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RIN ID: RIN 2060-AG58
FRL ID: [FRL-6854-7]
SUBJECT CATEGORY: National Emission Standards for Hazardous Air Pollutants: Paper and Other Web Coating
Public Hearing. If anyone contacts us by September 27, 2000 to request to speak at a public hearing, we will hold a hearing at 10 a.m. on October 11, 2000.
DOCUMENT SUMMARY: We are proposing a standard to limit hazardous air pollutant (HAP) emissions from facilities that coat paper and other web substrates and are major sources of HAP emissions. The standard is being proposed under section 112 of the Clean Air Act (CAA or Act), as amended on November 15, 1990, to protect public health and the environment by reducing HAP emissions from new and existing facilities. The CAA requires these sources to achieve the maximum degree of reduction in emissions of HAP that is achievable. The proposed standard would eliminate approximately 80 percent of nationwide HAP emissions from major sources.
SUMMARY: Environmental Protection Agency,
Commenters wishing to submit proprietary information for consideration must clearly distinguish such information from other comments and clearly label it as CBI. Send submissions containing such proprietary information directly to the following address, and not to the public docket, to ensure that proprietary information is not inadvertently placed in the docket: Attention: Mr. Paul Almodovar, c/o OAQPS Document Control Officer (Room 740B), U.S. Environmental Protection Agency, 411 W. Chapel Hill Street, Durham, NC 27711. The EPA will disclose information identified as CBI only to the extent allowed by the procedures set forth in 40 CFR part 2. If no claim of confidentiality accompanies a submission when it is received by EPA, the information may be made available to the public without further notice to the commenter.
Public Hearing. Persons interested in presenting oral testimony or inquiring as to whether a hearing is to be held should contact Ms. Janet Eck (see ADDRESSES above) at least 2 days in advance of the public hearing. Persons interested in attending the public hearing should also call Ms. Eck (see ADDRESSES above) to verify the time, date, and location of the hearing. The public hearing will provide interested parties the opportunity to present data, views, or arguments concerning these proposed emission standards.
Docket. The docket for this regulatory action is A9909. The docket is an organized and complete file of all the information we consider in developing this rule. It is a dynamic file because material is added throughout the rulemaking process. The docketing system allows you to readily identify and find documents so you can participate in rulemaking. Along with the proposed and promulgated standards and their preambles, contents of the docket will serve as the record in case of judicial review (see section 307(d)(7)(A) of the CAA). The regulatory text and other materials related to this rulemaking are available for review in the docket or copies may be mailed on request from the Air Docket by calling (202) 2607548. A reasonable fee may be charged for copying docket materials.
World Wide Web (WWW). In addition to being available in the docket, an electronic copy of this proposed rule is also available on the WWW through the Technology Transfer Network (TTN). Following signature, a copy of the rule will be posted on the TTN's policy and guidance page for newly proposed or promulgated rules http://www.epa.gov/ttn/oarpg. The TTN provides information and technology exchange in various areas of air pollution control. If more information regarding the TTN is needed, call the TTN HELP line at (919) 5415384.
Plain Language. In compliance with President Clinton's June 1, 1998 Executive Memorandum on plain language in government writing, this preamble is written using plain language. Thus, the use of ``we'' and ``us'' in this document refers to EPA. The use of ``you'' refers to the reader, and may include industry; State, local, and tribal governments; environmental groups; and other interested individuals.
Regulated Entities. Categories and entities potentially regulated by this action include those listed on the following table.
This table is not intended to be exhaustive, but is just a guide to
entities likely to be regulated by final action on this proposal. It
lists the types of entities that may be regulated, but you should
examine the applicability criteria in section II of this preamble and in
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Sec. 63.3290 of the proposed rule to decide whether your facility is
likely to be regulated by final action on this proposal. If you have
any questions about whether your facility will be subject to the
standard, call the person listed in the preceeding FOR FURTHER INFORMATION CONTACT section.
Regulated Entities
Examples of
Category SIC NAICS potentially regulated
codes codes entities
Paper and Other Web Coating.. 2653 322211 Those facilities with
2657 322212 web coating
\a\2671 322221 operations\b\ that
2672 322222 coat substrate used
\a\2673 322223 in products
\a\2674 322224 including, but not
2675 322225 limited to:
2679 322226 corrugated and solid
\a\2754 322299 fiber boxes; folding
2761 323111 paperboard boxes,
3074 323116 including sanitary;
3081 325992 flexible packaging
3083 326111 (packing paper and
3291 326112 plastics film,
\a\3497 326113 coated and
3861 32613 laminated); pressure
3955 326192 sensitive tape and
\a\3996 32791 labels, coated and
332999 laminated paper, not
339944 elsewhere classified
(nec); plastics,
foil, and coated
paper bags; bags:
uncoated paper and
multiwall; diecut
paper and board;
converted paper and
paperboard products,
nec (gift wrap,
paper wallpaper,
cigarette paper);
commercial printing,
gravure; manifold
business forms;
plastic aseptic
packaging;
unsupported plastics
film and sheet;
laminated plastics
plate, sheet, and
profile shapes;
abrasive products;
laminated aluminum
(metal) foil and
leaf, flexible
packaging;
photographic
equipment and
supplies; carbon
paper and inked
ribbons; linoleum,
asphaltedfelt base,
and other hard
surface floor
coverings.
\a\ Facilities in these SIC codes are expected to be primarily covered
under the printing and publishing national emission standards for hazardous air pollutants (NESHAP).
\b\ Web coating operations refer to the continuous application of a
layer of material across the entire length of the usable substrate to:
provide a covering, finish, or protective layer to the substrate;
provide adhesion between two substrates for lamination; and where the
continuous web substrate is flexible enough to be wound or unwound as rolls.
Background Information Document. The Background Information
Document (BID) for the proposed standard may be obtained from the TTN; the paper and other web coating docket (A9909); the U.S.
