-New Source Performance Standards- Beverage Can Surface Coatings Public Participation Status of Regulation A public hearing on the proposed regulation is scheduled for January 6, 1981 at 9 a.m. at the Envi- ronmental Research Center Auditorium, Research Tri- angle Park, NC. EPA in- vites public comment on the proposed NSPS, espe- cially on the use of high- solids or water-based end- sealing compounds. Persons wishing to present additional data, views or other comments on this NSPS at the hearing should contact Deanna Tilley, Standards Development Branch (MD-13), U.S. EPA, Research Triangle Park, NC 27711, telephone (919) 541-5477, no later than December 30,1980. This proposed NSPS was published in the Federal Register (45FR 78980) on November 26, 1980. A Written comments will be accepted on or before February 5, and should be submitted (in duplicate if possible) to: Central Docket Section (A-130), Atten- tion: Docket Number A-80-4, U.S. EPA, Room 2903B, Waterside Mall, 401 M Street SW, Washing- ton, DC 20460. The docket contains all information considered by EPA in developing these proposed standards, and is open for public inspection and copying. The background information document "Beverage Can Surface Coating Operations, Background Infor- mation for Proposed Standards" (EPA-450/3-80- 036a) is available from the EPA Library (MD-35), Research Triangle Park, NC 27711, telephone (919) 541-2777. public hearing is scheduled January 6, 1981, and the final regulation is expected around November, 1981. l " °|» 3" C 3 ° •< JS O 7 5 * I m 3 IIS5&II5 m?f' Ills DOES 3Sn aiEAIJJ JOJ ssauisng Vd3 L ILLZ ON '1-ied a|6uBui ipjeasay i' Hi"iii'.K i II At; ] saieis 2 3' 8 2. !J c H. 2 = > -i m -i 0) W_ 3 O *-*• 5»' 3 1 o 11 « ^ -* 0) Q) M -• — < ^ O O -• O 9 O G) (H S =S to i-* - SB to i-* g. Q.T3 S 0 = ^» "O 3 Q ffi P S * 3 O~ CD Q) U lllf t> O) r* Q. sir?- 5 a 5L 3 ? s c to w 5J ^ « o_ re 9J o a ^ S M S 5 S | < I S3 5 " a 3 S » c • ° 2 a aS'g 5 -.33m 3" c re -, m 5- 3 3 01 B ~ » cr re o> ^ 5S aS < a ^ » xvEPA United States Environmental Protection Agency Off ice of Air Quality Planning and Standards Research Triangle Park, NC 27711 December 1980 New Source Performance Standards Beverage Can Surface Coatings Proposed Regulation ------- -New Source Performance Standards- Beverage Can Surface Coatings New Source Performance Standards The Clean Air Act, as amended in 1977, calls for a comprehensive national program to reduce air pol- lution and improve air quality. The Act requires the U.S. Environmental Protection Agency (EPA) to establish nationwide emission standards for selected new stationary industrial sources. These New Source Performance Standards (NSPS), in accordance with Section 111 of the Act, are designed to prevent new air pollution problems. NSPS apply to categories of new, modified, or reconstructed stationary sources that cause or con- tribute significantly to air pollution that could endanger public health or welfare. The recently proposed NSPS for beverage can surface coating operations is discussed below. Beverage Can Surface Coatings Setting Standards to Limit Emissions Section 111 of the Clean Air Act requires EPA to list categories of station- ary sources identified as major contributors to air pollution. After careful study and evaluation, EPA has classified the industrial surface coating of cans as one such source. The industrial surface coating of cans is one of the largest among industrial operations identified as sources of volatile organic ompounds (VOC). This in- dustry ranks second on EPA's priority list of 59 sources targeted for NSPS development. The coating of beverage cans is the largest and fastest growing seg- ment of the can coating industry. The beverage can coating industry emitted an estimated 77,000 metric tons of VOC in 1977, accounting for about 4 percent of the 2 million metric tons of VOC emissions from all industrial surface coating operations. The beverage can industry uses a wide variety of coat- ings to protect the contents from the metal can and to protect the can from the environment. The epoxy, acrylic or polyester enamel coatings used contain or- ganic solvents such as ketones, esters, ethers and aro- matics. The proposed NSPS would apply to all new, mod- ified, and reconstructed beverage can surface coating operations for which construction began after No- vember 26, 1980. Affected facilities include the areas where coatings are applied, the flash-off areas, and the drying or curing ovens. Emissions from the application of end-sealing compounds, storage, handling, and clean-up of coatings and solvents are not included in the standards. The proposed standards set separate limits for seven operations in the manufacture of two-piece and three-piece containers. Plant operations affected by the proposed standards include the following for two-piece beverage cans: each exterior base coat operation, overvarnish coating operations, inside spray coating operations, and interior or exterior end sheet coatings. The same operations are covered in the making of three-piece beverage cans, with the addition of interior base coat operations. The proposed standards would limit VOC emissions from two-piece beverage cans, expressed as kilograms These solvents evaporate during the coating process and form