&EPA
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450-3-80-036b
August 1983
Air
Beverage Can EIS
Surface Coating
Industry—
Background Information
for Promulgated
Standards of Performance
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EPA-450/3-80-036b
Beverage Can 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
August 1983
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DISCLAIMER
This report has been reviewed by the Emission Standards and
Engineering Division of the Office of Air Quality Planning and Stand-
ards, U.S. Environmental Protection Agency, and has been 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,
North Carolina 27711, or from National Technical Information Service,
5285 Port Royal Road, Springfield, Virginia 22161.
PUBLICATION NO. EPA-450/3-80-036b
11
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ENVIRONMENTAL PROTECTION AGENCY
Background Information
and
Final Environmental Impact Statement
for
Beverage Can Surface Coating Industry
by:
Jack R. Farmer (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
two-piece 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 sta-
tionary 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 Administrators, 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
iii
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TABLE OF CONTENTS
Chapter
1 SUMMARY 1-1
1.1 Summary of Changes Since Proposal 1-1
1.2 Summary of Impacts of Promulgated Action 1-2
2 SUMMARY OF PUBLIC COMMENTS 2-1
2.1 General 2-1
2.2 Emission Control Technology 2-12
2.3 Modification and Reconstruction 2-19
2.4 Economic Impact 2-20
2.5 Energy Impact 2-22
2.6 Environmental Impact 2-23
2.7 Legal Considerations 2-24
2.8 Test Methods and Methodology 2-29
2.9 Reporting and Recordkeeping 2-29
2.10 Miscellaneous 2-41
2.11 References 2-41
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LIST OF TABLES
Number Page
2-1 List of Commenters on the Proposed Standards of Perform-
ance for the Beverage Can Surface Coating Industry 2-32
2-2 Comparison of BID Environmental and Energy Analyses
with Analyses Based on CMI/American Can Projections
of Beverage Can Surface Coating Activities 2-34
2-3 Emission Reductions from Emission Control Options, Two-
Piece Steel or Aluminum Integrated Facility, 1985 2-35
2-4 Energy Requirements for Emission Control Options, Two-
Pi ece Cans, Subject to NSPS in 1985 2-36
2-5 Data Base, Beverage Can Surface Coating 2-37
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1. SUMMARY
On November 26, 1980, the Environmental Protection Agency (EPA)
proposed standards of performance for the beverage can surface coating
industry (45 CFR 78980) under authority of Section 111 of the Clean
Air Act. Public comments were requested on the proposal in the
Federal Register. Eighteen comments were received, mostly from
beverage can makers. Also commenting were State air pollution control
agencies, coating suppliers, a trade association, and Federal
agencies. Four presentations were made at the public hearing on
January 6, 1981. The comments that were submitted, along with
responses to those 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
The significant changes to the standards involve the scope of the
standards and enforcement procedures. Three-piece cans and coating of
sheet stock for steel and aluminum ends have been excluded because
EPA's analysis of revised industry projections indicated that no
capacity would be subject to the promulgated standards through 1985.
Provisions have been added requiring the use of analytical precision
statements as outlined in paragraph 4.4 of Method 24 when Method 24
data are used to calculate VOC content of waterborne coatings for
compliance determinations. Reporting requirements after the
initial performance test, except those required under the general
provisions of 40 CFR 60, have been changed to require semiannual
reports of exceedances rather than immediate reporting as initially
proposed.
1-1
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1.2 SUMMARY OF IMPACTS OF PROMULGATED ACTION
1-2.1 Alternatives to Promulgated Action
The regulatory alternatives are discussed in Chapter 6 of the
Background Information Document (BID) for the proposed standards.
These regulatory alternatives reflect different levels of emission
control, one of which is selected as representing the best
demonstrated technology, considering costs, nonair quality health, and
environmental and economic impacts for beverage can surface coating
operations. These alternatives remain the same.
1.2.2 Environmental Impacts of Promulgated Action
Environmental impacts are discussed in Chapter 7 of the proposal
BID. Because of the exclusion of three-piece can and end coating
operations from the promulgated standards and revised industry
projections for two-piece beverage cans, impacts on volatile organic
compound (VOC) emissions are changed. No changes result in the water
and solid waste environmental impacts.
Total reduction in VOC emissions resulting from the promulgated
standards in the fifth year will be 2,900 Mg, as compared with a
reduction of 4,800 Mg estimated under the proposed standards, a
difference of 1,900 Mg. Of this difference, 1,200 Mg are the result
of a downward revision of 1985 two-piece can estimated production and
700 Mg are from the exclusion of three-piece can and end sheet
coating.
This represents a 32-percent reduction in baseline emissions, the
same as estimated for the proposed standards.
1.2.3 Energy and Economic Impacts of Promulgation
Energy and economic impacts are discussed in Chapters 7 and 8 of
the proposal BID as amended by Docket item IV-B-12. The economic
impacts are unchanged.
Reduction in energy requirements, from the baseline, under the
promulgated standards is 19,000 GJ, as compared to 36,000 GJ under the
proposed standards, a difference of 17,000 GJ. Of this difference,
8,000 GJ are the result of a downward revision of 1985 two-piece can
1-2
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estimated production and 9,000 GJ are from the exclusion of three-piece
can and end sheet coating. In both cases this represents a 1-percent
reduction from the baseline.
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
The list of commenters, their affiliations, and the EPA docket
number assigned to each of their comments is shown in Table 2-1.
Eighteen letters commenting on the proposed standards and the
Background Information Document (BID) and four presentations made at
the public hearing were reviewed. The significant comments have been
combined into the following ten categories:
1. General
2. Emission Control Technology
3. Modification and Reconstruction
4. Economic Impact
5. Energy Impact
6. Environmental Impact
7. Legal Considerations
8. Test Methods and Monitoring
9. Reporting and Recordkeeping
10. Miscellaneous
The comments, issues, and their responses are discussed in the
following sections of this chapter. A summary of the changes to the
regulation is included in Section 1.1 of Chapter 1.
2.1 GENERAL
2.1.1 Comment: Four participants at the public hearing (IV-F-1A,
IV-F-1B, IV-F-1C, IV-F-1D), two of whom subsequently submitted written
comments (IV-D-3, IV-D-6), and two commenters (IV-D-4, IV-D-5) stated
that in view of the projected decrease in production of three-piece
beverage cans through 1985, these cans should be excluded from the
standard.
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Response: The growth projections appearing in the draft
Environmental Impact Statement (EIS) were based on then-current
industry estimates of projected market shares of two- and three-piece
beverage cans. The four "model" three-piece plants projected to be
subject to NSPS by 1985 were those projected to become subject to the
modification or reconstruction provisions of 40 CFR 60. Three-piece
can shipments were projected to stabilize at 14.5 billion units
through 1985. This projection did not consider the impact of
escalating energy costs and the inroads that plastic packaging would
make into the metal-can share of the market. Both of these factors
developed fully after the draft EIS was prepared. EPA's analysis of
revised industry projections shows that three-piece can shipments in
1985 will be about 1.5 billion units. As a result, EPA has
recalculated the estimated emission and energy reduction that will
occur in the first 5 years after proposal. Results of these
recalculations are shown in Table 2-2.
The 1980 and 1985 projections of shipments are based on data
provided by the American Can Company and the Can Manufacturers
Institute (CMI).1 2 3
Industry was unable to supply estimates of the fraction of
existing capacity that would be subject to NSPS under the
reconstruction and modification provisions of 40 CFR 60. In response
to a request, the Can Manufacturers Institute reported that future
expansion in existing facilities, which would be considered
"reconstruction" and which would require the use of NSPS material, is
not expected to exceed 1 percent. Market geography makes it
impossible to estimate the fraction of capacity that would be subject
to the modification provisions.3 4 One canmaker reported that an
affected facility on all of its beverage can lines would be subject to
modification by 1985.5 An estimate that 5 percent of capacity, based
on a 20-year life, would become subject to NSPS each year was made in
the BID and the proposed regulation. No exception was taken to this
estimate during the public hearing or the public comment period.
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Consequently, 5 percent of existing 1980 capacity is assumed to come
under the modification or reconstruction provisions of 40 CFR 60
annually during the 1980-1985 period.
The capacity used for coating sheets for three-piece can bodies
will become available for coating steel and aluminum two-piece end
stock as the three-piece can is replaced by the two-piece can during
1980-1985. A 5-percent annual obsolescence rate and a 10-percent
estimated scrap rate for the production of three-piece can bodies and
steel and aluminum ends is assumed, based on 1979 actual shipments as
reported by CMI6 and industry projections.1 2 3 These data imply that
there will be an excess sheet coating capacity in 1985 and, therefore,
that no end sheet coating facilities would be subject to NSPS.
Detailed calculations follow.