Environmental Protection Agency Library (MD35), Research Triangle
Park, North Carolina 27711, telephone number (919) 5412777; or the
National Technical Information Service, 5285 Port Royal Road,
Springfield, Virginia 22161, telephone (703) 4874650. Please refer to
``National Emission Standards for Hazardous Air Pollutants: Paper and
Other Web CoatingBackground Information for Proposed Standards'' (EPA453/R00002).
Outline. The information presented in this preamble is organized as follows:
I. What are the subject and purpose of this proposed rule?
II. Does this proposed rule apply to me?
III. What is the proposed emission standard?
IV. When do I show initial compliance with the proposed rule? V. What testing and monitoring must I do?
VI. What notification, recordkeeping, and reporting requirements must I follow?
VII. What are the environmental, energy, and economic impacts of this proposed rule?
VIII. What is the basis for selecting the level of the proposed standards?
IX. What is the basis for selecting the format of the proposed standards?
X. Administrative requirements
The CAA requires us to establish standards to control HAP emissions from source categories identified under section 112(c) of the CAA. An initial source category list was published in the Federal Register on July 16, 1992 (57 FR 31576). The source category list identifies ``Paper and Other Web Coating (Surface Coating)'' as a source category because it contains major sources. Under the CAA, a major source is defined as ``* * * any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit, considering controls, in the aggregate, 10 tons per year (tpy) or more of any one HAP or 25 tpy or more of any combination of HAP.'' We have estimated that there are over 400 existing paper and other web coating facilities, with approximately 210 estimated to be major sources.
The purpose of the proposed rule is to reduce emissions of HAP from paper and other web coating major sources. The source category is for major sources only. Area sources are not included in this source category and therefore are not subject to the proposed standards. We estimate that annual baseline organic HAP emissions from this source category are approximately 35,000 megagrams per year (Mg/yr) (39,000 tpy). The proposed rule would eliminate approximately 29,000 Mg/yr (32,000 tpy) of these organic HAP emissions (about an 80 percent reduction).
The organic HAP emitted from the paper and other web coating process include toluene, methanol, methyl ethyl ketone, xylenes, phenol, methylene chloride, ethylene glycol, glycol ethers, hexane, methyl isobutyl ketone, cresols and cresylic acid, dimethylformamide, vinyl acetate, formaldehyde, and ethyl benzene. These pollutants can cause reversible or irreversible toxic effects following sufficient exposure. The potential toxic effects include eye, nose, throat, and skin irritation, and blood cell, heart, liver, and kidney damage.
The degree of adverse effects to human health from exposure to HAP
can range from mild to severe. The extent and degree to which the human
health effects may be experienced are dependent upon (1) The ambient
concentration observed in the area (as influenced by emission rates,
meteorological conditions, and terrain); (2) the frequency and duration
of exposures; (3) characteristics of exposed individuals (genetics,
age, preexisting health conditions, and lifestyle), which vary
significantly with the population; and (4) pollutantspecific characteristics
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(toxicity, halflife in the environment, bioaccumulation, and persistence).
II. Does This Proposed Rule Apply to Me?
The paper and other web coating source category includes any facility located at a major source and engaged in the coating of paper, plastic film, metallic foil, and other web surfaces. The source category does not include printing operations covered under the printing and publishing national emission standards for hazardous air pollutants (NESHAP) (40 CFR part 63, subpart KK). The source category does not include coil coating, i.e., the application of an organic coating to the surface of any metal strip at least 0.15 millimeter (0.006 inch) thick that is packaged in a roll or coil, which is being regulated as a separate source category. Fabric coating is also being regulated as a separate source category. However, we identified facilities in the paper and other web coating source category that also apply coatings to fabric, sometimes on the same coating lines. We are proposing that such coating lines be part of the paper and other web coating source category and not subject to the future fabric coating NESHAP. Paper and other web coating may be simply referred to as ``web coating'' since paper is one of several web substrates in the paper and other web coating source category.
The proposed rule applies to you if you own or operate any web coating lines at a facility that is a major source of HAP emissions. This means that the coating lines at a major source would be subject to the proposed standard without regard to the relative proportion of HAP emissions from the web coating lines to total HAP emissions at the source.
If your facility is a nonmajor (area) source, i.e., actual and potential annual emissions are less than 10 tons of any single HAP and less than 25 tons of all HAP combined, you would not be subject to this proposed rule.
If your facility is a major source, you would be required to meet the proposed emission limits for all the web coating lines at your facility. We have defined a web to be a continuous substrate (e.g., paper, plastic film, foil) that is capable of being rolled at any point during the coating process. We have defined a web coating line to be any number of work stations, of which one or more applies a layer of coating material along the length of a continuous web substrate, and any associated drying equipment between an unwind (or feed station) and a rewind (or cutting station). Printing presses subject to the printing and publishing NESHAP are not web coating lines.
We define an affected source as a stationary source, group of stationary sources, or part of a stationary source to which a specific NESHAP applies. Within a source category, we select the specific emission sources (emission points or groupings of emission points) that will make up the affected source for that category. To select these emission sources, we mainly consider the constituent HAP and quantity emitted from individual or groups of emission points.
For the paper and other web coating NESHAP, the affected source is proposed to be the collection of all the web coating lines at a facility. We are not proposing requirements for operations related to coating line and parts cleaning, coating mixing and storage, film formation, and wastewater.
Coating lines and equipment that are not in the source category, and thus, not in the affected source, include those that perform both coating and printing and comply with the national emission standards for the printing and publishing industry; those that coat coil, even if only part of the time, and therefore, are in the coil coating source category; and those that coat only fabric and are in the fabric coating, printing, and dyeing source category (but if both fabric and other web coating is performed on a coating line, the line is included in the paper and other web coating affected source).
