Control Techniques Guidelines for
Paper, Film, and Foil Coatings

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                                  EPA 453/R-07-003
                                    September 2007
    Control Techniques Guidelines for
      Paper, Film, and Foil Coatings
   U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
   Sector Policies and Programs Division
        Research Triangle Park, NC

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TABLE OF CONTENTS

I.     Introduction	1
II.    Background and Overview	2
III.   Applicability	3
IV.   Process Description and Sources of VOC Emissions	5
    A.    Process Description	5
    B.    Sources of VOC Emissions	7
V.    Available Control Options and Regulatory Approaches	10
    A.    Available Controls for VOC Emissions from Coatings	11
       1.    Pollution Prevention Measures	11
       2.    Emission Capture and Add-on Control Systems	11
    B.    Available Controls for Cleaning Materials	14
       1.    Product Substitution/Reformulation	14
       2.    Work Practice Procedures	14
    C.    Existing Federal, State,  and Local Recommendations or Regulations	14
       1.    The 1977 CTG	14
       2.    The 1983 NSPS	15
       3.    The 2002 NESHAP	15
       4.    Existing State and Local VOC Requirements	16
VI.   Recommended Control Options	17
    A.    Coatings	17
    B.    Cleaning Materials	19
VII.  Cost Effectiveness of Recommended Control Options	19
VIII.  References	21
LIST OF APPENDICES
Appendix A: Control of Volatile Emissions from Existing Stationary Sources - Volume II:
             Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty
             Trucks
Appendix B: Paper, Film, and Foil Surface Coating Facilities in Current Nonattainment Areas
             and Associated State or Local Requirements (Based on 2002 NEI and December
             2006 Nonattainment Designations)
Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating
             Facilities (not including California)
Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating
             Facilities

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               11

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I.      Introduction

       Clean Air Act (CAA) section 172(c)(l) provides that state implementation plans (SIPs)
for nonattainment areas must include "reasonably available control measures" (RACM),
including "reasonably available control technology" (RACT), for sources of emissions. Section
182(b)(2)(A) provides that for certain nonattainment areas, States must revise their SIPs to
include RACT for each category of volatile organic compound (VOC) sources covered by a
control techniques guidelines (CTG) document issued between November 15, 1990 and the date
of attainment.

       The United States Environmental Protection Agency (EPA) defines RACT as "the lowest
emission limitation that a particular source is capable of meeting by the application of control
technology that is reasonably available considering technological and economic feasibility." 44
FR 53761  (Sept. 17,  1979).  In subsequent Federal Register notices, EPA has addressed how
states can meet the RACT requirements of the Act.

       CAA section 183(e)  directs EPA to list for regulation those categories of products that
account for at least 80 percent of the VOC emissions, on a reactivity-adjusted basis, from
consumer and commercial products in areas that violate the NAAQS for ozone (i.e., ozone
nonattainment areas). EPA issued the list on March 23, 1995, and has revised the list
periodically. See 60 FR 15264 (March 23, 1995); see also 71 FR 28320 (May 16, 2006), 70 FR
69759 (Nov. 17, 2005); 64 FR 13422 (Mar. 18, 1999).  Paper, film, and foil coatings are included
on the current section 183(e) list.

       This CTG is intended to provide state and local air pollution control authorities
information that should assist them in determining RACT for volatile organic compounds
(VOCs) from paper,  film, and foil coatings. In developing this CTG, EPA, among other things,
evaluated the sources of VOC emissions from the paper, film, and foil coating industry and the
available control approaches for addressing these emissions, including the costs of such
approaches. Based on available information and data, EPA provides recommendations for
RACT for paper, film, and foil coating.

       States can use the recommendations in this CTG to inform their own determination as to
what constitutes RACT for VOCs for paper, film, and foil coatings in their particular
nonattainment areas.  There  are several hazardous air pollutants (HAP) that are also VOCs. The
information contained in this document is provided only as guidance.  This guidance does not
change, or substitute for, requirements specified in applicable sections of the CAA or EPA's
regulations; nor is it  a regulation itself.  This document does not impose any legally binding
requirements on any entity.  It provides only recommendations for state and local air pollution
control agencies to consider in determining RACT. State and local pollution control agencies are
free to implement other technically-sound approaches that are consistent with the CAA and
EPA's implementing regulations.

       The recommendations contained in this CTG are based on data and information currently
available to EPA.  These general recommendations may not apply to a particular situation based
upon the circumstances of a specific source. Regardless of whether a State chooses to  implement

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the recommendations contained herein through State rules, or to issue State rules that adopt
different approaches for RACT for VOCs from paper, film, and foil coatings, States must submit
their RACT rules to EPA for review and approval as part of the SIP process.  EPA will evaluate
the rules and determine, through notice and comment rulemaking in the SIP approval process,
whether the submitted rules meet the RACT requirements of the CAA and EPA's regulations.
To the extent a State adopts any of the recommendations in this guidance into its State RACT
rules, interested parties can raise questions and objections about the substance of this guidance
and the appropriateness of the application of this guidance to a particular situation during the
development of the State rules and EPA's SIP approval process.

       Section 182(b)(2) of the CAA requires that a CTG issued between November 15, 1990,
and the date of attainment include the date by which States subject to 182(b) must submit SIP
revisions in response to the CTG.  Accordingly, EPA is providing in this CTG a one-year period
for the required submittal. Pursuant to section 182(b)(2), States required to submit rules
consistent with section 182(b) must submit their SIP revisions within one year of the date of
issuance of the final CTG  for paper, film, and foil coatings.  States subject only to the RACT
requirements in CAA section 172(c)(l) may take action in response to this CTG, as necessary to
achieve attainment of the national primary ambient air quality standards.

II.     Background and Overview

       There have been three federal actions relative to some or all segments of the paper, film,
and foil surface coating industry.  In May 1977, EPA published a CTG for controlling VOC
emissions from  surface coating of paper (1977 CTG).  In October 1983, EPA promulgated the
new source performance standards (NSPS) for surface coating of pressure sensitive tape and
labels (1983 NSPS)2 which is a subset of the paper,  film, and foil surface coating industry.
Finally, in December 2002, EPA promulgated the National Emission Standards for Hazardous
Air Pollutants: Paper and  Other Web Coating (2002 NESHAP).3

       The 1977 CTG, 1983 NSPS, and 2002 NESHAP provide a thorough discussion of the
paper, film, and foil surface coating industry, the nature of VOC emission (and in the case  of the
2002 NESHAP, organic HAP emissions) from the industry, available control technologies for
addressing such emissions, the costs of available control options, and other information. The
1977 CTG recommends and the 1982 NSPS establishes VOC emission limits, whereas the 2002
NESHAP establishes organic HAP emission limits and does not address non-HAP VOC.

       At least 44 State and local jurisdictions have specific regulations that control  VOC
emissions from paper, film, and foil surface  coating operations (or segments of the paper, film,
and foil surface coating industry).  A discussion of the applicability and control options found in
the federal actions and State and local rules is presented in Section V of this document.

       We developed the recommended approaches contained in this document after reviewing
existing State and local VOC emission reduction approaches, the 1977 CTG, the 1983 NSPS,
and the 2002 NESHAP, as well as information obtained since issuance of the 2002 NESHAP.

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       The remainder of this document is divided into six sections. Section III describes the
scope of sources to which the control recommendations in this CTG could apply. Section IV
describes the paper, film, and foil industry, including the types of paper, film, and foil products,
coating materials (i.e., coatings and adhesives) and the coating processes, and identifies the
sources of VOC emissions from these processes. Section V describes the available control
approaches for addressing VOC emissions from this product category and summarizes Federal,
State and local approaches for addressing such emissions. Section VI provides our
recommendations for RACT for paper, film, and foil coating. Section VII discusses the cost-
effectiveness of the recommended control approaches. Section VIII contains a list of references.

III.    Applicability

       This CTG provides control recommendations for reducing VOC emissions stemming
from the use of coatings in paper, film, and foil surface coating operations. This section
addresses EPA's recommendations as to the scope of entities to which the RACT
recommendations in this CTG should apply. As explained above, this document is a guidance
document and provides information for States to consider in determining RACT. When State
and local pollution control agencies develop RACT rules, they may elect to adopt control
approaches that differ from those described in this document and/or promulgate applicability
criteria that differ from those recommended here.

       In terms of applicability, we recommend that the control approaches for cleaning
discussed in section VI of this CTG apply to each facility where the total actual VOC emissions
from all paper, film and foil coating operations, including related  cleaning activities, are equal to
or exceed 6.8 kg/day (15 Ib/day), or an equivalent level such as 3  tons per 12-month rolling
period, before consideration of controls.

       We do not recommend these control approaches for facilities that emit below this level
because of the very small VOC emission reductions that can be achieved.  The recommended
threshold level is equivalent to the evaporation of approximately two gallons of solvent per day.
Such a level is considered to be an incidental level  of solvent usage that could be expected even
in facilities that use very low-solvent coatings, such as UV cure coatings.  Furthermore, based on
the 2002 NEI data and the 2004 ozone  nonattainment designations, facilities emitting below the
recommended threshold level collectively emit less than 2 percent of the total reported VOC
emissions from paper, film, and foil coating facilities in ozone nonattainment areas.  For these
reasons, we are not extending our recommendations in this CTG to these low emitting facilities.
For purposes of determining whether a facility meets the 6.8 kg/day (15 Ib/day) threshold,
aggregate emissions from all paper, film, and foil surface coating  operations and related cleaning
activities at a given facility, prior to controls, are included.

       We recommend applying the control recommendations for coatings only to individual
paper, film and foil surface coating lines with the potential to emit at least 25 tons per year (tpy)
of VOC from coatings, prior to controls.  We do not extend our control recommendations for
coating operations to coating lines with the potential to emit below this threshold because some
of these coating lines cannot use low VOC content coatings  and add-on controls will generally
be too costly for the emission reduction that would be achieved from these low-emitting coating

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lines. We believe that control of a surface coating line that has a potential to emit above the 25
tpy threshold (prior to controls) will generally be cost effective. We also recommend providing
paper, film, and foil surface coating facilities with the option of using an enforceable limitation
on potential emissions to keep an individual paper, film and foil surface coating line below this
25 tpy potential to emit threshold.

       In addition, coating performed on or in-line with any offset lithographic, screen,
letterpress, flexographic, rotogravure, or digital printing press is part of a printing process and is
not part of the paper, film, and foil coating category. Size presses and on-machine coaters on
papermaking machines apply sizing (e.g., starch) or water-based  clays are part of the
papermaking process and are not part of the paper, film, and foil  coatings category. Therefore,
the recommendations in this final CTG do not apply to these activities.

       For those facilities where actual emissions  from all paper, film and foil surface coating
operations are greater than 15 Ib/day before  consideration of controls, and where  no individual
coating lines have the potential to emit 25 tpy or more of VOC before controls, we recommend
applying only the recommended work practices for cleaning.

       In developing their RACT rules, State and local agencies  should consider carefully the
facts and circumstances of the affected sources in their States.  As noted above, States can adopt
the above recommended 6.8 kg/day (15 Ib/day) actual VOC emissions or equivalent applicability
criterion, or they can develop other applicability criteria that they determine are appropriate
considering the facts and circumstances of the sources in their particular nonattainment areas.
EPA will review the State RACT rules in the context of the SIP revision process.

       Based on the 2002 National Emission Inventory (2002 NEI), we estimate that there are
716 paper, film, and foil surface coating facilities in the United States. Of these, we estimate that
474 facilities are located in current ozone nonattainment areas (based on April 2004
designations) and 251 of the facilities located in ozone nonattainment areas emit more than the
6.8 kg/day (15 Ib/day) VOC applicability threshold described above. The 2002 NEI was also
used as the source of statistical information concerning the paper, film, and foil surface coating
industry as a whole.

       According to the 2002 NEI, paper, film, and foil surface coating facilities are located
throughout the United States, with the Pacific Coast and the Northeastern States having the
largest numbers of facilities. Appendix B shows that these facilities are distributed across 21
States.  Appendices C and D summarize the current State and/or local requirements that are
applicable to paper, film and foil surface coating.

       In addition to the 2002 NEI, we reviewed relevant information in the Background
Information Document (BID) for the 2002 NESHAP. 4 The BID for the 2002 NESHAP
indicated that there are about 429 paper, film, and  foil surface coating facilities in the United
States.  This information was based on the 1996 Toxic Release Inventory (TRI) database for 12
Standard Industrial Classification (SIC) codes identified for the paper and other web industry.
We believe that the NEI data provides a more accurate and current prediction of the total number
of paper, film, and foil surface coating facilities.

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IV.    Process Description and Sources of VOC Emissions

       The paper, film and foil coatings product category listed under section 183(e) of the CAA
includes coatings that are applied to paper, film, or foil surfaces in the manufacturing of several
major product types for the following industry sectors: pressure sensitive tape and labels
(including fabric coated for use in pressure sensitive tapes and labels); photographic film;
industrial and decorative laminates; abrasive products (including fabric coated for use in abrasive
products) and flexible packaging (including coating of non-woven polymer substrates for use in
flexible packaging).  The category also includes coatings applied during miscellaneous coating
operations for several products including: corrugated and solid fiber boxes; die-cut paper
paperboard, and cardboard; converted paper and paperboard not elsewhere classified; folding
paperboard boxes, including sanitary boxes; manifold business forms and related products;
plastic asceptic packaging; and carbon paper and inked ribbons.

       Coating performed on or in-line with any offset lithographic,  screen, letterpress,
flexographic, rotogravure, or digital printing press is not part of the paper, film and foil coating
category. In addition, size presses and on-machine coaters that function as part of an in-line
papermaking system are not part of the paper, film, and foil coating category. The application of
inks, coatings and adhesives on or in-line with rotogravure or flexographic printing presses used
in the production of flexible packaging is addressed in the CTG for Flexible Package Printing
(EPA 453/R-06-003, September 2006). The application of inks, coatings and adhesives on or in-
line with publication rotogravure printing presses is addressed in the  CTG for Graphic Arts:
Rotogravure and Flexography  (EPA 450/2-78-033).  The application of inks, coatings and
adhesives on or in-line with offset lithographic or letterpress printing presses is addressed in the
CTG for Offset Lithographic Printing and Letterpress Printing (EPA  453/R-06-002, September
2006).

A.     Process Description

       The paper, film, and foil surface coating process can be described as a web  coating
process, which is a process that applies a continuous layer of coating material across essentially
the entire width or any portion of the width of a web substrate to:  (1) provide a covering, finish,
or functional or protective layer to a substrate; (2)  saturate a substrate for lamination; or (3) to
provide adhesion between two substrates for lamination. The web coating operations and
emission control techniques do not vary significantly among the sectors of the paper, film, and
foil surface coating industry.

       A typical coating line consists of a series of one or more unwind/feed stations; one or
more coating applicators; the flash-off area (the area between two or  more consecutive coating
applicators or between the coating applicator and the drying oven); one or more drying ovens;
and one or more rewind/cutting stations.

       There are several different types of coating applicators that may be used to apply
coatings. The most common types of applicators include: rotogravure, reverse roll, slot die,

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knife, flexography, Mayer rod, dip and squeeze, and extrusion/calendering.4 The type of coating
applicator used may differ among coating application stations in the same coating line.

       Rotogravure (web-fed gravure) coaters are used extensively by the printing industry, but
they are also used for coating.  The coating materials (or inks) are picked up in the recessed areas
of the roll and transferred directly to the substrate.  Several gravure coaters may be combined on
one coating line. In gravure coating, the coatings include both solvent and waterborne systems.4

       The reverse roll coater applies a constant thickness of coating to the substrate, usually by
means of three rollersa metering roller, a backing roller, and an applicator (transfer) roller. A
metering roller picks up the coating solution from a trough and transfers it to an applicator roller.
(Sometimes there is no metering roller and the coating is pumped directly onto an applicator
roller.) The web is supported by a backing roller where the applicator roller contacts the paper.
The applicator roller then transfers the coating to the substrate, as the web passes between the
backing roller and the applicator roller.  The applicator roller turns in a direction opposite to that
of the paper, hence the name reverse roll coater.  This reverse direction of the applicator roller
reduces striations in the coating that can form if the applicator roller is turned in the same
direction as the paper web.

       The slot die coater is similar to an extruder but is less heavy-duty than an  extruder since
less viscous materials are used with a slot die coater (a discussion of extruders is provided further
below). In a slot die coater, the coating is extruded through an adjustable-width orifice onto the
substrate and is sometimes followed by a smoothing roller.  Slot die coaters are typically used for
application of hot-melt coatings and adhesives, but may also be used to apply aqueous coatings.4

       A knife coater consists of a blade that scrapes off excess coating from the  substrate. The
tray or trough of coating is located behind the knife blade.  A continuous sheet of substrate is
drawn between the knife blade and the support roller. As coating is deposited on the substrate,
the knife blade spreads it across the substrate to the desired thickness. The position of the knife
relative to the substrate surface can be adjusted to control the thickness of the coating.  Some
knife coaters use high velocity air as the knife blade; these are known as air-knife coaters.
Knife coaters can apply solutions of much higher viscosity than roll coaters, thus less solvent is
emitted per pound of coating applied.  Knife coaters handle coatings with viscosity up to
10,000 centipoise (cp), while reverse roll coaters operate best with coatings that have a viscosity
ranging from 300 to  1500 cp. Knife coaters, however, usually operate at lower speeds than roll
coaters and show a greater tendency to break the web.4

       Inflexographic coating, the area to be coated is delineated by a raised surface on a
flexible plate that is usually made of rubber or other elastomeric materials. Because of the ease
in plate preparation, flexography is more suited to short production runs than gravure. Coating
materials applied with flexography must be very fluid to work properly and include waterborne
and solvent-based systems. The solvents used must be compatible with the rubber or polymeric
plates; thus aromatic solvents are not used. Flexography is performed both on wide web (<18
inches) and narrow web (<18 inches),  and on sheets as well as web.4

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       The Mayer rod (or wire-wound rod) coater is a metering device used to control the
thickness of an applied coating. Typically, the coating is applied via a roller, and the excess
coating is removed by a rod covered by a spiral-wound stainless steel wire. The rod wipes the
coating off the substrate except for the portion which escapes through the spaces between the
wires.  Larger wire diameters result in larger spaces, and therefore heavier coatings.4

       The dip and squeeze coater, also called a dip coater, impregnates or saturates the
substrate rather than applying a coating to the web surface. The substrate is fed and dipped into
a coating-filled pan by a system of rollers. The saturated web is then passed through nip rollers
that squeeze off any excess coating.4

       The extrusion coater creates a web substrate or applies coating materials to a preformed
web substrate by forcing it through a die.  A typical extrusion coater forms a plastic film or
coating of the hot-melt type by forcing a molten polymer resin through a die as the web passes
below the die.  The extruded web is then cooled to restore the coating to a solid state. Nearly all
extrusion coatings are made of low-density polyethylene (LDPE). They account for a large
portion of the coatings used in the printing product and packaging industry,  divided about evenly
between cartons/cardboard and flexible materials.4

       In calendering, a process similar to extrusion, material is pressed by a roller or between
rollers to form a web such as vinyl sheeting. Calendering may also be used to apply a coating to
a substrate, as in the manufacture of duct tape.  Prior to calendering, resins, plasticizers, and
pigments are blended together in a series of blenders, mixers, and mills.  Plasticizers are used to
improve the flexibility of the coating/material.  After mixing, the mixture is conveyed to the
calender. In a typical four-roll calender, the molten coating is rolled into a continuous sheet,
which is then cooled.4

       After the coating application described above, the applied coating may be heat dried or
cured in one or more drying ovens. The major functions of the drying oven are to dry the coating
by evaporating the solvent and/or finish the curing of a polymeric coating.

