EPA-450/3-80-036a
Beverage Can Surface
Coating Industry —
Background Information
for Proposed Standards
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
September 1980
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This report has been reviewed by the Emission Standards and Engineering Divi-
sion of the Office of Air Quality Planning and Standards, U.S. Environmental
Protection Agency, and approved for publication. Mention of trade names or
commercial products is not intended to constitute endorsement or recommenda-
tion for use. Copies of this report are available through the Library Ser-
vices Office (MD-35), U.S. Environmental Protection Agency, Research Triangle
Park, N.C. 27711, or from National Technical Information Services, 5285 Port
Royal Road, Springfield, Va. 22161.
PUBLICATION NO. EPA-450/3-80-036a
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ENVIRONMENTAL PROTECTION AGENCY
Background Information
and Draft
Environmental Impact Statement
for
Beverage Can Surface Coating Industry
Prepared by:
Don R. Goodwinl
Director, Emission Standards and Engineering Division
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
(Date)
The proposed standards of performance would limit emissions of volatile
organic compounds from new, modified, and reconstructed beverage can
surface coating lines. Section 111 of the Clean Air Act (42 USC
7411), as amended, directs the Administrator to establish standards of
performance for any category of new stationary sources of air pollution
which "causes or contributes significantly to air pollution which may
reasonably be anticipated to endanger public health or welfare." All
regions are affected.
Copies of this document have been sent to the Department of Labor;
Department of Agriculture; Department of Commerce; Council of Environ-
mental Quality; members of the State and Territorial Air Pollution
Program Administrators (STAPPA), and the Association of Local Air
Pollution Control Officials (ALAPCO); to EPA Regional Administrators;
and to other interested parties.
The comment period for review of this document is 60 days and is
expected to begin on or about September 25, 1980.
For additional information contact:
Mr. Gene Smith
Standards Development Branch (MD-13)
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Telephone: (919) 541-5421.
Copies of this document may be obtained from:
U.S. EPA Library (MD-35)
Research Triangle Park, NC 27711
National Technical Information Service
5285 Port Royal Road
Springfield, Virginia 22161
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TABLE OF CONTENTS
Chapter
1
SUMMARY
1.1 Regulatory Alternatives 1-1
1.2 Environmental Impact 1-1
1.3 Economic Impact 1-3
INTRODUCTION
2.1 Background and Authority for Standards 2-1
2.2 Selection of Categories of Stationary Sources 2-4
2.3 Procedure for Development of Standards of
Performance 2-6
2.4 Consideration of Costs 2-8
2.5 Consideration of Environmental Impacts I. ... 2-9
2.6 Impact on Existing Sources '. . . . 2-10
2.7 Revisions of Standards of Performances |. . . . 2-11
i
THE BEVERAGE CAN COATING INDUSTRY I. ... 3-1
3.1 General '. . . . 3-1
3.2 Processes or Facilities and Their Emissions ...... 3-2
3.2.1 Two-Piece Beverage Can Coating 3-2
3.2.2 Three-Piece Beverage Can Coating 3-5
3.3 Baseline Emissions 3-8
3.4 References 3-27
EMISSION CONTROL TECHNIQUES 4-1
4.1 Alternative Emission Control Techniques 4-2
4.1.1 Waterborne Coatings 4-2
4.1.2 Add-on Emission Control Systems 4-9
4.2 Viable Emission Control Options 4-11
4.3 References I. ... 4-14
MODIFICATION AND RECONSTRUCTION 5-1
5.1 Modification .5-1
5.2 Reconstruction 5-3
5.3 References i 5-3
r ' • •
MODEL PLANTS AND REGULATORY ALTERNATIVES 6-1
6.1 Model Plants 6-1
6.1.1 Two-Piece Beverage Cans 6-2
6.1.2 Three-Piece Beverage Cans 6-13
6.1.3 End-Forming Plants 6-14
6.2 Base Case |. . . . 6-15
6.3 Regulatory Alternatives 6-15
6.4 References i. . . . 6-20
V
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TABLE OF CONTENTS (continued)
Chapter Page
7 ENVIRONMENTAL IMPACT 7-1
7.1 Air Pollution Impact 7-1
7.1.1 General 7-1
7.1.2 State Regulations and Controlled Emissions . . . 7-3
7.1.3 Comparative Emissions from Model Plants
Employing Various Emission Control Options . . . 7-6
7.1.4 Estimated VOC Emission Reduction in
Future Years 7-11
7.2 Water Pollution Impact 7-17
7.3 Solid Waste Impact 7-24
7.4 Energy Impact 7-24
7.5 Other Environmental Impacts 7-25
7.6 Other Environmental Concerns 7-35
7.6.1 Irreversible and Irretrievable Commitment
of Resources 7-35
7.6.2 Environmental Impact of Delayed Standards. . . . 7-35
7.7 References 7-35
8 ECONOMIC IMPACT 8-1
8.1 Industry Characterization 8-1
8.2 Cost Analysis of Control Options 8-10
8.2.1 Introduction 8-10
8.2.2 New Facilities 8-15
8.3 Other Cost Considerations 8-20
8.4 Economic Impacts 8-20
8.4.1 Summary 8-26
8.4.2 Methodology 8-28
8.4.3 Economic Impacts 8-34
8.5 Potential Socioeconomic and Inflationary Impacts. . . . 8-52
8.5.1 Annualized Cost Criterion 8-59
8.5.2 Product Price Criterion 8-61
8.6 References 8-61
Appendix
A EVOLUTION OF THE BACKGROUND DOCUMENT A-l
B INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS B-l
C DATA ON LOW-SOLVENT WATERBORNE COATINGS C-l
D EMISSION MEASUREMENT AND CONTINUOUS MONITORING D-l
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LIST OF TABLES
Table
1-1
3-1
3-2
3-3
3-4
3-5
3-6
3-7
3-8
3-9
3-10
3-11
3-12
3-13
Assessment of Environmental and Economic Impacts
for each Regulatory Alternative Considered 1-2
Number of Beverage Cans by Construction Process, 1978 3-3
CTG-Recommended Emission Limitations for Can Surface
Coatings 3-11
Emission Distributions 3-14
Model Plant Operating Parameters, Base Case, CTG Waterborne
Coatings: Coating of Bodies for Aluminum and Steel,
Two-Piece 12-oz Beverage Cans 3-17
Model Plant Coating, VOC Emissions, and Air Flow Parameters,
Base Case, CTG Waterborne Coatings: Coating of Bodies
for Aluminum and Steel Two-Piece 12-oz Beverage Cans 3-18
Model Plant Operating Parameters, Base Case, CTG Waterborne
Coatings: Coating of Steel Body Stock for Three-Piece
12-oz Beverage Can 3-19
Model Plant Coating, VOC Emissions, and Air Flow Parameters,
Base Case, CTG Waterborne Coatings: Coating of Steel Body
Stock for Three-Piece 12-oz Beverage Cans 3-20
Model Plant Operating Parameters, Base Case, CTG Waterborne
Coatings: Coating of Can Bodies for Three-Piece 12-oz
Beverage Cans 3-21
Model Plant Coating, VOC Emissions, and Air Flow Parameters,
Base Case, CTG Waterborne Coatings: Coating of Can Bodies
for Three-Piece 12-oz Beverage Cans 3-22
Model Plant Operating Parameters, Base Case, CTG Waterborne
Coatings: Coating of Steel- and Aluminum-End Sheets 3-23
Model Plant Coatings, VOC Emissions, and Air Flow Parameters,
Base Case, CTG Waterborne Coatings: Coating of Steel- and
Aluminum-End Stock 3-24
Model Plant Operating Parameters, Base Case, CTG End-Sealing
Compound: Steel and Aluminum Ends 3-25
Model Plant Coating, VOC Emissions and Air Flow Parameters,
Base Case: Application of End-Sealing Compound 3-26
vn
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LIST OF TABLES (continued)
Table
4-1
4-2
6-1
6-2
6-3
6-4
6-5
6-6
6-7
6-8
6-9
6-10
6-11
6-12
7-1
7-2
VOC Content of Waterborne Coatings with Lowest VOC Content
in General Use
VOC Content of Higher Solids Solvent-Borne Coatings
in General Use
Can Surface Coating, Two- Piece Aluminum- and Steel -
Integrated Facility, Evaluation of Emission Control
Options
Can Surface Coating, Three-Piece Steel -Sheet Coating,
Evaluation of Emission Control Options
Can Surface Coating, Three-Piece Can-Forming Lines:
Evaluation of Emission Control Options
Can Surface Coating, Aluminum- and Steel -End Sheet Coating,
Evaluation of Emission Control Options
End Forming (Steel and Aluminum): Evaluation of Emission
Control Options
Summary of Model Plant Parameters, Two-Pi ece Can Surface
Coating
Summary of Model Plant Parameters, Three-Piece Steel Can
Sheet Coating
Summary of Model Plant Parameters, Three- Pi ece Steel Can
Inside Spray
Summary of Model Plant Parameters, Steel- and Aluminum- End
Sheet Coating
Summary of Model Plant Parameters, End Forming (Steel and
Aluminum), Application of End-Sealing Compound
Incineration Requirements/Solvent-Borne Coatings for
Equivalence with Regulatory Alternative II
Incineration Requirements/Solvent-Borne Coatings for
Equivalence with Regulatory Alternative III
Baseline Emissions, Beverage Can Surface Coatings
Profile of Organic Emissions Regulations by States. .....
Page
. . 4-12
. . 4-13
6-3
6-4
6-5
6-6
6-7
6-8
6-9
6-10
6-11
6-12
6-18
6-19
7-2
. . 7-5
vm
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LIST OF TABLES (continued)
Table
7-3
7-4
7-5
7-6
7-7
7-8
7-9
7-10
7-11
7-12
7-13
7-14
7-15
7-16
7-17
7-18
Recommended CTG Emission Limitations for Can Surface
Coatings 7-7
Emission Control Options 7-8
Emissions from Base Case and Emission Control Options,
Two-Piece Aluminum- and Steel-Integrated Facility 7-9
Emissions from Base Case and Emission Control Options,
Three-Piece Can Sheet Coating 7-10
Emissions from Base Case and Emission Control Options,
Three-Piece Can Forming (Inside Spray) 7-12
Emissions from Base Case and Emission Control Options,
Sheet Coating, Steel or Aluminum Ends 7-13
Emissions from Base Case and Emission Control Options,
End Forming (Steel and Aluminum), End-Sealing Compound
Application 7-14
Annual Production of Beverage Cans, 1978-1985 7-15
Estimated Beverage Can Production Subject to NSPS,
1980-1985 7-16
Emission Reductions from Emission Control Options,
Two-Piece Steel- and Aluminum-Integrated Facility 7-18
Emission Reductions from Emission Control Options,
Three-Piece Can Sheet Coating, 1985 . 7-19
Emission Reductions from Emission Control Options,
Three-Piece Can Forming, 1985 ..... 7-20
Emission Reductions from Emission Control Options,
Sheet Coating, Steel and Aluminum Ends, 1985 7-21
Emission Reduction from Emission Control Options, End
Forming, Steel and Aluminum, 1985 7-22
Beverage Can Surface Coating: Emission Reduction from
Regulatory Alternatives, 1985 7-23
Energy Impact of Emission Control Options, Two-Piece
Aluminum Cans 7-26
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LIST OF TABLES (continued)
Table Page
7-19 Energy Impact of Emission Control Options, Three-Piece
Can Sheet Coating 7-27
7-20 Energy Impact of Emission Control Options, Three-Piece
Steel Can, Inside Spray 7-28
7-21 Energy Impact of Emission Control Options, Steel- and
Alunimum-End Sheet Coating 7-29
7-22 Energy Requirements for Emission Control Options,
Two-Piece Cans, Subject to NSPS in 1985 7-30
7-23 Energy Requirements for Emission Control Options,
Three-Piece Can Sheet Coating, Subject to NSPS in
1985 7-31
7-24 Energy Requirements for Emission Control Options,
Three-Piece Can Inside Spray, Subject to NSPS in
1985 7-32
7-25 Energy Requirements for Emission Control Options,
Sheet Coating, Alunimum and Steel Ends, Subject to NSPS
in 1981 7-33
7-26 Beverage Can Surface Coating: Net Reductions in Energy
Requirements from Regulatory Alternatives 7-34
8-1 Major U.S. Merchant Producers of Metal Cans, 1975 8-4
8-2 Annual Shipments of Metal Cans—Value and Quantity,
1972-1979 8-6
8-3 Metal Can Shipments 8-8
8-4 Beverage Can Shipments 8-9
8-5 Evaluated Options for Control of VOC Emissions from Coating
Operations at Integrated Two-Piece Can-Forming Lines
(Aluminum and Steel) 8-11
8-6 Evaluated Options for Control of VOC Emissions from Coating
of Steel Sheet for Three-Piece Cans 8-12
8-7 Evaluated Options for Control of VOC Emissions from Coating
Operations at Three-Piece Can Forming Lines, Inside
Spray 8-13
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LIST OF TABLES (continued)
Table
8-8
8-9
8-10
8-11
8-12
8-13
8-14
8-15
8-16
8-17
8-18
8-19
8-20
8-21
8-22
8-23
8-24
8-25
Evaluated Options for Control of VOC Emissions from
Coating of Steel- and Aluminum-Ends for Three-Piece
Cans
Page
8-14
Cost Data, Two-Piece Aluminum- and Steel-Integrated
Facility 8-16
Cost Data, Three-Piece Steel-Sheet Coating Facility 8-17
Cost Data, Three-Piece Steel Inside Spray 8-18
Cost Data, Sheet Coating, Steel and Aluminum Ends 8-19
Sources of Cost Data for Coating and Emission Control
Systems
8-21
Schedule of Coating Material Costs 8-22
Parameters Used to Derive Operating Costs 8-23
Capital and Operating Costs Required to Meet Growth in
Demand for Two-Piece Beverage Cans 8-24
Definitions 8-30
Cost Data for Two-Piece Aluminum or Steel Integrated
Facilities 8-36
Cost Data for Three-Piece Sheet Coating Facilities 8-37
. . . 8-38
Cost Data for Three-Piece Can-Forming Facilities, Inside
Spray
Cost Data for Steel- and Aluminum-End Sheet Coating
Facilities 8-39
Present Worth Costs and Rankings for Two-Piece Steel
or Aluminum Integrated Facilities 8-41
Present Worth Costs and Rankings for Three-Piece
Sheet Coating Facilities 8-42
Present Worth Costs and Rankings for Three-Piece Can
Forming Facilities, Inside Spray 8-43
Present Worth Costs and Rankings for Steel- and
Aluminum-End Sheet Coating Facilities ... 8-44
XI
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LIST OF TABLES (continued)
Table Page
8-26 Price Impacts of Regulatory Alternatives on Two-Piece
Aluminum or Steel Integrated Facilities 8-46
8-27 Return on Investment Impacts of Regulatory Alter-
natives on Two-Piece Aluminum or Steel Integrated
Facilities 8-47
8-28 Incremental Capital Requirements of Regulatory Alter-
natives for Two-Piece Aluminum or Steel Integrated
Facilities 8-48
8-29 Price Impacts of Regulatory Alternatives on Three-
Piece Sheet Coating Facilities 8-49
8-30 Return on Investment Impacts of Regulatory Alternatives
on Three-Piece Sheet Coating Facilities 8-50
8-31 Incremental Capital Requirements of Regulatory Alter-
natives for Three-Piece Sheet Coating Facilities 8-51
8-32 Price Impacts of Regulatory Alternatives on Three-
Piece Can Forming Facilities 8-53
8-33 Return on Investment Impacts of Regulatory Alternatives
on Three-Piece Can Forming Facilities 8-54
8-34 Incremental Capital Requirements of Regulatory Alternatives
for Three-Piece Can Forming Facilities 8-55
8-35 Price Impacts of Regulatory Alternatives on Steel- and
Aluminum-End Sheet Coating Facilities 8-56
8-36 Return on Investment of Regulatory Alternatives on Steel-
and Aluminum-End Sheet Coating Facilities 8-57
8-37 Incremental Capital Requirements of Regulatory Alternatives
on Steel- and Aluminum-End Sheet Coating Facilities 8-58
8-38 Incremental Annualized Cost of Compliance with
Regulatory Alternatives 8-60
8-39 Return on Investment Impacts of Regulatory Alternatives
on Small-Scale Two-Piece Aluminum- and Steel-Integrated
Facilities 8-63
xn
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Figure
LIST OF FIGURES
3-1 Process Diagram--Two-Piece Can Fabricating and Coating
Operation 3-6
3-2 Process Diagram—Three-Piece Steel Can Fabricating and
Coating Operation 3-9
8-1
Geographical Distribution of Can Manufacturing Plants 8-2
xm
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1. SUMMARY
1.1 REGULATORY ALTERNATIVES
Section 111 of the Clean Air Act (42 U.S.C. 7411) as amended directs
the Administrator to establish standards of performance for any category of
new stationary sources of air pollution that "causes or contributes signifi-
cantly to air pollution which may reasonably be anticipated to endanger
public health and welfare." The beverage can surface coating industry has
been determined to fall into this classification and standards of performance
have been developed for volatile organic compounds (VOC).
Three regulatory alternatives are considered. The first involves no
additional regulation. Emissions from new, modified, or reconstructed
beverage plants would be governed by State regulations.
The second regulatory alternative would limit emissions to those that
would result from the use of best available waterborne coatings. These
emission limitations may also be met through the use of solvent-borne
coatings and emission control systems.
The third regulatory alternative is the same as the second except that
no-varnish inks or radiation-curable coatings are used in applying the
lithography and or overvarnish coats.
1.2 ENVIRONMENTAL IMPACT
Under Regulatory Alternative I, there would be no environmental impact,
either beneficial or adverse. VOC emissions under Regulatory Alternative
II would be reduced by 7,500 Mg per year in 1985 and under Regulatory
Alternative III by 8,900 Mg. No adverse economic impacts would result from
any of the regulatory alternatives. A matrix summarizing the environmental
and economic imports is presented in Table 1-1.
1-1
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1.3 ECONOMIC IMPACT
No adverse economic impacts on the beverage can industry are likely to
occur under any of the regulatory alternatives. Control options that are
equal to or less than the cost of complying with the emission limitations
specified by SIPs are available for each production facility. Some control
options, if used, would impact the affected facilities.
Under Regulatory Alternative II, the use of solvent-borne coatings and
an emission control system would result in price increases of less than 2
percent for two-piece beverage can production facilities. An additional
capital outlay of up to 5 percent would be required, depending on the size
of the facility. Regulatory Alternative III would have no impact on two-
piece lines even if solvent-borne coatings were used.
1-3
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2. INTRODUCTION
2.1 BACKGROUND AND AUTHORITY FOR STANDARDS
Before standards of performance are proposed as a Federal regulation,
air pollution control methods available to the affected industry and the
associated costs of installing and maintaining the control equipment are
examined in detail. Various levels of control based on different technolo-
gies and degrees of efficiency are expressed as regulatory alternatives.
Each of these alternatives is studied by EPA as a prospective basis for a
standard. The alternatives are investigated in terms of their impacts on
the economics and well-being of the industry, the impacts on the national
economy, and the impacts on the environment. This document summarizes the
information obtained through these studies so that interested persons will
be able to see the information considered by EPA in the development of the
proposed standard.
Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411) as amended, herein-
after referred to as the Act. Section 111 directs the Administrator to
establish standards of performance for any category of new stationary
source of air pollution which ". . . causes, or contributes significantly
to air pollution which may reasonably be anticipated to endanger public
health or welfare."
The Act requires that standards of performance for stationary sources
reflect ". . . the degree of emission reduction achievable which (taking
into consideration the cost of achieving such emission reduction, and any
nonair quality health and environmental impact and energy requirements) the
Administrator determines has been adequately demonstrated for that category
of sources." The standards apply only to stationary sources, the construc-
tion or modification of which commences after regulations are proposed by
publication in the Federal Register.
2-1
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The 1977 amendments to the Act altered or added numerous provisions
that apply to the process of establishing standards of performance.
1. EPA is required to list the categories of major stationary sources
that have not already been listed and regulated under standards of perform-
ance. Regulations must be promulgated for these new categories on the
following schedule:
a. 25 percent of the listed categories by August 7, 1980.
b. 75 percent of the listed categories by August 7, 1981.
c. 100 percent of the listed categories by August 7, 1982.
A governor of a State may apply to the Administrator to add a category not
on the list or may apply to the Administrator to have a standard of perform-
ance revised.
2. EPA is required to review the standards of performance every 4
years and, if appropriate, revise them.
3. EPA is authorized to promulgate a standard based on design, equip-
ment, work practice, or operational procedures when a standard based on
emission levels is not feasible.
4. The term "standards of performance" is redefined, and a new term
"technological system of continuous emission reduction" is defined. The new
definitions clarify that the control system must be continuous and may
include a low- or non-polluting process or operation.
5. The time between the proposal and promulgation of a standard under
section 111 of the Act may be extended to 6 months.
Standards of performance, by themselves, do not guarantee protection
of health or welfare because they are not designed to achieve any specific
air quality levels. Rather, they are designed to reflect the degree of
emission limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction, taking
into consideration the cost of achieving such emission reduction, any
non-air-quality health and environmental impacts, and energy requirements.
Congress had several reasons for including these requirements. First,
standards with a degree of uniformity are needed to avoid situations where
some States may attract industries by relaxing standards relative to other
States. Second, stringent standards enhance the potential for long-term
growth. Third, stringent standards may help achieve long-term cost savings
2-2
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by avoiding the need for more expensive retrofitting when pollution ceilings
may be reduced in the future. Fourth, certain types of standards for coal-
burning sources can adversely affect the coal market by driving up the
price of low-sulfur coal or effectively excluding certain coals from the
reserve base because their untreated pollution potentials are high. Con-
gress does not intend that new source performance standards contribute to
these problems. Fifth, the standard-setting process should create incen-
tives for improved technology.
Promulgation of standards of performance does not prevent State or
local agencies from adopting more stringent emission limitations for the
same sources. States are free under section 116 of the Act to establish
even more stringent emission limits than those established under Section 111
or those necessary to attain or maintain the National Ambient Air Quality
Standards (NAAQS) under Section 110. Thus, new sources may in some cases
be subject to limitations more stringent than standards of performance
under Section 111, and prospective owners and operators of new sources
should be aware of this possibility in planning for such facilities.
A similar situation may arise when a major emitting facility is to be
constructed in a geographic area that falls under the prevention of signif-
icant deterioration of air quality provisions of Part C of the Act. These
provisions require, among other things, that major emitting facilities to
be constructed in such areas are to be subject to best available control
technology. The term Best Available Control Technology (BACT), as defined
in the Act, means
... an emission limitation based on the maximum degree of
reduction of each pollutant subject to regulation under this Act
emitted from, or which results from, any major emitting facility,
which the permitting authority, on a case-by-case basis, taking
into account energy, environmental, and economic impacts and
other costs, determines is achievable for such facility through
application of production processes and available methods, systems,
and techniques, including fuel cleaning or treatment or innovative
fuel combustion techniques for control of each such pollutant.
In no event shall application of "best available control technol-
ogy" result in emissions of any pollutants which will exceed the
emissions allowed by any applicable standard established pursuant
to sections 111 or 112 of this Act. (Section 169(3))
2-3
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Although standards of performance are normally structured in terms of
numerical emission limits where feasible, alternative approaches are some-
times necessary. In some cases physical measurement of emissions from a
new source may be impractical or exorbitantly expensive. Section lll(h)
provides that the Administrator may promulgate a design or equipment stand-
ard in those cases where it is not feasible to prescribe or enforce a
standard of performance. For example, emissions of hydrocarbons from
storage vessels for petroleum liquids are greatest during tank filling.
The nature of the emissions, high concentrations for short periods during
filling and low concentrations for longer periods during storage, and the
configuration of storage tanks make direct emission measurement impractical.
Therefore, a more practical approach to standards of performance for storage
vessels has been equipment specification.
In addition, Section lll(j) authorizes the Administrator to grant
waivers of compliance to permit a source to use innovative continuous
emission control technology. In order to grant the waiver, the Administra-
tor must find: (1) a substantial likelihood that the technology will
produce greater emission reductions than the standards require or an equiva-
lent reduction at lower economic energy or environmental cost; (2) the
proposed system has not been adequately demonstrated; (3) the technology
will not cause or contribute to an unreasonable risk to the public health,
welfare, or safety; (4) the governor of the State where the source is
located consents; and (5) the waiver will not prevent the attainment or
maintenance of any ambient standard. A waiver may have conditions attached
to assure the source will not prevent attainment of any NAAQS. Any such
condition will have the force of a performance standard. Finally, waivers
have definite end dates and may be terminated earlier if the conditions are
not met or if the system fails to perform as expected. In such a case, the
source may be given up to 3 years to meet the standards with a mandatory
progress schedule.
2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES
Section 111 of the Act directs the Adminstrator to list categories of
stationary sources. The Administrator "... shall include a category of
sources in such list if in his judgment it causes, or contributes signifi-
2-4
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cantly to, air pollution which may reasonably be anticipated to endanger
public health or welfare." Proposal and promulgation of standards of
performance are to follow.
Since passage of the Clean Air Amendments of 1970, considerable atten-
tion has been given to the development of a system for assigning priorities
to various source categories. The approach specifies areas of interest by
considering the broad strategy of the Agency for implementing the Clean Air
Act. Often, these "areas" are actually pollutants emitted by stationary
sources. Source categories that emit these pollutants are evaluated and
ranked by a process involving such factors as (1) the level of emission
control (if any) already required by State regulations, (2) estimated
levels of control that might be required from standards of performance for
the source category, (3) projections of growth and replacement of existing
facilities for the source category, and (4) the estimated incremental
amount of air pollution that could be prevented in a preselected future
year by standards of performance for the source category. Sources for
which new source performance standards were promulgated or under develop-
ment during 1977, or earlier, were selected on these criteria.
The Act amendments of August 1977 establish specific criteria to be
used in determining priorities for all major source categories not yet
listed by EPA. These are (1) the quantity of air pollutant emissions that
each such category will emit, or will be designed to emit; (2) the extent
to which each such pollutant may reasonably be anticipated to endanger
public health or welfare; and (3) the mobility and competitive nature of
each such category of sources and the consequent need for nationally appli-
cable new source standards of performance.
The Administrator is to promulgate standards for these categories
according to the schedule referred to earlier.
In some cases it may not be feasible immediately to develop a standard
for a source category with a high priority. This might happen when a
program of research is needed to develop control techniques or because
techniques for sampling and measuring emissions may require refinement. In
the developing of standards, differences in the time required to complete
the necessary investigation for different source categories must also be
considered. For example, substantially more time may be necessary if
2-5
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numerous pollutants must be investigated from a single source category.
Further, even late in the development process the schedule for completion
of a standard may change. For example, inablility to obtain emission data
from well-controlled sources in time to pursue the development process in a
systematic fashion may force a change in scheduling. Nevertheless, priority
ranking is, and will continue to be, used to establish the order in which
projects are initiated and resources assigned.
After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be deter-
mined. A source category may have several facilities that cause air pollu-
tion, and emissions from some of these facilities may vary from insignificant
to very expensive to control. Economic studies of the source category and
of applicable control technology may show that air pollution control is
better served by applying standards to the more severe pollution sources.
For this reason, and because there is no adequately demonstrated system for
controlling emissions from certain facilities, standards often do not apply
to all facilities at a source. For the same reasons, the standards may not
apply to all air pollutants emitted. Thus, although a source category may
be selected to be covered by a standard of performance, not all pollutants
or facilities within that source category may be covered by the standards.
2.3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
Standards of performance must (1) realistically reflect best demon-
strated control practice; (2) adequately consider the cost, the non-air-
quality health and environmental impacts, and the energy requirements of
such control; (3) be applicable to existing sources that are modified or
reconstructed as well as new installations; and (4) meet these conditions
for all variations of operating conditions being considered anywhere in the
country.
The objective of a program for developing standards is to identify the
best technological system of continuous emission reduction that has been
adequately demonstrated. The standard-setting process involves three
principal phases of activity: (1) information gathering, (2) analysis of
the information, and (3) development of the standard of performance.
2-6
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During the information-gathering phase, industries are queried through
a telephone survey, letters of inquiry, and plant visits by EPA representa-
tives. Information is also gathered from many other sources, and a litera-
ture search is conducted. From the knowledge acquired about the industry,
EPA selects certain plants at which emission tests are conducted to provide
reliable data that characterize the pollutant emissions from well-controlled
existing facilities.
In the second phase of a project, the information about the industry
and the pollutants emitted is used in analytical studies. Hypothetical
"model plants" are defined to provide a common basis for analysis. The
model plant definitions, national pollutant emission data, and existing
State regulations governing emissions from the source category are then
used in establishing "regulatory alternatives." These regulatory alterna-
tives are essentially different levels of emission control.
EPA conducts studies to determine the impact of each regulatory alter-
native on the economics of the industry and on the national economy, on the
environment, and on energy consumption. From several possibly applicable
alternatives, EPA selects the single most plausible regulatory alternative
as the basis for a standard of performance for the source category under
study.
In the third phase of a project, the selected regulatory alternative
is translated into a standard of performance, which, in turn, is written in
the form of a Federal regulation. The Federal regulation, when applied to
newly constructed plants, will limit emissions to the levels indicated in
the selected regulatory alternative.