Many industrial facilities perform both coating and printing
operations. Within the printing industry, the product and packaging
rotogravure and wideweb flexographic industry segment (that includes
the flexible packaging industry as a major subsector) does the most
coating, with material use distributed almost equally between inks and
other types of coatings. Printing operations are covered under the
NESHAP for the printing and publishing industry. The printing and
publishing NESHAP also includes an option for facilities that perform
both printing and coating to include certain coating operations.
Therefore, many facilities that could potentially be subject to the
proposed NESHAP for the paper and other web coating industry may have
coating lines already subject to the printing and publishing NESHAP.
Such web coating lines included in compliance demonstrations under the
printing and publishing NESHAP are not subject to this standard. A
detailed discussion of the printing and publishing industry is included
in the BID for that industry (Docket No. A9242, National Emission
Standards for Hazardous Air Pollutants: Printing and Publishing
IndustryBackground Information for Proposed Standards (EPA453/R95 002a)).
III. What Is the Proposed Emission Standard?
In the proposed rule, you would be able to choose any one of three options to limit organic HAP emissions at existing and new sources and meet the allowable level. The HAP emission limits are based on emission capture and control technology that can reduce total organic HAP emissions by 95 percent at existing sources and 98 percent at new sources. The emission limits reflect this level of control by limiting organic HAP emissions to no more than 5 percent and 2 percent of the organic HAP applied each month at existing and new sources, respectively; and by limiting emissions based on the weight of the solids part of your coating or the weight of your total coating. As discussed in section VIII of this preamble, we believe expressing emission limits in this way is appropriately based on the maximum achievable control technology (MACT) level of control and offers flexibility to reduce emissions through the use of control technology, pollution prevention, or a combination of the two.
The three HAP emission limits proposed for existing sources are: (1) Limit emissions to no more than 5 percent of the organic HAP applied for the month; (2) limit the total amount of organic HAP in your coatings, or the total amount of organic HAP emitted, to no more than 20 weight percent of the total solids applied to web substrates in a month; or (3) limit the total amount of organic HAP in your coatings, or the total amount of organic HAP emitted, to no more than 4 weight percent of the total mass of coating material applied to the web substrate in a month.
The three HAP emission limits proposed for new sources are: (1)
Limit emissions to no more than 2 percent of the organic HAP applied
for the month; (2) limit the total amount of organic HAP in your
coatings, or the total amount of organic HAP emitted, to no more than 8
weight percent of the total solids applied to web substrates in a
month; or (3) limit the total amount of organic HAP in your coatings,
or the total amount of organic HAP emitted, to no more than 1.6 weight percent of the
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total mass of coating material applied to the web substrate in a month.
In submitting comments, please specify whether the comment pertains to one or all of the emission limitation options of the proposed standard. We will further evaluate the proposed standard based on our review of public comments and other information we may receive. The final rule may reflect any one of the proposed options to limit organic HAP emissions, a combination of the proposed options, or all three options.
The General Provisions (40 CFR part 63, subpart A) would also apply to you. The General Provisions codify procedures and criteria we use to carry out all part 63 NESHAP promulgated under the CAA. The General Provisions contain administrative procedures, preconstruction review procedures, and procedures for conducting compliancerelated activities such as notifications, recordkeeping and reporting, performance testing, and monitoring. The proposed rule refers to individual sections of the General Provisions that we believe will be of particular interest to you. However, unless specifically overridden in table 1 of the proposed rule, all of the General Provisions requirements would apply to you.
You may be subject to both the paper and other web coating NESHAP and other future or existing rules, such as new source performance standards (NSPS) and State rules requiring reasonably available control technology limits on volatile organic compounds (VOC) emissions. You must comply with all rules. Duplicative recordkeeping and reporting requirements and differences in emission limitations may be resolved through your title V permit.
Today's proposed rule would limit total organic HAP emissions from
coating lines. We did not identify inorganic HAP as pollutants emitted by this source category.
IV. When Do I Show Initial Compliance With the Proposed Rule?
Existing sources would have to comply with the final rule no later than 3 years after the effective date of the final rule. The effective date is the date of publication of the final rule in the Federal Register. New or reconstructed sources would have to comply upon start up of the affected source or the effective date of the final rule, whichever is later. Details of compliance requirements can be found in the General Provisions, as outlined in table 1 of the proposed rule.
Before your initial compliance demonstration, you would choose one of the three emission limit options for your affected source. In your initial compliance certification, you would notify the Administrator of your choice, and after that you would monitor and report compliance results accordingly. If you decide to change to another emission limitation option, you are also required to notify the Administrator, as with other changes at the facility, discussed in section VI. V. What Testing and Monitoring Must I Do?
In addition to the specific testing and monitoring requirements specified below for the affected source, the proposed rule adopts the testing requirements specified in Sec. 63.7 and specifies that performance tests at existing sources must be conducted by the compliance date.
You may comply with the proposed standards by applying materials meeting the organic HAP emission rate limits, by using capture and control equipment to reduce organic HAP emissions by 95 percent at existing sources and by 98 percent at new sources, or by using a combination of low organic HAP materials and capture and control equipment to meet the organic HAP emission rate limits.
If you demonstrate compliance based on the coating materials applied on your coating lines, you must determine the organic HAP content of materials applied. To make this determination, you may either use EPA Method 311 of appendix A of 40 CFR part 63, use an alternative method for determining the organic HAP content (but only after obtaining EPA approval), or use the volatile organic content of the coating materials applied as the value for the organic HAP content. The volatile organic content must be determined by EPA Method 24 of appendix A of 40 CFR part 60 (or an approved alternative method). If you are demonstrating compliance by applying coating materials that meet the emission limit based on coating solids applied, the solids content of the materials must be determined using EPA Method 24. You may rely on manufacturer's data to determine the organic HAP content or volatile matter and solids content when these data are equivalent to those obtained from Method 311 (or an approved alternative method) and Method 24 (or an approved alternative method), respectively. You must also determine the mass of each coating material applied using company records. You must calculate the organic HAP content and mass of all coating materials applied on the coating lines for each monthly period. However, only changes in a material formulation would require a redetermination of total organic HAP weight fraction for that material. To demonstrate compliance, you must calculate the average mass of organic HAP in coating materials applied and show that it is less than the organic HAP emission limits specified.
