United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/3-SO-035b
October 1982
Air
Metal Coil
Surface Coating
industry —
Background Information
for Promulgated Standards
Final
EIS
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EPA-450/3-80-035b
Metal Coil Surface
Coating Industry —
Background Information
for Promulgated 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
October 1982
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This report has been reviewed by the Emission Standards and
Engineering Division of the Office of Air Quality Planning and
Standards, EPA, and approved for publication. Mention of
trade names or commercial products is not intended to constitute
endorsement or recommendation for use. Copies of this report
are available through the Library Services 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, Virginia 22161.
11
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ENVIRONMENTAL PROTECTION AGENCY
Background Information
and
Final Environmental Impact Statement
for
Metal Coil Surface Coating Industry
Prepared by:
_
Don R. Goodwin (Date)
Director, Emission Standards and Engineering Division
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
1. The promulgated standards of performance would limit emissions of
volatile organic compounds from new, modified, and reconstructed
metal coil 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 of the United
States would be affected by these standards.
2. Copies 'of this document have been sent to the Department of
Labor; Department of Agriculture; Department of Commerce; Office
of Management and Budget; Council of Environmental Quality;
members of the State and Territorial Air Pollution Program Admini-
strators, and the Association of Local Air Pollution Control
Officials; EPA Regional Administrators; and other interested
parties.
3. For additional information contact: Mr. Fred Porter
Standards Development Branch (MD-13)
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Telephone: (919) 541-5578
4. 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
m
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TABLE OF CONTENTS
Page
SUMMARY 1-1
1.1 Summary of Changes Since Proposal 1-1
1.2 Summary of Impacts of Promulgated Action 1-1
1.2.1 Alternatives to Promulgated Action 1-1
1.2.2 Environmental Impacts of Promulgated Action 1-2
1.2.3 Energy and Economic Impacts of Promulgated Action. . 1-2
1.2.4 Other Considerations 1-2
SUMMARY OF PUBLIC COMMENTS 2-1
2.1 General 2-1
2.2 Emission Control Technology 2-7
2.3 Environmental Impact 2-9
2.4 Legal Considerations 2-10
2.5 Test Methods and Monitoring 2-10
LIST OF TABLES
Page
2-1 List of Commenters on the Proposed Standards for the Metal
Coil Surface Coating Industry 2-2
IV
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1. SUMMARY
On January 5, 1981, the U.S. Environmental Protection Agency (EPA)
proposed standards of performance for metal coil surface coating operations
(45 FR 1102) under authority of Section 111 of the Clean Air Act. Public
comments were requested on the proposal in the Federal Register. There
were seven commenters, composed mainly of coil coaters and coating manu-
facturers. Also commenting were the Ohio Environmental Protection Agency
and the U.S. Department of the Interior. Two presentations were made at
the public hearing on February 4, 1981. The comments that were submitted,
along with responses to these comments, are summarized in this document.
The summary of comments and responses serves as the basis for the revisions
made to the standards between proposal and promulgation.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
Significant changes in the standards since proposal involve compliance
and reporting procedures. Specifically, a procedure was added to the
compliance provisions by which coil coaters can compute a monthly emission
limit for affected facilities that control emissions by the combined use of
low-solvent technology and higher solvent coatings with a control device.
In addition, reporting of monthly performance test data has been dropped
from the standards, but owners and operators are required to record and
maintain these data.
1.2 SUMMARY OF IMPACTS OF PROMULGATED ACTION
1.2.1 Alternatives to Promulgated Action
The regulatory alternatives are discussed in Chapter 6 and Appendix E
of the background information document (BID) for the proposed standards.
These regulatory alternatives reflect the different levels of emission
control, from which one is selected that represents the best demonstrated
technology, considering costs, nonair quality health, and environmental and
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economic impacts for metal coil surface coating. These alternatives remain
the same.
1.2.2 Environmental Impacts of Promulgated Action
Environmental impacts are discussed in Chapter 7 and Appendix E of the
proposal BID. These impacts remain unchanged.
1.2.3 Energy and Economic Impacts of Promulgated Action
Energy and economic impacts are discussed in Chapters 7 and 8 and
Appendix E of the proposal BID. These impacts remain unchanged.
1.2.4 Other Considerations
1.2.4.1 Irreversible and Irretrievable Commitment of Resources.
Chapter 7 of the proposal BID contains a. discussion of irreversible and
irretrievable commitment of resources. These impacts remain unchanged.