As early as is practical in each standard-setting project, EPA repre-
sentatives discuss the possibilities of a standard and the form it might
take with members of the National Air Pollution Control Techniques Advisory
Committee. Industry representatives and other interested parties also
participate in these meetings.
The information acquired in the project is summarized in the Background
Information Document (BID). The BID, the standard, and a preamble explain-
ing the standard are widely circulated to the industry being considered for
control, environmental groups, other government agencies, and offices
within EPA. Through this extensive review process, the points of view of
2-7
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expert reviewers are taken into consideration as changes are made to the
documentation.
A "proposal package" is assembled and sent through the offices of EPA
Assistant Administrators for concurrence before the proposed standard is
officially endorsed by the EPA Administrator. After being approved by the
EPA Administrator, the preamble and the proposed regulation are published
in the Federal Register.
As a part of the Federal Register announcement of the proposed regula-
tion, the public is invited to participate in the standard-setting process.
EPA invites written comments on the proposal and also holds a public hearing
to discuss the proposed standard with interested parties. All public
comments are summarized and incorporated into a second volume of the BID.
All information reviewed and generated in studies in support of the standard
of performance is available to the public in a "docket" on file in Washington,
D.C.
Comments from the public are evaluated, and the standard of performance
may be altered in response to the comments.
The significant comments and EPA's position on the issues raised are
included in the "preamble" of a "promulgation package," which also contains
the draft of the final regulation. The regulation is then subjected to
another round of review and refinement until it is approved by the EPA
Administrator. After the Administrator signs the regulation, it is pub-
lished as a "final rule" in the Federal Register.
2.4 CONSIDERATION OF COSTS
Section 317 of the Act requires an economic impact assessment with
respect to any standard of performance established under Section 111 of the
Act. The assessment is required to contain an analysis of (1) the costs of
compliance with the regulation, including the extent to which the cost of
compliance varies depending on the effective date of the regulation and the
development of less expensive or more efficient methods of compliance;
(2) the potential inflationary or recessionary effects of the regulation;
(3) the effects the regulation might have on small business with respect to
competition; (4) the effects of the regulation on consumer costs; and
(5) the effects of the regulation on energy use. Section 317 also requires
that the economic impact assessment be as extensive as practicable.
2-8
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The economic impact of a proposed standard upon an industry is usually
addressed both in absolute terms and in terms of the control costs that
would be incurred as a result of compliance with typical, existing State
control regulations. An incremental approach is necessary because both new
and existing plants would be required to comply with State regulations in
the absence of a Federal standard of performance. This approach requires a
detailed analysis of the economic impact from the cost differential that
would exist between a proposed standard of performance and the typical
State standard.
Air pollutant emissions may cause water pollution problems, and captured
potential air pollutants may pose a solid waste disposal problem. The
total environmental impact of an emission source must, therefore, be analyzed
and the costs determined whenever possible.
A thorough study of the profitability and price-setting mechanisms of
the industry is essential to the analysis so that an accurate estimate of
potential adverse economic impacts can be made for proposed standards. It
is also essential to know the capital requirements for pollution control
systems already placed on plants so that the additional capital requirements
necessitated by these Federal standards can be placed in proper perspective.
Finally, it is necessary to assess the availability of capital to provide
the additional control equipment needed to meet the standards of performance.
2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS
Section 102(2)(C) of the National Environmental Policy Act (NEPA) of
1969 requires Federal agencies to prepare detailed environmental impact
statements on proposals for legislation and other major Federal actions
significantly affecting the quality of the human environment. The objective
of NEPA is to build into the decisionmaking process of Federal agencies a
careful consideration of all environmental aspects of proposed actions.
In a number of legal challenges to standards of performance for various
industries, the United States Court of Appeals for the District of Columbia
Circuit has held that environmental impact statements need not be prepared
by the Agency for proposed actions under Section 111 of the Clean Air Act.
Essentially, the Court of Appeals has determined that the best system of
emission reduction requires the Administrator to take into account counter-
2-9
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productive environmental effects of a proposed standard, as well as economic
costs to the industry. On this basis, therefore, the Court established a
narrow exemption from NEPA for EPA determination under Section 111.
In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to Section 7(c)(l), "No action taken under the Clean Air Act
shall be deemed a major Federal action significantly affecting the quality
of the human environment within the meaning of the National Environmental
Policy Act of 1969." (15 U.S.C. 793(c)(l))
Nevertheless, the Agency has concluded that the preparation of environ-
mental impact statements could have beneficial effects on certain regulatory
actions. Consequently, although not legally required to do so by Sec-
tion 102(2)(C) of NEPA, EPA has adopted a policy requiring that environmen-
tal impact statements be prepared for various regulatory actions, including
standards of performance developed under Section 111 of the Act. This
voluntary preparation of environmental impact statements, however, in no
way legally subjects the Agency to NEPA requirements.
To implement this policy, a separate section in this document is
devoted solely to an analysis of the potential environmental impacts associ-
ated with the proposed standards. Both adverse and beneficial impacts in
such areas as air and water pollution, increased solid waste disposal, and
increased energy consumption are discussed.
2.6 IMPACT ON EXISTING SOURCES
Section 111 of the Act defines a new source as ". . . any stationary
source, the construction or modification of which is commenced ..." after
the proposed standards are published. An existing source is redefined as a
new source if "modified" or "reconstructed" as defined in amendments to the
general provisions of Subpart A of 40 CFR Part 60, which were promulgated
in the Federal Register on December 16, 1975 (40 FR 58416).
Promulgation of a standard of performance requires States to establish
standards of performance for existing sources in the same industry under
Section 111 (d) of the Act if the standard for new sources limits emissions
of a designated pollutant (i.e., a pollutant for which air quality criteria
2-10
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have not been issued under Section 108 or which has not been listed as a
hazardous pollutant under Section 112). If a State does not act, EPA must
establish such standards. General provisions outlining procedures for
control of existing sources under Section lll(d) were promulgated on Novem-
ber 17, 1975, as Subpart B of 40 CFR Part 60 (40 FR 53340).
2.7 REVISION OF STANDARDS OF PERFORMANCE
Congress was aware that the level of air pollution control achievable
by any industry may improve with technological advances. Accordingly,
Section 111 of the Act provides that the Administrator ". . . shall, at
least every 4 years, review and, if appropriate, revise ..." the standards.
Revisions are ,made to assure that the standards continue to reflect the
best systems that become available in the future. Such revisions will not
be retroactive, but will apply to stationary sources constructed or modified
after the proposal of the revised standards.
2-11
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3. THE BEVERAGE CAN COATING INDUSTRY
3.1 GENERAL
The metal can industry is defined in the Standard Industrial Classi-
fication Manual under SIC 3411 as establishments primarily engaged in manu-
facturing metal cans from purchased materials. Beverage cans are included
in this category. As used in this report the term "beverage cans" includes
two-piece and three-piece metal containers for soft drinks and beer (includ-
ing malt liquors).
According to the Can Manufacturers Institute, in 1976 approximately
100 companies with almost 500 plants at 300 locations in the United States
manufactured metal cans of all types.1
In 1978 there were 48,500 production workers in the can industry.
This represented a 19 percent decrease from 1973, when 60,200 production
workers were employed in the industry. Approximately half of these workers
were in the beverage can sector. Total industry employment in 1978 was
58,500, compared to 69,800 workers in 1973. This gradual reduction in
employment can be attributed to the closing of marginal facilities and the
installation of more efficient equipment, especially in beverage can manu-
facture, where relatively labor-intensive facilities for three-piece can
lines have been giving way to more productive two-piece can lines. Approx-
imately half of the industry work force is estimated to be in the beverage
can sector.
Beverage cans are made in two-piece and three-piece styles. Two-piece
beverage can bodies are made of steel or aluminum. The top for two-piece
beverage cans is made of aluminum regardless of the body material. The
three-piece beverage can is similar to that used in the food industry and,
except for the top, is made of steel. The top is made of aluminum to
permit easy pull-tab opening.
3-1
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A protective coating is applied to the inside of both two- and three-
piece beverage cans to isolate the contents from the metal can body. A
protective coating may or may not be applied to the exterior surface prior
to lithography. In some cases an overvarnish is applied to protect the
lithography, to improve appearance, and to increase mobility during filling
operations.
In 1978 over 54 billion beverage cans were produced. Use, type, and
construction materials of these cans are shown in Table 3-1.2
3.2 PROCESSES OR FACILITIES AND THEIR EMISSIONS
A two-piece beverage can is made by forming the body and bottom end in
one piece by the draw and wall-iron method (DWI). The DWI method uses
coiled stock, which is cupped in a press and the walls of the cup drawn or
extended to the desired container height. Such cans have considerably
thicker bottoms than side walls. An aluminum top is attached after the can
is filled.
A three-piece beverage can is made of two end pieces and a rectangular
sheet (body blank), to which base coats, lithography, and overvarnish have
been applied. The precoated metal sheet is slit to body size and rolled or
formed into a tubular body and soldered, welded or cement sealed at the
seam. An inside spray is applied and one end is attached to the body by
roll seaming. The other end is attached during packaging of the product.
The materials used in fabricating two-piece beverage cans are aluminum
and malleable steel. Materials used in fabricating three-piece cans are
tinplate and tin-free steel (TFS). These materials range in thickness from
0.006 to 0.15 inch. Sheet sizes vary, depending on the can style. Twelve-
ounce beverage cans are usually made from steel sheets of 30-by-32 inches
to 37-by-42 inches. A typical sheet yields 35 12-ounce can bodies.
3.2.1 Two-Piece Beverage Can Coating
Two-piece beverage cans bodies are coated after fabrication. The
coatings used depend on end use or customer specifications. Two-piece
beverage cans consist of a steel or aluminum body and an aluminum end
(top). Four separate coats may be applied to the can body: exterior base
coat, lithography/overvarnish coat, inside spray coat, and bottom coat.
3-2
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TABLE 3-1. NUMBER OF BEVERAGE CANS BY
CONSTRUCTION PROCESS, 1978
Number (billions)
Percent of total
Beer
Three piece
Two piece
Steel
Aluminum
Soft drinks
Three piece
Two piece
Steel
Aluminum
Total
Three piece
Two piece
Steel
Aluminum
28.9
2.5
26.4
5.8
20.6
25.5
12.0
13.5
4.0
9.5
54.4
14.5
39.9
9.8
30.1
53.2
4.7
48.
10.
37.8
46.8
22.0
24.9
7.4
17.5
100
26.6
73.4
18.1
55.3
3-3
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The aluminum ends are formed from precoated aluminum coils or sheets with
only the end-sealing compound being applied at the beverage can plant.
The process for coating two-piece cans begins after the can has been
formed, except for necking and flanging operations. The coating process is
in line with the fabrication process. Prior to coating, the cans are
washed to remove oil and dirt. Aluminum cans are usually pretreated with
an agent to improve paint bonding and corrosion resistance. The cans
proceed to the coating area at rates in the range of 600 to 800 cans per
minute per line. In 1978 one vender began marketing modular two-piece
beverage can lines with a 500 can-per-minute capacity. One such line is
scheduled to begin operation in the United States for a major canmaker.
While no other modular lines are on order, the vendor reports that negoti-
ations are under way for one other domestic line.3 4
After cleaning and treatment, an exterior base coat may be applied
using a mandrel coating system. The coated cans usually proceed on a pin
conveyor to an oven that bakes the coating. Upon leaving the oven, the
cans are conveyed to printing and overvarnish machines. Mandrel coatings
are used to apply up to four colors followed by application of an over-
varnish if desired. Recently, inks requiring no overvarnish (no-var inks)
have been accepted by some companies. Cans are then oven or radiation
cured.
The cans proceed in the process lines to the inside spray application
station. Inside body spray is applied by spray nozzles as each can travels
around a turret. The coated cans are then oven cured, leak tested, necked
and flanged, and palletized for shipment.
Can bottoms are roll or spray coated as part of one of the three
coating operations, i.e., base coat, lithography/overvarnish, or inside
spray. The entire bottom of steel two-piece cans is coated; only the rim
of aluminum cans is coated.
The aluminum end of a two-piece can is stamped from precoated aluminum
coil or sheet, after which an end-sealing compound is applied. The end is
attached to the can after filling. The only emissions attributable to the
two-piece can line are from the application of end-sealing compound.
Except for end-sealing operation, emissions occur at the coater,
flashoff area (the area between the coater and cure oven), and cure oven
for each of the coating operations described above. For end-sealing com-
3-4
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pound, emissions occur at the applicator and the area in which they are air
dried. Distribution of total plant emissions for a plant using waterborne
coatings is estimated to be:5
Percent of total emissions
Ends made
at plant
10
4
15
1
55
15
Ends not made
at plant
12
5
18
1
64
Operation
Exterior base coat
Lithography
Overvarnish
Bottom coat
Inside spray
End sealing
A process flow sheet (Figure 3-1) illustrates the steps in the manu-
facture of a two-piece beverage can.
3.2.2 Three-Piece Beverage Can Coating
Can stock, ready for use, is received as coils or palletized bundles
of sheets. If stock is in coil form, it is cut into sheets before coating.
Three separate coats are applied using roll coaters: an interior base
coat, an exterior base coat, and a lithography/overvarnish coat.
The interior base coat is usually applied first. This coat provides
protection for both the contents of the can and the can itself. The coated
sheet is then conveyed to a wicket-type oven where the coat is cured. The
wickets travelling on the oven conveyor hold the sheets in an upright
position as they are conveyed through the oven. The oven has a cooling
zone in which the sheets cool to near room temperature. As they emerge
from the oven the sheets are stacked and transported to the next operation.
The exterior base coat is applied to the opposite side of the sheet, using
a similar procedure.
After the exterior and interior base coats are applied, the sheet is
ready for lithography and overvarnish. These coatings are applied in one
continuous operation. Litho-offset with either dry or wet plates is normally
used. The printed sheets are then usually roll-coated with an overvarnish
coating over the wet, uncured ink. Use of specially formulated inks may
obviate the requirement for application of overvarnish. After application,
the lithography/overvarnish coat is heat cured by passing the sheets through
a wicket oven, or radiation cured.
3-5
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Emissions from base coating operations occur at the coater, the flash-
off area, and the cure oven. Emissions from the flashoff area and cure
oven emanate from the coating applied to the can; emissions from the coater
include VOC from the coating and from the solvent that is used to continu-
ously clean the coater rolls when solvent-borne base coatings are used.
The bodymaking process forms beverage cans from the coated sheets.
Sheets are slit into body-size blanks and fed into a bodymaker, which forms
the body blank into a cylinder. The seam is welded, cemented, or soldered,
and usually sprayed on the inside and outside of the seam with an air-dry
lacquer to protect the exposed metal. Emissions from seam coating are
relatively minor, representing from 2 to 4 percent of total emissions.6 7
The cylinders are flanged to provide proper can end assembly.
The interior of the cylinder is sprayed with a coating to ensure a
protective lining between the beverage and the can. Emission points from
three-piece beverage can inside-spraying operations are the coater, flash-
off area, and cure oven.
Three-piece cans usually have one end attached at this point. The
cans are tested for leakage, then stacked and palletized for shipment.
Bottoms of three-piece cans are made of steel; tops or tabbed ends are made
of aluminum. Can ends are stamped from precoated sheets or coils in a
reciprocating press and the perimeter coated with a rubber end-sealing
compound that functions as a gasket when the end is attached to the can.
End-sealing compounds for beverage cans in use today are almost exclusively
solvent-based compounds that are air dried after application.
Steel ends are formed from sheets to which interior and exterior coats
have been applied. After forming, an end-sealing compound is applied.
Aluminum ends for three-piece cans are fabricated in the same manner as
those for two-piece cans.
Emissions from one three-piece beverage can plant using solvent-borne
coatings are reported as being distributed among coating operations as
follows.6
3-7
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Ends made
at plant
24
24
15
15
2
20
Ends not made
at plant
30
30
19
19
2
-
Percent of total emissions
Operation
Exterior base coat
Interior base coat
Overvarnish
Inside spray
Side-seam spray
End-sealing compound
Emissions from cleaning operations are included in these figures.
Another plant using solvent-borne coatings reports the following
distribution of emissions among operations.7
Percent of total emissions
Er
Operation
Exterior and interior base coat
Overvarnish
Inside spray
Cleanup solvents
End sealing
No data were available for plants using waterborne coatings.
A process flow sheet (Figure 3-2) illustrates the steps in the manu-
facture of a three-piece beverage can. The major coatings for a three-piece
beverage can considered in this study are the interior coat, the exterior
base coat, the Overvarnish, the inside spray, and end-sealing application.
Emissions from the process are dependent on the solvent and solids content
of the coating used and the thickness of each coating applied.
3.3 BASELINE EMISSIONS
The can manufacturing industry today uses both waterborne and solvent-
borne coatings. Cure oven and other exhaust from solvent-borne coatings
may or may not be captured and incinerated, depending on the emission
limitations imposed by the applicable State Implementation Plan (SIP).
Ends made
at plant
17
4
32
35
12
Ends not made
at plant
19
5
36
40
-
3-8
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3-9
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Upon completion of the current round of SIP revisions, can plants located
in oxidant nonattainment areas will be required to meet the regulations
based on emission limitations recommended in the control technique guide-
lines (CTG).8 To meet these limitations, can plants using solvent-borne
coatings would be required to capture and incinerate at least a portion if
not all of the VOC emissions, or convert to waterborne coatings.
Emission limitations for beverage can surface coating recommended in
the CTG , which will be the baseline emissions for subsequent analyses, are
shown in Table 3-2.
Five general base cases, covering eleven coating operations, are used
to describe beverage can surface coating. These base cases and the coating
operations involved in each are presented below:
Two-piece steel and aluminum beverage cans
Exterior base coat
Lithography/overvarnish
Inside spray
Coating of steel stock for three-piece beverage cans
Exterior base coat
Interior base coat
Lithography/overvarnish
Forming of three-piece beverage cans
Inside spray coat
Steel ends for three-piece beverage cans
Exterior coat
Interior coat
End-seal ing application
Aluminum ends for three-piece and two-piece beverage cans
Exterior coat*
Interior coat*
End-sealing application.
Inside coatings are applied to prevent damage to the can and its con-
tents by corrosion. Exterior coatings are applied to protect the exterior
*Applicable only when ends are made from aluminum sheets.
3-10
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TABLE 3-2. CTG-RECOMMENDED EMISSION LIMITATIONS
FOR CAN SURFACE COATINGS8
Recommended limitation
Affected facility
kg per litre
of coating
(minus water)
Ib per gal
of coating
(minus water)
Sheet base coat (exterior and
interior) and overvarnish;
two-piece can exterior
(base coat and overvarnish)
Two- and three-piece can interior
body spray, two-piece can
exterior end (spray or roll
coat)
Three-piece can side-seam spray
End-sealing compound
0.34
0.51
0.66
0.44
2.8
4.2
5.5
3.7
3-11
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of the can from corrosion, and to serve as a base for lithography. Over-
varnish is applied following lithography to protect the design from abra-
sion and to reduce friction for automated can-handling equipment. Tradi-
tionally, coating materials have been resins (alkyd, epoxy, acrylic, or
polyester) that contain various additives and sometimes pigments or color-
ants, dissolved or dispersed in vehicles consisting of organic solvents.
In the manufacture of two-piece cans, the coatings are applied to
individual can bodies after they have been formed by the drawing and iron-
ing process from uncoated stock. Coatings are oven dried and baked.
Exterior coatings are applied to two-piece can bodies by mandrel coating,
and interior coatings are applied by spray coating. In the manufacture of
bodies for three-piece cans, coatings are applied to flat sheets of can
body material by roller coating. The coatings are oven dried and baked.
Sheets are then slit into blanks from which the can bodies are formed and
inside spray applied.
Steel ends are stamped from precoated coil or roll-coated sheet, and
end-sealing compound is applied. Only sheet coating of end steel stock
will be discussed in this report, as coil coating is covered by another
standard. Depending on customers' requirements, one or more coatings may
be omitted in any particular instance. In general, when more than one
coating is applied to a can body or sheet, each coating is oven dried and
baked before the next coating is applied. Application of two interior
spray coats to steel two-piece cans at a recently constructed plant is
accomplished without an intermediate curing step.9
Aluminum ends are required for all beverage cans. These ends are
manufactured from precoated sheets or coils. When aluminum sheet is the
raw material, ends are usually made in a three-piece can sheet-coating
plant. Exterior and interior coats are applied, the ends stamped from the
coated sheet, and end-sealing compound applied. Base coaters used for
coating steel sheets are also used for coating the aluminum end sheet
stock. When sheet stock is the raw material, aluminum ends are usually
made at a merchant facility, for shipment directly to brewery or soft drink
filling lines. In some instances, generally at captive two-piece beverage
can plants, aluminum ends are made from precoated aluminum coil. A three-
3-12
-------
piece can plant visited during the preparation of this document fabricates
aluminum ends from precoated aluminum strip;6 a two-piece can plant that
was visited purchases aluminum ends from other sources.10
With the exception of end-sealing operations, each of the coating
operations is comprised of three emission points: coating application,
flashoff area, and cure oven. Each end-sealing operation is comprised of
two emission points, sealing application, and an area in which the ends are
air dried.
The total VOC emitted per can or can end for each coating is a func-
tion of the coating thickness and the solvent and solids contents of the
coating. The distribution of the total emissions among the three emission
sources depends upon coating thickness, solvent content of the coating,
type of solvent, ambient temperature, time and distance between the coater
and the oven, and ventilation at the coater and between the coater and the
oven. For each model case, total emissions per 1,000 cans or ends, are
presented, based on the operating factors selected for each case.
When waterborne or low-solvent coatings are used without add-on con-
trols, the distribution of emissions among the coater, flashoff area, and
cure oven has no impact on total emissions from each coating operation
because VOC from all emissions sources are discharged to the atmosphere.
Distribution of emissions does have an impact on ventilating air required
to maintain VOC concentrations at the work area at or below those specified
by OSHA. When solvent-borne coatings and add-on emission control systems
are used, distribution of emissions has an impact not only on ventilating
air requirements, but also on requirements for capture and control of VOC
emissions. Emission distributions used in base case and subsequent calcu-
lations are shown in Table 3-3.
Traditionally, insurance underwriters and oven standards16 have re-
quired that flammable vapor concentrations not exceed 25 percent of the
lower explosive limit (LEL) in oven air, as measured at the exhaust. Under
current oven design criteria for installations using solvent-borne coatings,
cure ovens are designed as if all of the VOC in the coating used would pass
through the cure oven and an exhaust air flow rate set to result in 25 per-
cent of LEL. The 25 percent of LEL is used because of energy requirements.
A typical cure oven exhaust rate is 2,000 scfm. For waterborne coating,
3-13
-------
TABLE 3-3. EMISSION DISTRIBUTIONS11 12 13 14 15
(percent)
Coating operation
Emission distributions
Coater and flashoff
Cure oven
Two-piece aluminum or steel cans
Exterior base coat
Lithography/overvarnish
Inside spray
Sheet coating, three-piece steel cans
Exterior base coat
Interior base coat
Cure oven
Inside spray, three-piece steel cans
Sheet coating, steel or aluminum ends
Exterior coat
Interior coat
75
75
80
10
10
10
80
10
10
25
25
20
90
90
90
20
90
90
3-14
-------
factors other than safety govern the exhaust rate, which results in rela-
tively low VOC concentrations. Typical flow rates for cure ovens on bever-
age can lines using waterborne coatings are the same as for solvent-borne
operations. When waterborne coatings are used, exhaust air flow is based
on considerations other than percent of LEL. Sufficient air must pass
through the oven to clear the VOC and compounds that may be formed during
the curing process. In general, air flows are the same as for solvent-borne
coatings.17 18
Maximum allowable concentrations and threshold limit values (TLV) have
been established for organic solvent constituents customarily found in can
coating systems. Most of the organic solvents used in major proportions in
the coating systems have TLVs of 100 ppmv (parts per million by volume) or
greater. The ventilating air at coater and flashoff have therefore been
calculated on concentration rates of 100 and 500 ppmv VOC in the air. For
!
each of the base cases, minimum ventilating air rates on this basis are
presented per 1,000 cans or ends.
Another element of can coating cost relating to emissions is oven heat
requirement, which also relates to ventilation. For each of the base
cases, oven heat requirements are presented per 1,000 cans or ends. While
oven heat and ventilation requirements differ for steel and aluminum cans,
the difference is insignificant for equivalent coating weights. Therefore,
energy requirements for aluminum cans have been used for the model plant
analysis. It is recognized that coating thicknesses for steel cans are
generally higher than for aluminum cans for the same container content.
Additionally, coating thicknesses vary from use to use for either steel or
aluminum. Consequently, the coating thicknesses shown in the model plant
operating parameters were selected for analytical purposes.
In determining and selecting base case model operating factors for the
calculation of emissions, minimum air flows, and relative oven heat require-
ments, reliance was placed on contacts with can industry representatives,
coatings manufacturers, on can plant visits, and on published litera-
ture.19 20 21 22 Various operating parameters are found in existing and
newly constructed beverage can plants. Variations exist for each company,
plant, customer, and product in sheet size, sheet base box weight (the
weight in pounds of 31,360 square inches of sheet material), can body
3-15
-------
weight, coating composition, coating thickness, line speed, ventilation
facilities, oven baking temperature and cycle, oven air circulation and
exhaust practices, product mix, mechanical operating efficiency, and operat-
ing hours—in short, all operating factors. As a result, the base case
plants are not patterned after any specific individual operating plant or
plants. Rather, each of the operating factors selected for each of the
cases was selected to be representative for that factor in new plants,
based on interviews and plant visits, and each resulting base case is a
composite based on the selected factors.
Several baseline operating factors, calculated emissions, calculated
minimum air flow at coater and flashoff area, and calculated minimum cure
oven exhaust and heat requirements are shown in Tables 3-4 and 3-5 for
two-piece operations, in Tables 3-6 and 3-7 for three-piece can sheet
coating. These factors are shown in Tables 3-8 and 3-9 for three-piece can
forming, in Tables 3-10 and 3-11 for steel- or aluminum-end coating and in
Tables 3-12 and 3-13 for end-sealing operations. Emissions, air flows, and
heat requirements are expressed on the basis of 1,000 cans or ends. The
emissions for various emission control options will be stated with respect
to these base levels.
3-16
-------
TABLE 3-4. MODEL PLANT OPERATING PARAMETERS, BASE CASE
CTG WATERBORNE COATINGS: COATING OF BODIES FOR ALUMINUM AND STEEL,
TWO-PIECE 12-OZ BEVERAGE CANS
Exterior
base coat
Lithography/
Overvarnish
Inside
spray
Can body weight, lb/1,000 cans
(aluminum/steel)
Dry coating weight, mg/can
Coating
Volume-percent solids
Weight-percent solids
Weight-percent VOC
Weight-percent water
Specific gravity (kg/litre)
kg VOC/litre of solids
kg VOC/litre of coating,
less water
Cure oven exit temperature, °F
Oven pin entering temperature, °F
Oven conveyor entering tempera-
ture, °F
Ambient air temperature, °F
34/72
400
25
35
12
53
1.124
0.54
0.34
400
200
70
34/72
120
25
29
13
58
1.026
0.53
0.34
400
200
70
34/72
200
17
22
21
57
1.