       Cleaning activities also occur at paper, film, and foil surface coating facilities. Cleaning
materials are used during these activities to remove coating residue or other unwanted materials
from equipment related to coating operations, as well as  spray gun cleaning, etc.  Cleaning
materials are typically mixtures of VOC-containing solvents.

B.     Sources of VOC Emissions

       Primarily, VOC emissions from paper, film, and foil surface coating operations result
from the evaporation of volatile components of the coatings and cleaning materials.a  The
majority  of VOC emissions from these materials occur during coating application/flash-off,
a In a previous notice, EPA identified specific categories, including paper, film and foil coating, the cleaning
operations of which would not be covered by EPA's 2006 CTG for industrial cleaning solvents (71 FR 44522,
44540, October 5, 2006).  In the notice, EPA expressed its intention to address cleaning operations associated with
these categories in the CTGs for these specified categories if the Agency determines that a CTG is appropriate for
the respective categories.

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coating curing/drying, and cleaning. The coating applicator(s)/flash-off area(s) and oven(s) are
the main VOC emissions sources on the coating line.  The VOC contained in the coatings
evaporate from the web into the coating application/flash-off area during coating
application/flash-off or are evaporated from the web during the heating process in the dryers.
The remaining VOC emissions are from cleaning operations. In most cases, VOC emissions
from mixing, surface preparation,  handling and storage of coatings and solvents, and
waste/wastewater operations are small. The following discussion describes the two primary
emission sources (coatings and cleaning materials).

1.      Coatings

       The VOC emissions from paper, film, and foil coatings occur during coating
applicati on/flash-off and drying/curing of the coatings. Some of the VOC in the coatings
evaporates from the web into the coating application area during coating application.  Additional
VOC evaporates from the web in the flash-off area (prior to entering the dryer).  The majority,
usually greater than 90 percent,  of the VOC in the coatings volatilizes in the drying ovens.  The
VOC that evaporates from the web in the drying oven(s) are vented through an exhaust stack.
The amount of VOC emitted varies depending on the type of coatings being used.

       Traditionally, conventional solvent-based coatings (which generally have higher VOC
content), have been used in the paper, film, and foil surface coating industry. Due to increased
regulation at the federal and State  level, the industry has steadily moved toward alternative
coating formulations that reduce the amount of air emissions per unit amount of coating solids
used. The types of coatings used in the paper, film, and foil  surface coating industry include
solvent-borne, waterborne, hot-melt adhesives and other 100 percent solids coatings, reactive,
and radiation-cure coatings.

       Solvent-borne coatings are widely used in the paper,  film,  and foil surface coating
industry. The solvent content of the coating is highly variable in solvent-borne coatings, and
depends primarily on the type of coating applicator used (e.g., reverse roll coaters require the use
of coatings with lower viscosities than knife coaters, therefore could require a higher solvent
content). For solvent-borne coatings, coating formulations typically range from 40 to 80 percent
solvents by weight, as supplied by the manufacturer. Users may dilute solvent-borne coatings
with additional solvents.  Solvent-borne coatings are typically applied at 60 to 90 percent solvent
by weight and sometimes higher.  The primary solvents in solvent-borne coatings include
methanol, toluene, xylene, methyl  ethyl ketone, acetone, ethyl acetate, and ethanol. Knife
coaters, reverse roll coaters, and gravure coaters are commonly used to apply solvent-borne
coatings.

       Waterborne coatings contain water as a significant part of the fluid, although some
organic solvents may be used at up to 30 percent of the fluid. Most coating equipment used for
solvent-borne coatings can also  be used for waterborne coatings. Knife coaters and gravure
coaters are particularly well suited to application of waterborne coatings. However, troughs or
trays may have to be mixed more often when they contain waterborne coatings than when they
contain solvent-borne coatings because waterborne coatings are more susceptible to coagulation
or agglomeration of their solids.

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       Hot-melt adhesives and other 100 percent solids coatings such as wax coatings, wax
laminations, extrusion coatings, extrusion laminations, and coal seal coatings contain very little
or no solvent.  Accordingly, these coatings emit very little VOC.

       In a hot-melt adhesive application, the solid coating material is heated, delivered to the
coater head in a molten state, and added onto the web by a heated gravure coater, a heated roll
coater, or an extrusion coater. The coated web is then chilled, restoring the coating to its solid
state. Hot-melt adhesives use less energy than waterborne or solvent-borne coating operation
because there are no dryers. The use of hot-melt adhesives also minimizes fire and explosion
dangers because there are no volatile hydrocarbons.

       The use of hot-melt adhesives, although growing, is still limited by several factors.
Because the equipment for hot-melt adhesives is quite different from solvent-borne and
waterborne coatings, existing equipment would have to be replaced to implement hot-melt
adhesive use.  Controlling the amount of hot-melt adhesives applied to the substrate can be
difficult with hot-melt coatings, resulting in poor coating quality. The hot-melt coater head is
more susceptible to streaking due to plugging or dirt accumulation.  Cleaning the coater head is
difficult and time consuming, making changes to coat a different substrate or use a different hot-
melt adhesive on the same hot-melt adhesive line more difficult,  and therefore reduces the
flexibility of the coater to coat  many different products. Additionally, hot-melt adhesives do not
have the strength or resistance  to environmental stresses such as  heat or cold, as do solvent-borne
coatings. The hot-melt adhesives are typically darker in color and therefore, are not used on
transparent surfaces. Finally, hot-melt adhesives cannot be used on a film substrate that is
sensitive to heat because the substrate could melt during the coating process.

       Reactive coatings are cured via a chemical (usually polymeric) reaction that forms other
compounds. The resulting compounds are generally not VOC and/or stay with the substrate as
residual VOC and is not emitted whether or not the substrate is dried.4 Reactive coatings are
frequently used in the surface coating of decorative and industrial laminates and abrasives.
Reactive coatings include styrene formaldehyde, phenolic, melamine, and epoxy resins.

       Radiation-cure coatings (also called prepolymer coatings) are a special type of reactive
coatings. These coatings are cured by exposure to electron beam (EB) or ultraviolet (UV)
radiation. Radiation-cure coatings are solventless and are almost entirely composed of resins.
They are applied in a liquid state via some typical coating application methods (e.g., gravure and
flexography), and polymerize into a solid state upon exposure to UV or EB radiation.  UV-cured
coatings require the addition of a photoinitiator to catalyze the polymerization reaction; EB-
cured coatings do not, because the highly excited electrons emitted by the EB  source are capable
of initiating the polymerization reaction.

       Benefits of radiation-cured coatings extend beyond decreased solvent usage and the
associated emission reductions, including VOC emissions.  The instantaneous nature of the
curing process eliminates the need for drying ovens on the production line, which often leads to
production increases and may allow direct integration of ancillary operations (e.g., cutting,
slitting, folding) into the production line. Because no drying ovens are used, both energy usage

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and the space required for a coating line are greatly reduced. Since the coatings will not cure
unless exposed to the proper type of UV or EB radiation, they will not cure on the production
equipment during operation or during process downtime. As a result, it is not necessary to clean
application devices at the end of each shift or during breaks and cleaning is easier than some
other coatings, such as hot-melt coating.

       Although industry generally perceives UV coating usage as expensive because it may be
costly to switch a coating line from solvent-based coating equipment to radiation-cured systems,
there are often savings with the use of radiation-cured coatings due to the above-mentioned
benefits that can offset capital costs. Another industry perception is that the coatings themselves
are more expensive. Although this may be true on a volume-to-volume basis, a radiation-cured
coating will cover a much greater area of substrate (2 to 4 times) than an equal volume of a
solvent-based coating because the radiation-cured coating is 100 percent solids and has no loss of
volume due to evaporation of solvent.

       There are, however, several limitations to the use of radiation-curable systems.  The
extent of cure penetration can be a problem if the coating is very thick or heavily  pigmented,
which could result in coating not being completely cured. Because low viscosity  solvents are not
used, application of the relatively higher viscosity radiation-cured coatings can be problematic;
although this factor is less important in the application to web substrates than other substrates
which use spray coating.  Also, skin contact with radiation-cured coatings has the potential for
irritation and/or allergic reaction. This is especially true during cleaning, since the combination
of cleaning solvents and the radiation-cured coatings increases dramatically the level of irritation
to the skin.

2.     Cleaning Materials

       Cleaning materials are another source of VOC emitted by paper, film, and foil surface
coating operations.  Cleaning materials are used to remove excess coatings from coating
equipment. These materials are typically mixtures of organic solvents. The cleaning material
may be a solvent,  or a specific mixture of individual solvents. Cleaning materials are used to
wash the coating applicators and outsides of the coating machines, and to remove residues of
excess coatings between job changes. Cleaning may be done manually, using shop towels for
example.

V.     Available Control Options and Regulatory Approaches

       As previously mentioned, there are two main sources of VOC emissions from paper, film,
and foil surface coating operations: (1) evaporation of VOC from the coatings; and
(2) evaporation of VOC from the cleaning materials. This section summarizes the available
control options for reducing these VOC emissions and regulatory approaches.
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A.     Available Controls for VOC Emissions from Coatings

       Common control techniques for reducing VOC emissions from paper, film, and foil
surface coatings include pollution prevention measures and the operation of emission capture and
add-on control systems.  Provided below is a summary of these control techniques.

1.      Pollution Prevention Measures

       Product substitution/reformulation is commonly used as a pollution prevention measure
in the paper, film, and foil surface coating industry to decrease VOC emissions from coatings.
Lower VOC content coatings (such as waterborne and higher solids content coatings) or coatings
with no solvents (e.g., hot-melt adhesives) may be used to reduce VOC emissions by reducing or
eliminating the organic solvent present in the coating.  As previously discussed, these coatings
include waterborne, hot-melt, reactive and radiation-cure coatings. Coating manufacturers have
developed and are continuing to develop waterborne and other alternative coating formulations
that replace conventional organic solvent-borne coatings. These coatings are available for a
number of applications.  Conversion to these coatings can lower VOC emissions greatly, and
most paper, film, and foil surface coating operations are  capable of converting to these coatings.
However, for some products, the currently available low-VOC coatings or coatings with no
solvents do not meet the performance requirements of some paper, film, and foil surface coating
operations and therefore are not viable options for  production of these products.

2.      Emission Capture and Add-on Control Systems

       When low-VOC content coatings cannot be used due to performance requirements
calling for higher VOC content coatings, VOC emissions from paper, film and foil surface
coating operations can be reduced by the use of capture systems in conjunction with add-on
control systems that either destroy or recover the VOC in the exhaust streams.

Capture Systems

       Capture systems, such as hoods and enclosures, collect solvent-laden air from process
vents (e.g., drying oven vents) and/or fugitive emissions (e.g., application and flash-off area)
containing VOC and direct the captured air to a control device. Emissions from the drying oven
can be ducted directly to a control device, making the drying oven the principal element of the
capture system. In addition, capture systems are used to collect fugitive emissions from solvents
that evaporate from other parts of the coating line, such as the coating application and flash-off
areas, and route them to a control device.

       An efficient capture system maximizes the capture of emissions and minimizes the
quantity of dilution air. Facilities may combine several captured VOC-laden streams and duct
them to a single control device.

       The most common types of capture systems used by the paper, film, and foil surface
coating industry are hoods or enclosures. Hood and enclosure capturing methods include hoods,
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floor sweeps, partial enclosure of coating stations, room enclosures, and permanent total
enclosure (PTE).  There are capture systems in use with efficiencies as high as 100 percent.5

Add-on Control Devices in Paper, Film and Foil Surface Coating

       Add-on control devices reduce the amount of VOC emissions by either destruction or
recovery with or without recycling of VOC collected from exhaust streams. Two categories of
add-on control devices are typically used by the paper, film, and foil industry: combustion
(thermal  or catalytic oxidation) and recovery (adsorption and condensation).  While many
control devices can be used to reduce VOC emissions, the following summary covers those
control devices known to be used with surface coating operations: oxidation, adsorption, and
condensation. In addition, there are other control measures that are known to reduce VOC
emissions, but are not frequently in use in the paper, film, and foil surface coating industry.
These  alternative control technologies are also discussed below.

       Oxidation destroys VOC emissions in an exhaust stream by exposing the stream to an
oxidizing atmosphere at high temperatures. Oxidizers may be of thermal or catalytic design and
combust VOC-containing exhaust streams. Catalytic oxidizers are similar to thermal oxidizers
but employ a catalyst to aid in the oxidation reaction.  As a result, catalytic oxidizers operate at a
lower combustion temperature relative to that required in thermal oxidizers. Both types of
oxidizers generally utilize either regenerative or recuperative techniques to preheat inlet gas in
order to decrease energy costs associated with high oxidation temperatures. They may also use
primary or secondary heat recovery to reduce energy consumption. In general, oxidizers may
achieve destruction efficiencies of greater than 95 percent as applied to surface coating
application operations with  high and constant concentrations of VOC.

       Adsorption occurs when the unbalanced molecular forces on the surface of solids (the
adsorbent) attract and retain gases and particulate matter that come in contact with the solid.
Several materials can be used as the adsorbent, such as activated carbon, organic resin polymer,
and inorganic materials. Carbon adsorbers are the type of adsorber most commonly used in the
paper,  film, and foil surface coating industry.  In a carbon adsorber, activated carbon is used as
the adsorbent in a regenerable fixed bed. In a typical carbon adsorber, VOC-laden air is passed
through a fixed bed of granular activated carbon. The VOC in the entering air stream are
adsorbed onto active sites on the surface area of the carbon. Adsorber beds are typically
operated in parallel to avoid interruption of VOC control. In this arrangement, when the
adsorption capacity of one bed is exhausted, it can be removed from  service and a second
adsorber bed can be put into service, ensuring that a control device is operating at all times.  The
spent carbon in the first adsorber bed is then regenerated and can be put into service again.

       Carbon  adsorption systems can achieve control device efficiencies greater than 95
percent.6 In contrast to combustion, carbon adsorption does not destroy the VOC  it removes
from the air stream. Carbon adsorbers used in paper, film and foil surface coating are thermally
regenerated, usually by passing steam through the carbon beds.7  The VOC are removed from the
carbon (desorbed)  and transferred to the steam. The VOC-containing steam is then condensed,
and the VOC solvent is separated from the water. The recovered solvent can then be decanted
for sale or reuse. Regeneration can also be achieved with hot air.  Hot-air regeneration can be
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quite attractive when dealing with water soluble solvents.7 Carbon adsorption is most easily
adaptable to coating lines that use a single solvent; if solvent mixtures are collected by adsorbers,
they usually are distilled for reuse.8

       There are two options for disposing recovered solvents that cannot be reused. The first is
to sell the material back to the solvent supplier or an independent firm that specializes in
reclaiming contaminated solvents. The other option is to use the recovered solvent as a fuel in
coating ovens or in boilers. However, many coating ovens and boilers are gas-fired  and would
require burner modifications to burn solvent.  Carbon adsorption is generally economically
attractive only if the recovered solvent can be reused directly.7

       Carbon adsorbers are most suitable for solvents that are immiscible with water, such as
toluene and xylene, but are not recommended for water-soluble VOC, such as methyl ethyl
ketone and methyl isobutyl ketone.  In the case where a water-soluble VOC is present, the water
vapor will be adsorbed and desorbed along with the VOC vapor, and the VOC may require
subsequent purification if it is to be reused.

       The presence of solid particles or polymerizable substances in the inlet air stream to  a
carbon adsorber may require pretreatment of the inlet air. Cooling and dehumidification may also
be required as pretreatment in some cases.6 Adding equipment, such as a dehumidification
system, increases the costs associated with the use of a carbon adsorption system.

