Environmental Quality, Air Quality

Rule R307-344

Paper, Film, and Foil Coatings

Notice of Proposed Rule

(New Rule)

DAR File No.: 36726
Filed: 09/06/2012 04:18:38 PM

RULE ANALYSIS

Purpose of the rule or reason for the change:

In 2006, EPA tightened the 24-hour PM2.5 national ambient air quality standard from 65 to 35 micrograms per cubic meter. Currently, seven Utah counties have been found by EPA to not meet this standard. Paper, film, and foil coating operations emit volatile organic compounds (VOCs), which are precursors to the formation of PM2.5. This rule for the PM2.5 State Implementation Plan will lower VOCs that are emitted from paper, film, and foil coating operations, as well as clarify regulatory requirements to the industry.

Summary of the rule or change:

This rule applies to paper, film, and foil coating operations, including related cleaning activities, that have the potential to emit 2.7 tons of volatile organic compounds (VOC) per year and that are located in Box Elder, Cache, Davis, Salt Lake, Tooele, Utah, and Weber counties. The rule establishes reasonably available control technology requirements to reduce VOC emissions. Owners and operators have the option to reduce VOCs by applying coatings with the VOC limits established in the rule or to use add-on controls to achieve at least a 90% VOC reduction. During the public comment period, the Air Quality Board is requesting public input on the appropriateness of applying this rule in Tooele and Box Elder counties.

State statutory or constitutional authorization for this rule:

• Subsection 19-2-104(1)(a)

Anticipated cost or savings to:

the state budget:

The majority of the requirements in this rule were already found in the Utah Air Quality rule, Rule R307-340, which has been proposed to be repealed. Therefore, there are no anticipated costs or savings to the state budget. (DAR NOTE: The proposed repeal of Rule R307-340 is under DAR No. 36725 is this issue, October 1, 2012, of the Bulletin.)

local governments:

The majority of the requirements in this rule were already found in the Utah Air Quality rule, Rule R307-340, which has been proposed to be repealed. Therefore, there are no anticipated costs or savings to local government.

small businesses:

Anticipated cost to sources is approximately $1,440 per ton VOC removed.

persons other than small businesses, businesses, or local governmental entities:

This rule applies to owners and operators of paper, film, and foil coatings operations that emit 2.7 tons of VOC per year. There are no anticipated costs or savings to persons other than small businesses, businesses, or local government entities.

Compliance costs for affected persons:

The compliance cost to implement the requirements of this rule is approximately $1,440 per ton VOC removed.

Comments by the department head on the fiscal impact the rule may have on businesses:

The cost to business to comply with this rule is approximately $1,440 per ton VOC removed.

Amanda Smith, Executive Director

The full text of this rule may be inspected, during regular business hours, at the Division of Administrative Rules, or at:

Environmental Quality
Air QualityRoom Fourth Floor
195 N 1950 W
SALT LAKE CITY, UT 84116-3085

Direct questions regarding this rule to:

• Mark Berger at the above address, by phone at 801-536-4000, by FAX at 801-536-0085, or by Internet E-mail at [email protected]

Interested persons may present their views on this rule by submitting written comments to the address above no later than 5:00 p.m. on:

10/31/2012

Interested persons may attend a public hearing regarding this rule:

• 10/16/2012 11:00 AM, Mountainland Association of Governments, 586 E 800 N, Orem, UT
• 10/15/2012 11:00 AM, Bridgerland Applied Technology College, 1301 N 600 W, Rooms 171 D and E, Logan, UT
• 10/17/2012 06:00 PM, Utah Department of Environmental Quality, 195 N 1950 W, Room No. 1015, SLC, UT
• 10/17/2012 02:00 PM, Utah Department of Environmental Quality, 195 N 1950 W, Room No. 1015, SLC, UT

This rule may become effective on:

12/06/2012

Authorized by:

Bryce Bird, Director

R307. Environmental Quality, Air Quality.

R307-344. Paper, Film, and Foil Coatings.

R307-344-1. Purpose.