Input data
Beverage can shipments:
Three-piece cans
Two-piece cans
Sheet stock data:
Three-piece can sheets
End sheets
Coats per sheet:
Three-piece can sheets
End sheets
1979
(106 units)
9,748
44,694
Units/sheet
35
132
1980
(106 units)
1,500
61,900
Sheet size
(inches)
35 x 42
24 x 42
Three (exterior base coat,
interior base coat,
overvarnish)
Two (exterior coat,
interior coat)
Calculations for 1979
Three-piece cans:
9.748 x 1Q6 cans shipped x sheets required x 1.10 sheets used
year
35 cans
sheets required
x (35 x 42) square inches x 3 CQats = 1>351>070 x 1Q6 square inches
sheet
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Three-piece can ends:
(9.748 x 1.5) 106 ends shipped sheets required x 1.10 sheets used
year 132 ends sheets required
x (24 x 42) square inches x 2 coats = 245 650 x 10e square 1ncnes
sheet
(assumes all steel ends and half of aluminum ends are made from sheets)
Two-piece can ends:
(44.694 -i- 2) x ips ends shipped sheet required x 1.10 sheets used
year 132 ends sheets required
x (24 x 42) square inches x 2 CQats = 375430 x 10e square 1nches
sheet
(assumes that half of the ends are made from aluminum sheets and half
from precoated coil stock)
Total 1979 capacity for beverage cans: 1,972,150 x 106 square inches
Total 1979 capacity available in 1985: 1,449,710 x 106 square inches
1,972,150 (1 - 0.05)6 = 1,449,710
Calculations for 1985 (performed the same as calculations for 1979)
Three-piece cans: 207,900 x 106 square inches
Three-piece ends: 37,800 x 106 square inches
Two-piece ends: 519,960 x 106 square inches
Total capacity required in 1985: 765,660 x 106 square inches
Excess sheet coating capacity, 1985:
1,449,710 - 765,660 = 684,050 x 106 square inches
(Total capacity) (required capacity) (excess capacity)
Because the estimated demands in 1985 for three-piece cans and
end stock coating capacity will be about 50 percent of estimated
available capacity, EPA has determined that no plants would become
subject to NSPS and that standards are not required. Consequently,
three-piece can coating operations and end sheet coating operations
are excluded from the promulgated standards.
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These exclusions and the revised projection for two-piece cans
necessitate changes in the environmental and energy impacts shown in
Tables 7-12 and 7-22 of the draft EIS. Revised environmental and
energy impacts are presented in Tables 2-3 and 2-4, respectively.
2.1.2 Comment: Several comments were received stating that the
proposed standards were not based on the best demonstrated system of
continuous emission reduction (BDT). Three commenters (IV-F-1A,
IV-D-3, IV-D-6) stated that the use of waterborne coatings has not
been demonstrated as being commercially available. One conmenter
(IV-D-3) questioned that solvent-borne coatings and incineration could
be used in the event waterborne coatings were impractical. One
comnenter (IV-F-1C) stated that promulgation of the proposed standards
would force the industry to turn to one supplier for inside spray
materials.
Response: As a result of these comments, EPA significantly
expanded the data base upon which the standards are based through
telephone and written communications with coaters and coating
suppliers. The expanded data base, shown in Table 2-5, substantiated
EPA's previous determination that the use of waterborne coatings is
BDT and that coatings meeting the promulgated emission limits are
available from more than one supplier. Summary of the data base is
presented in the following paragraphs. While the coating of steel
sheets for three-piece can bodies and steel and aluminum sheets for
ends are excluded from the standards (see comment 2.1.1), coating data
for these processes are included in the table. The discussion that
follows is limited to two-piece beverage cans because the promulgated
standards cover only this sector of the beverage can surface coating
industry.
Commercially available waterborne coatings for two-piece cans are
being used by a large number of carmakers representing a majority of
the industry. Identity of coatings, VOC content, and reported usages
are shown in Table 2-5. A summary of these data follows.
2-5
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Two-piece can exterior base coat
Five canmakers, four merchant and one captive, reported using
coatings with VOC contents equal to or less than that specified in the
standards. Three of these canmakers identified four coatings from one
supplier as being used, two reporting the use of complying coatings
for all base coat requirements.10 12 Of the remaining canmakers, one
canmaker did not identify the coating being used,13 and the other
claimed confidentiality for the coating being used.32 One additional
coating from a second supplier has been qualified for use on one
merchant coater's new and existing can lines. In discussions with
canmakers during the collection of the data, no specific cases were
identified in which waterborne coatings could not be used for the
application of exterior base coat to two-piece beverage cans.
Two-piece can overvarnish/clear base coat
Four canmakers, three merchant and one captive, reported using
coatings with VOC contents equal to or less than that specified in the
standards. Two of these canmakers identified four coatings from two
suppliers as being used, one reporting the use of complying coatings
for all overvarnish requirements.12 Of the remaining canmakers, one
did not identify the coating being used,13 and the other claimed
confidentiality for five coatings being used. All of the captive
canmakers1 requirements are being satisfied by waterborne coatings
meeting the NSPS emission limitations. Five additional coatings
meeting the NSPS emission limitations are available from three
suppliers. Future testing is planned for some of these coatings.
In discussions with canmakers during the collection of the data,
no specific cases were identified in which waterborne coatings could
not be used for the application of overvarnish or clear base coat to
two-piece beverage cans.
Two-piece can inside spray
Seven canmakers, five merchant and two captive, reported using
coatings with VOC contents equal to or less than that specified in the
standards. Five of these canmakers identified four coatings from
three suppliers as being used, two reporting the use of complying
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coatings for all inside spray requirements.12 15 Of the remaining
two, one did not identify the coating being used,13 and the other
claimed confidentiality for the coating being used. During the
collection of the data, two specific cases were identified in which
industry maintained that satisfactory waterborne coatings were not
available. One canmaker reported that for two plants making cans for
export, excessive pinholing occurred because the extreme abuse the
cans received in shipping and handling caused separation of the
coating from the inside of the can. In subsequent discussions, the
canmaker reported that the problems had been resolved and that
waterborne coatings meeting the NSPS emission limitations are now
being used for all inside spray operations at one plant. A program is
underway at the second plant to develop a satisfactory waterborne
inside spray system.25 This plant is currently incinerating VOC
emissions from inside spray operations to meet local regulations. In
the second instance, a canmaker reported difficulty in applying
waterborne inside spray to steel cans. In this case, solvent-borne
coatings are still used and incineration is employed to satisfy the
local emission limitations. The same procedures can be used to
satisfy NSPS emission limitations if required. The necessary capture
and destruction of VOC can be attained by enclosing the flashoff areas
and incinerating the flashoff and oven exhausts.29
2.1.3 Comment: One public hearing participant (IV-F-1D) took
exception to statements made in the beverage can factsheet that
probably 4 new three-piece can plants and 10 to 20 new two-piece can
plants were to be built between 1980 and 1985. This is not consistent
with data that industry presented at the NAPCTAC meeting in June 1980,
which indicated a dramatic reduction in three-piece can production and
a leveling off of demand for two-piece cans. This comment was
subsequently submitted in written form (IV-D-6).
Response: The beverage can factsheet (Docket Item 76-36 III-C-1),
a summary of the proposal BID and regulation published at time of
proposal, states that "EPA estimates 10 to 20 two-piece beverage can
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plants and 4 three-piece beverage can plants will be affected by the
proposed NSPS, the latter subject under the modification or
reconstruction provisions." These plants are model plants and are the
number that were considered subject to NSPS for the purposes of the
economic analyses. It should be noted that the statement concerning
three-piece can plants specifically excludes new facilities and
indicates that facilities in place in 1979 would become subject to the
modification or reconstruction provisions. The estimates of the
number of model plants that could be subject to NSPS were based on
industry estimates of the projected market share of two-piece and
three-piece beverage cans that were later changed by data provided by
the industry during the public comment period. As mentioned
(comment 2.1.1), EPA analyzed the new industry data and developed
revised projections that show that no three-piece can plants would be
subject to the NSPS through 1985.
Insofar as two-piece can plants are concerned, based on the
revised projections (see comment 2.1.1) EPA estimates that between 7
and 15 two-piece model plant equivalents would be subject to NSPS in
1985. Half of these will be subject under the reconstruction or
modification provisions. These estimates assume that an average of
5 percent of existing capacity will become subject to NSPS under the
modification and reconstruction provisions each year through 1985.
This is consistent with industry projections that show an increase in
two-piece can shipments from 49.6 billion cans in 1980 to 61.9 billion
cans in 1985.
2.1.4 Comment: One respondent (IV-H-1) suggested that the BID could
be improved by (1) comparing the approximately 900 counties subject to
CTG limitation to the counties presently in nonattainment for ozone
and (2) indicating the impact of achieving the various regulatory
alternatives on the nonattainment states.
Response: Uncertainty as to the exact location of new
facilities and specifics as to which existing facilities will be
modified or reconstructed preclude analyses on a county-by-county
basis.
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2.1.5 Comment: Two public hearing participants (IV-F-1C, IV-F-1D)
stated that if NSPS emission limitations were promulgated, major
reformulation from coatings developed to meet RACT would be required.
This redirection of coating suppliers' efforts would be at the expense
of developing coatings that satisfy RACT. One of these participants
subsequently submitted the comment in writing (IV-D-3). One commenter
stated that the lack of continuity of units between the format of the
standards and that of RACT will cause some coating suppliers to
reformulate (if possible) after they have just recently reformulated
(IV-D-2).
Response: EPA agrees that major reformulation may be required
for some low-solvent coatings. However, based on the data presented
in Table 2-5, this does not appear to be a problem. Coatings listed
in this table were developed to satisfy RACT requirements. A majority
of these coatings also will satisfy NSPS requirements.
2.1.6 Comment: One public hearing participant (IV-F-1D) and one
commenter (IV-D-2) questioned the format of the proposed standards.
The NSPS for the beverage can industry are based on kilograms of VOC
per litre of coating solids. This differs from the format, kilograms
of VOC per litre of coating minus water, currently being used by the
States. While the new method may be more useful, it does not directly
compare with the old method. Therefore, a coating may comply with the
old method but not the new or vice versa.