       Condensation is where organic compounds {i.e.., VOC) are removed from gas streams by
cooling the gas to a temperature less than the dew point of the compound. The recovered VOC
compounds can then be reused or sold. Highly volatile VOC require lower temperatures for
condensation. Therefore, refrigeration is often necessary to reach the low temperatures required
for acceptable removal efficiencies.9 Removal efficiencies usually range from 50 to 90 percent.6

       The most common types of condensers used are surface and contact condensers.  In
surface condensers, the coolant does not contact the gas stream.  Surface condensers allow for
direct recovery of VOC from the gas stream.9 Unlike surface condensers, contact condensers
cool through direct contact of the coolant with the gas stream. The contact condenser coolant,
which is  a liquid at ambient or chilled temperature, is sprayed into the gas stream. In a contact
condenser, the condensed VOC are  contaminated with coolant and therefore cannot usually be
reused or resold directly; further processing is necessary to complete the recovery process.10

       Alternative control technologies, such as liquid absorbers and biofilters are used
infrequently in the paper, film, and foil surface coating industry.  Ultraviolet (UV) oxidation is
not currently utilized by the paper, film, and foil  surface coating industry. However, it has been
shown to be an effective control technology for VOC emissions from coatings in other
industries. The use of these types of alternative control technologies would be highly dependant
on facility needs and characteristics.
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B.     Available Controls for Cleaning Materials

       Pollution prevention is the most common emission control technique for reducing VOC
emissions from cleaning materials. The pollution prevention measures applicable to the paper,
film, and foil surface coating industry include product substitution/reformulation and work
practice procedures. Cleaning materials with low or no VOC content or low-VOC composite
vapor pressure may be used to reduce or eliminate VOC emissions from using these materials.
Work practice procedures may also reduce VOC emissions during cleaning operations by
reducing the amount of VOC that can evaporate due to exposure to air.

       No add-on control technologies are being used specifically for reducing VOC emissions
from cleaning operations associated with paper, film, and foil surface coating. However, if
cleaning operations are performed within a capture system which is ducted to an add-on control
system, such as a PTE routed to a thermal oxidizer, the VOC emissions from the cleaning
operation would be reduced by destruction in the thermal oxidizer. Further, there are controlled
cleaning operations where cleaning is automated, enclosed, and vented to a control device.

1.      Product Sub stituti on/Reformul ati on

       Reducing the composite vapor pressure or VOC content of the cleaning material used,
either by substitution or reformulation, is one pollution prevention measure that is used to reduce
VOC emissions from cleaning operations.  However, little information is available regarding the
types of low-VOC  or VOC-free cleaning materials that could be used in the paper, film, and foil
surface coating industry.

2.      Work Practice Procedures

       Work practices are widely used in the paper, film, and foil surface coating industry as a
measure of reducing VOC emissions from cleaning materials during cleaning operations.  These
measures include: covering cleaning material mixing tanks; storing cleaning solvents and
solvent-soaked rags and wipes in closed containers; and cleaning spray guns in an enclosed
system. Use of recycled solvents for cleaning is also typical in the industry.

C.     Existing Federal State, and Local Recommendations or Regulations

       The following discussion is a summary of EPA actions,  as well as State and local
regulations that address VOC emissions from paper, film, and foil surface coating processes.
Appendices B, C, and D summarize State and local provisions.

1.      Thel977CTG

       The 1977 CTG recommended limiting VOC emissions from paper coating operations.
The 1977 CTG recommended VOC limits apply to paper coating lines, which are defined as
consisting of the application/flash-off area and the drying oven. Cleaning materials were not
addressed in the 1977 CTG.
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       The 1977 CTG recommended RACT for paper coating was 0.35 kg/1 (2.9 Ib/gal) of
coating, excluding water and exempt compounds, as applied. This recommended limit was
based on the use of conventional solvent-borne coatings and oxidation of the dryer exhaust
which achieved an overall control efficiency of 81 percent. The limit was expressed in terms of
a coating VOC content to encourage the development and use of low-VOC content coatings.
Equivalent solid-based limits for paper coating operations were presented in A Guideline for
Surface Coating Calculations" (EPA-340/1-86-016).11 For paper coating , the 1977 CTG-
equivalent limit was 0.58 kg/1 (4.8 Ib/gal) of solids using a representative coating solids. These
equivalent limits were calculated using an assumed VOC density of 0.88 kg/1 (7.36 Ib/gal).  This
assumed VOC density is the same as that used in calculating the limits recommended in the 1977
CTG.

2.     The 1983 NSPS

       In 1983, EPA promulgated new source performance standards for pressure  sensitive tape
and label surface coating operations (1983 NSPS), 40 CFR 60, subpart RR.  The 1983 NSPS
only applies to pressure sensitive tape and label surface coating lines that commenced
construction, reconstruction, or modification after December 30, 1980.  The 1983 NSPS defines
a coating line to include the coating applicators, flash-off areas, and drying ovens between web
unwind stations and web rewind stations.  The 1983 NSPS requires a 90-percent reduction of
VOC emissions. Alternatively, it establishes a limit of 0.20 kg VOC/kg (0.20 Ib VOC/lb) solids
applied, based on a VOC emission reduction of 90 percent. Any pressure sensitive tape  and label
surface coating operations that inputs 45 megagrams per year (Mg/yr) VOC (50 tpy) or less into
the coating process are not subject to the 1983 NSPS emission limit (other requirements such as
recordkeeping and reporting do apply). Cleaning materials were not addressed in the 1983
NSPS.

3.     The 2002 NESHAP

       In 2002, EPA promulgated the National Emission Standards for Hazardous Air
Pollutants: Paper and Other Web Coating (2002 NESHAP), 40 CFR part 63, subpart JJJJ, which
applies to major sources of HAP emissions (i.e., stationary sources that emit or have the potential
to emit 10 tpy or more of any one HAP, or 25 tpy or more of any combination of HAP).  The
2002 NESHAP addresses organic HAP emissions, including VOC HAP emissions, from all web
coating lines at a paper, film, and foil surface coating facility, which include coating application
and any associated curing and/or drying equipment between an unwind station and a rewind or
cutting station.

       The 2002 NESHAP has different emission limitations for sources that commenced
construction or reconstruction on or before September 13, 2000 (existing sources),  and sources
that commenced construction or reconstruction after September 13, 2000 (new sources). The
2002 NESHAP limits for existing sources are based on an overall HAP emission reduction of 95
percent and are expressed as follows: (1) no more than 5 percent of the organic HAP applied; (2)
no more than 0.04 kg/kg (0.04  Mb) coatings applied; or (3) no more than 0.20 kg/kg (0.20 Mb)
solids applied. Similarly, the limits for new sources are based on a HAP emission  reduction of
98 percent and are expressed as follows:  (1) no more than 2 percent of the organic HAP applied;
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(2) no more than 0.016 kg/kg (0.016 Mb) coatings applied; or (3) no more than 0.08 kg/kg (0.08
Ib/lb) solids applied.

       Compliance with the 2002 NESHAP can be demonstrated by any of the following
methods: (1) all coatings purchased have organic HAP contents that individually meet the
organic HAP emission limit; (2) all coatings applied have organic HAP contents that individually
meet the organic HAP emission limit; (3) total monthly organic HAP applied does not exceed an
equivalent allowable organic HAP (which is a facility-specific weighted average calculated
based on HAP content of the coatings applied); (4) use one or more capture systems and control
devices; or (5) use a combination of coatings and capture systems and control devices meet the
organic HAP emission limit.

4.      Existing State and Local VOC Requirements

       In addition to the EPA actions described above,  at least 44  State and local jurisdictions
have regulations that affect VOC emissions from all or part of the paper, film, and foil surface
coating industry.  Some of these regulations are general surface coating rules; many are specific
to  the paper, film, and foil  surface coating industry and  cover the coating line.  Generally, the
State and local regulations allow compliance with their  requirements to be demonstrated using
low-VOC coating or add-on control devices in conjunction with higher-VOC coating.

       Almost all of the jurisdictions that specifically address all or part of the paper, film, and
foil surface coating industry have adopted the recommended VOC emission limits in the 1977
CTG. However, there are fourteen jurisdictions that have more stringent requirements than the
1977 CTG. These jurisdictions allow compliance either using compliant coatings, or by using an
add-on control system. Seven jurisdictions have VOC emission limits that are more stringent
than the 1977 CTG, five in California and two in Illinois. The California jurisdictions limit VOC
emissions to 265 g/1 (2.2 Ib/gal) of coating, excluding water and exempt compounds, as applied.
The two jurisdictions in Illinois limit VOC emissions to 0.28 kg/1 (2.3 Ib/gal) of coating,
excluding water and exempt compounds, as  applied.  As an alternative to the VOC  emission
limits, these California and Illinois jurisdictions allow facilities to install capture systems and
control devices to reduce VOC emissions from these coating operations. The required overall
emission reduction, including capture and control  efficiency, ranges from 55 percent to  90
percent. Specifically, the San Diego County Air Pollution Control District (San Diego) and the
Ventura County Air Pollution Control District (Ventura) both require an overall control
efficiency of 90 percent. Finally, there are seven jurisdictions that have VOC emission  limits
that are the same as the 1977 CTG.  However, these jurisdictions require 95 percent emission
reduction as an alternative to the VOC emission limit. The 95-percent overall control efficiency
is the most stringent and likely can only be met with a permanent total enclosure that achieves
100 percent capture efficiency.

       Several jurisdictions in California have requirements to regulate the VOC content of
cleaning materials used in the paper, film and foil  surface coating industry.  These regulations
are aimed at reducing VOC emissions from cleaning materials by combining work practice
standards with limits on the VOC content or composite  vapor pressure of the solvent being used.
In  some cases, the jurisdictions allow the use of add-on  controls as an alternative to the  VOC
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content/vapor pressure limits. The different air pollution control authorities in California have
established similar work practice standards.  However, the cleaning material VOC content/vapor
pressure limits vary by jurisdiction, as do the overall control efficiency required when add-on
controls are used as an alternative.

       There are 10 States that have cleaning material regulations that apply to paper, film, and
foil surface coating operations. Of these, 9 States do not limit the VOC content/vapor pressure
of cleaning materials.  Instead, they have established equipment standards, work practices, and/or
recordkeeping requirements. There is one State that requires work practices as well as limiting
the vapor pressure  of the cleaning materials.  The cleaning material regulations are summarized
in detail in the CTG.

VI.    Recommended Control Options

       Based on a  review of the 1977 CTG, the 1983 NSPS, the 2002 NESHAP, and the current
State and local requirements discussed above, we recommend emission limits and work practices
for controlling the VOC emissions from coatings and cleaning materials used in paper, film and
foil surface coating operations. The following discussion summarizes EPA's recommendations
for controlling VOC emissions.

A.     Coatings

       For the purposes of this CTG, we recommend defining coatings as materials applied onto
or impregnated into a substrate for decorative, protective, or functional purposes. Such materials
include, but are not limited to, solvent-borne coatings, waterborne coatings,  adhesives, wax
coatings, wax laminations, extrusion coatings, extrusion laminations, 100 percent solid
adhesives, UV cured coatings, electron beam cured coatings, hot melt coatings, and cold seal
coatings. Materials used to form unsupported substrates, such as calendaring of vinyl, blown
film, cast film, extruded film, and co-extruded film, are not considered coatings.

       To control VOC emissions from coatings used in paper, film and foil surface coating, we
recommend an overall VOC control efficiency of 90 percent for each coating line.  Alternatively,
we recommend emission limits that are equivalent to 90 percent overall control.  We recommend
applying the control recommendations only to individual surface coating lines with the potential
to emit, prior to controls, at least 25 tpy of VOC from  coatings.  The coating line is defined as a
series of coating applicators, flash-off areas, and any associated curing/drying equipment
between one or more unwind/feed stations and one or more rewind/cutting stations.  We also
recommend providing paper, film, and foil surface coating facilities with the option of using an
enforceable limitation on potential emissions to keep an individual paper, film and foil surface
coating line below  this 25 tpy potential to emit threshold.

       We recommend an overall VOC control efficiency of 90 percent as RACT for each
paper, film, and foil surface coating line, as defined above.  This emission reduction is based on
the San Diego and  Ventura levels of control, as well as the 1983 NSPS. The San Diego and
Ventura regulations require that if an add-on control is used as the compliance option, the control
system must achieve 90 percent overall emission reduction. We are not recommending the 95-
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percent overall emission reduction in the 2002 NESHAP and seven States regulations. A
95 percent overall emission reduction would require facilities to install and operate a PTE (i.e.,
achieve 100 percent capture efficiency) in conjunction with a control device that reduces
emission by 95 percent.  We do not believe that it is reasonable or feasible to retrofit a PTE in all
cases.

       As an alternative to an overall 90 percent control efficiency, we recommend VOC
content-based emission limits that are equivalent to 90 percent overall control, which can be met
by use of low-VOC content materials or combinations of materials and controls. To determine
these equivalent content-based emission limits for this product category (except for pressure
sensitive tape and label surface coating lines), we used the same baseline coating, 20 weight
percent solids and 80 weight percent solvent (organic HAP for the NESHAP and VOC for this
CTG), used to develop similar limits in the 2002 NESHAP.  Using this baseline coating content,
the VOC content-based emission limits equivalent to 90-percent emission reduction are 0.40 kg
VOC/kg (0.40 Ib VOC/lb) solids applied and 0.08 kg VOC/kg (0.08 Ib VOC/lb) coating applied.
We recommend these limits for paper, film and foil surface coating except for pressure sensitive
tape and label surface coating lines.

       As an alternative to 90 percent emission reduction, the NSPS for pressure sensitive tapes
and labels provides an alternative limit of 0.20 kg VOC/kg (0.20 Ib VOC/lb) solids applied. We
recommend the same alternative limit of 0.20 kg VOC/kg (0.20 Ib VOC/lb) solids applied and an
additional equivalent limit of 0.067 kg VOC/kg (0.067 Ib VOC/lb) of coating as RACT for
pressure sensitive tape and label surface coating lines. See Table 1 for a summary of the
recommended RACT limits for the paper, film, and foil surface coating source category.

                   Table 1. Summary of Recommended RACT Limits
Units
Emission Reduction (%)
kg VOC/kg solids
(Ib VOC/lb solids)
kg VOC/kg coating
(Ib VOC/lb solids)
RACT Limits
Pressure
Sensitive Tape
and Label
Surface Coating
90
0.20
0.067
Paper, Film, and Foil
Surface Coating (Not
including Pressure
Sensitive Tape and Label)
90
0.40
0.08
       The VOC content limits can be met by averaging the VOC content of materials used on a
single surface coating line each day (i.e., daily within-line averaging).  We do not recommend
the use of cross-line averaging (i.e., averaging across multiple lines) to meet the VOC content
                                                                         12
limits.  However, we have previously provided guidance on cross-line averaging.   The
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guidance is directed to State and local agencies that elect to adopt a discretionary economic
incentive programs (EIP) and includes guidance on the use of cross-line averaging.

B.     Cleaning Materials

       For cleaning materials, we are recommending work practices to reduce VOC emissions.
We are not recommending the application of add-on controls. Add-on controls would be a costly
alternative for reducing VOC emissions from cleaning materials because the area to be
controlled is quite large and a large volume of air would be captured and directed to a control
device. However, as mentioned previously, any cleaning activities that occur within a capture
device would be controlled by the associated control device. We are also not recommending the
use of a VOC content or VOC composite vapor pressure limit for cleaning materials because we
do not have information available regarding current VOC content or VOC composite vapor
pressure usage to determine a RACT limit for cleaning materials used in paper, film, and foil
surface coating operations.

       To control VOC emissions from cleaning materials used in paper, film, and foil  surface
coating, we recommend work practices for use  in all paper, film, and foil surface coating
facilities meeting the applicability threshold noted above.  We recommend that facilities
implement work practices to ensure that VOC emissions are minimized from mixing, storage,
and handling of cleaning materials, and cleaning-related waste materials. Specifically, we
recommend the following: (1) store all VOC-containing cleaning materials in closed containers;
(2) ensure that mixing and storage containers used for VOC-containing materials are kept closed
at all times except when depositing or removing these materials; (3) minimize spills of VOC-
containing cleaning materials; (4) convey VOC-containing cleaning materials from one location
to another in closed containers or pipes; and (6) minimize VOC emissions from cleaning of
storage, mixing, and conveying equipment.

VII.   Cost Effectiveness of Recommended Control Options

       We estimated the cost effectiveness of our recommendations in this CTG based  on
information collected during the development of the 2002 NESHAP. Although there is limited
cost information available, we believe that the cost estimates and other related studies developed
for the 2002 NESHAP are appropriate for estimating the cost impact of our recommendations in
the CTG for the following reasons. The recommended level of control covers the same
processes as the 2002 NESHAP (i.e., all coating applicators and any associated drying/curing
equipment between the unwind/feed station and the rewind/cutting station).  In addition, both the
2002 NESHAP emission limits and the recommended limits are based on the use of similar
control measures (i.e., product substitution/reformulation, add-on control systems, or a
combination of these two options). Finally, the 2002 NESHAP cost data is the most recent
available.

       To develop emission and cost impacts for the 2002 NESHAP, EPA conducted a model
plant analysis, in which it evaluated HAP emissions associated with different kinds of coating
processes, the emission reduction capabilities of various control options, and the costs of such
controls. The model plants were developed to represent a range of sizes and emissions.  Table 2
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presents a summary of the model plant characteristics, the approach for complying with the
requirements of the 2002 NESHAP, the HAP emission reduction associated with compliance,
and the associated capital and annual cost estimates.  We believe that the model plant analysis
performed in the development of the 2002 NESHAP is representative of current operations in the
paper, film, and foil surface coating industry.

       The annual costs of complying with the 2002 NESHAP were estimated using 1998
dollars related to the use of thermal oxidizers to achieve a 95 percent HAP overall control
efficiency.4  The control option based on use of thermal oxidizers was chosen because this option
was expected to be the worst-case for costs. All other control options are expected to have lower
annual costs. These costs estimates were scaled to 2005 dollars and used to estimate annual
costs and cost effectiveness for this CTG.

       Based on the 2002 NEI database, we estimate that there are a total of 474 paper, film, and
foil surface coating facilities located in ozone nonattainment areas (using April 2004
designations). As previously mentioned, we are recommending that the control options
described in this CTG apply to facilities in ozone nonattainment areas with individual coating
lines with a potential to emit 25 tpy of VOC or greater, prior to the consideration of controls.
Based on VOC emissions data in the 2002 NEI database, 251 of the facilities in ozone
nonattainment areas have individual coating lines that have the potential to emit VOC at or
above this level.