000
1.24
0.51
400
150
70
3-17
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TABLE 3-6. MODEL PLANT OPERATING PARAMETERS, BASE CASE,
CTG WATERBORNE COATINGS: COATING OF STEEL BODY STOCK
FOR THREE-PIECE 12-QI BEVERAGE CAN
Sheet size, inches
Can bodies per sheet
Base box weight, Ib
Dry coating weight, mg/in2
Coating
Volume-percent solids
Weight-percent solids
Weight-percent VOC
Weight-percent F^O
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kg VOC/litre of solids
kg VOC/litre of coating,
less water
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55
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12
53
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400
200
70
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35
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2.5
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29
13
58
1.026
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0.34
400
200
70
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overvarnish
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35
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2.5
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13
58
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0.53
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400
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70
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3-19
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3-20
-------
TABLE 3-8. MODEL PLANT OPERATING PARAMETERS, BASE CASE,
CTG WATERBORNE COATINGS: COATING OF CAN BODIES
FOR THREE-PIECE 12-OZ BEVERAGE CANS
Inside spray
Can body weight, lb/1,000 cans 68
Dry coating weight, mg/can 200
Coating
Volume-percent solids 17
Weight-percent solids 22
Weight-percent VOC 21
Weight-percent H20 57
Specity gravity (kg/litre) 1.000
kg VOC/litre solids 1.24
kg VOC/litre of coating, less water 0.51
Cure oven exit temperature, °F 400
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3-21
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3-22
-------
TABLE 3-10. MODEL PLANT OPERATING PARAMETERS, BASE CASE,
CTG WATERBORNE COATINGS: COATING OF STEEL- AND ALUMINUM-END SHEETS
Sheet size, inches
Ends per sheet
Base box weight, Ib
Dry coating weight, mg/in2
Coating
Volume-percent solids
Weight-percent solids
Weight-percent VOC
Weight-percent H20
Specific gravity (kg/litre)
kg VOC/litre solids
kg VOC/litre of coating, less water
Ambient air temperature, °F
Oven wicket entering temperature, °F
Cure oven exit temperature, °F
Exterior
coati ng
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132
118
1.25
25
29
13
58
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70
200
400
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coati ng
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132
118
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57
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0.51
70
200
400
3-23
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S- s- o ro
Q. 0) -P
-P OJ O
i— ro S- H-
rO 0 3
-p o cj
o
I—
3-24
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TABLE 7-3. RECOMMENDED CTG EMISSION LIMITATIONS FOR
CAN SURFACE COATINGS3
Affected facility
Recommended limitation
kg per litre Ib per gal
of coating of coating
(minus water) (minus water)
Sheet base coat (exterior and
interior) and overvarnish;
two-piece can exterior
(base coat and overvarnish)
Two and three-piece can interior
body spray, two-piece can
exterior end (spray or roll
coat)
Three-piece can side-seam spray
End sealing compound
0.34
2.8
0.51
0.66
0.44
4.2
5.5
3.7
7-7
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TABLE 3-12. MODEL PLANT OPERATING PARAMETERS, BASE CASE,
CTG END-SEALING COMPOUND: STEEL AND ALUMINUM ENDS23 24
End-sealing compound
Volume-percent solids
Weight-percent solids
Weight-percent VOC
Weight-percent H20
Specific gravity (kg/litre)
kg VOC/litre of solids
Wet end-sealing compound applied
mg/end, aluminum
mg/end, steel
44
53
47
0.948
1.01
150
230
3-25
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TABLE 3-13. MODEL PLANT COATING, VOC EMISSIONS AND
AIRFLOW PARAMETERS, BASE CASE: APPLICATION OF
END-SEALING COMPOUND2
Emissions
kg/1,000 ends
Ventilating air
acf per 1,000 ends
100 ppv
500 ppv
Aluminum ends
Steel ends
0.71
0.108
5,700
8,050
1,140
1,735
3-26
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3.4 REFERENCES
1. The Can Manufacturers Institute, Inc. Economic Profile (1976). Wash-
ington D.C. Enclosure to letter. Smith, Andrea M., letter to Diehl,
Robert, Springborn Laboratories, Inc. May 23, 1979.
2. The Can Manufacturers Institute, Inc. Metal Can Shipments Report,
1978. Washington, D.C. 1979.
3. Telecon. Massoglia, M., Research Triangle Institute, with Cook, D.,
Container Technology, Inc. September 17, 1979. Can surface coating.
4. Telecon. Massoglia, M., Research Triangle Institute, with Cook, D.,
Container Technology, Inc. September 25, 1979. Beverage can plants.
5. Permit application for the Miller Brewing Company, Reidsville, N.C.
plant, July 12, 1978.
6. Trip Report. Massoglia, M., Research Triangle Institute, to the
Atlanta Plant, American Can Company.
7. Letter, Lafser, F., Missouri Department of Natural Resources, to Beracha
B., Metal Container Corporation. February 23, 1979. Permit
number 0273-001 through 0279-017. Enclosure.
8. United States Environmental Protection Agency. Control of Volatile
Organic Emissions from Stationary Sources. Volume II: Surface Coat-
ing of Cans, Coils, Fabrics, Automobiles, and Light Duty Trucks.
Research Triangle Park, N.C. EPA Publication No. EPA-450/2-7-008.
May 1979. p. iv.
9. Telecon. Massoglia, M., Research Triangle Institute, with De Moss, P.,
Metal Container Corporation. August 6, 1979. Can surface coating.
10. Trip Report. Massoglia, M., Research Triangle Institute, to Jackson-
ville Plant, Metal Container Corporation.
11. State of California Air Resources Board. Source Test Report No. C-8-
017 for Crown Cork and Seal Company. May 1978. p. 3.
12. State of California Air Resources Board. Source Test Report No. C-8-
020 for National Can Corporation. May 1978. p. 3.
13. State of California Air Resources Board. Source Test Report No. C-8-
024 for Ball Corporation. May 1978. p. 3.
14. Meeting between R. McKirahan, G. Payne, W. Diehl, H. Schnitzer, W. Hoi ley,
and T. Gabris. Springborn Laboratories. November 10, 1978.
15. Ref. 8, p. 2-15.
16. Standard for Ovens and Furnaces—Design, Location, and Equipment. NFPA
86A-1977.
3-27
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17. Telecon. Massoglia, M., Research Triangle Institute, with Anderson,
J., FECO, February 21, 1980. Beverage Can Surface Coating Cure Ovens.
18. Telecon. Massoglia, M. , Research Triangle Institute, with Flanagan,
P., Midland-Ross. February 21, 1980. Beverage Can Surface Coating
Cure Ovens.
19. Goodell, Paul H. Economic Justification of Powder Coating. Society
of Mechanical Engineers. Technical paper F6 76-459. 1976.
20. Robinson, G. Thomas. Can Paint Oven Exhausts Be Cut Back? Products
Finishing. March 1977. p. 82-83.
21. Finishing Highlights. Products Finishing. May 1978. p. 50-53.
22. Waste Disposal from Paint Systems Discussed at Detroit Meeting.
American Paint and Coatings Journal. February 23, 1976. pp. 35-36.
23. Telecon. Massoglia, M., Research Triangle Institute, with Martino, M.,
Whittaker Corporation. February 27, 1980. Beverage Can End-Sealing
Compound.
24. Telecon. Massoglia, M., Research Triangle Institute, with Dalton, M.,
W. R. Grace & Co., January 18, 1980. End-Sealing Compound.
3-28
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4. EMISSION CONTROL TECHNIQUES
This chapter describes and evaluates emission control techniques
applicable to the beverage can surface coating industry. The purpose of
these control techniques is to reduce emissions of volatile organic com-
pounds (VOCs) to the air. These compounds, which include ketones, alcohols,
esters, saturated and unsaturated hydrocarbons, and ethers, are used for
coatings, thinners, and cleaning materials in industrial finishing proc-
esses.
Several types of control techniques are presently in use in either the
beverage can surface coating industry or in related industries. These
methods can be categorized as either add-ons or new coating systems.
Add-ons are pollution control equipment used to reduce emissions by recov-
ering or destroying solvents before they are emitted to the air. The
elimination of a coating operation; i.e., base coat or overvarnish, is also
a viable option for the reduction of VOC emissions in those instances where
customer performance requirements can be met without the coat.
New coatings may contain reduced quantities of VOC compared to tradi-
tional solvent-borne materials. In other instances some part of the VOC
content may be incorporated into the finish by polymerization. With the
exception of powder and electrodeposition coatings, new coatings can gen-
erally be applied with existing equipment. Examples of industrial finish-
ing processes that use new coatings are roll, mandrel or spray application
of waterborne coatings, spray of powder materials, and roll or mandrel
application of high solids and UV-curable coatings.
Because of their generally lower organic solvent content, new coating
materials used in place of conventional solvent-borne coatings in indus-
trial finishing processes can result in substantial reductions in VOC
emissions.
4-1
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4.1 ALTERNATIVE EMISSION CONTROL TECHNIQUES
4.1.1 Waterborne Coatings
The use of waterborne coatings is the most common control technique
presently in use in the beverage can surface coating industry. It reported-
ly accounted for 80 percent of all low-solvent "compliance coatings" used
by the can industry in 1977.1 One estimate placed waterborne coating
consumption for the entire can market at approximately 11 million litres (3
million gallons) during 1977.2
Nearly all waterborne coatings used by the can industry are for bev-
erage cans. In 1977, 12 percent of the approximately 95 million litres
(25 million gallons) of coatings consumed by the beverage can segment were
waterborne. Other estimates place waterborne coatings at between 15 and 25
percent of total coatings use during 1978 for beverage cans.3 4 5
Waterborne coatings are used in the beverage can industry for base
coats, inside sprays, and overvarnishes.6 7 Both clear (unpigmented) and
opaque (pigmented) coatings are used on beverage cans. Overvarnishes are
generally used for clear base coats. Only a small segment of the beverage
can industry uses clear base coats. One merchant canmaker reports that
less than 2 percent of base coats used are clear.8
The term waterborne as used in this report refers to any coating which
uses water rather than organic solvents as the primary carrier. The vola-
tile portion of the waterborne coating generally contains 70 to 80 volume-
percent water.
Waterborne coatings are attractive to the can industry for several
reasons. They generally can be applied with existing equipment, with
little or no modification.9
The various coatings that are applied to beverage cans--inside sprays,
base coats, overvarnishes, etc.—have narrow specific requirements. All of
these can be met with presently available waterborne coatings.10
The emission of volatile organics from waterborne coatings depends on
the sol vent-to-sol ids ratio in the paint, the film thickness applied, the
surface area of the parts to be coated, and the number of units finished
per hour.
4-2
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End-sealing compounds currently in use are solvent-based materials,
most of which do not meet the emission limitations recommended in the CTG.
Processes are underway to assess the suitability of solvent-based compounds
satisfying the emission limitations recommended in the CTG and water-based
compounds in which the carrier contains no VOC.
4.1.1.1 Waterborne Spray. In the beverage can industry, waterborne
spray coatings are used in place of traditional solvent-borne materials for
inside sprays for beer and soft drink cans.6 7 il One can manufacturer
estimated that in 1978 over 7.5 million litres (2 million gallons) of
waterborne spray coating would be used for the interior of two-piece cans
alone.12 One coatings manufacturer estimated that in 1978 as much as 15
percent of the two-piece beverage can market was using waterborne coatings
for inside sprays.5
The first waterborne inside spray was introduced in early 1975.5 Most
waterborne inside sprays in current use are based on either acrylic or
epoxy,5 13 and are typically applied at approximately 20 weight-percent
solids from an 80/20 volume-percent waterborne carrier.6 7 14 One coating
supplier provides an inside spray coating with 21.6 weight-percent solids
that accounts for more than 75 percent of the waterborne usage.15 These
coatings are applied to both two-piece and three-piece cans without the use
of special equipment.1 16
Airless spray is the preferred application method, although air spray
is still used for older three-piece can lines. Dry coating weights are
comparable to those applied with conventional solvent-borne sprays, general-
ly 0.4 to 1.2 mg/cm2 (2.5 to 8 mg/in2), depending on whether the coating is
for beer or soft drinks, for steel or aluminum, or for two- or three-piece
cans.
6 17 18
Curing requirements for waterborne coatings are generally comparable
to those for solvent-borne coatings. It is rarely necessary to increase
oven temperatures and/or stay time to accommodate waterbornes.
4.1.1.2 Waterborne Mandrel Coating. Mandrel coating is the method
used to apply exterior base coat and overvarnish to two-piece cans. It
should be noted that some two-piece can makers eliminate exterior base coat
and/or overvarnish.
4-3
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Mandrel-applied waterborne exterior base coats for two-piece cans have
been in use since the mid-19701s. Today, approximately 20 percent of the
exterior base coating for two-piece cans is waterborne.5 It was estimated
that in 1978 approximately 3 million litres (800,000 gallons) of waterborne
base-coating material was used for two-piece cans,19 representing approxi-
mately 20 percent of the roughly 15 million litres (4 million gallons) of
base coating used by this segment of the beverage can coating industry.5
While current use of waterborne overvarnish is not as widespread as
use of waterborne exterior base coat, such varnishes have been commercially
used for two-piece cans since 1974. Consumption of waterborne varnish for
two-piece cans has been estimated at approximately 1.1 million litres
(300,000 gallons) for 1977.19
Conversion from solvent-borne coatings to waterborne materials requires
only minor equipment modifications, such as replacement of lines and pumps
with components constructed from corrosion-resistant materials such as
stainless steel.1 9 Most of the waterborne base-coating materials are
either acrylics or polyesters and are applied at between 50 and 60 weight-
percent solids.4 15 18 The solvent content of these base coats is generally
between 20 and 30 volume percent of the volatile portion of the coating,
but efforts are being made to lower this proportion.5 18 One coating on
the market contains 42.6 volume-percent (56.6 weight-percent) solids,
19.5 weight-percent VOC, and 33.9 weight-percent H20.20 Coating weights for
waterborne base coatings for two-piece cans are generally comparable to
those applied, with solvent systems, approximately 300 mg/can for aluminum
and 350 to 500 mg/can for steel.6 9 21 22
Overvarnishes must be compatible with lithographic inks and be scuff
resistant. Most waterborne varnishes for two-piece cans are based on
either polyester or acrylic and are applied at between 32 and 38 weight-
percent solids (27.6 and 33.2 volume-percent solids).4 23 One coating on
the market contains 34.7 volume-percent (37.9 weight-percent) solids, 14.9
weight-percent VOC, and 47.2 weight-percent H20.24 Coating weights for
waterborne overvarnishes are generally comparable to those applied with
solvent-borne coatings and range from 120 to 150 mg/can.21 25
4.1.1.3 Waterborne Roll Coating. Waterborne coatings are used for
three-piece cans, but not as extensively as for two-piece cans. Waterborne
4-4
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roll coating is being used to a limited extent on sheets for three-piece
can bodies for base coats, overvarnish, and exterior end coat. Annual
consumption of waterborne coatings for three-piece cans has been estimated
at approximately 2.6 million litres (700,000 gallons).19
Waterborne white base coats containing modified acrylic resins have
been used commercially for three-piece cans since 1976. One factor which
may have delayed acceptance of these materials for this application has
been poor adhesion to tin-free steel plate. This may be because plates are
generally not pretreated in the plant, but are received pretreated. They
may contain small quantities of lubricant to facilitate feeding into the
coater and the presence of this lubricant may be the cause of inadequate
wetting and adhesion.
Roll-coated waterborne varnishes are also used commercially on a
limited basis. These coatings typically contain 30 to 36 weight-percent
solids (25.7 to 31.3 volume-percent solids) with 20 volume-percent VOC in
the volatile portion of the material.18 26 One factor which has limited
the use of waterborne wet ink varnishes for three-piece cans has been
incompatibility between the varnishes and the lithographic inks,27 and the
increasing use of no-var inks (inks not requiring overvarnish).
Roll-coated waterborne exterior end coatings have also been commer-
cialized. Formulated for optimum scuff resistance, these coatings are
generally based on epoxy, polyester, or modified acrylics.27
4.1.1.4 Electrodeposition. There is presently no indication that
electrodepostion is used commercially for coating beverage cans. Major can
and coatings manufacturers, however, hold patents on processes for applying
inner lacquers by electrodeposition, along with companion patents covering
waterborne lacquer for use in the electrodeposition process.28 29 30 In
this process, an aqueous dispersion is fed into inverted can bodies. The
can is made the anode of the system, and coating is electrodeposited onto
the inside. The process is similar to both flow coating and electrocoat-
ing.31
One company has two prototype machines in the late stages of engineer-
ing. Pilot runs with a line speed of 300 cans/minute were scheduled for
early 1979.31 According to the inventor, the equipment is potentially
scalable to normal production speeds of 800 to 1,000 cans/minute. The
4-5
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process is capable of applying coatings as thin as 1 mg/in2, and coated
cans have reportedly received approval from two breweries, based on pre-
liminary pack tests.32
4.1.1.5 Ultraviolet-Cured Coatings. A new technology that has received
a great deal of attention over the past 10 years is UV curing, a radiation-
initiated polymerization for curing industrial finishes and printing inks.
This technology has been used for "drying" inks in the beverage can industry.
UV-curable coating materials are 100 percent convertible to solids,
that is, they contain essentially no residual volatile organic compounds.
As a result, they offer substantial reductions in the emission of volatile
organic compounds (VOC) over conventional solvent-borne coatings. UV-
curable coatings generally fall into two major types, unsaturated polyester/
styrene systems, and acrylic systems.
A third type of UV coating, developed by one of the major can com-
panies, employs epoxy resins in combination with a photoreactive curing
agent that cures the epoxy much like a conventional epoxy coating.33 This
system is receiving little commercial use.
UV-curable overvarnish is used for approximately 10 percent of the
three-piece beverage can markets. Very little, if any, use is reported for
two-piece cans.34
Several factors have deterred the use of UV-cured overvarnish:35 36
Cost of the coating, which ranges between $6.60 and $7.90 per
litre ($24 to $30 per gallon).
Application problems. Thickness is difficult to control with
available application equipment, and flow and leveling are poor
compared to conventional materials.
Monomer toxicity.
One major can company, although directing most of its efforts in UV
cure towards flat-sheet lithography, has been investigating overvarnishes.
A photocurable epoxy has been used as a dry ink varnish over millions of
printed sheets for nonfood applications such as aerosol cans, and for both
aluminum and tin-free steel beverage can ends.37 38 In addition, a line
was recently started for the application of UV-cured acrylic wet ink var-
nish for two-piece cans. The bottom-rim varnish on this line is also UV
cured.38
4-6
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While UV-cured white base coats have been considered, there is no evi-
dence of commercial use of this technology in the beverage can industry.39
One major can company claims to be working on such a material, but at
present does not have a commercial coating.38
4.1.1.6 High-Solids Coatings. High-solids coatings contain at least
80 volume-percent solids.40 Contact with beverage can manufacturers during
the development of this document did not uncover any high-sol ids coatings
in use in recently constructed beverage can lines or planned for use in the
near future.41 42 43 44 45 46 47
4.1.1.7 Powder Coatings. While a powdered epoxy spray process and
materials suitable for applying inside lacquer coatings to beverage cans
has been developed by one coating company,48 contacts with beverage can
manufacturers during the development of this document did not uncover any
use of powder coatings in recently constructed beverage can lines in use or
planned for use in the near future.43 44 45 46
4.1.1.8 End-Sealing Compounds. Practically all of the end-sealing
compound used by the beverage can industry is solvent-based. Little, if
any, used today has a VOC content that would meet the emission limitation
recommended in the CTG. Research and development is being conducted on new
higher solids solvent-based and water-based compounds that would result in
emissions which are equal to or less than the recommended emission limita-
tion.49 50 51 52
The leading supplier of beverage can end-sealing compound is currently
not offering a compound that meets the CTG-recommended emission limitation,
projecting that such compounds will be available by 1982.49 Another sup-
plier, representing most of the remaining market, introduced a solvent-based
CTG-compliance end-sealing compound in 1979, and is currently working on a
second-generation model with a higher solids and a lower VOC content. The
compliance material is being tested by a major soft drink producer.51
A major brewery is currently evaluating ends lined with solvent-based
end-sealing compounds supplied by two merchant can manufacturers. Ends
made by one canmaker are in the final stage of clearance.53
Considerable attention is being given to the development of water-based
end-sealing compounds. These materials, which contain no or only a neglig-
ible amount of VOC, are formulated to be air dried and do not require oven
4-7
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or forced air drying.49 50 52 Test runs were initially satisfactory.
However, problems developed that resulted in temporary discontinuance of
the tests. One producer of beverage can ends found the water-based mater-
ials to be satisfactory during the winter months but experienced problems
when the ends were shipped to and stored in a hot humid environment.54 55
A major canmaker states as its goal to eventually be totally dependent on
water-based end-seal ing compounds. However, the determining factor is
customer acceptance. To that end, canmakers are engaged in a program to
qualify water-based end-compounds with their customers, who are performing
functional and taste tests to determine which, if any, of the available
compounds are acceptable. Qualification testing of new end-sealing com-
pounds is a lengthy process and may take as long as 18 months after a new
compound becomes available.56
While water-based end-sealing compounds require only air drying, some
canmakers feel it necessary to heat dry by forced-air drying.51 52 Under
some circumstances, e.g., high humidity, the evaporation of moisture after
packaging of the ends may result in the accumulation of sufficient moisture
in the paper sleeves that they break open during handling. To preclude
this, some installations may include a small hot air dryer in the end line
prior to packaging. At this time, it is not known if a drier is required
on all installations.50
A major captive canmaker is engaged in an aggressive program to evalu-
ate ends lined with water-based end-sealing compounds. While some problems
are being experienced, they are considered solvable as the industry gains
experience in the use of water-based end-sealing compounds. The water
adsorption problem could be ameliorated by reducing to a minimum the time
that ends are in the immediate vicinity of the filling line.56
4.1.1.9 No-Var Inks. According to one ink manufacturer, approxi-
mately half of all two-piece beverage cans use no-var inks in place of
conventional inks plus overvarnish.57 No-var inks also exist for three-
piece cans. No-var inks are specially formulated inks that provide the
desired surface characteristics without the use of an overvarnish.37
No-var ink eliminates an added coating step and resulting VOC emissions.
One can manufacturer has discontinued the use of no-var inks for two-piece
cans because the increased friction was found to be detrimental to high-
speed can manufacturing and filling lines.58
4-8
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No-var inks are usually applied over clear or white exterior base
coats, but at least one beverage can manufacturer is applying no-var inks
directly over freshly cleaned aluminum.6 Most no-var inks are thermally
curable and are applied by dry offset printing, at weights comparable to
the conventional inks that they are replacing.
No-var inks may not meet the specifications for gloss and scuff resis-
tance that have been set up by some beverage-can customers. In such cases,
can manufacturers apply overvarnish.
During 1979 there was a trend away from no-var inks. One merchant
canmaker reports a decrease in the use of no-var inks and UV-curable over-
varnishes from 80 percent in 1979 to 5 percent in the early part of 1980.59
4.1.2 Add-on Emission Control Systems
Incineration is the most universally used add-on emission control sys-
tem for VOC emissions from industrial processes. It is used throughout the
industrial finishing industry, but only to a limited extent in the beverage
can coating industry, where both noncatalytic (thermal or direct fired) and
catalytic units are in evidence.26 60 61 62
4.1.2.1 Thermal Incinerators. Direct-fired afterburners operate by
heating sol vent-laden air to near its combustion temperature and then
bringing it in direct contact with a flame. In general, high temperature
and high organic concentration favor combustion; a temperature of 760° C
(1,400° F) sustained for 0.5 second is normally sufficient for nearly
complete combustion.
Because the solvent emissions are below the combustible limit, auxil-
iary heating of the air is necessary for incineration. The quantity of
heat to be supplied depends on the temperature of the incoming air stream
and the concentration of the organic in the air stream. The higher the
concentration, the lower the auxiliary heat requirement, because of the
fuel value of the organic materials. To reduce the cost of thermal incine-
ration, heat-transfer devices are used to recover at least part of the heat
of combustion.59 6S 64
Thermal incinerators are in use on several can coating lines for both
two- and three-piece beverage cans.26 59 60 At the present time, most are
used to control emissions from bake ovens. One coater is using thermal
4-9
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incineration to control emissions from inside spray coaters and flashoff
areas as well. He reports, however, that the line will be converted to
waterborne coatings because of recent increases in the cost of natural
gas.65 Although individual afterburner units can be used, in many cases
the exhaust from several ovens is ducted into one common incinerator.59 60
Operating temperatures are generally in the range of 650° to 815° C
(1,200° to 1,500° F). Heat recovery is used with some units, with recovery
as high as 50 percent.26 60
4.1.2.2 Catalytic Incineration. This add-on emission control system
makes use of a metal catalyst to promote or speed combustion of volatile
organic compounds. Oxidation takes place at the surface of the catalyst to
convert organics into carbon dioxide and water.66 67 The catalysts, usually
noble metals such as platinum and palladium, are supported in the hot gas
stream so that a high surface area is presented to the waste organics. A
variety of designs are available for the catalyst, but most units use a
noble metal deposited on a high area support, such as ceramic rods or
honeycomb or alumina pellets.66 67 68
As with thermal incinerators, the performance of the catalytic unit is
dependent on the temperature of the gas passing across the catalyst and the
residence time and the type of organic being oxidized.68
Use of a catalyst permits lower operating temperatures than are used
in direct-fired units. Temperatures are normally in the range of 260° to
320° C (500° to 600° F) for the incoming air stream, and 400° to 540° C
(750° to 1,000° F) for the exhaust. The exit temperature from the catalyst
depends on the inlet temperature, the concentration of organic, and its
heat of combustion.
Primary and secondary heat recovery can be used to minimize auxiliary
fuel requirements for the inlet air stream and to reduce the overall energy
needs for the plant. Although catalysts are not consumed during chemical
reaction, they gradually lose their effectiveness in burning the organics.
This deterioration is caused by poisoning with chemicals such as phos-
phorous and arsenic, which react with the catalyst; by coating the catalyst
with particulates or condensates; and by high operating temperatures. In
most cases, catalysts are guaranteed for 1 year by the equipment supplier,69
but with proper filtration, cleaning, and attention to moderate operating
4-10
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temperatures, the catalyst should have a useful life of 2 to 3
years.66 69 70
Catalytic incineration is currently used in the beverage can coating
industry only for oven emissions.60 Typical operating temperature is 310°
to 430° C (600° to 800° F).60
4.1.2.3 Carbon Adsorption. While adsorbers are not currently used in
the beverage can coating industry, they have been used successfully in
other finishing industries.71 72 73
One major beverage can manufacturer had installed a carbon absorption
unit at one plant, but after 3 years effort to make the unit work depend-
ably, concluded that carbon adsorption was not a viable control option.
Problems of carbon adsorption enumerated by the company include added fuel
requirements, requirement for extra control to remove organic tar-like
residues prior to adsorption, short carbon life, removal of water-miscible
solvents from the steam condensate discharge, and corrosion of the adsorber
tank and carbon bed supporting screen.74
4.2 VIABLE EMISSION CONTROL OPTIONS
Emissions can be controlled through the use of either new coatings, or
add-on emission control systems. Add-ons ordinarily destroy the organic
solvent emissions. New coatings contain a lower amount of volatile organic
material than traditional coatings.
While the trend in the beverage can industry is away from solvent-
borne and toward waterborne coatings, solvent-borne coatings may continue
to be used for new, modified or reconstructed facilities.46 Therefore
incineration, either in a new facility or as an add-on to a modified or
reconstructed existing facility, must be considered a viable control option.
Field investigations indicate that both thermal and catalytic incineration
are capable of removing at least 90 percent of the solvents captured from
exhaust air streams.75
While there may be some use of solvent-borne coatings with add-on
controls, waterborne coatings will dominate new can lines and modified or
reconstructed existing lines. VOC contents of waterborne coating with
lowest VOC content in general use are shown in Table 4-1. VOC contents of
solvent-borne coatings identified as the highest solid content in general
use are shown in Table 4-2.
4-11
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TABLE 4-1. VOC CONTENT OF WATERBORNE COATINGS WITH LOWEST
VOC CONTENT IN GENERAL USE8 1S 20 24 59 76
VOC content
Coating operation
kg VOC per
litre of solids
kg VOC per
litre of coating,
less water
Two-piece cans
Exterior base coat, except clear
Overvarnish and clear base coat
Inside spray
Three-piece cans
Exterior base coat
Interior base coat
Overvarnish
Inside spray
Steel and aluminum end sheets
Exterior coat
Interior coat
End-sealing application3
0.29
0.46
0.89
0.50
0.50
0.46
0.64
0.50
0.50
0.05
0.22
0.30
0.43
0.32
0.32
0.30
0.36
0.32
0.32
0.05
Currently undergoing qualification tests.
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TABLE 4-2. VOC CONTENT OF HIGHER SOLIDS SOLVENT-BORNE
COATINGS IN GENERAL USE5 7?a
Coating operation
Two-piece cans
Exterior base coat
Overvarnish
Inside spray
Three-piece cans
Exterior base coat
Interior base coat
Overvarnish
Inside spray
Steel and aluminum end sheets
Exterior coat
Interior coat
End-sealing application
kg VOC
per litre
of solids
1.00
2.55
3.01
1.00
3.30
1.47
3.01
1.04
3.30
1.07
kg VOC
per litre
of coating,
less water
0.45
0.64
0.66
0.45
0.72
0.54
0.66
0.47
0.72
0.43
Overall
control
efficiency
equivalent to
waterborne
71
82
70
50
85
69
79
52
85
95
Average of coatings used by a major canmaker.
Currently undergoing qualification tests.
4-13
-------
UV-cure overvarnish and no-var inks are considered viable alternative
control options for the use of solvent-borne overvarnish followed by incin-
eration, or for the use of waterborne overvarnish.
4.3 REFERENCES
1. Kosiba, R. L. Update-Water-Borne Coatings for Metal Containers.
(Presented at NPCA Chemical Coatings Conference II, Water-Borne Ses-
sion. May 11, 1978.) p. 52.
2. Ref. 1, p. 53.
3. Water-Borne Coatings: Panacea or Expedient. Industry Week, 66.
August 29, 1977.
4. Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc. October 19, 1978. Telephone
conversation with Donald Watts, M&T Chemicals, Rahway, NJ.
5. Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc. October 18, 1978. Telephone
conversation with Russell Craig, Rohm and Haas Company, Philadelphia,
PA.
6. Trip Report. Diehl, Robert, and William H. Holley, Springborn Labora-
tories, Inc., to Adolph Coors Company, Golden, CO. November 10, 1978.
7. Trip Report. Holley, William H., Springborn Laboratories, Inc., to
Crown Cork and Seal Company, Inc., Lakeville, MN. December 8, 1978.
8. Telecon. Massoglia, M., Research Triangle Institute with Kosiba, R.,
National Can Corporation. June 24, 1980. Beverage can surface coating.
9. Strand, R. C. Water-Borne Coatings in Metal Packaging. (Presented at
NPCA Chemical Coatings Conference, Water-Borne Session. April 23,
1976.) p. 36.
