/

svEPA
          United States
          Environmental Protection
          Agency
         Office of Air Quality
         Planning and Standards
         Research Triangle Park NC 27711
EPA-450/3-88-018
December 1988
Air
Protocol for
Determ!-:  ^ the Daily
Volatile organic
Compound Emission
Rate of Automobile
and Light-Duty Truck
Topcoat Operations

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                       BPA-450/3-88-018
 Protocol for
 Determining the Daily
 Volatile Organic
 Compound Emission
 Rate of Automobile
 and  Light-Duty Truck
 Topcoat Operations
      Emission Standards Division
   U.S. ENVIRONMENTAL PROTECTION AGENCY
      Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina  27711
          December 1988
     U.S. Environmental Protection Agency

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This report has been reviewed by the Emission  Standards  Division  of the
Office of Air Quality Planning and  Standards,  EPA,  and approved  for
publication.  Mention of trade names or commercial  products  is  not intended
to constitute endorsement or recommendation  for  use.  Copies  of  this
report are available through the Library Services  Office (MD-35), U.S.
Environmental Protection Agency, Research Triangle  Park, NC   27711, or
from the National  Technical  Information Service, 5285 Port Royal  Road,
Springfield, Virginia  22161.
                     PUBLICATION NO. EPA-450/3-88-018

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                       TABLE OF CONTENTS
     SUBJECT                                                   PAGE

1    INTRODUCTION                                               1-1
2    DEFINITIONS                                                2~!
3    SYMBOLS                                                    3'1
4    DAILY VOC EMISSION RATE CALCULATION                        4-1
5    TOTAL DAILY VOC GENERATED                                  5-1
6    TOTAL DAILY VOLUME SOLIDS DEPOSITED                        6-1
7    TOTAL DAILY BAKE OVEN EXHAUST CONTROL CREDIT               7-1
8    DAILY COATING USAGE                             .           8-1
9    VOC GENERATED PER GALLON OF AS APPLIED COATING USED        9-1
10   ANALYTICAL VOC CONTENT OF AS APPLIED COATINGS             10-1
11   FORMULATION SOLVENT CONTENT OF AS APPLIED COATINGS        11-1
12   FORMULATION VOLUME SOLIDS CONTENT OF AS APPLIED
       COATINGS                                                12-1
13   DAILY TRANSFER EFFICIENCY VALUES                          13-1
14   DAILY  INDIVIDUAL BAKE OVEN EXHAUST CONTROL DEVICE
       VOC LOADING VALUES                                      14-1
15   MONTHLY VEHICLE COATING SUMMARY                           15-1
16   DAILY VEHICLE COATING SUMMARY                             16-1
17   MONTHLY COATING USAGE                                     17-1
18   TRANSFER EFFICIENCY TEST PROCEDURE - IN PLANT             18-1
19   TRANSFER EFFICIENCY TEST PROCEDURE - PILOT LINE           19-1
20   ALTERNATE TRANSFER EFFICIENCY PROCEDURES FOR
       UNTESTED  BOOTHS AND/OR COATINGS                         20-1
21   TEST PROCEDURE FOR DETERMINING BAKE OVEN EXHAUST CONTROL
       DEVICE VOC  LOADING FOR SPECIFIC  COATING                 21-1
22   BAKE OVEN EXHAUST CONTROL DEVICE EFFICIENCY               22-1
23   DELETED                                                   23-1

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     SUBJECT                                                   PAGE

24   ACCOUNTING FOR CAPTURED PURGED COATING                    24-1
25   RECORDS OF WITHDRAWALS OF COATING FROM MIX TANKS OR
        CIRCULATING SYSTEM                                     25-1
26   NOTES ON ALTERNATE WEIGHTING FACTORS                      26-1
27   NOTES ON USING COMBINED BASECOAT/CLEARCOAT
       TRANSFER EFFICIENCY TEST RESULTS                        27-1
28   NOTES ON USING TRANSFER EFFICIENCY TESTS RESULTS WHEN
       THE TEST ENVELOPE IS MORE THAN ONE BOOTH LONG           28-1
29   NOTES ON USING COMBINED BASECOAT/CLEARCOAT BAKE OVEN
       CONTROL DEVICE VOC LOADING DATA                         29-1
30   NOTES ON ACCOUNTING FOR DILUTION SOLVENT ADDED BY THE
       COATING MANUFACTURER AT A SATELLITE PAINT PLANT         30-1
31   CALCULATING FORMULATION WEIGHT FRACTION SOLVENT
       OF AS SUPPLIED COATING                                  31-1
32   CALCULATING FORMULATION SOLVENT CONTENT
       OF AS SUPPLIED COATING                                  32-1
33   CALCULATING FORMULATION VOLUME SOLIDS CONTENT
       OF AS SUPPLIED COATING                                  33-1
34   RECORDKEEPING REQUIREMENTS                                34-1
35   NOTES ON USING THIS PROTOCOL TO DETERMINE
       THE DAILY VOC EMISSION RATE OF AUTOMOBILE
       AND LIGHT-DUTY TRUCK SURFACER OPERATIONS                35-1

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                                                                  ADDED 12/88
            SUBJECT                                                   PAGE

APPENDIX A  EXAMPLE CALCULATIONS                                       A-l
APPENDIX B  SUMMARY OF ADDITIONS AND REVISIONS TO
            JUNE 10, 1988 VERSION OF PROTOCOL                          B-l
                                     1 n

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                             1  -  INTRODUCTION
     This protocol  determines  the dally VOC emission  rate (pounds  of VOC
per gallon of coating solids deposited) for a  complete automobile  and
light-duty truck topcoat operation.   The protocol  considers  the following
factors:

     -Daily usage of each coating
     -VOC generated per gallon of each coating used
     -Volume solids content of each coating used
     -Daily weighted transfer efficiency of each coating used
     -Daily weighted bake oven exhaust control credit

     The protocol describes how to determine each of these factors,
including the necessary testing and recordkeeping.

     The protocol is designed for use  in cases where  (1) the topcoat
emission limit  is stated in units of pounds of VOC per gallon of solids
deposited,  (2)  compliance is to be demonstrated for each day, and (3) the
entire  topcoat  operation (i.e., all spray  booths, flash-off areas and
bake ovens  where topcoat is applied, dried, and cured; except  final off-
line repair)  is treated as  a single entity.

     The protocol uses  the  number of square feet coated  on each vehicle
 in each booth with  each coating  as the basis  for the  daily weighting of
 individual  transfer efficiency and bake  oven  exhaust  control values.
 These  data  are  also used to prorate the  total usage  of each coating  in a
month  to each of the production  days  in  that  month.   This can  be  done  in
 lieu  of directly monitoring and  recording  the usage  of each category
 each  day.   Therefore,  the  emission rate  for each  day in  a month is
 calculated  at the  end of that month.
                                    1-1

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                                                     REVISED  12/88
     Sample information sheets  and  calculations  are  provided  in  Appendix
A.  Use of these sample sheets  is  not  required by  the  protocol.   Alternative
data presentation formats may be chosen by the owner/operator.   A schematic
drawing of the sample coating line  used in the examples  is  presented in
Figure 1.  Some notes on the sample coating line are presented  in Figure  2.

     The protocol is intended as a  living document which will  be improved
as experience is gained with its use.   The protocol  is divided  into small
sections which are amenable to changes, addition of new sections and
incorporation into computer programs.   The equations are presented in a
form that is amenable to incorporation into computer programs.   In some
equations, asterisks ("*") are used to indicate  multiplication and slashes
("/")  are used to indicate division.  The protocol as presented here is
complete and must be used in its current form for  compliance determinations.

      In  using the protocol, the owner/operator must initially identify
various  test conditions  and parameters, data collection procedures and
data  presentation formats.   For example, the owner/operator needs to
choose the spray booths  and coatings  for transfer efficiency test  (Sections
18 and 19) and  a method  of  accounting  for  coating withdrawals (Section
25).   These  choices  are  subject to  review  by the appropriate regulatory
agency(ies).   The owner/operator should  therefore discuss these  choices
with  the agency(ies) before tests  are performed or data are collected.
 Pre-test review, which is  a requirement  of many regulations and  permits,
 provides an  opportunity to  identify and  resolve potential issues  in
 advance and  thereby minimize  the chances of  later  questions about the
 representativeness  or  validity of  data and the  need  for retesting or
 redesign of  data collection procedures or data  presentation  formats.

      The protocol  was  originally published on June 10,. 1988.   This printing
 includes changes and additions made in November and December  of 1988.
 The changes  and additions are summarized in  Appendix B.

                                    1-2

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                             2 - DEFINITIONS
Formulation Solvent Content - The weight of photochemical!,/ reactive
organic solvents in a specific volume of coating (pounds per gallon) as
determined using the procedures in Sections 11, 31, and 32.  Volatile by-
products of cross-linking reactions (cure volatiles) are not included in
the formulation solvent content.

Mix Tank - A coating reservoir which is connected to the circulating
system which delivers coating to the coating application equipment.
Coating and dilution solvent are added to the circulating system through
a mix tank.  If the circulating system is kept full, changes in the
coating level  in a mix tank provide useful  information for determining
the volume of coating used over a period of time.  Totes are mix tanks
when they are plugged directly into the circulating system.

VOC Generated - The amount of VOC released  from an  as applied coating
under specific application conditions, including cure volatiles released
from those coating solids which are cured in a bake oven, and recognizing
that cure volatiles are not released from coatings  solids which are not
cured in a bake oven.  (i.e. overspray coating solids)
                                   2-1

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                               3 - SYMBOLS
                                Variables
BRFRAC(M,N) -  Fraction of the total square footage coated on day N
that is coated in spray booth M and baked in oven M.   These are the bottom
row fractions in the daily vehicle coating summary for day N (decimal fraction)

BTE(I,M) - Transfer efficiency for coating I in booth M (decimal  fraction)

CA(I,J) - Analytical VOC content of the batch of coating I used in
addition J (pounds of VOC per gallon)

CDE(M) - Efficiency of control device which treats exhaust from bake
oven M (decimal fraction)

CDL(I,M) - VOC loading from coating  I to control device which treats
exhaust from bake oven M (pounds of VOC per gallon of solids deposited)

CF(I.J) - Formulation solvent content of the batch of coating I used in-
addition 0 (pounds of solvent per gallon)

CFRAC(I,M,N) - Fraction of total square footage coated in booth M on day
N that is coated with coating I.  These are the fractions in the column
for booth M coating summary for day  N (decimal fraction)

CP(I)  - Volume of coating  I that is captured by the purge capture system
in  a  single purge cycle.
                                   3-1

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DAYSQFT(I.N) - Total  square footage coated with coating I on day N
(square feet)

DCC(N) - Total bake oven exhaust control  credit for day N (pounds of VOC
per gallon of solids  deposited)

DENS(I.J) - Density of the batch of coating I used in addition J (pounds
per gallon)

DER(N) - Daily emission rate for the topcoat operation on day N (pounds
of VOC per gallon of  solids deposited)

DSD(N) - Total volume of solids deposited on day N (gallons)

DVG(N) - Total mass of VOC generated on day N  (pounds)

DVOL  (I,J,A)  - Density of the volatiles in ingredient A of the batch of
coating  I used in addition 0 (pounds per gallon)

END(I) -  Volume  level of coating I in mix tank at end of month (gallons)

GDAY(I.N)  -  Volume of coating I used on day N  (gallons)

GMON(I)  - Volume of  coating  I used in the month (gallons)

MONSQFT(I)  - Square  footage  coated with coating I in the month  (square  feet)

NPURGE(I.N)  - Number of  purge cycles  of coating I on day N

PADD(I,J) - Volume of coating  I added to mix tank in addition J  (gallons)

RADD(I,K) - Volume of dilution  solvent  added to the  mix tank  for coating
 I in addition K  (gallons)
                                    3-2

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RCA(I) - Analytical VOC content of coating I (pounds of VOC per gallon,
as applied)

RCF(I) - Formulation solvent content of coating I (pounds of solvent per
gallon as applied)

RCV(I.N) - VOC generated per gallon of coating I on day N (pounds of VOC
per gallon, as applied)

RD(I,K) - Density of dilution solvent added to the mix tank for coating
I in addition K (pounds per gallon)

RVS(I) - Formulation volume solids content of coating I, as applied
(decimal fraction)

RFRAC(I,M,N) - Fraction of total square footage coated with coating I on
day N that is coated in booth M.  These are the fractions in the row for
coating  I in the  daily vehicle coating summary for day N (decimal fraction)

