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Air Toxics Update: New Requirements for Paper and Other Web Coating

  • 11/24/2020 9:13:00 AM
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EPA recently updated several federal regulations for hazardous air pollutants (also known as HAP or air toxics). EPA’s actions address the Risk and Technology Review (RTR) required under the U.S. Clean Air Act.

This is the ninth in a series of articles covering EPA’s updates to air toxics regulations (also known as National Emission Standards for Hazardous Air Pollutants or NESHAP). The changes update individual subparts of 40 Code of Federal Regulations (CFR) Part 63. Find background on the NESHAP RTR requirements and a general overview of the recent changes in the Air Toxics Update. In the following weeks, Iowa DNR will continue to address changes to specific regulations affecting Iowa businesses.

Updates to the Standards for Paper and Other Web Coating
On July 9, 2020, EA published the final NESHAP RTR Amendments for Paper and Other Web Coating (Subpart JJJJ). Facilities in this source category coat paper and other web substrates, and produce items such as 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, circuit boards, and business forms. The NESHAP requirements are intended to reduce HAP emissions from chemicals such as toluene, methanol, xylenes and formaldehyde. Iowa DNR estimates that two Iowa facilities are currently subject to the NESHAP for Paper and Other Web Coating.

New Requirements

The changes to the standards include, but are not limited to, the following:

  • RTR Assessment: Following the RTR, EPA determined that risks from this source category to be acceptable and that no new cost-effective controls are available. EPA did not change any standards as a result of the RTR.
  • Revised Testing: Periodic performance testing is required every five years for facilities using thermal oxidizers. Previously, only an initial test was required. Additionally, annual catalyst testing is required for facilities using catalytic oxidizers.
  • Determining volatile organic matter retained in the coated web: EPA added an equation to be used to account for volatile organic matter retained in the coated web.
  • Temperature sensor validation: EPA removed the temperature sensor calibration requirement and replaced it with validation requirements to ensure continued compliance.
  • Operating parameter clarification: EPA finalized an operating parameter clarification that a deviation from a 3-hour average operating parameter is not a deviation of the standard, unless the emission limitations for the month in which the deviation occurred are exceeded.
  • Startup, Shutdown, and Malfunction: The amendments revise and clarify regulatory provisions related to emissions during periods of startup, shutdown and malfunction (SSM) to indicate that the standards apply continuously, including during periods of SSM.
  • Electronic Reporting: The updated standards also include electronic reporting of compliance reports and performance test results and reports through EPA’s Central Data Exchange, using the Compliance and Emissions Data Reporting Interface (CEDRI). Note: Affected facilities must also comply with Iowa requirements for submitting reports, as specified in Iowa administrative rules or in air permits.

Compliance Deadlines
The compliance date for affected existing facilities is July 9, 2021, with the exception of electronic reporting of semiannual reports. Affected sources that commenced construction or reconstruction after September 19, 2019 (new sources), must comply with all requirements (except for the electronic reporting of semiannual reports), by July 9, 2020 or upon startup, whichever is later. All affected sources must use the CEDRI reporting template for semiannual reports for the subsequent semiannual reporting period after the form has been available in CEDRI for one year.

For more information: Paper and Other Web Coating

Implementation in Iowa
DNR plans to begin rulemaking to incorporate the updated standards—which will give DNR authority to administer the rules. In the interim, EPA will implement the NESHAP RTR changes. DNR is available to answer questions about the new amendments and will work with EPA Region 7 to assist facilities.

DNR staff will review the changes and contact facilities which we know are impacted and have substantively different requirements in their permits from the updated NESHAP. However, an affected facility should carefully review the updated NESHAP to be aware of any new requirements and compliance dates. An affected facility must still comply with the NESHAP RTR requirements even if the requirements are not included in an Iowa air permit.

If you have technical questions about the NESHAP changes, please contact Michael Hermsen (email:; phone: 515-725-9577). For general questions, please contact Christine Paulson (email:; phone: 515-725-9510).