If you use an emission capture and control system to comply with the proposed standard, you must demonstrate that the overall control efficiency reduces total organic emissions by at least 95 percent at existing sources and 98 percent at new sources. Alternatively, you may use capture and control equipment in combination with low organic HAP materials and demonstrate you meet the organic HAP emission limit specified. To comply using the combined approach, you must determine the overall control efficiency of the equipment and the organic HAP and solids content of the materials applied. These values must be determined for each monthly period.
The overall control efficiency for a capture and control system would be demonstrated based on emission capture and reduction efficiency. To determine the capture efficiency, you would either verify the presence of a permanent total enclosure using EPA Method 204 of 40 CFR part 51, appendix M, in which case you could assume 100 percent capture; or use EPA Method 204A through F, or Appendix A of 40 CFR part 63, Subpart KK, to measure capture efficiency.
You must determine the emission reduction efficiency of a control device by conducting a performance test or using a continuous emission monitoring system (CEMS). If you use CEMS, you must determine the inlet and outlet concentration to calculate the control efficiency. The CEMS must comply with performance specification 8 or 9 in 40 CFR part 60, appendix B.
If you conduct a performance test, we are proposing that the
removal efficiency of a control device be determined based on three
runs, each run lasting 1 hour. Method 1 or 1A of 40 CFR part 60,
appendix A, must be used for selection of the sampling sites. Method 2,
2A, 2C, 2D, 2F, or 2G of 40 CFR part 60, appendix A, must be used to
determine the gas volumetric flow rate. Method 3, 3A or 3B, of 40 CFR part 60, appendix A, must be used for gas
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analysis to determine dry molecular weight. Method 4 of 40 CFR part 60,
appendix A, must be used to determine stack moisture. Method 25 or 25A
of 40 CFR part 60, appendix A, must be used to determine organic
volatile matter concentration. Alternatively, any other test method or
data that have been validated according to the applicable procedures in
Method 301 of 40 CFR part 63, appendix A, may be used if approved by the Administrator.
If you use a solvent recovery system, you may alternatively determine the overall control efficiency using a liquidliquid material balance. If you demonstrate compliance with the material balance, you must measure the amount of all materials applied during each month and determine the volatile matter content of these materials. You must also measure the amount of volatile matter recovered by the solvent recovery system during the month and calculate the overall solvent recovery efficiency.
The test methods we propose to require, as discussed above, are existing EPA methods that are familiar to the industry, readily available, and appropriate to the device or the parameter being measured. The tests selected are expected to establish adequately whether the facility is complying with the standard.
According to paragraph (a)(3) of section 114 of the CAA, monitoring of stationary sources is required to determine the compliance status of the sources, and whether compliance is continuous or intermittent. For affected sources complying with the proposed standard with capture and control systems, initial compliance is determined through an initial performance test and ongoing compliance through continuous monitoring. We are proposing the parameters to be monitored for certain types of control devices now used in the industry. You must set the values of these parameters that correspond to compliance with the proposed standard during your initial performance test. These values are your ``operating limits.'' If future monitoring shows that capture and control equipment is operating outside the range of values established during the initial performance test, then you are deviating from the operating limits.
If you use a capture and control system to meet the proposed standard, you are required to submit a plan identifying the operating limit and monitoring procedures for the capture system. You must monitor in accordance with your plan unless we require an alternate monitoring procedure.
If you use a thermal or catalytic oxidizer, you must monitor temperature using a continuous parameter monitoring system. If you use a thermal oxidizer, you must establish the average combustion temperature recorded during the performance test as the operating limit. If you use a catalytic oxidizer, you must establish as the operating limits the average gas temperatures recorded during the performance test both upstream and downstream of the catalyst bed. The timeweighted average of the values recorded during the performance test shall be computed to establish the parameter value(s). For catalytic oxidizers, temperature monitors are placed immediately before and after the catalyst bed. For thermal oxidizers, the temperature monitor is placed in the firebox or in the duct immediately downstream of the firebox before any substantial heat exchange occurs.
If you use a solvent recovery system, you must conduct monthly mass balances or operate continuous emission monitors as described in the performance test section.
If you use a combination of capture and control devices and lowHAP materials, you are required to monitor the parameters of the capture and control devices as indicated above. In addition, you must record data on the HAP and solids content of the materials applied to determine the HAP emission rate as described in the performance test section.
The proposed rule specifies the types of parameters that must be
monitored for common types of control devices: temperature monitoring
for oxidizers and either continuous emission monitor systems or mass
balance measurements for solvent recovery. These parameters were
selected because they are good indicators of control device performance, and because continuous parameter monitoring
instrumentation is available at a reasonable cost. You must install,
calibrate, maintain, and operate all monitoring equipment as specified
in the proposed rule. If you use control devices other than those
identified in the proposed standard, you must submit the operating
parameters to be monitored to the Administrator for approval. You could
be approved, on a casebycase basis, to monitor parameters not
specifically listed in the proposed standards. The authority to approve
the parameters to be monitored is retained by the Administrator and is not delegated.
VI. What Notification, Recordkeeping, and Reporting Requirements Must I Follow?
The proposed rule requires you to comply with notification, recordkeeping, and reporting requirements, generally as described in the General Provisions (see table 1 of the proposed rule) and specifically as designed to support demonstration of compliance with this proposed rule. We believe that these requirements are necessary and sufficient to ensure that you comply with the requirements in the proposed subpart JJJJ.
