ILLINOIS POLLUTION CONTROL BOARD
January
22,
1987
PETITION FOR SITE—SPECIFIC
VOLATILE ORGANIC MATERIAL
EMISSION LIMITATIONS
)
R85-28
FOR NATIONAL CAN CORPORATION
)
ADOPTED RULE.
FINAL ORDER.
OPINION AND ORDER OF THE BOARD
(by J.
Theodore Meyer):
This
matter
comes
before
the
Board
upon
a November
8,
1985,
petition
for site—specific
relief filed
on behalf of National
Can
Corporation
(National).
National requests site—specific relief
from
35
Ill. Adm.
Code 215.204(b)(3) which provides that interior
can body spray coating materials contain no more than
4.2 lbs.
of
volatile organic material
(VOM)
per gallon.
National
seeks
to
increase this limitation
to 5.8 lbs of VOM per gallon for the
interior
can body spray coating materials used
at its Rockford
plant.
Hearing was held on
February
4,
1986.
Briefs were
filed
by National and the Illinois Environmental Protection Agency
(Agency)
on March
25 and 26,
1986, respectively with National
submitting
a reply brief on March
31,
1986.
The Department of
Energy and Natural Resources
issued
a negative declaration
for
this rulemaking
on June 9,
1986,
and the Economic Technical
Advisory Committee concurred with this finding at its June 20,
1986, meeting.
First Notice was adopted by the Board on September
25,
1986
and published at
10
Ill.
Peg.
17959,
October
17,
1986.
Two
comments were received during the first notice period.
Second
Notice was adopted on December
5,
1986.
The Joint Committee on
Administrative Rules
(JCAR)
considered
this rulemaking
at its
January
13,
1987 meeting and
issued
a
Certificate of
No
Obj ection.
National owns and operates
a facility in Rockford,
Illinois
in Winnebago County which employs 150 people
in the manufacture
of metallic beverage and food cans.
The production process at
issue
is the manufacture of three—piece
steel beer cans.
(Pet.
Exh. A).
The three—piece
steel beer cans must be coated
twice
in
the
inside
with
an
“interior
body
spray”
to
insure
that
the
can’s
contents
do
not
adversely
react
with
the
steel
can
body,
thereby
preventing
flavor
deterioration.
(P.
at
10).
The
steel
beer
can
is
manufactured
for
use
by
a
single
brewery
customer.
(R.
at
6).
VOMs are emitted during the
metal
coating
operations.
National
has
developed
a
compliant
end
sealing
compound
for
use
in
the
manufacture
of
aluminum
cans
but
has
been
unable
to
develop
an
interior
body
spray
which
complies
with
the
4.2
lbs.
75-138
—2—
of VOM per gallon emission limitation
of Section 215.204(b)(3).
(Pet.
at
3).
Mr. Alan Cans testified for National on how
interior body coating materials are selected by National.
Once
a
coating
is obtained
it undergoes an extensive testing
procedure.
A coating is first tested by filling
up
a finished
steel can with electrolytic solution
to determine milliamp charge
(MA).
The MA is a measure of the resistance of the coating,
electrolytic corrosion, with the can contents.
If the MA is
high, then
the coating
is rejected.
If
an acceptable MA is
obtained, the cans are then filled with the customer’s
product
(i.e.,
beer)
and are stored
for six months.
At the end
of six months, the customer’s
flavor panel
tastes the beer.
If
there
is
a bad taste or
if the MA is still high,
the improperly
coated beer can is rejected and
a new coating must be found.
(R.
at 10—il).
Mr. Cans testified that finding an acceptable
interior body spray
for use with beer
is more difficult than
finding
an acceptable one for soft drink
cans.
Taste
is not
a
critical issue with soft drinks which have a sweet taste
and high
carbonation level whereas a brewery prides itself on the taste of
its beer.
(R. at 12).
Mr.
Gans also testified on the efforts undertaken by
National
to obtain a complaint interior body spray
for use on
its
three—piece
steel beer
cans.
Prior
to the 1982 compliance date,
National
and PPG, one of
its primary suppliers, developed a
compliant coating.