10. Ref. 9, p. 20.
11. Water-Borne Coating Systems are Maturing. Industrial.Finishing. 41.
May 1977.
12. Ref. 1, p. 62.
13. Lawson, D. 0. Water-Borne Spray Can Coatings. ACS Division of Organic
'Coatings and Plastics Chemistry. 37(2):45. September 1977.
14. Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc. October 20, 1978. Telephone
conversation with R. Whitmire, Glidden-Durkee Division, SCM, Strong-
ville, OH.
4-14
-------
15. Letter from Nimon, L., Glidden Coating and Resins to Massoglia, M.,
Research Triangle Institute. June 11, 1980. NSPS-beverage cans.
16. Pollution Solutions by Glidden. Modern Metals. 83. April 1978.
17. Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc. December 6, 1978. Telephone
conversation with Jeff Leyh, PPG Industries, Inc., Columbus, OH.
18. Ref. 9, p. 35.
19. Ref. 1, p. 63.
20. Material Safety Data Sheet Covering "Purair" S21-121A, Modified Acrylic
Aqueous Exterior White Base Coating. Inmont Corporation, Cincinnati,
OH.
21. Memo from Holley, William H., Springborn Laboratories, to Diehl,
Robert, Springborn Laboratories, Inc. November 27, 1978. Telephone
conversation with Emil Bader, Inmont Corporation, Clifton, NJ.
22. Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc. November 13, 1978. Telephone
conversation with Mr. Gault, Rohm and Haas Company, Philadelphia, PA.
23. Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc. October 19, 1978. Telephone
conversation with K. Pierce, Cook Paint and Varnish Company, Kansas
City, MO.
24. Material Safety Data Sheet covering "Purair" S145-121, Modified Acrylic
Aqueous Finishing Varnish. Inmont Corporation, Cincinnati, OH.
25. Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc., December 12, 1978. Telephone
conversation with John Swanson, Whittaker Coatings Company, Chicago,
IL.
26. Trip Report. Gabris, T., Springborn Laboratories, Inc., to American
Can Company, Plant Number 23, Hillside, NJ. December 19, 1975.
27. Ref. 1, p. 58.
28. Kossmann, H. USP 3,801,485, to American Can Company. April 2, 1974.
29. Colberg, K. H., and Zukowski, R. J. USP 3,939,110, to American Can
Company. February 17, 1976.
30. Brower, L. R. et al. U.S. Patent 4,119,522 to Standard T. Chemical
Company, Chicago, IL. October 10, 1978.
4-15
-------
31.
32.
New Non-Immersion Electrocoat Process'.
42(10):69-70. July 1978.
Products Finishing.
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc. December 5, 1978. Telephone
conversation with Lloyd Brower, Standard T. Chemical Company, Chicago,
IL.
Tarwid, W. A., and D. E. Kester. Photocurable Epoxide Coatings for
Metal Containers. ACS Division of Organic Coatings and Plastics
Chemistry Preprints. 37(2):67-72. September 1977.
Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc. October 18, 1978. Telephone
conversation with John Kelley, DeSoto, Inc., Chemical Coatings Divi-
sion, Des Plaines, IL.
Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc. October 10, 1978. Telephone
conversation with Jeff Leyh, PPG Industries, Coatings and Resins
Division, Delaware, OH.
Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc. October 13, 1978. Telephone
conversation with James Kelley, The O'Brien Corp.
Pansing, H. E., A Review of New Developments in Packaging Inks and
Coatings. Package Development. §(l):24-25. January/February 1976.
Joosten, L. UV Metal Decorating—A Four Year Progress Report. (Pre-
sented at NPCA Chemical Coatings Conference II, Radiation Cured Coat-
ings Session. May 10, 1978.) p. 65-72.
Good Future for UV Cure. Products Finishing. 42(8):53. May 1978.
U.S. Environmental Protection Agency. Control of Volatile Organic
Emissions From Existing Stationary Sources - Volume I: Control Methods
for Surface-Coating Operations. Research Triangle Park, N.C. Publica-
tion No. EPA-450/2-76-028. November 1976. p. 71.
Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc. October 23, 1978. Telephone
conversation with George Wilhelm, Ashland Chemical, Columbus, OH.
Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc. October 13, 1978. Telephone
conversation with J. D. Pontius, Sherwin-Williams Company, Chicago, IL.
Telecon. Massoglia, M., Research Triangle Institute with Ambrose, T.,
American Can Company. June 28, 1978. Can surface coating.
4-16
-------
44. Telecon. Massoglia, M. Research Triangle Institute with Menke, R. ,
Reynolds Aluminum. July 26, 1978. Can surface coating.
45. Telecon. Massoglia, M., Research Triangle Institute with Kosiba, R.,
National Can Corporation. August 3, 1979. Can surface coating.
46. Telecon. Massoglia, M., Research Triangle Institute with DeMoss, P.,
Metal Container Corporation. August 6, 1979. Can surface coating.
47. Telecon. Massoglia, M., Research Triangle Institute with Donaldson, R. ,
Reynolds Aluminum, October 31, 1979. Beverage can surface coating.
48. Meeting Report. Diehl, Robert, et al. Meeting with Edmonston, Robert,
and Maureen Dal ton, W. R. Grace and Co., Springborn Laboratories,
Inc., Enfield, CT. October 25, 1978.
49. Telecon. Massoglia, M., Research Triangle Institute with Dalton, M.,
W. R. Grace & Co. January 18, 1980. End-sealing compound.
50. Telecon. Massoglia, M., Research Triangle Institute with Munford, P.,
The Dexter Corporation. February 8, 1980. End-sealing compound.
51. Telecon. Massoglia, M., Research Triangle Institute with Martino, M.,
Whittaker Corporation. February 27, 1980. Beverage can end-seal ing
compound.
52. Telecon. Massoglia, M., Research Triangle Institute with Kuzara, J.,
H. B. Fuller Company. March 31, 1980. Beverage can end-sealing
compound.
53. Telecon. Massoglia, M., Research Triangle Institute with Hardwick, W.,
Anheuser-Busch. April 14, 1980. Beverage can end-sealing compound.
54. Telecon. Massoglia, M., Research Triangle Institute with Granato, J.,
Owens-Illinois. March 26, 1980. Beverage can end-seal ing compound.
55. Telecon. Massoglia, M., Research Triangle Institute with Mossburg, J.,
Owens-Illinois. March 31, 1980. Beverage can end-sealing compound.
56. Letter from Rivetna, R., National Can Corporation to NAPCTAC, U.S.
Environmental Protection Agency. June 3, 1980. National Can Corpora-
tion comments regarding New Source Performance Standards for VOC emis-
sions from beverage can surface coating industry.
57. Memo from Holley, William H., Springborn Laboratories, Inc., to Diehl,
Robert, Springborn Laboratories, Inc. November 22, 1978. Telephone
conversation with Al Benevenia, Inmont Corporation. Clifton, NJ.
58. Letter from Hall, R. G., Ball Metal Container Group, to Massoglia,
M. F., Research Triangle Institute, February 25, 1980.
4-17
-------
59. Massoglia, M. , Research Triangle Institute, Memorandum to the Record.
June 12, 1980. Meeting with National Can Corporation on May 20, 1980.
60. Trip Report. Gabris, T., Springborn Laboratories, Inc., to Conti-
nental Can Company, Portage, IN. March 3, 1976.
61. Trip Report. Gabris, T., Springborn Laboratories, Inc., to National
Can Corporation, Danbury, CT. April 27, 1976.
62. Trip Report. Gabris, T., Springborn Laboratories, Inc., to American
Can Company. Plant Number 025, Edison, NJ. December 29, 1975.
63. Lund, H. F. Industrial Pollution Control Handbook. New York, McGraw-
Hill, 1971. p. 7-8 to 7-11.
64. Heat Recovery Combined with Oven Exhaust Incineration. Industrial
Finishing. 52(6):26-27.
65. Telecon. Massoglia, M., Research Triangle Institute and Salman, D.,
U.S. Environmental Protection Agency, with Fitzgerald, N., Metal
Container Corporation. April 1, 1980. Beverage can lines.
66. Lund, H. F. Industrial Pollution Control Handbook. New York, McGraw-
Hill, 1971. p. 5-27 to 5-32.
67. How Does Catalytic Incineration Stack Up? Finishing Highlights.
8(7):10. November/December 1976.
68. Danielson, J. A. Air Pollution Engineering Manual. Cincinnati,
Public Health Service Publication 999-AP-40, 1967. p. 178-184.
69. Kent, R. W. Thermal Versus Catalytic Incineration. Products Finish-
ing. 40(2):83-85. November 1975.
70. Combustion Engineering, Air Preheater Division. Fuel Requirements,
Capital Costs and Operating Expense for Catalytic and Thermal After-
burners. Wellsvilie, NY. EPA Contract No. 68-02-1473, Task 13.
71. Kanter, C. V. et al. Control of Organic Emissions from Surface Coat-
ing Operations. (Presented at the 52nd APCA Annual Meeting.) June
1959.
72. Elliott, J. H., N. Kayne, and M. F. Leduc. Experimental Program for
the Control of Organic Emissions from Protective Coating Operations.
Report No. 7, Los Angeles APCD. 1961.
73. Lund, H. F. Industrial Pollution Control Handbook. New York, McGraw-
Hill, 1971. p. 13-13, 19-10.
74. Letter from McKirahan, R., American Can Company to Gallagher, V. U.S.
Environmental Protection Agency. July 29, 1976. Guidelines for
control of organic emissions.
4-18
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75.
76.
77.
Trip Report,
Can Company,
Gallagher, V.
Lemogue, PA.
, Environmental Protection Agency to American
January 22, 1976.
Telecon. Massoglia, M.
Mobil Chemical Company.
Research Triangle Institute with Gerhardt, G.
June 26, 1980. Beverage can surface coating.
Letter from McKirahan, R., American Can Company to Gabris, T., Debell
and Richardson, Inc. (now Springborn Laboratories). February 5, 1976.
Industrial surface coating questionnaire.
4-19
-------
-------
5. MODIFICATION AND RECONSTRUCTION
Under section 111 of the Clean Air Act of 1970, emission standards may
be established for new stationary sources. The New Source Performance
Standards (NSPS) apply to affected facilities which are located primarily
at newly constructed plants in certain source categories. An affected
facility may be defined as a single emission point, a group of emission
points, a line, or an entire plant.
NSPS can also apply to existing facilities that are modified or recon-
structed. Provisions applicable to modifications and reconstructions
appear in the Code of Federal Regulations (40 CFR 60), "Environmental
Protection Agency Regulations on Standards of Performance for New Stationary
Sources," under Subpart A, "General Provisions," Sections 60.14 and 60.15.
5.1 MODIFICATION
Modification is defined in 40 CFR as "any physical change in, or
change in the method of operation of, an existing facility which increases
the amount of any air pollutant (to which a standard applies) emitted into
the atmosphere by that facility or which results in the emission of any
pollutant (to which a standard applies) into the atmosphere not previously
emitted." For purposes of modification emissions are measured in terms of
kilograms per hour.
In certain circumstances, however, such changes are not considered
modifications. If, for example, the change is made to increase the produc-
tion rate of an existing facility within design rates and does not involve
a capital expenditure on the stationary source containing that facility, it
is not considered a modification. A capital expenditure is an amount more
than the current annual asset guideline repair allowance, which is calcu-
lated using the rates for various industries tabulated in Internal Revenue
Service Publication 534.
5-1
-------
There are other exceptions to the definition of modification. In a
beverage can plant, simply increasing the line speed (cans per minute)
within design limits does not constitute a modification. Increasing actual
operating hours by running three shifts rather than two per day, or extend-
ing 8-hour shifts to 10, also is not a modification. In addition, routine
repair, maintenance, and replacement of worn parts in a facility are not
modifications.
According to 40 CFR 60.14(3)(4), use of an alternate raw material does
not constitute a modification if it can be demonstrated that the existing
facility was designed to accommodate that alternative use. Therefore, the
use of alternative coating materials which would increase emissions, would
not be a modification if the existing facility was designed to use these
materials. Such changes are not likely to occur.
If a change to a can coating line involved the installation of equip-
ment primarily to reduce solvent emissions, this change would not be a
modification.
Other possible changes that could result in increased VOC emissions
include:
Change to Larger Cans. If can sizes were increased and the
same production rates were maintained, more coating materials
would be used and more solvents would be emitted. This would
occur if a line producing two-piece 12-ounce beverage cans were
converted to the production of 16-ounce cans. Many facilities
are designed to permit routine changes of can size.1
Change to Thicker Coatings. A change to a thicker coating, if
other factors remain constant, could result in increased solvent
emissions. For example, changing from production of two-piece
aluminum cans for malt liquor to two-piece aluminum cans for soft
drink use would require the application of a thicker inside spray
coating. Changing from two-piece aluminum to two-piece steel
would require the application of a thicker exterior base coat.
Both of these examples result in increased coating use and conse-
quently increased solvent emissions. In merchant can plants, the
ultimate users of the cans may require different coating thick-
ness. Thus, the canmaker would be required to change the thick-
ness of coating applied or production lots change. Within design
limits of the can line, these changes require only an adjustment
to the coater.
Additional Coating Stations. If for any reason one or more
coating stations were added, emissions would be increased. For
example, for aluminum two-piece cans for soft drinks, the inner
5-2
-------
lacquer is deposited in one application, while for steel two-piece
cans, the lacquer is generally applied in two coats. When a line
is converted from aluminum to steel cans, additional stations
might be required for the inside spray coat. In some instances
the additional spray station may have been built into the line.
5.2 RECONSTRUCTION
While modification refers to comparatively minor changes in a facility
or its method of operation, which result in an increase in emissions,
reconstruction refers to a substantial change in an existing facility,
regardless of change in emission rate. As with a modified facility, a
reconstructed existing facility, by definition, becomes an affected facil-
ity and subject to NSPS.
A reconstructed facility is defined as one in which:
The fixed capital cost of the new components exceeds 50 percent
of the fixed capital cost that would be required to construct a
comparable entirely new facility, and
It is technologically and economically feasible to meet the
standards.
Roll and mandrel coaters, spray units, and ovens used in coating
beverage cans generally last more than 20 years2 3 4 5 and are not replaced
before that time unless process changes dictate it. In some cases, a line
may be moved to another location within a plant and ovens may deteriorate,
requiring some rebuilding. Ultimately, however, worn out or obsolete units
must be replaced, and such changes, if they meet the above requirements,
qualify as reconstructions.
Ovens could be replaced with more efficient models using recirculating
inert air6 or alternate energy sources, such as oil or electricity. Again,
this would be considered a reconstruction if the above requirements were
met.
5.3 REFERENCES
1. Letter. Donaldson, R., Reynolds Aluminum Can Division, to Drake, W.,
Research Triangle Institute. January 31, 1980. Response to request
for comments on Draft BID chapters 3-6. p.4.
2. Trip Report. Gabris, T., Springborn Laboratories Inc., to Continental
Can Company, Sparrows Point, MD. January 28, 1976.
5-3
-------
3. Trip Report. Gabris, T. , Springborn Laboratories, Inc., to American
Can Company, Plant No. 025, Edison, NJ. December 29, 1975.
4. Trip Report. Gabris, T., Springborn Laboratories Inc., to National
Can Corporation, Danbury, CT. April 27, 1976.
5. Trip Report. Gabris, T., Springborn Laboratories Inc., to American
Can Company, Baltimore, MD. January 22, 1976.
6. Midland-Ross Corp. Product Bulletin INA-777. Ross Inertair Oven
Systems Reduce Fuel Consumption by up to 90%. Ross Air Systems Divi-
sion. New Brunswick, NJ.
5-4
-------
6. MODEL PLANTS AND REGULATORY ALTERNATIVES
This chapter presents a number of regulatory alternatives that will
be used in analyzing the range of environmental impacts (Chapter 7) and
economic impacts (Chapter 8) associated with the control of VOC emissions
from the beverage can surface coating industry. Individual emission
control technologies applicable to can surface coating operations are
described and evaluated in Chapter 4.
An emission control system can be either a coating material and
application technique, an add-on control device, or a combination of the
two. The choice of systems depends on the particular coating operation
and the degree of control desired.
Cans are made in one of two ways. The "two-piece" can is drawn and
wall-ironed from a shallow steel or aluminum cup and requires only one
aluminum end, which is attached after the can is filled with a product.
Forming and coating of two-piece cans are accomplished under one roof.
The aluminum ends may be made at a separate plant.
"A "three-piece" can is made from a rectangular sheet (body blank)
and two circular ends. The metal sheet is rolled into a cylinder and
soldered, welded, or cemented at the seam. One end is attached during
manufacturing, the other during packaging of the product. The body
blanks and the end stock may be coated at one facility and formed into
can bodies and ends at another. In some cases the ends themselves may be
made at a separate facility. The can body and the bottom ends are made
of tinplate steel or tin-free steel. The top is made of aluminum.
6.1 MODEL PLANTS
Because of the nature of the industry and the possible fragmentation
of three-piece can facilities, five sets of model plants are considered
appropriate. Coating formulations and emission data for the model plants
6-1
-------
are presented in Tables 6-1 through 6-4 and operating parameters in
Tables 6-5 and 6-8. The following coating operations are considered:
Two-piece aluminum- and steel-can integrated facility (Tables 6-1)
and 6-6)
Exterior base coat
Lithography and overvarnish
Inside spray (2 applications for steel cans)
Three-piece steel-sheet coating (Tables 6-2 and 6-7)
Exterior base coat
Interior base coat
Lithography and overvarnish
Three-piece steel-can forming (Tables 6-3 and 6-8)
Inside spray
Steel- and aluminum-end sheet coating (Tables 6-4 and 6-9)
Exterior base coat
Interior base coat
Steel- and aluminum-end forming (Tables 6-5 and 6-10)
End-sealing application
Although there are many alternatives for controlling emissions from
can surface coating operations, the alternatives shown in Tables 6-1
through 6-4 are considered representative and only these options are
applied to the model plants.
Model plant extensive parameters, presented in Tables 6-1 through
6-10 with emission rates based on 1,000 cans or ends produced, are inde-
pendent of production rate. Except for the application of end-sealing
compound, emissions from these plants are further classified as coming
from the coater-flashoff area and cure oven.
Descriptions of the model plants follow.
6.1.1 Two-Piece Beverage Cans
While each coating and forming line is a complete facility in itself,
more than one line are usually found within a beverage can plant. Recently
constructed two-piece can plants have contained two to six lines.1 2345
Two sizes of plants are presented for analyzing the economic impact
of regulatory alternatives for the control of VOC emissions from two-piece
beverage can plants.
6-2
-------
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6-7
-------
TABLE 6-6. SUMMARY OF MODEL PLANT PARAMETERS,
TWO-PIECE CAN SURFACE COATING3
(All Data Are per 1,000 Cans Unless Otherwise Indicated)
Emission control optian
Base case
IA
IB"
1C
ID
VOC emissions
kg K
Mg/year, small scale
Mg/year, large scale
Ventilation aird
scf, 100 ppmv
scf , 500 ppmv
acf, 100 ppmv
acf, 500 ppmv
Cure ovens6
scf, small scale
scf, large scale
acf, small scale
acf, large scale
Btu, small scale
Btu, large scale
10s Btu/year, small scale
106 Btu/year, large scale
Incinerator
scf, small scale
scf, large scale
acf, small scale
acf, large scale
Btu, small scale
Btu, large scale
106 Btu/year, small scale
106 Btu/year, large scale
0.392
157
940
22,660
4,530
24,415
4,885
8,565
7,500
14,980
13,110
80,590
73,820
32,240
177,200
0.235
94
564
11,040
2,210
11,910
2,380
8,565
7,500
14,970
13,110
79,700
79,250
31,880
175,100
10,560
9,495
17,140
15,270
134,750
124,100
53,900
297,800
0.167
67
401
7,070
1,415
7,615
1,525
5,710
5,000
9,980
8,740
52,160
47,660
20,860
114,400
7,275
6,565
11,670
10,430
93,120
82,460
37,250
197,900
0.267
107
641
15 ,480
3,095
16,680
3,335
8,565
7,500
14,970
13,110
79,930
73,180
31,970
175,600
0.226
90
542
8,830
1,765
9,510
1,900
5,710
5,000
9,980
8,740
52,420
47,920
20,968
115,000
Emission distribution used in developing model plant parameters.
For external base coat and overvarnish
Coater and flashoff
Cure oven
For inside spray
Coater and flashoff
Cure oven
75
25
80
20
Small-scale plant—700 cans/rain, 400 million cans/year.
°Large-scale plant 800 cans/min, 2,400 million cans/year.
At 70° F. Aggregate of all coating operations.
At 400° F. Separate cure oven for exterior base coat, lithography/overvarnish and inside spray.
Data are aggregates of these coatings steps.
Incinerator parameter: primary heat recovery—35 percent, afterburner temperature--1,400° F. One
incinerator serves all coating operations. Secondary heat recovery limited to that attainable at
15 percent LEL.
6-8
-------
TABLE 6-7. SUMMARY OF MODEL PLANT PARAMETERS,
THREE-PIECE STEEL CAN SHEET COATING3
(All Data Are per 1,000 Cans Equivalent Unless Otherwise Indicated)
Emission control option
Base case
IIA
IIB
IIC
Emission distribution in developing model plant parameters. For all coating operations.
Coater-flashoff
Cure oven
10
90
.110
VOC emissions
kg b
Mg/year, small scale.
Mg/year, large scaleu
Ventilation aird
scf, 100 ppmv
scf, 500 ppmv
acf, 100 ppmv
acf, 500 ppmv
Cure ovens
scf, small scale
scf, large scale
acf, small scale
acf, large scale
Btu, small scale
Btu, large scale
10s Btu/year, small scale
106 Btu/year, large scale
Incinerator
scf, small scale
scf, large scale
acf, small scale
acf, large scale
Btu, small scale
Btu, large scale
10s Btu/year, small scale
10s Btu/year, large scale
0.234
94
187
1,790
358
1,930
385
1,905
1,560
3,330
2,730
32,590
30,400
13,040
24,320
0.073
29
58
490
100
530
105
3,445
3,445
6,025
6,025
39,880
39,880
15,950
31,900
3,630
3,630
6,225
6,225
27,230
27,230
10,890
21,780
0.064
26
51
395
80
435
85
2,780
2,780
4,865
4,865
29,750
29,750
11,900
23,800
2,945
2,945
5,050
5,050
26,870
26,870
10,750
21,500
0.215
86
172
1,600
321
1,725
345
1,905
1,560
3,330
2,725
31,120
28,920
12,450
23,140
0.180
72
144
1,340
268
1,445
289
1,270
1,040
2,220
1,820
20,990
19,430
8,395
15,540
Small scale—90 sheets/rain, 400 million cans/year.
cLarge scale—110 sheets/min, 800 million cans/year.
At 70° F. Aggregate of all coating operations.
8At 400° F. Separate cure oven for external base coat, internal base coat, and lithography/overvarnish.
Data are aggregates of these coatings steps.
Incinerator parameters: primary heat recovery—35 percent, afterburner temperature: 1,400° F. One
incinerator serves all coating operations. Secondary heat recovery limited to that attainable at
15 percent LEL.
6-9
-------
TABLE 6-8. SUMMARY OF MODEL PLANT PARAMETERS
THREE-PIECE STEEL CAN INSIDE SPRAY3
(All Data Are per 1,000 Cans, Unless Otherwise Indicated)
Emission control option
VOC emissions
kg
Mg/year, small scale
Mg/year, large scale
Ventilation air
scf, 100 ppmv
scf, 500 ppmv
acf, 100 ppmv
acf, 500 ppmv
Cure ovens6
scf, small scale
scf, large scale
acf, small scale
acf, large scale
Btu, small scale
Btu, large scale
106 Btu/year, small
106 , Btu/year , 1 arge
Incinerator
scf, small scale
scf, large scale
acf, small scale
acf, large scale
Btu, small scale
Btu, large scale
106 Btu/year, small
106 Btu/year, large
aEmission distribution
Coater
Base case
. 0.207
c 83
c 166
12,350
2,470
13,300
2,660
926
1,850
1,620
3,235
12,710
18,580
scale 5,085
scale 14,860
scale
scale
used in developing model
and flashoff 80
Option IIIA Option IIIB
0.086
34.4
68.8
2,990
598
3,220
644
926
1,850
1,620
3,235
12,290
18,146
4,910
14,510
2,650
2,975
2,830
4,445
20,646
34,740
8,255
27,790
plant parameters.
0.107
43
86
6,380
1,275
6,875
1,375
926
1,850
1,620
3,235
12,540
18,410
5,016
14,730
Cure oven 20
Small scale, 400 million cans/year.
'Large scale, 800 million cans/year.
At 70° F. Includes coater and flashoff.
3At 400° F.
Incinerator parameters: primary heat recovery—35 percent, afterburner
temperature--!,400° F. Secondary heat recovery limited to that attainable
at 15 percent LEL.
6-10
-------
TABLE 6-9. SUMMARY OF MODEL PLANT PARAMETERS
STEEL- AND ALUMINUM-END SHEET COATING
(All Data Are per 1,000 Ends, Unless Otherwise Indicated)
Emission control option
Base case
Option IVA
Option IVB
VOC emissions
kg b
Mg/year
Ventilation airc
0.0305
34
0.0137
15
0.0145
16
scf, 100 ppmv
scf, 500 ppmv
act, 100 ppmv
acf, 500 ppmv
Cure ovens
scf
acf
Btu
106 Btu/year
Q
Incinerator
scf
acf
Btu
106 Btu/year
2,275
455
2,450
490
336
589
11,310
12,440
540
110
580
116
336
589
11,110
12,200
336
589
2,620
2,880
108
22
116
23
336
589
11,170
12,290
aEmission distribution used for all coating operations in developing model
plant parameters.
Coater and flashoff 10
Cure oven 90
Based on 1.1 billon ends per year.
GAt 70° F. Includes coater and flashoff.
At 400° F. Separate cure ovens for exterior and interior basecoater. Data
are aggregate of exterior and interior base coat.
elncinerator parameters: primary heat recovery—35 percent, afterburner
temperature—1400° F. One incinerator serves both exterior and interior
base coating. Secondary heat recovery limited to that attainable at
15 percent LEL.
6-11
-------
Based on 1.1 billion ends per year.
DAt 70° F.
TABLE 6-10. SUMMARY OF MODEL PLANT PARAMETERS,
END FORMING (STEEL AND ALUMINUM), APPLICATION OF
END-SEALING COMPOUND
(All Data Are per 1,000 Ends Under Otherwise Indicated)
Emission control option
Base case VA VB
Aluminum ends
VOC emissions
kg 0.071 0.071 0.0036
Mg/yra 78 78 4
Ventilation air
scf, 100 ppmv 5,290 5,290
scf, 500 ppmv 1,060 1,060
acf, 100 ppmv 5,700 5,700
acf, 500 ppmv 1,140 1,140
Steel ends
VOC emissions
kg 0.108 0.108 0.0053
Mg/yra 189 189 6
268
54
289
58
Ventilation air
scf, 100 ppmv
scf, 500 ppmv
act, 100 ppmv
acf, 500 ppmv
8,050
1,610
8,675
1,735
8,050
1,610
8,675
1,735
395
79
426
85
6-12
-------
Number of can lines
Production rate, each line,
cans per minute
Operating hours per year
Annual production, million cans
Small scale
700
4,700
400
Large scale
6
800
8,400
2,400
One United States can-line vendor has developed a modular 500-can-per-
minute line that is preassembled on pallets, tested, and then shipped in
40 foot sections for installation and assembly. There are no plants of
this type currently in operation in the United States. One plant is
scheduled for installation for a national can manufacturer in 1980. No
other U.S. orders are outstanding. However, negotiations are underway
for one additional plant.6 7 The present and near-future status of this
size of facility is not considered significant enough to warrant the
inclusion of a 500-can-per-minute facility as a model plant at this time.
6.1.2 Three-Piece Beverage Cans
No record could be found of construction of three-piece beverage can
plants within the past five years. The industry indicates an overcapacity
because of the trend toward two-piece cans.8 9 10 However, two sizes of
plants are postulated for analyzing the economic impact of regulatory
alternatives for the control of VOC emissions from three-piece beverage
can plants that may be modified or reconstructed.
6.1.2.1 Small-Scale Three-Piece Can Plant. A small-scale three-piece
beverage can plant produces beverage cans on a job-lot basis for customers
requiring a modest number of cans for only a few product lines. Clientele
is probably limited to regional' soft drink plants and breweries.
Three-piece cans are in demand for soft drinks. The annual production
of soft drink cans is currently about 25 billion units, with growth
projected at approximately 7 percent.11 Thus, there appears to be a need
for 250-500 million incremental units of capacity every year. It is not
unreasonable, then, to postulate a new facility with an annual capacity
of 400 million units.
One base coater, operating 4,240 hours a year at 90 sheets per
minute, is used to apply the exterior and interior base coats. One
printing line satisfies the decoration and lithography requirements. The
6-13
-------
can-forming operation might consist of 12 body lines, each rated at three
can bodies per second, serving one inside spray line and associated cure
oven. The capacity factor for compatibility is 3,090 hours per year.
Steel and aluminum ends are assumed to be purchased from larger
beverage can facilities and other suppliers.