1.2.4.2 Environmental and Energy Impacts of Delayed Standards.
Chapter 7 of the proposal BID contains a discussion of the environmental
and energy impacts of delayed standards. These impacts remain unchanged.
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2. SUMMARY OF PUBLIC COMMENTS
Table 2-1 shows the list of commenters, their affiliations, and the
U.S. Environmental Protection Agency (EPA) docket number assigned to each
of their comments. Six letters commenting on the proposed standards and
the background information document (BID) for the proposed standards were
received. The significant comments have been combined into the following
categories:
1. General
2. Emission control technology
3. Environmental impact
4. Legal considerations
5. Test methods and monitoring.
The comments, issues, and their responses are discussed in the following
sections of this chapter. A summary of the changes to the standards is
included in Section 1.2 of Chapter 1.
2.1 GENERAL
2.1.1 Comment: Two commenters (IV-F-la, IV-D-5) questioned the need for a
new source performance standard (NSPS) for coil coating, stating that, for
economic reasons, new coil coating lines already employ the best technology
for capturing VOC emissions to burn as fuel for their ovens and, therefore,
do not contribute significantly to VOC emissions nationwide. They also
questioned EPA's determination that coil coating contributes significantly
to air pollution.
Response: Section 111 of the Clean Air Act requires EPA to promulgate
NSPS's for all source categories that contribute significantly to harmful
air pollution [Section lll(b)(l), (f)(!)]. Metal coil coating is such a
category [40 CFR 60.16 (Source Category No. 22); 44 FR 49222 (August 21,
1979)].
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TABLE 2-1. LIST OF COMMENTERS ON THE PROPOSED STANDARDS
FOR THE METAL COIL SURFACE COATING INDUSTRY
Docket number Commenter and affiliation
IV-D-1 Cecil S. Hoffman
U.S. Department of the Interior
Office of the Secretary
Washington, DC 20240
IV-D-2 J. V. Day
Kaiser Aluminum and Chemical Corporation
300 Lakeside Drive
Oakland, California 94643
IV-D-3 Jack Bates
IV-F-lb DeSoto, Incorporated
1700 South Mount Prospect Road
Des Plaines, Illinois 60018
IV-D-4 James F. McAvoy, Director
State of Ohio Environmental Protection Agency
361 East Broad Street
Columbus, Ohio 43216
IV-D-5 Lawrence C. Tropea, Jr.
Director of Environmental Control
Reynolds Metals Company
Richmond, Virginia 23261
IV-D-6 F. N. Mudge
Vice President—Technology
Anaconda Aluminum Company
. Louisville, Kentucky 40202
IV-F-la Frank Graziano
Chairman, Technical Committee
National Coil Coaters Association
2300 East Pratt Boulevard
Elk Grove Village, Illinois 60007
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EPA recognizes that the recent trend in the coil coating industry has
been toward the use of incineration with heat recovery as an energy
conserving and economically attractive operating setup. EPA appreciates
the emission reduction that has been achieved by this trend; however,
promulgation of an NSPS is necessary to ensure that emission reductions
reflecting best demonstrated technology (BDT) are achieved.
2.1.2 Comment: One commenter (IV-F-la) stated that EPA regulations cover-
ing VOC emissions from metal surface coating operations are inequitable in
that the emission limits proposed for coil coating are more stringent than
the limits proposed for other metal coating operations.
Response: Section 111 requires that each NSPS reflect BDT for that
source category. EPA uses the same approach in evaluating BDT for different
source categories. The fact that the resulting emission limits are different
for different source categories is irrelevant ["Portland Cement Association v.
Ruckelshaus," 486 F.2d 375, 389 (D.C. Cir. 1973); "National Lime Associ-
ation v. EPA," 627 F.2d 416, 447 n. 108 (D.C. Cir. 1980)].
2.1.3 Comment: One respondent (IV-F-la) commented that the projected
growth of coil coating used in the background study (12 percent per year)
is too high and that a rate of 8 to 10 percent is more realistic.
Response: The 12-percent per year growth rate mentioned in the
background study is a misstatement of the growth rate used in the analyses.
Total coating capacity was estimated to increase by a constant amount each
year over a 5-year period. The increase used was equal to 12 percent of
the total industry capacity in the baseline year. This is not equal to a
12-percent annual growth rate. Stated on a percentage basis, the annual
growth rates assumed were 12 percent the first year, 10.7 percent the
second year, 9.8 percent the third year, 9.0 percent the fourth year, and
8.5 percent the fifth year. Over the 5-year period, the average annual
growth rate was approximately 10 percent per year. This growth rate is
within the range of the growth rate values suggested by the commenter, and,
therefore, EPA concludes that the projections in the background study are
reasonable.