The purpose of this rule is to limit volatile organic compound (VOC) emissions from roll, knife, and rotogravure coaters and drying ovens of paper, film, and foil coating operations.

 

R307-344-2. Applicability.

R307-344 applies to paper, film, and foil coating operations, including related cleaning activities, that have the potential to emit 2.7 tons per year of VOC and that are located in Box Elder, Cache, Davis, Salt Lake, Tooele, Utah and Weber counties.

 

R307-344-3. Definitions.

The following additional definitions apply to R307-344:

"Coating" means a protective, functional, or decorative film applied in a thin layer to a surface. This term often applies to paints such as lacquers or enamels. It is also used to refer to films applied to paper, plastics, or foil.

"Foil coating" means a coating applied in a web coating process on any foil substrate other than paper or fabric, including, but not limited to, typewriter ribbons, photographic film, magnetic tape, and metal foil gift wrap, but excluding coatings applied to packaging used exclusively for food and health care products for human and animal consumption.

"Knife coating" means the application of a coating material to a substrate by means of drawing the substrate beneath a blade that spreads the coating evenly over the width of the substrate.

"Paper coating" means uniform distribution of coatings put on paper, film, foils and pressure sensitive tapes regardless of substrate. Related web coating processes on plastic film and decorative coatings on metal foil are included in this definition. Paper coating covers saturation operations as well as coating operations.

"Roll coating" means the application of a coating material to a substrate by means of hard rubber or steel rolls.

"Roll printing" means the application of words, designs and pictures to a substrate usually by means of a series of hard rubber or steel rolls each with only partial coverage.

"Rotogravure coating" means the application of a uniform layer of material across the entire width of the web to substrate by means of a roll coating technique in which the pattern to be applied is etched on the coating roll. The coating material is picked up in these recessed areas and is transferred to the substrate.

"Saturation" means dipping the web into a bath.

"Web" means a continuous sheet of substrate.

 

R307-344-4. Emission Standards.

Each owner or operator shall not apply coatings with a VOC content in excess of the amounts specified in Table 1 or shall use an add-on control device as specified in R307-344-6.

 

TABLE 1

Paper, Film, and Foil Coating Limitations

(values in pounds VOC per pound of coating, minus water, as applied)



COATING CATEGORY                         VOC EMISSION RATES



Paper, film and foil                            0.08



Pressure sensitive tape

and label                                       0.067

 

R307-344-5. Work Practices and Recordkeeping.

(1) Control techniques and work practices are to be implemented at all times to reduce VOC emissions from fugitive type sources. Control techniques and work practices include:

(a) Using tight fitting covers for open tanks;

(b) Using covered containers for solvent wiping cloths;

(c) Using collection hoods for areas where solvent is used for cleanup;

(d) Minimizing spills of VOC-containing cleaning materials;

(e) Conveying VOC-containing materials from one location to another in closed containers or pipes;

(f) Cleaning spray guns in enclosed systems; and

(g) Using recycled solvents for cleaning.

(2) The owner or operator shall maintain records from the manufacturer that demonstrate compliance with the emission standards of R307-344-4.

 

R307-344-6. Optional Add-On Controls.

(1) The owner or operator may install and maintain an

incinerator, carbon adsorption, or any other add-on emission control device, provided that the emission control device will attain at least 90% efficiency performance.

(2) The owner or operator of a control device shall provide certification from the manufacturer that the emission control system will attain required efficiency performance.

(3) Emission control systems shall be operated and maintained in accordance with the manufacturer recommendations. The owner or operator shall maintain for a minimum of two years records of operating and maintenance sufficient to demonstrate that the equipment is being operated and maintained in accordance with the manufacturer recommendations.

 

R307-344-7. Compliance Schedule.

(1) All sources in Davis and Salt Lake counties are subject to this rule upon the effective date.

(2) Sources in Box Elder, Cache, Tooele, Utah and Weber counties shall be in compliance with the rule by January 1, 2014.

 

KEY: VOC emission, paper coating, film coating, foil coating

Date of Enactment or Last Substantive Amendment: 2012

Authorizing, and Implemented or Interpreted Law: 19-2-104(1)(a)