       To estimate the costs associated with the add-on control recommendation in this CTG, we
assumed that 47 percent of the facilities in the 2002 NEI database (119 facilities) are currently
complying with the 2002 NESHAP.  Since the 2002 NESHAP requires a 95-percent HAP
emission reduction, which also achieves a 95-percent VOC emission reduction and is higher than
the recommended 90-percent emission reduction, we assume that facilities already in compliance
with the 2002 NESHAP would not be required to upgrade or install a thermal oxidizer to
implement the emission reduction recommended in the CTG and therefore would have no
additional annual costs. In addition, we assumed that since the facilities represented by Model
Plant 4 (see Table 2) already have an overall control  efficiency of 90 percent, these facilities
would not be required to upgrade the thermal oxidizer.

       Using the 2002 NEI, we found that 57  of the remaining 132 facilities reported the use of
control devices. Therefore, we removed 57 facilities from the model plant analysis.  We then
distributed the remaining 75 facilities across the model plants in the same ratios as those used
during the development of the 2002 NESHAP and apply the  annual costs (scaled to 2005 dollars)
for each model plant. Based on the average number of coating lines per facility identified in
Table 2, all of these facilities have individual coating lines with the potential to emit of 25 tpy
VOC or greater, prior to the consideration of controls.  Using this approach, we estimate that the
total annual cost associated with this CTG is $24.5 million per year.

       We used the 2002 NESHAP model plant emissions to estimate the aggregate VOC
emission reduction.  Table 3 presents the nationwide emission estimates using the model plant
approach.  As shown in Table  3, we estimate that VOC emissions from facilities in ozone
nonattainment areas are approximately 21,000 Mg/yr (23,100 tpy). Applying the 90-percent
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emission reduction to facilities above the emission cutoffs and that are located in ozone
nonattainment areas yielded an emission reduction of approximately 18,900 Mg/yr (20,800 tpy).
Therefore, the cost effectiveness was estimated to be $1,300 per Mg ($1,200 per ton) of VOC.
Table 3 presents the nationwide annual cost estimates for the paper, film, and foil surface coating
industry.

      We believe that our work practice recommendations in this CTG will result in a net cost
savings. Implementing work practices reduces the amount cleaning materials used by reducing
the amount that evaporates and is wasted.

VIII. References

1.     Control Of Volatile Organic Emissions From Existing Stationary Sources, Volume II:
      Surface Coating Of Cans, Coils,  Paper Fabrics, Automobiles, And Light Duty Trucks.,
      EPA-450/2-77-008, U. S. Environmental Protection Agency, Research Triangle Park,
      NC, May 1977. The 1977 CTG is included as Appendix A to this CTG.

2.     U.S. Environmental Protection Agency.  Standards of Performance for Pressure Sensitive
      Tape and Label Surface Coating Operations.  40 CFR part 60, subpart RR. October 18,
       1983.

3.     U.S. Environmental Protection Agency. National Emission Standards for Hazardous Air
      Pollutants: Paper and Other Web Coating. 40 CFR part 63, subpart JJJJ. December 4,
      2002.

4.     National Emission Standards for Hazardous Air Pollutants for Source Categories:
      Paper and Other Web Coating Operations  Background Information for Proposed
      Standards. EPA-453/R-00-002.  U.S. Environmental Protection Agency. Research
      Triangle Park, NC.  April 2000.

5.     Docket No. A-99-09. U.S. Environmental Protection Agency, Washington, DC. 1999.
      Responses from the paper and other web coating NESHAP survey.

6.     Handbook: Control Technologies for Hazardous Air Pollutants. EPA-625/6-91-014,
      U.S. Environmental Protection Agency, Cincinnati, Ohio.  June 1991.

7.     Pressure Sensitive Tape and Label Surface Coating IndustryBackground Information
      for Proposed Standards. EPA-450/3-80-003a, U.S. Environmental Protection Agency,
      Research Triangle Park, North Carolina. September 1980. pp. 3-14 to 3-15.

8.     Compilation of Air Pollutant Emission Factors  (AP-42), Volume I (Fifth Edition) .U.S.
      Environmental Protection Agency, Research Triangle Park, North Carolina. January
       1995. p. 4.2.2.6-3.

9.     OAQPS Control Cost Manual, 4th ed. EPA-450/3-90-006, U.S. Environmental
      Protection Agency, Research Triangle Park, North Carolina. January 1990.
                                          21

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10.    Telecommunication.  Sutton, L., EC/R Inc., Durham, North Carolina, with T. Godonis,
      American Biltrite, Inc., Moorestown, New Jersey.  March 19, 1998. Question regarding
      condensers.

11.    A Guideline for Surface Coating Calculations. EPA-340/1-86-016. U.S. Environmental
      Protection Agency, Washington, DC. July 1986.

12.    Improving Air Quality with Economic Incentive Programs. U. S. Environmental
      Protection Agency. Research Triangle Park, NC.  EPA-452/R-01-001. January 2001.
                                          22

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                            Table 2.  Specifications for Model Plants Developed for the 2002 NESHAP


Model
Plant
No.
la
Ib
lcc'd
2a

2b
3a

3b
4d
5d

Percent of
Database
Major
Sources
20
3
10
25

1
11

1
24
5
Overall
HAP
Control
Efficiency
(%)
0
0
0
50

50
80

80
90
95


Approach for
Capture and
Control"
PTE and new control
device
PTE and new control
device
No change
PTE and increase
T.O. efficiency
PTE
PTE and increase
T.O. efficiency
PTE
No change
No change
Average
Number
of
Coating
Lines
2
12

5

31
3

8


Average
Number
of
Coating
Stations
5
9

11

154
8

15




Coating
Use
(tpy)
2,108
7,521

8,607

369,929
7,518

14,516


Uncontrolled
Coating Line
HAP
Emissions
(tpy)
99
1,765

276

2,522
915

6,890



HAP
Emission
Reduction
(tpy)
94
1,677

124

1,135
137

1,034



Total Model
Plant
Capital
Costs ($)b
2,479,820
6,780,733

531,481

1,686,000
473,044

290,000



Total Model
Plant
Annual Cost
($/yr)b
713,596
1,923,790

174,162

873,287
161,250

120,638


a PTE = permanent total enclosure; T.O. = thermal oxidizer
b Costs developed in 1998 dollars.
0 Although a control efficiency of zero is stated, this model plant is assumed to be using compliant coatings.
d These model plants were not included in the analysis because they are assumed to be already in operating at the CTG's recommended level of control
                                                                  23

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                            Table 3.  Annual Cost Estimates for Paper, Film, and Foil Surface Coating Industry
Model
Plant
(a)
la
Ib
Ic
2a
2b
3a
3b
4d
5e

Model
Plant VOC
Emissions
(tpy) (b)
198
3,530
96
276
2,522
366
2,756
198
80

Percent of
Facilities
Requiring
Additional
Control
20%
3%
10%
25%
1%
11%
1%
24%
5%

Control Approach
for Complying with
Draft CTG
Recommendations
Install capture system
and new T.O.
Install capture system
and new T.O.
None
Install Capture system
and Increase T.O.
destruction efficiency
Install capture system
Install capture system
and Increase T.O.
destruction efficiency
Install capture system
None
None

1998
Dollars
Model
Plant Total
Annual
Cost ($/yr)
$713,596
$1,923,790
$0
$174,162
$873,287
$161,250
$120,638
$0
$0

Number of
Facilities
Impacted
by CTG (c)
15
2
7
19
1
8
1
18
4
75
Total VOC
Emissions in
Ozone
Nonattaiment
Areas (tpy)
2,970
7,943

5,175
1,892
3,020
2,067


23,066
2005 Dollars
Model
Plant
Total
Annual
Cost ($/yr)
$857,781
$2,312,499
$0
$209,352
$1,049,738
$193,831
$145,013
$0
$0

Nationwide
Total
Annual Cost
($/yr)
$12,866,713
$5,203,123
$0
$3,925,352
$787,304
$1,599,107
$108,760
$0
$0
$24,490,359
Cost
Effectiveness
($/ton)
$4,814
$728
$0
$843
$462
$588
$58
$0
$0
$1,180
(a) Model plants were defined during the development of the POWC NESHAP (40 CFR 63, subpart JJJJ).  (See Table 2)
(b) Model plant HAP emissions multiplied by 2:1 VOC to HAP ratio
(c) The number of facilities in the 2002 NEI located within ozone nonattainment areas and with individual coating lines with the potential to emit at least 25 tons per year of VOC from coatings, prior
to controls. Distributed across model plants using the percent of facilities subject to the NESHAP. (See Reference 10).

(d) In the 2002 NESHAP, facilities in this model plant category operate with an overall control efficiency of 90 percent, therefore, no upgrade in equipment would be necessary in order to comply with
the 90-percent recommended level of control in the draft CTG.

(e) In the 2002 NESHAP, facilities in this model plant category operate with an overall control efficiency of 95 percent, therefore, no upgrade in equipment would be necessary in order to comply with
the 90-percent recommended level of control in the draft CTG.
                                                                                 24

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                       Appendix A

Control of Volatile Organic Emissions from Existing Stationary
 Sources - Volume II:  Surface Coating of Cans, Coils, Paper,
        Fabrics, Automobiles, and Light-Duty Trucks

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Appendix A: Control of Volatile Emissions from Existing Stationary Sources - Volume II:
  Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks
       I
       I
       I

       I
       I

       I
       I
       fr*

       I
       I
       I
       I
       I

       I
       I

       I
       I
                       May lf>77
                             ft NO, 1.2-07.1)
        CONTROL OF VOLATILE
            ORGANIC EMISSIONS
                  FROM EXISTING
        STATIONARY SOIKCKS -
VOLl ME II: SURFACE COATING
        OF CANS, COILS, PAPER.
       FABRICS, AUTOMOBILES,
     AM) Llfill'I -DUTY TRUCKS
  i .N. i: \ v I HI > MK vi A I. I'm n t:<: 11 (^ i (; t" s*: v
     Offitf .
   HfHrnrvh Trinitplr Park, l^ci-rth I iarnlLnij 1^77 j ]
                                 A-l

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              A-2

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                        Appendix B

   Paper, Film, and Foil Surface Coating Facilities in Current
Nonattainment Areas and Associated State or Local Requirements
     (Based on 2002 NEI and December 2006 Nonattainment
                       Designations)

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Appendix B: Paper, Film, and Foil Surface Coating Facilities in Current Nonattainment Areas and Associated State or Local
                  Requirements (Based on 2002 NEI and December 2006 Nonattainment Designations)
State or Local Jurisdiction
California
Bay Area AQMD
Mojave Desert AQMD
Number of
Facilities in
Ozone
Nonattainment
Areas
38
11
1
Product Applicability

Paper, Fabric, and Film
Applies to coating lines that emit
more than 14.3 Ib VOC per day
Paper, Fabric, and Film
Applies to coating lines that emit less
than 14.3 Ib VOC per day
Cleaning Materials
Organic solvents or solvent-
containing materials
Applicable State Emission
Limit

2.2 Ib VOC per gallon
coating (excluding water) or
lib VOC per gallon
(excluding water) if using a
control device)
VOC emission limit of 5 tpy
or 3. 5 Ib VOC per gallon
coating (excluding water)
VOC emission limit of
50 g VOC/1 (0.42 Ib/gal)
1, 1 90 Ib VOC per month
Alternative Control Device Limits

Use capture and control system to
meet emission limit
Overall control efficiency of 85%
or an incinerator with a control
efficiency of 90%
Overall control efficiency of 85%
or use specified work practices
Overall control efficiency of 90%
                                                     B-l

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 Appendix B: Paper, Film, and Foil Surface Coating Facilities in Current Nonattainment Areas and Associated State or Local
               Requirements (Based on 2002 NEI and December 2006 Nonattainment Designations) (continued)
State or Local Jurisdiction
San Joaquin Valley
Unified APCD
South Coast AQMD
Colorado
Number of
Facilities in
Ozone
Nonattainment
Areas
3
23
8
Product Applicability
Organic solvents or solvent
containing materials that come into
contact with a flame, or are baked,
heat cured, or heat-polymerized in the
presence of O2
Organic solvents or solvent
containing photochemically reactive
solvent (except solvents that are
baked, heat cured, or heat-
polymerized)
Organic solvents or solvent
containing non-photochemically
reactive solvent (except solvents that
are baked, heat cured or heat-
polymerized)
Paper, Film, and Fabric
Cleaning Materials
Paper, Fabric, Plastic-Film, and Vinyl
Coating
Applicable State Emission
Limit
15 lb/ day (emissions from
air or heat drying for the first
12 hours must be included)
40 Ib/day (emissions from air
or heat drying for the first 12
hours must be included)
3,000 Ib/day (emissions from
air or heat drying for the first
12 hours must be included)
Coating lines and wash
primer: 265 g/1 (excluding
water)
Plastisol: 20 g/1 (excluding
water)
VOC limits of 25 g/1
(0.21 Ib/gal)
1 977 CTG Limits"
Alternative Control Device Limits
Overall control efficiency of 85%
Overall control efficiency of 85%
Overall control efficiency of 85%
Overall control efficiency of 90%
Use specified work practices
Use capture and control system to
meet emission limit
b 1977 CTG recommended limits: Paper Coating = 0.35 kg/1 (2.9 Ib/gal) coating, as applied (minus water and exempt compounds); Fabric Coating= 0.35 kg/1
(2.9 Ib/gal) coating, as applied (minus water and exempt compounds); Vinyl Coating = 0.45 kg/1 (3.8 Ib/gal) coating, as applied (minus water and exempt
compounds).
                                                            B-2

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Appendix B: Paper, Film, and Foil Surface Coating Facilities in Current Nonattainment Areas and Associated State or Local
             Requirements (Based on 2002 NEI and December 2006 Nonattainment Designations) (continued)
State or Local Jurisdiction
Connecticut
Delaware
Georgia
Illinois
Outside Chicago and Metro
East Areas
Chicago and Metro East
Areas
Indiana
Maine
Maryland
Michigan
Missouri
New Jersey
Number of
Facilities in
Ozone
Nonattainment
Areas
4
2
5
29
Unknown0
Unknown0

9
1
5
11
3
27
Product Applicability
Paper, Fabric, and Vinyl Coating
Paper, Fabric, and Vinyl Coating
Cleaning Materials
Paper, Fabric, and Vinyl Coating

Paper, Fabric, and Vinyl Coating
Paper coating
Specialty High Gloss Catalyzed
Coating
Paper, Fabric, and Vinyl Coating
Paper, Fabric, and Vinyl Coating
Paper, Fabric, and Vinyl Coating
Paper, Fabric, and Vinyl Coating
Paper, Fabric, and Vinyl Coating
Paper, Fabric, and Vinyl Coating
Paper, Fabric, and Vinyl Coating
Applicable State Emission
Limit
1 977 CTG Limits"
1 977 CTG Limits13
Composite vapor pressure no
more than 45 mmHg @
20C; OR solvent must be at
least 80% water
1 977 CTG Limits13

1 977 CTG Limits"
3.51bVOCpergallon
coating (except water)
2.3 IbVOC per gallon
coating (except water)
1 977 CTG Limits"
1 977 CTG Limits"
1 977 CTG Limits"
1 977 CTG Limits"
1977 CTG Limits"
1977 CTG Limits"
Alternative Control Device Limits
Overall control efficiency of 95%
Overall control efficiency of 95%
Use work practices to minimize
emissions
Overall control efficiency of 95%

Overall control efficiency of 81%
(control device must get 90%)
Overall control efficiency of 81%
(control device must get 90%)
Overall control efficiency of 81%
(control device must get 90%)
Overall control efficiency of
67.5% (Fabric and Vinyl only)
Overall control efficiency of 95%
Use capture and control system to
meet emission limit
Use capture and control system to
meet emission limit
Use capture and control system to
meet emission limit
Control emissions by 90%
! The number of facilities located within the Illinois jurisdictions is unknown.
                                                        B-3

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Appendix B: Paper, Film, and Foil Surface Coating Facilities in Current Nonattainment Areas and Associated State or Local
            Requirements (Based on 2002 NEI and December 2006 Nonattainment Designations) (continued)
State or Local Jurisdiction
New York
North Carolina
Pennsylvania
Rhode Island
South Carolina
Tennessee
Virginia
West Virginia
Number of
Facilities in
Ozone
Nonattainment
Areas
6
23
29
1
4
7
11
1
Product Applicability
Paper, Fabric, and Vinyl Coating
Cleaning Materials
Paper, Fabric, and Vinyl Coating -
CTG limits (on a Ib/gal coating basis)
apply only if using a control device
Paper and Fabric Coating
Vinyl Coating
Paper, Fabric, and Vinyl Coating
Cleaning Material
Paper, Fabric, and Vinyl Coating
Cleaning Material
Paper, Fabric, and Vinyl Coating
Paper, Fabric, and Vinyl Coating
Paper, Fabric, and Vinyl Coating
Cleaning Materials
Applicable State Emission
Limit
1977 CTG Limits"
No numeric limit
1977 CTG Limits"
4.4 Ib VOC per gallon
coating solids
7.69 Ib VOC per gallon
coating solids
1977 CTG Limits"
No numeric limit
1977 CTG Limits"
No numeric limit
1977 CTG Limits"
1977 CTG Limits"
1977 CTG Limits"
6.8 kg/day (15 Ib/day)
Alternative Control Device Limits
Control emissions by 80% using an
incinerator
Use work practices to minimize
VOC emissions
None
Use capture and control system to
meet emission limit
Use capture and control system to
meet emission limit
Control emissions by 95%
Keep records of cleaning materials
usage
Control emissions by 90% using an
incinerator
Keep records of cleaning materials
usage
Overall control efficiency of 95%
Use capture and control system to
meet emission limit
Overall control efficiency of 95%
Use work practices to minimize
emissions; Do not use VOCs for
cleanup activities unless equipment
is used to collect the cleaning
compounds and to minimize
evaporation
                                                     B-4

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Appendix B: Paper, Film, and Foil Surface Coating Facilities in Current Nonattainment Areas and Associated State or Local
            Requirements (Based on 2002 NEI and December 2006 Nonattainment Designations) (continued)
State or Local Jurisdiction
Wisconsin
Number of
Facilities in
Ozone
Nonattainment
Areas
7
Product Applicability
Paper, Fabric, and Vinyl Coating
Applicable State Emission
Limit
1 977 CTG Limits"
Alternative Control Device Limits
Control emissions by 90% using an
incinerator
                                                     B-5

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                        Appendix C

Summary of State-Specific Regulations for Paper, Film, and Foil
      Surface Coating Facilities (not including California)

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   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                          California)
   State/Locality
  Operations
   Covered
VOC Numerical
     Limit1
               Compliance Method
      Citation
Alabama
(Jefferson County)
Fabric coating
    0.35 kg/1
   (2.9 Ib/gal)
                    Paper coating
                     0.35 kg/1
                    (2.9 Ib/gal)
                    Vinyl coating
                     0.45 kg/1
                    (3.8 Ib/gal)
For sources located in Jefferson County:
 1.  Use low solvent coating technology; or
 2.  A capture and control system that have an overall
    VOC emission reduction that meet the applicable
    emission limit each day; or
 3.  Use powder coating technology; or
 4.  Average two or more coatings on a coating line
    that has no add-on VOC control equipment if:
  a.  The coating is the same type of operation (source
      category) and is subject to the same limits; and
  b.  The coatings are on the same coating line; and
  c.  The coatings are averaged on the basis of pounds
      of VOC emitted per gallon of coating solids
      applied to the substrate; and
  d.  The compliance demonstration is on a 24-hour
      period (calendar day); and
  e.  The VOC emissions shall be equal to or less than
      those emitted when all the surface coatings
      delivered to the application system comply with
      the applicable regulated VOC emission rate
      restriction.
Exemption: 55 gallons of "low-use coatings" may be
exempted on an annual rolling basis
Keep records of cleaning materials.	
Alabama DEM Air
Division Chapter 335-
3-6-.24 and 335-3-6-
.32(6), (7), and (9)
                                                             C-l

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   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                  California) (continued)
State/Locality
Alabama (except
Jefferson County)
Alaska3
Arizona
Arizona/Pima
Arizona/Final
Operations
Covered
Fabric coating
Paper coating
Vinyl coating

VOC Numerical
Limit1
0.35 kg/1
(2.9 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.45 kg/1
(3.8 Ib/gal)

Compliance Method
For sources NOT located in Jefferson County:
1 . Use low solvent coating technology; or
2. 90 percent emission reduction using incineration;
or
3 . Another equivalent control technology
Exemptions: Sources with the potential to emit less
than 100 ton VOC/yr and paper coating (335-3-6-. 1 1(6)
doesn't apply to any sources except sources in the State
which manufacture audio or video recording tape.
Keep records of cleaning material usage.