2.1.4 Comment: One commenter (IV-F-lb) stated that he was unsure whether
or not the standards permit a coater to use low VOC-content coatings that
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have a VOC content greater than 0.28 kilograms per liter (kg/£) of coating
solids in conjunction with other lower VOC-content coatings and to comply
by computing the weighted average of the VOC contents.
Response: The standards state that an affected facility is in
compliance if each coating used has a VOC content less than or equal to
0.28 kg/£ of coating solids or-if the volume weighted average VOC content
of all coatings used in a calendar month is less than or equal to 0.28 kg/£
of coating solids. A procedure for computing the volume weighted average
VOC content is provided in the standards. EPA considers that the concerns
of the commenter are clearly covered in the standards as written and,
therefore, made no changes to the wording of the standards in response to
this comment.
2.1.5 Comment: One public hearing participant (IV-F-lb) stated that the
definition of "affected facility" should be changed from each coating
operation to an entire coating line to permit averaging of the two coating
operations on a tandem coil coating line. The public hearing participant
later submitted this comment in a letter (IV-D-3).
Response: The choice of the affected facility for these standards
is based on the Agency's interpretation of Section 111 of the Act and
judicial construction of its meaning. Under Section 111, the NSPS must
apply to "new sources"; "source" is defined as "any building, structure,
facility, or installation which emits or may emit any air pollutant" [Sec-
tion lll(a)(3)]. Most industrial plants, however, consist of numerous
pieces or groups of equipment that emit air pollutants and that might be
viewed as "sources." EPA therefore uses the term "affected facility" to
designate the equipment, within a particular kind of plant, chosen as the
"source" covered by given standards.
In choosing the affected facility, EPA must decide which pieces or
groups of equipment are the appropriate units for separate emission
standards. The Agency must do this in light of the terms and purpose of
Section 111. One major consideration is that the use of a narrower
definition results in bringing replacement equipment under the NSPS sooner.
For example, if an entire plant were designated as the affected facility,
no part of an existing plant would be subject to the standards unless the
plant as a whole were "modified." If, on the other hand, each piece of
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equipment were designated as an affected facility, then, as each piece is
replaced, it would be a new source subject to the standards. Because the
purpose of Section 111 is to minimize emissions by the application of BDT
(considering cost, other health and environmental effects, and energy
requirements) at all new and modified sources, there is a presumption that
a narrower designation of the affected facility is proper. This ensures
that new emission sources would be subject to the standards as they are
installed. This presumption can be overcome, however, if the Agency
concludes that relevant statutory factors (technical feasibility, cost,
energy, and other environmental impacts), point to a broader definition.
Designation of an entire coil coating line or an entire plant as an
affected facility was considered in the development of the standards.
These options were rejected in favor of designating each coating operation
as an affected facility. In addition to the advantages cited above, this
designation also simplifies recordkeeping and enforcement activities and,
in many cases, gives added flexibility to owners or operators by allowing
them to use different control technologies on each coating operation without
the need for complicated averaging calculations.
2.1.6 Comment: One commenter (IV-D-6) stated that the definition of "coil
coating" is too broad and would result in the regulation of many operations
not considered in the development of the standards. The commenter suggested
that the definition of "coil coating" be modified to exclude operations
that process only metal with thicknesses less than 0.178 mm (0.007 in.),
commonly considered to be metal foil, and to exclude operations covered by
the proposed NSPS for can coating.
Response: Metal foil is defined by the Aluminum Association as metal
strip with a thickness less than 0.152 mm (0.006 in.). While metal foil
fits the definition of metal coil contained in the proposed standards
(i.e., a continuous metal strip packaged in a roll or coil), coating
formulations, application rates, emissions, and process operations for foil
are quite different from those for coil. In the background study for the
coil coating standards, EPA did not evaluate foil processing operations nor
identify BDT. Foil processing is therefore excluded from coverage under
the coil coating standards. EPA has, therefore, modified the definition of
"coil coating" to exclude operations that process only metal with a thickness
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less than 0.152 mm (0.006 in). This cutoff point is based on the formal
definition of "foil products" that is used by the aluminum industry and
that was communicated to EPA by the Aluminum Association and verified by a
major producer of foil products. EPA could find no basis for selecting
0.178 mm (0.007 in.) as the point of differentiation as suggested by the
commenter. The comment regarding operations covered by the coil coating
standards that are also covered by the can coating standards reflects a
misinterpretation of the coverage of the standards. Coil coating of can
stock is covered by the coil coating standards but is excluded from coverage
by the can surface coating standards.
