4 The record articles

Amendments to Paper and Other Web Coatings NESHAP

Posted: April 15th, 2020

Authors: Robert K. 

On March 11, 2020, U.S. EPA finalized minor amendments to the 2002 Paper and Other Web Coating (POWC) National Emission Standards for Hazardous Air Pollutants (NESHAP).  The POWC NESHAP is codified at 40 CFR Part 63 Subpart JJJJ and applies to new and existing major stationary sources of hazardous air pollutants (HAP) at which web coating lines are operated.  This includes pressure-sensitive tapes and labels, flexible packaging, photographic film, coated vinyl, wall coverings, sandpaper and other abrasives, paperboard boxes, vinyl flooring, industrial and decorative laminates, carbon paper and carbonless paper, and circuit boards and business forms.  This action finalizes the residual risk and technology review (RTR) conducted for POWC. U.S EPA identified no new cost-effective controls under the technology review that would achieve significant further emissions reductions.  Therefore, U.S. EPA proposes no revisions to the standards based on developments in practices, processes, or control technologies.

The amendments will become effective once published in the Federal Register and the compliance date for existing sources will be 365 days from the date of publication.  Modified and reconstructed sources must comply upon startup.

The amendments include:

  • The elimination of the startup, shutdown and malfunction (SSM) exemption. For existing sources, compliance with this provision will be required beginning 365 days from the date of publication in in the Federal Register.
  • The addition of periodic air emissions performance testing. This will be required once every five years for facilities using thermal oxidizers and annually for facilities using catalytic oxidizers to demonstrate compliance with the standards.
  • A new requirement for facilities to submit electronic copies of compliance reports and performance tests through U.S. EPA’s Central Data Exchange (CDX) using the Compliance and Emissions Data reporting Interface (CEDRI).
  • The addition of provisions for more flexible monitoring requirements. For example, the amendments allow the use of several consensus standards as an alternative to U.S. EPA Method 24 for determining the volatile organic compound (VOC) content for coatings.
  • Amendments to provide regulatory clarity.

If you have any questions about the changes to the POWC NESHAP, or questions about any of the other myriad of printing and coating rules, reach out to Bob Kuklentz at rkuklentz@all4inc.com or at (610) 933-5246 x124.


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