Response: Compliance with the standards is determined by
comparing the volume-weighted average VOC content of all coatings and
diluent solvents used at each affected facility for each calendar
month with the appropriate emission limitation. This calculation
requires determination of the VOC content of each coating used as mass
per volume of coating solids.
The RACT format can be converted to the NSPS format using the
following equation:
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kilogram of VOC per litre of solids =
kilogram of VOC per litre of coating less water
1 (litre of coating) - kilogram of P61 C0atin9 1ess water
It is recognized that the conversion is sensitive to the VOC
density; the lower the VOC density, the higher the calculated VOC
content. In the conversion of VOC content expressed in the RACT
format for selection of the numerical emission limitations of the
promulgated standards, a density of 0.85 was used. This is lower than
that normally used in waterborne coatings, and resulted in a higher
numerical emission limitation than would have been determined had the
density of the VOC used in the coating been available. This action
favors the coater. Coatings formulated under the existing standards
may still to be used in existing facilities; however, any new,
modified, or reconstructed facility will be required to use coatings
meeting the promulgated emission limitations.
2.1.7 Comment: One commenter (IV-D-4) questioned the need for an
NSPS that requires industry to do what is already being done. New
installations in nonattainment areas would be required to use lowest
allowable emission rate (LAER) which in this case would be "achieved
in practice," that would be the same as the proposed NSPS.
Installations in attainment areas, if any, would of course be required
to apply best available control technology (BACT), which would be the
coatings now in use and the same as the proposed NSPS.
Response: In enacting Section 111, Congress intended to insure
that every new, modified, or reconstructed facility, wherever located,
control emissions to at least a nationally uniform emission ceiling.
Congress recognized that in individual cases greater emissions
reduction could be achieved than that achievable through application
of BDT. For these individual cases, the Act may require application
of more stringent requirements. Even though, as the commenter
suggests, BACT or LAER requirements applicable in such individual
cases may eventually spur development of broadly demonstrated coatings
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similar to or better than NSPS-level coatings, Section 111 still
requires the Agency to set minimum nationally applicable standards
that will insure control of emissions at new sources to at least the
level achievable through use of BDT.
2.1.8 Comment: One respondent (IV-D-5) stated that the proposed
standards do not require the "best demonstrated system of continuous
emission reduction ..." By regulating the VOC content of coatings
for new sources without regard to the quantity of coating supplied,
the Agency is encouraging the construction of new facilities with
greater emissions than identical existing CTG facilities. The
quantity of coating needed by the various canmakers to produce an
acceptable can is a much more significant factor in emission reduction
technology than is the VOC content of the waterborne coatings which
might be used. Manufacturing materials that inherently require less
applied coating than other materials represent a better system of
emission reduction. This is an obvious conclusion drawn from the
draft EIS and from information contained in Docket A-80-4. As a
result of ignoring this fact, the Agency has prepared a standard that
cannot possibly be construed as meeting the intent of Section 111 of
the Clean Air Act.
Response: In EPA's judgment the promulgated standards are
based on BOT (see comment 2.1.2). Formatting the standards in terms
of mass of VOC per unit of production, e.g., 1,000 cans, was
considered in the development of the standards. This approach was
discarded because of inflexibility in accommodating the range of
coating thicknesses used by the industry to meet the requirements of
the many types of beverage cans produced by the industry, especially
at merchant can plants. Such an approach also raises problems in
setting numerical limits for the standards. If an industry-average
coating thickness is used as the basis, coaters using an above-average
coating thickness would be penalized. Specifying maximum thickness
for each coating use is an unreasonable approach and could only
effectively be accomplished at an exorbitant cost. Consequently, this
format was rejected in favor of the mass of VOC per volume of coating
solids format.
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2.2 EMISSION CONTROL TECHNOLOGY
2.2.1 Comment: A comment was made at the public hearing (IV-F-1B)
that the proposed emission limitations were so stringent that coating
suppliers would not have any latitude to vary formulations as required
to meet the wide range of equipment used and the environmental
conditions encountered in beverage can surface coating operations.
Response: The coating data presented in Table 2-5 indicate
that coating suppliers are providing coatings meeting the promulgated
emissions limitations for a wide range of equipment and environmental
conditions. Only two specific cases were identified, involving
two-piece can inside spray operations, in which waterborne coatings
could not be used. In these cases operational and environmental
requirements were being satisfied through the use of solvent-borne
coatings and incineration (see comment 2.1.2). Furthermore, the
monthly averaging provisions of the standards for each affected
facility would permit the use of some coatings not meeting the
standards, provided other coatings with lower VOC were used to bring
the monthly average to the promulgated emission limitations. As
indicated in Table 2-5, a range of waterborne coatings is available.
2.2.2 Comment: At the public hearing one participant (IV-F-1B)
stated that under NSPS, existing coating systems that have not yet
been able to meet RACT values must meet even more stringent emission
standards. Essentially only incineration, a counterproductive
energy-consuming system, can be used.
Response: Existing equipment is not required to meet the
promulgated standards unless the facility undergoes modification or
reconstruction as defined in 40 CFR 60. Under such circumstances, EPA
considers that there are sufficient coatings commercially available to
meet the standards. (See comment 2.1.2 above.) Incineration is
considered to be a reasonable and affordable option (Chapter 8,
proposal BIO as amended by docket item IV-B-12).
2.2.3 Comment: One participant at the public hearing (IV-F-1C) and
two commenters (IV-D-3, IV-D-5) expressed concern that if NSPS
materials for two-piece can inside spray are not available,
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afterburners will have to be used. This could very well call for an
overall control efficiency of 80 percent, requiring approximately
90 percent capture efficiency, which is not attainable.
Response: Coating data presented in Table 2-3 (comment 2.1.2)
indicate the availability of a variety of waterborne coatings for
inside spray. The VOC content of waterborne coatings reported as
being used by both merchant and captive canmakers ranges from 0.46 to
0.90 kg VOC/litre of solids compared with the promulgated emission
limitation of 0.89 kg VOC/ litre of solids. The promulgated
regulations permit monthly averaging, which should facilitate
satisfying the requirements. (See comment 2.2.1.)
During the collection of data, only two cases were identified in
which satisfactory waterborne coatings were not available. In these
cases, solvent-borne coatings and incineration provided the requisite
emission reduction.
A typical higher solids, solvent-borne inside spray coating in
general use contains 3.01 kg VOC/litre of coating solids (Table 4-2,
proposal BID). An overall control efficiency of 70 percent is
required to reduce the VOC emissions from the use of this typical
inside spray coating to the emission level prescribed in the
promulgated standards. A test at a two-piece can plant, using Method
25 procedures, showed a 78-percent capture efficiency of VOC emissions
from coater, flashoff area, and cure oven on an inside spray line.
This capture efficiency is thought to be conservative because the cure
oven quench exhaust was not quantified in the test.29 30 Combining
this capture efficiency with a nominal 90-percent incinerator
destruction efficiency results in an overall control system efficiency
of 70 percent. It is the Agency's engineering judgment that, in
instances in which the use of waterborne coatings may not be
applicable, the necessary capture and control (destruction or
recovery) are attainable at a reasonable and affordable cost
(Chapter 8, proposal BID and docket item IV-B-12).
2.2.4 Comment: Three participants at the public hearing (IV-F-1B,
IV-F-1C, IV-F-1D), two of which provided additional information in
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subsequent correspondence (IV-D-3, IV-D-4), stated that because of
(1) difficulties being experienced in implementing the RACT program,
(2) the limited capabilities of users to qualify new coatings, (3) the
problems involved in qualifying NSPS materials on existing lines prior
to the construction of new facilities, and (4) small incremental emis-
sion reduction from NSPS compared to that resulting from the trend
away from three-piece cans to two-piece cans, RACT values should form
the basis for NSPS.
Response: The problems of implementing RACT and the problem
generated by the limited capabilities of users to qualify new coatings
appear to be overstated in light of the data shown in Table 2-5.
Numerous coatings with VOC content equal to or less than RACT are
being used on existing two-piece can lines. In addition to meeting
RACT, many of these coatings also satisfy the NSPS requirements. (See
comment 2.1.2.)
The problems of qualifying NSPS materials on existing lines prior
to the construction of new facilities would not be resolved by using
RACT as the basis of the NSPS. One practice prevalent throughout the
industry is that coatings must be qualified on each line regardless of
the use in other plants operated by the same canmaker.
EPA agrees that there has been a significant reduction in VOC
emissions as a result of RACT and the trend away from three-piece cans
to two-piece cans. However, EPA is mandated under Section 111 of the
Clean Air Act to base NSPS on the BDT, which for this industry is the
use of coatings with lower organic solvent content than RACT coatings.
In view of this and in the light of data presented in Table 2-5
(comment 2.1.2), EPA has determined that the promulgated emission
limitations for two-piece cans represent BDT.
2.2.5 Comment: One participant at the public hearing (IV-F-1D)
commented that EPA, in proposing NSPS, has tried to design can lines
and specific materials.
Response: To perform the environmental and economic analyses
required in NSPS development, model plants were formulated. These are
not intended to represent what an actual plant should look like, but
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rather to present a range of capacities as the basis of subsequent
analyses. The model plants are based on coatings currently in use on
sufficient lines to warrant the determination of the availability of
NSPS-compliance coatings. EPA's specification of BDT is not in any
way a requirement that facilities use a specific technology.
2.2.6 Comment: One commenter (IV-D-4) challenged the implied
assumption in the BID that the industry is using coatings which are
RACT as defined in CTG-II. The projected emissions of VOC assume that
all the coatings being applied today in two-piece beverage cans are
RACT. This is not the case, as shown in Tables C-l, C-2, and C-3 on
pages C-4 to C-6 of Appendix C in the BIO. These tables list the VOC
content of coatings that are in general use today for two-piece
beverage cans and that are the proposed standards for the two-piece
can.
