Tenn. Comp. R. & Regs. 1200-03-16-.40

Current through December 10, 2024

Section 1200-03-16-.40 - BEVERAGE CAN SURFACE COATING

(1) Applicability.

(a) The provisions of this rule apply to the following affected facilities in beverage can surface coating lines: each exterior base coat operation, each overvarnish coating operation, and each inside spray coating operation.

(b) The provisions of this rule apply to each affected facility which is identified in subparagraph (a) of this paragraph and commences construction, modification, or reconstruction after November 6, 1988.

(2) Definitions and Symbols.

(a) Definitions.

1. "Beverage can" means any two-piece steel or aluminum container in which soft drinks or beer, including malt liquor, are packaged. The definition does not include containers in which fruit or vegetable juices are packaged.

2. "Exterior base coating operation" means the system on each beverage can surface coating line used to apply a coating to the exterior of a two-piece beverage can body. The exterior base coat provides corrosion resistance and a background for lithography or printing operations. The exterior base coat operation consists of the coating application station, flashoff area, and curing oven. The exterior base coat may be pigmented or clear (unpigmented).

3. "Inside spray coating operating" means the system on each beverage can surface coating line used to apply a coating to the interior of a two-piece beverage can body. This coating provides a protective film between the contents of the beverage can and the metal can body. The inside spray coating operation consists of the coating application station, flashoff area, and curing oven. Multiple applications of an inside spray coating are considered to be a single coating operation.

4. "Overvarnish coating operation" means the system on each beverage can surface coating line used to apply a coating over ink which reduces friction for automated beverage can filling equipment, provides gloss, and protects the finished beverage can body from abrasion and corrosion. The overvarnish coating is applied to two-piece beverage can bodies. The overvarnish coating operation consists of the coating application station, flashoff area, and curing oven.

5. "Two-piece can" means any beverage can that consists of a body manufactured from a single piece of steel or aluminum and a top. Coatings for a two-piece can are usually applied after fabrication of the can body.

6. "VOC content" means all volatile organic compounds (VOC) that are in a coating. VOC content is expressed in terms of kilograms of VOC per litre of coating solids.

(b) Symbols.

Ca = the VOC concentration in each gas stream leaving the control device and entering the atmosphere (parts per million as carbon)

Cb = the VOC concentration in each gas stream entering the control device (parts per million as carbon)

Dc = density of each coating, as received (kilograms per litre)

Dd = density of each VOC-solvent added to coatings (kilogram per litre)

Dr = density of VOC-solvent recovered by an emission control device (kilograms per litre)

E = VOC destruction efficiency of the control device (fraction)

F = the proportion of total VOC emitted by an affected facility which enters the control device to total emissions (fraction)

G = the volume-weighted average of VOC in coatings consumed in a calendar month per volume of coating solids applied (kilograms per litre of coating solids)

He = the fraction of VOC emitted at the coater and flashoff areas captured by a collection system

Hh = the fraction of VOC emitted at the cure oven captured by a collection system

Lc = the volume of each coating consumed, as received (litres)

Ld = the volume of each VOC-solvent added to coatings (litres)

Lr = the volume of VOC-solvent recovered by an emission control device (litres)

Ls = the volume of coating solids consumed (litres)

Md = the mass of VOC-solvent added to coatings (kilograms)

Mo = the mass of VOC-solvent in coatings consumed, as received (kilograms)

Mr = the mass of VOC-solvent recovered by emission control device (kilograms)

N = the volume-weighted average mass of VOC emissions to atmosphere per unit volume of coating solids applied (kilograms per litre of coating solids)

Qa = the volumetric flow rate of each gas stream leaving the control device and entering the atmosphere (dry standard cubic meters per hour )

Qb = the volumetric flow of each gas stream entering the control device (dry standard cubic meters per hour)

R = the overall emission reduction efficiency for an affected facility (fraction)

Se = the fraction of VOC in coating and diluent VOC-solvent emitted at the coater and flashoff area for a coating operation

Sh = the fraction of VOC in coating and diluent solvent emitted at the cure oven for a coating operation

Vs = the proportion of solids in each coating, as received (fraction by volume)

Wo = the proportion of VOC in each coating, as received (fraction by weight).

(3) Standards for volatile organic compounds.

