National Emission Standards for Hazardous Air
Pollutants (NESHAP) for Source Category:
Surface Coating of Metal Cans
Background Information for Proposed Standards
-------
EPA-453/R-02-008
November 2002
National Emission Standards for
Hazardous Air Pollutants (NESHAP)
for Source Category:
Surface Coating of Metal Cans
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Emission Standards Division
Research Triangle Park, North Carolina
-------
Disclaimer
This report has been reviewed by the Emission Standards 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.
11
-------
Table of Contents
Page
Chapter 1. Introduction 1-1
1.0 Overview 1-1
1.1 Background 1-2
1.2 Summary of Existing Federal/State/Local Regulations 1-3
1.3 Project Hi story 1-5
1.3.1 Data Gathering 1-5
1.3.2 Emissions and Control Data 1-6
1.4 References 1-6
Chapter 2. Metal Can Manufacturing—Surface Coating Source Category 2-1
2.0 Industry Profile 2-1
2.1 Metal Can Manufacturing and Coating Processes 2-6
2.1.1 Three-Piece Can Bodies 2-6
2.1.2 Two-Piece Can Bodies 2-12
2.1.2.1 Draw-and-Iron Process 2-12
2.1.2.2 Draw-Redraw Process 2-15
2.1.3 Can Ends 2-15
2.1.3.1 Aluminum Beverage Can Ends 2-15
2.1.3.2 Food Can and Other Sheet-Coated Ends 2-16
2.2 Coatings 2-17
2.2.1 Coating Technologies 2-17
2.2.2 Characteristics of Interior and Exterior Coatings 2-24
2.2.2.1 Interior Coatings 2-24
2.2.2.2 Exterior Coatings 2-26
2.3 Characterization of HAP Emissions from Metal Can Surface Coating Facilities . . . 2-28
2.3.1 HAP Emissions 2-28
2.3.1.1 1995 Toxic Release Inventory Data 2-28
2.3.1.2 ICRData 2-29
2.3.2 HAP Emission Sources and Emission Reduction Techniques 2-30
2.3.2.1 Coating Operations 2-31
2.3.2.2 Cleaning Operations 2-31
2.3.2.3 Can Washing Operations 2-32
2.3.2.4 Mixing Operations 2-32
2.3.2.5 Coating/Solvent Storage 2-32
2.3.2.6 Wastewater 2-32
2.4 References 2-33
Chapter 3. Emission Control Techniques 3-1
3.1 Capture Systems 3-4
3.2 Add-On Control Devices 3-4
3.2.1 Combustion Control Devices 3-6
3.2.1.1 Thermal Incineration 3-6
3.2.1.2 Catalytic Incineration 3-10
in
-------
Table of Contents (continued)
Page
3.2.2 Recovery Devices 3-13
3.2.2.1 Carbon Adsorption 3-14
3.3 Pollution Prevention Techniques 3-19
3.3.1 High Solids Coatings 3-19
3.3.1.1 Background 3-19
3.3.1.2 Applicability to Metal Can Surface Coating Operations 3-19
3.3.2 Waterborne Coatings 3-20
3.3.2.1 Background 3-20
3.3.2.2 Applicability to Metal Can Surface Coating Operations 3-22
3.3.3 Ultraviolet (UV)-Curable Finishes 3-23
3.3.3.1 Background 3-23
3.3.3.2 Applicability to Metal Can Surface Coating Operations 3-24
3.3.4 Powder Coatings 3-25
3.3.4.1 Background 3-25
3.3.4.2 Applicability to Metal Can Surface Coating Operations 3-26
3.4 References 3-26
Chapter 4. Model Plants and Control Options 4-1
4.0 Introduction 4-1
4.1 Model Plants 4-1
4.1.1 Model Plant 1—Two-Piece Beverage Can 4-4
4.1.2 Model Plant 2—Two-Piece Food Can 4-7
4.1.3 Model Plant 3—One-Piece Aerosol Can 4-8
4.1.4 Model Plant 4—Sheetcoating 4-8
4.1.5 Model Plant 5—Three-Piece Food Can Body Assembly 4-11
4.1.6 Model Plant 6—Three-Piece Non-Food Can Body Assembly 4-12
4.1.7 Model Plant 7—End Lining 4-13
4.2 Control Options 4-16
4.2.1 Control Options for Two-Piece Draw and Iron Beverage and Food Can 4-16
4.2.2 Control Options for One-Piece Aerosol Cans 4-18
4.2.3 Control Options for Sheetcoating Operations 4-18
4.2.4 Control Options for Three-Piece Food and Non-Food Can Assembly and
End Lining 4-21
4.3 Enhanced Monitoring 4-22
4.3.1 Enhanced Monitoring for Two-Piece Beverage and Food Cans and
Sheetcoating Operations 4-22
4.3.2 Enhanced Monitoring for Three-Piece Can Assembly and End Lining
Operations 4-23
Chapter 5. Summary of Environmental and Energy Impacts 5-1
5.1 Basis for Impacts Analysis 5-1
5.2 Primary Air Impacts 5-2
5.3 Secondary Environmental Impacts 5-11
IV
-------
Table of Contents (continued)
Page
5.3.1 Secondary Air Impacts 5-11
5.3.2 Secondary Water Impacts 5-13
5.3.3 Secondary Solid Waste Impacts 5-13
5.4 Energy Impacts 5-13
5.4.1 Electricity 5-13
5.4.2 Fuel 5-14
5.5 References 5-14
Chapter 6. Model Plant Control Costs 6-1
6.0 Introduction 6-1
6.1 Assumptions 6-2
6.1.1 Capital Equipment Costs 6-2
6.1.2 Monitoring, Recordkeeping, and Reporting Costs 6-4
6.1.2.1 Computer Equipment Costs 6-5
6.1.2.2 Performance Testing Costs 6-5
6.1.2.3 Monitoring Equipment Costs 6-6
6.1.2.4 Operation and Maintenance Costs 6-6
6.1.3 Material Costs 6-6
6.2 Overall Costs 6-7
6.2.1 Estimated Costs for Industry Segments 6-7
6.2.1.1 Two-Piece Beverage Can Facilities (Model Plant 1) 6-8
6.2.1.2 Two-Piece Food Can Facilities (Model Plant 2) 6-8
6.2.1.3 One-Piece Aerosol Can Facilities (Model Plant 3) 6-8
6.2.1.4 Sheetcoating Facilities (Model Plant 4) 6-8
6.2.1.5 Three-Piece Food Can Assembly Facilities (Model Plant 5) 6-8
6.2.1.6 Three-Piece Nonfood Can Assembly Facilities (Model Plant 6) 6-9
6.2.1.7 End Lining Operations (Model Plant 7) 6-9
6.2.2 Overall Total Annual Cost 6-9
6.3 Cost Effectiveness 6-34
6.4 Small Businesses 6-36
6.5 References 6-36
LIST OF FIGURES
Figure 2-1. Number of can manufacturing plants by State 2-3
Figure 2-2. Metal can shipments by end use, 1997-1999 (millions of cans) 2-5
Figure 2-3. 1997 metal can shipments by manufacturing process 2-5
Figure 2-4. Three-piece can sheet base coating operation 2-8
Figure 2-5. Sheet printing operation 2-9
Figure 2-6. Three-piece can fabrication process 2-11
Figure 2-7. Two-piece draw-and-iron aluminum beverage can manufacturing process .... 2-13
Figure 3-1. Thermal incinerator—general case 3-7
Figure 3-2. Regenerable-type thermal incinerator 3-9
Figure 3-3. Schematic of a typical catalytic incineration system 3-12
-------
Table of Contents (continued)
Page
Figure 3-4. Typical carbon adsorber operating continuously with two fixed beds 3-16
LIST OF TABLES
Table 1-1. 1977 Metal Can CTG (RACT) VOC Limits 1-3
Table 1-2. Summary of California AQMD VOC Limits 1-4
Table 1-3. Two-Piece Beverage CanNSPS VOC Emission Limits 1-5
Table 2-1. Types of Cans and Their Uses 2-4
Table 2-2. Coatings and Their Purposes 2-17
Table 2-3. Coating Technologies: VOC/HAP Content and Uses 2-20
Table 2-4. HAP Emissions From Can Manufacturing Facilities 2-29
Table 2-5. HAP Emissions From Metal Can (Surface Coating) Facilities 2-30
Table 3-1. Emission Reduction Techniques Used by Coating Process/End Use 3-2
Table 3-2. Add-On Control Efficiencies Currently Achieved by Coating Process/End Use . 3-5
Table 4-1. Summary of Metal Can (Surface Coating) Model Plant Categories 4-3
Table 4-2. Two-Piece Beverage Can Plants 4-5
Table 4-3. Two-Piece Food Can Plants 4-7
Table 4-4. One-Piece Aerosol Plants 4-8
Table 4-5. Sheetcoating Plants 4-9
Table 4-6. Three-Piece Food Can Body Assembly Plants 4-11
Table 4-7. Three-Piece Non-Food Can Body Assembly Plants 4-13
Table 4-8. End Lining Operations Plants 4-14
Table 4-9. Summary of Two-Piece Beverage Facility Control Device Characteristics .... 4-17
Table 4-10. Summary of Two-Piece Food Facility Control Device Characteristics 4-17
Table 4-11. Summary of One-Piece Aerosol Facility Control Device Characteristics 4-18
Table 4-12. Summary of Sheetcoating Control Device Characteristics 4-19
Table 4-13. Current UV-Cured Coating Uses 4-20
Table 5-1. Summary of Primary Air Impacts 5-2
Table 5-2. Two-Piece Beverage Can Segment Impacts 5-3
Table 5-3. Two-Piece Food Can Segment Impacts 5-5
Table 5-4. One-Piece Aerosol Can Segment Impacts 5-5
Table 5-5. Sheetcoating Segment Impacts 5-6
Table 5-6. Food Can Assembly Segment Impacts 5-8
Table 5-7. Non-Food Can Assembly Segment Impacts 5-9
Table 5-8. End Lining Segment Impacts 5-9
Table 5-9. Summary of Secondary Air Impacts 5-12
Table 5-10. Summary of Energy Impacts 5-13
Table 6-1. Summary of RTO Air Flows 6-4
Table 6-2. Two-Piece Beverage Can Facilities (Model Plant 1) Costs 6-10
Table 6-3. Two-Piece Food Can Facilities (Model Plant 2) Costs 6-13
Table 6-4. One-Piece Aerosol Facilities (Model Plant 3) Control Costs 6-13
Table 6-5. Sheetcoating Facilities (Model Plant 4) Control Costs 6-14
Table 6-6. Three-Piece Food Can Assembly Facilities (Model Plant 5) 6-17
Table 6-7. Three-Piece Nonfood Can Assembly Facilities (Model Plant 6) 6-19
Table 6-8. End Lining Operations (Model Plant 7) 6-20
VI
-------
Table of Contents (continued)
Page
Table 6-9. Summary of Total Annual Costs 6-23
Table 6-10. Cost Effectiveness of Controls for Metal Can (Surface Coating) Industry .... 6-35
vn
-------
LIST OF ABBREVIATIONS, ACRONYMS, AND UNITS OF MEASURE
ACT
APCD
AQMD
BID
CO
CO2
CTC
CTG
EB
EGBE
EPA
fWmin
gal
HAP
ICR
L
Ibs
LEL
MACT
MEK
Mg
MRI
m3/min
NESHAP
NOX
NSPS
OAQPS
OSHA
ppm
RACT
RTO
SOX
TAC
THC
TRI
TTN
UV
VOC
VOHAP
alternative control techniques
air pollution control device
Air Quality Management District
background information document
carbon monoxide
carbon dioxide
control technology center
control techniques guidelines
electron beam
ethylene glycol butyl ether
U. S. Environmental Protection Agency
cubic feet per minute
gallon(s)
hazardous air pollutant
information collection request
liter
pounds
lower explosive limit
maximum achievable control technology
methyl ethyl ketone
megagram
Midwest Research Institute
cubic meters per minute
national emission standards for hazardous air pollutants
nitrogen oxides
new source performance standards
Office of Air Quality Planning and Standards
Occupational Safety and Health Administration
part(s) per million
reasonably available control technology
regenerative thermal oxidizer
sulfur oxides
total annualized cost or total annual cost
total hydrocarbon(s)
Toxic Chemical Release Inventory
Technology Transfer Network
ultraviolet
volatile organic compound
volatile organic hazardous air pollutant
Vlll
-------
This page intentionally left blank.
IX
-------
Chapter 1
Introduction
1.0 OVERVIEW
Section 112 of the Clean Air Act (CAA) requires the U. S. Environmental Protection Agency
(EPA) to establish emission standards for all categories of sources of hazardous air pollutants.
These national emission standards for hazardous air pollutants (NESHAP) must represent the
maximum achievable control technology (MACT) for all major sources. The CAA defines a
major source as:
"... any stationary source or group of stationary sources located within a contiguous area
and under common control that emits or has the potential to emit, in the aggregate,
10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any
combination of hazardous air pollutants."
In July 1992, the Documentation for Developing the Initial Source Category List was published.1
"Metal Can Manufacturing (Surface Coating)" was included as a source category. The Metal
Can Manufacturing (Surface Coating) Industry NESHAP project establishes air emission
standards for major sources in this source category.
The purpose of this document is to summarize the background information gathered during the
development of the Metal Can Manufacturing (Surface Coating) Industry NESHAP. The
following sections provide additional details on the background of the metal can source category,
a summary of existing Federal/State/local regulations, and a brief summary of the project history.
1-1
-------
1.1 BACKGROUND
Metal cans are used to store a wide variety of products, including beverages, foods, aerosol
products, paints, medicines, and many other products. The metal can industry may be divided by
manufacturing process, coating operation, and can contents. The main can manufacturing
processes for the metal can industry are three-piece and two-piece can body manufacturing and
can end manufacturing. Breakouts of these categories would include the draw-and-iron and two-
piece draw/redraw processes. The draw-and-iron process is used to manufacture both one- and
two-piece cans.
Decorative tins and metal crowns and closures manufacturing/coating operations are similar to
can manufacturing and are sometimes coated on the same lines as traditional cans. Because of
the similarities and co-location with can coating, the EPA is including the coating of decorative
tins and metal crowns and closures as part of the metal can source category.
Coating operations are performed on both the exterior and interior of a metal can. The exterior
coatings in use are base coat, inks, overvarnishes, rim coat, bottom coat, side seam stripe, and
repair coatings. The interior coatings in use are sheet-applied protective coatings, inside sprays,
side seam stripe, and end seal compound. Further explanation of the can manufacturing process
and the coating operations are provided in Chapter 2.
Organic hazardous air pollutants (HAP) are present in many of the inks, coatings, primers and
adhesives applied to metal cans during the coating operations. Many of the same HAP are also
present in some of the materials used for cleaning associated with surface coating operations.
Glycol ethers make up the majority of the HAP used and emitted by the metal can manufacturing
industry. Additional details on HAP use associated with various can coating technologies and
industry segments are further discussed in Chapter 2.
1-2
-------
1.2 SUMMARY OF EXISTING FEDERAL/STATE/LOCAL
REGULATIONS
The EPA published a control techniques guidelines document (CTG) for "Control of Volatile
Organic Emissions from Existing Stationary Sources—Volume II: Surface Coating of Cans,
Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks" (EPA-450/2-77-008) in 1977 to
provide guidance to states in controlling volatile organic compounds (VOC) emissions from can
manufacturing operations.3 The CTG recommended emission limits for all coating operations
based on reasonably available control technology (RACT). Table 1-1 summarizes these limits,
which are expressed in pounds of VOC emitted per gallon of coating applied, subtracting the
volume percent of water in the coating. These limits can be achieved by either using coatings
with VOC content equal to or less than the limits or by reducing the level of VOC actually
emitted to these levels using add-on controls.
Table 1-1. 1977 Metal Can CTG (RACT) VOC Limits3
Affected operations
Sheet basecoat and overvarnish
Two-piece can exterior
Two- and three-piece can interior body spray, two-piece can end
Three-piece can side seam spray
End seal compound
VOC limit,
kg VOC/L coating - water
0.34
0.34
0.51
0.66
0.44
Most State VOC rules are at exactly these levels, at least for nonattainment areas within the
State. However, a few local and regional agencies, such as California's Bay Area and South
Coast air quality management districts (AQMDs) have adopted stricter standards.4'5 The South
Coast AQMD limits also affect manufacturers of pails, 55-gallon drums, and decorative tins,
which are regulated as miscellaneous metal parts in some States. Table 1-2 summarizes the Bay
Area and South Coast AQMD VOC limits. In addition to limits from coating operations, both
the Bay Area and South Coast AQMDs regulate cleaning operations. For example, metal can
1-3
-------
Table 1-2. Summary of California AQMD VOC Limits
Affected operations
Sheet basecoat and overvarnish
Two-piece can exterior base coat & varnish
Two- piece can interior body spray
Three-piece can interior body spray
Two-piece can exterior end
Three-piece can side seam spray
Inks
End seal compound: food/beverage cans
Nonfood
VOC limit, kg VOC/L coating - water
Bay Area AQMD
0.225
0.25
0.51
0.51
0.51
0.66
0.3
0.44
South Coast AQMD3
0.225
0.25
0.51
0.44
~
0.66
0.3
0.44
3South Coast AQMD also has a list of "exempt" solvents that may be subtracted from the VOC total.
coating operations in the South Coast AQMD are subject to Rule 1171, which limits the vapor
pressure of solvents used and the cleaning methods that can be used, requires the use of covered
nonporous containers, and prohibits the use of propellants. Rule 1171 also allows facilities to
use add-on controls that achieve at least 90 percent capture and 95 percent destruction
efficiencies as an alternative to work practices. The Bay Area rule requires the following work
practices: (1) closed containers must be used for storage or disposal of cloth or paper used for
solvent surface preparation and cleanup; (2) fresh or spent solvent must be stored in closed
containers; and (3) the use of organic compounds for the cleanup of spray equipment including
paint lines is prohibited unless equipment for collecting the cleaning compounds and minimizing
their evaporation to the atmosphere is used.
In addition to VOC regulations, many States have their own list of air toxics (many of which are
also designated as HAP under the CAA) and air toxics rules that may apply to metal can coating
facilities. These regulations typically regulate a large number of chemical compounds. These
air toxics regulations typically specify allowable fenceline concentrations for the individual air
toxics. If a facility's annual emissions of a regulated compound exceed a specified level, the
1-4
-------
State may require facility to perform dispersion modeling to determine whether the allowable
concentration is exceeded at any point beyond the fenceline. The decision to require modeling
depends on several factors, including the toxicity of the pollutant, its status as a VOC or HAP,
the National Ambient Air Quality Standards (NAAQS) attainment status of the facility location,
and other considerations. If the actual or modeled emissions at the fenceline exceed the
allowable concentration, the facility must reduce its air toxic emissions.
In 1983, EPA promulgated a new source performance standard (NSPS) for two-piece beverage
can surface coating (40 CFR 60, subpart WW).6 The NSPS emission limits are more stringent
than the CTG VOC emission limits, and are expressed in terms of mass (kilograms [kg]) of VOC
emitted per volume (liter [L]) of coating solids used. As an example, the NSPS limit for
two-piece can exterior base coatings is 0.29 kg of VOC per L of coating solids (0.46 kg VOC/L
of coating solids for clear base coats), whereas the applicable CTG limit is equivalent to 0.53 kg
VOC/L of coating solids. Table 1-3 summarizes the NSPS emission limits. These limits apply
to new sources nationwide, regardless of nonattainment status.
Table 1-3. Two-Piece Beverage Can NSPS VOC Emission Limits6
Coating operation
Exterior base coat (except clear base coat)
Clear base coat and overvarnish
Inside spray
VOC emission limit,
kg VOC/L coating solids applied
0.29
0.46
0.89
1.3 PROJECT HISTORY
1.3.1 Data Gathering
In 1998, an information collection request (ICR)7 was developed by EPA to determine HAP
usage, controls, and emissions associated with the metal can manufacturing industry. The ICR
was sent to 37 U.S. can manufacturing companies in July of 1998. Responses were received
from 211 facilities representing 32 companies.
1-5
-------
In addition to information obtained from these questionnaires, several site visits were made to
metal can manufacturing facilities with surface coating operations. Also, the EPA has met with
multiple trade organizations and industry representatives over the past 5 years.
Based on data obtained from the Can Manufacturers Institute (CMI), industry meetings, and TRI
data, the total number of can manufacturing facilities in the United States is estimated to be
between 210 and 220. However, the ICR responses represent facilities producing more than
98 percent of the total number of cans manufactured/shipped in the United States.
1.3.2 Emissions and Control Data
The available emissions and control information for the metal can manufacturing industry has
been summarized in Chapters 2 and 3. Most of the information collected is based on calendar
year 1997, and is representative of current practices. In some segments of the industry, coating
operations shifted away from HAP to non-HAP VOC and waterborne materials. Control
efficiency data are relevant to current conditions for the purpose of MACT determination.
1.4 REFERENCES
1. U. S. Environmental Protection Agency. Documentation for Developing the Initial Source
Category List: Final Report. Publication No. EPA-450/3-91-030. Research Triangle Park,
NC. July 1992.
2. U. S. Environmental Protection Agency. Preliminary Industry Characterization: Metal Can
Manufacturing—Surf ace Coating. Research Triangle Park, NC. September 1998.
3. U. S. Environmental Protection Agency. OAQPS Guidelines. Control of Volatile Organic
Emissions from Existing Stationary Sources - Volume II: Surface Coating of Cans, Coils,
Paper, Fabrics, Automobiles, and Light-Duty Trucks. Publication No. EPA-450/2-77-008.
Research Triangle Park, NC. May 1977.
4. Bay Area (California) Air Quality Management District Regulation 8, Organic Compounds,
Rule 11 - Metal Container, Closure, and Coil Coating. December 20, 1995.
5. California South Coast Air Quality Management District Rule 1171: Solvent Cleaning
Operations. June 13, 1997.
1-6
-------
6. U. S. Environmental Protection Agency. New Source Performance Standards for the
Beverage Can Surface Coating Industry. 48 FR 38737. Washington, D.C. U.S.
Government Printing Office. August 25, 1983.
7. U. S. Environmental Protection Agency. Information Collection Request for the Metal Can
Manufacturing Industry. July 22, 1998. [Docket A-98-41, Item II-C-15]
1-7
-------
Chapter 2
Metal Can Manufacturing—
Surface Coating Source Category
This chapter characterizes the metal can manufacturing industry, including facilities, products,
manufacturing and coating processes, sources of HAP emissions, and emission reduction
techniques. The information in this chapter comes from readily available sources including the
literature, industry representatives, and State and local air pollution control agencies.
2.0 INDUSTRY PROFILE
A can is defined in the dictionary as "a usually cylindrical metal container." However,
government agencies and industry groups use different criteria to determine what is a can, such
as shape, capacity, materials used for its construction, the phase of the product contained (solid,
liquid, or gas), and the material thickness or gauge.
Metal cans are used to contain a wide variety of products, including beverages, foods, aerosol
products, paints, medicines, and many other products. Metal cans and can parts are made from
aluminum or steel. Although most cans are cylindrical in shape, cans may be manufactured in
other shapes, including rectangular cans such those used to contain gasoline or paint thinner and
oblong cans used for packing hams and other meats.
Decorative tins (for example, potato chip and popcorn tins), and metal crowns and closures (for
example, metal bottle caps and jar lids) are similar to traditional can ends and are sometimes
coated on the same lines as traditional metal cans and ends. Because of these similarities and the
2-1
-------
co-location with the coating of traditional cans, the EPA is including the coating of decorative
tins and metal crowns and closures as part of the metal can source category.
The Standard Industrial Classification (SIC) code for the manufacturing of metal cans is 3411.
However, coating of metal sheets used to make cans may be performed by sheet coating
facilities, which are included in SIC code 3479. Metal crowns and closures appear under SIC
code 3466.
The coating of some can parts is done on metal coil coating lines. A separate NESHAP is under
development for metal coil surface coating, which is examining all metal coil coating, regardless
of the product manufactured from the coil. So the metal can NESHAP will not examine the coil
coating of can parts. Also, some can parts or labels are not metal. Examples include the paper
labels on most food cans and the cardboard bodies of composite cans (for example, frozen
concentrate fruit juice cans). These nonmetal materials or products are not included as part of
the metal can manufacturing (surface coating) source category, but may be regulated under
another source category, such as paper and other web coating, or printing and publishing.
It is estimated that 220 plants in the United States are engaged in one or more can manufacturing
processes, as identified by SIC code 3411. Figure 2-1 presents the distribution across the
country of the 208 metal can plants identified in the project database. As Figure 2-1 indicates,
can manufacturing plants are concentrated in California, Texas, and several States in the East
and Midwest. To minimize shipping distance, the distribution of can plants tends to be clustered
around agricultural regions or areas of dense human population, depending on the cans' end use.
The operations performed by can manufacturing facilities vary from plant to plant. Many of
these plants operate complete can manufacturing processes. However, some plants perform only
sheet printing and coating, sending finished sheets to other facilities that complete the can
manufacturing process. Other plants produce only can ends from coils or sheets that may be
purchased precoated or coated on site. Still other plants operate can manufacturing processes
2-2
-------
and produce other container products such as metal crowns and closures. In addition, some
metal can manufacturing facilities are co-located with food packaging plants.
2-3
-------
to
Hawaii: 2
Puerto Rico: 2
TOTAL: 208
Figure 2-1. Number of can manufacturing plants by State.
-------
Most metal cans produced today are two-piece cans and three-piece cans. Table 2-1 summarizes
the different variations of two- and three-piece cans and typical uses. As Table 2-1 shows,
two-piece draw-and-iron aluminum cans typically hold beverages but may also hold food and
nonfood products. Cans containing nonfood products are called general line cans. Another type
of aluminum draw-and-iron can is the one-piece aluminum can, which is used for aerosol and
pumped applications for pharmaceutical products (e.g., saline solution), cosmetics (e.g.,
perfume, hair spray, and air freshener), as well as nonpropelled products such as fuel additives.
The one-piece can is so called because the aerosol or pump valve is attached directly onto the top
of the can (that is, no top end piece is required). Some industry representatives refer to one-
piece aluminum cans as bottles. Two-piece steel draw-and-iron cans are used to contain food
items.
Table 2-1. Types of Cans and Their Uses
This manufacturing
process . . .
Three-piece
Draw and iron
Two-piece draw/
redraw
Ends
Crowns and closures
Uses this material . . .
Steel
Aluminum (one- and
two-piece)
Steel (two-piece only)
Steel, aluminum
Steel, aluminum
Steel
To hold . . .
Food, juices, spices, aspirin, & other non-food items
such as paints and glues (includes decorative tins);
includes aerosols
Two-piece: primarily beer, carbonated beverages, juices
One-piece: aerosol & pump products (perfume, air
freshener, hair spray, saline solution); fuel additives
Food, other nonfood items
Food, shoe polish, sterno fuel, car wax, other non-food
items
Food and nonfood items
Food and nonfood items
Figure 2-2 presents 1997 though 1999 shipments of the various types of cans produced in the
United States, broken down by end use. As Figure 2-2 indicates, the vast majority of cans are
used to contain food and beverage products, whereas nonfood packaging accounts for only about
3 percent of metal can production.
2-5
-------
100,679 102'800 102,253
120,000n
100,000
80,000
60,000
40,000
20,000
oJ
^77
f.