6.1.2.2 Large-Scale Three-Piece Can Plant. The product of this
plant is the same as that of the small-scale three-piece can plants, with
perhaps a greater variety of decorating to suit a more diverse clientele.
The hardware and methods are similar, with a capacity of 800 million cans
per year achieved by twice as many lines as a small-scale plant. The
principal difference in operating style is that this plant will make its
own steel ends and, in fact, export some of them to smaller plants such
as the one already described.
The justification for a three-piece plant of this scale, in view of
the market description in Section 6.1.2, is tenuous. If such a plant
were to be built, it would probably be in a densely populated region of
the sunbelt such as southern California.
Two coating lines rated at 110 sheets/minute are postulated, with
35 can bodies per sheet at capacity factors of 3,460 hours/year. Because
neither line need be dedicated to any particular coat, scheduling is more
flexible and changeover down-time can be reduced.
There are also two printing lines. The assumed higher population
density in the region permits larger filling plants and longer runs of
particular designs. To be compatible with the coating machines requires
a line speed of 90 sheets/minute and a capacity factor of 2,120 hours/year.
The can-forming operation might consist of 18 body lines, each rated
at three can bodies per second, serving three ovens for curing the inside
spray. The capacity factor for compatibility is 4,120 hours/year.
6.1.3 End-forming Plants
Steel ends are made from coated sheets, and aluminum ends from
coated sheets or precoated coils. Precoated coils are not included in
beverage can surface coating model plants. This activity is subject to
proposed coil surface coating standards. Two model plants are applicable
to beverage can ends, (1) steel or aluminum sheet coating and (2) steel-
or aluminum-end forming.
6-14
-------
6.1.3.1 Steel- or Aluminum-Sheet Coating. An exterior and an
interior coat are applied to steel or aluminum sheets from which ends are
formed. These coatings are applied on one machine dedicated to end stock
coating running 90 sheets/minute, with a capacity factor of 1,540 hours/
year for each coat.
6.1.3.2 Steel- or Aluminum-End Forming. End blanks are stamped out
from coated sheets. Aluminum ends are also formed from precoated coils.
A battery of sampling; shallow drawing; rolling machines; and, for ends
used as tops for beverage cans, tab forming and processing machines are
used. Rated speeds are from five to ten ends per second with an annual
production rate of 1.1 billion ends per year. Following stamping of the
ends, end-sealing compound is applied. The finished ends are packaged in
paper sleeves, and stored at the end plant for a minimum of 48 hours for
adequate air drying of the end-sealing compound.
6.2 BASE CASE
Although many plants in operation today use solvent-borne coatings,
the trend is toward waterborne systems.2 s 4 s 9 12 is Waterborne coat-
ings were used in developing emission limitations recommended in the CTG
for can surface coating operations.14 State Implementation Plans are
currently undergoing revision to require emission limitations at least as
stringent as those recommended in the CTG. Accordingly the use of water-
borne coatings meeting emission limitations recommended in the CTG, for
all can surface coating operations is properly considered the base case
for the manufacture of two- and three-piece steel cans, two-piece aluminum
cans, and steel ends. Solvent-based end-sealing compounds meeting the
CTG emission limitations are the base case emissions for each of the
model plants are shown in Tables 6-1 through 6-5, stated per thousand
cans or ends.
6.3 REGULATORY ALTERNATIVES
This section presents a discussion of the regulatory alternatives to
be considered for the beverage can industry. The impacts on emissions
for each regulatory alternative are discussed in Chapter 7 of this docu-
ment.
6-15
-------
The following emission control options, described in detail in
Chapter 4, were considered in developing regulatory alternatives for
beverage can surface coating operations.
a. Incineration, thermal (solvent borne). VOC emissions from
solvent-borne coatings, carried in vapor form in air, are
heated with the carrier air to, for example, 1,400° F to
burn or oxidize the VOC materials exothemically, essentially
to carbon dioxide and water vapor. Primary heat recovery is
provided, in which a portion of the heat is recovered by
using the incinerator exhaust gases to preheat the incoming
process gas stream. Control efficiency is nominally 90 per-
cent of the emissions captured.
b. Incineration, catalytic (solvent borne). VOC emissions from
solvent-borne coatings, carried in vapor form in air, are
preheated with the carrier air to, for example, 600° F, then
passed through a precious metal catalyst bed to burn or
oxidize the VOC materials exothemically, essentially to
carbon dioxide and water vapor. Primary heat recovery is
provided, in which a portion of the heat is recovered by
using the incinerator exhaust gases to preheat the incoming
process gas stream. Control efficiency is nominally 90 per-
cent of the emissions captured.
c. Low solvent—waterborne. This option entails the use of
coating in which the volatiles portion consists of water and
volatile organic compounds with about 80 percent being water.
d. UV cure. The solvent-borne overvarnish is replaced by a
100 percent solids UV curable overvarnish composition which
contains monomers that cure or polymerize under the influence
of ultraviolet radiation and moderate heat. Although no VOC
is present in the system, up to 5 percent of the coating
weight may be vaporized in the oven.
e. No-varnish inks. The solvent-borne overvarnish applied over
lithographic inks is replaced by a system based on abrasion-
resistant inks which eliminate the need for overvarnish to
protect the printing and decoration.
f. Water-based end-sealing compounds. The solvent-based end-
sealing compound meeting the emission limitation recommended
in the CTG is replaced by a water-based compound formulated
with no VOC.
The first regulatory alternative considered is no additional regula-
tion. Under this alternative, emissions from beverage can plants would
continue to be governed by State regulations. Existing beverage can
6-16
-------
plants located in ozone nonattainment areas will be subjected to SIP
emission limitations generally based on the Control Technique Guideline
document (CTG). New plants located in ozone nonattainment areas will be
required to limit emissions to the lowest achiebable emission rate (LAER)
and new plants in attainment areas to best available control technology
(BACT). For beverage cans EPA has generally considered both LAER and
BACT to be equivalent to the emission limitations recommended in the CTG.
(The promulgation of an NSPS equivalent to the CTG limitations would have
the same impact as no NSPS and is therefore not included as a separate
regulatory alternative.)
The second regulatory alternative considered is one based on emis-
sion limitations resulting from the use of best available waterborne
coatings for all coating operations. Similar reductions are attainable
by the use of solvent-borne coatings and add-on controls. For end-sealing
compounds, emission limitations based on the use of water-based materials
with no VOC content are used in this regulatory alternative. Emission
reduction resulting from this regulatory option, and incineration require-
ments if a facility elects to use solvent-borne coatings, are shown in
Table 6-11. Other alternative emission control systems under the second
regulatory alternative include eliminating the exterior base coat, elimi-
nating the need for overvarnish through the use of no-varnish inks, or
the use of UV-curable overvarnish coatings.
The third regulatory alternative is the same as the second except
that no-varnish inks or UV-curable overvarnishes are used for lithography/
overvarnish operations. Emission reductions resulting from this regulatory
option, and incineration requirements if a facility elects to use solvent-
borne coatings, are shown in Table 6-12. Elimination of a coating opera-
tion, e.g., exterior base coat, is also a viable alternative emission
control system under the third regulatory alternative.
6-17
-------
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6-19
-------
6.4 REFERENCES
1. Memorandum from Massoglia, M., Research Triangle Institute, to the
Record. April 26, 1979. Trip Report: Visit to Winston-Sal em Plant,
Container Division, Joseph Schlitz Brewing Company.
2. Telecon. Massoglia, M., Research Triangle Institute with Menke, R.,
Reynolds Aluminum. July 26, 1979. Can surface coating.
3. Memorandum from Massoglia, M., Research Triangle Institute, to the
Record. July 9, 1979. Trip Report: Visit to Jacksonville Plant,
Metal Container Corporation.
4. Memorandum from Gabris, T., Springborn Laboratory, Inc., to the Record.
April 27, 1976. Trip Report #128, National Can Corporation, Danbury, CT.
5. Telecon. Massoglia, M., Research Triangle Institute with DeMoss, P.,
Metal Container Corporation. August 6, 1979. Can surface coating.
6. Telecon. Massoglia, M., Research Triangle Institute with Cook, D.,
Container Technology, Inc. September 17, 1979. Beverage can plants.
7. Telecon. Massoglia, M., Research Triangle Institute with Cook, D.,
Container Technology, Inc. September 25, 1979. Beverage can plants.
8. Telecon. Massoglia, M., Research Triangle Institute with Ambrose, T.,
American Can Company. June 28, 1979. Can surface coating.
9. Telecon. Massoglia, M., Research Triangle Institute with Payne, G.,
The Can Manufacturers Institute. August 1, 1979. Can surface coating.
10. 1979 Industrial Outlook. U.S. Department of Commerce. Washington,
D.C. January 1979. p. 82.
11. Beverage Industry. Annual Manual, 1976-1977, p. 130.
12. Telecon. Massoglia, M., Research Triangle Institute with Tolosky, E.,
Crown Cork and Seal Company. August 1, 1979. Can surface coating.
13. Telecon. Massoglia, M., Research Triangle Institute with Kosiba, R.,
National Can Corporation. August 3, 1979. Can surface coating.
14. Control of Volatile Emissions from Existing Stationary Sources, Vol-
ume II: Surface Coating of Cans, Cork, Paper, Fabrics, Automobiles,
and Light-Duty Trucks. U.S. Environmental Protection Agency. Research
Triangle Park, N.C. Publication No. EPA-450/2-77-008. May 1977.
pp. iii-v.
6-20
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7. ENVIRONMENTAL IMPACT
7.1 AIR POLLUTION IMPACT
7.1.1 General
Metal can surface coating lines are major point sources of solvent
emissions. The coatings contain volatile organic compounds (VOC) that are
released into the air as the coatings dry. The metal can surface coating
industry is one of several industries which apply solvent compound coatings
that generate VOC emissions. In 1973, total United States consumption of
solvent in paints and coatings was about 1,900,000 Mg (4,185 million
pounds),1 2 of which 1,285,000 Mg (2,820 million pounds) were used directly
in the manufacture of coating materials, and 620,000 Mg (1,365 million
pounds) were used as thinner and for other miscellaneous purposes.2 Solvent
consumption in metal container coatings for 1979 is estimated at 134,000 Mg
(295 million pounds), projecting from 1973 data and assuming a stable ratio
of solvent usage to number of containers.
Solvent emissions from the beverage can industry occurs in the applica-
tion, flashoff, and curing operations. The baseline emissions that are
used to determine the incremental environmental impact of new source per-
formance standards are emissions that would result with the emission limita-
tion recommended in the control technique guideline document for metal can
surface coating.3 Emissions based on the CTG limitations are shown in
Table 7-1.
The objective of new source performance standards is to limit pollut-
ant emissions, to the level achieved by the best system of continuous emis-
sion system, as determined by the Administrator. Several alternative VOC
emission control option have been identified for beverage can surface
coating operations.
The following sections discuss state regulations and the impact of each
regulatory alternative on VOC emissions. Emissions under each alternative
7-1
-------
TABLE 7-1. BASELINE EMISSIONS, BEVERAGE CAN
SURFACE COATINGS3
Coating operation
kg VOC/1,000
units
Two-piece steel and aluminum cans
Exterior base coat
Overvarnish
Inside spray
Total
Three-piece steel sheets
Exterior base coat
Interior base coat
Overvarnish
Total
Three-piece steel can bodies
Inside spray
Sheet coating, steel or aluminum ends
Exterior base coat
Interior base coat
Total
End forming (aluminum and steel)
End-seal ing application, aluminum
End-sealing application, steel
0.137
0.054
0.201
0.392
0.137
0.045
0.045
0.227
0.189
0.0041
0.0158
0.0199
0.071
0.108
Based on emission limitations recommended in the CTG.
7-2
-------
emission control system that could serve as a basis for standards are
compared to assess the environmental impact and degree of emission control
achieved by each system. Other environmental impacts, such as potential
water pollution and solid waste generation, are also assessed.
7.1.2 State Regulations and Controlled Emissions
In August 1971, Los Angeles County, California, adopted Rule 66, which
controlled organic compound emissions. In 1976, Rule 66 was supplanted by
South Coast Air Pollution Control District (SCAPCD)* Rule 442, which had
similar provisions. Rule 442 states that emissions of photochemically
reactive solvents^ are not to exceed 18 kilograms (39.6 pounds) per day and
emissions of nonphotochemically reactive solvents are limited to 1,350
kilograms (2,970 pounds) per day. Emissions from organic materials that
come into contact with flame or are baked are limited to 6.5 kilograms
(14.3 pounds) per day. Emissions above these limits are subject to 85 per-
cent emission control. The regulation also provides exemptions for water-
based coatings if the volatile content is 8d percent water.
^Replaced by the South Coast Air Quality Management District (SCAQMD) on
February 1, 1977.
'Photochemically reactive solvent means any solvent with an aggregate, or
more than 20 percent of its total volume, composed of the chemical com-
pounds classified below, or which exceeds any of the following individual
percentage composition limitations, referring to the total volume of
solvent:
a. A combination of hydrocarbons, alcohols, aldehydes, ethers,
esters, or ketones having an olefinic or cycloolefinic type of
unsaturation except perchloroethylene: 5 percent
b. A combination of aromatic compounds with eight or more carbon
atoms to the molecule except ethyl benzene, methylbenzoate, and
phenyl acetate: 8 percent
c. A combination of ethylbenzene, ketones with branched hydrocarbon
structures, trichloroethylene or toluene: 20 percent
Whenever any organic solvent or any constitutent of an organic solvent may
be classified from its chemical structure into more than one of the above
groups of organic compounds, it shall be considered a member of the most
reactive chemical groups, that is, that group having the least allowable
percent of the total volume of solvents.
7-3
-------
A review of state VOC regulations published in The Environmental
Reporter (July 1979) shows a wide range of control requirements. A summary
of the state VOC regulations is presented in Table 7-2. Six states have
rules specific to surface coating operations; 21 states (including the
District of Columbia and Puerto Rico) specify numerical emission limits for
VOC in mass per unit of time; nine states have broadly worded general rules
requiring that "reasonable care" be exercised to reduce organic emissions.
Almost half the states have no rules or regulations except for the storage,
loading, and transfer of volatile organic compounds where large tanks and a
high throughput are involved, e.g., petroleum distribution systems.
The regulations of 15 of the states specifying numerical emission
limits appear to have been modeled after Regulation IV of the California
South Coast Air Quality Management District. Typically, emission limits
are given for equipment where any organic materials are exposed to high
temperatures and where photochemically reactive materials are used or
applied. These provisions clearly cover drying ovens and coating facili-
ties, although they are not named directly. In addition, some state regula-
tions include provisions controlling the use of nonphotochemically reactive
solvents, drying of articles after removal from equipment, cleanup opera-
tions, acceptable methods of control (incineration, adsorption, etc.), and
disposal of waste solvents. Exemptions are usually granted where waterborne,
high-solid, or low-organic coating materials are used.
There are many variations and interpretations of requirements among
states that have Rule 442-type regulations. There has been considerable
debate at both the State and Federal levels over what constitutes a photo-
chemically reactive solvent and a nonphotochemically reactive solvent. The
situation is further complicated because the States are currently revising
their regulations.
The Clean Air Act Amendment of 1977 requires all states to submit
revised State Implementation Plans (SIP) to EPA for approval by January 1,
1979. Revised SIPs must include strategies demonstrating attainment of
ambient air quality standards for carbon monoxide and photochemical oxidants
by December 31, 1982. An extension to December 31, 1987, may be granted if
it is demonstrated that attainment is not possible by 1982 despite imple-
mentation of reasonably available control technology.
7-4
-------
TABLE 7-2. PROFILE OF ORGANIC EMISSIONS REGULATIONS BY STATES4
Organic solvents
No specific
rule
Alaska
Delaware
Georgia
Hawai i
Idaho
Iowa
Mai ne
Massachusetts
Minnesota
Missouri
Montana
Nebraska
New Jersey
New Mexico
Oregon
South Carolina
South Dakota
Utah
Vermont
Washington
West Virginia
"Reasonable
care"
Arizona
Arkansas
Florida
Kansas
Mississippi
Nevada
New Hampshire
North Dakota
Wyoming
Numerical
emissions
limits
Alabama
California
(SCAQMD)
Colorado
Connecticut
District of
Columbia
Illinois
Indiana
Kentucky
Louisiana
Mary! and
Mary! and
New York
North Carolina
Ohio
Oklahoma
Pennsylvania
(Philadelphia)
Puerto Rico
Rhode Island
Tennessee
Texas
Virginia
Wisconsin
Special can
or surface
coating rules
California
(SCAQMD)
Illinois
Kentucky
Michigan
Texas
Wisconsin
7-5
-------
Attainment of the ozone standard in areas designated as nonattainment
is to be accomplished by a variety of measures, including the application
of reasonably available control technology to VOC sources for which control
technique guideline documents have been published. Such a document has
been published for metal can surface coating operations. Revised SIPs are
currently under review by EPA. In addition, several states have indicated
that VOC emission limitations based on those recommended in the CTG would
also be required in about 515 counties in their jurisdiction that have not
been designated as nonattainment areas.5 This brings the number of counties
subject to CTG emission limitations to over 900. It is estimated that
imposing CTG limitations on metal can surface coating plants located in
these 900 counties would reduce VOC emissions by as much as 113,000 Mg.5
Emission limitations recommended in the CTG for can surface coating are
shown in Table 7-3.
7.1.3 Comparative Emissions from Model Plants Employing Various Emission
Control Options
The various options that have been considered in this document (see
chapter 4) and selected as emission control options are summarized in
Table 7-4. Comparative emissions of model plants using these options are
discussed below for each of the beverage can model plants developed in
Chapter 6.
Annual emissions for each of the model plants are determined by apply-
ing the emission factors, expressed as kilograms of VOC per 1,000 cans,
developed in Chapter 6.
7.1.3.1 Two-Piece Aluminum and Steel Integrated Facility. Two model
plants are assumed for two-piece can manufacturing: a small-scale plant,
with two lines producing 400 million cans per year, and a large-scale
plant, with six lines producing 2,400 million cans per year. Annual emis-
sions for each of these plants for the base case and for emission control
options listed in Table 7-4 are shown in Table 7-5.
7.1.3.2 Three-Piece Can Sheet Coating. Two model plants are assumed
for new sheet coating lines: A small-scale plant coating sheets equivalent
to 400 million cans per year, and a large-scale plant coating sheets equiv-
alent to 800 million.cans per year. Annual emissions for each of these
plants for the base case and for emission control options listed in Table 7-4
are shown in Table 7-6.
7-6
-------
TABLE 7-3. RECOMMENDED CTG EMISSION LIMITATIONS FOR
CAN SURFACE COATINGS3
Recommended limitation
Affected facility
kg per litre
of coating
(minus water)
Ib per gal
of coating
(minus water)
Sheet base coat (exterior and
interior) and overvarnish;
two-piece can exterior
(base coat and overvarnish)
Two and three-piece can interior
body spray, two-piece can
exterior end (spray or roll
coat)
Three-piece can side-seam spray
End sealing compound
0.34
2.8
0.51
4.2
0.66
0.44
5.5
3.7
7-7
-------
TABLE 7-4. EMISSION CONTROL OPTIONS'
I Two-piece aluminum or steel integrated facility
Operations Exterior base coat, lithography/overvarnish, inside spray
Base case CT6 waterborne coatings for all operations
Option IA Solvent-borne coating. Capture and incineration of
coater and cure oven emissions from all operations and
flashoff emissions from inside spray
Option IB Same as IA except no-varnish or UV-cure inks for
1ithography/overvarnish
Option 1C Low-solvent coatings for all operations
Option ID Same as 1C except no varnish or UV-cure inks for
lithography/overvarnish ,
II Three-piece can sheet coatings
Operations Exterior base coat, interior base coat, lithography/
overvarnish
Base case CTG waterborne coatings for all operations
Option IIA Solvent-borne coatings for all operations. Capture
and incineration of coater, flashoff, and cure oven
emissions
Option IIB Same as IIA except no-varnish or UV-cure coatings for
1ithography/overvarnish
Option IIC Low-solvent coatings for all operations
Option IID Same as IIC except no-varnish or UV-cure coatings for
lithography/overvarnish
III Three-piece can forming
Operation Inside spray
Base case CTG waterborne coating
Option IIIA Solvent-borne coating. Capture and incineration of
coater, flashoff, and cure oven emissions
Option IIIB Low-solvent coating
IV
Sheet coating, steel or aluminum ends
Operations Exterior base coat, interior base coat
CTG waterborne coatings for all operations
Solvent-borne coatings for all operations. Capture
Base case
Option IVA
and incineration of coater, flashoff, and cure oven
emissions
Option IVB Low-solvent coating
End forming (aluminum and steel)
Operation End-sealing compound application
Base case CTG solvent-based compound
Option VA CTG solvent-based compound
Option VB Water-based compound
aThese options are identified and described in Chapter 6.
7-8
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7.1.3.3 Three-Piece Steel-Can Forming. Two model plants, a small-
scale plant forming 400 million cans per year and a large-scale plant
forming 800 million cans per year, are assumed. Annual emissions for each
of these plants for the base case and for emission control options listed
in Table 7-4 are shown in Table 7-7.
7.1.3.4 Sheet Coating, Steel or Aluminum Ends. One size model plant
with a capacity of coating sheets to make 1.1 billion ends per year is
assumed. Annual emissions for the base case and for each emission control
option listed in Table 7-4 are shown in Table 7-8.
7.1.3.5 End Forming, Aluminum or Steel. One size model plant with a
capacity of forming 1.1 billion ends per year is assumed for the manufacture
of aluminum ends from precoated aluminum strip or the manufacture of steel
ends from precoated steel sheets. Annual emissions for the base case and
for each emission control option listed in Table 7-4 are shown in Table 7-9.
7.1.4 Estimated VOC Emission Reduction in Future Years
7.1.4.1 General. Growth in total beverage can manufacturing from
1978 to 1983 is estimated at about 5.5 percent per year, based on forecasts
published in Metal Bulletin6 and Modern Packaging.7 Growth in two-piece
aluminum beverage cans is estimated at about 7 percent per year. Annual
production of three-piece steel beverage cans is expected to remain essen-
tially unchanged from 1978 to 1983, while production of two-piece steel
beverage cans is projected to increase by 10 percent per year. These
estimates are the basis of the projections shown in Table 7-10. There are
other industry projections that would change the estimates of 1985 capacity
subject to the NSPS. For example, some industry sources project the demise
of the three-piece can over the next 5 years.8 9 Others indicate that while
the use of three-piece beverage cans will drop, they will still represent
a significant share of the market.6 7
Plants for which construction, modification or reconstruction began
after the proposal date will be subject to the NSPS. The capacity subject
to NSPS is estimated shown in Table 7-11. These projections assume that
5 percent of the 1980 capacity will be subject to NSPS, because of modifi-
cation or reconstruction.
Incremental environmental impact, expressed as changes in VOC emissions,
is the difference between emissions under limitations recommended in the
7-11
-------
TABLE 7-7. EMISSIONS FROM BASE CASE AND EMISSION CONTROL OPTIONS,
THREE-PIECE CAN FORMING (INSIDE SPRAY) (Mg/year)
Small scale
(400 million cans/yr)
Large scale
(800 million cans/yr)
Base case
Option IIIA
Option IIIB
83
34
43
166
69
86
7-12
-------
TABLE 7-8. EMISSIONS FROM BASE CASE AND EMISSION CONTROL OPTIONS,
SHEET COATING, STEEL AND ALUMINUM ENDS
(Mg/year)
Base case
Option IVA
Option IVB
Exterior
base coat
5
2
4
Interior
base coat
29
13
12
Total
34
15
16
7-13
-------
TABLE 7-9. EMISSIONS FROM BASE CASE AND EMISSION CONTROL
OPTIONS, END FORMING (STEEL AND ALUMINUM), END-SEALING
COMPOUND APPLICATION
(Mg/year)
Aluminum
Steel
Base case
Option VA
Option VB
78
78
4
189
189
6
7-14
-------
TABLE 7-10. ANNUAL PRODUCTION OF BEVERAGE CANS, 1978-1985
(billion cans)
Type of can
Two-piece steel
Two-piece aluminum
Three-piece steel
Total
1978
9.
30.
14.
54.
8
1
5
4
1979
10.8
32.1
14.5
57.4
1980
11.
34.
14.
60.
9
1
5
5
1981
13.
36.
14.
63.
0
4
5
9
1982
14.3
38.7
14.5
67.5
1983
15.8
41.2
14.5
71.5
1984
17.4
43.9
14.5
75.8
1985
19.1
46.8
14.5
80.4
Data for 1978 are based on actual production. All other years are
estimates.
7-15
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CTG and emissions under the emission control options. Using the emission
factors developed in Chapter 6 for the base case and the various emission
control options, emission reductions from NSPS through 1985 can be estimated.
These estimates are shown in Table 7-12 for aluminum and steel two-piece
can facilities, Table 7-13 for three-piece can sheet coating, Table 7-14
for three-piece can forming, Table 7-15 for sheet coating for steel or
aluminum ends, and Table 7-16 for aluminum or steel end forming.
No emission reductions would result under Regulatory Alternative I.
Regulatory Alternative II would reduce emissions in 1985 by 9,782 Mg per
year, Regulatory Alternative III by 11,205 Mg per year. Reductions from
individual beverage can surface coating operations presented in Table 7-12
through 7-16 are summarized in Table 7-17.
7.2 WATER POLLUTION IMPACT
Because there are no process water streams in can coating operations,
the problem of water pollution from coating operation discharges to plant
effluent wastewater streams normally does not exist. However, there are
opportunities for intermittent discharge of pollutants to plant effluent
wastewater streams when low-sol vent waterborne coatings are used. This
problem is essentially the same under all control options using waterborne
coatings.
The use of low-solvent waterborne coatings could result in water
pollution during cleaning of coating equipment at the ends of coating runs.
Where solvent-borne coatings are used, the solvents are normally not misci-
ble with water, and equipment is cleaned with organic cleaning solvents
also not miscible with water. Residual solvent-borne coating material in
the reservoir of the coating machine is recovered and collected at the end
of a coating run, together with the cleaning solvent for reuse in future
coating runs. Small quantities of cleaning solvent contaminated with dirt,
foreign matter, and coating material may not be reusable, but because the
solvents are not miscible with water, the waste is not discharged into
plant effluent wastewater streams.
However, where waterborne coatings are used, water with soap or deter-
gent is used for equipment cleanup. While residual waterborne coating
material on the coating machine at the end of a run is recovered and col-
lected for reuse, cleaning water contaminated with dirt, foreign matter,
7-17
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-------
TABLE 7-14. EMISSION REDUCTIONS FROM EMISSION CONTROL OPTIONS,
THREE-PIECE CAN FORMING, 1985a
Coating operation
Base case
kg/103
units Mg
Option IIIA
kg/103
units Mg
Option IIIB
kg/103
units Mg
Inside spray
Reduction from NSPS
0.230 644 0.097 272 0.119 333
372 311
Affected capacity is based on 2.8 billion can equivalents subject to NSPS
in 1985.
3Based on 90 percent transfer efficiency.
7-20
-------
TABLE 7-15. EMISSION REDUCTIONS FROM EMISSION CONTROL OPTIONS,
SHEET COATING, STEEL AND ALUMINUM ENDS, 1985a
Coating operation
Exterior base coat
Interior base coat
Total
Reduction from NSPS
Base
kg/103
units
0.0042
0.0263
0.0305
case
Mg
86
550
636
—
Option
kg/103
units
0.0016
0.0122
0.0138
IVA
Mg
33
255
288
348
Option
kg/103
units
0.0040
0.0105
0.0145
IVB
Mg
84
219
303
333
Affected capacity is based on 3.5 billion steel ends and 17.4 billion
aluminum end equivalents subject to NSPS in 1985.
7-21
-------
TABLE 7-16. EMISSION REDUCTION FROM EMISSION CONTROL OPTIONS,
END FORMING, STEEL AND ALUMINUM, 1985a
Coating operation
Aluminum ends
Steel ends
Total
Reduction from NSPS
Base
kg/103
units
0.071
0.108
case
Mg
2,478
378
2,856
Option
kg/103
units
0.071
0.108
VA
Mg
2,478
378
2,856
0
Option
kg/103
units
0.0036
0.0053
2
VB
Mg
126
19
145
,711
aAffected capacity is based on 34.9 billion aluminum ends and 3.5 billion
steel ends subject to NSPS in 1985.
7-22
-------
TABLE 7-17. BEVERAGE CAN SURFACE COATING: EMISSION REDUCTION FROM
REGULATORY ALTERNATIVES, Mg PER YEAR, 1985
Regulatory alternative
Emission source
II
III
Two-piece steel and aluminum can
integrated facilities
Three-piece can sheet coating
Three-piece can forming
Steel or aluminum end sheet
coating
Steel or aluminum end forming
Total
0
0
0
0
0
4,113
54
311
333
2,711
7,522
5,400
152
311
333
2,711
8,907
7-23
-------
soap, and small amounts of coating material, including solvent, could be
discharged into plant effluent wastewater streams.
The level of water pollution from coating cleanup operations is very
low. The problem with some organic solvents in effluent water is more a
matter of chemical oxygen demand (COD) than toxicity. A COD load is not a
pollutant in itself; it becomes a problem only if it is discharged to a
stream in sufficient concentration and quantity to deplete the oxygen in
the stream and affect fish and other water life. .
