of the paper coating industry
using organic solvents.
VOC react in the atmosphere to form ozone, which
irritates the eyes, impairs respiratory function, da-
mages plant tissue and deteriorates rubber and other
materials.
In 1978, PSTL operations emitted an estimated
600,000 metric tons of VOC nationwide, in con-
trast to about 2 million metric tons of VOC emis-
sions from all industrial surface coating operations.
Currently, 80 to 85 percent of all PSTL operations
use organic solvent coatings. But EPA predicts that
by 1990 only 10 percent of all coatings used by the
PSTL industry will be organic solvent-based coatings,
reducing VOC emissions to 91,000 metric tons per
year. This decline is anticipated because of the in-
creasing availability of low-solvent coatings, the high
cost and dwindling supply of organic solvents, and
increasing regulation of solvent use.
The major source of VOC emissions in PSTL plants is
the drying/curing oven, where 80 to 95 percent of the
solvent is evaporated and vented to the atmosphere or
to a control device. The other primary source of
VOC is fugitive emissions, which escape directly into
the atmosphere without passing through a stack. The
affected facility is defined as an adhesive, release or
precoat coating head, its associated drying/curing
oven, and the flash-off area between the coating head
and oven. VOC emissions from formulation, storage
and cleanup operations are not included in the stand-
ard because they are very low. Other parts, such as
wind and rewind operations are not VOC emission
sources.
The NSPS for PSTL operations would cover only new
facilities that are substantially modified or recon-
structed. Certain physical or operational changes re-
sulting in increased emission rates are considered
modifications. If the cost of component replacement
in an existing source is more than 50 percent of the
cost to construct a new source, the replacement could
be considered a reconstruction.
Setting Standards
to Limit Emissions
The proposed NSPS would apply to new, modified
and reconstructed PSTL surface coating operations
for which construction began after December 30,
1980. The proposed standards would limit VOC
emissions to 0.20 kilograms of VOC per kilogram
of coating solids applied, or a 90 percent overall
VOC emission reduction.
Coating operations which emit less than 125 kilo-
grams per day or 15 megagrams (metric tons) of or-
ganic solvents per year would be exempt from the
proposed standards. Records would be required to
verify eligibility for this exemption.
If controlled only through
existing state standards,
yearly VOC emissions
would be about 27,400
metric tons in 1985, or 80
percent less compared to
uncontrolled operations.
The proposed standards
further would reduce VOC
emissions to about 23,100
metric tons nationwide in 1985, a 90 percent reduc-
tion beyond emissions from uncontrolled facilities
and a 16 percent reduction beyond state standards.
Achieving and
Maintaining the
Standards
The proposed NSPS reflect
the best demonstrated sys-
tem of continuous emis-
sion reduction, considering
costs, health, environmen-
tal, energy and other im-
pacts unrelated to air qual-
ity.
Techniques for reducing
most VOC emissions include use of low-solvent
coatings or control equipment. Use of low-solvent
coatings is the best alternative when considering
environmental impacts. Available for both adhesives
and releases, they can be purchased as waterborne,
emulsion or 100 percent solids formulations. Advan-
tages of low-solvent coatings include low cost, good
viscosity at a high solids content, and negligible air
pollution, toxicity or fire hazards. However, use of
low-solvent coatings for some operations do have
some technical problems, and cannot be applied in
all cases.
Carbon adsorption and thermal incineration are con-
trol devices that have been used successfully to con-
trol VOC emissions. A carbon adsorption unit re-
quires filtering to reduce carbon bed fouling. The
solvent that is captured by a carbon adsorption unit
can be reused or reprocessed. Cost effectiveness of
thermal incineration can be improved by adding heat
exchange equipment to recover heat for heating work
areas.
To determine compliance with the proposed standard,
EPA is proposing the use of two reference test meth-
ods, Reference Method 24 and Reference Method
25. Reference Method 24 would determine the VOC
content of the coatings, and Reference Method 25
would measure the VOC concentration in exhaust gas
streams. However, manufacturers' formulation data
can also be used to determine monthly compliance.
The owner or operator is required to report any viola-
tion exceeding VOC emission limits within 10 days of
the end of the month. The owner or operator is also
required to report any incinerator temperature devia-
tion exceeding that allowed in the proposed standard
within 10 days of the end of the month.
Impacts
Energy: Total industry-wide energy use is expected
to decline in the next decade because of the trend
toward more energy efficient, low-solvent coatings.
Nationwide energy impacts from the proposed NSPS
will depend on the specific type of VOC emission
control selected. Use of low-solvent coatings would
have the most beneficial energy impact and would
reduce energy usage. A potential nationwide net
energy savings of 27,100 barrels of oil per year could
result if all PSTL facilities were to use carbon adsorp-
tion because of recycling of usable recovered solvent.
Use of thermal incineration, however, could require
an estimated 31,000 additional barrels of crude oil
per year. The actual impact would most likely range
between the two extremes.
Environmental: The pro-
posed standards would re-
duce yearly VOC emissions
by 1985 to 23,100 metric
tons, or 90 percent below
that expected from totally
uncontrolled facilities.The
proposed standards would
reduce VOC emissions by
4300 metric tons or 16 per-
cent beyond the amount expected from facilities con-
trolled to state standard levels. National wastewater
discharges would increase by 13 percent (661,000
gallons). The solid waste impact of the proposed
NSPS would be small compared to existing plants.
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