/
s
32,082 31'784 32,349
X^X
f f f 4,375 4,404 4 457
/XX/^
/ \ \ \ \s
beverage food general
D1997 D1998 D1999
Figure 2-2. Metal can shipments by end use, 1997-1999
(millions of cans).
Figure 2-3 presents 1997 shipments and market share for two- and three-piece cans. As
Figure 2-3 shows, current production is dominated by two-piece cans, which accounted for
83 percent of cans shipped in 1997. The number of one-piece cans is less than 0.1 percent of the
cans manufactured and thus is not included in Figure 2-3.
01,
w
Figure 2-3. 1997 metal can shipments by manufacturing
process.2
2-6
-------
Two-piece steel and aluminum draw-redraw cans, which are shallower than draw-and-iron cans,
are used for food products (such as pet foods, tuna, salmon, and snack foods) and nonfood
products (such as car wax, shoe polish, and Sterno fuel). Can ends, used for all types of cans,
include the standard ends and several types of easy-open ends. They also include metal ends for
composite can bodies, such as frozen fruit juice cans, which have bodies made of cardboard or
other nonmetal materials.
2.1 METAL CAN MANUFACTURING AND COATING PROCESSES
Can body manufacturing and can end manufacturing involve three-piece, two-piece, and one-
piece processing. The three-piece manufacturing process is relatively simple and involves
forming and welding of the can body. Two-piece processing includes cans manufactured by the
draw-and-iron and draw-redraw processes. The manufacture of one-piece cans is discussed
under the draw-and-iron process description for two-piece cans. The can and end manufacturing
processes are described in detail in Sections 2.1.1 through 2.1.3.
2.1.1 Three-Piece Can Bodies
Three-piece can bodies are made from flat sheets cut from coils of tin-plated or tin-free steel,
depending on the end use. The tin plating is applied to prevent rust. Tin-free steel is
electrocoated with a layer of metallic chromium covered by a layer of chromium oxide.
Before the bodies are formed, coatings are usually applied to the interior and exterior surfaces
with a roller onto the flat sheet. Three-piece interior and exterior coatings are discussed briefly
below. Section 2.2 contains a detailed discussion of the coatings used in can manufacturing.
Interior coatings protect the can from corrosion by the contents and/or protect the contents from
being contaminated by dissolved metal from the can. Occasionally, however, pigmented interior
coatings enhance the visual appearance of the inside of the can. After the can is fabricated, some
facilities spray the interior with additional coating to cover any defects in the roller-applied
2-7
-------
coating. End seal compounds (explained in Section 2.2.3) and interior side seam striping
(explained below) are also interior coatings.
Exterior coatings are applied for decoration, to protect the can from corrosion, to protect the
printed designs from marring or abrasion, or to reduce friction on the bottom of the can to
facilitate handling. Typical exterior coating operations are base coating, size coating, decorative
ink and overvarnish application, bottom coating, side seam stripe application, and repair coating.
Exterior coatings are usually applied with direct-roll coaters except for side seam and repair
coatings, which are applied with a spray. Most roller-applied coatings (except for printing inks
and overvarnishes) can be applied using the same coating equipment, and many facilities use the
same equipment to apply a variety of coatings to can bodies, ends, crowns and closures, and
decorative tins.
Figure 2-4 shows how sheets are coated on one side. Steel sheets feed onto a conveyor that
transfers them to a coater that applies the coating to the sheets. After passing horizontally
through a short flashoff area, the sheets are picked up by wickets and conveyed through a wicket
oven. The sheets are typically run through an additional coating process to coat the opposite
side. For this the sheets are flipped, stacked, and returned to the front of the coating line,
returned directly to the front of coating line, or flipped and sent to another coating line. The
curing oven operates at temperatures of up to 425°F, often with multiple heating zones for proper
curing of coatings. The heating zones are followed by a cooling zone that reduces the
temperature of the sheet using ambient air from inside or outside the plant. Line speeds range
from 60 to 110 sheets per minute depending on the design and age of equipment, and the type of
coating, the 60 sheet-per-minute line speed is for lithography printing and varnish, which run
more slowly than other sheet coating operations. Oven exhaust rates usually vary between
2,000 and 14,000 standard cubic feet per minute.
Decorations on three-piece cans may be printed on the can body or on paper labels that are then
glued onto the can. As noted previously, paper label printing and gluing is not included in this
source category. Inks applied using the offset lithography process are illustrated in Figure 2-5.
2-8
-------
Inks are applied by a series of rollers transferring the design from the plate cylinder to a blanket
cylinder, then onto the metal sheet. Decorative inks are usually applied over an exterior base
coat but may be applied directly to the metal. The transfer of inks is influenced by
environmental
2-9
-------
COATING
TRAY
to
i
o
APPLICATION
ROLLER
WICKETS
!f\ "*T""~ PRESSURE
y y ROLLER
SHEET (PLATE)
FEEDER
BASE COATER
WICKET OVEN
SHEET (PLATE)
STACKER
Figure 2-4. Three-piece can sheet base coating operation.
-------
INK
• APPLICATORS
BLANKET
CYLINDER
VARNISH
TRAY
/ \
SHEET (PLATE)
FEEDER
LITHOGRAPH
COATER
OVER-VARNISH
COATER
WICKET OVEN
SHEET (PLATE)
STACKER
Figure 2-5. Sheet printing operation.
-------
factors such as temperature, draft, and humidity because the inks can become emulsified in the
presence of water. An overvarnish is applied on top of the decoration by a direct roll coater
while the inks are still wet. The inks and overvarnish cure in a wicket oven similar to, but
usually smaller than, the base coat oven. Exhaust rates range from 1,500 to 8,000 scfm. If the
required design has more than two colors, the first set of inks is dried in an oven. Another set of
inks is then applied, followed by an overvarnish and baking in an oven. At least 100 existing
three-piece printing lines are known to use ultraviolet-radiation-cured (UV-cured) printing inks
and more than 30 lines also use UV overvarnishes. These coatings are applied in the same
manner as solventborne or waterborne coatings, but are cured by exposure to ultraviolet radiation
rather than heat. Consequently, these coatings do not need to pass through a drying oven.
After the coatings are applied, the sheets are transported to the fabrication process, as illustrated
in Figure 2-6. The sheets are unloaded from a stacker to a conveyor and transported to the
slitter, which cuts the sheet into body blanks. The body blanks enter the body maker where each
blank is formed into a cylinder and the seam is welded or cemented, then sprayed with a coating
called a "side seam stripe" to protect exposed metal along the seam. The coating may be applied
to the inside of the can, the outside, or both sides depending on customers' concerns about rust
on the outside of the can or chemical reaction between the metal and the product on the inside.
The side seam stripe is cured in an electric or gas-fired oven, or by exposure to a direct-flame
burner. The cylinders are flanged in preparation for the attachment of ends, and are sometimes
necked down to reduce the size of the ends, which reduces the amount of material required to
make the ends.
In addition to protective interior coatings that are roll-coated onto flat sheets before forming,
some facilities apply inside sprays after the body has been formed, especially for larger size cans
(22 ounces and larger) to cover flaws in the sheet coating and ensure that no metal is exposed.
The spray coating is cured or baked in a single pass vertical or horizontal oven at temperatures of
up to 425°F. The typical oven exhaust rate is approximately 2,000 scfm.
2-12
-------
to
BODY MAKER
•SIDE SEAM*
SPRAY
ENDSEAMER
OVEN
PALLETIZED LOAD
LEAK TESTER
INSIDE
BODY
SPRAY
NECKER AND FLANGER
Figure 2-6. Three-piece can fabrication process.3
-------
Some cans pass through a header that forms ridges on the can to provide additional axial and
panel strength. Next, one end is applied to each can in the double seamer, where the edges of the
can body and end are folded together, then folded again to form a seal. The finished cans are
checked for leaks, and then are stacked on pallets for storage. Line speeds for three-piece can
manufacturing range from 350 to 800 cans per minute.
2.1.2 Two-Piece Can Bodies
Two-piece cans are made by forming a cup-shaped container with one piece of aluminum or
steel and attaching an end to it. Two-piece cans are manufactured either by the draw-and-iron
process or the draw-redraw process. After the fabrication process, various coatings are applied
and cured. These processes are described in detail below.
2.1.2.1 Dmw-and-lron Process
Aluminum Beverage Cans and One-Piece Cans. Figure 2-7 illustrates the aluminum
draw-and iron can manufacturing process. Metal coil is continuously fed into a cupper that
stamps shallow metal cups from the coil. In the draw-and-iron process, each cup is stamped,
placed on a cylinder, and forced through a series of rings of decreasing annular space, which
further draw out the wall of the can and iron out folds in the metal.
After the draw-and-iron step, the can bodies are trimmed to the desired length and washed to
remove lubricants used in the draw-and-iron step. Beverage cans are typically conveyed directly
to the printing and varnishing area after washing; however, about 10 percent of beverage cans
first receive an exterior base coat due to customer preference. The base coat is transferred from
a feed tray through a series of rollers and onto the can, which rotates on a mandrel. The base
coat cures at 350°F to 400°F in single or multi-pass continuous, high production ovens at a rate
of 500 to 2,000 cans per minute.
2-14
-------
CANS
to
PRINTER AND OVER-VARNISH
COATER
OVEN INTERIOR BODY SPRAY
AND EXTERIOR END SPRAY
AND/OR ROLL COATER
LEAK
TESTER
NECKERAND
FLANGER
OVEN
Figure 2-7. Two-piece draw-and-iron aluminum beverage can manufacturing process.
-------
The decorative coating process consists of a lithographic printing step and an overvarnish
application step. Four to eight colors of ink are applied to printing blankets on a lithographic
printer that transfers the designs and lettering to the can as it rotates on a mandrel. Rollers apply
an overvarnish while the inks are still wet, then, in some instances, a rim coat is applied with a
roller to the bottom of the can to facilitate handling. The cans then pass through a drying oven at
325°F to 400°F to cure the inks and overvarnish.
One manufacturer of two-piece aluminum beverage cans uses UV-cured printing inks and
overvarnishes. These coatings are applied the same way as solventborne or waterborne coatings,
but are cured by exposure to ultraviolet radiation rather than heat and do not need to pass
through a drying oven.
The inside spray coating is then applied to the interior surface of the can and a rim coat is
applied, if required. The thickness of the coating depends on the aggressiveness of the contents;
cans containing very aggressive products may require a thicker initial coating or a second
coating. The cans then pass through an oven to cure the inside spray. The open end of the can is
necked and flanged. One-piece cans are subjected to more severe necking than beverage cans
because the valve is placed directly on the can (i.e., there is no end piece); therefore, more
durable coatings are required. Then the cans are tested for leaks using pressure or light, and
tested for acceptable coating thickness by electrical resistance. Cans that fail either test are
automatically removed from the process for recycling. Cans that pass are stacked in cartons or
on pallets for storage.
Two-Piece Draw-and-Iron Steel Food Cans. The two-piece draw-and-iron steel food can
manufacturing process is similar to the aluminum beverage can process except that food cans are
typically decorated with paper labels so the printing and overvarnish steps are unnecessary.
Instead, a "wash coat" is applied to protect the can from corrosion. The wash coat is applied
after the washing process, but before drying. The cans are inverted and the wash coat is poured
over the exterior surface. The cans then pass through a drying oven to cure the wash coat.
2-16
-------
Food cans are made from steel because they are usually vacuum-packed. To provide additional
axial and panel strength, the cans pass through a header that forms three radial creases in the
metal (called "beads") after the wash coat is applied. Wash coatings are formulated to withstand
this fabrication process.
2.1.2.2 Draw-Redraw Process
As in the draw-and-iron process, aluminum or steel coil is continuously fed into a cupper that
stamps shallow metal cups from the coil. Shallow cans may be stamped only once, whereas
deeper cans may require one or two additional stamps. The cans are then stacked on pallets for
storage.
Draw-redraw cans are typically produced from precoated coils; if so, there are no additional
coating steps in the manufacturing process (coil coating for draw-redraw cans is covered under
the coil coating source category). However, some can manufacturers purchase uncoated coils
and perform sheet coating at the plant in a manner similar to the three-piece can coating
operation. Most draw-redraw cans are labeled with printed paper; however, a new process called
distortion printing has been developed in which the design is printed on the can prior to forming.
The design stretches to its intended dimensions when the can is formed.
2.1.3 Can Ends
2.1.3.1 Aluminum Beverage Can Ends
Aluminum beverage can ends are made exclusively from precoated coil. Beverage can ends are
stamped from coils in a reciprocating press. After stamping, the ends are scored in an oval
pattern and a tab is attached to form an "easy open" end. These steps are performed after the end
piece has been coated and therefore damage the coating. Repair coatings are applied after these
steps to restore the integrity of the coatings.
2-17
-------
Because they are flat, can ends must be thicker than bodies to resist pressure. Aluminum
beverage cans are usually necked down to reduce the amount of material used to make a can by
reducing the diameter of the ends.
After stamping, scoring, and tab attachment, the ends are transported to a curler which forms a
trough or "curl" on the perimeter of the can end. A bead of a liquid polymer dispersion called an
end seal compound is applied in the curl to create a hermetic seal when the end is attached to a
can by the double seamer. Solvent-based end seal compounds are usually air dried and water-
based compounds are dried in electric or gas-fired ovens at approximately 110°F. The oven
exhaust rate is about 300 scfm. The ovens can be part of a coating line or stand-alone
installations, depending on the facility.
2.1.3.2 Food Can and Other Sheet-Coated Ends
Ends for food cans are typically coated on metal sheets rather than coils. Can end sheet coatings
are applied by direct-roll coaters similar to those used in sheet coating operations for three-piece
can bodies, and some facilities use the same coating lines to coat can bodies and ends. Because
both the interior and exterior surfaces are usually coated, each sheet is subjected to two separate
application and drying steps. If UV-cured exterior coatings are used, these coatings are applied
first. The UV coating is set by passing the sheets under a bank of UV drying lamps. The sheets
are then collected and turned over by wickets in preparation for the interior coating application,
which is applied by a direct-roll coater. The sheets then pass through a drying oven to cure the
interior coatings and complete the cure of the exterior UV-cured coating. Can ends are then
formed in processes similar to those used to produce aluminum beverage can ends. The end seal
compound application step is also similar to that used in aluminum beverage can manufacturing.
Sheet-coated easy-open can ends require additional fabrication steps such as when the metal is
scored and when a tab is attached. These steps are performed after the end piece has been coated
and therefore damage the coating. Repair coatings are applied after these steps to restore the
integrity of the coatings.
2-18
-------
2.2 COATINGS
Can manufacturing processes include several coating application steps, as described in
Section 2.2. Table 2-2 summarizes the different types of coating formulations applied to cans
and their specific uses.
Section 2.2.1 introduces the general types of coatings used in can manufacturing; Section 2.2.2
describes the required properties and formulations of can coatings based on the application
process and the end use of the can.
Table 2-2. Coatings and Their Purposes
Coating application type
Purpose
Exterior:
Base coat, size coat
Inks
Overvarnishes
Rim coat
Bottom coat
Side seam stripe
Repair
To protect metal; also a base for printing inks
Decoration and information; also minor use to ID cans and indicate
pasteurization
Protection of printed design and base coat
Applied to bottom rim of can to reduce friction for improved handling
Protect can from abrasion and rust
Protect seam from abrasion and rust
Repair coatings damaged during fabrication or handling
Interior:
Sheet-applied protective coatings
Inside sprays
Side seam stripe
End seal compound
Protect metal from contents and vice versa (three-piece cans)
Protect metal from contents and vice versa (two-piece cans; some
three-piece cans)
Protect seam and surrounding bare metal from corrosion by contents
Provide hermetic seal between can and end pieces
2.2.1 Coating Technologies
In the past, most coatings used in can manufacturing contained a high concentration of solvents,
resulting in significant emissions of volatile organic compounds (VOC). However, in the 1970s,
clean air regulations created demand for coatings with lower VOC content, which led to the
development of alternative can coating formulations and technologies such as high(er)-solids,
waterborne, UV-cured, and powder coatings. While some can coating operations still use
conventional solventborne coatings, newer coating technologies have gained acceptance from
2-19
-------
industry for many applications. Suppliers of coatings to the can industry, through the Can
Manufacturers Institute (CMI), provided the EPA with a summary of the range of VOC and HAP
content in formulations used in different coating processes. This information is shown in
Table 2-3. The VOC information in Table 2-3 is not directly related to the development of the
MACT standards for HAP, however, it is included on Table 2-3 and the following discussion
because many HAP are VOC and also as additional background information. The VOC and
HAP content were reported in different units and the EPA does not have the information to
accurately convert the data to common units; so they cannot be directly compared. Note that the
HAP content data reflect as-applied values, which in some cases, such as three-piece can
fabrication, includes addition of thinning materials that may contain HAP.
According to Table 2-3, conventional solventborne coatings have high concentrations of VOC,
typically 70 to 75 percent by volume or 4.0 to 6.6 pounds of VOC per gallon of coating, minus
water (Ib VOC/lb gal coating minus water). The VOC component may consist of a single
compound or a mixture of volatile ethers, acetates, aromatics, glycol ethers, and aliphatic
hydrocarbons. The HAP content of conventional solventborne coatings ranges from 0.06 to
1.6 Ib HAP/lb solids applied.
Some of the advantages of conventional solventborne coatings are good abrasion resistance,
good performance for a wide range of applications, and easy application. However, because
most can manufacturers are subject to regulations limiting VOC emissions, low-VOC coatings
are being developed as replacements for conventional solventborne coatings in many
applications. Conventional solventborne coatings are still used for three-piece exterior sheet
coating processes where high abrasion resistance is required or where the metal is subsequently
subjected to fabrication steps (e.g., can ends, beaded three-piece cans, and draw-redraw cans). In
addition, conventional solventborne inks are used in three-piece steel can lithographic printing.
Current conventional solventborne three-piece can inks are alkyd-based and do not contain HAP,
but do contain VOC. Conventional solventborne coatings are also used as interior coatings
(including sheet coatings, inside sprays, and side seam stripe coatings) for cans containing
certain foods and nonfood products (e.g., paints and varnishes) for which no suitable low-VOC
2-20
-------
coatings have been developed. Conventional solventborne coatings have been eliminated from
two-piece beverage can coating and are expected to be eliminated from two-piece draw-and-iron
food can manufacturing by 1999.
More recent and alternative can coating formulations and technologies such as
• high solids coatings
• waterborne formulations
• ultraviolet (UV)-curable finishes
• powder coatings
are also mentioned in Table 2-3 and are considered to be pollution prevention technologies.
These technologies are further discussed in terms of general background information and their
applicability to metal can manufacturing surface coating operations in Chapter 3 (Section 3.3).
2-21
-------
Table 2-3. Coating Technologies: VOC/HAP Content and Uses3
Coating technology
VOC content, Ib VOC/gal
coating minus water
Range of HAP content,
Ib HAP/lb solids applied
Main industry uses
Comments
ALUMINUM BEVERAGE CANS
Waterborne epoxy
Waterborne white polyester,
acrylic
Waterborne varnish polyester,
acrylic
UV varnish
2.8-3.6
1.4-2.1
1.4-2.1
<0.01
0.20-0.30
0.06 - 0.20
0.06 - 0.20
<0.01
Inside spray
Exterior base coat
Exterior overvarnish and bottom
rim coat
Exterior overvarnish and bottom
rim coat
UV is only an option for less
demanding uses
STEEL FOOD CAN COATINGS
Solventborne aluminum
pigmented epoxy
Waterborne epoxy
Waterborne topcoat epoxy and
acrylic
Waterborne washcoat
5.5-6.0
2.4-3.3
2.8-3.2
1.7-2.2
1.0-1.5
0.2-0.5
0.2-0.4
0.1-0.2
Inside spray for draw-and-iron pet
food cans
Inside spray for draw-and-iron
food cans
three-piece can inside spray
Wash coat for draw-and-iron food
cans
Expected to convert fully to
waterborne in 1999
INTERIOR SHEET COATINGS
Solventborne epoxies
(includes pigmented, whites,
buff, gray)
Waterborne epoxy
4.8-6.0
1.7-2.0
0.3 - 1.6
0.04-0.10
three-piece cans:
- Fruits & vegetables
- Soups & pastas
- Meat & fish
- Petfood
- Paint & aerosol
three-piece cans:
- Fruits & vegetables
- Soups & pastas
Solvent reformulation will
increase cost & VOC content.
Waterborne and high-solids
coatings are not viable for
paint and aerosol products.
Waterborne creates
operational inefficiencies if
coaters cannot be dedicated.
Pigmented types not yet
developed.
to
to
to
-------
Table 2-3. (continued)
Coating technology
Vinyl organosol (includes
pigmented)
High solids vinyl organosol
(includes pigmented)
Oleoresinous
VOC content, Ib VOC/gal
coating minus water
4.6-6.5
3.2-4.0
1.2-3.5
Range of HAP content,
Ib HAP/lb solids applied
0.3- 1.5
0.2-0.3
0-0.1
Main industry uses
High flexibility:
- Drawn cans
- Easy -open ends
Good flexibility:
- Shallow drawn cans
- Easy -open end
- three-piece cans
- Meat, fish, pet food
- Tomatoes, juices
three-piece cans:
- Mild foods only (corn)
Comments
Reformulation will increase
cost & VOC content
Expanding usage in recent
years
Limited product resistance
EXTERIOR SHEET COATINGS
Solventborne
- Varnish
- White
High solids varnish
-White
UV overvarnish
Solventborne clear and gold
epoxies
Waterborne clear and gold
epoxies
High-performance UV
Vinyl organosol
High-solids vinyl organosol
4.0-6.0
4.0-5.0
2.6-3.0
2.3 -3.0
0.01
4.8-6.0
1.8-2.2
<0.01
4.5-6.5
3.2-4.0
0.15-0.70
0.06 - 0.40
0.1-0.2
0.1-0.2
0.01
0.8-1.6
0.04 - 0.25
O.01
0.3-0.6
0.2-0.3
High process's/flexible decorated
bodies:
- Beaded food cans
- Draw-redraw cans
Low-process decorated three-piece
bodies:
- Tomato products
- Aerosol and general line cans
Decorated three-piece bodies
- Low-process foods
- Aerosol and general line
High abrasion/flexibility needs
- Food can ends
- Draw/redraw cans
Food ends
Food ends
Draw/redraw cans
Draw/redraw cans
UV not an option for whites
UV not an option for whites
Waterborne or UV are options
only for less demanding uses
Vinyl is unsuitable for some
retorting equipment
to
-------
Table 2-3. (continued)
Coating technology
VOC content, Ib VOC/gal
coating minus water
Range of HAP content,
Ib HAP/lb solids applied
Main industry uses
Comments
END SEAL COMPOUNDS
High-solids solventborne,
waterbase
High-solids solventborne,
waterbase
Waterbase
Waterbase
0-3.7
0-3.7
0
0
0-0.36
0 - 0.44
0
0
Beer/beverage
Food:
- High-fat
- Sanitary (nonaseptic)
- Sanitary (aseptic)
Aerosol
General Line
Reformulation is required to
eliminate HAP from high-
solids solventbase sealants
Waterbase end seal
compounds have limited
commercial use on aseptic
packs
SIDE SEAM STRIPE COATINGS
Epoxy and/or acrylic
Vinyl organosol
High-solids vinyl organosols
Waterborne coatings
4.5-6.6
5.0-6.5
3.5-5.0
2.3-3.0
0.02 - 1.2
0.7- 1.2
0.5-0.7
0.2-0.3
Thin film requirements
- Seam exteriors
- Interior for mild foods and
decorative tins
Medium film weight requirements:
- Interior for most foods
Medium film weight requirements:
- Interior for most foods
Thin and medium film weight
applications
Mostly replaced by high-
solids coatings in recent years
Gradually moving to high-
solids coatings in recent years
(see below)
Expanding commercial use;
proven technology
- Early development state
- No dedicated commercial
lines
- Will require extensive
testing and customer
approval to expand use
to
to
-------
Table 2-3. (continued)
Coating technology
Powder coatings
VOC content, Ib VOC/gal
coating minus water
<0.01
Range of HAP content,
Ib HAP/lb solids applied
<0.01
Main industry uses
Thick film requirements:
- Acid foods
- Latex paints
Comments
Not practical for lower film
weight requirements
a Source: Supplier Coating Matrix submitted by CMI at the July 17, 1997 meeting between CMI and EPA.
b "High process" means cans are subjected to heat cycles such as retort or pasteurization after the coatings are applied; therefore coatings must be able to
withstand these cycles.
to
to
-------
2.2.2 Characteristics of Interior and Exterior Coatings
Metal can coatings must possess certain physical and/or chemical properties to perform properly.
In general, coatings must exhibit resistance to chemicals, flexibility, and adhesion to the metal
surface. Coatings for beer and certain beverage cans must be able to survive an aqueous
pasteurization cycle of 20 to 30 minutes at temperatures ranging from 140°F to 160°F, and
coatings for foods cooked in the can must be able to withstand conditions of 250°F and
15 pounds per square inch (psi) steam pressure for up to 90 minutes. In addition, coatings
applied using different methods (e.g., sheet, coil, or spray application) must meet different
requirements for viscosity and other parameters that affect the quality of the coating. Also,
coatings applied prior to fabrication processes, such as coatings for ends and two-piece draw-
redraw cans, must be able to withstand these processes. Finally, the end use of the can also
affects the coating formulations that can be used.
2.2.2.1 Interior Coatings
The primary purpose of the interior coating is to form a barrier between the can and its contents.
Specifically, interior coatings must protect the metal from corrosive contents and must not stain
on contact with the contents, affect the color, flavor, odor, or appearance of foods, or otherwise
contaminate the contents.
Metal cans contain a wide variety of products. The formulation of the interior coating depends
on the can fabrication and product canning processes involved as well as the chemical properties
of the contents. Interior coating formulations are typically categorized as food and nonfood
coatings due to differences in required properties and regulations affecting their formulation. All
interior coatings for cans containing edible products must meet Food and Drug Administration
(FDA) regulations, whereas interior coatings for nonfood products do not. The FDA
requirements limit the variety of solvents and resins that can be used in coating formulations for
food cans. However, because of the unique requirements of different products contained in cans,
a wide variety of interior coating formulations are used. The different types of interior coating
formulations used in metal can manufacturing are discussed in the following sections according
to the application process.
2-26
-------
Sheet-Applied Interior Coatings. Three-piece can bodies are sheet coated (rather than coil
coated) because bare margins are required to apply the weld or cement. Sheet-applied coatings
are also used to coat two- and three-piece steel can ends that are used to contain products for
which no suitable coil-applied interior coatings have been developed, such as chemically
aggressive foods (e.g., tomatoes) and non-food products (e.g., paints and varnishes). These
products require resin systems such as oleoresins, epoxy-esters, epoxy-phenolic resins, and
alkyds, which cannot be cured in the high-speed ovens used in coil coating processes.
Interior sheet coatings are typically conventional or high-solids solventborne coatings, or
waterborne coatings. The formulation of interior coatings varies greatly with the end use of the
can. Conventional solventborne coatings are used for cans containing certain foods and non-
food products (e.g., paints and varnishes) for which no suitable low-VOC coatings have been
developed.
Inside Sprays. As described in Section 2.1, inside sprays are applied to all two-piece beverage
and food cans, and a few three-piece steel food cans. Most inside spray coatings are waterborne
epoxy or acrylic formulations; some manufacturers of large three-piece cans and three-piece pet
food cans use solventborne coatings but are expected to convert to waterborne coatings in the
near future. Waterborne coating formulations for beverage cans vary only slightly for most
applications and contents. However, the application rate may vary widely because some
beverages, such as Gatorade® and other sports beverages, are more aggressive and thus require a
thicker coating.