If the NESHAP apply to you, you must send an initial notification to the EPA Regional Office in the region where your facility is located and to your State agency. If you have an existing source, you must submit the initial notification no later than 1 year before the required compliance date for the standard. If you have a new or reconstructed source, you must submit the notification no later than 120 days after either the date of initial startup or the effective date of the final rule, whichever is later.
The Initial Notification Report notifies us and your State agency that you have an existing facility that is subject to the proposed standard or that you have constructed a new facility. Thus, it allows you and the Federal or State enforcement agency to plan for compliance activities. The General Provisions for NESHAP specifies the information you must include in the initial notification and other reporting requirements for new or reconstructed sources.
If the NESHAP apply to you, you will have several options for demonstrating compliance. If you demonstrate compliance by using a capture and control system to reduce emissions of HAP, you must conduct a performance test as described above. Prior to conducting the performance test, you must notify us or the delegated State or local agency at least 60 calendar days before the performance test is scheduled to begin, as indicated in the General Provisions for NESHAP. C. Notification of Compliance Status
You are required to send a notice of compliance status within 180 days after the compliance date as specified in the General Provisions for NESHAP. This report must include your compliance certification, the results of any performance tests and monitoring, and a description of how you will demonstrate continuing compliance.
The notification of compliance status must specifically identify whether lowHAP materials, emission capture and control systems, or a combination of lowHAP materials and capture and control systems were used to comply with this regulation. For capture and control systems, it must also identify the operating limits established during the performance test. Specific reporting requirements are dependent upon how you choose to comply with the proposed rule.
To comply with the proposed standard based on organic HAP content or organic HAP emissions on a weight basis, records must be maintained of the organic HAP, volatile organic content and solids content of each coating applied, and the amount of each coating applied on paper and other web coating lines each month.
If capture and control technology is used, you are required to keep records of the equipment monitoring parameter measurements specified in the proposed rule that are discussed in section V above. You must also develop a startup, shutdown, and malfunction plan. You would have to make the plan available for inspection if the Administrator requests to see it. It would stay in your records for the life of the affected source or until the source no longer must meet the standard in the proposed rule.
Each reporting year is divided into two semiannual reporting
periods. If no deviations occur during a semiannual reporting period,
you would submit a semiannual compliance report stating that the
affected source has been in compliance. A deviation is any instance in
which you fail to meet any requirement or obligation of the proposed
standard or any term or condition adopted to meet the proposed
standard. The following semiannual compliance reports would be required under this proposal when deviations occur:
You would also have to send us reports for each semiannual reporting period in which the following occur:
We developed model plant facilities to represent the industry based on the data we collected. We estimated environmental, energy, and economic impacts based upon what these facilities must do to meet the proposed rule. There are several options for demonstrating compliance with these standards, and each facility has flexibility to adopt the compliance option which has the least economic impact for their individual situation. Most of the existing major source facilities in this industry apply solventbased coatings and utilize thermal oxidation to reduce emissions. Therefore, in estimating the impacts associated with the proposed rule, we assumed that most facilities would install a permanent total enclosure and either install a new thermal oxidizer or improve an existing one. If a facility complies with the proposed rule by applying coatings that meet the proposed emission limitation, the capital and operating costs and other impacts would be lower than estimated. Hence, the estimates presented below may overestimate the costs and other impacts as some facilities may comply with the proposed rule by applying lowHAP coatings.
For existing affected sources in the paper and other web coating industry (approximately 210 major sources), the nationwide baseline organic HAP emissions are estimated to be 35,000 Mg/yr (39,000 tpy). We estimate that implementation of the final rule would reduce emissions from major sources by approximately 29,000 Mg/yr (32,000 tpy), or approximately 80 percent.
We have projected the growth of the paper and other web coating industry and anticipate 32 new affected sources will be constructed over the next 5 years. These sources will need to comply with NSPS in 40 CFR part 60 for VOC and, therefore, we estimated baseline emissions using a 90 percent reduction of organic HAP as the existing level of control. We estimated that nationwide organic HAP baseline emissions from new sources will be about 2,875 Mg/yr (3,170 tpy). We estimate that implementation of the final rule would reduce emissions from new affected sources by about 2,300 Mg/yr (2,535 tpy), or approximately 80 percent.
Secondary environmental impacts are considered to be any air, water, or solid waste impacts, positive or negative, associated with the implementation of the final standard. These impacts are exclusive of the direct organic HAP air emissions reductions discussed in the previous section.
We estimate that more than 99 percent of the organic HAP emissions from paper and other web coating are VOC. Therefore, the capture and control of organic HAP that are presently emitted will result in a decrease in VOC emissions. Consequently, we estimate the current nationwide VOC emissions from the paper and other web coating source category to be at least 35,000 Mg/yr (39,000 tpy), the nationwide organic HAP estimate. The proposed emission controls for organic HAP will reduce nonHAP VOC emissions as well. Emissions of VOC have been associated with a variety of health and welfare impacts. The VOC emissions, together with nitrogen oxides, are precursors to the formation of groundlevel ozone, or smog. Exposure to ambient ozone is responsible for a series of public health impacts, such as alterations in lung capacity and aggravation of existing respiratory disease. Ozone exposure can also damage forests and crops.
The use of newly installed or upgraded control devices to meet the
proposed standard would result in greater electricity consumption (see
section VII of this preamble). Increases in emissions of nitrogen
oxides, sulfur dioxide, carbon monoxide, and carbon dioxide, as well as
certain HAP, from electric utilities could result. The operation of
newly installed or upgraded control devices would also require
combustion of supplemental fuel, typically natural gas (see section VII of this preamble), resulting in
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additional emissions of nitrogen oxides, carbon monoxide, and carbon dioxide.