Citation
Alabama DEM Air
Division Chapters
335-3-6-.01and335-
3-6-. 11(6), (7),
and (9)

POWC - Incorporated by Reference, Subpart JJJJ
POWC - Incorporated by Reference, Subpart JJJJ
POWC - Incorporated by Reference, Subpart JJJJ
a Alaska does not have applicable air regulations. No cleaning material regulations.
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.
                                                            C-2

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   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                  California) (continued)
State/Locality
Arizona/Maricopa
Arkansas'3
Operations
Covered
Fabric coating
Paper coating
Vinyl coating
Cleaning
Materials

VOC Numerical
Limit1
0.35 kg/1
(2.9 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.45 kg/1
(3.8 Ib/gal)
35 mm Hg at 20C

Compliance Method
Apply all coatings containing more than 240 g VOC/L
(2 Ib/gal), minus exempt compounds using:
1 . Low pressure spray gun; or
2. An electrostatic system; or
3. Hydraulic pressure atomizer (including airless and
air assisted airless); or
4. Non-atomizing or non-spraying application
methods; or
5 . Alternate methods approved by regulatory
authorities
Use control systems meeting the following:
1 . Prevent at least 85% of the VOC emitted, except as
controlled using the alternative for very dilute
streams (see 3 below)
2. Use an 87% efficient capture system;
3 . Use a 90% efficient control system or for VOC
input less than 100 ppm - control to less than 20
mg VOC/M3 and the control system gets 85%
control
Exemptions: coatings and solvents with a VOC
content less than 18g VOC/L (0.15 Ib VOC/gal)
Work practices to minimize emissions

Citation
Regulation III, Rule
336, section 301
through 306

b Arkansas does not have applicable air regulations. No cleaning material regulations.
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.
                                                            C-3

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   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                               California) (continued)
State/Locality
Colorado
Connecticut
Operations
Covered
Fabric Coating
Paper Coating
Plastic-Film
Coating
Vinyl Coating
Fabric coating
Paper coating
Vinyl coating
VOC Numerical
Limit1
0.35 kg/1
(2.9 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.45 kg/1
(3.8 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.45 kg/1
(3.8 Ib/gal)
Compliance Method
1. Use compliant coatings;
2. Use emissions averaging;
3 . Use a capture system approved by the authority or
a system that meets the NSPS for Magnetic Tape
4. Use an add-on control system to meet the limit
Exemptions: fabric and paper coating operations with
uncontrolled actual emissions (including fugitives) are
less than 6.8 kg/day (15 Ib/day) and 1.4 kg/hr (3 Ib/hr).
No cleaning materials regulations
1. Compliant coatings;
2. Daily-weighted average coating content;
3. Install capture and control system that reduces
emissions by 95 percent
Exemptions: any coating unit with uncontrolled actual
emissions from all coating units are less than 6.8 kg
VOC per day (15 Ib/day) combined
No cleaning materials regulations.
Citation
CO DPHE
AQCC
Regulation No. 7
5 CCR 1001-9
Section IX. E, I, J, and
K
RSCA Title 22a
Section 22a-174-3c,
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                        C-4

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   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                               California) (continued)
State/Locality
Delaware
Florida
Operations
Covered
Fabric coating
Paper coating
Vinyl coating
Cleaning
Materials
Fabric Coating
Paper Coating
Vinyl Coating
VOC Numerical
Limit1
0.35 kg/1
(2.9 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.45 kg/1
(3.8 Ib/gal)
Composite vapor
pressure of 45 mm
Hg at 20 C
Or
Solvent must be at
least 80% water, as
applied
0.35 kg/1
(2.9 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.46 kg/1
(3.8 Ib/gal)
Compliance Method
1. Compliant coatings;
2. Daily weighted average coating content
3 . Install capture and control system that reduces
emissions by 95 percent
Exemptions: any coating unit with uncontrolled actual
emissions from all coating units are less than 15 Ib
VOC/day
Does not apply to hand-wipe cleaning operation
Use work practices to minimize emissions
1. Use of compliant coatings;
2. Use of incineration that reduces VOC emissions by
90 percent.
Exemptions: all emission units subject to the same
limitation that emit less than 6.8 kg VOC per day (15
Ib/day) and 1 .4 kg/hr (3 Ib/hr) combined
No cleaning material regulations.
Citation
DNREC Regulation
24, Section 16, 17,
and 18

FAC Chapter 62-
296.500, 503, and 504
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                        C-5

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   Appendix C:  Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                  California) (continued)
State/Locality
Georgia
Hawaii0
Idaho
Operations
Covered
Fabric Coating
Paper coating
Vinyl coating

VOC Numerical
Limit1
2.9 Ib/gal
OR
4.79 Ib/gal coating
solids (if coating
content is >
2.9 Ib/gal)
2.9 Ib/gal
OR
4.79 Ib/gal coating
solids (if coating
content is >
2.9 Ib/gal)
3. 8 Ib/gal
OR
7.86 Ib/gal coating
solids (if coating
content is >
3. 8 Ib/gal)

Compliance Method
1 . Use low solvent compliant coating technology
2. Use 24-hr weighted average of low solvent coating
on a single coating line that meets 4.79 Ib VOC/gal
coating solids for fabric and paper or 7.86 Ib/gal
coating solids for vinyl (averaging across coating
lines is not allowed)
3 . Use capture and control that reduces VOC
emissions by 90 percent and overall VOC
emissions do not exceed 4.79 Ib VOC/gal coating
solids for fabric and paper or 7.86 Ib/gal coating
solids for vinyl
Exemptions: Sources located outside Cherokee,
Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette,
Forsyth, Fulton, Gwinnett, Henry, Paulding, and
Rockdale counties with potential VOC emissions
are less than 100 tons per year; Sources located within
Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas,
Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding, or
Rockdale counties with actual VOC emissions are less
than 15 Ib/day; total use of coatings, inks and other
VOC-containing materials is less than 55 gal/yr
No cleaning material regulations.

Citation
GDNR
OGCA 12-9-1
391-3-l-.03(2)(w)and
(x)

POWC - Incorporated by Reference, Subpart JJJJ
0 Hawaii does not have applicable air regulations. No cleaning material regulations.
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.
                                                           C-6

-------
   Appendix C:  Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                    California) (continued)
   State/Locality
  Operations
   Covered
VOC Numerical
     Limit1
               Compliance Method
      Citation
Illinois (not
including Chicago
and Metro East
areas)
Fabric Coating
Paper coating-
Specialty High
Gloss
Catalyzed
Coating	
                    Paper coating -
                    all others
                    Vinyl Coating
    0.35 kg/1
   (3.8 Ib/gal)
    0.42 kg/1
   (3.5 Ib/gal)
                     0.35 kg/1
                    (2.9 Ib/gal)
                     0.45 kg/1
                    (3.8 Ib/gal)
 1.  Control emissions by an afterburner system which
    provides an overall 81% VOC emission from the
    coating line, and 90% of the nonmethane VOC
    (measured as total combustible carbon) which
    enters the afterburner.
 2.  The combined actual emissions from selected
    coating lines (not including those constructed or
    modified after 7/1/79), is less than or equal to the
    combined allowable emissions calculated using the
    formula provided in the regulation.
Exemptions:  Coating plants in which uncontrolled
VOC emissions are limited by the operating permit to
22.7 Mg/yr (25 tpy); or the total coating usage does not
exceed 9,463 1/yr (2,500 gal/yr); or touch-up and repair
coatings used by a vinyl if the source-wide volume is
less than 0.95 1 (1 quart) per eight-hour period or
exceeds 209 1/yr (55 gal/yr) for any rolling twelve-
month period.
No cleaning material regulations.	
Title 35, Subtitle B,
Chapter I; Subchapter
c, Part 215, Subpart F,
sections 215.204(c),
(e) and (f) and
215.205(b) and
215.206 (a) and (b)
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                              C-7

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                    California) (continued)
   State/Locality
  Operations
   Covered
VOC Numerical
     Limit1
               Compliance Method
      Citation
Illinois (Chicago
areas)
Fabric Coating
    0.28 kg/1
   (2.3 Ib/gal)
                    Paper coating
                     0.28 kg/1
                    (2.3 Ib/gal)
                    Vinyl Coating
                     0.28 kg/1
                    (2.3 Ib/gal)
 1.  Apply coatings that, during each day, do not exceed
    the daily-weighted average VOC content limit
 2.  Use a capture and control system which has an
    overall VOC emission reduction of 81% and the
    control device has a 90% efficiency
 3.  Capture and control system reduces VOC
    emissions to meet the applicable VOC emission
    limit.
Exemptions:  Coating plants in which combined actual
uncontrolled VOC emissions do not exceed 6.8 kg/day
(15 Ib/day); or touch-up and repair coatings used by a
vinyl if the source-wide volume is less than 0.95 1 (1
quart) per eight-hour period or exceeds 209 1/yr (55
gal/yr) for any rolling twelve-month period.
No cleaning material regulations.	
Title 35, Subtitle B,
Chapter I; Subchapter
c, Part 218, Subpart F,
sections 218.204(c),
(e) and (f) and
218.205(a) and
218.207(b)and
218.208(a)and(c)
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                   California) (continued)
   State/Locality
  Operations
   Covered
VOC Numerical
     Limit1
               Compliance Method
      Citation
Illinois (Metro East
areas)
Fabric Coating
    0.28 kg/1
   (2.3 Ib/gal)
                    Paper coating
                     0.28 kg/1
                    (2.3 Ib/gal)
                    Vinyl Coating
                     0.28 kg/1
                    (2.3 Ib/gal)
 1.  Apply coatings that, during each day, do not exceed
    the daily-weighted average VOC content limit
 2.  Use a capture and control system which has an
    overall VOC emission reduction of 81% and the
    control device has a 90% efficiency
 3.  Capture and control system reduces VOC
    emissions to meet the applicable VOC emission
    limit.
Exemptions:  Coating plants in which combined actual
uncontrolled VOC emissions do not exceed 6.8 kg/day
(15 Ib/day); or touch-up and repair coatings used by a
vinyl if the source-wide volume is less than 0.95 1  (1
quart) per eight-hour period or exceeds 209 1/yr (55
gal/yr) for any rolling twelve-month period.
No cleaning material regulations.	
Title 35, Subtitle B,
Chapter I; Subchapter
c, Part 219 SubpartF,
sections 219.204(c),
(e) and (f) and
219.205(a) and
219.207(b)and
219.208(a)and(c)
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                             C-9

-------
   Appendix C:  Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                  California) (continued)
State/Locality
Indiana
Iowa
Kansas'1
Operations
Covered
Fabric Coating
Paper coating
Vinyl Coating
VOC Numerical
Limit1
0.35 kg/1
(2.9 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.58 kg/1
(4.8 Ib/gal)
Compliance Method
1 . Use compliant coatings or
2. Fabric and vinyl coating operations can install
capture and control devices with an overall
efficiency greater than 67.5% given that the capture
efficiency is greater than 75% and the control
device efficiency is greater than 90%
Exemptions: Facilities existing before 1/1/80 not
located in Clark, Elkhart, Floyd, Lake, Marion, Porter,
and St. Joseph Counties which have potential emissions
less than 90.7 Mg/yr (100 tpy); Facilities constructed
after 1/1/80 located in any county with potential
emissions less than
22.7 Mg/yr (25 tpy), Facilities existing before 7/1/90
and not located in Clark, Elkhart, Floyd, Lake, Marion,
Porter, and St. Joseph Counties and facilities
constructed after 7/1/90 and located in any county with
actual uncontrolled emissions less than 15 Ib VOC/day
No cleaning material regulations.
Citation
IDEM Air Pollution
Control Board title
326
326 IAC 8-2-1, 8-2-5,
8-2-11
POWC - Incorporated by Reference, Subpart JJJJ




d Kansas has no applicable air regulations. No cleaning material regulations.
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.
                                                           C-10

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                               California) (continued)
State/Locality
Kentucky
Louisiana
Maine
Operations
Covered
Fabric Coating
Paper Coating
Vinyl Coating
Fabric Coating
Paper coating
Vinyl Coating
Fabric Coating
Paper coating
VOC Numerical
Limit1
15% by weight of
VOCs net input into
the facility OR
0.35 kg/1
(2.9 Ib/gal)
15 % by weight of
VOCs net input into
the facility OR
0.35 kg/1
(2.9 Ib/gal)
15% by weight of
VOCs net input into
the facility OR
0.45 kg/1
(3. 8 Ib/gal)
0.28 kg/1
(2.3 Ib/gal)
0.28 kg/1
(2.3 Ib/gal)
0.28 kg/1
(2.3 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
Compliance Method
Exemptions: facility with actual uncontrolled
emissions less than 3 Ib/hr; 15 Ib/day; or 10 tpy based
on maximum production and 8,760 hr/yr. Low use
coating if plantwide consumption is less than or equal to
55 gal/previous 12 months
No cleaning material regulations.
1 . Capture system with at least 80% efficiency
2. Low solvent coating
3 . Incinerator with at least 90% control efficiency
4. Carbon adsorption
Exemptions: all emission units subject to the same
limitation that emit less than 6.8 kg VOC per day (15
Ib/day) and 1 .4 kg/hr (3 Ib/hr) combined
No cleaning material regulations.
1 . Low solvent coating
2. Capture and control system that gets 95% control
or 4.9 Ib/gal solids
Citation
401KAR61:120
LAC Title 33 2 123 .A,
C
06 096 Chapter 123
3. A and B; and
Chapter 129 l.E, 3.B
andC
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                        C-ll

-------
   Appendix C:  Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                    California) (continued)
   State/Locality
  Operations
   Covered
VOC Numerical
     Limit1
               Compliance Method
      Citation
                    Vinyl Coating
                     0.45 kg/1
                    (3.8 Ib/gal)
                  Exemptions: maximum theoretical VOC emissions
                  from all coating units, lines or operations under the
                  same surface coating category less than 10 tpy. Or
                  Coating units, lines or operations whose total actual
                  coatings usage from all coating units, lines or operations
                  under the same surface coating category is less than 50
                  gal/yr of coatings. OR facilities that use powder
                  coatings or other non-VOC coating methods.
                  No cleaning material regulations.	
Maryland
Fabric Coating
    0.35 kg/1
   (2.9 Ib/gal)
                    Paper Coating
                     0.35 kg/1
                    (2.9 Ib/gal)
                    Vinyl Coating
                     0.45 kg/1
                    (3.8 Ib/gal)
 1.  Use low VOC coatings or adhesives;
 2.  Use a control device that, results in an emission
    reduction equal to or greater than the emission
    reduction that would have been achieved by
    complying low use VOC coatings
 3.  Reduce emissions by using water-based coatings,
    resins, inks, or similar products that contain less
    than 25 percent VOC by volume of the volatile
    portion of the product; or
 4.  A alternative method approved by authority
Exemptions: Facilities with emissions less than 20 Ib
VOC/day
No cleaning material regulations.	
ACM Subtitle 11
26.11.19.02 and .07
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                             C-12

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                               California) (continued)
State/Locality
Massachusetts
Michigan
Minnesota
Mississippi
Operations
Covered
Fabric Coating
Paper Coating
Vinyl Coating
Fabric Coating
Paper Coating
Vinyl Coating
VOC Numerical
Limit1
4.8 Ib/gal solids, as
applied (does not
exclude water)
4.8 Ib/gal solids, as
applied (does not
exclude water)
7.8 Ib/gal solids, as
applied (does not
exclude water)
2.9 Ib/gal
2.9 Ib/gal
3. 8 Ib/gal
Compliance Method
1 . Use low/no solvent coatings
2. Use add-on controls
3 . Use Daily weighted averaging
Exemptions: facilities for which the total amount of all
coatings exempted is less than 55 gal on a 12-month
rolling period and facilities with uncontrolled VOC
emissions less than 15 Ib/day
Keep records of cleaning materials usage
1 . Use compliant coatings
2. Use volume weighted average emissions coating
content
3 . Use add-on controls combined with volume
weighted average
Exemptions: Facilities with a combined actual VOC
emission rate less than 100 Ib/day or 2,000 Ib/month
and facilities may exclude low-use coatings that total 55
gallons or less per rolling 12-month period.
No cleaning materials regulations
Citation
3 10 CMR 7. 18(14),
(15) and (16)
R3 3 6. 16 10(2), (7) and
(8) and
R336.2040(12)(a)
and(b)
POWC - Incorporated by Reference, Subpart JJJJ
POWC - Incorporated by Reference, Subpart JJJJ
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                        C-13

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                  California) (continued)
State/Locality
Missouri
Montana
Nebraska
Nevada6
New Hampshire
Operations
Covered
Fabric Coating
Paper Coating
Vinyl Coating
Other coatings
VOC Numerical
Limit1
2.9 Ib/gal
2.9 Ib/gal
3.81b/gal
3 Ib/gal
Compliance Method
1 . Comply with daily volume-weighted average, as
applied, on a Ib/gal coating basis
2. Comply with daily volume-weighted average, as
applied, on a Ib/gal coating solids basis;
3 . Comply with a combination of capture and control
system and daily volume -weighted average.
Exemptions: Does not apply to sources located outside
of Clay, Jackson, and Platte counties and sources with
total uncontrolled potential VOC emissions is less than
6.8 kg/day (2.7 tpy).
No cleaning material regulations.
Citation
10CSR10-
2.230(l)(A)and(B),
(4) and (5)
POWC - Incorporated by Reference, Subpart JJJJ
POWC - Incorporated by Reference, Subpart JJJJ

Fabric Coating
Paper Coating
Vinyl Coating

0.35 kg/1
(2.9 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.45 kg/1
(3.8 Ib/gal)

1 . Use compliant coatings
2. Use add-on controls
3 . Implement a "bubble" and comply with the
calculated solids-based emission rate limit
4. Meet either an approved coatings -based or an
approved solids-based modified emission limit
using RACT order provisions
Exemptions: (1) sources with theoretical potential
emissions less than 10 tons VOC per any consecutive
12-month period since December 31, 1989; (2)
No cleaning materials regulations.