Response; The assumption that industry is currently using RACT
coatings was not made in the development of the NSPS. Rather, the
assumption was made that SIP emission limitations would be based on
RACT and that RACT should form the baseline case against which the
environmental and energy analyses could be made.
EPA recognizes that on some can lines, coatings with VOC content
lower than RACT are being used. These coatings serve as the bases for
the promulgated emission limitations. On other lines RACT coatings
are being used, and on the remaining lines coatings with VOC content
higher than RACT are in use. In the development of a baseline for use
in the environmental and energy analyses, EPA made the assumption that
in the absence of NSPS, the Industrywide average VOC content would be
equal to RACT.
2.2.7 Comment; One commenter (IV-D-5) requested that ink/lithography
emissions should be explicitly excluded in the preamble to avoid
future confusion, particularly at the State and local agency level.
Response; The promulgation preamble contains such a statement.
2.2,8 Comment; One commenter (IV-D-5) stated that the last line of
paragraph 6, page 3-4, draft EIS, should read ". . . two-piece can end
line."
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Response: Paragraph C, page 3-4, draft EIS should read as
shown in the comment.
2.2.9 Comment: One respondent (IV-D-5) stated that the seventh line
of paragraph 4, page 3-17, draft EIS should read "... when coll
stock is."
Response: Seventh line of paragraph 4, page 3-17, draft EIS
should read as shown in the comment.
2.2.10 Comment: One commenter (IV-D-5) stated that the distinction
should be made in the draft EIS (p. 3-10) between steel and aluminum
with regard to exterior base coat for two-piece cans.
Response: No distinction is made between steel and aluminum
two-piece cans in the development of model plants. While it is
recognized that different coatings thicknesses are required, the
additional effort is not justified by the marginal improvement in
accuracy that would result in estimating emissions and energy
requirements in the subsequent analyses.
2.2.11 Comment: One commenter (IV-D-5) stated that a BID reference
(4-57) covering the use of no-varnish inks was outdated.
Response: Reference 57, Chapter 4, draft EIS, was included to
indicate the trend away from no-varnish inks. The citation from this
reference must be taken in the context of the entire section in which
it appears, the last paragraph of which states, "During 1979 there was
a trend away from no-var inks. . ."
2.2.12 Comment; One commenter (IV-D-5) indicated that Reference 46,
Chapter 4, draft EIS, is superseded by Reference 65. There is no
indication that any new or modified facility would use solvent-borne
coatings with incineration, even if it were a feasible means of
achieving NSPS.
Response; Use of solvent-borne coatings and incineration must
be considered as a viable alternative to satisfying NSPS requirements.
One captive canmaker recently built a new plant using incineration and
is currently operating this facility using solvent-borne coatings.
2.2.13 Comment; Recommendation is made that the end-sealing
application should be deleted from Tables 4-1 and 4-2, draft EIS.
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Several years elapse between "qualification tests" and "general use."
Waterborne end-sealing compound 1s not a realistic option at this
time. (IV-D-5).
Response; Tables 4-1 and 4-2 of the draft EIS are Intended to
present state-of-the-art. The use of waterborne end-sealing materials
1s footnoted to Indicate that the material 1s undergoing qualification
tests. As such, Its Inclusion 1n Table 4-1 1s considered appropriate.
The same 1s true with the use of solvent-borne end-sealing materials
listed 1n Table 4-2. The preamble to the proposed regulation excludes
end-sealing compound emissions because the technology was not
considered as having been demonstrated.
2.2.14 Comment; Exception was taken (IV-D-7) to EPA's statement 1n 45
FR 78982 that "transfer efficiencies of 90 percent with Inside spray
operations are consistently achieved." Exactly what EPA's use of
10-percent VOC assessment 1n this Instance means was unclear. It was
requested that EPA consider allowing a facility that demonstrates a
consistent transfer efficiency (for Inside coating operations) of
greater than 90 percent to credit that percentage above 90 percent
against other coating operations that may exceed the compliance
limits.
Response; Because of the absence of standardized procedures
for determining transfer efficiencies, the complicated calculations
for estimating transfer efficiencies, and the high transfer
efficiencies consistently achieved for Inside spray operations (over
90 percent), EPA determined that Introducing a transfer efficiency
into the equations prescribed for determining compliance would
unnecessarily complicate the compliance procedures. Because of the
high transfer efficiencies (90 percent or higher) that are consis-
tently achieved, inclusion of such a term 1n the compliance equation
would be equivalent to introducing essentially the same term on both
sides of the equation. Consequently, the promulgated standards are
based on an assumed 100-percent transfer efficiency. It should be
noted that a 90-percent transfer efficiency was used in the
environmental and energy analyses for inside spray operations.
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2.2.15 Comment: One participant at the public hearing (IV-F-1D)
questioned the feasibility of specifying NSPS emission limitations for
steel and aluminum end sheet coating so close to the RACT
number—0.50 kg VOC/litre of solids versus 0.54 kg VOC/litre of
solids.
Response: The comment is no longer applicable. Coating of
aluminum and steel sheets for ends has been eliminated from the
promulgated standards. (See comment 2.1.1.)
2.2.16 Comment: One commenter (IV-D-2) questioned the use of an
assumed VOC density of 0.85 kg/litre of solids in converting RACT
numbers to kilograms of VOC per litre of solids. It is dangerous to
propose new standards on assumptions rather than hard data. For
example, an error of 5 percent in VOC density would result in a change
of 37 percent in the calculated kilograms of VOC per litre of solids.
Furthermore, no can manufacturer or coating supplier has been able to
duplicate the data in the BID. One commenter questioned using VOC
content based on other than Reference Method 24 data (IV-D-5).
Response: EPA recognizes that the conversion of VOC content from
RACT terms is sensitive to the density of the VOC solvent. The
selected density of 0.85 kg/litre is below that of the VOC normally
used in waterborne coatings. Use of this density results in a higher
VOC content per volume of solids than if actual VOC density of the
coating upon which the promulgated emission limitations are based were
used. Inasmuch as this favors the coater, EPA considers this approach
appropriate. The 37-percent error in calculated kilogram of VOC per
litre of solids from a 5-percent error in density appears to be
overstated. EPA calculations on the impact of a 5-percent error in
density indicate, as shown below, that even if the assumed density of
0.85 kg/litre were inaccurate by 5 percent, the resulting effect on
conversion from RACT to NSPS terms would not be significant.
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Calculated
VOC content Percent
Density (kg/litre solids) change
VOC content kg/litre of coating less water = 0.50.
0.85 x 0.95 1.313 8.2
0.85 1.214 0
0.85 x 1.05 1.137 6.3
VOC content kg/litre of coating less water = 0.15
0.85 x 0.95 0.184 1.1
0.85 0.182 0
0.85 x 1.05 0.180 1.1
The following equation was used in converting the RACT format to NSPS.
kilogram of VOC per litre of solids =
_ kilogram of VOC per litre of coating less water
1 (litre of coating) - "log"" of v°c Per ^trc i of coating less water
density OT vot
In using this equation to develop the basis for the promulgated
emission limitations, an organic solvent density of 0.85 kg/litre was
assumed. As mentioned above and in the response to Comment 2.1.6,
this is below the density of the VOC normally used in waterborne
coatings. Use of this density results in a higher VOC numerical
limitation than would have been determined if the actual VOC density
were used. This action favors the coater.
2.3 MODIFICATION AND RECONSTRUCTION
2.3.1 Comment: One commenter (IV-D-3) felt that the replacement of a
coater or oven should not be classified as reconstruction because it
is replacement in kind due to wear, not to increased material usage,
and that replacement should not be subject to NSPS.
Response: In promulgating 40 CFR 60.15, EPA intended to
subject to NSPS existing sources that have undergone such extensive
component replacement that they have become essentially new sources.
Application of BDT to facilities with largely new components furthers
the intent of Congress that emissions be minimized through application
2*19
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of BDT with the turnover in the nation's industrial component base.
This purpose is advanced through coverage of facilities that undergo
substantial component replacement, whether the replacement is due to
wear or increased material usage, and whether or not an emissions
increase results from the replacement.
Under Section 60.15, the replacement of a piece of equipment does
not in itself subject an existing facility to NSPS. However, once the
cost of components over time exceeds 50 percent of the cost of a
comparable new facility and it is technologically and economically
feasible for the facility comply, NSPS would apply. In making
decisions that involve the expenditure of funds that would trigger the
reconstruction provisions, industry also would consider the cost of
any control system that may be necessary to meet the NSPS
requirements.
2.4 ECONOMIC IMPACT
2.4.1 Comment: Two respondents (IV-D-6, IV-D-7) and one public
hearing participant (IV-F-10) questioned EPA's conclusion that the
proposed standards would have little economic impact on the beverage
can industry. Recommendations that the adoption of emission limits
lower than RACT would essentially shut off expansion in the beverage
can industry were ignored. EPA would be imposing VOC emission limits
below the (current) lowest achievable levels of several can coating
manufacturers. If those manufacturers could not achieve the new
levels, the November 26 proposals would be regulating them out of
business at the outset. This in turn would reduce or restrict
competition within the coating supply industry, which would cause
substantial economic hardship to can manufacturers. One public
hearing participant (IV-F-1A) stated that EPA ignored industry's
comments that adopting emission limitations lower than RACT would
essentially shut off expansion in the beverage can industry.