It is expected that some paper and other web coating facilities will comply with the proposed standard by substituting nonHAP materials for organic HAP presently in use. In some cases, the nonHAP materials may be VOC, however, in other cases, nonVOC materials (e.g., water) may be used. Facilities converting to waterborne materials as a means or partial means of compliance may have reduced Resource Conservation and Recovery Act hazardous waste disposal if the status of the waste material changes from hazardous to nonhazardous. An increase in wastewater discharge may then occur if this waste material and waterborne wash up materials are discharged to publicly owned treatment works. However, we do not expect any significant increases in wastewater discharge to result from the proposed rule.
New and upgraded catalytic oxidizers will require catalysts. Catalyst life is estimated to be more than 10 years. Spent catalysts will represent a small amount of solid waste, and sometimes the spent catalyst will be regenerated by the manufacturer for reuse. Activated carbon used in solvent recovery systems is returned to the manufacturer at the end of its useful life and converted to other salable products. Little solid waste impact is expected from this source.
The operation of new and upgraded control devices will require additional energy. Capture of previously uncontrolled solventladen air will require fan horsepower. Operation of oxidizers, particularly thermal oxidizers, may require supplemental fuel (typically natural gas) to increase the combustion temperature and improve destruction efficiency.
The total additional electrical energy required to meet the proposed standard is estimated to be 313 million kilowatthours per year. Fuel requirements total 3.7 billion British thermal units per year. These fuel impacts are based on a ``worstcase'' scenario, that is the use of thermal oxidizers at all facilities, which is the control scenario expected to result in the highest energy impacts.
The total nationwide capital and annualized costs (1998 dollars) attributable to compliance with the proposed standard have been estimated for existing and new sources. Costs are based on the use of permanent total enclosures, thermal oxidizers, and monitoring equipment. The capital costs with other methods of control (e.g., applying lowHAP coatings) are expected to be significantly lower.
It is expected that any new facility using solventbased coatings will install control systems to comply with applicable State and Federal regulations for reducing VOC emissions from the various sectors of this source category (e.g., the standards of performance for new stationary sources in 40 CFR part 60). The data we gathered on this industry indicate that thermal oxidation is the most common control technology installed to meet the requirements of the existing regulations. Thermal oxidation is capable of achieving a 98 percent reduction of HAP emissions. Therefore, the additional costs to a new facility resulting from this proposed standard were estimated based on the costs of constructing a permanent total enclosure to deliver all HAP emissions to the existing thermal oxidizer.
Capital costs would be incurred by installing capture and control systems at existing facilities presently without capture and control systems, and upgrading capture and control systems at existing facilities that do not meet the proposed standard. Additionally, we estimated the cost for the purchase of monitoring equipment needed as a capital investment to meet the monitoring, recordkeeping, and reporting requirements of the proposed rule. Total nationwide capital costs are estimated to be $210 million with the cost for existing sources and new sources estimated to be $198 million and $12 million, respectively.
Total nationwide annual costs of the proposed standard have been estimated at $68 million with the annual cost for existing and new sources estimated to be $63 million and $5 million, respectively. These costs include capital recovery over a 10year period, operating costs for the newly installed and upgraded capture and control systems, and costs for monitoring, recordkeeping, and reporting. These are net costs after taking into account the costs presently being incurred for the baseline control level.
The economic impact analysis (EIA) shows that the expected price increases for affected output would range from only 0.1 to 1.1 percent as a result of the proposed standard. The expected change in production of affected output is a reduction of 0.1 to 1.1 percent as a result of the proposed standard. There are three plant closures predicted out of 169 facilities included in the economic model. Although any facility closure is cause for concern, it should be noted that the baseline economic condition of the facilities predicted to close affects the closure estimate provided by the economic model. Facilities which are already experiencing adverse economic conditions for reasons unconnected to this rule are more vulnerable to the impact of any new costs than those that are not. The facilities predicted to close appear to have low profitability levels currently. While the rule may adversely impact the three facilities predicted to close, we do not predict an adverse economic impact to the industry as a whole. VIII. What Is the Basis for Selecting the Level of the Proposed Standards?
Section 112(c) of the CAA directs us to develop a list of all categories of major sources and appropriate area sources that emit one or more of the 188 HAP listed under section 112(b) of the CAA. Paper and other web coating is a listed source category because of its organic HAP emissions that include, but are not limited to, toluene, methanol, methyl ethyl ketone, xylenes, phenol, methylene chloride, ethylene glycol and glycol ethers, hexane, methyl isobutyl ketone, cresols and cresylic acid, dimethylformamide, vinyl acetate, formaldehyde, and ethyl benzene. Section 112(d) of the CAA then directs us to promulgate regulations establishing standards for each category or subcategory of major and area sources of HAP listed pursuant to section 112(c). Those emission standards are to reflect the application of MACT.
In selecting the affected source(s) for MACT standards, our primary goal is to ensure that MACT is applied to all the HAPemitting equipment within the source category or subcategory being regulated. The affected source also defines where new source MACT applies under a particular standard. Specifically, the General Provisions define the terms ``construction'' and ``reconstruction'' with reference to the term ``affected source'' (Sec. 60.2) and provide that new source MACT applies when construction and reconstruction occur (Sec. 60.5). The collection of equipment evaluated in determining MACT (including the MACT floor) is usually the collection of equipment used in defining the affected source.
In defining the affected source for the paper and other web coating
proposed NESHAP, we considered available information on HAP emissions, control
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configurations, industry practices, products produced, and the impacts
of other standards. In general, paper and other web coating facilities
are covered by the SIC codes listed in the Regulated Entities table.
However, facilities classified under other SIC codes may be subject to
the proposed standard if the facility meets the definition of a major
source and conducts paper and other web coating (see section II of this preamble).
