— 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. OOC$ 3«n BIBAUJ JO) ssauisng |epi|jo 9EE Vd3 piej saaj pue a6eiso,j I ILLZ ON '>| a|6ueiji ipjeasay Aoua6v IB1U3UJUOJIAU3 ?-°Z*ll. V^figol. S £»=• "?fpB§ yflsi1!? ft*! CLCrt O S rr 9 O ^ 3T i -. "i fp 5 3-C 3 *^»O • H. ^ — • J* • 5'" 3 3! 5 § o ,u w — iu ^^ »*• _ ^.- — _. :T"* C^ * ^^ li^Uil? So'^^-i1 i1 ? lHr«i| ^"iss» 2 -* g-o§>? Sil 238 cB.5 3 | 3 wi re har nal of t ent syst EPA is ch of natio I 01 7 I & x " o S' ° 3 £ c S & •5 * a •O ~ Q) " "8 I! 3'S 1? It 3 ^ — <5 ~ H » S -S « 5 a a-p * ° T ~ 8 " •o 8 ^11° z CT 0) Q) (B O) " Q. rr -• " " » 9 n " ?3 2 -I C 0> 8 Ml 3- > - „ C <0 w S 3 § 2. » o. « 5 S 2^83 s;I!' ~ -K w u. as? ? - 3 3 o. 3" C » 3 » ^- 3 3 a, s •* e 5 3. < a ~ » o i? vxEPA 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 ------- -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. ------- |