NH CAR Chapter
Env-A1200
e Nevada has no air regulations applicable to the PFF industry. No cleaning material regulations.
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.
                                                           C-14

-------
   Appendix C:  Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                    California) (continued)
   State/Locality
  Operations
   Covered
VOC Numerical
     Limit1
               Compliance Method
      Citation
New Jersey
Fabric Coating
    0.35 kg/1
   (2.9 Ib/gal)
                    Paper Coating
                     0.35 kg/1
                    (2.9 Ib/gal)
                    Vinyl Coating
                     0.45 kg/1
                    (3.8 Ib/gal)
 1.  Control emissions by 90 percent
 2.  Control emissions such that the hourly VOC
    emission rate does not exceed a calculated max
    hourly emission rate
Exemptions: total surface coating formulation
containing VOC are applied at a rate less than 1A gallon
per hour and 2 !/> gallons per day
No cleaning materials regulations.	
NJAC Title 7, Chapter
27,subchapter 16
7:27-16.7
New Mexico
POWC - Incorporated by Reference, Subpart JJJJ
New York
Fabric Coating
                    Paper Coating
                    Vinyl Coating
   2.9 Ib/gal
                     2.9 Ib/gal
                     3.8 Ib/gal
 1.  Use a VOC incinerator that with 80% removal
    efficiency
 2.  Determine overall removal efficiency of an air
    cleaning device on a solids as applied basis unless
    the air cleaning device has an 85% removal
    efficiency
Exemptions:  Low-use coatings where the combined
facility-wide usage is less than 55 gallons on a 12-
month rolling average

Use work practices to minimize VOC emissions from
cleaning materials.	
NY ECL part 228
Sections 228.1, 3, and
7
f New Mexico has a local agency with air regulations, but they could not be accessed on the Internet.
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.
                                                              C-15

-------
   Appendix C:  Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                 California) (continued)
State/Locality
North Carolina
North Dakota8
Operations
Covered
Fabric Coating
Paper Coating
Vinyl Coating

VOC Numerical
Limit1
4.8 Ib/gal coating
solids, OR
2.9 Ib/gal if using a
control device
4.8 Ib/gal coating
solids, OR
2.9 Ib/gal if using a
control device
7.9 Ib/gal coating
solids, OR
3.8 Ib/gal if using a
control device

Compliance Method
Exemptions: Sources with VOC emissions less than 15
Ib/day
No cleaning material regulations.

Citation
NCAC 2D.0920 and
21

g North Dakota does not have applicable air regulations.
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.
                                                          C-16

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                               California) (continued)
State/Locality
Ohio (Ashtabula,
Butler, Clark,
Clermont,
Cuyahoga,
Delaware, Franklin,
Geauga, Greene,
Hamilton, Lake,
Licking, Lorain,
Lucus, Mahoning,
Medina, Miami,
Montgomery,
Portage, Stark,
Summit, Trumbull,
Warren, and Wood
Counties)
Operations
Covered
Fabric coating
Paper coating
Vinyl coating
VOC Numerical
Limit1
4.8 Ib/gal solids (if
using a control
system)
OR
2.9 Ib/gal coating
4.8 Ib/gal solids (if
using a control
system)
OR
2.9 Ib/gal coating
4.8 Ib/gal coating
(excluding water
and exempt
solvents)
OR
25% VOC by
volume of the
volatile matter of
the coating
Compliance Method
1 . Use complying coatings
2. Use a capture and control system with overall VOC
emission reduction greater than 81%, by weight, in
the overall VOC emissions from the coating line;
and the control equipment has an VOC emission
reduction efficiency of 90% by weight
3. Vinyl coating line only: install capture system with
75% by weight control efficiency and a control
system that reduces emissions by 90% by weight
Exemption: Emissions from all coating lines at the
facility is less 15 Ib VOC/day (before add-on controls)
and a paper coating line which has a maximum
application of coating materials less
than or equal to 3 gal/day
No cleaning material regulations apply to paper coating
lines
Citation
OAC 3745-21-09 (F),
(G), and (H)
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                        C-17

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                               California) (continued)
State/Locality
Ohio (remaining 64
counties)
Oklahoma -
attainment areas not
in Tulsa County
Operations
Covered
Fabric coating
Paper coating
Vinyl coating
Coating
Operations
VOC Numerical
Limit1
4.8 Ib/gal solids (if
using a control
system)
OR
2.9 Ib/gal coating
4.8 Ib/gal solids (if
using a control
system)
OR
2.9 Ib/gal coating
4.8 Ib/gal coating
(excluding water
and exempt
solvents)
OR
25% VOC by
volume of the
volatile matter of
the coating
Ranges from 4.8 to
6.5 Ib/gal
(depending on type
of coating)
Compliance Method
1 . Use complying coatings
2. Use a capture and control system with overall VOC
emission reduction greater than 81%, by weight, in
the overall VOC emissions from the coating line;
and the control equipment has an VOC emission
reduction efficiency of 90% by weight
3. Vinyl coating line only: install capture system with
75% by weight control efficiency and a control
system that reduces emissions by 90% by weight
Exemption: Existing facilities (for which construction
or modification commenced before October 19, 1979)
and have the potential to emit less than 100 tpy VOC.
Emissions from all coating lines at the facility is less 15
Ib VOC/day (before add-on controls) and a paper
coating line which has a maximum application of
coating materials less
than or equal to 3 gal/day
No cleaning material regulations apply to paper coating
lines
1 . Compliant coatings
2. Incineration, absorption, adsorption, or other
process so long as emissions are no more than they
would be using compliant coatings
Exemptions: sources that emit less than 100 Ib/day of
VOC.
Include VOC emissions from clean up in determining
compliance
Citation
OAC 3745-21-09 (F),
(G), and (H)
Title 252, Chapter
100,252:100-37-25
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.
                                                        C-18

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                               California) (continued)
State/Locality
Oklahoma - Tulsa
County
Oregon
Pennsylvania
Operations
Covered
Coating
operations
Fabric Coating
Paper Coating
Vinyl Coating
Existing
Coating of
Paper & Film in
the Medford-
Ashland
AQMA
Fabric Coating
Paper Coating
Vinyl Coating
VOC Numerical
Limit1
Ranges from 3.0 to
4.3 Ib/gal
(depending on type
of coating)
2.9 Ib/gal
2.9 Ib/gal
3. 8 Ib/gal
551b/100sqyards
of material per pass
0.58 kg/1 coating
solids (4.84 Ib/gal)
0.58 kg/1 coating
solids (4.84 Ib/gal)
0.92 kg/1 coating
solids (7.69 Ib/gal)
Compliance Method
1 . Compliant coatings
2. Incineration, absorption, or other equipment so long
as emissions are no more than they would be using
compliant coatings, and at least 85% overall control
efficiency
Include VOC emissions from clean up in determining
compliance
1 . Use low solvent coatings;
2. Use an incineration system that gets 90% control or
3 . An equivalent means of control
Exemptions: Sources whose potential VOC emissions
are less than 10 tpy (or 3 Ib VOC/hr or 15 Ib VOC/day
actual).
Keep records of cleaning materials usage
1. Use compliant coatings, as applied.
2. Use combination of compliant coatings and capture
and control systems
Exemptions: A facility that has had actual VOC
emissions less than 1 .4 kg/hr (3 Ib/hr), 7 kg/day
(15 Ib/day) or 2,455 kg/yr (2.7 tpy) during any calendar
year since January 1, 1987
No cleaning material regulations.
Citation
Title 252, Chapter
100,252:100-39-46
OAR 340-232-0 160
129-52
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                        C-19

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                               California) (continued)
State/Locality
Rhode Island
South Carolina
South Dakota
Operations
Covered
Fabric coating
Paper coating
Vinyl coating
Fabric coating
Paper coating
Vinyl coating
VOC Numerical
Limit1
4.8 Ib/gal coating
solids or
2.9 Ib/gal coating
4.8 Ib/gal coating
solids or
2.9 Ib/gal coating
3.8 Ib/gal coating
solids or
7.86 Ib/gal coating
0.35 kg/1
(2.9 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.45 kg/1
(3. 8 Ib/gal)
Compliance Method
1 . Reduce VOC emissions by 95% using a control
system;
2. Use compliant coatings;
3. Use control systems to meet coating content limits;
4. Use daily-weighted averaging
5 . Use an approved alternative method
Exemptions: Actual uncontrolled VOC emissions are
less than 15 Ib/day since 12/31/89.
Keep records of cleaning materials usage.
1 . Low solvent technology
2. Incineration that reduces VOC emissions by 90
percent
3 . Carbon bed solvent recovery or
4. Alternative technology
Exemptions: plants with total potential VOC
emissions less than 550 pounds (250 kilograms) in any
one day (nominal size - 100 tons per year) or more than
150 pounds (68 kilograms) in any one hour.
Keep records of cleanup materials
Citation
Air Pollution Control
Regulation No. 19
62.5, St. 5, Part B and
C
POWC - Incorporated by Reference, Subpart JJJJ
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                        C-20

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                   California) (continued)
   State/Locality
  Operations
   Covered
VOC Numerical
     Limit1
               Compliance Method
      Citation
Tennessee
Fabric coating
    0.35 kg/1
   (2.9 Ib/gal)
                     Paper coating
                     0.35 kg/1
                    (2.9 Ib/gal)
                     Vinyl coating
                     0.45 kg/1
                    (3.8 Ib/gal)
 1.  Use compliant coatings;
 2.  Meet limit using weighted average VOC content
 3.  Reduce emissions by 95% using capture and
    control system
Exemptions:  Facilities located in Davidson,
Rutherford, Sumner, Williamson, or Wilson County
with actual uncontrolled VOC emissions from all paper
coating operations less than 6.8 kg (15 Ib) per day or
whose max theoretical VOC emissions from all paper
coating operations are less than 10 tpy.  Facilities in
Hamilton or Shelby County with potential VOC
emissions from all paper coating operations less than 25
tpy, Facilities located in any other county with
potential VOC emissions from all paper coating
operations less than 100 tpy.
No cleaning material regulations.	
1200-3-18-14, 15, 16
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                            C-21

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                               California) (continued)
State/Locality
Texas -
Beaumont/Port
Arthur, Dallas/ Fort
Worth, El Paso, and
Houston/ Galveston
Areas










Operations
Covered
Fabric Coating

Paper Coating

Vinyl Coating











VOC Numerical
Limit1
2.9 Ib/gal
(0.35 kg/1)
2.9 Ib/gal
(0.35 kg/1)
3. 8 Ib/gal
(0.45 kg/1)
not including
plastisol








Compliance Method
1. Use compliant coatings;
2. Use a vapor control system that gets 80% overall
control or
3 . Any alternate methods of control must be approved
Exemptions: (1) Sources that emit uncontrolled VOC
less than 3 Ib/hr or 15 Ib in any consecutive 24-hr
period. (2) sources that emit uncontrolled VOC less
than 100 Ib in any consecutive 24-hr period if
documentation is received and approved that
demonstrates that the performance criteria cannot be
achieved with compliant coatings and control
equipment is not technically or economically feasible.
(3) a source with total coating and solvent usage is less
than 150 gal in any consecutive 12-month period. (4)
aerosol spray cans
No cleaning material regulations.
Citation
TAG Title 30, Parti,
Chapter 115,
Subchapter E,
Division 2, Rule
115. 420 through
115.427










1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                        C-22

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                               California) (continued)
State/Locality
Texas - Gregg,
OO"
Nueces, and
Victoria Counties
Utah
Operations
Covered
Fabric Coating
Paper Coating
Vinyl Coating
Fabric coating
Paper coating
Vinyl coating
VOC Numerical
Limit1
2.9 Ib/gal
(0.35 kg/1)
2.9 Ib/gal
(0.35 kg/1)
3. 8 Ib/gal
(0.45 kg/1)
not including
plastisol
0.35 kg/1
(2.9 Ib/gal) OR
4.8 Ib/gal coating
solids
0.35 kg/1
(2.9 Ib/gal) OR
4.8 Ib/gal coating
solids
0.45 kg/1
(3.8 Ib/gal) OR
7.9 Ib/gal coating
solids
Compliance Method
1. Use compliant coatings;
2. Use a vapor control system that gets 80% overall
control or
3 . Any alternate methods of control must be approved
Exemptions: (1) Sources that emit uncontrolled VOC
less than 550 Ib in any consecutive 24-hr period. (2)
aerosol spray cans
No cleaning material regulations.
1 . Use low solvent technology coatings;
2. Reduce VOC emissions by 90% using an
incinerator or using a carbon adsorber
Exemptions: Sources whose VOC emissions are less
than 6.8 kg (15 Ib) in any 24 hour period, nor more than
1 .4 kg (3 Ib) in any one hour
Work practices to minimize VOC emissions from
cleaning materials
Citation
TAG Title 30, Parti,
Chapter 115,
Subchapter E,
Division 2, Rule
115. 420 through
115.427
R307-340-2andll
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                        C-23

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                                    California) (continued)
   State/Locality
  Operations
   Covered
VOC Numerical
     Limit1
               Compliance Method
      Citation
Vermont
Paper Coating
   2.9 Ib/gal
                    Other coating
                    sources
                     3.5 Ib/gal
 1.  Daily weighted average of VOC content must
    comply with VOC limit.
 2.  Install capture and control device where the overall
    reduction efficiency is greater than or equal to the
    required reduction efficiency (an efficiency is not
    specified).
Exemptions: Paper coating sources that have actual
uncontrolled VOC emissions less than 15 Ib/day. Other
VOC sources with allowable VOC emissions less than
50 tpy any year since 1/1/90.
No cleaning material regulations.	
5-253.10
Virginia
Fabric Coating
   2.9 Ib/gal
                    Paper Coating
                     2.9 Ib/gal
                    Vinyl coating
                     3.8 Ib/gal
 1.  Use of waterborne coatings;
 2.  Use of high-solids coatings;
 3.  Carbon adsorption;
 4.  Incineration; or
 5.  Any technology with an equivalent control
    efficiency when compared to the use of a coating
    complying with the VOC limit
Exemptions: Coating plants with actual VOC
emissions less than 2.7 tpy, 15 Ib/day and 3 Ib/hr. All
VOC emissions from purging or washing solvents must
be included.
No cleaning material regulations.	
9 VAC 5-40-4330 and
9 VAC 5-40-4480
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                             C-24

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                               California) (continued)
State/Locality
Washington
West Virginia
Operations
Covered
Fabric coating
Paper coating
Vinyl coating
Fabric coating
Paper coating
Vinyl coating
Cleaning
Materials
VOC Numerical
Limit1
0.35 kg/1
(2.9 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.45 kg/1
(3. 8 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.35 kg/1
(2.9 Ib/gal)
0.45 kg/1
(3.8 Ib/gal)
6.8 kg/day
(15 Ib/day)
Compliance Method
Exemption: Coating and dryer operations with
potential uncontrolled VOC emissions less than 18 kg
(40 lb)/24-hr period.
No cleaning material regulations.
1 . Daily weighted emission limitation
2. Use a capture and control system with an overall
emission reduction of 95%
Exemptions: coating operations at facilities with
uncontrolled actual VOC emissions less than 0.68 kg
(15 Ib) per day.
Use work practices to minimize emissions.
Do not use VOCs for cleanup activities unless
equipment is used to collect the cleaning compounds
and to minimize their evaporation to the atmosphere.
Citation
WAC 173-490-040(6)
42-21-13, 14, and 15
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                        C-25

-------
   Appendix C: Summary of State-Specific Regulations for Paper, Film, and Foil Surface Coating Facilities (not including
                                               California) (continued)
State/Locality
Wisconsin
Wyoming
Operations
Covered
Fabric coating
Paper coating
Vinyl coating
VOC Numerical
Limit1
0.35 kg/1
(2.9 Ib/gal) OR
4.8 Ib/gal coating
solids
0.35 kg/1
(2.9 Ib/gal) OR
4.8 Ib/gal coating
solids
0.45 kg/1
(3.8 Ib/gal) OR
7.9 Ib/gal coating
solids
Compliance Method
1. Use of low solvent coatings
2. Use a vapor recovery system
3 . Use incinerator with a 90% emission reduction
4. Daily volume -weighted average
Exemptions: coating operations at facilities with
uncontrolled actual VOC emissions less than 0.68 kg
(151b)perday.
No cleaning material regulations.
Citation
NR 422.04, 07 and 08
POWC - Incorporated by Reference, Subpart JJJJ
1 Numerical limits are as applied, minus water and exempt compounds, unless otherwise noted.