The formulations of inside sprays for food cans, like sheet coatings for food cans, vary
significantly according to the type of product contained. The thickness of coating applied to the
interior of food cans is approximately twice the thickness applied to beverage cans.7 The
application rate is higher for food cans because the contents are typically more chemically
reactive than beverages and because consumers expect canned foods to have a longer shelf life
than beverages.
2-27
-------
Interior Side Seam Stripe Coatings. The side seam stripe is applied to the seams of three-
piece cans after welding to protect the exposed metal from the contents of the can. Most interior
side seam stripe coatings are either conventional or high-solids solventborne coatings, although
powder coatings are sometimes used when high film weights are required, such as for containing
latex paints and highly acidic foods. Because powder coating technology is not conducive to
low film weights, powder coatings are only used when a thick film weight is acceptable.
The resin base for most interior side seam stripe applications is a vinyl organosol, although
epoxy and acrylic resins are sometimes used for mild foods and decorative tins. Waterborne
coatings are currently in development, but extensive testing is required before they are accepted
for commercial use.
End Seal Compounds. End seal compounds are applied to the rims of can ends to provide a
hermetic seal when the end is attached to the can. End seal compounds are typically vinyl
organosol or plastisol formulations.
End seal compound formulations vary widely in VOC and HAP content due to the wide variety
of products that are packaged in cans. End seals with no-VOC and no-HAP content have been
developed for aerosol and general line cans, two-piece beer and beverage cans, and certain food
products. However, no-VOC end seal compounds are not suitable for some other food products.
Nevertheless, coating manufacturers are continuing to reduce the amount of VOCs and HAPs in
end seal compounds. High solids and waterborne formulations are now available for products
that formerly required compounds with VOC content in the range of conventional solventborne
coatings.
2.2.2.2 Exterior Coatings
There are no FDA requirements for exterior coatings. As a result, manufacturers can use a wider
variety of coating formulations for exterior coatings than for interior coatings. However,
exterior coatings must be durable and coatings for cans containing food or pasteurized beverages
must withstand exposure to heat during the retort or pasteurization process.
2-28
-------
Most exterior coatings are applied by rollers to sheets or preformed cans. Coating operations in
this category include the two- and three-piece can base coating and size coating, steel food can
end coating, and application of decorative inks, overvarnishes, rim coats, and bottom coats.
Other exterior coating operations are wash coating for two-piece steel cans, in which the coating
is poured over the exterior surface of the can, and application of repair coatings, which may be
applied by either conventional or electrostatic spraying techniques. Coating formulation
considerations for each type of coating application are discussed below.
Overvarnishes and Rim Coats. Three-piece can overvarnishes are typically solvent-based
coatings containing polyester resins. However, UV coatings may be used with conventional or
UV inks.
Two-piece beverage can overvarnishes and rim coats are typically waterborne acrylic or
polyester coatings similar to those used for two-piece beverage can exterior base coats; however,
one two-piece beverage can facility that uses UV printing inks also uses UV overvarnish
coatings.
Wash coatings and exterior coatings for draw-redraw cans.
Two-piece
coatings
ce draw-and-iron food can wash coatings are typically waterborne epoxy or acrylic
wwciUii5c, similar to two-piece food can inside sprays. Exterior coatings for two-piece draw-
redraw cans must be flexible and durable to withstand fabrication processes. Vinyl, vinyl
organosol, and epoxy formulations are typically used.
Can End Coatings. Aluminum beverage can coatings are coil-coated alkyds, alkyd
melamines, waterborne acrylic epoxies, or polyesters. Food can ends are typically epoxy
coatings; where high flexibility and abrasion resistance are required, solventborne formulations
are required. Waterborne epoxy or UV coatings are used for general line cans and foods not
requiring pasteurization or retort.
2-29
-------
Exterior Side Seam Stripe Coatings. Exterior side seam stripe coating formulations may be
solventborne, high-solids solventborne, water borne, or powder type coatings. These coatings
typically use either vinyl organosol, epoxy, or acrylic resins, similar to interior side seam stripe
coatings. A wider variety of resins may be used for exterior side seam stripe coatings because
FDA requirements do not apply to exterior coatings.
2.3 CHARACTERIZATION OF HAP EMISSIONS FROM METAL CAN
SURFACE COATING FACILITIES
2.3.1 HAP Emissions
2.3.1.1 1995 Toxic Release Inventory Data
Table 2-4 presents total HAP emissions from the 177 can manufacturing facilities (i.e., facilities
that reported SIC code 3411, "Metal Cans," as their primary SIC code) and two dedicated crown
manufacturing facilities (SIC code 3466) that responded to the 1995 Toxic Release Inventory
(TRI) survey. (Note that other can coating facilities emitting significant quantities of air toxics
may have reported under SIC code 3479, "Metal Coating and Allied Services.") The TRI data
indicate that many metal can manufacturing facilities emit significant quantities of HAP. Of
these 177 facilities, 135 could be considered major sources based on their reported actual HAP
emissions (not considering the facilities' potential to emit).
As Table 2-4 shows, glycol ethers represent 71 percent of reported HAP emissions from these
facilities. Ethylene glycol monobutyl ether (EGBE), a type of glycol ether, is the primary
solvent used in waterborne beverage can coatings, and accounted for 84 percent of total HAP
emissions associated with metal can production in 1995. N-hexane, which represents
approximately 10 percent of reported HAP emissions, is used primarily in end seal compounds
for beverage and food cans. According to industry representatives, end seal compounds for
many food cans are being reformulated substituting heptane (a nonHAP compound) for n-
hexane. Waterbased end seal compounds for beverage cans contain no HAP. However, there
are still some solventborne compounds in use that contain n-hexane.
2-30
-------
Table 2-4. HAP Emissions From Can
Manufacturing Facilities
HAP compound
Certain glycol ethers
Xylene (mixed isomers)
n-hexane
Methyl isobutyl ketone
Methyl ethyl ketone
Ethylbenzene
Toluene
Trichloroethylene
Methanol
1,1,1 -trichloroethane
Tetrachloroethylene
Hydrogen fluoride
Ethylene glycol
Naphthalene
Total:
Annual emissions,
ton/yr
6,861
1,123
922
296
243
105
97
32
12
10
8
5
o
5
2
9,720
Source: 1995 TRI database (177 facilities under SIC code 3411 and
2 facilities under SIC code 3466).
2.3.7.2 ICRData
Table 2-5 presents the specific HAP breakout of the total organic HAP emissions from the
208 facilities in the source category that responded to the information collection request (ICR).
This data is based on 1997 emissions from the source category as reported in Form-A of the ICR.
Of the 208 facilities, 150 are considered major sources based on potential to emit and 8 are
synthetic minor sources (leaving 142 major source facilities that are subject to the NESHAP).
As Table 2-5 shows, glycol ethers represent 71 percent of the reported HAP emissions; EGBE
accounted for the majority of glycol ethers; and xylenes and hexane accounted for 10 and 9
percent, respectively.
2-31
-------
The baseline emissions for the overall metal can manufacturing source category are estimated to
be approximately 9,775 tons per year from the estimated 220 facilities (based on the reported
data from the 208 facilities in the database). The few missing facilities not included in the
project database are assumed to be single facility companies with relatively small production
capacities and HAP emissions.
Table 2-5. HAP Emissions From Metal Can (Surface Coating) Facilities
Organic HAP compound
Glycol ethers
Xylenes (isomers and mixture)
Hexane
Methyl ethyl ketone
Methyl isobutyl ketone
Ethyl benzene
Isophorone
Formaldehyde
Toluene
Trichloroethylene
Napthalene
Methanol
Cumene
Diethanolomine
Methlyene chloride
Total
Annual emissions, ton/yr*
(entire database, 208 facilities)
6,906
933
868
339
306
122
82
67
75
40
21
5
3
3
3
9,775
Annual emissions, ton/yr*
(major sources, 150 facilities)
6,775
910
847
324
297
119
82
66
61
39
20
3
2
3
3
9,559
* Does not include HAP < 1 ton/yr
2.3.2 HAP Emission Sources and Emission Reduction Techniques
The majority of HAP emissions from metal can surface coating facilities are from the coating
application and curing processes. Other potential sources of HAP emissions are coating
equipment cleaning operations, coating mixing and thinning operations, storage of coatings and
solvents, and can washing operations. These emission sources and the associated emission
reduction techniques are described below.
2-32
-------
2.3.2.1 Coating Operations
Emissions from coating operations occur during coating application, flashoff (the evaporation of
solvents that occurs as the cans or sheets are transported from the application area to the oven),
and curing. The majority of these emissions occur in the drying or curing process, ranging from
50 to 80 percent depending on the type of coating and other site-specific factors. Conventional
coatings for the interior and exterior can body and end surfaces are cured in ovens which are
vented either to a control device or directly to the atmosphere. Ultraviolet radiation-cured
coatings do not contain significant amounts of HAP; therefore, no capture device is necessary.
The UV coatings are cured in open air under banks of UV lights. Emissions from side seam
stripe and end seal compound application operations may be vented to a control device but are
typically uncontrolled. Industry representatives maintain that controlling emissions from these
operations is not cost-effective because the captured emission streams would have a very low
solvent concentration.
Emissions of HAP can vary widely depending on the HAP content of the coating formulations
used. Low-HAP solventborne and waterborne coating formulations, UV-cured coatings, and
powder coatings can significantly reduce emissions from coating operations.
As will be discussed in Chapter 3, the predominant method of add-on control used to control
emissions from can coating operations is capture and incineration of the solvent vapors. Capture
devices used for the application and flashoff areas include floor sweeps, close-capture hoods
(hoods that capture emissions close to the point of generation), canopy hoods, partial enclosures,
(i.e., enclosures that do not meet the criteria specified in EPA Method 204), and permanent total
enclosures (i.e., enclosures that meet the criteria specified in EPA Method 204). Types of
incinerators are recuperative or regenerative thermal and catalytic oxidizers.
2.3.2.2 Cleaning Operations
Coating equipment and tools require periodic cleaning to remove buildup of coatings and dirt.
Cleaning activities may take place at the equipment location or parts may be removed and taken
to a cleaning station. Many facilities use water-based cleaning solutions, but solvent-based
2-33
-------
solutions are required for most three-piece can manufacturing facilities because the roller
material is not compatible with water-based solutions. The most common technique for reducing
emissions from cleaning operations in which solvents are used is through work practices
designed to minimize emissions. Examples of work practices are the use of covered containers
for storing solvent-laden rags and for dispensing solvents, avoidance or restriction of the use of
atomizing sprays, and the selection of low-vapor-pressure solvents where possible. Emissions
from dedicated cleaning stations and on-line cleaning are sometimes routed to incinerators.
2.3.2.3 Can Washing Operations
The draw-and-iron step in draw-and-iron can manufacturing requires the use of lubricants which
must be removed before coatings are applied. Can washing operations typically use solutions of
either sulfuric, hydrochloric, or hydrofluoric acid to etch the can surface to promote
ink/overvarnish adhesion. Facility wide air emissions of acids from can washing operations are
typically much less than 1 ton per year and are typically uncontrolled.
2.3.2.4 Mixing Operations
Most can manufacturing facilities purchase premixed coatings, and for these facilities no mixing
operations are required. However, some premixed coatings are thinned with solvents on-site to
obtain the proper viscosity. Emissions from mixing vessels may be uncontrolled or vented to
incinerators used to control emissions from coating operations.
2.3.2.5 Coating/Solvent Storage
Coatings may be stored in 55-gallon drums, totes, or in fixed tanks. At least one facility
maintains its coating storage at constant temperature to maintain the viscosity level needed for
application, eliminating breathing losses. The same facility eliminates emissions during filling
by using a vapor return system.
2.3.2.6 Wastewater
Based on EPA's current information, the major source of wastewater from can manufacturing is
washing operations at draw-and-iron can manufacturing facilities. If hydrofluoric or some other
2-34
-------
acid is used in can washing, these streams may contain very low concentrations of hydrofluoric
acid; however they are not expected to be large sources of air emissions.
2.4 REFERENCES
1. Can Manufacturers Website: http://www.cancentral.com/mcs.htm.
2. Can Manufacturers Website: http://www.cancentral.com/mcsmt.htm.
3. U. S. Environmental Protection Agency. OAQPS Guidelines. Control of Volatile Organic
Emissions from Existing Stationary Sources - Volume II: Surface Coating of Cans, Coils,
Paper, Fabrics, Automobiles, and Light-Duty Trucks. Publication No. EPA-450/2-77-008.
Research Triangle Park, NC. May 1977.
4. Letter dated July 18, 1997 from Zilke, R., Akzo Nobel Coatings Inc., to M. Wiggins, MRI.
[Docket Number A-98-41. Item Number II-D-6]
2-35
-------
This page intentionally left blank.
2-36
-------
Chapter 3
Emission Control Techniques
This chapter discusses organic HAP and volatile organic compound (VOC) emission control
techniques that are currently being used for surface coating operations in metal can
manufacturing facilities. There are two approaches to limiting HAP emissions resulting from
surface coating operations in the metal can manufacturing industry:
• Capture and control
• Pollution prevention
The first approach utilizes capture systems and add on control devices to destroy or remove the
HAP from the air stream. Capture and control are discussed separately in this chapter. The
second approach, focusing on pollution prevention, is to substitute low HAP or HAP-free
materials for materials (coatings, inks, cleaning solvents, etc.) presently in use. This second
approach also includes the use of more recent coating technologies such as powder coatings and
ultraviolet (UV) radiation-cured coatings which do not contain significant amounts of HAP.
Table 3-1 summarizes available information on the emission reduction techniques used in the
coating operations at metal can manufacturing facilities. The information was obtained from a
survey of can manufacturers conducted by CMI in 1997, except where footnoted. The two major
factors that influence the emission reduction technique used are: (1) the applicability of Federal,
State, or local regulations affecting metal can surface coating operations; and (2) the availability
of "compliant" coatings (i.e., coatings with VOC and/or organic HAP content below applicable
emission limits) for the end use of cans that are produced by a facility. For example, the data in
Table 3-1 indicate that many sheet coating lines reduce emissions through add-on capture and
incineration, presumably because there are many food products for which acceptable low-VOC
3-1
-------
Table 3-1. Emission Reduction Techniques Used by Coating Process/End Use"
Coating process/end use
Number of lines using emission reduction technique
uvb
Powder
Non-HAP
waterbome
Non-HAP
solvent-borne
Waterborne
coatings +
capture/
incineration
HAP-containing
solvent-borne
coatings +
capture/
incineration
HAP-containing
waterborne
coatings
HAP-containing
solvent-borne
coatings
(no emission
reduction)
SHEET COATING
Three-piece printing
Three-piece can overvarnish
Three-piece sheet base coating
Two-piece draw-redraw base coating
100
30
3
0
0
0
0
0
0
0
0
0
63
0
0
0
0
0
3
0
0
26
106
2
0
0
4
0
0
34
9
0
END SEAL COMPOUNDS
Food
Sanitary food
Aseptic food
Two-piece aluminum beverage
General line
Aerosol
"Compound" (end use not specified)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
24
0
58
0
26
113
0
0
0
34
0
0
0
0
0
0
0
0
0
0
9
2
0
0
0
0
0
0
0
0
0
1
0
0
53
110
3
75
14
0
21
INSIDE SPRAYS
Two-piece aluminum beverage
Steel draw-and-iron food cans
Three-piece steel food cans
0
0
0
0
0
0
0
0
0
0
0
0
74
9
0
0
0
1
109
7
0
0
0
0
TWO-PIECE DRAW & IRON CAN EXTERIOR COATINGS
Base coat
Beverage can printing
Beverage can overvarnish
Rim coat
Steel food can wash coat
0
5
5
20
0
0
0
0
NKC
0
0
0
0
NK
0
0
0
0
NK
0
15
37
49
NK
2
0
0
0
NK
0
28
68
128
NK
5
0
0
0
NK
0
to
-------
Table 3-1. (continued)
Coating process/end use
Number of lines using emission reduction technique
uvb
Powder
Non-HAP
waterbome
Non-HAP
solvent-borne
Waterborne
coatings +
capture/
incineration
HAP-containing
solvent-borne
coatings +
capture/
incineration
HAP-containing
waterborne
coatings
HAP-containing
solvent-borne
coatings
(no emission
reduction)
SIDE SEAM STRIPE
Overall
0
6
0
0
0
ld
0
227
With the exception of the data for side seam stripe operations, these data are from the 1997 survey of can manufacturers conducted by CMI. Information on some non-
members, especially smaller companies, is not represented. The survey results presented to EPA did not allow EPA to identify data from specific facilities. Therefore,
information from other sources was not included unless it could be determined that the data were not double-counted.
Information on the number of lines using UV coatings provided by Radtech International North America.
"NK" = not known.
-------
coatings have not been developed. Conversely, most two-piece beverage can facilities use
waterborne coatings without control because coatings have been developed that allow facilities
to meet existing (VOC) regulations in most areas without add-on controls.
3.1 CAPTURE SYSTEMS
Capture systems are designed to collect solvent laden air and direct it to a control device. In
most can coating operations, solvent is removed from the thousands of cans coated each minute
by evaporation in and around the coating applicator and in the subsequent curing oven. The
exhaust from the applicators and ovens is then vented either to a control device or directly to the
atmosphere. Some coatings, such as end seal compounds, can take up to 48 hours to fully cure
and the associated air emissions are only partially captured and typically not controlled.
Differences in capture efficiency contribute much more to the variation in overall efficiencies
than the choice of control device. Reported capture efficiencies in Table 3-2 ranged from
estimates of less than 50 percent to the 100 percent capture which is assumed for systems
meeting the requirements of permanent total enclosures. Test procedures are available to
determine capture efficiency and to confirm the presence of permanent total enclosures.1'2
Capture systems can be improved by extending the system to collect additional solvent laden air
from other coating and cleaning operations and through constructing additional hooding and
enclosures. In theory, capture can improve to (nearly) 100 percent for any given line or group of
lines by retrofitting walls and increasing ventilation to meet the requirements of permanent total
enclosures. In practice, it may be prohibitively expensive to retrofit some existing facilities.
3.2 ADD-ON CONTROL DEVICES
Add-on control devices are addressed within two categories: combustion control devices and
recovery devices. Combustion control devices are defined as those devices used to destroy the
contaminants, converting them primarily to carbon dioxide (CO2) and water. The combustion
control devices evaluated within this section include thermal incineration with recuperative and
regenerative heat recovery and catalytic incineration.
3-4
-------
Table 3-2. Add-On Control Efficiencies Currently Achieved
by Coating Process/End Use"
Coating process/end use
(1)
Range of CE
achieved, %b
(2)
Range of DE
achieved, %c
Best OCE achieved by a particular line, %d
(3)
CE
(4)
DE
(5)
OCE
[(3)X(4)]
SHEET COATING
Three-piece printing
Three-piece can overvamish
Three-piece sheet base coating
Two-piece draw-redraw base coating6
60 - 100
60 - 100
60 - 100
95.2
90-95
90-95
90-95
99.3
100
100
100
95.2
95
95
95
99.3
95
95
95
94.5
END SEAL COMPOUNDS
Foodf-g
Sanitary Foodf>g
Aseptic Food
Two-piece aluminum beverage
General Line (non-food)
Aerosol
90
70
0
0
0
0
93.2
90
0
0
0
0
90
70
0
0
0
0
93.2
90
0
0
0
0
83.9
63
0
0
0
0
INSIDE SPRAYS
Aluminum beer & beverage cans
Steel draw-and-iron food cans
Three-piece steel food cans
50-93
90
77 - 97.5
90-98.5
93.4
91.6-92
91.4
90
97.5
98.5
93.4
92
90
84
89.7
TWO-PIECE DRAW & IRON CAN EXTERIOR COATINGS
Base coat
Printing & Overvamish
Steel food can wash coat
50 - 92.2
50-91.4
90
95
90-98.5
93.4-95
90
91.4
90
95
98.5
95
85.5
90
85.5
SIDE SEAM STRIPE11
Overall
90h
92.5
90h
92.5
83.3
a With the exception of the data for side seam stripe operations, these data are from the 1997 survey of can manufacturers
conducted by CMI. Information on some non-members, especially smaller companies, is not represented. The survey results
presented to EPA did not allow EPA to identify data from specific facilities. Therefore, information from other sources was
not included unless it could be determined that the data were not double-counted.
b "CE" means capture efficiency.
c "DE" means destruction efficiency
d "OCE" means overall control efficiency (CE x DE).
e Information was only available for one facility.
f Some industry representatives question the accuracy of capture efficiency for end seal compound application because unless
baked in an oven, flashoff from end seams continues for several hours after application.
g For food and sanitary food cans, only one facility in each category reported control of emissions from end seal compound
application.
h Industry representative from Can Corporation of America estimated 90% for their one facility.
3-5
-------
Recovery devices are used to collect organic HAP/VOC prior to their final disposition, which
may include organic HAP/VOC reuse, destruction, or disposal. One recovery device that is
addressed in this section is carbon adsorption in conjunction with regeneration of the carbon bed
by steam or hot air. Another system discussed is a proprietary system that uses oxidant-ozone
counterflow wet scrubbing and granular-activated carbon adsorption with cold oxidation
regeneration. Also within the recovery devices section, information regarding carbon adsorption
with final destruction of organic HAP/VOC by incineration is provided.
As reported by the ICR respondents, the metal can industry has 147 add-on control devices at
73 facilities. Of those control devices, 142 are combustion control devices and 5 are recovery
devices. It should be noted that the 5 recovery devices are all located at one facility.
3.2.1 Combustion Control Devices
Combustion is a rapid, high-temperature, gas-phase reaction in which organic HAP and/or VOC
are oxidized to CO2, water, sulfur oxides (SOX), and nitrogen oxides (NOX). If combustion is not
complete, partial oxidation products, which may be as undesirable as the initial organic HAP
and/or VOC, could be released. In order to avoid such occurrences, excess air (above the
stoichiometric requirement) is used.1 More complete process descriptions are provided below
for each type of combustion control device.
3.2.1.1 Thermal Incineration
Thermal incineration is a process by which waste gas is brought to adequate temperature, and
held at that temperature for a sufficient residence time for the organic compounds in the waste
gas to oxidize. The constituents of the waste streams generated by metal can manufacturing
surface coating operations will be converted to CO2 and water in the presence of heat and
sufficient oxygen.
A schematic diagram of a typical thermal incineration unit is provided in Figure 3-1. Primary
components of the thermal incineration unit include a fan, a heat recovery device, the
combustion chamber, and the exhaust stack. The heat recovery device is used to preheat the
3-6
-------
incoming waste stream so that less auxiliary fuel is required in the combustion chamber. This
type of heat recovery is known as primary heat recovery and can generally be described as either
recuperative or regenerative. If the exhaust stream is of sufficient temperature and/or heating
value so that little or no auxiliary fuel is needed, heat recovery may not be cost effective and thus
may not be implemented. However, when auxiliary fuel is required, heat recovery can be used to
minimize energy costs. Each type of heat recovery is discussed in more detail later in this
section.
UZXL1_|Q_
Figure 3-1. Thermal incinerator—general case.
In order for the thermal incinerator to achieve the desired destruction efficiency, certain key
parameters must be controlled. These parameters include the combustion airflow rate, the waste
stream flow rate, auxiliary fuel requirements, residence time, combustion chamber operating
temperature, and the degree of turbulence between the air and combustible materials. Residence
time is the time required for the initiation and completion of the oxidation reactions. Operating
temperature is a function of the residence time, the oxygen concentration, the type and
concentration of the contaminant involved, the type and amount of auxiliary fuel, and the degree
3-7
-------
of mixing. The destruction efficiency for a particular contaminant is a function of the operating
temperature and residence time at that temperature. A temperature above 816°C (1500°F) will
destroy most organic vapors and aerosols. Turbulence, or the mechanically induced mixing of
oxygen and combustible material, can be increased by the use of refractory baffles and orifices to
force adequate mixing in the combustion chamber. Alternatively, mixing can be enhanced by
the use of over-fire air, the injection of air into the combustion zone at a high velocity, or by a
forced air draft.1
Standard Operating Conditions for Thermal Incinerators. Thermal incinerators
generally operate at a temperature ranging between 650° and 870°C (1200° and 1600°F) and
require a minimum residence time of 0.3 seconds in the combustion zone.1 Most thermal units
are designed to provide no more than 1 second of residence time to the waste gas in the
combustion chambers.3 The average operating temperature reported in the ICR responses was
773°C (1425°F) with nominal residence times of 0.5 to 1.5 seconds.
Thermal incinerators can be designed to control flow rates in excess of 2,832 cubic meters per
minute (m3/min) (100,000 cubic feet per minute [ft3/min]). The organic HAP/VOC
concentration of waste streams controlled via thermal incineration can be from the part per
million (ppm) range to 25 percent of the lower explosive limit (LEL). The organic HAP/VOC
concentrations typically cannot exceed 25 percent LEL for safety and insurance reasons.
Heat Recovery in Thermal Incinerators. Heat recovery reduces the incinerator's or other
process' energy consumption. Primary heat recovery means preheating the incoming waste
stream to the incinerator by transferring heat from the incinerator exhaust so the combustion
chamber requires less auxiliary fuel. Secondary heat recovery means exchanging heat in the
exhaust and leaving the primary device for heat recovery to some other medium used in plant
processes.
Recuperative or regenerative devices can be used for primary heat recovery. The waste gas
preheater shown in Figure 3-1 could be a recuperative heat exchanger. As shown in this figure, a
3-8
-------
heat exchanger transfers heat to the incoming waste stream from the incinerator exhaust stream.
In a recuperative heat exchanger, the incinerator's effluent continuously heats the incoming
stream in a steady-state process. Typical heat exchangers for recuperative heat recovery include
plate-to-plate and shell-and-tube. Choosing a type of heat exchanger depends on the waste gas
flow rate, the desired heat exchange efficiency, the temperature of the incinerator exhaust stream
(used for preheat), and economics. Recuperative heat exchangers can recover 70 percent of the
energy in the incinerator exhaust gas, thereby reducing fuel, the primary operating cost, by
70 percent.4
An incinerator employing regenerative heat recovery is presented in Figure 3-2. Figure 3-2
illustrates a two-chamber design in which process exhaust air is purified in a conventional
combustion chamber but uses two beds of ceramic material to recover thermal energy. The
^
t n i rv«r^ t } o fff TV 7T1
HIWJ-.ZKD vxsn
1
|
I—
ox i
OOO_iZOO«W
iiIS tnr\r\-7
WODOXJUJ
Figure 3-2. Regenerable-type thermal incinerator.
3-9
-------
process exhaust passes through a bed of ceramic heat sink material that was left hot at the end of
a preceding cycle. As the air passes over the ceramic, it extracts heat from the bed. This leaves
the ceramic bed cool at the end of the cycle and raises the air temperature to near the desired
thermal destruction temperature (combustion chamber temperature). Firing natural gas, propane,
or fuel oil into the combustion chamber adds heat to reach the destruction temperature. The
airstream leaving the combustion chamber passes through the other ceramic bed, which was left
cool during the preceding cycle. The ceramic bed absorbs the heat from the airstream, leaving
the ceramic bed hot at the end of this cycle and the exit airstream relatively cool.