Subsequently, the coating was rejected for
failing the taste test.
(R. at 13).
In May, 1983,
PPG and Mobil
developed more compliant coatings which were applied
to cans and
submitted
to National’s customer.
In October, 1983,
the customer
notified National
that the coating failed
the MA test and
it
should resubmit more cans.
(R. at 14).
In January, 1984,
National was notified that the new batch also
failed,
this time
for taste.
At this time,
National went back
to its suppliers
requesting
the development of new coatings.
In June 1984,
PPG
and Glidden submitted new coatings.
These coatings were tested
and submitted
to National’s customer
in August,
1984.
The cans
underwent the shelf—life
test for six months.
In February,
1985,
National was contacted by its customers that the cans needed
to
be
tested again with the same product.
By the end of June,
1985,
all of the cans were rejected.
At this time,
none of National’s
coating suppliers would send
it any more coatings.
(R.
at 15).
Mr.
Cans testified that National’s suppliers are more interested
in high—volume coating applications
in which hundreds of
thousands of gallons are used annually.
National has the only
three—piece
steel beer can plant
in the United States
and
National’s coating
suppliers cannot economically justify the
expenditure
for research and development of a compliant interior
can body coating when the demand for such
a coating
is
approximately 10,000 gallons per year.
CR.
at 15—16).
Using
the third quarter
of 1985 as
a representative
manufacturing period, National asserts that it exceeded its daily
75-139
—3—
allowable
emission
limitation
approximately
ten
percent
of
the
time,
and on those non—compliance days,
the excess emissions
averaged
13 pounds per
day with the maximum exceedance being 30
pounds
per day.
These numbers are based on
an
average
of
approximately
700 pounds of VOM per day being emitted from the
plant.
(R.
at
19).
Also,
National
contends
that
the
VOM
emissions
attributable
to
the
manufacturing
of
three—piece
steel
cans
in 1985 were about 12 tons.
This number represents
approximately 12
of the total VOM emissions emitted from
National’s plant
in 1985.
(P.
at 39).
Technical
Feasibility
and
Economic
Reasonableness
National
contends
that
the
only
emission
control
technology
available
to it
to control VOM emissions is thermal
incineration.
(R.
at
20).
Carbon—absorption technology
is not
compatible
with
can coating operations because too many solids
are
picked
up
into
the
carbon—absorption
unit
which
tends
to
bind
it,
thereby
allowing
the
VONs
to
pass
through
the
unit.
Also,
National
contends
that
the
VOMs
change
during
the
baking
of
the
can
which
also
allows
VOM5
to pass through the unit.
(R.
at 20—
21).
National estimated the cost of acquiring
and installing an
incineration unit at
its Rockford plant with
a heat recovery of
60
efficiency.
The cost
of such a
unit was estimated to be
$300,000, which includes purchasing and installing the
incineration
unit,
and
an
annual
operating
cost
of
$80,000.
(R.
at
21).
Based
on
an
average
production
level
of
12
million
steel
cans
per
year,
the
cost
to
control
VOM
emissions
from
the
non—
compliant coating would be approximately $6,500 per
ton.
(P. at
22).
National also explored the possibility of acquiring
an
incineration unit with
a more efficient recovery system.
However, such
a unit would cost between $100,000 and $200,000
more than the unit which had been evaluated.
(P.
at
25).
Both National and the Agency submit that $6,500
per
ton of
VOM control
is unreasonable from an economic standpoint.
In
summary, National’s argues that it
is able
to afford
the cost of
controlling
its
VOM
emissions,
but
it
makes
little
sense
economically
to
spend
$80,000
on
an
annual
basis
to
control,
on
the
average,
13
lbs.
of
excess
VOM
emissions
per
day
when
those
emissions occur only over
the span of less than forty—five days
per
year.
(P.
at
29).
The
Agency
appears
to
be
in
agreement
with
National’s
position.
Environmental
Impact
National’s
facility
is
located
in
Winnebago
County
which
has
been
classified
by
USEPA
as
“cannot
be
classified
or
better
than
National
Standards”
for
ozone.
(40
CFP
81.314).