Response: Because EPA's analyses of industry projections
showed that no end or three-piece capacity would be subject to the
standards in 1985, only two-piece cans are covered by the promulgated
standards (comment 2.1.1). Therefore, response will be limited to
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two-piece beverage cans. The promulgated standards will not apply to
existing facilities except when they become subject to the
modification or reconstruction provisions of 40 CFR 60. Industry's
recommendations concerning the adoption of emission limits lower than
RACT were not ignored. For example, as a result of industry comments
at the NAPCTAC meeting, application of end-sealing compound was
excluded from the proposed standards. Industry's recommendations were
considered in the development of the promulgated standards, but in the
light of other economic and coating availability data, a determination
was made that the promulgation of NSPS for the beverage can surface
coating industry would not result in exorbitant or unreasonable
economic impacts. As a result of this and other comments, EPA
reviewed the economic analyses and the cost data upon which they were
based. It was found that the cost data used for the economic analyses
reported in Chapter 8, Volume I BID, included only the capital costs
involved in the construction of the coating portion of a two-piece can
line and did not include the cost of the front- and back-end
equipment. Costs were revised and the economic analysis redone.
Revised costs and analyses are included in Docket Item IV-B-12. The
revised economic analyses show significantly smaller economic impacts
than those reported in Volume I of the BID. Therefore EPA's
conclusions that no adverse economic impacts are expected to occur are
still valid. Coatings meeting the promulgated standards are available
and in use in a sufficient number of cases to warrant the
determination that the technology is available (see comment 2.1.2).
EPA projects a net savings to result from the use of waterborne
coatings. The use of solvent-borne coatings and incineration as an
alternative means of compliance is estimated to reduce the return on
investment by about 2 percent, depending on plant size. From 2 to
5 percent additional capital outlay would be required over that
required to achieve RACT. While these are negative economic impacts,
they are considered reasonable and affordable.
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2.5 ENERGY IMPACT
2.5.1 Comment: One comment was made that the energy requirements in
Tables 6-6, 7-18, and 7-22, draft EIS, do not t$ke into account that
ventilating air must be heated in winter (IV-D-5).
Response: Ventilating air must be heated in the winter whether
or not NSPS are promulgated. The energy analysis is based on the
incremental energy requirements between the base case and the emission
control option under consideration. In all cases except one, the
ventilating air requirements are significantly less than for the base
case. End forming, the exception, has been excluded from the
standards. Thus, any error introduced by not including the heating of
ventilating air results in a lower energy savings than would actually
be realized over the base case.
2.5.2 Comment: One commenter (IV-D-7) took exception to the
statement in the preamble that the proposed standards would result in
a net energy reduction because less coating per can would be used
(based upon higher solids contents of waterborne coatings).
Experience indicates that waterborne coatings require as much or more
energy expenditure as solvent-borne coatings. Further review or data
collection concerning this issue was recommended. The commenter
offered to submit data for both waterborne and solvent-based can
coatings, upon EPA's request.
Response: This comment was subsequently withdrawn (IV-D-19)
because appropriate inquiries by the commenter to other canmakers led
to the conclusion that the comment was not applicable to the industry
as a whole. However, because the issue was raised, EPA considers that
a general discussion of energy requirements is appropriate.
It is assumed that the comment applies only to two-piece cans
because the commenter1 s company makes only that type of can. Under
some conditions, cure oven energy requirements for waterborne-coated
two-piece cans may be higher than for solvent-borne coatings. As
discussed in Chapter 3 of the proposal BID, when waterborne coatings
are used, exhaust air flow through the cure oven is based on
considerations other than the lower explosive limit. Sufficient air
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must pass through the oven to clear the VOC and compounds that may be
formed during the curing process. In general, air flows are about the
same as when solvent-borne coatings are used.
In such a case, the"energy to heat and vaporize the water content
of the coating would be greater than that required for an equivalent
volume of VOC. However, energy required to heat and vaporize water or
VOC is less than 10 percent of the total energy requirements when pin
ovens are used. The greater portion of the energy requirements is for
heating the air, heating the cans, and heating the pins. Similar
consideration would apply to other than pin-type ovens.
In determining incremental energy impacts, both the base case and
regulatory alternative energy requirements were based on the use of
waterborne coatings. Because the energy impact is based on the
difference between the base case and the alternative under analyses
and for the reasons cited above, the energy analyses are considered to
be sufficiently accurate for standards development purposes.
2.6 ENVIRONMENTAL IMPACT
2.6.1 Comments: Two participants at the public hearing (IV-F-1C,
IV-F-1D) stated that emission reductions will occur naturally as a
result of conversion from three-piece to two-piece can production.
Coating material used for the manufacture of two-piece cans is
approximately 28 percent less than the coating material used for the
manufacture of three-piece cans, regardless of whether the material
used is conventional high solvent or RACT. Therefore, a net emission
reduction results with the shift from three-piece cans to two-piece
cans. This reduction far outweighs any reduction that will occur as a
result of implementation of NSPS. These comments were subsequently
submitted in writing (IV-D-3, IV-D-6).
Response: EPA agrees that there has been a significant
reduction in VOC emissions as a result of the trend away from
three-piece cans to two-piece cans. Emission data to date
substantiate this. It is also true that reduction attainable through
the promulgation of the beverage can surface coating NSPS will be much
less than that achievable upon complete implementation of the RACT
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program. However, EPA is required under Section 111 of the Clean Air
Act to promulgate NSPS for industries within source categories on the
Priority List where, as in the case of this industry, application of
control technology will achieve significant reduction beyond that
achieved without NSPS. Application of BDT, which for this industry is
the use of coatings with lower organic solvent content than RACT
coatings, would achieve such a reduction. As a result, Section 111
requires EPA to promulgate standards reflecting such application.
2.7 LEGAL CONSIDERATIONS
2.7.1 Comment: Three canmakers (IV-F-1B, IV-F-1D, IV-D-2) were
concerned that moving an existing plant to another site would subject
the plant to NSPS or State new source emission limitations. One
canmaker (IV-D-15) subsequently submitted hypothetical situations to
support his contention that problems would be encountered by State
interpretation, which would consider the facility as a new source even
if NSPS did not apply.
Response: Movement of an affected facility to another site, in
itself, is exempted from NSPS under §60.14(e)(6). This exemption
applies to 40 CFR 60 only. State or local regulations and other
Federal regulations covering prevention of significant deterioration
or new source review could apply to the move.
2.7.2 Comment: One respondent (IV-D-2) stated that the Agency's
definition of an affected facility as each coating operation, as
opposed to an entire line or an entire manufacturing plant, may not
provide the same degree of latitude as the existing "bubble concept"
and may limit methods of compliance. One commenter (IV-D-3)
recommended that an alternate compliance plan be incorporated in the
NSPS. If the total facility emissions are equivalent to NSPS
limitations using an alternate compliance plan, there is no detriment
to the environment; therefore, an alternate compliance plan should be
*
permissible. Particularly in a facility that would have a combination
of NSPS and RACT limitations, an alternate compliance plan should be
allowed. This would permit the facility to use the same materials for
all lines, NSPS and RACT in combination. This plan would improve
implementation of an air pollution control program.
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Response: The "bubble concept" refers to application of a
standard to an entire plant rather than to individual emission points,
although emission ceilings may concurrently be assigned to individual
emission points. The term "affected facility" refers to the
particular portion of a plant to which a standard applies. In this
case the affected facility has been defined as a surface coating
operation, which consists of a coating application station(s),
flashoff area(s), and cure oven. The choice of the affected facility
for any standard is based on the Agency's interpretation of the Clean
Air Act, as amended, and judicial construction of its meaning. Under
Section 111, the NSPS must apply to "new sources"; a "source" is
defined as "any building, structure, facility, or installation which
emits or may emit any air pollutant" [Section 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 uses the term "affected facility" to designate the
equipment, within a particular kind of plant, that is chosen as the
"source" covered by a given standard.
In choosing the affected facility, EPA must decide which pieces
or groups of equipment are the appropriate units for separate emission
standards in the particular industrial context involved. The Agency
does this by examining the situation in light of the terms and purpose
of Section 111. One major consideration in this examination is that
the use of a narrower definition results in bringing replacement
equipment under the NSPS sooner; if, for example, an entire plant were
designated the affected facility, no part of the plant would be
covered by the standard unless the plant as a whole were "modified."
If, on the other hand, each piece of equipment were designated the
affected facility, as each piece were replaced, the replacement piece
would be a new source subject to the standard. Because the purpose of
Section 111 is to minimize emissions by application of the best
demonstrated control technology (considering cost, other health and
environmental effects, and energy requirements) at all new and
modified sources, the presumption is that a narrower designation of
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the affected facility is proper. This designation insures that new
emission sources within plants will be brought under coverage of the
standards as they are installed. This presumption can be overcome
where the impacts attributable to the narrower designation are
unreasonable in the light of emissions reduction resulting from the
selection of that definition.
The Agency has determined that the selection of each coating
operation as the affected facility would not result in unreasonable
impacts. It is technologically and economically feasible to control
each surface coating operation. Choosing a combination of surface
coating operations or the whole plant as the affected facility would
be inconsistent with the language and intent underlying Section 111
because this broader definition would delay NSPS coverage of new
facilities within the plant. Bubbling emissions at NSPS-regulated
facilities with emissions at RACT facilities could permit all
NSPS-regulated facilities in a plant to achieve less than BDT-level
control. This would be inconsistent with Section Ill's requirement
that emissions at NSPS-regulated facilities be controlled to the level
reflecting application of BDT. Therefore, the Agency has selected
each surface coating operation as the affected facility for these
standards.