START(I) - Volume level of coating I in mix tank at start of month (gallons)

TCOL(M.N)  - VOC loading to control device which treats exhaust from bake
oven M weighed for day N (pounds of VOC per gallon of solids deposited)

TCP(I,N) - Total  volume of coating I which is captured by purge capture
system on  day N (gallons)

TE(I,N)  - Transfer efficiency  for  coating I on day N  (decimal fraction)

VFS  (I,J,A) - Volume solids content of ingredient A added to the batch of
coating  I  used in addition J (decimal fraction)
                                    3-3

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VOL (I,J,A)  - Volume of ingredient  A  added  to  the  batch  of  coating  I  used
in addition  J (gallons)

VS(I,J) - Formulation volume solids content of the batch of coating I used
in addition  J (decimal  fraction)

WITH(I.P) -  Volume of coating I removed from mix tank for coating I in
withdrawal P (gallons)
WITHTOT(I) - Total volume of coating I removed from mix tank for coating
I  in the month (gallons)

WT (I.J.A) - Mass of ingredient A added to the batch of coating I used in
addition  J (pounds)

WTFRSV  (I,J) - Formulation weight  fraction solvent content of the  batch
of coating I used in addition  J (decimal fraction)

WTNR (I,J,A) - Weight  fraction water or exempt  solvent  in  ingredient A
added  to the batch  of  coating  I used in addition  J  (decimal fraction)

 WTSOLV (I.J.A)  - Weight fraction solvent content  of ingredient  A added  to
 the batch of coating I used in addition J  (decimal  fraction)

 WTVOL (I»J,A)  -  Weight fraction volatiles  content of ingredient A  added
 to the batch of coating I used in  addition J (decimal  fraction)
                                    3-4

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              Indices.  Counters,  Limits
A                    Ingredient index for formulation  calculations
B                    Number of ingredients in the formula  for a
                        coating
BC                   Base Coat
CC                   Clear Coat
I                    Coating Index
j                    Coating Addition Index
K                    Dilution Solvent Addition Index
L(i)                 Number of Additions of Coating I  in Month
M                    Booth or Oven Index
N                    Day Index
p                    Withdrawal Index
R(I)                 Number of Additions of Dilution Solvent to
                     Mix Tank for Coating I in Month
5(1)                 Number of Withdrawals from Mix Tank for
                     Coating  I in Month
T                    Number of Booths/Ovens in Topcoat Operation
V                    Number of Coatings Used
W                    Number of (Operating) Days  in Month
 Y                    Month  Index
                          3-5

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                 4 - DAILY VOC EMISSION RATE CALCULATION


     The daily VOC emission rate is calculated by dividing the total
pounds of VOC generated that day by the total  gallons of solids deposited
that day and then subtracting that day's bake  oven exhaust control  credit.

     On day N, the daily emission rate is:

     DER(N) = CDVG(N) / DSD(N)] - DCC(N)

     A sample calculation is presented in Figure 20.
                                   4-1

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                      5  -  TOTAL  DAILY  VOC  GENERATED
     The total  VOC generated each day is  calculated  by multiplying the
volume of each  coating used that day by the pounds  of VOC generated per
gallon of that  coating and summing the results.

     The VOC generated on day N is:

               V
     DVG(N) = SUM [GDAY(I.N) * RCV(I.N)]
              1=1

     A sample calculation is presented in Figure 16.
                                    5-1

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                     6 - TOTAL DAILY SOLIDS DEPOSITED
     The total  gallons of solids deposited each day is calculated by
multiplying the volume of each coating used that day by its formulation
volume solids content and by its daily transfer efficiency and summing
the results

     The solids deposited on day N are:

               V
     DSD(N) = SUM CGOAY(I.N) * RVS(I) * TE(I,N)]
              1=1

     A sample calculation is presented in Figure 17.
                                    6-1

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           -  7 - TOTAL DAILY BAKE OVEN EXHAUST CONTROL CREDIT
     The bake oven exhaust control credit is determined for each day by
weighting together the individual bake oven control device VOC loading
values for that day and the previously determined incinerator efficiencies
The daily weighting factors are the fractions of the total square footage
coated that day that are coated in the spray booth associated with each
bake oven.   These weighting factors are the bottom row fractions in the
daily vehicle coating summary.

     The bake oven exhaust control credit on day N is:

               T
     DCC(N)  = SUM [TCDL(M,N)  * CDE(M)  * BRFRAC(M.N)]
              M-l

     A sample calculation  is  presented in Figure 19.
                                  7-1

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                         8 - DAILY COATING USAGE


     The volume of each coating used each day can be calculated by
prorating the volume of that coating used in a month to each day in the month,
The prorating factor is the ratio of the total square footage coated with
that coating on the day to the total square footage coated with that
coating in the month.

     The volume of each coating used on day N is:

     GDAY(I.N) = GMON(I) * DAYSQFT(I.N) / MONSQFT(I)

     A sample calculation is presented in Figure 14.

     If the owner/operator chooses to make an adjustment for captured
purge coating, then TCP(I.N) should be subtracted from the above result.

     The owner/operator may elect to.determine the daily usage of a
coating directly by measuring the start-of-day and end-of-day volume of
the  coating  in its mix  tank, additions of the coating or dilution solvent
to  the mix tank, and withdrawals of coating  from the mix tank.  The daily
usage  is equal to:


     STARTDAY  - ENDOAY  +  ADDITIONS  - WITHDRAWALS
                                    8-1

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  9 - DAILY CALCULATION OF VOC GENERATED PER GALLON OF EACH COATING USED


     The amount of VOC generated per gallon of each coating used is
calculated each day using the analytical VOC content of the as  applied
coating, formulation solvent content of the as applied coating  and the
daily transfer efficiency for that coating.

     The amount of VOC generated per gallon of coating I used on day N  is

     RCV(I.N) = RCF(I) * [1 - TE(I,N)] + RCA(I) * TE(I,N)

     A sample calculation is presented in Figure 15.
                                   9-1

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            10 - ANALYTICAL VQC CONTENT OF  AS  APPLIED COATING
     The analytical  VOC content of  an as  applied coating can  be calculated
from records on the additions of coating  and dilution solvents to that
coating's mix tanks during the month.

     For each addition of coating,  the following information  is needed:

     - Gallons of coating added
     - Analytical VOC content by EPA Method 24 (pounds by VOC per gallon)
       of the production batch from which the addition was made

     For each addition of dilution solvent, the following information is needed.

     - Gallons added
     - Density (pounds per gallon)

     The owner/operator  may  elect  to have the EPA Method 24 analysis
 performed  by  the coating supplier  or manufacturer.  The owner/operator
 may  elect  to  have the  dilution  solvent density value provided  by the
 solvent  supplier or manufacturer.  All other information should be
 available  from the  owner/operator  records of additions  of coating and
 dilution solvent to mix  tanks.   Sample records are presented  in Figure  11;

      At  the option  of  the owner/operator, a fixed  (maximum) analytical  VOC
 content  value can  be used for each coating  as long as the use of such
 values does not  underpredict the emission  rate  of  the topcoat operation.
                                    10-1

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     The analytical  VOC content of the as  applied coating I  (pounds of
VOC per gall-on of coating)  is equal  to:
          SUM  CPADD(I.J) * CA(I,J)] + SUM  [RADD(I.K)  * RD(I,K)]
          J=l                          K=l
RCA(I) =	

          L(I)             R(D
          SUM  PADD(I.J) + SUM  RADD(I.K)
          J-l              K-l
     A sample calculation is presented in  Figure 13.

     For waterborne coatings, if the precision adjustment factors in
Reference Method 24 are used by the enforcing agency, the resulting
analytical VOC content should never be less than the formulation solvent
content.  If the adjusted analytical VOC content is less than the formulation
solvent content, then the analytical VOC content should be set equal to
the formulation solvent content.  That is:

     If CA(I,J) LESS THAN CF(I,J) THEN CA(I.J) = CF(I.J)
                                   10-2

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        11 - FORMULATION SOLVENT CONTENT OF AN AS APPLIED COATING
     The formulation solvent content of an as applied coating can be
calculated from records on the additions of coating and dilution solvents
to that coating's mix tanks during the month.

     For each addition of coating, the following information is needed:

     - Gallons of coating added
     - Formulation solvent content (pounds of solvent per gallon) of the
production batch from which the addition of as supplied coating was made.

     For each addition of dilution solvent, the following information.is
needed:
     - Gallons added
     - Density (pounds per gallon)

     The owner/operator should obtain formulation solvent content data
for the as supplied coating from the coating supplier or manufacturer.
These data should be generated using the procedures described in Sections
31 and 32.  The owner/operator may elect to have the dilution solvent
density value provided by the solvent supplier or manufacturer.   All
other information should be available from the owner/operator records of
additions of coating and dilution solvent to mix tanks.   Sample  records
are presented in Figure 11.

     At the option of the owner/operator, a fixed (maximum)  formulation
solvent value can be used for each coating as long as the use of such
values does not underpredict the emission rate of the topcoat operation.
                                   11-1

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     The formulation solvent content of the as applied coating I (pounds
of VOC per gallon of coating) is equal  to:

              L(D                           R(I)
              SUM   [PADD(I.J) * CF(I,J)] +  SUM  [RADD(I.K)  * RD(I.K)]
              J-l                            K-l
     RCF(I) = 	

              L(D             R(D
              SUM  PADD(I.J) + SUM  RADO(I.K)
              J-l              K-l
                                   11-2

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      12  -  FORMULATION VOLUME SOLIDS CONTENT OF AS APPLIED COATINGS
     The formulation  volume  solids content of an as applied coating can
be calculated from records on the addition of coating  and  dilution solvents
to that coating's mix tanks  during the month.

     For each addition of coating,  the following  information  is  needed:

     - Gallons of coating added
     - Formulation volume solids content of  the production batch from which
       the addition of as supplied coating was  made.

     For each addition of dilution solvent,  the following information is
needed:

     - Gallons added

     The owner/operator  should obtain  formulation volume solids content
 data for the as  supplied coating from  the coating supplier or manufacturer.
 These  data should be generated using  the procedure in Section 33.  All
 other information should be available  from  the owner/operator records of
 additions  of coating and dilution" solvent to mix tanks.  Sample records
 are presented in Figure  11.

      At the option of the owner/operator, a fixed (minimum)  formulation
 volume solids value  can  be  used  for each coating as long  as  the use  of
 such values does not underpredict the emission rate of  the topcoat
 operation.
                                    12-1

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The volume solids content of the as applied coating I is equal to:
         SUM  [PADD(I.J) * VS(I,J)]
         J-l
RVS(I) =
                          R(D
         SUM  PADD(I.J) + SUM  RADD(I,K)
         J*l              K-l
                               12-2

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                      13 - DAILY TRANSFER  EFFICIENCY
     For each coating transfer efficiency  shall  6e  determined  each  day  by
weighting together the previously determined individual  booth  transfer
efficiencies for that coating.  The individual  booth  transfer  efficiencies
are the values for individual  booths [or groups (parallel, and/or series)
of booths] determined by the procedures  in Sections 18,  19 and 20.
The daily weighting factors for each coating are the fractions of the
total square footage coated with that coating that  day that are coated  in
each booth [or group of booths] in which that coating is used.  These
weighting factors are the coating row fractions in  the daily vehicle
coating summary.  These weighting factors  provide the relative amount  of
solids deposited in each booth.  An example calculation  is presented in
Figure 10.

     The daily transfer efficiency for each coating is  calculated by the
following equation.
TE(I.N) =
            T
           SUM [RFRAC(I.M) / BTE(I.M)]
           M-l

     Note that since the weighting factors give the relative amount of
solids deposited in each booth, dividing a weighting factor by the
appropriate transfer efficiency tells the amount of solids sprayed.
                                   13-1

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    14  -  DAILY  INDIVIDUAL BAKE  OVEN  CONTROL  DEVICE  VOC  LOADING VALUES


     Bake oven  exhaust control  device VOC loading values are determined
each day for each bake oven which is vented  to a VOC control device by
weighting together the previously determined coating specific bake oven
control device  VOC loading values for each coating used in the spray
booth(s) associated with that bake oven.  The weighting factors are the
fractions of the total square footage coated that day in the spray booth(s)
associated with the bake oven that were coated with each coating used in
that spray booth(s).

                  V
     TCDL(M.N)  = SUM [CDL(I.M) * CFRAC(I,M,N)]
                 1-1

     A sample  calculation  is presented  in Figure 18.