                                                        C-26

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                      Appendix D

Summary of California Regulations for Paper, Film, and Foil
                Surface Coating Facilities

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This page intentionally left blank.

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Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities
Operation
Material
voc
limitation
Compliance Requirements
Citation
Antelope Valley Air Pollution Control District
Paper, fabric
and film
Coating
Plastisol
Wash primer
Content limit
of265g/las
applied (except
water and
exempt
compounds)
Content limit
of20g/las
applied (except
water and
exempt
compounds)
Content limit
of265g/l
material used
1 . Use compliant coatings; or use an collection system that has a capture
efficiency of at least 90 %, by weight and the control device has an
emission reduction efficiency of 95 % by weight or to an outlet
concentration of 50 ppmv (as carbon)
2. Coatings containing 20 g VOC/1 material or more must be applied
using hand application methods; HVLP spray (air dried coatings only);
or one of the following coalers: flow, roll, dip, foam, and die.
Alternative coating methods must be approved.
3 . Containers and mixing tanks must be free from leaks and covered
except when adding or removing materials, cleaning or when the
container is empty.
4. Solvent cleaning must use one of the following: wipe cleaning; closed
containers or hand held spray bottles w/out propellant-induced force;
cleaning equipment which has a solvent container that is closed at all
times (except when adding or removing parts or during repair); remote
reservoir cleaner; non-atomized solvent flow where solvent is collected
in a container or collection system that is closed at all times except for
solvent collection and pressure relief (as needed) openings; and solvent
flushing methods where solvent is collected in a container or collection
AVAQMDRule 1128
and 1171
                                            D-l

-------
     Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Material
  VOC
limitation
Compliance Requirements
Citation
             Solvent cleaning
             materials
             (excluding hand
             wiping)
               Content limit
                 of950g/l
              (7.91 g/gal) and
                   VOC
                 composite
              partial pressure
               of 35 mmHg
               @20C (68F)
                  system that is closed at all times except for solvent collection and
                  pressure relief (as needed) openings (discharged solvent must be
                  collected into containers without atomizing into the air and solvent
                  may be flushed through the system by air or hydraulic pressure or by
                  pumping).
              5.   All VOC-containing solvents must be stored in non-absorbent, non-
                  leaking containers which must be kept closed at all times, except when
                  filling or emptying. Cloth and paper containing with VOC-laden
                  solvents should be stored in closed, non-absorbent, non-leaking
                  containers.
              6.   Use closed containers for disposal of cloth or paper used in stripping
                  cured coatings that are impregnated with solvent containing VOC
              Exemptions: operations using aerosol coating products, application of
              coatings to fine arts paintings, scenic or theatrical backgrounds for motion
              pictures, television, and theater.	
                                                                           D-2

-------
Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Material
voc
limitation
Compliance Requirements
Citation
Bay Area Air Quality Management District
Paper, fabric,
and film
















Coating lines that
emit more than
6.5 kg/day (14.3
Ib/day)














Content limit
of265g/l
(2.2 Ib/gal), as
applied
(excluding
water) or
emission limit
of 120 g/1
(1 Ib/gal) as
applied,
excluding
water (using
an approved
control
system)



1 . Use an approved control system
2. Use low-solvent coatings that meet the content limit
3. Keep all containers storing organic solvents or tanks for mixing
coatings covered at all times except when material is being added or
removed, when the tank or container is being cleaned, or when the
container is empty.
4. Do not allow leaks from containers storing organic solvents or from
tanks used for mixing coatings.
5. Do not utilize open containers to store or dispose of cloth or paper
laden with organic compounds that is used for surface preparation,
cleanup or coating removal.
6. Do not store spent or fresh organic compounds to be used for surface
preparation, cleanup or coating removal in open containers.
Exemptions:. Operations that manufacture flexible packaging materials
for packaging food or healthcare products for human or animal
consumption and where the coating is applied on the same line as printing
or decorative design. These operations are subject to Rule 20 (Graphic Arts
Printing and Coating Operations).
BAAQMD 8-12


















-------
Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)

Operation


















Material
Coating lines that
emit less than
6.5 kg/day (14.3
Ib/day)













voc
limitation
Emission limit
of 4,533 kg/yr
(5 tpy); or
Coating
content limit
of420g/l(3.5
Ib/gal), as
applied
(excluding
water or
exempt
compounds)
and solvent
content limit
of50g/l(0.42
Ib/gal)


Compliance Requirements
1 . Meet emission limit or use compliant coatings or use an emission
control system with an overall efficiency of 85% or 90% for an
incinerator.
2. For solvents used for surface preparation or cleanup must either use a
control system with an overall control efficiency of 85% or more; or
one of the following (1) use closed containers for the storage or
disposal of cloth or paper used for solvent surface preparation and
cleanup; and (2) use organic solvent for the cleanup of spray
equipment, including paint lines, with a compliant VOC content unless
either the (a) solvent is pressurized though spray equipment with
atomizing air off or dispensed from a small non-atomizing container,
and collected and stored in a closed container until recycled or
properly disposed of offsite; or (b) a spray gun washer subject to and
in compliance with the requirements of Regulation 8, Rule 16 is used;
and (3) close containers of solvent or coating when not in use.
Exemptions: surface coating using non-refillable aerosol cans; film
cleaning operations using 1,1,1-trichloroethane exclusively

Citation
BAAQMD 8-4
















El Dorado County Air Quality Management District
Machinery,
process, or
operation with
the potential
to emit
organic
compounds








Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Any that are
conducted at or
below ambient
temperatures




15 Ib/day and
31b/hr





40 Ib/day and
81b/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1 . Reduce VOC emissions by 85% or more; or equip process with B ACT
2. Do not dispose or allow the release of organic compounds from
storage or transfer operations of more than 1.5 gal of liquid (or
equivalent amount of vapor).
Exemptions: (1) stationary storage containers less than 250 gal; (2) any
single use or operation which annually uses a total volume of VOC which is
less than the emission limits, unless it is part of a large operation subject to
regulation; and (3) sources in existence before March 1, 1984.







EDCAQMDRule216














                                                         D-4

-------
Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Solvent
Cleaners






















Material
Solvents used on
substrates during
the manufacturing
process or for
surface
preparation

Solvents used for
maintenance and
repair




Solvents used for
cleaning coatings
or adhesives
application
equipment


Solvents used for
cleaning polyester
resin application
equipment







voc
limitation
70 g VOC/1
material





900 g VOC/1
material and a
composite
partial pressure
of 20 mm Hg
or less at 20C
(68F)
Vwo A /
950 g VOC/1
material and a
composite
partial pressure
of 35 mmHg
or less at 20C
(68F>
vu r )
200 g VOC/1
material; or
1, 100 g VOC/1
and composite
partial pressure
of 1.0 mmHg
or less at 20C
(68F) or
solvent
reclamation
system
Compliance Requirements
1. Use complaint cleaning materials AND Use one of the following
cleaning devices or methods:
a. Wipe cleaning;
b. Non propellant spray bottles or containers
c. Cleaning equipment which has a solvent container that can be, and
is, closed during cleaning operations, except when depositing and
removing objects, and is closed during non-operation with the
exception of maintenance and repair to the cleaning equipment
itself;
d. Non-atomized solvent flow method where the cleaning solvent is
collected in a container or a collection system which is closed
except for solvent collection openings and, if necessary, openings
to avoid excessive pressure build-up inside the container; or
e. Solvent flushing method where the cleaning solvent is discharged
into a container which is closed except for solvent collection
openings and, if necessary, openings to avoid excessive pressure
build-up inside the container. The discharged solvent from the
equipment must be collected into containers without atomizing
into the open air. The solvent may be flushed through the system
by air or hydraulic pressure, or by pumping.
2. Use a collection and control system that collects at least 90 percent of
the emissions and reduces VOC emissions by at least 95 percent or
has an outlet concentration less than 50 ppmw (as carbon)








Citation
EDCAQMD Rule 235























                                                         D-5

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       Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Material
voc
limitation
Compliance Requirements
Citation
Great Basin Unified Air Pollution Control District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Photochemically3
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
Non-
photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
15 Ib/day and
31b/hr
40 Ib/day and
81b/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
3,000 Ib/day
and 450 Ib/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1 . Reduce VOC emissions by 85% or more
2. Control emissions by incineration with an emission reduction of 90%
or use adsorption, or another approved method of control.
Exemptions: (1) transport of storage of organic containing materials; (2)
the volatile content of materials consists of only water and non-
photochemically reactive organic solvents containing less than 20% by
volume of VOC, and does not come into contact with a flame; (3) the
volatile content of materials consists of only water and non-
photochemically reactive organic solvents and more than 50% by volume of
VOC is evaporated prior to entering a chamber heated above ambient
temperature, and does not come into contact with a flame; and (4) the
solvent content is less than 5% by volume of non-photochemically reactive
organic solvents, and does not come into contact with a flame.
GBUAPCDRule417
 A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceeds ay of the following individual
percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, orketones having an olefmic or cyclo-olefmic
type of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketons
having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classified from its chemical structure
into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the least allowable  percentage of the
total volume of solvents.
                                                                                          D-6

-------
       Appendix D:  Summary of California Regulations for Paper, Film, and Foil  Surface Coating Facilities (continued)
Operation
Material
voc
limitation
Compliance Requirements
Citation
Imperial County Air Pollution Control District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Photochemicallyb
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
15 Ib/day and
31b/hr
40 Ib/day and
81b/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1 . Emissions from cleanup with photo-chemically reactive solvents must
be included in compliance determination
2. Reduce VOC emissions by 85% or more using a capture and control
system (an incinerator must have an emission reduction of 90% or
more).
Exemptions: (1) transport of storage of organic containing materials; and
(2) the volatile content of materials consists of only water and non-
photochemically reactive organic solvents containing less than 20% by
volume of VOC, and does not come into contact with a flame; and (3) use,
application, evaporation, or drying halogenated hydrocarbons or
perchloroethylene .
ICAPCDRule417
 A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the chemical compounds classified below or which exceeds any of the
following individual percentage composition limitations, referred to the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketones having an olefmic or
cyclo-olefmic type of unsaturation: 5 percent; (2) a combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) a combination of
ethylbenzene, ketones having branched hydrocarbon structures, or toluene: 20 percent.
                                                                                       D-7

-------
       Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities  (continued)
Operation
Material
voc
limitation
Compliance Requirements
Citation
Kern County Air Pollution Control District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Photochemically0
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
Non-
photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
15 Ib/day
40 Ib/day
(emissions
from air or
heat drying for
the first 12
hours must be
included)
3,000 Ib/day
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1 . Reduce VOC emissions by 85% using an incinerator with an emission
reduction of 90%; or adsorption, or another approved method of
control.
Exemptions: (1) transport of storage of organic containing materials; (2)
the volatile content of materials consists of only water and non-
photochemically reactive organic solvents containing less than 20% by
volume of VOC and does not come into contact with a flame; (3) the
solvent content is less than 20% by volume of non-photochemically
reactive organic solvents and does not come into contact with a flame; and
(4) use, application, evaporation, or drying halogenated hydrocarbons or
perchloroethylene .
KCAPCDRule410
 A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceeds ay of the following individual
percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having an olefinic or cyclo-olefinic type
of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketons
having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classified from its chemical structure
into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the least allowable percentage of the
total volume of solvents.
                                                                                          D-8

-------
      Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
  Operation
    Material
    VOC
  limitation
                     Compliance Requirements
       Citation
Mojave Desert Air Quality Management District
Organic
solvents or
solvent
containing
materials
All VOC
containing
materials
Non-VOC
containing
organic solvent
 540 kg/month
  (1,190 lb/
    month)
  272 kg/day
 (600 Ib/day)
 on a 30-day
rolling average
1.   For VOC-containing materials:
    a.   use product reformulation or substitution;
    b.   process changes;
    c.   improvement of operational efficiency;
    d.   development of innovative technology; or
    e.   install a collection and control system that reduces emissions by
        85% or more provided that capture system has a capture efficiency
        of 90% by weight and the control system has a destruction
        efficiency of 95% or more by weight or an output concentration of
        50 ppm (as carbon)
2.   Non-VOC organic compounds
    a.   include the drying period of 12 hrs after application of solvent
3.   Store all VOC containing materials in nonabsorbent, non-leaking
    containers which must be kept closed at all times (except during
    emptying or filling).
4.   Dispose of all VOC containing materials to prevent evaporation into
    the atmosphere.
Exemptions:  (1) transport or storage of organic solvent materials; (2) use
of 1,1,1-trichloroethylene, methylene chloride, and trichlorofluoroethane;
and (3) aerosol products	
MDAQMD Rule 442
                                                                            D-9

-------
Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Material
voc
limitation
Compliance Requirements
Citation
Monterey Bay Unified Air Pollution Control District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized at a
temperature of
194F (90C) in
the presence of O2
Any that do not
come into contact
with a flame, or
are not baked,
heat cured, or
heat-polymerized
in the presence of
02
15 Ib/day
40 Ib/day
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1 . Emissions from cleanup with solvents must be included in compliance
determination
2. Reduce VOC emissions by 85% or more using a capture and control
system (an incinerator must have an emission reduction of 90% or
more).
Exemptions: (1) transport or storage of solvent materials; (2) any source in
existing prior to March 19, 2001 with actual VOC emissions less than 15
Ib/day (solvents that are baked, heat-cured, heat-polymerized or exposed to
flame) or 40 Ib/day (solvents that are not baked, heat-cured, heat-
polymerized or exposed to flame)
MBUAPCDRule416
                                                         D-10

-------
       Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Material
voc
limitation
Compliance Requirements
Citation
Placer County Air Pollution Control District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Photochemicallyd
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
Non-
photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
15 Ib/day and
31b/hr
40 Ib/day and
81b/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
3,000 Ib/day
and 450 Ib/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1 . Reduce VOC emissions by 85% or more by incineration (if incinerator
has an emission reduction of 90% or more), adsorption, or another
approved method of control.
2. Do not dispose or allow the release of organic compounds from storage
or transfer operations of more than 1.5 gal of liquid (or equivalent
amount of vapor).
3 . Emissions from cleanup with solvents must be included in compliance
determination
Exemptions: (1) transport of storage of organic containing materials; (2)
the volatile content of materials consists of only water and non-
photochemically reactive organic solvents containing less than 20% by
volume of VOC, and does not come into contact with a flame; and (3) the
solvent content is less than 20% by volume of non-photochemically
reactive organic solvents, and does not come into contact with a flame.
PLAAPCDRule219
 A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of chemicals compounds classified below or which exceed any of the
following individual percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketones having an olefmic
or cyclo-olefmic type of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combination of
ethylbenzene, ketones having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent.  Whenever any organic solvent or any constituent of an organic solvent may be classified from
its chemical structure into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the least
allowable percentage of the total volume of solvents.
                                                                                          D-ll

-------
Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Paper treating
operations
Solvent
Cleaners
Material
Melamine resin
coating
Phenolic resin
coating
Solvents used on
substrates during
the manufacturing
process or for
surface
preparation
Solvents used for
maintenance and
repair
Solvents used for
cleaning coatings
or adhesives
application
equipment
voc
limitation
O.llbVOC/gal
coating as
applied (except
for water and
exempt
compounds)
1.75 Ib
VOC/gal
coating as
applied (except
for water and
exempt
compounds)
70 g VOC/1
material
900 g VOC/1
material and a
composite
partial pressure
of 20 mm Hg
or less at 20C
(68F)
950 g VOC/1
material and a
composite
partial pressure
of 35 mmHg
or less at 20C
(68F)
Compliance Requirements
1 . Use compliant coatings or us a capture and control system that has an
overall efficiency of 85% by weight
2. Total VOC emissions including control must meet the level of coating
content limits.
1 . Use complaint cleaning materials AND Use one of the following
cleaning devices or methods:
a. Wipe cleaning;
b. Non propellant spray bottles or containers
c. No spray discharge into open air
2. Use a collection and control system that collects at least 90 percent of
the emissions and reduces VOC emissions by at least 95 percent or
has an outlet concentration less than 50 ppmw (as carbon)
Citation
PLAAPCD Rule 230
PLAAPCD Rule 240
                                                         D-12

-------
    Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Material
  VOC
limitation
Compliance Requirements
Citation
            Solvents used for
            cleaning polyester
            resin application
            equipment
              200 g VOC/1
               material; or
              1,100 g VOC/1
              and composite
             partial pressure
              of 1.0 mmHg
              or less at 20C
               (68F) or
                solvent
               reclamation
                system
                                                                     D-13

-------
       Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Material
voc
limitation
Compliance Requirements
Citation
Sacramento Metropolitan Air Quality Management District
Organic
solvents or
solvent
containing
materials






















Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Photochemically6
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)



Non-
photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)


6.8 kg (15 Ib)
per day and
1.4 kg (3. lib)
per hour



18 kg (40 Ib)
per day and
3. 6 kg (7.9 Ib)
per hour
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1,350kg
(3,000 lb)/day
and 200 kg
(441 lb)/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1 . Reduce VOC emissions by 85% overall using an incinerator
(incinerator must have an emission reduction of 90% or more); or
adsorption, or another approved method of control.
2. Emissions from cleanup with solvents must be included in compliance
determination
3. Do not dispose of 5 liters (1.3 gal) per day of photochemically reactive
solvent or solvent containing materials such that they are emitted to the
atmosphere.
Exemptions: (1) transport of storage of organic containing materials; (2)
the volatile content of materials consists of only water and non-
photochemically reactive organic solvents containing less than 20% by
volume of VOC and does not come into contact with a flame; (3) the
solvent content is less than 20% by volume of non-photochemically
reactive organic solvents and does not come into contact with a flame; and
(4) use, application, evaporation, or drying halogenated hydrocarbons or
perchloroethylene .











