-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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