The inlet and discharge airstreams are reversed, so that the ceramic beds absorb and reject heat
from the airstream on a cyclical basis. When the cycle reverses and the ceramic bed at the inlet
becomes the bed at the outlet, some contaminated air is left in the ceramic bed chamber. The
volume of contaminated air in the inlet heat sink chamber must be displaced into the combustion
chamber before extracting the high-temperature combustion air through it to attain the maximum
overall destruction efficiency from a regenerative thermal incinerator. A system designed to
"purge" the chamber is provided in a three-chamber design. In this system the same type of
absorption/rejection of heat occurs, but the third chamber allows time between inlet and
discharge cycles to purge each chamber at the end of an inlet cycle. Regenerative heat recovery
systems can recover 95 percent of the energy in the incinerator exhaust gas, with a comparable
reduction in fuel, the major operating cost.4
Thermal Incinerator Efficiency. Studies indicate that a well designed and operated
commercial incinerator can achieve at least a 98 percent destruction efficiency (or an outlet
concentration of 20 ppm) of nonhalogenated organics. This destruction efficiency corresponds
to incinerators that are operated at 871°C (1600°F) with a nominal residence time of 0.75
second.3
Those metal can facilities with thermal incinerators reported destruction efficiencies ranging
from 73 to 100 percent. However, most of the reported values were in the 90 to 95 percent
range. (See Tables 4-6 through 4-9 for facility specific control device information.)
3-10
-------
3.2.1.2 Catalytic Incineration
Catalytic incineration is comparable to thermal incineration in that VOC and/or organic HAP are
heated to a temperature sufficient for oxidation to occur. The temperature required for oxidation
with catalytic incineration is considerably lower than that required for thermal incineration
because a catalyst is used to promote oxidation of contaminants. The catalyst is imposed on a
large surface containing many active sites on which the catalytic reaction occurs. Platinum is the
most widely used catalyst; palladium is also commonly used. Because the metals used as
catalysts are expensive, only a thin film is applied to the supporting substrate. Ceramic materials
are commonly used as the supporting substrate.5
Figure 3-3 is a schematic of a typical catalytic incineration system. As indicated in this figure,
components of the system include a fan, a preheat chamber, a catalyst chamber, a waste gas
preheater (recuperative heat recovery device), secondary heat recovery, and a stack. The preheat
chamber is used to heat the incoming waste stream to the required oxidation temperature, usually
between 149° and 482°C (300° and 900°F) for catalytic incineration.10 The mixing chamber is
used to thoroughly mix the hot combustion products from the preheat chamber with the exhaust
waste stream. This ensures that the stream sent to the catalyst bed is of uniform temperature.
Combustion of the VOC in the waste gas then takes place at the catalyst bed. The catalyst bed
may be a fixed bed or a fluidized bed consisting of individual pellets enclosed in a screened unit.
The recuperative heat recovery device (if incorporated) is a shell-and-tube or plate-to-plate heat
exchanger. A heat recovery device is used if supplemental fuel requirements are expected to be
high.10
Many parameters affect the performance of a catalytic incineration system. The primary factors
include operating temperature, space velocity (inverse of residence time), organic HAP/VOC
concentration and species, and catalyst type and susceptibility to contaminants.5 The optimum
operating temperature depends on the type of catalyst, as well as the concentration and type of
organic HAP/VOC. Space velocity is defined as the volume of gas entering the catalyst bed
divided by the volume of the catalyst bed. In general, as space velocity increases, destruction
efficiency decreases.5 One factor that increases the space velocity is increased temperature. The
3-11
-------
amount and type of organic HAP/VOC determine the heating value of the waste stream and thus
the amount of supplemental fuel required to maintain the desired operating temperature.
3-12
-------
,^ ug f/Ynrc"
:<ŁŁ.
id
<~»< igffvs-11-* 11 int
CD
o
a
•> fYl i m i irf|-i i rv^
11 iTi i rvrns-
Figure 3-3. Schematic of a typical catalytic incineration system.
-------
The type of catalyst that is used is determined by the organic HAP/VOC in the waste stream.
Particulates and catalyst poisons in the waste stream can affect the efficiency of the catalyst and
its lifetime. Some materials that are considered catalyst poisons include heavy metals (mercury,
lead, iron, etc.), silicon, sulfur, halogens, organic solids, and inert particulates.5 Particulates and
poisons reduce the activity of the catalyst site, minimizing sites available for the oxidation
reaction. These materials can also mask, plug, or coat the catalyst surface, thereby eliminating
available catalyst sites.
Standard Operating Conditions for Catalytic Incineration. The catalyst bed in
catalytic incinerators generally operates at temperatures ranging between 149° and 482°C (300°
and 900°F), with temperatures rarely exceeding 538°C (1000°F). The contact time required
between the contaminant and the catalyst so that complete oxidation occurs is normally
0.3 second. The excess air requirements for catalytic incineration units are usually only 1 to
2 percent higher than the stoichiometric requirements.1'5 Catalytic incinerators can be designed
to control waste gas flow rates up to about 1,416 nrVmin (50,000 ft3/min). The VOC content of
the waste stream may be in the part-per-million range up to 25 percent LEL. The range of
operating temperatures reported in the ICR responses was 370° to 420°C (700° to 800°F) with a
nominal residence time of 1.0 tol.5 seconds.
Catalytic Incinerator Efficiency. A well operated and maintained catalytic incineration unit
can achieve destruction efficiencies of 98 percent, comparable to thermal incineration units. The
destruction efficiency would decrease in the presence of the catalyst poisons and particulates
described above.6 Those metal can facilities with catalytic incinerators reported destruction
efficiencies ranging from 90 to 98 percent. (See Tables 4-6 through 4-9 for facility specific
control device information.)
3.2.2 Recovery Devices
Organic HAP and/or VOC in a waste gas stream can be collected through adsorption of the
contaminants onto a porous bed. The contaminants can then be recovered, if desired, by
desorption of the bed with steam or hot air. Contaminants can be condensed and recovered or
3-14
-------
disposed of after desorption or regeneration. Alternatively, contaminants can be sent to an
incinerator for destruction after regeneration by hot air. The following section discusses the use
of activated carbon adsorption systems followed by steam and hot air regeneration.
3.2.2.1 Carbon Adsorption
The carbon adsorption process used to control organic HAP/VOC emissions from waste gas
streams can be subdivided into two sequential processes. The first process involves the
adsorption cycle, in which the waste gas stream is passed over the adsorbent bed for contaminant
removal. The second process involves regeneration of the adsorbent bed, in which contaminants
are removed using a small volume of steam or hot air, so that the carbon can be reused for
contaminant removal.
Adsorption is the capture and retention of a contaminant (adsorbate) from the gas phase by an
adsorbing solid (adsorbent). The four types of adsorbents most typically used are activated
carbon, aluminum oxides, silica gels, and molecular sieves. Activated carbon is the most widely
used adsorbent for air pollution control and is the only type of adsorbent discussed in this
section.1 Both the internal and external surfaces of the carbon are used as adsorption sites.
Diffusion mechanisms control the transfer of the adsorbate from the gas phase to the external
surface of the carbon, from the external surface of the carbon to internal pores, and finally to an
active site in the pores. Adsorption depends on a mass transfer gradient from the gas phase to
the surface. There are two distinct adsorption mechanisms: physical adsorption and
chemisorption. In physical adsorption (also referred to as van der Waals adsorption), the
adsorbate is attracted to the carbon by a weak bonding of gas molecules to the solid (similar to
the attraction forces between molecules in a liquid).1 Some method of heat removal from the
carbon may be necessary because adsorption is an exothermic process, depending on the amount
of contaminant being removed from the gas phase. In chemisorption, the adsorbate is actually
chemically bonded with the adsorbing solid. Chemisorption is not as easily reversible as
physical adsorption.7
3-15
-------
Regeneration is the process of desorbing the contaminants from the carbon. Regeneration of the
carbon bed is usually initiated prior to "breakthrough." Breakthrough, as the name implies, is
that point in the adsorption cycle at which the carbon bed approaches saturation and the
concentration of organics in the effluent stream begins to increase dramatically. If the carbon
bed is not regenerated, the concentration of VOC in the effluent will continue to increase until it
is equal to that of the inlet; i.e., the carbon is saturated. Regeneration can be accomplished by
reversing the conditions that are favorable to adsorption—by increasing the temperature and/or
reducing the system pressure. The ease of regeneration depends on the magnitude of the forces
holding the VOC to the surface of the carbon. The most common method of regeneration is
steam stripping. Low-pressure, superheated steam is introduced into the carbon. The steam
releases heat as it cools; this heat is then available for adsorbate vaporization. Another
regeneration method is the use of hot, inert gas or hot air. With either steam or hot air
regeneration, the desorbing agent flows through the bed in the direction opposite to the waste
stream. This desorption scheme allows the exit end of the carbon to remain contaminant-free.1
In a regeneration process, some adsorbate, known as the "heel," may remain in the carbon after
regeneration. The actual capacity of the carbon is referred to as the working capacity and is
equal to the total capacity of the carbon less the capacity taken by the heel.7
Adsorption units that are commonly used to remove contaminant from waste gas streams include
the following:
1. Fixed or rotating regenerable carbon beds;
2. Disposable/rechargeable carbon canisters;
3. Traveling bed carbon adsorbers;
4. Fluid bed carbon adsorbers; and
5. Chromatographic baghouses.
Of the five adsorption systems listed above, the first two are most commonly used for air
pollution control. The disposable/rechargeable canisters are used for controlling low flow rates
(less than 3 m3/min (100 ft3/min) and would not be used to control the high-volume flow rates
3-16
-------
typical of the metal can surface coating operations. Only the fixed-bed, regenerable carbon
adsorption system is discussed in this chapter.7
A fixed-bed, regenerable carbon adsorption system is presented in Figure 3-4. The components
of the carbon adsorption system include:
1. A fan (to convey the waste gas into the carbon beds);
2. At least two fixed-bed carbon adsorption vessels;
3. A stack for the treated waste gas outlet;
4. A steam valve for introducing desorbing steam;
5. A condenser for the steam/contaminant desorbed stream; and
6. A decanter for separating the organic HAP/VOC condensate and water.
3-17
-------
LU
I
*-
Ł
1
L
OHiwS XDC
XEUOfc
^
XDO
oozauzK
4^ow-oo:<
n fVTV H i rnn
CO-
XIIOOLUWM
\ \\ V
O
^~
ODI—iU-
Figure 3-4. Typical carbon adsorber operating continuously with two fixed beds.
In the system depicted in Figure 3-4, one carbon vessel is being used for adsorption while the
other is being regenerated. Both vessels will alternate in the adsorption and regeneration modes.
The steam is used to regenerate a vessel and is then sent to a condenser. The condensate is a
water and organic HAP/VOC mixture. The decanter can be used to separate the condensate into
a water stream and a condensate stream. The resulting water may be treated or discharged to the
sewer depending on its measured toxicity. The condensed organics can be recycled (if usable),
used as a fuel, or disposed of.
3-18
-------
Hot air or a hot inert gas could be employed in lieu of using steam for regeneration. After
regeneration, the desorbing stream would then consist of an air or gas stream with a high organic
HAP and/or VOC concentration. This air or gas stream could then be sent to an incinerator for
final destruction of organic HAP and/or VOC.
Factors That Affect Adsorption Efficiency. Several factors affect the amount of material
that can be adsorbed onto the carbon bed. These factors include type and concentration of
contaminants in the waste gas, system temperature, system pressure, humidity of waste gas, and
residence time.7
The type and concentration of contaminants in the waste stream determine the adsorption
capacity of the carbon. Adsorption capacity is defined as the pounds of material adsorbed per
pound of carbon. In general, adsorption capacity increases with a compound's molecular weight
or boiling point, provided all other parameters remain constant. There is also a relationship
between concentration and the carbon adsorption capacity. As concentration decreases, so does
the carbon capacity. However, the capacity does not decrease proportionately with the
concentration decrease. Therefore, carbon capacity still exists at very low pollutant
concentration levels.7
Increases in operating temperature decrease adsorption efficiency. At higher temperatures, the
vapor pressure of the contaminants increases, reversing the mass transfer gradient.
Contaminants would then be more likely to return to the gas phase than to stay on the carbon. At
lower temperatures, the vapor pressures are lower, so the carbon will likely retain the
contaminants.1
The system pressure also improves adsorption's effectiveness. Increases in the gas phase
pressure promote more effective and rapid mass transfer of the contaminants from the gas phase
to the carbon. Therefore, the probability that the contaminants will be captured is increased.1
3-19
-------
The relative humidity or moisture content of the gas phase reduce the adsorption efficiency.
Although water vapor is not preferentially adsorbed over the contaminants, the presence of water
vapor in the gas phase has been demonstrated to have a negative effect on the adsorption
capacity of the carbon. However, the effect of humidity or moisture in the gas phase is
insignificant for VOC concentrations greater than 1,000 ppm and during the initial startup of the
adsorption cycle (the carbon is drier). Indeed, some moisture content in the gas phase can be
beneficial. For instance, when high concentrations of contaminants with high heats of
adsorption are present, the temperature of the carbon bed may rise considerably during
adsorption due to the exothermic nature of the process. The presence of water may minimize the
temperature rise.7
Adsorption efficiency varies slightly if contaminants don't have enough contact (residence) time
with the active sites of the carbon which allows mass transfer to occur. Contaminants especially
need this time if many molecules (high-concentration streams) are competing for the same sites.
Residence time of the contaminants with the active sites can be increased by using larger carbon
beds, but then the pressure drop across the system increases, resulting in increased operating
costs.1
Standard Operating Conditions of Carbon Adsorbers. Fixed-bed carbon adsorption
units have been sized to handle flow rates ranging from several hundred to several hundred
thousand ft3/min. There is no obvious practical limit to flowrate because multibed systems
operate with multiple beds in simultaneous adsorption cycles. The VOC and/or organic HAP
concentrations of the waste streams controlled by carbon adsorption units can range from the
part per billion level to as high as 20 percent of the LEL. Adsorption systems typically operate
at ambient pressure and temperatures ranging between 25° and 40°C (77° and 104°F).1
Carbon Adsorption Efficiency. Carbon adsorption recovery efficiencies of 95 percent and
greater have been demonstrated to be achievable in well designed and well operated units.8"10
The performance of the carbon adsorption unit is negatively affected by elevated temperature,
low pressure, high humidity, as previously discussed.
3-20
-------
3.3 POLLUTION PREVENTION TECHNIQUES
The following sections discuss pollution prevention alternatives to reducing air emissions
associated with metal can surface coating operations. Some of these options, such as the use of
high solids and waterborne coatings and inks, are widely used throughout the metal can industry,
while others, such as UV-cured and powder coatings, are used in several smaller applications.
3.3.1 High Solids Coatings
3.3.1.1 Background
High solids coatings are solventborne coatings that have reduced organic solvent content.
According to the CMI survey data presented in Table 2-3, high-solids coatings typically contain
from 2.3 to 5.0 Ib VOC/lb gal minus water coating, and the organic HAP content of high-solids
coatings ranges from 0.2 to 0.7 Ib HAP/lb solids applied. The range of organic HAP content of
high solids inks used by facilities that responded to CMFs 1997 survey is from approximately
6 to 17 percent by weight. The most widely used high-solids coating is polyurethane.
High-solids coatings are typically applied by either spray or roller methods. High-solids
coatings have higher viscosities than conventional coatings. Application of high-solids coatings
requires different application equipment from conventional solventborne coatings, such as
heating units to reduce viscosity.
3.3.1.2 Applicability to Metal Can Surface Coating Operations
High-solids coatings have replaced conventional solventborne coatings as exterior base coatings
in some low-process three-piece and two-piece draw-redraw can manufacturing. ("Low process"
means that there are no retort steps and that pre-coated metal is not subjected to fabrication steps
that may damage the coating.) High solids coatings have also been developed for use as interior
coatings for cans containing meat, pet food, fish, tomatoes, and juices, particularly shallow draw-
redraw cans and easy-open can ends. High-solids decorative inks are also used in two-piece
aluminum can manufacturing. These inks are polyester-based and have the consistency of a
solid paste. The printing process is called dry offset lithography because the ink is almost a
3-21
-------
solid. High solids solventborne end seal compounds are used for beer and beverage cans as well
as food cans.
3.3.2 Waterborne Coatings
3.3.2.1 Background
Waterborne coatings are surface coatings in which water is the main solvent or dispersing
agent.11 The various waterborne formulations available have distinct differences based on the
types of polymers used in the formulation. Waterborne coatings contain a polymer or resin base,
water, and organic solvent. The organic polymers found in water-based coatings include alkyds,
polyesters, vinyl acetates, acrylics, and epoxies, which can be dissolved, dispersed, or
emulsified. The water acts as the main carrier or dispersant, while the organic solvent aids in
wetting, viscosity control, and pigment dispersion. Waterborne coatings may be water emulsions,
solutions, or colloidal dispersions. The various polymers determine the cured film properties of
the finish. However, there is one common feature: each type employs water as the major
solvent or carrying liquid for polymers.11'12
Waterborne finishes formulated with water-emulsion polymers are true emulsions; the polymers
are discrete water-insoluble spherical particles of high molecular weight uniformly dispersed in
water. Waterborne coatings considered as solutions are formulated with copolymers formed in a
polymerization reaction occurring in a water-miscible solvent such as alcohol. The polymers
have polar groups that allow water-reducibility and, thus, true solutions of polymers in water.
Waterborne finishes known as colloidal dispersions contain colloidal dispersion polymers in
which particles of a medium molecular weight (not as high as the emulsion polymers) are
dispersed in water. The colloidal dispersion polymers have polar groups, thus allowing some
degree of solubility. The colloidal dispersion formulations are not true solutions but are also not
true emulsions because there is some degree of solubility of the polymers in the solvent.12
Each type of waterborne coating exhibits different film properties depending on the type of
polymer in the formulation. The water-emulsion formulations are of a higher molecular weight
and therefore offer advantages in the areas of durability and chemical and stain resistance.11'12
3-22
-------
Water-reducible formulations offer high gloss, clarity, and good application properties.
However, their film is not as durable as that of the water-emulsions, and the viscosity and
properties of the finishes are very dependent on molecular weight.11 The water-soluble
formulations exhibit properties of the water-emulsion and water-reducible formulations. The
water-soluble finishes offer high gloss and good application properties and are also durable and
chemical- and stain-resistant.11
Waterborne finishes can be formulated for air/force drying or for baking, depending on the
binders in the formulation. Waterborne finishes may cure in the same manner as the
solventborne finishes. Curing occurs through oxidative or thermosetting cross-linking reactions.
Waterborne finishes may also cure via latex coalescence.11'13 Latex coalescence occurs when a
polymer is dissolved in solvent, then dispersed in water. Either the solvent or water then
evaporates, leaving a polymer dispersed in solvent or water. As the remaining liquid evaporates,
the pressures force the polymer to coalesce. No polymerization takes place; these are a special
form of nonconvertible finishes.
The VOC and organic HAP content of waterborne coatings varies substantially. Waterborne
coatings are usually not free of VOC and/or organic HAP. Cosolvents are added to allow
adequate coalescence and film formation, as well as color penetration for pigmented materials.
Based on the survey information reported in the project database, the two-piece beverage
industry segment uses predominantly waterborne coatings. Inside sprays for both food and
beverage cans average 55 to 65 percent water with organic HAP contents ranging from 1.7 to
3.7 Ib HAP/gal solids. The overvarnishes used on beverage cans averaged 53 percent water and
1.2 Ib HAP/gal solids. Rim/bottom coatings averaged 40 percent water and 1.8 Ib HAP/gal
solids. The overall organic HAP emission reduction for a metal can facility depends on the
number of finishing steps and coating lines for which waterborne finishes can be used.
3-23
-------
3.3.2.2 Applicability to Metal Can Surface Coating Operations
Both solvent-borne and waterborne materials are extensively used in the surface coating
operations associated with the metal can industry. In recent years, the industry and its coating
suppliers have made significant strides in reformulating most of the solvent-borne coatings and
inks, as described above, so that lower-HAP (and lower-VOC) materials can be used. Some of
the lower organic HAP/VOC coatings may not apply to all segments of the metal can industry.
Waterborne coatings are currently being used by most of the metal can manufacturers. The
potential exists for waterborne coatings to be used, at least in part, by all segments of the metal
can industry. However, the waterborne coatings currently available are better suited to certain
applications than others. According to the CMI survey data presented in Table 2-3, waterborne
coatings contain approximately 1.4 to 3.6 Ib VOC/lb gal coating, minus water. The organic HAP
content of waterborne coatings ranged from 0.06 to 0.4 Ib HAP/lb solids applied.
Beverage can manufacturers use waterborne coatings extensively. Waterborne coatings are used
for two-piece beverage can base coats, overvarnishes, inside sprays, and rim coats. Waterborne
coatings are also used for two-piece food can wash coats, two- and three-piece can inside sprays
and exterior end coatings, and three-piece can exterior base coats. Waterborne interior side seam
stripe coatings have been developed for thin and medium film weight requirements but have not
yet been commercialized.
Waterborne coatings can use the same application equipment as conventional solventborne
coatings; however, equipment used to apply waterborne coatings must be dedicated to
waterborne coatings. This is because solventborne coating residues are incompatible with
waterborne coatings and must be completely removed from the equipment before water-based
coatings can be used. Removing solventborne coating residue from the application equipment is
a laborious and uneconomical process. Moreover, additional costs may be incurred because
some equipment that is susceptible to corrosion, including tanks, piping, and process equipment,
may need to be replaced.
3-24
-------
Water-based end seal compounds are used for general line and aerosol cans, and have limited
application for certain beverages and foods. Conventional solventborne coatings are also used as
interior coatings (including some sheet coatings, inside sprays, and side seam stripe coatings) for
cans containing certain foods and non-food products (e.g., paints and varnishes) for which no
suitable replacement coatings have been developed.
3.3.3 Ultraviolet (UV)-Curable Finishes
3.3.3.1 Background
Radiation curing is a technology that utilizes electromagnetic radiation energy to affect chemical
and physical change of organic finish materials by the formation of cross-linked polymer
networks. One type of radiation used is UV light. The primary components of UV-curable
finishes are multifunctional polymers (acrylates, acrylated oligomers), monofunctional diluent
monomers, and the photoinitiators. The oligomers provide most of the desired coating
properties, such as flexibility, hardness, and chemical resistance. The monomers decrease the
viscosity of the polymers and improve other features such as gloss, hardness, and curing speed.
The photoinitiator absorbs the UV light and initiates free radical polymerization, the curing
process. The diluent serves as a viscosity modifier for the coating, enabling the coating to be
applied to the substrate. It is similar to a solvent in this regard. In traditional UV finishes,
however, most of the diluent also polymerizes and becomes part of the coating film.14 However,
the small amount of diluent in the coating that does not reach the piece and, thus, is not
incorporated into the final film, is emitted.
Ultraviolet-curable finishes are convertible finishes; the curing process is via polymerization.
The curing process for UV-curable finishes is very fast. As the substrate is exposed to UV
radiation, the photoinitiator absorbs the light and initiates near-instant polymerization.
Polymerization, or curing, of the material is rapid, providing a final film that is stain-, scratch-,
and mar-resistant. Finished pieces can immediately be stacked because the curing is so rapid.
Other properties of the UV-cured film include heat resistance, durability, and good build.
3-25
-------
Ultraviolet-curable finishes do not typically contribute substantial organic HAP emissions (due
to the polymerization process discussed above) and often are considered to contain up to 97 to
100 percent solids since 100 percent of the components react to form the coating. However, as
previously stated, a plant's overall emission reductions depend on the number of coating steps
used by a facility that switches from solvent-borne to UV-curable coatings.
Two categories of UV coatings are currently in use: (1) acrylate epoxies, urethanes, and
polyesters known as "free radical" types; and (2) cationic epoxies. As the names imply, free
radical UV coatings contain photochemical initiators that release free radicals when bombarded
by UV light, whereas the photochemical initiators in cationic epoxies produce protons. Free
radical UV coating technology is older and is the most commonly used type of UV coating.
However, cationic epoxies are being developed with superior properties and are expected to
eventually replace free radical-type UV coatings.
The UV coatings have the advantages of rapid curing, low process temperatures, extremely low
VOC content (less than 0.01 Ib VOC/gal coating) and HAP content, and lower energy costs due
to the elimination of drying ovens. Additionally, UV application and curing equipment occupies
less plant space than conventional coating and drying equipment. However, UV coatings are
more expensive than conventional coatings. Also, UV coatings require specialized equipment;
consequently, retrofitting an existing coating line involves a significant capital investment.
Finally, UV-cured coatings are used only as exterior coatings because they have not been
approved by the FDA for use in interior coatings, due to the tendency of UV coatings to release
the photoinitiator compounds, which are potentially harmful, into the contents of the can.
3.3.3.2 Applicability to Metal Can Surface Coating Operations
Ultraviolet-curable finishes are currently used in only a few applications and segments of the
metal can industry.14 Ultraviolet radiation-cured overvarnishes and inks are currently used at
one two-piece beverage can facility and are used for rim coats at some two-piece beverage can
facilities. Additionally, UV exterior coatings (including inks) are used on several sheet coating
lines at steel can and can end sheet coating facilities. Ultraviolet radiation-cured inks are widely
3-26
-------
used for three-piece can decoration. However, UV coatings that are not inks have not yet
received widespread acceptance in the industry. According to a 1995 EPA report on UV
coatings (report no. EPA-600/R-95-063), manufacturers have had the following problems with
UV coatings: yellowing of UV overvarnishes, difficulties obtaining the proper shade with UV
white base coats, inadequate abrasion resistance, and slow cure speed. However, representatives
of UV coating manufacturers maintain that advances in UV coating chemistry, notably new
cationic epoxy formulations with improved performance characteristics, will gain increasing
acceptance by can manufacturers in the near future.
Ultraviolet-curable finishes can be applied using spray equipment, roll coaters, or curtain
coaters. Therefore, the potential exists for UV-curable finishes to be used on can exteriors as
well as flat coil or panels, and some companies see progress in this direction. However, curing
of interior areas and three-dimensional pieces, such as the inside of a metal can and a can's
curved exterior surface combined with the bottom, remains very difficult because all of the
coating material must be exposed to the UV radiation. Problems arise in curing surfaces that do
not get direct exposure to the radiation. Therefore, the only UV-curable finishes that are used in
the metal can industry are on flat line operations. Many studies in other industries are being
conducted in the area of three-dimensional UV-curing so that UV-curable materials may
experience more widespread use in the future.14
3.3.4 Powder Coatings
3.3.4.1 Background
Powder coatings are composed of fine, dry particles of paint solids and contain very low
concentrations of VOC and HAP. They are applied using electrostatic deposition, fluidized bed
dipping, or flame spraying, and are heat-cured in infrared ovens.
There are two types of powder coatings: thermoplastic and thermoset. Thermoplastic powder
coatings are based on high molecular weight thermoplastic resins. These coatings melt and flow
upon the application of heat, even after they have cooled and solidified. Thermoset powder
coatings, on the other hand, cannot be melted after heat is applied because the curing process
3-27
-------
results in a chemical change to a heat resistant compound. Both types of powder coatings
require high curing temperatures, ranging from 60° to 204°C (140° to 400°F).
3.3.4.2 Applicability to Metal Can Surface Coating Operations
Powder coatings exhibit many favorable qualities for can coating applications, including
excellent resistance to various chemicals, abrasion resistance, and barrier qualities. Powder
coatings can be used as rim coatings for two-piece beverage cans, and are currently used for
three-piece side seam stripe coatings at some facilities. However, the application processes are
generally not fast enough for can coating line speeds. Also, powder coatings are not yet
available in the variety of colors, finishes, and textures required by can manufacturers and their
customers.