     As  an  alternative,  the  source  owner or  operator may  choose to  set

                    V
     TCDL(M.N) =  MIN CDL(I.M)
                   1=1
                                    14-1

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                   15 - MONTHLY VEHICLE COATING SUMMARY
     For each month, calculate the total  number of square feet coated
with each coating.  These values can be calculated by summing the daily
totals from the daily vehicle coating summary for each day in the month.
If the owner/operator elects in Section 16 to use equivalent vehicles
instead of square feet, then equivalent vehicles should be used in this
Section too.
                   W
     MONSQFT(I) = SUM DAYSQFT(I,N)
                  N-l
A sample monthly vehicle coatiny summary is shown in Figure 5.
                                   15-1

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                    16 - DAILY VEHICLE COATING SUMMARY
     The coatings used and the number of square feet coated with each
coating in each spray booth are determined daily.  The square foot figures
are determined from the specifications for each type or style of vehicle
coated.

     For each day, the total square feet coated with each coating in each
booth is calculated.  The fraction of the total square feet coated in
each booth that is done with each coating and the fraction of the total
square feet coated with each coating that is done in each booth are also
calculated each day.  These two items are the coating column fractions
(CFRAC) and coating row fractions (RFRAC) in the daily vehicle coating
summary.  The fraction of the total  square feet coated each day that is
done in each booth is also calculated.  This is the bottom row fraction
in the (BRFRAC) daily vehicle coating summary.   A sample daily vehicle
coating summary is shown in Figure 4.

     The owner/operator may elect to substitute "equivalent vehicles",
and appropriate documented fractions thereof, for square footage values.
Equivalent vehicle means a typical vehicle selected as the basis for
equating an increase or decrease in  the fractional  size of all  other -
vehicles or portions of vehicles coated in a particular topcoat operation
calculated to the nearest 0.01 vehicle.  A sample equivalent vehicle
calculation is presented in Figure 22.

     The owner/operator may elect to set the daily number of square feet
of in-line repair work done with each coating equal  to 4 percent of total
square footage (excluding in-line repair) coated with that coating on that
day.  A sample calculation is presented in Figure 23.
                                   16-1

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     A sample of the information needed for each vehicle processed is
provided in Figure 3.   The owner/operator may el.ect to record this information
or just use this information to create running daily totals for the daily
vehicle coating summary.
                                   16-2

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                        17  -  MONTHLY  COATING  USAGE
     The monthly usage of each as  applied  coating  can  be  determined  from
the start-of-month and end-of-month  volume of that coating  in  its  mix
tank, records of additions of coating and  dilution solvent  to  the  mix
tank, and records of withdrawals of  coating from the mix  tank.

     The following equation can be used to determine the  monthly usage  of
an as applied coating.

                                  L(I)             R(D
     GMON(I) = START(I) - END(I) + SUM  PADD(I.J)  + SUM  RADD(I,J)
                                           - SUM  WITH(I.P)
     A sample calculation is presented in Figure 12.
                                   17-1

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                                                          REVISED  11/88
            18  -  TRANSFFR  EFFICIENCY TEST PROCEDURE - IN PLANT
Applicability


     This procedure can be used to determine  by  in-plant testing the transfer
efficiency with which specific coatings  are applied in an automobile or
light-duty truck topcoat operation.  The transfer efficiency of color and
clear coats applied in main color booth(s) must  be determined with this
method or with the pilot line test method described  in Section 19.  The
choice of in-plant or pilot line test is made by the  owner/operator.  At
the option of the owner/operator, the transfer efficiency  of other coatings
applied in main color booth(s) (e.g., blackout)  and  coatings applied in
other booths (e.g.,  separate "interior" color booth,  tutone or in-line
repair) may  be determined by this procedure,  by  the  pilot  line  test
procedure described  in Section 19, or by the alternate procedure  described
in  Section ZU  (Alternate Transfer Efficiency Procedure for Untested Booths
and/or Coatings).  The  results determined by this procedure,  the  pilot
line  test  procedure  described  in Section 19, and the alternate procedure
described  in Section 2U  are  combined for each coating each day in the
Daily  Transfer Efficiency  Values section (Section 13).
      This procedure for transfer efficiency  uses the measured weight of
 coating solids applied to vehicles  or foiled vehicles in production
 facilities.
                                    18-1

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                                                          REVISED  11/88
Transfer Efficiency Procedure

A. The owner/operator selects  the  spray booth(s) to be Included in the
test.  A main color booth must  be  included in the test.  Each identical
parallel booth in the same assembly  line need not be tested.

B. The owner/operator selects  the  coatings to be used in the test.  This
procedure can be run for each  coating  used, but it is not necessary to
test every coating.  The coatings  may  be grouped based on processing
sequence.  Only one coating need be  tested from each group and the result
used for all  of the coatings in that group.  Some sample groupings are
straight shades, non-metallic  basecoats, metallic basecoats, mica basecoats
and  clear coats.  These sample groupings are not the only possible groupings,
Others may be appropriate based on processing sequence (e.g., the processing
sequence for metallic basecoats and mica basecoats may be the same or
silver basecoat may be applied with only air spray while all other metallic
basecoats are applied with air spray and electrostatic spray).  The
owner/operator must explain in the test report  the groupings used and the
 rationale for choosing a particular coating from each group for testing.
To  simplify  testing and more closely represent  actual  process  conditions,
basecoat and  clear coat  can be tested together  at  the  owner/operator
option  as noted later in this procedure.

C.   Select an  area in the  facility for the body weighing  or foil  weighing
which  has  relatively constant temperature  and minimal  air movement.

 D.   Topcoat  must  be the  only  coating applied during  the  test.   If the
 body is weighed,  weight  loss from all other materials  must  be  accounted for
 in  the initial  test weight.
                                   18-2

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                                                          REVISED  11/88
E.  A minimum of two foiled or unfoiled  vehicle  bodies  (or major
subassemblies thereof)  are to be  weighed to  determine weight of solids
applied.  The test is considered  acceptable  if each  final weight gain
result is within 10 percent of the average weight gain.

F.  Identify and preweigh vehicle bodies or  major  subassemblies to  be
painted to the nearest 0.05 Ib.  If foil method  is  used preweiyh all
available foil and tape.  After vehicle is foiled,  reweigh  all  unused
foil and tape to determine beginning weight  of  test  foil  and  tape by
difference.

G.   Isolate  selected paint material at  each spray  station by  using  an
auxiliary paint  system  or paint  pots.   Alternatively, at the  owner/
operator option,  coating  usage may be measured from the main  circulating
system tanks.

H.   At tne  owner/operator option,  determination of the amount of material
used during  the  test may  be  made  by weight  or volumetric measurement as
 follows:

 Weight Measurement

      1.  Weigh the tank of reduced paint after  all  supply and  return
          lines have been filled, to nearest 0.05 Ib.

      2.  Connect the paint tank  to the system  and  paint  the  test vehicles
          or targets.

      3.  Reweigh the tank to nearest O.Ob Ib.
                                    lb-3

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                                                                       REVISED 11/88
     4.   Determine weight  of  paint material used by subtracting final
         weight of tank from  the initial weight of tank.

     5.   Obtain  paint  samples for weight solids determination.

     6.   The initial and final weighings of the paint tank must both
         be done  with  the  tank pressurized or both be done with the
         tank not pressurized.

Volume Measurement

     1.   a.  Verify  diameter of  paint  tank.

         b.  Determine level  in  paint  circulating tank  prior to test, to
             nearest 0 .1  inch.

     2.  Paint the test vehicles or targets.   (It  is suggested that the
         number of units  painted should be chosen to achieve approximately
         a 3" to 4"  drop in a typical  circulating  tank.)

     3.  Determine the paint level  after  the test to the nearest U.I inch.

         Paint usage from a  cylindrical tank is  determined  as  follows:

         Gallons Paint Used  s \  \ r^h -  Volume occupied by  all other equipment
                 job          231n     in the  measured  section of  the  tank.


         231  = Cubic inches  per gallon

           J|  = 3.141b
                                   18-4

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                                                                     REVISED  11/88
           r = Radius of tank in inches

           h = Drop of paint level in tank in inches

           n = Number of vehicle bodies or major subassemblies painted to
              achieve the measured liquid level  drop in circulating tank

     4.   Obtain  paint samples for  testing weight solids fraction and
         coating  density.

J.  Reweigh the  painted  test  vehicles,  foil  or components to the nearest
    U.U5 Ib after paint  has cured, and  cooled.

K.  Determine  the weight solids of the  paint samples using ASTM-D 2369-86.

L.  Determine  the coating  density using ASTM-D 1475  (Ib/gallon).

M.  The transfer efficiency  is  calculated  by dividing  the weight of paint
    solids applied to the vehicle or foil  by the weight of  paint solids  used.

Calculation for Paint Usage by  Weight

       Transfer Efficiency - average weight gain of target  	
                            (average weight coating  consumed  per job)  x
                                            (weight fraction solids)*

Calculation for Paint Usage by Volume

        Transfer  Efficiency * average weight gain of target	
                             (average gallons coating used per job)  x  (density)  x
                                              (weight  fraction solids)*

 The test result  for coating  I  in  booth M is  referred to in the section on
 Daily Transfer Efficiency as BTE(I.M).
                                    18-5

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                                                         REVISED 11/88
* If more than one coating  Is  sprayed  on  each test vehicle (e.g. basecoat
and clear coat),  then  the denominator  Is  the sum of all solids sprayed.

General  Comments

At the owner/operator option,  separate transfer efficiency values for BC and
CC can be determined directly  by  coating  at least two  vehicles with BC only
and at least two vehicles with BC/CC.   The average weight gain  per job for
CC only can be determined by subtracting  the average weight gain per job for
BC only from the average weight gain per job  for BC/CC.

Frequency of Certification

Transfer efficiency tests must be conducted for an  initial  compliance
test.  The owner/operator must review the operating  conditions  annually
thereafter.  The most recent test results remain valid as long  as  the
owner/operator demonstrates that no significant changes have  occurred  in
paint technology or processing.  Significant  product,  processing,  material
or application equipment changes will  necessitate  reevaluation  of  the
transfer efficiency of the operations which have  been  modified.  Such
 complete  reevaluation must  be done  as soon as practicable (not  later than
180  days after start-up) after start-up and stabilization of  the new
 product,  process, material  or application equipment.  The results of this
 reevaluation  (i.e., new transfer efficiency values)  must be used retro-
 actively  to  the  start-up of the new product, process, material  or application
 equipment.   Reevaluation is not necessary for:

     A.   Model year product changes, unless there are  significant changes
         in  size  and shape  of  the typical  vehicle.

     B.  Processing and  material  changes  such as new model year or special
         order colors  of the same formula type, minor  changes in line
         rate, minor changes in processing sequence, minor  changes  in
         equipment types, etc.
                                    18-b

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                                                          ADDED 11/88
           19 - TRANSFER  EFFICIENCY TEST PROCEDURE - PILOT LINE
A - Applicability
     This procedure can be used to determine  by  pilot  line testing the
transfer efficiency with which specific coatings are applied in an
automobile or light-duty truck topcoat operation.  The transfer efficiency
of color and clear coats applied in main color booth(s) must be determined
with this method or with the in plant test method  described in Section
Ib.  The choice of in-plant or pilot line test is  made by  the owner/operator.
At the option of the owner/operator, the transfer  efficiency of other
coatings applied in main color booth(s) (e.g., blackout) and coatings
applied in other booths  (e.g., separate "interior" color booth, tutone  or
in-line repair) may be determined by this procedure, by the in-plant  test
procedure described in Section la, or by the alternate procedure  described
in Section 20 (Alternate Transfer Efficiency Procedure for Untested Booths
and/or Coatings).  The  results determined by this  procedure, the  in-plant
test  procedure described in Section 18, and the  alternate  procedure
described in Section 2U  are combined for each coating  each day  in the
Daily Transfer Efficiency Values section (Section  13).
                                    19-1

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                                                          ADDED 11/88
B -

This procedure for transfer efficiency  uses  the measured weight of coating
solids applied to vehicles  or foiled vehicles in pilot line facilities.
The production line process is simulated  in  the pilot line.  The pilot
line data are validated against production line data to verify that a
credible simulation has been carried  out.  Once the  pilot line data have
been validated, the pilot TE results  are  adjusted to improve the correlation
with production line data.

C - Selection of Spray Booth(s) and Coating(s) to be Tested

1.  The owner/operator selects the production spray  booth(s)  to  be  simulated
in the pilot line test.  Each identical parallel booth  in the  same  assembly
line need not be simulated separately.