2.1.7 Comment: One public hearing participant (IV-F-lb) commented that
affected facilities where waterborne coatings are used for a significant
portion of the time, but where solvent-borne coatings are also used, should
be allowed to meet the waterborne emission limit when waterborne coatings
are used and the emission limit for solvent-borne coatings and a control
device for the remainder of their coating operations. This method of
compliance is not allowed by the proposed standards.
Response: The few coil coating lines that are the basis for the
comment use waterborne coatings for 80 to 90 percent of their coating
operations and solvent-borne coatings for the remainder of the time.
Incinerators for these lines are designed for operation only when solvent-
borne coatings are used and do not have heat recovery facilities. Where
such incinerators are used to reduce emissions from waterborne coatings,
previous EPA analyses indicate that energy costs are very high because of
the required use of a large quantity of supplemental fuel and that emission
reductions are small because of the low VOC concentration in the exhaust
stream. The costs per unit of emission reduction achieved become exorbitant
under these circumstances. Consequently, a procedure was added to the
promulgated standards by which coil coaters can calculate an emission limit
each month based on the relative amounts of coatings used with and without
the emission control device in operation. Operators can then comply with
the calculated emission limit, which will have a value between 0.14 (or a
90-percent emission reduction) and 0.28 kg VOC/A of coating solids applied,
by the combination of waterborne coatings and solvent-borne coatings with a
capture system and control device.
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Two approaches were considered for this provision. Under the first
approach (the one incorporated), owners or operators compute an affected
facility's monthly emission limit, weighted according to the coating solids
applied with each control technology, and then compute actual monthly
emissions to determine compliance. Under the second approach, each affected
facility would be required to achieve compliance with the emission limit
for low VOC-content coatings (0.28 kg VOC/2 of coating solids applied)
during the portion of the month when these coatings are used, and would be
required to achieve compliance with the emission limit for higher VOC-content
coatings and a control device (0.14 kg VOC/2 of coating solids applied, or
a 90-percent emission reduction) for the portion of the month when this
system is used.
The second approach has a disadvantage relative to the first one in
that the averaging time over which compliance must be demonstrated may
range from 1 day (or less) to a calendar month (~30 days). The established
emission limits are based on a calendar month averaging time to allow
owners or operators the flexibility of using coatings with a wide range of
VOC content, which is very common in the industry, and still achieve
compliance on a monthly basis. If the averaging time is reduced to less
than a calendar month, the data may not support the emission limits now
specified. In view of this disadvantage, the first approach was incorpor-
ated into the standards. The number of installations to which this
provision applies is quite small, but the provision was determined
necessary to allow particular installations to continue with their normal
operating patterns.
2.2 EMISSION CONTROL TECHNOLOGY
2.2.1 Comment: One public hearing participant (IV-F-la) and one commenter
(IV-D-5) stated that the emission limit for low VOC-content coatings
contained in the proposed standards, 0.28 kg VOC/£ of coating solids
applied, is too stringent and would stifle research and development
activities in low-solvent technology. It was further stated that the
emission limit in the proposed standards was based mainly on coatings
applied to architectural and building products and that the technology was
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not demonstrated for all applications. Particular reference was made to
the coating of can-end stock as requiring a separate emission limit for
low-solvent technology.
Response: EPA believes that the data obtained during the background
study adequately demonstrate the availability of waterborne coatings that
will meet the proposed emission limits for most applications. EPA did not
identify any low VOC-content coatings applicable for coil coating can-end
stock and does not know of any now in use. The coil coating lines identified
during the background study that coat can-end stock all use solvent-borne
coatings. In recent discussions, several coating manufacturers stated that
they are now working on the development of waterborne coatings for can-end
stock and that the operating requirements for this application pose difficult
problems in reducing the VOC content of the coatings. Reasons cited for
these problems include the limitations established by the U.S. Food and
Drug Administration on the ingredients that can be used in such coatings
and the severe stress that the coatings must withstand during the can-end
forming process.
Some coating manufacturers have indicated that coatings for can-end
stock with a VOC content in the range of 0.4 to 0.5 kg/A of coating solids
may become available within the next few years, but they do not expect the
levels of VOC content to be much below this range. Emissions from such
coatings would be substantially greater than emissions from other coil
coating operations that use either low VOC-content coatings or higher
VOC-content coatings and incineration.