The various can coating emission control options do not require any
changes in can washing or other operations performed prior to coating, and
therefore have no effect on noncoating water pollution aspects of can
manufacture.
7.3 SOLID WASTE DISPOSAL IMPACT
There is essentially no potential solid waste impact associated with
any of the can coating regulatory control options.
Small quantities of solid waste, either a slurry of coating material
in cleaning solvent or lumps or films of coating material, are generated
during equipment cleanup at the end of a coating run. For the no-varnish
inks control option, this source of solid waste is nonexistent, because no
overvarnish coating is applied. For waterborne coating control options,
cleanup waste is a water rather than a solid waste disposal matter. For
all other control options, cleanup waste is the same as for base cases.
Another potential source of solid waste is project rejects from the
coating operations. In general, all reject cans and scrap metal are re-
cycled. The product reject and recycle rate for control option coating
processes is expected to be no different from the base cases, so that there
will be no control option impact on this solid waste source.
7.4 ENERGY IMPACT
The application of can coatings considered in this document use energy
in the form of electricity, natural gas, and in some instances other fossil
fuels. Electricity is used to drive coating equipment, sheet and can con-
veyors, ventilating blowers at the coater and flashoff areas, oven circu-
lating and exhaust blowers, incineration system blowers, and UV lamps for
UV-curing coating systems. Natural gas is used as fuel for the drying and
curing ovens and may be used as fuel for incinerators.
7-24
-------
The energy impacts associated with each emission control option are
summarized in Tables 7-18 through 7-21. These tables compare the primary
energy required for the base case beverage can surface coating module with
the primary energy required when pollution reduction coatings and/or add-on
emission controls are used. The data in Tables 7-18 through 7-21 represent
only energy requirements affected by the emission control options, not the
total requirements. Energy requirements for coater and conveyor drivers,
can forming equipment, and similar steps are not included. However elec-
trical energy requirements for ventilating air, cure oven air, incinerator
air; and natural gas requirements for cure ovens and incinerators, are
included.
Data in Tables 7-18 through 7-21 are presented on the basis of 1,000
cans or ends. Combining these data with the estimated beverage can produc-
tion subject to NSPS in 1985 (see Table 7-10) results in the estimated
changes in energy requirements compared to the base case as shown in
Tables 7-22 through 7-25. Analysis of the data in Tables 7-18 through 7-21
indicates that there is only an insignificant difference in energy require-
ments between 100 and 500 ppmv VOC as xylene in ventilating air. Therefore
only data for 100 ppmv are presented in Tables 7-22 through 7-25.
Energy requirements for the base case and control options for aluminum
or steel end forming are essentially the same. There would be no reduction
in energy requirements for beverage can surface coating under Regulatory
Alternative I. Regulatory Alternative II would result in a net energy
reduction of 59,790 gigajoules per year in 1985; Regulatory Alternative III
in a reduction of 889,339 gigajoules. Net energy reductions from individual
beverage can surface coating operations presented in Tables 7-22 through
7-25 are summarized in Table 7-26. . '
7.5 OTHER ENVIRONMENTAL IMPACTS
Other environmental areas which are affected by can coating emission
control options are space and use of petroleum-derived materials.
Compared to base cases, no-varnish inks control options in lieu of
overvarnish eliminate a coating step and reduce plant space requirements.
Low solvent waterborne and UV-curing coating control options have no plant
space impact. Incineration control options require plant space for the
add-on control equipment and associated duct work.
7-25
-------
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TABLE 7-21. ENERGY IMPACT OF EMISSION CONTROL OPTIONS0
STEEL OR ALUMINUM END SHEET COATING
(106 joules per 1,000 ends)
Electrical energy
Ventilating air, 100 ppmv, VOC
Ventilating air, 500 ppmv, VOC
Cure oven/incinerator air
Subtotal (10.0 ppmv)
Subtotal (500 ppmv)
Natural gas
Cure oven
Incinerator
Subtotal
Total energy demand
With ventilating air at 100 ppmv
With ventilating air at 500 ppmv
Base
case
0.058
0.012
0.069
0.127
0.081
11.923
0
11.923
12.050
12.004
Emission
Option IVA
0.014
0^003
0.069
0.083
0.072
11. 712
2.762
14.474
14.557
14. 546
control option
Option IVB
0.003
0.001
0.069
0.072
0.070
11.775
0
11.775
11.847
11.845
Totals to not include energy requirements that are the same for all
options; e.g., electricity to drive coating equipment, sheet and can
conveyors, etc.
7-29
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TABLE 7-25. ENERGY REQUIREMENT FOR EMISSION CONTROL
OPTIONS, SHEET COATING, ALUMINUM OR STEEL ENDS,
SUBJECT TO NSPS IN 1981a'b
(gigajoules)
Electricity
Natural gas
Total
Reduction due
to NSPS
Base
case
2,654
249,191
251,845
Emission control option
IVA
1,735
302,507
304,241
(52,395)
IVB
1,505
246,098
247,602
4,243
VOC concentration in ventilating air is pprav 100 as xylene.
Affected capacity is based on 3.5 billion steel ends and
17.4 billion aluminum ends subject to NSPS in 1985.
DFigures in parentheses indicate an increase in energy require-
ments over the base case.
7-33
-------
TABLE 7-26. BEVERAGE CAN SURFACE COATING: NET REDUCTIONS IN ENERGY
REQUIREMENTS FROM REGULATORY ALTERNATIVES
(gigajoules per year in 1985)
Regulatory alternative
Source
II
III
Two-piece steel and aluminum can
integrated facilities
Three-piece can sheet coating
Three-piece can forming
Steel or aluminum end sheet
coating
Steel or aluminum end forming
Total
26,847
884,444
0
0
0
0
0
4,499
39
4,243
0
35,658
32,830
1,039
4,243
0
922,556
7-34
-------
The quantities of petroleum-derived organic solvent materials used for
solvent-borne base case coatings are reduced by low-solvent waterborne and
eliminated by UV curing and no-varnish ink control options.
7.6 OTHER ENVIRONMENTAL CONCERNS
7.6.1 Irreversible and Irretrievable Commitment of Resources
Other than those resources initially required to construct incinera-
tion add-on control systems, or special ovens for UV-curing coatings, there
do not appear to be any irreversible or irretrievable commitments of re-
sources associated with the can coating control options.
7.6.2 Environmental Impact of Delayed Standards
Delayed implementation of emission control standards for beverage can
coatings will have a negative environmental effects on emissions of VOC to
the atmosphere, negative impacts on energy and petroleum resources, and
minor or no positive impacts on water and solid waste.
7.7 REFERENCES
1. Tess, Roy W. Chemistry and Technology of Solvents; Chapter 44 in
Applied Polymer Science. Organic Coatings and Plastics Division,
American Chemical Society. 1975.
2. Stanford Research Institute. Sources and Consumption of Chemical Raw
Materials in Paints and Coatings by Type and End-Use. Menlo Park, CA.
November 1974.
3. United States Environmental Protection Agency. Control of Volatile
Organic Emissions from Stationary Sources. Volume II: Surface Coat-
ing of Cans, Coils, Fabrics, Automobiles, and Light-Duty Trucks.
Research Triangle Park, NC. Publication No. EPA-450/2-7-008. May
1977. p. iv.
4. Environmental Reporter. July 1979.
5. Massoglia, M. F. Industry Characterization and Required Effort to
Control VOC Emissions. Research Triangle Institute, Research Triangle
Park, NC. January 1980. p. III-3.
6. Metal Bulletin. May 19, 1978. p. 23.
7. Packaging Trends, Modern Packaging. June 1978. p. 10.
8. Business Climate Outlook 1981-1985: A 5-Year Projection of the Economy,
• Energy, Selected Industries and Materials. American Can Company.
April 1980. pp. 37-40.
9. Letter from Payne, G., Can Manufacturers Institute, to Goodwin, D.,
U.S. Environmental Protection Agency. June 16, 1980.
7-35
-------
-------
8. ECONOMIC IMPACT
8.1 INDUSTRY CHARACTERIZATION
The metal can industry is defined in the Standard Industrial Classifi-
cation Manual under SIC 3411 as establishments primarily engaged in manufac-
turing metal cans from purchased materials. Metal cans include: food,
milk, oil, beer, and general line containers; aluminum cans; tin cans;
packers' cans; tinned pails; and other pails, except shipping and stamped.
Metal cans are used to package beverage, food, and nonfood products.
They are normally made of steel or aluminum, and are often coated inside
and/or outside for protective or decorative purposes.
The largest market for cans of a similar size and shape is in soft
drink and beer containers. The popular sizes of these cans are 12-ounce
and 16-ounce capacities. The beverage can is coated on the interior to
protect the contents and on the exterior to provide decoration and product
brand identification. Coating materials are designed to meet a variety of
performance requirements. The high degree of sophistication in this coating
and decorating technology is made possible by the large market for these
cans.
The metal can industry is made up of approximately 100 companies with
nearly 500 plants at 300 locations in the United States. Major producing
areas are east, north central, Pacific, and middle Atlantic states.1
Geographical distribution of can plants is shown in Figure 8-1.2
There are two general types of metal can plants: merchant vendor
plants and captive plants. Merchant vendor plants produce a wide variety
of two- and three-piece cans for sale to the beer and soft drink industry
and to food and nonfood packagers. Captive plants are owned by bottlers or
food processors and manufacture cans for use by the parent company or its
subsidiaries. Approximately 30 percent of all cans are captively produced
by food companies such as Campbell Soup, H. J. Heinz, and General Foods and
8-1
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8-2
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by major breweries such as Adolph Coors, Schlitz, Carlings, Anheuser-Busch
and Miller. Most captive beverage can plants are owned by breweries and
produce only 12-ounce and 16-ounce steel or aluminum two-piece beer cans.
Some merchant vendor plants are, in effect, captive because their facilities
serve a particular brewery.
Table 8-1 lists the major U.S. merchant producers of metal cans and
their can sales for 1975. This does not include producers of cans for
captive use.
The can industry is highly concentrated. In 1975 the two major pro-
ducers, Continental Group and American Can, accounted for approximately
37 percent of the value of all can shipments. National Can and Crown Cork
and Seal accounted for another 14 percent.
Continental Group, founded in 1904, is the largest metal can manufac-
turer, presently employing 18,000 people in 91 can-manufacturing plants in
the United States. Continental operates 20 two-piece beverage can lines
that use aluminum as the primary raw material.
American Can, the second largest can manufacturer, has 27 beverage can
plants located in 15 states, and 30 food-packaging plants manufacturing
metal composite cans in 16 states. American Can manufactures both two-piece
and three-piece beverage cans.
The third largest can manufacturer, National Can, operates 41 plants
throughout the country for both food and nonfood packaging. Crown Cork and
Seal, the fourth largest can company, manufactures and sells cans, crowns,
closures and packaging machinery. It has 26 plants in the United States.
These companies and others have made major contributions to can pack-
aging development. While the three-piece can has been used for packaging
beverages for over 40 years, the development of two-piece cans is a compar-
atively new technology. .
Manufacture of two-piece cans began in 1958 when Kaiser Industries
made a two-piece, 7-ounce beer can. In 1959 Adolph Coors Co. introduced
the first aluminum can for beer. Reynolds Metals Co. had developed machin-
ery for high-speed manufacture of two-piece cans by 1963, and in 1971,
Crown Cork & Seal introduced tin-plated steel two-piece cans. In 1972,
Continental Can, now Continental Group, installed the first UV printer for
cans. American Can developed a two-piece can in 1975 that was 30 percent
8-3
-------
TABLE 8-1. MAJOR U.S. MERCHANT PRODUCERS OF
METAL CANS, 1975s
Rank
1
2
3
4
5
6
7
8
9
10
11
Company
Continental Group
American Can Co.
National Can Co.
Crown Cork & Seal
Reynolds Metals
Ball Corp.
Diamond International
Van Dorn
Kaiser Aluminum & Chemical
J. L. Clark
Sherwin-Williams
Other merchant suppliers
Captive producers
TOTAL
Million $
1,175
1,125
535
315
150
70
60
60
55
30
30
1,020
1,545
6,170
8-4
-------
lighter than three-piece cans and, soon afterward, Alcoa introduced a
reduced-diameter, taller, lightweight, two-piece can. Continuing improve-
ments in can manufacturing are expected as manufacturers strive to keep
ahead of competitive packaging.
In 1978 there were 48,500 production workers in the can industry.
This represented a decrease of 19 percent from 1973, when 60,200 production
workers were employed in the industry. Between 1977 and 1978 the number of
production workers declined 0.4 percent. Total workers in the industry
declined 16 percent between 1973 and 1978, dropping from 69,800 to 58,500
workers. This gradual reduction in employment can be attributed to the
closing of marginal facilities and the installation of more efficient
equipment, particularly the replacement of three-piece can lines with
two-piece can facilities.
Plant sizes in terms of employment vary with the types of cans produced,
the number of lines and degree of integration of systems. Two-piece bever-
age can plants are more automated than the older three-piece can operations.
Some plants specialize in coating body sheets and end sheets for three-piece
steel cans. The precoated sheets are sent to other plants for final forming
into cans. Sheet plants usually employ about 120 people. Plants that have
three-piece can sheet-coating and bodymaking operations may have a work
force of 700 to 800 people, including administrative staff. More modern
two-piece canmaking facilities may employ about 200 people. Employees in
coating operations typically comprise about 6 to 15 percent of the work
force.
Capital investment for beverage can plants has recently been reported
to range from $20 million, for plants making two-piece steel cans at the
rate of 800 million per year, to $37.5 million, for plants making combina-
tions of two sizes of two-piece cans and ends.4
The Department of Commerce forecasts total can shipments of 92.9 bil-
lion with a value of $9,775 million for 1979, an increase of 14 percent
over 1978.5 Shipments of beverage cans in 1979 are estimated to be 65 bil-
lion units with a value of $3.5 billion.
Shipments of beverage cans have increased steadily since 1967, account-
ing for a greater share of the metal can market. Annual value and quality
of metal cans since 1972 are shown in Table 8-2. Also included are the
8-5
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annual quantities of steel and aluminum cans and year-to-year percentage
changes.
The major products that are packaged in metal cans are shown in
Table 8-3. Between 1967 and 1977, cans used to package beverages grew from
37 to 58 percent of the cans produced. Increased use of cans to package
beverages is expected to continue. Production of food and nonfood cans has
been essentially static since 1967.
Beverage can shipments from 1971 to 1978 are shown in Table 8-4. All
of the aluminum cans are two-piece. Approximately 40 percent, or 9.8 bil-
lion, of the steel cans shipped in 1978 were two-piece. The remaining 14.5
billion steel cans were of three-piece construction.6
Conservative estimates predict a 2.2 percent compound annual growth in
the unit shipments of all metal cans1 between 1977 and 1982. Other sources
project increases of between 3.3 and 3.9 percent per year through 1990.7 8
Most of this growth will take place in containers for beer and soft drinks.
One estimate places the compound annual growth rate for all beverage cans
at 5.5 percent, from 51 billion cans in 1977 to nearly 80 billion cans in
1985.9 Another source forecasts compound annual increases in can shipments
of approximately 7 and 5.5 percent for soft drink and beer cans, respec-
tively, through 1980.10 Food cans are expected to grow at less than 1
percent through 1990,1:L and nonfood cans should continue a slow decline.
Estimates of aluminum beverage can growth range from 5 to 8 percent per
year through 1985, while steel can unit production is expected to increase
at roughly 2 percent per year over the same period.9 12
A review of Table 8-4 shows that over the past 6 to 8 years nearly all
of the growth in the beverage can industry has been in two-piece aluminum
cans. As the above projections indicate, this trend is expected to continue,
particularly for beer cans. Two-piece aluminum is expected to represent
approximately 95 percent of the beer can market by 1980.1
While aluminum is still the dominant two-piece package, use of steel
two-piece cans is increasing. Presently, approximately 20 percent of
two-piece cans are estimated to be steel, and this share is expected to
increase to 30 percent by 1980.* The lower price per pound for steel has
been the main incentive for this change.
8-7
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The continued trend toward two-piece beverage cans is related to lower
labor requirements in manufacture, reduced material needs because of thinner
sidewalls, better graphics, and convenient recycling for aluminum cans.1
8.2 COST ANALYSIS OF CONTROL OPTIONS
8.2.1 Introduction
Considerations pertaining to the definition of model plants and to the
selection of regulatory alternatives are discussed in detail in section 6.0.
A brief summary of these topics is presented here to support the analysis
of control option costs.
In order to analyze a large segment of beverage can surface-coating
operations, model plants have been defined for both two-piece and three-
piece beverage can operations. The scale of can production for the model
plants is:
Type of Plant
Small-scale two-piece
Large-scale two-piece
Small-scale three-piece
Large-scale three-piece
Annual Can Production
400 million
2,400 million
400 million
800 million
The coating operations associated with these plants and included in
this cost analysis are:
Two-piece aluminum- or steel-can integrated facility
Exterior base coat
Lithography and overvarnish
Interior spray
Three-piece steel-sheet coating
Exterior base coat
Interior base coat
Lithography and overvarnish
Three-piece steel-can forming
Interior spray
Sheet coating, steel or aluminum ends
Exterior base coat
Interior base coat
The control options evaluated for these operations are summarized in
Tables 8-5 through 8-8. These options are evaluated relative to the emis-
8-10
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VOC emissions
Deduction, %
Inside spray
Type of coating
kg VOC/mre solids
Incineration
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sion limitations recommended in the CTG for the base case. As explained in
chapter 6.0, these limitations are being widely adopted by states for their
SIP's.
Tables 8-9 through 8-12 summarize additional parameters of the model
plants with estimated capital and operating costs for new facilities.
These are only the incremental costs associated with the coating systems
and emission control systems; that is, no "front-end" or "back-end" equip-
ment costs are included. Both capital and operating costs have mid-1978
bases. The costs shown do not include any recovery of capital investment.
Further discussions of these costs and the assumptions and bases used in
the cost analysis are included in section 8.2.2.1.
Costs for the base case and control options for the application of
end-sealing compounds are essentially the same. No changes in equipment
are required. Costs of solvent-based and water-based end-sealing compounds
are comparable. The option using water-based materials does not require
ventilating air. However, the energy savings are minimal. Consequently,
no option selected would have an economic impact.
8.2.2 New Facilities
As previously discussed in section 6.1.1, recently constructed two-
piece can plants have included two to six lines. Consequently, the small-
scale model plants were defined as having two lines and the large-scale
plants as having six lines so that the cost analysis would be relevant to
current plant design practices.
Because of the industry trend toward increased manufacture of two-
piece cans, the task of defining model three-piece can plants is less
certain. However, large-scale and small-scale model three-piece plants
have been defined that have capacities similar to existing plants and
represent a range of capacities into which any new three-piece plants would
likely fall. A more detailed discussion of the rationale for the defini-
tion of these plants is given in section 6.1.2.
In addition to the costs of new facilities, model plant parameters
such as production rates, operating hours, emission rates, and emission
reductions are given in Tables 8-9 through 8-12.
8-2.2.1 Capital Costs. The capital costs given in Tables 8-9 through
8-12 include the cost of coating systems and emission control systems, but
8-15
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they do not include capital costs of other can-line equipment. The costs
were developed using a mid-1978 basis from the sources referenced in Table 8-13.
Tables 8-9 through 8-12 give the capital costs for coating and emission
control systems for each coating operation of each control option, for both
small-scale and large-scale model plants. In addition to comparisons
between options, these costs may also be compared to the cost of implement-
ing CTG recommendations (the base case). Most states are adopting the CTG
limits for their State Implementation Plans.
8.2.2.2 Operating Costs. The operating costs indicated in Tables 8-9
through 8-12 were also developed using a mid-1978 basis. The coating
materials costs used in the analysis are shown in Table 8-14.21
Other operating cost parameters used in the analysis are indicated in
Table 8-15.
8.2.2.3 Base Cost of Facility. Maximum economic impact and minimum
negative environmental impact will occur if growth in beverage can require-
ments is satisfied by the construction of new two-piece facilities subject
to NSPS.
Capital costs for the construction of a two-piece beverage can plant
are estimated at approximately $30 (1979 dollars) per 1,000 cans annual
capacity.22 2S 24 Annual operating costs, including annualized capital
costs, are estimated at $50 per 1,000 cans manufactured.24 2S Using these
figures, the estimates of capital and operating requirements shown in
Table 8-16 can be calculated. Incremental capital and annual operating
costs (less annualized capital costs) are also shown in Table 8-16. These
cost data represent the additional costs above those required to attain the
emission levels specified in the base case.
8.3 OTHER COST CONSIDERATIONS
The can manufacturing industry is currently obligated to comply with
water and OSHA regulations. The costs associated with compliance with
other regulations are not judged to significantly affect the analysis
contained in section 8.5.
8.4 ECONOMIC IMPACTS
This section presents the estimated impacts of the regulatory alterna-
tives on new production facilities in the beverage can industry. Three
8-20
-------
TABLE 8-13.
SOURCES OF COST DATA FOR COATING AND EMISSION
CONTROL SYSTEMS
Coating or control system
Solvent-borne coating
Waterborne coating
High-solids coating
Ultraviolet-cured coating
No-var ink utilization
Thermal incineration
Reference no.
15,16,17
15,16,17
15,16
15,16
15,16
18,19,20
8-21
-------
TABLE 8-14.
SCHEDULE OF COATING MATERIAL COSTS21
($/gal)
Operation
Interior
base coat
Exterior
base coat
Qvervarnish
Inside
spray
Three-piece steel cans
Solvent-borne coating
Waterborne coating
High-solids coating
UV-cured coating
No-var ink
Two-piece aluminum cans
Solvent-borne coating
Waterborne coating
High-solids coating
UV-cured coating
No-var ink
4.50
5.25
10.00
6.50
7.25
10.00
6.25
5.25
10.00
4.75
5.50
17.00
7.00
5.25
5.10
17.00
7.00
4.00
4.00
8-22
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TABLE 8-15. PARAMETERS USED TO DERIVE OPERATING COSTS
Operating labor
Operator
Supervision
Maintenance
Labor
Materials
Utilities
Electricity
Steam
Natural gas fuel
Recovered solvent value
$12/h
15% operating labor charge
$14/h
Equal to labor
$0.033kWh
$5/M Ib
$3/MM Btu
$0.085/1b
8-23
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TABLE 8-16. CAPITAL AND OPERATING COSTS REQUIRED TO MEET GROWTH
IN DEMAND FOR TWO-PIECE BEVERAGE CANS
(1979 dollars)
Year
Basic plant
Increased demand, billion cans
Capacity requirements, billion
cans
Capital costs, 106 $
Cumulative capital costs,
106 $
Annual i zed capital
costs, 106 $a
Cumulative annual i zed
capital costs
Operating costs (including
annual ized capital
costs, 106 $
Operating costs (excluding
annual ized capital
costs), 106 $
Cumulative operating
costs
Incremental costs to meet
NSPS emission limitation
Capital costs, 106 $
Cumulative capital costs,
106 $
Annual ized capital
costs, 106 $a
Cumulative annual ized
capital costs
Operating costs (excluding
annual ized capital
costs), 10s $
Cumulative operating
costs, 106 $
1981
3.68
4.09
122.7
122.7
21.0
21.0
184.0
163.0
163.0
8.8
8.8
1.5
1.5
0.8
0.8
1982
3.92
4.36
130.8
253.5
22.4
43.4
196.0
173.6
336.6
9.4
18.2
1.6
3.1
0.9
1.7
1983
4.17
4.63
138.9
392.4
23.8
67.2
208.5
184.7
521.3
10.0
28.2
1.7
4.8
0.9
2.6
1984
4.40
4.89
146.7
539.1
25.1
92.3
220.0
194.9
716.2
10.5
38.7
1.8
6.6
1.0
3.6
1985
4.71
5.23
156.9
696.0
26.8
119.1
235.5
208.7
924.9
11.3
50.0
1.9
8.5
1.1
4.7
Total
20.88
23.20
696.0
119.1
1,044.0
924.9
50.0
8.5
4.7
Based on a 15-year recovery period and 15 percent interest factor.
8-24
-------
regulatory alternatives were described in Chapter 6: no regulation (Alterna-
tive I), a regulation based on the best available waterborne coatings
(Alternative II), and a regulation based on the best available waterborne
coatings with no-varnish inks or UV cure for the lithography/overvarnish
coating operation (Alternative III). Alternative I would obviously have no
economic impact on the industry; therefore, only the impacts of Alterna-
tives II and III are considered in this section.
Impacts are estimated for four types of production facilities: two-
piece aluminum or steel can fabrication, three-piece sheet coating, three-
piece can forming, and steel end coating and fabrication for three-piece
cans.* The specific techniques, or control options, that can be used to
comply with the regulatory alternatives were also described in Chapter 6.
The costs of each control option for the four facilities were presented in
section 8.2. Since there is no lithography/overvarnish coating step in the
three-piece can forming and the steel end coating facilities, the impacts
of Alternatives II and III are identical for these facilities. Thus, the
choice of one of these alternatives as the basis for the standard would
affect only the three-piece sheet coating and two-piece integrated facilities.
An analysis of the cost data in section 8.2 is combined with the
industry profile data in section 8.1 to determine the economic impacts of
the regulatory alternatives. In particular, impacts on product price,
return on investment, and additional capital required by the industry to
comply with the regulatory alternatives are estimated. Changes in industry
growth and structure are treated qualitatively. A summary of these impacts
is presented in section 8.4.1. Section 8.4.2 describes the methodology
that was used to determine the impacts. Section 8.4.3 contains the estimat-
ed impacts on each production facility of each regulatory alternative.
*A fifth affected facility is the application of the sealing compound
for steel and aluminum ends. However, the regulatory alternative would
require the same level of control as the CTG, which the states use to develop
their State Implementation Plans (SIPs). Thus, the regulatory alternative
would have no impact on this facility, and it is ignored for the remainder of
this analysis.
8-25
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8.4.1 Summary
No economic impacts on the beverage can industry are likely to occur
under any of the regulatory alternatives. Among the control options con-
sidered for each production facility, there is at least one whose cost is
equal to or less than the cost of complying with the SIP, or "base case,"
level of control. Even if no regulation was proposed (Alternative I), the
results show that firms building new production facilities have an economic
incentive to achieve a greater level of control than is required by the
SIPs, or are at least indifferent to a move towards a more stringent
control level (e.g., when the cost of meeting the SIP standard and the cost
of an option that further reduces emissions are identical). This is not to
say that all of the control options have no impact on the affected facil-
ities, only that options are available to each facility that would have no
impact.
Incineration option A would have an effect on product price or return
on investment (ROI), and would require an additional capital outlay by the
firm. Under Regulatory Alternative II, firms building new small-scale
facilities involved in the production of three-piece cans (sheet coating,
can forming, and end coating) would have to increase the output price by
0.7 percent, or absorb the additional costs and accept a cut in the rate of
return of 1.5 to 4.4 percentage points. Large-scale facilities would have
to increase the output price by 0.9 percent, or accept a cut in the rate of
return of 1.8 to 10.1 percentage points. Increases in capital requirements
for the three types of production facilities (both small and large scale)
range from 6 to 13 percent.
Three points must be noted concerning the estimated impacts for three-
piece can production facilities. First, these impacts occur only under the
most stringent incineration strategies. Other options are available to
each of the production facilities that would have no impact; more specifically,
it appears that firms have an economic incentive (either cost minimization
or profit maximization) to adopt these options, even in the absence of a
regulation. Second, these impacts would be smaller for an integrated
three-piece facility (one with the sheet-coating, can-forming, and end-
coating operations under one roof) than the sum of the impacts estimated
for each separate facility. Only one incinerator would be required for the
8-26
-------
integrated facility; the cost data used in the analysis assume that each
affected facility has an incinerator. Third, as discussed in section 8.1,
it is extremely unlikely that any new three-piece can facilities will be
constructed—the economics of two-piece beverage can production have ren-
dered the three-piece can obsolete as far as future capacity expansion is
concerned. Thus, no impacts are anticipated for this sector of the industry.
The only impacts of Alternative II on two-piece can production facil-
ities occur when emissions from solvent-borne coatings used for the interior
and exterior base coats and the lithography/overvarnish are incinerated
(option A). .This option would result in a price increase of less than
2 percent. If'the additional costs were absorbed by the firm, small-scale
producers (400 million cans per year) would see the ROI decline by about 6
percentage points. Additional capital outlays would amount to between 4
and 5 percent of the capital required to meet the SIP level of control for
small-scale facilities, and would amount to less than 2 percent for large-
scale producers. On the other hand, however, another incineration option
(B) and and the waterborne coating options (C and D) would have no effect
on price, ROI, or capital outlays. Under Alternative III, the control
options would have no impact on firms investing in new facilities.
In conclusion, then, two key factors lead to a finding of "no impact"
on the beverage can coating industry. First, it is very unlikely that any
new three-piece can facilities will ever be constructed. Second, even if a
new facility did come onstream, control options exist which enable the firm
to meet the requirements of either regulatory alternative at a cost that is
equal to or less than the cost of complying with existing SIP regulations.