On or after the date on which the initial performance test required by 1200-3-16-.01(5)(a) is completed, no owner or operator subject to the provisions of this rule shall discharge or cause the discharge of VOC emissions to the atmosphere that exceed the following volume-weighted calendar-month average emissions:

(a) 0.29 kilogram of VOC per litre of coating solids from each two-piece can exterior base coating operation, except clear base coat;

(b) 0.46 kilogram of VOC per litre of coating solids from each two-piece can clear base coating operation and from each overvarnish coating operation; and

(c) 0.89 kilogram of VOC per litre of coating solids from each two-piece can inside spray coating operation.

(4) Performance test and compliance provisions.

(a)1200-3-16-.01(5)(d) does not apply to monthly performance tests and 1200-3-16 - .01(5)(f) does not apply to the performance test procedures required by this rule.

(b) The owner or operator of an affected facility shall conduct an initial performance test as required under 1200-3-16-.01(5)(a) and thereafter a performance test each calendar month for each affected facility.

1. The owner or operator shall use the following procedures for each affected facility that does not use a capture system and a control device to comply with the emission limit specified under paragraph (3) of this rule. The owner or opertor shall determine the VOC-content of the coatings from formulation data supplied by the manufacturer of the coating or by an analysis of each coating, as received, using Reference Method 24 (as specified in rule 1200-3-16-.01(5)(g) 24.). The Technical Secretary may require the owner or operator who uses formulation data supplied by the manufacturer of the coating to determine the VOC content of coatings using Reference Method 24 or an equivalent or alternative method. The owner or operator shall determine from company records the volume of coating and the mass of VOC-solvent added to coatings. If a common coating distribution system serves more than one affected facility or serves both affected and exiting facilities, the owner or operator shall estimate the volume of coating used at each facility by using the average dry weight of coating, number of cans, and size of cans being processed by each affected and existing facility or by other procedures acceptable to the Technical Secretary.

(i) Calculate the volume-weighted averge of the total mass of VOC per volume of coating solids used during the calendar month for each affected facility, except as provided under sub-part (iv) of this part. The volume-weighted average of the total mass of VOC per volume of coating solids used each calendar month will be determined by the following procedures.

(I) Calculate the mass of VOC used (Mo + Md) during the calendar month for the affected facility by the following equation:

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(Sum Ldj Ddj will be O if no VOC solvent is added to the coatings, as received.) where n is the number of different coatings used during the calendar month and m is the number of different diluent VOC-solvents used during the calendar month.

(II) Calculate the total volume of coating solids used (Ls) in the calendar month for the affected facility by the following equation:

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where n is the number of different coatings used during the calendar month.

(III) Calculate the volume-weighed average mass of VOC per volume of solids used (G) during the calendar month for the affected facility by the following equation:

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(ii) Calculate the volume-weighted average of VOC emissions discharged to the atmosphere (N) during the calendar month for the affected facility by the following equation:

N = G Equation (4)

(iii) Where the value of the volume-weighted average of mass of VOC per volume of solids discharged to the atmosphere (N) is equal to or less than the applicable emission limit specified under paragraph (3) of this rule, the affected facility is in compliance.

(iv) If each individual coating used by an affected facility has a VOC content equal to or less than the limit specified in paragraph (3) of this rule, the affected facility is in compliance provided no VOC-solvents are added to the coating during distribution or application.

2. An owner or operator shall use the following procedures for each affected facility that uses a capture system and control device that destroys VOC (e.g. incinerator) to comply with emissions limit specified in paragraph (3) of this rule.

(i) Determine the overall reduction efficiency (R) for the capture system and control device.

For the initial performance test, the overall reduction efficiency (R) shall be determined as prescribed in items (I), (II), and (III) below. In subsequent months, the owner or opertor may use the most recently determined overall reduction efficiency for the performance test providing control device and capture system operating conditions have not changed. The procedure in items (I), (II) and (III) below, shall be repeated when directed by the Technical Secretary or when the owner or operator elects to operate the control device or capture system at conditions different from the initial performance test.

(I) Determine the fraction (F) of total VOC used by the affected facility that enters the control device using the following equation:

F = Se He + Sh Hh Equation (5)

where He an Hh shall be determined by a method that has been previously approved by the Technical Secretary. The owner or operator may use the values of Se and Sh specified in Table 1 or other values determined by a method that has been previously approved by the Technical Secretary.