2.  The owner/operator selects the coatings to be  used  in  the test.   This
 procedure can be run for each coating used,  but  it  is not  necessary  to
 test  every  coating.  The  coatings may be grouped by  the owner/operator
 based  on  processing sequence.  Only one coating  need be tested from each
 group and the result used  for all of the coatings in that  group.  Some
 sample groupings are straight  shades, non-metallic basecoats, metallic
 basecoats,  mica  basecoats  and clear coats.  These sample groupings are
 not the  only  possible  groupings.  Others may be appropriate based on
 processing  sequence (e.g., the sequence for metallic basecoats and mica
 basecoats may be the same  or silver basecoat may be applied with only air
 spray while all  other metallic basecoats are applied with air spray and
 electrostatic spray).   The owner/operator must explain in the test report
 the groupings used and the rationale  for choosing a particular coatir
 from each group for testing.  To simplify testing and more closely
 represent actual process conditions,  basecoat and clear coat  can be
ing
                                    19-2

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                                                      ADDED  11/88
tested together at the owner/operator option as noted later in this
procedure.  The coatings used  in the pilot test must be coatings  that are
used in the plant (i.e., same  manufacturer, product code and solvent
reduction conditions).

D - In-Plant Survey and Data Collection

1.  The owner/operator conducts an in-plant survey of the spray booth(s)
to be simulated in the test to determine the operating parameters.

     The  following parameters must be noted:

     - Number of spray stations
     - Type and number of spray guns at each spray station
     - Portion of vehicle coated at each spray station

     Additional parameters may  be noted at  the option of the  owner/operator.
These additional  parameters could include any  or all of the following:
 (Note:   The more  parameters that are noted  in  the  plant and faithfully
 reproduced  in  the pilot  line  test,  the greater the likelihood of  the  pilot
 line  test producing  acceptable  results which pass  the  tests for data  validity.)

      "Fluid nozzles  and  tips
      °A1r pressures  at  the  heel  of  guns
      ••Electrostatic  voltage settings
      "Reciprocator  trigger  points
      "Fluid delivery rate  per gun
      "Open gun times
      °Paint temperature
      "Paint viscosity
                                    19-3

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                                                         ADDED 11/88
     "Analytical  weight  solids
     °Fan  width
     °Dry  film thickness
     °Gun  to target  distance
     "Resistivity of paint
     "Line speed  adjusted to  plant  specifications
     °Traverse speed (strokes per minute  for  recips,  cycles  for bells)
     "Contour bar for reciprocators should  be designed  for  vehicle
      being sprayed
     °Booth balance
     °Booth downdraft (Ifpm)
     "Booth temperature
     "Booth relative humidity
     "Bell RPM
     °Bell shaping air
     "Bell and  recip. angles
     "Set  zone  pressure  to  those at the process  of interest

     The in-plant values for  each  parameter noted  must  be recorded  and
presented  in the test report.  In  situations  where the  coating of interest
is applied in two or more "identical" parallel booths,  the  noted parameters
must be measured in at least  two of these booths.   The  individual booth
measurements and average measurement must be presented  in the test  report.

2.  For each coating to be tested,  the owner/operator determines the
average weight of solids sprayed per vehicle in the production booth(s)
to be simulated.  This  is to be done either by determining the average
mass of coating used per vehicle and multiplying by the analytical  weight
solids content,  or by determining the average volume of coating used per
vehicle and multiplying by the analytical coating density and  by the
analytical weight solids content.

                                     19-4

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                                                          ADDED 11/88
     The averaye mass or volume  of  coating  used per vehicle may be
determined from usage on a  block of vehicles as in the in-plant TE test,
from direct measurements (e.g.,  use of  temporary  in-line meters), or from
gun on times and fluid flow rates.  (See  Parts L-7 and L-8 of this section.)
In situations where the coatiny  of  interest is applied in two or more
"identical" parallel  booths, coating  usage  per vehicle must be determined
usiny data from at least two of  these booths.

3.  For each coating to be tested,  the owner/operator determines  the
average in-plant dry film build  for Class I and Class II areas.   This is
to be done by  taking before and after dry film build  measurements on at
least two vehicles.   (See Part L-6  of this section).   At least  one before
and  after dry  film build measurement must be made for each  square foot
of Class  I surface area coated  per vehicle.  These measurements must be
uniformly distributed  over the  Class I area of the vehicle, with the  same
distribution used for before and after measurements.   At  least  two before
 and  after dry  film  build measurements must be made for each square foot
 of Class  II  surface  area coated per vehicle.  [Large flat  interior panels
 (e.g.,  interior of  commercial panel vans)  may be treated as Class I  area
 for dry film build  measurements.]  These measurements must be uniformly
 distributed over the Class II area of  the  vehicle, with the same distribu-
 tion used for before and after  measurements,  (See Part L-5 of this
 section.)  In situations where  the coating of interest is  applied in two
 or more "identical" parallel  booths,  the vehicles on which the film build
 measurements are made must be coated in  at least two of these  booths.

 4.  The  owner/operator calculates  the overall  averaye dry  film build by
 weiyhtiny toyether tne averaye  Class I and Class II  film builds  by the
 square feet of Class  I and Class II  area coated  per  vehicle.
                                    ly-b

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                                                         ADDED 11/88
E - Pilot Line Set-Up

1.  Select an area in the pilot  facility for the body weighing or foil
weighing which has relatively  constant temperature and minimal air movement.

2.  Topcoat must be the only  coating  applied during the test.  If the
body is weighed, weignt loss  from  all other materials must be accounted
for in the initial test weight.

3.  Prepare the pilot line to simulate the in-plant conditions.  The pilot
line must use the same number of spray stations or steps as there are in-
plant.  At each station the same type and number of gun(s) must be used and
the same portions of the vehicle must be coated.  Additional  parameters,
documented in-plant are set in the pilot.  The  pilot  line values for each
parameter that was documented in-plant must be  recorded and presented in
the test report.  Portions of the vehicle which are not designated for
coating in-plant must not be  coated to a greater extent in the pilot
facility than they are coated in-plant  (i.e., overs pray that  unavoidably
lands  in these areas in plant is acceptable in  pilot, but intentional
excess coating of undesignated areas in  the  pilot test is not acceptable).
 F -  Pilot Line Test

 1.   A minimum of two foiled or unfoiled vehicle bodies  (or major subassem-
 blies thereof) are to be weighed to determine weight  of  solids  applied.
 The  test  is  considered  potentially acceptable, subject  to pilot line  data
 validation,  if each final weight gain result is within  10 percent of  the
 average weight gain.
                                   19-6

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                                                          ADDED 11/88
2.  Identify and preweigh vehicle bodies  or major subassemblies  to be
painted to the nearest U.Ob Ib.   If  foil  method  is used  preweigh all
available foil and tape.  After vehicle is foiled,  reweigh  all  unused  foil
and tape to determine beginning  weight  of test foil  and  tape  by  difference.

3.  Isolate selected paint material  at  each spray station  by  using  an
auxiliary paint system or paint pots.  Alternatively,  at the  owner/operator
option, coating usage may be measured from the main  circulating  system tanks,

4.  At  the  owner/operator option, determination  of the amount of material
used during the test may be made by weight or volumetric measurement as
follows:
    Weight  Measurement

    i.  Weigh the  tank  of  reduced paint  after all supply and return lines
        have  been  filled,  to nearest U.Ub Ib.

    ii.  Connect the paint  tank  to the  system and  paint  the.test vehicles
        or targets.

   iii.  Reweigh the tank to nearest O.Ub Ib.

    iv.  Determine weight of paint material  used by  subtracting  final
         weight of tank from the initial  weight  of tank.

     v.  Obtain paint samples for weight  solids  determination.

    vi.  The  initial and final  weighings of the  paint  tank  must  both
         be done with the tank pressurized or both be  done  with  the
         tank not  pressurized.
     Volume Measurement

     i.   a.   Verify diameter of  paint tank.
                                    19-7

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                                                       ADDED 11/88

       b.  Determine level  in paint circulating tank prior to test, to
           nearest 0.1 inch.

  ii.  Paint the test vehicles or targets.  (It is suggested that the
       number of units painted should be chosen to achieve approximately
       a 3" to 4" drop in a typical circulating tank.)

  iii.  Determine the paint level after the test to the nearest 0.1 inch.

        Paint usage from a cylindrical tank is determined as follows:

        Gallons Paint Used =  ||  r2h -  Volume occupied by all other equipment
                job           231n     in the measured section of the tank.

        231 = Cubic inches per gallon

          || = 3.1416

           r = Radius of tank  in  inches

           h = Drop of paint  level  in tank in inches

           n = Number of vehicle  bodies or major subassemblies painted to
              achieve the measured liquid level drop  in circulating  tank

    iv.   Obtain  paint samples for testing weight solids fraction  and  coating
         density.

5.  Reweigh the  painted  test  vehicles,  foil  or  components  to the  nearest
0.05 Ib  after  paint  has  cured, and cooled.

6.  Determine  the weight solids  of the paint samples  using ASTM-D 2369-86.

7.  Determine  the coating  density using ASTM-D  1475 (Ib/gallon).

                                   19-8

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                                                           ADDED 11/88
                                      *

8.  For each coating tested,  determine  the  average weight of solids
sprayed per vehicle in  the  pilot  test.  This is done either by multiplying
the average mass of coating used  per vehicle by the analytical weight
solids content, or by multiplying the average volume of coating used per
vehicle by the analytical  coating density and by the analytical weight
solids content.

9.  For each coating tested,  the  owner/operator determines the average
pilot line dry film build  for Class  I and Class II areas.  This is to be
done by taking before and  after dry  film  build measurements on at least
two vehicles.  (See Part L-6  of this section.)  At least one before and
after dry film measurement must be made for each square foot of Class I
area coated per vehicle.  At  least two  before and after dry film build
measurements must be made for each square foot of Class II surface area
coated per vehicle.  The locations for  film build measurements must be
uniformly distributed over the Class I  and  Class II areas  on  vehicle
with the same distribution used for before  and after measurements.   (See
part L-b of this section.)

10.  The owner/operator calculates the overall  average pilot  line dry
film build by weighting together the average Class  I and Class II film
builds by the  square feet of Class I and Class  II  area coated  per vehicle.

G - Pilot Line Data Validation

1. All  of  the  following tests must be met (except  as  described  in Part K)
in order for  the pilot data for  a particular coating to be considered  valid.
 If any of  the following tests  are not met, the pilot data  are not  valid
and  cannot  be  used  to  calculate  in-plant transfer  efficiency.   (See  Figure
24.)
                                    19-9

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                                                          ADDED 11/88
2.  The average weight of solids  sprayed per vehicle in the pilot test
must be within or equal  to ^20 percent of the average weight of solids
sprayed per vehicle in-plant.

3.  The overall average dry  film  build  in  the pilot test must be within or
equal to +_ 20 percent of the overall  average dry film build in-plant.

4.  The percent change in weight  of solids  sprayed per vehicle  from plant
to pilot and the percent change in  overall dry film build from  plant to
pilot must be within 20 percentage  points  of each other.

    If A - Solids sprayed pilot - Solids  sprayed plant   *100
                    Solids sprayed  plant

    and B » Overall film build pilot -  Overall  film build plant  *100
                        Overall  film build plant

then the absolute value of A - B  must be  less  than or equal to  20.

H - Calculation of Pilot Line TE

1.   If  all  the pilot  line data validation tests are  satisfied,  then the
pilot line TE  is calculated by dividing the weight  of paint solids
applied to  the vehicle  or foil by  the weight of paint solids  used.

Calculation  for  Paint Usage by Weight  (See Figure  25.)

Pilot Transfer Efficiency = average weight gain of target	
                             (average weight coating consumed per job) x
                             (weight  fraction solids)*
                                   19-10

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                                                           ADDED 11/88
Calculation for Paint Usage by  Volume

Pilot Transfer Efficiency = average weight  gain  of  taryet	
                            (average gallons  coating  used  per job) x
                            (density) x  (weight  fraction solids)*

*If more than one coating is sprayed on  each  test vehicle  (e.g., basecoat
and clear coat), then the denominator is the  sum of all solids  sprayed.

I - Adjustment of Pilot Line TE

1.  The pilot line TE values must be adjusted based on  the differences  in
average weight solids sprayed per vehicle and overall average dry  film
build between the pilot line and tne plant.  (See Figure 26.)   The adjusted
values may be used in the section on Daily  Transfer Efficiency. The
adjusted pilot line test result for  coating I in booth  M  is referred  to
as BTE(I.M).

