DAR File No. 36726

Environmental Quality, Air Quality

Rule R307-344

Paper, Film, and Foil Coatings

Change in Proposed Rule

DAR File No.: 36726
Filed: 12/10/2012 12:02:10 PM

RULE ANALYSIS

Purpose of the rule or reason for the change:

During the public comment period, stakeholders and existing small sources expressed their concerns about the 2.7 tons per year applicability being applied to existing sources in Box Elder and Tooele counties. The EPA also submitted comments regarding the record-keeping requirements. The changes to the proposed rule are in response to these comments.

Summary of the rule or change:

Section R307-344-2 is changed stating that in Tooele and Box Elder counties, the rule applies to existing sources as of 02/01/2013, that have the potential to emit 5 tons per year or more of VOC and applies to new sources that have the potential to emit 2.7 tons per year or more VOC. The rule still applies in Cache, Davis, Salt Lake, Utah and Weber counties to sources that have the potential to emit 2.7 tons per year or more VOC. Language is added to Section R307-344-4 to clarify that exempt solvents are not included in the VOC content limits for the coating used. Section R307-344-5 is changed to require owners and operators to maintain records demonstrating compliance with the rule on an annual basis and to require them to make those records available to the director upon request. Subsection R307-344-5(3) is amended by adding application requirements. Section R307-344-6 is changed to clarify that the owner or operator must provide documentation that the emission control system will attain the requirements of Section R307-344-6. (DAR NOTE: This change in proposed rule has been filed to make additional changes to a proposed new rule that was published in the October 1, 2012, issue of the Utah State Bulletin, on page 65. Underlining in the rule below indicates text that has been added since the publication of the proposed rule mentioned above; strike-out indicates text that has been deleted. You must view the change in proposed rule and the proposed new rule together to understand all of the changes that will be enforceable should the agency make this rule effective.)

State statutory or constitutional authorization for this rule:

• Subsection 19-2-104(1)(a)

Anticipated cost or savings to:

the state budget:

The changes to this rule do not result in any new requirements to the state; therefore, there are no anticipated costs or savings to the state budget.

local governments:

The changes to this rule do not result in any new requirements to local governments; therefore, there are no anticipated costs or savings to local governments.

small businesses:

Because the rule's applicability to existing sources in Box Elder and Tooele counties is changed from sources with the potential to emit 2.7 tons per year VOC to sources with the the potential to emit 5 tons per year VOC, the rule will apply to fewer sources in those counties, resulting in a savings of up to $1,440 per ton of VOC removed.

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

Because there are no new requirements for persons other than small businesses, businesses, or local government entities, there are no anticipated costs or savings.

Compliance costs for affected persons:

Because the rule's applicability to existing sources in Box Elder and Tooele counties is changed from sources with the potential to emit 2.7 tons per year VOC to sources with the the potential to emit 5 tons per year VOC, the rule will apply to fewer sources in those counties, resulting in a savings of up to $1,440 per ton of VOC removed.

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

Because the rule's applicability to existing sources in Box Elder and Tooele counties is changed from sources with the potential to emit 2.7 tons per year VOC to sources with the the potential to emit 5 tons per year VOC, the rule will apply to fewer sources in those counties, resulting in a savings of up to $1,440 per ton of 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 mberger@utah.gov

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:

This rule may become effective on:

02/01/2013

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.](1) R307-344 applies to sources located in Cache, Davis, Salt Lake, Utah and Weber counties that have the potential to emit 2.7 tons per year or more of VOC, including related cleaning activities.

(2) In Box Elder and Tooele counties, R307-344 applies to the following sources:

(a) Existing sources as of February 1, 2013, with the potential to emit 5 tons per year or more of VOC, including related cleaning activities; and

(b) New sources as of February 1, 2013, that have the potential to emit 2.7 tons per year or more of VOC, including related cleaning activities.

 

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 and
exempt solvents (compounds not classified as VOC), 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.]All sources subject to R307-344 shall maintain records demonstrating compliance with all provisions of R307-344 on an annual basis.

(a) Records shall include, but not limited to, inventory and product data sheets of all coatings and solvents subject to R307-344.

(b) These records shall be available to the director upon request.

(3) No person shall apply coatings unless these materials are applied with equipment operated according to the manufacturer's specifications, and by the use of one of the following methods:

(a) Flow coater;

(b) Roll coater;

(c) Dip coater;

(d) Foam coater;

(e) Die coater;

(f) Hand application methods;

(g) High-volume, low pressure (HVLP) spray; or

(h) Other application method capable of achieving at least 65% transfer efficiency, as certified by the manufacturer.

(4) All persons shall perform solvent cleaning operations with cleaning materials having VOC content of 0.21 pounds per gallon or less.

 

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]documentation [from the manufacturer] that the emission control system will attain [required efficiency performance] the requirements of R307-344-6.

(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]2013

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