-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.
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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
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-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.
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