BTE(I,M) » Pilot TE * Solids sprayed pilot * Overall  film  build plant
                      Solids sprayed plant   Overall  film  build pilot

J - Frequency of Certification

1.  Transfer efficiency  tests must be conducted for an  initial  compliance
test.  The owner/operator must  review the operation conditions  annually
thereafter.  Significant product, processing, material  or application
equipment  changes will necessitate complete  reevaluation  of the transfer
efficiency of the operations which have been modified.   Such complete
 reevaluation must be  done  as soon as  practicable (not later than 18U  days
after  start-up) after start-up  and stabilization of the new product,
 process, material or application equipment.  The result of this reevaluation
                                  19-11

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                                                           ADDED 11/88
(i.e., new transfer efficiency  values) must be used  retroactively to the
start-up of the new product,  process, material, or application equipment.
Reevalnation is not automatically  necessary for:

    i.  Model  year product  changes, unless there are significant changes
        in size and shape of  the typical  vehicle.
    ii.  Processing and material  changes  such as new model year or special
         order colors of the same formula type, minor  changes  in line
         rate, minor changes in processing  sequence, minor changes in
         equipment types, etc.

2.  If no significant changes occur over a year, the owner/operator must
still   revalidate and readjust the pilot test  data  annually.   (See Figure  27.)
This is done by conducting an annual  in-plant survey of  average weight  of
solids sprayed per vehicle and average Class  I  and Class II  dry film
build  for each coating previously tested on the pilot  line.   (These data
should be collected in the same manner as in  the initial  pre-test survey.)
The pilot line test data are then revalidated against  the new in~plant
data as described in Parts G and K of this section. If  all  the  required
tests  are passed,  then the  pilot data are still  valid  and new adjusted  TE
values are  calculated as described in Parts I and  K of this  section.   If
the pilot data are  no  longer valid, then a new TE  test must  be conducted.
 (Note:  If  a  coating that was used in the most recent  pilot  test  is  no
longer used in-plant,  then  the annual  revalidation and readjustment  may be
done using  another  coating  from the same group of  coatings.)

3.  Similarly,  at  the  owner/operator  option, the effect of minor process
 or product  changes  on  transfer efficiency may be taken into account  at
                                   19-12

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                                                              ADDED 11/88
   any time without necessarily having to conduct a complete new pilot line
   test.  This may be done by following the procedure in part J-2 of  this
   section.  If the pilot test data are still  valid compared to the new in-
   plant data, then new adjusted TE values may be calculated without  performing
   a new pilot TE test.

   K - General Comments

        At the owner/operator option, separate TE values for BC and CC can
   be determined directly by coating at least two vehicles with BC only and
   at least  two vehicles with BC/CC.  The average weight gain per job for CC
   alone can be determined by subtracting the average weight gain per job
   for BC only from the average weight gain per job for BC/CC.

        The  BC only vehicles and  the BC/CC vehicles must meet the within 10
   percent weight gain tests (Part F-l) for the test to be considered
   potentially valid,  subject to  pilot line data validation.

        The  BC/CC vehicles must  pass  all  the  pilot line data validation
   tests in  Part la.  The BC  only  vehicles must pass the test in Part G-2.
   The  BC  only vehicles do not  have to be  assessed witn  respect  to the test
   in Part G-3, G~4 and G-5  (i.e., there  is no need to  collect BC only film
   build  data in  the  plant).

         The  adjustments to  pilot  BC and  pilot CC TE  should  be made as  follows;

BTE(BC.M)  - Pilot  BC TE *  BC  solids sprayed  pilot * Overall  BC/CC  film  build plant
                          BC  solids sprayed plant   Overall  BC/CC  film  build pilot

BTE(CC.M)  = Pilot  CC  TE *  CC  solids sprayed pilot * Overall  BC/CC  film  build plant
                          CC  solias sprayed plant   Overall  BC/CC film build pilot
                                      19-13

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                                                       ADDED 11/88
L - Additional  Information  and  Definitions

1.  Each dry film build measurement  should  be performed  consistent with
ASTM B499-87, "Measurement  of Coating Thicknesses  by the Magnetic Method:
Nonmagnetic Coatings on Magnetic Basis Metals."   The number of dry film
build measurements should be as specified in parts D-3 and F-9 of this
section, rather than as specified in part 6.3.4 of ASTM B499-87.

2.  Class I means exterior surfaces  designated to be coated that are
visible with hood, deck lid and doors closed.

3.  Class II means all surfaces designated to be coated that are not
Class I.

4.  All weight solids determinations must be done with ASTM D2369-86

5.  Dry film build measurements are not required to be made on non-magnetic
substrates  (e.g., plastic parts) for which the magnetic instruments
described in ASTM B499-87 cannot be directly used to measure coating
thickness if the total designated coated area (Class  I plus Class  II)  of
these substrates is less than  25 percent of the total area  (Class  I plus
Class  II) coated on the  vehicles.   The total Class  I  and total  Class  II
areas coated  (including  non-magnetic  substrate area)  must  be used  to
determine the  number  of  Class  I  and Class  II dry  film build measurements
 required and to  calculate overall average  dry film  build.   (See Figures
 28 and  29.)  The  dry  film build measurements  that  would  normally be made
 on a  particular  part, but  are  not made because the  part  is constructed of
 a non-magnetic substrate must  be made on a corresponding  part.   For
 example,  if a  vehicle has  a 10 square foot Class  I  plastic front fender
 and no dry  film build measurements  are made on that fender, then the
                                   19-14

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                                                         ADDED  11/88
(approximately)  10  measurements  that would normally be made on the fender
could be made  as additional measurements on a rear quarter panel.   Other
examples of corresponding  parts  are hood and deck lid, engine compartment
and trunk interior, etc.

     If 2b percent, or more,  of  the total area  (Class I plus Class II)
coated on the  vehicle is  on non-maynetic substrates, then in-plant and
pilot line dry film build measurement  are  required  for the non-maynetic
substrates.  These measurements  can be  accomplished by wrapping the non-
magnetic substrates with foil  or by attaching magnetic basis metal (e.g.,
steel) shims to the non-magnetic substrates.  The film build measurement
device must be  calibrated for the foil  or  shims.

6.  The  requirement to take before and after dry film build measurements
on at least two vehicles can be met at the  owner/operator option  by taking
before and after measurements on portions  of a  greater number of  vehicles
as long  the equivalent of at least two complete vehicles  (i.e., two of
each  panel or surface) is measured.

      The before and  after measurements for a particular  panel or  surface
must  be  made on  the  same vehicle.  An example  of an equivalent  vehicle
would be all  before  and after measurements from front windshield  forward
on one  vehicle,  all  before and  after measurements  from front  windshield
to rear windshield on  a  second  vehicle, and all before and after  measurements
from the rear windshield back on a third vehicle.   The equivalent vehicle
 approach may  be helpful when the owner/operator chooses  to perform in-plant
dry  film build  measurements while the vehicles are still  in process  (e.g.,
 on the conveyor) as opposed  to  removing the vehicles from the production
 line.
                                   i9-lb

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                                                         ADDED 11/88
7.  The method used to determine  in-pi ant  average mass or volume of coating
used per vehicle is chosen by  the owner/operator from the options presented
in Part D-2 of this section.   The in-plant determinations of average mass
or volume of coating used per vehicle  and  Class I and Class II dry film
builds must be made contemporaneously.   For example, if coating usage per
vehicle is determined from usage  on a  block of vehicles, then  the vehicles
on which film build measurements  are made  must be included in  that block.
If temporary in-line meters or fluid flow  rates and  gun on times are used
to determine coating usage per vehicle for manual guns, the metering or
gun on time measurements must include  the  manual  coating of the vehicles
on which film build measurements  are made.  If temporary in-line meters
or fluid flow  rates and gun on times are used to  determine  coating usage
per vehicle for automatic guns, the metering  or gun  on  time measurements
must be done during the same shift in which  the  automatic  coating  of the
vehicles on which film build measurements  are made.

8.   If gun  on  times and fluid flow rates are used to determine in-plant
average coating usage per vehicle, caution must  be  used to  account for
fluid  flow  rate variation during  the spray cycle of each piece of  equip-
ment.  This variation could be caused by partial  triggering  of manual
guns or  fluid  pressure  changes in  automatic guns.
                                   IS-lb

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    20 - ALTERNATE TRANSFER EFFICIENCY PROCEDURES  FOR UNTESTED BOOTHS
                             AND/OR COATINGS

     This section describes an alternate transfer  efficiency procedure
that may be used for those parts of the topcoat operation whose transfer
efficiencies are not determined using the test procedure in either Section
19 or 20.  These parts may include color and clear coatings applied in
untested booths (e.g. separate "interior" color booth, tutone, or in-line
repair); and other coatings applied in tested booths (e.g. blackout
applied in a main color booth).

     The following predetermined transfer efficiency values may be used
by these situations:

     Air Atomized Spray            40 percent
     Electrostatic Spray       .    55 percent

     If a particular coating is applied with both  types of equipment,
then the two transfer efficiency values should be  weighted by relative
square  footage coated by each method.
     Transfer Efficiency
                            Air Fraction +' Estatic Fraction
                                .4              .55

     Where  Air  Fraction + Estatic Fraction = 1

     The  transfer efficiency  for coating I in booth M is referred to as
 BTE(I,M)  in the section on Daily Transfer Efficiency.
                                   20-1

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 21 - TEST PROCEDURE FOR DETERMINING BAKE OVEN EXHAUST CONTROL DEVICE VOC
                      LOADING FOR SPECIFIC COATINGS
     This procedure is used to determine the bake oven exhaust control
device VOC loading for specific solvent-borne coatings used in an automobile
or light-duty truck topcoat operation.

Scope
This procedure simulates the loss of VOC from a freshly painted
surface by weight difference before and after baking.  Metal  test panels
are subjected to simulated coating film build, flashing and baking sequence.
The weight loss during baking is then related to the volume of solids
deposited on the test panels to compute a control device inlet loading in
pounds VOC per gallon solids applied.  Identification of the points at
which painted vehicles would enter oven zones whose effluents are vented
to a control device provides the data needed to determine the oven VOC
loading available for destruction in control device equipped zones.

A baking oven must be used to thoroughly cure the paint film.  Gas-fired
ovens are more representative of actual production; however, a vented
electric oven may be used.

Film thickness is to be measured with an instrument, such as an
Elcometer or Dualscope.  Ensure that this equipment is capable of
measurements on substrate selected if direct measurements on the panels
are to be taken.
                                   21-1

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Process

The processing conditions must be determined prior to beginning the
test, including film thicknesses, flash times, and baking sequence, to
ensure use of values that represent the range of conditions found in the
plant.

Identify all locations in the process sequence in which oven effluent
is vented directly to a control device for VOC destruction.  This will
affect the number of panel weight measurements taken and the number of
test panels that need to be run.  If more than one oven is vented to a
control device then panels need to be run for each different baking
sequence and ventilation pattern.

Selection of Coatings for Evaluation

This procedure need not  be run  for each coating used.  The coatings used
may  be grouped based on  similar appearance characteristics, processing
sequences and dry film thicknesses.  One coating can be tested from each
group  and the result used for  all of the coatings in that  group.   Some
sample groupings are straight  shades (colors  that do not receive a clear
coat), non-metallic basecoats,  metallic basecoats, mica basecoats  and
clear  coats.   In order to more  closely represent actual process conditions,
basecoat  and  clear  coat  can  be tested  together  at owner/operator option
as noted  later  in the  procedure.

 For each  coating  evaluated,  run triplicate  test panels  for each  production
 bake oven which  is  vented to a control device.
                                    21-2

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Weight Measurements to be Recorded

Weigh panel  before paint is applied (W)

Coat panel according to plant process sequence.

Weigh coated panel at point in bake cycle at which exhaust air is first
vented to the incinerator (Wl).

Weigh coated panel at point in bake cycle at which exhaust air is no
longer vented to the incinerator (W2). (Note:  Panel  should be cooled to
room temperature before weighing).

If W2 does not represent a fully cured coating film,  then a duplicate
painted panel should remain in the oven to complete the full  bake cycle.
Cool and weigh this panel (W3).  [This weight (W3) should be used to
determine the Gallons Solids Applied (GSA), covered later in this section],

Measurement of Film Thickness

Coupons should be coated and baked along with the test panels for
measurement of film thicknesses of basecoat and clearcoat on the panels.
For straight shade systems, film thickness measurements may be taken
directly on the panels.