Although the industry manufactures an extensive list of products, the coating processes used by the different segments of the industry are very similar. Typically, the web substrate is put on a web coating line where it is unwound, coated, rewound and/or cut to size, and packaged. Alternatively, a web may be unwound, coated, and combined with another material by lamination (either before or instead of being rewound). The web coating line may include one work station or multiple work stations which apply the coating to the web. Each work station typically uses a single type of coating applicator (e.g., reverse roll, knife roll, gravure cylinder, dip, and squeeze). When there are multiple work stations on a single web coating line, each station may use a different type of applicator depending on the needs of a specific product. Typically, a drying oven immediately follows each work station.
The primary organic HAP emission source in web coating is the solvent used in the coatings. The solvent acts as a vehicle for the material that is used to coat the web. Once the coating is on the web, the solvent is usually evaporated in dryers or otherwise converted to another material some time during the coating process.
In the various segments of the paper and other web coating industry, the same primary organic HAP emission sources can be found. Dryer organic HAP emissions can represent more than 90 percent of the total organic HAP emissions from coating operations. Some emitted organic HAP are not captured in the dryer exhaust. This uncaptured or fugitive organic HAP include that which evaporate from the coatings into the coating room during application, and that which evaporate from the web in the dryers but are then swept out of the dryer as the web travels toward the succeeding work station. Most, if not all, of the solvent emitted can be collected if capture equipment is installed to collect fugitive solvent vapors.
Dryer exhaust and fugitive emissions can be vented to control devices such as oxidizers or solvent recovery systems. Organic HAP may escape destruction or recovery by the control system, as they may be retained in the coated web. Organic HAP that remains in the web after removal from the coating line may leave the facility in the coated web product or may evaporate during additional processing (e.g., slitting, folding, stitching, etc.).
Coating application and drying/curing are the largest emission
sources of organic HAP emissions for all segments of the paper and
other web coating industry. Because these emission points are on the
web coating lines, the web coating lines are the largest emission
source. Therefore, the proposed affected source is broadly defined as
the collection of all web coating lines at a facility (see section II
of this preamble). This broad definition was selected to provide
sources with flexibility for compliance demonstrations, i.e., averaging
emissions from all web coating lines rather than demonstrating compliance for each individual line.
C. What Is the MACT Floor That Is the Basis for the Proposed Standard?
Data were obtained from 268 paper and other web coating facilities. Facility data were obtained through survey instruments, facility visits, and data reported to EPA's Aerometric Information Retrieval System.
Of the 268 facilities, 210 were estimated to have the potential to be major sources. These 210 facilities were analyzed to identify the top performing facilities in terms of emission limitations from coating lines. The best controlled facilities used capture and control systems to reduce HAP emissions. Capture technology included work station hoods and total enclosures around the coating lines. Control technology included catalytic and thermal oxidation, as well as solvent recovery systems using carbon adsorption or condensation units.
In many cases, existing control devices were originally designed and operated to control VOC emissions. We assumed that the performance of these control devices with respect to VOC and organic HAP is equivalent because the organic HAP commonly used in this industry are also VOC.
Of the 210 facilities in the MACT floor database, 119 used capture and control systems. The same types of capture and control systems were used by these facilities even though the types of coatings, web substrates and products varied widely. All of the facilities were ranked by the percent overall emissions reductions achieved for the collection of all the coating lines at each facility. The average reduction achieved by the best controlled 12 percent of the facilities was 95 percent. Consequently, we identified 95 percent overall control of organic HAP emissions as the MACT floor for existing sources.
We also determined that new sources employing permanent total enclosures with new destruction or recovery systems can be designed to achieve 98 percent overall control of organic HAP emissions. This is the anticipated level of control for new sources using the emission capture and control technologies used by the best controlled sources in the category. Although some facilities reported more than 98 percent overall control of organic HAP emissions, this higher level of control may not be achievable on a continuous basis under all normal operating conditions applicable to new sources. Consequently, 98 percent overall control of organic HAP emissions is the MACT floor for new sources. D. What Are the Control Options Beyond the MACT Floor?
We did not identify any control equipment capable of achieving emissions reductions beyond the MACT floor for new sources. We identified and considered one control level more stringent than the MACT floor for existing sources. The more stringent level for existing sources would require 98 percent overall control of organic HAP emissions from coating lines. In evaluating this control option to select the most appropriate MACT level, we calculated the additional costs and emissions reductions associated with requiring existing sources to achieve this more stringent level of control. While many existing sources can improve upon existing capture and control systems to achieve a 98 percent overall control of organic HAP emissions from coating lines, we believe that most of these same facilities would need to fully replace existing capture and control systems to achieve the more stringent level of control.
We calculated the cost effectiveness (i.e., cost for each ton of
HAP reduced) for reducing HAP emissions at existing sources meeting the
MACT floor and the more stringent level of control. Requiring existing
sources to meet the MACT floor level results in estimated emissions
reductions of 28,700 Mg/yr (31,600 tpy) at an estimated cost of $63
million per year or $1,990 per ton of HAP reduced. We determined that
the incremental cost for the more stringent level of control ($84.5
million) compared to the incremental emissions reductions (3,766 tpy)
(an incremental cost effectiveness of $22,433 per ton of HAP reduced) did not warrant going beyond the MACT floor. Therefore, we
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did not select the more stringent control option as the basis for the standard.
For reasons discussed above, we selected the MACT floors for existing and new paper and other web coating lines as the appropriate level of control for this source category. The proposed level of control for existing sources is 95 percent overall control of organic HAP emissions from coating lines, alternatively stated as limiting emissions to no more than 5 percent of the organic HAP applied. The proposed level of control for new sources is 98 percent overall control of organic HAP emissions from coating lines, alternatively stated as limiting emissions to no more than 2 percent of the organic HAP applied.
Paper and other web coating facilities may be able to reduce the HAP content of the coatings applied on their coating lines. We consider such HAP reductions as pollution prevention and believe pollution prevention is a desirable outcome. To encourage further pollution prevention, we are also proposing emission limitations in two formats that reflect the MACT level of control, but would not require sources to use addon controls to achieve that level.