This second factor applies equally to new two-piece facilities under Alter-
native II; under Alternative III, none of the control options would have an
adverse effect on the industry. Therefore, the regulatory alternatives
should have no effect on the industry growth rate, nor will they alter the
structure of the industry by forcing existing firms out of the market or by
precluding new firms from entering.
8.4.2 Methodology
The methodology used to estimate the impacts of the regulatory alter-
natives is described in this section. A discounted cash flow (DCF) approach
is used to evaluate the profitability of investing in new production facil-
8-27
-------
Hies and, more specifically, to determine which of several alternative
facilities is the most profitable for the firm. For a given type of produc-
tion facility, the firm can choose one of several possible configurations.
These configurations correspond to the "base case" and the control options
for which cost data were provided in section 8.2. For example, a firm
investing in a new two-piece can-forming facility has three configurations
from which to choose: the "base case," which meets the SIP level of control,
a solvent-borne coating line with an incinerator (control option A), and a
line using best available waterborne coatings (control option B). Using
the DCF approach, the most profitable configuration for each type of produc-
tion facility can be selected. The resulting choices show which facilities
would be constructed by the industry in the absence of the regulatory
alternatives and thus constitute a baseline from which the impacts of those
alternatives can be measured.
The remainder of this section is organized as follows. A general
description of the DCF approach is provided in section 8.4.2.1. This
background is needed in order to understand the particular application of
the DCF approach presented in section 8.4.2.2 that is used to estimate the
economic impacts. Finally, how the impacts are calculated using this
method is discussed in section 8.4.2.3.
8.4.2.1 Discounted Cash Flow Approach. An investment project generates
cash outflows and inflows. Cash outflows include the initial investment,
operating expenses, and interest paid on borrowed funds. Cash inflows are
the revenues from sales of the output produced by the project, depreciation
of the capital equipment, and recovery of the working capital at the end of
the project's life. Cash outflows and inflows can occur at any time during
the project's lifetime. For this analysis, it is assumed that all flows
take place instantaneously at the end of each year. Furthermore, it is
assumed that all investments are conventional investments, that is, they
are represented by one cash outflow followed by one or more cash inflows.26
This assumption insures the existence of a unique internal rate of return
for each project.27 For a project with a lifetime of N years, there are
N + 1 points in time at which cash flows occur: at the end of year zero,
the end of year one, and so on until the end of the Nth year.
8-28
-------
The initial (and only) investment is assumed to be made at the end of
year zero. This cash outflow comprises the sum of the fixed capital cost
and the working capital. It is offset by an investment tax credit, which
is calculated as a percentage of the fixed capital cost and represents a
direct tax saving. The cash flow in year zero can be given by the follow-
ing equation:
YQ = (FCC + WC) - (TCRED x FCC)
(8-1)
The variables for this and subsequent equations are defined in Table 8-17.
The project generates its first revenues (and incurs further costs) at
the end of year one. The net cash flows in this and succeeding years can
be represented by the following equation:
= (R. - E+) (1 - T)
DtT
t = 1,
N
(8-2)
The first term of equation 8-2 represents the after-tax inflows of the
project generated by sales of the output after netting out all deductible
expenses. Revenues are given by
Rt = P • Q • U (8-3)
Deductible operating expenses, Et, are the sum of the fixed and variable
operating costs and can be represented by
E. = V-U + F (8-4)
\f
Variable costs include expenditures on raw materials, labor (operating,
supervisory, and maintenance), and utilities. Fixed costs include expendi-
tures for facility use, insurance, administrative overhead, etc. For
income tax purposes, E. is deductible from gross revenues, R^. Hence, the
after-tax cash inflow to the firm can be determined by netting out these
expenses and multiplying the result by (1 - T).
Federal income tax laws also allow a deduction for depreciation of the
capital equipment (not including working capital). Although depreciation
is not an actual cash flow, it does reduce income tax payments (which are
cash outflows) since taxes are based on net income after deducting the
depreciation allowance.28 The expression in equation 8-2, DtT, represents
the annual tax savings to the firm resulting from depreciation; it is
treated as a cash inflow. In the analysis in this section, the straight
8-29
-------
TABLE 8-17. DEFINITIONS
Symbol
Explanation
DF
t
DF
DSL
F
FCC
Jt
N
NPV
P
PDEBT
Q
Rt
rD
r
T
TCC
TCRED
U
V
WC
X
depreciation in year t
discount factor = (1+r)
-t
sum of the discount factors over the life of the project =
N
I (1+r)
t=0
-t
present value of the tax savings due to straight line depre-
ciation =
N
I D.T(l+r)
t=0 *
-t
operating expenses in year t
annual fixed costs
fixed capital costs
interest paid on borrowed funds in year t
project lifetime in years
net present value
price per unit of output
proportion of investment financed by borrowing
annual plant capacity
revenues in year t
interest rate on borrowed funds
discount rate, or cost of capital
corporate tax rate
total capital cost
investment tax credit
capacity utilization rate
annual variable operating costs
working capital
minimum [$2,000, 0.2 x FCC]
net cash flow in year t
percentage that each source of capital i is of total capital
8-30
-------
line method of depreciation is used. The salvage value of the facility is
assumed to be zero, so the annual depreciation expense is simply given by
(FCC - X)/N, where N is the lifetime of the project and X is $2,000 or 20
percent of the fixed capital costs, whichever is less.
The net cash flows represented by equation 8-2 occur at the end of the
first through the Nth years. Additional cash inflows occur at the end of
the first and Nth year. The additional cash inflow at the end of the first
year is the tax savings attributable to the additional first year deprecia-
tion deduction of 20 percent of the fixed capital cost or $2,000, whichever
is less. By law, the basis for calculating normal depreciation allowances
must be reduced by the amount of the additional first year depreciation.29
The additional cash inflow at the end of the Nth year occurs when the
working capital, initially treated as a cash outflow, is recovered.
Because these cash flows occur over a future period of time, they must
be discounted by an appropriate interest rate to reflect the fact that a
sum of money received at some future date is worth less than an equal sum
received today. This discount factor, DFt, can be given by:
DFt = (1+ r)
-t
t = 0, 1, ..., N (8-5)
The sum of the discounted cash flows from a project is called the net
present value of that project. That is,
N
NPV = Z (Y.
t=l *
N
NPV = I [Y.
t=l T
DFt) - YQ or
r)"1]
(8-6)
The decision criterion, if funds are available, is to invest in the project
if it has a positive NPV at a discount rate equal to the weighted average
cost of capital.
To employ this methodology requires the estimation of the weighted
average cost of capital to the firm, or more generally, to a group of firms
operating in the same industry. RTI calculated the weighted average cost
8-31
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of capital for firms in the metal beverage container industry by employing
a methodology where:
WACC =
Z K
Z K
(8-7)
in which WACC is defined as the weighted average cost of capital, Z. is the
percentage that each source of capital is of the total (IZ. = 1.0), and K.
is the cost of each capital component. The cost of the capital components
are defined as K! = the required rate of return on long term debt, K2 = the
required rate of return on preferred stock, and K3 = the required rate of
return on common equity. Incurring long term debt and issuing preferred
and capital stock are the usual methods of raising capital employed by a
firm.
Data on weights and the required rates of return for the various debt
instruments were compiled from the financial statements of metal beverage
container producing firms. These financial statements were available in
publications such as Moody's Industrial Manual and The Value Line Investment
Survey. The result of these calculations was an estimated weighted average
cost of capital (discount rate) of 11.8 percent for the beverage can industry.
8.4.2.2 Project Ranking Criterion. The specific application of DCF
used in the economic analysis is discussed in this section. What is needed
is a criterion for ranking alternative investment projects in terms of
profitability. It is assumed that, in the absence of the regulatory alter-
natives, any firm building a new production facility would invest in the
most profitable configuration of that facility. This choice can be com-
pared with the one that would have to be built to comply with the regula-
tory alternative; this forms the basis for calculating price and rate of
return impacts.
Equation 8-6 can be rearranged and used as the ranking criterion. The
procedure begins by substituting the expressions for R and E (given by
equations 8-3 and 8-4, respectively) in equation 8-2. Next, the expres-
sions for Yg in equation 8-1 and Y. in equation 8-2 are substituted into
equation 8-6. NPV in equation 8-6 is then set equal to zero and the unit
price, P, is solved for by rearranging the terms in Y, so that the price is
on the left hand side of the equal sign and all other terms are on the
right hand side:
8-32
-------
p =
DF-(1-T)-Q-U
V*U + F + I
Q-U
(8-8)
where
Z = YQ - DSL - WC(l+r)~N - XCl+r)"1-!
and all other variables are defined in Table 8-17. The resulting expres-
sion for P, called the present worth cost, has two terms. The first, or
"capital cost" term is that part of the present worth cost accounted for by
the initial capital outlay (adjusted for the tax savings attributable to
depreciation, recovery of working capital, etc.) and including the return
on the invested capital. The second, or "operating cost" term is a func-
tion of the fixed and variable operating costs. Hence, for any configur-
ation, the present worth cost just covers the unit operating costs and
yields a rate of return, r, over the project's lifetime on the unrecovered
balances of the initial investment. It also represents the cost to the
manufacturer of an input to the production of a beverage can, namely, the
coating.
For each type of facility, equation 8-8 is used to calculate the
present worth cost of the coating from each configuration. The results are
then ranked in order of cost, from lowest to highest. The most profitable
configuration is the one that can coat a can for the lowest cost.
8.4.2.3 Determining the Impacts of the Regulatory Alternatives. This
section describes how the impacts of the regulatory alternatives are esti-
mated using the ranking method discussed in section 8.4.2.2. The estimated
impacts are presented in section 8.4.3. Three categories of impacts are
estimated: price, return on investment, and incremental capital require-
ments.
Price impacts are calculated directly from equation 8-8. Given the
imputed cost of the coating for each control option, cost increases from
the base unit cost of the most profitable line can be calculated. These
cost increases are translated into price impacts by dividing them by the
price received by the producer for the beverage can.
Whereas price impacts are calculated by assuming that all of the
incremental costs associated with a given control option are passed forward
to the consumer, return on investment (ROI) impacts are estimated by assum-
8-33
-------
ing that the producer absorbs all of the incremental costs, thus lowering
the ROI. In this case, the price facing the consumer does not change. For
any control option, a discount rate exists that enables the producer to
maintain the imputed cost of the coating at its baseline level. The base-
line cost is the present worth cost associated with the most profitable
line configuration and is determined from the procedure described in sec-
tion 8.4.2.2.
The baseline present worth cost was calculated from equation 8-8 using
a specific value of the discount rate, r. As mentioned previously, the
discount rate employed was that calculated as the weighted-average cost of
capital. The calculation of the rate of return impact begins by setting P =
P in equation 8-8, where P is the baseline (lowest) cost and then itera-
tively solving for the value of r that equates the right hand side of
equation 8-8 with P. This value, say r*, will always be less than r, the
baseline rate of return. The difference between r* for each control option
and r constitutes the rate of return impact.
The incremental capital requirements are calculated from the cost data
presented in section 8.2. The additional capital required to meet the
standards is used as a partial measure of the financial difficulty firms
might face in attempting to conform to the standard. Incremental capital
requirements also constitute a barrier for firms entering the beverage can
market. The magnitude of the additional capital relative to the baseline
capital requirements is a measure of the size of this barrier.
8.4.3 Economic Impacts
This section presents the estimated impacts of Regulatory Alternatives
II and III on each of four types of production facilities. For each type,
the firm is confronted with a set of configurations, corresponding to the
"base case" and the control options, from which it selects the most profit-
able by applying the ranking methods described in section 8.4.2.2 This
choice is compared with the configuration needed to comply with the regula-
tory alternatives; the resulting impacts (if any) are then estimated using
the methods described in section 8.4.2.3.
For ease of reference, the four production facilities and the coating
operations involved in each are shown below:
8-34
-------
Two-piece aluminum- or steel-can Integrated facility
• Exterior base coat
• Lithography/overvarnish
• Interior spray
Three-piece steel-sheet coating
• Exterior base coat
• Interior base coat
• Lithography/overvarnish
Three-piece steel-can forming
• Inside spray
Steel- or aluminum-end coating and forming
• Exterior base coat
• Interior base coat
Because the only distinction between the regulatory alternatives involves
the use of no-varnish inks or a UV cure for the lithography/overvarnish
step under Regulatory Alternative III, the impacts on the three-piece can
forming and steel end coating facilities would be identical under both
regulatory alternatives. It should also be noted that the control options
that satisfy Regulatory Alternative III would also satisfy Regulatory
Alternative II. That is, a firm may choose control options satisfying
Regulatory Alternative III to meet the standards of Regulatory Alterna-
tive II.
Table 8-18 presents the capital and operating costs for small-scale
(400 million cans per year) and large-scale (2,400 million cans per year)
two-piece aluminium or steel can integrated facilities. The costs are
based on those given in section 8.2 and are reproduced here to illustrate
the form in which they were used for the analysis. The "annual operating
costs" reported in section 8.2 for the base case and each control option
are here disaggregated into "fixed" and "variable" costs. Table 8-19 and
Table 8-20 show the costs for three-piece sheet coating facilities and
three-piece can forming facilities, respectively. Costs are estimated for
small (400 million cans per year) and large (800 million cans per year)
plants in each case. Table 8-21 supplies cost data for steel- and aluminum-
end coating facilities; only one plant size is considered (1,100 million
ends per year). Note that the estimated costs are not annualized costs,
8-35
-------
TABLE 8-18. COST DATA FOR TWO-PIECE ALUMINUM OR STEEL
INTEGRATED FACILITIES
Small scale
Large scale
Installed Operating cost Installed Operating cost
capital cost (103 $/year) capital cost0 (103 $/year)
Control option (103 $) Fixed0 Variable'
(10s $) Fixedd Variable6
Base case
IA
IB
1C
ID
4
4
3
4
3
,560.0
,765.0
,402.0
,560.0
,202.0
182.
190.
136.
182.
128.
4
6
1
4
1
1,
1,
1,
1,
1,
533.6
791.4
604.9
533.6
391.9
14
14
10
14
9
,050.0
,275.0
,188.0
,050.0
,970.0
562.0
571.0
407.5
562.0
398.8
9
12
10
9
8
,988.0
,146.0
,569.5
,988.0
,931.2
Two lines rated at 700 cans/minute operating 4,700 hours per year. Annual
production is 400 million cans.
Six lines rated at 800 cans/minute operating 8,400 hours per year. Annual
production is 2,400 million cans.
cFrom Table 8-9 in section 8.2.
4 percent of the capital cost.
eEqual to the annual operating cost reported in Table 8-9 minus the fixed
cost (see footnote d).
8-36
-------
TABLE 8-19. COST DATA FOR THREE-PIECE SHEET COATING FACILITIES
Control option
Base case
IIA
IIB
n.c
IID
Smal
Installed
capital cost
(103 $)
2,830.0
3,027.0
2,739.0
2,830.0
2,549.0
1 scale
a
Operating cost
(103 $/year)
Fixedd
113.2
121.1
109.6
113.2
102.0
Variable6
892.8
899.9
824.4
892.8
793.0
Large
Installed
capital cost
(103 $)
5,660.0
5,870.0
5,298.0
5,660.0
5,098.0
scale
Operating cost
(103 $/year)
d e
Fixed Variable
226.4 1,738.6
234.8 1,814.2
211.9 1,622.1
226.4 738.6
203.9 549.1
aOne line at 90 sheets/minute operating 4,240 hours/year split between exterior
and interior coating; one line at 90 sheets/minute operating 2,120 hours/year
for lithography/overvarnish. Annual production equivalent to 400 million cans.
Two lines at 110 sheets/minute operating 3,460 hours/year split between exterior
and interior coating; two lines at 90 sheets/minute operating 2,120 hours/year
for lithography/overvarnish. Annual production equivalent to 800 million cans.
cFrom Table 8-10 in section 8.2.
4 percent of the capital cost.
eEqual to the annual operating cost reported in Table 8-10 minus the fixed
cost (see footnote d).
8-37
-------
TABLE 8-20. COST DATA FOR THREE-PIECE CAN FORMING FACILITIES-
INSIDE SPRAY
Small scale
Large scale
Installed Operating cost Installed Operating cost
(103 I/year) capital costc (103 $/year)
capital cost
Control option (103 $) Fixed Variable*
(103 $) Fixedd Variable6
Base case
IIIA
IIIB
1,580.0
1,766.0
1,580.0
63.2
70.6
63.2
499.8
543.4
449.8
2,100.0
2,300.0
2,100.0
84.0 901.0
92.0 1,105.0
84.0 901.0
One line at 2,160 cans/minute operating 3,090 hours/year. Annual production
is 400 million cans.
Two lines at 1,080 cans/minute operating for 4,120 hours/year. Annual
production is 800 million cans.
cFrom Table 8-11 in section 8.2.
4 percent of the capital cost.
p
Equal to annual operating cost reported in Table 8-11 minus the fixed cost
(see footnote d).
8-38
-------
TABLE 8-21. COST DATA FOR STEEL- AND ALUMINUM-END
SHEET COATING FACILITIES3
Control Option
Base case
IVA
IVB
Installed ,
capital cost
(10s $)
1,415.0
1,595.0
1,415.0
Operating cost
(10s $/year)
Fixed0
56.6
63.8
56.6
Variable01
387.4
403.4
387.4
aThe facility consists of one line at 90 sheets/minute operating for 3,080
hours/year split between the exterior and interior coats with an annual
production of 1.1 billion ends/year.
bFrom Table 8-12 in section 8.2.
C4 percent of the capital cost.
Equal to the annual operating cost from Table 8-12 minus the fixed cost
(see footnote c).
8-39
-------
that is, they do not include a "capital recovery" component. This aspect
of cost accounting is implicitly handled in the DCF approach.
For each facility these costs were inserted into equation 8-8 to
determine the present worth cost of applying a coating under each of the
control options. All calculations assumed straight line depreciation of
capital equipment, a 100 percent capacity utilization rate, an investment
tax credit of 10 percent, a corporate tax rate of 46 percent, and a project
life of 10 years. Additionally, the calculated discount rate of 11.8
percent applicable to beverage can manufacturing was employed. Working
capital was not estimated for this study.
Table 8-22 presents the unit present-worth cost of coating 1,000 cans
associated with each control option for both small- and large-scale two-
piece can integrated facilities. For each alternative, the control options
are ranked from least expensive to most expensive. Under Alternative II,
it is assumed that customer demands dictate that firms are not allowed to
eliminate the overvarnish (by using no-varnish inks or a UV curve). Thus,
firms can not choose control option IB or ID. Under Alternative III,
no-varnish inks or UV-curable overvarnishes are used for lithography/
overvarnish operations. Therefore, firms cannot choose control option IA
or 1C.
Table 8-23 contains the present worth costs and rankings of these
costs for three-piece sheet coating facilities. Constraints on the control
options available to the firms under each of the two alternatives are as
indicated above.
Present worth costs and rankings for three-piece can forming facil-
ities and for steel and aluminum-end sheet coating facilities are presented
in Table 8-24 and Table 8-25, respectively. Neither of these two types of
facilities perform lithography/overvarnish operations; therefore only two
control options exist for these firms. Regulatory Alternatives II and III
are identical as applicable to these firms.
The impacts of Regulatory Alternatives II and III are based on the
present worth costs and rankings presented in Tables 8-22 through 8-25.
Section 8.4.3.1 gives the estimated impacts on two-piece aluminum or steel
can integrated facilities. The remaining sections present the impact
estimates for three-piece sheet coating facilities (section 8.4.3.2),
8-40
-------
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TABLE 8-24. PRESENT WORTH COSTS AND RANKINGS FOR THREE-PIECE
CAN FORMING FACILITIES-INSIDE SPRAY3
Control
option
Base case
IIIA
IIIB
Small scale
Costa ($71,000 cans)
2.226
2.450
2.101
Rankb
2
3
1
Large scale
Cost3 ($71,000 cans)
1.776
2.092
1.776
Rankb
1
2
1
3A11 cost calculations assumed straight line depreciation of capital equip-
ment, an investment tax credit = 10 percent, a corporate tax rate = 46 per-
cent, a project life = 10 years, and a discount rate = 11.8 percent. Work-
ing capital was not estimated for this study.
Costs were ranked from lowest (rank = 1) to highest.
8-43
-------
TABLE 8-25. PRESENT WORTH COSTS AND RANKINGS FOR STEEL-
AND ALUMINUM-END SHEET COATING FACILITIES
Control
option
Cost*
($71,000 cans)
Ranku
Base case
IVA
IVB
0.670
0.725
0.670
1
2
All cost calculations assumed straight line depreciation of capital
equipment, an investment tax credit = 10 percent, a corporate tax rate =
46 percent, a project life - 10 years, and a discount rate = 11.8 percent.
Working capital was not estimated for this study.
Costs were ranked from lowest (rank = 1) to highest.
8-44
-------
three-piece can forming facilities (section 8.4.3.3), and steel- and aluminum-
end coating facilities (section 8.4.3.4).
8.4.3.1 Impacts on Two-Piece Facilities. Table 8-26 shows the price
impacts of the regulatory alternatives by control option for small-scale
and large-scale facilities. The return on investment (ROI) impacts and the
incremental capital requirements are presented in Tables 8-27 and 8-28
respectively.
Under Regulatory Alternative II, the best available waterborne coating
(control option C) allows the firm a chance for compliance at no additional
cost. The incineration option (control option A) would cause the small-
scale firm to experience a price impact of 1.5 percent, a negative ROI
impact of 5.7 percentage points, and an increase in capital requirements of
4.5 percent. Ostensibly, the large-scale firm would not consider the
incineration option as there is no positive rate of return associated with
this option.
Regulatory Alternative III would have no economic impact on small or
large two-piece facilities. The base case (CTG waterborne coatings) is the
least profitable technique; thus, firms have an economic incentive to adopt
one of the control options, even in the absence of a regulation.
8.4.3.2 Impacts on Sheet-Coating Facilities. Price impacts, ROI
impacts, and incremental capital outlay requirements are given in Tables
8-29, 8-30, and 8-31, respectively.
Under Regulatory Alternative II, firms are indifferent between using
the best available waterborne coatings (option C) and CTG waterborne coat-
ings (base case). There would thus be no impact on firms using option C
under Regulatory Alternative II. The incineration strategy (option A)
under this alternative would result in price impacts of 0.2 to 0.3 percent,
negative ROI impacts of 1.6 to 1.8 percentage points (assuming costs are
absorbed by the firms), and additional capital requirements of 5.5 to 7.0
percent.
Neither of the two options available to comply with Regulatory Alter-
native III would have associated price, ROI, or capital requirements impacts
as the present worth coating costs of both control options are less than
those associated with the base case.
8-45
-------
TABLE 8-26. PRICE IMPACTS OF REGULATORY ALTERNATIVES ON TWO-PIECE
ALUMINUM OR STEEL INTEGRATED FACILITIES (%)a
Control
option
IA
IB
1C
ID
Smal
Alternative II
1.54
N/A
0.00
N/A
1 scale
Alternative III
N/A
0.00
N/A
0.00
Large
Alternative II
1.84
N/A
0.00
N/A
scale
Alternative III
N/A
0.00
N/A
0.00
A baseline price of $50 per 1,000 cans was used to calculate the impacts.
The unit present worth costs and rankings from Table 8-22 were used to
determine the cost increases, which were then translated into price in-
creases by dividing them by $50. The "base case" unit cost was assumed to
be incorporated in the $50 base price for 1,000 cans. Thus, increases over
this "base case" cost due to the control options would generate the price
increases reported in the table. If the unit coating cost of a control
option was less than the "base case" cost, then there is no impact and the
table entry will read "0.00."
8-46
-------
TABLE 8-27. RETURN ON INVESTMENT IMPACTS OF REGULATORY ALTERNATIVES
ON TWO-PIECE ALUMINUM OR STEEL INTEGRATED FACILITIES
Control
option
IA
IB
1C
ID
Small
Alternative II
-5.67
N/A
0.00
N/A
scale
Alternative III
N/A
0.00
N/A
0.00
Large
Alternative II
___b
N/A
0.00
N/A
scale
Alternative III
N/A
0.00
N/A
0.00
Baseline ROI = 11.8 percent.
3No positive rate of return exists for this control option.
8-47
-------
TABLE 8-28. INCREMENTAL CAPITAL REQUIREMENTS OF REGULATORY ALTERNATIVES
FOR TWO-PIECE ALUMINUM OR STEEL INTEGRATED FACILITIES (10s $)a
Control
option
IA
IB
1C
ID
Smale
Alternative II
205.0 .
(4.5)b
N/A
0.00
N/A
scale
Alternative III
N/A
0.00
N/A
0.00
Large
Alternative II
225.0 ,
(1.6)b
N/A
0.00
N/A
scale
Alternative III
N/A
0.00
N/A
0.00
Calculated from Table 8-18.
Percentage change from the "base case" amount.
N/A signifies that the control option is not applicable to the regulatory
alternative under consideration.
8-48
-------
TABLE 8-29. PRICE IMPACTS OF REGULATORY ALTERNATIVES ON THREE-PIECE
SHEET COATING FACILITIES (%)a
Control
option
Small scale
Large scale
Alternative II Alternative III Alternative II Alternative III
IIA
IIB
IIC
IID
0.23
N/A
0.00
N/A
N/A
0.00
N/A
0.00
0.27
N/A
0.00
N/A
N/A
0.00
N/A
0.00
A baseline price of $60 per 1,000 cans was used to calculate the impacts.
The unit present worth costs and rankings from Table 8-23 were used to
determine the cost increases, which were then translated into price in-
creases by dividing them by $60. The "base case" unit cost was assumed to
be incorporated in the $60 base price for 1,000 cans. Thus, increases over
this "base case" cost due to the control options would generate the price
increases reported in the table. If the unit coating cost of a control
option was less than the "base case" cost, then there is no impact and the
table entry will read "0.00."
8-49
-------
TABLE 8-30. RETURN ON INVESTMENT IMPACTS OF REGULATORY ALTERNATIVES
ON THREE-PIECE SHEET COATING FACILITIES3
Control
option
IIA
IIB
IIC
IID
Small
Alternative II
-1.55
N/A
0.00
N/A
scale
Alternative III
N/A
0.00
N/A
0.00
Large
Alternative II
-1.84
N/A
0.00
N/A
scale
Alternative III
N/A
0.00
N/A
0.00
Baseline ROI = 11.8 percent.
8-50
-------
TABLE 8-31. INCREMENTAL CAPITAL REQUIREMENTS OF REGULATORY ALTERNATIVES
FOR THREE-PIECE SHEET COATING FACILITIES (103 $)a
Control
option
IIA
IIB
IIC
IID
Smal
Alternative II
197.0 ,
(7.0)b
N/A
0.00
N/A
1 scale
Alternative III
N/A
0.00
N/A
0.00
Large
Alternative II
310.0 .
(5.5)b
N/A
0.00
N/A
scale
Alternative III
N/A
0.00
N/A
0.00
^Calculated from Table 8-19.
Percentage change from "base case" amount.
N/A signifies that the control option is not applicable to the regulatory
alternative under consideration.
8-51
-------
8.4.3.3 Impacts on Can Forming Facilities. Price impacts, ROI impacts,
and incremental capital outlay requirements are presented in Tables 8-32,
8-33, and 8-34, respectively.
Under Regulatory Alternative II, large-scale firms are indifferent
between the best available waterborne coatings (control option B) and CTG
waterborne coatings (base case) since the costs are identical. Small-scale
firms would have an economic incentive to adopt control option B as the
unit present worth coating cost is slightly less. Thus, no impacts arise
from adoption of this control option. Large firms would ostensibly adopt
control option B even without regulatory action.
The incineration option (control option A) implies a price impact of
0.4 percent for small firms, and 0.5 percent for large firms. Small firms
would suffer a decline in ROI of 4.4 percentage points; large firms would
suffer a decline of 10.1 percentage points. Capital requirements would
increase by 11.8 percent for small firms and by 9.5 percent for large
fi rms.
8.4.3.4 Impacts on Steel- and Aluminum-End Sheet Coating Facilities.
Price impacts, ROI impacts, and incremental capital requirements are given
in Tables 8-35, 8-36, and 8-37, respectively.
Firms are indifferent between the best available (option B) and CTG
(base case) waterborne coatings. Thus, no economic impacts are associated
with this control option.
The incineration option would result in price increases of 0.1 percent,
a decline in ROI of 3.2 percentage points, and incremental capital require-
ments of 12.7 percent.
8.5 POTENTIAL SOCIOECONOMIC AND INFLATIONARY IMPACTS
Executive Order 12044 requires that the inflationary impacts of major
legislative proposals, regulations, and rules be evaluated. The regulatory
alternatives would be considered a major action (thus requiring the prepara-
tion of an Inflation Impact Statement) if either of the following criteria
apply:
1. Additional annualized costs of compliance, including capital charges
(interest and depreciation), will total $100 million within any calendar
year by the attainment date, if applicable, or within five years of
implementation.
8-52
-------
TABLE 8-32. PRICE IMPACTS OF REGULATORY ALTERNATIVES
ON THREE-PIECE CAN FORMING FACILITIES (%)a
Control option
Smal1 scale
Large scale
IIIA
IIIB
0.37
0.00
0.53
0.00
A baseline price of $60 per 1,000 cans was used to calculate the impacts.