2.7.3 Comment: One commenter (IV-D-3) stated that EPA's banking
policy provides a built-in incentive for industry to develop materials
superior to RACT. Resulting reduction in emissions from existing
plants will far outweigh any benefits that might result from the
implementation of NSPS.
Response: The NSPS program does not prevent existing plants
from banking emissions. NSPS are emission limits for new, modified,
and reconstructed affected facilities based on BDT. In accordance
with Section 111, these standards insure at least a specified minimum
level of control at new, modified, and reconstructed facilities,
wherever located--including those for which banking and other economic
incentives may not be sufficient to induce good control of VOC
emissions in the absence of NSPS.
-------
2.7.4 Comment: One commenter (IV-D-3) was concerned that the
promulgation of NSPS would jeopardize the ongoing RACT program if a
new line were added to an existing plant, which is very common in the
can business. The new line would be governed by NSPS limitations.
Different coatings would be required for use on the new line than on
the old line. Maintaining inventory and regulating the use of the two
different sets of coatings for the production of the same can would be
unmanageable. If the plant used alternate compliance, a complicated
calculation scheme would be needed to demonstrate compliance with both
NSPS and RACT. The dual system of RACT and NSPS in a plant will not
work and will lead to demise of one or another in terms of
practicality. Either the entire facility will be switched to NSPS, or
RACT materials will be incinerated on NSPS lines. This concept is
contrary to the recent U.S. EPA policy of discouraging the use of
afterburners.
Response: The situation that would result from the addition of
a new line subject to NSPS to an existing plant appears to be no
different from the situation in existing plants that make more than
one type of beverage can, each of which may require different types of
coating. The same procedures used to maintain inventories and
regulate the use of different coatings in the latter plant are
considered to be applicable to the situation described in the comment.
The procedures outlined for determining compliance for plants
using RACT coatings31 and in the draft regulation for plants using
NSPS coatings are not incompatible and permit the use of RACT coatings
on one line and NSPS coatings on another. Furthermore, in enacting
Section 111, Congress recognized that to enhance air quality over the
long run it is important that new sources within a plant achieve
limits based on the best demonstrated technology, irrespective of the
level of control at existing sources within the plant.
Compliance of the NSPS affected facilities in a can plant would
be determined using volume of coatings, VOC content thereof, and
diluent solvent used in the affected facility by the procedures
presented in the proposed regulations. Compliance of that portion of
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the plant subject to RACT would be in accord with provisions of the
applicable State and local regulations. The data required for these
calculations are considered to be those that any prudent manufacturer
would maintain even if the NSPS were not promulgated.
2.7.5 Comment: One commenter (IV-D-2) felt that the information
needed by EPA to determine compliance and to calculate emission
inventories could be done with annual reports as opposed to monthly
compliance determinations. These reports would only need to list each
coating used by the plant along with kilograms of VOC per litre of
solids and actual usage amounts. Those plants required to run control
equipment would also have to report the average percentage of VOC
reduction by the equipment and the number of production hours that the
control equipment was not running, which could be backed up by a
simple chart record.
Response: Annual reports are not considered an acceptable
basis for determining compliance. Such an approach would permit a
wide fluctuation in the mass of VOC emitted to the atmosphere at any
one time. All of the canmakers contacted during the development of
the standards reported maintaining coating-usage data on at least a
monthly basis. As stated in paragraph 2.9.1, EPA has investigated
alternatives for reducing recordkeeping and reporting burdens and has
changed the requirement for immediate reporting of noncompliance to
semiannual reporting.
The promulgated regulations do not require reporting the average
percentage of VOC reduction if an incinerator was used, or the number
of hours the control system was not operating. Where compliance is
achieved through the use of incineration, the owner or operator is
required to identify and report, semiannually, all 3-hour periods
during which the operating temperature, when cans are being processed,
was more than 28° C below the average temperatures of the device
during the most recent performance test. The destruction efficiency
of the control device determined during the most recent performance
test is used in determining compliance during any calendar month.
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2.8 TEST METHODS AND METHODOLOGY
2.8.1 Comment: Two commenters (IV-D-2, IV-D-6) questioned the
relationship of the proposed standards and the use of Reference
Method 24 for determining compliance. Recommendations were made that
the proposed standards should include a "cushion" that would allow for
differences in test findings resulting from variation of the three
experimentally determined physical constants used to calculate VOC
content of coatings. Upward readjustment of the proposed standards to
at least RACT level is required to avoid capricious erroneous
noncompliance findings.
Response: EPA recognizes the potential variability in the
results when Method 24 is used to analyze water-based coatings. EPA
intends for enforcement agencies to consider this variability when
using Method 24 results to determine compliance with the standard.
The promulgated regulation requires that when Method 24 data are used
to determine VOC content of waterborne coatings for compliance
determinations, they be adjusted as described in Section 4.4 of
Method 24.
If the VOC level of a waterborne coating, based on formulation,
is at or below the standard, there is less than one chance in 10,000
that the Method 24 adjusted results would show the VOC level to be
above the standard. The Agency considers this risk insignificant
compared to the usefulness of Method 24 in determining compliance.
2.9 REPORTING AND RECORDKEEPING
2.9.1 Comment: One commenter (IV-D-2) stated that the recordkeeping
requirements are unnecessarily tedious and time consuming, ask for
much nonessential information, and necessitate intimidating and
complex calculations. Production people would be required to do
day-to-day and even hour-to-hour monitoring. The recordkeeping
requirements penalize manufacturers that must meet the standards using
control equipment instead of compliance coatings. The Agency's
estimate that the proposed requirements would cost the industry
12 person-years over the first 5 years of the standards is
unrealistically low. The commenter added that his company has less
2-29
-------
than 10 percent of the nation's two-piece can business, and
conservatively estimates a cost of 2.3 person-years over the first
5 years of the standards. Even if the Agency's estimate is correct,
the requirements are unnecessarily involved and are another example of
an inflationary, nonproductive expense imposed upon industry by a
governmental agency.
Response: The reporting and recordkeeping requirements were
selected as being the minimum required to insure continuous compliance
with the standards. EPA disagrees that day-to-day or hour-to-hour
monitoring will be required. Compliance is determined on a monthly
basis and requires data that any prudent manufacturer would normally
maintain. For facilities using waterborne coatings, required data
consist of the volume and VOC content of each coating and the volume
and density of each diluent VOC solvent used during each calendar
month. When an emission control system is used, the most recently
determined overall reduction efficiency of the system also is
required.
EPA has been investigating alternative ways of reducing
monitoring, recordkeeping and reporting burdens on owners and
operators. The goal is to reduce all recordkeeping and reporting that
is not essential to insuring proper operation and maintenance. After
reviewing the requirements in the proposal, EPA determined that
monitoring and compiling data are essential for both the owner or
operator and EPA to insure proper operation and maintenance. A
responsible owner or operator would need monitoring information
compiled in a usable form to determine when adjustments in the control
system are needed to insure that it is performing at its intended
effectiveness level. It was judged, however, that immediate reporting
of noncompliance with the standards is not essential to EPA.
Semiannual reporting is considered sufficient to enable EPA to
efficiently discharge its enforcement responsibility. Therefore,
after initial performance testing, the requirement to immediately
report all instances of noncompliance, as required in the proposal
package, has been changed to require only semiannual reports. Reports
2-30
-------
required under the general provisions of 40 CFR 60 remain unchanged.
States delegated the authority to enforce these standards remain free
to impose their own reporting requirements in conjunction with this
regulation.
Recordkeeping provisions of the proposed standards require
maintaining records of all data and calculation for at least 2 years.
In addition, records of incinerator operating temperatures are
required if incineration is used, as are data on daily solvent
recovery if a sol vent-recovery system is used. Incinerator
temperatures and daily sol vent-recovery data are considered essential
to the operation of these devices and would be generated, maintained,
and examined whether or not required by the standards.
Details of the estimate that 12 person-years would be required by
industry during the first 5 years of the standard are contained in the
Reports Impact Analysis (Docket Item II-1-53). The estimates of
industry requirements during the first 5 years have been revised
downward to 11 person years as a result of the change between proposal
and promulgation (Docket Item IV-J-2). In a subsequent discussion the
commenter stated that the 2.3 person-years was a worst case estimate
based on all existing facilities being modified or reconstructed
during 1980-1985.5
Annual recordkeeping and reporting requirements for each affected
facility used in the Reports Impact Analysis are as follows:
Estimated
Report person-hours
One-time reports required by the General
Provision of 40 CFR 60 98
Recurring reports
Monthly compliance determination 24
Report noncompliance 1
Report quarterly incineration operating parameter 8
Maintain daily record of solvent recovery 60
It is EPA's judgment that the estimates are based on best
available data, that the estimates are realistic, and that the
requirements are not inflationary.
2-31
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TABLE 2-1. LIST OF COMMENTERS ON THE PROPOSED STANDARDS OF
PERFORMANCE FOR THE BEVERAGE CAN SURFACE COATING INDUSTRY
Dockent number
Commenter and affiliation
IV-D-1
IV-D-2
IV-D-3
IV-F-1C'
IV-D-4
IV-D-5
IV-D-6
IV-F-1D'
IV-D-7
IV-D-19
IV-D-8
IV-D-9
IV-D-14
IV-D-10fc
Jack M. Heinemann
Advisor on Environmental Quality
Federal Energy Regulatory Commission
Washington, D.C. 20426
Kelly Murphy, P.E.