Coating formulations and organic HAP content vary depending on the coating characteristics required for the products being produced. We evaluated the coating data available to us to establish a baseline organic HAP content for the coatings currently used in this source category. For existing sources, we reduced the baseline organic HAP content of coatings by 95 percent to establish the emission limitations of 0.20 kilograms (kg) of HAP emitted per kg of coating solids applied and 0.04 kg of HAP emitted per kg of coating applied. Similarly, for new sources, we reduced the baseline organic HAP content by 98 percent to establish the emission limitations of 0.08 kg HAP emitted per kg of coating solids applied and 0.016 kg of HAP emitted per kg of coating applied.
We believe these emission limitations, expressed in the proposed
standard as both a HAP content limit and a HAP emission limit, are
appropriately based on the MACT level of control. Compliance with the
HAP content limits and equivalent HAP emission limits must be
determined using the monthly average HAP applied on a mass solids or
mass coating basis. Sources operating capture and control systems can
comply with these emission limitations by determining the organic HAP
content of the coatings applied on all their coating lines and
factoring in the capture and control efficiency such that the monthly
average controlled organic HAP emissions from the affected source meet these limits.
IX. What Is the Basis for Selecting the Format of the Proposed Standards?
The proposed format for the emission standard is an overall percent reduction of emissions, taking into account both capture and control system efficiencies. Data available to us regarding the efficiency of capture and control systems used in this industry indicate that overall efficiency is typically determined by a performance test for capture systems and oxidizers and liquidliquid material balance for solvent recovery systems. The proposed standard allows for determining overall control efficiency through a variety of mechanisms to be consistent with industry practices. We selected this format because it reflects MACT at all facilities and allows flexibility in the method selected for achieving the percent reduction limit.
The use of an allowable concentration of emissions in the exhaust gases discharged to the atmosphere was also considered. The major disadvantage of this format is its inability to identify the overall control efficiency of the capture and control system, and thus, the overall percent reduction of organic HAP emissions. The concentration of emissions in exhaust gases could be decreased by increasing dilution air through the capture and control system. Thus, we do not believe an exhaust gas concentration limit is appropriate for demonstrating the overall percent reduction of emissions.
To encourage the use of low and noHAP materials, two additional
formats are proposed. These formats limit emissions to either mass of
HAP per mass of coating solids applied, or mass of HAP per mass of
coating material applied (both solids and liquid). Affected sources can
use either low or noHAP coating materials to meet these limits or
capture and control systems, or a combination of the two. These formats
do not establish any certain percent reduction requirement for capture
and control systems but do accurately reflect application of MACT.
Thus, they can provide flexibility for a source to combine addon
control with use of lowHAP materials to achieve the emissions reductions.
X. Administrative Requirements
Under Executive Order 12866 (58 FR 51735, October 4, 1993), EPA
must determine whether the regulatory action is ``significant'' and
therefore subject to review by the Office of Management and Budget
(OMB) and the requirements of the Executive Order. The Executive Order
defines ``significant regulatory action'' as one that is likely to result in a rule that may:
(1) Have an annual effect on the economy of $100 million or more or
adversely affect in a material way the economy, a sector of the
economy, productivity, competition, jobs, the environment, public
health or safety, or State, local, or tribal governments or communities;
(2) Create a serious inconsistency or otherwise interfere with an action taken or planned by another agency;
(3) Materially alter the budgetary impact of entitlements, grants,
user fees, or loan programs, or the rights and obligation of recipients thereof; or
(4) Raise novel legal or policy issues arising out of legal
mandates, the President's priorities, or the principles set forth in the Executive Order.
Pursuant to the terms of Executive Order 12866, it has been determined that this rule is not a ``significant regulatory action'' because none of the listed criteria apply to this action. Consequently, this action was not submitted to OMB for review under Executive Order 12866.
Executive Order 13132, entitled ``Federalism'' (64 FR 43255, August 10, 1999), requires EPA to develop an accountable process to ensure ``meaningful and timely input by State and local officials in the development of regulatory policies that have federalism implications.'' ``Policies that have federalism implications'' is defined in the Executive Order to include regulations that have ``substantial direct effects on the States, on the relationship between the national government and the States, or on the distribution of power and responsibilities among the various levels of government.''
Under section 6 of Executive Order 13132, EPA may not issue a
regulation that has federalism implications, that imposes substantial
direct compliance costs, and that is not required by statute, unless
the Federal government provides the funds necessary to pay the direct
compliance costs incurred by State and local governments, or EPA consults with State and local officials early in the
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process of developing the proposed regulation. The EPA also may not
issue a regulation that has federalism implications and that preempts
State law, unless the Agency consults with State and local officials
early in the process of developing the proposed regulation.
This proposed rule does not have federalism implications. It will not have substantial direct effects on the States, o
FOR FURTHER INFORMATION CONTACT Mr. Paul Almodovar, Coatings and Consumer Products Group, Emission Standards Division (MD13), U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711; telephone number (919) 5410283; facsimile number (919) 541 5689; email address: almodovar.paul@epa.gov.
14 CFR Part 39 40 CFR Part 52 14 CFR Part 71 33 CFR Part 165 50 CFR Part 679 26 CFR Part 1 40 CFR Part 180 47 CFR Part 73 50 CFR Part 17 33 CFR Part 117 44 CFR Part 67 50 CFR Part 648 14 CFR Part 97 33 CFR Part 100 40 CFR Part 63 50 CFR Part 622 26 CFR Part 301 39 CFR Part 111 40 CFR Part 300 50 CFR Part 660 44 CFR Part 65 40 CFR Parts 52 and 81 40 CFR Part 271 47 CFR Part 64 50 CFR Part 665 47 CFR Part 76 50 CFR Part 229 14 CFR Part 23 14 CFR Part 25 21 CFR Part 522