Because the use of higher VOC-content coatings with a control device
has been determined to be technically and economically feasible and not
exorbitantly costly, EPA has not established a separate emission limit for
coil coating of can-end stock.
2.2.2 Comment: One commenter (IV-F-la) suggested that, instead of placing
stringent emission limits on coil coaters, EPA should require other metal
surface coating operations to change to the use of precoated coil as a more
environmentally favorable process.
Response: EPA has identified BDT (considering cost, other health and
environmental effects, and energy requirements) for each metal surface
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coating operation and has based the standards for each operation on that
technology. The Agency believes that this procedure is consistent with the
provisions of Section 111 of the Clean Air Act. This comment addresses
other surface coating NSPS's and does not question or cast any doubt on the
appropriateness of the coil coating NSPS; therefore, no changes have been
made as a result of this comment.
2.2.3 Comment: One commenter (IV-D-5) suggested that the proposed stand-
ards incorrectly emphasize the installation of incinerators over the use of
low-solvent technology and stated that EPA did not consider low-solvent
technology in the development of the standards. The commenter further
stated that the energy analysis was flawed by incorrect assumptions related
to coater room exhausts.
Response: These comments were originally submitted at the National
Air Pollution Control Techniques Advisory Committee (NAPCTAC) meeting in
June 1980 and were resubmitted along with additional comments relating to
the proposed standards. Subsequent to the NAPCTAC meeting and prior to
proposal, EPA made changes to the standards in response to these comments.
Several additional regulatory alternatives were evaluated, and separate
provisions were added to the standards relating to the use of low-solvent
technology. As proposed, the standards allow compliance by either low-
solvent technology or incineration. The comment regarding consideration of
low-solvent technology is therefore not applicable. Changes were also made
to the provisions relating to coating rooms. As a result, the coater room
exhaust is no longer required to enter the oven or control device. The
energy-related comment referring to the coater room exhaust requirement
also no longer applies. EPA therefore believes that an adequate response
has been made to these comments and that they do not pertain to the proposed
standards.
2.3 ENVIRONMENTAL IMPACT
2.3.1 Comment: One commenter (IV-D-5) stated that the draft environmental
impact statement (EIS) in the proposal BID may understate final emission
levels by a factor of 2 because incinerators are only capable of achieving
a 90-percent reduction in VOC emissions rather than the 95 percent reduction
assumed in the development of the draft EIS.
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Response: EPA believes that the emission test data presented in the
proposal BID adequately demonstrate the ability of incinerators to reduce
emissions by 95 percent when operated at a temperature of 760° C (1,400° F)
or more. This conclusion is based on emission tests at four plants where
the incinerators were operated at 760° C (1,400° F) or greater and that
achieved an emission reduction of 95 percent or greater and on tests at a
fifth plant where an emission reduction of 95 percent or more was achieved
at temperatures below 760° C (1,400° F). These data are itemized in
Chapter 4 of the proposal BID.
2.4 LEGAL CONSIDERATIONS
2.4.1 Comment: One commenter (IV-D-5) stated that EPA's raw data base for
the proposed standard is inadequate and was not based on Reference Method 25
testing.
Response: The standards are based on the Reference Method 25 test
conducted by EPA during the background study. This test showed a
95-percent reduction across the incinerator at a temperature of 760° C
(1,400° F). During that test, a continuous flame ionization detector (FID)
was also used to measure VOC concentration in the incinerator outlet. The
FID measurements consistently showed an emission reduction of approximately
99 percent at 760° C (1,400° F). There are other test data available that
were obtained with an FID. In all these tests where the incinerator was
operated at 760° C (1,400° F) or greater, the FID data consistently show an
emission reduction of approximately 99 percent. These other data reinforce
the validity of selecting 95 percent as the standard based on Reference
Method 25 measurements.
2.5 TEST METHODS AND MONITORING
2.5.1 Comment: One commenter (IV-D-2) believes that Reference Method 25
is inappropriate as the only method for compliance testing because it is
virtually unavailable to any source outside the Los Angeles area, where the
air pollution control district owns the equipment and performs the tests,
or outside the service area of a single commercial laboratory in the
Midwest capable of carrying out the technique.
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Response: There are at least five commercial laboratories in the
Midwest and Northeast that are capable of performing compliance tests using
Reference Method 25. Most of these laboratories are capable of supplying
testing services to any region of the country.