Environmental Engineer
Ball Metal Container Group
Westminister, Colorado 80020
R. M. Rivetna
Manager, Environmental Engineering
National Can Corporation
Chicago, Illinois 60631
Richard D. McKirahan
American Can Company
Greenwich, Connecticut 06830
R. H. Donaldson, P.E.
Manager, Environmental & Energy
Compliance
Reynolds Aluminum
Can Division Headquarters
Richmond, Virginia 23234
George 0. Payne, Jr.
Chairman, Hydrocarbons Task Force
Can Manufacturers Institute
Washington, D.C. 20036
Cecelia J. Pollara
Regulatory Affairs Analyst
Adolph Coors Company
Golden, Colorado 80410
Harry H. Hovey, Jr., P.E.
Director, Division of Air
New York State Department of Environ-
mental Conservation
Albany, New York 12233
George 0. Payne
Continental Can Company
Chicago, Illinois
Harvey M. Sheldon
Nisen, Elliott & Meier
Chicago, Illinois 60602
See footnote at end of table.
(continued)
2-32
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TABLE 2-1. (continued)
Docket number
Commenter and affiliation
IV-D-11
IV-D-12
IV-D-13
IV-D-15
IV-F-1B'
IV-D-16
IV-D-171
IV-H-1
IV-F-1A*
Harvey M. Sheldon
Nisen, Elliott & Meier
Chicago, Illinois 60602
R. Turner
Manager, Environmental and Energy
Miller Brewing Company
Milwaukee, Wisconsin 53201
R. H. Shinn
Director of Research
Crown Cork and Seal Company, Inc.
Philadelphia, Pennsylvania 19138
Robert A. Gere
Manager, Air Compliance
Corporate Public Affairs
American Can Company
Greenwich, Connecticut 06830
Paul W. Mailman
General Counsel
Can Manufacturers Institute
Washington, D.C. 20036
R. M. Rivetna
Manager, Environmental Engineering
National Can Corporation
Chicago, Illinois 60631
Robert T. Miki
Deputy Assistant Secretary for
Regulatory Policy (Acting)
U.S. Department of Commerce
Washington, D.C. 20230
George Gerhardt
Mobil Chemical Company
Public hearing comment.
Identical to IV-D-6, submitted by a law firm representing the Can
Manufacturers Institute.
°Provided additional data in support of IV-D-3.
2-33
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TABLE 2-2. COMPARISON OF BID ENVIRONMENTAL AND ENERGY ANALYSES WITH ANALYSES BASED ON
CMI/AMERICAN CAN PROJECTIONS OF BEVERAGE CAN SURFACE COATING ACTIVITIES
Shipments
(109 units)
1980
ro
i
CO
-p.
Two-piece steel and
aluminum cans
Three-piece sheet coating
Three-piece can forming
Steel and aluminum end
coati ng
Total
BID
46.0
14.5
14.5
75.0
CMI
49.6
5.6
5.6
60.8
1985
BID
65.9
14.5
14.5
94.9
CMI
61.9
1.5
1.5
63.4
Capacity
subject
to NSPS
(109 units)
BID
31.4
3.5
3.5
20.9
CMI
22.3
0
0
0
Emissions
reduced
by NSPS
(Mg)
BID
4,113
54
311
333
4,811
CMI
2,924
0
0
0
2,924
Energy
reduction
(GJ)
BID
26,847
4,499
39
4,243
35,658
CMI
19,066
0
0
0
19,066
-------
N>
Ui
TABLE 2-3. EMISSION REDUCTIONS FROM EMISSION CONTROL OPTIONS, TWO-PIECE STEEL
OR ALUMINUM INTEGRATED FACILITY, 1985a
Coating operation
Exterior base-coat
operation
Li thography/overvarn i sh
Inside spray
Total
Reduction from NSPS
Base
kg/103
units
0.137
0.054
0.223
0.414
case
Mg
3,055
1,204
4,973
9,232
~
Option
kg/103
units
0.076
0.073
0.097
0.246
IA
Mg
1,695
1,628
2,163
5,486
3,746
Option
kg/103
units
0.076
0.005
0.097
0.178
IB
Mg
1,695
112
2,163
3,970
5,262
Option
kg/103
units
0.073
0.046
0.164
0.283
1C
Mg
1,628
1,023
3,657
6,308
2,924
Option
kg/103
units
0.073
0.005
0.164
0.242
ID
Mg
1,628
112
3,657
5,397
3,835
a
NOTE: Revised; originally Table 7-12, proposal BID.
'Affected capacity is based on 22.3 billion can equivalents subject to NSPS in 1985.
'Based on a 90-percent transfer efficiency.
-------
ro
OJ
TABLE 2-4. ENERGY REQUIREMENTS FOR EMISSION CONTROL OPTIONS,
TWO-PIECE CANS SUBJECT TO NSPS IN 1985a'b)C
(gigajoules)
Base
case
Electricity 52,048
Natural gas 1,894,563
Total 1,946,611
Reduction
due to NSPS
Small scale
Large scale
Emission control option
IA
54,412
5,041,428
5,095,840
(3,149,229)
IB
37,821
3,415,334
3,453,155
(1.506,544)
1C
48,012
1,879,043
1,927,055
19,556
ID
31,153
1,232,320
1,263,473
683,138
case IA
47,142 49,505
1,735,408 4,632,379
1,782,550 4,681,884
(2,899,334)
Emission control option
IB
34,587
3,058,936
3,093,523
(1,310,973)
1C
43,128
1,720,356
1,763,484
19,066
10
27,897
1,126,529
1,154,426
628,124
NOTE: Revised, originally Table 7-22, proposal BID.
aVOC concentration in ventilating air is ppmV 100 as xylene. Affected capacity is based on 22.3 billion cans subject to NSPS in 1985.
Figures in parentheses indicate an increase in energy requirements over the base case.
cAssumes 25 percent of two-piece cans are steel, the same ratio as in 1978.
-------
TABLE 2-5. DATA BASE, BEVERAGE CAN SURFACE COATING
Coating
VOC
Status
Two-piece can exterior base coat
Standard: 0.29 kg/litre of solids
Inmont S21-143XL 0.267
Inmont S21-121A 0.29
0.2510
Inmont S21-53B (S21-140) 0.2811
Inmont S-21-54 0.29
Midland Dexter 1401W111 0.23
Not specified 0.24
Claimed confidential 0.24
Used on four lines, Metal Container
Corporation, Jacksonville, FL8
Available commercially from Inmont;9
in use by Crown Cork10
In use by Reynolds12
In use by Crown Cork10
Qualified for use on Reynolds new
and existing lines12
In use by American Can for beer and
soft drink cans13
In use by Continental Can Company,
U.S.A.32
Overvarnish and clear base coat two-piece
cans and three-piece sheets
Standard: 0.46 kg VOC/litre of solids
Inmont S12-121
PPG-CE 3180D
0.4614
0.3616
Inmont S-145-124
Not specified
Whittaker 62C10A
Whittaker 62C10-3
Inmont 145-144
0.37
0.34
0.38
0.26
0.3811
Commercially available from Inmont14;
qualified alternative for Miller's
Fulton plant; in use at Miller's
Fort Worth plant15
In use by Reynolds at multiple lines
and locations12
In use at Miller's Fulton and Reids-
vine plants; proposed but not yet
tested for the Milwaukee plant15
Planned for new lines by Reynolds17
Typical of coatings used by Reynolds
in new and existing plants18
Commercially available from Whittaker
for two-piece steel and aluminum
cans
19
Commercially available from Whittaker
for two-piece aluminum cans19
In use by Reynolds at multiple lines
and locations12
(continued)
2-37
-------
TABLE 2-5. (continued)
Coating
VOC
Status
Inmont 145-144A
Not specified
Inmont 145-145
Claimed confidential
Claimed confidential
Claimed confidential
Claimed confidential
Claimed confidential
0.2811 In use by Reynolds at multiple lines
and locations12
0.43 In use by American Can13
0.4511 Proposed for startup of Miller's
Moultrie plant15
0.41 In use by Continental Can Company,
U.S.A.32
0.35 Not specified32
0.34 In use by Continental Can Company,
U.S.A.32
0.35 In use by Continental Can Company,
U.S.A.32
0.33 In use by Continental Can Company,
U.S.A.32
Two-piece can inside spray
Standard: 0.89 kg VOC/litre of solids
Du Pont RK-Y-6077
Glidden 62-640C-549A
Glidden 640C-560A
0.89 Commercially available from Du Pont20
In use by Reynolds at multiple
lines and locations12
In use at Miller's Reidsville plant15
0.89 Commercially available from Glidden
for 75 percent of waterborne
users21
In use by Reynolds at multiple lines
and locations12
In use by Crown Cork and Seal10
Qualified alternative for Miller's
Reidsville plant15
0.46 In use on four lines, Metal Con-
tainer Columbus plant. Intended
as replacement for 62-640C-549A;
has been qualified for some soft
drinks; one soft drink bottler
plans commercialization22
Being considered by Reynolds for
qualification12
In use on all one lines at Metal
Container Jacksonville plant8
(continued)
2-38
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TABLE 2-5. (continued)
Coating
VOC
Status
Dexter-Midland 4000W13M
Not specified
Not specified
Not specified
Claimed confidential
0.85 Commercially available from Dexter-
Midland23
In use at one National Can plant for
soft drink cans24
Qualified for use by National Can
for all beer customers except
Olympia and for full range of soft
drink uses24
0.89 Typical of coatings used by Reynolds
on new and existing lines18
0.61 In use at one plant by American Can13
0.84-0.89 In use by Crown Cork25
0.86 In use by Continental Can Company,
U.S.A.32
Three-piece can inside spray
Proposed standard: 0.64 kg VOC/litre of solids
PPG CS625-1
PPG CS625-2
PPG 3020
Mobil 78W263
Not specified
0.69
0.6926
0.66
0.61
0.58
Available from PPG26
In fourth month of qualification
testing at National Can; results
are promising;24 this is a higher
viscosity version of PPG CS625-1
In use by Crown Cork and Seal10
In fourth month of qualification
testing at National Can; results
are promising24
In use by American Can for soft
drinks. American Can currently is
not making three-piece beer cans13
Three-piece sheet interior base coata
Proposed standard: 0.50 kg VOC/litre of solids
Mobil S-9536-004
Mobil 79W195A
0.50 In fourth month of qualification test
at National Can; results are
promising27
0.53 In fourth month of qualification test
at National Can; results are
promising
24
See footnotes at end of table.
