ILLINOIS POLLUTION CONTROL BOARD

September 25, 1986

PETITION FOR SITE—SPECIFIC

)

VOLATILE ORGANIC MATERIAL

)

EMISSION LIMITATIONS

)

R85—28

FOR NATIONAL CAN CORPORATION

)

Proposed Rule.

First Notice.

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.

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,

(R.

p.

10).

The

steel

beer

can

is manufactured for

use by

a single brewery customer.

(R.

p. 6).

VOM5 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.

of VOM per gallon emission limitation of

Section 215.204(b) (3).

(Pet, p.

3).

Mr. Alan Gans 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 inillianip charge

(MA).

The MA

is a measure of the resistance of the coating,

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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.

pp.

10—11).

Mr.

Gans 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.

p. 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.

p.

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 because maybe the cans manufactured

were not

up to par.

CR.

p.

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,

p.

15).

Mr.

Gans

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.

(R.

pp. 15—16).

Using the third quarter of 1985 as

a representative

manufactur,ing period, National asserts that it exceeded its daily

allowable emission limitation approximately ten percent of the

time, and on those non—compliance days, the excess emissions

72-446

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—3—

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.

p.

19).

Also, National contends that the VON

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.

(R.

p.

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.

p. 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

blind

it, thereby allowing the VOMS to pass through the unit.

Also, National contends that

the VOMs change during

the baking

of the can which also allows VOMS to pass through the unit.

(R.

pp. 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.

p.

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.

(R.

p. 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.

(R.

p.

25).

Both National and the Agency submit that $6,500 per

ton of

VOM control

is unreasonable from an economic standpoint.

In a

nutshell, National’s argument

is 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,

(R.

p.

29),

The Agency appears

to be

in agreement

with National’s position and has proposed additional language

so

that a cap could be placed on the available emissions for

National.

(R.

p. 42).

The Agency has proposed, with National

in

agreement,

that National be able

to show compliance pursuant

to

Section 215.207 on a weekly basis

rather than

a daily basis.

Environmental Impact

National’s facility is located

in Winnebago County which has

been classified by USEPA as “cannot be classified or better than

72447

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National Standards”

for ozone.

(40 CFR 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

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 VOM 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.

(R.

p. 43).

Conclusion

Based

on

the

foregoing

facts,

the

Board

finds

that

National’s compliance with 35 Ill, Adm. 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 VOM

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 VOM

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 the Agency’s proposed language setting a cap on National’s

emission by requiring National

to demonstrate compliance with

Section 215.207 on a weekly rather than daily basis.

The Board

will include such a requirement

in

its First Notice Order.

However,

the Board notes that the emission of volatile organic

material

is governed by Section 215.204 and Section 215,207

establishes the internal offset provision.

During the first

notice period, the

Board requests that the participants address

the mechanics of how this provision will be implemented.

ORDER

The Board hereby orders first notice publication

in the

Illinois Register of

the following amendment

to 35 Ill.

Adni.

Code

215.206:

72-448

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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

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—piece

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 kg/i

(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 215.207 on

a weekly weighted average basis.

IT

IS

SO

ORDERED.

72-449

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—6—

I,

Dorothy

M. Gunn,

Clerk of the

Illinois Pollution Control

Board,

hereby certify that the abov

Opinion and Order was

adopted on the

5~

day of

~.

,

1986 by a vote

of

~,-C

.

Dorothy M.Zunn,

Clerk

Illinois Pollution Control Board