EPA PUBLISHES FINAL NESHAP for SURFACE COATING of METAL CANS
(40 CFR Part 63 Subpart KKKK)
The EPA has published the final National Emission Standards for Hazardous Air Pollutants (NESHAP) rule for Surface Coating of Metal Cans on November 13, 2003 (68 FR 64432). The compliance date for existing sources is November 13, 2006. For new or reconstructed sources, if the initial startup of the source is before the promulgation date, the compliance date is November 13, 2003; if the initial startup of the new or reconstructed source is after the promulgation date, the compliance date is the initial start-up date.
The source category includes facilities that apply coatings during any stage of the can manufacturing process to metal cans or ends (including decorative tins) or to metal crowns or closures for any type of can body. Affected sources can include: coating application lines, drying and curing ovens, mixing and thinning areas, and equipment cleaning.
The rule applies to operations that use greater or equal to 1500 gallons of coatings per year and is a major source or located at a major source of Hazardous Air Pollutants (HAP) emissions. A major HAP facility is one that emits or has the potential to emit 10 tons per year of any one HAP or 25 tons per year of a combination of HAPs. EPA has determined that the following HAPs may be emitted: ethylene glycol monobutyl ether (EGBE), other glycol ethers, xylene, hexane, MIBK or MEK.
The rule does not apply to operations located at an area source. An area source is those that have the potential to emit HAP emissions, but are not major sources. Facilities can limit a source’s potential to emit below major source thresholds to establish area source status.
The rule applies if coating metal sheets for further processing, but does not apply if coating coils for further processing. Coil coating is covered by another NESHAP – Surface Coating of Metal Coil (Subpart SSSS). This rule does not apply to the coating of pails or drums, which are covered under the Miscellaneous Metal Parts & Products NESHAP – 40 CFR Part 63 Subpart MMMM. R&D equipment or maintenance activities are not applicable to the rule.
Four sub-categories have been identified:
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1 and 2-piece D&I can body coating |
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sheetcoating |
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3-piece can body assembly coating |
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end coating |
Compliance options are either material selection, use of capture and control equipment, or a combination of both. Sources are required to establish capture and control system operating parameters during an initial performance test and a Startup, Shutdown, and Malfunction (SSM) Plan if that option is used.
If a site has multiple operations, it is subject to more than one emission limit. Emission limits are proposed for materials used for various operations (lb HAP/gal solids) and for capture and control equipment (% control efficiency or a 20 ppmdv THC [as carbon] outlet limit).
All sources are required to determine the mass of organic HAP and the volume fraction of coating solids in materials used each month. Sources are also required to develop a work practice standard (WPS) plan to minimize emissions from cleaning, storage, transfer, mixing, and waste handling operations. Existing WPS Plans may be used if the rule requirements are satisfied.
Sources are subject to initial notification requirements, notification of performance testing, notification of compliance status and periodic (semi-annual) reporting and several recordkeeping requirements.
For additional information, please contact Air/Compliance Consultants, Inc. at 412-826-3636.
Author: Nancy Hirko
Date: 09/15/03
Updated by Kimberly Coy 01/27/04