Table 1. - Distribution of VOC Emissions

	Emission distribution
Coating operation	Coater/	Curing
	flashoff (Se)	oven (Sh)
Two-piece aluminum or steel can:
Exterior base coat operation	0.75	0.25
Overvarnish coating operation	0.75	0.25
Inside spray coating operation	0.80	0.20

(II) Determine the destruction efficiency of the control device (E) using values of the volumetric flow rate of each of the gas streams and the VOC content (as carbon) of each of the gas streams in and out of the device by the following equation:

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where n is the number of vents before the control device, and m is the number of vents after the control device.

(III) Determine overall reduction efficiency (R) using the following equation:

R = EF Equation (7)

(ii) Calculate the volume-weighted average of the total mass of VOC per volume of coating solids (G) used during the calendar month for the affected facility using equations (1), (2) and (3).

(iii) Calculate the volume-weighted average of VOC emissions discharged to the atmosphere (N) during the calendar month by the following equation:

N = G x (1 - R) Equation (8)

(iv) If the volume-weighted average of mass of VOC emitted to the atmosphere for the calendar month (N) is equal to or less than the applicable emission limit specified in paragraph (3) of this rule, the affected facility is in compliance.

3. An owner or operator shall use the following procedure for each affected facility that uses a capture system and a control device that recovers the VOC (e.g., carbon adsorber) to comply with the applicable emission limit specified in paragraph (3) of this rule.

(i) Calculate the volume-weighted average of the total mass of VOC per unit volume of coating solids applied (G) used during the calendar month for the affected facility using equations (1), (2) and (3).

(ii) Calculate the total mass of VOC recovered (Mr) during each calendar month using the following equation:

Mr = Lr Dr Equation (9)

(iii) Calculate overall reduction efficiency of the control device (R) for the calendar month for the affected facility using the following equation:

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(iv) Calculate the volume-weighted average mass of VOC discharged to the atmosphere (N) for the calendar month for the affected facility using equation (8).

(v) If the weighted average of VOC emitted to the atmosphere for the calendar month (N) is equal to or less than the applicable emission limit specified in paragraph (3) of this rule, the affected facility is in compliance.

(5) Monitoring of emissions and operations.

The owner or operator of an affected facility that uses a capture system and an incinerator to comply with the emission limits specified under paragraph (3) of this rule shall install, calibrate, maintain, and operate temperature measurement devices as prescribed below.

(a) Where thermal incineration is used, a temperature measurement device shall be installed in the firebox. Where catalytic incineration is used, temperature measurement devices shall be installed in the gas stream immediately before and after the catalyst bed.

(b) Each temperature measurement device shall be installed, calibrated, and maintained according to the manufacturer's specifications. This device shall have an accuracy the greater of ± 0.75 percent of the temperature being measured expressed in degrees Celsius or ± 2.5°C.

(c) Each temperature measuement device shall be equipped with a recording device so that a permanent continuous record is produced.

(6) Reporting and recordkeeping requirements.

(a) The owner or operator of an affected facility shall include the following data in the initial compliance report required under rule 1200-3-16-.01(5)(a).

1. Where only coatings which individually have a VOC content equal to or less than the limits specified in paragraph (3) of this rule are used, and no VOC is added to the coating during the application or distribution process, the owner or operator shall provide a list of the coatings used for each affected facility and the VOC content of each coating calculated from data determined using either Reference Method 24 (as specified in 1200-3-16-.01(5)(g) 24.) or data supplied by the manufacturer of the coatings.

2. Where one or more coatings which individually have a VOC content greater than the limits specified under paragraph (3) of this rule are used or where VOC are added or used in the coating process, the owner or operator shall report for each affected facility the volume-weighted average of the total mass of VOC per volume of coating solids.

3. Where compliance is achieved through the use of incineration, the owner or operator shall include in the initial performance test required under 1200-3-16 - .01(5)(a) the combustion temperature (or the gas temperature upstream and downstream of the catalyst bed), the total mass of VOC per volume of coating solids before and after the incinerator, capture efficiency, and the destruction of efficiency of the incinerator used to attain compliance with the applicable emission limit specified under paragraph (3) of this rule. The owner or operator shall also include a description of the method used to establish the amount of VOC captured by the capture system and sent to the control device.

