Memorandum
Date: 		April 30, 2019
To:		Surface Coating of Metal Can (40 CFR Part 63 subpart KKKK) Docket 
From:		Paula Hirtz, OAQPS/SPPD/MMG
Subject:		Site Visit Report for the Ball Metal Beverage Container Corporation Facility 

The U.S. Environmental Protection Agency (EPA) conducted a site visit to the Ball Metal Beverage Container (Ball) plant located at 12340 Township Road, Findlay, OH 45840, on November 16, 2017. The EPA conducted the site visit to support the development of the risk and technology review for the Surface Coating of Metal Can National Emission Standard for Hazardous Air Pollutants (NESHAP) at 40 CFR Part 63 subpart KKKK. The plant is a major source of HAP emissions and is therefore subject to the NESHAP. The EPA visitors included Paula Hirtz of EPA and Brian Palmer and Bryan Lange of Eastern Research Group, Incorporated (EC/R), contractors to EPA. Other attendees included: 
Glenn Jost, Plant Manager, Ball
Alan R. Gans, Environmental, Health and Safety Manager (EHS), Ball
Allan Yee, EHS, Ball
Rick Garcia, EHS, Ball
Sueanne Pfifferling, Pfifferling and Associates, LLC.
Sylvester Giustino, Can Manufacturers Institute (CMI)

The site visit began with a meeting and presentation that provided an overview of the Findlay plant operations for can and end making, process descriptions for all emission points, MACT applicability, emission calculations and reporting for MACT, and was followed by a tour of the plant. The information that follows was shared during the visit.
Background Information
The Ball Findlay plant is the Ball Corporations largest plant and has been in operation for 43 years. It started with all steel can manufacturing but is now mostly aluminum beverage can manufacturing with one steel food can line. The plant operates 24 hours a day, 7 days a week, on two 12-hour shifts. The Ball Findlay plant supplies aluminum cans to some of the largest beverage companies. 
Can Manufacturing Process
The Ball Findlay plant operates 3 lines; two 2-piece aluminum beverage can lines, and one 2-piece steel food can line. The plant also manufactures can ends. The production process starts with sheets of coil stamped into cups. They are then drawn into a can shape through a bodymaker. The total length of sheet coil through the plant measures 3 miles and the plant stamps 3,000 cups per minute through the cupper. Both sides of coil sheet are lubed. The process also includes trimmers to make the cans uniform in size. An on-line quality check is conducted to ensure the can height and opening meets specifications.
Before the coating is applied to the formed cans they go through washers (sodium hydroxide removes the lube and sulfuric acid etches the can surface) and a drying oven. The coating application process uses ink to print the design to the outside of the can. The ink is added manually to the reservoir using a spatula as needed and up to six colors of ink are used. A varnish coating containing HAP is applied after the ink. A bottom coater roll coats the bottom of the can. The inside coating is applied to the cans from one of the eight internal coaters. The inside coating is a phenolic epoxy which contains HAP. It is sprayed using a high efficiency airless spray application.  A bag house is used to control the inside coating overspray. The cans are then processed through a leak tester. The cans are processed through ovens after each coating application. The ovens have heating capacities ranging from 2 to 3 million BTU and residence times ranging from 10 to 20 seconds for each can. Neck flangers are used to form the curl on top of the can. The can lids are made on a separate line and the pull tabs are fastened to the lid. The colored and plain tabs are pre-lubed and additional lube is added as needed. The lube and coating for the tabs do not contain HAP. A non-HAP waterborne end seal compound is applied to the grove on the lid. The plant tour also included the materials storage area which housed several 6,000 gallon tanks for the wash coat materials and the inside and overvarnish coatings. The tab lube was contained in 5 gallon pails. 
Most of the emissions from the ink and the over varnish are emitted from the ovens versus the coating application stations. The plant uses a lithographic style coating application process to roll the waterborne ink onto the outside surface of the metal cans. The ink is mostly solid. The coatings are "applied as supplied" which means no thinning of the inks and coatings occurs at the plant, except for the over varnish.  Water is added to the over varnish as needed to maintain the proper viscosity. 

As a customer may or may not require, a white basecoat or ink is applied to the entire outside surface of the can before applying the additional design. The white ink is applied only to the areas that are not covered with the additional design. The solvent used for cleanup of printer ink is isopropyl alcohol which is not a HAP. If the ink color needs to be changed, the ink wells are cleaned with the isopropyl alcohol. 

All inside can coatings go thru a Food and Drug Administration approval process which includes shelf life testing. For steel cans, the inside coating must withstand the heat and acids and fats of the food. Several coating vendors supply all coatings to the can industry. Customer driven coating selections occasionally drive changes in the coatings to accommodate seasonal and product promotions. Changes to the inside coatings are due to the characteristics of different foods.
The conversion to waterborne coatings was a costly effort for the Findlay plant. The conversion was driven by the new source performance standard (NSPS), reasonably achievable control technology (RACT), and state implementation plans (SIP) for ozone attainment. The city of Findlay, Ohio is in attainment.

Compliance Option used by the Ball Findlay OH Plant
The Ball Findlay OH plant is a major source of HAP emissions and is therefore subject to 40 CFR Part 63 subpart KKKK. EGBE and MEK are emitted by the plant but were delisted as HAP before the compliance date of subpart KKKK. The plant employs the use of two compliance options in subpart KKKK  -  the compliant material option for the non-aseptic end seal operation and the emission rate without add-on controls option for all coatings used on the three can lines. The average monthly emission rates are below the emission limits for the 2-piece food and the 2-piece beverage cans.
General Information about the Metal Can Industry 
Additional information was shared about the metal can manufacturing industry:
 It was an industry-wide practice for facilities to install thermal oxidizers to become synthetic minors.
 Powder coating does not work for the industry.
 In metal can manufacturing, the ovens account for 85% of the emissions and the coating application process accounts for 15% of the emissions. 
 UV coating is limited to certain exterior coating used only on specific/designated can lines and cannot be used for all applications as customer needs may vary.