3.4 REFERENCES
1. Bethea, R. M. Air Pollution Control Technology. New York, Van Nostrand Reinhold
Company. 1978.
2. Edgerton, S., J. Kempen and T.W. Lapp, Midwest Research Institute. The Measurement
Solution: Using a Temporary Total Enclosure Method for Capture Efficiency Testing.
EPA-450/4-91-020. August 1991.
3. Seiwert, JJ. Regenerative Thermal Oxidation for VOC Control. Smith Engineering
Company. Duarte, CA. Presented at Wood Finishing Seminar—Improving Quality and
Meeting Compliance Regulations. Sponsored by Key Wood and Wood Products and
Michigan State University. Grand Rapids. March 5, 1991. 27pp.
4. Memorandum and attachments from Farmer, J. R., EPA, to Distribution. Thermal
Incinerator Performance for NSPS. August 22, 1980. 29pp.
5. Radian Corporation. Catalytic Incineration for Control of VOC Emissions. Park Ridge, NJ,
Noyes Publications. 1985.
6. Telecon. Caldwell, M. J., Midwest Research Institute, with J. Minor, M & W Industries.
June 20, 1991. Catalytic incineration.
7. Calgon Corporation. Introduction to Vapor Phase Adsorption Using Granular Activated
Carbon.
3-28
-------
8. Crane, G. Carbon Adsorption for VOC Control. U. S. Environmental Protection Agency.
Research Triangle Park, NC. January 1982.
9. Kenson, R.E. Operating Results from KPR Systems for VOC Emission Control in Paint
Spray Booths. Met-Pro Corporation. Harleysville, PA. Presented at the CCA Surface
Finish'88 Seminar and Exhibit!on. Grand Rapids, MI. May 18, 1988. 10pp.
10. VIC Manufacturing. Carbon Adsorption/Emission Control. Minneapolis, MN.
11. Ballaway, B. New Developments in Waterborne Finishes. Industrial Finishing. December
1989.
12. Detrick, G. F. and K. Kronberger. Addressing the VOC Issue in Industrial Finishes.
American Paint and Finishes Journal. September 11, 1989.
13. Del Donno, T. A. Waterborne Finishes Outlook Bright. Industrial Finishing. December
1988.
14. Letter and attachments from Rechel, C. J., RadTech International, to J. A. Edwardson, and
J. Berry, EPA/ESB. October 13, 1993. Potential for reduction of emissions by the use of
UV curable finishing systems.
3-29
-------
This page intentionally left blank.
3-30
-------
Chapter 4
Model Plants and Control Options
4.0 INTRODUCTION
This chapter describes model plants and control options for representative types of metal can
surface coating facilities. As discussed in previous chapters, the project database contains
information on 208 can manufacturing facilities producing more than 98 percent of all cans made
in the United States. Therefore, the model plants described for this industry are quite
representative of the actual facilities comprising the subcategory or coating type segment
included. The model plants were developed to evaluate the general effects of various control
options on the source category. However, since the project database includes practically all
known affected sources, the associated costs and impacts discussed in Chapter 6 were developed
for each individual facility rather than for the model plant types. Control options for each model
plant were selected based on the applicability of presently available control technologies to the
industry segment represented.
4.1 MODEL PLANTS
Model plants have been developed to represent the actual range of capacity and overall control
efficiency as determined by responses to the information collection requests. Model plants have
been specified for the following seven primary types of metal can surface coating facilities:
• Two-piece beverage can facilities;
• Two-piece food can facilities;
• One-piece aerosol can facilities;
• Sheetcoating facilities;
• Three-piece food can assembly facilities;
4-1
-------
• Three-piece non-food can assembly facilities; and
• End lining facilities.
Because the majority of facilities comprising the metal can surface coating industry were
surveyed and are included in the project database, these model plants represent groupings of
actual facilities in the database. These groupings are based on the subcategories and coating
type segments determined as part of the background information, determination of MACT
floor(s), and evaluation of regulatory alternatives.
Table 4-1 summarizes data for the seven types of model plants, including the number of actual
facilities in each model plant category, the total and average amounts of coatings and solids used
by those facilities, and the associated total and average organic HAP emissions, both before and
after existing controls. These total and average values were derived from the facility-specific
values given in tables 4-2 through 4-8.
The number of facilities in each model plant category is the total number of sources in the
project database that apply surface coatings of that type. Since an individual facility may apply
more than one coating type, one facility may be represented in several model plants. However,
each category includes only coatings specific to that category. For example, overvarnishes and
interior body base coats are included only in the sheetcoating source category, end seal
compounds only in the end lining source category, etc.
4-2
-------
Table 4-1. Summary of Metal Can (Surface Coating) Model Plant Categories
Industry segment
Number of Facilities (sources)
Total Coating Usage
(gallons of coating)
Total Coating Solids Usage
(gallons of solids)
Total HAP Emissions (tons/yr)
Before Existing Controls
Total HAP Emissions (tons/yr) After
Existing Controls
Model Plant No.
Average Coating Usage
(gallons of coating)
Average Coating Solids
(gallons of solids)
Average HAP Emissions (tons/yr)
Before Existing Controls
Average HAP Emissions (tons/yr)
After Existing Controls
Overall Control (%)
with Existing Controls
Two-piece
beverage
57
25,758,833
6,243,476
6,524
4,922
1
451,909
109,535
114
86
25
Two-piece
food
11
2,503,204
604,999
989
843
2
227,564
55,000
90
77
15
One-piece
aerosol
2
146,875
47,692
172
18
o
J
73,438
23,846
86
9
90
Sheetcoating
60
9,265,269
3,496,786
9,596
2,522
4
154,421
58,280
160
42
74
Food can
assembly
28
351,724
115,419
430
408
5
12,562
4,122
15
15
5
Non-food can
assembly
13
34,216
13,001
50
50
6
2,632
1,000
4
4
0
End lining
53
2,607,435
1,127,850
840
840
7
49,197
21,280
16
16
0
-------
4.1.1 Model Plant 1—Two-Piece Beverage Can
Two-piece beverage can manufacturing was determined to be a coating type segment within the
one- and two-piece draw and iron subcategory. Model Plant 1 represents an overall average of a
total industry population of 57 two-piece aluminum beverage can operations. Operating
parameters for all 57 plants are given in Table 4-2, including information on annual coating
usage, annual organic HAP emissions, and overall control efficiencies.
Twenty, or 35 percent, of the 57 facilities making two-piece beverage can bodies have control
devices on at least some of their process lines. Since, the organic HAP usage and emission
values for Model Plant 1 in Table 4-1 are an overall average of the total amount of organic HAP
used and emitted by all 57 facilities, they include those facilities with multiple control devices,
those with some controls, and those with no controls. The range of add-on control for the
facilities used to determine Model Plant 1 is 0 (no control) to 86 percent.
4-4
-------
Table 4-2. Two-Piece Beverage Can Plants
Blind
facility ID
163
177
136
63
199
124
28
159
106
79
123
147
162
77
57
105
48
112
37
53
27
30
34
44
54
58
61
65
67
70
72
HAP emissions
(Ibs) after existing
controls
23,924
46,843
59,795
40,648
126,916
66,867
106,434
253,986
80,533
148,211
168,778
139,491
208,939
112,247
198,444
159,334
149,901
63,695
118,161
254,521
35,872
129,743
130,845
236,711
136,642
312,652
327,714
162,709
265,205
50,892
304,179
HAP emissions
(Ibs) before
existing controls
164,992
173,493
207,983
141,385
384,010
185,730
287,660
633,550
198,787
348,127
392,507
317,829
423,700
227,005
375,986
301,855
283,559
109,194
190,582
385,121
35,872
129,743
130,845
236,711
136,642
312,652
327,714
162,709
265,205
50,892
304,179
Coating usage
(gal of coating)
330,615
320,792
562,733
426,203
676,665
400,441
687,964
823,392
447,101
664,935
557,714
808,046
706,320
497,510
581,379
631,397
578,124
230,442
435,304
729,712
87,375
303,894
244,098
493,365
449,024
768,184
606,757
358,948
443,673
109,584
422,657
Solids usage
(gal of solids)
77,887
79,462
127,210
106,301
157,617
90,692
158,866
212,758
107,956
181,877
118,051
214,748
171,084
115,759
147,921
146,405
145,560
58,838
110,655
175,188
19,748
69,048
59,755
164,590
105,254
184,279
144,928
93,667
90,732
31,426
93,763
Overall
control (%)
86
73
71
71
67
64
63
60
59
57
57
56
51
51
47
47
47
42
38
34
0
0
0
0
0
0
0
0
0
0
0
4-5
-------
Table 4-2. (continued)
Blind
facility ID
75
78
80
82
85
88
89
91
92
101
108
117
118
120
130
133
135
142
144
149
150
158
178
179
189
198
HAP emissions
(Ibs) after existing
controls
73,188
466,619
311,977
227,766
212,135
203,572
142,893
195,963
223,544
274,328
199,316
106,311
197,880
138,516
107,542
547,128
191,981
82,731
143,068
171,915
208,678
219,066
173,841
130,042
115,239
157,493
HAP emissions
(Ibs) before
existing controls
73,188
466,619
311,977
227,766
212,135
203,572
142,893
195,963
223,544
274,328
199,316
106,311
197,880
138,516
107,542
547,128
191,981
82,731
143,068
171,915
208,678
219,066
173,841
130,042
115,239
157,493
Coating usage
(gal of coating)
128,211
685,226
593,845
589,832
719,832
401,858
273,266
322,297
391,559
417,196
363,833
273,590
353,216
304,991
260,231
850,150
374,488
146,784
359,617
308,050
359,897
473,696
454,739
360,637
268,188
339,257
Solids usage
(gal of solids)
29,855
168,325
128,484
146,756
180,309
88,617
66,283
76,355
92,809
99,101
86,219
69,383
83,418
76,242
60,228
210,936
87,971
34,176
86,777
73,561
82,272
120,364
105,451
83,252
60,141
84,164
Overall
control (%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4-6
-------
4.1.2 Model Plant 2—Two-Piece Food Can
Coating of two-piece draw and iron food cans was determined to be a separate coating type
segment from the two-piece beverage can segment because of differences in the coating types
applied. The two-piece food can segment uses inside sprays and base coats while the two-piece
beverage can segment uses inside sprays, base coats, rim and bottom coats, overvarnishes, and
decorative inks. Model Plant 2 represents an overall average of a total industry population of 11
two-piece food can operations. Operating parameters for all 11 plants are given in Table 4-3,
including information on annual coating usage, annual organic HAP emissions, and overall
control efficiencies.
Table 4-3. Two-Piece Food Can Plants
Blind
facility ID
96
151
71
148
12
173
139
67
119
25
93
HAP emissions
(Ibs) after existing
controls
13,132
11,978
12,845
59,917
64,619
118,771
106,473
121,055
289,975
129,317
758,484
HAP emissions
(Ibs) before existing
controls
55,224
49,992
52,893
185,492
64,619
118,771
106,473
121,055
335,529
129,317
758,484
Coating usage
(gal of coating)
99,764
90,392
95,392
343,000
216,758
369,612
179,376
227,964
405,622
131,052
344,272
Solids usage
(gal of solids)
26,490
23,993
25,348
90,179
50,128
88,045
41,703
43,451
97,935
32,629
85,099
Overall
control (%)
76
76
76
68
0
0
0
0
14
0
0
Five facilities, or 45 percent, of the 11 facilities making two-piece food can bodies have control
devices on at least some of their process lines. The average organic HAP usage and emission
values specified for Model Plant 2 in Table 4-1, therefore, include facilities with multiple control
devices, those with some controls, and those with no controls. The range of control for the
facilities used to determine Model Plant 2 is 0 (no control) to 76 percent.
4-7
-------
4.1.3 Model Plant 3—One-Piece Aerosol Can
Due to the unique requirements of coatings used on aerosol cans, surface coating of one-piece
aerosol cans was also considered a separate coating type segment within the draw and iron
subcategory. Model Plant 3 represents an overall average of the 2 one-piece aerosol can
facilities included in the database. Operating parameters for both plants are given in Table 4-4,
including information on annual coating usage, annual organic HAP emissions, and overall
control efficiencies.
Table 4-4. One-Piece Aerosol Plants
Blind
facility ID
115
55
HAP emissions
(Ibs) after existing
controls
20,686
15,575
HAP emissions
(Ibs) before existing
controls
206,858
137,467
Coating usage
(gal of coating)
94,943
51,932
Solids usage
(gal of solids)
32,032
15,661
Overall
control (%)
90
89
4.1.4 Model Plant 4—Sheetcoating
This subcategory includes all of the flat sheet metal coating operations associated with three-
piece aerosol, food, and general line cans, decorative tins, two-piece draw redraw, and crowns
and closures. The coatings used include interior and exterior base and end coatings, decorative
inks, and overvarnishes, all of which are applied by roller to flat metal sheets. The best-
performing sources typically control emissions through the use of partial or total enclosures
routed to thermal or catalytic oxidizers that achieve VOC destruction efficiencies of 95 percent
or higher. Fifty of the 60 sheetcoating facilities, or 83 percent, have at least one control device.
Operating parameters for all 60 plants are given in Table 4-5, including information on annual
coating usage, annual organic HAP emissions, and overall control efficiencies.
4-8
-------
Table 4-5. Sheetcoating Plants
Blind
facility ID
201
11
52
148
43
183
7
116
56
167
8
155
160
122
40
21
22
9
107
36
23
109
71
203
180
99
181
157
132
151
193
190
HAP emissions (Ibs)
after existing
controls
0
0
166
26,138
13,492
19,303
23,502
21,285
10,860
69,636
20,896
13,992
20,043
29,422
15,609
23,663
52,089
31,004
18,500
38,186
91,953
62,731
23,788
24,384
23,288
15,370
24,134
27,463
36,191
28,118
103,100
146,928
HAP emissions (Ibs)
before existing
controls
0
0
166
176,964
318,397
133,125
199,173
425,698
248,302
707,687
208,960
199,461
291,297
239,901
312,183
124,389
381,745
315,078
126,596
381,856
675,437
434,756
23,788
128,339
122,525
49,109
126,897
272,602
187,316
28,118
873,119
754,249
Coating usage
(gal of coating)
5,982
55
18,284
606,400
221,347
154,663
173,634
207,107
133,800
753,373
193,549
92,234
125,703
150,539
103,487
126,003
180,132
126,834
59,150
131,166
246,784
165,275
71,597
79,771
69,312
35,234
80,518
98,997
71,924
71,597
314,183
276,402
Solids usage
(gal of solids)
5,162
55
18,284
214,672
81,637
107,828
92,600
80,331
40,349
243,718
68,926
41,586
49,028
70,917
36,145
51,034
99,163
50,823
24,872
45,658
105,991
71,632
26,554
26,785
23,625
15,590
24,320
27,599
35,158
25,573
82,122
115,828
Overall
control (%)
0
0
0
85
96
86
88
95
96
90
90
93
93
88
95
81
86
90
85
90
86
86
0
81
81
69
81
90
81
0
88
81
4-9
-------
Table 4-5. (continued)
Blind
facility ID
154
16
145
68
127
42
200
195
184
129
103
38
66
97
205
172
204
32
141
20
164
25
41
161
196
19
95
96
HAP emissions (Ibs)
after existing
controls
100,917
106,860
66,400
82,799
67,570
136,317
94,737
71,091
84,641
68,796
46,888
245,916
176,292
31,472
32,869
38,609
108,181
154,864
291,416
246,943
127,630
113,757
281,869
90,558
71,245
515,387
149,493
385,854
HAP emissions (Ibs)
before existing
controls
589,601
445,249
262,261
145,518
355,634
354,120
653,360
374,166
497,304
312,332
141,150
780,084
966,845
93,422
32,869
165,469
569,371
154,864
605,134
529,051
276,335
395,678
473,211
253,316
247,809
515,387
149,493
385,854
Coating usage
(gal of coating)
182,268
241,918
132,134
123,934
115,108
177,099
167,322
158,648
183,279
137,717
69,851
291,613
224,786
40,229
50,124
54,341
132,033
115,292
266,985
272,573
96,482
129,240
195,811
80,127
66,480
235,707
64,335
114,795
Solids usage
(gal of solids)
77,065
79,921
47,898
55,973
45,092
87,422
60,215
41,969
48,722
39,419
26,620
136,046
84,081
14,703
15,188
15,519
42,445
56,545
103,304
81,426
38,879
33,313
69,551
20,965
15,783
101,188
25,743
28,228
Overall
control (%)
83
76
75
43
81
62
86
81
83
78
67
68
82
66
0
77
81
0
52
53
54
71
40
64
71
0
0
0
4-10
-------
4.1.5 Model Plant 5—Three-Piece Food Can Body Assembly
The three-piece food can body assembly segment consists of facilities that apply aseptic side
seam stripe, non-aseptic side seam stripe, and/or inside spray on can bodies that will be used to
hold food products. Model Plant 5 represents an overall average of a total industry population of
28 three-piece food can assembly operations. Only one facility, or less than 4 percent of the total
number, uses add-on control devices on a food can assembly operation. Operating parameters
for all 28 plants are given in Table 4-6, including information on annual coating usage, annual
organic HAP emissions, and overall control efficiencies.
Table 4-6. Three-Piece Food Can Body Assembly Plants
Blind
facility ID
8
16
26
47
59
71
83
107
121
127
134
137
143
145
148
151
157
160
161
165
167
HAP emissions
(Ibs) after existing
controls
5,573
23,610
7,903
26,726
67,061
6,309
64,691
1,542
4,269
9,052
30,575
9,059
7,889
200
199,297
6,427
8,472
29,664
5,181
23,054
10,598
HAP emissions
(Ibs) before existing
controls
5,573
66,979
7,903
26,726
67,061
6,309
64,691
1,542
4,269
9,052
30,575
9,059
7,889
200
199,297
6,427
8,472
29,664
5,181
23,054
10,598
Coating usage
(gal of coating)
1,802
48,555
6,875
5,619
14,339
2,394
13,366
2,090
882
12,560
23,485
2,200
1,537
55
45,100
2,394
7,822
19,174
1,787
7,810
10,446
Solids usage
(gal of solids)
848
10,286
2,428
1,693
4,188
859
4,238
487
280
2,926
5,351
662
329
28
14,652
859
6,363
6,010
664
3,541
8,646
Overall
control (%)
0
65
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4-11
-------
Table 4-6. (continued)
Blind
facility ID
190
192
192
194
195
200
202
204
205
206
HAP emissions
(Ibs) after existing
controls
38,591
5,209
31,743
24,562
23,295
22,922
17,213
18,899
58,053
27,904
HAP emissions
(Ibs) before existing
controls
38,591
5,209
31,743
24,562
23,295
22,922
17,213
18,899
58,053
27,904
Coating usage
(gal of coating)
14,820
2,028
6,903
16,775
5,236
14,080
9,341
12,207
22,007
18,035
Solids usage
(gal of solids)
4,357
873
1,964
4,200
1,878
4,335
4,661
3,960
8,184
5,667
Overall
control (%)
0
0
0
0
0
0
0
0
0
0
4.1.6 Model Plant 6—Three-Piece Non-Food Can Body Assembly
The three-piece non-food can body assembly segment consists of facilities that apply non-aseptic
side seam stripe on cans that will be used to hold nonfood and aerosol products. Facilities in this
category do not use aseptic side seam stripes and inside sprays. Model Plant 6 represents an
overall average of 13 three-piece non-food can body assembly facilities. None of these facilities
use add-on control devices to control emissions from non-food can body assembly coating
operations. Operating parameters for all 13 plants are given in Table 4-7, including information
on annual coating usage, annual organic HAP emissions, and overall control efficiencies.
4-12
-------
Table 4-7. Three-Piece Non-Food Can Body Assembly Plants
Blind
facility ID
11
32
40
42
66
68
103
107
110
145
164
180
183
HAP emissions
(Ibs) after existing
controls
6,040
3,057
1,078
30,288
4,397
10,382
9,965
3,999
2,964
18,894
2,199
4,788
0
HAP emissions
(Ibs) before existing
controls
6,040
3,057
1,078
30,288
4,397
10,382
9,965
3,999
2,964
18,894
2,199
4,788
0
Coating usage
(gal of coating)
1,510
5,647
400
7,752
1,101
2,719
2,681
1,484
1,100
5,536
816
1,506
1,964
Solids usage
(gal of solids)
380
4,168
89
2,109
293
753
765
329
244
1,239
181
486
1,964
Overall
control (%)
0
0
0
0
0
0
0
0
0
0
0
0
0
4.1.7 Model Plant 7—End Lining
End lining operations involve the application of end seal compound onto end pieces. The end
seal compound is applied in a bead around the end piece, and curing takes place under ambient
conditions rather than in a curing oven. Since end seal compounds take a longer period of time
to cure than other coatings, controlling HAP emissions is inefficient. No facilities in the
database use add-on control devices on end lining operations. Operating parameters for all
53 facilities in this subcategory are given in Table 4-8, including information on annual coating
usage, annual organic HAP emissions, and overall control efficiencies.
4-13
-------
Table 4-8. End Lining Operations Plants
Blind
facility ID
2
8
8
11
16
18
21
22
25
32
40
42
47
62
66
67
68
71
80
84
95
96
100
103
107
126
127
134
136
139
143
HAP emissions
(Ibs) after existing
controls
33,930
0
5,821
0
18,963
133,909
0
94,744
6,381
22,594
0
0
7,413
385,762
8,712
0
0
7,037
0
72,071
0
9,202
24,865
0
0
135,930
11,282
13,242
102,833
12,430
97,667
HAP emissions
(Ibs) before existing
controls
33,930
0
5,821
0
18,963
133,909
0
94,744
6,381
22,594
0
0
7,413
385,762
8,712
0
0
7,037
0
72,071
0
9,202
24,865
0
0
135,930
11,282
13,242
102,833
12,430
97,667
Coating usage
(gal of coating)
11,083
42,529
31,498
5,221
43,618
43,477
20,552
503,543
18,990
17,458
19,756
53,602
40,113
124,723
24,454
79,409
26,349
20,942
60,667
70,658
16,412
27,387
74,004
7,227
16,000
51,169
22,385
43,209
38,710
36,994
28,822
Solids usage
(gal of solids)
6,761
23,774
12,221
2,906
20,958
20,130
7,572
213,813
7,368
7,213
11,656
25,251
15,564
57,321
9,354
38,148
14,298
8,125
35,854
32,220
6,046
10,626
28,714
4,148
9,440
23,691
8,685
16,968
17,923
14,354
6,742
Overall
control (%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4-14
-------
Table 4-8. (continued)
Blind
facility ID
145
148
149
151
160
161
164
171
172
175
179
180
185
190
191
192
193
194
197
199
200
204
205
HAP emissions
(Ibs) after existing
controls
4,979
57,994
0
3,870
5,673
30,863
0
2,473
6,486
4,920
144,554
0
143,864
7,625
0
14,380
8,814
2,283
13,500
0
6,939
11,299
7,037
HAP emissions
(Ibs) before existing
controls
4,979
57,994
0
3,870
5,673
30,863
0
2,473
6,486
4,920
144,554
0
143,864
7,625
0
14,380
8,814
2,283
13,500
0
6,939
11,299
7,037
Coating usage
(gal of coating)
42,276
172,600
31,968
20,942
30,700
91,855
1,763
29,442
25,121
20,421
46,933
15,080
74,004
41,263
81,080
42,797
26,233
12,357
40,178
19,826
37,550
61,143
20,942
Solids usage
(gal of solids)
19,500
66,969
23,538
8,125
11,912
35,640
1,040
14,186
11,091
7,907
21,730
9,186
26,567
16,010
33,486
16,605
10,178
4,794
15,589
9,532
14,569
23,723
8,125
Overall
control (%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4-15
-------
4.2 CONTROL OPTIONS
Control options available to the metal can surface coating industry include increased capture and
control, reformulation of coatings, and use of alternate coating types, such as UV-cured or
powder.
4.2.1 Control Options for Two-Piece Draw and Iron Beverage and Food Can
The two-piece draw and iron can coating subcategory uses primarily waterborne coatings to
meet VOC emissions limitations imposed by federal and state regulations. Use of these coatings
has diminished the need for facilities to utilize add-on control devices because a majority of the
facilities meet current VOC emission limits. Reported facility data indicate that the beverage
can segment currently controls 25 percent of its overall organic HAP emissions, with the highest
individual facility control efficiency at 86 percent. The food can segment currently controls
15 percent of its overall organic HAP emissions, with the highest individual facility control
efficiency at 76 percent. Twenty of the 57 two-piece beverage facilities and 5 of 11 food can
facilities use add-on control devices. All of the control devices used at two-piece beverage and
food facilities are thermal or catalytic oxidizers with recuperative or regenerative systems. Table
4-9 and Table 4-10 summarize the control systems for each controlled facility in the two-piece
beverage and food can segments, respectively.
With existing coating technologies and metal can surface coating requirements, the most
significant decrease in organic HAP emissions from these segments could be achieved through
the addition of add-on control systems. The majority of metal can coatings used in these
segments have already been reformulated to contain the minimum amounts of VOC and organic
HAP achievable with current waterborne coating technology and still meet stringent
performance requirements.
4-16
-------
Table 4-9. Summary of Two-Piece Beverage Facility Control Device Characteristics
Blind Facility ID
28
37
48
53
57
63
77
79
105
106
112
123
124
136
147
159
162
163
177
199
No. of Control
Devices
2
1
1
1
1
1
1
1
1
2
1
1
1
2
1
1
1
1
1
1
Oxidizer Type
Thermal
Thermal
Thermal
Thermal
Thermal
Thermal
Thermal
Catalytic
Thermal
Thermal
Catalytic
Thermal
Thermal
Thermal
Thermal
Thermal
Thermal
Thermal
Thermal
Thermal
Recuperative
X
X
X
X
X
Regenerative
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Table 4-10. Summary of Two-Piece Food Facility Control Device Characteristics
Blind Facility ID
71
96
119
148
151
No. of Control
Devices
1
2
1
2
1
Oxidizer Type
Thermal
Thermal
Thermal
Thermal
Thermal
Recuperative
X
X
Regenerative
X
X
X
X
4-17
-------
The use of UV-cured coatings is another possible way to lower organic HAP emissions without
the use of add-on control devices. There are currently 11 facilities using UV-cured coatings for
decorative inks, overvarnish, and rim/bottom coat. There are a number of reasons that the use of
UV-cured coatings is not widespread: the cost associated with retrofitting existing production
lines, the limited number of coatings that meet the manufacturers internal stringent QA/QC
requirements, the involved process of certifying the coating with the FDA, and the process of
convincing customers that the coating meets their specific performance requirements.
4.2.2 Control Options for One-Piece Aerosol Cans
Two facilities are included in the one-piece aerosol can segment, both of which use add-on
controls. One facility uses an adsorption system and the second facility uses a catalytic oxidizer
to control emissions. The average control efficiency for the two facilities is 89.5 percent, with
one achieving 90 percent control efficiency and the other 89 percent. Table 4-11 is a summary
of the control systems for these facilities.