Dry film thickness measurements should be recorded for basecoat and
clearcoat for each panel tested.
                                   21-3

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Determination of Dry Solids Density

Dry solids density may be calculated as shown below.  Information needed
to perform this calculation includes the weight fraction solids, volume
fraction solids, and gallon weight of the coating materials as applied.
These values should be determined using the procedures specified in EPA
Method 24.  The one-hour bake should be used in the weight fraction solids
determination.  The formulation volume fraction solids value should be
generated using the procedure described in Section 33.  Solids density is
calculated using the following equation:

     SD    =  WFS x WGC
                  VFS

     SD   =    Solids Density (Ibs solids/gal solids)

     WFS   =   Weight Fraction Solids (Ibs sol ids/1 bs  paint)

     WGC   =   Weight Per Gallon of Coating (Ibs paint/ gal paint)

     VFS   =   Volume Fraction Solids (gal solids/gal  paint)

If base coat and clear coat are applied to the  same panel, determine the
weighted average paint solids density by the ratio of film thickness as follows:
     WSD   =     Tl       x  D     +     T2       x  D
                                                      cc
              Tl + T2                  Tl + T2

     WSD   =  Weighed Solids Density

     Tl    =  BC Film Thickness

     T2    =  CC Film Thickness
                                   21-4

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           =  BC Solids Density

     Dcc   =  CC Solids Density

Calculations

The following calculations are used to express bake oven control  device
loading in pounds VOC per gallon solids applied (GSA).

Weight of coating solids applied = coated panel weight after full bake
minus panel weight before coating application.

     WPS       W3  -  W            or

     WPS   =   W2  -  W          if W2 represents a fully cured paint film

  where WPS  =  weight of coating solids applied

Weight of VOC available for control equals panel weight at point which
all exhaust air is vented to control device minus panel weight at point
which exhaust air is no longer vented to the control device.

     WSA   =   Wl   -  W2

  where WSA  =  weight of VOC available for control

Set up the following ratio for each panel measured:

     weight of VOC available for control/weight of paint solids applied

        RATIO  =  WSA/WPS
                                   21-5

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Convert this ratio to units of pounds  VOC available for control  per gallon
of coating solids applied by multiplication of this ratio  by paint  solids
density.

     CDL   =   RATIO x WSD

   where CDL = VOC loading expressed in terms  of pounds VOC per  gallon
               solids applied.

     WSD   =  weighted solids density  expressed in  terms of pounds  solids
              per gallon solids

Frequency of Certification

Bake oven exhaust control device VOC loading must be determined  for an
initial compliance test.  The owner/operator must review the operating
conditions annually thereafter.  The most recent test results remain valid
as long as the owner/operator demonstrates that no  significant changes
have occurred in coating technology or processing.   A significant change
in coating technology is considered to be a major difference in  the
generic nature of the coating chemistry.  Annual variations in color
palette or routine minor solvent blend adjustments  for processing,  quality,
or other reasons do not constitute significant changes in  coating tech-
nology.  Significant process changes may include changing  ducting to the
incinerator, or major size modifications to spray booths,  flash  tunnels,
or ovens.

Equipment

Use triplicate aluminum or thin steel  panels with a minimum area of 20
square  inches for each coating evaluated.

For weight measurements, use a balance with accuracy to O.OOlg.
                                   21-6

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Coating is to be applied in a laboratory spray booth  with  booth  air velocity
representative of production conditions.

Coating materials must be the specific formulations  (in  as-applied  condition)
as used in the plant whose control  device VOC  loading is to  be determined.
                                   21-7

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               22 - BAKE OVEN EXHAUST CONTROL DEVICE EFFICIENCY
       The efficiency of a bake oven exhaust control  device  (incinerator
  destruction efficiency)  should be  determined  using  the  following  methods
  for the inlet  and  outlet streams:

       (a)   EPA  Method 25  to determine VOC concentration;
       (b)   EPA  Method 1 or 1A  for sample and velocity traverses;
       (c)   EPA  Method 2,  2A, 2C, or 2D for velocity and volumetric
            flow rates;
       (d)   EPA Method 3 for gas analysis;
       (e)   EPA Method 4 for stack gas moisture.

      Three runs of EPA Method  25 should  be  made for  each stream.   The  EPA
 Method 25 results  for both streams  may be adjusted by  the result generated
 by rumnng a blank  (zero  air or nitrogen) stream through the  sampling
 train.  
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23 - DELETED
     23-1

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               24  -  ACCOUNTING  FOR  CAPTURED  PURGED  COATING
     At the option of the owner/operator,  the  coating  collected  by  a
purge capture system may be subtracted  from the  amount of  each coating
used each day.  To do this, records  must be kept of the number of purge
cycles for each coating each day and the standard amount of each coating
captured in a purge cycle.  The standard amount  of coating captured may
be established by direct measurement or by calculation of  the volume  of
as sprayed coating in the line(s) being purged.

     The total volume of a coating that is captured by the purge capture
system on a particular day is:

    •TCP(I.N) = CP(I) * NPURGE(I.N)
                                    24-1

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25- RECORDS OF WITHDRAWALS OF COATING FROM MIX TANKS OR CIRCULATING SYSTEMS

     If the owner/operator elects to deduct from topcoat usage any quantity
of coating that is not consumed in the topcoat operation, then the following
documentation is required.

     Records must be kept of each withdrawal  of coating from mix tanks or
circulating system.  Withdrawals include discrete removal of coating from
the mix tanks or circulating system in ways other than spraying or purging,
and coating continuously supplied through the circulating system to
operations other than topcoat.  Examples of the first type of withdrawal
are coating removed for use in final off-line repair or because of quality
considerations.  An example of the second type of withdrawal is coating
supplied through the circulating system to a fascia coating or wheel
coating operation.

     The records for each coating must include the date of each discrete
withdrawal and the volume of coating withdrawn.  A sample record is
provided in Figure 11.  Continuous withdrawals must be accounted for
either by establishing standard values for the volume of coating sprayed
per part outside of topcoat (e.g. fascia or wheel) or by extending the
daily and monthly vehicle coating summaries to include the coating done
outside of the topcoat operation.

     If the owner/operator chooses not to document withdrawals of topcoat
materials not consumed in the topcoat operation, then the quantity of
such withdrawals may not  be excluded from the calculation of daily topcoat
emission rate.
                                   25-1

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                26 - NOTES ON ALTERNATE WEIGHTING FACTORS
     The weighting factors presented earlier in this procedure are based
on the square footage coated on each vehicle with each coating in each
booth.  These factors should give an accurate weighting of individual
transfer efficiency and bake oven control  device VOC loading values in
most cases.

     If a source owner or operator desires, weighting factors based on
the square feet - mils (i.e. surface area  coated times dry film build)
coated on each vehicle with each coating in each booth may be used.  Such
weighting factors could be slightly more accurate than weighting factors
based solely on square footage.

     In cases where there is a separate "interior" color booth in which
coating is applied to edges and interior surfaces at a significantly
lower dry film build than coating is applied to exterior surfaces in the
main color booth, it may be to the sources' advantage to use weighting
factors based on square feet - mils.  In cases where "interior" coating
is done in the main color booth, it is probably to the owner or operator's
advantage to use weighting factors based only on square feet coated.

     Weighting factors based on square feet - mils should not be used in
Sections 27 and 29.  Weighting factors based on square footage coated
should be used in Sections 27 and 29.
                                   26-1

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                       27  -  NOTES  ON  USING COMBINED
           BASECOAT/CLEARCOAT TRANSFER EFFICIENCY JEST RESULTS
     As noted In the Transfer Efficiency Test Procedure (Sections  18 and  19),
some transfer efficiency tests may result in a measured transfer efficiency
value for BC/CC combined, rather than individual  values for BC and CC.
In this case the measured values may be directly  used  for each BC.  That
is, for each BC, BTE(I.M) should be set equal  to  the measured  transfer
efficiency value for BC(I)/CC.  For CC, BTE(CC, M)  must be calculated
each day from the daily weighted average of the measured transfer  efficiency
values for each BC/CC combination weighted by the fraction of  the  total
square footage coated in booth M on day N with each BC.  These weighting
factors are the coating column fractions in the daily  vehicle  coating
summary.  On day N:

                    SUM   CFRAC (I.M.N)
                   ALL BC
     BTE(CC, M) = 	
                    SUM   [CFRAC (I,M,N)/BTE(I,M)]
                   ALL BC

     A sample calculation is presented in Figure 21.
                                   27-1

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   28  -   NOTES  ON  USING  TRANSFER  EFFICIENCY  TEST  RESULTS  WHEN  THE  TEST

                   ENVELOPE IS MORE  THAN ONE BOOTH  LONG

     Some transfer efficiency tests  may span more than one spray booth.   For
example, an interior color booth  and main color booth may be covered by  a
single test.  If a transfer efficiency test spans booths  M and M1, then
BTE(I.M) and BTE(I.M') must be set equal to the test result for coating  I.
                                    28-1

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        29 -  NOTES  ON  USING COMBINED BASECOAT/CLEARCOAT BAKE  OVEN

                     CONTROL DEVICE VOC LOADING DATA
     As noted in the Test Procedure for Determining Bake Oven Exhaust
Control Device VOC Loading for Specific Coatings, at the owner/operator
option, control  device VOC loading values may be determined for BC/CC
combined, rather than individual  values for BC and CC.   In this case, for
each basecoat, set CDL(I,M) equal  to the measured value for that basecoat/
clearcoat.  For clearcoat, CDL(CC,M) must be calculated each day.   CDL(CC,M)
should be set equal  to the daily weighted average of the measured  control
device VOC loading values for each basecoat/clearcoat weighted by  the
fraction of the total square footage coated in booth M on day N with each
basecoat.  These are the coating column fractions in the daily vehicle
coating summary.

                   SUM    [CDL(I,M) * CFRAC(I,M,N)]
                   ALL BC                   	
    CDL(CC.M) =    SUM    [CFRAC(I.M.N)]
                   ALL BC

     A sample calculation is presented in Figure 8.

     As noted in the section on Daily Individual Bake Oven Control Device
VOC Loading Values (Section 14), as an alternative, TCDL(M.N) can be set
equal to the minimum value measured by the test procedure.  In this case
there would be no need to calculate a separate value, CDL(CC,M), for
clearcoat.
                                   29-1

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    30 - NOTES ON ACCOUNTING FOR DILUTION SOLVENT ADDED BY THE COATING

                 MANUFACTURER AT A SATELLITE PAINT PLANT
     Some assembly plants have nearby satellite paint plants at which the
coating manufacturer may add dilution solvent  or other ingredients
to coatings before delivering them to the assembly plant.   Satellite
paint plants frequently deliver coatings to the assembly  plant  in  ready-
to-spray condition (i.e. no solvent additions  are made at  the assembly
plant) on a just-in-time basis.

     The satellite paint plant must maintain records of all  dilution
solvent additions and all other additions made before shipping  coatings
to the assembly plant.  The satellite paint plant must also adjust the
analytical VOC content, formulation solvent content and volume  solids
content of each container (drum, tote, etc.) of coating shipped to the
assembly plant to account for these additions.  These adjustments  should
be made using calculations similar to those presented in Sections  10, 11
and 12.
                                   30-1

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31 - CALCULATING FORMULATION WEIGHT FRACTION SOLVENT AS OF SUPPLIED COATING

     This section describes the calculations which should be performed to
determine the formulation weight fraction solvent content of an as supplied
coating.  These calculations should be based on the coating manufacturer's
formula and batch production records at a point in the coating manufacturing
process at and beyond which coating ingredients are mixed or blended only.
(No more chemical reactions should take place in the coating manufacturing
process.)  All materials added before packaging for shipment (e.g., for
tinting and adjusting to receive quality control approval) should be
included in-these calculations.

1 - Set B equal  to the number of ingredients in the formula for coating
I,  including  those ingredients added to tint or adjust the coating.

2 - Set WT(I.J.A) equal  to  the pounds of ingredient A added to the batch
of  coating  I  used in addition J.   [For ingredients added  by volume,
WT(I,J,A) can be calculated by multiplying  the  volume  (gallons) added by
the density (pounds  per  gallon) of the ingredient  as  in  Steps  2 through 4
of  Section  33.   Density  should be  determined using ASTM  D-1475.   For  dry
materials,  actual density,  not bulk density, should be determined
analytically.  The density analysis may  be  performed  by  the supplier  of
 the ingredient.]