VOM
emissions
from
National’s
facility
are
ozone
precursors
and,
as
a
result,
are
regulated
in
an
effort
to
control
the
formation
of
ozone
in
the
atmosphere.
Mr.
Robert
Godare
of
the
Agency
testified
that
75-140
—4—
the
ozone
monitoring
station
near National’s plant reported
no
exceedances
of
the
ozone
standard
in
1983,
1984
or
1985.
Mr.
Godare also testified that although the VON emissions from
National’s plant could cause
a recognizable odor downwind of the
plant,
the
Agency
has
received
no
complaints
of
odors
emanating
from National’s plant.
(P.
at
43).
Conclusion
Based
on the foregoing facts,
the Board
finds that
National’s compliance with
35
Ill.
Adin. Code 215.204(b)(3)
although technologically feasible
is not economically reasonable
in light of the fact that coating suppliers cannot be expected
to
expend
the necessary time and resources on research and
development of
a compliant
interior can body coating material
based
on annual demand
of only 10,000 gallons.
The Board also
finds
that
the
add-on
control
technology
to
control
excess
VON
emissions
from
National’s
plant
is
available
but
not
economically
justified.
Requiring
the installation and operation of such
control
technology
would
impose
an
unreasonable
financial
hardship on National without conferring
a measurable
environmental benefit on
the surrounding
area.
Also,
since
the
production of steel cans at National’s facility occurs on such
a
sporadic basis,
it makes little
sense
to require National
to
spend
$80,000
per
year
to control
13 pounds of excess VON
emissions per day of steel
can production which National asserts
is less than forty—five days per year.
Lastly,
the
participants
are
in
agreement
over
the
inclusion
of language requiring National
to demonstrate compliance
under
Section
2l5.207 using
the applicable limitation contained
in
Section
215.204
(4.2 lbs/gal),
on
a weekly rather
than daily
basis.
CREER
The Eoard hereby adopts the following amendment
to
35
Ill.
Adm.
Code 215.206:
Title
35:
ENVIRONMENTAL
PROTECTION
SUBTITLE
B~
AIR
POLLUTION
CHAPTER
I:
POLLUTION CONTROL BOARD
SUBCHAPTER
c:
EMISSION
STANDARDS
AND
LIMITATIONS FOR STATIONARY SOURCES
PART
215
ORGANIC MATERIAL EMISSION STANDARDS
AND LIMITATIONS
SUBPART
F:
COATING OPERATIONS
Section 215.206
Exemptions from Emission Limitations
75-141
—5—
The limitations of this
Subpart shall not apply to:
1)
Coating
plants
whose
emissions
of
volatile
organic
material
as limited by the operating permit will not
exceed 22.7 Mg/year
(25 T/year),
in the absence of air
pollution
control
equipment;
or
2)
Sources
used
exclusively
for
chemical
or
physical
analysis or determination of product quality and
commercial acceptance provided that:
A)
The operation
of the source
is not an integral
part
of
the
production
process;
B)
The emissions from the
source do not exceed 363
kg
(800 lbs)
in any calendar month; and,
C)
The exemption
is approved
in
writing by the
Agency.
3
Interior body spray coating material
for three—~iece
steel
cans used by National Can Corporation
at
its
Rockford can manufacturing plant
in Loves Park,
-
Illinois,
provided
that:
A
The emission of volatile organic material
from
the interior body spray coating line shall not
exceed 0.70 k9/l
(5.8 lb/gal)
of coating
material,
excluding
water,
delivered to the
coating
applicator;
and
B)
The emission of volatile organic material shall
comply
with
the
provisions
of Section 215.204
by
use
of the
internal offset provisions of Section
215.207 computed on
a weekly weighted average
basis.
IT IS SO ORDERED.
I, Dorothy
N.
Gunn,
Clerk of the Illinois Pollution Control
Board,
hereby
certify
that
the
a,~ove Opinion
and
Order
was
adopted
on
the
~
day of
~
,
1987 by a vote
of
C.,-C--~
/
/~•~
.
~
~
~
Dorothy
N.
1Cunn,
Clerk
Illinois
Pollution
Control
Board
75-142