Table 4-11. Summary of One-Piece Aerosol Facility Control Device Characteristics
Blind Facility ID
55
115
No. of Control
Devices
5
2
Oxidizer Type
Adsorber
Catalytic Oxidizer
Recuperative
X
Regenerative
4.2.3 Control Options for Sheetcoating Operations
There are several control options for sheetcoating operations, including increased capture and
control, reformulation, and use of UV and powder coatings. This subcategory currently controls
approximately 74 percent of the organic HAP emissions generated from coatings. There are a
total of 107 control devices at fifty facilities. The number of control devices at controlled
facilities ranges from one to thirteen. All controlled facilities use thermal or catalytic oxidizers,
usually with some type of heat recovery system. Table 4-12 presents a summary of the control
device systems for the sheetcoating subcategory.
4-18
-------
Table 4-12. Summary of Sheetcoating Control Device Characteristics
Blind
Facility ID
7
8
9
16
20
21
22
23
25
36
38
40
41
42
43
56
66
68
97
99
103
107
109
116
122
127
129
132
141
145
148
154
155
157
160
161
No. of Control
Devices
1
2
4
4
1
o
5
2
2
1
1
4
2
13
1
4
3
3
2
4
1
1
1
3
1
1
3
1
1
1
2
2
1
1
1
1
2
Control/Oxidizer Type
Thermal
Thermal
Thermal
Catalytic
Thermal
Thermal
Thermal
Thermal
Thermal
Thermal
Thermal and Catalytic
Thermal
Catalytic
Catalytic
Thermal
Thermal
Thermal and Catalytic
Thermal
Thermal
Catalytic
Thermal
Thermal
Thermal
Thermal
Thermal
Thermal and Catalytic
Thermal
Thermal
Thermal
Catalytic
Thermal
Thermal
Thermal
Thermal
Thermal
Thermal
Recuperative
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Regenerative
X
X
X
X
X
X
X
X
X
4-19
-------
Table 4-12. (continued)
Blind
Facility ID
164
167
172
180
181
183
184
190
193
195
196
200
203
204
No. of Control
Devices
1
2
5
1
1
1
1
1
2
2
4
1
2
2
Control/Oxidizer Type
Thermal
Thermal
Catalytic
Catalytic
Catalytic
Thermal
Thermal
Catalytic
Thermal
Thermal
Catalytic
Thermal
Thermal
Thermal
Recuperative
X
X
X
X
X
X
X
X
Regenerative
X
X
X
X
X
New coating technologies, including UV-cured and powder coatings, could also reduce HAP use
and emissions. Twenty facilities in this subcategory use 28 UV coatings. Table 4-13 is a
summary of the can and coating types for which UV coatings are currently being used.
Table 4-13. Current UV-Cured Coating Uses
Industry Segment
Decorative tin
Three-piece aerosol can
Three-piece food can
Three-piece general line can
Coating Type
Decorative inks
Decorative inks
Overvarnish
Decorative inks
Exterior body base coat
Exterior end base coat
Interior body base coat
Interior end base coat
Decorative inks
Overvarnish
4-20
-------
4.2.4 Control Options for Three-Piece Food and Non-Food Can Assembly
and End Lining
Only one facility in the three-piece food can assembly segment uses add-on controls, and there
are currently no add-on controls in either the three-piece non-food can assembly or end lining
operation segments. The coatings used in this segment include side seam stripe, inside spray,
and end seal compound for both aseptic and non-aseptic applications. Since control options for
these three segments are the same, they are discussed together. The only cost effective option
for these facilities is coating reformulation. The use, formulation, and application methods of
coatings used in these segments makes use of add-on controls for organic HAP emissions
impractical and inefficient.
Side seam stripes cure within a very short period of time after application. Side seam stripe is
applied to the can seam just after it is welded, and the heat from the weld serves to cure it.
Because the equipment used to weld and apply side seam stripe is stationary, the can must be
moving. In order to capture emissions, an enclosure would have to be built around the entire
path the cans travel from the time of application until the coating is fully cured. Capturing and
controlling emissions would be quite expensive because of the low organic HAP concentration
in the airstream. As stated previously, use of powder side seam stripe is an option for lowering
organic HAP emissions for certain applications.
The major organic HAP constituent in end seal compounds is hexane, which is being replaced
with heptane as a way to eliminate organic HAP emissions. This segment of the industry is
currently in the process of integrating reformulated end seal compounds into the manufacturing
process for all non-aseptic applications. The reformulated coating is expected to replace all non-
aseptic end seal compounds within the near future. Some aseptic end seal compounds may also
need to be reformulated in order to meet the MACT limits.
4-21
-------
4.3 ENHANCED MONITORING
4.3.1 Enhanced Monitoring for Two-Piece Beverage and Food Cans and
Sheetcoating Operations
A system must be in place in all facilities to monitor the usage of organic HAP. For facilities
operating control devices, capture and control device performance must be monitored. Organic
HAP levels in coatings must be determined using formulation data of sufficient quality to assure
accurate determination of organic HAP emissions. A Material Safety Data Sheet (MSDS) may
not provide data accurate enough to show compliance with a regulation, but a certified product
data sheet will. For facilities that meet the applicable regulations through the use of compliant
coatings, data must be specific and accurate enough to determine compliance with emission
limits.
Capture equipment must be monitored to allow the determination of capture efficiency. For a
permanent total enclosure (PTE), the pressure drop across the fan or measure of fan current
usage can be an indicator of capture efficiency. For capture equipment that does not meet the
definition of a PTE, an alternate method must be used to determine capture efficiency.
Oxidizer performance must be monitored to ensure the destruction efficiency of the unit. This
must first be determined through compliance testing and later through monitoring of parameters
such as the combustion/oxidation chamber temperature. Additional parameters such as pressure
drop, auxiliary fuel usage, and fan current can be monitored in conjunction with the temperature
to determine control device performance. Oxidizer temperature must be maintained at or above
the temperature used to demonstrate compliance.
Capture and control device parameters can be monitored manually by measuring and recording
pertinent parameter values at required intervals or through the use of continuous recorders such
as strip chart recorders or plant control systems.
4-22
-------
4.3.2 Enhanced Monitoring for Three-Piece Can Assembly and End Lining
Operations
Organic HAP control for these two segments is based on the use of low- or no-HAP coatings.
Monitoring requirements include accurate accounting of organic HAP usage to demonstrate
compliance.
4-23
-------
This page intentionally left blank.
4-24
-------
Chapter 5
Summary of Environmental and Energy Impacts
This chapter discusses primary air, secondary environmental (air, water, and solid waste), and
energy impacts for existing sources resulting from the control of HAP emissions under the
proposed standards for the metal can manufacturing surface coating source category. Potential
impacts are presented for each of the seven model plants which were derived from the
subcategories and industry segments discussed previously :
• Two-piece beverage can body facilities;
• Two-piece food can body facilities;
• One-piece aerosol can body facilities;
• Sheetcoating facilities;
• Three-piece food can body assembly facilities;
• Three-piece non-food can body assembly facilities; and
• End lining facilities.
5.1 BASIS FOR IMPACTS ANALYSIS
This analysis assumes that regenerative thermal oxidizers (RTO) will be used to control organic
HAP emissions to comply with the proposed standards for HAP emissions from two-piece
beverage can body coating, two-piece food can body coating, and sheetcoating operations.
There are only two one-piece aerosol can facilities in the data base, both of which meet the
existing source emission limit. Therefore, no additional controls will be needed in these
facilities to meet the proposed standards. This analysis also assumes that both food and non-
food three-piece can body assembly facilities and both aseptic and non-aseptic end lining
5-1
-------
operations will use reformulated coatings to achieve compliance with the proposed standards.
These assumptions were based on control techniques currently employed by the industry and
practical limitations associated with the surface coating processes involved.
5.2 PRIMARY AIR IMPACTS
Primary air impacts consist of the reduction in organic HAP emissions from the baseline level
that is directly attributable to the proposed standards. The proposed standards are expected to
reduce organic HAP emissions from existing metal can manufacturing facilities by 6,800 tons
per year, or 71 percent, from a baseline level of 9,600 tons per year (ton/yr). A summary of the
primary air impacts associated with implementation of the proposed standards is shown in
Table 5-1.
Table 5-1. Summary of Primary Air Impacts
Emission Source (Subcategory or Industry Segment)
Two-piece beverage can body coatings
Two-piece food can body coatings
One-piece aerosol can body coatings
Sheetcoatings
Three-piece food can assembly coatings:
- inside spray
- aseptic side seam stripe
- nonaseptic side seam stripe
Three-piece non-food can assembly coatings:
- general line side seam stripe
- aerosol side seam stripe
End lining coatings:
- aseptic end seal compounds
- nonaseptic end seal compounds
HAP
Baseline
Emissions
(ton/yr)
4,922
843
18
2,522
408
34
93
281
49
11
39
841
38
803
HAP
Emissions
After
MACT
(ton/yr)
1,881
153
18
436
314
29
92
193
41
9
32
38
38
0
Emission reduction from
baseline
ton/yr
3,111
690
0
2,087
94
5
1
88
8
1
6
803
0
803
Percent
63
82
0
82
23
15
1
31
15
11
17
95
0
100
5-2
-------
Total
9,603
2,811
6,792
71
Tables 5-2 through 5-8 present the primary air impacts resulting from individual facilities and
the overall impact to the seven primary industry categories.
Table 5-2. Two-Piece Beverage Can Segment Impacts
Facility ID
27
28
30
34
37
44
48
53
54
57
58
61
63
65
67
70
72
75
77
78
79
80
82
85
88
89
HAP Baseline
Emissions
(ton/yr)
17.9
53.2
64.9
65.4
59.1
118.4
75.0
127.3
68.3
99.2
156.3
163.9
20.3
81.4
132.6
25.4
152.1
36.6
56.1
233.3
74.1
156.0
113.9
106.1
101.8
71.4
HAP Emissions
After MACT
(ton/yr)
5.8
46.9
20.4
17.6
32.6
48.6
42.9
51.7
31.0
43.6
54.4
42.8
20.3
27.6
26.8
9.3
27.7
8.8
34.1
49.7
53.7
37.9
43.3
53.2
26.1
19.6
Emission reduction from baseline
ton/yr
12.1
6.4
44.5
47.8
26.4
69.8
32.0
75.6
37.3
55.6
102.0
121.1
0.0
53.7
105.8
16.2
124.4
27.8
22.0
183.7
20.5
118.1
70.6
52.9
75.6
51.9
Percent
67.5
11.9
68.6
73.1
44.7
59.0
42.7
59.4
54.6
56.0
65.2
73.9
0.0
66.0
79.8
63.6
81.8
75.9
39.2
78.7
27.6
75.7
62.0
49.9
74.3
72.6
5-3
-------
Table 5-2. (continued)
Facility ID
91
92
101
105
106
108
112
117
118
120
123
124
130
133
135
136
142
144
147
149
150
158
159
162
163
177
178
179
189
198
199
Total
HAP Baseline
Emissions
(ton/yr)
98.0
111.8
137.2
79.7
40.3
99.7
31.8
53.2
98.9
69.3
84.4
33.4
53.8
273.6
96.0
29.9
41.4
71.5
69.7
86.0
104.3
109.5
127.0
104.5
12.0
23.4
86.9
65.0
57.6
78.7
63.5
4,921.8
HAP Emissions
After MACT
(ton/yr)
22.5
27.4
29.2
43.2
31.8
25.4
17.4
20.5
24.6
22.5
34.8
26.8
17.8
62.2
26.0
29.9
10.1
25.6
63.4
21.7
24.3
35.5
62.8
50.5
12.0
23.4
31.1
24.6
17.7
24.8
46.5
1,810.7
Emission reduction from baseline
ton/yr
75.5
84.4
107.9
36.5
8.4
74.2
14.5
32.7
74.3
46.8
49.6
6.7
36.0
211.3
70.0
0.0
31.3
45.9
6.4
64.3
80.1
74.0
64.2
54.0
0.0
0.0
55.8
40.5
39.9
53.9
17.0
3,111.1
Percent
77.0
75.5
78.7
45.8
20.9
74.5
45.5
61.5
75.1
67.5
58.7
20.0
67.0
77.3
73.0
0.0
75.6
64.2
9.2
74.8
76.7
67.6
50.6
51.7
0.0
0.0
64.2
62.2
69.2
68.5
26.7
63.2
5-4
-------
Table 5-3. Two-Piece Food Can Segment Impacts
Facility ID
12
25
67
71
93
96
119
139
148
151
173
Total
HAP Baseline
Emissions
(ton/yr)
32.3
64.7
60.5
6.4
379.2
6.6
145.0
53.2
30.0
6.0
59.4
843.3
HAP Emissions
After MACT
(ton/yr)
12.8
8.3
11.1
6.4
21.7
6.6
25.0
10.6
23.0
6.0
22.5
153.1
Emission reduction from baseline
ton/yr
19.5
56.3
49.4
0.0
357.5
0.0
120.0
42.6
7.0
0.0
36.9
690.2
Percent
60.4
87.1
81.7
0.0
94.3
0.0
82.8
80.0
23.2
0.0
62.2
81.9
Table 5-4. One-Piece Aerosol Can Segment Impacts
Facility ID
115
55
Total
HAP Baseline
Emissions
(ton/yr)
10.3
7.8
18.1
HAP Emissions
After MACT
(ton/yr)
10.3
7.8
18.1
Emission reduction from baseline
ton/yr
0.0
0.0
0.0
Percent
0.0
0.0
0.0
5-5
-------
Table 5-5. Sheetcoating Segment Impacts
Facility ID
7
8
9
11
16
19
20
21
22
23
25
32
36
38
40
41
42
43
52
56
66
68
71
95
96
97
99
103
107
109
116
122
127
HAP Baseline
Emissions
(ton/yr)
11.8
10.4
15.5
0.0
53.4
257.7
123.5
11.8
26.0
46.0
56.9
77.4
19.1
123.0
7.8
140.9
68.2
6.7
0.1
5.4
88.1
41.4
11.9
74.7
192.9
15.7
7.7
23.4
9.2
31.4
10.6
14.7
33.8
HAP Emissions
After MACT
(ton/yr)
11.8
9.1
6.7
0.0
10.6
13.4
10.8
6.8
13.1
14.0
4.4
7.5
6.0
18.0
4.8
9.2
11.6
6.7
0.1
5.3
11.1
7.4
3.5
3.4
3.7
1.9
2.1
3.5
3.3
9.5
10.6
9.4
6.0
Emission reduction from baseline
ton/yr
0.0
1.3
8.8
0.0
42.8
244.3
112.7
5.1
12.9
31.9
52.5
69.9
13.0
104.9
3.0
131.7
56.6
0.0
0.0
0.1
77.0
34.0
8.4
71.3
189.2
13.8
5.6
19.9
6.0
21.9
0.0
5.3
27.8
Percent
0.0
12.5
56.8
0.0
80.2
94.8
91.3
43.2
49.6
69.3
92.3
90.3
68.1
85.3
38.5
93.5
83.0
0.0
0.0
1.9
87.4
82.1
70.6
95.4
98.1
87.9
72.7
85.0
65.2
69.7
0.0
36.1
82.2
5-6
-------
Table 5-5. (continued)
Facility ID
129
132
141
145
148
151
154
155
157
160
161
164
167
172
180
181
183
184
190
193
195
196
200
201
203
204
205
Total
HAP Baseline
Emissions
(ton/yr)
34.4
18.1
145.7
33.2
13.1
14.1
50.5
7.0
13.7
10.0
45.3
63.8
34.8
19.3
11.6
12.1
9.7
42.3
73.5
51.5
35.5
35.6
47.4
0.0
12.2
54.1
16.4
2,522.0
HAP Emissions
After MACT
(ton/yr)
5.2
4.7
13.7
6.3
13.1
3.4
10.2
5.5
3.7
6.5
2.8
5.2
32.3
2.1
3.1
3.2
9.7
6.5
15.3
10.9
5.6
2.1
8.0
0.0
3.5
5.6
2.0
435.5
Emission reduction from baseline
ton/yr
29.2
13.4
132.0
26.9
0.0
10.7
40.2
1.5
10.1
3.5
42.5
58.7
2.5
17.2
8.5
8.8
0.0
35.9
58.1
40.7
30.0
33.5
39.4
0.0
8.6
48.5
14.4
2,086.5
Percent
84.9
74.0
90.6
81.0
0.0
75.9
79.6
21.4
73.7
35.0
93.8
92.0
7.2
89.1
73.3
72.7
0.0
84.9
79.0
79.0
84.5
94.1
83.1
??
70.5
89.6
87.8
82.7
5-7
-------
Table 5-6. Food Can Assembly Segment Impacts
Facility ID
8
16
26
47
59
71
83
107
121
127
134
137
143
145
148
151
157
160
161
165
167
190
192
194
195
200
202
204
205
206
Total
HAP Baseline
Emissions
(ton/yr)
2.8
11.8
4.0
13.4
33.5
3.2
32.3
0.8
2.1
4.5
15.3
4.5
3.9
0.1
99.6
3.2
4.2
14.8
2.6
11.5
5.3
19.3
18.5
12.3
11.6
11.5
8.6
9.4
29.0
14.0
407.8
HAP Emissions
After MACT
(ton/yr)
2.8
11.2
4.0
8.9
29.4
2.8
15.6
0.6
1.0
3.6
9.1
2.2
1.1
0.1
61.9
2.8
4.2
13.9
2.2
11.5
5.3
14.3
18.5
9.2
11.6
9.6
8.4
8.9
26.9
12.5
313.9
Emission reduction from baseline
ton/yr
0.0
0.6
0.0
4.4
4.2
0.3
16.8
0.2
1.1
1.0
6.2
2.4
2.9
0.0
37.8
0.4
0.0
0.9
0.4
0.0
0.0
5.0
0.0
3.1
0.1
1.9
0.2
0.5
2.1
1.5
93.9
Percent
0.0
5.2
0.0
33.2
12.4
10.5
51.8
23.3
51.8
21.4
40.5
52.0
72.6
7.4
37.9
12.1
0.0
6.4
15.8
0.0
0.0
25.8
0.0
25.1
0.6
16.3
2.6
5.7
7.4
10.7
23.0
Table 5-7. Non-Food Can Assembly Segment Impacts
5-8
-------
Facility ID
11
32
40.0
42.0
66
68
103
107
110
145
164
180
183
Total
HAP Baseline
Emissions
(ton/yr)
3.0
1.5
0.5
15.1
2.2
5.2
5.0
2.0
1.5
9.4
1.1
2.4
0.0
49.0
HAP Emissions
After MACT
(ton/yr)
1.9
1.5
0.5
12.5
1.8
4.4
4.3
2.0
1.5
7.5
1.1
2.4
0.0
41.4
Emission reduction from baseline
ton/yr
1.2
0.0
0.0
2.6
0.4
0.8
0.7
0.0
0.0
1.9
0.0
0.0
0.0
7.6
Percent
38.1
0.0
0.0
17.5
19.2
15.7
13.6
0.0
0.0
20.4
0.0
0.0
0.0
15.5
Table 5-8. End Lining Segment Impacts
Facility ID
2
8
11
16
18
21
22
25
32
40
42
47
62
66
67
HAP Baseline
Emissions
(ton/yr)
17.0
2.9
0.0
9.5
67.0
0.0
47.4
3.2
11.3
0.0
0.0
3.7
192.9
4.4
0.0
HAP Emissions
After MACT
(ton/yr)
0.0
2.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3.7
0.0
2.2
0.0
Emission reduction from baseline
ton/yr
17.0
0.0
0.0
9.5
67.0
0.0
47.4
3.2
11.3
0.0
0.0
0.0
192.9
2.2
0.0
Percent
100.0
0.0
0.0
100.0
100.0
0.0
100.0
100.0
100.0
0.0
0.0
0.0
100.0
50.5
0.0
5-9
-------
Table 5-8. (continued)
Facility ID
68
71
80
84
95
96
100
103
107
126
127
134
136
139
143
145
148
149
151
160
161
164
171
172
175
179
180
185
190
191
192
193
194
HAP Baseline
Emissions
(ton/yr)
0.0
3.5
0.0
36.0
0.0
4.6
12.4
0.0
0.0
68.0
5.6
6.6
51.4
6.2
48.8
2.5
29.0
0.0
1.9
2.8
15.4
0.0
1.2
3.2
2.5
72.3
0.0
71.9
3.8
0.0
7.2
4.4
1.1
HAP Emissions
After MACT
(ton/yr)
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3.7
0.0
0.0
0.0
2.5
0.0
0.0
1.9
2.8
0.0
0.0
1.2
1.5
1.8
0.0
0.0
0.0
3.8
0.0
0.0
0.0
1.1
Emission reduction from baseline
ton/yr
0.0
3.5
0.0
36.0
0.0
4.6
12.4
0.0
0.0
68.0
5.6
2.9
51.4
6.2
48.8
0.0
29.0
0.0
0.0
0.0
15.4
0.0
0.0
1.7
0.6
72.3
0.0
71.9
0.0
0.0
7.2
4.4
0.0
Percent
0.0
100.0
0.0
100.0
0.0
100.0
100.0
0.0
0.0
100.0
100.0
43.4
100.0
100.0
100.0
0.0
100.0
0.0
0.0
0.0
100.0
0.0
0.0
53.8
25.4
100.0
0.0
100.0
0.0
0.0
100.0
100.0
0.0
5-10
-------
Table 5-8. (continued)
Facility ID
197
199
200
204
205
Total
HAP Baseline
Emissions
(ton/yr)
6.7
0.0
3.5
5.6
3.5
841.1
HAP Emissions
After MACT
(ton/yr)
0.0
0.0
3.5
5.6
0.0
38.4
Emission reduction from baseline
ton/yr
6.7
0.0
0.0
0.0
3.5
802.7
Percent
100.0
0.0
0.0
0.0
100.0
95.4
5.3 SECONDARY ENVIRONMENTAL IMPACTS
Secondary environmental impacts include any adverse or beneficial environmental impacts other
than the primary impacts described in Section 5.2. Secondary impacts include impacts that result
from the operation of any new or additional add-on HAP control systems. To comply with the
proposed standard, it is anticipated that metal can manufacturing surface coating facilities in the
one- and two-piece draw and iron beverage and food can and sheetcoating subcategories will use
regenerative thermal oxidizer control systems that result in secondary air impacts. Secondary
water and solid waste impacts for these subcategories are expected to be minimal.
Secondary impacts for the three-piece can body assembly and end lining coating subcategories
are expected to be negligible. It is anticipated that can assembly facilities and end lining
operations will use reformulated coatings to comply with the proposed standard. Use of
reformulated coatings will not have any secondary environmental impacts. It is anticipated that
the reformulated coating organic HAP constituents will be replaced with other VOC.
5.3.1 Secondary Air Impacts
Secondary air impacts consist of generation of byproducts from fuel combustion needed to
operate control devices and reduction of VOC. Fuel combustion is necessary to maintain
operating temperatures in regenerative thermal oxidizers (RTOs). Byproducts of fuel
combustion include emission of carbon monoxide (CO), nitrogen oxides (NOX), sulfur dioxide
(SO2), and particulate matter less than 10 microns in diameter (PM10).
5-11
-------
Regenerative thermal oxidizers use natural gas as the auxiliary fuel. Estimated natural gas
consumption rates are described in Section 5.4. Emissions from combustion in the RTOs were
estimated using AP-42 emission factors for large uncontrolled industrial boilers.
Electricity for the operation of RTOs and associated auxiliary equipment was assumed to be
generated at coal-fired utility plants built since 1978. Estimated electricity requirements and the
fuel energy needed to generate this electricity are described in Section 5.4. Utility plants built
since 1978 are subject to the new source performance standards (NSPS) in subpart Da of
40 CFR 60.l Emissions of CO, NOX, SO2, and PM10 were calculated using AP-42 emission
factors.2 The sulfur content of the coal was assumed to be 3.4 percent. A summary of the
estimated impacts for each of the four secondary air emission source types is presented in
Table 5-9.
In addition to the generation of by-product emissions from fuel combustion, secondary air
impacts include the reduction of VOC emissions. Volatile organic compounds are precursors to
ozone. Both non-HAP VOC and organic HAP VOC are reduced by implementation of the
standards, but the amount of VOC reduction achieved by the standard has not been estimated.
Therefore, the secondary air impact of reduced VOC emissions cannot be quantified.
Table 5-9. Summary of Secondary Air Impacts
Total
Increased emissions, ton/yr
C0a
35.18
N0xb
144.67
S02C
774.08
PM10d
69.61
a CO emissions were estimated using AP-42 emission factors of 5 Ib CO/ton of coal and 84 Ib CO/10 ft of natural
gas.3
b NOX emissions were estimated using AP-42 emission factors of 11 Ib NOX/ ton of coal and 190 Ib NOX/106 ft3 of
natural gas.3
0 SO2 emissions were estimated using AP-42 emission factors of 68.4 Ib SO2/ton of coal and 0.6 Ib SO2/106 ft3 of
natural gas.3
d PM10 emissions were estimated using AP-42 emission factors of 13.2 Ib PM10/ton of coal and 1.9 Ib PM10/106 ft3 of
natural gas.3
5.3.2 Secondary Water Impacts
No secondary water impacts are expected.
5-12
-------
5.3.3 Secondary Solid Waste Impacts
Solid waste impacts are expected to be minimal. Since the pollutants produced from the
implementation of controls (RTOs or reformulation) are expected to consist primarily of
volatilized solvents (i.e., organic HAP and VOC), very little particulate matter or solid waste
will be generated.
5.4 ENERGY IMPACTS
Energy impacts consist of the electricity and fuel needed to operate the RTOs used to comply
with the proposed standards. The estimated electricity and fuel impacts for each of the three
subcategories using RTOs are presented in Table 5-10. In each case the impacts are based on the
total amount of electricity and fuel needed to operate the control device; any additional
electricity and fuel needs for existing controls are assumed to be negligible. The electricity and
fuel impacts are discussed in the sections below. No energy impacts are associated with the
reformulation of coatings.
Table 5-10. Summary of Energy Impacts
Subcategory or segment
Two-piece beverage can body
Two-piece food can body
Sheetcoating
Total
Increase in electricity
consumption, kwh/yr
2.85e+07
3.81e+06
2.09e+06
3.44e+07
Increase in fuel energy, Btu/yr
To generate
electricity
2.78e+ll
3.72e+10
2.04e+10
3.35e+ll
Auxiliary fuel
for RTOs
5.57e+ll
7.44e+10
4.08e+10
6.72e+ll
Total
8.356+11
1.12e+ll
6.12e+10
l.Ole+12
5.4.1 Electricity
Electricity would be needed to operate RTOs used to control emissions for the two-piece
beverage can, two-piece food can, and sheetcoating segments. Specifically, electricity would be
needed to operate the RTOs' fans and electronics. As noted above, electricity was assumed to be
generated in coal-fired utility plants. The amount of fuel energy required to generate the
electricity was estimated using a heating value of 14,000 Btu/lb of coal4 and a power plant
efficiency of 35 percent. The amount of electricity required to operate the RTOs was determined
5-13
-------
using the total annual cost spreadsheet program.5 The spreadsheet calculates the amount of
electricity using the airflow of each RTO.
5.4.2 Fuel
In addition to electricity, fuel would be required to operate the RTOs. The amount of natural gas
needed to operate the RTOs was determined by using the total annual cost spreadsheet program.5
The spreadsheet calculates the amount of natural gas required using the airflow of each RTO. If
a facility provided the amount of natural gas in the metal can information collection request
(ICR) response, then that amount was used. A RTO retention chamber temperature of 1425°F
(774°C) was used for cost calculations. Additional details on the procedure used to calculate
fuel requirements are described in the OAQPS Control Cost Manual.6
5.5 References
1. 40CFRPart60. SubpartDa.