The unit present worth costs and rankings from Table 8-24 were used to
determine the cost increases, which were then translated into price in-
creases by dividing them by $60. The "base case" unit cost was assumed to
be incorporated in the $60 base price for 1,000 cans. Thus, increases over
this "base case" cost due to the control options would generate th'e price
increases reported in the table. If the unit coating cost of a control
option was less than the "base case" cost, then there is not impact and
the table entry will read "0.00."
8-53
-------
TABLE 8-33. RETURN ON INVESTMENT IMPACTS OF REGULATORY ALTERNATIVES
ON THREE-PIECE CAN FORMING FACILITIES3
Control option
Small scale
Large scale
IIIA
IIIB
-4.39
0.00
-10.13
0.00
Baseline ROI = 11.8 percent.
8-54
-------
TABLE 8-34. INCREMENTAL CAPITAL REQUIREMENTS OF REGULATORY ALTERNATIVES
FOR THREE-PIECE CAN FORMING FACILITIES (103 $)
Control option
IIIA
IIIB
Small scale
186.0
(11.8)
0.0
Large scale
200.0 ,
(9.5)b
0.0
Calculated from Table 8-20.
Percentage increase from the "base case" amount.
8-55
-------
TABLE 8-35. PRICE IMPACTS OF REGULATORY ALTERNATIVES
ON STEEL- AND ALUMINUM-END SHEET COATING FACILITIES (%)c
Control option
Impact
IVA
IVB
0.09
0.00
aA baseline price of $60 per 1,000 cans was used to calculate the impacts.
The unit present worth costs and rankings from Table 8-25 were used to
determine the cost increases, which were then translated into price in-
creases by dividing them by $60. The "base case" unit cost was assumed to
be incorporated in the $60 base price for 1,000 cans. Thus, increases over
this "base case" cost due to the control options would generate the price
increases reported in the table. If the unit coating cost of a control
option was less than the "base case" cost, then there is no impact and the
table entry will read "0.00."
8-56
-------
TABLE 8-36. RETURN ON INVESTMENT IMPACTS OF REGULATORY ALTERNATIVES
ON STEEL- AND ALUMINUM-END SHEET COATING FACILITIES3
Control option
Change in ROI
IVA
IVB
-3.24
0.00
Baseline ROI = 11.8 percent.
8-57
-------
TABLE 8-37. INCREMENTAL CAPITAL REQUIREMENTS OF REGULATORY ALTERNATIVES
ON STEEL- AND ALUMINUM-END SHEET COATING FACILITIES (10s $)
Control option
Impact
IVA
IVB
180.0 ,
(12. 7)'
0.0
Calculated from Table 8-21.
""Percentage increase from the "base case" amount.
8-58
-------
2. Total additional cost of production is more than 5 percent of the
selling price of the product.
8.5.1 Annualized Cost Criterion
To estimate the incremental annualized cost of compliance with the
regulatory alternatives, the increase in can production between 1980 and
1985 that could be attributed to new sources needed to be determined. This
was done by increasing estimated production in 1979, 65 billion cans, at a
compounded annual growth rate of 5.5 percent (see section 8.1.). All of
the difference between 1985 production of 89.6 billion cans and 1980 produc-
tion of 68.6 billion, or 21 billion cans. In addition, if the actual life
of a facility is assumed to be 10 years, then 10 percent must be replaced
each year by lines that will be subject to NSPS regulations. Therefore,
taking 10 percent of the 1980 production of 68.6 billion cans (over the
five year interval) will yield an additional 34 billion cans. Total produc-
tion over the next five years that will be subject to NSPS regulations is
therefore 55 billion cans.
It was further assumed that all new sources would be one of four
types: (1) small three-piece facilities, (2) large scale three-piece, (3)
small-scale two-piece, and (4) large-scale two-piece facilities. For each
type of facility, the projected increase in output was translated into
"model plant equivalents" by dividing it by the capacity of the facility
(400 million for small scale facilities, 800 million for a large three-piece
plant, and 2,400 million for a large two-piece plant). A small three-piece
plant consisted of one small sheet coating, one small can forming, and
0.364 end coating facility. A large three-piece plant consisted of one
large sheet coating, one large can forming, and 0.727 end coating facility.
The option that had the greatest impact described in section 8.4.3 was
chosen to test for compliance with the annualized cost criterion, to gene-
rate "worst case" results. For all facilities, this was the incineration
option A. The annualized cost of this option was determined by multiplying
a capital recovery factor of 0.1755 (which assumes a discount rate of 11.8
percent and a depreciation period of 10 years) by the installed capital
cost reported in Tables 8-18 through 8-21 and adding this figure to the sum
of the fixed and variable costs. The annualized cost of the "base case"
was similarly determined; the difference between these two costs is the
8-59
-------
incremental annualized cost attributable to the control option. This was
multiplied by the appropriate number of "model plant equivalents" for each
production facility, which were then combined into the four plant size and
type classifications described above. All results are given in Table 8-38.
As the table shows, the maximum impact would be $51 million (large-scale
two-piece), well under the $100 million threshold. In actuality, the
incremental cost of compliance would be much closer to zero, since the
regulatory alternatives would have no impact (see 8.4.3.1). Thus, the
regulatory alternatives do not qualify as a major action by this criterion.
8.5.2 Product Price Criterion
To determine if the price of a three-piece can would rise by 5 percent
or more because of the regulatory alternatives, the maximum price impacts
from Table 8-29 (small- and large-scale sheet-coating facilities), Table 8-32
(can-forming facilities), and Table 8-35 (end-coating facilities) were
summed. Regulatory Alternative II would force small scale facilities to
raise prices by 0.7 percent and large scale facilities by 0.9 percent.
Under Regulatory Alternative III, the price increases would be 0.5 and 0.6
percent for small and large scale facilities, respectively. Alternative
III has no impact, so the price increase would be zero percent.
For two-piece can facilities, under Regulatory Alternative II, the
largest impact for small scale firms was 1.5 percent and for large scale
firms, 1.8 percent. Alternative III has no impact, so the price increase
would be zero percent.
The price increases under both alternatives for three- and two-piece
facilities are well under the 5 percent threshold. Therefore, neither
alternative qualifies as a major action.
8-60
-------
TABLE 8-38. INCREMENTAL ANNUALIZED COST OF COMPLIANCE WITH
REGULATORY ALTERNATIVES, 1985
All incremental
production from
Model plant
equivalents
Control
option
Incremental
cost (103 $)
I. Small three-piece
Sheet coating
Can forming
Steel ends
II. Large three-piece
Sheet coating
Can forming
Steel ends
III. Small two-piece
plants
IV. Large two-piece
plants
138
138
50
69
69
50
138
23
IIA
IIIA
IVA
IIA
IIIA
IVA
IA
IA
6,900
11,592
2,750
21,242t
8,349
17,043
2,750
28,142t
41,676t
50,738L
The incremental annualized cost is equal to the sum of the incremental
operating cost and the incremental annualized capital cost. All cost data
are from Tables 8-18, 8-19, 8-20, and 8-21. To calculate the incremental
annualized capital cost the incremental capital investment was multiplied
by a capital recovery factor of 0.1755 which is based on an interest rate
of 11.8 percent and a depreciation period of 10 years.
DTotal incremental annualized cost of compliance.
8-61
-------
8.6 REFERENCES
1. United States Department of Commerce. U.S. Industrial Outlook, 1979.
Washington, D.C. January 1979. p. 80-84.
2. The Can Manufacturers Institute, Inc. Economic Profile, 1976. Washington,
D.C. 1977.
3. C. H. Kline and Company.
4. Modern Metals. April 1978. p. 32.
5. United States Department of Commerce. U.S. Industrial Outlook, 1979.
Washington, D.C. January 1979. p. 81.
6. The Can Manufacturers Institute, Inc. Metal Can Shipments Report,
1978. Washington, D.C. 1979.
7. McGraw 91. December 1977. A32.
8. Predicasts. October 1978.
9. Metal Bulletin. May 19, 1978. p. 23.
10. Beverage Industry. Annual Manual. 1976-77. p. 130.
11. # Predi. P 54. March 31, 1978. p. 5.
12. Packaging Trends. Modern Packaging. June 1978. p. 10.
13. The Can Manufacturers Institute, Inc. Metal Can Shipments. Annual
Report. 1969.
14. Current Industrial Reports. Metal Cans. Summaries for 1972 through
1976.
15. Telecon. Karpac, J. FECO Division of Bangor Punta with Schumer, R.,
PEDCo Environmental, Inc. February 21, 1979.
16. Telecon. Eckert, R., Rutherford Company, Inc., with Schumer, R.,
PEDCo Environmental, Inc. February 22, 1979.
17. Telecon. Young, F., Crown Cork and Seal with Schumer, R., PEDCo
Environmental, Inc. February 27, 1979.
18. Telecon. Snyder, D., Smith Environmental, Inc., with Knox, A., PEDCo
Environmental, Inc. August 24, 1978.
19. Telecon. Pauletta, C., C-E Air Preheater, Inc. , with Knox, A., PEDCo
Environmental, Inc. August 30, 1978.
8-62
-------
20. Telecon. Sands, S., Eclipse Lookout Co. with Knox, A., PEDCo Environ-
mental, Inc. August 22, 1978.
21. Telecon. Spaulding, P., Immont Inks with Schumer, R. , PEDCo Environ-
mental, Inc. February 23, 1979.
22. Church, F. Coors Cranks up Super!ine, Plans to Peddle Canmaking Know-
How. Modern Metals. October 1978. pp. 82-93.
23. Telecon. Massoglia, M., Research Triangle Institute with Cook, D.,
Container Technology, Inc. September 17, 1979. Can surface coating.
24. Telecon. Massoglia, M., Research Triangle Institute with McMillan,
D., Adolph Coors Company. August 30, 1979. Beverage can surface
coating.
25. Telecon. Massoglia, M., Research Triangle Institute with Donaldson,
R., Reynolds Aluminum. October 31, 1979. Beverage can surface coat-
ing.
26. Bussey, L. E. The Economic Analysis of Industrial Projects. Englewood
Cliffs, NJ, Prentice-Hall, Inc., 1978. p. 220.
27. Bussey, L. E. The Economic Analysis of Industrial Projects. Englewood
Cliffs, NJ, Prentice-Hall, Inc., 1978. p. 222, footnote 23.
28. Bussey, L. E. The Economic Analysis of Industrial Projects. Englewood
Cliffs, NJ, Prentice-Hall, Inc., 1978. p. 73.
29. Bussey, L. E. The Economic Analysis of Industrial Projects. Englewood
Cliffs, NJ, Prentice-Hall, Inc., 1978. p. 78.
8-63
-------
-------
APPENDIX A
EVOLUTION OF THE BACKGROUND DOCUMENT
-------
-------
APPENDIX A
EVOLUTION OF THE BACKGROUND DOCUMENT
This study to develop proposed standards of performance for beverage
can surface coating operations began in September 1978 with Springborn
Laboratories, Inc., initiating the development of background information.
In May 1979 responsibility for preparation of the Background Information
Document (BID) was assigned to the Research Triangle Institute. Major
events since RTI was assigned responsibility are shown in Table A-l.
Initial RTI activities included a review of preliminary drafts of the
Springborn SSEIS and the preparation of the Phase II and III Work Plan. In
June 1979, the Air Pollution Technical Information Center conducted a
literature search on the beverage can surface coating industry. Project
personnel reviewed this information during the next month and selected
specific literature items for further study and analysis.
Prior to RTI's assumption of responsibility for preparation of the
BID, EPA's Emission Monitoring Branch prepared an emission test plan that
involved testing of a three-piece beverage can facility using solvent-borne
coatings without an emission control system and a two-piece beverage can
facility using solvent-borne coatings with incineration. The emission test
at the three-piece can plant, scheduled in July, was aborted because of
fire damages to the test equipment. This test as well as the emission test
of the two-piece can plant were performed in October by the Research Corpora-
tion of New England (TRC) in cooperation with RTI. The test of the three-
piece plant was only partially successful because of loss in shipment of
the coating samples to the laboratory. The test of the two-piece plant was
successful. However, results were not available for inclusion in the draft
BID because of delays in the laboratory analysis of the gas sampler.
In May 1979 the RTI project team met with Springborn Laboratories to
coordinate transfer of responsibility. Also during May a meeting was held
with officials of Midland-Ross Corporation, a vendor of coating cure ovens
and emission control systems.
From May 1979 to date, numerous telephone contacts were made with
coating suppliers, equipment vendors, and beverage can surface coaters to
obtain information on the coating processes, equipment, coating formula-
tions, and emission control systems.
A-3
-------
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The technical background chapters describing the industry, emission
control techniques, reconstruction and modification considerations, model
plants, and regulatory alternatives were completed in December 1979 and
mailed to industry for review and comment. The preliminary economic analy-
sis was completed in January 1980 and the final economic analysis in Febru-
ary.
Industry comments on the draft BID were analyzed and incorporated into
a revised version that was sent to Working Group in February 1980. Working
Group comments as well as delayed industry comments were considered and
incorporated into the present version of the BID along with the proposed
standards and preamble to complete the package that was distributed to
NAPCTAC members in May 1980. Similar packages were sent to industry and
environmental groups.
NAPCTAC review was accomplished in June and the proposal package
submitted for Steering Committee review and AA concurrence in July.
A-5
-------
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
Table B-l lists the locations in this document of certain information
pertaining to environmental impact, as outlined in Agency Guidelines
(39 FR 37419, October 21, 1974).
-------
-------
TABLE B-l. LOCATIONS OF INFORMATION CONCERNING
ENVIRONMENTAL IMPACT WITHIN THE BACKGROUND INFORMATION DOCUMENT
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419,
October 21, 1974)
Location within the Background
Information Document
Background and summary
of regulatory alternatives
Statutory basis for proposing
standards
Relationships to other regulatory
agency actions
Industry affected by the regula-
tory alternatives
Specific processes affected
by the regulatory alternatives
Chapter 6, Section 6.3
Chapter 2, Section 2.1
Chapters 3, 7, and 8
Chapter 3, Section 3.1, and
Chapter 8, Section 8.1
Chapter 3, Section 3.2.
B-3
-------
-------
APPENDIX C
DATA ON LOW-SOLVENT
WATERBORNE
COATINGS
-------
-------
APPENDIX C
DATA ON LOW-SOLVENT WATERBORNE COATINGS
C.I INTRODUCTION
Data on low-solvent waterborne coatings currently in use or being
marketed by coating suppliers are presented in this appendix. It should be
noted that the coatings included in this appendix represent the lower VOC
content coatings being used by some coaters rather than representing the
range of coatings used throughout the beverage can surface coating industry.
The data presented here consolidate and summarize coating information.
C.2 LOW-SOLVENT WATER-BASED COATINGS
C.2.1 Exterior Base Coat
Low VOC content coatings being used for exterior base coating for two-
piece cans and three-piece sheets range from 0.23 to 0.36 kilogram of VOC
per litre of coating solids. Identification and current status are shown in
Table C-l.
C.2.2 Overvarnish
Low VOC content coatings used for overvarnish for two-piece cans and
three-piece sheets, and for exterior coating for steel- and aluminum-end
sheets, range from 0.33 to 0.50 kilogram of VOC per litre of coating solids.
Identification and current status are shown in Table C-2.
C.2.3 Inside Spray, Two-Piece Cans
Low VOC content coatings used for inside spray for two-piece cans range
from 0.83 to 0.95 kilogram of VOC per litre of coating solids. Identification
and current status are shown in Table C-3.
C.2.4 Inside Spray, Three-Piece Cans
Low VOC coatings used for inside spray for three-piece steel cans range"
from 0.58 to 0.64 kilogram of VOC per litre of coating solids. Identification
and current status are shown in Table C-4.
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C.2.5 Interior Base Coat, Three-Piece Cans
Low VOC content coatings used for interior base coating for three-piece
sheets and interior coating for aluminum- and steel-end sheets range from 0.50
to 0.53 kilogram of VOC per litre of coating solids. Identification and
current status are shown in Table C-5.
C.2.6 Exterior Coat, Three-Piece Cans
Low VOC content coatings used for exterior base coating for three-piece
sheets contain 0.50 kilogram of VOC per litre of coating solids. Identifica-
tion and current status are shown in Table C-6.
C.2.7 Exterior Coat, Steel- and Aluminum-End Stock
Low VOC content coatings used for exterior coatings for steel and aluminum
sheets for end stock range from 0.48 to 0.52 kilogram of VOC per litre of
coating solids. Identification and current status are shown in Table C-7.
C.2.8 Interior Coat, Steel- and Aluminum-End Stock
Low VOC content coatings used for interior coating for steel and aluminum
sheets for end stock range from 0.48 to 0.52 kilogram of VOC per litre of
coating solids. Identification and current status are shown in Table C-8.
C-8
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C-12
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C.3 REFERENCES
1. Letter from Donaldson, R., Reynolds Metal Company to Drake, W., Research
Triangle Institute. January 31, 1980.
2. Telecon. Massoglia, M. , Research Triangle Institute with Donaldson, R.,
Reynolds Metal Company. October 31, 1980. Beverage can lines.
3. Telecon. Salman, D., U.S. Environmental Protection Agency and Massoglia, M.,
Research Triangle Institute with Fitzgerald, N., Metal Container Corpora-
tion. April 1, 1980. Beverage can lines.
4. Material Safety Data Sheet. "Purair" S121-121A, Modified Acrylic Aqueous
Exterior White Base Coating. Inmont Corporation. Cincinnati, OH.
5. Material Safety Data Sheet. "Purair" S145-121, Modified Acrylic Aqueous
Finishing Overvarnish. Inmont Corporation. Cincinnati, OH.
6. Telecon. Massoglia, M., Research Triangle Institute, with Gerhardt, G.,
Mobil Chemical Company. June 26, 1980. Beverage can surface coating.
7. Trip Report. Massoglia, M., Research Triangle Institute, to Miller
Brewing Company, Reidsville, NC. April 22, 1980.
8. Technical Information, DuPont Packaging Finishes. RK-Y-6077. Water-
Based Interior Spray Can Coating.
9. Telecon. Massoglia, M., Research Triangle Institute with La Barre, G.,
E. I. DuPont de Nemours & Co. June 20, 1980. Beverage can .surface
coating.
10. Letter from Nimon, L., Glidden Coating & Resins to Massoglia, M., Research
Triangle Institute. June 11, 1980.
11. Massoglia, M., Research Triangle Institute, Memorandum to the Record.
June 12, 1980. Meeting with National Can Company, May 29, 1980.
12. Telecon. Massoglia, M., Research Triangle Institute, with Scalgo, J. ,
Dexter-Midland. June 25, 1980. Beverage can surface Coating.
13. Telecon. Massoglia, M., Research Triangle Institute with Kosiba, R.,
National Can Company. June 24, 1980. Beverage can surface coating.
C-13
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APPENDIX D
EMISSION MEASUREMENT AND
CONTINUOUS MONITORING
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APPENDIX D - EMISSION MEASUREMENT AND
CONTINUOUS MONITORING
D.I EMISSION MEASUREMENT METHODS •
During the standard support study for the can coating industry, the
U.S. Environmental Protection Agency conducted tests for volatile organic
compounds (VOC) at two plants. At one three piece steel can manufacturing
plant one set of equipment (line) used to apply and cure the base coat
to the sheets of steel was tested. The purpose of this test program was
to determine the relative amounts of VOC emitted from various portions
of the process line compared to the VOC in the coating used. The specific
areas of concern were the application station including the flashoff
area prior to the oven and the oven exhaust. The amount of solids
applied to the steel sheets was also determined. To reduce variations
in the test results due to process variations incurred from using different
solvent content coatings, all of the test program was conducted with the
same base coat. Since the purpose of the test program was to determine
the relative amounts of VOC emitted from the various parts of the line,
no attempt was made to assure that this coating represents the 'average1
coating used at this plant or in the industry. The coating used, however,
represents about 30 percent (by volume) of the total coating used at
this plant.
A total of six runs were conducted to determine the average VOC
emissions split. Each run consisted of coating approximately 1900
sheets of metal and lasted approximately 30 minutes. During each run a
material balance was conducted on the weight of coating (as applied),
and roller cleaning (or backwash) solvent. Additionally, thirty individual
sheets were preweighed, inserted into the 1900 sheets, coated, cured, and
D-3
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then reweighed to obtain an average, solids weight gain on the sheets due
to the coating process. (As an additional procedure, each of these
thirty sheets were also checked using an instrument in use by the company
which measures solids weight gain as a function of electrical resistance
of the solids thickness.) During each run, stack tests were conducted
at the main drying oven exhaust and the cooling zone exhaust. The stack
tests included determining 0) the volumetric flow rates at both locations
using EPA Reference Methods 1 and 2, (.2) the average VOC concentration
at both locations using proposed EPA Reference Method 25, "Determination
of Total Gaseous Nonmethane Organic Emissions as Carbon (TGNMO)", and
(3) the continuous VOC concentration at the main oven exhaust by direct
measurement with a flame ionization analyzer calibrated with propane.
At the second plant, a two piece aluminum can manufacturing plant,
the equipment used to apply and cure the interior coating (inside spray)
to the cans was tested. The purposes of this test program were to
determine (1) the relative amounts of VOC emitted from various portions
of the process line compared to the total VOC in the coating used and
(2) the effectiveness of the enclosed conveyor system in capturing VOC
emitted. The specific areas of concern were (1) the application station,
(2) the enclosed conveyor system between the application station and the
oven, and (3) the oven exhaust. The amount of solids applied to individual
cans was also determined for a limited number of cans. Because this plant
uses only one type of interior coating, the emission data should be re-
presentative of this plant within the limits of accuracy of the data. However,
no attempt was made to ascertain the relationship of this coating or plant
to the 'average' within the industry.
0-4
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This plant is a computer controlled plant with four lines (sets of
equipment) used to manufacture cans. The test program consisted of
performing a material balance of the volume of interior coating used
during a test period of 3 to 8 hours each day for 4 days. The number
of cans produced to which interior coating was applied was determined by
monitoring the individual counters on each interior coating nozzle on
all four lines. This provided daily average coating usage per can.
Because one line was producing a different size can, the number of cans
coated on that line was adjusted by a ratio of surface area coated to
surface area of the cans coated on the other lines. Throughout the test
program, a total of six stack test runs were completed at the interior
spray operation on one of the four production lines to characterize the
average VOC emissions split. During each run of approximately 30 minutes,
the total number of cans coated on that line was recorded, and the average
VOC concentration at three locations was determined using proposed EPA
Reference Method 25 and an integrated bag sampling technique analyzed by
FIA. Additionally, throughout the test program, volumetric flow rates were
determined at these locations and three other locations. The number of
cans coated, the volumetric flow rates, and average VOC concentrations
were used to obtain average VOC emission rates per can at these various
locations. The average VOC Emission rate on a per can basis has been
estimated from the company's record of solvent content of the coating
and the average coating usage obtained from the material balance. The
percentage split of emissions are based on this estimate.
D-5
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D.2 PERFORMANCE TEST METHODS
Performance test methods are needed to determine the VOC content of
the coating and to determine the overall control efficiency of an add-on
VOC control system.
D.2.1 Volatile Organic Compound Content of the Coating
The volatile organic content of the coating may be determined by
the manufacturer's formulation or from Reference Method 24, "Determination
of Volatile Organic Content tas Mass) of Paint, Varnish, Lacquer, or
Related Products."
Reference Method 24 combines several ASTM standard methods which
determine the volatile matter content, density, volume of solids, and water
content of the paint, varnish, lacquer, or related coating. From this
information, the mass of volatile organic compounds (VOC) per unit volume
of coating solids is calculated. The estimated cost of analysis per
coating sample is $150. For aqueous coatings, there is an additional $100
per sample for water content determination. Because the testing equipment
is standard laboratory apparatus, no additional purchasing costs are
expected.
D.2.2 Control Efficiency of VOC Add-on Control System
If the VOC content of the coatings used exceeds the level of the
recommended standard, the efficiency of the add-on control system must be
determined. This would be used in conjunction with the VOC content of the
coating used to determine compliance with the recommended standard.
For those types of control systems which do not destroy or change the
nature of VOC emissions, the recommended procedure is a material balance
system where the mass of the VOC recovered by the control system is
D-6
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determined and used in conjunction with, the mass of VOC in the coating
used over the same period of time. The length of time during which this
material balance is conducted will be dependent on the Agency decision
on whether to require continual compliance or to demonstrate compliance
during an initial performance, test. Examples of control systems where
this procedure would be applicable are refrigeration and carbon adsorption
systems.
For those control systems which alter the VOC emissions (such as
incinerators] a different approach is recommended. Ideally, the procedure
would directly measure all VOC emitted to the atmosphere. However, this
would require measurement of the VOC emissions which escape capture prior
to the incinerator (control system) by construction of a complex ducting
system and measurement of the VOC emissions exhausting to atmosphere from
the control system.
The recommended procedure requires simultaneous measurement of the
mass of VOC (as carbon) entering the control system and exiting the control
system to the atmosphere. Methods 1, 2, 3, and 4 are recommended to
determine the volumetric flow measurements. Reference Method 25
is recommended to determine the VOC (as carbon) concentration. These
results are then combined to give the mass of VOC (as carbon) entering the
control system and exiting the control system to the atmosphere. The
control efficiency of the control system is determined from these data.
Th.e average of three runs should be adequate to characterize the control
efficiency of the control system. The length of each run would be dependent
on the operational cycle of the control system employed. Minimum
sampling time would be in the range of 30 minutes and would be dependent on
the size of the evacuated tanks and the sampling rate employed to obtain a
D-7 :
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sample. The control agency should also consider the representativeness of
the solvents and coatings used during the test program. It is assumed
that the manufacturers of the oven and incinerator will design the system based
on a maximum organic loading which would occur at the maximum line speed,
with use of the highest percent solvent content coating, and the lowest
molecular weight solvent (which are typically the most difficult to
combust). The designer would also assume 100 percent capture (i.e., no
fugitive losses). Although the actual testing time using Reference Method
25 is only a minimum of 1 1/2 hours, the total time required for one
complete performance test is estimated at 8 hours, with an estimated overall
cost of $4,000.
D.3 MONITORING SYSTEMS AND DEVICES
The purpose of monitoring is to ensure that the emission control
system is being properly operated and maintained after the performance
test. One can either directly monitor the regulated pollutant, or instead,
monitor an operational parameter of the emission control system. The aim
is to select a relatively inexpensive and simple method which will indicate
that the facility is in continual compliance with the standard.
For carbon adsorption systems, the recommended monitoring test is
identical to the performance test. A solvent inventory record is
maintained, and the control efficiency is calculated every month. Excluding
reporting costs, this monitoring procedure should not incur any additional
costs for the affected facility, because these process data are normally
recorded anyway, and the liquid volume meters were already installed for the
earlier performance test.
For incinerators, two monitoring approaches were considered:
(1) directly monitoring the VOC content of the inlet, outlet, and fugitive
D-8
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vents so that the monitor-ing test would be similar to the performance tests;
and (2} monitoring the operating temperature of tfie incinerator as an
indicator of compliance. The first alternative would require at least two
continuous hydrocarbon monitors with recorders, Cabout $4,000 each), and
frequent calibration and maintenance. Instead, it is recommended that a
record be kept of the incinerator temperature. The temperature level for
indication of compliance should be related to the average temperature
measured during the performance test. The averaging time for the
temperature for monitoring purposes should be related to the time period
for the performance test, in this case 1 1/2 hours. Since a temperature
monitor is usually included as a standard feature for incinerators, it is
expected that this monitoring requirement will not incur additional costs
for the plant. The cost of purchasing and installing an accurate temperature
measurement device and recorder is estimated at $1,000.
D-9
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D.3 REFERENCES
1. (Proposed) Method 25 - Determination of Total Gaseous Nonmethane Organic
Emissions as Carbon: Manual Sampling and Analysis Procedure.
Federal Register. 40 CFR Part 60, vol. 44, No. 195. October 5, 1979.
p. 57808.
2, (Proposed) Method 24 (Candidate 2) - Determination of Volatile Organic
Compound Content (as mass) of Paint, Varnish, Lacquer, or Related
Products. Federal Register 40 CFR Part 60, vol. 44, No. 195. October 5.
1979. p.' 57807.
D-10
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing}
REPORT NO.
EPA-450/3-80- 036a
I. RECIPIENT'S ACCESSION NO.
TITLE AND SUBTITLE
Beverage Can Surface Coating Industry - Background
Information for Proposed Standards
5. REPORT DATE
September 1980
6. PERFORMING ORGANIZATION CODE
AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3056
2. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air, Noise, and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Draft
14. SPONSORING AGENCY CODE
EPA/200/04
5. SUPPLEMENTARY NOTES
16. ABSTRACT
Standards of Performance for the control of emissions from the beverage can
surface coating industry are being proposed under the authority of section 111
of the Clean Air Act. These standards would apply to all beverage can surface
coating lines for which construction or modification began on or after the date
of proposal of the regulations. This document contains background information
and environmental and economic assessments of the regulatory alternatives con-
sidered in developing the proposed standards.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air pollution
Pollution control
Standards of performance
Beverage cans
Volatile organic compound
Surface coating
Air Pollution Control
13B
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
230
2O. SECURITY CLASS IThis page I
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDI TION is OBSOLETE
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