 3 - For each ingredient  in the  formula,  determine  the weight  fraction
 volatiles,  WTVOL (I.J.A),  using  the appropriate portion  of ASTM  D-2832.
 (Note that  weight  fraction volatiles equals 1  minus weight fraction
 nonvolatiles.)  This information  may be  provided to the  coating  manufacturer
 by the supplier of the ingredient.
                                    31-1

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4 - For each ingredient in  the  formula which contains water or exempt*
solvents, determine  the weight  fraction water or exempt solvent, WTNRU.J.A)
This information may be provided  to  the coating manufacturer by the
supplier of the ingredient.

5 - For each ingredient in  the  formula, calculate the weight fraction
solvent, WTSOLV(I,J,A), using the following equation:

      WTSOLY(I,J,A)  = WTVOL (I.J.A)  - WTNR (1,0, A)

6  - Calculate the formulation weight fraction  solvent content  of the  as
 supplied  coating WTFRSV(I.J), using the following  equation:
      WTFRSVd.J)
 B
SUM  vrrsoLVd.j.A)  * WKI.J.A)

 B
SUM WT(I,J,A)
 *Exempt  solvent means organic solvents which are  determined by  the
 Administrator of the EPA to have negligible photochemical  reactivity and
 which  are  similarly recognized in the particular  regulation with which
 compliance is being determined using this procedure.
                                    31-2

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   32 - CALCULATING FORMULATION  SOLVENT CONTENT  OF  AS  SUPPLIED  COATING
     This section describes  the calculations  which  should  be  performed  to
determine the formulation solvent content,  CF(I,J),  of an  as  supplied
coating.

1 - Determine the density of the coating,  DENS(I.J), using ASTM  D-1475.
(Note, this is the same density analysis made in determining  the analytical
VOC content of the coating.)

2 - Calculate the formulation solvent content, CF(I,J), of the as supplied
coating using the following equation:

      CF(I,J) = WTFRSV(I.J)  * DENS(I.J)
                                   32-1

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      33 - FORMULATION VOLUME SOLIDS  CONTENT  OF  AS  SUPPLIED  COATING
     This section describes  the  calculations which  should  be performed to
determine the formulation volume solids  content  of  an  as supplied  coating.
These calculations should be based  on  the  coating manufacturer's formula
and batch production records at  a point  in the coating manufacturing
process at and beyond which  coating ingredients  are mixed  or blended
only.  (No more chemical  reactions  should  take place in the coating
manufacturing process.)   All  materials added before packaging  for  shipment
(e.g., for tinting or adjusting  to  receive quality  control approval)
should be included in these  calculations.

1 - Set B equal to the number of ingredients  in  the formula for coating
I, including those ingredients added to  tint or  adjust the coating.

2 - For ingredients added by weight, set WT(I,J,A)  equal to the pounds of
ingredient A added to the batch  of  coating I used  in addition  J.   For
ingredients added by volume, set VOL(I,J,A) equal  to the gallons of
ingredient A added to the batch  of  coating I used  in addition  J.

3 - Determine the density, DEN(I,J,A), of each ingredient  A in the batch
of coating I used in addition J  using  ASTM D-1475.   For dry materials,
actual density, not bulk density, should be determined analytically.  The
units for DEN(I,J,A) are pounds  per gallon. This  information  may  be
provided to the coating manufacturer by  the supplier of the  ingredient.

4 - For ingredients added by weight, calculate the  volume  (gallons) of
ingredient A added to the batch  of coating I used  in addition  J using the
following equation:

     VOL(I,J,A) = WT(I,J,A)  / DEN(I.J.A)

                                   33-1

-------
     For ingredients added by volume, calculate the weight (pounds) of
ingredient A "added to the batch of coating I used .in addition J using the
following equation:

         WT(I,J,A) = DEN(I,J,A) * VOL(I,J,A)

5 - For each ingredient in the formula, determine the weight fraction
volatiles, WTVOL(I,J,A),  using the appropriate portion of ASTM D-2832.
(Note that weight fraction volatiles equals 1 minus fraction nonvolatiles.)
This information may be provided to the coating manufacturer by the
supplier of the ingredient.

6 - For each ingredient in the formula, determine the density of the
volatiles in that ingredient, DVOL(I,J,A).  The units for DVOL(I,J,A)
are pounds per gallon.  This information may be provided to the coating
manufacturer by the supplier of the ingredient.

7 - For each ingredient in the formula, determine the volume fraction
solids, VFS (I,J,A) using the following equation:

         VFS(I,J,A) = 1 - WTVOL(I.J,A)  * WT(I,J.A)
                          DVOL(I,J,A) * VOL(I,J,A)

8 - As an alternative to  steps 5 through 7, the volume fraction solids of
an ingredient may be determined directly.  This would be particularly
useful for ingredients which contain no solids (e.g., solvents) or no
volatiles (e.g., dry solids).  Ingredients which are thought to be; pure
liquid resins should be checked as in step 5 to ensure that there are no
volatiles (e.g., low molecular weight olig-imers) present before concluding
that they contain only solids.  This information may be provided to the
coating manufacturer by the supplier of the ingredient.
                                   33-2

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                                                          REVISED 11/88
9 - Calculate the formulation volume solids content of the as supplied
coating using the following equation:
   VS(I,J)
 B
SUM VFSd.J.A) * VOL(I.J.A)

 B
SUM VOLd.J.A)
                                    33-3

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                     34  -  RECQRDKEEPING  REQUIREMENTS
     The source owner or operator must maintain  at the source,  for the
time period required by the applicable regulation, all records  and
calculations used to determine daily YOC emissions from each topcoat
operation.
                                    34-1

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35 - NOTES ON' USING THIS PROTOCOL TO DETERMINE THE DAILY VOC EMISSION

       RATE OF AUTOMOBILE AND LIGHT-DUTY TRUCK SURFACER OPERATIONS
     This section reserved for instructions on how to use this protocol
     to determine the daily VOC emission rate of automobile and light-duty
     truck surfacer operations.
                                    35-1

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     APPENDIX A
EXAMPLE CALCULATIONS
         A-l

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                             Figure 1

Spray  Booth  and Bake  Oven  Layout  for Example Calculations
                     To Incinerator
Interior
Color
Booth


Oven
         Main Color
         Booth #1
         Main Color
         Booth §2
                                                             [n-Line
                                                             tepair
                                                             Booth
                     To Incinerator

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                               FIGURE  2
         Notes on sample  coating  line  and sample calculations
Coatings Used

   Red
   White
   Blue Metallic
   Clear Coat
(R)  straight  shade
(W)  base coat
(B)  base coat
(CC)
Body Styles

  2-door
  4-door
Tutones

About half of the red vehicles
receive B/CC accent color in tutone booth.
                                       Daily  Production

                                       About  800 vehicles  per
                                       day
The daily calculations are presented for July 14,  19XX.   The  index (14)
indicates the 14th day of the month.

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                                                        FIGURE 3
                                                    (See Section 16)
                                    Individual Vehicle Coating Records - July 14, 19XX
Vehicle
Interior
Main Color #1
ID/Style
07140001-2
07140002-2
07140003-2
07140004-4
Color Sq Ft
R 42.0
U 42.0
B 42.0
B 44.0
Color Sq Ft CC Sq
R 150.0 150.0

B 150.0 150.0

Main Color 12
                                                     W  150.0   IbU.O






                                                     B  160.0   160.0
Tutone
                                                                              B 70.0  70.0
In-line Repair
                                                                                        B 25.0  25.0
07140780-4    R 44.0
                                        R  160.0   160.0
                                                 B 70.0  70.0

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                                                         FIGURE 4
Coating

   R


   W


   B


   CC


Total
Interior

17200(.213)
(.513)

10320(.213)
(.308)

6020(.142)
(.179)

O(.OOO)
(.000)

33540(.136)
(1.000)
Dally Vehicle
Main til
46500(.575)
(.625)
6200(.128)
(.083)
7750(.182)
(.104)
13950(.187)
(.188)
74400(.302)
(1.000)
(See Section 16)
Coating Summary -
Main #2
15500(.192)
(.147)
31000(.639)
(.294)
13950(.328)
(.132)
44950(.602)
(.426)
105400(.428)
(1.000)
July 14, 19XX
Tutone
O(.OOO)
(.000)
O(.OOO)
(.000)
14000(.330)
(.500)
14000(.188)
(.500)
28000(.114)
(1.000)
Repair
1600(.020)
(.317)
960(.020)
(.190)
760(.018)
(.151)
1720(.023)
(.341)
5040(.020)
(1.000)
Total

80800(1.000)
(.328)

48480(1.000)
(.197)

42480(1.000)
(.172)

74620(1.000)
(.303)

246380(1.000)
(1.000)
                                         Square  Feet  Coated  (Row  Fraction)
                                         (Column  Fraction)

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                   FIGURE  5





               (See Section  15)





  Monthly Vehicle Coating  Summary  -  July  19XX
Coating                            Square Feet Coated





   R                               1,535,200





   W                               1,018,080





   B                               849,600





   CC                              1,641,640

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                    FIGURE  6

                (See Section  18)

        Transfer Efficiency Test  Results


Coating                            Main Color TE

   R                                     .68

   W                                     .b7

   B                                     .47

   CC                                    .74
 Each coating was  tested because each  coating  is  processed
 differently.  CC  was  tested  separately.   See  Figure  21
 for example with  CC tested together with  BC.

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                         FIGURE 7

                      (See Section 20)

               Untested  Transfer Efficiencies
Coating
R
W
B
CC
Interior
.40
.40
.40
NA
Tutone
NA
NA
.40
.55
Repair
.40
.40
.40
.55
All interior coating Is done with air spray.   Straight shades
and basecoats are applied by air spray In tutone and repair
booths.  Clearcoat is applied by electrostatic spray in tutone
and repair booths.

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                            FIGURE 8

                        (See Section 21)

Bake Oven Exhaust Control  Device VOC Loading - Panel  Test Results


          Coating            Main Color        Tutone

             R                  2.0              NA

           W/CC                 2.3              NA

           B/CC                 2.1              2.0
Calculation of separate value for main color CC for July 14, 19XX.
(See section 29.)

           Main II                               Main #2
  (2.3)(.083)  t (2.1)(.104)              (2.3)(.294)  + (2.1)(
  _  =   2.2      _   =  2.2

         .083  + .104                            .294  + .132

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                      FIGURE  9





                  (See Section  22)





Bake Oven Exhaust Incinerator Efficiency  Test  Results
              Main #1      96%





              Main #2      96%





              Tutone       94%

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                FIGURE 10

            (See Section 13)

   Daily Weighted TE  for July 14. 19XX
     ,213 + .575  +  .192 +  .020
     74TT   .68    .68     .40
    1.710
                                                   .585
W
     .213 + .128 +  .639  +  .020
     T40~   757"   75T~    .40
    1.928
                .519
    .142  + .182 + .328 + .330 +  .018
            747"   ~37~   T4TT   ~4lT
                                                =  .433
       2.31
 CC
      =  .690
     .187 + .602 + .188 + .023
     774"   774"   T?5~   .55
1.45

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                                              FIGURE 11

                                    (See Section 10, 11, 12 and 25)

                                Monthly Additions for Red - July 19XX
Start 1510
End   1210
                       Coating

Date

7/1
7/3
7/7
7/9
7/12
7/15
7/18
7/21
7/24
7/28
7/30

Batch

A
A
A
B
B
C
C
C
D
D
D

Gal
PADD
1000
600
850
1000
850
800
700
1000
900
1000
1000

Formula
CF
3.70
3.70
3.70
3.60
3.60
3.80
3.80
3.80
3.60
3.60 .
3.60

Analytical
CA
4.00
4.00
4.00
3.90
3.90
4.20
4.20
4.20
3.90
3.90
3.90
Formula
Vol Solids
VS
.47
.47
.47
.48
.48
.46
.46
.46
.48
.48
.48
                9700
Diluent
Gal
RADD
50
60
6U
6U
50
60
340
Density
RD
6.8
6.8
6.8
6.8
6.8
6.8

                                   Withdrawals for Red - July 19XX.
                                    Date      Gal       Destination
                                    77TI      50       Final repaTF

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                                     FIGURE  12
(See Section 17)
Monthly Coating Usage
Coating Gallons Formula
(RCF)
R 10290 3.78
W 3500 4.11
B 3400 4.49
CC 4200 3.31
- July 19XX
Analytical*
(RCA)
4.10
4.32
4.72
3.65
Vol Solids
(RVS)
.456
.423
.359
.527
For red. monthly usage = 1510 -  1210  +  9700  +  340  -  50  =  10290
The data for this calculation came from Figure 11.