2. AP-42. 1995 Edition. Section 1.1.
3. AP-42. 1995 Edition, p. 1.1-18 thru 21 and 1.4-5 thru 1.4-6.
4. AP-42. 1995 Edition, p. 1.1-1.
5. Vatavuk, William M. Estimating Costs of Air Pollution Control. Boca Raton, FL. Lewis
Publishers, 1990.
6. OAQPS Control Cost Manual. Fourth Edition. EPA 450/3-90-006. January 1990. Chapter
3.
5-14
-------
Chapter 6
Model Plant Control Costs
6.0 INTRODUCTION
Model plants and their associated control options were described in Chapter 4. Since the project
database contains information from essentially all known affected sources, the model plants and
estimated control costs are representative of the actual sources comprising each industry segment
or subcategory. This chapter describes the estimated costs of applying the control options to all
sources in each of the seven primary model plant categories.
There are 150 MACT floor facilities in the database, including eight synthetic minor sources,
based on their status as a title V permitted source. Although used in determining the MACT
floor limits for the applicable model plant categories, the eight synthetic minor source facilities
were not assigned any costs since they will not have to comply with any of the NESHAP
requirements.
Section 6.1 discusses assumptions that were made in calculating costs associated with the metal
can surface coating NESHAP. The control scenarios evaluated are described, and the inputs
used for the costing analysis are discussed. Results of the costing analysis are presented in
Section 6.2, both by the seven types of model plants and for the metal can surface coating
industry overall. The cost effectiveness of add-on controls is presented in Section 6.3.
Section 6.4 describes the cost impact to small businesses, and references are provided in
Section 6.5.
6-1
-------
6.1 ASSUMPTIONS
This section describes the assumptions that were made in the costing analysis. The assumptions
are divided into sections associated with add-on control devices; monitoring, recordkeeping and
reporting; and material reformulation.
6.1.1 Capital Equipment Costs
Calculation of capital equipment costs is based on the assumption that all sources in the two-
piece beverage, two-piece food, and sheetcoating industry segments will be required to install
new control equipment including capture devices/hoods, regenerative thermal oxidizers (RTOs),
and associated ductwork. It was assumed that new control equipment would be installed at all
sources with HAP emissions greater than the proposed HAP emission limit for the applicable
model plant category or segment, regardless of whether the source currently uses control
equipment. Thus, at a source with control equipment it was assumed that the old control
equipment would be removed, and the new control equipment would be used to control total
airflow from coating operations and associated HAP emissions. Because some sources may, in
reality, be able to retain and/or modify existing controls and only add new controls for a portion
of the air stream to achieve the required overall emissions reductions, this assumption may result
in an overestimation of actual costs.
For the few sources that have existing organic HAP emission levels within 10 percent of the
applicable organic HAP emission limit, it was assumed that those sources would only have to
improve or enhance their current capture efficiency to demonstrate compliance. Using the
proposed limits, three sources (one two-piece beverage can source and two sheetcoating sources)
were identified that met the criteria for needing only capture device enhancements. The capital
equipment costs for capture and ductwork modifications for each of these three sources were
estimated to be $400,000. This results in an annualized cost of $97,550 per source based on an
estimated equipment life of 10 years and an interest rate of 7 percent.
There are only two affected major source one-piece aerosol can sources, so the MACT floor is
set by the higher HAP emission rate. Therefore, both sources are expected to meet the organic
6-2
-------
HAP emission limit without added material costs or capital equipment. All other model plant
categories are assumed to use reformulated coatings to limit surface coating HAP emissions and
comply with the proposed MACT limits. These model plant categories are largely uncontrolled,
and the organic HAP emission limits can be met by reformulation.
Inputs for the add-on control analysis were developed primarily from the MACT database.
Equations from the EPA cost manual were then used to develop capital equipment and
operation/maintenance costs for each source.1>2 Capital equipment costs reflect a single RTO
being purchased to reduce HAP emissions to comply with the applicable emission source limit.
To calculate the capital costs, the solvent loading and total air flow of the RTO had to be
estimated. The total amount of air flow that will be routed to the RTO determines the size of the
RTO and, thus, the cost of installing and maintaining it. Most sources with add-on control
equipment included gas flows as part of the information collection request (ICR) submittal.
Using data from these sources, a correlation was made between gas flow in standard cubic feet
per minute (scfm) and total gallons of coating used at the facility. This correlation was not valid
for the entire range of reported coating usage, so gas flows were grouped by divisions in the data
and averaged. These divisions are shown in Table 6-1.
Using a combination of ICR information and the information in Table 6-1, each facility in the
two-piece beverage, two-piece food, and sheetcoating model plant categories was analyzed. If
the facility was previously uncontrolled or submitted no air flow information, a total air flow was
assigned according to the total coating usage at the facility. This air flow was used as an input
for equations from the EPA cost manual to develop capital equipment costs for each facility.1
The capital equipment costs include purchase, installation, and operation of an RTO and
installation costs of $200,000 for a permanent total enclosure. Both costs are annualized based
on an equipment life of 10 years and an interest rate of 7 percent.
6-3
-------
Table 6-1. Correlation Between Coating Usage and RTO Air Flows
Total coating usage (gallons)
0-200,000
200,001-650,000
>650,000
Total air flow (scfm)
20,000
22,000
25,000
The control device inlet temperature was based on an average of database sources. The waste
gas heating value was estimated at 0.1 BTU/standard cubic foot (scf) and was used in calculating
the amount of auxiliary fuel required to operate the thermal oxidizer. Since the actual waste gas
heating value is likely to be higher, this conservatively estimates the amount of auxiliary fuel
required. It was assumed that a new RTO would have 95 percent heat recovery. Other
assumptions for capital equipment costing include a 10-year equipment life cycle and 7 percent
interest rate, resulting in a cost recovery factor of 0.1424.3 Labor required to operate the thermal
oxidizer was estimated based on the EPA Cost Manual, and the labor rate for this industry was
obtained from the Bureau of Labor Statistics.4 Natural gas and electricity unit costs were
estimated based on information obtained from the U.S. Department of Energy web sites.5'6
6.1.2 Monitoring, Recordkeeping, and Reporting Costs
Since monitoring, recordkeeping, and reporting (MR&R) will be done on a continuous basis
after the compliance date, the associated costs are considered annual costs. Based on the
proposed NESHAP requirements for compliance training of all staff involved with coating
operations, daily coating records, monthly record compilation, and semi-annual reporting, an
average metal can surface coating facility will spend an estimated 1,193 labor hours per year
(914 technical, 9 management, and 270 clerical) to implement the proposed MR&R
requirements.3 The total technical labor hours include the tasks conducted by a "coating,
painting and spraying machine operator" which total 729 hours annually. These tasks include
tracking the coating usage on each coating line, periodic checking of the monitoring equipment,
annual calibration of the monitoring equipment, and maintenance of the monitoring equipment.
Using recent labor rates for the metal can industry (based on SIC group 341) from the Bureau of
Labor and Statistics, the fully burdened labor rates are $73.35/hr for technical (e.g., engineer),
$30.26 for a coating process operator, $83.58/hr for management, and $27.93/hr for clerical
6-4
-------
personnel.4 Multiplying the labor rates by the estimated hours for MR&R results in an average
annual MR&R cost of $52,700 per facility. This total cost includes computer equipment costs,
performance testing costs, monitoring equipment costs, and operation and maintenance costs
which are discussed in more detail in the following sections.
6.1.2.1 Computer Equipment Costs
Recordkeeping and reporting costs assume the use of a computer and software for tracking
coating usage at each facility. An assumed cost of $2,000 for computer equipment, including
spreadsheet software, was used. Facilities using more than 100,000 gallons of coatings per year
were excluded based on an assumption that computer equipment is readily available at such large
facilities. Of the 142 major source facilities, an estimated 35 facilities will require computer
equipment. Assuming that a new computer will be bought every 5 years and using a 7 percent
interest rate, the capital recovery factor is 0.2439. Multiplying the capital investment cost of
$2,000 by the capital recovery factor yields an annualized computer equipment cost of $488 for
each of the 35 facilities required to purchase computers.
6.1.2.2 Performance Testing Costs
Any major source purchasing and installing new capture and control equipment to comply with
the NESHAP will also have to conduct performance testing. Performance testing on an RTO
was estimated to require 160 hours per air pollution control device (APCD). Testing of the
associated capture device(s) or enclosure(s) using method 204 was estimated to require 80 hours
per device, for a total of 240 hours per APCD. Contract labor was estimated at $80 per hour for
conducting the performance testing, resulting in a total cost estimate of $19,200 per APCD
(240 hours x $80/hr). Since performance testing is expected to occur once with each title V
permit renewal and renewals typically occur once every 5 years, performance testing costs are
annualized using a 5-year life cycle and 7 percent interest rate, giving a cost recovery factor of
0.2439. This results in an annualized cost of $4,683 per control device.
6-5
-------
6.1.2.3 Monitoring Equipment Costs
Any major source purchasing and installing new capture and control equipment to comply with
the NESHAP is also required to purchase and install monitoring equipment. We assumed that
continuous parameter monitoring of the RTO combustion temperature would be used to meet the
monitoring requirement of the standard. The cost of a data acquisition system was estimated to
be $4,000. This includes $3,000 for a data logger and $1,000 for software and necessary
accessories (including thermocouples, electrical wiring, etc.).7 We also estimated a 10-year
equipment life cycle for the monitoring equipment and 7 percent interest rate, resulting in a cost
recovery factor of 0.1424.3 Since we estimate that 122 of the 142 major source facilities will
require monitoring equipment, the total annualized cost per source is approximately $570 per
year.
6.1.2.4 Operation and Maintenance Costs
Operation and maintenance include the costs associated with the paperwork requirement
incurred continuously over the life of the ICR. For rules that require respondents to submit
notifications and reports to EPA and maintain records these costs are estimated for photocopying
and postage. Photocopying costs per response were estimated at 0.5 hour of clerical labor at a
wage rate of $27.93/hr. First class postage was estimated at $7.63 per response for mailing to
regulatory agencies. Photocopying and postage costs will be applied to the semi-annual reports
that are required for compliance. There will be a total of 284 responses per year from the 142
sources. This equals 142 clerical labor hours and a total annual burden of $5,991.
6.1.3 Material Costs
It was assumed that facilities in model plant categories that are expected to use add-on control
devices to limit HAP emissions from coating operations will not change to lower HAP coatings.
Facilities in the two-piece beverage can, two-piece food can, and sheetcoating segments were
assumed to purchase and install a new RTO rather than incur material costs. The only
exceptions are facilities with reported organic HAP emission rates that are less than 10 percent
above the organic HAP emission rate for these coating type segments. In these three cases, it
was assumed that the source could meet the limit by improving existing capture equipment at an
6-6
-------
annualized cost of $98,000. All other model plant categories, except for one-piece aerosol can
facilities, are assumed to reformulate coatings to limit surface coating HAP emissions.
Since reformulation costs vary in different coating type segments, industry representatives and
trade associations were consulted for accurate cost ranges. Since some of the specific material
cost ranges received from industry are considered confidential business information (CBI), an
average cost was estimated for each coating type segment. The coating usage of each source was
analyzed to estimate the amount of high HAP-containing coatings used by the facility in the
baseline year of 1997. A high HAP-containing coating is defined as a coating with an organic
HAP content per volume of solids (Ib HAP/gal solids) greater than the MACT floor limit for the
coating type segment. Costs were calculated by assuming that each source will use the same
amount of coatings that were consumed in the baseline year of 1997 and that there will be a
higher cost per gallon for low- or no-HAP coatings than for high HAP-content coatings. The
cost increase was assumed to be $2.00 per gallon for inside sprays, $5.00 per gallon for side
seam stripes, and $2.00 per gallon for non-aseptic end seal compounds. These incremental costs
are the estimated additional material costs that each facility will incur, rather than total material
costs.
If a source had an organic HAP emission rate less than or equal to the proposed organic HAP
emission limit for a coating type segment, no additional material costs were assigned to the
source. If a source had an organic HAP emission rate higher than the proposed organic HAP
emission rate for a coating type segment, material costs at the per gallon rate for the coating type
were used.
6.2 OVERALL COSTS
This section presents results of the add-on control costing analysis. Results for individual
industry segments are presented first, followed by overall industry total annual cost (TAG)
estimates.
6.2.1 Estimated Costs for Industry Segments
6-7
-------
This section contains a summary table for each model plant showing the blind facility
identification, whether the facility is a MACT floor facility, a synthetic minor source, or a small
business, and the number of existing APCDs at the source. Remaining columns show the
various costs expected to be incurred by that source to comply with the metal can surface coating
NESHAP.
6.2.1.1 Two-Piece Beverage Can Sources (Model Plant 1)
Estimated costs for two-piece beverage can sources (Model Plant 1) are shown in Table 6-2.
There are 57 affected major sources with annualized costs of $19.3 million for capital equipment
and $2.8 million for MR&R. These costs total $22.1 million per year.
6.2.1.2 Two-Piece Food Can Sources (Model Plant 2)
Estimated costs for two-piece food can sources (Model Plant 2) are given in Table 6-3. There
are 11 affected major sources with annualized costs of $2.8 million for capital equipment, and
$327,000 for MR&R. These costs total $3.1 million per year.
6.2.1.3 One-Piece Aerosol Can Sources (Model Plant 3)
Estimated costs for one-piece aerosol can sources (Model Plant 3) are shown in Table 6-4. Since
there are only two affected major sources in this segment, the MACT floor is set by the higher
HAP emission rate. Therefore, both facilities are expected to meet the organic HAP emission
limit without added material costs or capital equipment. The two facilities combined have
annualized costs of $105,000 for MR&R.
6.2.1.4 Sheetcoating Sources (Model Plant 4)
Estimated costs for sheetcoating sources (Model Plant 4) are presented in Table 6-5. There are
60 affected sources (56 major sources and 4 synthetic minor sources). These sources have
annualized costs of $22.8 million for capital equipment and $1.9 million for MR&R. These
costs total $24.7 million per year.
6.2.1.5 Three-Piece Food Can Assembly Sources (Model Plant 5)
6-8
-------
Estimated costs for three-piece food can assembly sources (Model Plant 5) are given in Table 6-
6. There are 27 major sources and 3 synthetic minor sources. These sources have annualized
costs of $1.0 million for material and $743,000 for MR&R. These costs total $1.8 million per
year.
6.2.1.6 Three-Piece Nonfood Can Assembly Sources (Model Plant 6)
Estimated costs for three-piece nonfood can assembly sources (Model Plant 6) are presented in
Table 6-7. There are 13 affected sources (11 major sources and 2 synthetic minors). These
sources have annualized costs of $70,000 for material and $186,000 for recordkeeping and
reporting. These costs total $256,000 per year.
6.2.1.7 End Lining Sources (Model Plant 7)
Estimated costs for end lining sources (Model Plant 7) are shown in Table 6-8. There are 54
affected sources (49 major sources and 5 synthetic minors). These sources have annualized costs
of $2.9 million for material and $1.3 million for MR&R. These costs total $4.2 million per year.
6.2.2 Overall Total Annual Cost
The total annual cost is the sum of annualized material costs, annualized computer costs,
annualized performance testing costs, annualized capital equipment costs, and annual
recordkeeping and reporting costs for all affected sources. The total annual cost for the metal
can surface coating NESHAP for the 142 affected major sources is estimated to be $56.2 million.
A summary of the total annual costs associated with implementation of the metal can surface
coating NESHAP is provided in Table 6-9.
6-9
-------
Table 6-2. Two-Piece Beverage Can Sources (Model Plant 1) Costs
Blind
FACID
89
65
48
130
112
118
144
108
101
58
117
106
37
163
158
30
70
80
78
67
162
159
123
72
44
189
Floor Facility
Yes
Synthetic Minor
Small Business
Number of
APCDs
1
1
2
1
1
1
1
1
Annual Material
Costs
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Annualized
Capital Costs
$360,074
$360,074
$738,922
$360,074
$285,739
$360,074
$360,074
$360,074
$360,074
$387,340
$360,074
$440,603
$330,613
$0
$360,074
$360,074
$341,897
$387,340
$387,340
$193,670
$407,242
$334,679
$360,074
$360,074
$360,074
$360,074
Annual MR&R
Costs
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$26,350
$52,700
$17,567
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
Total Annual
Costs
$412,774
$412,774
$791,622
$412,774
$338,439
$412,774
$412,774
$412,774
$412,774
$440,040
$412,774
$493,303
$383,313
$52,700
$412,774
$412,774
$394,597
$413,690
$440,040
$211,237
$459,942
$387,379
$412,774
$412,774
$412,774
$412,774
-------
Table 6-2. (continued)
Blind
FACID
136
124
28
88
54
27
178
63
92
179
85
53
61
79
198
133
82
57
147
105
135
150
77
91
177
120
Floor Facility
Yes
Yes
Yes
Yes
Yes
Yes
Synthetic Minor
Small Business
Number of
APCDs
2
1
2
1
1
1
1
1
1
1
1
Annual Material
Costs
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Annualized
Capital Costs
$0
$296,040
$382,531
$360,074
$360,074
$341,897
$360,074
$0
$360,074
$360,074
$387,340
$466,936
$360,074
$285,594
$360,074
$387,340
$360,074
$439,170
$97,556
$405,080
$360,074
$360,074
$391,798
$360,074
$0
$360,074
Annual MR&R
Costs
$26,350
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$26,350
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
Total Annual
Costs
$26,350
$348,740
$435,231
$412,774
$412,774
$394,597
$412,774
$52,700
$412,774
$386,424
$440,040
$519,636
$412,774
$338,294
$412,774
$440,040
$412,774
$491,870
$150,256
$457,780
$412,774
$412,774
$444,498
$412,774
$52,700
$412,774
-------
Table 6-2. (continued)
Blind
FACID
34
149
199
142
75
Totals
Floor Facility
7
Synthetic Minor
0
Small Business
0
Number of
APCDs
1
23
Annual Material
Costs
$0
$0
$0
$0
$0
0
Annualized
Capital Costs
$360,074
$360,074
$405,080
$341,897
$341,897
$19,287,617
Annual MR&R
Costs
$52,700
$26,350
$26,350
$52,700
$52,700
$2,837,017
Total Annual
Costs
$412,774
$386,424
$431,430
$394,597
$394,597
$22,124,630
to
-------
Table 6-3. Two-Piece Food Can Sources (Model Plant 2) Costs
Blind
FACID
67
12
173
139
25
93
148
71
151
119
96
Totals
Floor Facility
Yes
Yes
Yes
Yes
Yes
5
Synthetic Minor
0
Small Business
0
Number of
APCDs
1
1
1
2
1
6
Annual Material
Costs
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Annualized
Capital Costs
$193,670
$360,074
$360,074
$360,074
$130,929
$360,074
$352,071
$0
$0
$644,086
$0
$2,761,052
Annual MR&R
Costs
$17,567
$52,700
$52,700
$26,350
$17,567
$52,700
$10,540
$13,175
$13,175
$52,700
$17,567
$326,741
Total Annual
Costs
$211,237
$412,774
$412,774
$386,424
$148,496
$412,774
$362,611
$13,175
$13,175
$696,786
$17,567
$3,087,793
Table 6-4. One-Piece Aerosol Sources (Model Plant 3) Control Costs
Blind
FACID
115
55
Totals
Floor Facility
Yes
Yes
2
Synthetic Minor
0
Small Business
Yes
1
Number of
APCDs
2
12
14
Annual Material
Costs
$0
$0
$0
Annualized
Capital Costs
$0
$0
$0
Annual MR&R
Costs
$52,700
$52,700
$105,400
Total Annual
Costs
$52,700
$52,700
$105,400
-------
Table 6-5. Sheetcoating Sources (Model Plant 4) Control Costs
Blind
FACID
190
22
32
66
183
43
16
200
56
164
145
122
204
107
172
132
36
40
52
8
20
127
21
23
203
97
Floor Facility
Yes
Yes
Yes
Synthetic Minor
Yes
Yes
Small Business
Yes
Number of
APCDs
1
2
1
3
1
3
1
1
3
1
2
1
2
1
2
1
1
2
2
1
3
3
2
2
4
Annual Material
Costs
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Annualized
Capital Costs
$316,847
$689,944
$220,948
$351,586
$0
$0
$0
$283,685
$97,556
$271,329
$602,431
$333,108
$283,685
$407,242
$571,264
$307,161
$252,795
$250,744
$0
$252,795
$314,574
$326,930
$617,501
$602,473
$677,250
$476,988
Annual MR&R
Costs
$17,567
$26,350
$17,567
$13,175
$26,350
$52,700
$0
$13,175
$52,700
$17,567
$10,540
$52,700
$13,175
$13,175
$17,567
$52,700
$52,700
$17,567
$0
$13,175
$52,700
$17,567
$26,350
$52,700
$52,700
$52,700
Total Annual
Costs
$334,414
$716,294
$238,515
$364,761
$26,350
$52,700
$0
$296,860
$150,256
$288,896
$612,971
$385,808
$296,860
$420,417
$588,831
$359,861
$305,495
$268,311
$0
$265,970
$367,274
$344,497
$643,851
$655,173
$729,950
$529,688
-------
Table 6-5. (continued)
Blind
FACID
201
160
167
129
205
161
157
95
184
25
195
193
148
71
151
9
196
96
7
68
19
99
11
103
181
42
Floor Facility
Yes
Yes
Synthetic Minor
Yes
Yes
Small Business
Yes
Number of
APCDs
1
2
1
2
1
1
1
1
2
2
1
4
4
1
2
1
1
1
1
Annual Material
Costs
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Annualized
Capital Costs
$0
$341,897
$97,556
$406,505
$341,897
$333,108
$641,700
$286,825
$299,112
$130,929
$325,815
$362,841
$0
$261,859
$261,859
$1,668,097
$666,836
$632,445
$0
$670,553
$360,074
$270,131
$0
$0
$500,735
$514,615
Annual MR&R
Costs
$52,700
$13,175
$26,350
$52,700
$17,567
$17,567
$26,350
$26,350
$52,700
$17,567
$17,567
$26,350
$10,540
$13,175
$13,175
$52,700
$52,700
$17,567
$52,700
$13,175
$52,700
$52,700
$0
$0
$52,700
$13,175
Total Annual
Costs
$52,700
$355,072
$123,906
$459,205
$359,464
$350,675
$668,050
$313,175
$351,812
$148,496
$343,382
$389,191
$10,540
$275,034
$275,034
$1,720,797
$719,536
$650,012
$52,700
$683,728
$412,774
$322,831
$0
$0
$553,435
$527,790
-------
Table 6-5. (continued)
Blind
FACID
116
41
180
141
154
38
109
155
Totals
Floor Facility
Yes
6
Synthetic Minor
4
Small Business
Yes
Yes
4
Number of
APCDs
1
12
1
1
1
3
3
1
99
Annual Material
Costs
$0
$0
$0
$0
$0
$0
$0
$0
$0
Annualized
Capital Costs
$0
$1,787,523
$495,670
$446,675
$525,227
$773,740
$567,451
$304,383
$22,784,893
Annual MR&R
Costs
$52,700
$52,700
$17,567
$52,700
$52,700
$52,700
$52,700
$52,700
$1,865,584
Total Annual
Costs
$52,700
$1,840,223
$513,237
$499,375
$577,927
$826,440
$620,151
$357,083
$24,650,478
Oi
Oi
-------
Table 6-6. Three-Piece Food Can Assembly Sources (Model Plant 5)
Blind
FACID
26
137
83
59
190
121
47
16
200
202
145
204
107
206