VOC. VOC react in the atmosphere to form ozone, which impairs respiratory functions, irritates the eyes, damages plant tissues, and deteri- orates rubber and other materials. The proposed standards define a beverage can as any two-piece steel or aluminum container or any three- piece steel container in which soft drinks, beer or malt liquors are packaged. Cans in which fruit or veg- etable juices are packaged are excluded from the standard. ^ The NSPS for beverage can surface coating operations would cover only new facilities, or existing facilities that are substantially modified or reconstructed. Physical or operational changes resulting in increased emission rates may be considered modifications. If the cost of componenet replacement in an existing source is more than 50 percent of the cost to con- struct a new source, the replacement may be consid- ered a reconstruction. EPA estimates 10 or 20 two-piece beverage can plants and 4 three-piece beverage can plants will be affected by the proposed NSPS, the latter subject under modi- fication or reconstruction provisions. of VOC per liter of coating solids applied, for the following operations: (1) 0.29 from each exterior base coating operation, (2) 0.46 from each over- varnish coating operation, (3) 0.89 from each inside spray coating operation, and (4) 0.50 from each interior or exterior end sheet coating operation. The proposed limits for three-piece can coating operations would limit emissions to 0.50 kilograms of VOC per liter of coating solids applied for the fol- lowing operations: (1) exterior base coating opera- tions, (2) interior base coating operations, and (3) both interior and exterior coating operations on metal sheets for steel or aluminum ends. Emissions from each inside spray coating operation would be limited to 0.64 kilograms of VOC per liter of coating solids applied. Achieving and Maintaining the Standards The proposed NSPS reflect the best demonstrated sys- tem of continuous emis- sion reduction considering cost, health, energy, and environmental factors as well as factors unrelated to air quality impacts. The proposed VOC emis- sion limits are based on the use of the best available waterborne coatings. Technologies available to achieve the standards include: (1) the use of low-VOC or waterborne coatings, and (2) solvent-borne coat- ings used in combination with emission control systems. Low-VOC or waterborne coatings have been used successfully by the beverage can industry for all coating operations covered by the proposed standards. EPA expects that improved water-based end-sealing compounds will be available by 1982 and expects to propose a standard at that time. No problems are anticipated in using equipment for solvent-based compounds for water-based com- pounds. Incineration is the only emission control device demonstrated to effectively control VOC emissions. Both thermal and catalytic incinerators have been used successfully. However, any control technique can be used, as long as the proposed VOC emission limits are achieved. To determine compliance with the proposed standards, the owner or operator would be required to conduct monthly performance tests by calculating the volume-weighted average of VOC emissions during the calendar month. EPA is proposing the use of two reference test methods to obtain information re- quired in conducting these monthly performance tests. Reference Method 24 would be used to deter- mine the average VOC content of coatings. However, the use of coating manufacturers' data would also be acceptable. Reference Method 25 would be used to determine the percentage of VOC reduction achieved when an emission control system is used for com- pliance. Both reference methods were promulgated on October 3, 1980 (45 FR 65956). The owner or operator would be required to report, within 10 calendar days, each instance in which the volume-weighted average is greater than the emission limitations in the proposed standards. If incineration is used to achieve compliance, continuous monitoring and quarterly reporting of deviations in incinerator operating parameters would also be required. Impacts Energy: Beverage can makers use electricity to power equipment, and natural gas to fuel drying and curing ovens. Based on industry growth projections, the proposed standards would result in an overall annual energy reduction of about 36,000 gigajoules by 1985. This is equivalent to an overall decrease of 34 million cubic feet of natural gas per year in 1985. Environmental: EPA estimates that by 1985, the standards would reduce VOC emissions by about 5,280 tons, or 32 percent beyond the State-regulated level that would occur if no NSPS had been proposed. Little or no solid waste or water pollution impacts are expected to result from implementing the pro- posed standard. Economic/Industrial: EPA expects minimal economic impact on the beverage can industry as a result of the proposed standards. The industry would have an economic incentive to control emissions, even if not regulated. At least one control option is available to each affected facility with a cost equal to or below the cost of complying with State standards. However, if solvent- borne coatings are used with emission control devices, a significant cost increase is possible. ------- |