* See Figure 13 for sample calculation.

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                                                   FIGURE 13

                                               (See Section 10)

                         Analytical  VOC Content of as Applied Red Coating - July 19XX
       Coating Additions
                                                        Diluent Additions
Gallons   x
PADD(I.J)

  1000
   600
   850
  1000
   850
   800
   700
  1000
   900
  1000
  1000
  9700
Test VOC
 CA(I.J)
  4,
  4,
  4.
  3.
  3.
  4.
  4.
  4.
  3.
  3.
00
00
00
90
90
20
20
20
90
90
  3.90
      =  Total VOC
Gallons
PADD(I,K)

   50
   60
   60
   60
   50
   60
  340
Density  =
RP(I,K)

  6.8
  6.8
  6.8
  6.8
  6.8
  6.8
Total VOC
   340
   408
   408
   408
   340
   480
              2312
                              RCA(I) = 38825 + 2312 = 4.10
                                        9700 +  340

-------
   FIGURE 14
(See Section 8)
Coating
I

R

W

B

CC
Month's Usage
GMON(I) x

10290

3500

3400

4200
Day's Sq. Ft.
PAYSQFT(I.14^ t
80800

48480

42480

74620
Month's Sq. Ft.
' MONSOFT(I)

1535200

1018080

849600

1641640
Day's Usage
GDAY(I,14)

541.6 .
.
166.7

170.0
190.9

-------
                                            FIGURE 15

                                         (See Section 9)

               VOC Generated  per Gallon of as Applied Coating Used - July 14, 19XX


Coating                 Formula            1-TE              Analytical        TE               VOC Gen
   I                     RCF(I)      x      	       +         RCA(I)    x   TE(I.14)    =    RCV(I,14)

   R                     3.78             .415                  4.10           .585             3.97

   W                     4.11             .481                  4.32           .519             4.22

   B                     4.49             .567                  4.72           .433             4.59

   CC                    3.31             .310  '                3.65           .690             3.55

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               FIGURE  16
             (See Section 5)
Total  Dally VOC Generated - July 14. 19XX
Coating
I
R
W
B
	 CC
Total
Gallons
GDAY(I.H) x
541.6
166.7
170.7
190.9

VOC/Ga1
RCV(I,14) *
3.97
4.22
4.59
3.55

VOC Generated
(Pounds)
2150.2
703.5
780.3
677.7
4311.7 = DVI

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                                          FIGURE 17
                                       (.See Section 6)
                     Total nally Volume Solids Deposited - July  14.  19XX
Coating
I
R
U
B
CC
Gallons
GDAY(I.M) x
541.6
166.7
170.0
190.9
Vol Solids
RVS(I) x
.456
.423
.359
.527
Dally TE
TE(I,14) =
.585
.519
.433
.690
Solids Dep
^Gallons)
144.5
36.6
26.4
69.4

Total
                                                                               276.9 = DSD(14)

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                              FIGURE 18





                          (See Section 14)





Dally Individual  Bake Oven Exhaust Control Device VOC Loading Values
   Main 01   2.0(.625)  + 2.3(.083)  + 2.1(.104)  + 2.2(.188) = 2.07
   Main n   2.0(.147)  +  2.3(.294)  + 2.1(.132)  + 2.2(.426)  = 2.19
   Tutone                                                  = 2.00

-------
                                           FIGURE 19

Booth/ Oven
Main n
Main #2
Tutone

Total Dally Bake Oven
VOC Loading
TCDL(M,14)
2.07
2.19
2.00
(See Section 7)
Exhaust Control
Control Eff
CDE(M)
.96
.96
.94

Credit - July 14, 1988
Wtg Factor Control Credit
BRFRAC(M,14)
.302 .60
.428 .90
.114 .21
Total
1.71 = DCC(14)

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                     FIGURE 20





                  (See Section 4)





Dally VOC Emission  Rate Calculation  -  July 14,  19XX
       DER(14)  =  [DV6(14)/DSD(14)]  -  DCC(14)









               =  [4311.7/276.9]  - 1.71





               =  13.86  pounds VOC per gallon solids deposited

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                                        FIGURE 21

                                    (See Section 27)


Calculating CC TE from combined BC/CC Transfer Efficiency Test Results


TE test results

W/CC     .640

B/CC     .580


CC TE for July 14, 19XX

                                   Main Color Booth #1
                    BTE(CC,  Main  1)  =  .083 +  .104  =  .187  = .605
                                      .083 *  .104     .309
                                      7BW    7550

                                    Main  Color Booth  12

                    BTE(CC,  Main  2)  =  .294 +  .132  =  .426  = .620
                                      .294 +  .13?     7657
                                      76W    75W

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                                         FIGURE 22

                                     (See Section 16)

Sample Calculation of Equivalent Vehicles


     Vehicle            Process  Step            Square Feet Coated            Equivalent Vehicles

   2-Door Sedan         Main Color                      184                          0.92
                        Tutone                           10                          0.05

   4-Door Sedan         Main Color                      200                          1.00
                        Tutone                           12                          0.06

   Station Wagon        Main Color                      229                          1.15
                        TUtone                           17                          0.09
   In this sample, the "base vehicle" is the 4-Door Sedan Main Color step.
   (200 square feet coated is equated to 1.00 equivalent vehicle.)

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                        FIGURE  23

                    (See Section 16)

Sample Calculation of 4 Percent Standard Dally Repair Rate


       Using data for red (R) coating In Figure 4:

           Booth            Square Feet Coated

         Interior                  17200
         Main II                   46500
         Main 12                   15500
   Total (excluding                /9200
          repair)


      Repair Square  Feet Coated  =  79200  * 0.04  «  3168

      Total  (Including  repair)  - 79200 + 3168 = 82368

-------
                                           FIGURE 24
                                        (See Section 19)
                               Pilot  Line TE Test Data Validation
                                                                  ADDED 11/88
Wt solids sprayed/vehicle
Average Class I film build
Average Class II film build
Overall average film build
 In-Pi ant
2.80 Ibs
2.20 mils
1.30 mils
1.90 mils
Solids sprayed test   3.10 - 2.80  * 1UO  = +9.7% OK
                          3.10
Overall film build change 1.83 - 1.90 * 100 =  -3.7% OK
                              1.90
Consistency of solids sprayed    ABS[9.7  - (-3.7)] =  13.4 Ł20 OK
  and overall film build
Pilot
3.10 Ibs
2.00 mils
1.50 mils
1.83 mils

-------
                                      ADDED 11/88
                    FIGURE  25

                (See Section 19)

          Calculation of Pilot Line TE

Weight solids sprayed per vehicle (pilot) 3.10 Ibs

Weight solids deposited per vehicle (pilot) 1.98 Ibs

Pilot TE = 1.98   =  0.64
           3.10

-------
                                        ADDED 11/88
                    FIGURE  26

                (See Section 19)

      Calculation  of Adjusted Pilot Line TE


Weight solids  sprayed per vehicle  (pilot) 3.1U Ibs

Weight solids  sprayed per vehicle  (plant) 2.80 Ibs

Overall  average  dry  film  build  (pilot) 1.83 mils

Overall  average  dry  film  build  (plant) 1.90 mils

Pilot TE = 0.64

Adjusted Pilot TE  =0.64  *  3.10  * 1.90  =0.74
                           2.80

-------
                                                             ADDED  11/88


                                      FIGURE 27

                                   (See Section 19)

            Annual  Revalidation  and Readjustment of Pilot Line TE Test Data


                                    New  In-Plant             Old Pilot

Wt solids sprayed/vehicle           3.20  Ibs                 3.10 Ibs

Average Class I film build          2.0  mils                 2.0 mils

Average Class II film build         1.3  mils                 1.5 mils

Overall average film build          1.77  mils                1.03 mils

Solids sprayed test                 3.10 - 3.20  * 100  = -3.1% OK
                                         3.20

Overall film build change           1.83 - 1.77  * 100  = +3.4% OK
                                         1.77

Consistency of solids sprayed and
overall  film build                   ABS(-3.1  - 3.4)  =  6.7  <_ 20  OK

New Adjusted Pilot TE =0.64 * 3.10 *  1.77
                               1720"   OT

                      = 0.60

-------
                                                           ADDED 11/88


                                      FIGURE 28

                                  (See Section 19)

          Determination  of Required Number of Dry Film Build Measurements  for

                            Vehicle with Plastic Parts




                                Square Footage Coated
"Magnetic"
(Steel)
111)
70
180
•ea 50 * 100
"Non-Magneti c"
(Plastic)
40
10
50
= 22% < 25%
Total
IbO
80
230

Class I

Class II

 Total

Percent non-maynetic area 50
                          230

Therefore, dry film build measurements are not needed on non-magnetic areas.

The required number of before  and after measurements per vehicle are:

      IbO on 110 square feet of magnetic Class I area

      IbO on 70 square feet of  magnetic Class II area (160 = 80 * 2)

-------
                                                                ADDED 11/88
                                     FIGURE 28 (Continued)

                                     Square Footage Coated
"Magnetic"
(Steel)
90
70
"Non-Magnetic"
(Plastic)
60
10
Total
150
80
Class I

Class II

Total                      160                  70            230

Percent non-magnetic area 70  * 100  - 30%  >  25%
                          •210

Therefore, dry film build measurements are required on non-magnetic areas,

The  required number of before and after measurements per vehicle  are:

     IbO on 150 square feet of Class I area

     160 on 80 square feet of Class II area

-------
                                                         ADDED 11/88
                                       FIGURE 29

                                   (See Section 19)

                     Calculation of Overall Average Dry Film Build

                                  Square Feet Coated

                   Class I               150

                   Class II                80

                   Total                 230

Overall average dry film build equals:

average Class I dry film build * 150  +  average Class  II  dry film build * 80
                 230                                     230	

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                                 APPENDIX  B
SUMMARY OF ADDITIONS AND REVISIONS TO JUNE 10, 1988 VERSION OF PROTOCOL
                                      B-l

-------
Revised Section 18 added November 1988.
Scope moved from page 18-2 to 18-1.
New language in paragraph B on page 18-2.
No changes on page 18-3.
New item 6 at top of page 18-4.
One line moved from page 18-4 to 18-5, and
one sentence moved from page 18-6 to 18-5.
New language in Frequency of Certification
on page 18-6.
                 B-2

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CO

 CO
         O
   v«
   d)
           Q)
     'o
       •o

        I
                      ft

-------
D*
Pag

-------
r
              fit
 *< ,
'^j
                             ,:;

-------
New Figures 24 - 29 added November 1988.

These figures illustrate new Section 19 also added
November 1988.
                       B-5

-------
New page iii added December 1988.

Adds Appendix A (Example Calculations)
and Appendix B (Summary of Additions and Changes) to
table of contents.  The example calculations were
previously in a separately bound volume.
                       B-6

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Revised page 1-2 added December 1988.

New language in first sentence to indicate that example
calculations are in Appendix A.

Adds paragraph about agency review of owner/operator
selected conditions and parameters.

Adds paragraph which notes that changes and additions
from original June 10, 1988, version are summarized
in Appendix B.
                        B-7

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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
EPA-450/3-88-018
4. TITLE AND SUBTITLE
Protocol for Determining the Daily Volatile Organic
Compound Emission Rate of Automobile and Light-Duty
Truck Topcoat Operations
7. AUTHOR(S)
David Salman (MD-13) (919) 541-5417
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Chemicals and Petroleum Branch
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Emission Standards Division
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
December 1988
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT

     This protocol determines  the  daily VOC emission rate (pounds of VOC per  gallon
of coating solids deposited) for a complete automobile and light-duty truck topcoat
operation.   The protocol  is designed for use in cases where (1) the topcoat  emission
limit is stated in units of pounds of VOC per gallon of solids deposited,  (2)  complianc
is to be demonstrated for  each day,  and (3) the entire topcoat operation (i.e.,  all
spray booths, flash-off areas  and  bake ovens where topcoat is applied, dried,  and
cured; except final off-line repair)  is treated as a single entity.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Automobile Topcoat
Light-Duty Truck Topcoat
Volatile Organic Compound Emissions
18. DISTRIBUTION STATEMENT
Release Unlimited
b. IDENTIFIERS/OPEN ENDED TERMS

19. SECURITY CLASS (This Report)
20 SECURITY CLASS 1 This page)
c. COSATI Field/Group

21. NO. OF PAGES
22. PRICE
EPA Form 2220-1 (Rev. 4-77)    PREVIOUS EDITION is OBSOLETE

-------