134
8
165
127
194
160
167
205
161
157
192
143
Floor Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Synthetic Minor
Yes
Yes
Yes
Small Business
Yes
Number of
APCDs
2
Annual Material
Costs
$0
$0
$72,902
$128,843
$74,100
$0
$40,455
$0
$41,525
$33,483
$275
$20,120
$4,180
$53,460
$64,625
$9,010
$32,540
$25,120
$54,445
$5,950
$0
$105,730
$8,935
$0
$34,515
$7,685
Annualized
Capital Costs
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Annual MR&R
Costs
$0
$0
$52,700
$52,700
$17,567
$0
$35,133
$0
$26,350
$52,700
$10,540
$26,350
$13,175
$52,700
$26,350
$13,175
$52,700
$17,567
$35,133
$26,350
$26,350
$17,567
$17,567
$26,350
$35,133
$26,350
Total Annual
Costs
$0
$0
$125,602
$181,543
$91,667
$0
$75,588
$0
$67,875
$86,183
$10,815
$46,470
$17,355
$106,160
$90,975
$22,185
$85,240
$42,687
$89,578
$32,300
$26,350
$123,297
$26,502
$26,350
$69,648
$34,035
-------
Table 6-6. (continued)
Blind
FACID
195
148
71
151
Totals
Floor Facility
Yes
Yes
14
Synthetic Minor
3
Small Business
1
Number of
APCDs
0
Annual Material
Costs
$26,180
$179,500
$11,970
$11,970
$1,047,518
Annualized
Capital Costs
$0
$0
$0
$0
$0
Annual MR&R
Costs
$35,133
$21,080
$13,175
$13,175
$743,070
Total Annual
Costs
$61,313
$200,580
$25,145
$25,145
$1,790,588
oo
-------
Table 6-7. Three-Piece Nonfood Can Assembly Sources (Model Plant 6)
Blind
FACID
32
66
183
110
164
145
107
40
68
11
103
42
180
Totals
Floor Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
9
Synthetic Minor
Yes
Yes
2
Small Business
0
Number of
APCDs
0
Annual Material
Costs
$0
$5,505
$0
$0
$0
$8,700
$0
$0
$13,595
$0
$0
$34,650
$7,530
$69,980
Annualized
Capital Costs
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Annual MR&R
Costs
$17,567
$13,175
$26,350
$0
$17,567
$10,540
$13,175
$17,567
$26,350
$0
$0
$26,350
$17,567
$186,208
Total Annual
Costs
$17,567
$18,680
$26,350
$0
$17,567
$19,240
$13,175
$17,567
$39,945
$0
$0
$61,000
$25,097
$256,188
-------
Table 6-8. End Lining Operations (Model Plant 7)
Blind
FACID
84
140
190
47
22
80
67
32
66
16
62
200
136
164
145
204
107
172
134
40
8
18
179
126
127
21
Floor Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Synthetic Minor
Yes
Small Business
Yes
Number of
APCDs
Annual Material
Costs
$141,316
$0
$0
$0
$751,936
$0
$0
$34,916
$2,202
$0
$249,447
$0
$77,420
$0
$0
$0
$0
$1,970
$3,441
$0
$0
$86,954
$93,866
$102,338
$44,770
$0
Annualized
Capital Costs
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Annual MR&R
Costs
$52,700
$0
$17,567
$17,567
$26,350
$26,350
$17,567
$17,567
$26,350
$0
$52,700
$13,175
$26,350
$17,567
$21,080
$13,175
$13,175
$35,133
$26,350
$17,567
$26,350
$52,700
$26,350
$52,700
$17,567
$26,350
Total Annual
Costs
$194,016
$0
$17,567
$17,567
$778,286
$26,350
$17,567
$52,483
$28,552
$0
$302,147
$13,175
$103,770
$17,567
$21,080
$13,175
$13,175
$37,103
$29,791
$17,567
$26,350
$139,654
$120,216
$155,038
$62,337
$26,350
to
o
-------
Table 6-8. (continued)
Blind
FACID
2
171
175
191
149
199
194
160
139
205
161
95
192
143
25
193
148
71
151
197
100
185
96
68
11
103
Floor Facility
Synthetic Minor
Yes
Yes
Yes
Yes
Small Business
Yes
Yes
Yes
Number of
APCDs
Annual Material
Costs
$22,166
$0
$0
$0
$0
$0
$0
$0
$73,988
$41,884
$183,710
$0
$85,594
$57,644
$37,980
$52,466
$345,200
$41,884
$0
$80,356
$148,008
$148,008
$54,774
$0
$0
$0
Annualized
Capital Costs
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Annual MR&R
Costs
$52,700
$0
$0
$52,700
$26,350
$26,350
$17,567
$13,175
$26,350
$17,567
$17,567
$26,350
$17,567
$26,350
$17,567
$26,350
$10,540
$13,175
$13,175
$52,700
$52,700
$52,700
$17,567
$13,175
$0
$0
Total Annual
Costs
$74,866
$0
$0
$52,700
$26,350
$26,350
$17,567
$13,175
$100,338
$59,451
$201,277
$26,350
$103,161
$83,994
$55,547
$78,816
$355,740
$55,059
$13,175
$133,056
$200,708
$200,708
$72,341
$13,175
$0
$0
to
-------
Table 6-8. (continued)
Blind
FACID
42
180
Totals
Floor Facility
10
Synthetic Minor
5
Small Business
4
Number of
APCDs
0
Annual Material
Costs
$0
$0
$2,964,238
Annualized
Capital Costs
$0
$0
$0
Annual MR&R
Costs
$13,175
$17,567
$1,261,291
Total Annual
Costs
$13,175
$17,567
$4,225,529
to
to
-------
Table 6-9. Summary of Total Annual Costs
Blind
FACID
26
137
84
89
65
48
130
112
118
144
140
108
101
58
117
106
37
163
158
30
70
83
83
59
59
190
Model Plant Category
Nonaseptic side seam stripe (Food)
Nonaseptic side seam stripe (Food)
Nonaseptic end seal compounds
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Nonaseptic end seal compounds
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Aseptic side seam stripe (Food)
Nonaseptic side seam stripe (Food)
Aseptic side seam stripe (Food)
Nonaseptic side seam stripe (Food)
Aseptic end seal compounds
Floor
Facility
Yes
Yes
Yes
Synthetic
Minor
Yes
Yes
Small
Business
Number
of
APCDs
1
1
2
1
1
Annual
Material
Costs
$0
$0
$141,316
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$6,071
$66,831
$57,150
$71,693
$0
Annualized
Capital
Costs
$0
$0
$0
$360,074
$360,074
$738,922
$360,074
$285,739
$360,074
$360,074
$0
$360,074
$360,074
$387,340
$360,074
$440,603
$330,613
$0
$360,074
$360,074
$341,897
$0
$0
$0
$0
$0
Annual
MR&R
Costs
$0
$0
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$0
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$26,350
$26,350
$26,350
$26,350
$17,567
Total
Annual
Costs
$0
$0
$194,016
$412,774
$412,774
$791,622
$412,774
$338,439
$412,774
$412,774
$0
$412,774
$412,774
$440,040
$412,774
$493,303
$383,313
$52,700
$412,774
$412,774
$394,597
$32,421
$93,181
$83,500
$98,043
$17,567
to
-------
Table 6-9. (continued)
Blind
FACID
190
190
121
121
47
47
47
22
22
80
80
78
67
67
67
162
159
123
72
32
32
32
66
66
66
66
Model Plant Category
Nonaseptic side seam stripe (Food)
Sheetcoating
Aseptic side seam stripe (Food)
Nonaseptic side seam stripe (Food)
Aseptic end seal compounds
Aseptic side seam stripe (Food)
Nonaseptic side seam stripe (Food)
Nonaseptic end seal compounds
Sheetcoatings
Beverage can coatings
Nonaseptic end seal compounds
Beverage can coatings
Beverage can coatings
Food can coatings
Nonaseptic end seal compounds
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
General line side seam stripe (nonfood)
Nonaseptic end seal compounds
Sheetcoatings
Aerosol side seam stripe (nonfood)
Aseptic end seal compounds
Nonaseptic end seal compounds
Sheetcoatings
Floor
Facility
Yes
Yes
Yes
Yes
Synthetic
Minor
Small
Business
Number
of
APCDs
1
2
1
1
1
1
3
Annual
Material
Costs
$74,100
$0
$0
$0
$0
$12,360
$28,095
$751,936
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$34,916
$0
$5,505
$0
$2,202
$0
Annualized
Capital
Costs
$0
$316,847
$0
$0
$0
$0
$0
$0
$689,944
$387,340
$0
$387,340
$193,670
$193,670
$0
$407,242
$334,679
$360,074
$360,074
$0
$0
$220,948
$0
$0
$0
$351,586
Annual
MR&R
Costs
$17,567
$17,567
$0
$0
$17,567
$17,567
$17,567
$26,350
$26,350
$26,350
$26,350
$52,700
$17,567
$17,567
$17,567
$52,700
$52,700
$52,700
$52,700
$17,567
$17,567
$17,567
$13,175
$13,175
$13,175
$13,175
Total
Annual
Costs
$91,667
$334,414
$0
$0
$17,567
$29,927
$45,662
$778,286
$716,294
$413,690
$26,350
$440,040
$211,237
$211,237
$17,567
$459,942
$387,379
$412,774
$412,774
$17,567
$52,483
$238,515
$18,680
$13,175
$15,377
$364,761
to
-------
Table 6-9. (continued)
Blind
FACID
183
183
43
16
16
16
16
115
44
189
62
200
200
200
200
110
56
136
136
12
164
164
164
124
202
202
Model Plant Category
General line side seam stripe (nonfood)
Sheetcoatings
Sheetcoatings
Inside spray
Nonaseptic end seal compounds
Nonaseptic side seam stripe (Food)
Sheetcoatings
Aerosol can coatings
Beverage can coatings
Beverage can coatings
Nonaseptic end seal compounds
Aseptic end seal compounds
Inside spray
Nonaseptic side seam stripe (Food)
Sheetcoatings
Aerosol side seam stripe (nonfood)
Sheetcoatings
Beverage can coatings
Nonaseptic end seal compounds
Food can coatings
Aerosol side seam stripe (nonfood)
Nonaseptic end seal compounds
Sheetcoatings
Beverage can coatings
Inside spray
Nonaseptic side seam stripe (Food)
Floor
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Synthetic
Minor
Yes
Yes
Yes
Yes
Small
Business
Yes
Yes
Yes
Yes
Number
of
APCDs
1
3
1
1
1
2
1
3
2
1
1
Annual
Material
Costs
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$249,447
$0
$19,250
$22,275
$0
$0
$0
$0
$77,420
$0
$0
$0
$0
$0
$7,040
$26,443
Annualized
Capital
Costs
$0
$0
$0
$0
$0
$0
$0
$0
$360,074
$360,074
$0
$0
$0
$0
$283,685
$0
$97,556
$0
$0
$360,074
$0
$0
$271,329
$296,040
$0
$0
Annual
MR&R
Costs
$26,350
$26,350
$52,700
$0
$0
$0
$0
$52,700
$52,700
$52,700
$52,700
$13,175
$13,175
$13,175
$13,175
$0
$52,700
$26,350
$26,350
$52,700
$17,567
$17,567
$17,567
$52,700
$26,350
$26,350
Total
Annual
Costs
$26,350
$26,350
$52,700
$0
$0
$0
$0
$52,700
$412,774
$412,774
$302,147
$13,175
$32,425
$35,450
$296,860
$0
$150,256
$26,350
$103,770
$412,774
$17,567
$17,567
$288,896
$348,740
$33,390
$52,793
to
-------
Table 6-9. (continued)
Blind
FACID
28
145
145
145
145
145
88
54
122
27
178
204
204
204
204
107
107
107
107
206
206
172
172
172
134
134
Model Plant Category
Beverage can coatings
Aerosol side seam stripe (nonfood)
Aseptic end seal compounds
Nonaseptic end seal compounds
Nonaseptic side seam stripe (Food)
Sheetcoatings
Beverage can coatings
Beverage can coatings
Sheetcoatings
Beverage can coatings
Beverage can coatings
Aseptic end seal compounds
Inside spray
Nonaseptic side seam stripe (Food)
Sheetcoatings
Aerosol side seam stripe (nonfood)
Inside spray
Nonaseptic end seal compounds
Sheetcoatings
Inside spray
Nonaseptic side seam stripe (Food)
Aseptic end seal compounds
Nonaseptic end seal compounds
Sheetcoatings
Aseptic end seal compounds
Inside spray
Floor
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Synthetic
Minor
Small
Business
Number
of
APCDs
2
2
1
2
1
2
Annual
Material
Costs
$0
$8,700
$0
$0
$275
$0
$0
$0
$0
$0
$0
$0
$0
$20,120
$0
$0
$4,180
$0
$0
$21,560
$31,900
$0
$1,970
$0
$0
$35,200
Annualized
Capital
Costs
$382,531
$0
$0
$0
$0
$602,431
$360,074
$360,074
$333,108
$341,897
$360,074
$0
$0
$0
$283,685
$0
$0
$0
$407,242
$0
$0
$0
$0
$571,264
$0
$0
Annual
MR&R
Costs
$52,700
$10,540
$10,540
$10,540
$10,540
$10,540
$52,700
$52,700
$52,700
$52,700
$52,700
$13,175
$13,175
$13,175
$13,175
$13,175
$13,175
$13,175
$13,175
$26,350
$26,350
$17,567
$17,567
$17,567
$13,175
$13,175
Total
Annual
Costs
$435,231
$19,240
$10,540
$10,540
$10,815
$612,971
$412,774
$412,774
$385,808
$394,597
$412,774
$13,175
$13,175
$33,295
$296,860
$13,175
$17,355
$13,175
$420,417
$47,910
$58,250
$17,567
$19,537
$588,831
$13,175
$48,375
Oi
to
Oi
-------
Table 6-9. (continued)
Blind
FACID
134
134
132
36
40
40
40
52
63
8
8
8
8
92
18
179
179
20
165
126
173
127
127
127
85
21
Model Plant Category
Nonaseptic end seal compounds
Nonaseptic side seam stripe (Food)
Sheetcoatings
Sheetcoatings
Aerosol side seam stripe (nonfood)
Nonaseptic end seal compounds
Sheetcoatings
Sheetcoatings
Beverage can coatings
Aseptic end seal compounds
Nonaseptic end seal compounds
Nonaseptic side seam stripe (Food)
Sheetcoatings
Beverage can coatings
Nonaseptic end seal compounds
Beverage can coatings
Nonaseptic end seal compounds
Sheetcoatings
Nonaseptic side seam stripe (Food)
Nonaseptic end seal compounds
Food can coatings
Inside spray
Nonaseptic end seal compounds
Sheetcoatings
Beverage can coatings
Nonaseptic end seal compounds
Floor
Facility
Yes
Yes
Yes
Yes
Yes
Synthetic
Minor
Yes
Small
Business
Number
of
APCDs
1
1
2
1
2
1
3
Annual
Material
Costs
$3,441
$29,425
$0
$0
$0
$0
$0
$0
$0
$0
$0
$9,010
$0
$0
$86,954
$0
$93,866
$0
$32,540
$102,338
$0
$25,120
$44,770
$0
$0
$0
Annualized
Capital
Costs
$0
$0
$307,161
$252,795
$0
$0
$250,744
$0
$0
$0
$0
$0
$252,795
$360,074
$0
$360,074
$0
$314,574
$0
$0
$360,074
$0
$0
$326,930
$387,340
$0
Annual
MR&R
Costs
$13,175
$13,175
$52,700
$52,700
$17,567
$17,567
$17,567
$0
$52,700
$13,175
$13,175
$13,175
$13,175
$52,700
$52,700
$26,350
$26,350
$52,700
$52,700
$52,700
$52,700
$17,567
$17,567
$17,567
$52,700
$26,350
Total
Annual
Costs
$16,616
$42,600
$359,861
$305,495
$17,567
$17,567
$268,311
$0
$52,700
$13,175
$13,175
$22,185
$265,970
$412,774
$139,654
$386,424
$120,216
$367,274
$85,240
$155,038
$412,774
$42,687
$62,337
$344=497
$440,040
$26,350
to
-------
Table 6-9. (continued)
Blind
FACID
21
23
203
97
53
61
79
198
133
82
57
147
2
171
171
201
55
175
175
105
135
150
77
91
191
177
Model Plant Category
Sheetcoatings
Sheetcoatings
Sheetcoatings
Sheetcoatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Nonaseptic end seal compounds
Aseptic end seal compounds
Nonaseptic end seal compounds
Sheetcoatings
Aerosol can coatings
Aseptic end seal compounds
Nonaseptic end seal compounds
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Beverage can coatings
Nonaseptic end seal compounds
Beverage can coatings
Floor
Facility
Yes
Yes
Yes
Synthetic
Minor
Yes
Yes
Yes
Yes
Small
Business
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Number
of
APCDs
3
2
2
4
1
1
1
1
12
1
1
1
Annual
Material
Costs
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$22,166
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Annualized
Capital
Costs
$617,501
$602,473
$677,250
$476,988
$466,936
$360,074
$285,594
$360,074
$387,340
$360,074
$439,170
$97,556
$0
$0
$0
$0
$0
$0
$0
$405,080
$360,074
$360,074
$391,798
$360,074
$0
$0
Annual
MR&R
Costs
$26,350
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$0
$0
$52,700
$52,700
$0
$0
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
Total
Annual
Costs
$643,851
$655,173
$729,950
$529,688
$519,636
$412,774
$338,294
$412,774
$440,040
$412,774
$491,870
$150,256
$74,866
$0
$0
$52,700
$52,700
$0
$0
$457,780
$412,774
$412,774
$444,498
$412,774
$52,700
$52,700
to
oo
-------
Table 6-9. (continued)
Blind
FACID
120
34
149
149
199
199
142
75
194
194
194
160
160
160
160
167
167
139
139
129
205
205
205
161
161
161
Model Plant Category
Beverage can coatings
Beverage can coatings
Beverage can coatings
Nonaseptic end seal compounds
Beverage can coatings
Nonaseptic end seal compounds
Beverage can coatings
Beverage can coatings
Aseptic end seal compounds
Inside spray
Nonaseptic side seam stripe (Food)
Aseptic end seal compounds
Inside spray
Nonaseptic side seam stripe (Food)
Sheetcoatings
Nonaseptic side seam stripe (Food)
Sheetcoatings
Food can coatings
Nonaseptic end seal compounds
Sheetcoatings
Nonaseptic end seal compounds
Nonaseptic side seam stripe (Food)
Sheetcoatings
Nonaseptic end seal compounds
Nonaseptic side seam stripe (Food)
Sheetcoatings
Floor
Facility
Yes
Yes
Yes
Synthetic
Minor
Small
Business
Number
of
APCDs
1
1
2
1
2
Annual
Material
Costs
$0
$0
$0
$0
$0
$0
$0
$0
$0
$19,620
$34,825
$0
$0
$5,950
$0
$0
$0
$0
$73,988
$0
$41,884
$105,730
$0
$183,710
$8,935
$0
Annualized
Capital
Costs
$360,074
$360,074
$360,074
$0
$405,080
$0
$341,897
$341,897
$0
$0
$0
$0
$0
$0
$341,897
$0
$97,556
$360,074
$0
$406,505
$0
$0
$341,897
$0
$0
$333,108
Annual
MR&R
Costs
$52,700
$52,700
$26,350
$26,350
$26,350
$26,350
$52,700
$52,700
$17,567
$17,567
$17,567
$13,175
$13,175
$13,175
$13,175
$26,350
$26,350
$26,350
$26,350
$52,700
$17,567
$17,567
$17,567
$17,567
$17,567
$17,567
Total
Annual
Costs
$412,774
$412,774
$386,424
$26,350
$431,430
$26,350
$394,597
$394,597
$17,567
$37,187
$52,392
$13,175
$13,175
$19,125
$355,072
$26,350
$123,906
$386,424
$100,338
$459,205
$59,451
$123,297
$359,464
$201,277
$26,502
$350,675
to
VO
-------
Table 6-9. (continued)
Blind
FACID
157
157
95
95
192
192
192
184
143
143
25
25
25
195
195
195
193
193
93
148
148
148
148
148
71
71
Model Plant Category
Nonaseptic side seam stripe (Food)
Sheetcoatings
Nonaseptic end seal compounds
Sheetcoatings
Aseptic side seam stripe (Food)
Nonaseptic end seal compounds
Nonaseptic side seam stripe (Food)
Sheetcoatings
Nonaseptic end seal compounds
Nonaseptic side seam stripe (Food)
Food can coatings
Nonaseptic end seal compounds
Sheetcoatings
Aseptic side seam stripe (Food)
Nonaseptic side seam stripe (Food)
Sheetcoatings
Nonaseptic end seal compounds
Sheetcoatings
Food can coatings
Aseptic side seam stripe (Food)
Food can coatings
Nonaseptic end seal compounds
Nonaseptic side seam stripe (Food)
Sheetcoatings
Food can coatings
Nonaseptic end seal compounds
Floor
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Synthetic
Minor
Small
Business
Number
of
APCDs
1
1
1
1
2
2
1
1
1
Annual
Material
Costs
$0
$0
$0
$0
$0
$85,594
$34,515
$0
$57,644
$7,685
$0
$37,980
$0
$0
$26,180
$0
$52,466
$0
$0
$0
$0
$345,200
$179,500
$0
$0
$41,884
Annualized
Capital
Costs
$0
$641,700
$0
$286,825
$0
$0
$0
$299,112
$0
$0
$130,929
$0
$130,929
$0
$0
$325,815
$0
$362,841
$360,074
$0
$352,071
$0
$0
$0
$0
$0
Annual
MR&R
Costs
$26,350
$26,350
$26,350
$26,350
$17,567
$17,567
$17,567
$52,700
$26,350
$26,350
$17,567
$17,567
$17,567
$17,567
$17,567
$17,567
$26,350
$26,350
$52,700
$10,540
$10,540
$10,540
$10,540
$10,540
$13,175
$13,175
Total
Annual
Costs
$26,350
$668,050
$26,350
$313,175
$17,567
$103,161
$52,082
$351,812
$83,994
$34,035
$148,496
$55,547
$148,496
$17,567
$43,747
$343,382
$78,816
$389,191
$412,774
$10,540
$362,611
$355,740
$190,040
$10,540
$13,175
$55,059
-------
Table 6-9. (continued)
Blind
FACID
71
71
151
151
151
151
197
9
196
100
119
185
96
96
96
7
68
68
68
68
19
99
11
11
11
103
Model Plant Category
Nonaseptic side seam stripe (Food)
Sheetcoatings
Aseptic end seal compounds
Food can coatings
Nonaseptic side seam stripe (Food)
Sheetcoatings
Nonaseptic end seal compounds
Sheetcoatings
Sheetcoatings
Nonaseptic end seal compounds
Food can coatings
Nonaseptic end seal compounds
Food can coatings
Nonaseptic end seal compounds
Sheetcoatings
Sheetcoatings
Aerosol side seam stripe (nonfood)
General line side seam stripe (nonfood)
Nonaseptic end seal compounds
Sheetcoatings
Sheetcoatings
Sheetcoatings
General line side seam stripe (nonfood)
Nonaseptic end seal compounds
Sheetcoatings
Aerosol side seam stripe (nonfood)
Floor
Facility
Yes
Yes
Yes
Yes
Yes
Yes
Synthetic
Minor
Yes
Yes
Yes
Yes
Small
Business
Number
of
APCDs
1
4
4
2
1
1
2
1
Annual
Material
Costs
$11,970
$0
$0
$0
$11,970
$0
$80,356
$0
$0
$148,008
$0
$148,008
$0
$54,774
$0
$0
$11,000
$2,595
$0
$0
$0
$0
$0
$0
$0
$0
Annualized
Capital
Costs
$0
$261,859
$0
$0
$0
$261,859
$0
$1,668,097
$666,836
$0
$644,086
$0
$0
$0
$632,445
$0
$0
$0
$0
$670,553
$360,074
$270,131
$0
$0
$0
$0
Annual
MR&R
Costs
$13,175
$13,175
$13,175
$13,175
$13,175
$13,175
$52,700
$52,700
$52,700
$52,700
$52,700
$52,700
$17,567
$17,567
$17,567
$52,700
$13,175
$13,175
$13,175
$13,175
$52,700
$52,700
$0
$0
$0
$0
Total
Annual
Costs
$25,145
$275,034
$13,175
$13,175
$25,145
$275,034
$133,056
$1,720,797
$719,536
$200,708
$696,786
$200,708
$17,567
$72,341
$650,012
$52,700
$24,175
$15,770
$13,175
$683,728
$412,774
$322,831
$0
$0
$0
$0
-------
Table 6-9. (continued)
Blind
FACID
103
103
103
181
42
42
42
42
116
41
180
180
180
141
154
38
109
155
Model Plant Category
General line side seam stripe (nonfood)
Nonaseptic end seal compounds
Sheetcoatings
Sheetcoatings
Aerosol side seam stripe (nonfood)
General line side seam stripe (nonfood)
Nonaseptic end seal compounds
Sheetcoatings
Sheetcoatings
Sheetcoatings
General line side seam stripe (nonfood)
Nonaseptic end seal compounds
Sheetcoatings
Sheetcoatings
Sheetcoatings
Sheetcoatings
Sheetcoatings
Sheetcoatings
Totals
Floor
Facility
Yes
Yes
Yes
Yes
56
Synthetic
Minor
Yes
Yes
Yes
18
Small
Business
Yes
Yes
13
Number
of
APCDs
1
1
1
1
12
1
1
1
3
3
1
144
Annual
Material
Costs
$0
$0
$0
$0
$34,650
$0
$0
$0
$0
$0
$7,530
$0
$0
$0
$0
$0
$0
$0
$4,081,736
Annualized
Capital
Costs
$0
$0
$0
$500,735
$0
$0
$0
$514,615
$0
$1,787,523
$0
$0
$495,670
$446,675
$525,227
$773,740
$567,451
$304,383
$44,833,563
Annual
MR&R
Costs
$0
$0
$0
$52,700
$13,175
$13,175
$13,175
$13,175
$52,700
$52,700
$17,567
$17,567
$17,567
$52,700
$52,700
$52,700
$52,700
$52,700
$7,325,316
Total
Annual
Costs
$0
$0
$0
$553,435
$47,825
$13,175
$13,175
$527,790
$52,700
$1,840,223
$25,097
$17,567
$513,237
$499,375
$577,927
$826,440
$620,151
$357,083
$56,240,611
to
-------
6.3 COST EFFECTIVENESS
The cost effectiveness of controlling organic HAP emissions from metal can surface coating
operations is the cost per ton of HAP emissions reduced. Table 6-10 shows total HAP reduction,
total control costs, and cost effectiveness for each of the four primary industry subcategories.
Overall cost effectiveness for the metal can surface coating industry cost also provided.
Cost effectiveness for the seven industry segments ranges from $4,500/ton ($4,900/Mg) to
$33,600/ton ($37,000/Mg). The cost effectiveness for the overall metal can surface coating
industry is $8,300/ton ($9,100/Mg).
6-33
-------
Table 6-10. Cost Effectiveness of Controls for Metal Can (Surface Coating) Industry
MACT Implementation
Emission Reductions
Total HAP emission reductions
(ton/yr)
(Mg/yr)
Industry Costs
Materials
Capital Equipment
MR&R
Total cost for industry
Cost Effectiveness ($/ton)
($/Mg)
Model Plant
Two-Piece
Beverage Can
Sources
3,111
2,822
$0
$19,287,617
$2,837,017
$22,124,634
$7,112
$7,840
Two-Piece
Food Can
Sources
690
626
$0
$2,761,053
$326,740
$3,087,793
$4,475
$4,933
One-Piece
Aerosol Can
Sources
0
0
$0
$0
$105,400
$105,400
Sheetcoating
Sources
2,087
1,893
$0
$22,784,893
$1,865,580
$24,650,473
$11,811
$13,022
Three-Piece
Food Can
Assembly
94
85
$1,047,518
$0
$743,070
$1,790,588
$19,049
$21,066
Three-Piece
Nonfood Can
Assembly
8
7
$69,980
$0
$186,207
$256,187
$32,023
$36,598
End Lining
Operations
803
728
$2,964,238
$0
$1,261,287
$4,225,525
$5,262
$5,804
Totals
6,792
6,162
$4,081,736
$44,833,563
$7,325,301
$56,240,600
$8,280
$9,127
-------
6.4 SMALL BUSINESSES
Based on the small business size cut-off of 1,000 corporate employees established by SIC
code 3411, 15 companies in the project database were identified as small businesses. Seven are
designated as area sources. Therefore, there are eight small businesses included in the total
population of facilities used for evaluating and determining MACT floor(s). These eight
facilities are identified in Table 6-9. Only five of the facilities are major sources of HAP
emissions and will have to meet the NESHAP requirements. The other three facilities are
synthetic minor sources. Total annual costs for the five major source small businesses are
$1.1 million.
6.5 REFERENCES
1. U. S. Environmental Protection Agency. OAQPS Control Cost Manual, Fifth Edition. EPA-
450/3-90-006, February 1996.
2. Memorandum from M. Icenhour, MRI, to P. Almodovar, EPA/ESD/CCPG. Tabular Costs
for Metal Can (Surface Coating) NESHAP. March 1, 2002.
3. Vatavuk, W. M. Estimating Costs of Air Pollution Control. Boca Raton, FL. Lewis
Publishers, 1990.
4. Bureau of Labor and Statistics website. November 20, 2001. http://www.bls.gov.
5. Average Revenue for U. S. Electric Utilities. November 30, 2001.
http ://www. eia. doe. gov/emeu/aer/txt/tab0815 .htm.
6. National Average Natural Gas Prices. 1995-2001. November 30, 2001.
http ://www. eia. doe.gov/pub/oil_gas/natural_gas/data_publications/natural_gas_monthly/
current/pdf/table_04.pdf.
7. The Data Acquisition Systems Handbook. Omega Engineering, Inc. 2000.
6-35
-------
TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
1. REPORT NO.
EPA-453/R-02-008
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
National Emission Standards for Hazardous Air Pollutants
(NESHAP) for Source Category: Surface Coating of Metal Cans
Background Information for Proposed Standards
5. REPORT DATE
November 2002
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, NC 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Air and Radiation
U. S. Environmental Protection Agency
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
National emission standards for the control of organic HAP emissions from surface coating operations at
metal can manufacturing facilities are being proposed under the authority of Section 112 of the Clean Air
Act. These standards would reduce air toxics from all major source metal can manufacturing facilities
(defined as those sources that emit or have the potential to emit 10 tons/yr [9.1 Mg/yr] or greater of
individual HAPs, or 25 tons/yr [22 Mg/yr] or greater of any combination of HAPs). This document contains
background information and environmental and economic impact assessments of the regulatory alternatives
(including MACT) considered in developing the proposed standards.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air Pollution
Metal Can
Hazardous Air Pollutants
Surface Coating
Can Coatings
Volatile Organic Compounds
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (Report)
Unclassified
21. NO. OF PAGES
159
Release Unlimited
20. SECURITY CLASS (Page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77)
PREVIOUS EDITION IS OBSOLETE
-------
United States Office of Air Quality Planning and Standards Publication No. EPA 453/R-02-008
Environmental Protection Emission Standards Division November 2002
Agency Research Triangle Park, NC
------- |