2.5.2 Comment: One commenter (IV-D-2) stated that Reference Method 25 is
highly laboratory oriented and requires extensive capital investment if
individual sources must prepare to carry out the testing procedure. This
commenter further stated that Reference Method 25 is subject to criticism
for potential bias; that no suppliers exist for an instrument to handle
analyses of Reference Method 25 test samples; and that, while one U.S.
company has offered an instrument for sale, it has not performed reliably.
Response: At least one company has already built a prototype instrument,
which has functioned reliably as the nonmethane organic analyzer described
in Reference Method 25. In addition, there are now a number of commercial
laboratories capable of supplying this service.
2.5.3 Comment: One commenter (IV-D-2) was particularly concerned with the
inability of Reference Method 25 to account for the bias that can be
introduced by particulate matter, such as a flake of paint or a droplet of
condensed hydrocarbon.
Response: Although organic particulate matter could be a potential
problem if it were collected in the Reference Method 25 sampling train,
this can be easily prevented by including a filter in the sample train
upstream of the cold traps. Using a filter is an option that is permitted
in Reference Method 25.
2.5.4 Comment: One commenter (IV-D-2) believes that alternative test
procedures are available by which direct measurement can be made of total
gaseous organic compounds with an FID. This method has adequately
demonstrated the ability to monitor emissions on a real-time basis—an
ability particularly important for cyclic processes or those that do not
emit a uniform level of pollutants. The commenter, therefore, urged that
the Agency consider substituting a more suitable method or, at least,
providing for one or more alternative methods. The commenter offered to
provide documentation and detail of the method considered superior and
practical.
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Response: EPA is presently developing a procedure using a flame
ionization analyzer that may be used as an alternative method in certain
cases. It will be permitted as an alternative procedure for determining
the efficiency of control devices on coating operations if the analyzer is
calibrated with the solvent material used in the coating process. This
procedure will be available for use as an alternative procedure as soon as
it is published in the Federal Register in its final form and the necessary
changes have been made in the appropriate regulations.
In the meantime, one can apply under §60.8(b) for alternative method
status. All that is required is that one submit a detailed written procedure
for the candidate method comparing the candidate method and the reference
method.
2.5.5 Comment: A comment received during the development of another
surface coating standard questioned the relationship of the proposed stand-
ards and the use of reference Method 24 for determining compliance. The
commenter stated that the proposed standards should include a "cushion"
that would allow for differences in test results caused by variations in
the three experimentally determined parameters used to calculate VOC content
of coatings.
Response: Upon evaluation, EPA determined that this comment is equally
applicable to the coil coating regulation.
EPA recognizes the potential variability in the results when Reference
Method 24 is used to analyze water-based coatings. The method itself
contains a procedure to account for this variability. The promulgated
standards require that, when Reference Method 24 results are used to
determine compliance, they be adjusted as described in Section 4.4 of
Reference Method 24. This adjustment applies only to waterborne coatings.
If the actual VOC level of a waterborne coating is at or below the
standard, there is less than 1 chance in 10,000 that the Reference
Method 24 adjusted results will show the VOC level to be above the standard.
2.5.6 Comment: One commenter (IV-F-la) challenged the use of the terms
"total enclosure" and "total capture of VOC emissions" in the proposed test
procedure for incinerators, stating that there is no such thing as total
enclosure and total capture.
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Response: EPA agrees that, taken literally, the terms "total enclosure"
and "total capture of VOC emissions" describe conditions that are extremely
difficult to achieve. Although these terms were used in a practical
engineering sense, a literal interpretation could lead to both compliance
and enforcement difficulties. In view of this possibility, EPA has changed
the wording of the test procedure to eliminate the two terms and has replaced
them with a requirement that coating station enclosures be maintained at a
negative pressure to achieve good capture of VOC emissions.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-80-035b
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Metal Coil Surface Coating Industry - Background
Information for Promulgated Standards
5. REPORT DATE
October 1982
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
3. 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
12. 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
Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Standards of performance for the control of VOC emissions from the metal
coil surface coating industry are being promulgated under Section 111 of the
Clean Air Act. This document contains a summary of public comments, EPA responses,
and a discussion of differences between the proposed and promulgated standards
of performance.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Air pollution
Pollution control
Standards of performance
Metal coil
Volatile organic compound
Surface coating
Air Pollution Control
13B
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. Of PAGES
20
20. SECURITY CLASS /This page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PRBVIOUS EDITION is OBSOLETE
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