KCAPCDRule410


























 A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceeds ay of the following individual
percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having an olefinic or cyclo-olefinic type
of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketons
having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classified from its chemical structure
into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the least allowable percentage of the
total volume of solvents.
                                                                                          D-14

-------
      Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
  Operation
    Material
   VOC
 limitation
                Compliance Requirements
       Citation
Solvent
Cleaning
Materials
General cleaning
activities, product
cleaning during
manufacturing or
surface
preparation for
coatings,
adhesives,
sealants, or ink
application;
Repair and
maintenance
cleaning
50 g VOC/1
(0.42 Ib/gal)
Use complaint cleaning materials AND Use one of the following
cleaning devices or methods:
a.  Wipe cleaning;
b.  Cleaning with closed containers or by using hand held spray
   bottles or containers without a propellant-induced force;
c.  Using cleaning equipment which has a solvent container that is
   closed during cleaning operations, except when depositing and
   removing objects, and is closed during non-operation with the
   exception of maintenance and repair to the cleaning equipment
   itself;
d.  Using a remote reservoir degreaser, non-vapor degreaser, or vapor
   degreaser used as required under Rule 454.
e.  Using solvent flushing method where the cleaning solvent is
   discharged into a container which is closed except for solvent
   collection openings and, if necessary, openings to avoid excessive
   pressure build-up inside the container. The discharged solvent
   from the equipment must be collected into containers without
   atomizing into the open air.  The solvent may be flushed through
   the system by air or hydraulic pressure, or by pumping.
Use a collection and control system that collects at least 90 percent of
the emissions and reduces VOC emissions by at least 95 percent or
has an outlet concentration less than 50 ppmw (as carbon)	
KCAPCD Rule 466
                                                                             D-15

-------
Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)

Operation

Material
voc
limitation

Compliance Requirements

Citation
San Diego County Air Pollution Control District
Paper, Film
and Fabric
















Pressure
sensitive tap
and label
manufacturing



Coating lines




Cleaning
materials











Coating lines






Content limit
of265g/las
applied
(excluding
water)
Content limit
of200g/l











Content limit
of 0.20 kg
VOC/kg
coating solids
as applied
(average for
month)
1. Use compliant coatings or reduce VOC emissions using a control
system with a combined collection and abatement efficiency of 90% by
weight or more;
2. Containers and mixing tanks must be free from liquid leaks and must
be covered except when adding or removing materials, cleaning, or
when the container is empty;
3 . Use compliant cleaning materials or use a system that totally encloses
the component parts being cleaned during washing, rinsing, and
draining or the cleaning
4. Transfer the cleaning solvent through the application equipment,
without exposure to air, into a container which has completely covers
the container and has no visible holes, breaks, openings or separations
between adjoining components
5. Coating or cleaning solvent container must display the content of
methylene chloride, CFC-11, CFC-12, CFC-113, CFC-114, orCFC-
115
Exemption: Any application process that has VOC emissions less than
14.3 Ib (6.5 kg) per day
1 . Use compliant coatings or reduce emissions by 90% overall over a
calendar month or calculate a weighted average emission reduction
Exemption: VOC input is less than 45 Mg (49.6 tons) of VOC per 12-
month period



SDAPCD Rule 67.5

















SDAPCD Rule 260.440






                                                         D-16

-------
       Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Organic
solvents or
solvent
containing
materials






















Material
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Photochemically'
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)



Non-
photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)


voc
limitation
6.8 kg (15 Ib)
per day and
1.4 kg (3. lib)
per hour



18 kg (40 Ib)
per day and
3. 6 kg (7.9 Ib)
per hour
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1,350kg
(3,000 lb)/day
and 200 kg
(441 lb)/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
Compliance Requirements
1 . Reduce VOC emissions by 85% overall using an incinerator; or
adsorption; or another approved method of control.
2. Emissions from cleanup with solvents must be included in compliance
determination
3. Do not dispose of 5 liters (1.3 gal) per day of photochemically reactive
solvent or solvent containing materials such that they are emitted to the
atmosphere.
Exemptions: (1) the organic solvent content of surface coating do not
exceed 30% by volume, excluding water and does not come into contact
with a flame; (2) the use of any air-dried material which contains less than
420 g/1 of coating applied (excluding water or exempt compounds) (3) the
use of a baked coating material which contains less than 360 g/1 of coating
as applied (excluding water or exempt compounds) and (4) any equipment,
process or operation which has implemented B ACT or LAER as a result of
NSR












Citation
SDAPCD Rule 66


























 The compositional limitations of any organic solvent referred to are the volume percentages of the following photochemically reactive compounds, compared to the total solvent volume: (1) A
combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketones having an olefmic or cyclo-olefmic type of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or
more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketones having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. (4)
Any aggregate of (1), (2), or (3) above, provided their individual volume percentages are not exceeded: 20 percent.  Whenever any organic solvent or any constituent of an organic solvent may be
classified from its chemical structure into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having
the least allowable percentage of the total volume of solvents.
                                                                                          D-17

-------
       Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Material
voc
limitation
Compliance Requirements
Citation
San Joaquin Valley Unified Air Pollution Control District
Organic
solvents or
solvent
containing
materials

















Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Photochemically8
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
Non-
photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
151b/day
(emissions
from air or
heat drying for
the first 12
hours must be
included)
40 Ib/day
(emissions
from air or
heat drying for
the first 12
hours must be
included)
3,000 Ib/day
(emissions
from air or
heat drying for
the first 12
hours must be
included)

1 . Reduce VOC emissions by 85% overall using an incinerator
(incinerator must have an emission reduction of 90% or more); or
adsorption, or another approved method of control.
2. Emissions from cleanup with solvents must be included in compliance
determination
3. All solvents must be stored in non-absorbent, non-leaking containers
which must be kept closed at all times, except when filling or emptying.
Cloth and paper containing laden with solvents should be stored in
closed, non-absorbent, non-leaking containers.
Exemptions: (1) transport of storage of organic containing materials; (2)
the volatile content of materials consists of only water and non-
photochemically reactive organic solvents containing less than 20% by
volume of VOC and does not come into contact with a flame; (3) use,
application, evaporation, or drying halogenated hydrocarbons or
perchloroethylene; (4) solvents containing less than 50 grams of VOC/liter
of material.; (5) operation that uses 55 gallons or less of organic solvents on
a 365-day rolling average.





SJVUAPCD Rule 4661
and 4663




















8 A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceeds ay of the following individual
percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having an olefmic or cyclo-olefmic type
of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketons
having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classified from its chemical structure
into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the least allowable percentage of the
total volume of solvents.
                                                                                          D-18

-------
    Appendix D: Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Material
  VOC
limitation
Compliance Requirements
Citation
            Solvent cleaning
            materials
            (excluding hand
            wiping)
              Content limit
               of550g/l
             (4.6 g/gal) and
                 VOC
               composite
             partial pressure
              of 35 mmHg
             @20C (68F)
                                                                   D-19

-------
       Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Material
voc
limitation
Compliance Requirements
Citation
San Luis Obispo County Air Pollution Control District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Photochemically11
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
Non-
photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
15 Ib/day and
31b/hr
40 Ib/day and
81b/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
3,000 Ib/day
and 450 Ib/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1. Reduce VOC emissions by 85% using an incinerator (the incinerator
must have an emission reduction of 90%); or adsorption, or another
approved method of control.
2. Include emissions from the cleanup with photochemically reactive
solvents in compliance determination
Exemptions: (1) transport of storage of organic containing materials;
(2) the volatile content of materials consists of only water and non-
photochemically reactive organic solvents containing less than 20% by
volume of VOC and does not come into contact with a flame; (3) use,
application, evaporation, or drying halogenated hydrocarbons or
perchloroethylene .
SLOCAPCD Rule 407
  A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceeds ay of the following individual
percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having an olefmic or cyclo-olefmic type
of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketons
having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classified from its chemical structure
into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the least allowable percentage of the
total volume of solvents.
                                                                                          D-20

-------
       Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Material
voc
limitation
Compliance Requirements
Citation
Santa Barbara County Air Pollution Control District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Photochemically1
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
Non-
photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
15 Ib/day and
31b/hr
40 Ib/day and
81b/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
3,000 Ib/day
and 450 Ib/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1 . Reduce VOC emissions by 85% using an incinerator (the incinerator
must have an emission reduction of 90%); or adsorption, or another
approved method of control.
2. Include emissions from the cleanup with photochemically reactive
solvents in compliance determination
Exemptions: (1) transport of storage of organic containing materials;
(2) the volatile content of materials consists of only water and non-
photochemically reactive organic solvents containing less than 20% by
volume of VOC and does not come into contact with a flame; (3) use,
application, evaporation, or drying halogenated hydrocarbons or
perchloroethylene .
SBAPCDRule317
 A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceeds ay of the following individual
percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having an olefinic or cyclo-olefinic type
of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketons
having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classified from its chemical structure
into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the least allowable percentage of the
total volume of solvents.
                                                                                          D-21

-------
       Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities  (continued)
Operation
Material
voc
limitation
Compliance Requirements
Citation
Shasta County Air Quality Management District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
at temperatures
above 400F
PhotochemicallyJ
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
Any
photochemically
reactive substance
15 Ib/day
40 Ib/day
40 Ib/day
1 . Reduce VOC emissions by 85%
2. Include emissions from the cleanup with photochemically reactive
solvents in compliance determination
Exemptions: (1) use, application, evaporation, or drying halogenated
hydrocarbons orperchloroethylene.
SHAAQMD Rule 3:4
J A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceeds ay of the following individual
percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having an olefinic or cyclo-olefinic type
of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketons
having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classified from its chemical structure
into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the least allowable percentage of the
total volume of solvents.
                                                                                          D-22

-------
      Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
  Operation
    Material
   VOC
 limitation
                 Compliance Requirements
       Citation
South Coast Air Quality Management District
Paper, Film
and Fabric
Coating lines
               Plastisol
               Wash primer
Content limit
of265g/las
  applied
 (excluding
 water and
  exempt
compounds)
                   Content limit
                    of20g/las
                  applied (except
                     water and
                      exempt
                   compounds)
                   Content limit
                     of265g/l
                   material used
Use compliant materials ; or use an collection system that has a capture
efficiency of at least 90 % by weight and the control device has an
emission reduction efficiency of 95 % by weight or to an outlet
concentration of 50 ppmv (as carbon)
Coatings must be applied using hand application methods; HVLP spray
(air dried coatings only); or one of the following coaters: flow, roll, dip,
foam, and die. Alternative coating methods must be approved.
Containers and mixing tanks must be free from leaks and covered
except when adding or removing materials, cleaning or when the
container is empty.
Solvent cleaning must use one of the following: wipe cleaning; closed
containers or hand held spray bottles w/out propellant-induced force;
cleaning equipment which has a solvent container that is closed at all
times (except when adding or removing parts or during repair); remote
reservoir cleaner; non-atomized solvent flow where solvent is collected
in a container or collection system that is closed at all times except for
solvent collection and pressure relief (as needed) openings; and solvent
flushing methods where solvent is collected in a container or collection
system that is closed at all times except for solvent collection and
pressure relief (as needed) openings (discharged solvent must be
collected into containers without atomizing into the air and solvent may
be flushed through the system by air or hydraulic pressure or by
pumping).
All VOC-containing solvents must be stored in non-absorbent, non-
SCAQMDRule 1128
and 1171
                                                                             D-23

-------
       Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
  Operation
    Material
  VOC
limitation
                       Compliance Requirements
       Citation
                Cleaning
                materials
                     Content limit
                     of 25 g/1 (or
                     0.21 Ib/gal)
                   leaking containers which must be kept closed at all times, except when
                   filling or emptying. Cloth and paper containing with VOC-laden
                   solvents should be stored in closed, non-absorbent, non-leaking
                   containers.
              6.   Use closed containers for disposal of cloth or paper used in stripping
                   cured coatings that are impregnated with solvent containing VOC
              Exemption: Any application process that has VOC emissions less than
               14.3 Ib (6.5 kg) per day
Tehama County Air Pollution Control District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
at temperatures
above 400F
                Photochemically
                reactive solvent
                (except solvents
                that are baked,
                heat cured or
                heat-
                polymerized)^
 15 Ib/day
                       40 Ib/day
1.   Reduce VOC emissions by 85%
2.   Include emissions from the cleanup with photochemically reactive
    solvents in compliance determination
Exemptions:  (1) use, application, evaporation, or drying halogenated
hydrocarbons orperchloroethylene.
TCAPCD Rule 4:22
 A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceeds ay of the following individual
percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having an olefmic or cyclo-olefmic type
of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketons
having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classified from its chemical structure
into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the least allowable percentage of the
total volume of solvents.
                                                                                  D-24

-------
Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation

Material
Any
photochemically
reactive substance
voc
limitation
40 Ib/day
Compliance Requirements

Citation

                                                         D-25

-------
Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Material
voc
limitation
Compliance Requirements
Citation
Ventura County Air Pollution Control District
Paper, Fabric,
and Film

















Coating materials








Reactive organic
compound (ROC)
emissions





Cleanup solvents

Content limit
of265g/l, as
applied
(excluding
water and
exempt
compounds)


Emission limit
of 120 g/1
(1 Ib/gal) as
applied,
excluding
water and
exempt
compounds)
200 g ROC/1
material used
1. Use compliant materials or reduce emissions by a combined capture
and destruction efficiency of 90%, on a 24-hr rolling average or if the
coating applied contains more than 1,200 g/1 or ROC as applied
(excluding water and exempt solvents), limit ROC emissions to 120 g/1
as applied (excluding water and exempt solvents) on a 24-hr average.
2. All containers and mixing equipment containing ROC material must
not leak and must be covered when in use, except for when adding or
removing materials.
Exemptions:. ROC emission limits do not apply during the first 24 hours
of a scheduled carbon adsorption system startup.









VCAPCD Rule 74.3


















                                                         D-26

-------
       Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Material
voc
limitation
Compliance Requirements
Citation
Yolo-Solano Air Quality Management District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Photochemically1
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
Non-
photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
15 Ib/day and
31b/hr
40 Ib/day and
81b/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
3,000 Ib/day
and 450 Ib/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1 . Reduce VOC emissions by 85%
2. Include emissions from the cleanup with photochemically reactive
solvents in compliance determination
3 . Do not dispose or allow the release of photochemically reactive
solvents more than 1.5 gal of liquid (or equivalent amount of vapor).
Exemptions: (1) transport of storage of organic containing materials;
(2) the volatile content of materials consists of only water and non-
photochemically reactive organic solvents containing less than 20% by
volume of VOC and does not come into contact with a flame; (3) use,
application, evaporation, or drying saturated halogenated organic solvents
or perchloroethylene.

 A photochemically reactive solvent is any solvent with an aggregate of more than 20 percent of its total volume composed of the following chemicals or which exceeds ay of the following individual
percentage composition limitations, referred to by the total volume of solvent: (1) A combination of hydrocarbons, alcohols, aldehydes, esters, ethers, or ketons having an olefinic or cyclo-olefinic type
of unsaturation: 5 percent; (2) A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene: 8 percent; (3) A combination of ethylbenzene, ketons
having branched hydrocarbon structures, trichloroethylene or toluene: 20 percent. Whenever any organic solvent or any constituent of an organic solvent may be classified from its chemical structure
into more than one of the above groups or organic compounds, it shall be considered as a member of the most reactive chemical group that is, that group having the least allowable percentage of the
total volume of solvents.
                                                                                          D-27

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Appendix D:  Summary of California Regulations for Paper, Film, and Foil Surface Coating Facilities (continued)
Operation
Solvent
Cleaners



























Material
Solvents used on
substrates during
the manufacturing
process or for
surface
preparation

Solvents used for
maintenance and
repair


Solvents used for
cleaning coatings
or adhesives
application
equipment


Solvents used for
cleaning polyester
resin application
equipment







voc
limitation
200 g VOC/1
material





900 g VOC/1
material and a
composite
partial pressure
of 20 mmHg
or less at 20C
((36 f)
950 g VOC/1
material and a
composite
partial pressure
of 35 mmHg
or less at 20C
(68F)
200 g VOC/1
material; or
1, 100 g VOC/1
and composite
partial pressure
of 1.0 mmHg
or less at 20C
(68F) or
solvent
reclamation
system
Compliance Requirements
1. Use complaint cleaning materials AND Use one of the following
cleaning devices or methods: Wipe cleaning;
a. Spray bottles or containers with a maximum capacity of 16 fluid
ounces without a propellant-induced force;
b. Cleaning equipment which has a solvent container that can be, and
is, closed during cleaning operations, except when depositing and
removing objects, and is closed during non-operation with the
exception of maintenance and repair to the cleaning equipment
itself;
c. Cleaning device or mechanism which has been determined by the
Air Pollution Control Officer to result in equivalent or lower
emissions;
d. Remote reservoir cold cleaner used
e. Non-atomized solvent flow method where the cleaning solvent is
collected in a container or a collection system which is closed
except for solvent collection openings and, if necessary, openings
to avoid excessive pressure build-up inside the container; or
f. Solvent flushing method where the cleaning solvent is discharged
into a container which is closed except for solvent collection
openings and, if necessary, openings to avoid excessive pressure
build-up inside the container. The discharged solvent from the
equipment must be collected into containers without atomizing
into the open air. The solvent may be flushed through the system
by air or hydraulic pressure, or by pumping.
2. Use a collection and control system that collects at least 90 percent of
the emissions and reduces VOC emissions by at least 95 percent or has
an outlet concentration less than 50 ppmw (as carbon)





Citation
YSAQMD2.31,
Section 300



























                                                         D-28

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United States                          Office of Air Quality Planning and Standards          Publication No. EPA 453/R-07-003
Environmental Protection               Air Quality Strategies and Standards Division                           September 2007
Agency                                       Research Triangle Park, NC

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