(b) Following the initial performance test, each owner or operator shall submit for each semiannual period ending June 30 and December 31 a written report to the Technical Secretary of exceedances of VOC content and incinerator operating temperatures when compliance with paragraph (3) of this rule is achieved through the use of incineration. All semiannual reports shall be postmarked by the 30th day following the end of each semiannual period. For the purposes of these reports, exceedances are defined as:

1. Each performance period in which the volume-weighted average of the total mass of VOC per volume of coating solids, after the control device, if capture devices and control systems are used, is greater than the limit specified under paragraph (3) of this rule.

2. Where compliance with paragraph (3) of this rule is achieved through the use of thermal incineration, each 3-hour period when cans are processed, during which the average temperature of the device was more than 28°C below the average temperature of the device during the most recent performance test at which destruction efficiency was determined as specified under paragraph (4) of this rule.

3. Where compliance with paragraph (3) of this rule is achieved through the use of catalytic incineration, each 3-hour period when cans are being processed during which the average temperature of the device immediately before the catalyst bed is more than 28°C below the average temperature of the device immediately before the catalyst bed during the most recent performance test at which destruction efficiency was determined as specified under paragraph (4) of this rule and all 3hour periods, when cans are being processed, during which the average temperature difference across the catalyst bed is less than 80 percent of the average temperature difference across the catalyst bed during the most recent performance test at which destruction efficiency was determined as specified under paragraph (4) of this rule.

(c) Each owner or operator subject to the provisions of this rule shall maintain at the source, for a period of at least 2 years, records of all data and calculations used to determine VOC emissions from each affected facility in the initial and monthly performance tests. Where compliance is achieved through the use of thermal incineration, each owner or operator shall maintain, at the source, daily records of the incinerator combustion chamber temperature. If catalytic incineration is used, the owner or operator shall maintain at the source daily records of the gas temperature, both upstream and downstream of the incinerator catalyst bed. Where compliance is achieved through the use of a solvent recovery system, the owner or operator shall maintain at the source daily records of the amount of solvent recovered by the system for each affected facility.

(7) Test methods and procedures.

(a) The reference methods in 1200-3-16-.01(5)(g) except as provided in 1200-3-16 - .01(5)(b), shall be used to conduct performance tests.

1. Reference Method 24 (as specified in 1200-3-16-.01(5)(g) 24.), an equivalent or alternative method approved by the Technical Secretary, or manufacturers formulation for data from which the VOC content of the coatings used for each affected facility can be calculated. In the event of dispute, Reference Method 24 shall be the reference method. When VOC content of waterborne coatings, determined from data generated by Reference Method 24, is used to determine compliance of affected facilities, the results of the Method 24 analysis shall be adjusted as described in Section 4.4 of Method 24.

2. Reference Method 25 or an equivalent or alternative method for the determination of the VOC concentration in the effluent gas entering and leaving the control device for each stack equipped with an emission control device. The owner or operation shall notify the Technical Secretary 30 days in advance of any test using Reference Method 25. The following reference methods are to be used in conjunction with Reference Method 25:

(i) Method 1 for sample and velocity traverses,

(ii) Method 2 for velocity and volumetric flow rate,

(iii) Method 3 for gas analysis, and

(iv) Method 4 for stack gas moisture.

(b) For Reference Method 24, the coating sample must be a 1 liter sample collected in a 1-liter container at a point where the sample will be representative of the coating material.

(c) For Reference Method 25, the sampling time for each of three runs must be at least 1 hour. The minimum sample volume must be 0.003 dscm except that shorter sampling times or smaller volumes, when necessitated by process variables or other factors, may be approved by the Technical Secretary. The Technical Secretary will approve the sampling of representative stacks on a case-by-case basis if the owner or operator can demonstrate to the satisfaction of the Technical Secretary that the testing of representative stacks would yield results comparable to those that would be obtained by testing all stacks.

Tenn. Comp. R. & Regs. 1200-03-16-.40

Original rule filed September 21, 1988; effective November 6, 1988.

Authority: T.C.A. §§ 68-25-105 and 4-5-202.