2-39
(continued)
-------
TABLE 2-5. (continued)
Coating VOC Status
PPG CS3038-1 0<.5726 Currently in use at National Can24
Three-piece sheet exterior base coat
Proposed standard: 0.50 kg/litre solids
Mobil S-9536-004 0.50 Commercially available from Mobil28
Mobil S-9536-006 0.50 Commercially available from Mobil28
American Can - Currently has no commonly used water-
borne coatings for three-piece base
coats13
End stock exterior coat
Proposed standard: 0.50 kg VOC/litre of solids
Mobil S-9536-005 0.50 Commercially available from Mobil;28
in use at National Can27
Celanese X1755 0.49 Under qualification at National Can24
Inmont Y112-11 0.43 Under qualification at National Can24
Inmont W131-13 0.48 Under qualification at National Can27
PPG CC3409 0.52 Under qualification at National Can24
O'Brien 854-C-1009 0.50 Under qualification at National Can24
Midland VW1501F 0.42 Under qualification at National Can24
End stock interior coatc
Proposed standard: 0.50 kg VOC/litre of solids
Celanese X1751 0.52 Under qualification at National Can27
Inmont W131-13 0.46 Under qualification at National Can27
aAmerican Can currently has no commonly used waterborne coatings for
three-piece can base coats.13
bAmerican Can has tested an end coating material with 2.37 Ib VOC/gal
of solids (0.28 kg/litre) and found it unsatisfactory.13
GNational Can feels that exterior end stock coats can be used for interior
coat with only minor reformulation that does not affect coating charac-
teristics or VOC content.24
2-40
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2.10 MISCELLANEOUS
2.10.1 Comment: One commenter (IV-D-5) felt that the draft EIS and
the proposed preamble and regulation are much more complex and lengthy
than necessary. Discussion of incineration and the three-piece can
should be eliminated.
Response: The material in the draft EIS and in the proposal
preamble and regulation was considered necessary to present the
technical basis and the rationale for the development of the proposed
standards. The beverage can surface coating industry is complex,
involving as many as eleven coating operations on five separate items.
Discussion of each of these was considered necessary to determine the
scope and level of the proposed standards. A discussion of
incineration was considered essential because one canmaker had
recently constructed two plants using solvent-borne coatings. Also
incineration is considered to be an affordable alternative to the use
of waterborne coatings. Other than the rationale for excluding
three-piece cans from the standards, no mention is made of this item
in the promulgation preamble and regulation.
2.11 REFERENCES
1. Business Climate Outlook 1981-85: A 5-Year Perspective on the
Economy, Energy, Selected Industries and Materials. Business
Research Operation Control, American Can Company. April 1980.
pp. 37-40.
2. Letter from Payne, G., Can Manufacturers Institute, to Docket
No. A-80-4, EPA, February 4, 1981. Formal Comment on Proposed
Standards of Performance for New Stationary Sources: Beverage
Can Surface Coating Industry, 45 FR 78980, Docket A-80-4.
3. Letter from Mailman, P., Can Manufacturers Institute, to Docket
No. A-80-4. March 30, 1981.
4. Telecon. Massoglia, M. F., Research Triangle Institute, with
Payne, G., Continental Can Company, Inc. April 13, 1981.
Beverage Can Surface Coating.
5. Letter from Murphy, K., Ball Metal Container Group, to
Massoglia, M. F., Research Triangle Institute. March 19, 1981.
6. Can Manufacturers Institute, Metal Can Shipments Report, 1979.
2-41
-------
7. Telecon. Massoglia, M. F., Research Triangle Institute, with
Feyler, W., Inmont Corporation. January 9, 1981. Beverage Can
Surface Coating.
8. Telecon. Massoglia, M. F., Research Triangle Institute, with
Fitzgerald, N., Metal Container Corporation. January 8, 1981.
Beverage Can Surface Coating.
9. Purair Material Safety Data Sheet. S121-1214. Modified Acrylic
Aqueous Exterior White Base Coating. Inmont Corporation.
Cincinnati, Ohio.
10. Letter from Shinn, R. H., Crown Cork and Seal Company, Inc., to
Goodwin, D. R., U.S. Environmental Protection Agency.
February 25, 1981.
11. Telecon. Massoglia, M. F., Research Triangle Institute, with
Feyler, W., Inmont Corporation. January 13, 1981. Beverage Can
Surface Coating.
12. Telecon. Massoglia, M. F., Research Triangle Institute, with
Donaldson, R., Reynolds Aluminum. January 12, 1981. Beverage
Can Surface Coating.
13. Telecon. Massoglia, M. F., Research Triangle Institute, with
Gere, R., American Can Company. January 16, 1981. Beverage Can
Surface Coating.
14. Purair Material Safety Data Sheet. S145-121. Modified Acrylic
Aqueous Finishing Overvarnish. Inmont Corporation. Cincinnati,
Ohio.
15. Letter from Turner, R., Miller Brewing Company, to Goodwin,
D. R., U.S. Environmental Protection Agency. February 10, 1981.
16. Telecon. Massoglia, M. F., Research Triangle Institute, with
Taylor, R., PPG Industries. January 12, 1981. Beverage Can
Surface Coating.
17. Telecon. Massoglia, M. F., Research Triangle Institute, with
Donaldson, R., Reynolds Metal Company. October 31, 1979.
Beverage Can Surface Coating.
18. Letter from Donaldson, R., Reynolds Metal Company, to Drake, W.,
Research Triangle Institute. January 31, 1980.
19. Letter from Swanson, J., Whittaker Coatings & Chemicals Group, to
Massoglia, M. F., Research Triangle Institute. June 30, 1980.
20. Telecon. Massoglia, M. F., Research Triangle Institute, with
LeBarre, G., Du Pont. June 20, 1980. Beverage Can Surface
Coating.
2-42
-------
21. Letter from Nimon, L., Glidden Coatings and Resins, to
Massoglia, M. F., Research Triangle Institute. June 11, 1980.
NSPS—Beverage Can.
22. Telecon. Massoglia, M. F., Research Triangle Institute, with
Nimon, L., Glidden Coatings and Resins. January 9, 1981.
Beverage Can Surface Coating.
23. Telecon. Massoglia, M. F., Research Triangle Institute, with
Scalzo, J., Dexter-Midland. June 25, 1980. Beverage Can Surface
Coating.
24. Telecon. Massoglia, M. F., Research Triangle Institute, with
Kosiba, R., National Can Company. January 8, 1981. Beverage Can
Surface Coating.
25. Telecon. Massoglia, M. F., Research Triangle Institute, with
Shin, R., Crown Cork and Seal Company, Inc. January 7, 1983.
Beverage Can Surface Coating.
26. Telecon. Massoglia, M. F., Research Triangle Institute, with
Warnick, W., PPG Industries. January 9, 1981. Beverage Can
Surface Coating.
27. Telecon. Massoglia, M. F., Research Triangle Institute, with
Kosiba, R., National Can Company. June 24, 1980. Beverage Can
Surface Coating.
28. Telecon. Massoglia, M. F., Research Triangle Institute, with
Gerhardt, G., Mobil Chemical Company. June 26, 1980. Beverage
Can Surface Coating.
29. Cha, S., Emission Test Report, Metal Container Corporation,
Jacksonville, Florida. EMB Report 79-15C-8. Wethersfield,
Connecticut: TRC Environmental Consultants, Inc. December 1979.
30. Memorandum from Massoglia, M. F., Research Triangle Institute, to
Docket A-80-4. September 22, 1981. Emission Test Report, Metal
Container Corporation, Jacksonville.
31. U.S. Environmental Protection Agency. Compliance with VOC
Emission Limitations for Can Coating Operations. 40 CFR Part 51
[AD-FRL-1694.3, Docket A-80-55]. Federal Register 45
(237):80824. December 8, 1980. ~
32. Memorandum from Massoglia, M. F., Research Triangle Institute, to
Docket A-80-4. October 30, 1981. Beverage Can Surface Coating
Information from Continental Can Company.
2-43
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-80-036b
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Beverage Can Surface Coating Industry—Background
Information for Promulgated Standards of Performance
5. REPORT DATE
August 1983
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. 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
Office of 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 emissions from the beverage can
surface coating industry are being promulgated 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 a summary of public
comments and responses that serves as the basis for the revisions made to the
standards between proposal and promulgation.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/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
8. DISTRIBUTION STATEMENT
Unlimited
INSECURITY CLASS (ThisReport!
Unclassified
21. NO. OF PAGES
53
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (R«v. 4-77) PREVIOUS EDITION is OBSOLETE
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