New Source Performance Standards-
    Pressure Sensitive Tape and Label Surface Coating Operations
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.
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
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
                              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
 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

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

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

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
                         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-

                         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

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.
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.